The federal government provides an array of subsidies to increase the consumption of biofuels such as corn ethanol. The subsidies include tax breaks, grants, loans, and loan guarantees. The government also imposes a mandate to blend biofuels into gasoline and diesel fuels. Biofuel supporters said that these policies would reduce gas prices, strengthen the economy, and benefit the environment, but none of those promises have turned out to be true.
The problem is not with the voluntary use of biofuels in the marketplace, but rather policies that mandate and subsidize biofuels. That top-down approach has harmed consumers, damaged the economy, and produced negative environmental effects. Even within the agricultural community, federal biofuel policies have adversely affected livestock producers and other businesses.
Congress should end its intervention in the biofuels industry. It should terminate subsidies and repeal the Renewable Fuel Standard. Individuals and markets can make more efficient and environmentally sound decisions regarding biofuels without subsidies and mandates.
What Are Biofuels?
Biofuels are derived from biological matter. Producers ferment sugar (sugarcane and sugar beets) and starch products (corn and potatoes) to create bioalcohols, and they ferment oilseed crops (soybeans and sunflower seeds) and animal fats to create biodiesel.
Ethanol, the most common biofuel, is mainly made from corn in the United States. Before federal subsidies and mandates were put in place, ethanol was already used as an additive to gasoline, allowing it to burn cleaner and more efficiently. The use of biofuels is not new, and it did not originally stem from government policies. A century ago, Henry Ford had planned for the Model T to run on ethanol, and Rudolf Diesel showcased a diesel engine that ran on peanut oil.1
Today, fuel suppliers mix biofuels into gasoline and diesel at blending stations. Most vehicles can handle gasoline blended with at most 10 percent ethanol (E10). In 2011 the Environmental Protection Agency (EPA) approved a blend of up to 15 percent ethanol (E15) for vehicles in model year 2001 and newer, but that mix is damaging to engines in older vehicles.2 Possible engine harm, automobile warranty concerns, and a lack of infrastructure have delayed adoption of E15.3 A further concern is that higher ethanol blends are harmful to the smaller engines in lawnmowers, motorcycles, and boats.4 Another fuel blend is E85, which contains from 51 percent to 83 percent ethanol and is used in flexible-fuel vehicles.5
The federal government distinguishes between conventional (first-generation) biofuels and advanced (second-generation) biofuels, including cellulosic ethanol. Producers create advanced biofuels from nonfood parts of crops and other biomass such as leaves, switchgrass, algae, and woodchips. However, developing commercially viable fuel from these sources has proven to be very difficult.
Federal Biofuel Policies
The federal government has supported biofuels for decades. Republican and Democratic administrations and congresses have put in place a variety of subsidies—including tax credits, import tariffs, grants, loans, and mandates—to increase the production, sale, and use of biofuels.
In response to the oil crisis of the 1970s, Congress passed the first ethanol tax credit in the Energy Tax Act of 1978. Later legislation, including the Biomass Research and Development Act of 2000, the Healthy Forests Restoration Act of 2003, and the American Jobs Creation Act of 2004, introduced or expanded subsidies for biofuels. Farm bills in 2002, 2008, and 2014 also added and expanded biofuel programs. Today, there are at least 11 different federal subsidy programs for biofuels providing loans, grants, and other benefits.6
However, the most important component of federal biofuel policy is the Renewable Fuel Standard (RFS). It mandates that billions of gallons of ethanol be blended into gasoline and diesel fuel each year. The Clean Air Act Amendments of 1990 mandated the sale of oxygenated fuels in some regions of the country, and that “kicked off the modern U.S. ethanol industry growth.”7 Then the Energy Policy Act of 2005 mandated that increasing amounts of renewable fuels be mixed into America’s fuel supplies over time, primarily corn-based ethanol. The Energy Independence and Security Act of 2007 greatly increased the mandated quantities.
Under the 2007 law, there must be 36 billion gallons of biofuels blended into the nation’s fuel supplies by 2022. No more than 15 billion gallons of that can be corn-based ethanol, and 21 billion gallons must be from advanced biofuels. After 2022 the EPA is granted authority to set annual targets.
