February 15, 2008
Mr. Stephen L. Johnson, Administrator
U.S. Environmental Protection Agency
1200 Pennsylvania, N.W.
Washington, DC 20460
Dear Administrator Johnson:
Americans face increasing pressure from sources that range from an unhealthy dependence on foreign oil to the potential consequences of global warming. To help mitigate these pressures the President signed the Energy Independence And Security Act of 2007 on December 19, 2007.
In addition to increasing the Renewable Fuels (RFS) to 36 billion gallons by 2022, the Act also directs EPA to ensure that the target volumes of renewable fuels are introduced into the United States commerce stream annually. We urge EPA to actively support the research and development needed to make higher blends of ethanol, including E20 and E30, available to American consumers.
While making renewable fuels readily available to all Americans is a long-term objective, the current transportation infrastructure is insufficient to move these products from the production centers in the Midwest to the dense population centers of our coastal areas. This logistical roadblock makes it impractical to satisfy the RFS mandate utilizing current blends of renewable fuels. By incorporating higher blends of ethanol, we can help meet annual target volumes of the RFS while working to improve the biofuels transportation infrastructure.
The recent study cosponsored by the U.S. Department of Energy and the American Coalition for Ethanol and conducted by the University of North Dakota Energy & Environmental Research Center and the Minnesota Center for Automotive Research, provides evidence that fuel mileage increases and tailpipe emissions decrease when increased blends of ethanol are used.
Additional studies funded and/or supported by the Energy Foundation, National Science Foundation, and Renewable Fuels Association, as well as a literature review commissioned by the Governor’s Ethanol Coalition, all confirm that ethanol is an environmentally sound alternative to fossil fuels.
We understand that EPA is working with others to look at issues beyond those relating to human health and the environment. It is important that those issues such as engine
Stephen L. Johnson
February 15, 2008
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performance, engine wear, etc., be studied; and we understand those studies may take a year or more to complete. As such, we strongly encourage EPA to immediately and expeditiously proceed with those studies relating to EPA’s legal responsibility dealing with human health and the environment. These studies need to be completed quickly in order to avoid serious market disruption resulting from the rapid expansion of the ethanol industry in the Midwest.
The Minnesota Department of Agriculture is leading an effort to provide the scientific basis that EPA needs to support a waiver for an E20 ethanol blend. We wish to express our support for the Minnesota Department of Agriculture and intend to assist in this endeavor. Intermediate blends of ethanol will offer more cost effective choices to consumers, reduce dependence on foreign oil, and offer a tool to aid in improving and maintaining air quality. We look forward to working closely with EPA staff to ensure the proper steps are expeditiously taken to expand our options for utilizing our renewable fuels resources.
Sincerely,
L. Roger Johnson
President, NASDA
Commissioner, North Dakota Department of Agriculture
Cc: Robert J. Meyers, EPA Assistant Administrator for Air & Radiation
Margo T. Oge, EPA Director, Office of Transportation & Air Quality
Jon Scholl, Agricultural Counselor to the EPA Administrator