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.

New research commissioned by Growth Energy and other industry leaders – including ADM, POET, and Marquis Energy – shows that U.S. industrial bioeconomy supported nearly 644,000 domestic jobs, contributed $210 billion to the U.S. GDP, and drove $49 billion in wages. Additionally, the report found that for every direct job created in the bioeconomy (i.e., a job in bioethanol production), another 11 jobs are created elsewhere in the supply chain. That adds up to a job multiplication factor of 12. For comparison’s sake, the job multiplication factor for the sector that includes solar photovoltaics is 6.50 and the multiplier for the sector that includes wind turbines is 3.73.

Providing new impetus for President Biden’s National Biotechnology and Biomanufacturing Initiative, the report illustrated state-by-state gains linked to the transformation of renewable biomass into new products.

And most importantly for policymakers, the report explains why, “A considerable competitive and policy advantage of these industrial bioeconomy jobs is their tie to U.S. soil, both literally and figuratively—these jobs are here and stay in the U.S.”

To learn more, check out the full report available here.

The post Biofuels at the Forefront of Growth Across the U.S. Industrial Bioeconomy appeared first on Growth Energy.

We applaud Ecology’s efforts to reduce Washington’s greenhouse gas (GHG) emissions in the transportation sector and believe the biofuels industry represents the greatest opportunity to lower carbon emissions immediately as future technologies are developed. Growth Energy’s members produce biofuels which, according to recent data from Environmental Health and Engineering, today’s bioethanol reduces greenhouse gas emissions (GHG) by nearly 50 percent compared to gasoline and can provide even further GHG reductions with additional readily available technologies. A study conducted in 2022 by the University of California – Riverside found that shifting from E10 to E15 (gasoline containing up to 15% ethanol) in light-duty vehicles reduces emissions including harmful particulates and air toxics such as carbon monoxide, and benzene.

Bioethanol’s Role in SAF Production

The opportunity for biofuels to contribute to the aforementioned carbon emissions reductions is evident in the aviation industry and the use of sustainable aviation fuel (SAF). With current technologies, farm-based feedstocks of bioethanol and corn oil are the primary source of clean, renewable energy that can be used to produce volumes large enough to meet demand. While Ecology’s proposed changes and the request for comments on those changes does not include modifications to the state’s carbon lifecycle analysis or the valuation of land use change penalties, Growth Energy believes these issues are critical to the success of SAF. Alcohol-to-Jet SAF, when
the policy and carbon intensity modeling is done correctly, can be a crucial component to Washington’s ambitious goal of aviation decarbonization.

Recognizing the Carbon-Reduction Values of Farm-Level Climate Smart Ag Practices

In order for Washington to take advantage of SAF’s ability to reduce carbon emissions, Ecology should consider recognizing farm-level climate-smart agriculture practices. There has been a wealth of data including a recent study done by Argonne National Laboratory (ANL) that show the possibility of a 35 percent reduction in carbon intensity through adoption of current best on-farm practices such as cover crops, no till, low carbon fertilizer use, and other innovations. Allowing appropriate credit will help bioethanol producers continue to further innovate and lower their carbon intensity, while providing key incentives for farmers to adopt these effective conservation practices. In a recently released 40B guidance for SAF production, the U.S. Department of Treasury acknowledged the role climate-smart agricultural practices play in reducing GHG emissions in the aviation industry.

Revising Land Use Change Penalty Based on Current Science

Currently, Washington’s greenhouse gases, regulated emissions, and energy use in technologies (GREET) assigns an indirect land use change (ILUC) penalty of 19.8g/MJ for cornstarch bioethanol. This number is largely based on outdated and flawed data. A review of the more recent science over the last 5 years indicates a decreasing trend in land use values with the newer data indicating values closer to 4 gCO2e/MJ. The ILUC value should reflect the latest science that better addresses innovation and increasing yields in agriculture. As Ecology considers alignment with other states’ clean fuel programs, it is important to note that Oregon assigns an ILUC penalty of
7.6g/MJ. We request Ecology consider aligning WA-GREET’s ILUC value for cornstarch bioethanol with Oregon’s value. By recognizing the latest science and adjusting the ILUC penalty, Ecology can allow bioethanol to continue its ability to further reduce GHG emissions within the state’s legacy vehicle fleet.

Expanding the Use of Low-CI Power Book-and-Claim Accounting

Ecology currently does not allow for biofuels producers to utilize low-carbon intensity power sourcing via book-and-claim accounting. Allowing biofuels producers to source contracted low-CI power via power purchase agreements incentivizes the generation of cleaner electricity. This would position Washington as a national leader, encouraging the use of low-CI power in other states as the vast majority of biofuels used in Washington is produced out of state. We encourage Ecology to take advantage of book-and-claim accounting for sourcing low-CI power by allowing all fuel types to access this CI reduction tool.

