Clean Fuels urges EPA to either raise RFS multiyear volumes or only finalize 2023 volumes

Clean Fuels Alliance America filed formal comments Feb. 10 on U.S. EPA’s Renewable Fuel Standard proposal for 2023-’25 and other changes.

After sending signals supporting growth for biomass-based diesel and advanced biofuels in June, EPA reverted to the pattern of flatlined volumes common in previous years.

Clean Fuels asks the agency 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.

“The clean fuels industry today meets a significant portion of the nation’s demand for heavy duty on-road fuels, helping to lower diesel fuel prices that impact the costs of all consumer goods,” said Kurt Kovarik, vice president of federal affairs with Clean Fuels. “The industry is investing to double production, based on signals from the administration in the SAF Grand Challenge and pledge to cut carbon emissions in half. Flatlined volumes for the RFS threaten to undermine our industry’s investments as well as derail the administration’s goals for domestic-energy security, jobs, economic opportunities, and environmental gains.”

The U.S. Energy Information Administration recently projected that domestic renewable diesel capacity could more than double through 2025 to 5.9 billion gallons.

EPA’s data show that more than 3.6 billion gallons of advanced biomass-based diesel was generated for the RFS program in 2022, an increase of more than 500 million gallons over 2021.

The growth is supported by investments of nearly $5 billion by oilseed processors to increase availability of vegetable oils and meal for domestic use.

But EPA proposed to keep RFS biomass-based diesel requirements below 3 billion gallons through 2025.

“In finalizing the overdue rules for 2021 and 2022, Administrator Regan committed to increase availability of homegrown fuels, put the RFS program back on track, and deliver certainty and stability,” Kovarik added. “December’s proposed volumes for biomass-based diesel and advanced biofuels contradict this sentiment.”

Kovarik wrote in his comments, “Clean Fuels asks that EPA increase the D4 biomass-based diesel volumes by 500 million gallons year over year and increase the D5 advanced volumes by 1 billion RINs year over year as supported through the data. If EPA is unable to significantly raise the volumes across the three years, we respectively request that the agency only finalize 2023 requirements as directed by the consent decree. Finalizing a no-growth scenario as proposed will have devastating consequences on the investments being made.”

Recently, Clean Fuels published a new study, “Economic Impact of Biodiesel on the U.S. Economy 2022,” conducted by LMC International.

The study finds that based on 2021 market data, the biodiesel and renewable diesel industry produced 3.1 billion gallons and generated $23.2 billion in economic activity, while supporting 75,200 jobs paying $3.6 billion in annual wages in the United States.

For every 100-million-gallon increase in domestic clean-fuel production, the direct, indirect and induced economic activity increases by $1.09 billion and U.S. jobs grow by 3,185.

The largest economic and employment benefits occurred in the farming, oilseed-processing and fuel-production sectors.

The study further calculates that producing 6 billion gallons of clean fuels in the U.S. would increase overall economic activity from the current $23.2 billion to $61.6 billion and support 187,003 jobs earning $8.8 billion in wages.

The construction of additional capacity would increase economic activity by an added $4.3 billion and support an additional 144,500 related temporary jobs earning $5.8 billion in wages.

Clean Fuels’ full comments can be accessed here.