The U.S. Environmental Protection Agency (EPA) has misinterpreted and overreached in drafting its “Biofuels and the Environment: First Triennial Report to Congress,” the Renewable Fuels Association (RFA) stated in comments submitted to EPA.

“EPA took the ‘Murphy’s Law’ approach to this draft report—they assumed if it can go wrong, it will go wrong,” said RFA President and CEO Bob Dinneen.

“RFA is greatly concerned that EPA has misinterpreted and expanded the scope of the triennial report as established by the Energy Independence and Security Act (EISA). Specifically, EISA compels EPA to assess only those environmental impacts that are likely to result from the requirements of the Renewable Fuels Standard (RFS). Unfortunately, EPA’s draft report seems to raise every conceivable environmental problem that could possibly arise from biofuels expansion, without any regard for the actual likelihood that the problem will occur,” the RFA wrote.

Additionally, “EPA neglects the EISA requirement to assess environmental impacts of the RFS ‘to date,’ choosing instead to focus on highly speculative potential future impacts” while making “no attempt whatsoever to compare the potential environmental impacts of biofuels to the impacts of the fossil fuels that are being displaced.”

Specifically, the RFA takes issue with the report’s failure to assess environmental impacts of the baseline petroleum fuel, its unbalanced reliance on oft-refuted literature, its lack of acknowledgement of best practices and technology adoption in both farming and biofuel production, and the enormous amount of uncertainty surrounding its assessments.

“RFA believes the draft report’s general approach and content should be substantively reconsidered. Further, we believe significant revisions are needed before the report can reasonably be finalized and submitted to Congress for consideration,” according to the comments.

The RFA has requested a meeting with EPA staff responsible for drafting the report to address concerns about the scope and accuracy of the current draft before it is submitted to Congress.

The full 14 pages of RFA’s comments can be read here.