Without any statutory changes, EPA could tweak the RFS program to better incentivize and reward better-performing fuels. By statute, advanced biofuels must deliver 50% or more GHG emissions reductions compared to a 2005 fossil-based baseline. However, many of ABFA’s members produce fuels that far exceed those minimum levels of carbon reduction, and EPA could modify the RFS program to better reward those reductions.

EPA has at its disposal a number of regulatory options to achieve this goal. For example, the Agency could provide additional compliance credit value for better performing fuels, drop-in fuels, or sustainable aviation fuel. Additionally, the Agency could expedite review and approval of more low-carbon fuel pathways for both new feedstocks and technologies to enable more RFS-compliant production of low-carbon renewable fuels.

As the RFS program moves beyond the statutory volume requirements set forth in the 2007 law, and moves to set new standards for 2023 and beyond, EPA has an opportunity to redesign its implementation of the program.  ABFA has developed a framework of recommendations including provisions mentioned above, for the Agency to consider as it engages in this process of setting the future direction of the RFS program (termed the “Set” process). We encourage the Agency to evaluate all options to increase the production and use of cleaner fuels for the nation’s future.