The Honorable Catherine Blakespear
Chair, Senate Environmental Quality Committee
1021 O Street, Room 3230
Sacramento, CA 95814

RE: Support for AB 30 (Alvarez) State Air Resources Board: gasoline specifications: ethanol blends

Dear Chair Blakespear,

On behalf of Growth Energy, I write in support of AB 30 (Alvarez) which would make transportation fuel blends of up to 15% ethanol (E15) legal for sale and use in California. Growth Energy is the world’s largest trade association representing 97 U.S. biorefineries that
produce more than nine billion gallons of cleaner-burning, renewable fuel annually. Our members account for more than half of the bioethanol produced in the United States each year. 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.

AB 30 will significantly reduce light-duty fuel costs for California’s consumers. A recent study by the University of California, Berkeley and the United States Naval Academy indicates that California drivers could save as much as 20 cents per gallon with the inclusion of E15 in the fuel supply. The same study indicates California drivers could save as much as $2.7 billion annually at the pump if E15 replaced E10.

Furthermore, E15 reduces fuel emissions and has notable environmental benefits. Testing by the University of California, Riverside shows E15 significantly reduces tailpipe emissions compared to E10. This includes the reduction of greenhouse gases and harmful
particulates that contribute to air pollution.

E15 is well tested and has already been used across the country. After extensively testing the fuel in 86 vehicles for a total of six million miles, the U.S. Environmental Protection Agency approved E15 in 2011 for all passenger vehicles model year 2001 and newer. Since
its approval, E15 has efficiently fueled 150 billion miles driven in the United States. E15 is available for sale in 34 states at more than 4,200 fuel retail locations. It is time for California to approve the sale and use of E15, just as every other state in the nation has done.

For the reasons outlined above, Growth Energy is pleased to support AB 30 and urge an AYE vote on this critical measure. We look forward to continued collaboration with your office and other policymakers to implement E15, reduce air emissions, and make fuel more affordable for Californians.

Sincerely,

Emily Skor
CEO
Growth Energy

cc The Honorable Members of the Senate Environmental Quality Committee
The Honorable Assemblymember David Alvarez, Author
Eric Walters, Chief Consultant, Senate Environmental Quality Committee
Scott Seekatz, Consultant, Senate Republican Caucus

The post Letter to California Senator Catherine Blakespear Urging Support for AB 30 appeared first on Growth Energy.

Thank you for the opportunity to provide stakeholder comments on the further development of the greenhouse gas reduction quota as part of Germany’s efforts to implement the recent changes to the European Union (EU)’s Renewable Energy Directive (RED) through the Ministerial Draft of Second Act for the Further Development of the Greenhouse Gas Reduction Quota (Entwurf eines zweiten Gesetzes zur Weiterentwicklung der Treibhausgasminderungs) dated 19 June 2025.

Growth Energy is the leading voice of America’s biofuel industry. Our members operate and support biomanufacturing facilities at the heart of America’s bioeconomy, delivering a new generation of clean fuel options. Growth Energy is the largest association of bioethanol producers in the United States, representing 97 U.S. plants that each year produce 9.5 billion gallons of low-carbon, renewable fuel; 130 businesses associated with the production process; and tens of thousands of bioethanol supporters around the country. Growth Energy represents the leading exporters in the bioethanol industry, helping to support nearly two billion gallons of ethanol exports to over 60 countries around the world.

Bioethanol plays a significant role in sustainably meeting the greenhouse gas reduction goals and use of renewable energy in RED. Biofuels decrease the use of fossil fuels and other harmful fuel additives without sacrificing food and protein requirements. Biofuels provide food and feed supply through their coproducts. Simultaneously, the use of biofuels reduces greenhouse gas emissions in transportation, enabling compliance with current mandates and reduction requirements while being fully compatible with the current vehicle fleet.

Specific Comments on “Entwurf eines zweiten Gesetzes zur Weiterentwicklung der Treibhausgasminderungs”

Article 3 of the proposed draft bill, change item 7 (reference to paragraph 13(1) of the Federal Immission Control Act/BImCchG) proposes a decrease in the maximum share of food and feed crops that can be used to meet bioenergy commitments. This proposal would decrease the already low amount of 4.4 percent to 3 percent in calendar year 2030.

We respectfully urge the German Ministerial authorities to reconsider this decrease and keep, as a minimum, the existing caps in place. Maintaining at least the 4.4 percent cap already adopted would better position Germany to achieve the greenhouse gas emissions reduction requirements set forth in RED. Recognizing the proven climate and sustainability benefits of food and feed based biofuels supports not only the transportation sector, but also other strategic areas such as energy security, economic competitiveness, rural development, and the bioeconomy.

While we recognize the interest in and concern for biofuels policies leading to land use changes served as the justification for this decrease, in the United States this has been widely discussed, investigated and debated and we have confirmed that increased biofuels production has not resulted in cropland expansion nor deforestation. Instead, U.S. bioethanol production from food and feed crops has increased in productivity and sustainable agricultural practices and hefty investment in technology developments have enabled higher output from the current existing land.

Considering the above, our recommendation and request is for Germany to maintain the existing provisions of paragraph 13(1) and refrain from introducing stricter limits and caps on food and feed crops for biofuels use as that would undermine and discard one of the most reliable and proven feedstocks that are currently available for adoption towards greenhouse gas emissions reduction targets. Alternatively, Germany could exempt U.S. bioethanol from any cap reduction in food and feed crops, as well as any other origins where there is no risk of deforestation.

