In comments submitted today to the U.S. Environmental Protection Agency, the Renewable Fuels Association called on EPA to abandon its proposal to create a de facto electric vehicle mandate and instead adopt a market-oriented, technology-neutral approach to transportation decarbonization.
The comments were submitted in response to EPA’s proposed multi-pollutant emissions standards for model years 2027 and later light-duty and medium-duty vehicles.
“Unfortunately, EPA’s proposal would effectively force automakers to produce more battery electric vehicles (BEVs) and strongly discourage them from pursuing other technologies that could achieve the same—or even better—environmental performance at a lower cost to American consumers,” wrote RFA President and CEO Geoff Cooper. “EPA’s proposed approach ignores the significant upstream emissions related to electricity generation, as well as the substantial emissions involved in battery mineral extraction and processing.”
RFA’s comments today follow Cooper’s testimony at a May EPA hearing, and a joint letter sent to the Agency this morning by a coalition of farm, biofuel and fuel marketer organizations.
In its extensive comments, RFA encouraged EPA to use a full lifecycle analysis approach to assessing the true greenhouse gas impacts of various transportation options. RFA noted that multiple studies show ethanol significantly reduces greenhouse gas emissions and is on the way to net-zero carbon emissions by 2050 or sooner. EPA’s proposed regulation favors BEVs by treating them as “zero emissions vehicles” and ignoring the upstream emissions related to electricity production, as well as mining and processing of critical battery minerals. In the end, RFA argued, emissions regulations should not dictate certain vehicle technologies, and should instead adopt technology-neutral approaches that embrace a broad portfolio of low-carbon fuel and vehicle options.
“If our nation is to reach its goal of net-zero GHG emissions by mid-century, we’ll need cleaner, more efficient cars and cleaner, more efficient fuels,” Cooper wrote. “And, we’ll need to account for their emissions honestly using a full lifecycle approach. Focusing only on emissions from the vehicle—while ignoring emissions related to the extraction and production of the fuel used to power the vehicle—will almost certainly result in falling far short of the administration’s overall climate goals.”
