The Environmental Protection Agency’s recently released Third Triennial Report to Congress on the environmental impacts of the Renewable Fuel Standard “takes some constructive steps but needs work,” according to the Renewable Fuels Association.

In comments during a peer review meeting last week, RFA Chief Economist Scott Richman pointed out several issues with the content they 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.”

Click to read Richman’s remarks. RFA will submit a full response to the Triennial report on March 6 when the formal written comments are due.