25x’25 Vision: By 2025, America’s farms, forests and ranches will provide 25 percent of the total energy consumed in the United States, while continuing to produce safe, abundant, and affordable food, feed and fiber.

25×25 Comments on 2018 RFS RVOs

Statement Release // 8.25.17 // Contact Ernie Shea, 410-252-7079




On the U.S. Environmental Protection Agency’s Proposed Rule:

Renewable Fuel Standard Program:

Standards for 2018 and Biomass-Based Diesel Volumes for 2019

Docket ID No. EPA-HQ-OAR-2017-0091

Federal Register / Vol. 82, No. 139 / Friday, July 21, 2017

Submitted August 17, 2017 1


The 25x’25 Alliance is a diverse, grassroots national alliance of nearly 1000 agriculture, forestry, conservation, business and environmental organizations working collaboratively to advance the goal of securing 25 percent of the nation's energy needs from renewable sources by the year 2025.

We are pleased to submit comments in response to the proposed 2018 cellulosic biofuel, advanced biofuel and total renewable fuel volumes and 2019 biomass-based diesel volume as directed by the Renewable Fuel Standard (RFS) program. The RFS has been an important tool for rural economic development and emissions reductions, and it has been a cornerstone policy in our nation’s effort to reduce our dependence on foreign oil.

As in recent years, the Environmental Protection Agency’s (EPA) proposed 2018 percentage standards for cellulosic biofuels, advanced biofuel and total renewable fuels fail to meet the congressionally established biofuel blending requirements. The EPA’s proposal to reduce the advanced biofuel and total renewable fuel volumes from the levels finalized in 2017 continues to demonstrate a missed opportunity along the nation’s move towards a more diversified energy future, as well as a failure to recognize the ability of achieving significant greenhouse gas (GHG) emission reductions.


The U.S. pursuit of alternative, clean and domestically produced transportation fuels stemmed from a belief among policy makers that the traditional methods of powering our vehicles were unsustainable for the long-term and presented a risk to our national security. It was in this context that Congress amended the Clean Air Act to first establish the RFS with the enactment of the Energy Policy Act of 2005 (EPAct of 2005, P.L. 109-58). This initial RFS (referred to as RFS1) mandated that a minimum of 4 billion gallons of biofuels be used in 2006, with volumes rising to 7.5 billion gallons by 2012. Two years later, the Energy Independence and Security Act of 2007 (EISA of 2007, P.L. 110-140) expanded the biofuel mandate volumes and extended the date through 2022. The expanded RFS (referred to as RFS2) required the annual use of 9 billion gallons of biofuels in 2008, rising to 36 billion gallons in 2022, with at least 16 billion gallons from cellulosic biofuels, and a cap of 15 billion gallons for starch-based ethanol. These biofuels are derived from a wide range of renewable feedstocks, including traditional crops, woody biomass, purpose-grown grasses, oil and greases, animal renderings, municipal wastes, and starch-based products.

Congress created the RFS to:

Reduce the risk of investing in renewable biofuels by establishing a predictable market for biofuels for a projected period of time;

Enhance U.S. energy security via the production of liquid transportation fuels from renewable, domestic feedstocks;

Decrease reliance on imported fossil fuels;

Provide an additional source of demand for U.S. agricultural commodities and drive agricultural and rural economic development;

Increase rural incomes and rural employment opportunities;

Ensure environmental benefits of renewable biofuels over fossil fuels; and

Respond to climate change concerns, as agricultural-based biofuels emit lower volumes of direct greenhouse gases (GHGs) as compared to fossil fuels.


Current Proposal

Similar to previous years, the EPA’s use of its "cellulosic waiver authority"1 in proposing Renewable Volume Obligations (RVOs) for 2018 once again represents a significant deviation from the volumes Congress set by statute (except for biomass-based diesel). EPA proposes to reduce the total renewable fuel volume from 26 billion gallons to 19.24 billion gallons. Within the total volume of renewable fuel, EPA has proposed to reduce the volume of advanced biofuels from 11 billion gallons to 4.24 billion gallons. As part of the advanced biofuels category, the EPA has also proposed to reduce the volume of cellulosic biofuels from 7 billion gallons to 238 million gallons. Furthermore, this represents a reduction of 73 million gallons of cellulosic biofuels that were mandated in the 2017 Final Rule. The volume of biomass-based diesel for 2018 was previously set at 2.1 billion gallons.2 EPA has again proposed a volume of 2.1 billion gallons of biomass-based diesel for 2019 although EPA does "not see any significant marketplace impediments that are likely to prevent the supply of 2.9 billion gallons of biodiesel and renewable diesel in 2018."3 The amount of conventional ethanol allowed in the proposed rule (15 billion gallons) is consistent with the 15 billion gallon "constant" volume for conventional, starch-based ethanol that has been stipulated in the statute since 2015.4 We commend EPA for avoiding the use of its "general waiver authority" and thus not applying its misinterpretation of the "inadequate domestic supply" waiver provision.

1 Federal Register / Vol. 82, No. 139 / Friday, July 21, 2017 / Proposed Rule / Page 34209

2 The 2018 biomass-based diesel volume requirement was established in the 2017 final rule (81 FR 89746, December 12, 2016).

3 Federal Register / Vol. 82, No. 139 / Friday, July 21, 2017 / Proposed Rule / Page 34234

4 Federal Register / Vol. 75, No. 58 / Friday, March 6, 2010 / Final Rule / Page 14746

Overall, this proposal has the effect of reducing the total amount of cellulosic biofuels and biomass-based diesel that can be used to meet the standards.

RFS Volume Comparison (in billions of gallons) Statutory 2016 RVOs

Final 2016 RVOs

Statutory 2017 RVOs

Final 2017 RVOs










Cellulosic biofuel








Biomass-based diesel

No less than 1.0


No less than 1.0


No less than 1.0



Advanced biofuel








Conventional ethanol








Total Renewable Fuel