2022 Report on Ethanol Market Concentration 

I. Introduction 

This Report presents the Federal Trade Commission’s (“Commission” or “FTC”) 

concentration analysis of the ethanol production industry for 2022.1 The report includes certain 

data and information from the U.S. Energy Information Administration (“EIA”), industry 

participants, and other sources.2 Section 1501(a)(2) of the Energy Policy Act of 2005 requires 

that the FTC annually “perform a market concentration analysis of the ethanol production 

industry . . . to determine whether there is sufficient competition among industry participants to 

avoid price-setting and other anticompetitive behavior.”3 Pursuant to the statute, the FTC must 

measure concentration using the Herfindahl-Hirschman Index (“HHI”) and consider all 

marketing arrangements among industry participants in preparing its analysis.4 Also pursuant to 

the statute, the FTC delivers its report to Congress and the Administrator of the Environmental 

Protection Agency (“EPA”) by December 1 of each year. 

The HHI is a measure of market concentration. A given market’s HHI is the sum of the 

squares of the individual market shares of all market participants.5 As in previous reports, FTC 

staff (“staff”) analyzed concentration based on U.S. ethanol production capacity and actual 

production of ethanol. Staff’s analysis does not address whether ethanol production in any 

geographic area constitutes a relevant antitrust market; instead, it calculates concentration on a 

1 This Report builds upon Commission reports from previous years. Prior reports contain background information 

not included in this Report. See FTC, Oil and Gas Industry Initiatives: Reports, https://www.ftc.gov/tipsadvice/competition-guidance/industry-guidance/oil-and-gas. 

2 Certain data and information relied upon in this Report may be revised or updated between annual reports. 3 Energy Policy Act of 2005, Pub. L. No. 109-58, § 1501, 119 Stat. 1067, 1074, amended by Energy Independence 

and Security Act of 2007, Pub. L. No. 110-140, 121 Stat. 1492. For purposes of this Report, we presume that 

Congress used the term “price-setting” to mean “illegal price fixing.” 

4 Id. 

5 For example, a four-firm market with market shares of 30 percent, 30 percent, 20 percent, and 20 percent has an 

HHI of 2600 [(30*30) + (30*30) + (20*20) + (20*20) = 2600]. HHIs range from 10,000 in a one-firm (pure 

monopoly) market to a number close to zero in a highly unconcentrated market. 

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nationwide basis, based on ethanol production capacity and actual ethanol production. For both 

measures, HHIs are calculated for producers and marketers. For both production capacity and 

actual production, concentration for producer shares is lower than concentration for marketer 

shares. Based on production capacity, the HHIs are 545 for producer-based shares and 869 for 

marketer-based shares. Based on actual production, the HHIs are 516 for producer-based shares 

and 922 for marketer-based shares. HHIs attributed to producers decreased from last year, while 

HHIs attributed to marketers increased. 

The low level of concentration and large number of market participants in the U.S. 

ethanol production industry continue to suggest that the exercise of market power to set prices, or 

coordinate on price or output levels, is unlikely on a nationwide basis. As has been the case each 

year since the Commission began reporting, the current HHIs indicate that the industry is 

unconcentrated nationwide.6 At this level of concentration, a single ethanol producer or 

marketer likely lacks market power at a national level. Successful anticompetitive coordination 

at a national level would require agreement among a very large number of competitors and thus 

is similarly unlikely. Moreover, imports and the possibility of entry would likely impede the 

exercise of market power by any group of domestic firms. 

II. Industry Updates 

A. Renewable Fuel Standard 

Since 2005, Congress has required that the national transportation fuel supply contain 

a minimum annual volume of renewable fuels, including fuel ethanol.7 This mandate, known 

6 The Commission and the U.S. Department of Justice characterize markets in which the HHI is below 1500 as 

unconcentrated. U.S. Department of Justice and Federal Trade Commission Horizontal Merger Guidelines § 5.3 

(2010), https://www.ftc.gov/sites/default/files/attachments/merger-review/100819hmg.pdf (“Horizontal Merger 

Guidelines”). 

