WASHINGTON, D.C.—In a hearing today, Growth Energy—the nation’s largest biofuel trade association—urged the U.S. Environmental Protection Agency (EPA) not to retroactively reduce renewable volume obligations (RVOs) for cellulosic biofuels under the Renewable Fuel Standard (RFS). 

Earlier this month EPA proposed a partial waiver that would reduce the requisite amount of cellulosic biofuels that needed to be blended into the nation’s fuel supply, as stipulated by the RFS, for the 2024 compliance year. In testimony, however, Growth Energy General Counsel Joe Kakesh warned that following through on the waiver could set a dangerous precedent for future retroactive reductions, and would undermine the growing market for cellulosic biofuels, which are biofuels produced from leftover plant parts like stems, leaves and other fibrous material. 

“EPA’s proposal to partially waive 2024 cellulosic volume requirements is inconsistent with EPA’s recent RFS policies and with the RFS itself. While 2024 cellulosic volumes may not yet have achieved RVO targets, many biorefiners have nevertheless been making headway in cellulosic biofuel production, and we’ve seen more and more of their cellulosic registrations being approved by the agency,” said Kakesh.  

“In any case, any waiver of 2024 cellulosic volume requirements here should not provide precedent for the future of the RFS program or suppress RFS program goals, which are to drive production and innovation of biofuels, including cellulosic biofuels, and not to passively track a biofuels marketplace without them,” he added. 

To read the full testimony as prepared for delivery click here.  

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WASHINGTON, D.C.—AAA projected last week that 107 million Americans will travel by car for the holidays this year. Based on this data, Growth Energy, the nation’s largest biofuel trade association, estimates that U.S. consumers could collectively save up to $250 million in fuel costs this holiday season if they were to choose Unleaded 88 (also called E15)—a fuel blend made with 15% homegrown bioethanol. 

“The more American biofuel blended into gasoline, the more cost savings, and the better it is for the environment,” said Growth Energy CEO Emily Skor. “Unleaded 88 is approved for use in more than 96% of cars on the road today and, on average, can retail for 10-30 cents less per gallon than standard fuel. Consumers can save their money for other expenses and pay less at the pump by choosing Unleaded 88 whenever they fill up during the holidays this year.” 

Apart from the cost savings, Unleaded 88 is also a critical part of establishing American energy dominance because it reduces our dependence on foreign oil. It also promotes cleaner air, reducing smog-forming pollutants and lowering emissions of particulate matter by up to 50% compared to gasoline. 

Travelers can plan their road trip and locate gas stations selling Unleaded 88 and other higher ethanol blends using the Get Biofuel Fuel Finder. To date, Americans have driven more than 130 billion miles on Unleaded 88. 

About Unleaded 88/E15  

Unleaded 88 (also known as E15) is a fuel blend made of gasoline and 15% bioethanol. The U.S. Environmental Protection Agency (EPA) has approved its use in all cars, trucks, and sport utility vehicles (SUVs) made in model year 2001 and newer—representing more than 96% of all vehicles on the road today. Unleaded 88/E15 can be found at over 3,700 gas stations in 33 states and is legal for sale in every state except California. Last summer drivers saved 10 to 30 cents per gallon by filling up with Unleaded 88 compared to regular, or E10. In some areas, Unleaded 88 saved drivers as much as a dollar per gallon at the pump. 

Learn more about Unleaded 88/E15 here. 

The post Americans Could Save $250 Million Filling Up with Unleaded 88 This Holiday Season appeared first on Growth Energy.

On behalf of the undersigned organizations representing American manufacturers, farmers and agribusinesses, wholesalers, retailers, restaurants, importers, exporters, distributors, transportation and logistics providers, and other supply chain stakeholders, we are writing to urge both the International Longshoremen’s Association and the United States Maritime Alliance to return to the bargaining table with the goal of reaching a new labor contract before the new Jan. 15 contract expiration date. It is imperative for the parties to resume negotiations and remain at the table until a new contract is reached.

We know significant issues remain between the parties. However, we continue to believe the only way to resolve these issues and come to an agreement is to actually stay at the negotiating table. The continuing start and stop of the negotiations leads to further uncertainty in the supply chain, which continues to cause challenges. The three-day strike in October had a significant impact on supply chain stakeholders that rely on the East Coast and Gulf Coast ports. The additional costs from mitigation efforts as well as post-strike resumption are still being felt. Companies have continued to implement mitigation strategies because of the ongoing threat of another strike in mid-January if a new contract is not achieved.

We understand that automation and technology continues to be the biggest issue of disagreement between the parties. We continue to believe there is a path forward for the parties to address this issue. It is critical that our ports and terminals have the ability to modernize their systems and processes in order to remain globally competitive and be able to handle the continuing rise of trade volumes, both imports and exports, through our ports. Modernization can only happen through true partnership between labor and management, as well as the other supply chain stakeholders that rely on these ports. Modernization efforts will benefit all parties and are essential to address current and future throughput issues.

We firmly believe the remaining issues can only be resolved by returning to the negotiating table and remaining until a final deal is complete.

Sincerely,

The post Growth Energy Joins Trade Letter Urging Port Labor Negotiations appeared first on Growth Energy.

Chairman Hall, Vice Chair Lear, Ranking Member Rogers, Jr., and members of the Committee,

Thank you for the opportunity to provide written testimony regarding House Bill 358. Growth Energy is the world’s largest association of biofuel producers, representing 97 U.S. plants that each year produce more than 9.5 billion gallons of renewable fuel, 123 businesses associated with the production process, and tens of thousands of biofuel supporters around 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. We remain committed to helping our country diversify its energy portfolio, sustain family farms, and drive down the costs of transportation fuels for consumers.

