Interagency Working Comments on Draft Language under EO12866 

Interagency Review. Subject to Further Policy Review.

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Interagency Comments on U.S. Environmental Protection Agency’s Draft Final Rulemaking, 

“Regulation of Fuels and Fuel Additives: 2013 Renewable Fuel Standards,” RIN 2060-AR43.

C. Compliance with the Total Renewable Fuel Standard in 2013

As described in Section III.B above, the NPRM addressed potential reductions in 

advanced biofuel and total renewable fuel under the cellulosic waiver authority. In this context, 

any reduction in advanced biofuel would be matched gallon-for-gallon (on an ethanol-equivalent 

basis) by reductions in total renewable fuel, effectively having no impact on volumes of nonadvanced biofuel such as corn-ethanol. 

In response to the NPRM, many stakeholders expressed concern about the E10 blendwall 

and the possibility that the applicable standards for 2013, absent a reduction in the advanced 

biofuel and total renewable fuel volume requirements, could require the consumption of more 

volumes of higher ethanol blends (E15 - E85) than can reasonably be absorbed by the market.1 

In order to evaluate these concerns, we estimated the volumes of ethanol that could be needed to 

meet the statutory volume requirements in 2013 and whether or not that volume could reasonably 

be used.

In the NPRM we proposed a significant reduction in the required volume of cellulosic 

biofuel. For today's final rule we are adjusting this volume requirement downward to 6 mill gal 

as described in Section II.D above. We also set a volume requirement for biomass-based diesel 

of 1.28 bill gal in a separate rulemaking.2 Table III.C-1 shows what the four volume 

requirements would be without any reductions in the statutory volumes of advanced biofuel or 

total renewable fuel.

Table III.C-1

Volumes of Renewable Fuel for 2013 Absent Reductions in Advanced Biofuel and Total 

Renewable Fuel (million ethanol-equivalent gallons)

D codes that can be used 

to meet this standard Required volume

Cellulosic biofuel 3, 7 6

Biomass-based diesel 4, 7 1,920

Advanced biofuel 3, 4, 5, 7 2,750

Total renewable fuel 3, 4, 5, 6, 7 16,550

Based on these volume requirements, we estimated the volumes of both ethanol and non-ethanol 

that could be used to satisfy these standards if there were no biomass-based diesel produced in 

excess of the 1.28 bill gal requirement. As such, these estimates may overstate the volume of 

ethanol that would have to be consumed because, as discussed above, there is significant 

capacity for biodiesel production beyond the 1.28 bill gal requirement for 2013. This scenario 

 

1

In the proposal, we requested comment on the degree to which the E10 blendwall might present a difficulty in 

meeting the applicable volume requirements in 2013.

2

77 FR 59458, September 27, 2012.

Deleted: be 

Deleted: expected 

Deleted: from 
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Interagency Review. Subject to Further Policy Review.

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also does not consider the availability of substantial numbers of carryover RINs from 2012, 

which is discussed in greater detail below.

Table III.C-2

Potential Volumes of Renewable Fuel for 2013 (million ethanol-equivalent gallons)

D code Ethanol Non-ethanol

Cellulosic biofuel 3 1 5

Biomass-based diesel 4 0 1,920a

Other advanced biofuel

 - Domestically 

produced

 - Imported

5

136b

580c

109b

0

Conventional Biofuel 6 13,800 0

Total 14,517 2,034

a Based on the applicable volume requirement of 1.28 bill gal, and assuming no excess.

b

From Production Outlook Reports as listed in Table III.B.2-2.

c Balance of advanced biofuel standard of 2.75 bill gal that is estimated to come from 

imported sugarcane ethanol.

In order to determine the volume of ethanol that would need to be consumed in blends 

higher than E10 in order to meet this standard, we assumed a total 2013 energy consumption for 

all gasoline-powered vehicles and engines of 14.58 Quadrillion Btu.

3

 Based on a denatured 

ethanol energy content of 77,000 Btu/gal and a gasoline energy content of 115,000 Btu/gal, we 

determined that the 14.5 bill gal of ethanol shown in Table III.B.1-2 would require 129.5 bill gal 

of E10 and 2.1 bill gal of E85.4 This volume of E85 would contain about 1.6 bill gal of ethanol. 

