Comment submitted by Growth Energy

Summary: Growth Energy, an association of ethanol producers, supports the proposed rule's goal of reducing emissions but argues that the EPA should more fully incorporate the benefits of biofuels into its analysis. They advocate for a lifecycle analysis that accounts for the carbon sequestration of biofuel feedstocks and urge the EPA to consider higher ethanol blends (like E15 and E85) as a viable, low-cost alternative to electric vehicles.