The deadline is fast approaching for submitting comments to EPA on their Reconsideration of the Final Determination of Mid-term Evaluation (MTE) of greenhouse gas (GHG) standards for model year 2022-25 cars and light trucks. The 25x’25 Alliance is offering input and recommendations that address the agency’s specific request for comments pertaining to the impact of the standards on advanced fuels technology; particularly, the potential for high-octane blends.
Over the past several years 25x’25 has been working with partners in the agriculture and auto manufacturing sectors to make the case that high-octane fuels can be delivered cost effectively through the use of ethanol. Research has shown that high-octane, low-carbon (HOLC) ethanol blends, paired with optimized engines, are among the lowest cost means of achieving compliance with fuel economy and greenhouse gas (GHG) standards for model year (MY) 2022-2025 and beyond.
The fact that EPA is even taking comments on a process that was abruptly closed in the last weeks of the Obama administration is attributable to the joint decision made in March by EPA Administrator Scott Pruitt and the National Highway Traffic Safety Administration (NHTSA) to reconsider the standards previously established for MY2022-2025 light-duty vehicles, and to set them back on the previously agreed-to schedule that coincides with NHTSA’s rulemaking due April 1, 2018.
For the first time in the MTE process, EPA has recognized the importance of considering fuels and engines as a system, and has explicitly invited comment on the role that fuel properties, especially octane rating, can play in facilitating compliance with the long-term fuel economy and GHG emissions standards.
It is important to note that EPA and DOE have continuously endorsed the utility of higher-octane fuels in achieving more efficient performance of the nation’s new car fleet, which will continue to use gasoline in large volumes to power internal combustion engines for many decades to come. Furthermore, the endorsement of the federal agencies is supported by a 2011 recommendation from the Alliance of Automobile Manufacturers to increase the minimum gasoline octane rating, commensurate with an increase in ethanol use, to help achieve future requirements for the reduction of GHG emissions.
High-octane gasoline, available for general use, could be used by automakers to support increased introduction of higher efficiency internal combustion power trains that can better address increasingly stringent fuel economy and emissions performance standards within the next few years. As performance standards are considered beyond model year 2025, high-octane fuel will be even more critical for supporting the deployment of compliant systems. It should also be noted that current “premium” fuel is not a viable solution for automakers because the octane rating is not high enough and the retail fuel price is cost-prohibitive to consumers. Ethanol provides the most cost-effective source of higher-octane that can be made widely available to markets across the country by 2025 though the use of existing and expanding distribution infrastructure.
By identifying the need to increase the octane rating of regular gasoline, EPA would open up competition in the marketplace, and allow ethanol producers and feedstock providers, like American corn growers, the opportunity to supply lower cost and cleaner octane. Additionally, increasing octane requirements would provide automobile manufacturers with near-term technology options they can utilize to achieve reduction in GHG emissions, improve fuel economy of the nation’s light duty fleet, lower fuel costs to consumers, and support sustainable job growth throughout the United States.
25x’25’s specific recommendations in response to EPA’s request for comments include:
- Harmonize EPA’s GHG and NHTSA’s fuel economy standards to achieve the same net regulatory effect.
- Establish a minimum octane level of 98 RON.
- EPA’s own technical modeling done in their Technical Assessment Report (TAR) utilized the benefits of high-octane fuels, such as having an “R-Factor” of 1.0 and using a 93 AKI (98 RON) fuel instead of an 87 AKI (91 RON) fuel. Additionally, EPA should correct its fuel economy equation (“R-factor”) to accurately certify vehicles running on ethanol blends.
- EPA should change the current Tier 3 fuel regulation to focus on the utility of octane rather than the specific use of the term “premium” fuel; thereby changing all references in the Tier 3 Preamble to “high-octane” fuel instead of “premium” fuel.
- Approve an alternative certification fuel with 25 percent ethanol and a minimum octane rating of 98 RON.
- Correct the outdated “MOVES2014” model used in calculating GHG emissions from ethanol.
- Allow Reid vapor pressure (RVP) relief to E15 and higher ethanol blends.
- Update the lifecycle analysis of corn ethanol.
Unfortunately, the encouragement offered by EPA’s reconsideration of GHG and fuel efficiency standards is tempered significantly by the agency’s notice of data availability (NODA) that was released this week and suggests further reductions to the advanced biofuel blending requirements under the Renewable Fuel Standard (RFS) for 2018 and, for bio-based diesel in 2019. Industry stakeholders had already expressed disappointment with the agency’s proposed reductions to advanced and overall biofuel requirements when it issued its proposed RFS rule in July, and are even more opposed to the current consideration.
25x’25 encourages its clean energy partners to tell EPA that if properly designed and implemented, future GHG and fuel efficiency standards can work in tandem with programs like the RFS to reduce emissions and fossil fuel consumption. Yet, that means creating opportunities for more biofuels that can help to attain future environmental and efficiency goals, not less.