By contrast, if no E85 were consumed, the total volume of E10 would be 131.1 bill gal and the 

maximum volume of ethanol that could be consumed would thus be 13.1 bill gal. As shown in 

Table III.C-2, the conventional biofuel volume alone exceeds this level. In the absence of 

carryover RINs from 2012, it would be extremely challenging to meet this standard.

In their comments on the NPRM, a number of refiners contended that E85 is not a viable 

strategy for consuming volumes of ethanol in excess of the E10 blendwall. Some called for 

reducing the required volumes of renewable fuel so that ethanol would comprise no more than 

10% of the gasoline fuel pool. We agree that, historically, E85 consumption has been very low. 

In 2012 EIA estimated that E85 consumption was about 40 mill gal, and in prior years it was 

less. EPA expects that consumption of E85, and perhaps blends with other concentrations of 

ethanol, will grow over time, and help obligated parties meet their renewable volume obligations. 

While current consumption of E85 (approximately 40 mill gal in 2012) is considerably 

lower than 2.1 bill gal that would be needed in the scenario outlined above, we note that the 

current price of E85 is only about 18% lower than the price of E10.

5

 Since the average

 

3

EIA Annual Energy Outlook 2013, Table 37.

4

To simplify this analysis we have not assumed any other ethanol blend levels and no E0. 

5

E85prices.com, 6-12-13

Deleted: .

Deleted: nearly impossible very challenging 

Formatted: Highlight

Deleted: In its Annual Energy Outlook 2013, EIA 

projects that E85 consumption will increase to 176 

mill gal in 2013, but this is still significantly less 

than the 2.1 bill gal that we estimate would need to 

be consumed under the limitations of the scenario 

described above.

Comment [A1]: EIA’s estimate is based on its 

best guess of future RFS mandates, not on deeper 

knowledge of market evolution or trends in the data, 

so this doesn’t really provide independent 

evidence.of how the E85 market can expand. EIA 

might provide additional guidance on this point. 

Deleted: .

Formatted: Highlight

Deleted: However, E15 or other blend levels are 

possible.
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volumetric energy content of E856is about 24% below that of E10, the current price of E85 is 

actually higher than the price of E10 on an energy equivalent basis. Moreover, the price gap 

between E10 and E85 is perceived as larger to consumers who will reasonably assume that a 

gallon of E85 will contain 85% ethanol, having an energy content 28% lower than E10. Those 

flex-fuel vehicle (FFV) owners that are purchasing E85 today are thus doing so for reasons other 

than the economic benefit (e.g., personal values, government fleet mandates) or because they are 

unaware that E85 contains less energy than E10. If the price of E85 were to fall relative to the 

price of E10, we would expect consumption of E85 to increase. Significant reductions in the 

price of E85 could result in higher volumes of E85 consumption, provided there is adequate 

availability of infrastructure for distribution of E85, availability of FFVs, standardization and 

knowledge of the energy content of E85, consumer education, and acceptance. Such a reduction 

in the price of E85 could occur with a significant reduction in the price of corn relative to the 

price of oil. Historically during periods of lower corn prices the desire to maximize profit caused 

an increase in ethanol blending. With the E10 market saturated, lower corn prices could result in 

lower E85 prices. At higher corn prices, as described more fully in Section III.D below, a longterm increase in E85 consumption would still need to come through a fall in the price of E85 

relative to E10, which would entail an increase in the price of RINs. Based on this, some 

increase in volumes of higher ethanol blends could be accomplished, with the extent of the 

required subsidy to E85 consumers through higher RINs prices depending E85 infrastructure, 

consumer acceptance, and the price of corn relative to the price of oil. 

There also are also mechanisms other than increased volume of E85 through which 

obligated parties could comply with the applicable volume requirements in the absence of 

reductions in the advanced biofuel and total renewable fuel volume requirements. One of those 

options is carryover RINs from 2012. EMTS was examined after the February 28, 2013 deadline 

for compliance with the 2012 standards to determine the total number of 2012 RINs that had not 

been used for compliance in 2012 or retired for any other reason. The totals are shown below.

Table III.C-3

Carryover RINs from 2012 into 2013 (million)

D Code RINs

Biomass-Based Diesel 4 353

Advanced Biofuel 5 196

Conventional Biofuel 6 2,117

Total 2,666

Although the rollover provisions in §80.1427(a)(5) limit the carryover of RINs to 20% of the 

next year's volume obligations for individual obligated parties, the values in Table III.C.1-3 are 

less than 20% of the values shown in Table III.C.1-1 for the nation as a whole. 

