Growth Energy Comments on Oregon’s Proposed Clean Fuels Program Extension

Thank you for the opportunity to comment on the Department of Environmental Quality’s (DEQ) proposal to extend its Clean Fuels Program and increase the Clean Fuel Standards to 20% below 2015 levels by 2030 and 37% below 2015 levels by 2035. 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; 104 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.

We sincerely appreciate DEQ’s attention and hard work to reshape Oregon’s fuel mix to make it
more sustainable. This objective is a central driver for our industry, and we look forward to
continuing our work on our common goals as you explore revisions to the Clean Fuel Program
(CFP) moving ahead. Specifically, liquid fuels will continue to play an important role in the
transportation sector, 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 and cutting consumer costs in the current and future
Oregon vehicle fleet.
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 or 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 provide even
further GHG reductions with additional readily available technologies.1 In the existing light duty
1 Environmental Research Letters: Carbon intensity of corn ethanol in the United States: state of the science (
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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’ve seen biofuels provide the foundation for the CFP. In fact, biofuels like bioethanol
have generated more than 75 percent of CFP credits. Additionally, even with room to further
improve GHG lifecycle modeling, the CFP recognizes the significant improvement in
bioethanol’s carbon intensity. In 2016, DEQ reported the average carbon intensity (CI) for
bioethanol at 64.5 gCO2e/MJ. Through 2021, the average recorded CI for bioethanol has
decreased to 53.98 gCO2e/MJ, a nearly 17 percent reduction in CI in just 5 years.2
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 air toxics such as carbon monoxide, benzene,
and other harmful particulates.
3 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 bioethanol fuels.
As we have noted previously, we continue to urge DEQ 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 Oregon – and
across the U.S. – is blended with 10 percent bioethanol. 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, more than 96 percent of the vehicles on the
road today, and is now for sale at more than 2600 locations in 31 states. We were very pleased
to see Oregon move forward with its recent approval of E15 as it is another tool to help further
reduce Oregon’s greenhouse gas emissions.
Additionally, as we have seen in California, low carbon fuel programs are helping to drive growth
in the use of E85 in flex-fuel vehicles. The use of E85 will promote even greater reductions in
GHG emissions and reductions of air toxics.
We would encourage DEQ and other state agencies to push for policies that: strongly
encourage and incentivize the use of higher bioethanol blends such as E15 and E85, the
production and use of flex-fuel vehicles, as well as continued investment in infrastructure for the
expanded use of E85.
With respect to some of the items in the proposal, we offer comment:
Correct the GREET Model to Reflect Updated Science on Land Use
While we are pleased that DEQ has a more realistic value for land use change of 7.6 gCO2e/MJ
compared to other programs, a review of the more recent science over the last 5 years indicates
2 DEQ CFP Data: Department of Environmental Quality : Quarterly Data Summaries : Oregon Clean Fuels
Program : State of Oregon
3 University of California Riverside:;
University of Illinois at Chicago:
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newer data indicates values closer to 4 gCO2e/MJ. The LUC value should reflect the latest
science that better addresses innovation and increasing yields in agriculture.
Crediting for Field-based Farm Practices
Growth Energy strongly supports the appropriate crediting of on-the-farm field practices in the
CFP. The U.S. EPA estimates that five percent of national GHG emissions is from crop
cultivation and energy, there is an opportunity for lower emissions in agriculture within the CFP.
There has been a wealth of data including a recent study done by Argonne National Laboratory
that show the possibility of a 35 percent reduction in carbon intensity through adoption of current
best on-farm practices such as cover crops, strip tillage, reduced fertilizer use, and other
4 With the CFP’s verification requirements, capturing these on the farm benefits for
biofuel pathways is now more realistic and scalable. 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.
Carbon Capture and Sequestration
New innovations at biorefineries throughout the U.S. 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 encourage DEQ
to allow for credit generation from carbon capture, utilization, and storage (CCUS).
Energy Allocation for Non-Fuel Products
Many bioethanol producers have continued to innovate their biorefineries and are producing
varying grades of bioethanol for applications beyond fuel. Some of these grades and
specifications require additional processing and energy. We encourage DEQ to clarify that its
carbon intensity model does not allocate the energy used for non-fuel production inappropriately
to biofuels.
Correcting Electricity Usage in Wet and Dry Distiller Grain (DDGS) Pathways
The Oregon GREET model currently distinguishes between wet and dry DDGS pathways for
thermal energy but does not do so with regard to electricity use. Electricity use between wet and
dry DDGS production is quite different. We recommend that DEQ further distinguish electricity
use as it does with thermal energy in its GREET model.
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.
5 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
4 Argonne National Laboratory:
5 Lawrence Berkeley National Laboratory:
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help the state meet its ambitious climate goals. As DEQ considers policies on zero emission
vehicles in conjunction with the CFP, we would strongly encourage DEQ to consider ways to
further develop this technology for consideration.
More broadly, we look forward to working with you through the regulatory process on revisions
to the CFP program and 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.
Thank you in advance for your consideration.

Read the full comment here.