7 See Energy Policy Act of 2005 § 1501, supra note 3. 

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as the Renewable Fuel Standard (“RFS”), increases every year. In 2007, Congress revised the 

RFS, significantly increasing the minimum volumes of ethanol and adding requirements for 

advanced biofuels.8 The annual use of renewable fuels did not keep pace with the statutory 

RFS requirements, however.9 This situation has prompted the EPA for several years to use its 

rulemaking authority to decrease the annual requirements below the statutory volumes.10 For 

2022, the RFS mandates 36.0 billion gallons of renewable fuel, 15.0 billion gallons of which 

can be conventional corn ethanol.11 The 2022 advanced biofuels target is 21.0 billion gallons, 

at least 16.0 billion gallons of which must be cellulosic biofuel.12 For 2022, the EPA reduced 

the requirement for total renewable fuel to 20.63 billion gallons, of which 15.0 billion gallons 

can be conventional corn ethanol.13 The EPA reduced the requirement for advanced biofuels 

to 5.63 billion gallons, at least 0.63 billion gallons of which must be cellulosic biofuel.14 

B. Supply and Demand 

Most market participants that staff interviewed characterize the ethanol industry as 

having excess capacity. Most market participants interviewed stated that demand for ethanol 

8 “Advanced biofuel” refers to a renewable fuel, other than ethanol derived from corn starch, that has lifecycle 

greenhouse gas emissions that are at least 50 percent less than the average greenhouse gas emissions of the baseline 

fossil fuel. 42 U.S.C. § 7545(o)(1)(B)(i). Advanced biofuels include, but are not limited to, cellulosic biofuel and 

biomass-based diesel. Id. § 7545(o)(1)(B)(ii)(I)-(VII). 

9 See 2013 Ethanol Report, supra note 1, at 4; 2014 Ethanol Report, supra note 1, at 3; 2015 Ethanol Report, supra 

note 1, at 3. 

10 See 2016 Ethanol Report, supra note 1, at 3 (discussing revised volume requirements), and subsequent reports. 

The Clean Air Act provides EPA authority to adjust cellulosic, advanced, and total volumes set by Congress as part 

of the annual rulemaking process. See EPA, Overview for Renewable Fuel Standard (last updated Feb. 22, 2022), 

https://www.epa.gov/renewable-fuel-standard-program/overview-renewable-fuel-standard. 

11 42 U.S.C. § 7545(o)(2)(B)(i)(I). 

12 Id. § 7545(o)(2)(B)(i)(II)-(III). 

13 EPA, Final Volume Standards for 2020, 2021, and 2022 (last updated Aug. 31, 2022), 

https://www.epa.gov/renewable-fuel-standard-program/final-volume-standards-2020-2021-and-2022/. The EPA’s 

volume requirements, like the statutory RFS mandate, set a target for total renewable fuels and include a nested 

requirement for advanced biofuels. Thus, each gallon of fuel that meets the advanced biofuels requirement also 

counts toward the total renewable fuels requirements. Once obligated parties meet the minimum requirement for 

advanced biofuels, they may meet any remaining obligation under the total renewable fuels requirement with 

conventional corn ethanol. 

14 Id. 

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has substantially recovered to a more normal level, along with demand for gasoline, after 

previously declining due to the COVID pandemic. 

Most market participants interviewed stated that the EPA’s waivers allowing E15 

gasoline (having a 15 percent ethanol blend) to be sold during the summer of 2022 had little 

impact on demand for ethanol.15 

C. Prices and Margins 

Ethanol prices were volatile this year. Prices briefly spiked in November 2021, 

declined dramatically, and then rose somewhat and declined slowly the rest of the year. 

Margins spiked in November along with prices, then declined to negative levels, and 

remained at low or negative levels the rest of the year. Figure 1 shows daily net cost of 

corn,

16 ethanol prices, and margins from the beginning of 2014 to October 14, 2022, 

expressed on a per-gallon basis.17 Margins are measured by a return over operating costs 

estimated for a hypothetical dry mill in Iowa, as reported by the Iowa State University Center 

for Agricultural and Rural Development.18 

15 See EPA, Fuel Waivers, https://www.epa.gov/enforcement/fuel-waivers (2022 Fuel Waivers, Nationwide) (last 

updated Aug. 27, 2022). 

16 Net cost of corn is the daily nearby futures price in Chicago plus Iowa corn basis. Weekly corn basis is calculated 

as the price that Iowa ethanol plants pay, as reported by the U.S. Department of Agriculture’s Livestock and Grain 

Market News, minus the Chicago Board of Trade nearby futures price. See infra note 18. 

17 October 14, 2022 is the last date for which data from Iowa State University were reviewed for purposes of this 

Report. 