We write today in support of Ohio’s efforts to establish primacy in the approval and regulation of Class VI carbon dioxide sequestration wells for potential projects in the state. Carbon sequestration is a critical tool for the bioethanol industry, particularly as demand for low-carbon liquid fuels continues to rise. Ohio is positioned as one of only a relatively handful of states with optimal carbon sequestration geology.

Liquid fuels are expected to continue to dominate the nation’s transportation fuel matrix in the coming decades. Domestic markets, as well as an increasing number of international markets, are placing a premium on low-carbon liquid fuels. By establishing primacy, Ohio’s bioethanol industry, coupled with favorable geology for sequestration in several regions of the state, will provide additional economic benefits to the biofuels industry and the rural Ohio economies it supports via increased access to these low-carbon domestic and international markets.

With the U.S. Department of Agriculture predicting further decreases in farm incomes, these new markets and economic opportunities are particularly important for rural communities dependent on grain prices and biofuels production. As of November 11, 2024, 154 Class VI permits were currently under review by the U.S. Environmental Protection Agency. Many of these permit applications have experienced delay after delay, preventing bioethanol producers from moving forward on capital- and labor-intensive carbon sequestration projects.

By establishing primacy, Ohio can move forward with CCUS projects without delays from federal agencies. Growth Energy’s members, and the corn growers with whom we work, will benefit greatly from Ohio’s efforts on Class VI primacy. Ohio can join North Dakota, Wyoming, and Louisiana in taking advantage of this economic opportunity for a variety of industries.

We thank State Representative Robb-Blasdel for introducing this legislation and working with stakeholders to ensure the economic benefits of CCUS projects can benefit Ohioans across its energy industry. Given our industry’s experience and expertise in carbon reduction, we are happy to assist the Committee with technical questions as they consider this important legislation.

The post Growth Energy Submits Testimony on Ohio Class VI Primacy appeared first on Growth Energy.

Chair Shink,

Thank you for the opportunity to provide testimony on SB 1171. Growth Energy is the world’s largest association of biofuel producers, representing 97 U.S. plants—including two plants in Michigan—that produce more than 9 billion gallons of renewable fuel annually; 123 businesses associated with the production process; and tens of thousands of biofuel supporters nationwide. Together, we are working to bring consumers better and more affordable choices at the fuel pump, improve air quality, and protect the environment for future generations. We remain committed to helping diversify our country’s energy portfolio, grow more energy jobs, decarbonize our nation’s energy mix, sustain family farms, and drive down the costs of transportation fuels for consumers.

Growth Energy supports SB 1171, which provides certain updates to the Motor Fuels Quality Act of 1984. As a partner with fuel retailers across the country, we work to ensure statutory and regulatory certainty in the fuel retail market so that consumers have access to fuels with higher blends of ethanol, which will help them save money at the pump while using a lower carbon fuel.

We appreciate the efforts in SB 1171 to streamline Michigan’s statute with federal regulations regarding dispenser labeling for retailers offering E15. E15 is a blend consisting of 15 percent bioethanol, has been approved for use by the EPA in all passenger vehicles model year 2001 and newer, more than 96 percent of the vehicles on the road today. It is now for sale at more than 3,400 locations in 32 states.

Provisions in SB 1171 ensure the federal label required by the U.S. Environmental Protection Agency in 40 CFR 1090.1510 for retailers offering E15 is sufficient for the state and provides consumers the assurance they are filling their tank with a more affordable fuel option that is safe for their engines. The EPA label is the standard for E15 dispensers and consistent for fuel retailers across the country.

According to recent data from Environmental Health and Engineering, today’s bioethanol reduces greenhouse gases (GHG) by nearly 50 percent compared to gasoline and can provide even further GHG reductions with additional readily available technologies. A national analysis showed a reduction of 580,000 tons of GHGs annually in Michigan if E15 replaced E10 gasoline. This is the GHG reduction equivalent of removing more than 126,000 vehicles from Michigan’s roads without impacting a single driver just by using a higher ethanol-blend fuel. These emissions reductions also come with meaningful consumer cost-savings. During the summer of 2023, E15 was sold at 15 cents less per gallon where available on average nationwide.

We thank Chair Shink for introducing this bill, appreciate the collaboration with the Department of Agriculture and Rural Development, and urge all members of the committee to support the bill.

The post Growth Energy Provides Testimony on Dispenser Labeling in Michigan appeared first on Growth Energy.

WASHINGTON, D.C. – Growth Energy CEO Emily Skor issued the following statement regarding President-elect Donald Trump’s nomination of America First Policy Institute (AFPI) Founder Brooke Rollins as Secretary of Agriculture:

“Growth Energy looks forward to engaging with Secretary Designate Rollins and demonstrating how our industry is vital to growing jobs and innovation across rural America and unleashing American energy dominance. The USDA Secretary is rural America’s voice in the White House, and we will work hard to ensure Rollins is well-positioned to deliver on President Trump’s rural agenda, expand markets for homegrown renewable fuel, and bring more low-cost options to the pump.”

The post Growth Energy Statement on Selection of Brooke Rollins to Lead USDA appeared first on Growth Energy.

