Flex-Fuel Vehicles and Ethanol No Panacea for Energy Independence

Back in September, I posted a rebuttal to pollster Frank Luntz, who advised President Trump on Laura Ingraham’s Fox News program to promote E85—motor fuel blended with 51-83 percent ethanol. Luntz claimed that by stumping for E85 and flex-fuel vehicles, Trump could make America “energy independent” by election day 2020 while giving Republicans a “real solution” to climate change without the “craziness” of Green New Deal. I suggested Luntz was hawking corporate welfare for corn farmers.

That drew the ire of ethanol enthusiast Marc J. Rauch, who posted a long response on the car review website of which he is the co-publisher. Normally I would not respond to content, like Rauch’s, which is regrettably littered with juvenile vocabulary and ad hominem attacks, but I think his specific claims about the ostensible advantages of ethanol-based fuels should be factually examined.

Would an E85 Campaign Enhance U.S. Energy Security?

Rauch purports to correct the “garbage” and “lies” I wrote about ethanol. He states:

Marlo, you write: “…because the market for petroleum is global, with multiple alternative routes of delivery, dependence on oil imports has never been a bona fide national security threat.” And in your editorial, you link this statement to another outstanding example of a stink tank (Cato Institute) for verification of your odoriferous statement.

My disparaging comment about oil import alarmism is accurate. The so-called oil weapon was never the lethal threat OPEC propaganda made it out to be. Petro states need to sell their oil to someone or they go broke, and petroleum is a global market with multiple buyers and sellers. Even if OPEC decided to stop selling us oil, we could still purchase crude from other sellers. As the Cato Institute study dissed by Rauch explains:

The 1973 Arab oil embargo is a perfect case in point. U.S. crude oil imports actually increased from 1.7 million barrels per day (mbd) in 1971 to 2.2 mbd in 1972, 3.2 mbd in 1973, and 3.5 mbd in 1974. Instead of buying from Arab members of OPEC, the United States bought from non-Arab oil producers. The customers that were displaced by the United States bought from Arab members of OPEC. Beyond the modest increase in transportation costs that followed from this game of musical chairs, the embargo had no impact on the United States.

What quadrupled oil prices during October-December 1973 was not the embargo but a series of OPEC decisions to cut crude oil production. Moreover, what caused shortages and gas lines in 1974 was not the OPEC production cuts but the U.S. government’s imposition of regulatory controls on petroleum product prices and allocation.  

In any case, my blog post devoted just two sentences to energy security. Rauch quotes from the first sentence (above) but keeps mum about the second:

And with America leading the world in crude oil production, imports accounting for just 11 percent of U.S. consumption, and friendly democratic Canada providing 43 percent of our oil imports compared to just 9 percent from Saudi Arabia, ramping up ethanol production would provide no discernible “energy security” benefit.   

To Rauch, however, every incremental contribution of ethanol towards “energy independence” is a big deal. He declares:

Frank Luntz was correct when he said that an E85 mandate would make America energy independent by election time November 2020. Actually, we wouldn’t even need an E85 mandate, an E30 or E40 mandate would probably be more than enough, and it would probably make us energy independent by early 2020.

I will go them one better. We don’t need any new mandates and don’t have to wait until 2020. “Based on preliminary data and model estimates, EIA estimates that the United States exported 140,000 b/d more total crude oil and petroleum products in September than it imported; total exports exceeded imports by 550,000 b/d in October,” the U.S. Energy Information Administration reports in its November 2019 Short-Term Energy Outlook. Assuming no changes in policy, “EIA expects total crude oil and petroleum net exports to average 750,000 b/d in 2020 compared with average net imports of 520,000 b/d in 2019.”

Since the 1973 Arab-Israeli War, the main oil-related energy security threat has been price shocks. As Bloomberg recently noted, every economic downturn since the 1970s was preceded by a doubling of oil prices. Price volatility is not a function of import dependence. Because oil is traded in global markets, every country faces similar crude oil prices regardless of how much or little of its consumption comes from imports.

Accordingly, the key to U.S. energy security today is what President Trump calls U.S. energy dominance—a domestic industry so productive it can stabilize global supplies and calm market jitters when regional conflicts, natural disasters, or cartel machinations depress foreign output. It is largely thanks to the productivity of U.S. frackers that gasoline prices fell in 2015 despite ongoing warfare in the Middle East, UN sanctions that cut Iran’s oil exports nearly in half, Russia’s invasion of Crimea, and continuing conflict in Ukraine.

