Comments: HOLC Fuels in Existing Fleet Could Double CO2 Reductions from Proposed Rule Sooner and At Little Cost

Source: By Reid Detchon, United Nations Foundation Climate Advisor, and Reg Modlin, former Chrysler executive • Posted: Tuesday, September 28, 2021

Former Chrysler Official & UN Foundation Climate Advisor Tell EPA:

HOLC Fuels in Existing Fleet Could Double CO2 Reductions from Proposed Rule Sooner and At Little Cost

Washington, DC – Two veterans of the transportation fuels and climate policy debates have urged EPA Administrator Michael Regan to exploit the enormous opportunity of High Octane Low Carbon (HOLC) fuels to strengthen EPA’s pending rulemaking on greenhouse gas (GHG) emissions standards.  Reid Detchon, former DOE official, now a senior climate advisor to the United Nations Foundation, and Reg Modlin, long-time auto industry executive and legal expert, with more than 80 years of combined experience in transportation fuels and environmental policy, wrote EPA:

“EPA has missed a substantial opportunity to replace GHG emissions from vehicles now on the road. … To achieve early wins in the climate challenge, … EPA should also consider improving the fuel used by over 250 million existing vehicles.”

Detchon and Modlin said that “adoption of an improved fuel could possibly double the CO2 reductions claimed by the Proposed Rule” because HOLC Fuels could reduce GHG emissions from the existing LDV fleet by more than 120 million tons annually.  The experts noted that the octane boost from increased ethanol content “would also enable a 40% reduction in the use of aromatic hydrocarbons…which comprise roughly 20% of all gasoline sold in the U.S.”  Aromatics are not only highly carbon-intensive and costly to produce; they are the predominant source of some of the most dangerous toxics in urban environments.

“A recent General Motors study found that nearly 96% of the fine-particle emissions from gasoline are caused by the aromatics in the fuel,” the experts noted.  The smaller the particle, the more danger it poses to public health, and aromatics produce one of the worst ultrafine particles known as polycyclic aromatic hydrocarbons (PAHs).  Detchon and Modlin emphasized that EPA’s models had once assumed that these particles dissipated quickly in the atmosphere.  However, EPA now admits that its atmospheric models “have been unable to predict the formation of secondary organic aerosols as a class—a major component of fine particle pollution in urban areas.”  SOAs and PAHs have a synergetic relationship which enables their long-range transport and greatly increases their ability to penetrate humans’ lungs and bloodstreams, and even reach the brain.

Detchon and Modlin point out that gasoline direct injection engines have largely replaced carburetors and port fuel injection, and this technology “greatly increases emissions of ultrafine particles when using today’s gasoline.”  Replacing aromatics with HOLC fuels would substantially reduce particulate-borne toxics.

As for the existing fleet, the experts note that “Test programs…have shown that today’s vehicles operate well on higher blends of ethanol blended with conventional gasoline.  Automakers have affirmed that such benefits would be realized by both new and existing internal combustion engines and therefore should be encouraged as additional solutions as soon as possible.”

Detchon and Modlin conclude by noting the 1990 Clean Air Act mandate on mobile source air toxics, which requires “the greatest degree of emission reduction achievable through the application of technology which will be available”.  They say:

“With emissions today causing premature deaths and stunting child development in the very cities that are the focus of the environmental justice movement, this is an approach that EPA should seize and embrace.  It does not require new legislation—EPA has all the authority it needs to act and the Proposed Rule provides a convenient vehicle.  Action, or inaction, now will affect public health for decades to come.”