Advanced Biofuels USA Recommends a Maryland Interagency Biofuels and Clean Fuel Standard Working Group

July 31, 2026

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by Joanne Ivancic* (Advanced Biofuels USA) Building on the work of the Maryland Biofuels Task Force, created to help the state meet the goals of the Climate Solutions Now Act (CSNA) of 2022, which requires a 60% reduction in greenhouse gas emissions from 2006 levels by 2031, and net-zero emissions by 2045, Advanced Biofuels USA has recommended to the Maryland Commission on Climate Change that an Interagency Biofuels and Clean Fuel Standard Work Group be created. In its recent report, the Commission recommended that Maryland evaluate a Clean Fuel Standard or other measures to increase production, importation, and use of lower-carbon transportation fuels

Today, Advanced Biofuels USA expanded on the recommendation made by the Maryland Biofuels Task Force, as it expanded on the Task Force report by broadening the focus to include sustainable aviation fuel and sustainable maritime fuels and filed the following with the Commission.

Organizational Request to the Maryland Commission on Climate Change

Recommendation to Establish a Maryland Interagency Biofuels and Clean Fuel Standard Working Group

TO: Maryland Commission on Climate Change

cc: MD Senator Karen Young (karen.young@senate.maryland.gov); Karen Simpson (karen.simpson@house.maryland.gov); Ken Kerr (ken.kerr@house.maryland.gov); Kris Fair (kris.fair@house.maryland.gov

Submitted by: Joanne Ivancic, Executive Director

Organization: Advanced Biofuels USA

Contact: info@advancedbiofuelsusa.org 301-644-1395 (office, landline)

Date submitted: July 31, 2026

Requested consideration: Creation of a Maryland Interagency Biofuels and Clean Fuel Standard Working Group per the2026 Commission recommendation package and annual report

Dear Commissioners:

I am writing to support the creation of a Maryland Interagency Biofuels and Clean Fuel Standard Working Group as recommended in the Commission’s 2026 recommendations package and annual report

Maryland has focused on decreasing our carbon footprint primarily through transition to electrification. The Commission recognizes that this is not the only approach to decreasing Maryland’s carbon footprint by noting in its recommendations the need for Maryland to evaluate a Clean Fuel Standard or other measures to increase production, importation, and use of lower-carbon transportation fuels. In this regard, Maryland needs to give serious consideration to the carbon (and other pollution) reduction possible by replacing fossil fuels with sustainable, renewable fuels in existing transportation and other uses that will be ‘on the roads’, in at least the mid- and long-term.

Advanced Biofuels USA, a nonprofit educational organization headquartered in Frederick, MD, since its creation in 2008, has provided information regarding understanding, development and use of sustainable renewable fuels in the US and around the world. Our free online library, with more than 60,000 indexed items, is designed to be a resource for policymakers as well as for the general public.

We have learned to defossilize fuels from other states, such as California with its Low Carbon Fuel Standard (LCFS). From that experience, we see clearly that renewable fuels can complement transportation electrification efforts to achieve defossilization and carbon pollution reduction goals. California Air Resources Board data for the four quarters ending in the fourth quarter of 2024 indicate that biomass-derived fuels generated approximately 3 out of 4 LCFS credits, with electric transportation generating approximately 1 out of 4 credits and other fuel and project pathways generating only 2% of all credits. California’s experience illustrates that continued investment in electric transportation can proceed alongside substantial emissions reductions from renewable fuels used in existing vehicles and equipment.

The Commission’s recommendation to look at a Clean Fuels Standard is especially important given recent military actions in the Middle East and the energy demands from data center leading to reversion to fossil fuel power generation. These have reinforced the need for energy security and energy independence in countries around the world.

Similarly, changes in federal clean-vehicle, clean-truck, fuel-efficiency, and funding policies highlight the value of looking at renewable fuel options. The time required to transition Maryland’s vehicle fleet and California’s experience with both biomass-derived fuels and electric transportation to meet its Low Carbon Fuel Standard lend credence to the benefit of a Clean Fuels Standard.

The Working Group would evaluate how higher biofuel blends and cleaner liquid fuels can support Maryland’s transition away from fossil fuels. We can’t wait. We need to work now to reduce emissions from existing gasoline- and diesel-powered vehicles that will continue to operate in Maryland. We need to make sustainable aviation fuel available in our airports and sustainable marine/maritime fuels available at the Port of Baltimore and at marinas throughout Maryland. People in Maryland deserve cleaner burning, less polluting fuel options now.

