On behalf of the Energy Future Coalition, Urban Air Initiative, Governors’ Biofuels Coalition, Clean Fuels Development Coalition, 25x’25 Alliance, Nebraska Ethanol Board, and Nebraska Ethanol Industry Coalition, Boyden Gray & Associates filed comments on EPA’s Proposed Renewable Fuel Standard Rule for 2017, asking EPA to revise its outdated and flawed analysis of air pollution from the production and use of ethanol and gasoline. In the Proposed Rule, EPA continues to rely on its 2010 lifecycle analysis, despite major improvements in the efficiency of corn agriculture and ethanol production, and despite the oil industry’s reliance on increasingly carbon-intensive sources of “tight oil.”

In its comments on the Proposed Rule, BG&A demonstrated that the best available evidence, including an updated model by Department of Energy scientists, shows that blending ethanol into gasoline significantly reduces lifecycle emissions of greenhouse gas and other air pollutants. Ethanol’s emissions benefits will continue to grow as ethanol production gets cleaner and gasoline production gets dirtier.

Comments of the Energy Future Coalition et al. on EPA’s Renewable Fuel Standard Program: Standards for 2017 and Biomass-Based Diesel Volume for 2018 (July 11, 2016)