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• Comments on EPA’s Proposed 2013 RFS Volume Requirements

  The Clean Air Act allows EPA to reduce the RFS volume requirements for “advanced fuels” and total renewable fuels whenever it downsizes the annual cellulosic biofuel requirement. CATF’s comments explain that EPA needs to take this step in order to avoid further increases in the climate-harming production of corn ethanol…

  Comments April 5, 2013

• CATF Comments Urging EPA to Waive the Corn Portion of the RFS

  In the midst of the worst drought in decades, CATF submitted comments with ActionAid, Friends of the Earth, and Environmental Working Group urging EPA to waive the portion of the RFS mandate that can be met using corn ethanol in 2012-2013. ActionAid’s report on the financial cost that the US…

  Comments October 11, 2012

• 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…

  Comments April 27, 2012

• CATF Comments on RFS Eligibility of Giant Reed, Camelina, and Other Feedstocks

  Comments submitted by CATF, EWG, FOE, NWF, and NRDC raise concerns about EPA’s land use change analysis for potential biofuel feedstocks and its failure to adequately address the threats they pose as invasive species. The comments also discuss a recent report on the impacts of corn stover removal in the…

  Comments February 6, 2012