Testimony of Scott Averhoff

Corn Producers Association of Texas

on June 25, 2015 before the Environmental Protection Agency

Hearing on Renewable Fuel Standard: Proposed Renewable Fuel

Volumes for Calendar Years 2014, 2015 and 2016

My name is Scott Averhoff, and I am speaking against the proposed renewable fuel 

volumes for calendar years 2014, 2015 and 2016. Thank you for the opportunity to 

testify today.

I am a corn, cotton, wheat and sorghum farmer from Waxahachie, Texas, which is 

just south of the Dallas/Fort Worth Metroplex. I currently serve on the board of the 

Corn Producers Association of Texas, and am speaking on behalf of our association’s 

membership and myself.

The state of Texas has four operating ethanol plants, which produce ethanol at a 

nameplate capacity of 390 million gallons. While my state may not be among the

largest ethanol producers, we are amongst the largest users of the product. In 2014, 

Texans consumed 1.2 billion gallons of ethanol – approximately 9 percent of the 

domestic consumption. This doesn’t take into account the considerable amount of 

ethanol’s co-product, distillers grains, used in Texas feedlots and dairies.

Living in a non-attainment area, I can appreciate that ethanol lowers the level of 

toxic emission in vehicle exhaust compared to gasoline. Energy experts estimated

global ethanol use to reduce greenhouse-gas emissions by 100 million metric tons in 

2012 – equivalent to taking 20.2 million vehicles off the road. The EPA should not 

halt progress made to reduce air pollution, improve human health and reduce 

greenhouse-gas emissions by moving forward with this proposal.

Despite increases in the amount of course grains used for ethanol over the years, 

the amount of land dedicated to such crops, including corn, has actually decreased 

6.9 percent globally from 1980 to 2013. Farmers in Texas plant approximately 2 

million acres of corn each year, and have done so since before the RFS. The 

agricultural industry has been able to meet the rising demands of all uses,

primarily by increasing the crop’s yields through advancements in technology and 

management practices.
 

In this regard, it’s important to also note that the same bushel of corn used to make 

this fuel is also making distillers grain, a high protein feed for livestock.

Disrupting the demand for corn used for ethanol, as put forth by your proposal, 

would have a rippling effect to the agricultural commodities market that will impact 

more than just corn farmers. Lessening the demand in the ethanol market for corn 

will cause farmers to plant alternative crops; in turn, increasing those crops’ 

production and decreasing their price. This not only impacts farmers, but taxpayers

as well through increased layouts of commodity and crop insurance programs.

Since the inception of the RFS, American corn farmers have risen to the challenge 

of increasing our production to meet the demand for this renewable fuel, while still 

providing for existing markets and maintaining a surplus. U.S. consumers have 

benefitted by having a clean-burning, domestically produced fuel. The EPA should 

not turn its back on Americans and halt the progress toward cleaner air and access 

to renewable fuel resources.

The proposal put forth by your agency would be detrimental to our nation. I urge 

the EPA to restore the Renewable Volume Obligations for each year to the statutory 

amount and maintain a strong methodology.