Growth Energy Comments on CARB Scoping Plan

Thank you for the opportunity to comment on the CARB Scoping Plan (the Board’s Draft 2022 Climate Change Scoping Plan update). Growth Energy is the world’s largest association of biofuel producers, representing 89 U.S. plants that each year produce more than 8 billion gallons of renewable fuel; 103 businesses associated with the production process; and tens of thousands of biofuel supporters around the country. Together, we are working to bring better and more affordable choices at the fuel pump to consumers, improve air quality, and protect the environment for future generations.

We remain committed to helping our country diversify our energy portfolio in order to grow more green energy jobs, decarbonize our nation’s energy mix, sustain family farms, and drive down the costs of transportation fuels for consumers.

While California and the Board have made great strides to address air quality, climate change, and the move away from the use of fossil fuels, challenges remain. To address those challenges and for the state to meet its ambitious goals, there must be significant and immediate emission
reductions from California’s on-road vehicle fleet. The Scoping Plan update will help define
future state actions to address these challenges, and it is critical that all solutions be considered.
Specifically, liquid fuels will continue to play an important role in the transportation sector for
decades to come, even as alternative technologies flourish. As such, it is imperative to consider
the vital role that environmentally sustainable fuel options such as bioethanol will play in
reducing greenhouse gas emissions, addressing air quality, and cutting consumer costs from
current and future California vehicles.
As we have continued to advocate, a primary solution for cleaning up the liquid fuel supply is the
promotion of additional use of bioethanol, from starch and cellulosic sources. According to
recent data from Environmental Health and Engineering, today’s bioethanol reduces
greenhouse gas emissions (GHG) by an average of 46 percent compared to gasoline and can
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provide even further GHG reductions with additional readily available technologies.
In the
existing light duty fleet, higher bioethanol blends can be immediately deployed to achieve
immediate GHG reductions, reduce harmful air toxics, and reduce consumer costs at the pump.
Already, we have seen biofuels provide the foundation for the state’s low carbon fuel standard
(LCFS). In fact, biofuels like bioethanol have generated more than 75 percent of LCFS credits.
Additionally, even with room to further improve GHG lifecycle modeling, CARB recognizes the
significant improvement in ethanol’s carbon intensity. In 2011, CARB reported the average
carbon intensity (CI) for ethanol at 88 g/MJ. Through 2021, the average recorded CI for ethanol
has decreased to 59.02 g/MJ, a 33 percent reduction in CI.

Ethanol’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
ethanol and ethanol-blended fuel reduces air toxics such as carbon monoxide, benzene, and
other harmful particulates.
To fully realize these and other important air quality benefits, there
needs to be a clear policy with a firm future for the role and growth of cleaner-burning, affordable
ethanol fuels.
1 Environmental Research Letters: Carbon intensity of corn ethanol in the United States: state of the science
3 University of California Riverside:;
University of Illinois at Chicago:

