CARB’s In-Use Locomotive Regulation Rule Will Hurt the American Economy Public Comment Deadline April 22, 2024

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April 16, 2024
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(Association of American Railroads) Policy Position: Congress should call on EPA to prevent CARB from moving forward with its new framework. EPA should instead ensure locomotive emissions regulations move forward in a responsible, measured fashion that takes into full account technology readiness, comprehensive costs and benefits of government actions, and impacts on small business.

Railroads and the California Air Resources Board (CARB) worked collaboratively for years to reduce emissions from line haul and yard operations across the state. Initiatives such as zero-emission cranes, yard service vehicles and other technology are at work in yards across California and the nation as anti-idling systems, fuel management systems and the use of renewable fuels are simultaneously reducing locomotive emissions.

The industry is taking decisive action against climate change, including testing emerging technologies such as battery-electric and fuel-cell locomotives that may reduce GHG emissions and criteria pollutants. However, despite substantial investments and an industry-wide push to unlock a zero-emissions solution, a clear technological path has not emerged and will require additional research and development.

Important to Know: The technology needed for zero-emission locomotives is not commercially available today. In fact, the U.S. Department of Energy in its recent FY25 Budget Request document stated that its goal was to demonstrate a 50% reduction in greenhouse gas emissions by 2030. This goal is far more reasonable than CARB’s expectation that locomotives are zero-emissions starting in 2030.  READ MORE

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Excerpt from Real Clear Markets/American Association of Railroads: The EPA has a unique opportunity to stand for the rule of law while still advancing its mission for a cleaner environment. Decisive action in defending its regulatory lane and rejecting the overtures of California, which is seeking to obliterate highly efficient locomotives – responsible for just 0.6 percent of U.S. greenhouse emissions – would also protect millions of American businesses and consumers across the country.

At issue is a waiver the state of California must receive to implement a sweeping measure it recently passed. The rule says that railroads must prematurely start retiring their existing locomotive fleet in 2030, and that after 2035 railroads may no longer purchase new locomotives for use in California unless they are “zero-emission.”  Yet no such locomotive is viable today and even the most optimistic forecasts say there is no way railroads could possibly replace thousands of locomotives in less than eleven years. This is to say nothing about very real grid capacity concerns.

Requiring railroads to deploy non-viable technology is wrongheaded. Especially because its lack of commercial viability is due to realities within the market and science – not obstinance.

Importantly, “rail is already one of the cleanest ways we move freight and has an important role to play in reducing freight transportation’s climate impacts,” say researchers at Third Way. The industry handles 40 percent of the nation's long-distance freight.

Railroads embody interstate commerce, operating across state lines every day throughout their integrated network. If EPA were to grant the waiver, the California rule would be national in scope immediately, because two-thirds of the locomotive fleet would be prohibited from operating in California by 2030, and because other states could replicate the regulation. A patchwork of unworkable state regulations would cripple supply chains.

Rail provides significant efficiencies for essential U.S. industries, particularly in the ability to move large quantities of goods long distances. This requires an ability to move seamlessly between states and do so with one set of equipment and corresponding regulation.

“Imagine a rail network where operators would need to switch locomotives repeatedly when crossing state lines,” writes former U.S. Transportation Secretary James Burnley. “That’s why we have a national rail system. It calls for national standards, not implemented on a state-by state basis.”

Nonetheless, California is also requiring railroads to deposit millions each year into an escrow account overseen by the state to be used exclusively in pursuit of the zero emissions goals. For large railroads, this will total about $800 million per year per railroad, while smaller railroads will be on the hook for roughly $5 million per year. Railroading is capital intensive, and many small railroads have said this will put them out of business, shifting freight to more carbon-intensive highways in the process. California has been troublingly agnostic about looming bankruptcies or creating counterproductive environment results.

Private dollars in this case would be better served supporting ongoing decarbonization research and development – like the testing of hydrogen and battery-hybrids – as well as network maintenance and improvement geared toward critical safety gains and capacity improvements for shippers.

