CATF Comments on RFS Eligibility of Palm-based Biofuels

CATF’s comments describe how a decision to qualify biofuels derived from palm oil as “renewable fuels” under the RFS would violate EPA’s statutory obligations, particularly its duty to ensure that qualifying fuels provide a reduction in lifecycle GHG emissions. CATF also contributed to a broader set of comments on the eligibility of palm-based fuels; those comments are appended to CATF’s legal comments.