Our region has much at stake in the debate over RFG, MTBE and ethanol. Seven of our eight states have or are participating in the federal RFG program. The use of RFG in the Northeast has provided substantial reductions in smog forming emissions and has dramatically reduced emissions of benzene and other known human carcinogens found in vehicle exhaust. However, substantial evidence has emerged to suggest that the unique characteristics of MTBE pose an unacceptable risk to our region's potable water supply. Groundwater testing conducted throughout the Northeast has detected low levels of MTBE in roughly fifteen percent of the drinking water tested. Nearly one percent of samples contained MTBE at or near state drinking water standards. MTBE's unpleasant taste and odor at higher concentrations and the frequency of MTBE detections poses a disproportionate and unacceptable threat to our region's drinking water.
The challenge facing us all is to mitigate the environmental and economic harm caused by MTBE contamination without sacrificing the environmental and public health benefits provided by RFG. Adding to this substantive challenge, is the need to address diverse regional interests in promoting a secure and growing market for ethanol and the opportunity to direct much needed support to a broad array of environmentally beneficial transportation fuels and advanced propulsion technologies. Of course, all this must be accomplished without exacerbating already skyrocketing gasoline prices.
Unfortunately, the law as currently written prevents both the U.S. Environmental Protection Agency (EPA) and the states from effectively addressing this challenge. The good news is that a diverse group of interests have come together to promote a set of legislative principles that will protect our air and water quality, ensure substantial growth in ethanol usage, and provide refiners with the flexibility needed to prevent gasoline price spikes or supply shortages. I would like to submit to the record copies of the legislative framework the Northeast states introduced in January of this year and subsequent statements endorsing this framework submitted by the American Lung Association, the Natural Resources Defense Council and the American Petroleum Institute. Since that time, the unprecedented coalition of interests supporting these legislative principles has grown to include several neighboring Mid-Atlantic states and the independent oil refiners Sun Oil Company and TOSCO.
Allow me to first review the legislative approach supported by our unique alliance. I will then directly address how this approach and other scenarios will affect the demand for renewable and environmentally beneficial transportation fuels.
Review of Legislative Framework
I. Repeal or waive the 2 percent oxygen mandate for RFG in the Clean Air Act
It is simply not possible to protect air quality, water quality and ensure gasoline price stability unless the oxygen mandate is lifted or, at a minimum, modified to require EPA to waive this requirement upon state request. Unless the oxygen requirement is lifted or waived, a substantial reduction in MTBE use creates a de facto summertime ethanol mandate. Ethanol usage is far preferable to MTBE from a groundwater perspective and promotion of ethanol can further a host of energy, agricultural, and environmental goals. However, we do not believe that an ethanol mandate in the summertime reformulated gasoline program represents sound environmental or economic policy for the Northeast. Due to its high volatility and the resulting increase in evaporative emissions, the use of ethanol during the summer ozone season may actually exacerbate urban and regional smog problems, absent further statutory or regulatory protections.
The growing outcry over skyrocketing gasoline prices demands that any legislative solution to the MTBE problem be mindful of effects on fuel price and supply. The economic impact of mandating the use of ethanol in the Northeast, California and the Gulf Coast is simply unknown. Setting aside the wisdom of coupling mandates with subsidies, serious questions remain about the cost and environmental impacts of transporting and distributing billions gallons of ethanol to regions of the country where it is not produced. There is no question that it is possible to dramatically increase ethanol production. Similarly there is no question that it is possible to ship massive quantities of ethanol to the Northeast by barge, rail and truck. The question is at what cost. While our region embraces the goal of increasing renewable fuels nationally and sees great promise in the development of a biomass ethanol industry in the Northeast, we are convinced that there are policy approaches to achieve these legitimate ends that are far preferable to mandating the use of ethanol in summertime RFG.
We are surprised and disappointed by legislative efforts to maintain the oxygen mandate and ban MTBE. These efforts seek short-term economic enrichment for one region of the country at the economic and environmental expense of all others. Simply stated, this approach holds no promise to build the consensus necessary to craft effective national legislation. We hope that this Committee will reject such shortsighted efforts to perpetuate the oxygen mandate and instead work toward building a national ethanol market that emphasizes product quality over market protection.
II. Severely curtail or eliminate MTBE use as a fuel additive
We propose a three step approach to reduce, and if necessary, eliminate MTBE from the fuel supply. This approach requires a reduction in MTBE use to historic levels and empowers both EPA and the states to further regulate MTBE while minimizing the potential for a patchwork of varying state requirements that could result in increased fuel prices.
a) Compel EPA to regulate or eliminate MTBE use as a fuel additive if necessary to protect public health' welfare or the environment from air or water pollution.
