California Air Resources Board

Thank you for the opportunity to provide comments on the California Air Resources Board’s (CARB) proposed changes to the Low Carbon Fuel Standard (LCFS). The Ohio Ethanol Producers Association represents three of Ohio’s eight bioethanol plants. Ohio ethanol producers currently have approved Tier 2 pathways for the LCFS and have a vested interest in ensuring biofuels remains an important element of California’s efforts to reduce greenhouse gas (GHG) emissions.
Biofuels has provided the greatest contributions to GHG reductions since the LCFS was first implemented. Bioethanol producers have continued to innovate, lower our carbon footprint, and provide an affordable fuel option for California drivers.
The Ohio Ethanol Producers Association would like to continue to provide consumer-friendly, environmentally beneficial fuel for California drivers. The proposed LCFS changes contain provisions that would have a detrimental impact on bioethanol’s ability to contribute to California’s GHG reduction efforts.
The proposed sustainability certification for crop-based biofuels raises several serious concerns:
While the proposed certification would impose additional requirements on biofuel producers and farmers, it fails to acknowledge on-farm climate-smart practices in calculating the carbon intensity (CI) score.
Concerns regarding land use change relative to corn starch ethanol are unjustified. The acreage dedicated to corn cultivation has remained relatively constant over several decades, mirroring figures from the 1930s. The national increase in corn production stems solely from improved yields. Even if land use change were a concern, it is adequately addressed by the existing 19.8-point penalty.
Certain aspects outlined in the audit are irrelevant to a carbon-reduction initiative. Factors such as farm labor practices or profitability have no impact on the CI score.
Furthermore, these new audit provisions unrelated to CI would exclusively apply to crop-based feedstocks, exempting other fuel sources from similar scrutiny.
We encourage CARB to delay any sustainability certification requirements for bioethanol in the 2024 rulemaking. If the requirements are finalized, it could inadvertently result in less bioethanol used in the state and increased GHG emissions.
Additionally, we ask that CARB continue the process of approving E15 for sale and use in California. With E15 approval, GHG reductions from bioethanol use will be even greater, as bioethanol has as much as a 46% reduction in GHG compared to gasoline.
We thank you for the opportunity to provide comments and are happy to answer any questions Board member or CARB staff may have.