RFS2 - Commenting

Wednesday, July 01, 2009

Yesterday, the NBB launched its grassroots effort and “RFS-2 Action Center” to encourage all biodiesel stakeholders to submit comments to the EPA on its proposed rulemaking on the RFS-2. Late yesterday, the EPA published a Federal Register Notice extending the comment period an additional 60 days to September 25. This extension signals yet another delay in the implementation of this important energy policy, at the very time that the program is needed the most.

In spite of yesterday’s extension, we are echoing yesterday’s call to utilize NBB’s “RFS-2 Action Center” to move forward immediately to submit your comments to the EPA and to urge your contacts to do the same. The lead request on NBB’s sample comments urges the EPA to act immediately with an interim rule that will provide legal clarity to obligated parties sufficient to insure that the 2009 volumes are met as required by law.

In the coming weeks, with support from your comment submissions, NBB will be communicating to the EPA the urgent need to act with an interim rule in order to move the program forward. Such action is necessary to free up the markets which have been locked down by the uncertainty created by a delayed regulatory process, and an overly complicated and burdensome proposed rule.

Meanwhile, we will continue to work on the development of NBB’s comments to the proposed rule. NBB’s comments will be similar to the sample comments posted on the NBB website, but will provide much more detailed and comprehensive positions and data to address all aspects of the proposed rule. NBB is continuing to pull together the necessary technical data to address the approximately 1,400 pages released by the EPA 56 days ago.

As discussed at the recent NBB Board meeting, I am appointing an RFS-2 Task Force to help review, guide, and approve the development and submission of NBB’s comments.

I am proud to announce today the members of this task force. They were carefully chosen to provide broad and inclusive representation of all biodiesel production. They were also chosen from among those who have been deeply engaged in the rulemaking process and keenly informed about the proposed rule. The role of this task force will be time intensive and tedious, and their charge will be to participate in a way that represents the biodiesel industry as a whole. If you have input to NBB’s comments, I strongly encourage you to contact the members of this task force, myself or NBB staff.

The Task Force members (click to e-mail) include:

·  Ron Marr, Chair , Minnesota Soybean Processors, (515) 249-2880

·  Ray Benevides, GEN-X Energy Group, (509) 547-2447

·  Brian Boyle , Stepan Company, (847) 501-2151

·  John Campbell , AGP,(402) 498-2239

·  Jim Conway, Griffin Industries, (859) 572-2582

·  Peter Loggenberg, Organic Fuels, (713) 979-2600

·  Anthony Reed , ADM,(202) 572-0584

·  Mike Szady, World Energy, (617) 889-7300

·  Dave Tielle, Keystone Biofuels, (717) 761-3511

With Independence Day fast approaching, assisting with this effort could not be more appropriate as a symbol for the kind of commitment that is necessary from all of us to help lead our nation toward greater energy independence. This is a critical time for the industry, and we must all work hard to achieve an acceptable outcome. Please continue to urge others to visit NBB’s RFS-2 Action Center and submit comments to the EPA. Best wishes for a happy July 4th weekend.

Sincerely,



Ed Hegland, Chairman
National Biodiesel Board