Colorado Corn Growers Association has submitted a letter to the Environmental Protection Agency to urge the agency not to approve a request for a waiver of the Renewable Fuel Standard.
The letter reads:
October 8, 2012
The Honorable Lisa P. Jackson, Administrator U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, NW Washington, DC 20004
Docket ID No. EPA-HQ-OAR-2012-0632
Administrator Lisa Jackson,
The effect of the Renewable Fuel Standard in Colorado has been incredibly positive. Our three ethanol plants produce 170 million gallons of ethanol annually and provide enough distillers grains for feed rations to more than 700,000 head of cattle.
During this year’s drought as corn prices increased, Front Range Energy in Windsor, Colo., idled its plant. This was a market decision. Within three weeks, the plant started back up due to increased demands from Denver consumers for the ethanol as well as from local livestock feeders for the distillers’ grain.
What we have seen in Colorado is not different than the rest of the country. The Renewable Fuel Standard (RFS) program has been a success. Since its implementation in 2005, it has: • Increased national energy security by facilitating market access for renewable fuel as a substitute for petroleum-based fuel, accelerating the nation’s progress toward energy independence. • Contributed to the reduction of greenhouse gas emissions. • Opened market channels to allow national ethanol consumption to grow from 3.9 billion gallon per year in 2005 to 13.9 billion gallon per year in 2011. • Encouraged investments for infrastructure making it possible for ethanol to replace the need for imported oil by 485 million barrels – in 2011 alone. • Initiated renewed economic vibrancy in Colorado’s rural economies which is fostering optimism for opportunity and financial sustainability. That optimism is a source of encouragement to younger generations bringing them back to their farming roots and involvement in family farm enterprises.
Implementation of the Standard has stimulated private sector investment in the infrastructure needed to produce and deliver renewable fuels to the marketplace, a marketplace completely dominated in ownership and market share by petroleum fuel interests – producers of the very fuels with which renewables must directly compete.
The need for continuation of the RFS as planned could not be more critical at this point in the process of achieving energy independence. A clear policy message is needed to assure investors of our nation’s conviction to continue moving toward renewables and away from dependency on foreign oil.
We also recognize the challenges currently faced by livestock-producing sectors of agriculture and do not wish hardship on our production partners who raise livestock and feed corn, hay, or other forage supplies decimated by the extreme drought situation facing much of our country.
While no sector can be insulated from risk and economic challenges associated with the current national drought, we believe it important our national policy not be a primary cause of irreparable harm to one sector of agriculture over another. Yet, we recognize that if the RFS were not in place, there would have been significantly fewer than 96 million acres planted to corn in the nation this year – and a drought of this current magnitude would have resulted in similarly tight supply and higher prices for corn and other feed-related commodities. We also recognize and support the analysis from both Purdue and Iowa State Universities indicating the devastation caused by drought as responsible for spiking prices of feed commodities rather than the RFS. Further, the recently released FAPRI-MU Report #11-12 from the University of Missouri identifies minimal opportunity for relief to livestock producers from a proposed twelve-month waiver as proposed.
In fairness, we support the waiver application process and other relief mechanisms incorporated into the RFS, and encourage objective analysis of data to arrive at a responsible decision based on the criteria in the Standard.
If allowed to continue working as designed, the RFS program will have an overall positive impact on the U.S. economy, our energy security, our energy independence, and our nation’s health.
Sincerely, Douglas Melcher Rick Palkowitsh President Public Policy Committee Chair Colorado Corn Growers Association Colorado Corn Growers Association