Biomass Based Diesel Volume Estimate for RVO 2026
This report provides background information and analysis to estimate Biomass Based Diesel Volume for the RFS RVO in 2026 and 2027. This industry has demonstrated that it can operate at an 80% utilization rate, and at our estimated end 2025 production capacity of 7.2 billion gallons (BG) translates into 5.75 BG per year of biodiesel and renewable diesel production to satisfy the Conventional, Advanced and Biomass Based Diesel categories. After allocating Biomass Based Diesel Renewable Identification Numbers to any Conventional and Advanced Biofuel category shortfalls, the Biomass Based Diesel volume for the RFS RVO 2026 can be increased from 3.35 BG in 2025 to 5.04 BG in 2026.
Increasing the utilization rate in either 2026 or 2027 to 85% producing 6.12 BG of Biomass Based Diesel annually leads to a 5.40 BG RVO. Increasing the capacity utilization to 90%, which may be achievable under the right conditions, could result in 6.48 BG of annual Biomass Based Diesel production which results in a 5.76 BG RVO.
The volume estimate relies on domestically produced biodiesel and renewable diesel. It does not account for imports or exports. The analysis sets aside the impacts of 45Z and focuses on domestic supply.
The volume estimate does not rely on any increase or decrease in the number of RINs available in the RIN bank at the end of 2025. The volume estimate accounts for the re-allocation of Biomass Based Diesel RINs to other biofuel categories to make up for any shortfall in those categories.
EIA Biodiesel Plant Capacity
The EIA publishes U.S. Biodiesel Capacity annually. The yearly August release provides capacity data as of January 1 of that year.
https://www.eia.gov/biofuels/biodiesel/capacity/
Table 1
EIA Biodiesel Production Capacity
Millions of Gallons
| MMG | Jan 1, 2021 | Jan 1, 2022 | Jan 1, 2023 | Jan 1, 2024 |
| Biodiesel Capacity | 2409 | 2255 | 2086 | 2090 |
The EIA has published monthly production capacity figures since January 2011. https://www.eia.gov/dnav/pet/hist/LeafHandler.ashx?n=PET&s=M_EPOORDB_8BDPC_NUS_MMGL&f=M
EIA Biodiesel Production
Annual Biodiesel production data from the EIA is shown in Table 2. Actual data is for 2021-2023, the February 2025 Short Term Energy Outlook (STEO) Forecast is used for 2024 and 2025. EPA EMTS data is shown for comparison.
EIA and EPA volumes may not exactly agree as some producers that are exporting products may not have generated RINs against those exports.
Table 2
EIA Annual Biodiesel Production
| 2021 | 2022 | 2023 | 2024 | 2025 | |
| Production MBD | 111 | 106 | 111 | 108 | 103 |
| Production MMG | 1700 | 1625 | 1700 | 1660 | 1580 |
| EPA EMTS MMG | 1697 | 1615 | 1660 | 1660 |
Biodiesel Production Capacity Utilization
Using the EIA actual biodiesel production and the EIA monthly biodiesel production capacity to calculate the average capacity during the year, one can determine the capacity utilization. See Table 3.
Table 3
Biodiesel Production Capacity Utilization
Based on EIA Data
| MMG | 2021 | 2022 | 2023 | 2024 |
| Production MMG | 1700 | 1625 | 1700 | 1660 |
| Capacity MMG | 2408 | 2171 | 2081 | 2006 |
| Utilization % | 70 | 75 | 82 | 83 |
The closure of biodiesel plants since 2021 has resulted in less available capacity, but a higher utilization for those remaining in operation.
Renewable Diesel Plant Capacity
Since September 2021, the EIA has published an annual table of Renewable Diesel and Other Biofuel Plant Production Capacity. This includes production of Renewable diesel, renewable heating oil, renewable jet fuel, renewable naphtha, renewable gasoline, other biofuels, and bio intermediates. The EIA capacity figures are higher than the actual Renewable Diesel production capacity figures cited by some companies, leading to some confusion when comparing figures from different sources.
