E15: Fueling America’s Shift to a Green Economy

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Table of ContentsSummary 3

Policy Recommendations for The First 100 Days Of The New Administration 3

The Problem 4

The Solution 5

Why E15 Should be a Priority 7

Climate 7

Health 7

Environmental Justice 8

Rural Development and Job Creation 9

How to Make E15 America’s Fuel 10

Policy Recommendations for The First 100 Days Of The New Administration 10

Legislative Recommendations for The President & The 117th Congress 12

Conclusion 13

APPENDIX: Myth Busting 14

AmericasFuel.com ■ AProjectofPOETLLC

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SummaryToday, our planet is warming faster, Americans are suffering from pollution-related health problems, and we are sending billions of dollars overseas every year—all because of our addiction to fossil fuels.

Breaking that addiction is complicated, and it won’t happen overnight. But there are steps we can take right now to slow climate change, make our communities healthier, and reduce our dependence on foreign oil—all while creating good jobs and boosting the American economy.

E15—a fuel blend consisting of 15% ethanol—is an important part of that transition.

While our ultimate goal should be a zero-carbon future, getting there will require different solutions—including ways to immediately reduce the harmful emissions poisoning the air and warming our planet. E15 is efficient, affordable, and available. It’s cleaner and less expensive than petroleum, it’s compatible with almost all existing cars, trucks and SUVs, and it’s a promising opportunity for family farms and rural communities across the country.

For all these reasons and more, the federal government should make it easier for more retailers to sell and more consumers to use E15 right now.

Policy Recommendations for The First 100 Days Of The New Administration

■ Strictly enforce the RFS and apply the U.S. 10th Circuit small refinery waiver decision nationwide

■ Set volumetric targets according to the clear intent of Congress – to increase biofuels in the fuel supply

■ Remove or improve retail fuel labeling requirements for E15 causing unnecessary confusion at the pump

■ Update EPA’s flawed modeling with accurate science reflecting biofuels’ GHG and air quality benefits

■ Undertake a Mobile Source Air Toxics rulemaking to reduce harmful constituents of gasoline and related health risks

■ Reinstate incentives for Flex Fuel Vehicles in federal fuel efficiency standards

■ Incentivize safer fuel infrastructure for cleaner fuels like E15 through existing USDA programs and funding authority

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The ProblemPetroleum-based gasoline has been powering the vast majority of vehicles on the road for more than a century, and the consequences have been severe.

The most alarming effect of burning petroleum has been to accelerate the effects of climate change. We are already seeing record-breaking wildfires, hurricanes and agricultural disasters in the U.S., and a 2018 report1 by the United Nations Intergovernmental Panel on Climate Change (IPCC) predicted even more dramatic changes linked to a warming planet—from worsening wildfires to increasing poverty—as soon as 2040.

Beyond harming the environment, tailpipe emissions also pose serious health risks—particularly among people living in “fenceline communities” located near refineries, highways and transportation hubs and made up largely of people of color.2 Harmful fuel additives like BTEX (benzene, toluene, ethylbenzene, xylenes) still make up 20% of gasoline by volume, and the ultra-fine particles released when BTEX is burned are toxic even at low levels, especially to children.3 A recent Harvard study4 also found that COVID-19 patients in areas with high levels of air pollution before the pandemic are more likely to die from the virus than patients living in areas with less air pollution from vehicles.

Finally, our reliance on petroleum means that we are still far from energy independence. The U.S. consumes more than 20 million barrels of oil per day,5 with the price of that oil set on the global market. In 2019 alone, the U.S. sent some $35 billion, or $275 per American household, to OPEC nations in exchange for oil.6 Meanwhile, American farmers and rural communities are struggling.

1 https://www.ipcc.ch/srccl/2 https://www.stateoftheair.org/key-findings/people-at-risk.html3 EESI “Guide to Gasoline Aromatics”4 https://www.ncbi.nlm.nih.gov/pmc/articles/PMC7277007/5 https://www.eia.gov/tools/faqs/faq.php?id=33&t=66 https://ethanolrfa.org/energy-independence/

https://www.ipcc.ch/srccl/ https://www.stateoftheair.org/key-findings/people-at-risk.htmlhttps://www.eia.gov/tools/faqs/faq.php?id=33&t=6 https://ethanolrfa.org/energy-independence/

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The SolutionThe answer to all these problems is to end Big Oil’s monopoly on America’s gas tank.