Fracking continues to produce energy security dividends. On September 14, 2019, 25 drones and cruise missiles bombed two major Saudi oil installations, knocking out 50 percent of Saudi and 5 percent of global oil production. Oil prices jumped 20 percent—but for less than a single day. By September 30th, prices returned to pre-attack levels. The impact on the U.S. economy was minuscule and fleeting.

Is an E85 Campaign Smart Politics?

Rauch scorned my political assessment of Luntz’s proposal:

You say that environmental groups are not fans of ethanol. If you mean those groups who are funded by oil industry entities, you’re correct. If you mean the entities that were created by oil industry PR firms and have names that make them sound like they are environmentally conscious, you’re correct.

The most prominent environmentalist critics of corn ethanol are Friends of the Earth, Environmental Working Group, National Wildlife Federation, and Sierra Club. Is Rauch prepared to state on the record that oil industry PR firms created those groups, or that, contrary to the groups’ corporate donation policies, FOE President Erich Pica, EWG President Ken Cook, NWF President Collin O’Mara, and Sierra Club President Loren Blackford are shills for Big Oil? If he doesn’t mean those organizations, which does he mean? Accusations hurled at unnamed entities and individuals cannot be tested and have zero credibility.

Rauch accuses me of self-contradiction because “you spent the better part of two decades arguing with environmental groups over catastrophic man-made climate change” but now “you want to use them to promote lies about ethanol.” He concludes: “You can’t talk out of both sides of your mouth. You’ll need to pick one position.”   

So, according to Rauch, to be consistent, I must either accept or reject everything environmentalists say. That is silly. Like most people, environmentalists may be wrong about some things (e.g., climate models are accurate—false!) but right about others (e.g., Renewable Fuel Standard-induced corn crop expansion promotes aquatic dead zones and habitat loss—true!).

Besides, I was not citing environmental groups as scientific experts but as political arbiters of climate policy for “progressive” voters. Many environmental groups oppose the Renewable Fuel Standard as faux climate policy. Thus, an E85 campaign would entice few left-leaning millennials and suburban housewives to support Trump.

Does E85 Deliver Superior Fuel Economy?

Rauch excoriates my argument that E85 is a political loser because its lower energy density and inferior fuel economy make it a market loser. My post on Luntz screen-captured a portion of the Environmental Protection Agency/Department of Energy website, fueleconomy.gov, showing annual fuel expenditure estimates for five flex-fuel vehicles. In each case, the typical flex-fuel vehicle owner would spend $500 more per year to fill up with E85 instead of regular gasoline.

Visiting the site again on September 18th, I noticed that for larger flex-fuel vehicles, the annual E85 fuel expenditure penalty is $550.

Rauch scorns such estimates as “purely theoretical . . . calculated only by mathematical equation; no one actually test drove these vehicles with the two fuels.”

Granted, the agencies do not test drive each vehicle. Fueleconomy.gov estimates annual fuel expenditures for literally hundreds of different models, and must do so in a timely manner. It would be impractical to hire professional drivers to take road trips for each new model on the same routes under similar traffic conditions and tote up fuel expenses. The agencies also use math. However, that does not mean the results are “purely theoretical.” To estimate fuel economy, manufacturers and the EPA run the vehicles “under controlled conditions in a laboratory using a series of tests specified by federal law,” fueleconomy.gov explains. The testers use machines called dynamometers to simulate driving under stop-and-go rush hour conditions and rural/highway conditions.

As the agencies’ Model Year 2019 Fuel Economy Guide states, “Estimates for all vehicles are based on laboratory testing under standardized conditions to allow for fair comparisons.” It further notes: “FFVs [flex-fuel vehicles] typically experience a 15 percent–30 percent drop in fuel economy when operating on E85 instead of regular gasoline due to ethanol’s lower energy content and other factors, assuming gasoline typically contains about 10 percent ethanol.”

I asked fueleconomy.gov to explain the methodology behind their fuel expenditure estimates in the figure above. They replied:

The annual fuel cost estimates are by default, based on the EPA Combined fuel economy of the vehicle and assumes 15,000 annual miles. For the fuel price, the price for gasoline and diesel is a national average price that comes from the EIA and is updated weekly: www.eia.gov/petroleum/gasdiesel.

