ABFA’s first priority on this subject is advocating EPA rescind its current policy that prohibits the use of “biointermediate” feedstocks under the RFS program. Biointermediate feedstocks are derived from RFS-compliant feedstocks, partially converted at one facility, then transferred to another facility to be processed into a finished fuel. Under EPA’s current regulations, the act of moving this fuel from one place to another in an intermediary form prevents the fuel from generating RIN credits under the RFS program. If EPA were to remove this impediment, the industry would be able to upgrade biomass products and qualified wastes into biointermediates, then transfer those products to existing refineries or biofuel conversion facilities to be finished into drop-in fuels such as renewable diesel, jet fuel, or gasoline.

Additionally, ABFA has urged EPA to alter its regulations around wood residues. Currently, the regulations require tracking procedures for wood products that are incompatible with existing industry practices. Small changes to these regulatory requirements to permit the use of approved feedstocks, such as wood residue, on an aggregate basis using a mass-balance approach, would make millions of tons of available feedstock available for use under the RFS.