Advanced Biofuels Association strongly objects to EPA’s 2023-’25 volumes in RFS proposal
The Advanced Biofuels Association submitted comments to U.S. EPA Feb. 10 urging the agency to increase the Renewable Fuel Standard program’s proposed renewable volume obligations (RVOs) for 2023-’25 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. “The Advanced Biofuels Association urges the agency to increase volumes of liquid renewable fuels to ensure a cleaner, more independent energy future for America, as the Biden administration has promised.”
The Advanced Biofuels Association encourages the EPA to revisit its volumetric-obligation calculations, citing research conducted by Lipow Oil Associates on the projected production capacity of renewable diesel in 2023, 2024 and 2025, and an analysis of global feedstock supply conducted by LMC.
The research finds that there are sufficient feedstocks available, accounting for food, to support an increase in renewable volumes and more than enough production capacity already on the ground and running to support increased RVOs.
The studies suggest that a reasonable approach is to raise the biomass-based diesel pool by 500 million gallons per year, totaling close to 8 billion RINs in the advanced pool by 2025.
“Based on current and projected volumes of the D5 pool, it is indefensible to claim that feedstocks and production capacity are insufficient to support growth in the advanced category, including those to produce SAF and renewable diesel and biodiesel,” McAdams said.
The Advanced Biofuels Association’s comments also addressed several key areas of significant opportunity the agency must consider as it moves to finalize the “set” rule.
Notably, the association recommends EPA reevaluate unnecessary restrictions on current and future renewable feedstocks to better support the production of low-carbon fuels.
“As the climate emergency grows, we will undoubtedly need an all-of-the-above approach to carbon reduction from the transportation sector,” McAdams said. “The Biden administration has a prime opportunity with EPA’s set-rulemaking process to disrupt the status quo and chart a more progressive RFS program that expands and expedites the transition to a lower-carbon future powered by American-made, renewable liquid transportation fuels. The Advanced Biofuels Association will continue to serve as a resource to the EPA throughout the rulemaking process and in our collective effort to reduce America’s transportation-based greenhouse-gas emissions.”
The Advanced Biofuels Association’s full comments can be accessed here.