Climate Policy Engagement Analysis
Climate Policy Engagement Overview: In 2021-23, RFA states top-line support for federal and state-level net-zero emissions goals and appears supportive of policies incentivizing increased production and use of ethanol. However, RFA seems to support a long-term role for internal combustion engine-powered vehicles, through support for ethanol over the full electrification of transportation. RFA also appears to advocate to weaken the integrity of sustainability criteria for biofuels under US policy.
Top-line Messaging on Climate Policy: In 2021-23, RFA communicated positive top-line messaging on climate policy. In July 2022 RFA stated support for California’s 2045 climate neutrality goal and New York’s 2050 carbon neutrality goal in comments on California’s LCFS and New York’s Scoping Plan. RFA also supported the US goal of net-zero GHG emissions by 2050 in a July 2021 open letter. This position appeared to be echoed by RFA President, Geoff Cooper, in a February 2023 press release. InfluenceMap could not find evidence that the RFA has taken a public position on the Paris Agreement.
Engagement with Climate-Related Regulations: In 2021-23, RFA appeared supportive of multiple US regulations incentivizing biofuels. In a March 2023 press release, RFA appeared supportive of the Renewable Fuel Standard (RFS). RFA President, Geoff Cooper, appeared supportive of renewable volume obligations set by the Environmental Protection Agency (EPA) under the RFS, in a February 2023 press release and January 2023 interview. In a January 2023 testimony, RFA Cooper, further applauded the EPA’s proposed renewable volume obligations for 2023-2025. RFA has also advocated for the removal of exemptions for small refineries under the RFS in numerous communications, including an April 2022 joint letter and February 2021 news release.
Regarding biofuel provisions under the Inflation Reduction Act (IRA), in it’s 2023 ‘Ready Set Go’ report, RFA supported measures incentivizing biofuels under the IRA, including the SAF blenders tax credit, Clean Fuel Production Credit and grants for higher-blend biofuel infrastructure. In a January 2023 press release, RFA echoed support for the Clean Fuel Production Credit and SAF blenders tax credit, and an April 2022 joint letter, signed by RFA, described the SAF blenders tax credit as “the most important action Congress can take to support the decarbonization of the aviation sector”. In a December 2022 consultation response, RFA supported the Clean Fuel Production Credit, but opposed an additionality requirement for renewable electricity.
In it’s 2023 ‘Ready Set Go’ report, RFA appeared to advocate for a national Clean Fuel Standard, alongside supporting Washington, Oregon and California’s Low Carbon Fuel Standards (LCFS). In July 2022 comments on New Yorks’ Draft Scoping Plan, RFA further advocated for New York to implement an LCFS. In March 2023 and December 2022 consultation responses, RFA also supported an increased 2030 carbon emissions reduction target under California’s LCFS. However, in a January 2022 Testimony, RFA President, Geoff Cooper appeared unsupportive of proposed light-duty GHG emissions standards because it incentivizes the production of electric vehicles (EVs) over biofuels. RFA also appeared to leverage its support for a national Clean Fuel Standard to oppose stringent tail-pipe GHG emissions standards for vehicles in a February 2023 consultation response. Furthermore, in October 2023 US federal regulatory comments, the RFA opposed the enactment of any new Corporate Average Fuel Economy Standards and instead supported the “No Action Alternative”, in addition to challenging the legality of the proposed rule.
RFA has frequently suggested that crop-based biofuels are a sustainable option, without acknowledging potential trade-offs, including in it’s 2023 ‘Ready Set Go’ report, 2022 ‘Zeroing in on New Opportunities’ report, and 2021 ‘Essential Energy’ report. RFA also opposed a cap on crop-based biofuels under California’s LCFS in July 2022 policy comments. Furthermore, in December 2022 and February 2023 consultation responses, RFA appeared to advocate for amendments which are more likely to underestimate the lifecycle emissions of corn-ethanol derived SAFs and make them eligible for tax credits under the SAF blenders tax credit and Clean Fuel Producers Credit.
Positioning on Energy Transition: In 2021-23, RFA appeared to support the use of ethanol to decarbonize transportation. In a November 2021 press release, RFA President, Geoff Cooper, supported E15 blending with gasoline in road transport and advocated for measures allowing year-round E15 blending in the US, in a December 2022 press release. RFA supported India’s 20% ethanol blending target in a January 2023 blog post. In a March 2022 blog, Cooper supported a transition from oil to ethanol in response to Russia’s invasion of Ukraine, however Cooper’s position on a wider transition aligned with IPCC guidelines is unclear. The RFA President also supported ethanol-based SAFs in a January 2023 Roll Call article and increased investment in biofuel infrastructure in an August 2022 press release. In a November 2022 consultation response, RFA urged measures to promote flex-fuel vehicles, which would enable E85 blending.
However, Cooper appeared to support the long-term role of internal combustion engine-powered vehicles, stating “we’re going to be using hundreds of billions of gallons of liquid fuels in internal combustion engines for decades to come”, in a May 2021 Politico article. Cooper appeared to echo support for the long-term role of ICE vehicles, through support for ethanol blending over the full electrification of road transport, in an October 2022 news release and February 2023 US Testimony. Similarly, in a February 2023 interview, Cooper appeared unsupportive of an electric vehicle (EV) mandate and in a January 2023 testimony to the EPA Cooper didn’t appear to support the incorporation of EVs under the RFS.