Never stop speaking out: Here's our letter to the EPA on the the Renewable Fuel Standard

POET Biofuels near Albert Lea, Minn.

POET Biofuels near Albert Lea, Minn.

Ethanol fatigue is a real thing.

The Environmental Protection Agency (EPA) continues to try and tear apart the Renewable Fuel Standard (RFS), leaving exasperated corn farmers and supporters of clean, renewable, homegrown ethanol banging their heads against their desks and saying, “We gotta fight this battle all over again?”

Unfortunately, yes, we have to fight that battle all over again.

Here at the Minnesota Corn Growers Association (MCGA), we know mustering up the energy to fight the same old battle about ethanol and the RFS can be tiresome. We also know that it feels like your voice doesn’t matter.

These feelings are understandable. These feelings are also exactly what EPA and ethanol’s critics hope for.

They want ethanol supporters to feel beaten down. Once the the pro-ethanol crow is too tired to stand up and speak out, that’s when EPA can truly cave in to Big Oil’s demands and deal a crippling blow to ethanol fuels.

Here at MCGA, we feel frustrated, but we’re not going to stop standing up for our corn farmers and homegrown ethanol. We can take any punch EPA and Big Oil throws at us, then come back with an uppercut and powerful right hook of our own.

We sent two Minnesota corn farmers to Kansas City to speak at a public hearing on the RFS. We also encouraged farmers and ethanol supporters to submit comments about EPA’s latest proposal to slash the corn ethanol portion of the RFS.

Finally, MCGA submitted its own comment letter on the RFS earlier this week. You can read it below.

As frustrating as it can be sometimes, never stop standing up and speaking out for ethanol, corn farming, agriculture and other issues that impact your way of life. If you don’t speak out, who will?

(PS — For those of you unfamiliar with the RFS, it’s a piece of legislation passed by Congress in 2005 and amended in 2007 that sets annual targets for the amount of homegrown biofuels blended in our nation’s fuel supply. EPA’s proposed cuts to the RFS would damage air quality, limit choices at the pump and could cost corn farmers up to $271 million in lost revenue.)

July 11, 2016

Ms. Julia MacAllister
Office of Transportation and

Air Quality Assessment and Standards Division

Environmental Protection Agency (EPA)
2000 Traverwood Drive

Ann Arbor, MI  48105

RE: Docket ID No. EPA-HQ-OAR-2016-0004

Dear Ms. Julia MacAllister:

On behalf of the more than 7,200 members of the Minnesota Corn Growers Association (MCGA), we request that the Environmental Protection Agency (EPA) adhere to the statutory requirements of the Renewable Fuel Standard (RFS) for the non-advanced biofuel (conventional) category.  Corn starch ethanol provides the predominant fuel volumes in the RFS today and as new technologies continue to advance, corn starch ethanol paves the way for other renewable technologies to gain market opportunity through the RFS program.

EPA cited a lack of compatible fueling infrastructure to distribute ethanol blended fuels to consumers as the justification for the proposed rule change for 2017.  MCGA believes this justification is flawed.  The United States Department of Agriculture (USDA) recently introduced one of the most expansive renewable fuel infrastructure grant programs in the history of the United States to address EPA’s concern.  The Biofuels Infrastructure Partnership (BIP) allows partners such as state commodity organizations, biofuels advocacy groups, biofuels industry, and others to match USDA funding.  The response was incredible, with 21 states offering $110 million worth of matching funds.  In 2016, $220 million worth of renewable fuel compatible infrastructure will be implemented.  It is estimated that 1,486 stations will receive fueling infrastructure, including 4,880 dispensers, and 515 underground storage tanks. Minnesota was awarded $8 million from the BIP grant program.  MCGA is proud to partner with 18 ethanol plants, health/industry advocacy associations, and the Minnesota Department of Agriculture in this opportunity to expand fueling infrastructure.

In addition to the investment in flex pumps and compatible tank systems, MCGA is fully engaged in the Department of Energy (DOE) Optima4 (Co-optimization of fuels and engines) program.  DOE is looking for opportunities to develop low carbon intensity transportation fuels that reduce our dependence on petroleum and bridge the gap to the next generation of energy efficient transportation systems.  The corn stakeholders have been working with the automobile manufacturers, agricultural industry partners, technical agency researchers, and pump manufacturers to apply the principles of the Optima program.

Today, Minnesotans have access to more than 300 stations that offer E85.  Beginning in September of 2013, a broad coalition (including MCGA) invested in ethanol infrastructure and helped install more than 40 stations with 120 flex-fuel pumps throughout the state. The flex pumps provide consumers multiple fueling options including: normal grades of gasoline; ethanol blends like E15, E30 or E85; diesel; or non-oxy premium for small engines and legacy vehicles. This epitomizes consumer choice at the pump.

