According to BIO's Brent Erickson, EPA rulemaking delays generated Renewable Fuel Standard (RFS) program instability and "intolerable investment uncertainty." Erickson claimed policy instability responsible for "chilling" up to $13.7 billion worth of investments needed by advanced biofuel industry to build capacity to meet RFS goals. As cited, heaviest impact was on cellulosic biofuel developers. Other effects included undercutting new employment opportunities and loss of 80,000+ direct jobs.