The proposed Working Group would not prejudge a fuel mandate, blend requirement, or implementation schedule. It would focus on the planes, trains, cars, trucks and equipment that will continue to use liquid and gas fuels during Maryland’s transition to a more renewably-powered, affordable, electrified transportation system.

The Working Groups could also identify research already existing in Maryland that would not only enhance production and delivery of fuels, but also develop technologies that can build on the strong biotechnology assets in Maryland (particularly in the I-270 Biotechnology Corridor) that have recently suffered serious decline. This research could serve to rebuild that biotechnology economic engine by again developing technologies to benefit, not only Maryland, but the entire world, from creative uses of waste methane to cutting edge enzymatic conversion of agricultural waste and grasses, research that Maryland has already financially supported and research that grows on the foundations set by the pharmaceutical industry’s biotechnology experience with hydrolyisis, fermentation, development of enzymes, etc.

The attached Supporting Research and Justification outlines the recommendation language and provides context for this request. It details the Working Group’s justification, potential for interagency and stakeholder collaboration, and the benefits of a coordinated assessment process. It highlights opportunities to address Maryland-specific data gaps and explains how the Working Group supports most of the Commission’s 2025 recommendations. It builds on work of others in the Maryland Biofuels Task Force, as well as on additional materials created by Advanced Biofuels USA as a Response and Addendum to Maryland Biofuels Task Force Report, available here.

The Working Group would create a process to assess emissions, air quality, life-cycle analysis, fuel affordability, infrastructure, impacts, public health, agency roles, consumer education, stakeholder engagement, and implementation. It could clarify agency responsibilities, identify legal authorities and gaps, coordinate research, explore funding, and develop policy options without assuming a specific outcome.

Please share this recommendation via the MCCC review process, including referral to a working group, individual review, or full Commission discussion, for the 2026 recommendations to the Governor and General Assembly.

Recommendation to Establish a Maryland Interagency Biofuels and Clean Fuel Standard Working Group

Supporting Research and Justification

1. Requested Commission Action

This submission respectfully requests that the Maryland Commission on Climate Change and the recipient(s):

Refer or circulate this proposal to the MCCC working group or the individual Commissioner best positioned to review and advance it;
Invite relevant state agencies and stakeholders to provide technical and implementation feedback;
Following the appropriate review process, adopt the proposed recommendation with any revisions the Commission determines appropriate;
Include the final recommendation in the Commission’s 2026 recommendation package and annual report; and
Transmit the recommendation to the Governor and the Maryland General Assembly through the Commission’s established annual process.

2. Proposed Recommendation

The Governor and General Assembly should establish a Maryland Interagency Biofuels and Clean Fuel Standard Working Group to evaluate how the State could support the adoption of a Clean Fuel Standard or related lower-carbon-fuel strategies, including increased use of higher biofuel blends and other cleaner-burning alternative fuels to reduce emissions from the transportation sector.

The Maryland Interagency Biofuels and Clean Fuel Standard Working Group should operate as a parallel and complementary effort to Maryland’s electric-vehicle adoption, charging-infrastructure support, and broader transportation-electrification strategy. It should not circumvent, eliminate, weaken, delay, or compete with those programs. Its work should recognize that a substantial number of internal-combustion vehicles and equipment will remain in service during the period in which Maryland must achieve significant greenhouse-gas reductions under the Climate Solutions Now Act.

The Maryland Interagency Biofuels and Clean Fuel Standard Working Group should include, at a minimum, representatives from the Maryland Department of the Environment, Maryland Department of Agriculture, Maryland Energy Administration, Maryland Department of Transportation, Maryland Motor Vehicle Administration, Maryland Department of Health, Department of Budget and Management, Department of General Services, Comptroller of Maryland, Maryland Department of Commerce, Governor’s Office, and other relevant agencies, offices, local governments, academic institutions, technical experts, industry, agriculture, citizen groups, representatives of airports and Port of Baltimore, and affected stakeholders.

