WASHINGTON, D.C. – Today, Growth Energy submitted comments on a notice from the Environmental Protection Agency that sets a weighting factor (F-factor) for flexible fuel vehicles for model year 2020 and would affect how the agency determines the F-factor for flexible fuel vehicles for model years 2021 and later.

“Recent trends in government and private investment in biofuels infrastructure and updated data on E85 availability all lead to growth in higher biofuel blends,” said Growth Energy Senior Vice President of Regulatory Affairs Chris Bliley. “EPA should seize on that data to provide appropriate, immediate credit to automakers to continue to produce flex-fuel vehicles to run on these higher biofuel blends.”

In the organization’s written comments, Growth Energy offered a detailed technical analysis on the benefits of an updated F-factor, noting that any upward revision should take immediate effect so it continues to accelerate automaker investment and innovation. They recommend the following:

  • Maintaining an F-factor of 0.14 until it takes action for an upward revision
  • Providing, through immediately issued guidance, 5 years of F-factor continuity and an additional 3-year safe-harbor to automakers for automaker certainty
  • Applying the 10th Circuit decision to limit small refinery exemptions, as dictated by the Renewable Fuel Standard (RFS)
  • Working with Growth Energy, its retail partners, and the AFDC to appropriately update station data for higher ethanol blends that should be increased to reflect the higher number of stations currently offering E85
  • Using highlighted data and correcting for flaws, providing an updated F-factor of 0.2 for model year 2021 and thereafter

Despite inconsistencies in the agency’s estimates of E85 use and the modeling in AEO 2020, Growth Energy believes that upon addressing the flaws in AEO 2020 and consideration of projected growth in E85 stations and uptake, EPA will be justified in establishing a F-factor of 0.20 for model year 2021 moving forward.

To read Growth Energy’s comments on EPA’s proposed rule on F-factor, click here.

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