Growth Energy strongly advocates for the role low-carbon biofuels and higher biofuel blends can play in Minnesota’s efforts to reduce the carbon intensity of transportation fuels used in the state. A primary solution for decarbonizing the liquid transportation fuel supply is the promotion of additional use of bioethanol. Bioethanol has a proven history of contributing to greenhouse gas (GHG) reductions in an existing low carbon fuel standard (LCFS): according to the Transportation Energy Institute, bioethanol is responsible for 31 percent of GHG reductions in California’s Low Carbon Fuel Standard (LCFS), the largest percentage among fuel sources.

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

Today, nearly all gasoline in Minnesota – and across the United States – 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. This accounts for more than 96 percent of the vehicles on the road today and is now sold at more than 3,400 locations in 31 states. Minnesota currently has 460 fuel retail sites offering E15.

Last summer E15 was sold at a nationwide average of 15 cents less per gallon where available and in some Minnesota locations, we saw E15 selling for as much as 33 cents less per gallon than regular gasoline – that is meaningful consumer cost-savings. Minnesota is already on its way to embracing the environmental and economic benefits of E15. In 2021, Minnesota had the highest bioethanol blend rate, 12.6 percent, in the country.

Beyond its capacity to deliver GHG reductions, E15 provides significant improvements in air quality. Research conducted by the University of California, Riverside found that the use of more bioethanol and bioethanol-blended fuel reduces emissions including harmful particulates and air toxics such as carbon monoxide and benzene. This study illustrates the vital role that higher ethanol blends play in protecting our air, our climate, and our health.

Given Minnesota’s status as a leader in bioethanol production and utilization, we would like to take this opportunity to raise several concerns with SF 2584. Notably, the Argonne National Laboratory’s Greenhouse Gases, Regulated Emissions, and Energy Use in Transportation (GREET) model uses the most up to date data and science to calculate fuels’ lifecycle GHG emissions. Modifying GREET for a clean transportation standard in Minnesota risks ignoring important GHG reductions among various fuel pathways. This could result in a clean transportation standard that contradicts the legislation’s stated commitment to fuel and feedstock neutrality.

Additionally, among SF 2584’s text is an unfair land use change (LUC) penalty for crop-based biofuels, namely that the standard “include a non-zero emissions factor reflecting indirect land use change for cropland-derived fuels, not less than the emissions factor derived from the Argonne GREET model.” We believe 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. A review of more recent science over the last five years indicates a decreasing trend in land use values, with the newer data indicating LUC values closer to 4gCO2e/MJ, far less than the outdated and erroneously inflated LUC value used in other states’ standards. Minnesota’s modeling and LUC value should reflect the latest science that better addresses innovation and increasing yields in agriculture.

We applaud the Minnesota Legislature for their efforts and consideration of methods to reduce GHG emissions in the state. SF 2584 contains provisions that will aid the Transportation Commissioner in implementing a fuel-neutral standard that, among other requirements, “creates broad rural and urban economic development.” Given Minnesota’s leadership in agriculture and biofuel production, if implemented properly, we believe this program could provide significant benefits for in-state bioethanol production. Yet we remain concerned about the lack of precision regarding the clean transportation standard’s implementation. Stakeholders representing a broad array of transportation-related and environmental groups convened over several months in 2023 for the Clean Transportation Standard Working Group. The group’s final report demonstrated the complexities surrounding the implementation of a clean transportation standard. We believe the committee should consider the realities of this complexity and the diverse interests of the advisory committee prescribed in SF 2584. We recommend a stronger commitment to ensure a truly technology-neutral standard as well as stakeholder engagement in the promulgation and implementation of the state’s clean transportation standard.

The consideration of biofuels, particularly bioethanol, is a crucial component to a clean fuel standard, one that can have an immediate impact on carbon emissions reductions as future decarbonization technologies are developed. We hope the committee recognizes the role bioethanol can play in reducing GHGs, providing a more cost-effective option for consumers, and helping Minnesota meet its ambitious decarbonization goals. We look forward to further engagement with the committee and are available to answer any technical questions that may arise.

The post Growth Energy Testimony on Minnesota Clean Transportation Standard Proposal appeared first on Growth Energy.