Indeed, the policy at hand poses significant challenges for the vast set of railroad customers ranging from farmers to auto manufacturers to retailers, particularly in the context of environmental progress. Rail customers will be forced to consider new costs and less fluid operations, disrupting improved supply chains while exacerbating inflation.

Yet maybe the most important point for the EPA to consider is the elephant in the room: CARB is not just ignoring reality and the fate of small businesses – it's trampling on federal statutes like the Clean Air Act and the ICC Termination Act of 1995, both of which clearly preempt states’ abilities to engage in these types of actions.  This isn't just about the railroad industry anymore; it's about the fundamental principles of regulatory authority and interstate commerce.  READ MORE

 

Excerpt from American Ag Network: Taxpayers Protection Alliance (TPA) led a coalition of 34 organizations and advocates opposing the Environmental Protection Agency’s (EPA) California Air Resources Board (CARB) rule to regulate diesel locomotives. In a letter to the agency, the signees urged the agency to reject this rule, which would impose crushing emissions standards that would harm American taxpayers and commerce. 

TPA President David Williams offered the following comment:

“It is critical that the EPA reject California’s attempt to set de facto nationwide environmental standards. The proposed CARB rule would result in massive costs for American businesses and consumers, and it would disrupt the critical role rail plays in interstate supply chains. Rail is an incredibly safe and clean mode of transport, yet California wants to crush the industry with infeasibly strict emissions standards.

“California’s attempted overreach needs to be stopped. The EPA can deny its waiver request, ensuring the federal government remains the entity regulating interstate transportation in fact as well as law – just as the Constitution intended. Rejecting CARB’s request would be a double win: It both would maintain constitutional balance and prevent the imposition of crushing and inflationary regulation.”

A link to the full letter can be found here. READ MORE

 

Excerpt from Office of U.S. Senator Pete Ricketts (R-NE): U.S. Senator Pete Ricketts led a bipartisan group of colleagues in a letter to Michael Regan, Administrator of the Environmental Protection Agency (EPA), opposing a rule from the California Air Resources Board (CARB) that would devastate the rail industry, jeopardize supply chains, and harm our economy.

“Attempts to create state-specific operational rules, such as those envisioned by CARB, would jeopardize the interoperability of the national network and would threaten the overall health of the supply chain,” wrote the senators. “CARB has stated its goal is to force the railroads to convert their national fleets to the currently unavailable and untested zero-emission locomotives. The CAA does not grant EPA the authority to allow states to mandate specifications for the design and manufacture of locomotives – which is precisely what CARB seeks in its authorization request.”

“If the EPA were to approve CARB’s authorization request, the results would be devastating for the rail industry and, subsequently, the economy as a whole..” wrote the senators. “In addition, the financial strain the spending account requirement of the Regulation would place on railroads could be multiplied across each other state that chooses to adopt the Regulation. Finally, the EPA’s actions could jeopardize the supply chain by forcing railroads to utilize largely unproven technology to power the locomotives.”

In addition to Ricketts, other signatories include Senators Shelley Moore Capito (R-WV), Joe Manchin (D-WV), John Boozman (R-AR), Mike Braun (R-IN), Kevin Cramer (R-ND), Joni Ernst (R-IA), Deb Fischer (R-NE), John Hoeven (R-ND), Cynthia Lummis (R-WY), Roger Marshall (R-KS), and Roger Wicker (R-MS).

The letter is supported by the Association of American Railroads (AAR) and the American Short Line and Regional Railroad Association (ASLRRA).

“Rail is already a solution to reducing transportation emissions,” said AAR President and CEO Ian Jefferies. “Despite significant progress and railroad investment to advance zero-emissions technologies, there are no commercially viable options today – and they cannot simply be willed into existence by the state of California. If allowed to proceed, the CARB rule stands to upend rail operations across the interconnected national network without resulting in any actual emissions reductions.”

“We commend Sen. Ricketts and his colleagues for their important leadership on this issue,” said ASLRRA President Chuck Baker. “Their letter conveys a fundamental message to EPA:  the federal government must stop California’s misguided measure in its tracks. This state-level mandate requires small railroads to pay draconian compliance costs, discard useful and practical locomotives decades before the end of their useful lives, and acquire new locomotives that are not yet commercially viable in order to meet completely arbitrary deadlines. CARB’s rule will be the death knell for small railroads in California if it’s allowed to proceed, and if other states follow this clearly illegal rulemaking, small railroads nationwide will shutter, crippling the country’s supply chain and increasing congestion and air pollution on the nation’s highways – ironically, exactly what CARB claims it wants to curtail.”

