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RFA: EPA’s 2023-2025 RVO Proposal a ‘Firm Foundation’ for Future of RFS

January 10, 2023



Proposed volume obligations for 2023-2025 bolster the Renewable Fuel Standard and provide growth opportunities for the ethanol industry, the Renewable Fuels Association said this morning in verbal testimony provided at an Environmental Protection Agency hearing.


“Overall, we believe the proposed ‘Set’ rule establishes a firm foundation for the future of the RFS and creates a pathway for sustainable growth in the production and use of low-carbon renewable fuels,” said RFA President and CEO Geoff Cooper. “Once finalized, the rule will further enhance our nation’s energy security, reduce carbon emissions, and strengthen the rural economy.”


Cooper also stated that RFA strongly supports EPA’s approach to small refinery exemptions, including its assumption that zero exemptions will be granted in 2023-2025. He agreed with EPA’s recent response to a fundamentally flawed GAO report on RFS compliance costs. The agency’s analysis demonstrated that small refineries actually paid slightly less than large refineries for D6 RINs.


When it comes to the idea of expanding the RFS to include renewable electricity made from biomass, Cooper said that EPA should maintain a level playing field and consistent approach to RIN generation for all renewable fuel pathways under the RFS.


RFA will provide more substantive written comments about EPA’s proposal by the Feb. 10 filing deadline.