The 2007 Clean Air Act provisions giving rise to the current version of the RFS (also known as the ethanol mandate) included so-called anti-backsliding provisions requiring EPA to study whether the program would adversely impact air quality. That study was due by June of 2009. EPA was also required to promulgate rules necessary to mitigate any such adverse impacts, and these rules were supposed to have been finalized by December 2010. None of this has been done.
A number of studies have concluded that the production and use of ethanol and other biofuels can raise certain emissions, including work done by EPA itself, although other studies are inconclusive or claim air quality improvements. In addition to air pollution, studies have also raised doubts whether corn ethanol use is reducing greenhouse gas emissions, which was one of the original goals of the program.
Perhaps more significant than what EPA’s final study says is the fact that a major environmental group is pushing the agency to conduct it. In this regard, the Sierra Club now joins the National Wildlife Federation, which believes that the RFS has led to the conversion of pristine grasslands into cropland and has advocated for changes to the program.
For many years, the environmental activist community was relatively absent from the RFS reform debate—with the exception of smaller organizations like the Environmental Working Group, Friends of the Earth, and the Clean Air Task Force. But with both the Sierra Club and National Wildlife Federation now actively involved, that may be changing.