Over the long-term, that means shifting all vehicles and related infrastructure completely off petroleum. That evolution depends on widespread adoption of zero and near-zero emission electric vehicles (EVs), including battery electric vehicles, plug-in hybrid electric vehicles, and hybrid electric vehicles. To realize the full zero carbon potential of EVs, the U.S. must invest in 100% renewable power generation and develop a nationwide electric transmission “supergrid”7 and EV charging network.

While a zero-carbon future is ideal, it’s also a long way off. Sales of EVs in particular are slowing8 at a time when the world’s demand for oil is not predicted to peak for two more decades.9 Even after every car sold is zero-emission, it will still be a decade before 70% of vehicles on the road are electric and 15 years before that number reaches 90%.10 Because the energy used to produce batteries and power electric vehicles comes from a variety of sources, including coal and fossil fuels, driving an electric vehicle in some regions of the country can actually generate higher greenhouse gas (GHG) emissions than driving a vehicle powered by a cleaner renewable fuel blend, like E15.

That’s why the immediate solution is to give every American access to renewable, low-carbon fuel that will reduce our dependence on foreign oil and cut GHG emissions from the almost 257 million gas-powered light duty vehicles on the road today.11

Biofuels, and E15 in particular, have been proven to work. Thanks to the Renewable Fuel Standard (RFS), which requires increases in the volume of renewable fuels consumed, almost all gasoline in the U.S. now contains approximately 10% ethanol.12 The result has been cleaner air and a healthier environment. Over the first ten years of the RFS, biofuels including E10 (a fuel blend consisting of 10% ethanol) cut transportation-related emissions in the U.S. by almost 590

7 https://climatecrisis.house.gov/sites/climatecrisis.house.gov/files/Climate%20Crisis%20Action%20Plan.pdf (pg. 51)8 https://www.mckinsey.com/industries/automotive-and-assembly/our-insights/mckinsey-electric-vehicle-index-eu-

rope-cushions-a-global-plunge-in-ev-sales9 https://www.wsj.com/articles/global-oil-demand-wont-peak-before-2040-opec-says-1160215840010 https://climatecrisis.house.gov/sites/climatecrisis.house.gov/files/Climate%20Crisis%20Action%20Plan.pdf (pg. 101)11 Growth Energy 10/15/2012 https://www.eia.gov/todayinenergy/detail.php?id=26092

https://climatecrisis.house.gov/sites/climatecrisis.house.gov/files/Climate%20Crisis%20Action%20Planhttps://www.mckinsey.com/industries/automotive-and-assembly/our-insights/mckinsey-electric-vehicle-ihttps://www.mckinsey.com/industries/automotive-and-assembly/our-insights/mckinsey-electric-vehicle-ihttps://www.mckinsey.com/industries/automotive-and-assembly/our-insights/mckinsey-electric-vehicle-ihttps://www.wsj.com/articles/global-oil-demand-wont-peak-before-2040-opec-says-11602158400https://climatecrisis.house.gov/sites/climatecrisis.house.gov/files/Climate%20Crisis%20Action%20Planhttps://www.eia.gov/todayinenergy/detail.php?id=26092 https://www.eia.gov/todayinenergy/detail.php?id=26092

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million metric tons—the equivalent of removing more than 124 million cars from the road.13 If the U.S. transitioned from E10 to E15, it would be the equivalent of removing an additional 3.85 million vehicles from U.S. roads each year.14

Biofuels are also making a difference at the state level. California and Oregon, which have led the country in pushing low-carbon transportation policies, have both relied heavily on biofuels to reduce GHG emissions.15 While EVs are a growing part of the states’ clean fuel programs, without biofuels generating carbon credits (tradeable certificates that represent the avoidance or removal of one ton of carbon dioxide emissions) the program would have resulted in drastic swings in energy prices and possibly failed.