The Maryland Interagency Biofuels and Clean Fuel Standard Working Group should evaluate and provide findings and recommendations concerning:

The potential role of higher biofuel blends and other cleaner-burning alternative fuels in reducing lifecycle greenhouse-gas emissions, criteria pollutants, and mobile-source air toxics from the existing and future internal-combustion fleet;
The relationship of these fuels to Maryland’s electric-vehicle, charging-infrastructure, transit, freight, school-bus, and fleet-decarbonization strategies;
Legal, regulatory, procurement, market, infrastructure, fuel-quality, testing, and labeling pathways;
Research gaps, data needs, lifecycle-accounting methods, and potential environmental, health, economic, agricultural, affordability, and energy-security effects;
Funding, financing, incentive, pilot program, and public-private partnership options;
Public education, consumer awareness, fleet training, and stakeholder engagement needs;
The roles, existing authorities, and implementation responsibilities of participating agencies; and
Legislative, regulatory, administrative, or budget actions that may warrant consideration.

The Maryland Interagency Biofuels and Clean Fuel Standard Working Group should submit its findings and recommendations to the Governor, the Maryland Commission on Climate Change, and the General Assembly by a date established in the legislation, executive order, or other action creating the Working Group.

Additional Context

Maryland’s 2025 climate plans include evaluating a Clean Fuel Standard or similar measures to boost the use of lower-carbon transportation fuels, especially in light of federal rollbacks of clean-vehicle and fuel-efficiency standards. A Maryland Biofuels and Clean Fuel Standard Working Group would assess how higher biofuel blends and other cleaner fuels could support, not compete with, the state's electric-vehicle adoption and electrification efforts. Its goal is to address emissions from the many internal-combustion engines that will still be in use during the transition.

The Working Group would unite agencies, local governments, experts, academia, industries, businesses, farms, fleets, fuel retailers, health and environmental groups, and communities. It could clarify authorities, pinpoint the required legal or regulatory powers, reduce duplication, and enhance coordination.

It could establish a consistent technical foundation for assessing lifecycle greenhouse-gas emissions, pollutants, toxins, fuel compatibility, infrastructure, costs, benefits, and uncertainties. By comparing methods and data, the Working Group could identify suitable analytical tools and develop common assumptions for evaluating fuel and engine pathways.

A benefit is identifying Maryland-specific data gaps, including fuel volumes, biofuel use, terminal readiness, fleet consumption, vehicle compatibility, procurement, emissions exposure, health impacts, and fueling demand, along with the fuel blending and deliver infrastructure for seaports and airports. Gathering available data and identifying research needs will help ground future recommendations in Maryland conditions.

The Working Groups could also identify research already existing in Maryland that would not only enhance production and delivery of fuels, but also develop technologies that can build on the strong biotechnology assets in Maryland that have recently suffered serious decline. This research could serve to rebuild that biotechnology economic engine by again developing technologies to benefit, not only Maryland, but the entire world, from creative uses of waste methane to cutting edge enzymatic conversion of agricultural waste and grasses, research that Maryland has already financially supported.

The process would improve stakeholder engagement and help identify barriers, benefits, unintended consequences, pilot opportunities, and public-private partnerships before policy decisions. It could compare voluntary programs, education, procurement, grants, incentives, demonstration projects, infrastructure, fuel quality, regulations, and legislative options without presuming outcomes.

Recent updates to federal lifecycle-analysis tools and ongoing energy-security issues highlight the need for a current, pathway-specific assessment. If findings support action, the Working Group could identify agency leadership, pilots, resources, performance metrics, reporting milestones, and coordination with existing electric-vehicle, transit, freight, school-bus, fleet, climate, and public-health initiatives. The Working Group could also evaluate a phased approach that prioritizes highest-impact opportunities.

The result would not be an automatic mandate. It would be a clearer, evidence-based set of options and recommendations for consideration by the Governor, General Assembly, Commission, and participating agencies.

