The Fuel Economy Rule: An EPA That Won’t See, Hear, or Speak to the Facts

Source: By Doug Durante, Clean Fuels Development Coalition • Posted: Thursday, August 26, 2021

The release of the highly anticipated revision of the Safe Affordable Fuel Efficient Vehicle (SAFE) proposed rule this month was, for the biofuels industry, yet another poke in the eye as the EPA totally ignored reality and continued their long history of taking every opportunity to not help the most successful alternative fuel in history.  An overstatement?  Not by a long shot, and I’ll come back to that.

But let’s look at what happened.  First of all, we get it. The administration wants to electrify everything.  Yeah, ok, right, fine, sure.  But can we put the EV discussion in perspective? While they work out the myriad of issues and challenges any new fuel would encounter like cost, infrastructure, recharging, battery life, cost, battery disposal, mineral mining and depletion, cost, range, consumer choice, –did I mention cost? —and other challenges, we will be burning hundreds of billions of gallons of gasoline containing billions of gallons of carcinogenic benzene.

With somewhere between 12 and 18 million new cars sold every year, the majority by far over the next decade will be internal combustion engines fueled by that gasoline.  And, those cars will remain on the road for a dozen years at least. So here we have a rule whose two objectives are to reduce GHG carbon emissions and achieve greater miles per gallon. By raising octane as part of a more realistic strategy we have a product in ethanol that will –guess what —reduce carbon emissions and achieve greater miles per gallon.  Silly us, thinking we would be relevant to this rule.

This rule was unveiled in concert with an executive order that established “goals” for EV production. It has no teeth, no funding, no force of law. Yet, the perception being created is that all is well and we are grabbing climate change by the throat and fighting back. Without question, the new efficiency rules will be so stringent that it will force feed EVs over time, but what about the interim?  It is clear that any meaningful efficiency gains and CO2 reductions from this rule as proposed are decades out, ethanol reduces GHG by 50% today.

This would be like telling your family what a wonderful feast we are going to have at the next Thanksgiving and how great the food will be but neglecting to develop any kind of strategy on what we are going to eat between now and then. So we got nothing on octane in this proposed rule.

Secondly, while much of the noise surrounding EVs is political, there are here and now health impacts that EPA has and continues to avert their eyes whenever we present them with information. And present them we did– I wrote a letter to incoming EPA Administrator Regan the day he was confirmed in the Senate urging him to use the SAFE Rule opportunity to recognize we can decarbonize gasoline and it is incumbent on us to do so as a public health measure.  I even got a nice reply that they were indeed looking at this and while I know it was a boiler plate response I was still somewhat encouraged.

In the ensuing 7 months CFDC and others have been meeting with Administration officials providing current, credible information as to how both emission and efficiency goals can be met by increasing the minimum octane standard in U.S. gasoline if they enforce existing toxic controls.  We have provided extensive documentation on aromatics used for octane and how they are not only the highest carbon component in gasoline but also the primary source of fine particulate matter.  So, by reducing these compounds and replacing them with low carbon clean octane, automakers are able to increase compression and –wait for it—emit less carbon and get better mileage.  (Gosh, if there was only a rule that was seeking to emit less carbon and get better mileage.)

Moreover, the Administration’s pledge to address environmental justice would immediately be furthered because the inner-city residents who have higher rates of just about everything bad in terms of health are breathing this fine PM.  EPA has admitted their models do not accurately capture secondary organic aerosols as carriers of particulates, but they continue to fixate on evaporative emissions.  Tailpipe emissions are four times more reactive in forming ozone, and those tailpipe emissions are greatly reduced with ethanol due to its oxygen properties that increase combustion.