WASHINGTON, D.C.  – Growth Energy CEO Emily Skor issued the following statement regarding President-elect Donald Trump’s nomination of North Dakota Governor Doug Burgum to serve as Secretary of the Interior and Chairman of the National Energy Council:

“Governor Doug Burgum is uniquely qualified to coordinate an all-of-government approach to U.S. energy dominance. Under his leadership, North Dakota has been a hotbed for innovation, with a thriving renewable fuel sector, growing alongside oil and gas while reducing emissions with carbon capture. We look forward to working with the next leader of the Interior Department and National Energy Council to deliver on President Trump’s goals for creating rural jobs and advancing U.S. energy dominance.”

The post Growth Energy Welcomes Selection of Doug Burgum as Energy Czar appeared first on Growth Energy.

A CLEANER BURNING FUEL

Ethanol is the cleanest, most affordable high-octane fuel on the market. It provides a superior octane boost without the carcinogens associated with other fuel additives.

MORE OCTANE FOR MORE POWER

High-octane fuels like ethanol enhance engine performance by delivering more horsepower and speed. Most vehicles require a minimum octane rating of 87. Ethanol, with an octane rating of 113, helps meet that in modern cars. Ethanol isa cleaner, renewable, and cost-effective alternative to toxic chemicals like lead and MTBE. As a result, ethanol is now blended into 98 percent of motor fuels in the U.S., providing a safe and efficient boost to fuel performance.

MORE OCTANE FOR GREATER EFFICIENCY

Turbocharging forces more fuel and air into a smaller volume, increasing pressure but potentially causing low-octane fuels to ignite prematurely, reducing efficiency and damaging the engine. High-octane fuels, like ethanol, are essential for high-compression, turbocharged, or supercharged engines, ensuring proper ignition timing and delivering more power. Future U.S. fuel efficiency standards may require higher-compression engines, necessitating higher-octane fuels, which ethanol can provide at a lower cost.

The post Engine Performance 101: Unlocking the Power of E15 appeared first on Growth Energy.

WASHINGTON, D.C.—Growth Energy CEO Emily Skor issued the following statement on the 2024 congressional election results:

“We’re excited to have so many new and familiar leaders in Congress ready to work on a bipartisan basis to deliver for rural America. Lawmakers from both parties campaigned and won on their support for jobs in the U.S. bioeconomy. We’re confident that our champions will continue to set the direction for Congress when it comes to lowering fuel costs with E15 and protecting and expanding rural America’s access to new markets and energy incentives.

“We congratulate incoming members of the 119th Congress, and we look forward to working with them to maintain robust, bipartisan momentum behind efforts to protect the Renewable Fuel Standard, extend clean energy incentives, break down trade barriers, and increase competition at the fuel pump.”

The post Growth Energy Congratulates Biofuel Champions Elected to Congress appeared first on Growth Energy.

WASHINGTON, D.C.—Growth Energy, the nation’s largest biofuel trade association, issued the following statement today after California Governor Gavin Newsom issued a directive to the California Air Resources Board (CARB) to expedite measures that could lead to lower gas prices without compromising environmental protections. This includes studying “how California could increase ethanol blending in gasoline (E15), which studies have shown could reduce prices while maintaining environmental protections.”

“We thank Gov. Newsom for voicing his support to approve E15, which can lower fuel costs for California families while helping to decarbonize the state’s light-duty vehicles,” said Growth Energy CEO Emily Skor. “We stand ready to assist the governor’s office and state to complete the approval process and permit the sale of this more affordable and environmentally-beneficial fuel option, which Americans have already relied on to travel 120 billion miles.”

The post Growth Energy Statement on California Governor Newsom’s Directive on E15 appeared first on Growth Energy.

WASHINGTON, D.C.—Growth Energy, the nation’s leading biofuel trade association, continued to urge the Internal Revenue Service (IRS) today to follow the best available science when crafting its long-awaited guidance on the 45Z Clean Fuel Production Credit. Specifically, Growth Energy called on the U.S. Treasury Department to quickly issue guidance, preferably in a rulemaking, that accurately rewards the full spectrum of tools available to reduce bioethanol emissions at the plant and on the farm, including carbon capture and storage, process heat and energy, and climate-smart agriculture (CSA).

Growth Energy called on the IRS to provide flexibility for biofuel producers to integrate climate-smart technologies.

“For the 45Z credit to function properly, the IRS should reward renewable fuel producers that maximize their GHG reductions through the full scope of lower-carbon production processes,” wrote Growth Energy CEO Emily Skor. “Fortunately the GREET model includes a broad range of at-the-plant technologies that should be incorporated into any 45Z model used in the SAF context and the emissions rate table used for 45Z on-road eligibility. At a minimum, any model or emissions rate table designed to estimate carbon intensity using best available practices must include adjustments for biomass power or heat, corn stover to process heat, combined heat and power, wet distiller’s grains, membrane dehydration, vapor recompression, advanced yeasts and enzymes, energy storage, and zero-CI electricity from solar, nuclear, geothermal, hydropower, and biomass facilities.”

With regard to climate-smart farming practices, “there is not a one-size-fits-all approach to CSA,” wrote Skor. “Farmers should be encouraged to adopt as many CSA practices as possible, with the flexibility to choose the CSA practices that work best for the specific circumstances at their farms. Farmers across the country face distinct challenges and advantages based on the location of their farm, types of crops grown, soil health, weather patterns, local equipment costs, and individual risk tolerance, among many other factors.”

Finally, Growth Energy reminded Treasury officials that time is of the essence and called on IRS to work quickly before October ends to take the critical first step of proposing a rulemaking with guidance for 45Z.

“At a minimum, the IRS should issue a proposed rule no later than November 1, 2024, including any proposed new models or model upgrades,” wrote Skor.

Read the letter here.