The fuel price for E85 comes from the Department of Energy’s Alternative Fuels Data Center Alternative Fuels Price Report which comes out quarterly: afdc.energy.gov/fuels/prices.html.

All fuel costs are rounded to the nearest $50.

To work through one of your examples see the math below the following screen capture:

The 2020 Chevrolet Tahoe C1500 2WD 5.3L, 8 Cylinder, Automatic 6-spd has a combined fuel economy of 18 MPG Combined for Regular gasoline and 13 MPG for E85.

For Regular Gasoline, the annual fuel cost works out as follows: 15,000 miles/18 MPG = 833 gallons of Regular Gasoline. The current default price for Regular is $2.55 per gallon. 833 gallons of Regular at $2.55 = $2,124 rounded to the nearest $50 = $2,100

For E85, the annual fuel cost works out as follows: 15,000 miles/13 MPG = 1,154 gallons of E85. The current default price for E85 is $2.31 per gallon. So, 1,154 gallons of E85 at $2.31 per gallon = $2,666 rounded to the nearest $50 = $2,650

I ran those numbers by the good folks at edmunds.com. I reminded them that in 2009, Edmunds conducted an actual road test comparing E85 and regular gasoline. Edmunds drove a 2007 Chevrolet Tahoe LT flex-fuel vehicle from San Diego to Las Vegas and back on regular gasoline, then repeated the journey the next day on E85. The average pump price of gasoline was $3.42 per gallon; that of E85 was $3.09 per gallon.

On gasoline, the round trip used 36.5 gallons of regular gas, achieved an average fuel economy of 18.3 mpg, and cost $124.66. On E85, the round trip used 50 gallons, achieved an average fuel economy of 13.5 mpg, and cost $154.29. Bottom line: “The fuel economy of our Tahoe on E85 under these conditions was 26.5 percent worse than it was on gas.”

Edmunds opined that the same test conducted today would have similar results:

In the article from 2009 we list the average price paid for regular gas at $3.42 a gallon and the average price paid for E85 was $3.09 a gallon. I found a website named E85prices.com, where users can list the price they paid for E85. I found a listing from yesterday [September 17th] out of Oceanside CA, the user lists E85 at $2.79 a gallon and regular fuel at $3.39 a gallon (regular fuel being almost identically priced the same as it was 10 years ago). For the sake of quick math, the E85 is priced about 10 percent less than it was ten years ago, so if the trip were done today it would cost about $27 more than gas.

On the accuracy of the estimates posted on fueleconomy.gov, Edmunds commented:

I believe the notion that it would cost an additional $550 in annual fuel expenses to be spot on. The total distance from San Diego to Las Vegas and back is 662 miles according to Google maps. The average driver in the U.S. drives 13,476 miles a year. 13,476/662 = 20.35—meaning you could do the SD to Las Vegas run 20.35 times, each time costing an additional $27 dollars more than if the driver used regular fuel. If we multiply 20.35 by $27, the total is $549.45.

Rauch faults me for comparing E85 to E10 (gasoline containing 10 percent ethanol) rather than to E0. If I compared E85 to ethanol-free gas, then it would be clear that E85 “provides much better fuel economy.” He explains:

The average U.S. cost of E0 is $2.88 cents. The average U.S. cost of E85 is $2.15. That’s a saving of 25 percent. If the vehicle got 10 percent fewer miles with E85, it’s a net gain for the consumer. If the vehicle got 15 percent fewer miles, it’s a net gain for the consumer. The same is true at any point up to 25 percent fewer miles, where the fuel economy of E85 would be even with E0.

Comparing E85 to E0 prices is a red herring. Less than nine percent of U.S. service stations (about 14,296 out of 168,000) carry E0. More than 98 percent of U.S. motor fuel contains ethanol, so less than 2 percent is E0, and a substantial fraction of that is consumed by recreational boats, motorcycles, and other small engines. Thus, the relevant fuel expenditure comparison is between E85 and E10 because the latter is what nearly all U.S. motorists put in their tanks.

Moreover, E0 prices cannot legitimately be used to justify increasing the ethanol mandate because the mandate is a factor inflating E0 prices. Refiners’ ever-increasing “renewable volume obligations” (RVOs) squeeze E0 out of the market, turning it into a pricy specialty fuel.