E15 will do even more. The higher percentage of renewable fuel means it can reduce harmful emissions even more than traditional E10. Any car manufactured in 2001 or later—more than 95% of vehicles on the road today16—can use it. And consumers have already driven 17 billion miles on E15—two miles for every person on Earth.17

13 https://www.bio.org/sites/default/files/legacy/bioorg/docs/RFS%2010%20Year%20GHG%20Reductions.pdf14 http://www.airimprovement.com/reports/national-e15-analysis-final.pdf 15 https://ww3.arb.ca.gov/fuels/lcfs/dashboard/dashboard.htm; https://www.oregon.gov/deq/aq/Documents/cfpQ12020DataSum.pdf16 https://growthenergy.org/wp-content/uploads/2020/11/Analysis-of-Ethanol-Compatible-Fleet-for-Calen-

dar-Year-2021-Final.pdf17 Growth Energy Weekly Rundown 10/15/20

https://www.bio.org/sites/default/files/legacy/bioorg/docs/RFS%2010%20Year%20GHG%20Reductions.pdfhttp://www.airimprovement.com/reports/national-e15-analysis-final.pdfhttps://ww3.arb.ca.gov/fuels/lcfs/dashboard/dashboard.htmhttps://www.oregon.gov/deq/aq/Documents/cfpQ12020DataSum.pdfhttps://ww3.arb.ca.gov/fuels/lcfs/dashboard/dashboard.htm https://growthenergy.org/wp-content/uploads/2020/11/Analysis-of-Ethanol-Compatible-Fleet-for-Calendahttps://growthenergy.org/wp-content/uploads/2020/11/Analysis-of-Ethanol-Compatible-Fleet-for-Calendahttps://www.oregon.gov/deq/aq/Documents/cfpQ12020DataSum.pdf

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Why E15 Should be a PriorityE15 is a unique opportunity to build bipartisan consensus on several key national priorities. Leaders from both parties recognize the benefits of E15—many of which fall into four major categories:

Climate

A recent comprehensive lifecycle analysis—assessing the overall GHG impacts of a fuel, including each stage of its production and use—shows that ethanol is actually 42% cleaner than traditional gasoline,18 and technology that is being implemented today will improve ethanol’s GHG advantage over petroleum even further.

Biofuels are becoming cleaner over time. Studies have shown that biofuel manufacturing promises to serve as a net sink of GHGs, absorbing more carbon than it releases, if a combination of renewable power generation, carbon sequestration, and continued reductions from sustainable agricultural practices are implemented. With the right incentives for growing corn more sustainably, farmers would be able to reduce or eliminate the net amount of carbon released into the atmosphere by growing crops closer together, using less fertilizer, tilling the soil less often, and taking other steps to store carbon in the soil. These continuing innovations in sustainable farming will further reduce the lifecycle carbon intensity of E15 over time, making it by far the most environmentally sustainable fuel for the most vehicles.

Health

Ethanol replaces harmful carcinogens and toxic additives, like MTBE and BTEX, used in regular gasoline, while still providing a high-octane boost—improving both performance and fuel economy. A study by the University of California Riverside found that ethanol blends reduce toxic emissions by up to 50%, including smog and ultra-fine particles.19

18 Argonne National Laboratory. 2019b. GREET 2019.Ibid. Argonne National Laboratory. 10.11578/GREET-Excel-2019/dc.20200706.1

19 https://fixourfuel.com/wp-content/uploads/2018/04/UC-Riverside-Study.pdf

https://fixourfuel.com/wp-content/uploads/2018/04/UC-Riverside-Study.pdf

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Another study by the University of Illinois Chicago found that introducing ethanol in cities around the world reduced benzene-related cancer by more than 20%—saving lives and reducing health care costs and lost wages.20

EnvironmentalJustice

Any solution to climate change needs to work for everyone, especially people who live in fenceline communities that disproportionately suffer from air pollution and related health risks.21 That means no solution should penalize anyone who is low income, lives on a fixed income, or comes from an underserved community.

In the short-term, that means EVs will only solve a small part of a big problem. A recent study found that, even with falling battery costs, EVs will remain significantly more expensive for automakers to build than internal-combustion vehicles for at least a decade.22 As a result, while consumers can save on gas with EVs, those vehicles will still cost more upfront—and the secondary market for EVs is extremely limited. Finally, most homes, especially multifamily dwellings and homes in less affluent neighborhoods, don’t have the infrastructure necessary to charge EVs.