The post Growth Energy: 45Z Tax Credit Guidance Must Be Scientific, Flexible, and Timely appeared first on Growth Energy.

Emergence of Ethanol as a Key Enabler of the Transition to Low-Carbon Fuels

The U.S. clean energy transition requires a transition to both carbon-free electricity and clean fuels. Ethanol has been the leader in the move to low-carbon fuels, as long-standing attempts to develop other advanced low-carbon liquid fuels (cellulosic biofuels, algae derived fuels, e-fuels, etc.) have not succeeded in achieving scalable production at an acceptable cost.

Since 2005, the overall carbon intensity (CI) a of ethanol has decreased by 23%. Ethanol’s CI today is 53.6 grams of carbon dioxide equivalent per megajoule of ethanol produced (gCO2e/MJ), 42% lower than unblended gasoline. This has enabled blends of ethanol and gasoline to reduce on-road vehicle greenhouse gas (GHG) emissions by over 544 million tons of CO2.

This reality leads the EFI Foundation (EFIF) to present in this report a strategic roadmap to further decarbonize the U.S. ethanol industry through a portfolio of actions that can help it reach a goal of net-zero carbon intensity by midcentury, and several additional options that can achieve net-negative carbon intensity. The strategic roadmap will enable ethanol to play a central role in decarbonizing the transportation sector, which accounted for 29% of total U.S. GHG emissions in 2021.

Continued decarbonization of ethanol, combined with higher blend levels, can complement the shift to electrification of light-duty vehicles—both battery electric vehicles (BEVs) and plug-in hybrid electric vehicles (PHEVs)—in achieving further reductions in 2030 and beyond. Conversion of ethanol into aviation fuel will allow blends of sustainable aviation fuel (SAF) at a significant scale. Further decarbonization of the U.S. ethanol industry also will strengthen its contribution to the U.S. economy, particularly to the rural economy.

In 2023, the United States produced 15.6 billion gallons of ethanol, making it the world’s leading producer and exporter of ethanol, responsible for producing over half of the global supply. The ethanol industry accounted for 28% of farm GDP, contributing $57 billion to total U.S. GDP in 2022. The ethanol industry supports more than 420,000 jobs.

Corn production for ethanol is a high value-added proposition—ethanol producers use about 30% to 40% of the U.S. corn crop, spending $38 billion, but require only about 1.5% of total U.S. farmland (an estimated 13.9 million acres). Since 2001, the U.S. food crops industry overall has maintained relatively consistent land use for planting while yields have continued to increase, indicating that corn is not in direct competition for acreage with other food crops. This report does not assume any increase in corn planting for ethanol production.

The post A Strategic Roadmap for Decarbonizing the U.S. Ethanol Industry appeared first on Growth Energy.

Last week, biofuels advocates and champions from across the country convened in Washington, D.C., for the 15th annual Growth Energy Biofuels Summit (GEBS).

Emily Skor, Growth Energy CEO, and Tom Willis, Growth Energy Chairman and President and CEO of Conestoga Energy Holdings, opened the summit by highlighting the critical role of biofuels and setting the tone for the week ahead.

“GEBS really is a remarkable gathering,” said Willis, “Leaders and champions for homegrown biofuels from all across the country, descending on our nation’s capital to make our presence felt, our voices heard, and our needs and priorities crystal clear.”

In her opening remarks, Growth Energy CEO Emily Skor emphasized, “What’s good for biofuels, producers, and the entire bioeconomy is good for working families on a budget; good for energy security and independence; good for environmental stewardship and decarbonization; and good for economic development in communities that need it most.”

GEBS—the premier advocacy event for biofuels—featured prominent keynote speakers such as U.S. Senator Pete Ricketts (R-Neb.) and U.S. Senator Tammy Duckworth (D-Ill.), among other energy industry leaders and government officials.

Secretary of Agriculture Tom Vilsack’s remarks highlighted exciting updates from the Biden administration.

“We’re working to create systems that will allow us to have our farmers be able to participate fully and completely in ecosystem service markets, which creates another new revenue source for them,” said Vilsack.

Ernest Moniz, 13th U.S. Secretary of Energy and CEO and founder of the Energy Futures Initiative Foundation (EFIF), previewed research on exciting opportunities to further decarbonize bioethanol.

“I would just note that the reality is, when you think about low carbon fuels, we have for decades been pursuing a variety of approaches towards low carbon fuels,” said Moniz. “The only one that to date has been found to be effective, scalable and affordable, frankly, has been ethanol production…And we can’t just sit around and pray. What we can do is work at this in the ethanol-approved, proven approach that can get us there.”

During more than 160 meetings with Congressional member offices, attendees stressed the importance of prioritizing policies such as a permanent solution for nationwide, year-round access to E15, accurate and timely guidance for the 45Z tax credit and setting Renewable Volume Obligations (RVOs) that align with current market conditions, among other issues.

The post Biofuels Summit 2024: Policy Priorities that Deliver on Shared Values appeared first on Growth Energy.

Thank you for the opportunity to provide written comments regarding the proposed Low Carbon Fuel Standard (LCFS) amendments. Growth Energy is the world’s largest association of biofuel producers, representing 97 U.S. plants that each year produce more than 9.5 billion gallons of renewable fuel; 121 businesses associated with the production process; and tens of thousands of biofuel supporters around 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. We remain committed to helping our country diversify our energy portfolio in order to grow more green energy jobs, decarbonize our nation’s energy mix, sustain family farms, and drive down the costs of transportation fuels for consumers.

