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RFA Calls for Changes in EPA’s Draft Triennial Report on RFS

March 6, 2023

Environment, EPA, Research


In formal written comments submitted today to the U.S. Environmental Protection Agency, the Renewable Fuels Association called for changes to the draft version of the Third Triennial Report to Congress on the environmental impacts of the Renewable Fuel Standard.


“Overall, a considerable amount of research is reflected in the external review draft report, and RFA appreciates the substantial amount of work that EPA staff and other contributors dedicated to the publication,” the comments state. “However, there are several issues that the Agency should address before finalizing the report.”


Principally, the association argues, EPA needs to refine its analysis of the impacts of the RFS on land cover and land management. RFA noted inconsistent time periods used in analyses referenced in the EPA report, as well as a lack of consideration of the role that urbanization played in driving land conversion, even though it has been a major cause of the loss of cropland over time.


In a related manner, the Triennial report is far too reliant on disputed research by Tyler Lark of the University of Wisconsin—research that has been called into question by EPA itself; the U.S. Department of Agriculture; and a group of experts from Argonne National Laboratory, Purdue University and the University of Illinois system.


Additionally, corn-based ethanol is the only biofuel for which the report provided a quantitative estimate of volumes attributed to the RFS. Likewise, given that the last triennial report was published in 2018, there is far too much time spent addressing developments that occurred well before then. Rather, the current report should focus on any environmental impacts that have occurred over the last five years or that are likely to occur in the future.


RFA also faulted EPA’s assumptions regarding future corn ethanol production as unrealistic, and it emphasized the findings from research about the effects of ethanol on air quality, which predominantly range from neutral to highly beneficial. Finally, shortcomings in the peer review process for the report were noted.


Click here for RFA’s written comments. Click here for related remarks by RFA Chief Economist Scott Richman at a February 24 virtual meeting on the Third Triennial Report.