Governors' Biofuels Coalition

In comments submitted to the U.S. Environmental Protection Agency last week, the National Corn Growers Association expressed strong support for the Renewable Fuel Standard and noted that granting a waiver at this point would be premature.

“NCGA and our member associations have long supported the RFS2, including the waiver provision process,” wrote NCGA President Pam Johnson, an Iowa corn grower. In response to a 2008 waiver request, EPA had established that severe harm to the economy attributed to the RFS was one of only two grounds for granting a waiver. “We believe the burden of proof for severe harm to the economy falls on the petitioner.”

He says since higher feed prices are only one piece of a complicated economic puzzle we believe the petitioners have failed to establish this proof.

NCGA also pointed out that, with harvest still underway, a complete count of the 2012 corn crop is unavailable, and that this information is needed for an informed decision by the EPA.

“USDA will continue to refine the crop production estimates throughout the fall,” Johnson noted. “There is potential for this yield forecast to change, up or down, as well as future changes in harvested acreage. Based on these crucial changes we encourage the Agency to wait until USDA has produced the November report before making any decision tied to corn availability.”

Although most livestock groups have lobbied for some waiver relief from the RFS, a large waiver may not be in their best long-term interest, NCGA’s comments state.

The NCGA says the RFS has increased national energy security by creating a market for renewable fuel as a substitute for petroleum-based fuel thereby accelerating the nation’s progress toward energy independence.

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