MN Bio-Fuels' executive director, Brian Werner, said the proposed rule "undervalues and overlooks the contributions that American-made biofuels can make in achieving enhanced vehicle efficiency and emissions reductions."

"As proposed, the rule notably deviates from the traditional technology-neutral approach that EPA has historically taken when setting greenhouse gas emissions standards for motor vehicles. The rule effectively compels automakers to produce battery electric vehicles to the detriment of similar technologies that can achieve the same or better environmental performance.

"Rather than giving automakers the flexibility to pursue innovative strategies for reducing emissions from the current and future light - and - medium - duty fleets through environmentally friendly, lower cost options like E15 and E85, the proposal tips the scale toward a single technology - electric vehicles," he said.

Werner said a level-playing field for all technologies and fuels is the key to reaching net-zero greenhouse gas emissions by mid-century, adding that laboratory tests have shown that today's low-carbon ethanol reduces greenhouse gas emissions by 50 percent compared to gasoline. 

"According to recent estimates and projections, internal combustion engine vehicles will still occupy more than half the light-duty vehicle marketplace by 2040. Incentivizing the use of higher blends of ethanol like E15 and E85 can immediately reduce carbon emissions from those vehicles.

"Moving forward, technology investments will ensure ethanol reduces greenhouse gas emissions by 70 percent on average by 2030 and 100 percent by 2050. Many production facilities are already utilizing or plan in the next three to five years to adopt a combination of technologies and practices that lower the carbon intensity of the ethanol produced," he said.

Lastly, Werner said the proposed rule falsely assumes that electric vehicles have a zero grams per mile compliance value, adding a proper lifecycle evaluation would include carbon emissions from power generated from coal or natural gas as well as high-energy and land use changes from critical mineral extraction.

"Ignoring the upstream emissions related to electricity generation and critical mineral extraction for electric vehicles creates an uneven playing field and risks undermining efforts to achieve our net-zero  climate goals," he said.

Read his full comments here.