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.

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

Environmental and Economic Value of Bioethanol

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

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

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

Use of GREET for Life Cycle Analysis Modeling

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

Reject Caps and Sustainability “Guardrails” on Biofuels

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

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

Expanding E15 and Higher Blends

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

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

Recognizing Carbon Capture and Other CI Reduction Methods

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

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

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

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

Sustainable Aviation Fuel (SAF)

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

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

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

Thank you for the opportunity to respond to the most recent request for information (RFI) regarding strategies to decarbonize America’s industrial sector. Growth Energy is expanding the bioeconomy and is the nation’s largest association of biofuel producers, representing 97 U.S. plants that each year produce 9.5 billion gallons of low-carbon, renewable fuel; 120 businesses associated with the production process; and tens of thousands of biofuel supporters around the country. Our members make low-carbon fuels and high protein animal feed and supply plant-based ingredients for everything from bioplastics to safer cleaning products.

As we have noted in other venues, U.S. leadership in the global sustainable biofuels markets is vital to decarbonization and future economic competitiveness in the on-road, aviation, marine shipping, and off-road sectors, in addition to the industrial sector, and biofuels are the best tool available to do so. While our members are primarily focused on transportation fuels, we are exploring other opportunities throughout the bioeconomy that could provide an outlet for our low-carbon biofuels and other key coproducts to compete
and help drive down greenhouse gas emissions. As such, we are happy to be a resource for the Department as it examines potential opportunities for further decarbonization in the industrial sector.

The industrial sector accounts for one third of greenhouse gas (GHG) emissions and requires a diverse and complex set of energy inputs, processes, and operations. While historically decarbonization has been more focused on the transportation sector, it is important to recognize biofuels and other bioproducts that would help reduce GHG emissions from the industrial sector as well. Importantly with any market for biofuels and bioproducts, the agency needs to think about scalability and reliable supply. The U.S. has
the largest and most developed biofuels industry in the world. Over the past 20 years, U.S. fuel ethanol production has grown from 2.1 billion gallons/year to 15.4 billion gallons/year. During this time, there has been no observable increase in corn acres planted or related adverse impacts on food prices. Instead, increases in corn demand have consistently been met by increased yield as agricultural practices have become more efficient over time.

Our members produce bioethanol today primarily for on-road fuel, but it is also used in some chemical and other industrial settings. Today, all engines (both on-road and off-road) are approved for use with gasoline blended with 10 percent bioethanol while all 2001 and newer passenger vehicles are approved for gasoline blended with 15 percent bioethanol alongside flex-fuel vehicles that are approved for all bioethanol blends up to E85. Our industry can also provide bioethanol in the future as a feedstock for sustainable aviation fuel as well as for other biochemicals. Additionally, our members produce distillers corn oil (DCO) as a coproduct that is then used as a feedstock for both biodiesel and renewable diesel which can be used to power numerous industrial engines. And as our members broaden the use of carbon capture, utilization, and storage (CCUS) technology, some are exploring the potential for fuels and other products produced from a nearly pure stream of captured carbon dioxide.

The U.S. biofuels industry continues to prove its ability to lower GHG emissions and deliver jobs and economic benefits to American workers and farmers. Extensive research from the Department’s own Argonne National Laboratory through its Greenhouse Gases,
Regulated Emissions, and Energy Use in Technologies (GREET) model has shown that today’s bioethanol provides a nearly 50 percent reduction compared to gasoline in lifecycle GHG emissions and can get to net-zero emissions with the use of readily available technologies such as CCUS. The biofuels industry has also helped to create hundreds of thousands of jobs here in the United States and provides a stable market for American farmers while continuing to reduce prices at the fuel pump for the on-road fleet.

Lower-carbon fuels and bioproducts will require scalability, highlighting the need for and importance of a stable policy environment. The federal Renewable Fuel Standard (RFS) is foundational to the entire U.S. biofuels industry and its ability to provide a variety of fuels and feedstocks for use across transportation sectors. Any expanded use of biofuels for off-road use will require a strong and growing RFS.

