The 25x’25 Alliance has joined a wide array of other clean air, public health, renewable energy and biofuel advocates in calling on federal and state regulators to put more focus on the composition of fuels to best deliver on the promises the agencies have placed in new engine technology they say will meet fuel efficiency and greenhouse gas (GHG) emissions standards into the next decade. By putting greater emphasis on what car and light truck engines can best burn, regulators will ensure consumers more efficient, more economic and more environmentally friendly transportation fuel.
The Alliance made its argument in comments submitted to EPA and the National Highway Transportation Safety Administration (NHTSA), as well as to the California Air Resources Board (CARB), in response to a draft Technical Assessment Report (TAR), a 1,200-plus page document issued earlier this year that is essentially a report card on the progress auto manufacturers are making in their pursuit of fuel economy standards that average 54.5 mph by 2025 for light duty cars and trucks.
Here’s how we got here: In October 2012, EPA adopted GHG emission standards through model years 2017-2025, with the 2022-2025 standards subject to the midterm evaluation process required by the agency’s regulations. Meanwhile, federal law allows the NHTSA to adopt Corporate Average Fuel Efficiency (CAFE) standards for only up to five model years at a time. So NHTSA is creating fuel efficiency standards now for model years 2022-2025. EPA and NHTSA will finalize their respective standards by April 1, 2018.
But as 25x’25 points out in its comments, a glaring omission from the Draft TAR is any effort to address and consider fuel quality and octane pathways for meeting the very aggressive GHG and fuel efficiency targets that have been established for model year 2022-2025 cars and light trucks. This is surprising, given the fact that DOE’s national laboratories have been reporting extensively over the past two years that major engine-efficiency and emission-reduction benefits can be derived from high-octane, low-carbon (HOLC) fuels, specifically blends of ethanol in the 25-30-percent range. And recent studies by the Ford Motor Company and others show ethanol blends of up to 30 percent (E30) would increase fuel efficiency and reduce tailpipe carbon emissions by seven percent each. Just as important, the Alliance points out, the combination of HOLC fuels and higher compression engines can enable a compliance pathway that is much more cost-effective than many other more expensive and complex technologies
“The EPA and NHTSA should put considerable focus on the composition of liquid fuels, and their co-optimization with advanced internal combustion engines through MY 2025, thereby recognizing octane – as many other federal and industry partners already have – as the single most important fuel property for maximizing efficiency and performance,” 25x’25 tells the agencies. “We believe that EPA and NHTSA can achieve the GHG and CAFE goals for 2022-2025, but only if significant consideration and analysis is given to how HOLC fuels can contribute to fuel economy and carbon reduction compliance.”
The Alliance says the draft TAR should contain a detailed analysis of how HOLC fuels and high compression engines interact and perform against other compliance pathways using cost parameters and customer acceptance metrics. The evidence demonstrates that utilizing high compression, high efficiency spark ignition engines in association with low-cost HOLC fuels represents the most affordable and sustainable pathway for achieving the desired model year 2022-2025 benchmarks.
In comments submitted by the High, Octane, Low Carbon (HOLC) Alliance, a group of stakeholders representing a wide range of energy and agricultural interests with a specific focus on motor fuels, EPA is told that “study after study from DOE and others show that dramatic efficiency gains can be had in gasoline vehicles by using higher-octane fuels (RON 98-100) than are currently available at the pump.” The group says that encouraging the introduction of optimized high-octane vehicles sooner rather than later can help to ensure that carbon footprint standards are met in 2025.
The HOLC Alliance goes on to remind EPA of its own assessment that a high-octane fuel such as a mid- level ethanol blend “could help manufacturers that wish to raise compression ratios to improve vehicle efficiency, as a step toward complying with the 2017 and later light-duty greenhouse gas and CAFE standards,” and that such a strategy would “enhance the environmental performance of ethanol as a transportation fuel by using it to enable more fuel efficient engines.”
The Environmental and Energy Study Institute cites the work of Co-Optima, a joint industry-DOE effort investigating future fuel and engine design, in asserting that “in the near term, ethanol is the best bio-based octane booster available” for today’s newer, more efficient engines.
25x’25 has long participated in an Ag-Auto Ethanol work group made up of agriculture interests, auto manufacturers and supply chain members intent on helping federal regulators understand the advantages higher ethanol-blend gasoline, ranging from 25 percent ethanol (E25) to E85, can provide in raising octane ratings, making gasoline burn cleaner and reducing greenhouse gas emissions. The Alliance has long understood the value of innovation in our transportation fuels. We urge federal and state regulators come to a similar understanding and encourage use of the fuel solutions readily available.