Growth Energy’s comments below focus on the IRS’ proposed application of the Greenhouse gases, Regulated Emissions, and Energy use in Transportation model (commonly referred to as the “GREET model”) for calculating the lifecycle emissions of hydrogen. Similar to the IRA’s provisions on SAF and clean fuel qualification, Section 45V establishes certain lifecycle GHG emissions standards in order to qualify as “clean hydrogen.” Section 45V provides that lifecycle emissions will be “determined under the most recent [GREET] model developed by Argonne National Laboratory, or a successor model (as determined by the Secretary). In the proposed rule implementing the Section 45V tax credit, the IRS interprets “most recent GREET model” to mean “the latest version of 45VH2–GREET developed by Argonne National Laboratory (ANL) that is publicly available on the first day of the taxpayer’s taxable year in which the qualified clean hydrogen for which the taxpayer is claiming the section 45V credit was produced.” The 45VH2-GREET model is, however, a successor GREET model modified specifically for this context and distinct in various features from the GREET model for calculating hydrogen’s lifecycle emissions in existence when the IRA was enacted.

As explained further below, a proper interpretation of the IRA demonstrates that Congress’ intent was for the Argonne GREET model used for over a decade before enactment of the IRA, and which is annually updated in accordance with new science and data, to be the “most recent GREET model” referenced by the statute. The 45VH2-GREET Model is a successor model, and as such, must adhere to the best available science for calculating lifecycle GHG emissions consistent with the function and principles of the original Argonne GREET model. These foundational principles are similarly applicable to deployment of any 40B-GREET and 45Z-GREET model the
Department of Energy may develop and IRS may require. Doing so will not only ensure adherence to the IRA and the accuracy of the lifecycle analysis, but also create stability and certainty regarding the significant investments being made in low-carbon energy and fuel sources.

…

Growth Energy appreciates that the IRS requests comment on the 45VH2–GREET model in the proposed rulemaking on the 45V hydrogen tax credit. We urge the IRS to provide a similar opportunity to comment on any other “successor” GREET model contemplated for use in the Section 40B and 45Z tax credit contexts. Doing so would ensure that stakeholders, such as Growth Energy’s members, are provided a full and fair opportunity to be heard on such a critical regulatory decision affecting their businesses.

Growth Energy appreciates the IRS’s consideration of this input as it finalizes the 45V hydrogen tax credit regulations and would welcome the opportunity to provide comments on behalf of its members regarding future rulemakings to implement the 40B and 45Z credits. We look forward to engaging further on this important work and would be happy to meet with your staff to present on these issues in more detail and answer any questions.

The post Growth Energy Comments on IRS’ Proposed 45V Hydrogen Regulations appeared first on Growth Energy.

Growth Energy highlighted just some of the proven emissions benefits of biofuels like ethanol in its comment, while also noting that NHTSA’s proposed standards may violate the Energy Policy and Conservation Act (EPCA), in particular the law’s prohibition on using electric vehicles (EVs) as a “baseline” to set fuel-economy standards and the law’s focus on using domestic energy sources to address America’s energy challenges.

“In setting the CAFE Standards, NHTSA is directed by EPCA to consider, among other factors, ‘the need of the United States to conserve energy.’ Increasing the nation’s use of biofuels meets that goal, by both providing another source of fuel that reduces our demand for petroleum and by reducing greenhouse gas (GHG) and other emissions,” said Growth Energy in its comments. “To begin with, ethanol and other biofuels significantly enhance energy security because of their flexibility—they can be used in existing internal combustion engine (ICE) vehicles and fueled at existing gas stations.  Consumers and operators of fleets around the country therefore have the ability to use more biofuels.”

To address its issues with the proposal, Growth Energy recommends that NHTSA remove EVs from its calculations in setting a baseline for the 2027-2032 CAFE standards; consider the GHG-reduction and energy security benefits of biofuels throughout the final rule; and preserve and expand its rules to allow for greater use of higher ethanol-blended fuels like E15 (15% ethanol), E85 (51%-85% ethanol), and other blends in between.

Read Growth Energy’s full comment here. The organization also expressed similar concerns to the U.S. Environmental Protection Agency (EPA) about its vehicle tailpipe emissions standards earlier this year. Learn more about Growth Energy’s actions on this topic at growthenergy.org/tailpipe-emissions.

The post Growth Energy to NHTSA: Biofuels Must Be Part of CAFE Standards appeared first on Growth Energy.