As discussed above, compliance with the statutory volume requirements for advanced 

biofuel and total renewable fuel in 2013 could in theory be met by the consumption of 2.1 bill 

gal of E85 containing about 1.6 bill gal of ethanol. However, given that there are over 2.6 bill 

 

6

E85 in this rulemaking is assumed to contain 74% ethanol on an annual average basis.

Formatted: Highlight

Comment [A2]: Isn’t it (.74*77kbtu + 

.26*115kbtu)/115 = 75.5%? 

Formatted: Highlight

Deleted: 22

Formatted: Font: 12 pt, Highlight

Formatted: Font: 12 pt, Highlight

Comment [A3]: (.85*77kbtu + .15*115kbtu)/115 

= 71.9%? 

Formatted: Highlight

Formatted: Font: 12 pt, Highlight

Comment [A4]: This part of the sentence was 

returned to the original EPA text.

Deleted: significantly 

Formatted: Font: 12 pt, Highlight

Deleted: and 

Formatted: Font: 12 pt, Highlight

Deleted: information

Formatted: Font: 12 pt, Highlight

Deleted: This 

Deleted: Furthermore,

Deleted: presumably

Formatted: Font: 12 pt, Highlight

Deleted: increases in the 

Deleted: could result in reductions in the price of 

E85 relative to the price of E10, with a 

commensurate increase in E85 consumption

Deleted: increases in the price of RINs could result 

in reductions in the price of E85 relative to the price 

of E10, with a commensurate increase in E85 

consumption. Based on this it is clear that some 

increase in volumes of higher ethanol blends could 

reasonably be accomplished through the market. 

Formatted: Font: 12 pt, Highlight

Deleted: ethanol producers through higher RINs 

prices depending on the price of corn relative to oil

Formatted: Font: 12 pt, Highlight

Deleted: While it is clear that some increased 

volume of E85 could be consumed in 2013, there

Formatted: Font: 12 pt, Highlight

Deleted: 

Deleted: other 

Deleted: ¶
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carryover RINs available, there are more than enough in the market to permit compliance with 

the 2013 advanced biofuel and total renewable fuel volume requirements even if E85 

consumption does not increase in 2013. These carryover RINs are also available to address any 

potential shortfalls in production of corn-based ethanol that may result from the 2012 drought.7 

We recognize that in some cases carryover RINs from 2012 may not be available to an 

obligated party that needs them. There are indications from some stakeholders that those who 

own carryover RINs may opt to retain and not sell them, instead rolling them over and banking 

them to use for their own obligations in a future year. There is no way to determine what 

fraction of carryover RINs may fall into this category. However, we note that the 14.5 bill gal of 

ethanol that might need to be consumed in 2013 (Table III.C-2) is only 1.4 bill gal above the E10 

blendwall. This is significantly less than the number of available carryover RINs available. 

Thus only about half of the carryover RINs in existence would need to be made available in 

order for the full statutory volume requirements for advanced biofuel and total renewable fuel to 

be met in 2013. 

In response to the NPRM, one stakeholder indicated that carryover RINs should not be 

considered in the process of setting standards. Instead, this stakeholder argued, carryover RINs 

were intended only to provide flexibility to enable companies to remain in compliance in years 

when circumstances such as drought or other biofuel supply shortage limit the availability of 

RINs. However, the final rulemaking for the RFS1 program did not describe the purpose of 

carryover RINs in such narrow terms. Droughts were indeed provided as an example of a market 

circumstance that could limit the production of renewable fuels, but the RFS1 final rule also 

described the use of carryover RINs more broadly as a means for protecting against any potential 

supply shortfalls that could limit the availability of RINs. The rule also put this flexibility in 

terms of availability of RINs and the potential for waivers:

The availability of excess previous-year RINs would thus provide compliance 

certainty in the event that the supply of current-year RINs falls below the RFS 

program requirements and the Agency does not waive any portion of the program 

requirements. (72 FR 23935)

In addition, carryover RINs are a valid compliance mechanism, and they will either be used for 

compliance purposes or eventually retired. The issue here is estimating the adequacy of the 

availability and use of ethanol in 2013 for compliance purposes, and the availability of carryover 

RINs is certainly relevant in analyzing that issue. Therefore, we believe that it is appropriate to 

consider carryover RINs in the context of evaluating the comments received on the need for 

further compliance relief to address the E10 blendwall.

