Environmental Justice Act of 2021

Submitted feedback to the National Highway Traffic Safety Administration (NHTSA) on its proposed rulemaking for Corporate Average Fuel Economy Standards for Passenger Cars and Light Trucks for Model Years 2027-2032 and Fuel Efficiency Standards for Heavy-Duty Pickup Trucks and Vans for Model Years 2030-2035, calling on NHTSA to develop a technology-neutral approach to meet fuel economy standards and decarbonize transportation fuel. Supported S. 3055 and H.R. 6152, the Adopt GREET Act, a bill to require the Environmental Protection Agency (EPA) to update its outdated lifecycle modeling for ethanol and biodiesel, specifically by adopting the latest Argonne National Labs Greenhouse Gas and Regulated Emissions and Energy Use in Transportation (GREET) Model. Supported S. 944 and H.R. 2434, the Next Generation Fuels Act, bills designed to overcome a host of barriers to the use of higher ethanol blends by creating a new high octane fuel standard, limiting aromatics in gas, ensuring all blends of ethanol receive the same RVP treatment as E10, and requiring future vehicles and retail fuel stations to be compatible with higher ethanol blends, among addressing other regulatory impediments to the deployment of higher octane blends. Supported S. 785/H.R. 1608, the Consumer and Fuel Retailer Choice Act of 2022, legislation that clarifies E15 should be allowed for sale year-round by extending the 1-psi Reid vapor pressure (RVP) waiver to fuel blends containing gasoline and over 10 percent ethanol.

Client expense: $64,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Natl Highway Traffic Safety Administration (NHTSA), SENATE

Responded to the Environmental Protection Agency's Science Advisory Board (SAB) workgroup draft commentary letter to Administrator Regan regarding the Renewable Fuel Standard (RFS) Set Rule, countering the biased allegations made by the workgroup concerning the greenhouse gas emissions (GHG) impacts of corn starch ethanol. Sent a letter to President Biden asking him to ensure the EPA promptly finalizes its proposed regulation to eliminate the 1-pound per square inch (psi) Reid vapor pressure (RVP) waiver for gasoline containing 10 percent ethanol (E10) in eight states. Submitted comments to EPA urging them to develop a technology-neutral approach when finalizing tailpipe emission standards for Model Years 2027-2032 light- and medium-duty vehicles to ensure meaningful reductions in greenhouse gas (GHG) emissions are achieved. Supported S. 944 and H.R. 2434, the Next Generation Fuels Act, bills designed to overcome a host of barriers to the use of higher ethanol blends by creating a new high octane fuel standard, limiting aromatics in gas, ensuring all blends of ethanol receive the same RVP treatment as E10, and requiring future vehicles and retail fuel stations to be compatible with higher ethanol blends, among addressing other regulatory impediments to the deployment of higher octane blends. Supported S. 785/H.R. 1608, the Consumer and Fuel Retailer Choice Act of 2022, legislation that clarifies E15 should be allowed for sale year-round by extending the 1-psi Reid vapor pressure (RVP) waiver to fuel blends containing gasoline and over 10 percent ethanol.

