WASHINGTON, D.C.—Growth Energy, the nation’s largest biofuel trade association, celebrated House passage of a permanent, legislative fix offering consumers year-round access to lower-cost E15. Approved by a vote of 218 to 203, the bipartisan bill now moves to the Senate, where Majority Leader John Thune has been tapped by President Trump to advance E15 legislation.

“American families are asking for help, and today’s vote brings us one step closer to delivering real savings at the pump,” said Growth Energy CEO Emily Skor. “We’re deeply grateful to bipartisan lawmakers from across the nation who always stood strong and rebuffed pressure to protect refinery profits at the expense of American consumers. All eyes are now on the Senate, where we have been working closely with our champions to clear a path forward for year-round E15. The sooner this bill reaches the President’s desk, the sooner we can deliver more savings to more communities in every corner of the country.

“We urge Senate leaders to quickly reject critics who oppose competition at the pump from lower-cost fuel. Year-round E15 simply allows retailers the option to offer a another, less expensive fuel choice to drivers. Now is the time to act.”

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Growth Energy CEO Emily Skor submitted the following letter to the editor in response to a recent WSJ editorial about ethanol and E15.

In a flagrantly misleading May 11 opinion piece, “An Ethanol Extortion Play,” the Wall Street Journal editorial board again makes it clear that it cares more about protecting margins for a few oil refineries than allowing competition at the pump that can protect drivers from volatile global oil prices.

Specifically, the editorial attacks bipartisan efforts in Congress to allow year-round sales of E15. Never mind the fact that E15 reduces emissions that cause smog, or that the U.S. blew past the so-called “blend wall” years ago. Never mind that the vast majority of existing fuel infrastructure can be used for E15 the same way it is for E10, or that E15 is approved for 96% of vehicles on the road today. And never mind that the vast majority of the fuel supply chain—including most refiners and fuel retailers—support the bill to lower gas prices.

Ultimately, the most important point here is one the editorial board completely ignores—E15 sells for less and saves consumers money. If Congress finally approves year-round E15, it doesn’t mandate anything. It allows retailers the choice to offer consumers a lower-cost fuel option.

The Wall Street Journal can play games to confuse people, but it can’t argue with the signs in front of any fuel station offering E15 at a steep discount to E10. Congress should remember that when it votes on year-round E15 this week.

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WASHINGTON, D.C.—Growth Energy, the nation’s largest biofuel trade association, announced today that the total number of retail locations selling E15—a more affordable fuel blend made with 15% American ethanol—now totals more than 5,000 stores, marking a new milestone in E15 availability.

“More and more fuel retailers across the U.S. are offering E15 because they know it’s a more affordable fuel option that their customers can rely on,” said Growth Energy CEO Emily Skor. “With 5,000 stores now selling E15 across the U.S., more drivers than ever are able to take advantage of E15’s lower prices. We congratulate every fuel retailer that’s made this milestone possible, and look forward to watching the total E15 store count continue to climb as retailers invest in ways to deliver better, more affordable fuel options.”

Since 2020 the number of stores selling E15 in the U.S. increased at an annualized rate of 15%. Between 2024 and 2025, the number of E15 stores jumped from 3,808 to 4,736, a total of more than 900 new stores representing an increase of 24% in that period. This increased rate of adoption was achieved despite the fact that, today, E15 can only be sold all year long if the U.S. Environmental Protection Agency (EPA) issues a waiver for retailers to do so. This is an outdated regulatory requirement that’s still on the books from a 35-year-old law that was enacted before E15 was first introduced as a fuel option.

“We’ve seen robust growth in E15 availability even with these outdated waiver-to-waiver regulations,” Skor added. “At the current rate of E15’s expanding retail footprint, we expect to see more than 1,200 additional retail locations begin to sell E15 in 2026. If Congress can deliver a permanent fix for year-round E15, however, that number would be exponentially higher. This is why it’s so important for Congress to take action and vote in favor of year-round E15 now—more consumers deserve access to E15’s cost savings, and that’s exactly what this greater regulatory certainty would provide.”

Congress is set to vote on a bill that would allow for the year-round sale of E15 on May 13. Supporters of E15 should visit growthenergy.org/E15Now and tell their elected officials to support the measure and finally make E15 available all year long.

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WASHINGTON, D.C.—Growth Energy, the nation’s largest biofuel trade association, today released new data showing that fuel retailers sold nearly 2.5 billion gallons of E15 in 2025, underscoring the growing demand for a lower-cost fuel option that could save drivers more than $150 million this summer alone.  

E15, sometimes seen as UNL 88 at the pump, is a fuel blend made with 15% American ethanol that can be used in 96% of all cars on the road today. The fuel blend can save consumers up to 30 cents per gallon. 

“Fuel prices are at their highest level in four years, and families need relief. E15 offers an immediate, affordable solution, and that’s why it’s so important for Congress to act now on legislation that will make E15 accessible year-round,” said Growth Energy CEO Emily Skor. 

Earlier this year, the U.S. Environmental Protection Agency issued an emergency waiver allowing for summer sales of E15. The temporary waiver ensures that retailers, refiners, and biofuel producers have the certainty they need to keep E15 on the market for the time being, but it falls short of the permanent fix retailers need to bring lower-cost E15 to more fueling locations.  

“Retailers sold nearly 2.5 billion gallons of E15 last year because consumers are actively looking for lower-cost fuel options,” Skor added. “But without policy certainty, retailers can’t deliver those savings to new markets and more consumers.” The U.S. House of Representatives is expected to vote next week on legislation that would finally allow year-round E15 sales nationwide, eliminating the need for temporary waivers and unlocking expanded access to lower-cost fuel options for consumers.  

The figures are based on data from over 2,500 retail stations across the U.S. that sell E15. Growth Energy encourages American drivers to reach out to their elected officials today and tell them to support year-round E15. Visit growthenergy.org/E15Now to learn more. 

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TOPEKA, KAN.—Growth Energy, the nation’s largest biofuel trade association, commended the Kansas legislature and Kansas Governor Laura Kelly for enacting an incentive for fuel retailers in the state to sell E15, a fuel choice made with 15% American-made ethanol that costs less and can be used in 96% of all cars on the road today. 