E15 doesn’t require new cars or new infrastructure, so it’s accessible and affordable to everyone. In fact, because ethanol is less expensive than gasoline, E15 is typically between 3-10 cents less than today’s standard E10 gasoline.23 That’s especially important for low-income families. And because E15 replaces some of the most harmful toxic components in gasoline, it helps clean the air in densely populated, heavily trafficked urban communities.

20 UIC Engineering: Health Impact of Blending Ethanol into Gasoline in 5 Global Cities21 TRECH Project Research Update 10/6/2022 https://www.greencarreports.com/news/1129461_evs-cost-more-to-build-even-after-batteries-get-cheaper23 Progress Report: E15 rapidly moving into the marketplace 10/7/20

https://www.greencarreports.com/news/1129461_evs-cost-more-to-build-even-after-batteries-get-cheaper

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RuralDevelopmentandJobCreation

In order to build back better, we need a plan for growing the economy, especially rural areas. Biofuels are part of the answer.

Biofuels are a homegrown remedy to ease trade uncertainty. In 2019, biofuels displaced more oil than the U.S. imported from Saudi Arabia, Iraq, and Kuwait combined.24 E15 can displace substantially more fossil fuel imports and provide farmers with dependable new domestic demand and price stability for their grain.

Higher demand for corn also means that family farms can stay in business without relying on billions in support from the federal government. Making E15 available nationwide drives demand for an additional 2 billion bushels of U.S. grain annually, which farmers are prepared to produce right now without converting any additional land to agricultural production. It would balance oversupplied grain markets and boost incomes for farmers.

Biorefineries also create good-paying, STEM-focused jobs. In 2019, almost 70,000 jobs were directly associated with ethanol production. When you include the direct, indirect and induced jobs supported by ethanol production, construction activity, agriculture, exports, and R&D that number rises to nearly 350,000 jobs in 2019.25

E15 would create even more opportunities in rural communities—many of which have been devastated by plants closing and jobs moving overseas and are hard to reach with traditional economic stimulus measures. Rising energy costs also disproportionately hurt rural poor communities.26 Lowering the cost of fuel for those communities with E15—while also creating jobs, injecting new capital investments, and boosting grain prices—would have a compounding effect, helping revitalize communities that desperately need it.

24 Fuels America: Myths and Facts about the RFS 25 ABF 2019 ethanol economic contribution report26 https://www.brookings.edu/opinions/how-higher-gas-prices-hurt-less-affluent-consumers-and-the-economy/

https://www.brookings.edu/opinions/how-higher-gas-prices-hurt-less-affluent-consumers-and-the-econom

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How to Make E15 America’s FuelIn order for more vehicles to run on cleaner E15, more fuel retailers need to offer it, so more consumers have access to it. The following recommendations would encourage the widespread adoption of E15 and the benefits that come with it.

Policy Recommendations for The First 100 Days Of The New AdministrationStrictlyEnforcetheRenewableFuelStandard

When it was passed in 2007, the RFS was designed to encourage cleaner, more efficient fuel blends with higher volumes of ethanol. Since then, however, EPA has mismanaged the RFS, repeatedly trying to reduce the volumes of renewable fuel below statutory levels and dragging their feet on issuing annual volume requirements for renewable fuel. The federal courts have repeatedly found EPA’s actions to be unlawful.

Apply the U.S. 10th Circuit Small Refinery Waiver Decision Nationwide

The EPA should enforce the U.S. 10th Circuit Court decision nationwide, and apply the court’s decision to any remaining or future Small Refinery Exemption (SRE) petitions. To preserve enforcement mechanisms, EPA must require petroleum refiners to purchase Renewable Identification Numbers (RINs) in a manner consistent with the law and in quantities that encourage the reduction of GHGs. RINs are the credits used to comply with the RFS—essentially the currency of the program. A healthy RIN value would give both retailers and refineries an added incentive to blend more low-carbon biofuel and break through the artificial barriers that oil refiners use to block E15 from the market.

Set Volumetric Targets According to the Clear Intent of Congress—to Increase Biofuels in the Fuel Supply

EPA must implement the RFS in accordance with both the statutory text and the clear intent of Congress—increasing the volume of renewable fuels in the fuel supply, especially after 2022 when EPA has greater discretion in setting renewable fuel standards. The EPA has declined to set renewable volume obligations (RVOs) for compliance year 2021. To get RVOs back on track, EPA should set strong blending targets for total renewable fuel volumes, restore the 500 million gallons of renewable fuel obligations ordered by the D.C. Circuit Court in 2017, and ensure timely consideration and approval of all future RVOs.

