“As Congress recognized when it enacted the Renewable Fuel Standard (RFS) almost twenty years ago, biofuels offer numerous climate and other benefits. When compared with petroleum, corn ethanol emits only about half as much greenhouse gases (GHGs), and cellulosic ethanol, made from the waste components of crops, emits even less,” Growth Energy said in the amicus brief. “Ethanol and other biofuels also emit less particulate matter and other pollutants harmful to human health. And all these benefits are readily available right now, all while enhancing energy security and supporting U.S. jobs.” 

In EPA’s rule, which is designed to reduce emissions of GHGs and other pollutants in vehicles for model years 2027 and later, the agency ignored biofuels and their enormous, congressionally recognized benefits.  

“EPA’s analyses treated vehicles that operate on biofuels the same as vehicles that operate exclusively on fossil fuels. EPA failed to consider using or incentivizing higher biofuel blends in vehicles as a way to reduce emissions. And EPA’s cost-benefit analysis looked only at the employment and energy security impacts of the petroleum industry, disregarding the biofuels industry entirely,” the amicus brief said. “For the agency that Congress entrusted to promote biofuels, EPA’s total failure to acknowledge biofuels in the Rule is arbitrary and capricious.” 

Read Growth Energy’s full amicus brief here. 

The post Growth Energy Amicus Brief Points Toward EPA’s Lost Opportunity on Biofuels  appeared first on Growth Energy.

GEBS is the premier advocacy event for advancing biofuels policies and securing America’s energy future. This year, attendees will participate in more than 100 meetings on Capitol Hill, giving lawmakers and rural champions the information and support they need to drive change and progress in the bioeconomy. The event program also features a lineup of influential guest speakers, including keynotes from U.S. Senator Tammy Duckworth (D-Ill.) and U.S. Senator Pete Ricketts (R-Neb.) and other sessions featuring government officials and energy industry leaders: 

• U.S. Secretary of Agriculture Tom Vilsack will provide insights into the Administration’s vision for biofuels in its broader decarbonization strategy. 

• EPA Administrator Michael Regan and Growth Energy CEO Emily Skor will engage in a conversation about the successes and challenges facing the biofuel industry today.  

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

“You aren’t just representatives of a crucial sector,” said Growth Energy CEO Emily Skor in her welcoming remarks to the biofuels summit this morning. “You are ambassadors for the future that our nation deserves … Because 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.” 

In her keynote, Skor focused on policy priorities that deliver on values shared across the political spectrum. Those include finalizing timely and accurate guidance for the 45Z tax credit, setting Renewable Volume Obligations (RVOs) that align with current market conditions, and securing a permanent, year-round solution for E15 access nationwide. 

On driving investment in America’s rural communities: 

“If growers and producers can count on RFS requirements that are timely, ambitious, and reliable, that economic stability ripples out into entire communities … RFS, SREs, carbon capture: These aren’t wish list items to help an industry. It’s a platform to secure and strengthen the rural economy.” 

On giving American consumers greater choice and lower prices: 

“Inflation and the cost of living are dominating kitchen-table conversations around the country — and biomanufacturers deliver relief straight to Americans’ pocketbooks. Drivers across America deserve the freedom to maximize their savings at the pump. That means E15 access should be permanent, year-round, and nationwide. Period.” 

On accelerating innovation in America’s bioeconomy: 

“We are just scratching the surface of the new bioeconomy. We aren’t competing over scarcity. We’re unleashing abundance. We can’t let 21st-century innovation be held back by messy bureaucracy or special interests pushing inaccurate science.” 

On securing American dominance in hard-to-electrify sectors: 

“Air travel. Marine and freight transportation. These markets need different solutions … Sustainable Aviation Fuel (SAF) is key to decarbonizing the skies. Both Republicans and Democrats understand this. The United States can choose to lead or choose to follow.” 

On unlocking foreign markets for American bioproducts: 

“It won’t be enough to bolster our bioeconomy here at home if we lack access to global markets. America is home to the most innovative biomanufacturers in the world. We need to be proactively knocking down barriers and opening new opportunities for them to compete and win.” 

