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US passed a dubious and historic milestone this week. The tax rate
on E85 renewable fuels now exceeds 100% in some formulations. By
comparison, the tax rate on E10 renewable fuel is running at an
estimated 41% and the tax rate on straight gasoline is running at
an estimated 35%.
As Shakespeare observed in Measure by Measure, “some
rise by sin, and some by virtue fall”.
Now, the idea of a carbon tax is that governments are supposed to
collect more tax against high-carbon fuels. Yet, policy in
practice works the other way. The less carbon you consume, the
higher percentage tax you pay.
In fact, it gets worse, seen another way.
Because E85 has roughly 28% lower fuel economy than straight
gasoline, the average person would use 20% more gallons driving on
E85 in order to get to a given destination, compared to using
straight gasoline. Yet, the taxes are applied not on a
cents-per-mile basis, or a gallons of gasoline equivalent (as is
the case for compressed natural gas) — they are applied on a
gallon basis. So, not only does E85 suffer pay 100% tax rates
compared to 35% for straight gasoline; drivers have to pay 28%
more tax in driving the same miles.
How it works, the “taxing virtue as sin” system
Let’s look at how the US, state and local governments work
together to hike the price of E85 renewable fuels through tax
policy adds cost to lower-carbon fuels, and takes away the price
incentive to switch to lower-carbon fuels.
First, let’s look at E85, E10 and gasoline prices as reported
this week by the Iowa Renewable Fuels Association.
The amazing news is that E85 fuel is available on a wholesale
basis for 55 cents per gallon from The Andersons. Absolute Energy
is not far behind, at $0.60 per gallon .On a wholesale
mile-for-mile energy cost (BTU) basis, E85 is less expensive now
than either straight gasoline or CNG (compressed natural gas),
despite the collapse in oil & gas prices over the past 18
In fact, E85 on a wholesale basis is up to 51% less expensive on
a mile-for-mile basis, compared to gasoline. Here’s the hard data
So, why aren’t E85 sales skyrocketing?
Partly due to there being 15 million flex-fuel vehicles on the
road out of 300 million registered vehicles. Partly due to there
being 3200 E85 outlets out of about 130,000 places to buy road
But that’s not the complete story. Some of it is contained in the
retail discount to gasoline, as opposed to the wholesale discount.
Let’s look at that:
Here’s the retail comparison.
Here’s the wholesale.
How did a lower-carbon fuel that was 51% cheaper at wholesale
become only 5% cheaper at retail?
In a word, taxes.
Here’s a breakdown of the fuel taxes imposed in California, as
reported at CA.gov for branded gasoline. Note that wholesale costs
have changed since CA.gov ran the numbers, but the taxes are
imposed on a gallon basis not a price basis, and remain the same.
Your eyes can quickly do the math that there’s something like
$0.56 in taxes per gallon, which means that E85 customers pay
$0.78 in taxes per gasoline-gallon equivalent (GGE). And that
means that, as fuel prices drop and the tax component (which is
fixed) becomes a bigger part of the cost of fuel, it becomes
almost impossible for renewable fuels to beat out gasoline on
price, entirely due to tax policy.
The rapacious mark-ups in E85
Boy, are fuel marketers making out like bandits with E85. The
mark-up from wholesale to retail, even after subtracting taxes, is
107%. Margins that even high-end brand marketers would be
By comparison, gasoline is a tougher business. The mark-up from
wholesale to retail is 22%, while CNG’s mark-up is 31%.
If you concluded that the overall impact of national E85 policy
is to disincentive E85 through high taxes, and offer massive
margins to the value chain (while denying value to the corn
farmer, the E85 refiner, or the end-user), you would find real
support in the hard data.
The solution is not too hard, from a tax POV. Simply do what is
done with Compressed Natural Gas and tax everything on a GGE
(gasoline gallon equivalent) basis.
At the end of the day, it’s revenue-neutral — renewable fuel
patrons would end up paying the same taxes as the patrons of
gasoline on a mile-for-mile basis. But it removes an unfair burden
that will stymie the adoption of high-blend renewable fuels by
From a wholesaling perspective, gas stations mostly sell gasoline
(in terms of fuel), so 22% overall margins must be generally
acceptable. Which suggests that someone could be buying E85 at
$0.55 from The Andersons, and marking it up to $1.23 to provide
the same margin as gasoline and pay for all those taxes. Even with
the lower fuel economy, that would be a 31% discount to straight
gasoline, and that would be a tasty incentive to switch to
Jim Lane is editor and
publisher of Biofuels Digest where this
was originally published.
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