Growth Energy Comments on Washington’s Proposed Cap-and-Invest Linkage and Biofuels

Thank you for the opportunity to comment on the Department’s discussions to link the state’s Cap-and-Invest program with those programs in existence in California and Quebec. Growth Energy is the world’s largest association of biofuel producers, representing 96 U.S. plants that each year produce 9 billion gallons of renewable fuel; 114 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 Department’s effort to reduce Washington’s greenhouse gas (GHG) emissions. Our industry represents the largest volume of accessible, low-carbon biofuels meant to achieve the objectives of the Department and the State of Washington.
As we have outlined in previous comments on both the Cap-and-Invest program and the program’s potential linkage with other carbon markets, we continue to be concerned about the restrictive definition of the exemption for biofuels and its impact on bioethanol. Specifically, while the program does contain an exemption for biofuels, it is limited to only those “fuels derived from
biomass that have at least 40 percent lower GHG emissions based on a full life-cycle analysis when compared to petroleum fuels for which biofuels are capable as serving as a substitute.”

We appreciate the Department’s discussion in the final rulemaking that “Ecology’s working assumption is that all biofuels meet the 40 percent standard for past and near future years unless that verification process clearly indicates otherwise.” However, we continue to believe this definition in the Cap-and-Invest program does not provide enough clarity and may be too restrictive, and ultimately could prohibit the use of sizeable volumes of lower-carbon bioethanol that could generate substantial GHG emission reductions for Washington and lower the state’s dependence on fossil fuels.

This issue is particularly important as the Department seeks to link the Cap-and-Invest program with those in Quebec and California where biofuels are already clearly exempt, and where they have shown to be leaders in GHG reductions in California’s low carbon fuel standard (LCFS). Bioethanol and other exempt biofuels such as renewable diesel and biodiesel are cumulatively responsible for 74% of California’s reductions since the implementation of their LCFS. Today’s bioethanol represents a nearly 50 percent reduction in GHG emissions compared to gasoline. And as readily available technologies such as carbon sequestration and climate-smart agriculture practices are adopted, ethanol can continue to improve toward net zero. For instance, by using the latest science on indirect land use change value (ILUC) rather than outdated and flawed data, the impact of ILUC on ethanol’s carbon intensity is closer to 4 gCO2e/MJ.2 This is a nearly 80% reduction from out-of-date models being used.

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.