“Kansas is the latest addition to a growing list of states taking action to save their constituents money by increasing E15 availability,” said Growth Energy CEO Emily Skor. “Drivers, farmers, and fuel retailers will all benefit from this incentive. We applaud Gov. Kelly, and the Kansas lawmakers and state biofuels and corn organizations who championed this legislation and worked together to see it signed into law. While this is welcome news for Kansans, we hope that Congress is paying attention and delivers the same savings to all Americans by passing a nationwide, year-round fix for E15 as soon as possible. Consumers can’t wait any longer.” 

Learn more about the Kansas E15 tax incentive here. To learn more about E15, click here. 

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WASHINGTON, D.C.—Growth Energy welcomed news that a bipartisan group of lawmakers had introduced an amendment to the Farm, Food, and National Security Act of 2026 (also known as the Farm Bill) this week that would finally allow for the year-round sale of E15.

“This landmark, bipartisan solution for year-round E15 would unlock new options at the pump, saving consumers up to 30 cents per gallon and expanding markets for America’s farmers,” said Growth Energy CEO Emily Skor. “With the summer driving season approaching fast, this amendment represents a critical opportunity to unleash investment in rural communities and shield U.S. consumers from volatility with lower-cost, American-made fuel. We urge the House to support this amendment and send it to the President, who has promised to sign year-round E15 into law without delay.”

Now that the deadline for amendments to the Farm Bill has passed, the House Rules Committee is set to consider the legislation next week. Growth Energy will continue to monitor the bill and urged its supporters to contact your legislators and urge them to support the bill.

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(Pictured above: POET Bioprocessing – Obion, photo courtesy of POET).

WASHINGTON, D.C.—Growth Energy, the nation’s largest biofuel trade association, welcomed three new producer plant members this week: POET Bioprocessing – Obion, Hereford Ethanol Partners LP, and PureField Ingredients LLC. Growth Energy’s total plant membership now sits at 98, and the organization continues to represent more than half of all U.S. bioethanol production capacity. 

“Growth Energy’s membership is defined by its commitment to innovation, and to our shared belief that American biofuels are a solution to some of our nation’s most-pressing challenges. Our three newest plant producer members—POET – Obion, Hereford Ethanol, and PureField—perfectly embody these values,” said Growth Energy CEO Emily Skor. “Each of them produces millions of gallons of ethanol every year—ethanol that saves consumers money, generates income for American farmers, and delivers more high-value coproducts like animal feed and biogenic CO2. We are thrilled to welcome them to Growth Energy and look forward to connecting them with our unmatched network of biofuel producers, supporters, and solutions providers.”

POET, the world’s largest producer of biofuels, has added its newest facility—POET Bioprocessing – Obion (pictured above)—to the Growth Energy membership roster. The company acquired the Tennessee-based Obion facility in 2025, increasing POET’s total production capacity by 120 million gallons and improving its access to southeastern markets. The plant provides high-performance fuel as well as premium, high-quality livestock feed solutions for regional, national, and international markets.

“POET has been with Growth Energy from the beginning,” said Joshua Shields, POET Senior Vice President of Corporate Affairs. “No other organization can match this team’s political savvy, innovative spirit, and deep commitment to American farmers and biofuel producers. Together, we will continue to usher in a new era of growth for U.S. agriculture and homegrown energy.”

Hereford Ethanol Partners LP is a family-owned facility based in Hereford, Texas. It has a current annual capacity of 100 million gallons—a number that will grow with new improvements underway in 2026. It also supplies wet distillers grain to Friona Industries—Hereford’s sister company and the second-largest cattle feeder in North America.

“We’re excited to work alongside our new partners at Growth Energy to advocate for farmers and producers across the nation,” said Don Gales, Chairman and Chief Executive Officer of Friona Industries. “The team at Growth Energy has a proven track record of unlocking new opportunities for America’s biofuel sector, and Hereford Ethanol Partners is proud to be a part of those conversations.” 

Finally, PureField Ingredients LLC operates a 52 million-gallon integrated food and biofuels facility in Russell, Kansas, converting locally grown wheat into high-value food ingredients while utilizing residual starch to produce ethanol. The company recently began operating its carbon capture and sequestration (CCS) system—one of the first Class VI wells permitted in the United States. The CCS capability makes PureField one of the lowest carbon fuel producers in the world, and reinforces long-term demand for approximately 20 million bushels of Kansas wheat and sorghum. 

“PureField sits at the intersection of food and fuel—maximizing the value of every bushel while strengthening domestic food and energy production,” said Aaron Buettner, CEO of PureField. “The addition of carbon capture provides a foundation for future growth of both food ingredient and biofuel production. We are excited to partner with Growth Energy to ensure policies continue to support U.S. producers and farmers and enable the next phase of growth in advanced biofuels.”

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WASHINGTON, D.C.—Growth Energy, the nation’s largest biofuel trade association, submitted comments to the U.S. Treasury and Internal Revenue Service (IRS) outlining recommendations for the implementation of the Section 45Z clean fuel production tax credit, as enhanced and extended by the One Big Beautiful Bill (OBBB).

“Treasury has done an outstanding job of collecting feedback from all relevant stakeholders, and we applaud their commitment to implementing 45Z in a way that ultimately maximizes the credit’s economic benefits,” said Growth Energy CEO Emily Skor. “With the right guidance, including flexible guidelines for farmers seeking to adopt innovative practices, 45Z can accelerate U.S. energy leadership and unlock billions of dollars in new investments across rural America. We look forward to Treasury’s final ruling that will give farmers and biofuel producers the certainty they need to expand access to more affordable fuel options.”

Among other recommendations, Growth Energy urged regulators to include on-farm practices in the credit calculation, follow the law to exclude indirect land use change (iLUC) from the credit calculation, and quickly finalize their final 45Z rule. These actions would provide near-term certainty for farmers, clarify how the 45Z-CF GREET model will be used to determine credit eligibility, and open pathways for a wider variety of crop-based feedstocks. Growth Energy also called on Treasury to eliminate administrative complications that could stall investment.

“Our members are critical to the supply of biofuel in the United States and have substantial interests in the sound implementation of the 45Z credit,” wrote Growth Energy. “Our industry is eager to advance the administration’s energy goals by providing low-cost, innovative, and American-made fuel as we remain committed to helping our country diversify its energy portfolio and provide consumers with better and more affordable choices at the fuel pump.”

Read the full comments on the 45Z rule here.

