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MEMORANDUM

Subject: Assessment of Statutory Factors for 2015-2017 biomass-based diesel (BBD)

Applicable Volumes pursuant to CAA section 211(o)(2)(B)(ii)(I)-(VI) 

From: U.S. EPA, Office of Transportation and Air Quality

To: EPA Air Docket EPA-HQ-OAR-2015-0111

EPA’s primary assessment of the statutory factors for years 2015 through 2016 is that 

because the proposed advanced biofuel volume requirements for 2015-2016 reflect the 

maximum volumes of all advanced biofuels (including BBD) that can reasonably be expected to 

be produced and consumed, and because the BBD requirement is nested within the advanced 

biofuel volume requirement, we expect that the advanced biofuel volume requirement will 

determine the level of BBD production and import; the same volume of BBD will be produced 

and imported regardless of the BBD applicable volumes that we require for 2015-2016. Since 

our decision on the BBD applicable volumes for 2015-2016 is not expected to impact the volume 

of BBD produced and imported during this time period, we do not expect our decision to result 

in a difference in any of the factors we are required to evaluate pursuant to CAA section 

211(o)(2)(B)(ii)(I)-(VI), with the exception, as described in the preamble, that in considering 

statutory factor 211(o)(2)(B)(ii)(III), we believe that our decision on the level of the nested BBD 

volume requirement can have an impact on the future development and marketing of non-BBD 

advanced biofuels and can also be seen as sending a supportive or non-supportive signal to 

potential investors in BBD. Similarly for 2017, even though we are proposing only the 2017 

BBD requirement at this time and not the 2017 advanced biofuel requirement, we believe this 

same primary assessment is appropriate since, as in previous years, the 2017 advanced biofuel 

requirement will be set to reflect the maximum volumes of all advanced biofuels (including 

BBD) that can reasonably be expected to be produced and consumed for 2017, and it is the 

advanced standard that can be expected to drive BBD production and use. 

As an additional supplementary assessment, we have considered the potential impacts of 

modifying the applicable volume of BBD from the proposed levels of 1.70 billion gallons in 

2015, 1.80 billion gallons in 2016, and 1.90 billion gallons in 2017, based on the assumption that 

in guaranteeing BBD volumes at any given level there could be greater use of BBD and a 

corresponding decrease in the use of other types of advanced biofuels for years 2015-2017.1 

 

1 Section 211(o)((2)(B)(i)(IV) of the Clean Air Act provides the statutory applicable BBD volumes for years 2009 –

2012. For years after 2012, section 211(o)(2)(B)(v) specifies that the applicable volume for BBD cannot be less 

than the requirement for 2012 which was 1.0 billion, and section 211(o)(2)(B) (ii) requires that EPA determine the 

annual BBD requirement taking into consideration a review of the implementation of the program and an analysis of 

various factors, in coordination with USDA and DOE. In setting this annual BBD volume, the statute does not 

establish any numeric criteria or other means of weighing the importance of the often competing factors, or how to 

balance the overarching RFS program goals. Based on these statutory requirements, EPA set the applicable volume 

for BBD at 1.28 billion gallons in 2013. As described in the preamble, a review of implementation of the BBD 

requirements to date and the expected annual rate of future commercial production of renewable fuels (in particular, 

BBD capacity, ability of the advanced biofuel and total renewable fuel standards to drive BBD production, the 
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However, setting a higher or lower BBD volume requirement than the levels proposed would 

only be expected to impact BBD volumes on the margin, protecting to varying degrees this 

advanced biofuel from being outcompeted by other advanced biofuels. At present, the other 

advanced biofuels that could be affected include the following: sugarcane ethanol; ethanol from 

grain sorghum, food waste, or cover crops; renewable diesel from food waste or cover crops;

renewable naphtha from food waste or cover crops; CNG/LNG from non-cellulosic sources; and 

cellulosic biofuel. However, as part of this proposed rulemaking, as discussed in section IV of 

the preamble, we have carefully evaluated the production/import potential for cellulosic biofuels, 

and will continue to update this analysis prior to setting final cellulosic biofuel volume 

requirements and corresponding percentage standards that reflects this detailed analysis. We 

think it is unlikely that our decision regarding a BBD applicable volume will have any impact on 

the production or import of cellulosic biofuels given our separate action in establishing a 

cellulosic biofuel standard that is nested within the advanced biofuel standard. Accordingly, the 

more likely affected biofuels are non-cellulosic advanced biofuels, and our assessment below 

discusses the possibility that our decision regarding the BBD applicable volumes for 2015-2017 

could impact the production and use of these non-cellulosic advanced biofuels. 