18 See Iowa State University, Center for Agricultural and Rural Development, Historical Ethanol Operating Margins, 

http://www.card.iastate.edu/research/biorenewables/tools/hist_eth_gm.aspx (last visited Oct. 25, 2022). “Return 

over operating costs” is specifically defined as the difference between the revenue from ethanol (including revenue 

from ethanol and dried distillers grains with solubles) and variable production costs (including corn, natural gas, and 

labor). As of November 2016, revenue includes sales of corn oil, a byproduct of ethanol, which could make margins 

not comparable before that date. 

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Figure 1: Ethanol Price, Corn Cost, and Margin 

Jan. 2014 to Oct. 2022 

-0.5 

0 

0.5 

1 

1.5 

2 

2.5 

3 

3.5 

Jan 2014 Jan 2015 Jan 2016 Jan 2017 Jan 2018 Jan 2019 Jan 2020 Jan 2021 Jan 2022 

4 

Ethanol Price ($/gallon) 

Return Over Operating Costs ($/gallon) 

Net Cost of Corn ($/gallon) 

Data from Iowa State University, Center for Agricultural and Rural 

Development, Historical Ethanol Operating Margins 

The average estimated margin from the beginning of 2021 through mid-October 2022 

was $0.25 per gallon, which is unchanged from the same period last year and higher than the 

margin in 2020.19 

D. Market Trends 

Domestic ethanol production capacity increased slightly, and actual production 

increased since last year’s Report. Production capacity (including capacity under construction) 

was 18.1 billion gallons per year.20 Actual production from July 2021 through June 2022 

19 Id. Margins as reported in previous Ethanol Reports. See supra note 1. 

20 Production capacity increased slightly from 17.77 billion gallons per year in 2021 to 18.127 billion gallons per 

year in 2022. Staff’s total capacity estimate takes into account information obtained through interviews with market 

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increased to 15.5 billion gallons per year from 14.5 billion gallons per year during the prior 12 

months.21 

Ethanol exports increased. From July 2021 through June 2022, the United States 

exported approximately 1.40 billion gallons of ethanol.22 This marked an increase from 1.27 

billion gallons of ethanol during the previous July-to-June period, after three consecutive annual 

declines during a July-to-June period.23 

Over 100 firms produced ethanol in 2022. The largest ethanol producer’s share of 

domestic capacity is approximately 17 percent, the same as last year.

24 

Most market participants interviewed cited ongoing transportation challenges due to 

either a shortage of drivers in trucking or railroad staffing issues. 

III. Analysis 

Section 1501(a)(2) of the Energy Policy Act of 2005 instructs the Commission to use 

HHIs to measure concentration in the U.S. ethanol production industry.25 HHIs can provide a 

snapshot of market concentration based upon the number of market participants and their 

participants and publicly available information, including information published online by the Renewable Fuels 

Association (“RFA”) as of September 8, 2022, regarding Ethanol Biorefinery Locations. RFA, Ethanol Biorefinery 

Locations, https://ethanolrfa.org/resources/ethanol-biorefinery-locations. Staff’s capacity total is greater than the 

EIA annual published estimate of 17.38 billion gallons. EIA, U.S. Fuel Ethanol Plant Production Capacity (release 

date: Aug. 8, 2022), http://www.eia.gov/petroleum/ethanolcapacity/. EIA’s Fuel Ethanol Production Capacity 

estimate is intended to measure estimated gallons of fuel alcohol that a plant is capable of producing over a period of 

one year (365 consecutive days) starting on the first day of each report month. Id. 

21 EIA, Monthly Energy Review, Table 10.3 Fuel Ethanol Overview (release date: Oct 26, 2022), 

https://www.eia.gov/totalenergy/data/browser/?tbl=T10.03#/?f=M&start=201903&end=202106&charted=7-18. 

22 Calculations based on July 2021-June 2022 monthly exports reported in EIA, U.S. Exports of Fuel Ethanol (Sept. 

30, 2022 release date), http://www.eia.gov/dnav/pet/hist/LeafHandler.ashx?n=PET&s=M_EPOOXE_EEX_NUSZ00_MBBL&f=M (calculating a monthly sum of barrels converted to U.S. gallons (1 barrel = 42 U.S. gallons)). 