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WASHINGTON, D.C.—Growth Energy, the nation’s largest biofuel trade association, applauded President Donald Trump, Environmental Protection Agency Administrator Lee Zeldin, and U.S. Department of Agriculture (USDA) Secretary Brooke Rollins for helping to deliver the largest renewable volume obligations (RVOs) in the nation’s history. Growth Energy also welcomed news that EPA would account for a number of small refinery exemptions (SREs) by reallocating 70% of those volumes.

“With this rulemaking, EPA and the administration are reinforcing their unwavering support for American-made biofuels and sending a strong signal about the continued role biofuels like ethanol will play in delivering American energy dominance and greater prosperity to the heartland,” said Growth Energy CEO Emily Skor. “We commend President Trump, EPA Administrator Zeldin, and USDA Secretary Rollins for working together to finalize this historic, growth-oriented proposal, which opens the market for more than 15 billion gallons of conventional biofuel in 2026 and 2027.

“USDA also deserves our industry’s thanks for its advocacy on behalf of American farmers—the agency worked tirelessly to ensure that the final RVOs reflected the President’s agenda for unleashing American energy and restoring prosperity to rural America. With so many farm families struggling to make ends meet, we must take every opportunity to build reliable, domestic markets for American agriculture.

“Furthermore, we applaud EPA for making the decision to reallocate 70% of all gallons lost to 2023-2025 SREs. This provides clarity and predictability across the liquid fuel supply chain, while guaranteeing that the new markets promised to American farmers and biofuel producers as part of the RVOs are not destroyed by costly exemptions.

“We are grateful to President Trump and his administration for its steadfast support for homegrown biofuels, and for setting a new high watermark for American ethanol. We look forward to continuing our work with EPA and Congressional champions as we continue to find ways to strengthen domestic energy security and open new market opportunities for U.S. farmers and rural communities.”

BACKGROUND

Under the RFS, EPA sets the number of gallons of renewable fuels (such as biofuels) that must be blended into the nation’s total fuel supply each year. Those renewable volume obligations (RVOs) apply to fuel producers (petroleum refiners) and importers, otherwise known as “obligated parties.”  Each obligated party is required to blend a certain percentage of renewable fuels into the transportation fuel they produce or import to meet the nationwide RVO. The law also allows EPA to grant exemptions from RFS blending requirements to certain refiners (SREs) in rare circumstances when a refiner demonstrates “disproportionate economic hardship” in its efforts to comply with the RFS.

On June 13, 2025, EPA proposed RVOs for 2026-2027, proposing that refiners must blend at least 15 billion gallons of conventional biofuels (i.e., ethanol) into the nation’s fuel blend for each plan year. The RVO proposal—also called the Set 2—also included requirements to blend more than one billion gallons of cellulosic biofuel, more than seven billion gallons of biomass-based diesel, and more than nine billion gallons of advanced biofuel for each plan year. Altogether, EPA’s proposal would require the blending of more than 24 billion gallons of renewable fuel each year, making it the largest RVO proposal in the program’s history.

On August 22, 2025, EPA released its decisions on 175 pending SRE petitions, covering compliance years 2016-2024. In all, EPA granted a total of 140 petitions: 63 full exemptions and 77 partial (50%) exemptions.

At the time, EPA also announced that it would release a supplemental proposal to its proposed Set 2 RVO to reallocate exempt SRE gallons from 2023-2025 compliance years to the 2026 and 2027 compliance years covered by Set 2. Although it had not yet issued decisions on 2025 SRE petitions, EPA estimated upwards of 2.1 billion 2023-2025 RINs were potentially subject to reallocation. Under this approach, refiners would be required to make up for lost gallons from those years, ensuring that SREs don’t compromise renewable fuel demand.

EPA released the supplemental proposal on SRE reallocation on September 16, 2025. It indicated that the agency is considering accounting for “volumes representing complete (100 percent) reallocation and 50 percent reallocation for SREs granted in full or in part for 2023 and 2024, as well as those projected to be granted for 2025, as part of the ongoing RFS rulemaking.” Growth Energy provided substantive comment in response to EPA’s proposal.

In November 2025, EPA also issued decisions on 16 SRE petitions for the 2021 through 2024 RVO compliance years. EPA granted 2 full exemptions and 14 partial (50%) exemptions and denied 2 petitions. The November 2025 exemptions totaled 740 million RINs, 510 million of which were for the 2023 and 2024 RVO compliance years.

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WASHINGTON, D.C.—Growth Energy, the nation’s largest biofuel trade association, applauded the Trump administration’s decision to grant emergency waivers allowing uninterrupted, nationwide sales of lower-cost E15, a fuel blend made with 15% ethanol that can be used in 96% of cars on the road today. The decision to issue an E15 summer waiver will ensure that consumers will maintain access to a fuel that saves drivers up to 30 cents per gallon.

“We applaud President Trump, EPA Administrator Zeldin, and our Midwestern governors for their support, and for taking swift action to ensure that retailers, refiners, and biofuel producers have the certainty they need to protect consumer access to savings at the pump,” said Growth Energy CEO Emily Skor. “With the conflict in the Middle East and its impact on the global oil marketplace, it’s more important than ever to shield U.S. consumers from volatility with lower-cost, American-made fuel.”

“Now, to bring E15 to new markets and more consumers, it’s vital that Congress act quickly on President Trump’s call for nationwide legislation allowing uninterrupted sales of lower-cost E15. It’s a common-sense solution that doesn’t cost taxpayers a dime. Not only will permanent legislation unlock greater fuel savings across the U.S.—it will deliver an immediate, badly-needed boost to the rural economy.”

For more information about the E15 summer waiver and emergency waivers, read Growth Energy’s FAQ here.

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WASHINGTON, D.C.—Growth Energy, the nation’s largest biofuel trade association, issued the following statement after it was announced that a legislative fix for year-round E15 was dropped from the January government funding bill, and that Congress will instead form a “rural energy council” to formulate another compromise bill with petroleum interests, and with expectations for a vote in February.

“Congress picked foreign refiners over American farmers and drivers today. What a travesty,” said Growth Energy CEO Emily Skor. “E15 delivers cost savings for consumers and generates long-term demand for American agriculture. These have been the facts during the twelve-year-long debate over the simple act of allowing consumers the choice to buy a better value fuel year-round. Failure to act will now lead to farmers missing out on a critical market during the worst farm crisis in 40 years. Consumers will also miss out on access to more affordable fuel choices. Instead of supporting farmers and affordability, Congress appears to have prioritized the demands of a few well-capitalized foreign refiners that plead poverty with lawmakers while boasting financial success with investors.

