Original publication date: July 2, 2015

Environmental Protection Agency’s Federal Ethanol Mandate:

Once Viewed as a “Green” Fuel Mandate, The Renewable Fuel Standard is Not Reducing Carbon Dioxide Emissions as Hoped, and is Not Supporting Wetlands, Monarch Butterflies, or Sustainable Agriculture
Source: Corn Policy, USDA, http://ers.usda.gov/topics/crops/corn/policy.aspx.

On June 25, 2015, the Environmental Protection Agency held a public hearing for its proposed changes to the 2014, 2015, and 2016 Renewable Fuel Standard. MCE testified in support of the proposed modification. In November 2015, the EPA finalized their changes as proposed at the hearing. Read former Agriculture Secretary Tom Vilsack’s statement about EPA’s finalized Renewable Fuel Standard here.

Read below to understand MCE’s position on the modification and ethanol as a fuel source generally.

Under the Clean Air Act, the EPA is required to establish annual percentage standards for each of the renewable fuel categories and is proposing the volume of biomass-based diesel that will be required in 2017.[1]

The Renewable Fuel Standard (RFS) is a U.S federal program that originated with the Energy Policy Act of 2005 and expanded with the Energy Independence and Security Act of 2007. The RFS program requires renewable fuel to be blended into transportation fuel in increasing amounts each year. The conventional (corn ethanol) and advanced (biomass-based and cellulosic) biofuels used must emit lower levels of greenhouse gases relative to the petroleum-based fuel. [2] Congress’ renewable fuel program is an attempt to combat climate change, expand domestic renewable fuel production, and maintain energy sovereignty.

EPA-proposed changes to renewable fuel volumes were lower than Congressional targets, but were still higher than in previous years. The proposed volumes reflected the amount of domestic biofuel produced and used and were meant to incentivize production of advanced biofuels over conventional corn ethanol. Based on the market’s ability to absorb higher ethanol blends and constraints in the fuel market to produce sufficient quantities of non-ethanol renewable fuels, the EPA hoped to set a more achievable standard than the statutory levels.[3]

The 2005 and 2007 Energy Bills deeply distorted and heavily subsidized the corn market- directly incentivizing unsustainable and environmentally detrimental land disturbance. At the inception of the RFS, corn ethanol was billed as a “green” alternative, a cleaner-burning fuel for our cars promising air quality benefits and the reduction of the greenhouse gas emissions that contribute to climate change. The original law intended for corn ethanol to be the primary biofuel used to meet the RFS initially, followed by a transition to more advanced biofuels. However, the development of cellulosic alternatives did not materialize as hoped and the federal corn ethanol mandate has failed to deliver on any of its promised environmental benefits.

The EPA’s 2015 draft update to the rule would have kept this failed policy on life support – which serves the narrow interest of the corn ethanol lobby and the corn ethanol lobby alone – while we pay the costs. Ever since the federal corn ethanol mandate was codified into law nearly a decade ago, we have read the headlines and heard the talking points regarding corn ethanol’s so-called environmental benefits. The production of corn ethanol has had unintended harms to the environment, including land conversion of important habitat and carbon sinks, and continued stress on our water and soil quality as a result of incentives to intensify corn production across the country.

MCE is grateful the EPA finalized their proposed rule in the fall of 2015. Here are major reasons MCE opposed the 2015 Draft EPA Rule Update:

  • Mandating minimal ethanol blending in commercial fuel production created an artificially high demand for corn–propping up corn prices at the expense of the environment and all of us that rely on clean air and water.
  • Higher corn prices effectively incentivize commodity crop production. This decreases the incentives to invest in renewable fuel sources like wind and solar or to grow the food people eat. The mandate is a clear price signal to the agricultural industry. Kansas and Missouri are among the top ten corn producing states in the country and have responded to this signal. Growing corn is profitable. Preserving a wetland or sustainably growing spinach is not.
  • The government-guaranteed market for corn ethanol may be profitable for industrialized agriculture, but the conversion of Midwest land into heavily-subsidized corn fields also yields poor air, soil, and water quality and has resulted in the destruction of valuable habitat- all while increasing climate change-causing greenhouse gas emissions.
  • The University of Minnesota found that corn ethanol’s total life cycle emissions are “twice as damaging to the air quality as gasoline.”[4] Additionally, Stanford University scientists found that ethanol-fueled cars generate higher ozone concentrations compared to those fueled by pure gasoline.[5]
  • Between 2008 and 2011, 23 million acres of grassland, shrubland and wetlands were converted to commodity crop production in large part a response to higher demand for corn.[6]These acres once served as carbon sinks. Now they release stored carbon and eliminate that function. University of California-Berkeley scientists note that such ethanol-related land conversion results in higher greenhouse gas emissions than fossil fuels.[7]
  • As the EPA is well aware, the pesticides and fertilizer used in industrial corn production cause fish kills, contributes to the Dead Zone in the Gulf of Mexico, and pollutes our drinking water supplies when it runs off farm fields.[8]
  • Land conversion destroys valuable habitat.[9] For example, as reported in the Kansas City Star, corn ethanol production has contributed to the annual destruction of 1 million acres of milkweed, the Monarch Butterfly’s only food source.[10]