Client expense: $150,000 · Firm income: Not reported

Hosted 50 advocates at a Washington, DC fly-in where participants met with members of Congress and the U.S. Department of Agriculture, promoting E15 year-round, technology-neutral clean fuel policy which recognizes farmers and ethanol producers contribution to reduce greenhouse gas (GHG) emissions, the Next Generation Fuels Act, the Farm Bill, ensuring the Renewable Fuel Standard is getting back on track, and implementation of the Inflation Reduction Act. Testified during a virtual public hearing on the Environmental Protection Agencys proposed Renewable Fuel Standard (RFS) rulemaking for 2023 through 2025 compliance years, in support of EPA 1) setting an effective conventional biofuel requirement of 15.25 billion gallons for 2023 through 2025, 2) projecting no small refinery exemptions (SREs) for 2023 through 2025 and reiterating refineries are able to pass on RIN costs to their customers, and 3) conceding its antiquated greenhouse gas (GHG) model needs to be updated. Thanked a bipartisan group of 31 lawmakers who sent a letter to the Environmental Protection Agency (EPA) and Office of Management and Budget (OMB) urging swift and diligent implementation of the outstanding regulatory action to remove the 1-psi volatility waiver for gasoline-ethanol blends in Midwest states, as the 2023 summer driving season quickly approaches. Submitted comments to the Environmental Protection Agencys proposed multi-year Renewable Volume Obligations (RVOs) for the 2023-2025 Renewable Fuel Standard (RFS) compliance years, highlighting areas of support in the proposal, while detailing how to adjust the rule to maximize this significant new phase of the RFS to ensure the overall goal of the program is left intact - to increase the percentage of renewable fuels consumed in the U.S. Submitted written testimony to the Senate Environment and Public Works Committee for their hearing on The Future of Low Carbon Transportation Fuels and Considerations for a National Clean Fuels Program, underscoring the critical role low-carbon biofuels and climate smart agriculture practices can play in ensuring federal clean fuel policy meets transportation decarbonization goals. Testified during a virtual public hearing on the Environmental Protection Agencys proposed rule in response to the requests from Midwest governors to remove the 1-psi volatility waiver for gasoline-ethanol blends containing 10 percent ethanol in their states. EPA is proposing to remove the 1-psi waiver in Illinois, Iowa, Minnesota, Missouri, Nebraska, Ohio, South Dakota, and Wisconsin starting in the summer of 2024. Supported S. 944 and H.R. 2434, the Next Generation Fuels Act, bills designed to overcome a host of barriers to the use of higher ethanol blends by creating a new high octane fuel standard, limiting aromatics in gas, ensuring all blends of ethanol receive the same RVP treatment as E10, and requiring future vehicles and retail fuel stations to be compatible with higher ethanol blends, among addressing other regulatory impediments to the deployment of higher octane blends. Supported S. 785/H.R. 1608, the Consumer and Fuel Retailer Choice Act of 2022, legislation that clarifies E15 should be allowed for sale year-round by extending the 1-psi Reid vapor pressure (RVP) waiver to fuel blends containing gasoline and over 10 percent ethanol.

Testified at a virtual public hearing on the Multi-Pollutant Emissions Standards for Model Years 2027 and Later Light-Duty and Medium-Duty Vehicles proposed by the Environmental Protection Agency (EPA), calling on EPA to give more consideration to ethanol, a lower-carbon and higher-octane alternative, to replace the fossil fuel powering 99 percent of the U.S. vehicle fleet. Submitted feedback to the Environmental Protection Agencys (EPA) proposed rule in response to the requests from eight Midwest governors to remove the 1-psi volatility waiver for gasoline-ethanol blends containing 10 percent ethanol in their states, arguing that EPAs proposal favors refiners and their anticompetitive behavior over consumers, retailers and the environment. Thanked EPA for issuing a national emergency waiver for E15 this summer, a step which will save motorists considerable money at the pump and reduce pollution from vehicles, and called on EPA to implement a permanent remedy to expand consumer access for E15 long-term. Supported S. 944 and H.R. 2434, the Next Generation Fuels Act, bills designed to overcome a host of barriers to the use of higher ethanol blends by creating a new high octane fuel standard, limiting aromatics in gas, ensuring all blends of ethanol receive the same RVP treatment as E10, and requiring future vehicles and retail fuel stations to be compatible with higher ethanol blends, among addressing other regulatory impediments to the deployment of higher octane blends. Supported S. 785/H.R. 1608, the Consumer and Fuel Retailer Choice Act of 2022, legislation that clarifies E15 should be allowed for sale year-round by extending the 1-psi Reid vapor pressure (RVP) waiver to fuel blends containing gasoline and over 10 percent ethanol.

