Growth Energy to EPA: Don’t Leave Carbon Reductions on the Table by Neglecting Biofuels in Tailpipe Emissions Standards

WASHINGTON, D.C.—Today, Growth Energy, the nation’s largest biofuels trade association, submitted comments to the U.S. Environmental Protection Agency (EPA) in response to the agency’s proposed Multi-Pollutant Emissions Standards for Model Years 2027 and Later Light-Duty and Medium-Duty Vehicles.

In its comments, Growth Energy challenged EPA’s legal justification to issue the rule and highlighted the inconsistencies in EPA’s approach to evaluating greenhouse gas (GHG) emissions over the lifecycles of electric vehicles (EVs) versus internal combustion engine vehicles. The comments also call on EPA to update its final standards to include biofuels as a necessary solution to reduce carbon emissions in the transportation sector.

“This proposal is unnecessarily narrow, presenting a false choice between only two paths forward – fossil-fuel-only vehicles or mass adoption of EVs. Neither outcome reflects reality, and EPA’s framework ignores the proven, available, and American-made solution of emissions-reducing biofuel,” said Growth Energy CEO Emily Skor.

“Internal combustion engine vehicles will be on the road for decades to come. We will need liquid fuels to power them, and the more oil we displace in those fuels with bio-based alternatives, the greater the environmental benefit.

“Instead of placing its thumb on the scale for a single technology, EPA’s final standards must reflect the entire lifecycle analysis of all technologies. Doing anything less undermines American ingenuity and innovation, and leaves carbon emissions reductions on the table,” she added.

Read the full comments here.


In April 2023, EPA released its Multi-Pollutant Emissions Standards for Model Years 2027 and Later Light-Duty and Medium-Duty Vehicles. Growth Energy responded to the initial proposal and then, in May, testified at a public hearing hosted by EPA on its tailpipe emissions proposal. At the hearing and in its comments to the agency, Growth Energy specifically called on EPA to: 

  • Accelerate the deployment of E15 nationwide;  
  • Approve and adopt high-octane, midlevel ethanol blends like E30;  
  • Expand access to Flex Fuel Vehicles (FFVs) in conjunction with use of E85; and 
  • Conduct a complete lifecycle analysis for EVs and internal combustion engine vehicles using the Argonne GREET model.  

Since that hearing, EPA released its final volumes for 2023-2025 under the RFS, limiting growth in the blending of conventional biofuels (i.e., ethanol) to 15 billion gallons each year.