Third-Party Verification for Fuel Pathways

Verification of pathways is an important component in ensuring the CFS attains its objectives. Bioethanol producers work with accredited and experienced firms to conduct audits and verify producers’ pathways achieve their GHG reductions. Auditors’ consistent work with biofuel producers allows audit teams to become more familiar with individual producers’ processes and operations over time. As a result, the audits become more efficient and effective, improving the integrity of the CFS. While we appreciate Ecology’s intent to strengthen the auditing process, we believe a firm rotation requirement would be costly to biofuel producers and could negatively impact audit quality. We encourage Ecology to find an alternative to an audit firm rotation requirement that satisfies the CFS’ verification needs without placing undue burdens on biofuel producers.

More broadly, we look forward to continuing to work with you as the proposed changes to the CFS are considered further, and to ensure the role of biofuels in making Washington’s fuel mix more sustainable and help the state achieve its ambitions climate goals through the use of bioethanol.

Thank you in advance for your consideration.

The post Growth Energy Provides Comments on Washington Clean Fuel Standard appeared first on Growth Energy.

S&P Global Senior Vice President and Head of Agribusiness Consulting Juan Sacoto moderated the panel, titled Business Models to Scale Biofuels Supply, and BASF’s Head of North American Business Development Jeremy Zidek and Raizen CEO Ricardo Mussa joined Skor as fellow panelists. Throughout the discussion, Skor highlighted how focused the bioethanol industry and its farm partners are on driving down the carbon intensity of their supply chain and overall production practices.  

“Bioethanol plants are making all the optimizations at the plant, [including] looking at carbon sequestration. The last thing for us to do is to decarbonize that feedstock,” Skor said. “The good thing is that we can do that—through the Inflation Reduction Act (IRA) we can monetize the value of low-carbon farming and we can pay a premium for that low-carbon corn because of the tax credits provided for in the IRA.” 

Realizing the full potential of these opportunities, however, will require clearer support from policymakers in Washington—including in the updated modeling guidelines that will be used to apply the IRA’s 40B sustainable aviation fuel credit and 45Z clean fuel production credit. 

“Washington has to send a signal and give us the guidance on the tax code that says ‘we will give you credit for everything you do on the farm,’” Skor said, specifically citing climate smart agriculture practices like no-till farming and cover crops. “We’ve got to make sure the modeling of carbon intensity allows bioethanol to be competitive.” 

Learn more about the importance of carbon modeling here.

The post Growth Energy CEO Spotlights Bioethanol’s Potential in Panel at CERAWeek appeared first on Growth Energy.

“While California has its sights set on the future, the state continues to overlook a significant challenge that it faces right now:  decarbonizing the millions of internal combustion engine (ICE) vehicles in the state that will continue to be on the road for decades.

“Despite its commitment to being an environmental leader, the state’s recently proposed changes to its LCFS ignore plant-based fuel options that could immediately help the state achieve its climate goals. Instead, the proposals put up roadblock after roadblock that prevent the deployment of crop-based biofuels—one of the only proven, drop-in solutions available today that can significantly lower the emissions of ICE vehicles.

“CARB’s proposed changes to crop-based biofuels’ status in the LCFS defy the program’s commitment to technology neutrality, fly in the face of the state’s administrative rules, and place an unfair burden on bioethanol that isn’t supported by science. This proposal would not only be an enormous missed opportunity for the state to decrease emissions from cars on the road today. It would increase California’s already infamously-high gas prices, making an already heavy economic burden on California families even heavier.

“Higher blends of bioethanol have been a keystone of California’s LCFS—they’ve been one of the top credit generators for the program for years. We strongly urge the board to reconsider the role that biofuels can continue to play in lowering carbon emissions, today.”  

Growth Energy’s full comment can be found here. Learn more about Growth Energy’s policy priorities on low-carbon fuel standards here.

The post Growth Energy: Proposed California LCFS Updates Leave Biofuels Behind appeared first on Growth Energy.

“In an important first step, the Biden administration has recognized the merits of using the GREET model in its guidance for eligibility in the 40B Sustainable Aviation Fuel (SAF) tax credit. America’s biofuel producers and their farm partners continue to innovate with myriad technologies that are further reducing the carbon intensity of low-carbon bioethanol, and we are ready to lead the aviation sector into a lower-carbon future. This guidance signals our potential ability to participate in the SAF market.

“New investments in SAF are highly dependent on the pending GREET modeling updates, however, and the industry needs more clarity around the proposed changes before we have certainty around market access. Today, under this guidance, SAF produced from other biofuels including Brazilian cane bioethanol qualifies for the 40B tax credit, but the path for American-made corn-based bioethanol remains unclear. U.S. tax policy shouldn’t advantage foreign firms over domestic ones.