“This council must deliver a solution for year-round E15. It’s imperative that leaders in Congress focus their energies on getting this over the finish line in an expedited timeline.

“We especially want to thank our congressional champions who have fought to make this issue a top priority for Congress. While the creation of a council to work on E15 legislation falls short of the immediate action we need, Growth Energy intends to fully participate in this process and ensure our champions in Congress have the support they need to deliver a victory for rural America.

“If lawmakers want to show they can still deliver practical solutions—solutions that lower costs, strengthen domestic energy production, and meet Americans where they are—passing year-round E15 is the place to start.” 

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In a letter sent today to congressional leadership, a coalition of more than 70 biofuel groups and agricultural organizations called for the immediate passage of legislation to allow year-round nationwide sales of the American-made E15 fuel blend, containing 15 percent ethanol. Year-round E15 would benefit drivers with savings of 10 to 30 cents per gallon and improve markets for America’s farmers.

“The U.S. Department of Agriculture projects a record 16.8-billion-bushel corn harvest in 2025—up roughly 13 percent from 2024,” the groups wrote. “While this demonstrates the strength and productivity of America’s farmers, it also intensifies pressure on corn prices and farm incomes. Expanding E15 access is one of the most immediate and practical ways to address this imbalance. When fully scaled, year-round, nationwide E15 is poised to create new domestic demand for billions of bushels of corn and sorghum, help stabilize markets, support farmers, and deliver consumer savings at the pump.”

The letter was led by Growth Energy, the American Farm Bureau Federation, the National Corn Growers Association, and the Renewable Fuels Association.

In recent years, the organizations noted, E15 availability during the summer driving season has depended on temporary emergency waivers. While these annual actions provide short-term relief, they are not a sustainable or reliable solution. Year-to-year uncertainty discourages investment in fuel infrastructure, confuses consumers, and undermines confidence among retailers and refiners.

“With a record corn crop filling bins across America, farmers cannot afford another season of uncertainty and negative margins. Markets need consistency and predictability, which requires permanent legislative action by Congress. We respectfully urge you to act this year to pass year-round E15 legislation,” the groups wrote.

Read the full letter here.

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WASHINGTON, D.C.—Growth Energy, the nation’s largest biofuel trade association, expressed its support today for regulatory amendments proposed by the U.S. Fish and Wildlife Service (FWS) and the National Marine Fisheries Service (NMFS) that streamline the regulatory process, addressing unnecessary barriers that have the potential to undermine the benefits of the Renewable Fuel Standard (RFS), a clean energy program that drives economic and environmental benefits by promoting the use of American biofuels. 

FWS and NMFS proposed a rulemaking that clarifies how Section 7 consultations are conducted under the Endangered Species Act (ESA). This is relevant to the RFS because some organizations have argued that the U.S. Environmental Protection Agency (EPA) should conduct costly and time-consuming “formal” ESA consultations regarding the agency’s proposed RFS renewable volume obligations (RVOs)—despite findings by several agencies that such consultations are unnecessary.  

“A strong RFS drives economic growth while making fuel more affordable—these amendments clarify that agencies like EPA can help the RFS deliver those benefits without unnecessary regulatory hurdles,” said Growth Energy CEO Emily Skor. “We commend FWS and NMFS for proposing these changes and look forward to seeing them finalized. We’ll continue to work with Congress and the Administration to maximize the positive impact of the RFS on drivers, the economy and the environment.” 

Read Growth Energy’s comments to FWS and NMFS here. 

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WASHINGTON, D.C.—Growth Energy, the nation’s largest biofuel trade association, applauded the Treasury Department and the Internal Revenue Service (IRS) today after the agencies published a notice for taxpayers seeking to claim the 45Q tax credit for carbon sequestration.  

American ethanol producers, and Growth Energy’s members in particular, are leaders in the deployment of carbon capture, utilization, and sequestration (CCUS) technology. Today’s notice provides a safe harbor that allows taxpayers to verify carbon sequestration, making it easier for participating biofuel producers to claim the 45Q tax credit for 2025. 

“American ethanol producers have always been on the cutting edge of carbon capture technology,” said Growth Energy CEO Emily Skor. “This safe harbor affirms the investments our members have made in CCUS today and supports more investment in CCUS in the future. We applaud the IRS and Treasury for working quickly to provide certainty for the 2025 tax year and look forward to working with them to continue supporting innovation and investment in rural communities across the U.S.”  

Read the IRS announcement here. 

Background 

Earlier this year, the U.S. Environmental Protection Agency (EPA) announced that it would reconsider the Greenhouse Gas Reporting Program, a part of which companies would use to verify and report their geologic carbon sequestration for the 45Q tax credit. Concerned about the impact of this proposal on those that rely on the program for verification, Growth Energy filed comments with EPA in November urging the agency to “do no harm” until a solution can be put in place by the Department of Treasury. With today’s action, IRS has provided such a solution, giving taxpayers a safe harbor to verify carbon sequestration they can use to claim the credit in 2025.  

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WASHINGTON, D.C.—Growth Energy today congratulated Julie Callahan on her confirmation as the U.S. Trade Representative’s (USTR’s) chief agricultural negotiator.

“As the Trump Administration works to strengthen America’s hand in global trade and deliver new opportunities for U.S. agriculture, Julie Callahan’s leadership will be essential,” said Growth Energy CEO Emily Skor. “Her deep experience at USTR and strong command of the issues facing our farmers and biofuel producers make her an outstanding choice for this critical role.”

“We look forward to continue working with her to advance trade opportunities and expand export markets for biofuels, and to support continued growth and certainty for rural communities across the country.” 

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DENVER, COLO. and ATLANTA, GA.—Growth Energy, the nation’s largest biofuel trade association, filed briefs in the U.S. Courts of Appeals for the 10th and 11th Circuits yesterday urging the courts to reject attempts by refiners to circumvent recent U.S. Supreme Court precedent on venue by bringing challenges to the U.S. Environmental Protection Agency’s (EPA) August 2025 small refinery exemption (SRE) decision in those two circuits, rather than in the U.S. Court of Appeals for the D.C. Circuit.

In June, the U.S. Supreme Court issued an opinion in EPA v. Calumet, which addressed Clean Air Act venue, or, in other words, the proper court in which to bring certain Clean Air Act challenges. The Court held that SRE decisions EPA issued in April and June 2022 were based on determinations that have “nationwide scope or effect,” and therefore must be litigated in the D.C. Circuit, whose decisions on agency actions often cover the entire U.S.

