At a recent conference, Environmental Protection Agency Office of Transportation and Air Quality director Margo Oge said the EPA was considering whether a renewable fuel standard for cellulosic ethanol of something less than 100 million gallons/year might be the most viable option for next year due to the possibility that 100 million gallons of cellulosic ethanol might not be available in 2010.

The comments are consistent with EPA's May 2009 Regulatory Announcement, which stated: "While based on industry plans available to EPA, we are not proposing that any portion of the cellulosic biofuel requirement for 2010 be waived, we are seeking additional and updated information that would be available prior to November 30, 2009 which could result in a change in this conclusion."

The Iowa Renewable Fuels Association (IRFA) sent a letter to Oge urging the EPA to maintain the full advanced biofuel volume requirements for 2010 as set forth by the revised renewable fuels standard (RFS) schedule in the Energy Independence and Security Act of 2007.

"The Iowa Renewable Fuels Association (IRFA) believes strongly that any action to reduce an RFS volume requirement must be taken only as a last resort. If the EPA ultimately concludes that the 'last resort' of reducing the cellulosic biofuel carve-out within the advance biofuels category is absolutely necessary, IRFA urges EPA to increase the undifferentiated advanced biofuels requirement by the same amount that cellulosic ethanol is reduced," said IRFA president Denny Mauser.

"Any adjustment to the cellulosic requirement should not impact the overall volume requirement of the renewable fuels standard (RFS) schedule."

Mr Mauser said by adding these waived gallons to the required gallonage for undifferentiated advanced biofuels, EPA would be allowing this amount to be met by other advanced biofuels, such as biomass-based diesel replacements, or even unforeseen volumes of cellulosic biofuel.

"There is clearly no shortage of total advanced biofuels production capacity to meet this requirement," he said.