Corn ethanol and the policy that mandates its production is devastating to our environment. At this major milestone, we must finally put our environment and science before narrow special interests, support using quality farm land for sustainable agricultural production, and invest in renewable fuels that don’t harm our environment. Increasing corn ethanol is not the way to achieve a sustainable clean future.[11]

Additional Resources on Ethanol’s Impacts on the Environment

Christopher K. Wright & Michael C. Wimberly, Recent Land Use Change in the Western Corn Belt Threatens Grasslands and Wetlands, 110 Proceedings of the National Academy of Sciences 4134, 4134 (2013), http://www.pnas.org/content/110/10/4134.full.pdf+html.

Center for Climate & Energy Solutions, Cellulosic Ethanol (2009), http://www.c2es.org/docUploads/Cellulosic-ethanol-11-09.pdf.

Union of Concerned Scientists, The Energy-Water Collision: Corn Ethanol’s Threat to Water Resources (2011). http://www.ucsusa.org/sites/default/files/legacy/assets/documents/clean_energy/ew3/corn-ethanol-and-water-quality.pdf.

Sierra Club Guidance on Biofuels, Sierra Club Grassroots Network, https://content.sierraclub.org/grassrootsnetwork/team-news/2015/02/sierra-club-guidance-biofuels.


[1] Environmental Protection Agency, Regulatory Announcement: EPA Proposes Renewable Fuel Standards for 2014, 2015, and 2016, and the Biomass-Based Diesel Volume for 2017,  http://www.epa.gov/oms/fuels/renewablefuels/documents/420f15028.pdf.

[2] Alternative Fuels Data Center: Renewable Fuel Standard, U.S. Department of Energy, http://www.afdc.energy.gov/laws/RFS.html.

[3] Environmental Protection Agency, Regulatory Announcement: EPA Proposes Renewable Fuel Standards for 2014, 2015, and 2016, and the Biomass-Based Diesel Volume for 2017, http://www.epa.gov/oms/fuels/renewablefuels/documents/420f15028.pdf.

[4] U Of M Study Finds Ethanol Worse For Air Quality Than Gasoline, CBS Minnesota (December 17, 2014 6:51 PM), http://minnesota.cbslocal.com/2014/12/17/u-of-m-study-finds-ethanol-worse-for-air-quality-than-gasoline/.

[5] Louis Bergeron, Stanford Researchers: Ethanol Results in Higher Ozone Concentrations Than Gasoline, Stanford Report (December 14, 2009), http://news.stanford.edu/news/2009/december14/ozone-ethanol-health-121409.html.

[6] Ethanol’s Broken Promise: Emissions from Land Use Change, Environmental Working Group (May 29, 2014), http://www.ewg.org/research/ethanols-broken-promise/emissions-land-use-change.

[7] Matthew Cimitile, Corn Ethanol Will Not Cut Greenhouse Gas Emissions, Scientific American (April 20, 2009), http://www.scientificamerican.com/article/ethanol-not-cut-emissions/.

[8] David Biello, Fertilizer Runoff Overwelms Streams and Rivers — Creating Vast “Dead Zones” , Scientific American (March 14, 2008), http://www.scientificamerican.com/article/fertilizer-runoff-overwhelms-streams/.

[9] Michael Wines, Setting The Table for a Regal Butterfly Comeback, with Milkweed, N.Y. Times (December 20, 2013), http://www.nytimes.com/2013/12/21/us/setting-the-table-for-a-fluttering-comeback-with-milkweed.html?_r=1.

[10] Eric Alder, National Effort to Plant Milkweed Aims to Rebuild Monarch Butterfly Population, The Kansas City Star (February 12, 2015), http://www.kansascity.com/news/local/article9931433.html.

[11] Emily Cassidy, How Corn Ethanol is Worse for Climate Change than The Keystone Pipeline, Environmental Working Group (May 29, 2015), http://www.ewg.org/agmag/2015/05/how-corn-ethanol-worse-climate-change-keystone-pipeline.