The Iowa Renewable Fuels Association (IRFA) has submitted written comments to the California Air Resources Board (CARB) in response to its October 14, 2025, Scoping Workshop regarding the introduction of E15 in California. The comments focus on CARB’s efforts to implement the state’s AB30 legislation, which legalized the sale of E15.
In its submission, the IRFA urged CARB to take a proactive approach to avoid unnecessary delays and to ensure the availability of E15 throughout California. The group argued that E15 could help mitigate the high fuel costs currently burdening California motorists, provided the right regulatory framework is put in place. “E15 can help reverse the increasingly high cost of fuel that has put a financial strain on motorists in California,” the IRFA stated, urging CARB to create a secure and efficient regulatory pathway to make E15 widely accessible.
Key Takeaways from IRFA’s Comments:
Learn from Iowa’s Experience:
The IRFA highlighted that California regulators need not worry about venturing into uncharted territory, as Iowa has more than a decade of experience with E15 and a history of ethanol blends at various levels. “Iowa is happy to share our extensive experience with E15 and ethanol blends,” the association said.
Consumer Savings:
IRFA pointed to Iowa’s success with E15, noting that sales of the fuel are expected to more than double in 2025, reaching nearly 500 million gallons—about 33% of the state’s fuel sales. E15 in Iowa is typically priced 10 to 20 cents lower than E10, making it an attractive option for consumers.
The IRFA also suggested that in California, the price difference could be even greater, with E15 potentially offering savings of 30 to 40 cents per gallon. “California has essentially put a ‘carbon price’ on fuel, and increasing ethanol content by 50% leads to significant carbon reduction. As such, we would expect substantial savings for consumers,” the group noted.
California RFG or Alternative Fuel:
The IRFA recommended that California update its CaRFG (California Reformulated Gasoline) specification to accommodate E15.
Infrastructure Upgrades:
The IRFA emphasized that no infrastructure upgrades at fuel terminals would be needed to accommodate E15 in California. The association pointed out that E15 has been successfully handled at terminals for the past 13 years without issue.
Regarding fuel retailers, the IRFA urged California authorities to follow the example set by Iowa and other states, recognizing that E10 dispensers can safely offer E15.
Potential E15 Impacts:
Given that nearly 95% of California’s vehicle fleet is made up of vehicles from 2001 or newer, the IRFA argued that offering E15 as a lower-cost option makes sense for California drivers.
Misfuelling Concerns:
The IRFA also raised concerns that imposing additional state-level requirements on retailers, beyond the U.S. EPA’s misfuelling regulations, could limit the availability of E15 and increase its cost for consumers.
E15 is Not a Mandate:
Finally, the IRFA reminded CARB that the AB30 legislation does not require any retailer to offer E15 or any motorist to choose it. The law simply establishes a framework that allows retailers to offer E15 if they believe it is a good business decision.
In conclusion, the IRFA called for swift action from CARB to ensure E15 availability in California, citing the fuel’s potential to lower costs for consumers and support the state’s broader environmental goals.