“Any GREET update must follow sound science and account for the proven environmental benefits of American-made bioethanol. The Department of Energy’s Argonne-GREET model —widely accepted as the gold standard carbon model by the nation’s scientists, academics, and researchers—already reflects the latest science showing bioethanol’s limited impact on land use and its significant reduction in greenhouse gas (GHG) emissions. The Biden administration should hold fast to this widely accepted science and ignore those who seek to limit SAF opportunities by pushing an inaccurate and outdated narrative about bioethanol.

“We will work with the Biden administration to ensure that these GREET updates reflect the most up to date science and environmental benefits of bioethanol as we seek to meet the ambitious goals of the president’s SAF Grand Challenge.”

Background

Section 40B of the Inflation Reduction Act (IRA) provided for two years of a sustainable aviation fuel (SAF) tax credit. In 2023 and 2024 SAF will qualify for a standalone blenders credit (40B) if the fuel reduces lifecycle greenhouse gas emissions by at least 50 percent. The value of this credit is determined on a sliding scale, equal to $1.25 plus an additional $0.01 for each percentage point by which the lifecycle emissions reduction of such fuel exceeds 50 percent.

Under the current version of the Department of Energy Argonne National Lab’s Greenhouse Gases, Regulated Emissions, and Energy Use in Transportation (GREET) model for lifecycle analysis, corn-based bioethanol achieves carbon emissions reductions sufficient to qualify for Section 40B credits. Growth Energy has repeatedly engaged with various federal agencies—including the U.S. Department of the Treasury and the Internal Revenue Service—urging officials there to fully adopt the model.

GREET presents the most accurate picture of the environmental benefits of corn-based bioethanol because it accounts for the differences in carbon intensity that biorefineries can achieve when deploying climate-smart agriculture techniques and carbon capture, usage, and sequestration technology. Growth Energy and the American biofuels industry are not alone in their support for GREET—a number of major airlines and other large companies in the aviation sector have similarly voiced support for the model to federal officials.

The post Growth Energy Statement on Treasury Department’s Guidance for 40B SAF Tax Credit appeared first on Growth Energy.

As you know, our ability to attract investment and build out U.S. SAF capacity will depend on how the program determines credit eligibility and valuation. This is especially true for a performance-based tax regime that ties the size of the incentive to a product’s lifecycle carbon score.

While the statute rightly recognizes the carbon lifecycle assessment (LCA) model developed by the International Civil Aviation Organization (ICAO) as a method for determining SAF credit eligibility and valuation, Congress was right to explicitly allow for the use of “any similar methodology.” The Department should immediately recognize Argonne GREET as a similar methodology for several reasons.

First, Argonne GREET incorporates the latest biorefining and feedstock production efficiencies and is updated regularly. Accuracy, transparency, and predictability are vital to securing private capital in a policy-driven marketplace. Second, and unlike the ICAO model, Argonne GREET allows users to account for climate smart and regenerative feedstock production practices. The IRA could unleash a new wave of U.S. bio-innovation practices but will not reach its full potential if those practices cannot be accounted for. Finally, tying a U.S. SAF credit to only one international model – in an inherently uncertain technical field – increases investment risk in direct contravention of the interagency SAF Roadmap’s goal to “reduce [industry] risk during scale-up and operations.”

As to whether Argonne GREET meets the statutory requirements for recognition as a similar methodology to ICAO/CORSIA, the models use the same tools to quantify lifecycle carbon emissions from SAF. Both approaches rely primarily on GREET data for direct (supply-chain) emissions and a general equilibrium economic model called GTAP to estimate indirect emissions (i.e., indirect land use change). Argonne GREET clearly complies with CAA § 211(o)(1)(H) because the model includes every aspect of the “full fuel lifecycle,” including both “direct emissions and significant indirect emissions.” It also includes the only example of significant indirect emissions cited (“land use changes”) and “all stages of fuel and feedstock production and distribution … adjusted to account for their relative global warming potential.”

While the scientific community’s understanding of different aspects of lifecycle carbon accounting is constantly evolving, particularly with regard to indirect emissions, proposed significant modifications should be run through the normal scientific, agency and public processes – and should not be added hastily as part of Treasury guidance.

We are aware that Argonne GREET is undergoing an update. Science-based updates are a normal course of business for lifecycle modeling and should not be cause for delay. Our companies are already engaged in discussions and commercial efforts to ramp up SAF production and feedstocks to meet the goals set forth by the U.S. and global climate leaders. With the right market signals, we can de-carbonize aviation and spur a new wave of U.S. innovation and clean energy jobs. However, modeling uncertainty today is a multiyear development problem due to the buildout schedules of SAF production facilities. To this end, we underscore the urgency for providing clarity on this issue as soon as possible to ensure the effective implementation and utilization of IRA Section 40B.

