WASHINGTON — Editor’s note: The following statements have been released by organizations following the U.S. Environmental Protection Agency’s final rule establishing biofuel volume requirements for 2023-2025 under the Renewable Fuel Standard (RFS) program.
National Farmers Union
National Corn Growers Association
American Soybean Association
U.S. Canola Association
Renewable Fuels Association
National Farmers Union
NFU Statement on EPA Blending Volumes for Renewable Fuels
Today, the Environmental Protection Agency (EPA) announced biofuel blending volumes for 2023, 2024, and 2025 that included volumes for advanced biofuels like biodiesel, renewable diesel, and corn ethanol.
“Today’s modest increase in advanced volumes is a step in the right direction for family farmers and the biofuels economy, but also a missed opportunity to further incentivize carbon reductions,” said NFU President Rob Larew. “Unfortunately, EPA did lower the conventional corn-based ethanol volumes and in doing so overlooked the benefits to consumers for lower priced, cleaner burning fuel.
NFU continues to be a strong supporter of higher-level blends of ethanol, which can contribute to a green energy transition and provide economic opportunities to rural communities.
National Corn Growers Association
EPA Sets Final Renewable Fuel Volumes for 2023-2025
The U.S. Environmental Protection Agency today released final volume requirements under the Renewable Fuel Standard for 2023, 2024 and 2025, providing for annual growth in total renewable fuel volumes, although with lower conventional biofuel volumes than EPA had proposed.
For 2023, EPA set an implied 15.25-billion-gallon requirement for conventional ethanol, which includes a supplemental 250 million gallons a prior court decision required EPA to restore to the RFS. For 2024 and 2025, EPA holds the implied conventional volume level at 15 billion gallons, despite proposing 15.25 billion gallons for those two years.
“Today’s final RFS volumes came in below levels EPA proposed for conventional biofuels for 2024 and 2025, holding ethanol volumes steady at 15 billion gallons,” said NCGA President Tom Haag. “A multi-year RFS volume rule offers stability and certainty for renewable fuels. However, when it comes to addressing pressing energy, environmental and economic challenges, EPA’s final rule falls short of the emission reductions and cost-saving benefits the higher proposed ethanol volumes would have provided.”
Separate from the volumes, Haag noted corn growers appreciate that EPA did not finalize a proposal to create a new program to generate RFS credits from automakers for electricity from renewable biomass, referred to as e-RINS.
“NCGA and its members strongly urged EPA to separate its e-RIN proposal from the RFS volumes because the proposal was wholly inconsistent with the way the RFS functions for other fuels and created an unlevel playing field across the RFS,” said Haag.
The RFS requires annual volumes of renewable fuels, such as ethanol, be used in the fuel supply to reduce emissions, expand and diversify the supply, improve energy security and lower costs.
The 2023-2025 volume is EPA’s first RFS rule based on qualitative environmental, economic and agricultural factors listed in the statute, rather than specific volumes in law. The new process allows EPA greater latitude, which the agency used to build on the strong baseline of the 2022 RFS volumes.
American Soybean Association
Soy Growers to EPA: Final RVOs Severely Undercut Rapid Growth, Potential of the Biofuels Industry
The Environmental Protection Agency released its final Renewable Volume Obligations for 2023, 2024, and 2025, which sets annual biofuel blending targets under the Renewable Fuel Standard. Soy growers are expressing disappointment, as the rule does not accurately reflect the growth expected in the industry and falls far below the industry’s current production.
The 2023 finalized rule made zero increases to the 2023 volumes compared to the draft rule. For 2024 and 2025, EPA made modest increases compared to the draft rule.
The total volumes for 2025 represent just over a 20% growth over the 2022 biomass-based diesel RVOs previously set by EPA. However, these totals match current production levels and do not actually account for growth in the industry. The Energy Information Administration predicts an increase in BBD production of over 800 million gallons in 2023 alone. The final rule offers RFS volume increases of just 590 million gallons over the course of three years.
“This announcement is a letdown for soy growers. It threatens the success of the biomass-based diesel industry by significantly dialing back annual increases in volume obligations and failing to account for the progress being made in biofuels investment and growth,” said American Soybean Association President Daryl Cates, a soybean grower from Illinois. “Farmers and biomass-based diesel producers face real, concerning consequences from low RFS volumes that do not reflect current production and demand, and we’re disappointed in this lack of support for the industry.”
ASA has steadily called on EPA and the administration to raise volumes to a level that will continue to support growth of the biofuels industry.
Biomass-based diesel is a vital domestic market for soybean farmers. The RFS has reduced U.S. dependence on foreign oil, reduced greenhouse gas emissions, and added value by increasing demand for soybeans and corn. Billions of dollars are being invested in biodiesel, renewable diesel, soybean crushing plants and other infrastructure to be able to produce more BBD.
The expanded crush capacity companies have announced for the next three years would increase soybean oil supplies by about 5.5 billion pounds. This translates into about 700 million gallons of renewable diesel, far above EPA’s three-year RVO growth of only about 590 million gallons. Adding growth from other feedstocks to the announced crush expansion creates a feedstock-abundant situation.
“EPA’s final rule undercuts these investments, and the market may not be able to absorb the expected future production,” Cates said. “It’s also a huge, missed opportunity for a low-carbon fuel to reduce greenhouse gas emissions and scale back the country’s reliance on imported oil.”
