Thank you for the opportunity to comment on CARB and its recent workshop on potential amendments to the state’s cap and trade regulation. Growth Energy is the world’s largest association of biofuel producers, representing 96 U.S. plants that each year produce more than 9 billion gallons of renewable fuel; 115 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 appreciate the continued interest of CARB in reducing greenhouse gas emissions in the state. Our industry represents the largest volume of accessible, low-carbon biofuels meant to achieve the objectives of the Board and the state of California.
As the presentation notes, bioethanol is appropriately exempt from the cap-and-trade program. Today’s bioethanol represents a nearly 50 percent reduction in GHG emissions compared to gasoline and can continue to improve toward net zero with readily available technologies such as carbon sequestration and climate-smart agriculture practices.
In fact, as CARB knows well, bioethanol and other exempt biofuels such as biodiesel and renewable diesel make up the bulk of the credits generated under state’s low carbon fuel standard and have been pillars on which the program’s GHG emissions reductions have been built. Given the GHG reductions that bioethanol has already achieved, California has the potential to reduce
GHG by 1.9M tons per year with the approval of E15 alongside the continued growth in the use of E85.
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 These fears have been largely based on outdated and flawed data.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.3 The ILUC value should reflect the latest science that better addresses innovation and increasing yields in agriculture.