Pricey Mr. Shultz:
Thanks for the chance to answer the latest request for data (RFI) concerning methods to decarbonize America’s industrial sector. Progress Power is increasing the bioeconomy and is the nation’s largest affiliation of biofuel producers, representing 97 U.S. crops that every yr produce 9.5 billion gallons of low-carbon, renewable gasoline; 120 companies related to the manufacturing course of; and tens of 1000’s of biofuel supporters across the nation. Our members make low-carbon fuels and excessive protein animal feed and provide plant-based elements for every little thing from bioplastics to safer cleansing merchandise.
As we now have famous in different venues, U.S. management within the world sustainable biofuels markets is important to decarbonization and future financial competitiveness within the on-road, aviation, marine transport, and off-road sectors, along with the economic sector, and biofuels are the perfect software out there to take action. Whereas our members are primarily centered on transportation fuels, we’re exploring different alternatives all through the bioeconomy that might present an outlet for our low-carbon biofuels and different key coproducts to compete
and assist drive down greenhouse fuel emissions. As such, we’re joyful to be a useful resource for the Division because it examines potential alternatives for additional decarbonization within the industrial sector.
The economic sector accounts for one third of greenhouse fuel (GHG) emissions and requires a various and sophisticated set of power inputs, processes, and operations. Whereas traditionally decarbonization has been extra centered on the transportation sector, you will need to acknowledge biofuels and different bioproducts that will assist scale back GHG emissions from the economic sector as nicely. Importantly with any marketplace for biofuels and bioproducts, the company wants to consider scalability and dependable provide. The U.S. has
the biggest and most developed biofuels business on the earth. Over the previous 20 years, U.S. gasoline ethanol manufacturing has grown from 2.1 billion gallons/yr to fifteen.4 billion gallons/yr. Throughout this time, there was no observable improve in corn acres planted or associated adversarial impacts on meals costs. As an alternative, will increase in corn demand have constantly been met by elevated yield as agricultural practices have develop into extra environment friendly over time.
Our members produce bioethanol at this time primarily for on-road gasoline, however it is usually utilized in some chemical and different industrial settings. At present, all engines (each on-road and off-road) are authorized to be used with gasoline blended with 10 p.c bioethanol whereas all 2001 and newer passenger automobiles are authorized for gasoline blended with 15 p.c bioethanol alongside flex-fuel automobiles which are authorized for all bioethanol blends as much as E85. Our business may also present bioethanol sooner or later as a feedstock for sustainable aviation gasoline in addition to for different biochemicals. Moreover, our members produce distillers corn oil (DCO) as a coproduct that’s then used as a feedstock for each biodiesel and renewable diesel which can be utilized to energy quite a few industrial engines. And as our members broaden using carbon seize, utilization, and storage (CCUS) expertise, some are exploring the potential for fuels and different merchandise produced from an almost pure stream of captured carbon dioxide.
The U.S. biofuels business continues to show its capability to decrease GHG emissions and ship jobs and financial advantages to American employees and farmers. In depth analysis from the Division’s personal Argonne Nationwide Laboratory via its Greenhouse Gases,
Regulated Emissions, and Power Use in Applied sciences (GREET) mannequin has proven that at this time’s bioethanol supplies an almost 50 p.c discount in comparison with gasoline in lifecycle GHG emissions and might get to net-zero emissions with using available applied sciences resembling CCUS. The biofuels business has additionally helped to create a whole lot of 1000’s of jobs right here in america and supplies a secure marketplace for American farmers whereas persevering with to scale back costs on the gasoline pump for the on-road fleet.
Decrease-carbon fuels and bioproducts would require scalability, highlighting the necessity for and significance of a secure coverage atmosphere. The federal Renewable Gasoline Commonplace (RFS) is foundational to all the U.S. biofuels business and its capability to supply a wide range of fuels and feedstocks to be used throughout transportation sectors. Any expanded use of biofuels for off-road use would require a powerful and rising RFS.
Moreover, the U.S. Division of the Treasury is within the midst of implementing a number of key tax biofuel tax incentives together with the Clear Gasoline Manufacturing (45Z), Carbon Seize (45Q), and Sustainable Aviation Gasoline (40B) credit. These provisions are important to our business’s capital-intensive investments to scale back greenhouse fuel emissions and in the end to the achievement of the administration’s broad local weather targets, together with the SAF Grand Problem and the potential to get to net-zero by 2050. As we now have articulated in a number of feedback to Treasury (out there right here, right here, right here, and right here), it’s important that the Argonne GREET mannequin be used for any lifecycle emissions evaluation as it’s the greatest software out there for measuring biofuel lifecycle emissions. Actually, earlier this yr, EPA highlighted that “the GREET mannequin is nicely established, designed to adapt to evolving information, and able to together with technological advances.” Additionally, implementation of those credit should permit for a variety of carbon depth discount methods together with, however not restricted to, CCUS applied sciences and tasks, renewable energy, and lots of rising farm and agricultural practices. From our earlier feedback, under is a desk of potential reductions of carbon depth at our bioethanol crops. Any significant targets for using crop-based biofuels for the economic or different exhausting to decarbonize sectors can’t be achieved with out using the Argonne GREET mannequin and recognition of a wide range of carbon depth discount methods.
Thanks in your consideration and we’re joyful to be a useful resource because the Division additional explores the potential for broader bioethanol use within the industrial sector.