 

7

Through April 2013 approximately 4.1 billion D6 RINs have been produced. This production rate projected 

through 2013 would indicate the production of approximately 12.3 billion D6 RINs. In addition, the production rate 

at ethanol facilities has been increasing. EIA’s weekly fuel ethanol production data shows that ethanol production 

had dropped to 770 ,000 barrels per day in late January but had recovered to 875,000 barrels per day by the third 

week of May. This later number projects to an annual production rate of approximately 13.4 bill gal of ethanol per 

year. When considered together with the estimated 2.1 billion carry over RINs we project there will be sufficient D6 

RINs to satisfy the unadjusted total renewable fuel standard. 

Formatted: Font: 12 pt, Highlight

Deleted: rolling them over to help assure 

compliance 
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Carryover RINs and increased E85 are not the only available mechanisms that obligated 

parties have for meeting the 2013 standards. There are also additional sources for non-ethanol 

biofuels that could be used for compliance in 2013 instead of relying on increased volumes of 

E85. As discussed in Section III.B.1 above, there is unused biodiesel production capacity and 

sufficient feedstocks available to permit biodiesel production in excess of 1.28 bill gal. In 

addition, various feedstocks not currently identified in Table 1 to 80.1426 can be used in 

facilities that have been grandfathered under §80.1403 to produce biodiesel that is categorized as 

renewable fuel, but not advanced biofuel, providing these feedstocks meet the definition of 

renewable biomass.

Several commenters noted the recent rise in D6 RIN prices, from approximately 5 ¢/RIN 

in early January 2013 to approximately 70 ¢/RIN by March 2013, as evidence that the E10 

blendwall had been reached and that obligated parties would have significant difficulty 

complying with the proposed renewable fuel volumes. We recognize that concerns about the 

blendwall is the underlying driver for these price increases. As discussed previously in this 

section, however, EPA projects that there will be sufficient RINs available to obligated parties to 

satisfy their advanced biofuel and total renewable fuel obligations in 2013 despite the challenge 

represented by the blendwall. 

One commenter also suggested that this increase in RIN prices would increase the cost of 

transportation fuel to US consumers by about $17 billion. EPA does not believe this is a credible 

cost increase as a result of high RIN prices even if it does represent the market value of RINs 

required for compliance with the RFS. It is incorrect to assume a direct correlation between the 

increase in RIN prices and a rise in average transportation fuel prices. The effect of the RFS 

program on average transportation fuel prices is driven by the cost of renewable fuels relative to 

the petroleum fuels they displace. The effect of increasing RINs prices is not to increase all 

transportation fuel prices, but rather to reduce the relative price of more renewable-fuel intensive 

fuels, relative to increasing the price of fuels with a low renewable content. Since the price of 

renewable fuels did not increase over this time period, we do not believe the higher RIN prices 

have caused a significant increase in the cost of transportation fuels to consumers.8

In their comments on the NPRM, some refiners indicated that absent a waiver related to 

the E10 blendwall they may reduce production of gasoline and/or diesel, or might increase 

exports of these products, in order to reduce their Renewable Volume Obligations (RVO) under 

the RFS program. We recognize that an individual obligated party may consider such actions if 

it cannot acquire the RINs needed for compliance and is faced with the prospect of noncompliance penalties. However, we do not believe such actions would be called for in 2013

because we believe that there is an adequate volume of RINs available for all obligated parties to 

meet their obligations under the program.

 

8

External analysts have begun to examine this issue. For example: 

Irwin, Scott and Good, Darrel. “High Gasoline and Ethanol RINs Prices: Is There a Connection?” Farmdoc Daily.

Department of Agricultural and Consumer Economics, University of Illinois-Champaign. 27 March 2013. Web. 15 

June 2013.