Growth Energy has previously submitted extensive comments demonstrating the vital role low carbon biofuels and higher biofuel blends can play in meeting California’s ambitious climate goals. As we have previously noted, biofuels have been among the largest contributors to the success of the LCFS program to date and are poised to continue to do so with appropriate updates to the program.

As our comments in response to the April workshop also noted, we continue to have serious concerns over the proposed amendments. Of particular concern are the details added to the sustainability certification requirements, the California Air Resources Board (CARB) neglecting to consider farm-level carbon reduction practices and technologies, the unilateral discretion given to the Executive Officer on new fuel pathway applications, and the authority given to the Executive Officer to modify land use change (LUC) penalty values in table 6 for the purposes of determining a fuel’s carbon intensity (CI).

Continued Concerns Over Proposed Sustainability Certification

In our comments on the April 10th workshop, we reiterated our concerns over the onerous and costly requirements on biofuels producers and farmers and how CARB’s Economic Impact Analysis (EIA) of the proposal does not discuss the sustainability certification requirement’s financial burden of implementation. In the recirculated EIA, this impact is still not sufficiently addressed. Rather, the 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.” This acknowledgement renders the need for a sustainability certification moot as potential LUC concerns for crop-based feedstocks are addressed in Table 6. Corn starch bioethanol is given an automatic 19.8 gCO2e/MJ penalty for indirect land use change (ILUC). Adding the sustainability certification requirement to the current ILUC score amounts to an unfair and unnecessary double penalty for corn starch bioethanol.

As we have previously commented, the concerns over LUC factors are unfounded relative to corn starch bioethanol. In fact, the United States is planting grain corn on roughly the same number of acres as was planted in 1900. At the same time, the per acre yield has increased more than 600%. As shown in the graph below, the number of acres harvested annually have consistently hewn to the average since 1900.

While the most recent proposal details the “best environmental management practices” required for biomass used in fuel pathways and those climate-smart agriculture (CSA) practices result in the reduction of carbon emissions, CARB continues to disregard these and other practices when factoring CI scores. Some of these practices include precision application of fertilizer, use of low CI fertilizer, no or low-till farming practices, and the use of cover crops. The use of these practices for measured carbon reduction is not new. Other state agencies are using some of these same practices to reduce the release of soil carbon in the state’s natural and working lands.

CSA practices are an important component to bioethanol’s continued efforts to get to net-zero. We urge CARB to recognize these practices and their carbon-reduction potential and allow CSA practices to be considered when determining a pathway’s CI. Finally, with respect to the proposed sustainability audit, the proposal’s audit requirements address issues that, while important to environmental and social justice, fall outside the scope of the LCFS. According to the April 10 staff presentation, the proposed sustainability audit process would require auditors to conduct: “review of management systems”, “review of social practices”, and an assessment of the “economic sustainability of the applicant.” The proposed amendments require approved certification systems for the sustainability requirement to take “social and economic criteria” into account alongside environmental concerns. While important and laudable goals themselves, “social and economic criteria” have no bearing on GHG reduction. Additionally, many aspects of these audit provisions are addressed by federal programs. For instance, the Fair Labor Standards Act has clear employment guidelines specifically for the agriculture industry. Furthermore, if the proposal is adopted, crop-based biofuels would be the only feedstock for which these criteria would be audited.

Expanding Specified Source Feedstocks

We acknowledge CARB’s recognition of the use of a variety of “waste, residue, by-product or similar material in a fuel pathway”, particularly the inclusion of distiller’s corn oil, and its consideration as specified source feedstock. Biofuels producers are pushing innovations to use every part of the corn crop. While traditionally considered waste, corn stover and corn kernel fiber have increasingly been used as a feedstock for bioethanol production. As a byproduct of corn bioethanol production, we encourage CARB to recognize and include corn stover and corn kernel fiber in the list of specified source feedstocks.

Biofuel Cap and Executive Officer Discretion on Fuel Pathways and LUC Values Betrays Technology Neutrality

CARB has made clear its intentions to increase the role and market for zero emissions vehicles (ZEVs) in the state. However, the revised amendments give the Executive Officer discretion to reject new fuel pathway applications for particular crop-based fuels solely based on achieving a threshold of 132,000 registered Class 3-8 ZEVs. It endows the Executive Officer with such an authority without a proper rulemaking. This, combined with a 20 percent cap on the use of specific biofuels for credit generation opportunities sets a dangerous precedent for the use of all GHG reducing feedstocks and technologies, violating the LCFS’ commitment to technology neutrality. The program already requires the use of a lifecycle model and assesses penalties for land use change, further limits make little to no sense. Using the full range of Class 3-8 trucks allows for the very real possibility this threshold can be met with smaller lighter vehicles (Class 3-4), thus leaving the larger, heavier vehicles (Class 7-8) reliant on liquid fuel that may only be available in fossil fuels if new biofuels pathways are not allowed. This could be especially true after an update to CA-GREET where legacy pathways are termed out. This situation would result in environmental backsliding and loss of GHG benefits.

Similarly, the proposed discretion of the Executive Officer to revise LUC values in Table 6 if such a value is deemed not “conservatively representative of a particular region/feedstock/fuel combination” also betrays the Standard’s technology neutrality. This proposed provision, much like the sustainability certification requirement, singles out crop-based feedstocks.

Not only are concerns over LUC values unwarranted for cornstarch bioethanol, but the proposal does not provide any opportunity for a LUC value to be revised down, even if the Executive Officer were presented with “the best available empirical data” indicating a lower value. For instance, data showing corn bioethanol with a LUC value less than the 19.8 gOC2/MJ would not be considered. To that end, we also believe the 19.8 gCO2e/MJ score is outdated and not based on the most up to date research. A review of more recent science indicates a decreasing trend in land use values with the newer data indicating values closer to 4 gCO2e/MJ.

