SUBMISSION: Clean Fuel Standard Regulatory Framework

BCBC supports the elimination of the federal Renewable Fuels Standard (RFS). History shows that when governments establish solutions via prescriptive regulations, this often impedes efficient and effective market innovation. No one knows what technologies will dominate in the future. Directing results (i.e., type of technology or, in this case, fuels and fuel additions) requires subsidies, leads to increased costs for industry and consumers, provides few opportunities to scale up outcomes, and – in the case of fuel standards – will limit carbon reductions. On the other hand, every time government defines a schedule for the removal of pollution precursor content (e.g., lead, SO2, halocarbons, etc.), the market responds with innovation. Simply put, the social benefits of the RFS are few and mainly involve a transfer of domestic wealth that could be used better elsewhere.