Deleted: significant 

Deleted: 

Formatted: Font: 12 pt, Highlight

Deleted: While it is likely that 

Deleted: an 

Deleted: , it is also likely that a variety of factors 

and market mechanisms contributed to the increase

in the price of D6 RINs

Comment [A5]: If there are things other than the 

blendwall that is driving up the price of RINs, we 

should explain them. But I think that it is important 

that the industry gets that we understand what is 

happening. If they do not think that we understand 

the problem, then they are far less likely to believe 

that we will fix in in the 2014 rule and we will have 

more months of RIN market uncertainty.

Comment [A6]: The $17 billion number is not 

out of thin air. Again, I think it makes sense to make 

clear that we understand how the market works so 

that it will have confidence that the problem will be 

addressed.

Deleted: total 

Deleted: costs

Deleted: cost 

Comment [A7]: The basic economics here is that 

RINs serve as a tax on petroleum gasoline and a 

subsidy to renewables production, resulting in 

change in relative prices but a small overall 

(weighted average) price change. This is made clear 

above in the discussion of E85 prices going down as 

RINs prices go up, in the long run (which we don’t 

seem to be in at the moment). 

Deleted: to the same degree as the price of RINs 

Deleted: for the reasons noted above, 

Deleted: , and we do not believe that such actions 

on the part of individual refiners would affect the 

availability of gasoline and diesel for the country as 

a whole. As the consumption of gasoline and diesel 

is highly inelastic in the short term, any reductions in 

supply of gasoline and/or diesel on the part of one 

refiner will be compensated for by increases in 

supply from other refiners or importers.
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For all of the reasons discussed above, EPA concludes that for 2013 adequate volumes of 

renewable fuel are available to meet the requirements for total and advanced biofuel, and that the 

E10 blendwall is not a barrier to compliance with these volumes given the various alternative 

methods to comply besides the blending of ethanol as E10. EPA notes that this conclusion is 

specific to the circumstances present for 2013. 

D. Final Applicable Volume Requirements for 2013

As shown in Table III.B-2, in order for an advanced biofuel requirement of 2.75 bill gal 

to be met, there would need to be 824 mill gal of advanced biofuels in addition to the volumes 

that would need to be produced or imported to meet the biomass-based diesel and cellulosic 

biofuel requirements. After reviewing the projected availability of advanced biofuel volumes 

from various sources, we have determined that it is likely that there will be sufficient volumes 

available to produce or import this 824 mill gal. First, we have determined that there are more 

than 500 million advanced biofuel carryover RINs from 2012 that can be used for compliance in 

2013. With regard to excess biodiesel, we have determined that there could be up to 250 mill gal 

of excess soy oil and up to 100 mill gal of excess corn oil available, which together could 

provide 500 million or more advanced biofuel RINs. With regard to other advanced biofuels, we 

project that up to 245 mill gal could be produced, and another 50 mill gal if pathways under 

consideration are approved in enough time for them to be used by producers in 2013. Finally, 

we project that the volume of imported sugarcane ethanol from Brazil can reach the actual 

import volumes in 2012, which was 580 mill gal, and potentially considerably more. It is clear 

that, in the aggregate, these sources of advanced biofuel RINs are substantially more than what is 

needed to meet the advanced biofuel requirement of 2.75 bill gal. Therefore, we do not believe 

that there is a compelling reason to reduce the required volume of 2.75 bill gal advanced biofuel 

for 2013. Moreover, we do not believe that the blendwall will represent an impediment to 

compliance in 2013 due to the availability of carryover RINs from 2012, opportunities for some 

increase in consumption of E85, and opportunities for non-ethanol biofuels. 

E. Volume Requirements for 2014

As described in the NPRM, we recognize that ethanol will likely continue to predominate 

in the renewable fuel pool in the near future, and that for 2014 the ability of the market to 

consume ethanol as E15 - E85 is highly constrained. Most stakeholders that submitted 

comments in response to the NPRM made reference to the impending E10 blendwall, though 

they differed on how EPA should address it. A number of obligated parties and other 

stakeholders have communicated to EPA that while the E10 blendwall may be manageable in 

2013, in 2014 compliance is expected to become significantly more difficult. We agree with this 

assessment. In 2014 the applicable volume of total renewable fuel set forth in the statute rises to 

18.15 billion ethanol-equivalent gallons, of which 14.4 bill gal would be non-advanced biofuel 

comprised primarily of corn-ethanol, and 3.75 bill gal would be advanced biofuel. A significant 

portion of advanced biofuel would also likely be sugar-cane ethanol imported from Brazil. 

