The Honorable Gina McCmthy 

Administrator 

U.S. Environmental Protection Agency 

1200 Pennsylvania A venue, NW 

Washington, DC 20460 

Dear Administrator McCarthy, 

We write to express significant concern with the recently proposed 2016 Renewable Volume 

Obligations (RVO) under the Renewable Fuel Standm·d (RFS). The RVO as currently proposed 

would constitute a breach of the ethanol blendwall, which would cause adverse impacts on 

American consumers and the economy. 

Congress expanded the RFS when it passed the Energy Independence and Security Act of 2007 

(EISA). EISA mandated an annually increasing volume of biofuel to be blended and consumed 

in the nation's motor fuel supply, reaching 36 billion gallons of biofuels in 2022. In 2007, the 

market assumptions regarding the future of transpmtation fuels in the United States were very 

different from the realities of the market today. The Energy Information Administration (EIA) at 

the time projected motor gasoline demand to significantly rise through 20221• Since then, EIA 

has revised its 2007 projection of motor gasoline in 2022 downward by 27% and projects motor 

gasoline demand to continue to decline tlu·ough 203 51• 

Increased fuel efficiency has led to slll'inking gasoline demand. This current reality, coupled with 

an increasing biofuel blending level requirement, has exacerbated the onset of the E1 0 

blendwall- the point at which the gasoline supply is saturated with the maximum amount of 

ethanol that the cunent vehicle fleet, marine and other small engines, and refueling infrastructure 

can safely accommodate. We agree with the EPA's conclusion in its first RVO proposal for 2014 

and in its current proposal for 2014, 2015, and 2016 that the ElO blendwall is a binding 

constraint. 

We are gravely concerned, however, that despite the Agency's recognition of the blend wall, the 

2016 proposal acknowledges that it will be breached nonetheless. Specifically, EPA states that 

the 2016 RVO "includes volumes of renewable fuel that will require either ethanol use at levels 

significantly beyond the level of the E 10 blend wall, or significantly greater use of non-ethanol 

renewable fuels than has occurred to date. "2 

1 Energy Information Administration, Annual Energy Outlook 2007-2015, Reference Case Table 11 

2 Federal Register, Vol. 80, No. 111 , Wednesday, June 10, 2015, Proposed Rules (p.33102), EPA Renewable Fuel 

Standard Program: Standards for 2014, 2015, and 2016 and Biomass-Based Diesel Vo/wnefor 2017; Proposed 

Rule 

PAINTED ON RECYCLED PAPER 
conventional transportation fuels5." This adverse economic harm falls hardest on America's 

lower income· families. 

EPA acknowledges that its 2016 RVO proposal would require significant greater use ofE15 and 

E85 in order to meet the proposed mandate in 2016. Therefore, this proposal is problematic not 

only" in principle, but it is also impractical since it would take decades, not months, to build out 

the compatible vehicle fleet and install the necessm·y retail infrastructure to accommodate the 

higher blends of ethanol. AAA calculates that only 5% of the vehicles on the road m·e approved 

to use E156 and the EIA calculates that only 6% of vehicles can use E857 . The refueling retail 

infi·astructure is even more limited with only 2% of retail stations selling E858 and only 100 

stations nationwide selling E 159. 

Congress will continue its work toward a bipmiisan solution to deal with the RFS. As this work 

continues, it is critical that EPA use its statutory authority to waive EISA's conventional biofuel 

volume to keep the blending requirements below the E10 blendwall, and to help limit the 

economic and consumer hmm this program has already caused. 

