WASHINGTON, D.C. – Growth Energy submitted comments in response to the U.S. Environmental Protection Agency’s (EPA) and U.S. Department of Energy’s (DOE) workshop on the greenhouse gas lifecycle analysis (LCA) of land-based crop biofuels used in the transportation sector. Growth Energy’s comments call on EPA to update LCA of biofuels, and ethanol in particular, to accurately reflect the latest science that shows ethanol achieving nearly 50% reductions in greenhouse gas emissions.

“Updating the LCA of ethanol is critical not only to faithfully implementing the Renewable Fuel Standard program (the only Clean Air Act program explicitly aimed at reducing GHG emissions), but for sound policymaking on a range of future potential rulemakings designed to facilitate the use of E15, flex fuel vehicles, and use of higher-level ethanol blends like E85, and sustainable aviation fuel (SAF),” wrote Growth Energy. “Robust and accurate cost-benefit analyses depend on accurate assessment of the GHG impacts of biofuels, particularly given utilization of the social cost of carbon (SCC) to monetize the benefits of anticipated GHG emission reductions.”

As part of its comments, Growth Energy included an in-depth analysis of the data from Lifecycle Associates as well as rebuttals to an anti-ethanol study released in February by Tyler Lark and others on the greenhouse gas impacts of ethanol. DOE’s own Argonne National Laboratory identified several flaws in the study, including deficiencies in modeling land transition and inaccurate classification of satellite data. Pieter Booth, Principal of Net Gain Ecological Services, found that the anti-ethanol study misleads readers and fails to properly evaluate and explain its findings.

“The authors characterize as fact numerous modeled results, giving the reader a misleading impression of false confidence in the conclusions which are drawn from highly uncertain models embedded with extensive assumptions that may or may not reflect the real-world,” wrote Booth.

Background

Growth Energy’s comments add to a previous rebuttal from a group of leading scientists that discredit many of the claims in the anti-ethanol study.

In early March, Growth Energy submitted a robust analysis of ethanol’s invaluable role in reducing greenhouse gas emissions as part of its comments in response to EPA’s proposed 2020-2022 Renewable Volume Obligations (RVOs). Growth Energy also sent a letter to DOE calling for the department to address the Lark study, whose authors claim was partially funded by the department.