Respectfully, we encourage the administration to immediately recognize “the most recent version” of the Argonne GREET model – as the statute does for ICAO/CORSIA – as a similar methodology. Unlike any new carbon modeling regime that would invite further delay, recognizing Argonne GREET now gives SAF investors a well-settled, durable, and predictable framework for assessing program eligibility and risk without undercutting ongoing and future modeling updates.

Our companies are committed to a sustainable future and are focused on accelerating the commercial deployment of SAF. We look forward to the opportunity to rely on this vitally important program.

The post SAF Leaders Letter to Biden Administration Calling for Argonne GREET Model appeared first on Growth Energy.

Dear Dr. Laskowski:

Thank you for the opportunity to comment on the Air Resources Board’s (CARB) latest Low Carbon Fuel Standard (LCFS) workshop held on February 22nd. Growth Energy is the world’s largest association of biofuel producers, representing 91 U.S. plants that each year produce more than 8 billion gallons of renewable fuel; 107 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 noted previously and reiterate here, 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. Specifically in response to the discussion at the workshop, we strongly support and encourage the Board to update emission factors and lifecycle modeling to reflect the latest science, data, and information to appropriately capture the latest innovation in the biofuels industry. Additionally, as was further discussed, the state should move quickly to approve the use of E15 and, the Board should recognize the benefits of low[1]carbon farm practices and how they can be driven by policies like the LCFS.

We provide more specific comments reiterating these important points below:

Bioethanol’s Environmental Benefits

As we have continued to advocate, a primary solution for cleaning up the liquid fuel supply is the promotion of additional use of bioethanol, from starch and cellulosic sources. According to recent data from Environmental Health and Engineering, today’s bioethanol reduces greenhouse gas emissions (GHG) by an average of 46 percent compared to gasoline and can provide even further GHG reductions with additional readily available technologies.1 In the existing light duty fleet, higher bioethanol blends can be immediately deployed to achieve GHG reductions, reduce harmful air toxics, and reduce consumer costs at the pump.

Already, we’ve seen biofuels provide the foundation for the LCFS. In fact, biofuels like bioethanol have generated more than 75 percent of LCFS credits. As recently as 2020, bioethanol was the largest LCFS volume and second-largest credit generator. Additionally, even with room to further improve GHG lifecycle modeling, the LCFS recognizes the significant improvement in bioethanol’s carbon intensity. In 2011, CARB reported the average carbon intensity (CI) for ethanol at 88 g/MJ. Through the third quarter of 2022, the average recorded CI for bioethanol has decreased to 59.39 g/MJ, a 33 percent reduction in CI.2 Additional CI reductions are anticipated as projects of diverse technological variety at ethanol biorefineries come online starting this year. In fact, during the presentation, it was noted that the carbon
intensity of ethanol has been adjusted in the CATS model to reflect the historical downward trend. We appreciate CARB’s recognition of this continued innovation in the industry and hope CARB will continue to update the program using the best and most up to date science.

1 Environmental Research Letters: Carbon intensity of corn ethanol in the United States: state of the science (iop.org)
2 CARB LCFS Data: https://ww2.arb.ca.gov/resources/documents/lcfs-pathway-certified-carbon-intensities

Bioethanol’s other environmental benefits are also noteworthy. The University of California, Riverside and the University of Illinois at Chicago, have concluded that the use of more bioethanol and bioethanol-blended fuel reduces harmful particulates and air toxics such as carbon monoxide, and benzene.3

To fully realize these and other important air quality benefits, CARB should implement a clear policy with a firm future for the role and growth of cleaner[1]burning, affordable bioethanol fuels.

Use of Higher Bioethanol Blends

As we have noted previously, we continue to urge CARB to further develop clear policies that recognize the realities of today’s fuel market and examine how homegrown biofuels can immediately contribute to achieving GHG reductions. Today, nearly all gasoline in California – and across the U.S. – is blended with 10 percent bioethanol. E15, a blend consisting of 15 percent bioethanol, has been approved for use by the U.S. Environmental Protection Agency (EPA) in all model year 2001 and newer passenger vehicles, more than 96 percent of the vehicles on the road today, and it is now for sale at more than 2,800 locations in 31 states. In fact, last summer where available, we saw E15 selling consistently for as much as nearly $1 less per gallon than regular gasoline – that is meaningful consumer cost-savings.3

E15 | California Air Resources Board and https://fixourfuel.com/wp-content/uploads/2018/04/UC-Riverside-Study.pdf  ; University of Illinois at Chicago: https://grains.org/wp-content/uploads/2018/11/Complete-Study-Summary.pdf

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While we were encouraged to see CARB post the final Tier I report for the multi-media evaluation of E15 as well as the positive emissions results for E15 from the recent testing done by the University of California-Riverside, it is time to expedite the state’s approval of E15 for California consumers and to help drive further immediate GHG emission reductions. Just recently the Phoenix, Arizona area approved the use of E15 in its Cleaner Burning Gasoline (CBG) program, effectively leaving only California and Montana as the only two states who have not approved the use of E15. As staff noted during the workshop, the new CATS model can be used to model the use of E15. Growth Energy is working on such modeling and intends to provide the results to CARB when the project is completed in the next few weeks.