The RFS is causing major economic and compliance problems. One problem is that cellulosic biofuel is supposed to be 44 percent of the total mandate by 2022, but actual production of these advanced fuels is far below expectations and running into major technical setbacks.8 In 2017 production of cellulosic biofuel will be just 1.6 percent of the 19 billion gallons of the overall biofuels mandated under the RFS.9
A broad range of groups oppose the RFS mandate, including environmental groups, anti-poverty groups, most economists, energy companies, and many farm groups. The RFS is opposed by the National Chicken Council, National Cattlemen’s Beef Association, National Pork Producers Council, National Turkey Federation, Milk Producers Council, and others.10 It is also opposed by the American Petroleum Institute, National Resource Defense Council, American Fuel and Petrochemical Manufacturers, Environmental Working Group, and Oxfam.11
Despite the opposition, the biofuel lobbies have so far held sway in Congress. Over time, however, opposition to the RFS has increased as the negative economic, technical, and environmental effects have become more obvious. The RFS is a failed experiment. Congress should recognize its mistake before more damage is done and repeal the mandate.
Such a reform would not end the biofuels industry. Some biofuels are cost competitive with traditional fuels and make a useful addition to gasoline mixed in at small levels. In the year before the government mandated ethanol use, American companies produced more than 81 million barrels of ethanol.12 Used at a modest level, ethanol is a cost-effective oxygenate for gasoline, meaning an additive that improves efficiency and helps meet fuel emissions requirements. A study by the University of Tennessee Institute of Agriculture estimated that with no RFS and no ethanol tax credit, demand for corn ethanol would have been 4.3 billion gallons in 2014, or about 30 percent of actual corn ethanol production that year.13
By ending federal subsidies and mandates, biofuels use would decline to efficient levels that maximized consumer benefits. Agriculture and food markets would benefit from the elimination of distortions that biofuel mandates are creating. The most competitive elements of the biofuels industry would survive and thrive in a free market.
The following sections discuss how current biofuels policies increase costs for drivers, raise food prices, and harm the environment.
Increase Costs for Drivers
Ethanol is not a good substitute for regular gasoline because it contains less energy. Ethanol has only two-thirds the energy content of regular gasoline.14 Drivers get fewer miles per gallon the higher the share of ethanol and other biofuels mixed into their tanks.
During times of high gas prices, ethanol may appear less expensive. But after adjusting for the energy content difference, higher concentrations of ethanol in fuel costs more. As an example, the national average price of regular gasoline in February 2016 was $1.71 per gallon and E85 was $1.52 per gallon.15 But adjusting for E85’s lower energy content pushed the price up to the equivalent of $1.99 per gallon at the time. The Energy Information Administration (EIA) estimates that the overall energy content of fuel at the pump fell 3 percent between 1993 and 2013 as mandated ethanol use increased.16
The additional cost of ethanol varies depending on current ethanol and gasoline prices. But, in general, the higher the ethanol content, the lower is gas mileage, and the more drivers must spend to go the same distance. Motorists can spend hundreds of dollars more per year running common flexible-fuel vehicles on E85 instead of regular gasoline blended with E10.17
Raise Food Prices
Ethanol production uses a large share of America’s corn crop and diverts valuable crop land away from food production. The resulting increases in food prices have hurt both urban and rural families. Families with moderate incomes are particularly burdened by the higher food prices created by federal biofuel policies. Higher corn prices also hurt farmers and ranchers who use corn for animal feed. Higher food prices caused by biofuel policies also hurt low-income families in other countries that rely on U.S. food imports. U.S. corn accounts for more than half of the world’s corn exports.18
Almost 40 percent of the entire U.S. corn crop has been used for ethanol in recent years, up from about 13 percent when Congress mandated the original quota in 2005.19 The remaining 60 percent is used for food, animal feed, and exports. In 2012 the amount of corn used to produce ethanol in the United States exceeded the entire corn consumption of the continent of Africa and of any single country except China.20
The U.S. Department of Agriculture noted that “increased corn prices draw land away from competing crops, raise input prices for livestock producers, and put moderate upward pressure on retail food prices.”21 These negative effects were particularly apparent during the 2012 drought in the United States, which destroyed crops, drove corn prices up 33 percent, and heightened concerns that the RFS was diverting food to fuel.22 Since corn is an ingredient in many foods, and an important feedstock for animals, many in the food industry (from cattle and chicken farmers to restaurant associations) complained about the mandate’s effect on food prices.