https://www.eia.gov/biofuels/renewable/capacity/
For example, Darling Ingredients 2023 SEC 10-K states that its annual Renewable Diesel production capacity is approximately 1.2 BG. The EIA shows the Diamond Green Diesel (Darling-Valero Joint Venture) plant capacity as follows: Norco 982 MMG, Port Arthur 537 MMG for a total of 1.519 BG. https://d18rn0p25nwr6d.cloudfront.net/CIK-0000916540/a65cefc5-ccdd-4b24-960e-9277ce179233.pdf
Irrespective of the differences in reporting, the EIA data in Table 4 shows an increase in annual Renewable Diesel and Other Biofuel Plant Capacity. https://www.eia.gov/biofuels/update/table1.pdf
Table 4
EIA Renewable Diesel and Other Biofuels Production Capacity
Millions of Gallons
| MMG | Jan 1, 2021 | Jan 1, 2022 | Jan 1, 2023 | Jan 1, 2024 |
| RD+ Other Capacity | 791 | 1750 | 3000 | 4328 |
Monthly U.S. Renewable Diesel and Other Biofuels Production Capacity is also available beginning with data from January 2021. Capacity had risen to 4580 MMG in September 2024 and remained there through the end of the year. https://www.eia.gov/dnav/pet/pet_pnp_capbio_dcu_nus_m.htm
Note: According to the EPA EMTS system, Renewable Jet Fuel is reported as a Biomass Based Diesel D4 RIN, Renewable Heating Oil has both D4 and advanced D5 designations, and Renewable Naphtha and LPG are reported as advanced D5 RINs. In 2023 and 2024, Advanced Biofuel D5 RIN generation was 200 MM of which approximately half was due to Renewable Diesel production from co-processing. The other half is made up of renewable naphtha, renewable heating oil and some other smaller volumes of biofuels. This volume of RINS equates to approximately 160 MM physical gallons of advanced biofuel.
In its November 6, 2024, Edition, Farmdoc Daily (University of Illinois) estimated Renewable Diesel Production Capacity. For 2023, Farmdoc cites EIA data. The forecast for 2024-2026 cites several sources including Render and Biodiesel magazine, Argus, and other industry sources. Farmdoc estimates 2024 capacity at 5.120 BG, for 2025. Capacity is estimated at 5.2 BG in 2026. https://farmdocdaily.illinois.edu/2024/11/updated-estimates-of-the-production-capacity-of-u-s-renewable-diesel-plants-through-2026.html
The following examples illustrate the difficulty in comparing data. Survey timings may be different and data sources used are not specifically identified. For example, Farmdoc includes the Chevron Geismar expansion in 2024. According to Chevron Fourth Quarter Earnings call held January 31, 2025, the unit was still in the final commissioning stages.
Another example of data inconsistency: Farmdoc cites the capacity of the three HF Sinclair facilities as Wyoming Renewables Sinclair 117 MMG, Cheyenne 92 MMG and Artesia 141 MMG for a total of 350 MMG, yet HF Sinclair for a total of 350 MMG, yet the HF Sinclair website cites a renewable diesel capacity of 380 MMG.
https://www.hfsinclair.com/sustainability/renewable-energy/
Lipow Oil Associates maintains a database similar to that of the EIA and Farmdoc, but different in that the capacity is based on Renewable Diesel production capacity (including those RD plants that have SAF capability). This database does not include renewable naphtha, heating oil or LPG production. The focus is on production that generates D4 Biomass Based Diesel RINs.
Comparison of Renewable Diesel Production Capacity Figures
In Table 5, the Lipow Oil Associates figures for Renewable Diesel production capacity along with an add on of 160 MMG for other advanced biofuels capacity are compared to the EIA and Farmdoc data.
Table 5
Comparison of Annual Production Capacity
Millions of Gallons
| End 2021 | End 2022 | End 2023 | End 2024 | End 2025 | |
| EIA | 1751* | 3000 | 4329 | 4580 | |
| Farmdoc | 1751** | 3000 | 4329 | 5120 | 5200 |
| Lipow # | 1406 | 2629 | 4048 | 4892 | 5242 |
| Lipow + 160 MM of D5 Capacity ## | 4208 | 5052 | 5402 |
*The EIA data for end 2021 is the data reported for a survey as of January 1, 2022, etc.
** The Farmdoc data for End 2021-End 2023 is the EIA data
# The Lipow data is for RD only
## An adjustment for other advanced biofuels is made to compare with EIA and Farmdoc
The figures are remarkably close. Once the EIA and Farmdoc update their data, greater convergence on 2024 production capacity between the sources is expected.
EIA Renewable Diesel and Other Biofuels Production
Annual Renewable Diesel and Other Biofuels production per the EIA data is in Table 6. The actual data is used for 2021-2023, the February 2025 Short Term Energy Outlook Forecast is used for 2024 and 2025. EPA EMTS Renewable Diesel data, both D4 and D5 generation, is shown for comparison.
EIA and EPA volumes may not exactly agree as some producers that are exporting products may not have generated RINs against those exports.