Rauch also argues that gasoline’s higher energy density should be depreciated by 25 percent due to energy losses from inefficient combustion. Citing chemist W.J. Hale’s book Prosperity Beckons: Dawn of the Alcohol Era, published in 1936, Rauch explains:

In his book, Dr. Hale writes that the inefficiency of burning gasoline in a gasoline-optimized internal combustion engine loses 25 percent of its energy value, whereas alcohol (ethanol) “enters into complete combustion” in the engine. Therefore, instead of comparing gasoline’s 116,000 BTUs to ethanol’s 76,000 BTUs (and advancing the idea that ethanol has 33 percent less energy than gasoline, as the oil industry lays out their story), you should deduct one-fourth of the gasoline BTUs. This the makes the comparison 87,000 BTUs for gasoline versus 76,000 for ethanol, presumably giving ethanol 12 percent less BTUs, not 33 percent less. “Thus,” Hale writes, “the custom of comparing fuels on their potentially available British Thermal Units becomes at once obsolete.”

I do not know whether Hale’s estimate was correct in 1936, but it is not accurate now. Although ethanol combusts more completely than gasoline, the impact on fuel economy is minor. Most of the energy in your tank—anywhere from 70 percent to 88 percent—is “lost to engine and driveline inefficiencies or used to power accessories,” according to fueleconomy.gov. Combustion inefficiency accounts for only about 3 percent of conventional engine energy losses, not 25 percent.

MIT Professor John B. Heywood’s authoritative text, Internal Combustion Fundamentals, corroborates DOE and EPA’s estimate: “For spark-ignition engines, for lean equivalence ratios, the combustion efficiency is usually in the range 95 to 98 percent” (p. 82). In other words, inefficiency due to incomplete combustion is in the range of 2-5 percent.

Does Vehicle-Fuel Co-Optimization Make Energy Content “Completely Irrelevant”?

Rauch claims ethanol’s lower energy content is “completely irrelevant” because “engines can easily be fully optimized to run on E85 and higher.” Well, if energy content were “completely irrelevant,” we would never have to refuel when the tank is empty.

Presumably, Rauch means the following. Ethanol is the cheapest high-octane fuel on the market. Octane is a measure of how much compression the air-fuel mixture in a cylinder can withstand before spontaneously combusting. Such premature detonation or “knocking” impairs efficiency and increases engine wear. When blended with gasoline, ethanol allows engines to operate with higher compression, which makes them more efficient in converting energy into work. Increase efficiency enough, and it can more than offset ethanol’s lower energy content. True enough. However, that is not the argument Luntz was making, hence it is not what I was rebutting.

Luntz was pushing a combination of E85 and flex fuel vehicles. Can engines be “fully optimized to run on E85,” as Rauch claims? Yes, but darn few are and you won’t find one in the showroom. There are some 20 million flex fuel vehicles on the road today. Nearly all are optimized to run on E10. Why? Because the whole point of a flex fuel vehicle is to be flexible—to run on any fuel mixture from E0 to E85. Running a high-compression engine on low-octane E10 would produce knocking, poor fuel economy, and, eventually, engine damage. Only about two percent—4,000 out of 168,000—of U.S. retail motor fuel stations sell E85. If a flex-fuel vehicle were optimized to run on E85, it would no longer flex. The owner’s travel options would be severely limited.

Rauch states that today’s vehicles can be converted into flex-fuel vehicles just by adjusting the software used in on-board computers. The conversion “wouldn’t cost auto manufacturers (and consumers) anything,” he claims. Amazon sells an E85 conversion kit (D Bosch EV1) for $135.00. Judging from the sole review (five stars), installation is probably something the average motorist would pay a garage mechanic to do. So, unless you’re a do-it-yourselfer, E85 conversion costs about $200.00. Not an arm and a leg, but not nothing, either.

More importantly, the cost of flex-fuel conversion is another red herring because the relevant issue is the cost and ease of converting a lower- to a higher-compression engine. That requires either boring out the cylinder walls to increase the volume of air-fuel mixture available for compression, or replacing the crank shafts with longer shafts to increase the length of piston stroke. Such modifications can cost thousands of dollars and void warranties. The typical customer for such modifications is not a commuter or soccer mom but an enthusiast with a vintage hot rod or muscle car well past its warranty.

