Review of EPA’s Proposed RFS Standards for 2023-2025

Ramboll and Net Gain Ecological Services have reviewed the Environmental Protection Agency’s (EPA’s) Proposed Renewable Fuel Standard 2023-2025 rule (the “Set Proposal” or “Proposed Rule”) and the accompanying Draft Regulatory Impact Analysis (DRIA) along with many of the cited articles. After careful review of the Set Proposal and the DRIA, and based on our own literature review and independent analysis, we find that there is no demonstrated causal link between the Renewable Fuel Standard (RFS), and land use change (LUC) or water quality. Furthermore, we conclude that the renewable fuel volumes suggested in the Proposed Rule for 2023-2025 are likely to have minimal or no effects on water quantity, quality or LUC. Our analysis focused on:

• The economic effect of the RFS on corn prices and acres planted in corn.
• The causal linkage between the RFS and LUC.
• Wetlands, ecosystems, habitat, and wildlife.
• Soil and water quality and water quantity.

Overall, our research concludes that the studies conducted by the EPA (2022b), Taheripour et al. (2022a), and Austin et al. (2022), are more representative of the likely effects of the implied conventional volume and ethanol production on corn prices and corn acres planted than are the results of Lark et al. (2022). The methods used by the EPA (2022b) and Taheripour et al. (2022a) account for effects of the global and domestic economies. The methods we use in this report, although high level, are based on 18 years of observed data. The results of our analysis confirm that the implied conventional volume has minimal to no effect on corn prices and acres of corn planted, consistent with the work by the EPA (2022b) and Taheripour et al. (2022a).