Bill Flores Member of Congress 

osta 

Member of Congress 

Sincerely, 

Peter Welch Member of Congress 

Steve Womack 

Member of Congress 

Bob Goodlatte 

Member of Congress 

3 Congressional Budget Office, The Renewable Fuel Standard: Issues for 2014 and Beyond (June 20 14) 

4 NERA Economic Consulting, Economic Impacts Resulting from Implementation of RFS2 Program (July 20 15) 

5 Charles River Associates, Impact of the Blend Wall Constraint in Complying with the Renewable Fuel Standard 

(November 2011) 

6 American Automobile Association, Press Release "New El5 Gasoline May Damage Vehicles and Cause 

Consumer Confusion" (December 20 12) 

7 Energy Information Administration, Annual Energy Outlook 2014 

8 Fuels Institute, E85: A Market Pe1jormance Analysis and Forecast (2014) 

9 Renewable Fuels Association data (www.ethanolrfa.org) 
~o1.v 6+attO 

~l3~ 
~.74t; 

~~ 
dJ--d_ 'Kotr¢f-
j;.t \JJ- -'L . 

OJiniwL 
lllcSJ 

9.4-----...1 (.J:u {AR-J.) 
NY-ot 
;J:_ 
\ 

U.-

juPt)JaMdi - ' i·i + 
)fJM,c 'B.frr 

;:__ 0 • • )II ,_ /...... c."-

•tvyvv[ a 
. 

-c 
Joe Heck Garret Graves 

Gary Palmer Joaquin Castro 

Jim Bridenstine Mia B. Love 

Page 4 

Robert J. Dold Tom Rice 

Robert Pittenger Barbara Comstock 

Dennis A. Ross Charles J. "Chuck" 

Fleischmann 

Robert Aderholt Cedric Richmond 

Mimi Walters Barry Loudermilk 

Kevin Brady Gregg Harper 

Thomas Massie Brian Babin 

Will Hurd Richard Hanna 

Doug LaMalfa Ron DeSantis 

Page 5 

Ryan Costello David P. Roe 

Denny Heck Peter King David Rouzer Jeff Miller 

Joseph R. Pitts Mark E. Amodei 

Scott Rigel! Dave Brat 

Marc A. Veasey Frank Guinta 

Scott DesJarlais John Ratcliffe 

David B. McKinley Chris Stewart 

David Schweikert Steven M. Palazzo 

Paul Gosar Mike Bishop 

Evan Jenkins David Valadao 

Glenn Grothman Devin Nunes 

Page 7 

Lois Frankel Blake Farenthold 

Kay Granger Steve Knight 

Jamie Herrera H. Morgan Griffith 

Beutler 

Martha MeSally Diane Black 

John Katko Markwayne Mullin 

Renee Ellmers Alexander X. Mooney Mo Brooks French Hill 

Paul Cook Chris Collins 

Ke ith Rothfus Scott Perry 

Page 8 

Christopher P. Dan Newhouse 

Gibson 

Billy Long Raul R. Labrador 

Andy Harris Mike Kelly 

Jim Jordan Lee Zeldin Jody Hice Doug Collins 

Andy Barr Charles W. Boustany, Jr. 

Carlos Curbelo Trent Kelly 

Randy K. Trey Gowdy 

Neugebauer 

Roger Williams Bradley Wenstrup 
Gus M. Bilirakis Chellie Pingree 

Pete Olson John Mica 

Mark Sanford Lynn Westmoreland 

John J. Duncan, Jr. Mac Thornberry 

Page 10 

Henry Cuellar Darrell E. lssa 

Charles W. Dent Dana Rohrabacher 

Jeb Hensarling Sam Johnson 

Joe Wilson Edward R. Royce 

Scott Garrett Michael K. Simpson 

Pete Sessions Kenny Marchant 

Louie Gohmert Ruben Hinojosa 

Marsha Blackburn G. K. Butterfield 

Bill Shuster Rodney P. Frelinghuysen 

Page 11 

Don Young Tom McClintock 

Steve Scalise Michael C. Burgess 

Walter B. Jones Matt Salmon 

Virginia Foxx Leonard Lance 

Steve Chabot John Abney Culberson 

Christopher H. Doug Lamborn 

Smith 

Lamar Smith Ted Poe 

Austin Scott Mick Mulvaney 

Frank A. LoBiondo Tim Murphy 

Sensenbrenner Stephen Fincher Gene Green 

Robert J. Wittman K. Michael Conaway 

Bruce Poliquin