Our supplementary assessment is described below, together with a discussion of the 

statutory factors the EPA must consider as part of its decision-making with regard to setting the 

applicable volume of BBD. Overall, the supplemental assessment and statutory factors analysis 

specified in CAA section 211(o)(2)(B)(ii)(I)-(VI) for the years 2015-2017, does not appear, 

based on available information, to provide a good reason for setting a higher or lower nested 

standard for BBD than 1.70 billion gallons in 2015, 1.80 billion gallons in 2016, and 1.90 billion 

gallons in 2017. 

1. Impact on the Environment

a. Air Quality

Based on our emissions and air quality impact analyses from the 2010 RFS2 final rule, 

we can assess the likely impacts on non-GHG pollutants associated with setting the applicable 

volume of BBD at levels higher or lower than 1.70 billion gallons in 2015, 1.80 billion gallons in 

2016, and 1.90 billion gallons in 2017. 

The 2010 RFS2 analysis estimated the upstream and downstream emission impacts 

associated with various types of renewable fuels, including BBD, ethanol, renewable diesel and 

cellulosic diesel at full implementation of the RFS2 program in 2022. The BBD and advanced 

 

benefits of providing additional support to the BBD industry through a higher nested standard, and the potential 

impact of our decision on the future commercial production of non-BBD, non-cellulosic advanced biofuels) led us to 

consider proposing applicable BBD volumes of 1.70 billion gallons in 2015, 1.80 billion gallons in 2016, and 1.90 

billion gallons in 2017. In the analysis presented in this memorandum, we have considered whether any of the 

other factors listed in the statute should lead us to propose higher or lower BBD volume requirements. The volumes 

could be set as low as the statutory minimum 1.0 billion gallons or, for 2015-2016 as high as the proposed advanced 

volume requirement minus the proposed cellulosic biofuel requirement 
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biofuels volumes assumed in the RFS2 analysis led to increases in some criteria pollutant and air 

toxics emissions and decreases in others.2 This indicates that some emissions increases or 

decreases might be associated with any change in the volume of BBD and other advanced 

biofuels. Depending on which of the competing advanced biofuels is compared to BBD, the 

emissions impacts of devoting a larger or smaller portion of the advanced biofuel standard to 

BBD will vary (assuming the advanced standard stays constant). However, given that other 

advanced biofuels also result in air quality impacts, and that the volumes at issue are relatively 

small when considered in the context of transportation fuel use throughout the geographic area in 

which the RFS program applies (the continental United States and Hawaii), the overall impacts 

of marginal shifts between BBD and other advanced biofuels is expected to be small, and this 

factor does not appear to provide a good reason for setting a higher or lower nested BBD volume 

requirement. 

b. Climate Change

Pathways for advanced biofuels approved by EPA, including BBD produced from virgin 

vegetable oils such as soy, meet the definitional requirement that advanced biofuels provide at 

least a 50% improvement in GHG performance compared to 2005 baseline petroleum fuels. We 

believe the trend to increasing the use of waste fats, oils, and greases as feedstock for the 

production of BBD is likely driven by the lower cost of these feedstocks compared to virgin 

vegetable oils such as soy oil. Since BBD produced from waste fats, oils, and greases receives 

the same RFS compliance credit as BBD produced form virgin vegetable oils, the growth in use 

of waste fats, oils, and greases is indicative of their cost advantage as a feedstock. The cheaper 

waste fats, oils, and greases will tend to be used preferentially toward meeting the BBD and 

advanced biofuel standards prior to the use of virgin vegetable oils such as soy oil. Similarly, the 

volume of non-food grade corn oil extracted from distillers grains and solubles produced during 

corn ethanol production has continued to grow as a source for BBD feedstock, again reflecting 

its lower cost compared to virgin vegetable oils like soy oil.