BACKGROUND:

At the end of last year, EPA finalized a rule which rolls back state preemption of in-use locomotives and opens the door to the California Air Resources Board’s (CARB) waiver for strict regulations on in-use locomotive emissions. In section 209(e) of the Clean Air Act, Congress preempted state and local governments from adopting or enforcing “any standard or other requirement relating to the control of emissions from… new locomotives or new engines used in locomotives.” In 1998, EPA established regulations that implement this preemption consistent with Congressional intent to prevent unreasonable burdens on interstate commerce. Given the nature of locomotive remanufacturing, EPA is defining “new locomotives and new engines used in locomotives” to include existing locomotives when they are remanufactured. 

The In-Use Locomotive Regulation would prohibit the operation of locomotives in California more than 23 years after manufacture unless those locomotives operated in a zero-emissions configuration. This technology is not commercially available today. As a result, the regulation would impose significant operational and financial burdens on freight railroads operating in California, including both Class I’s and short line railroads.

Read the full letter here or below:

Dear Administrator Regan:

On April 27, 2023, the California Air Resources Board (CARB), the air regulator for the State of California, finalized a regulation aimed at reducing emissions in the rail sector. The In-Use Locomotive Regulation (the “Regulation”) would impose significant operational and financial burdens on freight railroads operating in California, including both Class I’s and short line railroads. In order to go into full effect, the Regulation requires the EPA to issue a waiver pursuant to section 209 of the Clean Air Act (CAA) (42 U.S.C. 7543(e)). As the EPA considers this waiver request from CARB, we request that the EPA fully considers the limitations on the authority granted to it under the Clean Air Act and the broad impacts that such an approval would have on rail operations in California and across the United States, Canada, and Mexico.

As you are aware, beginning in 2030, the Regulation prohibits the operation in California of locomotives more than 23 years after its original manufacture date unless those locomotives operate in a zero-emissions configuration – technology that is not commercially available today. The Regulation also requires railroads to open and deposit funds into ‘spending accounts’ based on the emissions and energy consumption of each non-zero-emissions locomotive operating in California. These funds could only be utilized by the railroads to purchase these new, zero- emissions locomotives or to invest in the requisite infrastructure and demonstration projects associated with zero-emissions locomotives. The spending account provision of the Regulation would result in onerous financial constraints on railroads in California, with some estimates suggesting that the two Class I railroads with operations in California would each have to deposit approximately $800 million annually into such accounts. Finally, the Regulation imposes strict idling requirements on the railroads as well as stringent recordkeeping requirements by mandating that every instance of idling longer than thirty minutes be reported along with the reason for idling that length of time. 

The national rail network is an interconnected system of over 144,000 track miles that spans the United States, Canada, and Mexico. It is for that very reason that Congress has passed laws which unequivocally state that, as an intrinsically interstate form of transportation, the rail industry must be regulated at the federal level and not subjected to a patchwork of varying state and local regulations as trains move goods across the continent. Attempts to create state-specific operational rules, such as those envisioned by CARB, would jeopardize the interoperability of the national network and would threaten the overall health of the supply chain.

CARB has stated its goal is to force the railroads to convert their national fleets to the currently unavailable and untested zero-emission locomotives. The CAA does not grant EPA the authority to allow states to mandate specifications for the design and manufacture of locomotives – which is precisely what CARB seeks in its authorization request.

CARB’s authorization request, therefore, violates the restrictions laid out in the CAA. Section 209(e)(1) of the CAA clearly prohibits California or any other state from attempting to regulate emissions from new engines used in locomotives. Despite EPA’s misguided effort last year to remove regulatory preemption language, EPA is bound by the statutory language in section 209 when determining whether to issue a waiver. By forcing railroads to adopt new zero-emissions locomotives for their operations in California, CARB clearly goes beyond the parameters of section 209(e)(2) by attempting to change the fleet nationwide to new, zero-emissions locomotives.