Approval of E15

We acknowledge CARB’s consideration of the role E15 can play in reducing the state’s greenhouse gas (GHG) emissions while also providing a cost-savings opportunity for California drivers. Consumers have embraced E15’s reputation as a more environmentally beneficial, more affordable fuel. Since the US EPA approved E15 in 2011, at which time there were zero retailers offering it, its availability rapidly expanded to now 3,400 retail sites in 33 states. Since then, drivers in America have relied on E15 to drive 100 billion miles.

In contrast, with Nevada, Oregon, the Phoenix metro area, and most recently Montana approving E15 for sale, California remains the only state to have not approved this cost-effective, environmentally beneficial fuel that can be used in nearly all the state’s 31 million gasoline-powered vehicles. If CARB not only approved E15, but replaced E10 with E15, this switch would be responsible for the GHG-reduction equivalent of removing more than 400,000 ICE vehicles from California’s roads without negatively impacting California drivers. Neither will it have a negative impact on land use change for bioethanol.

We urge CARB to complete the analysis of and approval process for E15 so that Californians can take advantage of this more affordable, cleaner burning fuel that can be used to power more than 96% of the light duty vehicles on the road today.

E85, Flex-Fuel Vehicles, and CCUS

Additionally, we appreciate CARB’s August 2023 updates to the California Transportation Supply (CATS) Model that recognize the value of carbon capture utilization and sequestration (CCUS) in carbon reduction during bioethanol production. By accounting for CCUS, a process incentivized by the Inflation Reduction Act, the pathway carbon intensity (CI) for E85—approved for use in California—was updated such that it reduces the assumed CI score for bioethanol from 66 gCO2e/MJ to 35 gCO2e/MJ. We appreciate CARB’s recognition of the bioethanol industry’s efforts to further reduce carbon emissions via CCUS, a process which is incentivized by the Inflation Reduction Act of 2022. This is a welcome update to CATS and a recognition of the positive impact bioethanol has on California’s emissions reduction goals.

Additionally, California’s existing approval of E85 has resulted in significant growth of its use in flex-fuel vehicles (FFVs): more than 118 million gallons have been sold at 375 locations across the state in 2023 alone. The current size of California’s FFV fleet stands at more than 1.3 million vehicles. The use of E85 will promote even greater reductions in GHG emissions and reductions of air toxics. We would continue to encourage CARB to implement policies that strongly incentivize and as necessary, require the production and use of flex-fuel vehicles, as well as continued investment in infrastructure for expanded access to E85 in the state. In doing so, the Board will be achieving multiple goals: improving air quality and GHG emissions, reducing the state’s dependence on fossil fuels, and providing consumers with an affordable choice to power their vehicles. Again, this can be done without any negative land conversion impact.

Expand Access to Low-CI Power Sourcing for Biofuels Producers

With respect to Low-CI power sourcing, the proposal fails to recognize its carbon-reduction potential in biofuels production. The proposal currently only allows this mechanism for hydrogen as a transportation fuel, Direct Air Capture projects, and electricity as a transportation fuel. Firstly, this fails the LCFS’ fundamental policy goal of carbon intensity reduction in transportation fuels used in California. Allowing bioethanol producers to source new contracted low-CI power that is not included in a utility resource plan via a power purchase agreement does not impact electricity demand.

Secondly, biofuels production occurs largely in electricity markets outside of California. This renders the argument against expanding low-CI power sourcing due to purported resource shuffling moot. Additionally, by not expanding this provision to biofuels, it denies the state the opportunity to lead other jurisdictions towards increasing their low-CI power generation capability.

Finally, similar to other proposed provisions in the amendments, limiting the approved use of indirect accounting for Low-CI power sourcing to a handful of fuels and processes violates the LCFS’ commitment to technology neutrality.

Accelerate the Use of Sustainable Aviation Fuel (SAF)

As producers of one of the most scalable feedstocks for SAF production, we encourage CARB to continue to work with SAF producers, biofuel feedstock producers, and airlines to continue to seek ways to accelerate use of these important fuels to help decarbonize the aviation sector.

Thank you for the opportunity to provide input on the recent proposed amendments. The LCFS Program is a critical tool to addressing climate change, and we look forward to working with CARB to ensure the role of biofuels in making California’s fuel mix more sustainable and help the state achieve its progressive climate goals through the expanded use of bioethanol.

The post Growth Energy Submits Comments on California’s Proposed LCFS Amendments appeared first on Growth Energy.

WASHINGTON, D.C. – Growth Energy—the leading voice of America’s biofuel industry—urged the White House to swiftly finalize clear, flexible guidance for the 45Z clean fuels credit, which was signed into law two years ago this week.

“After two long years, we’re eager to see this administration’s clean fuel incentive reach its full potential,” said Growth Energy CEO Emily Skor. “That’s why we’ve been working closely with the administration and our bipartisan champions on Capitol Hill to ensure the Department of Treasury finalizes flexible guidance for 45Z, so farmers and biofuel producers can plan and invest ahead of the next harvest.

“Properly implemented, 45Z could be the starting pistol for rural communities waiting to access new economic opportunities and deliver on the promise of climate-smart agriculture. To unlock those investments, the White House must avoid pitfalls that encumbered its approach to the 40B sustainable aviation fuel (SAF) credit. That means setting the new guidelines without delay, and sending a strong market signal that all low-carbon innovations on the farm and at the plant will be properly rewarded.