Additionally, the U.S. Department of the Treasury is in the midst of implementing several key tax biofuel tax incentives including the Clean Fuel Production (45Z), Carbon Capture (45Q), and Sustainable Aviation Fuel (40B) credits. These provisions are critical to our industry’s capital-intensive investments to reduce greenhouse gas emissions and ultimately to the achievement of the administration’s broad climate goals, including the SAF Grand Challenge and the potential to get to net-zero by 2050. As we have articulated in multiple comments to Treasury (available here, here, here, and here), it is essential that the Argonne GREET model be used for any lifecycle emissions assessment as it is the best tool available for measuring biofuel lifecycle emissions. In fact, earlier this year, EPA highlighted that “the GREET model is well established, designed to adapt to evolving knowledge, and capable of including technological advances.” Also, implementation of these credits must allow for a wide range of carbon intensity reduction strategies including, but not limited to, CCUS technologies and projects, renewable power, and many emerging farm and agricultural practices. From our previous comments, below is a table of possible reductions of carbon intensity at our bioethanol plants. Any meaningful goals for the use of crop-based biofuels for the industrial or other hard to decarbonize sectors cannot be achieved without the use of the Argonne GREET model and recognition of a variety of carbon intensity reduction strategies.

Thank you for your consideration and we are happy to be a resource as the Department further explores the potential for broader bioethanol use in the industrial sector.

The post Growth Energy Provides Comments to DOE RFI on Decarbonizing Industrial Sector appeared first on Growth Energy.

My name is Dallas Gerber, Director of State Government Affairs for Growth Energy. We are the world’s largest association of bioethanol producers, representing 97 producer plants, including 5 plants here in Ohio, and 119 businesses associated with bioethanol production. Collectively, our members produce more than 9.5 billion gallons of cleaner-burning, affordable fuel. Together, we are committed to bringing better and more affordable choices at the pump for consumers, helping our country diversity our energy portfolio, creating more energy jobs, and sustaining family farms.

Producing ethanol provides a nearly threefold increase from the energy put into production with increasing plant efficiency and a growing suite of coproducts. Our industry simply takes the starch from the kernel of corn turning it into bioethanol, while the rest of the fat, fiber, and protein continues into nutrient-rich animal feed, corn oil which is used for additional biofuel production, and carbon dioxide, which is captured for commercial food and beverage use.

Today, 98 percent of all gasoline sold in the United States contains 10 percent bioethanol. E15— a fuel containing up to 15% bioethanol—is approved for use in all vehicles model year 2001 and newer. 96% of the vehicles on the road today can run on E15. Consumers across the country have now driven 100 billion miles on E15. There have been no adverse reports on fuel quality experienced with E15 since first being approved in 2011.

While E15 is available at more than 3,400 retail locations in 33 states, Ohio is falling behind. There are only 144 retail locations selling E15 in the state. That is around 2 percent of all stations in Ohio are selling E15. Compare that to Minnesota which has nearly 500 locations selling E15 or Wisconsin which has at least 350 locations.

We believe this legislation would provide an important, and temporary, tax credit to incentivize E15. Specifically, the bill’s nonrefundable 5 cent per gallon tax credit for fuel retailers who offer E15 helps Ohio compete with other Midwest states that are expanding E15 offerings through similar means.

While Ohio ranks 7th in bioethanol production in the United States, recent data shows it is second to last in term of statewide bioethanol blend rates. The only state with a lower blend rate is Alaska, which has zero bioethanol. Simply put, Ohio is not utilizing an Ohio-grown product that will help reduce fuel costs for drivers. For instance, at the relatively few retailers offering E15 in the state, Ohio drivers saved an average of 16 cents per gallon during the summer of 2023. In some instances, drivers even saved as much as 40 cents per gallon.

This temporary credit is important to ensure retailers that Ohio’s E15 market will continue to build out and invest in additional infrastructure, helping position Ohio for the future. It provides an opportunity to increase the domestic market for Ohio’s corn growers, who face the prospect of a 25% decline in farm income according USDA forecasts. Incentivizing E15 allows Ohio-grown corn to become affordable fuel for Ohio drivers, who would be saving several multiples of the temporary 5 cent incentive for every gallon of E15 they purchase.

The increased usage of ethanol also results in the availability of more nutrient-rich animal feed, an important co-product in the bioethanol production process, to the benefit of Ohio livestock farmers.

When the economic benefits to the consumer, and downstream benefits to the agriculture and bioethanol industries are considered in combination with there being no negative impact on Ohio’s fuel tax revenue, this proposal does not impact the state’s bottom line. As more states implement or consider similar incentives, we believe it is important Ohio does the same, thus ensuring a product made in Ohio using corn grown in Ohio can benefit Ohio consumers with lower prices at the pump for many years to come.

Thank you for your time, and I will be happy to answer any questions the committee may have.

The post Growth Energy Provides Testimony at Ohio Retail Tax Incentive Hearing 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.