Skor’s full biofuels summit speech, as prepared for delivery, is available here. 

The post Growth Energy Brings Industry Leaders Together for Biofuels Summit in D.C. appeared first on Growth Energy.

The first petition seeks to have the court correct errors that led to its rejection of the U.S. Environmental Protection Agency’s (EPA) decision to deny several oil refiners’ SRE petitions. The second petition asserts Growth Energy’s standing to challenge EPA’s decision to excuse some of those same refiners from RFS biofuel blending obligations.

“These petitions are consistent with how the RFS should work,” said Growth Energy CEO Emily Skor. “Congress clearly intended for SREs to provide rare relief for refineries, and only those seeking to comply in good faith with their RFS blending obligations. If the D.C. Circuit’s opinion stands, guardrails to ensure good faith compliance will disappear, allowing refineries to gamble on RIN markets, pocket any windfalls, and lean on the U.S. government when those gambles don’t go their way.”

Skor stated further that it’s clear that Growth and other biofuels producers have standing to participate in RFS disputes, including disputes about SREs. “Every SRE granted by EPA directly and negatively impacts biofuels blending, biofuels production, and our industry’s bottom line,” she added. “That type of competitive injury can’t be ignored, and we deserve to be able to protect our members’ interests in court.”

Read the first petition here and the second one here.

The post Growth Energy Files Two Petitions for Rehearing on Refinery Exemption Decisions appeared first on Growth Energy.

However, tariffs, technical trade barriers, and inaccurate carbon intensity scores pose challenges to U.S. exporters looking to satisfy growing biofuel demand across the globe. They also disadvantage U.S. farmers by closing off potential markets. This must be addressed

The post Trade: Eliminate Barriers for U.S. Ethanol appeared first on Growth Energy.

In his opening remarks before the groundbreaking, Conestoga CEO (and current Growth Energy Chairman) Tom Willis called on attendees to “remember today.”

“This is a day where western Kansas goes from producing natural gas energy, to the start of producing sustainable aviation fuel with our partner SAFFiRE,” he said. “This is transformational for western Kansas. This is transformational for the airline industry. This is transformational for agriculture and the value that it brings. It started here.”

Skor echoed Willis in her remarks, saying that the Conestoga and SAFFiRE plant “has the potential to be a big step for Kansas—and a huge leap for the entire biofuels industry.” She also called on policymakers to help support the project through the 45Z clean fuel production tax credit, for which guidance from the U.S. Treasury is still pending.

“SAF is a multi-billion-dollar opportunity,” she added. “Getting to that future will take all of us. It will take innovators like Conestoga and SAFFiRE. It will take policymakers like our champions here today, creating the right conditions and sending the right market signals. That means a 45Z clean fuel production credit that allows rural America to prosper at the speed of innovation, not the snail’s pace of bureaucracy.”

Growth Energy congratulates both of our members—Conestoga and SAFFiRE—for this exciting and potentially game-changing development for the future of cellulosic biofuel and SAF. You can read more about the plant on Southwest Airlines’ website (SAFFiRE Renewables is a wholly-owned subsidiary of Southwest).

The post Growth Energy Members Conestoga and SAFFiRE Break Ground on New Corn Stover Bioethanol Plant appeared first on Growth Energy.

“The [economic impact analysis] (EIA) acknowledges potential direct and indirect land use change (LUC) ‘is at least partially (and potentially fully) accounted for by the LUC scores added to crop-derived pathways,’” said Growth Energy Senior Vice President of Regulatory Affairs Chris Bliley in the comments. “This acknowledgement renders the need for a sustainability certification moot as potential LUC concerns for crop-based feedstocks are addressed.” 

Furthermore, farmers that produce corn and other crops used in the production of biofuels would be required to use climate smart agriculture practices to qualify for the “sustainability certification.” However, those same farmers would still not receive any credit for the emissions-reducing impact of deploying those practices under the LCFS. 