In 2012 the governors of Arkansas, Delaware, Florida, Georgia, Maryland, New Mexico, North Carolina, Texas, Utah, Virginia, and Wyoming petitioned the EPA for a waiver of the RFS in order to reduce corn prices, but the EPA denied the request.23 Yet according to a study by economists at the University of Nebraska–Lincoln, the drought’s impact on corn prices could have been “fully negated” by reducing the RFS by 23 percent that year.24
A number of studies have examined the link between biofuels policies and global food prices, as well as the adverse consequences on the world’s poorest citizens. The Food and Agriculture Organization of the United Nations, ActionAid, World Resources Institute, Organization for Economic Co-operation and Development, and the World Bank have all identified higher food prices as a negative effect of biofuel policies.25
The magnitude of the RFS’s effect on the prices of corn and other farm products is difficult to determine precisely, but the direction of the impact is clear. The RFS has increased demand for corn and pushed up prices. One study by University of California at Davis economists found that the RFS increases corn prices by 30 percent, while a Heritage Foundation study found the increase to be 68 percent.26 The Congressional Research Service (CRS) reports that economists “are nearly universally agreed that the strong, steady growth in ethanol demand for corn has had an important and sustained upward price effect, not just on the price of corn, but in other agricultural markets including food, feed, fuel, and land.”27
Proponents of the RFS and biofuel subsidies argue that the policies support economic growth in rural communities. Actually, the policies support corn growers at the expense of other rural industries such as livestock production, which use corn as animal feed.
In the future, biofuels may make more economic sense than they do today and become a preferred fuel choice by Americans in open markets. But current policies that mandate the increasing use of biofuels are imposing large costs on motorists, harming food consumers and livestock producers, and damaging the overall economy.
Harm the Environment
Supporters of biofuel subsidies and the RFS claim that the policies create environmental benefits, including a reduction in greenhouse gas emissions. But most evidence now indicates that biofuel policies do not reduce such emissions or benefit the environment overall.
Here are some of the factors to consider regarding biofuels and the environment:
- Biofuel policies draw additional land into agricultural production. After accounting for this land-use conversion, the additional use of fertilizers, insecticides, and pesticides, as well as the fossil fuels used for production and distribution, biofuel production is quite carbon intensive.28
- The United Nations Food and Agriculture Organization found that converting noncropland to production of corn ethanol released at least 17 times more emissions than the amount of reduced carbon dioxide emissions by the use of biofuels.29
- University of Michigan Professor John DeCicco found that even without accounting for indirect land use changes, biofuels increase the amount of carbon dioxide released into the atmosphere compared to regular gasoline.30
- Despite once hailing biofuels as a tool to mitigate climate change, the United Nations Intergovernmental Panel on Climate Change now acknowledges that biofuels policies negatively affect the lives of the poor, distort land use, and may have negative environmental consequences.31
- A study by Iowa State University researchers concluded that the increased production of biofuels generated by government policies has led to environmental harm from the use of fertilizers and land-use conversion for agricultural production, which can result in increased soil erosion, sedimentation, and nitrogen and phosphorous runoff into lakes and streams.32
Ethanol does have benefits as a fuel additive to help gasoline burn more cleanly and efficiently. However, in a report to Congress on the issue, the EPA projected that nitrous oxides, hydrocarbons, sulfur dioxide, particulate matter, ground-level ozone, and ethanol-vapor emissions, among other pollutants, would increase at different points in the production and use of ethanol.33
Many types of agricultural production affect the natural environment, both positively and negatively. Almost all industrial output has some unwanted effects, whether air pollutants or discharges into water systems. But those effects are not a reason to eliminate market activities that generate net value overall. The problem with biofuel policies is that they are both harmful to the economy and they have negative environmental effects. Biofuel policies were sold as being “green,” but today’s high levels of subsidized biofuel use does not benefit the environment.
Renewable Fuel Standard
The RFS illustrates the folly of trying to centrally plan energy markets. Current rules require a steadily increasing share of biofuels in gasoline until 2022. In 2016 ethanol exceeded 10 percent of all U.S. gasoline sales for the first time. Petroleum refiners are now coming up against a “blend wall” such that further biofuel increases will begin causing harm to vehicle performance and damage to engines and catalytic converters.
The RFS is also a bureaucratic nightmare. The 2007 law created separate requirements for different classes of biofuels, including conventional, advanced, cellulosic, and biomass. It also created a greenhouse gas accounting system because each fuel generates different lifecycle emission amounts. There are special rules for crops on forested areas and federal land, and there are complex procedures for the EPA to follow in setting each year’s mandated amounts.