Given the objective to reduce carbon emissions from the transportation sector, waiting for the market to transition to ZEVs without seeking solutions for the dominant powertrain on the roads is a strategy which ignores the substantial reductions which can be achieved in current and future ICEVs. Embracing strategies to reduce carbon emissions from the nearly 300 million ICEVs that will continue to operate in the U.S. for the next several decades is imperative.

Fortunately, total lifecycle, as well as tailpipe, emissions reductions are already being achieved by increasing use of biofuels and reducing the carbon intensity of the fuel mixtures used in ICEVs. Additional near-term steps to reduce the carbon intensity of fuels will play a critical role in limiting the expected increase in cumulative mobile source greenhouse gas (GHG) emissions. ICEV technologies and the associated fuels can continue to be employed over broad and energy-intensive transportation applications while making substantial contributions to near- and long-term GHG emissions reductions. In fact, substantial reductions in GHG emissions from LDVs in the near term can only be achieved by reducing emissions from ICEVs.

Stillwater Associates was engaged by the Transportation Energy Institute to identify and analyze the potential opportunities to expand on this critical GHG-reduction strategy. In this report, we examine the benefits achievable through the decarbonization of the existing on-road U.S. ICEV fleet given the extended timeframe which will be required to transition that fleet to ZEVs.

The post Decarbonizing Combustion Vehicles: Transportation Energy Institute appeared first on Growth Energy.

• The economic effect of the RFS on corn prices and acres planted in corn.
• The causal linkage between the RFS and LUC.
• Wetlands, ecosystems, habitat, and wildlife.
• Soil and water quality and water quantity.

Overall, our research concludes that the studies conducted by the EPA (2022b), Taheripour et al. (2022a), and Austin et al. (2022), are more representative of the likely effects of the implied conventional volume and ethanol production on corn prices and corn acres planted than are the results of Lark et al. (2022). The methods used by the EPA (2022b) and Taheripour et al. (2022a) account for effects of the global and domestic economies. The methods we use in this report, although high level, are based on 18 years of observed data. The results of our analysis confirm that the implied conventional volume has minimal to no effect on corn prices and acres of corn planted, consistent with the work by the EPA (2022b) and Taheripour et al. (2022a).

The post Review of EPA’s Proposed RFS Standards for 2023-2025 appeared first on Growth Energy.

Meeting the requirements of the Act is possible by grouping the GHG reductions options from dry mill ethanol plants into categories that are readily verified. This document reviews the GHG analysis for corn ethanol in GREET and identifies leading options to reduce GHG emissions and their corresponding effect on life cycle GHG emissions.

• Typical Dry Mill Ethanol Plant
• Carbon Capture and Sequestration
• Renewable Power
• Renewable Natural Gas
• Low Carbon Ammonia
• Manure Application
• Fertilizer Usage, including Bio-based Fertilizer
• No Till Farming
• Cover Crop

Each of these emission reduction options is represented in the GREET model and fuel producers could identify a combination of ethanol plant operation and corn farming parameters that are consistent with the GHG emission thresholds of the IRA to calculate their life cycle GHG emissions. Readily available GREET results for corn ethanol plant operation could be used by fuel producers to demonstrate GHG reductions under Section 45Z.

The post GHG Analysis of Dry Mill for Corn Ethanol Production under IRA appeared first on Growth Energy.

The primary objective of this program is to better understand the impact of increasing ethanol blending on gaseous and particulate emissions from current gasoline direct injection (GDI) and port fuel injection (PFI) light-duty vehicles in California. For this project, two fuels, namely an E10 and E15, were tested on twenty 2016 and newer modern gasoline fueled vehicles over triplicate FTP cycles. Measurements included regulated emissions, fuel economy, PM mass, particle number, black carbon, and emissions of benzene, toluene, ethylbenzene, xylene isomers, 1,3-butadiene, ethanol, and carbonyl compounds.

The post Comparison of Exhaust Emissions Between E10 and Splash Blended E15 appeared first on Growth Energy.

