Growth Energy Comments on EPA’s Renewable Fuel Standard (RFS) Program: Standards for 2023–2025 and Other Changes

Growth Energy is the world’s largest association of biofuel producers, representing 90 biorefineries that produce nearly 9 billion gallons annually of low-carbon renewable fuel and 107 businesses associated with the biofuel production process. Growth Energy respectfully submits these comments on the Environmental Protection Agency’s Proposed Standards for 2023–2025 and Other Changes (“Set”).

Congress established the Renewable Fuel Standard (“RFS”) program to spur the market to substantially increase the use of renewable fuel in the nation’s transportation fuel supply. Congress did so for the many important benefits that increased renewable fuel use would bring: reduction in harmful greenhouse gas (“GHG”) emissions, enhanced energy security and independence, and economic development, especially rural communities. The proposed 2023- 2025 standards undoubtedly provide such benefits, but only to a modest extent; the standards are still far below the levels of increased usage that could reasonably be achieved without causing significant economic or environmental harms.

Consequently, EPA’s proposal leaves significant climate, energy security, and economic benefits on the table at a time when such impacts must be prioritized. Growth Energy, therefore, urges EPA to carefully reconsider several parts of its proposal to ensure that they accord with the goals Congress set for the RFS program and EPA’s obligations to rely on the best available science. EPA should use the full force of the RFS program to drive an innovative, low-carbon, domestically sourced energy transformation in the transportation sector.