The available supplies of waste fats, oils, and greases feedstock and non-food grade corn 

oil feedstock are insufficient to produce even the statutory minimum volume for BBD of 1.0 

billion gallons. For any volume above the 1.0 billion gallon minimum, it is appropriate, 

therefore, to consider the impact of producing BBD from soy oil, the feedstock that will most 

likely be used at the margin to increase production over levels that can be attained using waste 

materials and non-food grade corn oil. Our analysis of soy-derived biodiesel as part of the 2010 

RFS rulemaking indicated that it provides a 57% reduction in lifecycle GHG emissions as 

compared to the 2005 petroleum baseline. Other non-cellulosic advanced biofuels which could 

compete with soy BBD within the advanced standard include: sugarcane ethanol (primarily from 

Brazil); ethanol from grain sorghum, non-cellulosic portions of food waste and cover crops;

renewable diesel from food waste or cover crops, naphtha from camelina oil, food waste or cover 

 

2 A complete discussion of the RFS2 air quality analysis and its limitations can be found in Chapter 3 of the RFS2 

Regulatory Impact Analysis (RIA). U.S. EPA 2010, Renewable Fuel Standard Program (RFS2) Regulatory Impact 

Analysis. EPA-420-R-10-006. February 2010. Docket EPA-HQ-OAR-2009-0472-11332. 
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crops; and CNG/LNG from non-cellulosic sources. These alternative advanced biofuels range in 

GHG reduction performance, with the waste-derived fuels providing the greatest reduction due 

to lack of any land use impact while biofuels made from crops having GHG reductions that are 

roughly comparable to soy biodiesel (e.g., sugarcane ethanol which has a 61% GHG reduction 

compared to gasoline; sorghum ethanol with estimated emission reductions of just over 50%;). 

Since for the years in question sugarcane and sorghum ethanol, and naphtha from camelina oil

are the most likely marginal replacements for soy biodiesel, as suggested by feedstock 

availability and fuel production capacity, we believe based on these lifecycle GHG reduction

calculations that if we set a marginally lower or higher BBD nested volume requirement and 

assumed this made a difference in how much BBD is ultimately used, that there would be no 

significant GHG impact. Therefore, this factor does not appear to provide a good reason for 

setting a higher or lower nested BBD volume requirement. 

We note, however, that certain advanced biofuels (e.g. ethanol from food waste or 

CNG/LNG from non-cellulosic feedstock) have significantly superior lifecycle GHG 

performance than soy biodiesel. Setting the nested BBD volume requirement sufficiently below 

the advanced biofuel requirement, as reflected in the proposed volumes, should provide a 

continuing incentive for the further development and marketing of such fuels, and may result in 

potentially increased GHG reductions through RFS implementation over the long term. 

c. Wetlands, Ecosystems, and Wildlife Habitats

As in the rulemaking establishing the BBD volume requirement for 2013, EPA has 

completed a largely qualitative assessment of impacts on wetlands, ecosystems, and wildlife 

habitats, consistent with available information.

The comparison of impacts on wetlands, ecosystems, and wildlife habitats will depend on 

which alternative advanced biofuel would be displaced by BBD from virgin oils such as soy oil. 

As noted above, soy oil is the most likely feedstock for biodiesel production after the lessexpensive waste fats, oils, greases, and non-food grade corn oil, and thus is the likely feedstock 

for producing marginal increases in BBD. Other non-cellulosic advanced biofuels which could 

compete with BBD within the advanced standard include: sugarcane ethanol (primarily from 

Brazil); ethanol from grain sorghum, non-cellulosic portions of food waste and cover crops;

renewable diesel from food waste or cover crops, naphtha from camelina oil, food waste or cover 

crops; and CNG/LNG from non-cellulosic sources. The advanced biofuels that are most likely to 

be impacted by the level at which the BBD applicable volume is established include grain 

sorghum ethanol and sugarcane ethanol, and naphtha from camelina oil. Such biofuels, like soy 

biodiesel, are made from planted crops and therefore are likely to have impacts on wetlands, 

ecosystems and wildlife habitats which are roughly comparable to, yet still may differ from, 

those of soy-based BBD. Depending on which of these alternative advanced fuels might replace 

soy-based BBD, the impacts of devoting a larger or smaller portion of the advanced biofuel 

standard to BBD will vary somewhat but, particularly given the relatively small volumes at issue, 

we do not believe that this factor provides a good reason for setting a higher or lower nested 

volume requirement for BBD. 
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We note, however, that certain advanced biofuels (e.g. ethanol from food waste, 

CNG/LNG from non-cellulosic feedstock, etc.) are not made directly from crops, and would 

therefore likely have significantly lower impacts on wetlands, ecosystems, and wildlife habitats 

than soy biodiesel. Setting the nested BBD volume requirement sufficiently below the 

advanced biofuel requirement, as reflected in the proposed volumes, should provide a continuing 

incentive for the further development and marketing of such fuels; to the extent such fuels 

become increasingly significant players in the advanced biofuel market, there could be longterm reductions in impacts on wetlands, ecosystems, and wildlife habitats as compared to a 

scenario where the BBD volume requirement is set at a level that did not incentivize production 

of such fuels. 