Soy farmers were encouraged by EPA’s 2022 volume target—which included the highest-ever number for total renewable fuels and specifically for biomass-based diesel since the renewable fuel standard was created—and were hopeful EPA would continue its support of the RFS. However, EPA’s final rule will limit growth in soy-based biofuels over the next three years and leaves farmers and biofuels industry partners reeling.
U.S. Canola Association
Statement of the U.S. Canola Association Regarding EPA Renewable Fuel Standard Volumes for 2023-25
The U.S. Canola Association (USCA) – a non-profit commodity organization representing the entire canola value chain, including growers, seed companies, processors and traders – is disappointed by the limited growth represented by the Environmental Protection Agency’s (EPA’s) biomass-based diesel and advanced biofuels volumes under the Renewable Fuel Standard (RFS) for 2023, 2024 and 2025. Canola is one of several crop feedstocks approved under the RFS for production of clean-burning biofuels, including biodiesel, renewable diesel, naphtha, heating oil, propane and sustainable aviation fuel.
The final RFS volumes for 2023-25 limit the opportunity to maximize the production of biomass-based diesel fuels that are available now to reduce greenhouse gas emissions from the transportation sector. The EPA’s final biomass-based diesel volumes – 2.82 billion gallons in 2023, 3.04 billion in 2024 and 3.35 billion in 2025 – do not reflect production levels already achieved and surpassed by the industry or the oilseed crush and biofuel processing capacity expansion plans. EPA data showed that the U.S. biomass-based diesel market reached 3.1 billion gallons in 2021 and exceeded that level in 2022, which are higher levels than the RFS volumes set by the EPA for 2023 and 2024. The U.S. Energy Information Administration’s Short Term Energy Outlook for June 2023 projects increases in U.S. production of biodiesel and renewable diesel of more than 800 million gallons in 2023 and 900 million gallons in 2024. The USCA and industry stakeholders supported increased RFS volumes, calling for the EPA to annually increase the biomass-based diesel volumes by 500 million gallons per year.
As noted in the USCA’s Feb. 10, 2023 letter to the EPA, the past performance and record of the agriculture and biofuels industries demonstrates the ability to respond with sustainable expansion and diversification of feedstocks. Canola acreage and yields in the primary growing region in North Dakota continue to trend upward. There is also significant potential for expansion of canola production as a winter crop.
The biofuel market is a valuable outlet for surplus canola oil not utilized for food production. In 2021-22, approximately 1.4 billion pounds of canola oil were used annually in biofuels.
Renewable Fuels Association
RFA: Final RVO Rule Fails to Deliver on Promise of Original Proposal
The 2023-2025 Renewable Fuel Standard volumes finalized today by the Environmental Protection Agency mark an unfortunate step backward from the volumes that were originally proposed, according to the Renewable Fuels Association.
EPA’s final rule includes conventional renewable fuel requirements of 15 billion gallons for both 2024 and 2025, down from the proposed volumes of 15.25 billion for both years. RFA called the reductions “inexplicable and unwarranted.”
“The RFS was intended to drive continual growth in all categories of renewable fuels well beyond 2022; instead, today’s final rule flatlines conventional renewable fuels at 15 billion gallons and misses a valuable opportunity to accelerate the energy sector’s transition to low- and zero-carbon fuels,” said RFA President and CEO Geoff Cooper. “By removing half a billion gallons of lower-carbon, lower-cost fuel, today’s rule needlessly forfeits an opportunity to further enhance U.S. energy security and provide more affordable options at the pump for American drivers.”
Despite the rule’s failure to finalize the strong proposed conventional renewable fuel volumes, the action “includes solid volumes for other renewable fuel categories and brings some stability and predictability to the marketplace for the next two and a half years,” Cooper said. “Despite the disappointing reduction in conventional renewable fuel numbers, we appreciate the fact that President Biden and EPA Administrator Michael Regan have continued to prioritize renewable fuels in our nation’s energy and climate strategy.”
EPA’s final rule includes a total volume obligation of 20.94 billion gallons for 2023, of which 15 billion gallons will come from conventional renewable fuels like corn ethanol. The rule also includes a supplemental volume requirement for 250 million gallons in 2023 to make up for illegally waived volumes in 2016. EPA finalized total volumes of 21.54 billion and 22.33 billion gallons in 2024 and 2025, respectively, with conventional renewable fuel requirements of 15 billion gallons for each of those two years.
RFA also welcomed EPA’s announcement that it would not implement RINs for electricity (eRINs) as part of today’s final rule. As the organization noted in oral testimony and written comments to EPA, the agency’s initial proposal for incorporating eRINs into the RFS was overly complex and inconsistent with RIN generation provisions for all other renewable fuels. RFA joined several other stakeholder groups in encouraging EPA to reconsider its eRIN proposal and take more time to get it right.
“We appreciate that EPA was responsive to the many questions and concerns raised by numerous stakeholders regarding eRINs, and we believe the agency did the right thing by calling a timeout on implementation of those provisions,” Cooper said. “We look forward to continuing to engage with EPA on the best methods for bringing renewable electricity into the RFS program.”
RFA provided substantive written comments on EPA’s proposal and offered oral testimony during a public hearing in January.
