Nove mber 11 , 2014

Mr. Christopher Grundler USEPA Headquarters William Jefferson Clinton Building 1200 Pennsylvania Avenue NW Washington, DC 20460

Dear Mr. Grundler:

The undersigned agricultural, conservation, environmental, public health, alternative fuel and bioenergy value chain partners are writing to endorse Volkswagen of America’s recent request for EPA to issue the enclosed Proposed Guidance Letter concerning th e E85 weighting factor (“F factor”) for model year 2016

- 2025 dual fuel vehicles. This guidance is critical to incentivize the continued production of flex fuel vehicles (FFVs) and to support the further advancement and deployment of biofuels into the natio n’s liquid transportation fuel pool; fuels which are essential to reducing greenhouse gas (GHG) emissions and enhancing air quality.

Automobile manufacturers offer a diverse portfolio of vehicle technologies that operate on alternative transportation fuel s. A diverse portfolio of vehicle technologies creates customer value by enabling consumers to choose the best package that fits their needs. Fuel choice among gasoline, diesel, ethanol, electricity, and natural gas is one important option considered by a consumer. Providing enhanced incentives for FFVs would create parity with other alternative fuel vehicles and level the playing field for the sale of FFVs. It is therefore crucial that EPA provide the regulatory framework that encourages the continual int roduction and expansion of FFVs as part of the overall advanced fuel vehicle technologies portfolio. FFVs will support the consumption of alternative transportation fuels in the marketplace and provide immediate GHG benefits. Without additional regulatory incentives to manufacture FFVs, automobile manufacturers may focus on other alternative vehicle technologies as a means to comply with the challenging 2017

- 2025 GHG and CAFE standards, resulting in fewer FFVs in the marketplace.

Furthermore, continuing to incentivize the production of FFVs helps facilitate successful implementation of the Renewable Fuel Standard (RFS) program. Increased use of E85 and midlevel blends in FFVs offers a readily available pathway for regulated entities to help meet the goals of the RFS

.
Today, over 17 million FFVs operate on American roadways. i The use of E85 and midlevel ethanol blends in FFVs represents the most cost

- effective and efficient way to help meet the ambitious new federal standards for reducing petroleum use and tailpipe emissions. Ethanol and

othe r advanced biofuels facilitate CO 2 emission reductions both within the vehicle, and, more importantly, throughout their production life cycle. But for these benefits to be realized, FFVs must continue to be built. Without the F factor requested by Volkswagen of America, the future

of FFVs is at great risk.

While there are multiple economic, national security and environmental reasons for continuing to provide meaningful federal incentives to help facilitate the continued production of FFVs, one of the most compelling is the GHG emission r eduction benefits they produce when vehicles arefueled with biofuels. Recent GREET analyses estimate that corn ethanol life

- cycle greenhouse

gas emissions are 19

- 48% (mean=34%) lower than conventional gasoline. ii At the current 10%

ethanol

- gasoline blend l evel the 34% carbon intensity (CI) reduction per gallon results in greenhouse gas savings from corn ethanol alone of approximately 35 million metric tonnes in 2012 or 2% of transportation related emissions. iii

In addition the latest version of GREET shows a 100% reduction in GHG emissions for forest

residue to ethanol

. iv Forest residue collection is part of sustainable forest management for wildfire protection and thinning of commercial forests. Thus the use of this feedstock results in

no indirect land use and promotes the growth of forest material with increased CO2 sequestration.

Going forward, research performed by the Life Cycle Associates (LCA) has shown that emerging co

- products such as corn stover used as animal feed and cellulosic ethanol from corn

s tover and corn kernel fiber will further reduce the CI of corn ethanol. Treating corn stover as a

co

- product to corn production and assuming blending requirements set by the Renewable Fuel Standard for corn and cellulosic ethanol, LCA has shown that the co mbined CI of corn

- based biofuels will approach 39 gCO 2 e/MJ by 2022. v This is a 60 percent reduction from average U.S. petroleum transportation fuels . For comparison purposes, advanced biofuels require a 50%

reduction in CI from the EPA Petroleum Baseline a nd cellulosic ethanol requires a 60% reduction in order to obtain the respective designation.

We urge EPA to issue the F factor guidance letter proposed by Volkswagen of America. Doing so will allow for expanded use of lower carbon intensive biofuels and w ill represent an important and helpful first step towards resolving the lack of parity in federal incentives for FFVs and other

alternative

- fueled vehicles.

Thank you for considering our request.

Respectfully submitted,

25x'25 Alliance

Advanced Biofuels USA Agricultural Retailers Association

American Coalition for Ethanol American Council on Renewable Energy

American Farm Bureau Federation

American Seed Trade Association Association of Equipment Manufacturers Chicago Area Clean Cities

Clean Fuels Development Coalition

Clean Fuels Foundation

Clean Fuels Ohio

CoBank

Colorado Corn CropLife America

East Tennessee Clean Fuels Coalition Eastern Pennsylvania Alliance for Clean Transportation Environment and Energy Study Institute

Ethanol Across Amer ica FlexFuel Awareness Campaign Genera Energy Genesee Region Clean Communities, Inc.

Greater Indiana Clean Cities Coalition
ICM, Inc

Illinois Corn Growers Association

Illinois Renewable Fuels Association

Iowa Corn Growers Association

Iowa Renewable Fuels Association

Kansas Corn Growers Association Kentucky Corn Growers Las Vegas Regional Clean Cities CoalitionMaryland Grain Producers Association

Minnesota Clean Cities

Minnesota Corn Growers Association

Missouri Corn Growers Associati on National Association of Conservation

Districts

National Corn Growers Association

National Farmers Union

Natural Resource Solutions NC Clean Energy Technology Center

Nebraska Clean Cities Coalition

Nebraska Corn Board

Nebraska Ethanol Board

Nebraska Et hanol Industry Coalition Nebraska Farmers Union

North Dakota Clean Cities Northeast Ohio Clean Transportation

Coalition

Ohio Corn & Wheat Growers Association

Renew the Earth Sapp Brothers Petroleum

Schmitt Industries South Carolina Clean Energy Business

Alliance Transportation Fuels Consulting

Urban Air Initiative Virginia Clean Cities

cc: EPA Administrator Gina McCarthy

Enclosures

- October 7, 2014 Volkswagen of America letter to EPA

- Volkswagen of America’s proposed F factor guidance letter

i According to the Department of Energy (2014): “... there are more than 17.4 million FFVs on U.S. roads today.” ( http://www.afdc.energy.gov/vehicles/flexible_fuel.html )

ii Wang, M., et al (2012) Well

- to

- wheels energy use and greenhouse gas emissions of ethanol from corn, sugarcane and cellulosic

biomass for US use. Environ. Res. Lett. 7 045905

iii EIA reports 2012 gasol ine consumption at 134 billion gallons and EPA reports 2012 total transportation related emissions at 1,827 million metric tons (http://www.epa.gov/climatechange/ghgemissions/sources.html)

iv Stefan Unnasch, Life Cycle Associates, analysis performed with GREET V. 2014.

v Boland. S. and Unnasch. S. (2014) Carbon Intensity of Marginal Petroleum and Corn Ethanol Fuels. Life Cycle Associates

Report LCA.6075.83.2014, Prepared for Renewable Fuels Association.

( http://ethanolrfa.org/page/

- /rfa

- association

- site/studies/LCA_Marginal_GHG_Emissions_2014.pdf?nocdn=1 )