Refiners have now brought new challenges, outside of the D.C. Circuit, to EPA’s August 2025 SRE decisions. The refiners argued that the determinations on which those decisions were based do not fit within the parameters for D.C. Circuit venue established under Calumet. In support of EPA’s own briefing opposing the refiners, Growth Energy argued that the refiners’ challenges rested on a “fundamental misunderstanding” of EPA’s decisions.

“The facts in this case are clear. EPA’s August 2025 SRE decisions were based on determinations of nationwide scope or effect and should be litigated in the D.C. circuit,” said Growth Energy CEO Emily Skor. “The courts should dismiss or transfer these challenges to the circuit where they belong, and avoid creating a patchwork of inconsistent case law that ultimately increases market uncertainty and undermines the strength of American farmers and biofuel producers.”

Read Growth Energy’s briefs in the 10th Circuit here and here. Read Growth Energy’s briefs in the 11th Circuit here and here. 

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Ethanol industry highlights ethanol deficit in Chinese purchases under Phase One Agreement as USTR reviews compliance.

WASHINGTON, D.C.—As the Office of the U.S. Trade Representative (USTR) heard testimony today on its Section 301 investigation into China’s implementation of the Phase One trade agreement, Growth Energy’s written comments highlighted significant shortfalls in Chinese purchases of U.S. ethanol and other agricultural commodities, and urged the administration to ensure Beijing is held to its commitments to American farmers and biofuel producers.

“The Trump Administration is right to closely scrutinize China’s failure to meet its agricultural purchase commitments,” said Growth Energy CEO Emily Skor. “America’s ethanol producers and corn growers stood ready to deliver on the market access promised under Phase One. When China committed to substantial agricultural purchases, our industry invested and prepared accordingly. We appreciate USTR’s leadership in examining these shortfalls and look forward to working with the administration to ensure American ethanol producers receive the fair treatment and market access they deserve.”

In comments submitted to USTR’s Section 301 investigation, Growth Energy detailed major gaps between China’s commitments and actual purchases:

Overall Agricultural Shortfalls:

• China’s agricultural purchases reached only 82 percent of committed levels in 2020 and 84 percent in 2021.

• Total agricultural gap: $12 billion below Phase One commitments.

• The additional $5 billion per year China agreed to “strive for” never materialized.

Ethanol-Specific Deficits:

• China was the third largest export market for U.S. ethanol in 2016

• U.S. ethanol exports to China fell 39 percent below the 2017 baseline in 2020, despite China committing to a 64 percent increase in overall agricultural purchases.

• Estimated cumulative ethanol purchase deficit: $88.6 million during the Phase One implementation period.

• Since 2021, ethanol exports to China have essentially disappeared.

Signed in January 2020, the Phase One agreement committed China to $32 billion in additional agricultural purchases over two years above 2017 levels. Although the agreement did not specify commodity-specific targets, ethanol was explicitly included as an eligible agricultural product.

Growth Energy represents 97 U.S. ethanol plants producing 9.5 billion gallons annually, along with 130 associated businesses. Its members are among the nation’s leading exporters, supporting nearly two billion gallons of ethanol exports to more than 60 countries worldwide.

Growth Energy’s complete comments to USTR are available here.

The post Growth Energy Urges Swift Action on China’s Unfulfilled Agricultural Purchases appeared first on Growth Energy.