Potential Collaborative Outcomes and Work Products of

The Maryland Interagency Biofuels and Clean Fuel Standard Working Group

Deliverable	Purpose
Agency authority and responsibility map	Identify which agencies possess existing authority, which agencies would serve supporting roles, and where new authority may be required.
Technical assessment framework	Establish consistent assumptions for lifecycle carbon, air-quality impacts, fuel compatibility, infrastructure readiness, costs, benefits, and uncertainties.
Maryland baseline and data-gap inventory	Compile available information and identify any missing data on fuel volumes, fleet use, terminals, retailers, state procurement, vehicle compatibility, emissions, and public health exposure.
Stakeholder engagement plan	Obtain input from fuel retailers, terminals, fleets, agricultural, environmental, and public health organizations, local governments, labor, vehicle and equipment interests, and affected communities.
Policy-options report	Present a range of voluntary, incentive-based, procurement, regulatory, and legislative options without presuming a predetermined outcome.
Implementation roadmap	If warranted by the findings, identify sequencing, responsible entities, potential pilots, resource needs, performance measures, and reporting milestones.

3. Justification, Benefits, and Outcomes

In 2025, the Maryland Commission on Climate Change recommended that the state evaluate a Clean Fuel Standard that could increase the use of lower-carbon transportation fuels. The proposed recommendation would move that work from a broad policy concept to a coordinated assessment process.

A Clean Fuel Standard or related clean-fuels framework would affect multiple agencies and policy areas. These include climate and air-quality regulation, lifecycle emissions analysis, fuel quality and labeling, state-fleet procurement, transit and commercial fleet operations, agricultural feedstocks, grants and financing, infrastructure development, public health, consumer education, and market oversight. No single agency is positioned to evaluate all of these issues independently.

Phased Petroleum Displacement and Market-Development Framework

Similar to the flexibility provided by a credit-trading mechanism, the Working Group could evaluate a phased petroleum-displacement strategy informed by prior fuel transitions, including the national phase-down of lead in gasoline, the corresponding phase-in of biofuels, and the potential gradual phase-down of petroleum-derived aromatic compounds in Maryland’s transportation-fuel supply. The assessment could begin with applications that are easiest to integrate and capable of delivering substantial air-quality, public-health, petroleum-reduction, and greenhouse-gas benefits at low or no additional cost. Prioritizing the lowest-cost, highest-impact opportunities could create a practical pathway toward more complex, higher-cost, and specialized applications while providing greater regulatory certainty, market stability, technology-development signals, and incentives for private investment.

Although E15 and B20, including biodiesel and renewable-diesel pathways, may offer the most immediate and broadly applicable opportunities, the Working Group’s assessment need not be limited to those blends. It could also evaluate E20 through E40, where technically appropriate and supported by market experience; B30, B50, and B100; sustainable aviation fuel and related airport infrastructure; and potential rail and marine applications. This phased approach would keep the initial fact-finding effort focused on the blends and applications most relevant to near-term statewide use while preserving a framework for evaluating higher blends and specialized applications as data, infrastructure, technology, and market conditions develop.

A formal working group would create a transparent forum to clarify agency roles, identify statutory or regulatory gaps, validate technical assumptions, consult affected stakeholders, and develop options for consideration by the Governor, the General Assembly, and the Commission.

4. Basis for Commission Consideration

A. Alignment with prior Commission direction

The proposal is designed to support—not replace—the Commission’s prior recommendation that Maryland evaluate the adoption of a Clean Fuel Standard or other measures to increase the use of lower-carbon fuels in transportation. Establishing the Maryland Interagency Biofuels and Clean Fuel Standard Working Group would provide the governance structure needed to carry out that assessment.

B. Complementary relationship to electrification

The proposal expressly preserves Maryland’s electric-vehicle adoption, charging-infrastructure support, and broader transportation-electrification strategy. The Maryland Interagency Biofuels and Clean Fuel Standard Working Group would operate as a parallel and complementary effort and would not circumvent, eliminate, weaken, delay, or compete with those programs. Its focus would be on the portion of the transportation system that will continue to use liquid fuels during the transition, including existing vehicles and difficult-to-electrify applications.

C. Need for current lifecycle and technical analysis

Recent updates to federal lifecycle-analysis tools and the continuing evolution of land-use accounting provide additional reasons for Maryland to conduct a current, pathway-specific assessment. The Maryland Interagency Biofuels and Clean Fuel Standard Working Group could determine how these tools should be applied in Maryland and how to evaluate benefits, risks, trade-offs, and uncertainties.

D. Economic, public-health, and resilience considerations

The requested assessment would extend beyond greenhouse gases. It would examine fuel affordability, mobile-source air pollution, public-health effects, agricultural and rural economic considerations, infrastructure readiness, petroleum dependence, and exposure to supply disruptions. These issues are relevant to a complete evaluation of net environmental and economic effects on the State.