For fuel refiners, the RFS has created a complicated system of credits and credit trading. Each refiner in the United States must have a certain percentage of its domestic sales contain blended ethanol, called a renewable volume obligation (RVO).34 But refiners have an option to meet part of their requirement by buying credits rather than blending more ethanol. In order to track this, the EPA requires a renewable identification number (RIN) to account for the amount of biofuel reaching the market and to make sure refiners blend enough ethanol. Refiners can hold on to these credits to meet their RFS requirement or they can purchase RIN credits from other refiners. Different RIN prices exist for different forms of biofuels.
Since refineries now face the blend wall, increased trading for RIN credits has caused the price of the credits to spike from pennies previously to more than a dollar in 2013 and then back up to nearly a dollar in 2016.35 The system also generates abuse as refineries buy fake credits with made-up RINs. Investor Carl Icahn says that “RINs have turned into a $15 billion market full of manipulation, speculation and fraud.”36 A report by a former head of EPA’s criminal investigations, Doug Parker, found that fraud in the RINs market could be as high as $1 billion.37 Parker concluded that the RFS program was “a ripe target for massive fraud and illicit gain.”38
Overmandating—requiring the use of more ethanol than can be blended—and forcing the purchase of RINs, could cost consumers billions of dollars at the pump.39 The consulting firm NERA warned that attempting to hit the original RFS targets in 2022 would result in severe economic harm:
When the required biofuel volume standards are too severe, as with the statute scenario, the market becomes disrupted because there are an insufficient number of RINs to allow compliance. “Forcing” additional volumes of biofuels into the market beyond those that would be “absorbed” by the market based on economics alone at the levels required by the statute scenario will result in severe economic harm.40
Federal mandates to continually increase biofuel use make no sense partly because we do not know the overall level of fuel demand in the future. If fuel demand is flat due to higher vehicle fuel efficiency, the blend wall problem will persist. Flexible-fuel vehicles capable of using E85 offer little economic relief for the blend wall. Demand for these vehicles is very low, and drivers who own flexible-fuel vehicles often fill their tanks with E10 because the energy content is higher than E85.
Proponents of the RFS pointed to oil price volatility as a reason to support federal policies. But in free markets there is nothing wrong with energy price changes, which work to balance supplies and demands. Besides, the passage of the RFS has done little to curb the effects of oil price volatility. And furthermore, ethanol is subject to its own price volatility. As CRS noted of a 2008 price spike, “The experience of $7.00-per-bushel corn, albeit temporary, shattered the idea that biofuels were a panacea for solving the nation’s energy security problems and left concerns about the potential for unintended consequences from future biofuels expansion.”41
While corn-based ethanol has kept up with mandates so far, the production of other biofuels has not. The production of cellulosic ethanol, made from nonfood sources, is nowhere near meeting targets, even though the RFS mandates 16 billion gallons to be used by 2022. High capital costs and difficulty in scaling up cellulosic biofuel conversion plants have prevented advanced biofuels from becoming economically viable.
The EPA has had to reduce Congress’s original annual quotas for cellulosic ethanol because not enough was available on the market. The EPA adjusted Congress’s first cellulosic target from 100 million gallons in 2010 to just 6.5 million. However, even the adjusted mandate was a stretch compared with reality; in fact, zero gallons were produced that year and the following one.42 For 2017 the EPA has set the target for cellulosic ethanol at 311 million gallons and total advanced biofuels at 4.28 billion gallons.43
Refiners have had to pay millions of dollars in waiver credits or surcharges for failure to comply with the EPA’s minimum volume requirements. Refiners pass these costs onto consumers. In January 2013 the Washington, D.C., Circuit Court of Appeals ruled that the EPA “let its aspirations for a self-fulfilling prophecy divert it from a neutral methodology,” and that the RFS target was an “unreasonable exercise of agency discretion.”44 It vacated the cellulosic ethanol requirement required by the RFS for the year 2012. The EPA has since proposed future cellulosic mandates that are equally out of touch with market realities.
The Wall Street Journal reported in 2016 that the RFS was creating big winners and big losers among companies because of the buying and selling of RINs:
Environmental regulations designed to boost the amount of ethanol blended into the U.S. gasoline supply have inadvertently become a multibillion-dollar windfall for some of the world’s biggest oil companies.
Companies including Chevron Corp., Royal Dutch Shell PLC, and BP PLC could reap a total of more than $1 billion this year by selling the renewable fuel credits associated with the ethanol program…
For other companies, especially smaller refiners, the rules have had the opposite effect, forcing them to spend hundreds of millions to buy credits to comply.45
Carl Icahn, who is a part owner of a refinery that is bearing heavy costs, complained that “a shadowy, unregulated trade in electronic credits called Renewable Identification Numbers (RINs) threatens to destroy America’s oil refineries, send gasoline prices skyward and devastate the U.S. economy.”46 Icahn wants policymakers to reform the RFS, but for all the reasons discussed here, it should be completely repealed.