We were involved in a joint letter a few weeks ago to the President that 30 different ag and ethanol organizations signed prior to the release of this proposed rule.  The Governors Biofuel Coalition wrote EPA, the Alliance for Automotive Innovation, which has 38 members and produces 98% of the cars sold in America today is on record acknowledging no matter what we do on EVs, we will need low carbon high octane liquid fuels.  All we were asking in all our meetings and in this correspondence was to give us a chance to make this case by soliciting comments in the proposed rule.  EPA could have at least made note of and acknowledged they had been getting lots of input on octane and that it could play a role in fuel economy.  Not only did they not do this but the salt in the wound is that the Trump EPA– not exactly known as stewards of the environment—did just that when they worked this rule. They did not act on it but at least allowed us to build the record and make our case. We put the information in front of them and they ignored it.

This brings me to my earlier point about the most successful alternative (to oil) fuel in our history, which is ethanol.  While it’s a high honor, there hasn’t exactly been a lot of competition.  We have tried to anoint a single fuel over the decades I have been involved in all this and it has never been the answer.  In the 80’s, it was so called synfuel, and no ever quite figured out what that was.  In the 90s, the Clinton Administration had a love affair with natural gas, with an occasional fling with methanol.  Hydrogen, green gasoline, and other fuels come and go while ethanol withstood prejudice and flat-out obstruction to emerge as not only the best, but essentially the only thing that actually worked.  Ethanol has displaced 10% of the gasoline in the U.S.  There is no one close—there aren’t even any honorable mentions.

EPA’s own data documents the reduction in aromatics as ethanol has gone from fringe player to a key part of the fuel mix.  It has been enormously effective in eliminating carbon monoxide and ground level ozone.  And, if EPA would open their eyes and ears, they would be forced to recognize the astounding advances in farming and agriculture practices, along with efficiency and yield gains in ethanol production resulting in carbon reductions superior to anything out there.

Why wouldn’t EPA do everything in their power to get more of this, rather than block it at every turn.  Particularly in light of their history of dealing with ethanol and the RFS, the SAFE Rule would have been a good time to start openly talking about the future of the RFS and what might be a higher value and better pathway for growth.

The bottom line is that this rule, if it is finalized, requires an annual increase in efficiency through 2026, then the post 2026 period will need another rule.  It denies automakers all the tools to affordably achieve the required reductions in emissions and gains in efficiency.  More importantly to all of us who breathe, it completely and totally ignores the health impacts of continuing to use high carbon toxic aromatics for octane.

The EV vision may or may not become a reality.  But as advocates point to even the most optimistic scenarios of a 40-50% market share in a decade, they are intellectually dishonest to not acknowledge gasoline isn’t going away.  How does EPA and the super green crowd justify not decarbonizing the largest source of ghg emissions over the next decade—and do their job to protect both climate and health?

What a sad irony that as this proposed rule to reduce oil use is introduced, the Biden Administration called on OPEC to pump more oil to lower gasoline prices.  If EPA opened the pathway to higher ethanol blends, we would save billions of barrels of oil, and produce that fuel here at home.  Higher ethanol blends represent zero cost to the federal government and would provide stunning economic benefits in terms of health care savings, jobs, increased tax revenue, and balance of trade.  If cellulosic ethanol is ever going to be widely available, where is that ethanol going to go if we do not have higher blends?  The Advanced Biofuel Community needs to weigh on this rule after being silent for the past year.  Ditto for the environmental community—while they of course weigh in on EVs, do they not care about billions of gallons of toxic gasoline? There are whispers throughout the Administration that they are hesitant to do anything that could be perceived as prolonging or supporting gasoline for fear of upsetting many in the environmental community.  If true, that is insane.

While we don’t expect the agency to insert a higher minimum octane standard in the rule at this point, at least in a preamble or introductory statement admit we need to focus on liquid fuels as transition to EVS and that the agency intends to aggressively address this in a future rulemaking on octane. EPA has announced they plan to develop a fine PM rule soon — that would be a good place to start.

EPA, look at the facts and the data and improve the proposed rule. At least set the stage for an octane increase by openly speaking about it.

|