Additionally, the LCFS is helping to drive growth in the use of E85 in flex-fuel vehicles. The use of E85 will promote even greater reductions in GHG emissions and reductions of air toxics. We also encourage CARB and other state agencies to push for policies that strongly encourage and incentivize the use of higher bioethanol blends such as E15 and E85, the production and use of flex-fuel vehicles, as well as continued investment in infrastructure for the expanded use of E85.

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Biofuels, Land Use, Corn Oil, and Food Supply

We also believe CARB’s concerns about the use of crop-based biofuels and their impact on land use are misplaced and unfounded. These fears have been largely based on outdated and flawed data. While CARB currently has an indirect land use change value (ILUC) for bioethanol of 19.8 gCO2e/MJ, a review of the more recent science over the last 5 years indicates a decreasing trend in land use values with the newer data indicating values closer to 4 gCO2e/MJ.4 The ILUC value should reflect the latest science that better addresses innovation and increasing yields in agriculture.

Related, we also believe that recent concerns about biofuel production on food cost and supply are unfounded. Our industry produces both food and fuel. Specifically, production of bioethanol results in a wide variety of co-products, perhaps the most significant of which is high-quality animal feed that contributes directly to the production of chicken, beef, pork, and other nutritious food.

Specifically, one bushel of corn produces 2.8 gallons of bioethanol as well as 17-18 pounds of distillers dried grains (DDGS), a highly nutritious animal feed. Our industry produces nearly 40

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million tons of animal feed per year. That feed is supplied to food producers here in the U.S. and around the world. Additionally, the renewable CO2 from bioethanol production is also critical for meat processing, beverage carbonation, and water treatment.

Data from the United Nation’s Food and Agriculture Organization (FAO) as well as from the U.S. Energy Administration (EIA) also show in the graph below that the price of food is closely correlated with the cost of crude oil rather than the cost of corn.

Relatedly, we are particularly concerned about CARB’s inclusion of corn oil in its evaluation of a possible cap on credits for diesel fuels from various virgin oil feedstocks. Corn oil is an important coproduct of the bioethanol production process that is then used to make other low carbon intensity, renewable fuels used for LCFS compliance. It makes little sense why it would be potentially capped for use.

Finally, as discussed previously relative to land use, farming practices like crop intensification and cover cropping have significantly improved the yield of all crops, further negating the impact of biofuel production on food crops. As the United States Department of Agriculture (USDA) and numerous others have noted, yields have (and continue to) climbed more than 700 percent while acreage has remained unchanged for the last century.

Page 7 of 8

With respect to some of the other items under consideration for LCFS revisions, we offer comment:

Crediting for Field-based Farm Practices

Growth Energy strongly supports the appropriate crediting of on-the-farm field practices in the LCFS. The U.S. EPA estimates that five percent of national GHG emissions is from crop cultivation and energy. There has been a wealth of data including a recent study done by Argonne National Laboratory that show the possibility of a 35 percent reduction in carbon intensity through adoption of current best on-farm practices such as cover crops, strip tillage, reduced fertilizer use, and other innovations.5

With the LCFS’ verification requirements, capturing these on the farm benefits for biofuel pathways is now more realistic and scalable. Allowing appropriate credit will help bioethanol producers continue to further innovate and lower their carbon intensity, while providing key incentives for farmers to adopt these effective conservation practices.

Carbon Capture and Sequestration

New innovations at biorefineries throughout the U.S. allow pure, biogenic carbon dioxide (CO2) to be captured at a massive scale, and multiple projects are already underway that repurpose, reuse, or provide a permanent storage solution for the majority of that CO2. We support and encourage CARB’s continued allowance for credit generation from carbon capture, utilization, and storage (CCUS).

5 Argonne National Laboratory: https://www.anl.gov/article/argonnes-pivotal-research-discovers-practices-technologies-key-to-sustainable-farming

Page 8 of 8

Correcting Electricity Usage in Wet and Dry Distiller Grain (DDGS) Pathways

The CALGREET 3.0 model currently distinguishes between wet and dry DDGS pathways for thermal energy but does not do so with regard to electricity use. Electricity use between wet and dry DDGS production is quite different. We recommend that CARB further distinguish electricity use as it does with thermal energy in its CALGREET 3.0 model.