We appreciate the opportunity to provide comments and recommendations in response
to the November 6 Biofuels Land Use Change Public Forum. Growth Energy is the world’s
largest association of bioethanol producers, representing 97 producer plants, more than
130 associate members up and down the supply chain, and tens of thousands of biofuels
supporters across the country. Together, we are working to bring better and more
affordable choices at the fuel pump to consumers, improve air quality, and protect the
environment for future generations.
As our comments during the rulemaking for the 2024 Amendments to the LCFS
repeatedly noted, the long-outdated LUC value for bioethanol codified in the previous
and current LCFS regulations warrants reconsideration.
A Large Body of Credible Scientific Evidence Supports a Lower LUC Value for
Corn Bioethanol.
Since the inception of the LCFS, CARB has over-penalized crop-based biofuels due to
the agency’s misconceptions of the nature of their impact on land use change. Initially,
in 2009, corn starch bioethanol was assigned a 30 gCO2e/MJ penalty1
, a number our
industry argued was unsupported by credible evidence and lacking an empirical basis.
In the rulemaking process that produced this hyper-conservative figure, scientists
emphasized that there was “much uncertainty in measuring indirect emissions related
to” biofuels, creating unresolved difficulties on “whether and how to calculate” indirect
1 Even this value illustrates how LUC estimates decrease as models are refined. In the 2009 rulemaking process,
CARB’s estimate decreased from 35 gCO2e/MJ to 32 gCO2e/MJ and finally to 30 gCO2e/MJ as new model inputs
were incorporated into the model. See Initial Statement of Reasons, Proposed Regulation to Implement the Low
Carbon Fuel Standard (March 5, 2009), at IV-31
https://ww2.arb.ca.gov/sites/default/files/barcu/regact/2009/lcfs09/lcfsisor1.pdf
land use change.2 CARB then acknowledged 30 gCO2e/MJ overstated estimated LUC
and revised the figure downward to 19.8 in 2016, which, almost a decade later, remains
the codified value.
Over the last decade, the models and underlying data sets used to estimate land use
change have been greatly refined, resulting in a clear downward trend. For example, a
2021 review of the scientific literature derived a central best LUC estimate of 3.9
gCO2e/MJ for corn bioethanol.3 The U.S. Department of Energy, in conjunction with
multiple federal agencies, recently updated the model for federal tax credit purposes
under Section 45Z; that 2025 model incorporates a LUC estimate of 5.75 gCO2e/MJ for
corn bioethanol while relying on the same basic suite of models as CARB’s 2015
figure.
4
And a November 2025 analysis published by Dr. Stefan Unnasch and
economist Brian Healy of Lifecycle Associates evaluated a range of recent models with
“updated data and refined treatment of co-products, livestock, and soil carbon,” and
concluded that such refinements result in LUC estimates of “roughly 5 gCO2e/MJ.”
In addition, recent testimony from Dr. Tristan Brown during the rulemaking process for
New Mexico’s Clean Transportation Fuel Standard provides a number of examples of
updated data sets using more recent science than what is currently used by the LCFS
for crop-based biofuels.5 Since 2014, the LCFS uses a combination of GTAP-BIO and
AEZ-EF modeling for land use change. Even in 2014, the data used in AEZ-EF was
based on 8-year-old international GHG inventory methods and default values. In written
testimony to New Mexico’s Environmental Improvement Board, Dr. Brown notes there
have been “steady improvements made to both the GTAP-BIO model and the overall CI
score calculation methodology.” Additionally, given GREET’s status as the “primary
means of calculating lifecycle GHG emissions”, Argonne National Laboratory created
the Carbon Calculator for Land Use Change from Biofuels Production (CCLUB). CCLUB
is intended to “replace[s] the obsolete AEZ-EF model” and utilize the latest land use
change research and observable data. Examples of these observations include a
leveling-off, and in some cases, a decline in the acres harvested for corn bioethanol, all
while yield increased. When using the most up-to-date research (GTAP-BIO + CCLUB),
Dr. Brown concludes that corn bioethanol’s LUC value is 6.1 gCO2e/MJ.
2 https://ww2.arb.ca.gov/sites/default/files/BARCU/barcu-attach-old/lcfs09.archive/251-2009_liska_perrin_bbb.pdf
3 Scully, et. al. Carbon intensity of corn ethanol in the United States: state of the science, 16 Environ. Res. Lett. 4
(2021).
4 45ZCF-GREET Model (January 2025), https://www.energy.gov/eere/greet
5 https://www.env.nm.gov/opf/wp-content/uploads/sites/13/2025/09/2025-09-02-EIB-25-23-Growth-Energys-NOIpj.pdf
Each of these four recent analyses are closely aligned around an estimated LUC range
of 3.9 – 6.1 gCO2e/MJ; far lower than the decade-plus old 19.8gCO2e/MJ currently
used in the LCFS.
Even these improved estimates likely overestimate LUC impacts. To elaborate, LUC
theory assumes that biofuels consumption in California can and will increase crop
commodity prices to a sufficient degree to drive farmers’ planting and land conversion
decisions across the globe. However, it is not possible in the real-world to isolate
impacts of California biofuels consumption from the multitude of other factors that may
more directly impact global crop commodities markets, including, for example, the
impact of agricultural, tariff, and land use policies implemented by other state and
foreign governments. This is particularly true in the context of corn bioethanol in
California, where CARB projects that bioethanol demand will decline as light-duty
electric vehicle penetration increases.6
Where bioethanol demand is declining, it simply
does not create any price signal that would drive increases in corn production.
Moreover, even if bioethanol demand were to remain steady or increase modestly,
analysis of existing trends demonstrates that over 600 million gallons of additional
bioethanol could be produced using the same corn acreage currently in production
today as a result of yield increases and other efficiency improvements.7
Indeed,
separate analyses by both Stillwater Associates and Ramboll have concluded (in the
context of the federal RFS program) that increased bioethanol demand in the U.S. has
very little to no impact on global corn prices.8
This is further affirmed by a growing body
of empirical evidence: for example, a 2022 International Energy Agency report
evaluated real-world data from 2005–2015 and found “no link” between increased U.S.
biofuel production and corn production or deforestation in Brazil.9
Instead, the report
casts doubt on any relationship between biofuel production and corn prices or livestock
production.
Despite the best available science converging around LUC estimates near 5 gCO2e/MJ
and the lack of empirical evidence to validate LUC theory, CARB concerningly relies on
6 CARB Standardized Regulatory Impact Assessment, 2024 LCFS Amendments (Dec. 19, 2023) at 18, Fig. 4.
7 Stillwater Associates, LLC, RFS Set II Proposal Analysis at 17, https://downloads.regulations.gov/EPA-HQ-OAR2024-0505-0646/attachment_3.pdf. See also
8
Id. at 9 (finding that “the actual effect on corn prices” from the most recent RFS program volume incentives “is
close to 0%.”); Ramboll and Net Gain Ecological Services, Review of Environmental Effects and Economic
Analysis of Corn Prices: EPA’s Proposed RFS Standards for 2023-2025 at 23-24, Figure 3-5, 3-6 (finding that “the
statistical dependency between corn prices and RFS volumes is either non-existent or very weak”).
9
IEA Bioenergy, Towards an improved assessment of indirect land-use change, Task 43 – Task 38 Report (October
2022).
repeatedly debunked studies from Searchinger et. al.10 and Lark et. al.11 for the Forum,
indicating an institutional unwillingness to consider more recent scientific evidence. In
contrast, we believe it is long past time for CARB to update the LUC values for cropbased biofuels in the LCFS consistent with the work of Dr. Brown, the U.S. DOE, and
other credible researchers.
Sustainability Requirements Render LUC Penalty Obsolete
In the most recent amendments to the LCFS, CARB implemented requirements for
crop-based biofuels purportedly to prove their sustainability, namely, to ensure that no
feedstocks for LCFS pathways came from land converted into cropland after 2008, and
verification processes to confirm sourcing.
12
In the most recently rulemaking, CARB’s Environmental Impact Analysis (EIA)
acknowledges potential direct and indirect land use change “is at least partially (and
potentially fully) accounted for by the LUC scores added to crop-derived pathways.”13
This acknowledgement renders the need for a sustainability certification moot and must
be accounted for in CARB’s current reconsideration of the LUC estimate appropriate to
apply to bioethanol.
This double penalty is particularly unbalanced where CARB denies bioethanol
producers the ability to utilize a wide range of on-farm practices to demonstrate GHG
reductions. It should be noted that many of those on-farm practices are recognized by
other California state agencies as tools to reduce the release of soil carbon.14
The
combination of an inflated LUC penalty untethered from the best available science with
10 See, e.g. Zilberman, D, Indirect land use change: much ado about (almost) nothing. GCB Bioenergy, 9(3), 485-
488. (2017) (“Searchinger et al. (2008) results may now be seen as fundamentally flawed not just because the ILUC
is uncertain and estimates vary considerably, but also because it fails to capture the basic features of agricultural
industries and land resources.”); see also https://growthenergy.org/wp-content/uploads/2022/02/Net-Gain-Rambollstudies.pdf
11See, e.g. Taheripour, et al., Comments on “Environmental Outcomes of the US Renewable Fuel Standard” (Mar.
21, 2022) (identifying “extreme” and “difficult to rationalize” inconsistencies in Lark et al. studies); Taheripour et
al., Response to comments from Lark et al. regarding Taheripour et al. March 2022 comments on Lark et al.
original PNAS paper (May 25, 2022) (reaffirming “major deficiencies, problematic assessments, and
misinterpretation” and determining that “the Lark et al. paper is more problematic than what we initially
evaluated”); Review of Recent PNAS Publication on GHG Impacts of Corn Ethanol, USDA (Dec. 14, 2022) (noting
“major methodological flaws” and observing that Lark’s findings “cannot be corroborated with USDA site level,
modeled, or national datasets.”).
12 https://ww2.arb.ca.gov/sites/default/files/2025-07/atta1_finalcomparison_070125.pdf
13 https://ww2.arb.ca.gov/sites/default/files/barcu/regact/2024/lcfs2024/recirculated_draft_eia.pdf
14 https://www.gov.ca.gov/2020/10/07/governor-newsom-launches-innovative-strategies-to-use-california-land-tofight-climate-change-conserve-biodiversity-and-boost-climate-resilience/
the failure to acknowledge scientifically-supported low-carbon agricultural practices
creates a significant distortion in bioethanol carbon intensity scores that unfairly harms
producers and California consumers.
Corn Acreage Unchanged Despite Increased Bioethanol Demand
Even as demand for bioethanol increased, the number of acres of corn planted and
harvested have remained largely unchanged. As we have referenced in multiple
previous comments during the most recent LCFS amendment rulemaking, the growth in
corn production in the United States has come from improvements in yield while the
number of acres used to produce corn are roughly the same number of acres used in
1900.
Since 1900, the top 25 years with the most increase in acreage relative to the nation’s
average of 77.745 million acres of corn production all occurred in or before 1933.15
15 https://afdc.energy.gov/files/u/data/data_source/10337/10337_corn_yield_acres.xlsx
Analysis of more recent trends again demonstrates that corn plantings have remained
stable while yield increased. The amount of land required to produce one billion gallons
of bioethanol has decreased from 3.1 million acres in 2007 to 1.9 million acres in
2024.16
Over this time, corn acres planted have remained constant, illustrating that both
the LUC penalty and the burdensome sustainability requirements are unnecessary for
corn starch bioethanol:
Conclusion and Recommendations
With the temporary approval of E15 via AB 30 and the subsequent rulemaking for
permanent approval, liquid fuels with higher bioethanol content have the potential to
significantly improve the carbon intensity of California’s transportation fuel mix. CARB
has a legal and policy imperative to expeditiously incorporate the best available science
16 Stillwater Associates, LLC, RFS Set II Proposal Analysis at 9, https://downloads.regulations.gov/EPA-HQ-OAR2024-0505-0646/attachment_3.pdf
on land use change estimates for bioethanol. As summarized above, the weight of the
credible scientific evidence requires a substantial downward shift in bioethanol’s LUC
value.
Growth Energy also encourages CARB to allow the use of climate-smart agricultural
practices, some of which include precision application of fertilizer, use of low CI fertilizer,
no or low-till farming practices, and the use of cover crops.17
We appreciate the opportunity to provide input on land use change. We urge CARB to
recognize the role biofuels have played and can continue to play in decarbonizing
California’s transportation fuel supply.
Sincerely,
Christopher P. Bliley
Senior Vice President of Regulatory Affairs
Growth Energy
17 https://growthenergy.org/policy-priority/climate-smart-agriculture/

