The Renewable Fuels Association late yesterday called on California to allow the lower-cost, lower-carbon E15 fuel blend, containing 15 percent ethanol, as part of its efforts to enhance the state’s Low Carbon Fuel Standard.
“E15 is a critical near-term strategy for decarbonizing liquid fuels, which will continue to dominate transportation in California for years, if not decades, to come,” wrote RFA Chief Economist Scott Richman in comments to the California Air Resources Board (CARB). “From a consumer perspective, E15 offers a unique opportunity to lower the cost of gasoline while cutting emissions of greenhouse gases and criteria pollutants.”
Richman cited a recent study indicating that E15 could shave 20 cents off the cost of a gallon of gasoline in California, which has the nation’s highest average fuel prices. This would equate to total statewide annual savings of $2.7 billion.
In the comments, submitted in response to modifications CARB proposed to California’s LCFS on August 12, RFA also pushed back on expanded feedstock tracking requirements as both unnecessary and overly burdensome.
These requirements were initially proposed primarily in response to the potential for rapid expansion of biomass-based diesel (BBD). However, Richman noted, in the changes to the proposed LCFS amendments issued on August 12, CARB “capped the generation of credits for BBD from ‘virgin soybean oil and canola oil’ at 20% of annual BBD volumes on a company-wide basis. Yet, CARB did not remove the sustainability requirements, even though they were intended to accomplish the same objective. Instead, CARB doubled down by making the requirements more onerous.”
RFA detailed the burdensome nature of these requirements, such as the need to maintain boundary coordinates of farms from which feedstocks are sourced, sign attestations about the specific land on which the feedstock was produced, and meet comprehensive chain-of-custody obligations. Instead, Richman wrote, “if California moves ahead with any feedstock certification program, there should be a provision to designate all U.S.-produced ethanol as already in compliance, so long as aggregate cropland area does not expand beyond a 2007 baseline. This would be consistent with the EPA’s approach under the federal Renewable Fuel Standard.”
