In formal comments submitted to the Environmental Protection Agency (EPA), Growth Energy urged the agency to finalize robust renewable volume obligations (RVOs) under the Renewable Fuel Standard (RFS) for 2023-2025. Growth Energy backed its comments with two new studies reaffirming the need for EPA to accurately model bioethanol’s climate benefits and reject unsupported claims that attempt to diminish bioethanol’s significant environmental benefits.

The research submitted by Growth Energy includes a report from Ramboll, building on previous research submitted in 2019 that debunks much of the flawed science concerning biofuels’ effect on land use change and other environmental impacts, including under the Endangered Species Act (ESA). The study adds to the wealth of public and private data demonstrating that the RFS remains “unlikely to result in material land conversion” or other impacts requiring further ESA reviews. A few key points from the study include:

• There is no evidence of a causal link between the Renewable Fuel Standard (RFS) and land use change (LUC).
• There is no credible evidence that the proposed RVO standards will adversely affect wetlands, ecosystems, wildlife habitat, or water quality.
• Modeling indicates that the statistical dependency between the implied conventional volume and corn prices is non-existent to very weak.

Growth Energy also submitted a report conducted by Environmental, Health and Engineering, Inc. which further highlights the important additional environmental and public health benefits of higher ethanol blends and adds to the literature knocking down flawed science on land use change.

• Better science, based on newer and more accurate modeling techniques, shows that the carbon intensity of corn ethanol is two to four times lower in terms of indirect land use change (iLUC) than previously thought.
• The carbon intensity (CI) estimates for the indirect land use change (iLUC) associated with corn ethanol have been converging on lower values when considering the best available science and improved models.
• Corn ethanol reduces greenhouse gas emissions by 46% compared to regular gasoline.
• As the percentage of ethanol blended with gasoline increases, the content of aromatics (hazardous air pollutants) in the fuel decreases.
• Higher ethanol fuel blends offer a valuable opportunity to reduce particulate matter concentrations and risk of adverse cardiovascular and respiratory outcomes.