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PMAA Testifies Before the EPA on RFS Proposed Rule

 

On Tuesday, PMAA participated in an EPA public hearing on the RFS. PMAA Executive Committee member Vern Kelley (Kelley Fuels, Shakopee, Minnesota), who is a petroleum marketer and a corn farmer, highlighted to policymakers that very few existing UST system components have been certified to handle E10 plus blends. Kelley said that marketers have no practical way to demonstrate existing underground storage tank (UST) systems are compatible with ethanol blends greater than E10 - a key legal hurdle. Last month, the EPA proposed 19.24 billion (15 billion gallons of corn ethanol) of renewable fuels for 2018. EPA is expected to release final RFS volume blending mandates by November 30, 2017.

Kelley said, "the inability of marketers to legally certify their equipment to be E15 compliant would cause severe economic harm through significant disruption of the gasoline supply and distribution network below the terminal rack. It has been estimated that 95 percent of all gasoline supply outlets in the United States cannot legally store or dispense ethanol blends higher than 10 percent. EPA, OSHA and state fire regulations have essentially drawn a line in the sand by requiring all facilities storing and dispensing gasoline blends greater than E10 to prove underground storage tank (UST) system COMPATIBILITY with higher ethanol content fuels. The often-impossible task of demonstrating compatibility with E15 for UST equipment currently in the ground has put the majority of petroleum marketers, the consuming public and the nation's gasoline supply and distribution chain in a precarious situation. While some existing UST systems may be compatible with E15, there is no practical way to certify compatibility other than by installing entirely new systems at prohibitively excessive costs."

Also testifying before the EPA this week was former PMAA Chair Matt Bjornson. Matt testified on behalf of the North Dakota Petroleum Marketers Association (NDPMA) which represents over 240 independent companies and co-operatives.

Click here to read Matt’s testimony.

EPA can fix the RFS by immediately reducing the maximum amount of ethanol blended into gasoline at 9.7 percent of anticipated demand for 2018 and future years. PMAA believes that reducing the ethanol mandate to this level is the most effective way to lower the value of RINS and, in turn, allow all petroleum marketers to compete on a level playing field and not break the law by storing and dispensing a product that is not compatible with their storage tank systems.

Click
here to read Kelley's testimony.

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