UNICA’s opposition is based on three contentions:

• Lower statutory volumes are unsupported and unnecessary. Brazil can increase production and export volumes of sugarcane ethanol if given long-term policy signals. Brazil is tracking to produce 6% more ethanol (an additional 450,000 gallons) in 2015 than 2014, and could produce up to 2 billion more gallons for export to the US in future years.

• Volume reductions outstrip EPA authority and undermine RFS intent. EPA’s proposed reductions run counter to Congressional intent in establishing the RFS by incentivizing dirtier fuel supplies.

• Cutting clean fuel consumption threatens climate goals. Favoring gasoline over ethanol undermines President Obama’s Climate Action Plan, the US-Brazil bilateral climate agreement, and both countries’ INDC pledges for December’s COP21 climate summit.

Should EPA continue to cut statutory volumes rather than preserve RFS goals until they can be achieved, UNICA suggests that EPA should:

• Only lower statutory volumes by an absolute minimum to reflect ample advanced biofuel supplies.

• Keep volume requirement reductions above 20% in 2015-2016 to consider statutory reset provisions.

• Change equivalence values for low-lifecycle emission fuels to increase supply and help obligated parties meet statutory volume requirements.

EPA has the power to spur advanced biofuels by maintaining their statutory volume requirements and encouraging production of low-lifecycle emission fuels. Let’s not reverse course on the road to sustainable transportation by artificially lowering demand.

—Leticia Phillips, UNICA Representative, North America