In detailed comments submitted today to the Environmental Protection Agency (EPA), the National Chicken Council (NCC) opined for a more reasonable and sustainable approach to the nation’s biofuel policy. The compelled diversion of corn from feed to fuel has exacted a heavy toll on the domestic chicken industry, American consumers, and results in higher fuel prices as EPA avers, the council said.
Regarding the 2019 rule, EPA is proposing an equal reduction for the overall advanced biofuel category and the renewable fuel total as it is exercised in the cellulosic waiver. NCC supports this action. Were the total renewable fuel volume requirement decreased by a lesser amount than the cellulosic waiver there would be an incentive for conventional biofuels to participate in the RFS program beyond the statutory cap of 15 billion gallons set by Congress.
EPA is proposing to leave the conventional ethanol implied mandate at 15 billion gallons, the statutory cap for that residual category of fuel. NCC urges that the effective conventional biofuel volume be reduced.
“NCC believes the proposed volume for 2019 is overly aggressive, overly reliant on corn-based ethanol, and causes disruptions to the nation’s feed supply,” the council wrote. “Therefore the proposed volumes, especially conventional ethanol, should be reduced in the final rule.
“Finally, as EPA has indicated it is undertaking technical analysis to inform future rulemakings under the reset provision (per 2018 proposed rule) and to address RIN market operations (per the 2019 proposed rule), NCC looks forward to and welcomes the opportunity to comment on both, and specifically urges EPA to provide a more workable and transparent off-ramp process for times of economic stress on chicken producers.”
The comments can be read in their entirety by clicking here.