Biofuels Groups Submit Final RFS Proposal Comments

Cindy Zimmerman

Biofuels stakeholder organizations have submitted final comments on the proposed Renewable Fuel Standards for 2023, 2024, and 2025 to the Environmental Protection Agency prior to the deadline on February 10.

The Renewable Fuels Association said the proposed renewable volume obligations for 2023-2025 will bolster the Renewable Fuel Standard and provide for sustainable growth in low-carbon renewable liquid fuels. “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.”

American Coalition for Ethanol (ACE) CEO Brian Jennings highlighted areas of support in the proposal, while detailing how to adjust the rule to maximize this significant new phase of the RFS to ensure the overall goal of the program is left intact — to increase the percentage of renewable fuels consumed in the U.S. Among ACE’s objections to the proposal are concerns it may retroactively waive blending levels established by this rulemaking and breaking precedent by giving Tesla and other vehicle manufacturers the ability to generate eRINs when all other RINs are generated by the producer of the renewable fuel.

In its formal comments, Clean Fuels Alliance America urged EPA to either raise RFS multiyear volumes or only finalize 2023 volumes. The group – which represents biodiesel, renewable diesel and sustainable aviation fuel – wants EPA to significantly increase the volumes for biomass-based diesel and other advanced biofuels over the next three years, based on the factors that EPA is required to consider, such as the commercial development of these fuels, the positive impact on the economy, the benefits for consumers, and the significant environmental benefits.

Comments from the Advanced Biofuels Association also urge the agency to increase the Renewable Fuels Standard Program’s proposed Renewable Volume Obligations (RVOs) for 2023 – 2025 to accurately reflect the volumes of advanced, biomass-based diesel, and cellulosic pools available in the market.

“The EPA’s multiyear RFS proposal ignores the proven production capacity of advanced low-carbon liquid transportation fuels, essentially undermining Congress’ intent for the program by flatlining renewable fuel obligations and stretching the law to categorize electricity as a ‘fuel’,” said Michael McAdams, president of the Advanced Biofuels Association.

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