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| Jon,
Thanks for all of your good data and work for our biofuel industry.
Unfortunately, "15 billion gallons is NOT 15 billion gallons".
This is because the EPA administrator has the latitude to adjust this renewable volume obligation based on total gasoline demand.
A week or so ago, Geoff Cooper of the Renewable Fuels Association send out this info:
"Looking at the Impact of Reduced Gasoline & Diesel Demand on 2020 RFS Requirements: Because the annual RVOs under the RFS are percentages, a dramatic increase or decrease in gasoline and diesel consumption can significantly alter the actual absolute volume of renewable fuel required to be blended. The attached two-pager shows a 10% decrease in 2020 gasoline and diesel consumption reduces the actual RFS conventional biofuel requirement in 2020 to 13.5-14.0 (depending on how EPA handles SREs in the wake of the 10th Circuit case)."
And since the current EPA Administrator was a Fossil Fuel Industry lobbyist prior to being assigned to the EPA, rather than a Scientist, I just
don't think we can count on decisions that are good for biofuels to come out of the current EPA?
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A Way forward. Ethanol treated like Strategic Energy that it is.