23 Id. 

24 See 2021 Ethanol Report, supra note 1, at 8 (largest producer’s share 17 percent). 

25 Energy Policy Act of 2005 § 1501(a)(2), supra note 3. 

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respective sales, production, or capacity.26 An analysis of competition among market 

participants using these HHIs assumes that the U.S. ethanol production industry is an appropriate 

(or “relevant”) antitrust market, a question that this Report does not address.27 Such an 

assumption precludes consideration of a broader product market that includes other gasoline 

blending components that might be viable substitutes for ethanol. In the event that ethanol 

competes with other blending components, HHIs based on fuel ethanol production and marketing 

would likely misstate concentration in the industry. This assumption also precludes 

consideration of whether broader or narrower geographic markets than the United States could 

provide further insight about competition in ethanol production and marketing. 

This Report presents four HHIs for the ethanol industry, based on two different measures 

of market share (production capacity and actual production) and two different methods of 

attributing those market shares to various market participants (producers and marketers). In 

regard to measuring market share, for purposes of this Report “production capacity” is defined to 

mean a plant’s maximum annual output of ethanol minus any required downtime for 

maintenance.

28 “Actual production” is defined to mean a plant’s actual annual output of 

26 The Commission and the U.S. Department of Justice regularly use HHIs to measure concentration in a relevant 

antitrust market as part of their analysis of the likely effects of a merger or acquisition on competition in that market. 

See Horizontal Merger Guidelines, supra note 6, § 5.3. 

27 A relevant antitrust market has both product and geographic aspects. A relevant product market is a product or 

group of products such that a hypothetical profit-maximizing firm that was the only seller of those products likely 

could profitably impose at least a small but significant and nontransitory increase in price (“SSNIP”). If such a price 

increase would not be profitable because of the loss of sales to other products, the product or group of products 

would not be a relevant product market. Similarly, a relevant geographic market is a region such that a hypothetical 

profit-maximizing firm that was the only seller of the relevant product in that region likely could impose at least a 

SSNIP above the competitive level. If such a price increase would not be profitable because of the loss of sales to 

sellers outside the region, the region would be too narrow to be a relevant geographic market. See id. §§ 4.1-4.2. 

28 Production capacity is also sometimes referred to as “operating capacity.” For purposes of this Report, production 

capacity is distinct from “nameplate capacity,” a common industry term that may refer to the intended full-load 

sustained output of a facility. Nameplate capacity may also be variously known as “rated capacity,” “nominal 

capacity,” “installed capacity,” or “stated design capacity.” 

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ethanol.29 In regard to attributing market shares to market participants, “producer” is defined to 

mean a firm that in fact manufactures the ethanol. As discussed below, “marketer” is defined to 

mean the firm, whether the producer itself or a third-party firm, that sells and transports a 

producer’s ethanol output. 

FTC staff calculated market shares based on domestic ethanol production capacity for 

producers and marketers. FTC staff relied on publicly available information and interviews with 

producers and marketers to determine the production capacity of each ethanol plant and 

marketing activities of marketers. FTC staff then calculated capacity-based HHIs for producers 

and marketers. 

EIA staff calculated market shares based on actual production for producers and 

marketers. Due to the confidential nature of the ethanol production data the EIA collects, FTC 

staff provided to EIA staff the information necessary to attribute market shares to market 

participants.

30 EIA staff then separately calculated production-based HHIs for producers and 

marketers.

31 

A. Concentration with Market Shares Based on Production Capacity 

FTC staff calculated market shares based on fuel ethanol production capacity.32 

Production capacity provides a useful and easily confirmable indicator of a producer’s 

29 Actual production is also sometimes referred to as “operating production.” 

30 For producers for which EIA maintains production data, FTC staff provided EIA with the identities of those 

producers’ marketers. EIA staff used this information, in conjunction with its own data on ethanol production, to 

calculate the HHIs that attribute market share to marketers. 

31 Because the production data are confidential, EIA staff did not disclose the volumes of ethanol attributable to any 

individual producer or the market shares based on those volumes. 

32 The RFA website provides frequently updated data on ethanol plant capacity and capacity expansion plans. 

Capacity information is also available on many individual producers’ websites, some of which also provide details 

of construction and expansion plans. Staff obtained the production capacity for some producers directly from firm 

officials. 