December 4, 2025
Matt Botill
Division Chief
Industrial Strategies Division
1001 I Street
Sacramento, CA 95814
Via electronic submission
RE: Biofuels Land Use Change Public Forum
Mr. Botill:

The post Comments in Response to California Biofuels Land Use Change Public Forum appeared first on Growth Energy.

Dear Mr. President:
We write on behalf of organizations representing ethanol producers, oil refiners, fuel
marketers, travel plazas, truck stops, and convenience store retailers to express the need
for long-term policy certainty across the transportation fuel sector. Our diverse group of
industries often have unique policy priorities and market concerns, but we have always
shared a common goal to provide affordable, reliable liquid fuels for consumers. However,
our collective ability to continue to do so is being threatened by the ongoing uncertainty
regarding the sale of year-round E15 and the administration of Small Refinery Exemptions
(SREs) under the Renewable Fuel Standard (RFS) program.
E15 continues to play an expanding role in the fuel marketplace, but unpredictable shortterm waivers, seasonal and geographic restrictions, and regionally unique summer
gasoline specifications in the Midwest have created a shifting regulatory environment that
complicates planning and investment. Legislation allowing the year-round, nationwide
sale of E15 would improve fungibility and substantially reduce many of the complexities
that arise for our industries as we operate in a national marketplace.
In addition, we believe Congress must take legislative action to reform the Small Refinery
Exemption program. The current SRE structure has encouraged a system of winners and
losers that distorts the marketplace, creates instability, and ultimately, hurts consumers.
A more consistent and narrowly applied SRE structure would create a far more predictable
regulatory environment.
The absence of nationwide E15 and the administration of the SRE program present varying
challenges for our industries. They both impact investment and compliance planning,
blending decisions, and the stability of national fuel supply chains. Addressing these two
issues through clear legislation would provide a more coherent and durable policy
foundation, reduce volatility, and enhance confidence for all participants in the
transportation fuel sector.
For these reasons, we respectfully urge you to support legislation that brings lasting
certainty to these fuels issues and supports a stable, efficient marketplace.
Thank you for your consideration of these matters. Our organizations remain committed to
supporting constructive solutions as Congress evaluates next steps.
Sincerely,
American Petroleum Institute
Growth Energy
National Association of Convenience
Stores
NATSO, Representing America’s Travel
Centers and Truck Stops
Renewable Fuels Association
SIGMA: America’s Leading Fuel Marketers
CC:
The Honorable Mike Johnson
Speaker, U.S. House of Representatives
The Honorable Hakeem Jeffries
Minority Leader, U.S. House of
Representatives
The Honorable John Thune
Majority Leader, U.S. Senate
The Honorable Chuck Schumer
Minority Leader, U.S. Senate
The Honorable Doug Burgum
Secretary, U.S. Department of the Interior
The Honorable Brooke Rollins
Secretary, U.S. Department of Agriculture
The Honorable Chris Wright
Secretary, U.S. Department of Energy
The Honorable Lee Zeldin
Secretary, U.S. Environmental Protection
Agency

December 4, 2025
President Donald J. Trump
The White House
1600 Pennsylvania Avenue, NW
Washington, DC 20500

Re: E15 Negotiations

The post Industry Letter to White House on E15 Negotiations appeared first on Growth Energy.

