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AERONAUTICS	

October 30, 2013 

U.S. Environmental Protection Agency 

Room 300, Ariel Rios Building 

1200 Pennsylvania Avenue, NW 

Washington, D.C. 20460 

Dear Administrator McCarthy: 

Recently, as the nation's gasoline approaches the E10 blendwall, 

Reps. Goodlatte, Costa, Womack, and Welch have called for you to 

adjust the nationwide adjustment in Renewable Fuel Standards (RFS) 

volume requirements in that mixture. As you are no doubt aware, the 10 

percent threshold is now an important reality. 

The United States fuel chain cannot absorb more ethanol. The 

consequences of breaching the blend wall will undoubtedly be costly. 

Numerous studies show that current infrastructure, engines, and 

vehicles cannot safely and functionally accommodate ethanol fuel which 

has surpassed the blend wall. As many of my colleagues have iterated 

for you, this could well be disastrous. 

When Congress passed the Energy Policy Act of 2005 establishing 

the first RFS, it did not foresee the market realities as we 

experience them today. Not only will unchanged ethanol levels harm our 

physical infrastructure, the continuation of the program will continue 

to skew U.S. corn markets. As you're certainly aware, over 40 percent 

of U.S. corn is used in ethanol production, a reality that has only 

exacerbated the volatility of U.S. corn markets since the expansion of 

the RFS in 2007. 

In terms of the consumer economy, the RFS will impose a greater 

burden on manufacturers to meet CAFE standards. As a result, the 

increased costs of production will be passed down to people who need 

cars to get to and from work—the middle class. 

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Furthermore, if the primary goal of the RFS is to protect the 

environment, the program is a miserable failure by most any measure. 

For example, lifecycle emissions of corn ethanol higher than 

conventional gasoline lifecycle emissions, a reality that has driven 

the National Academy of Sciences to state that on balance, the use and 

nroduction of ethanol lowers air aualitv and harms water aualitv. 

Even worse for the stability of the U.S. corn markets, the 

volatility of corn prices has led the industry to convert millions of 

acres of sensitive wetlands and grasslands into corn production, 

creating a vortex of self-perpetuating market destabilization. 

By the metrics the EPA most values, the RFS mandates have failed. 

While the current proposal on the table asks you to reduce the 

biofuel mandate from 18.15 billion gallons to 15.21 billion gallons, 

I'm writing to urge you to scrap the Renewable Fuel Standard 

altogether. Whereas the EPA has ruled that gas blended with up to 15 

percent ethanol is safe for use in cars made after 2001, the vast 

majority of car warranties only cover us of gasoline containing up to 

10 percent ethanol. Allowing the E10 blend wall to be breached will 

undoubtedly have disastrous economic effects in addition to the 

already disastrous environmental effects. 

The EPA can assist Congress as we try to avoid this dangerous 

economic and environmental situation by doing away with the RFS 

completely. Adjusting the RFS mandate downward is a decent first 

step, but ultimately the best course of action is to eliminate the RFS 

mandates entirely in order to bring them in line with the reality of 

the U.S. corn market situation. I unequivocally urge you to exercise 

your authority to take all necessary action to protect the American 

consumer and the economy.