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competitive significance.33 In determining each producer’s aggregate capacity, staff included the 

capacity of existing plants, as well as the projected capacity of plants currently under 

construction and plants currently undergoing expansion.34 Incorporating capacity from such 

projects into current market share calculations is consistent with the approach set forth in the 

Horizontal Merger Guidelines.35 

1. Attributing Market Shares to Producers 

Under the first approach to market concentration, FTC staff attributed market share to 

each producer based on the producer’s percentage of total production capacity. This method of 

calculation yielded an HHI of 545, a level regarded as unconcentrated under the Horizontal 

Merger Guidelines.36 This HHI is lower than the corresponding HHI of 561 in 2021.37 

2. Attributing Market Shares to Marketers 

Under the second approach, FTC staff attributed the market share of each producer to the 

firm that markets for that producer. Some producers sell the ethanol they produce directly to 

33 See Horizontal Merger Guidelines, supra note 6, § 5.2. In markets for homogeneous products (such as ethanol), a 

firm may derive its competitive significance primarily from its available capacity – i.e., its ability and incentive to 

increase production in the event of a competitor’s price increase or output reduction. Id. 

34 Staff included the capacity of these construction and expansion projects only where the producer had finalized 

construction plans, received the necessary financing for construction, and begun physical construction. Ethanol 

producers frequently announce capacity additions, new plants, plant sales, and cancellations of plans to build new 

capacity. These HHI calculations represent staff’s best estimate of the industry’s concentration as of October 2022. 

This approach therefore excludes any more recent publicly available information that might be relevant to industry 

HHI calculations. These HHI calculations also might not capture the full complexity of industry ownership 

structures, especially the degree of control by minority interests held by marketers or third-party management 

service firms. However, the HHI resulting from attributing production to the marketer should capture any such 

complexity not reflected in the producer HHI. 

35 See Horizontal Merger Guidelines, supra note 6, § 5.1. Firms that are not currently producing but likely would 

respond rapidly in the event of a SSNIP have competitive significance even though they do not currently supply the 

relevant market. Id. 

36 See id. § 5.3. 

37 See 2021 Ethanol Report, supra note 1, at 11. The industry continued to experience shifts in plant capacity 

through plant expansions, conversions, openings, and closures over the past 12 months. Because the HHI captures 

these adjustments in the aggregate, it ignores the individual activity of industry participants. For example, the HHI 

may include a producer’s acquisition of another producer’s facilities that coincided with the restart or reconstruction 

of an idled facility. Alternatively, the HHI may exclude a plant that was converted to other uses, formally closed, or 

judged unlikely to reopen in the near future. 

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blenders and end users. Many producers, however, enter into marketing agreements with third 

parties to sell their output. An ethanol marketer may represent and make limited decisions for 

multiple individual producers, essentially aggregating those producers’ capacities under a single 

entity. For purposes of competitive analysis, attributing production capacity to marketers rather 

than to the actual producers provides a measure of industry concentration that captures this 

aggregation. For a producer that engages in direct sales, staff attributed the market shares to the 

producer itself.38 For a producer that does not engage in direct sales, staff attributed the market 

shares to the third-party firm that marketed the producer’s ethanol output. This approach yields 

an HHI of 869, unconcentrated under the Horizontal Merger Guidelines. This HHI is higher than 

the corresponding HHI of 809 in 2021.39 

B. Concentration with Market Shares Based on Actual Production 

EIA staff calculated market shares based on actual production. Firms that produce 

ethanol must report their monthly production volumes to EIA. Using production data is 

instructive because capacity data have certain limitations, particularly insofar as stated capacity 

does not necessarily represent actual production capabilities. Ethanol plants can sometimes 

produce more than their stated design capacity (i.e., nameplate capacity) and sometimes operate 

at increasing rates as their owners and operators improve the production process and gain 

expertise in operating their plants.40 Thus, actual production may reflect a market participant’s 

competitive significance more accurately than would the sum of its plants’ stated design 

capacities. 

38 Some marketers publicly announce new agreements with producers. Where staff could not determine whether a 

producer marketed for itself or used an outside marketing firm, staff attributed market share to the producer. 

39 See 2021 Ethanol Report, supra note 1, at 12. 

40 Similarly, some ethanol producers may not be in a position to utilize their full plant capacity. Actual production 

may be a better indicator of their competitive significance in such cases. 

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There are some limitations on the accuracy of HHIs based on actual production, just as 

there are limitations on capacity-based HHIs. HHIs based on production over a given period 

may overstate or understate actual concentration due to entry and exit of firms, expansion of 

existing capacity, and variations in capacity utilization rates during the relevant period. 

