To the Public Comments Team,
We appreciate the opportunity to comment on the proposed updates to the gasoline carbon-intensity (CI)
baseline (to 90.17 gCO₂e/MJ) and the increase in the reduction target to 60 percent. We view these as useful
technical calibrations that provide clearer compliance signals while maintaining Japan’s overall policy
direction. Given this change will alter the U.S. market share potential for Japan’s on-road fuel use, we ask
Japan to initiate a revision of the U.S. corn ethanol CI score to restore the ability for U.S. ethanol to have full
market access potential.
Fuel ethanol from the United States can contribute to measurable reductions in the carbon intensity of finished
gasoline with predictable, scalable supply. Producers have reduced process energy needs through heat
integration and combined heat and power, increased the share of lower-carbon electricity and fuels, optimized
logistics, and adopted improved on-farm practices such as enhanced nitrogen management, reduced tillage,
and cover crops. These improvements are supported by plant-level data and established measurement,
reporting, and verification (MRV) systems suitable for robust lifecycle modeling.
We also note ongoing methodological advances under Argonne National Laboratory’s Greenhouse gases,
Regulated Emissions, and Energy use in Technologies (GREET) model. This includes more granular
treatment of farming inputs and yields, updated nitrous-oxide and energy factors, improved representation of
transport and co-products, and clearer pathways for facility-level decarbonization (including carbon capture
where applicable). As such refinements are reflected in policy lifecycle assessments (LCA), United States
corn-ethanol pathways become more competitive on a carbon basis and more representative of actual
performance.
We support Japan’s continued reliance on science-based, technology- and feedstock-neutral lifecycle
assessment applied consistently across pathways, as this approach provides compliance certainty, rewards real
emissions reductions, and ensures a level playing field for all low-CI options, including fuel ethanol from the
United States.
We appreciate your consideration of these comments.
Sincerely,
Ryan LeGrand
President & CEO
U.S. Grains & BioProducts Council
Emily Skor
CEO
Growth Energy
Geoff Cooper
President & CEO
Renewable Fuels Association
Subject: Comments from the U.S. Ethanol Industry on Japan’s Proposed Update to the Gasoline Carbon Intensity Baseline and Reduction Target