Ethanol/Fuel Cell Technology

Direct Ethanol Fuel Cells for the use in motor vehicle transportation have been in development by Nissan for some time. As recently as January of 2020, Nissan and Lawrence Berkeley National Laboratory have published research on the use of 100 percent ethanol in fuel cell technologies and innovations.6

This technology not only meets zero emission vehicle requirements, but further eliminates particulates from tailpipe emissions. Using bioethanol in conjunction with a fuel cell would require less infrastructure change and investment and would help the state meet its ambitious goals for climate and vehicle. We would strongly encourage CARB to consider ways to further develop this technology for consideration.

More broadly, we look forward to working with CARB as you work through the regulatory process on revisions to the LCFS program and 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.

Thank you in advance for your consideration.
Sincerely,
Chris Bliley
Senior Vice President of Regulatory Affairs
Growth Energy

The post Comments to CARB in Response to the February 22, 2023 Low Carbon Fuel Standard Workshop appeared first on Growth Energy.

Co-sponsored by the U.S. Grains Council (USGC), Growth Energy, and the Renewable Fuels Association (RFA), Export Exchange, the bi-annual event — interrupted in 2020 by the COVID-19 pandemic — offers attendees an unparalleled opportunity to meet and build relationships with domestic suppliers of corn, DDGS, sorghum, barley, and other commodities.

This year’s anticipated attendees represent a diverse cross-section of customers for U.S. grains.

“At a time when international trade should be championed by our country’s leaders, Export Exchange is critical for our industry,” said Ryan LeGrand, USGC president and CEO. “It is essential for us to strengthen the bonds between suppliers and partner countries, and the connections made next week will not only help propel our industry this year, but for years to come.”

Export Exchange will host business-to-business meetings between the international buyers and suppliers from the U.S. grain supply chain, so prospective customers can ask questions about this year’s U.S. corn crop and suppliers can explain the benefits of the world’s greatest agricultural supply chain.

“Our industry, and the U.S. rural economy, has so much to offer other countries around the globe, including the 11 million tons of DDGS we export to more than 50 countries annually,” said Growth Energy CEO Emily Skor. “This year’s Export Exchange offers a unique opportunity to showcase these products we provide and the experts we have in our field. We look forward to welcoming everyone to Minnesota for the first Export Exchange since 2018.”

In addition to networking opportunities, the conference will feature engaging speakers addressing critical issues facing U.S. agricultural exports, offering customers and sellers in attendance an increased awareness of the benefits of U.S. coarse grains and co-products.

“We’re proud of the line-up of topics and speakers for this event,” said RFA President and CEO Geoff Cooper. “This event is important not only for its networking and sales opportunities, but also as an educational opportunity for participants to learn more about the high quality and value of U.S. farm and biorefinery products—as is clearly shown by the reach of our exports. American-made distiller’s grains were exported to more than 50 countries on six continents in 2021.”

Scheduled sessions include:

• “Global View” – Thom Petersen, Minnesota Commissioner of Agriculture
• “Policy Opportunities and Challenges” – Jason Hafemeister, U.S. Department of Agriculture
• “World Agricultural Supply and Demand Estimate Report Overview” – Reece Cannady, U.S. Grains Council
• “Inflation, Monetary Policy and Commodities” – Arlan Suderman, StoneX
• “Shipping and Logistics Overview” – Jay O’Neil, HJ O’Neil Commodity Consulting
• “DDGS Global PS&D” – Matt Fitzhum, CHS
• “Pet Food Outlook” – Lisa Schole, Evolve Consulting
• “Aquafeed Demand” – Ronnie Tan, U.S. Grains Council
• “Poultry, Pork and Beef Meat Economic Outlook” – Brett Stuart, Global AgriTrends
• “Sorghum – The Right Choice” – Norman Ritz-Johnson, United Sorghum Checkoff Program
• “The Advantages of Buying U.S. Corn” – Dr. Alvaro Garcia, South Dakota State University; Shane Mueller, North Dakota State University; Dr. Vijay Singh, University of Illinois
• “High Protein DDGS and Corn Fermented Protein Nutritional Overview” – Jerry Shurson, University of Minnesota

The conference will also feature a domestic suppliers exposition featuring more than 30 exhibitors. Registration is available on site for those making last-minute plans to attend the Export Exchange event. View the full agenda here.

More than 20 pre- and post-Export Exchange trade teams from around the world will also take advantage of being in the U.S. by visiting various corn-growing states to get a firsthand look at corn harvest, stopping by ethanol plants to see DDGS production, exploring port facilities and more arranged by the U.S. Grains Council and in cooperation with a myriad of U.S.-based corn and coarse grain industries.

News and updates from Export Exchange will be available at www.exportexchange.org or on social media using the hashtag #ExEx22.

The post Nearly 500 International Customers Converge In Minneapolis Next Week For Export Exchange ‘22 appeared first on Growth Energy.