Ignoring Regulatory Context

Rauch ignores the regulatory context of policymakers’ recent interest in co-optimization, namely, the imposition of two federal mandates that increasingly work at cross purposes. The Corporate Average Fuel Economy (CAFE) program compels automakers to continually boost the fuel economy of vehicles they sell. At the same time, the Renewable Fuel Standard (RFS) program compels refiners to sell increasing volumes of ethanol, which, as discussed above, tends to decrease fuel economy.

Far from being “completely irrelevant,” the ethanol energy deficit was a key impetus for creating the Department of Energy’s Co-Optimization of Fuels and Engines (Co-Optima) Initiative. Co-Optima “brings together top scientists, engineers, and analysts from nine national laboratories with more than 20 university and industry partners across the country to investigate fuels and engines as dynamic design variables that can work together to boost efficiency and performance, while minimizing emissions.”

There is a voluminous literature on co-optimization, and the House Energy and Commerce Committee held three hearings on the subject during the 115th Congress. The overarching aim was to determine whether automakers, refiners, renewable fuel producers, retail fuel distributers, and U.S. party leaders could all agree to establish uniform (national) high-octane performance standards that would increase ethanol sales while enhancing fuel economy.  

Three things immediately become clear from this literature. First, discussion and debate centers around octane standards achievable through mid-level ethanol blends, such as E20-E40. None of the stakeholders, not even the renewable fuel interests, proposed octane levels requiring the use high ethanol blends (e.g. E51-E83).

That is hardly surprising. In 2018, Americans consumed about 143 billion gallons of gasoline, of which roughly 15 billion gallons, or 10.5 percent, is ethanol. Producing that 15 billion gallons consumed 38 percent of the total U.S. corn crop. Meeting even a ‘mild’ E85 mandate—a 51 percent renewable volume obligation—would require that more than all current U.S. corn acreage be dedicated to ethanol manufacture. To also meet domestic and global demand for corn as a food product, U.S. farmers would have to plow tens of millions of additional acres. The loss of wildlife habitat could be huge. Moreover, grain prices would increase, at least until markets fully adjust to the massive exogenous increase in demand, especially if the U.S. corn belt experiences another severe drought like that which occurred in 2012.

Second, although automakers were prepared to produce vehicles optimized to run on high-octane fuels, they expressed no interest in producing more flex fuel vehicles, which, as noted above, are typically optimized to run on E10. I say “were,” because some automakers now seem more interested in electrifying their fleets while others apparently have less need for a high-octane alternative to electrification due to the Trump administration’s relaxation of fuel economy standards.

Third, as discussed in more detail below, achieving major market penetration of high-octane fuels for use in high-compression engines would take many years and cost tens of billions of dollars. Contrary to Luntz and Rauch, President Trump could not achieve some kind of great leap forward, in either energy security or consumer savings, by stumping for ethanol between now and election day.

No Quick Fix

The Fuel Institute’s February 2019 report, Transitioning the U.S. Gasoline Pool to a Single High-Octane Fuel: A Baseline Analysis, is the most comprehensive assessment available of the prospects for achieving a high octane fuel marketplace. Here are some of the report’s findings.

Transitioning to a high octane fuel marketplace would require several federal rulemakings and perhaps new legislation as well. The history of prior fuel transitions, such as the shift to lead-free gasoline, low-sulfur fuels, and E10, suggests that implementing new octane requirements would require “coordinated actions by each sector involved: vehicle manufacturer, refining (and ethanol supply), distribution system, and retailing.”

Moreover, federal policymakers would have to impose a 50-state standard, because automakers don’t want to produce new vehicles that require fuels unavailable in certain states. At present, California, New York, Montana, Nevada, Delaware, parts of Arizona, and Oregon do not allow sales of E15, much less E30 or E40. The core rulemaking for the high octane fuel transition might be completed in two years but could also take as long as ten.

A separate rulemaking would be required for misfueling prevention (MFP), so that legacy vehicles do not fill up with ethanol blends exceeding E15 and new high-compression vehicles do not fill up with low-octane fuels. That rulemaking could take three years. Standardization and deployment of MFP technology could take five years.

Completing the necessary refinery modifications and additional pipelines and tankage for producing, handling, and segregating high octane fuels could take five years. About 50 percent of refineries would “require new tanks, costing an average of $2.5 million each,” or about $219.5 million in all.

