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Public Comment Analysis and Public Hearing Support for the EPA's Annual Renewable Fuel Annual Standards

Congress created the Renewable Fuel Standard (RFS) program in an effort to reduce greenhouse gas emissions and expand the nation’s renewable fuels sector while reducing reliance on imported oil.

The Clean Air Act requires the U.S. Environmental Protection Agency (EPA) to set the RFS volume requirements annually and finalize the standards by Nov. 30 of the year preceding the compliance year. The annual standards are based on the statutory targets. EPA establishes the RFS standards through a notice-and-comment rulemaking process with an opportunity for public comment and stakeholder engagement.

Since 2013, Abt Associates’ dedicated public comment management team has led the effort to collect, organize, and code more than 1.4 million comments on this annual rulemaking and support preparation of the response to comments documents. For this time-sensitive and often controversial work, we use our public comment management tool CommentCounts, which allows contractor and Agency staff to quickly understand the issues in the public comments and develop robust responses. Abt’s effort on the standards for 2017 and biomass-based diesel volume for 2018 includes the analysis of more than 750,000 public comments.

In additional, Abt provided administrative, logistical, technical, and onsite support for four heavily-attended RFS public hearings. We lead the effort on site selection and contract negotiations and identified the needed vendors, including court reporters to produce the verbatim transcript, audiovisual equipment and technicians, teleconference providers, and translation services.

Abt staff attended the public hearings to provide onsite support for testifier registration and for managing the vendors. Following the public hearings we organized the written testimony submitted by the testifiers and delivered the official verbatim transcripts of the testimony received by EPA at the hearings.

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North America