The Renewable Fuel Standard (RFS) celebrates its thirteenth anniversary this month and remains a foundational energy policy that enhances America’s energy security and improves the environment. Brazilian sugarcane biofuel producers are proud of the modest but important role they have played helping make the RFS a success, especially when it comes to supplying the U.S. with clean, advanced biofuels that offer superior environmental benefits.

The Environmental Protection Agency has proposed new RFS volume requirements for 2019, and there are certainly elements of the proposal that deserve broad support. At the top of our list is increasing the advanced biofuel requirements by 12 percent to 4.88 billion gallons in 2019 and recognizing that Brazilian sugarcane ethanol can supply at least 100 million gallons of that amount.

But EPA could also strengthen the proposal in ways that would encourage advanced biofuels to play a greater role greening the U.S. transportation sector. Here are two suggestions that Brazilian sugarcane producers recommend in our official comments submitted to the Agency today.

Expect More from Advanced Biofuels

We think the 2019 volume requirements should be even higher. Because under the right market conditions and with appropriate regulatory incentives, the advanced biofuel industry – including Brazil’s sugarcane industry – could produce more.

EPA designates sugarcane ethanol from Brazil as an advanced biofuel because it reduces greenhouse gases by at least 61 percent compared to gasoline. Brazil currently produces more than seven billion gallons of sugarcane ethanol each year, and typically makes between 400 million and 800 million gallons of its annual production available for other countries to import.

However, Brazil could export considerably greater volumes of sugarcane ethanol to the United States. In the past, Brazil has exported a record of 1.35 billion gallons to the United States in one year (2008) and 164 million gallons in one month (September 2008). At a mere 100 million gallons, EPA is underestimating the volume of sugarcane ethanol that can be made available to the U.S. market under the right conditions.

Create New Incentives for the Cleanest Fuels

One way EPA could help nudge those market conditions into a more favorable posture is by creating an incentive program that would give extra credit to the most climate-friendly biofuels. The RFS statute clearly grants EPA this authority, but to date, the Agency has not exercised it.

As a potential model, EPA need look no further than its program for regulating greenhouse gas emissions from motor vehicles. Under these regulations, vehicle manufacturers are required to meet fleet-wide average emission standards. The fleet-wide average is generally determined by taking the weighted average of the emissions associated with each vehicle produced by a manufacturer. However, EPA regulations create an incentive multiplier for electric and other advanced vehicles, which allows manufacturers to double-count these vehicles for purposes of determining their fleet-wide average.

Even though the Clean Air Act does not specifically contemplate such a multiplier, EPA determined it could create such an incentive to “promote the penetration of certain ‘game changing’ advanced vehicle technologies.”

We encourage EPA to create a similar incentive for game-changing advanced biofuels that exceed minimum RFS requirements.

Continuous Improvement

Over the past six years, nearly 1.3 billion gallons of sugarcane ethanol imported from Brazil flowed into American vehicles. During this time, sugarcane ethanol comprised only one percent of all renewable fuels consumed by Americans but has provided more than six percent of the entire U.S. advanced biofuel supply. Brazilian sugarcane producers take pride in this track record of success and are eager to contribute even more.

The RFS is now a teenager, and EPA must continue to play a thoughtful role guiding the program through unavoidable growing pains. We hope the Agency will stay laser focused on fostering the development of advanced and cellulosic biofuels.

Leticia Phillips

Leticia Phillips

Leticia Phillips is UNICA’s Representative for North America. Ms. Phillips is an expert on Brazil-US relations and leads the Brazilian sugarcane industry’s advocacy efforts before the main stakeholders in the region, including the US Congress, Federal agencies, State legislators and business and civil society.