Ms. Borchert,
Thanks for the chance to supply written feedback in response to the New Mexico Surroundings Division’s (NMED) draft of the Clear Transportation Gasoline Program (CTFP) rule. Progress Vitality is the world’s largest affiliation of biofuel producers, representing 97 U.S. crops that every 12 months produce greater than 9.5 billion gallons of renewable gasoline; 123 companies related to the manufacturing course of; and tens of hundreds of biofuel supporters across the nation. Collectively, we’re working to convey higher and extra inexpensive selections on the gasoline pump to customers, enhance air high quality, and defend the atmosphere for future generations. We stay dedicated to serving to our nation diversify our vitality portfolio as a way to develop extra inexperienced vitality jobs, decarbonize our nation’s vitality combine, maintain household farms, and drive down the prices of transportation fuels for customers.
We applaud New Mexico’s efforts to scale back carbon emissions via the CTFP. Progress Vitality has beforehand offered intensive feedback on comparable packages in California, Washington, and Oregon, making certain these states acknowledge the carbon discount worth of
elevated bioethanol use. In California, biofuels have been among the many largest contributors to the success of the LCFS program to this point and are poised to proceed to take action with acceptable updates to this system. Moreover, as talked about within the June 28, 2024 Advisory Committee assembly, bioethanol has been a big credit score generator within the Oregon and Washington packages. Like these states, we consider the CTFP has the chance to make the most of biofuels as a method of speedy greenhouse fuel (GHG) discount within the present light-duty automobile fleet as future applied sciences are additional developed.
Environmental Advantages of Bioethanol
In response to latest knowledge from Environmental Well being and Engineering, at present’s bioethanol reduces GHG by practically 50 % in comparison with gasoline and might present even additional GHG reductions with extra available applied sciences. The potential for fuels with larger blends of ethanol to scale back GHGs are additional illustrated in a nationwide evaluation displaying greater than 146,000 tons in GHG discount in New Mexico alone if E10 gasoline was changed with E15. That is the GHG discount equal of eradicating 32,000 automobiles from New Mexico’s fleet simply through the use of a better ethanol-blend gasoline.
Bioethanol’s different environmental advantages are additionally noteworthy. As has been researched by the College of California, Riverside and the College of Illinois at Chicago, using extra bioethanol and bioethanol-blended gasoline reduces dangerous particulates and air toxics resembling carbon monoxide, and benzene.
Use of GREET for Life Cycle Evaluation Modeling
We applaud NMED for using the Argonne Nationwide Laboratory’s GREET mannequin, with parameters particular to New Mexico, to calculate life-cycle emissions of fuels topic to the CTFS. ANL GREET is essentially the most correct device to look at the life-cycle greenhouse fuel emissions of all fuels and considers a variety of carbon discount processes and applied sciences that bioethanol manufacturing can make the most of. It’s the gold normal for measuring the emissions-reducing energy of farm-based feedstocks and biofuels and incorporates up-to-date science that extra precisely scores lifecycle carbon depth (CI) for corn bioethanol and different renewable fuels.
Applicable Land Use Change Penalties
As has been reiterated all through the Advisory Committee’s public assembly course of and in our earlier feedback, biofuels have been a serious driver of GHG reductions in present gasoline normal packages. They’ve been in a position to be so regardless of onerous, and we consider pointless, land use change (LUC) penalties for cornstarch bioethanol of various values, together with 19.8 gCO2e/MJ in California’s Low Carbon Gasoline Normal. This penalty was designed to mitigate purported land use change with respect to cornstarch bioethanol’s manufacturing. We consider these scores to be outdated and never primarily based on the freshest analysis. A overview of newer science signifies a reducing development in land use values with the newer knowledge indicating values nearer to 4 gCO2e/MJ.
Issues over land use change for cornstarch bioethanol are unfounded. The USA is planting grain corn on roughly the identical variety of acres because it was in 1900. On the identical time, the per acre yield has elevated greater than 600%. We urge NMED to rethink the applying of a 19.8 gCO2e/MJ LUC penalty for cornstarch bioethanol, think about knowledge primarily based on newer analysis and apply a LUC penalty that’s reflective of that knowledge.
Increasing E15 and Larger Blends
Emissions reductions via using E15, typically marketed as Unleaded 88, additionally include significant shopper cost-savings. In the course of the summer time of 2024, drivers saved 10 to 30 cents per gallon by filling up with Unleaded 88 in comparison with common, or E10. In some areas, Unleaded 88 saved drivers as a lot as a greenback per gallon on the pump.
Shoppers have embraced E15’s popularity as a extra environmentally useful, extra inexpensive gasoline. Because the US EPA authorised E15 in 2011, at which period there have been zero retailers providing it, its availability quickly expanded to what’s now greater than 3,714 retail websites in 33 states. Since then, drivers in America have relied on E15 to drive 140 billion miles.