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ImproveLabeling

Remove or Improve Retail Fuel Labeling Requirements for E15 Causing Unnecessary Confusion at the Pump

While almost all vehicles can use E15, fuel retailers are still required to label it in a way that can give consumers the false impression that E15 is not safe for their engines. Given that E15 compatible vehicles represent more than 97% of vehicle miles traveled, these labels are causing unnecessary confusion at the pump and should be removed. Alternatively, pumps could be required to display uniform labels for all fuels—including E10—and make it clear that E15 is compatible with most vehicles.

UpdateModeling

Update EPA’s Flawed Modeling with Accurate Science Reflecting Biofuels’ GHG and Air Quality Benefits

The EPA should adopt lifecycle GHG modeling of biofuels from the USDA that more accurately reflects continuing improvements in both biofuel production and on-farm sustainability practices. EPA should also update the flawed Motor Vehicle Emission Simulator (MOVES) model to better measure the actual benefits of biofuels on emissions of air pollutants, including criteria pollutants, GHGs, and air toxics.

MobileSourceAirToxicsRulemaking

Undertake a Mobile Source Air Toxics Rulemaking to Reduce Harmful Constituents of Gasoline and Related Health Risks

Years ago, EPA put a rule in place limiting the amount of benzene that could be used in gasoline after it was proven to cause cancer. At the time, EPA did not limit the other toxic components in gasoline—waiting to see how ethanol, which replaces these aromatics, worked before going any further. Today, we know that ethanol is effective, efficient, clean, and can be produced in large quantities. It’s time for EPA to use its existing authority to ratchet down the limits on all the toxic chemicals in gasoline and replace them with renewable fuels that reduce particulate matter and airborne toxins dangerous to human health.

CAFEStandards

Reinstate Full Incentives for Flex Fuel Vehicles in Federal Fuel Efficiency Standards

As the next administration revisits Corporate Average Fuel Economy (CAFE) standards, policymakers should ensure that states and automakers are sufficiently incentivized to reignite widespread production of flex fuel vehicles so American consumers maintain optimal ability to utilize low carbon fuels, including E15 and E85, in their engines.

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BiofuelInfrastructureProgram

Incentivize Safer Fuel Infrastructure for Cleaner Fuels like E15 through Existing USDA Programs and Funding Authority

As policymakers consider programs designed to roll out charging stations and hydrogen infrastructure for EVs, they should also focus on supporting biofuel infrastructure for the millions of vehicles capable of running on higher ethanol blends. Helping the nation’s fuel retailers replace outdated and potentially unsafe equipment and update pumps to better facilitate sales of E15, would go a long way towards making E15 available across the country.

Legislative Recommendations for The President & The 117th CongressBlenderIncentive

Encourage Fuel Retailers to Make the Switch to Cleaner Biofuel Blends

Providing a 5-cent blender tax credit over ten years would encourage retailers to switch out more expensive E10 and replace it with E15 at the pump. The Volumetric Ethanol Excise Tax Credit (VEETC), which encouraged the blending of ethanol in gasoline, did a great job moving gallons of renewable ethanol into the marketplace. However, when the credit expired in 2011, refineries became more resistant to blending higher volumes of renewable fuel. While the VEETC could be amended and put back into force, we would recommend a more nuanced approach that incentivizes only higher ethanol blends like E15 and not E10, which already dominates the fuel market. This would be a more cost-effective solution and could quickly lead to more vehicles running on cleaner fuel.

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ConclusionWhen it comes to ending our dependence on gasoline—and reversing all the consequences that come with it—there is no single magic bullet. We should keep working to eliminate all carbon emissions, but we also need a solution that is available, affordable, and can reduce the greenhouse gases being emitted by cars and trucks that are already on the road.

E15 represents that solution, and there are immediate steps the federal government can take to make ethanol and other biofuels more widely available so we can make progress on climate change, create good jobs, and continue to invest in the future.