d. Water Quality and Water Supply

As is the case when considering the impacts on wetlands, ecosystems, and wildlife 

habitats, the impact on water quality and water supply will depend on which alternative 

advanced biofuel is displaced by soy-based BBD. The advanced biofuels that are most likely to 

be impacted by the level at which the BBD applicable volume is established for the years in 

question include grain sorghum ethanol, sugarcane ethanol and naptha from camelina oil. Such 

biofuels, like soy biodiesel, are made from planted crops and therefore are likely to have impacts 

on water quality and water supply that are comparable to, yet still may differ from, those of soybased BBD. Depending on which of these alternative advanced fuels might replace soy-based 

BBD, the impacts of devoting a larger or smaller portion of the advanced biofuel standard to 

BBD will vary somewhat but, particularly given the relatively small volumes at issue, we do not 

believe that this factor provides a good reason for setting a higher or lower nested volume 

requirement for BBD. 

Some advanced biofuels s (e.g., CNG/LNG or ethanol made from food waste) 

will have little or no impact on water quality and water supply. While production of such fuels 

is likely to be limited in the short term, setting the nested BBD volume requirement significantly 

below the advanced biofuel requirement, as reflected in the proposed volumes, should provide a 

continuing incentive for the further development and marketing of such fuels; to the extent such 

fuels become increasingly significant players in the advanced biofuel market, there could be 

long- term reductions in impacts on water quality and water supply as compared to a scenario 

where the BBD volume requirement is set at a level that did not incentivize production of such 

fuels. 

2. Impact on Energy Security

The wider use of any advanced biofuels, including BBD and sugar cane or sorghum 

ethanol, diversify the U.S. liquid fuel mix and provide energy security benefits. This is true for 

both domestically produced and imported biofuels. Advanced biofuels, whether produced 

domestically or imported, will contribute, on the basis of energy displaced, to enhanced energy 

security. Based on these considerations, the supplemental analysis does not appear to suggest a
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distinct energy security advantage associated with selecting any particular BBD applicable 

volume for 2015, 2016 and 2017.

3. The Expected Annual Rate of Future Commercial Production of Renewable Fuels, including 

Advanced Biofuels in each Category 

The preamble, section II.C, provides an overview and discussion of the expected annual 

rate of future commercial production and import of total renewable fuels for 2015 and 2016, 

including advanced biofuels and BBD. 

In order to meet the advanced biofuel standards being proposed for 2015 through 2017, 

we anticipate at least 1.70 billion gallons in 2015, 1.80 billion gallons in 2016, and 1.90 billion 

gallons in 2017 of BBD will be produced, distributed, and consumed. The industry already has 

sufficient production capacity to meet the full 1.90 billion gallons being proposed for 2017 and 

there does not appear to be any limitations in supplying this volume to the market. We believe 

that an increase in the BBD volume to 1.70 billion gallons in 2015, 1.80 billion gallons in 2016, 

and 1.90 billion gallons in 2017 would strike the appropriate balance between providing a market 

environment where other types of advanced biofuels are incentivized and providing support and 

a degree of certainty for the BBD industry and the RFS program that are associated with

increasing the BBD volume requirement to proposed levels. This approach does not limit 

additional BBD production.

4. Impact of Renewable Fuels on Infrastructure

a. Deliverability of Materials, Goods, and Products Other than Renewable Fuels

We do not anticipate any significant impacts on deliverability of materials other than 

renewable fuels that might result from devoting a larger or smaller portion of the advanced 

biofuel standard to BBD for years 2015-2017. The EPA evaluated in the RFS2 final rule the 

impacts on the U.S. Transportation network from the distribution of the total additional volume 

of biofuels that would be used to meet the RFS standards. Oakridge National Laboratory 

(ORNL) conducted an analysis of biofuel transportation activity from production plants to 

petroleum terminals by rail, barge, and tank truck to identify potential distribution constraints to 

help support the assessment in the RFS2 final rule.3 The ORNL analysis concluded that the 

increase in biofuel shipments due to the RFS2 standards would have a minimal impact on U.S. 

transportation infrastructure. The majority of biofuel transportation is projected to be 

accomplished by rail. It was estimated that biofuels transport would constitute only 0.4% of the 

total freight tonnage for all commodities transported by the rail system through 2022.4 Given the 

 

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“Analysis of Fuel Ethanol Transportation Activity and Potential Distribution Constraints”, Oakridge National 

Laboratory, March 9, 2009. To simplify the ORNL analysis, BBD volumes were assumed to originate at the same 

points of production and to be shipped to the same petroleum terminals as the ethanol projected to be used to meet 

the RFS standards.