“While the most recent proposal details the ‘best environmental management practices’ required for biomass used in fuel pathways, and those CSA practices result in the reduction of carbon emissions, CARB continues to disregard these and other practices when factoring carbon intensity (CI) scores,” Bliley added. “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,” Bliley added. “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.” 

Read more about the sustainability certification and climate smart agriculture in the full comments as submitted here. 

The post Growth Energy: California LCFS Updates Stack the Deck against American Biofuels appeared first on Growth Energy.

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.

Few topics received as much attention as the 45Z clean fuels credit, which is slated to take effect in 2025. The credit was signed into law two years ago, and will become the primary incentive for the production of low-carbon fuels in transportation on the ground and in the air.

Properly implemented, 45Z could unlock major new investments in Sustainable Aviation Fuel (SAF), climate-smart agriculture, and other low-carbon innovations. That’s why Growth Energy has been working hand-in-hand with our leaders on Capitol Hill to ensure that the Biden Administration gives producers and our farm partners the certainty and flexibility we need to find the path that works best for American agriculture.

Speakers on hand who echoed that message included Jolene Riessen, President of the Iowa Corn Growers Association, and Steve Sukup, President and CEO, Sukup Manufacturing – a Growth Energy member.

For more insights from these witnesses — and our allies in Congress — check out some highlights below.

Rep. Zach Nunn: “I am proud that on day one as a freshman, I went against the establishment to make sure we fought for key tax credits that impact our state. Working with this team here, we held together that we made sure that biofuels were part of America’s energy solution and our national security solution.

Rep. Randy Feenstra: Right now, over 50% of our crop, corn and soybeans, goes to biofuels. Right now, if you look at our commodity prices, corn is under $5 and soybeans are under $10. Now, we could export more or we could use more of it. How do you use more? You do it through biofuels, ethanol, and biodiesel. To do that, we have to grow our markets through sustainable aviation fuel and other things. So I want to talk about 45Z. This is a tax credit that can dramatically expand markets. Right now, we have a thumb on the scale for electric vehicles and not liquid fuels. This gives us an opportunity to compete. And if we don’t, we’re going to probably see our commodity prices cut nearly in half again. Ms. Riessen can you talk about this?

Jolene Riessen: That 45Z is going to be a gamechanger for us when it comes to grain price. With 45Z, consumers are asking for low-carbon, so, one way of doing that is through carbon sequestration and 45Z helps ethanol plants get set up to be able to do that. When we do that, my corn goes to that ethanol plant, and we make better markets and prices.

In a recent study I saw, for every dollar invested in 45Z, it will return $4-$6.

Rep. Randy Feenstra: When our farmers are successful, our main streets are successful, our hospitals are successful, our schools, everything is successful.

Rep. Darin LaHood: I mentioned that I have a heavy ag district, and the potential economic growth around the biofuels industry. Again, I have been very engaged and spent a lot of time talking about it. As we look to future tax policy proposals, can you comment on the specific pro-growth initiatives that can better support our farmers and biofuel producers?

Steve Sukup: Well, practically one of every two rows of corn goes to biofuels. It provides us with energy self-sufficiency here in the U.S., which I think is absolutely critical and it can provide, going into 45Z, more incentives to reduce carbon emissions.

Rep. Nicole Malliotakis: Can you talk as farmers about how energy drives up the cost of food for the people I represent in New York? And also maybe you want to touch on some of the renewable energy sources that we can derive from corn?

Jolene Riessen: Ethanol is available – and you can put it right in the gas tank. We are pushing for the Next Generation Fuels Act to be passed to increase the amount of ethanol in the tank. This is from the American Lung Association, for every percent of ethanol that we are able to put into that fuel tank, we are also reducing our healthcare costs because we are taking particulates out of the air.

Steve Sukup: Biofuels are critical across the U.S. for energy efficiency and self-sustainability. That is what we have to increase. It lowers prices throughout.

The post On Display at the Iowa State Fair: Benefits of Biofuel Tax Credits appeared first on Growth Energy.