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Comments on EPA Proposed 2014 Standards for the Renewable Fuel Standard Program

Policy Integrity submitted comments to the Environmental Protection Agency (EPA) on the agency’s proposed 2014 standards for the Renewable Fuel Standard (RFS) program. EPA proposes to reduce renewable fuel targets from 2013 levels, due to concerns regarding industry’s ability to produce sufficient quantities of qualifying fuel and consumers’ ability to use the fuel. This backsliding highlights the RFS program’s inability to guarantee steady reductions in greenhouse gas emissions.

EPA can more efficiently and predictably address transportation-related greenhouse gas pollution via a cap-and-trade program for vehicle fuels. As detailed in our 2009 and 2013 petitions, EPA has broad authority to implement such a program under the Clean Air Act.