4 See sections 1.6.4 and 1.6.5 of the RFS2 RIA.
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small contribution of biofuel transport as a whole to total US freight tonnage, we do not believe 

that any particular BBD mandate would have a significant impact on the deliverability of 

materials other than renewable fuels. In addition, to the extent there was an impact, it would 

likely be comparable to impacts associated with the use of other advanced biofuels that it might 

displace. As a result, we do not believe that this factor provides a basis for selecting any 

particular BBD applicable volume for 2015, 2016 and 2017 

b. Sufficiency of Infrastructure to Deliver and Use Renewable Fuels

The rapid growth of biodiesel use has been driven by the RFS program and tax subsidies. 

The blending and distribution infrastructure has demonstrated the ability to respond to these 

incentives. For the 2015-2017 time period we anticipate that this will still be the case. The 

market has room to absorb more BBD. The proposed 2017 BBD level would represent about 3% 

of the diesel fuel supply. Most engines/vehicles in-use have been warranted by the manufacturer

for the 5% level, and most manufacturers now have at least some product offerings warranted for 

up to 20% biodiesel. Cold temperature concerns may limit blend concentrations in northern 

cities during winter conditions, but this cold weather limit can be offset with greater use during 

the summer months. Furthermore, a portion is likely to be renewable diesel, for which there is 

no blending limit or winter use concerns. Finally, the National Biodiesel Board (NBB) has 

extensive efforts underway working with the vehicle and engine manufacturers to continue to 

expand product offerings capable of operating on B20, working with their membership to 

improve fuel quality, and working with dealers and technicians to clear away obstacles standing 

in the way of expanding biodiesel acceptance in the marketplace. These should continue to bear 

fruit. 

In sum, we do not expect sufficiency of infrastructure to deliver and use renewable fuels 

to be a constraint for the proposed, or for marginally higher or lower nested BBD applicable 

volume requirements, and we do not believe this factor provides a good reason for selecting 

higher or lower BBD applicable volumes for 2015, 2016 and 2017. 

5. Impact of the Use of Renewable Fuels on the Cost to Consumers of Transportation Fuel and 

on the Cost to Transport Goods

In, the preamble, we provide illustrative cost estimates for hypothetical examples in 

which either soybean oil biodiesel or sugarcane ethanol fills the entire change in the proposed 

advanced biofuel mandates from 2014 through 2016. We estimate the difference in the price per 

energy-equivalent gallon of soybean oil biodiesel or sugarcane ethanol on the one hand, and the

petroleum-based fuel they would replace on the other. We then multiply this difference by the 

year-on-year change in the proposed advanced biofuel volume requirement. More detail on this 

analysis can be found in the Memo to the Docket titled “Illustrative Costs Impact of the Proposed 

Annual RFS2 Standards, 2014-2017.” This memo, for example, estimates the cost of using 

soybean oil biodiesel to replace petroleum diesel ranges from $218 million to $229 million in 

2015 and from $483 million to $679 million in 2016, while the cost for sugarcane ethanol to 

replace gasoline to satisfy the proposed year to year changes in the advanced biofuel volume 
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mandate ranges from $228 million to $615 million for 2015, and $424 to $1,303 million for 

2016. These cost estimates however, are based on current market conditions, and it is likely that 

market conditions will vary over time. The market will determine which advanced biofuels are 

used to meet the portion of the advanced standard based that is not dedicated to BBD. To the 

extent that cost considerations favor BBD, the cost benefit can be accomplished either through 

setting a higher BBD nested standard, or allowing the market to choose BBD over competing 

products in meeting the advanced and total RFS standards. Thus, this factor does not appear to 

clearly favor setting either a higher or lower BBD nested standard than the levels proposed. 

