Growth Energy Comments on Updates to California LCFS

Thank you for the opportunity to comment on the recent workshop to outline initial considerations for revisions to the California LCFS. 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 CARB’s attention and hard work to reshape California’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 LCFS 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 plant-based bioethanol will play in
reducing greenhouse gas emissions and cutting consumer costs in the current and future
California vehicle fleet.
Bioethanol’s Environmental Benefits
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.1 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’ve seen biofuels provide the foundation for the LCFS. In fact, biofuels like
bioethanol have generated more than 75 percent of LCFS credits. As recently as 2020,
bioethanol was the largest LCFS volume and second-largest credit generator. Additionally, even
with room to further improve GHG lifecycle modeling, the LCFS recognizes the significant
improvement in bioethanol’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 bioethanol has
decreased to 59.02 g/MJ, a 33 percent reduction in CI.2 Additional CI reductions are anticipated
as projects of diverse technological variety at ethanol biorefineries come on-line starting this
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
1 Environmental Research Letters: Carbon intensity of corn ethanol in the United States: state of the science
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carbon monoxide, and benzene.
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 ethanol fuels.
Biofuels, Land Use, and Food Supply
We also believe CARB’s concerns about the use of crop-based biofuels and their impact on land
use are misplaced and unfounded. These fears have been largely based on outdated and
flawed data. While CARB currently has an indirect land use change value (ILUC) of 19.8
gCO2e/MJ, 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.4 The ILUC
value should reflect the latest science that better addresses innovation and increasing yields in
Related, we also believe that recent concerns about biofuel production on food cost and supply
are unfounded. Our industry produces both food and fuel. Specifically, production of bioethanol
results in a wide variety of co-products, perhaps the most significant of which is high-quality animal
feed that contributes directly to the production of chicken, beef, pork, and other nutritious food.
Specifically, one bushel of corn produces 2.8 gallons of bioethanol as well as 17-18 pounds of
distillers dried grains (DDGS), a highly nutritious animal feed. Our industry produces nearly 40
million tons of animal feed per year. That feed is supplied to food producers here in the U.S. and
around the world. Additionally, the renewable CO2 from bioethanol production is also critical for
meat processing, beverage carbonation, and water treatment.
Data from the United Nation’s Food and Agriculture Organization (FAO) as well as from the U.S.
Energy Administration (EIA) also show in the graph below that the price of food is closely
correlated with the cost of crude oil rather than the cost of corn.
3 University of California Riverside: Comparison of Exhaust Emissions Between E10 CaRFG and Splash Blended
E15 | California Air Resources Board and; University of Illinois at Chicago:
4 Environmental Research Letters: Carbon intensity of corn ethanol in the United States: state of the science
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Finally, as discussed previously relative to land use, farming practices like crop intensification and
cover cropping have significantly improved the yield of all crops, further negating the impact of
biofuel production on food crops. As the United States Department of Agriculture (USDA) and
numerous others have noted, yields have (and continue to) climbed more than 700 percent while
acreage has remained unchanged for the last century.
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Use of Higher Bioethanol Blends
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
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. In fact, this summer
where available, we’ve seen E15 selling consistently for as much as $1 less per gallon than
regular gasoline – that is meaningful consumer cost-savings.
Sheetz, Grandview Heights, OH June 26, 2022
Through innovative, sustainable ag practices, we’re
producing more using less land
Yields have increased by 700%, while acres remained steady
1926 1936 1946 1956 1966 1976 1986 1996 2006 2016
Yearly Value Versus 1926
By the late 1930s, harvested corn yield was no
longer directly linked to corn planted.
Acres of total corn planted has generally
plateaued, even into the late 2010s.
Acres Planted
Source: USDA Crop Production Historical Track Records, 2019. (NASS data)
Average annual yield increase of ~8.8% 1937 -2016
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We were very glad to see CARB post the final Tier I report for the multi-media evaluation of E15
as well as the positive emissions results for E15 from the recent testing done by the University
of California-Riverside. We continue to encourage the state to expedite its approval of E15 for
California consumers and to help drive further immediate GHG emission reductions.
Additionally, the California LCFS is 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 also encourage CARB 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.
Mobil Station, San Diego, CA 4/6/20222
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With respect to some of the other items under consideration for California LCFS revisions, we offer
Crediting for Field-based Farm Practices
Growth Energy strongly supports the appropriate crediting of on-the-farm field practices in the California LCFS. The U.S. EPA estimates that five percent of national GHG emissions is from crop
cultivation and energy. 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 innovations.
5 With the California LCFS’ 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 support and
encourage CARB’s continued allowance for credit generation from carbon capture, utilization,
and storage (CCUS).
Correcting Electricity Usage in Wet and Dry Distiller Grain (DDGS) Pathways
The CALGREET 3.0 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 CARB further distinguish
electricity use as it does with thermal energy in its CALGREET 3.0 model.
Ethanol/Fuel Cell Technology
Direct Ethanol 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 ethanol in fuel cell
technologies and innovations.
6 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 California LCFS, we would strongly encourage CARB to
consider ways to further develop this technology for consideration.
More broadly, we look forward to working with CARB as you work through the regulatory
process on revisions to the California LCFS program and ensure the role of biofuels in making California’s
5 Argonne National Laboratory:
6 Lawrence Berkeley National Laboratory:
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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.