Client expense: $70,000 · Firm income: Not reported

Hosted 50 advocates at a Washington, DC fly-in where participants met with members of Congress and the U.S. Department of Agriculture, promoting E15 year-round, technology-neutral clean fuel policy which recognizes farmers and ethanol producers contribution to reduce greenhouse gas (GHG) emissions, the Next Generation Fuels Act, the Farm Bill, ensuring the Renewable Fuel Standard is getting back on track, and implementation of the Inflation Reduction Act. Testified during a virtual public hearing on the Environmental Protection Agencys proposed Renewable Fuel Standard (RFS) rulemaking for 2023 through 2025 compliance years, in support of EPA 1) setting an effective conventional biofuel requirement of 15.25 billion gallons for 2023 through 2025, 2) projecting no small refinery exemptions (SREs) for 2023 through 2025 and reiterating refineries are able to pass on RIN costs to their customers, and 3) conceding its antiquated greenhouse gas (GHG) model needs to be updated. Thanked a bipartisan group of 31 lawmakers who sent a letter to the Environmental Protection Agency (EPA) and Office of Management and Budget (OMB) urging swift and diligent implementation of the outstanding regulatory action to remove the 1-psi volatility waiver for gasoline-ethanol blends in Midwest states, as the 2023 summer driving season quickly approaches. Submitted comments to the Environmental Protection Agencys proposed multi-year Renewable Volume Obligations (RVOs) for the 2023-2025 Renewable Fuel Standard (RFS) compliance years, highlighting areas of support in the proposal, while detailing how to adjust the rule to maximize this significant new phase of the RFS to ensure the overall goal of the program is left intact - to increase the percentage of renewable fuels consumed in the U.S. Submitted written testimony to the Senate Environment and Public Works Committee for their hearing on The Future of Low Carbon Transportation Fuels and Considerations for a National Clean Fuels Program, underscoring the critical role low-carbon biofuels and climate smart agriculture practices can play in ensuring federal clean fuel policy meets transportation decarbonization goals. Testified during a virtual public hearing on the Environmental Protection Agencys proposed rule in response to the requests from Midwest governors to remove the 1-psi volatility waiver for gasoline-ethanol blends containing 10 percent ethanol in their states. EPA is proposing to remove the 1-psi waiver in Illinois, Iowa, Minnesota, Missouri, Nebraska, Ohio, South Dakota, and Wisconsin starting in the summer of 2024. Supported S. 944 and H.R. 2434, the Next Generation Fuels Act, bills designed to overcome a host of barriers to the use of higher ethanol blends by creating a new high octane fuel standard, limiting aromatics in gas, ensuring all blends of ethanol receive the same RVP treatment as E10, and requiring future vehicles and retail fuel stations to be compatible with higher ethanol blends, among addressing other regulatory impediments to the deployment of higher octane blends. Supported S. 785/H.R. 1608, the Consumer and Fuel Retailer Choice Act of 2022, legislation that clarifies E15 should be allowed for sale year-round by extending the 1-psi Reid vapor pressure (RVP) waiver to fuel blends containing gasoline and over 10 percent ethanol.

Legislation H.R. 2021, the Environmental Justice for All Act H.R. 2434, the Environmental Justice Act of 2021 S.1068/H.R.2193, Asuncion Valdivia Heat Illness and Fatality Prevention Act Draft Legislation, previously the Protect America's Children from Toxic Pesticides Act Draft Legislation, previously Protect Children, Farmers and Farmworkers from Nerve Agent Pesticides Act S.1830, Safe School Meals for Kids Act of 2021 H.R.4079, Save Americas Pollinators Act of 2021 S.984/H.R.2238 Break Free From Plastic Pollution Act S.1019/H.R.2229 The Baby Safe Food Act S. 1973 Filthy Fifty Act S.1970 Clean Water for Military Families Act (PFAS) S. 1976 PFAS Free Military Purchasing Act H.R. 2467 PFAS Action Act H.R. 4241 Filthy Fifty Act S. 1860 Lead-Safe Housing for Kids Act H.R. 4463 PFAS Safe Disposal Act H.R. 4224 PFAS Transparency Act H.R.4694 Food Chemical Reassessment Act of 2021 S. 2792 National Defense Authorization Act for FY2022 H.R. 4350 National Defense Authorization Act for FY2022 Rulemakings Environmental Protection Agency; Agency Information Collection Activities; Proposed Renewal of an Existing Collection and Request for Comment; Agricultural Worker Protection Standard Training, Notification and Recordkeeping; 86 FR 41840; 08/03/2021 Nominations PN407 Michal Ilana Freedhoff, Assistant Administrator for the Office of Chemical Safety and Pollution Prevention, Environmental Protection Agency

