Letter to California Energy Commission: Re: SBX1-2 – Transportation Fuels Assessment and Transportation Fuels Transition Plans – Docket #23-SB-02

(Renewable Fuels Association) The EPA approved the use of E15 nationwide in 2011 and currently California is the only state in the country that does not allow the sale of E15. All that needs to occur to facilitate the introduction of E15 in the state is for the California Air Resources Board (CARB) to approve the use of E15 in CA RFG. Since the Transportation Fuels Assessment is a joint program between CEC and CARB, this is an important forum for accelerating an E15 rulemaking.

The Multimedia Evaluation (MME) on E15, required by state law for new fuels, is complete, awaiting final approval from the California Environmental Policy Council.1 The MME and associated E15 emissions testing on 20 vehicles by the University of California, Riverside, show significant environmental benefits

.CEC states in the draft report that E15 is “likely to lower the price of CA fuel due to additional supply.” While it is true that extending the fuel supply with a renewable fuel puts downward pressure on fuel prices, it is also the case that wholesale ethanol in California historically trades at a material discount to wholesale CARBOB, providing further opportuity for lowering fuel prices to California consumers in addition to the price effect of introducing incremental supply. With an octane rating of 114, ethanol also displaces higher cost and toxic octane components in gasoline (e.g., aromatics) further adding to its economic, environmental and equity value.

The infrastructure to implement E15 in California is largely in place today and RFA encourages CEC to amend the “cons” section of the E15 discussion accordingly. 3 In 2015 a major study was conducted by U.S. DOE’s National Renewable Energy Laboratory (NREL) focused on the E15 readiness and compatibility of fuel supply chain infrastructure. 2 . The study is highly regarded and has been used by thousands of retailers and state and federal agencies to document best practices for E15 adoption. Notable findings in the study are:

• E15-compatible equipment is already broadly deployed in the marketplace. There are at least 56 major equipment manufacturers that offer various E15-compatible equipment and parts. Companies include but are not limited to, Franklin Fueling, Gilbarco, OPW, Emco, Wayne, NOV, and Bravo.

• Over 720 parts are identified that were directly built for compatibility with up to 25 percent ethanol (E25) or up to pure ethanol (E100).

• 90% of the 720+ parts were listed by Underwriters Laboratory (UL) and 35% were specifically UL listed for use with up to E25. The report is a well-documented analysis on how the U.S. fuel system and infrastructure is already largely compatible with E15 and, in many cases, E100.

In addition, California’s Underground Storage Tank (UST) infrastructure requirements are superior to those of most states. The existing UST infrastructure in California is highly compatible with, and ready for, the introduction of E15. READ MORE

Excerpt from American Ag Network: Renewable Fuels Association Senior Vice President for Industry Relations and Market Development Robert White says “E15 was approved by EPA and the first station opened back in 2012. So, we are now almost 12 years into the process of trying to get all the states approved to offer E15, and California remains the last holdout.”

But how can the state that prides itself on such tough auto emission standards refuse consumers a lower-carbon renewable fuel? White says, “They’ve been focused on their low-carbon fuel standard and expanding that, and, of course, their interest in electric vehicles. But, again, they can set whatever goals they want emission-wise, but don’t exclude the liquid fuels from helping out in the interim or the long term, and don’t stop innovation in technology at the same time.”

And until the California fuel policy-setting panel changes its stance, White says “No action by the California Air Resources Board is keeping the fuel price artificially inflated, but at the same time, causing more pollution than is necessary.”

White says ultimately, RFA expects California to become the 50th state to ok E15 sales as an interim step to bring down emissions and the highest gas prices in the nation. READ MORE