Ethanol stakeholder organizations submitted comments to the Environmental Protection Agency this week regarding the E85 Flexible Fuel Vehicle Weighting Factor (F-factor) for Model Year 2021 and Later Vehicles.

Comments from the Renewable Fuels Association (RFA) support EPA’s new approach to maintaining some level of certainty for automakers, but would like to see the agency “provide a long-term floor and “more robust” E85 usage factors for future model years, given expected growth and the many benefits provided by ethanol flex fuels.”

“Based on our discussion with automakers, it is clear that manufacturers will hesitate to invest in certain technologies, like FFVs, unless there is some assurance that those vehicles technologies will help enable CAFE and GHG standard compliance over multiple model years,” wrote Kelly Davis, RFA Vice President for Regulatory Affairs. “Fuel blenders and retailers also need multi-year certainty regarding the likely mix of light-duty vehicles so that they may appropriately direct their investments in wholesale and retail fuel infrastructure.”

The American Coalition for Ethanol (ACE) supports an F-factor of at least 0.20 for model year 2021 and later vehicles, and encourages EPA to consider “forward-looking data which indicate E85 use will significantly rise in the future. Until such time EPA establishes a 0.20 or greater F-factor, ACE strongly encourages the Agency to maintain the 0.14 F-factor, so the value does not default to zero.”

The National Corn Growers Association (NCGA) and 14 state corn grower groups also urged EPA to provide more certainty and use forward-looking data analysis to update policy that will lead to greater flex-fuel vehicle (FFV) production and increased demand for higher blends of ethanol.

“As the producers of the primary feedstock for ethanol, corn farmers support a forward-looking, consistent, long-term F-factor that provides automakers with greater certainty in compliance crediting for planning vehicle production,” the associations wrote.