Neither EPA nor the states, with the notable exception of California, have clear authority under federal law to prevent MTBE from harming drinking water supplies or the environment. EPA's recent efforts to explore existing authority under the Toxic Substances Control Act (TSCA) as a "safety net" in the absence of Congressional action does little to allay our concern over the inadequacy of existing Agency authority. Even a cursory review of the TSCA provisions suggests that its application to the question at hand will be arduous, inelegant and tangled in years of litigation. The Northeast states share EPA's frustration over the inadequacy of our mutual authority. Our inability to address public concern over MTBE contamination is eroding public confidence in the commitment and competence of all levels of government and exaggerates public anxiety over the risks posed by MTBE. While EPA's strained interpretation of TSCA is understandable against this public backdrop, only Congressional action that both authorizes and obligates EPA to reduce MTBE to whatever levels are necessary to protect public health, welfare or the natural environment will provide the protection the public demands and deserves. While our states and alliance partners do not believe that the currently available data supports a statutory ban of MTBE, we agree that EPA must be required to eliminate MTBE as a fuel additive if the Agency concludes through rulemaking that such action is necessary to protect public health, welfare or the environment.
b) Compel EPA to reduce MTBE usage in all gasoline to historic (Pre-1990) levels.
At minimum, within one year from enactment of legislation, EPA must be required to complete a rulemaking that limits MTBE usage in all gasoline to the levels in use prior to the Clean Air Act Amendments of 1990. Data on MTBE contamination prior to the adoption of the oxygen requirements in 1990, suggest that this severe curtailment of MTBE use coupled with the tremendous improvements in underground storage tanks that has occurred since 1990 will effectively mitigate the risks posed by MTBE contamination. However, I must stress that if EPA determines that even this severe curtailment of MTBE usage is not adequate to protect public health, welfare or the environment, the Agency is obligated to further reduce or eliminate MTBE in gasoline all together.
c) Authorize states to regulate MTBE beyond EPA requirements. If EPA fails to act in a timely manner or fails to effectively mitigate the harms posed by MTBE, states must be empowered to further regulate MTBE sold within their borders. In order to balance the need for measured state authority against the desire for maximum consistency in fuel specifications, we propose to adhere to the state petition process found in the current clean air statute. As in current law, state ability to implement independent fuel requirements would remain predicated upon EPA granting a state petition demonstrating the need for such action. Unlike current law which limits the grounds for state petitions to a demonstration that the action is necessary to attain a National Ambient Air Quality Standard (NAAQS), state MTBE petitions would be required to demonstrate that further regulation of MTBE is necessary to protect public health, welfare or the environment.
III. Enhance the RFG performance standards to reflect the stricter of real world RFG phase 1 performance or the existing RFG Phase 2 requirements for VOC, NOx and toxic emissions.
The RFG program has produced dramatic air quality improvements. Reductions in airborne tonics have substantially surpassed the performance standards of both Phase 1 RFG and the more stringent Phase 2 requirements that take effect this year. We believe that a substantial portion of these benefits has been provided by the high volume of oxygenates currently mandated in RFG. As we seek to provide refiners with the flexibility to reduce the use of MTBE, it is necessary to ensure that this flexibility does not result in higher polluting gasoline. For toxic emissions, this approach will require EPA to substantially enhance the RFG toxic performance standard over that currently required in the Phase 2 program. To date, the Northeast and Gulf Coast have achieved far greater air toxic reductions than the Midwest under the RFG program. Hence, we believe that setting enhanced air toxic requirements on a regional basis is the most accurate and equitable approach to ensuring that there is no loss of toxic emission benefits once the oxygen mandate is lifted or waived. This approach ensures that the environmental gains achieved across the country will be protected while acknowledging the circumstances that have resulted in the disparate toxic reductions provided by the RFG program to date. This approach is also consistent with the EPA's historic application of different regional RVP requirements in "northern" and "southern" grade gasoline. Our proposed approach would only apply in those states that opt to waive the oxygen requirement. We fully expect that several states will opt to maintain the oxygen requirement as a further incentive for ethanol use. In these states, there is no risk of air quality "backsliding" resulting from a reduction in oxygenate use and hence these enhanced regional toxic standards would not apply.