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APPENDIX: Myth BustingSince biofuels reduce demand for gasoline, the oil industry has spent years conducting a smear campaign against ethanol. Here are the facts to set the record straight:

Myth#1: Ethanol isn’t environmentally sustainable.

Truth#1: FALSE. Farmers who produce the corn used to make ethanol have become more efficient than ever while protecting grasslands and forests.

■ America’s farmers are producing more food and energy than ever before on less cropland. Since 1930, grain yields have climbed eight fold, and continue to increase each year, while total acres planted across the U.S. decreased more than 13%.27 Biofuel production is also becoming more efficient. Precision farming techniques and other advances in technology and sustainability have dramatically reduced the volume of water28 and fertilizer required to produce each bushel of corn. Likewise, ethanol plants have reduced their energy consumption by 42% thanks to new technologies and conservation practices that improve year over year.29

Myth#2: Producing corn for ethanol increases GHG emissions.

Truth#2: FALSE. Biofuels of all kinds, including ethanol, substantially reduce GHG emissions over the course of their lifecycle compared to oil.

■ The carbon intensity of ethanol is currently 42% lower than gasoline,20 and continues to improve over time. This is comparable to the lifecycle benefits from electric vehicles in many markets.

27 https://www.nass.usda.gov/Publications/Todays_Reports/reports/croptr20.pdf28 Growth Energy – Biofuels: Protecting our Planet 29 ibid 30 Argonne National Laboratory. 2019b. GREET 2019.Ibid. Argonne National Laboratory. 10.11578/GREET-Excel-2019/

dc.20200706.1

https://www.nass.usda.gov/Publications/Todays_Reports/reports/croptr20.pdf

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Myth#3: The U.S. can’t produce enough ethanol to roll out E15 nationwide.

Truth#3: FALSE. Biorefineries have become extremely efficient and new production capacity can be added quickly.

■ In 2008, the year after a law was passed increasing the amount of ethanol blended into fuels, the amount of ethanol produced in the U.S. jumped almost 30% to 9.3 billion gallons per year. Today, we produce almost double that amount.31 It won’t happen overnight, but if the demand for E15 grows, the U.S. can produce enough fuel to meet demand—and do it sustainably. Right now, there are over 2 billion gallons of idled capacity available. New biorefineries and major production expansions at existing facilities can be constructed in as little as one year.

Myth#4: E15 damages engines and would require new equipment.

Truth#4: FALSE. There has never been any evidence that E15 damages engines, and most existing retail fueling equipment can handle higher ethanol levels.

■ EPA’s decision to approve the use of E15 in cars manufactured in model year 2001 and after was based on data collected from a rigorous, lengthy and extreme testing process that examined the performance of engines, emissions systems, and automobile drivability.32 In fact, no other fuel mix has been tested more.33 Since then, consumers have driven billions of miles with no reported cases of engine damage, misfiring, or inferior performance.34 And most equipment manufactured after 1980, including storage tanks, dispensers, piping, hoses, valves, nozzles, hanging hardware, is compatible for blends well above 10% ethanol.35 The nation of Brazil, for example, runs all vehicles on a minimum E27—27% ethanol blend—with many of the same engines and infrastructure currently in service across the U.S.36

31 https://afdc.energy.gov/data/10342 32 https://growthenergy.org/2011/07/06/growth-energy-e15-most-tested-fuel-in-history-will-benefit-america/33 ibid34 https://ethanol.org/ethanol-essentials/facts-about-e1535 https://ethanolrfa.org/wp-content/uploads/2017/11/RFA-UST-TALKING-POINTS-11.2017.pdf36 https://vitalbypoet.com/stories/brazilian-ethanol-retail-infrastructure-provides-model-for-united-states

https://afdc.energy.gov/data/10342 https://growthenergy.org/2011/07/06/growth-energy-e15-most-tested-fuel-in-history-will-benefit-amerihttp://ethanolproducer.com/articles/15432/biofuel-industry-criticizes-epaundefineds-triennial-reporthttps://ethanol.org/ethanol-essentials/facts-about-e15https://ethanolrfa.org/wp-content/uploads/2017/11/RFA-UST-TALKING-POINTS-11.2017.pdfhttps://vitalbypoet.com/stories/brazilian-ethanol-retail-infrastructure-provides-model-for-united-st