On August 31 NATSO submitted formal comments with the Environmental Protection Agency (EPA) outlining the travel plaza and truckstop industry's perspective on the Renewable Fuel Standard (RFS), with a particular focus on EPA's proposed renewable volume mandates for 2018. NATSO generally supports the EPA's proposal because it appropriately recognizes that the RFS has the potential to cause problems in the retail fuels market, and seeks to address those potential problems while still accomplishing the RFS's objectives -- diversifying, increasing, and improving the emissions characteristics of the nation's fuel supply while lowering costs for consumers.
"The success of the Renewable Fuel Standard will hinge on NATSO's members' ability to acquire, blend, and sell biodiesel on a cost-effective basis relative to traditional diesel fuel," NATSO wrote.
NATSO specifically addressed the underlying purpose of the RFS in the context of imported biofuel. "The Program's objectives could be accomplished to the maximum extent by encouraging U.S. consumption of renewable fuel regardless of whether such fuel is produced domestically or overseas," NATSO wrote. "EPA appears to take the position that the RFS is designed only to encourage consumption of domestically produced biofuels. This is unsound policy, is inconsistent with the Program's purpose, and ultimately may run afoul of international trade law."
The purpose of the RFS, NATSO argued, is to: (i) reduce America's reliance on petroleum imports from unstable regions of the world; (ii) reduce greenhouse gas emissions and improve air quality by incentivizing domestic consumption of cleaner-burning fuels; and (iii) facilitating a market for American farmers.
NATSO also addressed EPA's apparent concerns with the functionality of the RIN market, noting that from its members' perspective, the RIN market is functioning propertly. "The RIN market provides the necessary price discovery and risk management vehicle for those parties involved in the production, distribution, and/or blending of renewable fuels," NATSO wrote. "That being said, NATSO's members would welcome additional oversight and enforcement if the Agency deems it necessary."
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