Ethanol groups comment on CAFE-GHG standards

Source: By By Erin Voegele, Ethanol Producer Magazine • Posted: Tuesday, October 10, 2017

The Renewable Fuels Association, Growth Energy and American Coalition for Ethanol have all submitted public comments to U.S. EPA and National Highway Transportation Safety Administration stressing the benefits of high-octane ethanol fuels in response to the EPA and NHTSA’s reconsideration of the Final Determination of the Mid-Term Evaluation of Greenhouse Gas Emission Standards for Model Year 2022-2025 Light-Duty Vehicles.

A part of a 2012 rulemaking, the EPA established MY 2017-2025 light-duty vehicle GHG standards and made a regulatory commitment to conduct a midterm evaluation (MTE) of the standards for 2022—2025. That review was originally completed last year. On Nov. 30, 2016, former EPA Administrator Gina McCarthy proposed to determine that the MY 2022-2025 standards remain as first established, and that rulemaking to change them was not warranted. The public comment period on that proposal was open through Dec. 30, 2016. On Jan. 12, McCarthy signed her determination to maintain the current GHG emissions standards for MY 2022-2025 light-duty vehicles. In March, current EPA Administrator Scott Pruitt announced the EPA would reconsider the mid-term evaluations and McCarthy’s determination.

On Aug. 21, the EPA opened a comment period on the reconsideration. The comment period is open through Oct. 5. The agency also held a public hearing on Sept. 6 in Washington, D.C. The RFA, Growth Energy and ACE were also among the groups that testified at that hearing.

In its comments, the RFA encouraged the agencies to consider the beneficial impacts of high-octane, low-carbon fuels on fuel economy and GHG emissions. The RFA also underscored that EPA has the authority and responsibility to regulate minimum gasoline octane ratings, and urged the agencies to undertake other actions that would facilitate broad commercial adoption of high-octane, low-carbon fuels.

RFA also stressed that the use of ethanol-based high-octane, low-carbon fuels in optimized engines would be the lowest cost means of achieve compliance with CAFE and GHG standards for MY 2022-2025 and beyond. The RFS also noted that the EPA retains broad authority to regulate gasoline octane levels and recommended steps the agency should take to help facilitate the use of high-octane, low-carbon fuels. In addition, RFA included a literature review of The Ricardo Report, which found broad consensus around the efficiency and emissions benefits related to using ethanol-based high-octane, low-carbon fuels.

“We were very encouraged to see EPA specifically ask for comment on the ‘potential for high-octane blends’ in the notice announcing the reconsideration of the last administration’s Final Determination,” said Bob Dinneen, president and CEO of the RFA. “Throughout the entire Midterm Review process, we have urged EPA and NHTSA to recognize that the fuels Americans put in their engines have a significant impact on fuel economy and GHG emissions. But until now, the agencies had largely ignored the impacts of fuels and focused only on the engine technologies that will be necessary to meet 2022-25 standards. The bottom line is that EPA has the statutory authority to create a regulatory framework that will pair high-octane, low-carbon fuels with high compression ratio engines, resulting in greater fuel economy and emissions benefits. Such fuels can serve as an important tool for complying with increasingly stringent future fuel economy and tailpipe GHG standards.”

Growth Energy comments highlighted the environmental benefits of higher ethanol blends, including greenhouse gas reductions, reduction in particulate matter emissions, and potential fuel efficiency gains through ethanol’s high-octane value.

“Vehicles and fuels operate as a system, so it’s not only logical, but truly essential to explore the benefits of high-octane fuels, like ethanol, when considering the potential achievements of future fuel economy standards. Ethanol significantly reduces greenhouse gas emissions, demonstrably supports automakers in achieving future fuel economy standards, and helps to reduce consumer costs,” said Emily Skor, CEO of Growth Energy.

“Additionally, biofuels ensure that consumers have access to fuels that are renewable, support our nation’s energy security, and invest in rural America, all while providing savings at the pump,” Skor continued. “We sincerely hope the agency will take these important facts into account as it reconsiders the standards for 2022 and beyond.”

In its comments, ACE set forth recommendations to accelerate the transition of transportation fuels to low-cost, high-octane fuel blends. ACE called on the agencies to approve an alternative certification fuel with 25 to 30 percent ethanol and a minimum octane of 98-100 RON, establish a performance standard for gasoline with a minimum octane level of 98-100 RON, make changes so ethanol is no longer penalized with respect to fuels economy or emissions, restore credits to automakers for the manufacture of flex fuel vehicles and consider new incentives for future engines designed to achieve maximum efficiency on high-octane fuels, ensure that the EPA’s GHG standards are harmonized with the U.S. Department of Transportation’s fuel economy requirements and efforts to improve fuel economy and reduce CO2 emissions by the California Air Resources Board, provide Reid vapor pressure (RVP) relief to E15 and higher ethanol blends, and update the lifecycle analysis of corn ethanol.

“While the CAFE-GHG program has resulted in meaningful progress with respect to fuel efficiency and GHG emissions, this progress will plateau unless EPA increases the octane rating of fuel used in future engines,” said Brian Jennings, executive vice president of ACE.  “With a blending-octane rating of 113, American-made ethanol is the lowest-cost, low-carbon source of octane on the planet.”