Thanks for the chance to supply feedback on the Division of Environmental High quality’s (DEQ) 2024 Clear Fuels Program (CFP) rulemaking. Development Vitality is the world’s largest affiliation of biofuel producers representing 97 U.S. crops that produce 9.5 billion gallons of cleaner-burning, renewable gasoline yearly; 119 companies related to the manufacturing course of; and tens of hundreds of biofuel supporters throughout the nation. Our final goal is to work collectively to carry higher and extra reasonably priced decisions on the gasoline pump, enhance air high quality, and defend the surroundings for future generations. We stay dedicated to serving to our nation diversify our vitality portfolio to be able to develop extra inexperienced vitality jobs, decarbonize our nation’s
vitality combine, maintain household farms, and drive down the prices of transportation fuels for shoppers.
Development Vitality has beforehand submitted in depth feedback demonstrating the important function low carbon biofuels and better biofuel blends can play in assembly Oregon’s bold local weather objectives. We recognize the chance to supply additional feedback on the proposed rulemaking and the way expanded E15 use might help the state obtain its targets.
Consideration of Sustainability Certification
In response to the April seventeenth CFP’s Rulemaking Advisory Committee assembly, we request the
Division not think about the proposal on sustainability certification for crop-based biofuels
at present into consideration by the California Air Sources Board (CARB). Now we have a spread
of considerations with the proposal, which we have now detailed in feedback to CARB.
The proposal’s sustainability certification for crop-based fuels cites considerations concerning land use
change (LUC) components which can be unfounded relative to corn starch bioethanol. The truth is, the United
States is planting grain corn on roughly the identical variety of acres as was planted in 1900.1 At
the identical time, the per acre yield has elevated greater than 600%.2
Moreover, the LUC concern is already addressed within the 2024 Clear Fuels Program and its carbon depth (CI) modeling.
Corn starch bioethanol is given an automated 7.6 gCO2e/MJ penalty for oblique land use change
(ILUC). Including the proposed sustainability standards to the present ILUC rating quantities to an unfair
1 https://www.nass.usda.gov/Publications/Todays_Reports/stories/croptr19.pdf,
https://www.nass.usda.gov/Charts_and_Maps/Field_Crops/cornac.php
2 https://www.agry.purdue.edu/ext/corn/information/timeless/YieldTrends.html
double penalty for corn starch bioethanol. We additionally imagine the 7.6 gCO2e/MJ penalty is outdated and never based mostly on the hottest analysis. A evaluate of more moderen science signifies a lowering development in land use values with the newer knowledge indicating values nearer to 4 gCO2e/MJ.3
Additional, the proposed sustainability certification will add onerous and dear necessities on biofuel producers and farmers. But CARB’s financial evaluation of the proposal doesn’t talk about the sustainability requirement’s monetary burden of implementation. Nor will the requirement enable bioethanol producers to make use of vital instruments like climate-smart agricultural practices for CI discount. A few of these practices embrace precision utility of fertilizer, use of low CI fertilizer, no or low-till farming practices, and the usage of cowl crops.4
Lastly, with respect to CARB’s proposed sustainability audit, the proposal’s audit necessities deal with points, whereas vital to environmental and social justice, fall outdoors the scope of the LCFS. The proposed sustainability audit course of would require auditors to conduct: “evaluate of administration methods”, “evaluate of social practices”, and an evaluation of the “financial sustainability of the applicant.” These things don’t have any bearing on GHG discount. Moreover, if the proposal is adopted, crop-based biofuels can be the one feedstock for which these standards can be audited.
Carbon Seize and Sequestration
New improvements at biorefineries all through the USA enable pure, biogenic carbon dioxide (CO2) to be captured at a large scale, and a number of initiatives are already underway that repurpose, reuse, or present a everlasting storage answer for almost all of that CO2. We recognize DEQ’s management on the problem of carbon seize utilization and sequestration (CCUS) and the approval of Purple Path Vitality LLC’s Tier 2 utility together with CCUS final yr. We encourage DEQ to proceed broad allowance for credit score era from CCUS.
We applaud DEQ’s efforts to acknowledge the worth of carbon emissions discount through CCUS. We additionally perceive and recognize that DEQ will settle for pathways with non-onsite CCUS permitted or recertified by the California Air Sources Board, we request DEQ works to make sure all CCUS operations stay eligible for CI crediting by sustaining present eligibility provisions. Limiting CI crediting solely to on-site sequestration prevents the overwhelming majority of biorefineries from benefiting as most crops’ areas would not have the geology mandatory for Class VI CO2 injection wells. Many of those bioethanol services will finally be using CCUS through a CO2 pipeline. Whether or not on-site or transported safely through pipeline to be sequestered elsewhere, carbon dioxide is faraway from the environment and contributes to the emissions discount advantages of bioethanol. These services shouldn’t successfully incur a penalty because of the geology of their location when different CCUS alternatives stay.
3 https://iopscience.iop.org/article/10.1088/1748-9326/abde08/pdf
4 https://growthenergy.org/policy-priority/climate-smart-agriculture/
Expanded Use of E15 and Greater Blends
We applaud Oregon permitting the sale of E15, gasoline containing as much as fifteen p.c ethanol, in 2021.5 We encourage the state to undertake insurance policies that encourage the expanded use of E15 in addition to increased blends similar to E85. Greater than 96% of all autos on the street as we speak can benefit from E15, which if changed E10 statewide, would end in greater than 190,000 tons in GHG reductions.6 That is the equal of eradicating greater than 41,000 autos off Oregon’s roads with out impacting a single driver.
Moreover, E85 is at present obtainable at solely 5 websites within the state7. With an current fleet of greater than 186,000 Flex Gasoline autos (FFVs)8, Oregon can make the most of E85, which can promote even higher reductions in GHG emissions along with reductions in air toxics. We encourage Oregon to incentivize the usage of FFVs and put money into infrastructure increasing entry to E85 within the state. Doing so would obtain a number of objectives: enhance air high quality and GHG emissions, cut back the state’s dependence on fossil fuels, and supply shoppers with an reasonably priced option to energy their autos.
Thanks for the chance to supply enter on the 2024 Clear Fuels Program rulemaking. The 2024 Clear Fuels Program is a vital instrument to addressing local weather change, and we stay up for working with DEQ to make sure the function of biofuels in making Oregon’s gasoline combine extra sustainable and assist the state obtain its progressive local weather objectives by means of the expanded use of bioethanol. Moreover, we’re comfortable to make ourselves obtainable for any questions DEQ could have.
Sincerely,
Chris Bliley
Senior Vice President of Regulatory Affairs
Development Vitality
5 https://growthenergy.org/2021/12/02/oregon-finalizes-e15-rule-to-take-effect-in-january/
6 http://www.airimprovement.com/stories/national-e15-analysis-final.pdf
7 https://getbiofuel.com/fuelfinder/
8 https://afdc.vitality.gov/vehicle-registration