a) Maintaining VOC and NOx Benefits The Phase 2 standards that take effect this year are more protective than the actual VOC and NOx reductions achieved under the RFG program to date. Hence, the phase 2 standards would remain in force. By combining the actual toxic emissions performance of Phase 1 RFG with the more protective Phase 2 standards for VOC and NOx, we believe we can equitably and effectively maintain the full air quality benefits provided by the RFG program.
b) Maintaining Carbon Monoxide Benefits While the carbon monoxide (CO) reductions provided by oxygenates have and will continue to diminish as newer technology vehicles enter the national fleet, oxygenates continue to provide important benefits in the few areas of the country that exceed the CO NAAQS. We do not propose any changes to the statutory requirements for oxygenate use affecting CO nonattainment areas. Recent evidence indicates that CO reductions also play a relatively minor but measurable role in ozone reduction. The Northeast states support recognition of these modest and decreasing benefits so long as we count them only once. Since EPA is currently seeking to account for these benefits in a regulation that would provide ethanol blends with a further relaxation of RVP requirements, we do not believe that it is necessary or credible to take account of these same benefits a second time in legislation.
c) PM Emissions- Advocates of the oxygen mandate have suggested that a comprehensive anti- backsliding approach must also include provisions to maintain reductions in particulate matter attributable to oxygenate use. While an ardent advocate of the need to reduce both direct PM emissions and PM emission precursors, NESCAUM does not believe there is adequate scientific evidence to justify addition of a new PM reduction obligation at this time. We urge EPA and academia to conduct the research necessary to build a general scientific consensus around the impact of oxygenates on PM emissions. However, we cannot delay efforts to enhance the environmental performance requirements for toxic emissions while we await the result of future studies. The inadequacy of our understanding of the relationship between oxygenates and PM is evident by the fact that there is currently no requirement for PM reductions in the RFG program. Unlike in the case of VOC, NOx and tonics, where there are existing performance requirements and intricate regulatory compliance regimes already in place, we believe it is premature to include PM reductions in the discussion of air quality backsliding.
IV. Promote consistency in fuel spe fixations through the timely implementation of effective federal requirements
The Northeast states understand and support the need to provide refiners and fuel suppliers with a consistent and coordinated set of regulatory requirements. The most effective means of achieving this consistency is to authorize and require timely action of the part of EPA. Our states are committed to working with other regions and EPA to develop a federal regulation that meets our collective needs.
V. Provide adequate lead time for the petroleum infrastructure to adjust in order to ensure adequate fuel supply and price stability
At present, the gasoline system in the Northeast and much of the nation is dependent upon the presence of high volumes of MTBE. As much as we need immediate action to address MTBE contamination and reinvigorate the RFG program, we recognize that a severe curtailment in MTBE use cannot be completed overnight. Depending on the ultimate extent of required reductions, our states anticipate that two to four years will be necessary to complete the phase down or elimination of MTBE in the Northeast. We are committed to working with our partners in the federal government and the refining industry to ensure that fuel quality, supply and price are protected as we reduce our current dependence on MTBE.
Impact on Renewable Fuel Use
As stated earlier, implementation of legislation based on these principles will result in a substantial increase in ethanol use over the coming decade. The severe curtailment and/or elimination of MTBE as a fuel additive coupled with maintenance of the mass toxic benefits achieved in Phase I RFG will force refiners to substantially increase their current use of ethanol. Key among the market factors leading to this increased demand is the need to replace the loss of octane in the fuel supply without increasing air toxic emissions. While experts vary on the exact magnitude of growth in ethanol demand, every analysis we have seen agrees that the competitive future for ethanol is very bright. The Exhibit 1 illustrates our best assessment of the growth in ethanol as a fuel additive if states are given the authority to lift the oxygen mandate and MTBE is phased down to pre 1990 levels. If MTBE is further reduced or eliminated, the growth of ethanol will be even greater. This projection reflects analysis conducted by NESCAUM, API and ALA using data generated by the USDOE, the USDA, and two leading consulting firms, MathPro and Downstream Alternatives. The more conservative estimate, assumes that the ethanol needed to satisfy PADD 1 and PADD 3 demand is met by pulling existing ethanol out of the Midwest markets, leaving national ethanol demand outside of California unchanged. It adds to this static 49-state assumption, the growth that would occur in the California market provided by MathPro's analysis conducted for the California Energy Commission.\1\ The MathPro study indicates that 40 to 60 percent of California gasoline would be blended with ethanol at 2.7 weight percent resulting in nearly one billion gallons of new ethanol demand annually. The assumption that all ethanol demand outside of California will be satisfied by shifting ethanol out of Midwest markets is an unreasonably conservative projection of the impact of our legislative approach. First, it assumes no additional policies are adopted by Midwest states to promote or require ethanol use and second it assumes that Midwest states opt to waive the oxygen standard. The alternative scenario that projects ethanol use more than doubling over the next decade was derived by combining the same MathPro analysis for California with the DOE estimate for ethanol growth in the Northeast\2\. As you can see, this analysis projects that ethanol use will fully double by 2004 growing from 1.5 to over 3 billion gallons per year.