We sincerely appreciate CARB’s attention and hard work to reshape California’s fuel mix to
make it more sustainable. This objective is a central driver for our industry, and we look forward
to continuing our work on our common goals as you explore revisions to the LCFS moving
ahead. Specifically, liquid fuels will continue to play an important role in the transportation
sector, even as alternative technologies flourish. As such, it is imperative to consider the vital
role that environmentally sustainable fuel options such as plant-based bioethanol will play in
reducing greenhouse gas emissions and cutting consumer costs in the current and future
California vehicle fleet.
Bioethanol’s Environmental Benefits
As we have continued to advocate, a primary solution for cleaning up the liquid fuel supply is the
promotion of additional use of bioethanol, from starch and cellulosic sources. According to
recent data from Environmental Health and Engineering, today’s bioethanol reduces
greenhouse gas emissions (GHG) by an average of 46 percent compared to gasoline and can
Page 2 of 8
provide even further GHG reductions with additional readily available technologies.1 In the
existing light duty fleet, higher bioethanol blends can be immediately deployed to achieve
immediate GHG reductions, reduce harmful air toxics, and reduce consumer costs at the pump.
Already, we’ve seen biofuels provide the foundation for the LCFS. In fact, biofuels like
bioethanol have generated more than 75 percent of LCFS credits. As recently as 2020,
bioethanol was the largest LCFS volume and second-largest credit generator. Additionally, even
with room to further improve GHG lifecycle modeling, the LCFS recognizes the significant
improvement in bioethanol’s carbon intensity. In 2011, CARB reported the average carbon
intensity (CI) for ethanol at 88 g/MJ. Through 2021, the average recorded CI for bioethanol has
decreased to 59.02 g/MJ, a 33 percent reduction in CI.2 Additional CI reductions are anticipated
as projects of diverse technological variety at ethanol biorefineries come on-line starting this
year.
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
1 Environmental Research Letters: Carbon intensity of corn ethanol in the United States: state of the science
(iop.org)
2 CARB LCFS Data: https://ww2.arb.ca.gov/resources/documents/lcfs-pathway-certified-carbon-intensities
Page 3 of 8
carbon monoxide, and benzene.
3 To fully realize these and other important air quality benefits,
there needs to be a clear policy with a firm future for the role and growth of cleaner-burning,
affordable ethanol fuels.
Biofuels, Land Use, and Food Supply
We also believe CARB’s concerns about the use of crop-based biofuels and their impact on land
use are misplaced and unfounded. These fears have been largely based on outdated and
flawed data. While CARB currently has an indirect land use change value (ILUC) of 19.8
gCO2e/MJ, a review of the more recent science over the last 5 years indicates a decreasing
trend in land use values with the newer data indicating values closer to 4 gCO2e/MJ.4 The ILUC
value should reflect the latest science that better addresses innovation and increasing yields in
agriculture.
Related, we also believe that recent concerns about biofuel production on food cost and supply
are unfounded. Our industry produces both food and fuel. Specifically, production of bioethanol
results in a wide variety of co-products, perhaps the most significant of which is high-quality animal
feed that contributes directly to the production of chicken, beef, pork, and other nutritious food.
Specifically, one bushel of corn produces 2.8 gallons of bioethanol as well as 17-18 pounds of
distillers dried grains (DDGS), a highly nutritious animal feed. Our industry produces nearly 40
million tons of animal feed per year. That feed is supplied to food producers here in the U.S. and
around the world. Additionally, the renewable CO2 from bioethanol production is also critical for
meat processing, beverage carbonation, and water treatment.
Data from the United Nation’s Food and Agriculture Organization (FAO) as well as from the U.S.
Energy Administration (EIA) also show in the graph below that the price of food is closely
correlated with the cost of crude oil rather than the cost of corn.
3 University of California Riverside: Comparison of Exhaust Emissions Between E10 CaRFG and Splash Blended
E15 | California Air Resources Board and https://fixourfuel.com/wp-content/uploads/2018/04/UC-RiversideStudy.pdf; University of Illinois at Chicago: https://grains.org/wp-content/uploads/2018/11/Complete-StudySummary.pdf
4 Environmental Research Letters: Carbon intensity of corn ethanol in the United States: state of the science
(iop.org)
Page 4 of 8
Finally, as discussed previously relative to land use, farming practices like crop intensification and
cover cropping have significantly improved the yield of all crops, further negating the impact of
biofuel production on food crops. As the United States Department of Agriculture (USDA) and
numerous others have noted, yields have (and continue to) climbed more than 700 percent while
acreage has remained unchanged for the last century.
Page 5 of 8
Use of Higher Bioethanol Blends
As we have noted previously, we continue to urge CARB to further develop clear policies that
recognize the realities of today’s fuel market and examine how homegrown biofuels can
immediately contribute to achieving GHG reductions. Today, nearly all gasoline in California –