We appreciate the opportunity to provide written testimony for S2930, which provides a tax credit for individual taxpayers who convert their gas-powered vehicle into a vehicle propelled by an alternative fuel source. Growth Energy strongly supports legislation that incentivizes the expanded use of fuels with higher blends of bioethanol. We applaud Rhode Island’s efforts to reduce greenhouse gas (GHG) emissions in the state’s transportation sector. Biofuels can play a major role in those efforts, as bioethanol emits 46% fewer GHGs compared to gasoline. Bioethanol’s other environmental benefits are also noteworthy. As has been researched by the University of California, Riverside and the University of Illinois at Chicago, the use of more bioethanol and bioethanol-blended fuel reduces harmful particulates and air toxics such as carbon monoxide, and benzene. In other states, where market-based solutions were implemented, e.g. California’s Low Carbon Fuel Standard, biofuels such as bioethanol have been among the largest contributors to GHG reductions.

And with as many as 780,000 vehicles in the state capable of fueling up with E15, a more affordable fuel containing up to 15% bioethanol approved by the US EPA in 2011 for vehicles model year 2001 and newer, even those vehicles without having converted their engine can contribute to GHG reductions. Additionally, vehicles capable of running on E85 number more than 43,000 in the state.

More than 100 billion miles has been driven on E15 in the United States since its approval by the EPA. Additionally, in California alone, more than 118 billion gallons of E85 fuel was sold in 2023. These fuels are being embraced by drivers across the country.

Not only would E15 adoption provide considerable environmental benefits for the state, but Rhode Island drivers would also enjoy lower fuel costs. During the summer of 2023, consumers across the United States saved an average of 16 cents per gallon of E15 compared to E10. In some instances, consumers saved anywhere from 33 to 60 cents per gallon.

Rhode Island has an opportunity to utilize bioethanol as an important GHG reduction tool. If the state replaced E10—the most common blend of gasoline sold in Rhode Island—with E15, nearly 50,000 tons of GHGs emissions would be avoided. This is the equivalent of removing nearly 11,000 vehicles from the roads, all without impacting a single Rhode Island driver.

Unfortunately, despite these readily available fuels being used across the country, there are zero retail fuel sites in Rhode Island offering either E15 or E85. As the Senate Finance Committee considers S2930, an important bill that incentivizes Rhode Island drivers to adopt environmentally beneficial transportation fuel sources, we encourage the legislature to consider the positive environmental impact of expanding the use of biofuels. While many legacy vehicles owners could take advantage of this tax credit by modifying their vehicle to run on E85, the lack of retail fuel sites in Rhode Island offering E85 discourages those owners from utilizing this opportunity to contribute to the reduction of GHGs.

We respectfully urge the General Assembly to consider policies that encourage the expanded use of fuels with higher blends of bioethanol, as legacy vehicles are expected to be on the road for many years. Expanding access to higher bioethanol blends allows these vehicles to contribute to GHG reductions immediately as future technologies are adopted.

The consideration of biofuels, particularly bioethanol, is a crucial component to carbon emissions reductions as future decarbonization technologies are developed. We hope the committee recognizes the role fuels with higher blends of bioethanol can play in reducing GHGs and providing a more affordable option for Rhode Island drivers. Thank you and we look forward to any questions you may have.

The post Growth Energy Testimony on Rhode Island Alternative Fuel Legislation 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.

Approval of E15
We applaud the California Air Resources Board’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 32 states. Since then, drivers in America have relied on E15 to drive 100 billion miles.

As producers of one of the most scalable feedstocks for SAF production, we appreciate the Board’s attention to development of this key market through its proposal to remove the exemption for intrastate jet fuel. 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 April 10th, 2024 workshop. 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 Comments on California’s Proposed LCFS Amendments 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 Oregon’s ambitious climate goals. We appreciate the opportunity to provide further comments on the proposed rulemaking and how expanded E15 use can help the state achieve its objectives.

Consideration of Sustainability Certification

In response to the April 17th CFP’s Rulemaking Advisory Committee meeting, we request the Department not consider the proposal on sustainability certification for crop-based biofuels currently under consideration by the California Air Resources Board (CARB). We have a variety of concerns with the proposal, which we have detailed in comments to CARB. The proposal’s sustainability certification for crop-based fuels cites concerns regarding land use change (LUC) factors that 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%.

Additionally, the LUC concern is already addressed in the 2024 Clean Fuels Program and its carbon intensity (CI) modeling. Corn starch bioethanol is given an automatic 7.6 gCO2e/MJ penalty for indirect land use change (ILUC). Adding the proposed sustainability criteria to the current ILUC score amounts to an unfair double penalty for corn starch bioethanol. We also believe the 7.6 gCO2e/MJ penalty 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.

