Docket ID No. EPA–HQ–OAR–2021–0427

We are urging the Environmental Protection Agency to reduce, not increase, the volume requirements for dirty sources of energy in the Renewable Fuel Standard.

Iowans continue to feel the effects of climate change. In recent years, we’ve experienced two derechos, violent winter tornados, flash flooding and extreme drought, adding up to billions of dollars in damages already. Iowans are ready for and deserve real climate solutions that mitigate and adapt to the challenges we are facing.

Iowa is inundated with over 10,000 large-scale livestock confinements, or factory farms, primarily hog factories that house approximately 26 million hogs. Factory farms account for 37% of methane emissions, which has more than 20 times the global warming potential of carbon dioxide. Instead of focusing on common sense policy solutions such as pasture-based livestock production and effective conservation practices, policymakers have incentivized false climate solutions like factory farm gas, also known as biogas. Biogas (turning factory farm methane into fuel for vehicles) promotes corporate concentration in the livestock industry and drives factory farm expansion further.

While Iowa farmers are forced to farm fence row to fence row to try get by, corporations like ADM ethanol have been making their profits by promoting this false energy solution. According to the Proceedings of the National Academy of Science (PNAS), 40% of all corn is now used to make ethanol and showed that ethanol causes more GHG emissions than gasoline amongst a series of other concerns.

In yet another attempt to tap into and hijack our taxpayer dollars, corporations are now proposing dangerous carbon capture and sequestration pipelines. Three profit driven corporations, Summit, Navigator and Wolf/ADM have their sights set on Iowa with plans to build nearly 2,000 miles of pipeline in Iowa alone. Carbon capture and sequestration promotes extractive energy systems such as ethanol and extends the life of the fossil fuel industry as the captured carbon is often used for enhanced oil recovery.

Relying on dirty fuels like factory farm gas, ethanol and carbon capture and sequestration to clean up our transportation sector will only dig a deeper hole. The EPA should recognize this by reducing, not increasing, the volume requirements for these dirty sources of energy in the Renewable Fuel Standard.