Specifically, the production-based HHIs provided below do not fully reflect the impact of new 

facilities that began production during the last 12 months, nor do they fully reflect the impact of 

plant closures and idling during the period. In both cases, these facilities produced only a 

fraction of what they otherwise could produce in a full year, leading to an understatement (in the 

case of new facilities) or an overstatement (in the case of idled facilities) of their competitive 

significance in the market. Similarly, the HHIs below do not account for the effects on 

concentration of plant expansions that have been in effect for less than 12 months and capacityenhancing improvement projects that are not yet in operation. These production-based HHIs 

reflect actual production volumes from July 2021 through June 2022. 

1. Attributing Market Shares to Producers 

Where EIA attributed the actual production market share directly to individual producers, 

the resulting HHI is 516, lower than the 2021 HHI of 526.41 

2. Attributing Market Shares to Marketers 

Calculating production-based concentration by attributing the market share of each 

producer to the firm that markets for that producer results in an HHI of 922, higher than the 2021 

HHI of 847.42 

41 See 2021 Ethanol Report, supra note 1, at 13. 

42 Id. 

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C. Entry and Imports 

The U.S. ethanol industry at a national level remains unconcentrated today. This implies 

that any unilateral or coordinated attempt to exercise market power is unlikely. Should the 

industry become more concentrated, the possibility of new firms entering the domestic market 

and the responsiveness of ethanol imports to relative changes in domestic ethanol prices would 

likely provide additional constraints on anticompetitive behavior by domestic firms. Potential 

entrants can purchase and restart existing production facilities that were idled due to recent 

economic conditions or can design and build new plants to enter the market. 

Ethanol import levels historically have responded to fluctuations in the price of U.S. 

ethanol relative to foreign ethanol prices, particularly prices for sugarcane-based ethanol from 

Brazil.43 This responsiveness would likely constrain any potential exercise of market power by a 

domestic firm. Additionally, to the extent U.S. prices increase because of the exercise of market 

power among a subset of U.S. producers or marketers, it is likely that other producers would 

react by exporting less to take advantage of more favorable U.S. ethanol prices (thereby 

increasing U.S. supply). 

IV. Conclusion 

Regardless of the particular measure of market share or the market share attribution 

method used to calculate concentration, the ethanol industry remains unconcentrated at a national 

level. Furthermore, the possibility of entry and the availability of ethanol imports likely provide 

43 Brazil has been the largest exporter of ethanol to the United States every year since 2011. See EIA, U.S. Imports 

by Country of Origin (release date: Oct. 31, 2022), 

https://www.eia.gov/dnav/pet/pet_move_impcus_a2_nus_epooxe_im0_mbbl_a.htm, and prior FTC reports on 

ethanol market concentration, supra note 1. Although the United States is a net exporter of ethanol, demand exists 

for imported ethanol with low greenhouse gas emissions, such as sugarcane-based ethanol. See EIA, U.S. ethanol 

exports fell for the first time in four years in 2019 (May 1, 2020), 

https://www.eia.gov/todayinenergy/detail.php?id=43575. 

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additional constraints on the exercise of market power by current industry participants. The low 

level of concentration and large number of market participants in the U.S. ethanol production 

industry continue to suggest that the exercise of market power to set prices, or coordination on 

price and output levels, is unlikely. 

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Figure 2: Domestic Fuel Ethanol Concentration 

Concentration Based on Production Capacity 2021 HHI44 2022 HHI 

Shares attributed to each producer 561 545 

Shares attributed to marketers for all marketing agreements 809 869 

Concentration Based on Actual Production 2021 HHI45 2022 HHI 

Shares attributed to each producer 526 516 

Shares attributed to marketers for all marketing agreements 847 922 

Note: Production capacity for 2022 includes the annual production capacity as of October 2022 

and the capacity additions under construction and expected completions within 12 to 18 months 

thereafter. Actual production data for 2022 are from the annual period of July 2021 through June 

2022. 

44 See 2021 Ethanol Report, supra note 1, at 15. 

45 Id. 

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Figure 3: Historical Fuel Ethanol Capacity and HHIs46 

0

100

200

300

400

500

600

0

2,000

4,000

6,000

8,000

10,000

12,000

14,000

16,000

18,000

20,000

200520062007200820092010201120122013201420152016201720182019202020212022

 Capacity (left axis)

 HHI Based on Production Capacity (Producer) (right axis) 

Million 

Gallons 

per Year 

HHI 

46 Figure 3 in this year’s report contains certain corrections in order to make HHI Based on Production Capacity 

(Producer) consistent with HHIs reported for this measure in previous years’ reports beginning in 2005. See supra 

note 1. 

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