Rail transportation remains the most fuel-efficient mode of transporting freight by land. A single locomotive can move one ton of freight 500 miles on a single gallon of fuel and can pull the equivalent freight of nearly 100 trucks. Railroads represent less than two percent of all transportation-sector greenhouse gas emissions, less than one tenth of the greenhouse gas emissions from the tucking sector. Approval of CARB’s authorization request could inadvertently increase overall emissions by forcing more shippers to utilize trucks as opposed to rail-based transportation.

If the EPA were to approve CARB’s authorization request, the results would be devastating for the rail industry and, subsequently, the economy as a whole. Under section 209(e)(2), other states would be able to follow California’s lead and adopt identical standards, further disrupting the uniform regulatory landscape. In addition, the financial strain the spending account requirement of the Regulation would place on railroads could be multiplied across each other state that chooses to adopt the Regulation. Finally, the EPA’s actions could jeopardize the supply chain by forcing railroads to utilize largely unproven technology to power the locomotives. The technology will also need to be evaluated by the Federal Railroad Administration to determine any safety concerns. Although railroads are currently investing in the research and development needed to commercialize zero emissions technology, that technology is years away from commercial viability.

It is for these reasons that we request the EPA carefully consider the environmental, supply chain, and modal shift implications that EPA approving CARB’s waiver request would have. The economy depends on the timely, efficient, and predictable movement of goods that is facilitated by the railroads. California has failed to demonstrate the extraordinary circumstances needed to satisfy the requirements of their waiver request. And if the EPA concludes that the Regulation would substantially change the design of future locomotives in use in California and across the country, the EPA must deny the given that EPA has no authority to waive the preemptive provisions of section 209(e)(1).  READ MORE

 

Excerpt from California Globe: Considering California’s less than glorious experience with its high speed rail program, one would think it would be wise for the state to stay away from the whole railroad thing entirely.

The California Air Resources Board (CARB)  has been called many things during its existence, but wise is not one of them, hence its request to the Environmental Protection Agency (EPA) to demand railroad locomotives be replaced with newer, cleaner equipment.

Equipment, by the way, that isn’t really technologically, let alone economically, extant quite yet and will almost certainly remain relatively unavailable by CARB’s deadline of 2030.

Last year, CARB approved its “In-Use Locomotive Regulation” that would force railroads to stop using any locomotive it has that is more than 23 years old and replace said locomotive with a zero-emission version.

Until then, a railroad can either try to buy what are called “Tier 4” locomotives – tier 4 locomotives and other types of tier 4 engines are meant to reduce particulate matter in the air and nitrogen oxide at the ground level, among other things – or it can pile money into a “spending account” to “fund their own trust account based on the emissions created by their locomotive operations in California. The dirtier the locomotive, the more funds must be set aside.”  

CARB passed the new rule despite the fact that it cannot enforce said rule without getting a waiver from the EPA  – they actually regulate rail emissions – to do so.  CARB submitted their request, a public hearing was held last month, and the EPA will make a decision soon, though no timeline is set yet.

According to the American Short Line and Regional Rail Association (ASLRRA), which has filed, along with others, to stop the new regulation, “zero emissions locomotives (required by 2030 by CARB) are not currently commercialized and are in a very few pilot programs in the United States.”

If this sounds familiar, that’s because CARB pulled a similar move regarding requiring that same “category tier 4” classification of motor in all harbor craft (pretty much all boats except fishing boats) starting in December.  

Again, the technology simply does not really exist to follow CARB rules.

“Operators of harbor craft in California (other than fishing boats, which are exempt) have until December 2024 to have all their boats operated with Tier 4 engines outfitted with diesel particulate filters (DPFs), attachments designed to burn particulate matter (soot) before it exits into the atmosphere,” wrote Waterways Journal  .“The problem is that such DPFs do not exist and cannot be developed by that target date.”

Even the Coast Guard is saying “no” to CARB and will not enforce the boat new regulation. 