The political tide is turning against ethanol and biofuels as more experts and policymakers are recognizing the shortcomings of federal policies. Biofuel policies promised a lot of benefits, but they have delivered more harm than good. While some farmers and agribusinesses gained, taxpayers, motorists, food consumers, livestock producers, and the environment have been harmed. Furthermore, the federal mandate is generating vast bureaucracy, imposing major losses on some refiners, and generating widespread fraud and abuse.
The administration should work with Congress to:
- Repeal the Renewable Fuel Standard. Biofuels existed before the RFS, and biofuels would remain after repealing it to the extent that they were economically viable. Repealing the mandate would create a more efficient biofuels market based on entrepreneurial initiative rather than government dependence.
- Eliminate biofuels subsidy programs. Congress should repeal all the biofuels spending programs that have been included in farm bills and other bills, including grant and loan programs.
- Allow producers and consumers to drive innovation. Make broad reforms to the energy sector to level the playing field between producers, fuels, and technologies. Congress should allow consumers to choose their favored fuels for transportation and other uses within open and competitive markets.
Nicolas Loris is an economist at the Heritage Foundation.
3 Kelsi Bracmort, “The Renewable Fuel Standard (RFS): In Brief,” Congressional Research Service, R43325, December 14, 2016, p. 9.
4 Ed Perratore, “Gas with Ethanol Can Make Small Engines Fail,” Consumer Reports, March 22, 2013.
6 Nicolas D. Loris, “Eliminate Favorable Treatment of Biofuels,” Heritage Foundation, July 25, 2016, Table 1.
8 Kelsi Bracmort, “The Renewable Fuel Standard (RFS): In Brief,” Congressional Research Service, R43325, December 14, 2016.
9 Kelsi Bracmort, “The Renewable Fuel Standard (RFS): In Brief,” Congressional Research Service, R43325, December 14, 2016, p. 5.
10 Letter to EPA Administrator Lisa Jackson, “Petition for Waiver or Partial Waiver of Applicable Volume of Renewable Fuel,” July 30, 2012, www.eesi.org/files/20120730-mf-Final-RFS-Waiver-Petition.pdf.
11 Nicolas D. Loris, “Eliminate Favorable Treatment of Biofuels,” Heritage Foundation, July 25, 2016.
12 U.S. Energy Information Administration, “Petroleum & Other Liquids: Ethanol Oxygenate,” September 30, 2015, www.eia.gov/dnav/pet/pet_pnp_oxy_dc_nus_mbbl_a.htm.
13 Daniel De La Torre Ugarte and Burton English, “10-Year Review of the Renewable Fuels Standard,” University of Tennessee, Institute of Agriculture, October 14, 2015.
14 U.S. Department of Energy, Office of Energy Efficiency and Renewable Energy, “Ethanol,” www.fueleconomy.gov/feg/ethanol.shtml. And see Dan Edmunds and Philip Reed, “E85 vs. Gasoline Comparison Test,” Edmunds.com, April 29, 2009.
16 U.S. Energy Information Administration, “Increasing Ethanol Use Has Reduced the Average Energy Content of Retail Motor Gasoline,” October 27, 2014.
18 U.S. Bureau of the Census, Statistical Abstract of the United States: 2012, August 2011, Table 852, www.census.gov/library/publications/2011/compendia/statab/131ed.html.
19 U.S. Department of Agriculture, Economic Research Service, “U.S. Bioenergy Statistics: Table 5—Corn supply, disappearance and share of total corn used for ethanol,” January 2017.
20 Colin Carter, Gordon Rausser, and Aaron Smith, “Commodity Storage and the Market Effects of Biofuel Policies,” University of California–Davis, March 20, 2015.
21 U.S. Department of Agriculture, Economic Research Service, “Bioenergy: Findings,” November 1, 2016, www.ers.usda.gov/topics/farm-economy/bioenergy/findings.aspx.
22 Steve Hargreaves, “Calls to Scrap Ethanol Mandate Intensify with Drought,” CNN Money, August 6, 2012.
23 Letter to EPA Administrator Lisa Jackson, “Petition for Waiver or Partial Waiver of Applicable Volume of Renewable Fuel,” July 30, 2012, www.eesi.org/files/20120730-mf-Final-RFS-Waiver-Petition.pdf.