“President Biden said that farmers would provide 95 percent of SAF over the next two decades, and this anniversary is a wonderful opportunity to move us closer to that goal.”

Starting in 2025, the president’s 45Z clean fuel production tax credit will become the primary incentive for the production of low-carbon fuels in transportation on the ground and in the air. According to an analysis published by Growth Energy on the first anniversary of the IRA, a properly implemented 45Z tax credit could add $21.2 billion to the U.S. economy, generate nearly $13.4 billion in household income, support more than 192,000 jobs across all sectors of the national economy, and provide farmers with a 10 percent premium price on low carbon corn used at a bioethanol plant.

The post Growth Energy Marks IRA’s Birthday with Call for Action on 45Z appeared first on Growth Energy.

Thank you for the opportunity to provide written comments in response to the New Mexico Environment Department (NMED) Clean Transportation Fuel Standard’s (CTFS) Advisory Committee and its technical report. Growth Energy is the world’s largest association of biofuel producers, representing 97 U.S. plants that each year produce more than 9.5 billion gallons of renewable fuel; 119 businesses associated with the production process; and tens of thousands of biofuel supporters around 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. We remain committed to helping our country diversify our energy portfolio in order to grow more green energy jobs, decarbonize our nation’s energy mix, sustain family farms, and drive down the costs of transportation fuels for consumers.

We applaud New Mexico’s efforts to reduce carbon emissions through the CTFS. Growth Energy has previously provided extensive comments on similar programs in California, Washington, and Oregon, ensuring those states recognize the carbon reduction value of
increased bioethanol use. In California, biofuels have been among the largest contributors to the success of the LCFS program to date and are poised to continue to do so with appropriate updates to the program. Additionally, as mentioned in the June 28 Advisory Committee meeting, bioethanol has been a significant credit generator in the Oregon and Washington programs. Like those states, we believe the CTFS has the opportunity to utilize biofuels as a means of immediate greenhouse gas (GHG) reduction in the current light-duty vehicle fleet as future technologies are further developed.

Environmental and Economic Value of Bioethanol

According to recent data from Environmental Health and Engineering, today’s bioethanol reduces GHG by nearly 50 percent compared to gasoline and can provide even further GHG reductions with additional readily available technologies.

The potential for fuels with higher blends of ethanol to reduce GHGs are further illustrated in a national analysis showing more than 146,000 tons in GHG reduction in New Mexico alone if E10 gasoline was replaced with E15. This is the GHG reduction equivalent of removing 32,000 vehicles from New Mexico’s fleet just by using a higher ethanol-blend fuel.

Bioethanol’s other environmental benefits are also noteworthy. As has been researched by the University of California, Riverside and the University of Illinois at Chicago, the use of more bioethanol and bioethanol-blended fuel reduces harmful particulates and air toxics such as carbon monoxide, and benzene.

Use of GREET for Life Cycle Analysis Modeling

We believe the Argonne National Laboratory’s GREET model is the most accurate tool to examine the life-cycle greenhouse gas emissions of all fuels and considers a wide range of carbon reduction processes and technologies that bioethanol production can utilize. It is the gold standard for measuring the emissions-reducing power of farm-based feedstocks and biofuels. It incorporates up-to-date science that more accurately scores lifecycle carbon intensity (CI) for corn ethanol and other renewable fuels.

Reject Caps and Sustainability “Guardrails” on Biofuels

As several members of the CTFS Advisory Committee noted in presentations and we reiterated above, biofuels have been a major driver of GHG reductions in existing fuel standard programs. They have been able to be so despite onerous, and we believe unnecessary, land use change (LUC) penalties for cornstarch bioethanol of varying values, including 19.8 gCO2e/MJ in California’s Low Carbon Fuel Standard. This penalty was designed to mitigate alleged land use change with respect to cornstarch ethanol’s production. We believe these scores to be outdated and not based on the most up to date research. A review of more recent science indicates a decreasing trend in land use values with the newer data indicating values closer to 4 gCO2e/MJ.

Concerns over land use change for cornstarch ethanol are unfounded. The United States is planting grain corn on roughly the same number of acres as it was in 1900. At the same time, the per acre yield has increased more than 600%. Capping the use of bioethanol in the CTFS or adopting a sustainability framework similar to what has been proposed by the California Air Resources Board would create an unfair double penalty on cornstarch ethanol in addition to violating the New Mexico legislature’s directive for technology neutrality in the program.

Expanding E15 and Higher Blends

Emissions reductions through the use of E15 also come with meaningful consumer cost-savings. During the summer of 2023, E15 was sold at 15 cents less per gallon where available on average nationwide. In some locations, we saw E15 selling consistently for as much as 60 cents less per gallon than E10.

Consumers have embraced E15’s reputation as a more environmentally beneficial, more affordable fuel. Since the US EPA approved E15 in 2011, at which time there were zero retailers offering it, its availability rapidly expanded to what is now more than 3,400 retail sites in 32 states. Since then, drivers in America have relied on E15 to drive 100 billion miles.

Recognizing Carbon Capture and Other CI Reduction Methods

Bioethanol producers constantly make improvements to their production process, increasing economic efficiency and more importantly, reducing CI. Among the newest tools bioethanol producers are utilizing to reducing CI is carbon capture utilization and sequestration (CCUS). Recently, California adjusted their modeling to account for CCUS, recognizing its importance in carbon reduction. By accounting for CCUS, the pathway CI for E85—approved for use in California—was updated such that it reduces the assumed CI score for ethanol from 66 gCO2e/MJ to 35 gCO2e/MJ. We urge NMED to also recognize the CI reductions CCUS provides to biofuels pathways.