\1\ Analysis of California Phase 3 RFG Standards, Submitted to the California Energy Commission by MathPro Inc., Subcontract No. LB60 100, December 7, 1999.
\2\ Estimating Refining Impacts of Revised Oxygenate Requirements for Gasoline, Oak Ridge National Laboratory, Studies for the U.S. DOE Office of Policy May-August 1999.
In order to promote a truly secure future for ETOH, it is time to shift our collective emphasis away from efforts at further market protection and toward to a rejuvenated focus on product quality. While mandates provide a level of absolute security that is never possible in a free market, this security comes at a considerable cost to the ethanol industry. Mandates undermine the public's confidence in the quality of ethanol as a motor fuel. As we have heard from a diverse number of government and private sector experts today, ethanol presents a host of compelling domestic economic and environmental benefits. The imposition of a sales quota, contradicts these expert sentiments by embracing the intuitive contradiction that ethanol is so good for the country that it cannot compete. I firmly believe that the renewable fuels market will never achieve its full market potential so long as that market is understood to depend on political power and not product quality. Moreover, markets that appear contingent upon politics will constantly face the insecurity of political change. Product quality will forever remain the only true security in a democratic nation with a free market economy.
As an advocate of a set of policies that are projected to more than double ethanol use within four years of enactment, I proudly embrace the label of ethanol advocate. At the same time, I recognize that ethanol like all products presents benefits and liabilities. Regardless of whether ethanol use flourishes under a free market or national sales quota, there are a host of economic and environmental considerations that must be accounted for as ethanol use expands.
Key Environmental Considerations from expanded ethanol use
Air Quality
Without further statutory or regulatory protections, the widespread use of gasoline containing ethanol will increase evaporative emissions of VOCs due to it high volatility characteristics. The obvious first step to address this problem is to remove the 1 lb. RVP waiver for conventional gasoline containing ethanol. Increased evaporative emissions have a deleterious impact on ambient levels of ozone and increase emissions of toxic pollutants such as benzene. Also of concern is the so-called "co-mingling" effect. When ethanol blends mix with non-ethanol blends they increase the volatility of the entire volume of fuel. Consequently, even if the ethanol fuel itself complies with RVP limits, its presence in a diverse fuels market will have consequences whenever a vehicle that has recently been fueled with an ethanol blend is re-fueled with an ethanol free gasoline.
The combustion of ethanol-blended gasoline results in a 50 to 70 percent increase in acetaldehyde emissions compared to MTBE blends. Ambient levels of this pollutant currently exceed health-based standards by a substantial amount in many areas in the Northeast. Increased ethanol use is also likely to cause some increase in NOx emissions in the Northeast. There are direct and indirect components to this anticipated NOx increase. Some engines have been shown to directly emit increased levels of NOx when burning fuel containing ethanol. In addition, the fact that ethanol blends cannot be shipped through gasoline pipelines will create indirect but potentially substantial increases in NOx and particulate emissions from the diesel truck, rail and barges used to move hundreds of millions of gallons of product from Midwest production facilities to markets in the Northeast.
Groundwater
There is broad agreement that the potential groundwater impacts of gasoline blended with ethanol are far less significant than those associated with MTBE blends. Nevertheless, the presence of ethanol in gasoline raises some concern with regard to groundwater contamination. In short, there is evidence to suggest that the microbes that biodegrade benzene, toluene and other volatile organic compounds are preferentially attracted to ethanol. The good news is that ethanol is quickly biodegraded when present in groundwater. The bad news is that the bacteria fails to degrade benzene and the other VOCs present in gasoline plumes until the ethanol is consumed. Hence, BTEX compounds are predicted to persist longer in groundwater when gasoline mixtures containing ethanol are leaked or spilled. Evidence presented to the Blue Ribbon Panel suggests that this effect, while not insubstantial, pales in comparison to the groundwater threat posed by MTBE.
