RFA, Growth Energy submit comments to EPA on RVOs

The Renewable Fuels Association and Growth Energy on Friday submitted comments to the Environmental Protection. Agency on its proposed 2020, 2021, and 2022 Renewable Volume Obligations under the Renewable Fuel Standard.

In summarizing RFA’s recommendations for EPA’s final rule, RFA President and CEO Geoff Cooper urged the agency to:

▪ Expeditiously finalize the proposed 2022 volumes and proposed approach to restoring the 500-million-gallon remand;

▪ Eliminate the proposed revision to the 2020 RVO and require obligated parties to comply with the 2020 standards finalized in 2019;

▪ Revise 2021 volumes to reflect a more accurate accounting of actual renewable fuel use; and

▪ Make official the denial of all pending SRE petitions and ensure future petitions are held to the same standards set forth in the unappealed holdings of the 10th Circuit Court decision in RFA v. EPA.

Growth Energy CEO Emily Skor said, “EPA’s proposal includes a number of forward-looking actions that underscore the critical role biofuels play in decarbonizing the transportation sector.”

“We are encouraged that EPA’s proposal for 2022 RVOs would place the RFS program back on track with 15 billion gallons implied conventional ethanol requirements that account for any estimated future small refinery exemptions. We urge the EPA to finalize the 2022 proposal immediately to get these RVOs in place for this compliance year and provide biofuel producers with much needed market certainty.

“However, EPA’s proposal includes some serious flaws that need to be addressed in the final rule. It contains unlawful and unnecessary retroactive cuts to the 2020 RVO and includes inexcusably late volumes for 2021 that simply reflect actual production volumes rather than spur refiners to meet Congress’s RFS goals,” Skor said.

“Such moves, if finalized, would create further uncertainty in the renewable fuel marketplace and undervalue biofuels as a low-carbon, homegrown fuel and its role in our nation’s battle with climate change.”


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