Growth Energy: EPA Must Quickly Finalize 2022 RVOs and Fix the Flaws of 2020, 2021 RVOs  

WASHINGTON, D.C. — Growth Energy submitted comments in response to the U.S. Environmental Protection Agency’s (EPA) proposed 2020, 2021, and 2022 Renewable Volume Obligations (RVOs), urging the agency to quickly finalize the proposed 2022 RVO and fix the flaws in the proposed 2020 and 2021 RVOs to fully capture the environmental, societal, and economic benefits of the Renewable Fuel Standard (RFS) as Congress intended. Importantly, Growth Energy’s comments address the critical importance of this rule’s impact on what happens when the agency begins work this year on a new rule – called “the Set” – that establishes multi-year targets for 2023 and beyond.

“The Renewable Fuel Standard was designed by Congress to reduce greenhouse gas emissions in our transportation sector, improve U.S. energy security, and support American economic growth,” said Growth Energy CEO Emily Skor. “If the Biden Administration enforces the RFS as previously promised, the RFS can be an even more powerful weapon in the fight against climate change, improving air quality, and addressing environmental justice concerns.

“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. 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.”

In its comments to the agency, Growth Energy urges EPA to update its lifecycle analysis to better reflect the greenhouse gas emissions reduction potential of biofuels as demonstrated in newer science and updated GHG lifecycle emissions modeling. Growth Energy’s comments also discuss the environmental justice concerns related to air quality and how higher biofuel blends may be an available solution.

Growth Energy’s comments to EPA also support clarity regarding the use of biointermediates in the production of renewable fuels, including sustainable aviation fuel, and speedy approval of several pending RFS pathway applications and registrations, including the production of cellulosic biofuel from kernel fiber and several other biofuels.

Read Growth Energy’s comments here.


The EPA’s proposed RVO rule would lower conventional ethanol volume to 12.5 billion gallons for 2020, advanced biofuel at 4.63 billion, and cellulosic at 510 million. In addition, it would set conventional ethanol at 13.32 billion gallons in 2021 and 15 billion gallons in 2022, while advanced biofuels would be set at 5.2 billion gallons in 2021 and 5.7 billion gallons in 2022, including 620 million gallons of cellulosic biofuel in 2021 and 770 million gallons of cellulosic biofuel in 2022. The proposal also adds a supplemental 250 million gallons in 2022 and 250 million gallons in 2023.  Additionally, in conjunction with its RVO proposal, EPA also proposed to deny 65 pending small refinery exemptions and provides important guidance to limit the abuse of small refinery exemptions in the future.

On January 4th, 2022, Growth Energy CEO Emily Skor testified at the EPA’s hearing on the RVO proposals.