The U.S. Scenario

The sustainable production and use of value-added agricultural commodities in the United States have supported farmers, revitalized rural communities, created jobs, increased local tax revenue, and generated economic savings for consumers. The establishment of ethanol biorefineries has created a steady and dependable market for grains. This has brought a new generation to farming and rejuvenated communities. Jobs and prospects offered by bioethanol facilities have strengthened agricultural economies, providing many positive influences on rural life.

In the United States, the significant growth of bioethanol production has not resulted in increased cropland area. Simultaneously, inputs into agricultural production have decreased, yields have increased, and efficiencies have been gained during the bioethanol production process that have enabled producers to get more bioethanol from each bushel of corn. Fuel is just one of the many things U.S. biorefineries produce that drives economic activity in rural communities.

The U.S. bioethanol industry continues to innovate and improve its processes to be even more sustainable and productive. Corn bioethanol only requires starch from the kernel, not the protein, fat, fiber, or other micronutrients. Because of this, bioprocessing facilities are able to transform crops and crop byproducts used to produce bioethanol into other in-demand coproducts such as corn oil, high-protein animal feed, food-grade CO2, biopolymers, and other innovative, items that form a part of the bioeconomy.

Without corn bioethanol, the high-protein animal feed in the form of distillers grains would not be produced in the United States. This would result in continued demand for that corn but as a less nutrient-dense feed source compared to distillers grain where the starch has been removed.

Additionally, this would remove the added benefits of bioethanol and other coproducts that have formed an important part of fueling and feeding the U.S. economy in a sustainable way. These coproducts play a vital role in the livestock and food processing sectors, indirectly contributing to the human food supply chain. Rather than diverting food resources, bioethanol production enhances agricultural efficiency by producing fuel and feed from the same crop input. During the U.S. ethanol production process, biogenic carbon is captured for use in food processing, including for use in carbonated beverages. When bioethanol production dropped during the height of COVID in the United States, the food industry experienced significant difficulties in sourcing the food-grade CO2 necessary for their food production.

Blanket restrictions or sought-after prohibitions on biofuels made from food and feed crops lack a precise understanding of our industry. This is a barrier to the circular, regenerative, and competitive bioeconomy that the EU and Germany seek to build through the implementation of RED and other similar policies. That is why we believe it’s necessary to have these discussions about removing the effective prohibition on food and feed crops in aviation and maritime, as well as addressing arbitrary caps for on-road use.

We would welcome the opportunity to discuss these production innovations and the circular/regenerative realities of the U.S. ethanol industry during future engagements. Such collaboration, we hope, will provide scientific reasoning for why the use of U.S. bioethanol from food and feed crops does not risk the environmentally harmful effects noted in the justification for the proposed reductions.

Thank you for your consideration of these comments as you seek to finalize your implementing acts for RED.

The post Growth Energy Comments to Germany on Proposed Crop Cap Reduction appeared first on Growth Energy.

Thank you for the opportunity to provide comments as part of this independent review of CleanBC’s policies and programs.

Growth Energy is the leading voice of America’s biofuel industry. Our members operate and support biomanufacturing facilities at the heart of America’s bioeconomy, delivering a new generation of clean fuel options. Growth Energy is the largest association of ethanol producers in the United States, representing 97 U.S. plants that each year produce 9.5 billion gallons of low-carbon, 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 two billion gallons of ethanol exports to over 60 countries around the world. Further, we have a strong history of positive collaboration with the Canadian biofuels industry and promoting our shared North American agricultural goals.

British Columbia (BC) has been a global leader in its efforts to implement the Low Carbon Fuel Standard (LCFS) and achieve a 30 percent reduction in fuel carbon intensity by 2030, relative to 2010 levels. This program has been successful in driving innovation in the production of low emissions biofuels. However, we have concerns that a forthcoming change related to domestic content requirements may undermine this policy—specifically, that the LCFS’ ability to meet its 5 percent renewable fuels requirement and emissions reductions in gasoline will be jeopardized.

In February 2025, BC’s Minister of Energy and Climate Solutions issued Ministerial Order No. M41. This order notes that effective January 1, 2026, the minimum five percent renewable fuel requirement for gasoline must be met with eligible renewable fuels (i.e. ethanol) produced in Canada.

BC’s low carbon fuel policy provides substantial economic incentives for ethanol producers who supply the required low carbon ethanol into the program. As a result, ethanol facilities, including those in the United States, have made significant financial investments in technologies to lower their carbon intensity level, such as deploying carbon capture utilization and storage technologies, to participate in the LCFS. Ministerial Order No. M41 puts those investments at risk and greatly diminishes the probability of future investments due to lack of financial certainty in the LCFS.

This order was seemingly implemented to address potential concerns in the Canadian biomass-based diesel (BBD) industry resulting from changes in U.S. tax policy for clean fuel production. It is important to note that the ethanol market in both the U.S. and Canada operates very differently in terms of production, feedstock, supply chain, end use, and competition. The BC LCFS and U.S. Clean Fuel Production Credit are both intended to drive reductions in carbon intensity. Rather than restrict U.S. ethanol with domestic content requirements, we urge you to consider additional ways to further incentivize Canadian biofuels. Restrictions such as these could result in higher regulatory compliance costs to BC’s obligated parties and ultimately higher fuel prices for BC consumers.

For these reasons, and others, we respectfully ask that you recommend the reversal of Ministerial Order No. M41, thereby removing the domestic production requirement for eligible renewable fuels in gasoline.

Thank you for your consideration of these comments as part of your review on CleanBC’s policies and programs. Canada, including BC, has been a significant partner and friend to the U.S. ethanol industry. We look forward to discussing how U.S. ethanol, an economically viable and available low-carbon product, can help support BC’s low carbon fuel goals.

The post Growth Energy Provides Comments to British Columbia on CleanBC Policies appeared first on Growth Energy.