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E15 and the Current and Future Light-Duty Fleet
As we have noted previously, we continue to urge CARB to further develop clear policies that
recognize the realities of today’s fuel market and examine how homegrown biofuels can
immediately contribute to achieving GHG reductions. Today, nearly all gasoline in California –
and across the U.S. – is blended with 10 percent ethanol. E15, a blend consisting of 15 percent
ethanol, has been approved for use by the U.S. Environmental Protection Agency (EPA) in all
passenger vehicles model year 2001 and newer, more than 98 percent of the vehicle miles
traveled. E15 is now available at more than 2600 stations in 31 states, and at a time of record
high fuel costs, E15 has been a lower-cost option for consumers – selling at some locations
nearly 60 cents less per gallon than regular gasoline. Moving to E15 statewide in California has
the potential of cutting 1.8 million metric tons of GHG emissions – the equivalent of taking more
than 400,000 cars off the road each year.4 California is in the process of evaluating E15 through
its multi-media evaluation process. It is critical that the multi-media working group complete its
evaluation of E15, so that it can deployed immediately to help deliver on the Board’s ambitious
air quality goals. Related, the modeling in the Scoping Plan should be updated to appropriately
reflect the approval and penetration of E15 in future years
4 Air Improvement Resources: National E15 Analysis Final (
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E85 and Flex-fuel Vehicles
Additionally, with California’s significant growth of E85 used in flex-fuel vehicles (more than 62
million gallons sold at more than 300 locations in 2021 alone), the use of E85 will promote even
greater reductions in GHG emissions, reductions of air toxics, and even greater consumer cost
savings with some locations selling at a $2 per gallon discount to regular gasoline. We would
continue to encourage CARB to push for policies that continue to strongly encourage,
incentivize, and require the production and use of flex-fuel vehicles in conjunction with the use of
higher bioethanol blends like E85, as well as continued investment in infrastructure for the
expanded use of E85 in the state.
Mobil Station, San Diego, CA 4/6/2022
Beyond the use of higher bioethanol blends such as E and E8 in today’s vehicle fleet, we
would again highlight some bioethanol considerations as the Scoping Plan is updated:
High Octane/Midlevel Bioethanol Blends
As CARB considers the future fleet, it is also important to consider the benefits of using higher
octane fuels such as bioethanol in conjunction with more efficient engines. Growth Energy has
been an industry leader in advocacy in this area, first commenting to both CARB and EPA about
the need for higher octane, midlevel ethanol blends when the greenhouse gas standards for
vehicles were being first developed in 2012. At that time, we submitted a proposal for a 100
Research Octane Number (RON), E30 (30 percent bioethanol) fuel blend for both vehicle
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certification and for consumer use. The science supporting the benefits of a high-octane fuel –
specifically a midlevel ethanol blend in the E20 to E30 range in conjunction with a high
compression ratio engine – is not new and has been well explored by several national
laboratories including Oak Ridge National Laboratory, National Renewable Energy Laboratory,
and Argonne National Laboratory as well as automobile manufacturers and other scientific
institutions. Bioethanol has a very high octane number relative to other gasoline hydrocarbons,
has a lower carbon content than the gasoline components it replaces, and has many other
benefits that assist in combustion to increase engine efficiency and reduce both tailpipe
greenhouse gas and criteria pollutant emissions.
To briefly summarize, multiple studies have shown that a high RON, midlevel bioethanol blend
(e.g., 96-RON E20 or 100-RON E30) when paired with various higher compression ratio engines
yield tailpipe CO2 emissions reductions of at least 5 percent, which in most instances were also
coupled with efficiency gains. Some studies also showed significant volumetric miles per gallon
savings associated with the higher efficiency engines and a high-octane fuel. One study that
was submitted to EPA in response to their Draft Technical Assessment Report (TAR) by Air
Improvement Resources, “Evaluation of Costs of EP ’s 2022-2025 GHG Standards with High
Octane Fuels and Optimized igh Efficiency Engines,” showed that the use of a 98 RON, E
would reduce the cost of a MY 2025 vehicle by $400 and a popular crossover SUV by as much
as $873. Not only are the benefits of midlevel ethanol blends well understood by the scientific
community, but the automobile industry has for years acknowledged the importance of
affordable, high-octane fuels coupled with high-compression ratio engines as important to
attaining regulatory compliance and improving vehicle performance in the most economical
manner possible.
When you examine the data, there are clear benefits of moving to a high-octane, midlevel
bioethanol blend, such as E30, including improved vehicle engine efficiency, lower tailpipe
emissions, and increased use of renewable fuel. We believe that the use of midlevel ethanol
blends will continue to drive investment in more efficient vehicles, as well as lower carbon
Bioethanol/Fuel Cell Technology
Direct bioethanol fuel cells for the use in motor vehicle transportation have been in development
by Nissan for some time. As recently as January of 2020, Nissan and Lawrence Berkeley
National Laboratory have published research on the use of 100 percent bioethanol in fuel cell
technologies and innovations.
This technology not only meets zero emission vehicle
requirements, but further eliminates particulates from tailpipe emissions. Using bioethanol in
conjunction with a fuel cell would require less infrastructure change and investment and would
help the state meet its ambitious goals for climate and vehicle. As CARB considers policies on
zero emission vehicles in conjunction with the LCFS, we would strongly encourage CARB to
consider ways to further develop this technology for consideration.
5 Lawrence Berkeley National Laboratory:
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More broadly, we look forward to working with the Board to ensure the role of biofuels in making
California’s fuel mix more sustainable and help the state achieve its climate goals through the
expanded use of bioethanol.
Thank you in advance for your consideration.

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