Growth Energy Submits Supplemental RVO Comments to Debunk Anti-Ethanol Study

WASHINGTON, D.C. — Yesterday, Growth Energy submitted supplemental comments to the U.S. Environmental Protection Agency (EPA) responding to erroneous comments from others on the environmental, economic, and compliance impacts of EPA’s proposed 2020, 2021, and 2022 Renewable Volume Obligations (RVOs) under the Renewable Fuel Standard (RFS). Growth Energy’s supplemental comments are in addition to its initial submission to EPA in early February.

In the supplemental submission, Growth Energy rebuts claims based on a recently published anti-ethanol study, whose conclusions about the greenhouse gas (GHG) emission impacts of ethanol are wildly out of step with the established scientific consensus. Environmental experts and leading government agencies agree that ethanol reduces GHG emissions when compared to gasoline, which helps to put our nation on a path toward net-zero emissions.

“As our nation’s top environmental agency, EPA is expected to use the best available science when making important decisions under the RFS and any other environmental law,” said Growth Energy CEO Emily Skor. “The recent comments submitted to EPA that implausibly claim biofuels are worse for greenhouse gas emissions than gasoline very obviously do not meet this standard and should be rejected outright. The U.S. Department of Energy, the U.S. Department of Agriculture, the California Air Resources Board, and EPA all agree that biofuels reduce carbon emissions.”

Read Growth Energy’s supplemental 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.