We respect the chance to touch upon the Division of Ecology’s (Ecology) proposed updates to the state’s Clear Gasoline Customary (CFS). Progress Power is the world’s largest affiliation of biofuel producers, representing 97 U.S. crops that every yr produce greater than 9.5 billion gallons of renewable gasoline; 119 companies related to the manufacturing course of; and tens of hundreds of biofuel supporters across the nation. Collectively, we’re working to deliver higher and extra reasonably priced decisions on the gasoline pump to customers, enhance air high quality, and shield the setting for future generations. We stay dedicated to serving to our nation diversify our power portfolio to be able to develop extra inexperienced power jobs, decarbonize our nation’s power combine, maintain household farms, and drive down the prices of transportation fuels for customers.
We applaud Ecology’s efforts to scale back Washington’s greenhouse gasoline (GHG) emissions within the transportation sector and consider the biofuels trade represents the best alternative to decrease carbon emissions instantly as future applied sciences are developed. Progress Power’s members produce biofuels which, based on latest information from Environmental Well being and Engineering, right this moment’s bioethanol reduces greenhouse gasoline emissions (GHG) by practically 50 p.c in comparison with gasoline and might present even additional GHG reductions with further available applied sciences. A examine carried out in 2022 by the College of California – Riverside discovered that shifting from E10 to E15 (gasoline containing as much as 15% ethanol) in light-duty autos reduces emissions together with dangerous particulates and air toxics comparable to carbon monoxide, and benzene.
Bioethanol’s Position in SAF Manufacturing
The chance for biofuels to contribute to the aforementioned carbon emissions reductions is clear within the aviation trade and the usage of sustainable aviation gasoline (SAF). With present applied sciences, farm-based feedstocks of bioethanol and corn oil are the first supply of fresh, renewable power that can be utilized to provide volumes giant sufficient to fulfill demand. Whereas Ecology’s proposed modifications and the request for feedback on these modifications doesn’t embody modifications to the state’s carbon lifecycle evaluation or the valuation of land use change penalties, Progress Power believes these points are vital to the success of SAF. Alcohol-to-Jet SAF, when
the coverage and carbon depth modeling is completed appropriately, generally is a essential part to Washington’s bold purpose of aviation decarbonization.
Recognizing the Carbon-Discount Values of Farm-Degree Local weather Good Ag Practices
To ensure that Washington to make the most of SAF’s potential to scale back carbon emissions, Ecology ought to contemplate recognizing farm-level climate-smart agriculture practices. There was a wealth of information together with a latest examine executed by Argonne Nationwide Laboratory (ANL) that present the potential for a 35 p.c discount in carbon depth by way of adoption of present finest on-farm practices comparable to cowl crops, no until, low carbon fertilizer use, and different improvements. Permitting applicable credit score will assist bioethanol producers proceed to additional innovate and decrease their carbon depth, whereas offering key incentives for farmers to undertake these efficient conservation practices. In a just lately launched 40B steerage for SAF manufacturing, the U.S. Division of Treasury acknowledged the position climate-smart agricultural practices play in lowering GHG emissions within the aviation trade.
Revising Land Use Change Penalty Primarily based on Present Science
Presently, Washington’s greenhouse gases, regulated emissions, and power use in applied sciences (GREET) assigns an oblique land use change (ILUC) penalty of 19.8g/MJ for cornstarch bioethanol. This quantity is essentially based mostly on outdated and flawed information. A evaluate of the newer science during the last 5 years signifies a reducing pattern in land use values with the newer information indicating values nearer to 4 gCO2e/MJ. The ILUC worth ought to replicate the most recent science that higher addresses innovation and growing yields in agriculture. As Ecology considers alignment with different states’ clear gasoline packages, you will need to observe that Oregon assigns an ILUC penalty of
7.6g/MJ. We request Ecology contemplate aligning WA-GREET’s ILUC worth for cornstarch bioethanol with Oregon’s worth. By recognizing the most recent science and adjusting the ILUC penalty, Ecology can enable bioethanol to proceed its potential to additional cut back GHG emissions inside the state’s legacy car fleet.
Increasing the Use of Low-CI Energy E book-and-Declare Accounting
Ecology presently doesn’t enable for biofuels producers to make the most of low-carbon depth energy sourcing by way of book-and-claim accounting. Permitting biofuels producers to supply contracted low-CI energy by way of energy buy agreements incentivizes the era of cleaner electrical energy. This is able to place Washington as a nationwide chief, encouraging the usage of low-CI energy in different states because the overwhelming majority of biofuels utilized in Washington is produced out of state. We encourage Ecology to make the most of book-and-claim accounting for sourcing low-CI energy by permitting all gasoline varieties to entry this CI discount software.
Third-Celebration Verification for Gasoline Pathways
Verification of pathways is a vital part in making certain the CFS attains its aims. Bioethanol producers work with accredited and skilled companies to conduct audits and confirm producers’ pathways obtain their GHG reductions. Auditors’ constant work with biofuel producers permits audit groups to change into extra acquainted with particular person producers’ processes and operations over time. Consequently, the audits change into extra environment friendly and efficient, enhancing the integrity of the CFS. Whereas we respect Ecology’s intent to strengthen the auditing course of, we consider a agency rotation requirement can be expensive to biofuel producers and will negatively affect audit high quality. We encourage Ecology to seek out an alternative choice to an audit agency rotation requirement that satisfies the CFS’ verification wants with out inserting undue burdens on biofuel producers.
Extra broadly, we stay up for persevering with to work with you because the proposed modifications to the CFS are thought-about additional, and to make sure the position of biofuels in making Washington’s gasoline combine extra sustainable and assist the state obtain its ambitions local weather targets by way of the usage of bioethanol.
Thanks prematurely in your consideration.
