Ethanol groups call for improvements on draft RFS impact report

By Erin Voegele | March 07, 2023

The Renewable Fuels Association and Growth Energy have praised many elements included in the U.S. EPA’s Third Triennial Report to Congress on the environmental impacts of the Renewable Fuel Standard, but are calling on the agency to make several important improvements to the report.

Both groups filed public comments on the report with the EPA ahead of a March 6 deadline. The agency released an external review draft of the Third Triennial Report on Jan. 3. The document was subject to a 60-day public comment period.

The EPA is required to report to congress on the environmental and resource conservation impacts of the RFS program under Section 2004 of the Energy Independence and Security Act of 2007. The reports are required to be made on a triennial basis. The first such report was completed in 2011, with the second completed in 2018. The third report aims to build on the previous two reports and provide an update of the impacts to date of the RFS program on the environment.

The draft report released Jan. 3 spans nearly 1,000 pages and addresses a wide variety of issues, including biofuel supply chain; biofuels and agricultural markets; domestic land cover and land management; air quality; soil quality; water quality; water use and availability; ecosystem health and biodiversity; invasive or noxious plant species; and international effects.

In formal written comments submitted March 6, the RFA advocated for several changes to be made to the draft report. “Overall, a considerable amount of research is reflected in the external review draft report, and RFA appreciates the substantial amount of work that EPA staff and other contributors dedicated to the publication,” the RFA’s comments state. “However, there are several issues that the agency should address before finalizing the report.”

Principally, the RFA argues, EPA needs to refine its analysis of the impacts of the RFS on land cover and land management. RFA noted inconsistent time periods used in analyses referenced in the EPA report, as well as a lack of consideration of the role that urbanization played in driving land conversion, even though it has been a major cause of the loss of cropland over time.

The RFA also said the Triennial report is far too reliant on disputed research by Tyler Lark of the University of Wisconsin—research that has been called into question by EPA itself; the USDA; and a group of experts from Argonne National Laboratory, Purdue University and the University of Illinois system.

In addition, the RFA noted that corn-based ethanol is the only biofuel for which the report provided a quantitative estimate of volumes attributed to the RFS. Likewise, given that the last triennial report was published in 2018, there is far too much time spent addressing developments that occurred well before then. Rather, the current report should focus on any environmental impacts that have occurred over the last five years or that are likely to occur in the future.

RFA also faulted EPA’s assumptions regarding future corn ethanol production as unrealistic, and it emphasized the findings from research about the effects of ethanol on air quality, which predominantly range from neutral to highly beneficial. Finally, shortcomings in the peer review process for the report were noted.

In its comments, Growth Energy said that while EPA’s draft of the report correctly makes several important conclusions about the biofuels industry, it continues to rely too heavily on outdated science that inaccurately measures the nature and scale of the environmental impacts attributable to the RFS. 

“Biofuels are an essential tool for combatting climate change with enormous potential for decarbonizing the transportation fuel sector, while bolstering domestic energy security, providing jobs in rural areas, and lowering the price at the pump for consumers,” said Growth Energy. “For the full potential of biofuels to be realized and to provide a balanced and credible review of the science on environmental impacts, EPA must use the best, most up-to-date science that omits reliance on flawed data and studies that have been discredited by other government agencies and academics.” 

Previously, Growth Energy has urged EPA to update its approach to modeling on several occasions. Most recently, in response to EPA’s proposed Renewable Volume Obligations (RVOs) for 2023-2025, Growth Energy introduced two new studies (available here and here) that further contributed to the growing body of research showing the overall environmental benefits of ethanol and the RFS. 

Growth Energy also supplemented its comments on the draft Third Triennial Report by commissioning an additional study on air quality impacts by Air Improvement Resources, Inc., and another study by Ramboll on land use change and other environmental impacts. Both of these studies conclude that EPA’s draft Triennial Report often overstates, to a significant degree, the environmental impacts of the RFS program, while understating biofuels’ environmental benefits.