Koch, ADM Led $16M Lobbying Push for E15 Rule That Rewrites Fuel Market

Public records show the two largest spenders on year-round E15 lobbying in 2025 were not ethanol producers but a fossil-fuel refiner and a grain conglomerate whose combined federal lobbying topped...

The single most striking documented fact in the 2025 ethanol blending debate is not found in any environmental impact statement or energy security analysis. It is found in federal lobbying disclosure records: Koch Companies — owner of oil refiner Flint Hills Resources, a company whose parent organization has spent decades opposing renewable-energy mandates — was the largest identified single-entity spender lobbying for year-round E15 fuel sales in 2025, reporting more than $9 million in total federal lobbying expenditures, with year-round E15 listed as a central issue, according to Washington Sun reporting on Lobbying Disclosure Act filings. Archer Daniels Midland, the nation's largest ethanol producer by volume, spent almost $7 million on federal lobbying in the same period, also with E15 expansion as a primary focus. Combined, those two entities alone account for more than $16 million in a single year's lobbying on a regulatory question — whether the Environmental Protection Agency should permanently waive summer-blend restrictions on E15 fuel — that the EPA is statutorily required to adjudicate on public health and air quality grounds under the Clean Air Act.

To understand why a fossil-fuel refiner would spend at that level to expand an ethanol blending rule, it is necessary to understand the financial architecture the lobbying is designed to protect. The Renewable Fuel Standard, created by the Energy Policy Act of 2005 and expanded by the Energy Independence and Security Act of 2007, requires a legally mandated minimum volume of renewable fuel in the U.S. transportation fuel supply each year. The EPA sets annual Renewable Volume Obligations that determine how many gallons of ethanol must be blended. Industry analyses cited by Growth Energy and the Renewable Fuels Association estimate the blending mandate supports a market worth more than $50 billion annually in ethanol sales, though independent verification of that figure requires cross-referencing USDA, EIA, and industry reports. Each incremental gallon mandated is direct revenue to producers and, at certain crude-to-ethanol price differentials, a cost advantage to refiners who blend rather than purchase Renewable Identification Numbers on the open market. Flint Hills Resources operates refineries in Minnesota, Texas, and Alaska. At those facilities, higher ethanol blend mandates can be commercially preferable to purchasing compliance credits, which explains the financial logic — if not the ideological consistency — of Koch's position.

The lobbying infrastructure behind ethanol policy is not new. It is, by documented measure, one of the most durable in American political history. Taxpayers for Common Sense, in a June 2015 report, calculated that the corn ethanol industry spent at minimum $187.5 million lobbying federal officials across election cycles from 2008 to 2014 alone. In 2010, a year when the industry was fighting to retain the Volumetric Ethanol Excise Tax Credit — a $0.45-per-gallon subsidy paid to fuel blenders — industry organizations spent $24.8 million on federal lobbying, according to the same Taxpayers for Common Sense analysis. The Congressional Budget Office estimated that credit cost taxpayers $6 billion annually at peak, with cumulative expenditure exceeding $40 billion over its 1978-to-2011 lifespan. Notably, the primary recipients of that credit were not ethanol producers but petroleum companies acting as fuel blenders — the same category of enterprise that Koch's Flint Hills Resources represents today.

The 2025 E15 campaign demonstrates that the coalition structure has broadened beyond traditional ethanol interests. Washington Sun reporting on 2025 Lobbying Disclosure Act filings identifies Growth Energy — the trade association formed in 2008 specifically to pursue more aggressive E15 lobbying than the Renewable Fuels Association — as spending in the range of tens of thousands to more than $1 million in 2025, with full-year filings potentially showing higher totals. The American Farm Bureau Federation and the American Soybean Association, neither of which is an ethanol producer, are also documented as spending in similar ranges and signing a joint letter to President Trump calling for year-round E15 legislation. The National Association of Convenience Stores, representing retail fuel sellers who would install and profit from E15 pumps, likewise signed the letter and recorded lobbying expenditures in the same period. This retail layer is analytically significant: it allows proponents to characterize E15 support as a small-business issue rather than a large-producer subsidy question, a reframing with direct value in congressional testimony and media coverage.

The corn supply chain's stake in these regulatory decisions is structural, not incidental. The USDA documents that approximately 40 percent of U.S. corn production is consumed by the ethanol industry. For the National Corn Growers Association and state-level corn grower organizations, the Renewable Fuel Standard is not primarily an environmental policy — it functions as a price floor for their commodity. The Taxpayers for Common Sense 2013 Political Footprint report calculated that the aggregate ethanol lobbying total in 2012, a year after both the Volumetric Ethanol Excise Tax Credit and the $0.54-per-gallon ethanol import tariff expired, still reached $22.3 million — demonstrating that the industry maintained full lobbying intensity even after losing two major subsidy instruments, redirecting that investment toward defending and expanding the RFS mandate itself. Archer Daniels Midland's position at the center of this ecosystem has roots going back to the 1970s: the company's then-CEO Dwayne Andreas was among the largest individual political donors of his era, contributing to both Republican and Democratic campaigns to maintain ethanol preferences, establishing a bipartisan access model that the industry has sustained for five decades.

What the records show, taken together, is a regulatory process in which the entities with the largest direct financial stake in the outcome are also the entities making the largest documented investments in influencing that outcome. The EPA's annual Renewable Volume Obligation determination and its authority under the Clean Air Act to issue volatility waivers for E15 are administrative proceedings that formally receive public comment. The lobbying expenditures documented here — $9 million from Koch, $7 million from ADM, additional millions from Growth Energy, RFA, AFBF, NACS, and agricultural associations — represent a parallel channel of influence operating through congressional appropriators, White House staff, and direct executive agency contact that is disclosed in Lobbying Disclosure Act filings but rarely aggregated into a single public accounting. The 2012 record lobbying expenditure of $286,297 by the American Coalition for Ethanol alone, documented in the Taxpayers for Common Sense 2013 report, illustrates how even smaller actors in this ecosystem maintain continuous regulatory-access spending across policy cycles.

Several material facts remain hidden from public view and would require specific disclosure instruments to surface. First, the company-by-company breakdown of Volumetric Ethanol Excise Tax Credits claimed between 1978 and 2011 — identifying precisely which petroleum refiners collected which sums from a program the ethanol industry paid to maintain — is confidential IRS data accessible only through FOIA litigation or congressional subpoena directed at Treasury. Second, Koch Companies' lobbying disclosure filings cover total federal expenditures; the specific dollar allocation to E15 versus other policy priorities within the $9 million total is not broken out, and would require the company's internal lobbying allocation records, obtainable only through voluntary disclosure or investigative subpoena. Third, state-level lobbying expenditures by corn grower associations and ethanol producer groups — a layer of political spending that runs parallel to federal filings and influences state fuel standard decisions — are reported to individual state ethics bodies under varying disclosure standards and have not been aggregated into any single public database. A Senate Commerce Committee or House Energy and Commerce Committee investigation with subpoena authority over Lobbying Disclosure Act supplemental filings, combined with a Treasury Inspector General review of VEETC claimant records, would be the instruments most likely to complete this accounting.