Setting a higher BBD volume requirement would only be expected, under the 

assumptions associated with this supplementary assessment, to impact biodiesel volumes on the 

margin, protecting them from being outcompeted by other advanced biofuels. Thus, the extra 

BBD volume requirement would merely replace other advanced renewable fuels that could be 

used to meet the advanced biofuel standard. As noted in the preamble, leaving room within the 

advanced standard for non-BBD advanced biofuels can incentivize the development and 

production of non-BBD advanced biofuels which may eventually provide a cost benefit as 

compared to BBD. In addition, this approach may temper to some extent BBD prices, by 

providing competition between the marginal BBD production volumes and other types of 

advanced biofuels. Therefore we believe that this factor supports maintaining the BBD volume 

requirement at a level sufficiently lower than the advanced biofuel volume requirement to 

incentivize production of non-BBD advanced biofuels, consistent with today’s proposal. 

6 Impact of Renewable Fuels on Other Factors 

a. Job Creation and Rural Economic Development

Executive Order 13563 directs federal agencies to consider regulatory impacts on job 

creation and employment. According to the Executive Order, “our regulatory system must 

protect public health, welfare, safety, and our environment while promoting economic growth, 

innovation, competitiveness, and job creation. It must be based on the best available science” 

(Executive Order 13563, 2011). Regulatory employment impacts are difficult to disentangle 

from other economic changes affecting employment decisions, over time and across regions and 

industries. Labor market responses to regulation are complex. They depend on labor demand 

and supply elasticities and possible labor market imperfections (e.g., wage stickiness, long-term 

unemployment, etc.). The unit of measurement (e.g., number of jobs, types of job hours worked, 

and earnings), may affect observability of that response. Net employment impacts are composed 

of a mix of potential declines and gains in different areas of the economy (e.g., the directly 

regulated sector, upstream and downstream sectors, etc.) over time. 

If the U.S. economy is at full employment, even a large-scale environmental regulation is 

unlikely to have a noticeable impact on aggregate net employment. Instead, labor would 

primarily be reallocated from one productive use to another and net national employment effects 
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from environmental regulation would be small and transitory (e.g., as workers move from one 

job to another). If the economy is operating at less than full employment, economic theory does 

not clearly indicate the direction or magnitude of the net impact of environmental regulation on 

employment; it could cause either a short-run net increase or short-run net decrease 

(Schmalansee and Stavins, 2011).

To the extent that the guaranteed volumes cause more BBD to be used to fulfill the 

advanced biofuel volume, there will be more employment and wage income earned producing 

BBD, but less employment and wage income in the production of other advanced biofuels that 

could be used to satisfy the advanced biofuel mandate. Given the small changes in job and wage 

income across the advanced biofuel sector that would likely result from changes in BBD volume, 

we do not believe that this factor provides a compelling reason for setting a higher or lower 

nested standard for BBD.

b. Price and Supply of Agricultural Commodities

In Sec II.F. of the preamble, we provide illustrative cost estimates for a hypothetical 

scenario in which soybean oil BBD fills the entire year-to-year increase in the proposed 

advanced biofuel standard. As part of this scenario analysis, we estimate price impacts on 

soybean oil from the higher demand for soybean oil BBD. We similarly analyzed a cost impact 

assuming Brazillian sugarcane ethanol satisfied the entire increase in the advanced standard. 

More detail on this analysis can be found in the Memo to the Docket.

To the extent that the guaranteed volumes cause more BBD to be used to fulfill the 

advanced biofuel volume, there may be small increases in the price of soybeans and soybean oil, 

but this should then result in offsetting price and supply impacts on feedstocks used to make 

other advanced biofuels such as grain sorghum and sugarcane. As a result, we do not believe 

that this factor provides a good reason for either raising or lowering the nested standard for BBD.

c. Food Prices 

As mentioned previously, in Sec II.F. of the preamble we estimate wholesale price 

impacts on soybean oil for a hypothetical example in which the entire change in the year-to year 

proposed advanced biofuel volume mandates is met with soybean oil BBD. More detail on this 

analysis can be found in the Memo to the Docket titled “Illustrative Costs Impact of the Proposed 

Annual RFS2 Standards, 2014-2017”.

To the extent that the guaranteed volumes associated with a BBD standard cause more 

BBD to be used to fulfill the advanced biofuel volume, there may be small increases in the price 

of soybeans, but this should then lead to offsetting price and supply impacts on crop feedstocks 
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used to make other advanced biofuels such as grain sorghum and sugarcane. Given the offsetting 

impacts and given that feedstock price is only one component in determining food prices, we 

would not expect any significant impact on food prices to result from setting the BBD nested 

volume requirement; therefore we do not believe that this factor provides a good reason for 

either raising or lowering the nested standard for BBD.