Secretary Naig Calls on EPA to Accelerate Biofuel Growth and Protect Congressional Intent in Final RFS Rule

DES MOINES, Iowa (Feb. 14, 2023) – Iowa Secretary of Agriculture Mike Naig submitted comments to the U.S. Environmental Protection Agency (EPA) regarding its proposed rulemaking and volume obligations for the Renewable Fuel Standard (RFS) for 2023, 2024 and 2025. Iowa is the undisputed national leader in biofuels production, with 42 ethanol biorefineries and 11 biodiesel facilities producing 4.5 billion gallons of ethanol and 349 million gallons of biodiesel respectively in 2022. 

“Iowa’s renewable fuels industry is critical to Iowa’s economy, providing thousands of good-paying jobs in communities across our state. Biofuels also provide more affordable and cleaner burning fuel options to consumers and create value-added markets for corn, soybeans, and other agriculture feedstocks,” said Secretary Naig. “I am hopeful that EPA will carefully review stakeholder feedback, uphold and respect the intent of the law and adopt final RFS volume obligations that accelerate availability and use of higher ethanol and biodiesel blends.”

In the letter, Secretary Naig focused his comments on three areas:

  • On ethanol, EPA should proceed with finalizing its proposed annual volumes for 2023, 2024, and 2025. These volumes, an implied 15.25 billion gallons per year, will set a course for increased domestic ethanol use and greater availability of higher ethanol blends such as E15 and E85 throughout the United States.
  • On biomass-based diesel, EPA’s proposed volumes for 2023, 2024, and 2025 are unacceptably low. In fact, the proposed volume for 2023 is nearly 800 million gallons below the actual production of biomass-based diesel in 2022. With current production already exceeding EPA’s proposed volumes and renewable diesel production anticipated to grow exponentially in the coming years, EPA must significantly raise both the biomass-based diesel and advanced biofuel levels. 
  • EPA’s proposal to allow Renewable Identification Number generation from renewable electricity (eRINs) is inequitable, inconsistent with the statutory intent of the RFS program, and unenforceable. The eRINs proposal turns the RFS program on its head by allowing electric vehicle manufacturers to generate eRINs, rather than the renewable natural gas producers that actually produce renewable electricity. The current eRINs proposal should be separated from the RFS volumes and reworked in a manner that is equitable to biofuels and consistent with the RFS law.

The full letter can be found here.


About the Iowa Department of Agriculture and Land Stewardship

Led by Secretary Mike Naig, the Department of Agriculture and Land Stewardship serves the rural and urban residents that call Iowa home. Through its 14 diverse bureaus, the Department ensures animal health, food safety and consumer protection. It also promotes conservation efforts to preserve our land and enhance water quality for the next generation. Learn more at

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