As to the locomotive issue, that is even more complicatedly absurd.  For example, trains do things like cross state lines, for one, so if California had its own rule locomotives would have to swapped out at the border.

Due to its crucial place in the goods movement system – more than half of all those containers from the Far East that come in through the Ports of Los Angeles/Long Beach leave the state – such a rule in California would be devastating to a national supply chain already stressed by the lingering impacts of the pandemic response and shaky economies.

While every form of railway would be impacted – the tier 4 locomotives, if they can be found, run at least $4 million each – the short lines, the “mom and pop shops” of the industry – would feel it the hardest.

...

There is also the issue of what happens if a waiver is approved.  Currently, a number of other states follow CARB’s lead, often because they have state laws that require them to do so. For example, Gov. Glenn Youngkin of Virginia was stunned to find out his state will institute the same “only electric cars can be sold new in 2030” as California has done.  Therefore, this waiver could have a cascade effect throughout the nation.

Creating a patchwork of railroad regulations would be disastrous for the industry, wrote a dozen U.S. Senators to EPA Administrator Michaely Regan just last week:

“The national rail network is an interconnected system of over 144,000 track miles that spans the United States, Canada, and Mexico. It is for that very reason that Congress has passed laws which unequivocally state that, as an intrinsically interstate form of transportation, the rail industry must be regulated at the federal level and not subjected to a patchwork of varying state and local regulations as trains move goods across the continent. Attempts to create state-specific operational rules, such as those envisioned by CARB, would jeopardize the interoperability of the national network and would threaten the overall health of the supply chain,”  the letter states.  “CARB has stated its goal is to force the railroads to convert their national fleets to the currently unavailable and untested zero-emission locomotives. The CAA does not grant EPA the authority to allow states to mandate specifications for the design and manufacture of locomotives – which is precisely what CARB seeks in its authorization request.”

For its part, though, CARB is not backing down. 

...

The letter from the senators can be read here:  https://www.ricketts.senate.gov/wp-content/uploads/2024/04/04.16.2024-Letter-to-EPA-Re-CARB-In-Use-Locomotive-Regulation.pdf     READ MORE

 

Excerpt from Inside EPA: The federal Surface Transportation Board (STB) is raising legal doubts about whether EPA should waive Clean Air Act (CAA) preemption to allow California’s air board to implement a novel rule aimed at cutting pollution from existing locomotives, saying the policy may be preempted by the Interstate Commerce Commission Termination Act of 1995 (ICCTA). “To the extent authorization under” section 209(e)(2) of the CAA “would give the Regulation or parts of it the ‘force and effect of federal law,’ EPA should consider interpreting and applying the CAA narrowly when making these determinations and erring on the side of finding CAA preemption should it have doubts as to the Regulation’s technical feasibility or whether aspects of it attempt to regulate the control of emissions from new locomotives or otherwise run afoul of or not qualify for authorization under § 209(e),” reads an April 22 letter to EPA from Anika S. Cooper, STB’s acting general counsel.  READ MORE

 

Excerpt from Inside EPA: Republican leaders of the House Energy & Commerce Committee are joining calls from a range of groups urging EPA to reject California’s request for a waiver of federal preemption to implement its novel rule to cut pollution from existing locomotives, while also raising questions about its adoption of a rule that eased the path to grant the state’s request. The state’s regulation “would force the premature retirement of reliable and affordable diesel locomotives and has the potential to upend our...  READ MORE

 

Excerpt from Inside EPA:  House Republicans and rail industry representatives used a June 13 hearing before a House science committee panel to further pressure EPA to reject the California Air Resources Board’s (CARB) pending request for a Clean Air Act waiver of federal preemption for its controversial regulation to lower pollution from existing locomotives. “If EPA allows CARB to implement this proposal and the rail industry is unable to meet the impossible demands, we will likely see a shift in modal transportation where all...  READ MORE

 

