American Coalition for Ethanol CEO Brian Jennings testified today during a virtual public hearing on the Environmental Protection Agency’s (EPA) proposed Renewable Fuel Standard rulemaking for 2023 through 2025 compliance years.

Jennings testified in support of EPA 1) setting an effective conventional biofuel requirement of 15.25 billion gallons for 2023 through 2025, 2) projecting no small refinery exemptions (SREs) for 2023 through 2025 and reiterating refineries are able to pass on RIN costs to their customers, and 3) conceding its antiquated greenhouse gas model needs to be updated.

The testimony highlighted concern over EPA’s proposed inadequate advanced biofuel blending targets and “alternative approach” to reduce conventional biofuel blending below 14 billion gallons for 2024 and 2025. Jennings encouraged the Agency to “increase [advanced] volumes consistent with new production capacity scheduled to come online” and “clarify it does not intend to issue retroactive waivers of volumes or reduce conventional biofuel requirements in the final rule.”

Jennings also implored EPA to adopt the Department of Energy’s Argonne National Lab’s GREET model for its lifecycle modeling, consistent with direction under the Inflation Reduction Act for the Treasury Department regarding implementation of the new 45Z clean fuel production tax credit.

Lastly, EPA rightfully noted in its proposal that climate-smart agriculture practices can measurably reduce corn ethanol’s carbon intensity. ACE continues to move forward with its USDA project, in partnership with top land-grant scientists and Sandia National Lab, to validate current model results showing significant GHG benefits of climate-smart farming practices on ethanol’s carbon footprint. “We have briefed top EPA leadership on this project and want to work in collaboration with the Agency to ensure corn ethanol’s benefits are acknowledged by EPA as part of the climate solution,” Jennings concluded.

ACE’s full testimony can be accessed here. ACE’s written comments to the proposed rulemaking will provide more comprehensive feedback on these issues and others. EPA’s comment period on the proposed RVOs closes on February 10 and advocates can utilize ACE’s Action Center to participate.