Table 6
EIA Renewable Diesel and Other Biofuel Production
| 2021 | 2022 | 2023 | 2024 | 2025 | |
| RD MBD | 56 | 98 | 170 | 209 | 233 |
| Other Biofuel MBD | 5 | 13 | 19 | 22 | 41 |
| Total MBD | 61 | 111 | 189 | 231 | 274 |
| RD MMG | 858 | 1500 | 2610 | 3210 | 3572 |
| Other Biofuel MMG | 77 | 200 | 291 | 338 | 628 |
| Total MMG | 935 | 1700 | 2901 | 3548 | 4200 |
| RD MMG EPA D4 | 782 | 1376 | 2351 | 3062 | |
| RD MMG EPA D5 | 62 | 77 | 71 | 46 | |
| RD MMG EPA Total | 844 | 1453 | 2422 | 3108 |
Renewable Diesel Production Capacity Utilization
Using the EIA actual Renewable Diesel and other advanced biofuel production and the EIA monthly biofuel production capacity to calculate the average capacity for the year, one can determine the capacity utilization in Table 7.
Table 7
Renewable Diesel Production Capacity Utilization
Based on EIA Data
| MMG | 2021 | 2022 | 2023 | 2024 |
| Renewable Diesel | 858 | 1500 | 2610 | 3210 |
| Other Advanced | 77 | 200 | 291 | 338 |
| Total | 935 | 1700 | 2901 | 3548 |
| Capacity | 986 | 2132 | 3544 | 4391* |
| Utilization % | 95 | 80 | 82 | 81 |
Company Data
Several publicly traded companies have published their capacity figures as well as actual production figures from which one may determine capacity utilization. Larger facilities tend to operate at higher utilization. Lower utilization at smaller facilities may be due to poorer unit economics, i.e., they don’t have economies of scale, scheduled maintenance or equipment limitations may prevent the facility from reaching full nameplate capacity.
As the industry becomes more familiar with the operating process, one would expect utilization to improve, assuming profitable economics.
Diamond Green Diesel
RD Production Capacity per 2023 SEC 10-K Page 9: 1.2 billion gallons per year
https://d18rn0p25nwr6d.cloudfront.net/CIK-0000916540/a65cefc5-ccdd-4b24-960e-9277ce179233.pdf
Actual RD Production is from the Interactive Analyst Center: 2023: 1246 MMG. 2024: 1253 MMG
https://vbench.virtuaresearch.com/IR/IAC/?Ticker=DAR&Exchange=NYSE#
Capacity Utilization: Approximately 104%
Phillips66
RD+SAF Production Capacity per News Release: Approx 50 MBD (800 MMG)
Renewable Fuels Produced: 3Q 2024: 44 MBD, 4Q 2024 42 MBD.
Capacity Utilization: Phillips66 was starting up its Rodeo expansion during the first half of 2024. Based on the last half of 2024 production figures, Phillips66 operated Rodeo at 86% utilization.
HF Sinclair
RD Production Capacity per website: 380 MMG
https://www.hfsinclair.com/sustainability/renewable-energy/
Sales Volumes per Quarterly Earnings Release: 2023: 214 MMG, 9 months 2024: 194 MMG https://s29.q4cdn.com/382181944/files/doc_news/HF-Sinclair-Corporation-Reports-2024-Third-Quarter-Results-and-Announces-Regular-Cash-Dividend-2024.pdf
Based on the reported sales volumes, HF Sinclair operated at 56% utilization in 2023 and at an annualized 68% in 2024.
Montana Renewables
RD Production Capacity per website 15 MBD (230 MMG)
https://montanarenewables.com/products/renewable-diesel/
Renewable Fuels Produced per Quarterly Earnings: 2023: 97 MMG, 9 months 2024 121 MMG.
https://www.prnewswire.com/news-releases/calumet-reports-third-quarter-2024-results-302299889.html
While the website indicates an annual nameplate production capacity of 230 MMG, statements at their earnings calls and their investor presentations indicate they will operate at an annual rate of 12 MBD or 183 MMG. The pretreater did not come on stream until April 2023, limiting production rates. Based on nameplate capacity, utilization in 2023 was 42%, rising to 70% for the first 9 months of 2024.
Analyzing the 2024 and 2025 RIN Bank Balances
Before estimating the Biomass Based Diesel volume for 2026, it is instructive to analyze the Renewable Fuel Standard and the RIN bank for 2024 and 2025.
Reported Fuel Obligation Volumes
Since 2020, the Actual Reported by Obligated Parties volumes have exceeded the Projected Gasoline plus Diesel Use estimated by the EPA in determining the RVO percentages. Table 8 contains data from EPA EMTS Renewable Volume Obligations Table 1, Estimated Versus Actual Gasoline and Diesel Volume Reported by Obligated Parties.
Based on this bias and using the EIA Short Term Energy Outlook of February 11, 2025, Lipow Oil Associates has estimated the volume of fuel that obligated parties will report in 2024 and 2025.