Ethanol industry says ethanol can help meet CAFE, GHG standards

Source: By Erin Voegsel, Ethanol Producer Magazine • Posted: Wednesday, September 28, 2016

Ethanol industry leaders have weighed in on a draft technical assessment report for the midterm assessment on greenhouse gas (GHG) emissions and CAFE standards for model year 2022-2025 light-duty vehicles, focusing on the benefits of high-octane midlevel blends.

The U.S. EPA and National Highway Traffic Safety Administration have established a coordinated national program for federal standards for GHG emissions and corporate average fuel economy (CAFE) for light-duty vehicles. As part of the program, EPA and NHTSA, in cooperation with the California Air Resources Board, jointly prepared a draft technical assessment report. The report was published in the Federal Register on July 27 and was subject to a public comment period that closed Aug. 26.

A notice posted to the Federal Register explains that the EPA and NHTSA have conducted two joint rulemakings to set CAFE and GHG standards for light-duty vehicles. The first set, covering model years 2012-2016, was finalized in May 2010. The second set, covering model years 2017-2022 for EPA and final standards for 2017-2021 and augural standards for 2022-2025 for NHTSA, became final in Oct. 2012. The second rule included a requirement that EPA conduct a midterm evaluation for the GHG standards established for model years 2022-2025.

The draft technical assessment report is the first formal step in the midterm evaluation process. NHTSA and CARB are also participating in the process. The draft technical assessment report examines a wide range of issues relevant to GHG emissions and CAFÉ standards for model year 2022-2025 vehicles. Within the report, the agencies share their initial technical analyses of those issues.

The Renewable Fuels Association, Growth Energy and American Coalition for Ethanol are among those who filed comments on the report.

According to the RFA, high-octane low-carbon (HOLC) fuels can play an important role in helping automakers comply with CAFE and GHG emissions standards in the 2022-2025 timeframe. In order to realize the benefits of these fuels, however, the RFA said the CAFE and GHG standards must treat fuels and engines as integrated systems.

“This is an important process because it will determine the path forward for future energy efficiency and environmental goals,” said RFA President and CEO Bob Dinneen. “EPA has correctly identified technologies that will effectively improve energy efficiency and reduce greenhouse gases. But the agency has failed to appropriately consider the fuels that will enable those technologies. That is an omission that must be addressed moving forward if future vehicles can in fact help us address climate change without backsliding on other critical air quality and public health priorities. We look forward to working with EPA and NHTSA as this process continues,” he added.

According to the RFA, it reviewed the draft technical assessment report and commissioned a technical analysis by Ricardo Inc. The RFA and Ricardo found that many of the advanced internal combustion technologies examined by the EPA and NHTSA would experience increased fuel efficiency and generate fewer emissions if operating on fuels with higher octane ratings that today’s regular gasoline. According to the Ricardo analysis, “It is clear that implementing a high octane fuel standard would provide opportunity for increased engine efficiency and hence reduced greenhouse gases, and doing so by blending with ethanol provides an even greater benefit due to ethanol’s high heat of vaporization combined with the inherently low carbon footprint of ethanol. Many of the technologies discussed in the [draft technical assessment report], including ones with the highest expected penetration rates, could produce greater GHG and fuel economy benefits if paired with fuels offering higher octane ratings and an inherently higher charge cooling characteristic.”

Growth Energy also focused on the benefits of using high-octane midlevel blends in future optimized engines. According to Growth Energy, benefits would include increased vehicle efficiency, increased acceleration, and significant reductions in GHG emissions. In particular, the group said midlevel blends, such as E30, have significantly more octane, allowing automakers to downsize and downspeed engines, making these vehicles much more efficient and ultimately saving consumers money at the pump as well as further reducing GHG emissions.

“Our comments highlight the wealth of available research that outlines the vital role that affordable, higher blends of ethanol can play in helping automakers achieve increasing future GHG and CAFE standards,” said Chris Bliley, director of regulatory affairs at Growth Energy. “Furthermore, we encourage the agencies involved in this review to not only acknowledge the important role higher blends can play, but ensure they are part of the larger goal in achieving greater efficiency and a reduction in harmful emissions.”

“Now is the time to capitalize on home grown biofuels to help move our nation forward—if we are serious about meeting the CAFE standards and reducing harmful emissions, greater blends of biofuels like ethanol must be part of the solution,” Bliley continued.

ACE made three main points in its comments. First, the groups said vehicle CO2 emissions will continue to rise until EPA, NHTSA and CARB deal with the impact fuel composition has on GHG emissions. ACE said it is encouraging the agencies to acknowledge the link between fuels and vehicles and create a pathway for LCHO fuels to help automakers comply with 2022-2025 standards. Second, ACE said that while the GHG and CAFE standards have spurred advancements to internal combustion engines, the agencies have not been proactive about improving the octane composition of the fuel those internal combustion engine technologies depend on, noting the goas of the CAFE-GHG program will go unrealized until a compliance mechanism is set in motion for higher-octane fuel. Third, ACE stressed that automobile engineers and government scientists who have researched engine technologies and fuel properties agree that ethanol is a low-cost, low-carbon, high-octane fuel that delivers the GHG and engine efficiency benefits necessary to achieve the goals of the GHG-CAFE program.

In addition, ACE asked the agencies to restore meaningful credits for flex fuel vehicles and consider the establishment of a new incentive for engines optimized for high-octane, low-carbon fuels. The group also urged fixes to be made to the MOVES2014 model and R-factor, and encouraged the goals of the CAFE-GHE program and renewable fuel standard (RFS) be harmonized.

“ACE has been in dialogue with automakers, agricultural organizations, and government researchers to develop strategies and action plans to accelerate the transition of North American transportation fuels to higher-octane, lower-carbon renewable fuels such as ethanol,” said ACE Executive Vice President Brian Jennings. “If the agencies hope to fulfill the ambitious goals of the CAFE-GHG program going forward, a regulatory framework needs to be initiated immediately for lower-carbon, higher-octane fuel such as ethanol.”