Thank you for the opportunity to comment as part of a Section 301 investigation into China’s
implementation of the Economic and Trade Agreement Between the Government of the United
States of America and the Government of the People’s Republic of China (“Phase One
Agreement”).
We appreciate the support and assistance of the Office of the U.S. Trade Representative (USTR)
on this important issue as well as the agency’s continued engagement with foreign governments
to expand market access for U.S. ethanol. Growth Energy is the nation’s largest association of
ethanol producers, representing 97 U.S. plants that each year produce 9.5 billion gallons of lowcarbon, renewable fuel; 130 businesses associated with the production process; and tens of
thousands of ethanol supporters around the country. Growth Energy represents the leading
exporters in the ethanol industry, helping to support nearly 2 billion gallons of ethanol exports to
over 60 countries around the world.
In January 2020, China committed to substantial purchases under the Phase One Agreement,
including for agricultural commodities. These commitments have not been fulfilled. We
welcome USTR initiating this investigation.
The 2017 baseline for U.S. agricultural exports to China amounted to $19.6 billion1
. The Phase
One Agreement does not specify how the additional agricultural purchases would be
proportioned per commodity, although ethanol is specifically included in the “other” category.
China agreed to $32 billion in additional agricultural purchases over two years ($12.5 billion in
2020 and $19.5 billion in 2021) above the 2017 baseline and agreed to strive for a further $5
billion in additional imports per year of agricultural products. Thus, China’s minimal purchase
commitment of $32.1 billion in 2020 and $39.1 billion in 2021 not including the strived-for $5
billion.
However, the actual U.S. agricultural exports to China in 2020 ($26.4 billion) and in 2021 ($32.8
billion) were far below these commitments and the added annual $5 billion also never
materialized. Actual exports only amounted to 82 percent of minimal commitments in 2020 and
84 percent of minimal commitments in 2021.
1 Trade data compiled from the U.S. Department of Agriculture’s Global Agricultural Trade System.
The 2017 baseline for U.S. ethanol was 55 million gallons valued at $83 million. However, this
baseline is well below U.S. ethanol exports to China in 2016, which amounted to 198 million
gallons valued at $313 million. In 2020, U.S. ethanol exports were valued at $50.9 million (32
million gallons) and in 2021 were valued at $162.4 (100 million gallons). Since then, no
meaningful volumes have been exported, including in 2022 while other agricultural commodities
were still generally increasing in export value to China.
$0
$50,000
$100,000
$150,000
$200,000
$250,000
$300,000
$350,000
2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024
U.S. Ethanol Exports to China
(in thousands of dollars)
0.00
100,000,000.00
200,000,000.00
300,000,000.00
400,000,000.00
500,000,000.00
600,000,000.00
700,000,000.00
800,000,000.00
2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024
U.S. Ethanol Exports to China (liters)
China committed to a 64 percent increase over the 2017 baseline for 2020 and a 99 percent
increase over the 2017 baseline for 2021 in its agricultural purchase commitments under the
Phase One Agreement. No specific dollar or volumes were noted for ethanol purchases.
However, using these percentages, an estimate of ethanol purchases can be extrapolated had
China adhered to its commitments. Accordingly, ethanol purchases fell below what was expected
considering the overall percentage increase of commitments over the 2017 baseline.
In 2021, U.S. ethanol exports experienced a 95 percent increase over the 2017 ethanol baseline,
which is aligned with the agreement’s overall commitment percentage increase applied to
ethanol purchases. However, in 2020, U.S. ethanol exports of $50.9 million was 39 percent lower
than the 2017 ethanol baseline of $83.2 million. The actual amount of U.S. ethanol exports in
2020 was below the anticipated $136.3 million in ethanol purchases if considering the
agreement’s overall 2020 purchase commitment percentage increase of 64 percent over the 2017
baseline.
Under this approach, there was an $85 million purchase deficit of U.S. ethanol by China in 2020
and a $3.2 million purchase deficit in 2021, for a combined total of $88.6 million in nonmartialized purchases of U.S. ethanol by China.
A second way to consider if China fulfilled its purchase commitments related to U.S. ethanol is
comparing the overall share of U.S. ethanol to other agricultural purchases. In 2017, U.S. ethanol
accounted for 0.4 percent of U.S. agricultural exports to China. Of the additional $32 billion in
additional agricultural purchases China committed to, 0.4 percent would mean $135.5 million of
the additional purchase commitments would be of U.S. ethanol. Factoring in the 2017 ethanol
baseline and actual exports, this method shows an $88.6 million U.S. ethanol purchase deficit by
China under the Phase One Agreement.
Both assumptions show deficits higher than the value of U.S. ethanol exports to China in 2017.
The above assumptions also did not include the additional $5 billion in agricultural purchases
China agreed to strive for.
2017
Baseline
Additional
Purchase
Commitments
Total
Purchase
Commitment
Percentage
Increase Over
Baseline
(Commitment)
Actual
Exports
Percentage
Increase
Over
Baseline
(Actual)
Difference in
Commitment
vs. Actual
Agriculture (billions)
2020 $19.6 $12.5 $32.1 64% $26.4 35% -$5.7
2021 $19.6 $19.5 $39.1 99% $32.8 67% -$6.3
Total $32.0 $71.2 $59.2 -$12.0
Ethanol (millions)
2020 $83.2 $53.1 $136.3 64% $50.9 -39% -$85.4
2021 $83.2 $82.4 $165.6 99% $162.4 95% -$3.2
Total $135.5 $301.9 $213.3 -$88.6
Thank you for your consideration of these comments related to our concerns that China has not
followed through on its agricultural purchases under the Phase One Agreement, neither generally
nor on ethanol specifically. Growth Energy looks forward to working further with USTR to
resolve unfairness issues facing U.S. ethanol.
Sincerely,
Chris Bliley
Senior Vice President of Regulatory Affairs
Growth Energy

December 1, 2025
Ms. Jennifer Thornton
General Counsel
Office of the U.S. Trade Representative
600 17th Street NW
Washington, DC 20508
Docket ID: USTR-2025-0007
Dear Ms. Thornton:

The post Growth Energy Comments on 301 Investigation into China Phase One Agreement appeared first on Growth Energy.