NCC on November 29 submitted comments to the Environmental Protection Agency (EPA) regarding a July notice of rulemaking that would further expand the Renewable Fuel Standard (RFS).

In the July notice of public rulemaking, EPA proposed percentage standards for renewable fuel use under the RFS. NCC submitted comments on that proposal detailing the uncertainty regarding the 2019/2020 crop year corn supply. Including EPA’s move earlier this year to allow year-round sales of E15, “NCC believes the proposed volumes and percentage standards for 2020 … is overly aggressive, overly reliant on corn-based ethanol, and likely to cause disruptions to the nation’s feed supply,” NCC said in its comments.

Additionally, NCC called for EPA to utilize a waiver within the original RFS statute that would decrease annual required volumes of ethanol in times of economic hardship, such as extreme weather events. EPA has never used this waiver authority.

“Thus, in order to provide necessary transparency to stakeholders, NCC strongly believes that EPA must, in its final 2020 required volume obligation rule, explicitly state the conditions and circumstances under which the off-ramp waiver authority would be exercised,” NCC said in its comments.

Under the RFS statute, EPA is required to finalize its 2020 annual renewable volume obligations (RVOs) rule by November 30. However, due to the July supplemental rule, EPA missed this deadline. The agency is expected to finalize both rules “this winter,” according to Agri-Pulse.