The complete comments are best viewed here, in PDF format. 

Taxpayers for Common Sense (TCS) and National Taxpayers Union provide the following comments to the Environmental Protection Agency (EPA) on its proposed rule entitled “Modifications to Fuel Regulations to Provide Flexibility for E15; Modifications to RFS RIN Market Regulations,” which was published at 84 Federal Register 10584 on March 21, 2019. Thank you for the opportunity to offer comments on this proposed rule, which will determine the extent to which corn ethanol is able to further penetrate an already distorted marketplace.

EPA proposes to expand 15 percent ethanol (E15) sales year-round despite current prohibitions on summertime use due to ozone concerns. However, we urge EPA to abandon its current proposal due to incomplete supporting data, a failure to comprehensively assess the economic and environmental costs of expanding E15, and the numerous taxpayer and consumer costs that would result if EPA’s proposal moved forward. EPA has partially assessed the large economic costs associated with increased biofuels use in past Renewable Volume Obligation (RVO) rules and detailed the negative impacts of increased biofuels use in its second triennial report to Congress. However, this current rulemaking omits any similar analysis. Before proceeding, EPA must revisit and expand these and other analyses to assess the full costs that increased availability of E15 will pose for both taxpayers and consumers.

The complete comments are best viewed here, in PDF format.