Overall, we find that the life-cycle fuel model updates developed by Life Cycle Associates (LC Associates) largely follow the existing precedent set by the California Air Resources Board (CARB) in its comprehensive life-cycle assessment (LCA) established in the California Low-Carbon Fuel Standard (LCFS). The changes made within WA-GREET to tailor it to Washington state-specific data on fossil fuel consumption and electricity production are largely aligned with existing life-cycle assessment practices and are consistent with the intended scope of the Washington Clean Fuels Program (WA CFP). We present a high-level summary of five key fuel pathways’ emissions in Figure 1, illustrating the difference in their carbon intensity calculated for Washington in WA-GREET against values calculated for California’s LCFS using CA-GREET. The most impactful changes in the Washington analysis are the inclusion of a Washington state-average carbon intensity for electricity (resulting in a 20% decrease in electricity grid carbon intensity relative to California), and the proposed use of a different ILUC emission factor for corn ethanol (a 17.5% decline in default corn ethanol carbon intensity relative to California). Changes to the crude oil carbon intensity were much smaller, with less than 1% difference compared to California petroleum products. Throughout this peer review, we document that there are several assumptions made in the analysis or omissions based on data gaps that affect the emissions estimates for petroleum products and electricity, and offer several recommendations on addressing those data gaps and developing more accurate estimates.

The post Washington Clean Fuels Standard – Carbon Intensity Model Peer Review appeared first on Growth Energy.

In general, the presentations kept to the presenter’s area of research and did not provide a direct review of the GHG emissions of biofuels in relationship to the EPA’s 2010 regulatory impact analysis (RIA) (EPA, 2010) or revised 2022 draft RIA. While reviewing these areas of research in isolation is an interesting exercise that is helpful for furthering the science over the long term, for EPA to “incorporate the best available science into an update of our lifecycle analysis (LCA) of biofuels” EPA will need to consider how to bring these research areas together into a holistic analysis.

The workshop focused primarily on issues related to land use conversion (LUC). Other LCA topics relevant to the analysis of biofuels including reassessment of the 2005 petroleum baseline, petroleum production and its impact on biofuels, natural gas and electric power were not part of the workshop discussion.

The opinions in this report are based on attendance of the workshop as well as extensive prior work on the GHG emissions of biofuels, including a February 2022 Report on Review of GHG Emissions of Corn Ethanol under the EPA RFS2 submitted as comment to the 2020‐2022 RFS Annual Rule.

The post Review of EPA Workshop on Biofuel Greenhouse Gas Modeling appeared first on Growth Energy.

EPA developed a consequential LCA approach that estimated the emissions associated with the incremental ethanol capacity induced by the RFS policy as well as the incremental crop production required to make up for the net effect of corn crops diverted to ethanol production and distiller’s grains sold as animal feed. The modeling approach involved a combination of the FASOM model that has been used to develop the U.S. inventory for agricultural emissions, the FAPRI model, which estimates the effect of the use of agricultural products on global agricultural production, and the GREET model, which estimates life cycle GHG emissions from the fuel used in ethanol plants. EPA’s analysis aligned the economic modeling of the FASOM and FAPRI modeling and calculated emission impacts that are tied to the model predictions including changes in rice and beef consumption as well as deforestation associated with new crop production.

The 2010 RIA overestimated the GHG impact of corn ethanol due largely to overestimating indirect land use conversion (ILUC) emissions as well as numerous small details associated with the life cycle of corn ethanol. EPA’s agro-economic models rely on economic projections to attribute land use change to crop production without considering factors such as changes in farming and cattle production practices. Recent data on deforestation has shown that land ownership is much more important in affecting deforesting than the macro-economic pressure or crop prices. Burning in the Amazon has declined and increased due to policies associated with land ownership. A more accurate representation of the effect of crops on pasture conversion is represented in more recent publications based on the GTAP model and EPA would generate similar results if its ILUC modeling tools included an accurate representation of factors such as flexibility in changing cattle stocking rates. The analysis inputs to GTAP modeling would yield similar results in the FASOM/FAPRI modeling system. If EPA continues to use the FAPRI results for its international LUC analysis, the results could be scaled to reflect the values from GTAP that more accurately represent the interaction between pasture and cropland.

Several other factors affecting corn ethanol have also changed since the publication or the 2010 RIA. Corn ethanol uses about 0.7 kWh to produce one gallon of ethanol and the GHG intensity of electric power has declined substantially with increased natural gas production, a reduction in coal-based power, and growth in renewable power. The RIA also underestimated the adoption of low emission technologies that have resulted in lower emissions from ethanol plants and many small details associated with each step of the ethanol life cycle.

The post Review of GHG Emissions of Corn Ethanol under the EPA RFS2 appeared first on Growth Energy.