Additionally, we have recently advocated for expanded crediting for low-CI power sourcing in California’s LCFS, Currently, the ability to credit low-CI power in a pathway is limited to specific fuel pathways. While CARB is considering expanding crediting ability to hydrogen-as-fuel pathways, we believe the ability to credit new low-CI power sourcing—power not included in a utility’s preexisting capacity—through power purchase agreements should be available to all feedstocks and pathways. With bioethanol production occurring entirely outside of New Mexico, the state has an opportunity to become a national leader by encouraging, via the CTFS, the adoption of low-CI power for bioethanol producers in other jurisdictions. We encourage NMED to consider the ability of all fuel pathways to credit low-CI power sourcing in their CI score.

On-farm carbon reduction practices, commonly called climate-smart agriculture (CSA), should also be credited in the CTFS. With the use of the GREET model, including the model’s Feedstock Carbon Intensity Calculator, along with the USDA’s database of CSA practices, the carbon reduction values can easily be quantified and verified. Among these practices are the use of cover crops, low or no-till farming, precision fertilizer application, and the use of enhanced efficiency fertilizer.

Bioethanol producers have a wide variety of tools at our disposal to reduce our product’s carbon intensity. We strongly urge NMED to consider maximizing the opportunities for bioethanol producers to lower the CI for bioethanol pathways.

Sustainable Aviation Fuel (SAF)

As producers of one of the most scalable feedstocks for SAF production, we appreciate NMED’s attention to development of this key market. We encourage NMED to work with SAF producers, biofuel feedstock producers, and airlines to seek ways to accelerate use of these important fuels to help decarbonize the aviation sector.

Thank you for the opportunity to provide input on the CTFS Advisory Committee’s technical report. The CTFS will be a critical tool in New Mexico’s decarbonization efforts, and we look forward to working with NMED to ensure the role of biofuels in making New Mexico’s fuel mix more sustainable and help the state achieve its progressive climate goals through the expanded use of bioethanol. Additionally, we are happy to make ourselves available for any questions NMED may have.

The post Growth Energy Submits Comments on New Mexico’s Clean Transportation Fuel Standard appeared first on Growth Energy.

On Wednesday, July 10, 2024, the U.S. House Agriculture Committee held a hearing titled, “Examining the Consequences of EPA’s Actions on American Agriculture.” Throughout the hearing, biofuels champions on the Committee raised the importance of biofuels to America’s farmers, and specifically talked about year-round E15 and sustainable aviation fuel. Read some of the highlights below and click the links to watch.

Rep. Tracey Mann (R-KS): I will just point out that it’s time for them to lock down year-round E15. We now have both chambers that have all said they are okay with E15 so it’s time to get that done.  

Rep. Mary Miller (R-IL): Could you also speak about the importance of biofuels and how regulatory certainty impacts a grower’s planting decision?  

Chris Chinn, Director, Missouri Department of Agriculture: Again, it’s about having that choice about where you want to market your crop. Whether it’s for biofuels or livestock, having that competition in the marketplace is a good thing and we want to make sure the farming community has many options and that they know what the rules are when they make those decisions. 

Rep. Shontel Brown (D-OH): How do you see the role of agriculture in the production of sustainable aviation fuels, and what conservation practices are you implementing on your farm to support this industry while ensuring environmental sustainability? 

Mr. Kippley, Vice President, National Farmers Union: On our farm, we’ve been using no-till for years. However, some of the current regulations will not allow us to meet everything that’s there. We need to open it up so that farms in the northern U.S. can easily access these benefits. Cover crops just don’t work in our part of the world. We’re limited in some ways by the current rules.  

Rep. Nikki Budzinski (D-IL): You mentioned the importance of RFS for growers as well as your support for year-round E15. Constituents in my district have expressed concerns that renewable volume obligations are not keeping up with the increasing rates of production, disincentivizing new and continued production of biofuels. Can you speak on what EPA can do to improve this disparity, and how EPA can improve the landscape of biofuels?  

Mr. Kippley: I think there is an opportunity for E30 in this country. They sell a lot of E30s up in our part of the world and we have a lot of people using them on all kinds of engines with no problems. I think the best way to boost this up is with E30… It’s a cleaner fuel, the gas mileage doesn’t change, and you do get a little better horsepower out of your vehicle.  

Rep. Nikki Budzinski (D-IL): One thing that is heavy on our minds in the Midwest is the 40B tax credit. What can the EPA do to advocate for a better outcome for the upcoming 45Z tax credit for biofuels?  

Mr. Kippley: I think they need to include more ways for all farmers to participate in this program. Feedstocks are going to be a very important part of this and they need to make sure it’s going to be available and we need to look at other options we can use to qualify.   

Rep. Zach Nunn (R-IA): Do you believe the EPA’s failure to extend the E15 waiver yet again this year has impacts on family farms and on corn and soybean growers across this country?   

Mr. Kippley: Absolutely. We’re always waiting for the numbers to come out. The EPA is always slow to get those renewable numbers out and as far as E15, we want year-round, and we would like to see it go up to E30.  

Rep. Zach Nunn (R-IA): Do you think the ability for biofuels in this country is a net advantage for American’s energy independence?  

Mr. Kippley: Absolutely.  

Thank you to our champions for raising these important issues! 

The post Congressional Champions Highlight Biofuels in Agriculture Committee Hearing appeared first on Growth Energy.