Excerpt from ConservAmerica:  Earlier this year, the California Air Resources Board (CARB) notified the Environmental Protection Agency (EPA) that it had adopted its In-Use Locomotive Regulation and requested the EPA’s authorization according to section 209(e) of the Clean Air Act (CAA). The EPA is currently determining whether the regulation meets the criteria for a waiver of federal preemption. Approving the waiver would allow California and other states to mandate zero-emissions locomotives even though these technologies are not yet available to meet the nation’s rail transportation needs. We have often seen how overly aggressive environmental regulations can hinder economic growth and innovation – and contrary to their purported goals - even increase pollution. Because of the interconnected nature of the United States rail system (combined with the fact that additional states could follow suit), EPA’s approval of California’s standards would have major national implications on our ability to efficiently move people, products, agriculture, energy, and material resources that our manufacturing sector needs around the country. Join ConservAmerica, in partnership with C3 Solutions, for a discussion on the In-Use Locomotive Regulation and CARB’s waiver request, the state of emissions reduction technologies, and the economic implications of these standards on the industry.

Panelists

Dr. Alex Scott - Alex Scott is an associate professor of supply chain management and the Gerald T. Niedert Professor in the Haslam College of Business at the University of Tennessee, Knoxville. He has spent twenty years working in and researching the U.S. transportation industry. Prior to joining academia, Scott worked for a decade in transportation and logistics, including with a large transportation company, a large third-party logistics provider, and an international consulting firm.

Dr. David Dismukes - David E. Dismukes served as the executive director and professor at the Center for Energy Studies, Louisiana State University from 2014 through 2022. He was also a professor in the Department of Environmental Sciences in the LSU College of the Coast & Environment (CCE). Post-retirement from LSU, Dr. Dismukes has continued to work in consulting. His research interests are related to the analysis of economic, statistical, and public policy issues in energy and regulated industries.

Dr. Mike Gorman - Professor Michael F. Gorman is the Niehaus Chair of Operations and Analytics in the Department of MIS, Operations and Analytics at the University of Dayton School of Business. He has 20 years of academic experience at University of Dayton, and the president of MFG Analytics. Previously, he worked for 10 years at BNSF Railway. He has over 50 academically reviewed publications and 100 conference and invited presentations.

Patricia Patnode - Patricia Patnode is a Research Fellow at the Competitive Enterprise Institute. Patricia is a regular contributor for The Cedar Rapids Gazette and The Conservator, and has also been featured in USA Today, the Washington Examiner and Discourse Magazine. She received a BA from Loras College in her home state of Iowa. 

Co-Hosts

Todd Johnston - Todd is the Vice President of Policy at ConservAmerica. Todd previously served at the Virginia Department of Environmental Quality and on committees with jurisdiction over environment, infrastructure, and energy issues in the U.S. Senate and House of Representatives. Todd has represented various industries on state and federal policy, permitting, and regulatory compliance matters.

Nick Loris - Nick is the Vice President of Public Policy at C3 Solutions. Nick studies and writes about a wide range of energy and climate policies, including natural resource extraction, energy subsidies, nuclear energy, renewable power and energy efficiency. He also studies ways in which markets will improve the environment, reduce emissions and better adapt to a changing climate.    READ MORE/WATCH recorded presentations; includes transcript