The retailers with flex-fuel pumps have gained market opportunity with their consumers.  The E15 (15% ethanol/85% gasoline) blend allows a station owner to offer an 88 octane (mid-grade fuel) for up to $0.10 less  per gallon than grade gasoline (87 octane) in Minnesota.  This blend is approved for use in all vehicles manufactured in 2001 or newer, representing approximately 80% of vehicles on the road today. Retailers offering renewable blends have increased their sales by 20%.  The benefit to the consumer at the pump is cost savings and access to a mid-grade fuel.  The RFS is working — stations are competing based on fueling options made available to the consumer.  EPA should not reduce corn starch ethanol when it is providing a less expensive fuel option for consumers and creating a competitive fueling market. Corn starch ethanol is paving the way for other renewable fuel sources to gain market access and a reduction in the RVO will undermine this progress.

Ethanol has created economic opportunities in Minnesota.  There are 21 ethanol plants in Minnesota (nearly half of which are farmer-owned cooperatives) that support nearly 18,116 jobs1. Ethanol has rejuvenated the rural economy in many parts of the state leading to better schools, updated infrastructure, and vibrant main street businesses2. The RFS has been a significant factor in economic2 gains.  Minnesota’s ethanol industry contributes $2.132 billion to the states gross domestic product and $7.372 billion in gross sales.  Volume of ethanol produced increased 11%2 in 2015 compared to 2014.  In addition, ethanol adds $1.5 billion to the Minnesota corn crop each year through co-products from the ethanol process2 including Distillers Grains, Gluten Feed, Gluten Meal, Corn Oil, Carbon Dioxide, and Green Chemicals.

There are also health benefits of corn ethanol.  The Minnesota Department of Health (MDH) and Minnesota Pollution Control Agency (MPCA) released an annual report this past July (Life and Breath report3) on the quality of our air in Minnesota and how it is affecting the public health.  A major source of air pollution is from mobile sources or tailpipe emissions.  This report estimates there are 2,100 deaths, 200 respiratory hospitalizations, 91 cardiovascular hospitalizations, and 400 emergency room visits for asthma in Minnesota as contributed to by mobile sources.  The EPA should be  working to reduce air pollution.  We should not cut a renewable fuel source (corn starch ethanol) that provides an immediate solution to displace petroleum.  At  the United Nations Climate Change Conference (COP21) in Paris, 64 countries mandated the use of ethanol in their fuel supply to combat climate change. There was no mention of ethanol in the Climate Plan for the United States.  Displacing gasoline’s aromatic hydrocarbons with ethanol reduces primary and secondary emissions of toxic air pollutants, including particulate matter, polycyclic aromatic hydrocarbons, and volatile organic compounds.  Unfortunately, the United States government is overlooking ethanol as part of the solution for our air quality issues and Climate Change.

Instead of cutting the RFS, EPA should work to  solve issues like air quality, climate change, and market barriers.  Obstacles like Reid Vapor pressure – an unnecessary regulation that blocks the sale of E15 to non flex-fuel vehicles during the summer months — should be removed to  advance the adoption of E15. If all gasoline contained 15 percent ethanol, we’d replace 7 billion gallons of foreign oil and remove as much as 8 million tons of greenhouse gas emissions from the air annually.

In summary, lower RVO numbers are bad for farmers and bad for all Americans.  The RFS was intended to change the way oil companies do business and spur investment in cleaner, low carbon, domestic fuels like ethanol. The RFS also was passed to boost investment in the infrastructure necessary to accommodate higher biofuel blends.  It was designed to give consumers more choices at the pump, lowering gas prices and move beyond today’s market reality where ethanol is used primarily as a gasoline additive to boost octane.

The RFS is a success and has played an important role in reducing petroleum imports, cleaning our air and strengthening the economic health of rural America.  Corn farmers have proven that they’re capable of growing enough corn to produce food, feed, fiber and fuel. Now is not the time to take America’s energy policy backward. Now is the time for EPA to preserve the RFS and keep American energy policy headed in the right direction.

Thank you for the opportunity to comment on this important issue.


Noah Hultgren
Minnesota Corn Growers Association


  • Urbanchuk, John, M. and Norvell, Stuart, D. 2016. Contribution of the Ethanol Industry to the Economy of Minnesota (Agriculture and Biofuels Consulting, LLP)

  • Fuels America Infographic. 2015. RFS Drives Economic Growth in Minnesota

  • Bael, David and Sample, Jeannette. 2015. Life and Breath Report (Minnesota Pollution Control Agency and Minnesota Department of Health)

  • Farrell, John. 2016. Co-Optimization of Fuels and Engines (Department of Energy)

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