However, the maximum volume of ethanol that could be consumed as E10 in 2014 is projected 

Deleted: Future circumstances may vary and could 

lead to a different conclusion.¶

Comment [A8]: If we are going to say E15, then 

we need to say highly. There are only 20 pumps in 

the nation.

Deleted: in a number of ways
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to be just 13.2 bill gal.9 Given the history of the market, it is unlikely that consumers will 

consume enough ethanol sold in blends greater than E10 to meet the volumes of renewable fuel 

stated in the statute. 

Given these challenges, EPA anticipates that it will be necessary to adjust the 2014 and 

subsequent cellulosic, total advanced, and total renewable volume requirements. We expect that 

in preparing the 2014 proposed rule, we will estimate the available supply of cellulosic biofuel, 

the E10 blendwall, and current infrastructure and market-based limitations to the consumption of 

ethanol in gasoline-ethanol blends above E10, and then establish volume requirements that 

obligated parties can meet given the existence of the E10 blendwall. EPA believes that the 

statute provides EPA with the authority, including the general waiver authority, and the tools 

needed to address these challenges. EPA is currently evaluating a variety of options and 

approaches consistent with our statutory authorities for use in establishing RFS requirements for 

2014. We will discuss these options in detail in the forthcoming NPRM for the 2014 standards 

and expect to utilize the notice and comment process to fully engage the public in consideration a

path forward that appropriately addresses the blendwall and other constraints.

We received a number of comments suggesting that because EPA was late in issuing 

these final RFS standards for 2013, and in light of concerns over the blendwall and RIN prices, 

that the Agency should take action to relieve or reduce burdens associated with RFS compliance 

in 2013. While we do not believe that it would be appropriate to remove or further reduce the 

statutory volume obligations for 2013 as some suggested, we do agree with the commenter who 

suggested that EPA provide additional time for obligated parties to demonstrate compliance with 

the 2013 standards. Knowledge of the volume requirements for 2014 is crucial to the strategies 

that obligated parties may implement when purchasing RINs and wet gallons of fuel for 

compliance with their individual 2013 RVOs. Given this, EPA's view is that delaying the 

compliance demonstration for the 2013 compliance period would alleviate some of the 

uncertainty and concerns that obligated parties have regarding the tardiness of the final rule and 

its effect on their decisions regarding RIN acquisition.

Therefore, we are extending the RFS compliance deadline for the 2013 RFS standards to 

June 30, 2014. This change affects §80.1451(a)(1) and adds a new paragraph (a)(1)(xiv). In 

addition to providing obligated parties with more time to demonstrate compliance, we believe 

that this extension will allow obligated parties to implement various purchasing and allocation 

strategies that help them comply on an individual basis given the tardiness of this final rule. The 

compliance demonstration deadline extension is for the 2013 compliance year only, and does not 

extend the compliance demonstration deadline in any subsequent year. Additionally, given the 

extension of the compliance demonstration deadline for the 2013 compliance period, we are 

extending the deadline for submitting reports for the attest engagement requirement for the 

corresponding compliance year until September 30, 2014. This change affects §80.1464(d) and 

adds a new paragraph (g). The attest engagement deadline extension is likewise for the 2013 

compliance year only, and does not extend the deadline in any subsequent year.

 

9

This volume is calculated using EIA’s 2013 Annual Energy Outlook assuming ethanol represents 10% of total 

motor gasoline consumption by volume

Deleted: It 

Deleted: would be challenging for the market to 

consume sufficient quantities of

Deleted: and to produce sufficient 

Deleted: non-ethanol biofuels (biodiesel, 

renewable diesel, biogas, etc.) to reach the mandated 

18.15 bill gal.

Deleted: likely 

Deleted: ments

Deleted: to 

Deleted: are likely to be necessary based on the 

projected circumstances for 2014

Deleted: , taking into account 

Deleted: , the availability of advanced biofuel, 

Deleted: . 

Deleted: 

Deleted: without being constrained by 

Formatted: Font: 12 pt, Highlight

Deleted: reality

Formatted: Font: 12 pt, Highlight

Formatted: Font: 12 pt, Highlight

Deleted: also 

Deleted: of 

Deleted: n

Deleted: appropriate 

Deleted: a given compliance year 
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Deleted: Section Break (Continuous)