The public comment period on the U.S. EPA’s proposed rule to set 2027 and 2027 Renewable Fuel Standard renewable volume obligations (RVOs) and revise RFS regulations closed Aug. 8. Biofuel groups have largely expressed support for the proposal but also outlined several ways to improve the rulemaking.The EPA <a href="https://ethanolproducer.com/articles/epa-releases-proposed-rule-to-set-2026-2027-rfs-rvos-make-significant-changes-to-rfs-program">released</a> the proposed rule on June 13. A public hearing was held in July.&nbsp;The agency has proposed to set the total 2026 RVO at 24.02 billion renewable identification numbers (RINs), a nearly 8% increase when compared to the 2025 RVO. The proposed 2027 RVO is 24.46 billion RINs, up nearly 2% when compared to the previous year.&nbsp;The proposed targets include an implied 15 billion gallon per year mandate for conventional biofuel, a category primarily met with corn ethanol. In addition, the proposed 2026 and 2027 RVOs for biomass-based diesel and advanced biofuel would represent a significant increase over the 2025 mandates.As part of the rulemaking, the EPA has proposed to reduce the 2025 cellulosic RVO from 1.38 billion RINs to 1.19 billion RINs and set the 2026 and 2027 cellulosic RVOs at only 1.3 billion and 1.36 billion, respectively.&nbsp;In addition to setting 2026 and 2027 RVOs, the proposed rule also includes a variety of provisions that would fundamentally alter the RFS program. This includes provisions aimed at boosting domestic biofuel production by limiting the ability for imported fuels and feedstocks to participate in the RFS. Specifically, the EPA is proposing to modify the value of a RIN based on whether the biofuel is derived from domestic or foreign sources. Under the proposed regulations, foreign biofuels and feedstocks would only generate 50% of the RIN value relative to domestic biofuels and feedstocks.&nbsp;To ensure renewable fuel producers are generating the appropriate number of RINs, the EPA is proposing that all domestic renewable fuel producers be required to keep records of feedstock purchases and transfers that identify the point of origin for each feedstock and report that information to the EPA.&nbsp;The proposed rule also aims to eliminate electricity, or eRINs, from the RFS. The EPA has taken steps in recent years to roll electricity into the RFS program, but, to date, has failed to approve a single eRIN pathway. The proposed rule aims to remove the definition of “renewable electricity” from RFS regulations along with the regulations associated with generating eRINs. If finalized, the proposed action will ensure that no RINs are generated in the future for electricity used in motor vehicles, according to EPA.&nbsp;Clean Fuels Alliance America submitted comments supporting the EPA’s proposed RVOs for biomass-based diesel and advanced biofuel, and encouraged the agency to swiftly finalize the RVO proportion of the rulemaking. “The proposal is a welcome signal to U.S. farmers and biofuel producers, and we are ready to meet these higher volumes with domestically produced fuel,” Clean Fuels wrote in its comments. “We ask that the final rule sustain the volumes as proposed to ensure that our capacity is fully utilized. These volumes are readily achievable, based on current domestic production and investments that have been made.”Kurt Kovarik, Clean Fuels’ vice president of federal affairs, added, “Domestic production of biodiesel and renewable diesel doubled since 2020 and continues to grow. The industry supplied more than 5 billion gallons of biodiesel, renewable diesel and SAF to the U.S. market in 2024, and we are poised to deliver more in 2026. Clean fuel production is essential to farm security, supporting 10 percent of the value of every bushel of U.S. soybeans.”“EPA is proposing many changes to the program and expressing the RVO in RIN-gallons rather than physical gallons,” Kovarik continued. “We ask that EPA follow through on its intent to support our industry’s investments in domestic fuel production by maintaining robust volumes even if some parts of the proposal are not finalized. We also urge EPA to ensure that the step-change in volumes is not eroded by small refinery exemptions.”The Renewable Fuels Association expressed strong support for the proposed RVOs, but also recommended slight modifications to the EPA’s plan to prioritize American-made renewable fuels over import-based fuels.&nbsp;“We strongly support EPA’s proposed RVOs and, specifically, the implied conventional renewable fuel volumes of 15 billion gallons for both 2026 and 2027,” wrote Geoff Cooper, president and CEO of the RFA. “This will provide the ethanol industry with room for growth as gasoline blends containing 15 percent ethanol (E15) continue to gain momentum in the marketplace. Expanding the use of domestically produced renewable fuels like ethanol is key to achieving President Trump’s vision for lower fuel prices, a stronger agriculture industry, and American energy dominance.”RFA’s comments voice support for EPA’s goal of prioritizing domestic renewable fuels and feedstocks over imported renewable fuels and feedstocks. However, the association believes certain modifications are needed to EPA’s proposed approach to better reflect market complexities in the wake of other recent policy developments, such as the Trump administration’s tariff implementation, modifications of renewable fuel tax credits under the One Big Beautiful Bill Act, and the significant increase in the proposed RVO for biomass-based diesel.&nbsp;“In the wake of these policy changes, we encourage EPA to consider refocusing potential RIN adjustments more narrowly on imports of finished renewable fuel from countries outside of the United States, Canada, and Mexico, as well as fuels made from certain imported feedstocks (sourced from certain countries of origin) that pose the greatest risk to the integrity of the RFS program,” Cooper wrote. &nbsp;The comments also point out that since corn and sorghum imports are virtually non-existent, EPA’s proposed “feedstock point of origin” tracking requirements are impractical and completely unnecessary for certain renewable fuels like grain-based ethanol.