Draft TAR is Important Step in Emission Reduction Efforts, But Omits HOLC Discussion

The federal Department of Transportation, EPA and the California Air Resource Board (CARB) this week released the highly anticipated draft Technical Assessment Report (TAR), a 1,200-plus page document 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.

The TAR is part of a “mid-term evaluation” – an assessment that is an important marker in the Obama administration’s effort to strengthen fuel economy standards, reduce emissions from the transportation sector and meet climate change goals laid out in the global agreement reached in Paris last December.

By releasing the draft report, EPA and DOT’s National Highway Traffic Safety Administration (NHTSA) fulfill a commitment made back in 2012 as part of the rulemaking process that established the “National Program” for fuel economy standards, improved vehicle efficiency and emission reductions. The draft TAR released this week covers model years 2022-2025. A final determination on whether or not the 2022-2025 standards set four years ago are appropriate is expected by April 1, 2018.

The incredible depth of the report is a challenge that stakeholders must dive through in analyzing exactly what it says.

Still, a cursory run through the massive document makes it clear that the low price of gasoline, which is expected to continue for some time to come, is skewing the auto consumer market back toward bigger, less efficient vehicles, like pick-up trucks, vans and SUVs. And that trend has some in the auto industry telling the federal agencies that it will make it more difficult to meet the 2025 fuel efficiency goals set back in 2012.

But the draft TAR also shows that automotive manufacturers are innovating and bringing new technology to market at a pace much more rapid and cost-effective than originally thought. That ‑ says the TAR’s authors ‑ means manufacturers will be able to meet the model year 2022-2025 standards established four years ago. The report also shows that manufacturers will be able to meet the stricter standards at similar or even a lower cost than was anticipated in the 2012 rulemaking, with substantial savings on fuel costs for consumers.

The TAR is heavy on technology, including aerodynamics, drivetrains, engine tech and hybridization, as well as addressing at length consumer experience and habits. Not surprisingly, the TAR contains a number of assumptions that will likely be the subject of much debate.

For example, the agencies’ assessment is that ‑ as was concluded in the 2012 rule ‑ high penetration levels of alternative fueled vehicles will not be needed to meet the MY2025 standards, with the exception of a very small percentage of passenger electric vehicles. The report also claims cost savings on fuel will offset increased technology/production costs, and that compliance can be met with advanced gasoline engine technology.

However, a glaring omission from the report 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 since 2012. 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) gasoline would increase fuel efficiency and reduce tailpipe carbon emissions by seven percent each.

A 60-day comment period on the draft TAR will commence once a formal notification is published in the Federal Register. We will have more to report once we complete our review. Meanwhile, 25x’25 partners – in fact, all stakeholders – are urged to do their own analysis of the report. It is crucial that all stakeholders comment and stress to EPA the importance of including a detailed discussion of high-octane, low-carbon fuels in the midterm review. These mid-level ethanol blends can be a critical tool in meeting this nation’s climate change goals, a pursuit at the heart of the fuel efficiency effort.

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