Thanks for the chance to supply written feedback in response to the New Mexico Surroundings Division (NMED) Clear Transportation Gasoline Customary’s (CTFS) Advisory Committee and its technical report. Progress Vitality is the world’s largest affiliation of biofuel producers, representing 97 U.S. vegetation 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 carry higher and extra inexpensive selections on the gasoline pump to shoppers, enhance air high quality, and shield the setting 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.
We applaud New Mexico’s efforts to scale back carbon emissions by means of the CTFS. Progress Vitality has beforehand offered in depth 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 so far and are poised to proceed to take action with applicable updates to this system. Moreover, as talked about within the June 28 Advisory Committee assembly, bioethanol has been a big credit score generator within the Oregon and Washington packages. Like these states, we imagine the CTFS has the chance to make the most of biofuels as a method of quick greenhouse fuel (GHG) discount within the present light-duty automobile fleet as future applied sciences are additional developed.
Environmental and Financial Worth of Bioethanol
Based on current information from Environmental Well being and Engineering, at this time’s bioethanol reduces GHG by almost 50 p.c in comparison with gasoline and may present even additional GHG reductions with further available applied sciences.
The potential for fuels with greater 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 the next 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 corresponding to carbon monoxide, and benzene.
Use of GREET for Life Cycle Evaluation Modeling
We imagine the Argonne Nationwide Laboratory’s GREET mannequin is probably 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 commonplace for measuring the emissions-reducing energy of farm-based feedstocks and biofuels. It incorporates up-to-date science that extra precisely scores lifecycle carbon depth (CI) for corn ethanol and different renewable fuels.
Reject Caps and Sustainability “Guardrails” on Biofuels
As a number of members of the CTFS Advisory Committee famous in shows and we reiterated above, biofuels have been a serious driver of GHG reductions in current gasoline commonplace packages. They’ve been in a position to be so regardless of onerous, and we imagine pointless, land use change (LUC) penalties for cornstarch bioethanol of various values, together with 19.8 gCO2e/MJ in California’s Low Carbon Gasoline Customary. This penalty was designed to mitigate alleged land use change with respect to cornstarch ethanol’s manufacturing. We imagine these scores to be outdated and never primarily based on the hottest analysis. A evaluation of more moderen science signifies a lowering development in land use values with the newer information indicating values nearer to 4 gCO2e/MJ.
Considerations over land use change for cornstarch ethanol are unfounded. The US is planting grain corn on roughly the identical variety of acres because it was in 1900. On the similar time, the per acre yield has elevated greater than 600%. Capping using bioethanol within the CTFS or adopting a sustainability framework just like what has been proposed by the California Air Sources Board would create an unfair double penalty on cornstarch ethanol along with violating the New Mexico legislature’s directive for expertise neutrality in this system.
Increasing E15 and Increased Blends
Emissions reductions by means of using E15 additionally include significant shopper cost-savings. In the course of the summer season of 2023, E15 was offered at 15 cents much less per gallon the place out there on common nationwide. In some places, we noticed E15 promoting persistently for as a lot as 60 cents much less per gallon than E10.
Shoppers have embraced E15’s repute as a extra environmentally helpful, extra inexpensive gasoline. Because the US EPA permitted E15 in 2011, at which era there have been zero retailers providing it, its availability quickly expanded to what’s now greater than 3,400 retail websites in 32 states. Since then, drivers in America have relied on E15 to drive 100 billion miles.
Recognizing Carbon Seize and Different CI Discount Strategies
Bioethanol producers consistently 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 decreasing CI is carbon seize utilization and sequestration (CCUS). Lately, California adjusted their modeling to account for CCUS, recognizing its significance in carbon discount. By accounting for CCUS, the pathway CI for E85—permitted to be used in California—was up to date such that it reduces the assumed CI rating for ethanol from 66 gCO2e/MJ to 35 gCO2e/MJ. We urge NMED to additionally acknowledge the CI reductions CCUS offers to biofuels pathways.
Moreover, we’ve got just lately advocated for expanded crediting for low-CI energy sourcing in California’s LCFS, Presently, the power to credit score low-CI energy in a pathway is restricted to particular gasoline pathways. Whereas CARB is contemplating increasing crediting potential to hydrogen-as-fuel pathways, we imagine the power to credit score new low-CI energy sourcing—energy not included in a utility’s preexisting capability—by means of energy buy agreements ought to be out there to all feedstocks and pathways. With bioethanol manufacturing occurring completely outdoors of New Mexico, the state has a chance 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 power of all gasoline pathways to credit score low-CI energy sourcing of their CI rating.
On-farm carbon discount practices, generally known as climate-smart agriculture (CSA), must also be credited within the CTFS. With using the GREET mannequin, together with the mannequin’s Feedstock Carbon Depth Calculator, together with 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 software, and using enhanced effectivity fertilizer.
Bioethanol producers have all kinds of instruments at our disposal to scale back our product’s carbon depth. We strongly urge NMED to think about maximizing the alternatives for bioethanol producers to decrease the CI for bioethanol pathways.
Sustainable Aviation Gasoline (SAF)
As producers of some of the scalable feedstocks for SAF manufacturing, we recognize NMED’s consideration to improvement of this key market. We encourage NMED to work with SAF producers, biofuel feedstock producers, and airways to hunt methods to speed up use of those essential fuels to assist decarbonize the aviation sector.
Thanks for the chance to supply enter on the CTFS Advisory Committee’s technical report. The CTFS might be a important device in New Mexico’s decarbonization efforts, and we stay up for 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 by means of the expanded use of bioethanol. Moreover, we’re completely satisfied to make ourselves out there for any questions NMED might have.
