The Michigan Corn Growers Association (MCGA), along with the National Corn Growers Association and 13 other state affiliate associations, urged the Environmental Protect Agency (EPA) to provide more certainty and use forward-looking data analysis to update policy that will lead to greater flex-fuel vehicle (FFV) production and increased demand for higher blends of ethanol.
The associations submitted comments in response to EPA’s request for input on data sources and analytical approaches on which to base an updated weighting factor (F-factor) for E85 FFVs for model year 2021 and later.
“As the producers of the primary feedstock for ethanol, corn farmers support a forward-looking, consistent, long-term F-factor that provides automakers with greater certainty in compliance crediting for planning vehicle production,” the associations wrote.
“Corn farmers have responded to the demand for clean, renewable fuel with increased productivity. Corn production has improved on all measures of resource efficiency, including higher crop yields per acre, resulting in greater corn production using less land and fewer inputs, further fortifying ethanol as a sustainable, low-carbon renewable fuel,” they added.
NCGA and State Corn Grower Associations made the following recommendations:
- We support EPA maintaining the current F-factor of 0.14 unless and until EPA adopts an updated, forward-looking, higher F-factor determination.
- Any future F-factor determination should remain current guidance until EPA adopts a new determination to avoid gaps in the F-factor and prevent a default to zero, supporting certainty for manufacturer decision making.
- We agree with the automotive industry that a five-year advance notice requirement, plus three years of a production safe harbor for FFV models, will provide greater regulatory predictability and encourage automaker planning and innovation in FFV production.
- We believe it is inappropriate for EPA to determine a new F-factor based only on backward-looking data or limited historical data. Use of updated and forward-looking growth in station numbers and per station E85 throughput, however, supports a F-factor of 0.2.
- We have serious concerns with the problematic changes made in federal energy outlook projections made in 2020 compared to 2019, including the treatment of RFS refinery waivers, which make the 2020 outlook unsuitable for F-factor determination without corrections.
- Multiple data sources cited in our comments, support an updated F-factor of at least 0.2.
- We urge EPA to rely on these data sources when determining a F-factor for MY 2021 and later, and we believe the data justifies a F-factor of 0.2.