24 Sunil Dhoubhadel, Azzeddine Azzam, and Matthew Stockton, “The Impact of Biofuels Policy and Drought on the U.S. Grain and Livestock Markets,” Journal of Agricultural and Applied Economics 47, no. 1 (2015): 77–103.
25 Nicolas D. Loris, “Eliminate Favorable Treatment of Biofuels,” Heritage Foundation, July 25, 2016.
26 Colin A. Carter and K. Aleks Schaefer, “US Biofuels Policy, Global Food Prices, and International Trade Obligations,” American Enterprise Institute, May 2015. And see David W. Kreutzer, “Renewable Fuel Standard, Ethanol Use, and Corn Prices,” Heritage Foundation, September 17, 2012.
27 Randy Schnepf, “Agriculture-Based Biofuels: Overview and Emerging Issues,” Congressional Research Service, May 1, 2013, p. 14.
28 “Fundamentals of a Sustainable U.S. Biofuels Policy,” James A. Baker III Institute for Public Policy, Rice University, January 2010. And see Adam J. Liska, et al, “Biofuels from Crop Residue Can Reduce Soil Carbon and Increase CO2 Emissions,” Nature Climate Change 4 (April 20, 2014): 398–401.
29 The State of Food and Agriculture, 2008 (Rome, Italy: Food and Agriculture Organization, United Nations, 2008), Chapter 5.
30 John M. DeCicco, Testimony on the Renewable Fuel Standard, House Subcommittees on the Interior, Energy, and Environment and on Health Care, Benefits, and Administrative Rules, House Committee on Oversight and Government Reform, March 16, 2016.
31 Lennart Olsson, Maggie Opondo, Petra Tschakert, “Chapter 13: Livelihoods and Poverty,” in “Climate Change 2014: Impacts, Adaptation, and Vulnerability,” Fifth Assessment Report of the Intergovernmental Panel on Climate Change, 2014, www.ipcc.ch/report/ar5/wg2.
32 Amani Elobeid et al., “Greenhouse Gas and Nitrogen Fertilizer Scenarios for U.S. Agriculture and Global Biofuels,” Iowa State University, Center for Agricultural and Rural Development, June 2011.
33 Environmental Protection Agency, “Biofuels and the Environment: The First Triennial Report to Congress,” 2011, http://cfpub.epa.gov/ncea/biofuels/recordisplay.cfm?deid=235881.
34 U.S. Department of Energy, Energy Information Administration, “RINs and RVOs Are Used to Implement the Renewable Fuel Standard,” June 3, 2013.
35 Bradley Olson, “Ethanol Rules Fuel Big Gains for Oil Firms,” Wall Street Journal, October 28, 2016.
36 Carl Icahn, “If Oil Refiners Crash, So Will the Economy,” Wall Street Journal, November 22, 2016.
37 Doug Parker, “White Paper Addressing Fraud in the Renewable Fuels Market and Regulatory Approaches to Reducing This Risk in the Future,” E&W Strategies, September 4, 2016.
38 Doug Parker, “White Paper Addressing Fraud in the Renewable Fuels Market and Regulatory Approaches to Reducing This Risk in the Future,” E&W Strategies, September 4, 2016.
39 Bradley Olson and Dan Murtaugh, “Ethanol Upending Refiners Pushes $13 Billion on U.S. Drivers,” Bloomberg, March 19, 2013. For an up-to-date display of RIN prices and trading, see Progressive Fuels Limited, “PFL Weekly RIN Recap,” www.progressivefuelslimited.com/web_data/PFL_RIN_Recap.pdf.
40 NERA Economic Consulting, “Economic Impacts Resulting from Implementation of the RFS2 Program,” July 27, 2015.
41 Randy Schnepf, “Agriculture-Based Biofuels: Overview and Emerging Issues,” Congressional Research Service, May 1, 2013, p. 14.
43 Environmental Protection Agency, “Final Renewable Fuel Standards for 2017, and the Biomass-Based Diesel Volume for 2018,” December 12, 2016.
44 American Petroleum Institute vs. Environmental Protection Agency, 906 F.2d 729 (2013) [D.C. Circuit Court].
45 Bradley Olson, “Ethanol Rules Fuel Big Gains for Oil Firms,” Wall Street Journal, October 28, 2016.
46 Carl Icahn, “If Oil Refiners Crash, So Will the Economy,” Wall Street Journal, November 22, 2016.