Further, the proposed sustainability certification will add onerous and costly requirements on biofuel producers and farmers. Yet CARB’s economic analysis of the proposal does not discuss the sustainability requirement’s financial burden of implementation. Nor will the requirement allow bioethanol producers to use important tools like climate-smart agricultural practices for CI reduction. 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.

Finally, with respect to CARB’s proposed sustainability audit, the proposal’s audit requirements address issues, while important to environmental and social justice, fall outside the scope of the LCFS. 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.” These items have no bearing on GHG reduction. Furthermore, if the proposal is adopted, crop-based biofuels would be the only feedstock for which these criteria would be audited.

Carbon Capture and Sequestration

New innovations at biorefineries throughout the United States 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 appreciate DEQ’s leadership on the issue of carbon capture utilization and sequestration (CCUS) and the approval of Red Trail Energy LLC’s Tier 2 application including CCUS last year. We encourage DEQ to continue broad allowance for credit generation from CCUS.

We applaud DEQ’s efforts to recognize the value of carbon emissions reduction via CCUS. We also understand and appreciate that DEQ will accept pathways with non-onsite CCUS approved or recertified by the California Air Resources Board, we request DEQ works to ensure all CCUS operations remain eligible for CI crediting by maintaining current eligibility provisions. Restricting CI crediting only to on-site sequestration prevents the vast majority of biorefineries from benefiting as most plants’ locations do not have the geology necessary for Class VI CO2 injection wells. Many of these bioethanol facilities will eventually be utilizing CCUS via a CO2 pipeline.

Whether on-site or transported safely via pipeline to be sequestered elsewhere, carbon dioxide is removed from the atmosphere and contributes to the emissions reduction benefits of bioethanol. Those facilities should not effectively incur a penalty due to the geology of their location when other CCUS opportunities remain.

Expanded Use of E15 and Higher Blends

We applaud Oregon allowing the sale of E15, gasoline containing up to fifteen percent ethanol, in 2021. We encourage the state to adopt policies that encourage the expanded use of E15 as well as higher blends such as E85. More than 96% of all vehicles on the road today can take advantage of E15, which if replaced E10 statewide, would result in more than 190,000 tons in GHG reductions. This is the equivalent of removing more than 41,000 vehicles off Oregon’s roads without impacting a single driver.

Additionally, E85 is currently available at only five sites in the state. With an existing fleet of more than 186,000 Flex Fuel vehicles (FFVs), Oregon can utilize E85, which will promote even greater reductions in GHG emissions in addition to reductions in air toxics.

We encourage Oregon to incentivize the use of FFVs and invest in infrastructure expanding access to E85 in the state. Doing so would achieve multiple goals: improve air quality and GHG emissions, reduce the state’s dependence on fossil fuels, and provide consumers with an affordable choice to power their vehicles.

Thank you for the opportunity to provide input on the 2024 Clean Fuels Program rulemaking. The 2024 Clean Fuels Program is a critical tool to addressing climate change, and we look forward to working with DEQ to ensure the role of biofuels in making Oregon’s fuel mix more sustainable and help the state achieve its progressive climate goals through the expanded use of bioethanol. Additionally, we are happy to make ourselves available for any questions DEQ may have.

The post Growth Energy Comment to Oregon DEQ on 2024 Clean Fuels Program (CFP) Rulemaking appeared first on Growth Energy.

Thank you for the opportunity to provide written testimony for HB 5440, which requires the use of the Argonne National Laboratory’s greenhouse gases, regulated emissions, and energy use in technologies (GREET) model in the Department of Energy and Environmental Protection’s lifecycle analysis of biofuels. Growth Energy strongly supports the use of GREET in any lifecycle analysis of biofuels, as it is the most accurate and up-to-date lifecycle analysis of greenhouse gas emissions for transportation fuels. Additionally, we support the inclusion of farm-level climate-smart agricultural practices when considering biofuels’ lifecycle emissions. There has been a wealth of data including a recent study done by Argonne National Laboratory showing 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.

Use of Higher Blends of Bioethanol Leads to Better Environmental Outcomes
Growth Energy also strongly advocates for the important role low-carbon biofuels can play an in reducing the state transportation sector’s carbon emissions. A primary solution for decarbonizing the liquid transportation fuel supply is the promotion of additional use of bioethanol. Today, 98 percent of all gasoline sold in the U.S. contains 10 percent bioethanol. E15 (gasoline with 15 percent bioethanol) is approved for all 2001 and newer vehicles, more than 96 percent of all light duty vehicles on the road today. Consumers
have now driven more than 100 billion miles on E15, and retailers have conducted millions of transactions with this fuel. There have been no adverse reports of fuel quality experienced with E15 since first being approved 13 years ago.