and across the U.S. – is blended with 10 percent ethanol. E15, a blend consisting of 15 percent
bioethanol, has been approved for use by the U.S. Environmental Protection Agency (EPA) in all
passenger vehicles model year 2001 and newer, more than 96 percent of the vehicles on the
road today, and is now for sale at more than 2600 locations in 31 states. In fact, this summer
where available, we’ve seen E15 selling consistently for as much as $1 less per gallon than
regular gasoline – that is meaningful consumer cost-savings.
Sheetz, Grandview Heights, OH June 26, 2022
Through innovative, sustainable ag practices, we’re
producing more using less land
Yields have increased by 700%, while acres remained steady
0
1
2
3
4
5
6
7
1926 1936 1946 1956 1966 1976 1986 1996 2006 2016
Yearly Value Versus 1926
Baseline
By the late 1930s, harvested corn yield was no
longer directly linked to corn planted.
Acres of total corn planted has generally
plateaued, even into the late 2010s.
Yield
Acres Planted
Source: USDA Crop Production Historical Track Records, 2019. (NASS data)
Average annual yield increase of ~8.8% 1937 -2016
Page 6 of 8
We were very glad to see CARB post the final Tier I report for the multi-media evaluation of E15
as well as the positive emissions results for E15 from the recent testing done by the University
of California-Riverside. We continue to encourage the state to expedite its approval of E15 for
California consumers and to help drive further immediate GHG emission reductions.
Additionally, the California LCFS is helping to drive growth in the use of E85 in flex-fuel vehicles. The use
of E85 will promote even greater reductions in GHG emissions and reductions of air toxics.
We would also encourage CARB and other state agencies to push for policies that strongly
encourage and incentivize the use of higher bioethanol blends such as E15 and E85, the
production and use of flex-fuel vehicles, as well as continued investment in infrastructure for the
expanded use of E85.
Mobil Station, San Diego, CA 4/6/20222
Page 7 of 8
With respect to some of the other items under consideration for California LCFS revisions, we offer
comment:
Crediting for Field-based Farm Practices
Growth Energy strongly supports the appropriate crediting of on-the-farm field practices in the California LCFS. The U.S. EPA estimates that five percent of national GHG emissions is from crop
cultivation and energy. There has been a wealth of data including a recent study done by
Argonne National Laboratory that show the possibility of a 35 percent reduction in carbon
intensity through adoption of current best on-farm practices such as cover crops, strip tillage,
reduced fertilizer use, and other innovations.
5 With the California LCFS’ verification requirements,
capturing these on the farm benefits for biofuel pathways is now more realistic and scalable.
Allowing appropriate credit will help bioethanol producers continue to further innovate and lower
their carbon intensity, while providing key incentives for farmers to adopt these effective
conservation practices.
Carbon Capture and Sequestration
New innovations at biorefineries throughout the U.S. allow pure, biogenic carbon dioxide (CO2)
to be captured at a massive scale, and multiple projects are already underway that repurpose,
reuse, or provide a permanent storage solution for the majority of that CO2. We support and
encourage CARB’s continued allowance for credit generation from carbon capture, utilization,
and storage (CCUS).
Correcting Electricity Usage in Wet and Dry Distiller Grain (DDGS) Pathways
The CALGREET 3.0 model currently distinguishes between wet and dry DDGS pathways for
thermal energy but does not do so with regard to electricity use. Electricity use between wet
and dry DDGS production is quite different. We recommend that CARB further distinguish
electricity use as it does with thermal energy in its CALGREET 3.0 model.
Ethanol/Fuel Cell Technology
Direct Ethanol Fuel Cells for the use in motor vehicle transportation have been in development
by Nissan for some time. As recently as January of 2020, Nissan and Lawrence Berkeley
National Laboratory have published research on the use of 100 percent ethanol in fuel cell
technologies and innovations.
6 This technology not only meets zero emission vehicle
requirements, but further eliminates particulates from tailpipe emissions. Using bioethanol in
conjunction with a fuel cell would require less infrastructure change and investment and would
help the state meet its ambitious goals for climate and vehicle. As CARB considers policies on
zero emission vehicles in conjunction with the California LCFS, we would strongly encourage CARB to
consider ways to further develop this technology for consideration.
More broadly, we look forward to working with CARB as you work through the regulatory
process on revisions to the California LCFS program and ensure the role of biofuels in making California’s
5 Argonne National Laboratory: https://www.anl.gov/article/argonnes-pivotal-research-discovers-practicestechnologies-key-to-sustainable-farming
6 Lawrence Berkeley National Laboratory: https://eta.lbl.gov/publications/ethanol-internal-reforming-solid
Page 8 of 8
fuel mix more sustainable and help the state achieve its progressive climate goals through the
expanded use of bioethanol.
Thank you in advance for your consideration.

The post Growth Energy Comments on Updates to California LCFS appeared first on Growth Energy.