November 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 the 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 nation’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 fuels. 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 introduction 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.iThe 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 

other advanced biofuels facilitate CO2 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 reduction benefits they produce when vehicles are 
fueled 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 level 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 

stover 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 combined CI of corn-based 

biofuels will approach 39 gCO2e/MJ by 2022.vThis 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 and 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 will 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 America

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 Coalition
Maryland Grain Producers Association

Minnesota Clean Cities

Minnesota Corn Growers Association

Missouri Corn Growers Association

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 Ethanol 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 gasoline 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)