E. Maryland precedent for interagency implementation groups

Maryland has used cross-agency and cross-sector working groups to address transportation and climate policies requiring coordinated implementation. The Maryland Interagency Biofuels and Clean Fuel Standard Working Group would apply the established model to assess a potential Clean Fuel Standard and cleaner-burning liquid-fuel pathways.

Benefits and Relationship to 2025 MCCC Recommendations

Table 1 shows how the Maryland Biofuels and Clean Fuel Standard Working Group could support most of the Commission’s 2025 recommendations by coordinating, conducting research, ensuring accountability, and implementing. Enhanced Flood Risk Disclosures have no direct or indirect link to the Working Group.

A Maryland Biofuels Working Group could strengthen the State’s climate goals by focusing on electrification, long-term planning, near-term fuel affordability, energy security, agricultural opportunities, and emissions reductions in rural communities and sectors where internal-combustion vehicles persist or are hard to decarbonize.

Table 1: Relationship of the Proposed Maryland Interagency Biofuels and Clean Fuel Standard Working Group to the 2025 MCCC Recommendations

MCCC Working Group	2025 Recommendation	Relationship to Prior Recommendation	How the Maryland Interagency Biofuels and Clean Fuel Standard Working Group Relates to the Recommendation
Mitigation Working Group	Protect SEIF and support clean energy projects in development.	Indirect support	Could help identify whether any SEIF-supported or related clean-energy funding tools may be relevant to clean-fuel infrastructure, transition planning, or complementary decarbonization strategies.
	Recommend policies to increase the use of low-carbon fuels in the transportation sector.	Direct support	This is the most direct relationship. The Working Group will help implement the Commission’s recommendation for Maryland to evaluate a Clean Fuel Standard by clarifying agency roles, research, legal options, infrastructure, and next steps.
	Develop a heat pump market transformation roadmap.	Process precedent	The proposed Working Group does not directly advance this recommendation. Still, it provides a useful precedent for a multi-agency market-transformation and implementation-roadmap process that could be applied to transportation fuels.
Adaptation and Resiliency Working Group	Climate and Health Profile Report Update	Indirect support	Could provide transportation-fuel, air-quality, and public health info relevant to climate and health analysis, especially where reduced petroleum use and cleaner fuels affect exposure and resilience.
	Next Generation Adaptation Plan Public Tracker	Indirect support	Could provide implementation milestones, agency actions, and clean-fuel deployment indicators that may be useful for public-facing tracking of Maryland’s broader climate response.
	Enhanced Flood Risk Disclosures	Not directly related	Not directly relevant to the proposed new biofuels/clean fuel standard working group’s scope.
Education, Communication, and Outreach Working Group	Continuous Improvement and Accountability in Climate Action	Direct support	Support this by creating a structured interagency process to gather input, define roles, update implementation needs, and improve transparency in clean-fuel policy development.
	Climate Education Month	Direct support	Could provide a platform, content, and agency coordination for public education on cleaner transportation fuels, fuel choice, lifecycle carbon, energy security, and transportation decarbonization.


Science and Technical Working Group	Accounting of Nitrous Oxide Emissions in Maryland	Indirect support	Could coordinate with MDA, MDE, and technical experts to ensure that feedstock, agricultural emissions, and updated lifecycle accounting are considered during biofuel evaluations under the Clean Fuel Standard.
	Measures to Decrease Methane Production and Emission	Indirect support	Could support the identification of renewable fuel pathways, including manure- and waste-based fuels, as well as other lower-carbon fuel opportunities that align with methane-reduction goals.
	Update of the 2008 'Global Warming and the Free State' Report	Indirect support	Could contribute updated transportation-fuel analysis, market and policy developments, lifecycle science, and clean-fuels implementation issues to any future statewide climate-impact update.
	The Cost of Climate Change: Health and Economic Benefits of Action by Maryland	Direct support	It can quantify avoided costs and benefits, such as lower-carbon fuels, reduced petroleum dependence, improved air quality, fuel savings, and transportation emissions reductions.
Individual Commissioner	Impact of the elimination of federal environmental regulations and efforts	Direct support	The working group would offer a state-level response to federal rollbacks by exploring how Maryland can use cleaner fuels and policies to address the transportation-emissions gap.