Key Economic Considerations from Expanded Ethanol use
Transportation and Distribution
As stated above, gasoline blends with ethanol cannot be transported via existing pipelines due to ethanol's affinity for water. Consequently, unless dedicated ethanol pipeline capacity emerges, the widespread use of ethanol in the Northeast will require transporting hundreds of millions of gallons of ethanol by rail, truck or barge. New storage tank capacity and blending facilities will also be needed in our region to accommodate increased demand. While there are broad differences of opinion about the magnitude of this logistical challenge, it is imprudent to support a market mandate that would require the Northeast to use disproportionate amounts of ethanol compared to the rest of the nation until these logistical impediments and their associated economic and environmental impacts are better understood.
Gasoline Cost Impacts
Detailed studies by the U.S. Department of Energy and the California Energy Commission suggest that any major shift from MTBE to ethanol should be phased in over three to four years to avoid dramatic price spikes or fuel shortages.
The Northeast states do not support a waiver of the Reid vapor pressure (RVP) requirements to accommodate the increased volatility of gasoline blended with ethanol. In order to meet the existing volatility requirements, the base gasoline into which both conventional and reformulated gasoline must be more severely refined. While opinions differ on the costs of this additional refining, they will not be insubstantial when incurred across the national fuel market.
Ethanol Subsidies
The fact that ethanol receives a 54cent per gallon subsidy -- in the form of a partial exemption from the federal fuel excise tax and an income tax credit -- has important l implications for the Highway Trust Fund in the Northeast. Currently, this subsidy reduces the nation's Highway Trust Fund by approximately $870 million dollars annually. A doubling or tripling of ethanol use in gasoline will have the effect of further reducing highway revenue by a substantial amount. While we are not seeking to address the validity of the ethanol subsidy if market conditions are allowed to determine future ethanol growth, an evaluation of ethanol tax policy is surely warranted if we impose a national ethanol sales mandate.
Renewable Fuels Standard
Many, though not all, of these concerns are mitigated if ethanol is used at the right time and in the right places. Not surprisingly, approaches that enable the market to determine how and where ethanol is used go long way toward encouraging the most economical and environmentally beneficial uses of ethanol. To the contrary, the constraints of a de facto summertime ethanol mandate in RFG legislative efforts to reinforce this outcome provide the worst possible environmental and economic scenario for a growing ethanol industry. Under this nonsensical approach, the national interest in promoting renewable fuels is imposed on regions of the country farthest away for the source of ethanol production at the one time of the year when ethanol's volatility leads to considerable public health concerns.
Compared against this looming disaster in national policy, our region has previously expressed interest in the concept of a Renewable Fuels Standard (RFS) approach. While we maintain a principled apprehension about the imposition of an overarching sales quota for the reasons stated above, the RFS takes a strong step toward free market principles by enabling economic and environmental considerations to influence when and where ethanol is sold. Moreover, an RFS legitimately emphasizes the national security, agricultural, and global environmental benefits that are furthered by an increased use in ethanol. The logic of these interests provides a far more compelling rational than the pretense that ethanol is necessary to protect urban air quality. Efforts to perpetuate the oxygen mandate must justify this position on the basis of ethanol's ability to improve summertime urban air quality which is on one of the weakest rationales for growth in ethanol use.
In July of last year, Senator Daschle wrote to NESCAUM and the region's Governors seeking to explain his support for replacing the oxygen mandate with a 2.1% RFS and seeking Northeast state input. I would like to submit to the record copies of my response as well as the responses from Governor Shaheen from New Hampshire and Governor King from Maine. While all three responses expressed apprehension regarding many of the issues outlined above, each letter expressed the belief that the flexibility provided by a properly designed RFS would better respond to our stated concerns about ethanol than Congressional inaction. Key to the proper design of an RFS, is the ability of refiners to avail themselves of market-based approaches to meet their ethanol sales quota. By enabling refiners to average internally and with other fuel suppliers to meet their annual renewable content minimums, we believe that ethanol will be used where it is cost-effective to do so. We simply don't know whether it will be cost effective to transport and distribute ethanol produced in the Midwest throughout the Northeast market. Unlike the oxygen mandate that would force refiners to sell a disproportionate amount of ethanol volume in Northeast regardless of economic considerations, a properly designed RFS enables refiners to sell ethanol where it makes economic sense.
