EPA publishes third RFS impact report

January 20, 2025

BY Erin Voegele

The U.S. EPA on Jan. 17 published its third triennial report to Congress on biofuels and the environment. The document, the third in a series of required reports to Congress, takes a critical view of the Renewable Fuel Standard’s impact on the environment.  

“The Third Report concludes that the effect of the Renewable Fuel Standard Program varies with time and the RFS Program had a modest positive effect on biofuel production and consumption, and thus had a modest negative effect on the environment,” said the EPA in a notice posted to its website. “These endpoints include air and water quality, water quantity, ecosystem health and biodiversity, soil quality, invasive species, and international impacts. The impacts of the RFS Program overlap with the more significant effects of biofuels as an industry.”

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The Renewable Fuels Association has slammed the report. “Any objective and science-based analysis of the Renewable Fuel Standard would reveal that the program has, without question, positively impacted the environment. Renewable fuels like ethanol reduce greenhouse gas emissions, slash harmful tailpipe pollution and displace the most toxic components of gasoline. When compared to the fuels it replaces, ethanol is also better for overall soil and water quality,” said Geoff Cooper, president and CEO of the RFA. “EPA may be obligated by law to publish this report every three years—a deadline they have never met—but this iteration hardly adds anything to the previous two attempts. For this third report, we agree with former USDA Secretary Tom Vilsack, who commented on Friday that any study that purports to cover the environmental impacts of the RFS but doesn’t consider greenhouse gas emissions is clearly incomplete.”

Clean Fuels Alliance America also criticized the analysis. “Clean Fuels asked EPA to include analysis of the environmental benefits of displacing fossil fuels – which biodiesel and renewable diesel are rapidly doing – to provide important context for the report,” said Paul Winters, director of public affairs and federal communications at Clean Fuels. “It appears EPA did not do so.”

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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 builds on the previous two reports and aims to provide an update of the impacts to date of the RFS program on the environment.

According to EPA, the first two reports were unable to separate the effects of the RFS program from the impact of other factors, such as market or other policy effects. The new report includes an attribution analysis that is designed to better separate the effects of the RFS program from other factors that also affect biofuel production and consumption in the U.S. 

Development of the new report has been ongoing for several years. A draft version of the third triennial report was published by the EPA in early 2023 and subject to a 60-day public comment period. A full copy of the 1,000-plus final report is available on the EPA’s website.  

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