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RFA Comments: Proposed 2023-2025 Volumes Create ‘Firm Foundation’ for RFS

February 10, 2023

EPA, Regulatory, RFS


The U.S. Environmental Protection Agency’s proposed renewable volume obligations for 2023-2025 will bolster the Renewable Fuel Standard and provide for sustainable growth in low-carbon renewable liquid fuels, the Renewable Fuels Association said in formal comments submitted to the agency today.


“Moving forward, expanding the use of low-carbon renewable fuels like ethanol is the most immediate and effective strategy for meeting the Administration’s carbon reduction goals,” wrote RFA President and CEO Geoff Cooper, who noted that under the RFS, renewable fuels like ethanol have already resulted in the avoidance of more than 1.2 billion metric tons of greenhouse gas emissions from the transportation sector. “Once finalized, the 2023-2025 RVOs will further enhance the energy security, carbon reduction, and economic benefits that have already been realized under the RFS program.”


For 2023, EPA proposes to maintain an implied conventional renewable fuel requirement of 15 billion gallons, along with an additional 250-million-gallon supplemental standard for 2023 that would complete EPA’s compliance with a 2017 court decision. The implied conventional requirement was proposed at 15.25 billion gallons for 2024 and 2025. According to RFA’s comments, “these volumes will drive continued adoption of technologies that reduce carbon intensity, as well as greater investment in the infrastructure needed to expand distribution and consumption of fuels with higher renewable fuel content, like E15 and E85.”


RFA’s comments also voiced strong support for EPA’s policy on small refinery exemptions, stating the agency’s approach matches “the spirit and intent of the law,” complies with recent court decisions, and brings much-needed certainty and long-term clarity to the RFS program.


Finally, RFA encouraged EPA to re-evaluate growth opportunities for advanced biofuels such as biomass-based diesel and ensure that its final approach to renewable electricity RINs, or “eRINs”, honors the RFS program’s statutory intent, and is consistent with RIN generation provisions for all other renewable fuel pathways. RFA also asked the agency to revisit some of the problematic conclusions in its Draft Regulatory Impact Analysis.


In the end, however, EPA is moving in the right direction on the Renewable Fuel Standard. “The RFS has been a tremendous success,” Cooper wrote. “It has bolstered energy security by reducing demand for petroleum imports; it has reduced greenhouse gas emissions by replacing petroleum with low-carbon, renewable alternatives; it has lowered fuel prices for American consumers; and it has created jobs and spurred economic development across the country.”