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 reduces emissions including harmful particulates and air toxics such as carbon monoxide, and benzene.

The potential for fuels with higher blends of bioethanol to reduce GHGs are further illustrated in a national analysis showing more than 177,000 tons in GHG reduction in Connecticut alone if E10 gasoline was replaced with E15. These studies illustrate the vital role that higher bioethanol blends play in protecting our air, our climate, and our health.

In addition to its clear environmental benefits, E15 saved drivers an average of 15 cents per gallon last summer. It is now available at more than 3,400 retail locations in 31 states, and higher bioethanol blends such as E85 are available at nearly 6,000 sites around the
country. Unfortunately, in Connecticut, there are no retail locations selling E15 and only 6 retail locations selling E85.

Biofuels Are the Primary Feedstock of SAF
Additionally, our members embrace the role biofuels play in the aviation industry, which the state’s work on the 2022 Comprehensive Energy Strategy categorized as an industry “hard to decarbonize.” The adoption of GREET for the sustainable aviation fuel (SAF) federal tax credit is critical to the inclusion of biofuels in the efforts to reduce aviation’s carbon emissions. With current technologies, farm-based feedstocks—including bioethanol and corn oil—are the primary source of clean, renewable energy that can be used to produce volumes large enough to meet the demand. As a result, harnessing the U.S. bioethanol industry, which at 17.4 billion gallons per year accounts for over 80% of biofuel production in the United States, will be necessary to achieve U.S. goals for decarbonizing the aviation sector. HB 5440 will provide the opportunity for biofuels to be an essential contributor to Connecticut’s aviation decarbonization efforts.

Given our experience with state and national fuel policy, and our focus on expanding the use of lower-cost, environmentally beneficial fuels with higher bioethanol blends, we are happy to assist the committee with technical questions as they consider this important legislation. Additionally, we are available to answer any questions on sustainable aviation fuel, GREET modeling, and biofuels’ role in decarbonization. Thank you in advance for your consideration.

The post Growth Energy Testimony Supporting Connecticut GREET Bill appeared first on Growth Energy.

Growth Energy strongly advocates for policies supporting sustainable aviation fuel (SAF) development, which presents an historic opportunity for Michigan farmers and bioethanol producers, including Growth Energy’s Michigan members which collectively have a production capacity of more than 200 million gallons of bioethanol, to help decarbonize the aviation industry.

In 2021, the United States produced approximately 5 million gallons of SAF but incentives like SB 447 can help the ethanol industry occupy up to half of the domestic aviation marketplace. Growth Energy members have committed over 1.1 billion gallons of ethanol capacity to SAF, which would ultimately produce more than 650 million gallons of SAF. To achieve these goals, getting the policy and life cycle modeling right is essential.

Growth Energy supports SB 447, which will provide a $1.00 tax credit for SAF sold for use in Michigan, which with additional tax incentives for each additional percentage reduction in GHG emissions. We are pleased to see the inclusion of the Argonne GREET model to measure reductions in greenhouse gas emissions. The GREET model uses the most updated science accounting for all emissions reductions made in bioethanol production. When using the most recent science, cornstarch bioethanol is a readily available source of clean, renewable energy available in large enough volumes to decarbonize the skies. Additional important factors contributing to ethanol’s lower carbon intensity include the consideration of low-carbon on-farm practices and carbon capture and underground sequestration.

SB 447 represents an opportunity for Michigan farmers and biofuel producers to benefit from this still-nascent market poised to skyrocket in the coming decades. To achieve 100% SAF usage by 2050, 63 new bioethanol plants of 200 million gallons production capacity each will need to be constructed. Michigan’s status as a leading state for corn and bioethanol production has the potential to be enhanced with the passage of SB 447.

Today, biofuels support more than half a million jobs across the rural bioeconomy. If bioethanol producers take full advantage of SAF opportunities, that number has the potential to double. SB 447 incentivizes Michigan to embrace SAF production and capitalize on the economic and employment benefits of the low-carbon economy.

We appreciate the opportunity to express our support for SB 447, thank Senator Singh for introducing the legislation, and respectfully request the committee’s support for the bill. Additionally, we are available to assist the committee with any technical questions.

The post Growth Energy Testimony in Support of Michigan SAF Bill appeared first on Growth Energy.