Growth Energy Again Urges Agency to Use Best Available Science When Measuring Environmental Impact of Biofuels, RFS 

WASHINGTON, D.C.—Growth Energy, the nation’s leading biofuels trade association, again today called on the U.S. Environmental Protection Agency (EPA) to rely on the best available science in its assessment of the environmental impacts of ethanol production and of the Renewable Fuel Standard (RFS).  

In response to a call for comments on EPA’s Third Triennial Report on biofuels and the environment, Growth Energy noted that while EPA’s draft of the report correctly makes several important conclusions about the biofuels industry, it continues to rely too heavily on outdated science that inaccurately measures the nature and scale of the environmental impacts attributable to the RFS. 

“Biofuels are an essential tool for combatting climate change with enormous potential for decarbonizing the transportation fuel sector, while bolstering domestic energy security, providing jobs in rural areas, and lowering the price at the pump for consumers,” said Growth Energy. “For the full potential of biofuels to be realized and to provide a balanced and credible review of the science on environmental impacts, EPA must use the best, most up-to-date science that omits reliance on flawed data and studies that have been discredited by other government agencies and academics.” 

Previously, Growth Energy has urged EPA to update its approach to modeling on several occasions. Most recently, in response to EPA’s proposed Renewable Volume Obligations (RVOs) for 2023-2025, Growth Energy introduced two new studies (available here and here) that further contributed to the growing body of research showing the overall environmental benefits of ethanol and the RFS. 

Growth Energy also supplemented its comments on the draft Third Triennial Report by commissioning an additional study on air quality impacts by Air Improvement Resources, Inc., and another study by Ramboll on land use change and other environmental impacts. Both of these studies conclude that EPA’s draft Triennial Report often overstates, to a significant degree, the environmental impacts of the RFS program, while understating biofuels’ environmental benefits. 

Read Growth Energy’s full comments here. 


EPA, in consultation with the U.S. Department of Agriculture (USDA) and the Department of Energy (DOE), is required under Section 204 of the Energy Independence and Security Act (EISA) to submit a triennial report to Congress that assesses the environmental and resource conservation impacts of the Renewable Fuel Standard (RFS). EPA issued the First Triennial Report in December 2011 and the Second Triennial Report in June 2018. EPA put the Third Triennial Report out in draft form in January 2023 and, for the first time, provided for a 60-day public comment period that included external peer review meetings to discuss the draft. All of the Triennial Reports assess a wide range of environmental impacts, including air, water, and soil quality, ecosystem health, and biodiversity. When it has been given the opportunity to do so, Growth Energy has long provided substantial technical input and scientific research to the EPA and other relevant federal agencies on the environmental impacts and benefits of the RFS program.