&nbsp;In addition, while RFA strongly supports EPA’s commitment to reallocating obligated renewable fuel blending volumes lost to small refinery exemptions, Cooper urged EPA to maintain a high standard for determining whether small refineries are truly experiencing “disproportionate economic hardship” (DEH).“To honor the clear intent and market-forcing purpose of the Clean Air Act’s RFS program, the Agency should maintain a rigorous analytical approach and a high standard of proof for small refiners to demonstrate DEH,” Cooper wrote. “SRE petitioners claiming DEH should be required to provide specific, verifiable data and evidence showing that 1) compliance with the RFS is a central cause of economic difficulty that rises to a level of ‘hardship’, 2) they are truly unable to obtain RINs ‘ratably’ at the same prices as their competitors, and 3) they are somehow unable to pass along their RIN costs in the price of refined products sold to wholesale customers.”The American Coalition for Ethanol also commended the EPA’s proposed RVOs, but suggested a few targeted changes to the provisions regarding American-made fuels.&nbsp;“ACE supports EPA proposing the highest RVOs to date, including more than 24 billion gallons of total renewable fuel for 2026 and 2027,” stated Brian Jennings, CEO of ACE, in written comments. “We applaud EPA for proposing to significantly increase advanced biofuel levels, so those gallons are not displacing corn ethanol in the conventional biofuel pool.”ACE also commends EPA’s proposal to keep RVOs whole even if small refinery exemptions (SREs) are granted for 2026 and 2027, and strongly supports a new “import RIN reduction” to favor American-made fuels.“This step aligns with the RFS goals of making the U.S. more energy secure and boosting the American rural economy,” Jennings wrote.Specifically, ACE urged the EPA to consider setting the implied target for conventional biofuels at higher than 15 billion gallons, and recognize higher projected use of E15 and E85.&nbsp;Similarly, Growth Energy called on EPA to swiftly finalize the proposed RVOs while protecting against the impact of small refinery exemptions (SREs).&nbsp;“The Trump administration has laid out an ambitious course that will unlock new investment, increase U.S. energy production, and provide reliable markets for our farmers,” said Emily Skor, CEO of Growth Energy. “We urge EPA to stand strong on the president’s vision and swiftly finalize the proposed volumes. At the same time, we recognize that a minority of refiners continue to demand special exemptions that would destroy the very demand this proposal is intended to deliver. The EPA has indicated that they intend to fully account for any lost gallons from 2026 and 2027 exemptions. Maintaining that approach will send a clear signal that producers and farmers can count on this EPA to ensure the promised volumes actually reach the marketplace.”&nbsp;Growth Energy also urged the EPA to continue to grow the RFS to help drive further investment in E15 and E85; limit SREs to small refineries that can fully demonstrate disproportionate economic hardship; finalize the proposal on E15 labeling and infrastructure; finalize the proposal to incentivize homegrown fuels and feedstocks; and approve pending pathways and registrations to help grow opportunities for cellulosic biofuels for corn and sorghum kernel fiber, aviation fuel and carbon capture.&nbsp;The RNG Coalition called the proposal a “step backwards” with regards to the proposed cellulosic RVOs and criticized the EPA’s plan to remove electricity from the RFS program. “We need EPA to do its job and follow Congress’s directives to increase market demand for more renewable fuel,” wrote Johannes Escudero, founder and CEO of the RNG Coalition. “EPA appears to recognize that there is more than enough supply of RNG and more than enough production capacity to meet the 2025 cellulosic biofuel volume requirement as well as to meet higher volumes in 2026 and 2027. But, instead of establishing market-forcing volumes based on the statutory factors listed by Congress, EPA appears to have changed course, taking a step backwards - limiting the cellulosic biofuel category based on its estimates of demand. We urge EPA to follow the statute and Congressional intent and to return to its growth rate methodology that would establish cellulosic biofuel volume requirements of at least 1.5 billion gallons for 2026 and at least 1.86 billion gallons for 2027.“The proposal also ignores the regulatory restrictions impacting RIN generation, despite there being more than sufficient available RNG supply,” Escudero continued. “In proposing to remove renewable electricity from the RFS, EPA is missing a significant opportunity to continue to grow the cellulosic biofuel category and facilitate compliance. EPA should expand the pathways for biogas-derived fuels, not restrict them. We urge EPA to work with the RNG industry to approve new pathways for fuels using RNG as a feedstock. One that can deliver fuel into the market almost immediately is a pathway for generating D3 RINs for refiners that utilize RNG to produce hydrogen used in the hydro-treating process.”

2025-08-11 - Biofuel groups weigh in on EPA’s RFS proposal  (4 publications)

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The public comment period on the U.S. EPA’s proposed rule to set 2027 and 2027 RFS RVOs and revise RFS regulations closed Aug. 8. Biofuel groups have largely expressed support for the proposal but also outlined several ways to improve the rulemaking.

Biofuel groups weigh in on EPA’s RFS proposal

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