RFA Comments on Oregon Clean Fuels Program

Cindy Zimmerman

The Renewable Fuels Association (RFA) is expressing some concerns related to a planned expansion of the Oregon Clean Fuels Program.

The Oregon CFP currently requires a 10% reduction in the carbon intensity (CI) of transportation fuels by 2025, and the state intends to expand the reductions to 20% by 2030 and 25% by 2035. In anticipation of the expansion, Oregon’s Department of Environmental Quality recently released a set of illustrative scenarios showing different ways that compliance in 2030 and 2035 could beT achieved.

The RFA is supportive of the program and its expansion, but identified some areas of concern related to specific aspects of the scenarios.

First, the scenarios do not assume any reduction in ethanol’s carbon intensity between 2024 and 2035, which is contrary to past experience as well as research on the carbon intensity of ethanol. Going forward, market signals from the Oregon program and the California Low Carbon Fuel Standard can be expected to provide incentive for ethanol producers to reinvest in technologies and processes that further reduce carbon intensity, thereby allowing ethanol to contribute even more substantial greenhouse gas reductions under the program.

Second, while the scenarios take into account extensive use of E15 in Oregon, that blend is not approved for sale in the state at this time. Thus, RFA is encouraging legislative or regulatory solutions to this problem that would allow the sale of lower-carbon E15 and help ensure the volumes reflected in these scenarios can be met. The ability of E15 consumption to ramp up and help meet CFP compliance targets is supported by recent market and regulatory developments, with the examples of Iowa and Minnesota showing growth in E15 demand. At the same time, some state and federal governments are not only providing matching grants for higher-blend infrastructure but seeking ways to remove regulatory burdens on potential retailers.

“RFA supports the expansion of Oregon’s Clean Fuels Program, provided that it is technology- and feedstock-neutral and is based on performance toward reducing carbon emissions,” said RFA Chief Economist Scott Richman. “We hope that the Oregon Department of Environmental Quality will take our concerns into consideration as it moves forward in the rulemaking process.”

Read RFA’s full comments here.

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