If high-octane fuels are made with E30, all participants in the “gasoline supply chain downstream of the refinery—e.g., terminal operators, jobbers, retailers—would experience significant equipment compatibility issues [and] operating costs.” Pipeline tankage and terminal tankage costs would exceed $3.3 billion. Total costs borne by retail service stations for E30-compatible pumps and storage tanks would exceed $20 billion.

More than 95 percent of service stations are independently owned, including about 122,000 convenience stores, of which 70,000 or 58 percent are single-store operators. Many of these small businesses have thin profit margins. If E30 became the fuel of choice to meet the high-octane standard, thousands of service stations could go out of business.

Indeed, even a high-octane fuel made from E15 could create financial risks for many service stations, according to the Petroleum Marketers Association of America (PMAA). The problem is not with the dispensers and underground storage tanks (UST), most of which are compatible with E15 (although few are certified for E30), but with the adhesive or “pipe dope” that connects the multitude of parts:

While many underground storage tanks may be compatible with ethanol blends over E10, piping and dispensing equipment running from the tank to the pump nozzle are not. Gasoline blends greater than E10 ethanol can quickly crack, dissolve, or corrode rubber seals, gaskets, plastic sump components, piping and dispenser equipment. Typically, there are over 100 such connections held together by pipe dope in a six-dispenser UST system. In most cases, pipe dope used in UST systems is not compatible with ethanol blends greater than E10.

PMAA cautions that removing and replacing underground storage tank piping could be “prohibitively” expensive for many service stations:

Piping can be buried four or more feet underground depending on the size of the tank and number of dispensers. Asphalt and concrete over piping must be jack-hammered away. Dirt and protective backfill must be excavated from over and under the piping to provide access. All piping connections including pipe to pipe connections, pipe to containment sumps connections, pipe to dispenser connections, etc.; must then be disconnected, (if possible), carefully cleaned, fitted and otherwise prepared for reconnection with E15 compliant pipe dope. All this must be done by skilled tank installers. During this process, which can take up to three or more days, the station must be closed and no sales are made. This process alone could cost small business petroleum marketers hundreds of thousands of dollars in installation expense and lost sales revenue.

Big Picture

The Fuels Institute estimates that full transition to a market where all new gasoline-powered vehicles are designed to run on high octane fuels would take 10 years, and three more years before high octane fuel vehicles constitute half of total vehicle stock. Clearly, a high octane fuel mandate “should not be viewed as a near-term option for achieving corporate average fuel economy and greenhouse gas vehicle standards.” Luntz and Rauch’s innuendo that Americans can reap important consumer and energy security benefits tomorrow if President Trump just ramps up his already well-known support for ethanol today is poppycock.

Mandating a high-octane fuel standard for new motor vehicles was never an idea whose time had come, and its prospects are dimmer now than in the previous Congress, when House Energy and Commerce Subcommittee Chairman John Shimkus (R-IL) worked to broker a deal among the major stakeholders. As matters stood then, refiners had no interest in a high octane standard unless it replaced the Renewable Fuel Standard’s volumetric sales mandates. In contrast, the renewable fuels industry had no interest in a high-octane standard absent a guarantee that ethanol would always be the octane booster of choice.

Retail fuel distributors were non-committal but indicated they would need substantial taxpayer support to replace existing pumps and tanks with E30-compatible equipment. Automakers were prepared to build cars designed and optimized to run on high-octane fuels, but only if (1) the federal government—for the first time—imposes uniform octane standards on all states, and (2) refiners and retailers commit to implement those standards.

As noted, automakers now seem split between those who view electrification as the chief pathway to “clean cars” and those who believe President Trump’s rollback of the Obama mileage standards obviates the need for electrification.

Rauch calls himself a “free-market entrepreneur,” yet he wants to expand the Renewable Fuel Standard, a central planning scheme that dictates how much and which types of biofuel refiners must sell each year, over a 17-year period. Although the RFS statutory targets expire after 2022, the program continues, with the EPA more directly in charge of determining annual blending targets, apparently in perpetuity.

This politically-imposed sales quota system is an affront to free market principles and, indeed, common sense. In a free enterprise system, government does not guarantee any industry’s share of the market, nor does the law obligate Company A to implement any part of Company B’s business plan unless A has voluntarily contracted with B to do so. The RFS provides corporate welfare to one set of companies (corn farmers, ethanol producers) by imposing a system of involuntary service on another set of companies (refiners, fuel importers). That is not the American way.