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carbon emissions carbon fiber carbon insets Carbon Intensity (CI)/Carbon Footprint carbon life cycle carbon markets Carbon Monoxide (CO) carbon negative carbon neutrality carbon offsets carbon pipeline carbon price carbon recycling carbon removal carbon sink carbon standard carbon tax Carbon tax border adjustments carbon tax-and-dividend carbon terminal carbon user fee Carbon Utilization and Biogas Education Program carbon-14 testing carbon-efficient fuels carbon/CO2 sequestration carcinogens cardoon Caribbean carinata carinata/brassica carinata carob CAS Registry cashew cashew apple Cashew Nut Shell Liquid (CNSL) CASI Cassava cassava price cassava pulp cassava stalk castor bean castor stalk catalysis catalysts catalytic decarboxylation catalytic hydrothermal conversion catalytic hydrothermal conversion-to-jet (CHCJ) catalytic hydrothermal gasification catalytic hydrothermolysis jet CHJ pathway cattails cattle cavitation CBD (cannabidiol) CBG (compressed biogas) cell culturing 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thermocellum cloud point clover cmelina CNG Conversion kit co co-generation co-location Co-op Extension co-operative co-processing co-products CO2 Electrolysis CO2 neutral fuels CO2Removal Certificates (CORCs) coal Coal and Biomass to Liquid (CBTL) Coast Guard coastal habitat conservation coastal hay cobalt cock's foot coco coco methyl ester (CME) cocoa Coconut coffee coffee cherries coffee grounds coffee pulp cold flow cold-tolerance college/university Colombia Colorado combined heat and power (CHP) Comment Request commercial flights commercialization commissioning commo Commodity Credit Corporation (CCC) Commodity Futures Trading Commission (CFTC) commodity trading common reed Community activity community college Community involvement/engagement community scale Community Wood Energy Program competition compliance compliance credits compost Compressed Natural Gas (CNG/R-CNG/bioCNG) compression ratios compression-ignition engine computer simulation concrete condensate Congo Congressional Budget Office (CBO) Connecticut Conservation Reserve Program (CRP) Conservation Stewardship Program (CSP) construction and demolition waste/debris consumer education contamination contest contrails conversion technology Cook Islands cook stoves cooking fuel cooperatives COP21 COP22 COP23 COP24 COP25 COP26 COP27 COP28 COP29 COP30 copper coppice cordgrass corn bran Corn cobs corn ethanol corn fiber corn growers corn harvest corn kernel corn meal corn oil corn oil/distillers corn oil (DCO) corn prices corn stalks corn stover corn supply corn surplus corn syrup corn-based products corn/maize Corporate Average Fuel Economy (CAFE) standards corporate social responsibility corrosion corruption CORSIA (Carbon Offsetting and Reduction Scheme for International Aviation) cosmetics Costa Rica cotton cotton seed hulls cotton seed oil cotton stalk cottonwood Council on Environmental Quality county cover crops cow rumen cracking Crambe crassulacean acid metabolism plants (CAM) crimes criteria pollutants Croatia crop crop insurance cropland croton crowdfunding crude oil Cuba cup plant cuphea currency/foreign exchange policy curriculum cusi cutworm caterpillars cyanobacteria (blue-green algae) cylindro Cyprus Czech Republic d D-3 (cellulosic) RINs D-4 (bio-based diesel) RINs d-5 D-5 (advanced biofuel) RINs D-6 (renewable fuel) RINs D-7 RINs (Cellulosic Diesel) D-8 (proposed) RINs D20 (20%DME) D5 (5%DME) dairy waste dandelion DARPA date kernel oil date palm date palm pits date palm waste Dates DDGS (distiller’s dried grains with solubles) dead zone decanol decision-support tool deep water drilling Defense Logistics Agency (DLA) Defense Production Act deficit definitions deforestation defossilization Dehydration Delaware DeltaWing demonstration demonstration scale/unit Denmark densify density Department of Agriculture (USDA) Department of Commerce Department of Defense (DOD) Department of Education Department of Energy (DOE) Department of Health and Human Services 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drop-in biofuels/hydrocarbons drought drought tolerant drought-resistant dry ice dual cropping Dubai duckweed e e-diesel e-LNG (synthetic/electro Liquified Natural Gas) e-methanol e-NG (synthetic natural gas) E. coli E0 E0 price E1 E10 E10 certification fuel E10 price E100 E100 conversion kit E11 E12 E13 E15 E15 price E15 pumps E2 E20 E20 price E20 pumps E22 E25 E25 pumps E27 E3 E30 E30 capable E30 certification fuel E30 optimized E30 price E30 pumps E35 E4 E40 E40 conversion kit E40 pumps E5 E5 price E50 E55 E6 E7 E70 