Growth Energy Comments on California’s Proposed LCFS Amendments

Thank you for the opportunity to provide written comments regarding the proposed Low Carbon Fuel Standard (LCFS) amendments. Growth Energy is the world’s largest association of biofuel producers, representing 97 U.S. plants that each year produce more than 9.5 billion gallons of renewable fuel; 119 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.

Growth Energy has previously submitted extensive comments demonstrating the vital role low carbon biofuels and higher biofuel blends can play in meeting California’s ambitious climate goals. As we have previously noted, biofuels have been among the largest contributors to the success of the LCFS program to date and are poised to continue to do so with appropriate updates to the program.

Approval of E15
We applaud the California Air Resources Board’s consideration of the role E15 can play in reducing the state’s greenhouse gas (GHG) emissions while also providing a cost savings opportunity for California drivers. Consumers have embraced E15’s reputation as a more environmentally beneficial, more affordable fuel. Since the US EPA approved E15 in 2011, at which time there were zero retailers offering it, its availability rapidly expanded to now 3,400 retail sites in 32 states. Since then, drivers in America have relied on E15 to drive 100 billion miles.

As producers of one of the most scalable feedstocks for SAF production, we appreciate the Board’s attention to development of this key market through its proposal to remove the exemption for intrastate jet fuel. We encourage CARB to continue to work with SAF producers, biofuel feedstock producers, and airlines to continue to seek ways to accelerate use of these important fuels to help decarbonize the aviation sector.

Thank you for the opportunity to provide input on the April 10th, 2024 workshop. The LCFS Program is a critical tool to addressing climate change, and we look forward to working with CARB to ensure the role of biofuels in making California’s fuel mix more sustainable and help the state achieve its progressive climate goals through the expanded use of bioethanol.