Clarifying Carbon Seize and Sequestration
Bioethanol producers continually make enhancements to their manufacturing course of, rising financial effectivity and extra importantly, decreasing CI. Among the many latest instruments bioethanol producers are using to scale back CI is carbon seize utilization and sequestration (CCUS). The newest analysis carried out by the Vitality Futures Initiative (EFI) Basis exhibits that simply using CCUS in bioethanol manufacturing can scale back its CI by as a lot as 57%, demonstrating the essential position CCUS performs in bioethanol’s path towards turning into a net-zero gasoline. We applaud NMED for recognizing CCUS as a method for carbon discount, and respect the inclusion of CCUS in sure Tier 2 pathways (Tier 1 fuels utilizing modern strategies or a course of that can’t be precisely represented utilizing the simplified calculators used to calculate Tier 1 carbon intensities) novel to New Mexico.
Nonetheless, given the wording of the draft guidelines, it may very well be interpreted in such a means that precludes fuels listed as Tier 2 fuels, resembling different jet gasoline, from using CCUS. As alcohol-to-jet sustainable aviation gasoline (SAF) turns into extra prevalent, SAF producers will depend on bioethanol, a Tier 1 gasoline, with CCUS to scale back CI. This leaves the query of whether or not SAF produced with a bioethanol pathway using CCUS might be authorised as a Tier 2 pathway.
We encourage NMED to make clear this provision, an whether or not modern strategies resembling CCUS can be utilized in different Tier 2 fuels resembling different jet gasoline. CCUS is a crucial device for sustainable aviation gasoline (SAF) producers to attain the carbon depth discount mandatory to satisfy our nation’s GHG discount objectives within the aviation sector.
Local weather-Sensible Agriculture Practices
With using the GREET mannequin, we encourage NMED to think about permitting on-farm carbon discount practices, generally known as climate-smart agriculture (CSA), also needs to be credited within the CTFS. With GREET’s Feedstock Carbon Depth Calculator and the USDA’s database of CSA practices, the carbon discount values can simply be quantified and verified.
Amongst these practices are using cowl crops, low or no-till farming, precision fertilizer utility, and using enhanced effectivity fertilizer. The beforehand talked about EFI Basis research discovered that these 4 CSA practices might lead to as a lot as 59% CI discount for bioethanol. NMED ought to make sure the inclusion of CSA practices as allowable CI discount instruments for crop-based biofuels.
Permitting Biofuels Producers to Entry Crediting for Low-CI Energy
Moreover, we proceed to advocate for expanded crediting for low-CI energy sourcing for biofuels producers via renewable vitality certificates (RECs). Within the draft CTFP guidelines, the flexibility to make the most of RECs in a pathway is proscribed to sure feedstocks. We consider the flexibility to credit score low-CI energy sourcing via energy buy agreements ought to be out there to all feedstocks and pathways.
The aforementioned EFI research indicated using carbon-free electrical energy within the bioethanol manufacturing course of can scale back its CI by 6% whereas using biomass for mixed warmth and energy (CHP) can scale back its CI by as a lot as 37%. The EFI research suggests biomass CHP might be applied with minimal prices and it’s prepared for widespread adoption within the close to time period.
With bioethanol manufacturing occurring fully exterior of New Mexico, the state has a possibility to change into a nationwide chief by encouraging, by way of the CTFS, the adoption of low-CI energy for bioethanol producers in different jurisdictions. We encourage NMED to think about the flexibility of all gasoline pathways to credit score low-CI energy sourcing of their CI rating.
Different Carbon Discount Processes and Applied sciences
Under are extra examples of the big variety of feedstocks and applied sciences bioethanol producers have out there for CI discount. We proceed to encourage NMED to supply crop-based biofuels the widest set of possible and able to undertake alternatives for carbon discount.
Sustainable Aviation Gasoline (SAF)
As producers of one of the vital scalable feedstocks for SAF manufacturing, we respect NMED’s consideration to improvement of this key market and the CTFP’s allowance of SAF to generate credit. We encourage NMED to work with SAF producers, biofuel feedstock producers, and airways to hunt methods to speed up use of those necessary fuels to assist decarbonize the aviation sector.
Thanks for the chance to supply enter on the draft CTFP proposal. The CTFS might be a essential device in New Mexico’s decarbonization efforts, and we look ahead to working with NMED to make sure the position of biofuels in making New Mexico’s gasoline combine extra sustainable and assist the state obtain its progressive local weather objectives via the expanded use of bioethanol. Moreover, we’re comfortable to make ourselves out there for any questions NMED might have.
