National Association of Egg Farmers File Comments on EPA Proposal for Ethanol

National Association of Egg Farmers, a coalition of farmers producing eggs from coast-to-coast, appreciates the opportunity to comment on the EPA proposed the 2014 volume requirements and associated percentage standards for the RFS program. The proposed 2014 standard for corn ethanol is 13.1 billion gallons, a reduction of 1.4 billion and equal to the 2013 consumption.  While members of the egg industry have questioned the use of corn for fuel, we support cellulosic biofuel and biomass-based diesel in the renewable fuel program. So this reduction in corn for ethanol production is supported by National Association of Egg Farmers.

National Association of Egg Farmers position on issues has consistently maintained that market forces are the best because they allow consumers to decide what goods and services they prefer instead of implementing federal regulations or new laws by Members of Congress.  Involvement in the market place by the federal government, although well-intentioned, can create a negative impact on certain businesses and the ethanol mandate is an example.  The U.S. ethanol mandate is responsible for claiming 37% of total corn production in the U.S. and 15% of total world corn production.  This is devastating to the end-users of corn in feeding animal agriculture including chickens producing eggs.  When any commodity is reduced, the corresponding effect on price catapults in the opposite direction.  When there was a small downward adjustment to the expected harvest in corn production, the corn prices jumped almost 18%.  The Federal law requires that fuel suppliers blend more and more ethanol into gasoline, until the annual total rises from 9 billion gallons of (ethanol) EtOH in 2008 to 36 billion in 2022.  Removing more corn from the commodity markets simply increases the price of corn, hurting consumers who buy animal products such as meat, milk and eggs which must be increased to offset the increased cost of production.  In the egg industry, the cost of feed is nearly 60% the cost of the egg produced with corn being the most widely used feed grain.  There is no other feed grain that provides the same quality nutrients needed by chickens in producing eggs to feed this nation.

Problems With Ethanol and Why EFA Opposes E15

* Ethanol costs 3.5 times as much as gasoline to produce, but contains only 65% as much energy per gallon as gasoline.

* The more ethanol there is in gasoline, the more often consumers have to fill up their tanks, the less value they get, and the more they must deal with repairs, replacements, lost earnings and productivity, and malfunctions that are inconvenient or even dangerous.

* Ethanol burns hotter than gasoline. It collects water and corrodes plastic, rubber and soft metal parts. Older engines and systems may not be able to handle E15 (15% ethanol) or even E12 (12% ethanol), which could also increase emissions and adversely affect engine, fuel pump and sensor durability.

* Corn growers will benefit from a higher ethanol use, however government mandates mean higher prices for corn.  Thus, eggs, beef, pork, poultry farmers must pay more for corn-based feed; grocery manufacturers face higher prices for grains, eggs, meat and corn syrup and overall grocery bills go higher.

Environmental Concerns

* Ethanol has only two-thirds the energy value of gasoline – and it takes 70% more energy to grow and harvest corn and turn it into EtOH than what it yields as a fuel. There is a “net energy loss.”

* Analysts also calculate that growing and processing corn into ethanol requires over 8,000 gallons of water per gallon of alcohol fuel.

* Ethanol blends do little to reduce smog, and in fact result in more pollutants evaporating from gas tanks, says the National Academy of Sciences.

Grow Grain for Food Not Fuel

Michigan State University scientists concluded, after examining 17 years’ worth of data, "It's 36 percent more efficient to grow grain for food than for fuel," said Dr. Ilya Gelfand, MSU.  "The ideal is to grow corn for food, then leave half the leftover stalks and leaves on the field for soil conservation and produce cellulosic ethanol with the other half." The results are published in the April 19, 2010 online issue of the journal Environmental Science & Technology.

National Association of Egg Farmers appreciates this opportunity to comment urging EPA not to expand usage of a food to convert it into a fuel.   We oppose E15 for the damaging effect it will have on feed costs to animal agriculture and the damage it will do to older model engines and its effect on the environment.