diesel E75 E78 E8 E80 E85 E85 conversion kit E85 optimized engines E85 price E85 pumps E90 E92 E95 E97 E98 earthquakes East Africa Eastern Europe economic development Economic Development Administration economic modeling economic policy economics Ecosystems Services Ecuador ED7 (7% ethanol 93% diesel) ED95 education Education Series 3030 educational business private educational tour EERE efficiency egg shell Egypt El Salvador Electric aircraft Electric Car/Electric 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Co-optimization engineering England enhanced oil recovery (EOR) entrepreneur environment environmental impact study (EIS) environmental justice/socially inclusive environmental policy Environmental Quality Incentive Program (EQIP) Environmentalists Enzymatic enzymatic conversion enzymatic depolymerization enzymatic hydrolysis enzyme production enzyme recycling Enzyme solicitation enzymes EPA (Environmental Protection Agency) EPACT (Energy Policy Act) Equatorial Guinea equipment eRINs/electric pathway Eritrea erosion control EROWI (Energy Return on Water Invested) ESG (Environmental Social Governance) esterification Estonia ETBE (ethyl tert-butyl ether) etha ethane ethanol ethanol benefits ethanol blend wall ethanol blended diesel ED ethanol blends/ethanol flex fuels ethanol emissions ethanol ether diesel fuel ethanol fire ethanol fuel cells ethanol hybrid ethanol pipeline ethanol prices ethanol production ethanol pumps ethanol tax ethanol terminal ethanol to gas ethanol tolerance 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feed Feed In Tariffs (FIT) feed prices Feedstock Flexibility Program for Bioenergy Producers feedstock logistics feedstock material feedstock prices feedstock storage feedstock terminal feedstock transportation Feedstocks fermentation ferry fertilizer fiber Fiji Financing Finland Fischer-Tropsch Synthetic Kerosene with Aromatics (FT-SKA) Fischer-Tropsch Synthetic Paraffinic Kerosene (FT-SPK) Fischer-Tropsch Synthetic Paraffinic Kerosene with Aromatics (FT-SPK/A) Fischer-Tropsch/FT fish feed fish oil fish waste fit for purpose Fixed Base Operator (FBO) flameleaf sumac flavors flax fleet turnover Fleets fleshings flex-fuel vehicles (FFV) flight tests Flightpath flixweed/tansy/herb-Sophia flood-prone soil Florida flue gas FOG (Fats/Oils/Grease) follow-the-crop food Food and Agriculture Organisation (FAO) Food and Drug Administration (FDA) food and fuel food policy food prices food processing waste food safety food security food vs biomaterials/bioplastics food vs fuel food waste for 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price gasoline-range hydrocarbons Gemany General Services Administration general waiver authority generators genetically engineered yeast cells genetically enhanced microbes genetically modified organism (GMO) genome Georgia Georgia (country) geothermal German Germany Gerrmany Ghana GHG (Greenhouse Gas Emissions) GHG (Greenhouse Gas Emissions) Intensity giant cane giant kelp Giant King Grass Giant Reed/Arundo GIS glass tubing gliricidia sepium global rebound effect Global South global warming global warming potential glucose glycerin glycerin standards glycerol goats gorse Governance practices) Government Accountability Office (GAO) government investment government resources government subsidies grain sorghum/milo grain speculators grains GRAND-AM grants grants-local grants-state grapefruit grapes graphene graphite GRAS (generally regarded as safe) Grasses grasses grasshoppers grease Great Green Fleet Great Lakes Greece green bonds green chemistry Green Deal EU green economy green house facility Green Jobs Green New Deal Green Racing Green Recovery green/black economy Greenland GREET Greenhouse Gases Regulated Emissions and Energy Use in Transportation Model Grenada gribble growers gua beans Guam guar Guatemala guayule Guerbet reaction Guinea Guinea Bissau Gulf states gulmohar Gumweed (grindelia squarosa) Guyana GWP gypsum h Haiti Halophytes harvest site processing harvesting Hawai'i hay hazardous waste hazelnut HBIIP Higher Blends Infrastructure Incentive Program HDCJ HDO-SAK (hydro deoxygenated synthetic aromatic kerosene) health health benefits health effects heat of combustion heat of vaporization heat-tolerance heather heating oil/fuel Heavy Duty Truck Rule heavy duty vehicles (HDV) hedging HEFA (Hydro-processed esters and fatty acids) HEFA50 helicopters hemicellulace enzymes hemicellulose hemicellulosic sugars Hemp hemp oil hemp seed herb hexanol HFO (Heavy Residual Fuel Oil) hibiscus high blend renewable fuels (HBRF) High Hydrogen Content Synthetic 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