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RFA: EPA’s Triennial Report on RFS Takes Some Constructive Steps but Needs Work

February 24, 2023

Environment, EPA, RFS


The U.S. Environmental Protection Agency’s Third Triennial Report to Congress on the environmental impacts of the Renewable Fuel Standard is still a work in progress that needs to be vetted carefully and refined, the Renewable Fuels Association noted in comments during a peer review meeting this morning.


“Overall, a considerable amount of research is reflected in the draft report, and clearly a substantial amount of work by EPA staff and others went into writing it,” RFA Chief Economist Scott Richman said at the meeting. “However, there are several issues with the content that we hope will be addressed in the final report.”


One example is how the report covers corn ethanol, which was the only biofuel in the program for which EPA conducted a quantitative analysis attributing a specific increase in volumes to the RFS. At the same time, Richman said, when it came to land use, EPA “combined corn and soybeans into a single category, masking the divergent trajectories of the two crops over the last decade.”


Richman also questioned the report’s overreliance on disputed research by Tyler Lark of the University of Wisconsin. “The term ‘Lark et al.’ appears at least 65 times in the report, not including footnotes,” Richman said. “However, the methods used in the 2022 study by Lark et al. have been critiqued or refuted by the USDA; researchers from Argonne, Purdue and the University of Illinois system; and even the EPA itself.”


As one of the authors of the papers by Lark et al. is a peer reviewer for the triennial report, there should be heightened diligence to ensure that the review of how Lark’s work is used in the report is thorough and objective, Richman said.


Click here for Richman’s remarks. A full response to the Triennial report will be provided on March 6, when the formal written comments are due.