Client expense: $179,425 · Firm income: Not reported

Legislation H.R. 2021, the Environmental Justice for All Act H.R. 2434, the Environmental Justice Act of 2021 S.1068/H.R.2193, Asuncion Valdivia Heat Illness and Fatality Prevention Act Draft Legislation, previously the Protect America's Children from Toxic Pesticides Act Draft Legislation, previously Protect Children, Farmers and Farmworkers from Nerve Agent Pesticides Act S.1830, Safe School Meals for Kids Act of 2021 H.R.4079, Save Americas Pollinators Act of 2021 S.984/H.R.2238 Break Free From Plastic Pollution Act S.1019/H.R.2229 The Baby Safe Food Act S. 1973 Filthy Fifty Act S.1970 Clean Water for Military Families Act (PFAS) S. 1976 PFAS Free Military Purchasing Act H.R. 2467 PFAS Action Act H.R. 4241 Filthy Fifty Act S. 1860 Lead-Safe Housing for Kids Act H.R. 4463 PFAS Safe Disposal Act H.R. 4224 PFAS Transparency Act H.R.4694 Food Chemical Reassessment Act of 2021 S.3283, Protect America's Children from Toxic Pesticides Act H.R.4963/S.2669 - Preventing Harmful Exposure to Phthalates Act S. 2792 National Defense Authorization Act for FY2022 H.R. 4350 National Defense Authorization Act for FY2022 Rulemakings Environmental Protection Agency; Agency Information Collection Activities; Proposed Renewal of an Existing Collection and Request for Comment; Agricultural Worker Protection Standard Training, Notification and Recordkeeping; 86 FR 41840; 08/03/2021 Nominations PN407 Michal Ilana Freedhoff, Assistant Administrator for the Office of Chemical Safety and Pollution Prevention, Environmental Protection Agency

Client expense: $188,096 · Firm income: Not reported

Legislation H.R. 2021, the Environmental Justice for All Act H.R. 2434, the Environmental Justice Act of 2021 S.1068/H.R.2193, Asuncion Valdivia Heat Illness and Fatality Prevention Act Draft Legislation, previously the Protect America's Children from Toxic Pesticides Act Draft Legislation, previously Protect Children, Farmers and Farmworkers from Nerve Agent Pesticides Act S.1830, Safe School Meals for Kids Act of 2021 H.R.4079, Save Americas Pollinators Act of 2021 S.984/H.R.2238 Break Free From Plastic Pollution Act S.1019/H.R.2229 The Baby Safe Food Act S. 1973 Filthy Fifty Act S.1970 Clean Water for Military Families Act (PFAS) S. 1976 PFAS Free Military Purchasing Act H.R. 2467 PFAS Action Act H.R. 4241 Filthy Fifty Act S. 1860 Lead-Safe Housing for Kids Act H.R. 4463 PFAS Safe Disposal Act H.R. 4224 PFAS Transparency Act H.R.4694 Food Chemical Reassessment Act of 2021 Rulemakings Environmental Protection Agency; Agency Information Collection Activities; Proposed Renewal of an Existing Collection and Request for Comment; Agricultural Worker Protection Standard Training, Notification and Recordkeeping; 86 FR 41840; 08/03/2021 Nominations PN407 Michal Ilana Freedhoff, Assistant Administrator for the Office of Chemical Safety and Pollution Prevention, Environmental Protection Agency

Client expense: $124,879 · Firm income: Not reported

Legislation H.R. 2021, the Environmental Justice for All Act H.R. 2434, the Environmental Justice Act of 2021 S.1068/H.R.2193, Asuncion Valdivia Heat Illness and Fatality Prevention Act Draft Legislation, previously the Protect America's Children from Toxic Pesticides Act Draft Legislation, previously Protect Children, Farmers and Farmworkers from Nerve Agent Pesticides Act S.1830, Safe School Meals for Kids Act of 2021 H.R.4079, Save Americas Pollinators Act of 2021 S.984/H.R.2238 Break Free From Plastic Pollution Act S.1019/H.R.2229 The Baby Safe Food Act S. 1973 Filthy Fifty Act S.1970 Clean Water for Military Families Act (PFAS) S. 1976 PFAS Free Military Purchasing Act H.R. 2467 PFAS Action Act H.R. 4241 Filthy Fifty Act S. 1860 Lead-Safe Housing for Kids Act Nominations PN407 Michal Ilana Freedhoff, Assistant Administrator for the Office of Chemical Safety and Pollution Prevention, Environmental Protection Agency

Client expense: $192,549 · Firm income: Not reported

Government targets: Energy, Dept of, Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, Interior, Dept of (DOI), SENATE

Legislation H.R. 2021, the Environmental Justice for All Act H.R. 2434, the Environmental Justice Act of 2021 S.1068, Asuncion Valdivia Heat Illness and Fatality Prevention Act Draft Legislation, previously the Protect America's Children from Toxic Pesticides Act Draft Legislation, previously Protect Children, Farmers and Farmworkers from Nerve Agent Pesticides Act

Client expense: $94,596 · Firm income: Not reported

Government targets: Energy, Dept of, Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, Interior, Dept of (DOI), SENATE