Iowa Renewable Fuels Association (IRFA) submitted written comments to the California Air Resources Board (CARB) regarding the October 14, 2025, Scoping Workshop on E15 Use in California. CARB is working to implement California legislation, known as AB30, that legalized the sale of E15 in the state.
In the comments, IRFA strongly encouraged CARB to avoid an unnecessary delay and embrace a proactive approach to enabling E15 availability across the state, concluding: “E15 can help reverse the increasingly high cost of fuel that has put a financial strain on motorists in California – if the correct regulatory framework is established. IRFA urges CARB to create a safe and secure regulatory pathway for E15 to expeditiously achieve widespread consumer access.”
Key points from IRFA’s comments include:
Learn From Iowa’s Experience
“There is no need for California regulators to step into the unknown or to worry about the risk/reward of the various options you are considering. Iowa is happy to share our decade-plus experience with E15 and our decades of experience with ethanol blends of all levels.”
Consumer Savings
“Iowa E15 sales in 2025 will more than double those in 2024, reaching nearly 500 million gallons, or 33% of Iowa’s fuel sales. Iowa has shown that when regulations allow consumers the option of E15, they choose it…In Iowa, E15 is typically priced 10 to 20 cents below E10.”
“IRFA believes the E15 discount in California should be larger than in Iowa, as California has essentially put a ‘carbon price’ on fuel. Increasing the ethanol content by 50% leads to a big carbon reduction. As such, we would expect the E15 discounts in California to be 30 to 40 cents per gallon. While various studies can predict varying levels of additional savings, the fact remains that E15 will absolutely save Californians money.”
California RFG or Alternative Fuel
“California should update its CaRFG specification to accommodate E15.”
Infrastructure Upgrades
At fuel terminals: “Absolutely no terminal infrastructure upgrades are necessary to accommodate E15 blending in California, and there has been no terminal issues with accommodating E15 over the last 13 years.”
At fuel retailers: “IRFA urges the California ‘authority having jurisdiction’ to follow the trail blazed by Iowa and other states and to recognize that ‘E10’ dispensers can safely offer E15.”
Potential E15 Impacts
“With nearly 95% of California’s vehicle fleet comprised of 2001 and newer vehicles, it makes sense to give these vehicle owners the lower-cost option of E15.”
Misfuelling Concerns
“Adding additional state level requirements for retailers to the mandated U.S. EPA misfuelling regulations would serve only to reduce the availability of E15 while simultaneously increasing the cost for motorists who can access it.”
E15 is not a mandate
“[AB30] does not require even one retailer to offer E15, nor does it require even one motorist to choose to purchase E15. Proper rules and guidelines simply make it possible for a retailer to offer E15 if they feel it is a good business decision.”
