The National Corn Growers Association filed comments with the Environmental Protection Agency (EPA) on ethanol and the Waters of the U.S. (WOTUS) regulations, following President Trump’s executive order, “Enforcing the Regulatory Reform Agenda.”
NCGA urged the EPA to use its authority to give drivers year-round access to higher blends of ethanol such as E15. EPA has previously issued a Reid Vapor Pressure waiver for 10 percent ethanol blends. Providing E15 with the same waiver would lead to more choices at the pump and cleaner air.
NCGA also encouraged EPA to update its lifecycle analysis for corn-based ethanol. EPA last updated its lifecycle analysis in 2010, projecting that corn-based ethanol would produce 21 percent fewer GHG emissions when compared to gasoline by 2022. Other federal government agencies have issued updated GHG lifecycle analysis for ethanol based on actual corn and ethanol production experience. Most recently, USDA analysis released in 2017 shows corn-based ethanol results in 43 percent fewer GHG emissions when compared to gasoline.
EPA’s outdated lifecycle analysis for corn-based ethanol is hindering ethanol exports, as well as expansion of domestic ethanol use. NCGA also believes EPA should review and update its emissions modeling and fuel petition procedures to help ensure sound regulatory decision-making for future high-octane fuels such as higher ethanol blends.
Finally, NCGA expressed support for Executive Order 13778, which directs EPA and the Army Corps of Engineers to review the 2015 Waters of the U.S. (WOTUS) rule. NCGA has serious concerns with the 2015 rule and supports Agency efforts to rescind and replace it with a rule that achieves the 1972 Clean Water Act’s underlying goal of protecting the chemical, physical, and biological integrity of the nation’s waters. NCGA is committed to working with the Agency on a rule that provides clarity and certainty for farmers and is in line with the Clean Water Act.