From both an environmental and economic standpoint, a properly designed RFS must also enable refiners to use ethanol if and when it makes sense to do so. The version of the RFS that was provided for our review last year allowed refiners to comply on an annual average basis. This flexibility is critical to ensure that ethanol is only used sparingly in cities that suffer from summertime ozone nonattainment. I am concerned that the more recent incarnations of the RFS seek to impose a quarterly averaging regime. Requiring one-quarter of our national ethanol use to occur during the summer months is unsound environmentally and will lead to increased fuel prices since refiners will be required to reduce to overall volatility of their blendstock to accommodate ethanol within allowable RVP limits. While I recognize that small ethanol producers do not presently maintain the tank capacity to store ethanol produced during the summer season, expanding this tank capacity seems far preferable than forcing the sale of ethanol in the summer months.
Of course the most important feature of a properly designed RFS is the magnitude of sales requirement itself. When Governor Shaheen stated that, "a renewables fuel requirement-- accompanied by elimination of the federal oxygenate mandate-- holds great promise and represents a wise precedent for the nation to establish,\3\ she was evaluating a 2.1 percent RFS that was understood to represent a doubling of ethanol production over the next ten years. We now understand Senator Daschle's approach to contemplate more than tripling ethanol use in this same time period. This contemplated increase from a statutory doubling to a tripling of ethanol under an RFS will greatly increase opposition to the RFS in our region.
\3\ Letter for Governor Jeanne Shaheen to Senator Tom Daschle, September 16, 1999
While it is awkward to offer suggestions on how to design a sales quota that on balance we deem unnecessary, one thing that I have learned from this debate is that those who can't imagine creative compromises are quickly left behind. If we are going consider adoption of policies that encourage ethanol use, these policies should be optimized to encourage entrepreneurial innovation and growth among small businesses and farmers and seek to remedy market barriers and the failure of financial markets effectively internalize the full social costs and benefits of different actions. Toward this end, we wish to applaud Senator Daschle and Senator Lugar's recognition of the additive environmental and potential economic attributes of biomass ethanol in fashioning a differential credit for biomass in their current RFS proposal.
Obviously, the opportunity to cure "market failures: through quotas and mandates can be quite seductive. Hence, before I abandon this creative flourish, I also suggest that RFS supporters consider broadening the universe of fuels that could count towards RFS compliance to include fuels that enable extremely low emission performance. The Northeast states have long advocated for policies that reward advanced transportation technologies like electric and hybrid electric vehicles, compressed natural gas in urban bus fleets and ultimately fuel cell technologies. These technologies promote many of the same national security and fuel diversification goals that we understand form the substantive foundation of the RFS. Moreover, those technologies that rely on electric drive trains achieve far greater reductions in air pollution emissions than internal combustion engines regardless of the volume percentage of renewable fuels. We as a nation have failed woefully to achieve the laudable Energy Policy Act goal of diminishing our reliance on petroleum transportation fuels by 10 percent this year. If we are truly committed to decreasing our reliance on foreign petroleum, it seems worth contemplating a flexible national approach that will inspire the ingenuity and creativity that our nation has to offer.
Conclusion
In conclusion, let me stress that the preferred approach of the Northeast states is to: (1) lift the oxygen mandate; (2) severely curtail and if necessary eliminate MTBE; (3) maintain the VOC, NOx, and toxic emission benefits, and (4) allow ethanol to grow on the basis of its legitimate and considerable attributes. I am pleased to learn that many of the strongest traditional advocates of a growing ethanol industry recognize that it is possible to support ethanol while opposing ethanol mandates. I would like to submit a set of six editorials from newspapers in Nebraska and Iowa commenting on state efforts to mandate the use of ethanol over the last year. The headlines demonstrate that our interest in promoting ethanol on the basis of product quality is shared by many of our Midwest neighbors:
-- From the Des Moines Sundav Register, September 19, 1999 - "Let ethanol prove itself: Iowa farmers need help, but coercion at the gas pump is wrong,"
-- From the Ouad Citv Times, September 19, 1999, "Ethanol-only proposal doesn't help consumers,
-- From the Omaha World Herald, March 9, 2000 - "More Alcohol, Less Choice
Obviously, we are troubled that having failed to impose ethanol mandates in their own states, several prominent Midwest officials now seek Congressional action to impose ethanol mandates on the Northeast. Still, I remain optimistic that by emphasizing market principles in the effort to promote the use of renewable and clean fuels we can fashion a workable solution to the legislative challenges that lie ahead. Thank you for the opportunity to appear before the Committee. I welcome the opportunity to respond to any questions you may have.