ACE Urges NHTSA to Develop a More Technology-Neutral Approach to Meet Fuel Economy Standards

October 17, 2023

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(American Coalition for Ethanol) American Coalition for Ethanol (ACE) CEO Brian Jennings submitted feedback to the National Highway Traffic Safety Administration (NHTSA) today on its proposed rulemaking for Corporate Average Fuel Economy Standards for Passenger Cars and Light Trucks for Model Years 2027–2032 and Fuel Efficiency Standards for Heavy-Duty Pickup Trucks and Vans for Model Years 2030–2035, calling on NHTSA to develop a technology-neutral approach to meet fuel economy standards and decarbonize transportation fuel.

“In contrast to NHTSA’s proposed rule and the Environmental Protection Agency (EPA) so-called “multipollutant proposal” for model years 2027 through 2032, we support technology-neutral policies which provide market participants with a host of options for compliance, because the tasks of decarbonizing the transportation sector and maximizing fuel economy are too important and complex for a one-size-fits-all solution,” Jennings stated in submitted comments.

ACE’s comments discuss 1) legal problems associated with the proposal including vehicles that operate only on electricity, 2) the economic feasibility of NHTSA’s proposed rule, 3) energy security and environmental concerns about the proposal, and 4) how high-octane fuels such as higher ethanol blends should be part of the solution to achieve fuel economy standards and reduce carbon pollution from transportation emissions.

First, according to the Energy Independence and Security Act of 2007, Congress clearly states NHTSA may not consider the fuel economy of electric only vehicles. Second, the one-size-fits-all solution, proposed by NHTSA and EPA, with respect to decarbonizing and improving the efficiency of the U.S. light-duty vehicle transportation sector is not economically feasible. Third, whereas the U.S. must rely on foreign nations to supply the U.S. with the critical minerals and batteries needed for electric vehicles, the U.S. is the world’s leading producer of corn feedstock for making fuel ethanol and the top supplier of ethanol as well. Fourth, ethanol delivers the highest octane at the lowest cost, allowing automakers to benefit by continuing to develop high-compression engines to achieve efficiency improvements and reduced emissions.

“If the overarching goal for the Biden Administration is net-zero emissions by mid-century, let’s start making progress right now by taking full advantage of the 15 billion gallons of domestically produced ethanol available today as an affordable way to boost octane and meaningfully reduce GHG emissions from gasoline powered engines,” Jennings comments concluded.

To access ACE’s full comments, click here. READ MORE

Groups Call on NHTSA to Rethink Proposed CAFE Standards that Weaken Energy Security (Renewable Fuels Association)

Ethanol Blog: Ag, Biofuels Groups Say Fuel Economy Standards Place Overreliance on EV (DTN Progressive Farmer)

Renewable fuel, transportation groups attack fuel economy proposal: The groups argued the Department of Transportation rule threatens national energy security and improperly favors electric vehicles. (Politico Pro Greenwire)

CAFE standards become front lines in EV war: The Biden administration's plans to strengthen fuel economy are being cited by industry groups as a back channel ban on gasoline cars. (Politico Pro Climatewire)

Automakers Blast US Plan to Hike Fuel Efficiency Rules (Reuters)

Ethanol supporters argue for fuel diversity: Rather than promoting electric vehicles, the government should adopt “a diversified portfolio of approaches” in the transportation sector such as flex fuel vehicles, said three ethanol advocates on Monday. (Successful Farming)

Growth Energy to NHTSA: Biofuels Must Be Part of CAFE Standards (Growth Energy)

Excerpt from Renewable Fuels Association: The National Highway Traffic Safety Administration’s proposed new fuel economy standards “greatly missed the intent” of the Corporate Average Fuel Economy program to enhance energy security, according to technical comments filed today by the Renewable Fuels Association, National Farmers Union and National Corn Growers Association. The proposal, they assert, will lead to an overreliance on foreign critical minerals due to its myopic dependence on electric vehicles.

“As NHTSA determines the appropriate CAFE and fuel efficiency standards, it should avoid putting all our eggs in the electrification basket,” the three national trade associations wrote. “NHTSA’s current proposal greatly missed the intent of the CAFE program. As Congress has acknowledged, solving energy security and air pollution issues related to the transportation sector requires a diversified portfolio of approaches.”

The associations noted an overreliance on electric vehicles that ignores specific challenges of these new vehicles, such as “the increased energy security vulnerabilities flowing from the critical minerals needed for electric vehicle batteries,” as well as the feasibility of the auto industry to produce sufficient volumes, secure needed critical mineral supplies and develop an appropriate workable charging station infrastructure.

The comments conclude with a call on NHTSA to work with the U.S. Environmental Protection Agency to reinstitute strong incentives for flex fuel vehicles that use lower-carbon, American-made ethanol.

“Whether FFVs currently run on gasoline or E85, building up the portion of the fleet capable of running on E85 gives the country an additional option to address potential future oil or critical mineral crises in a way that can protect our national security and reduce greenhouse gas emissions,” the comments state. “Given vehicles’ long useful life, EPA and NHTSA should not wait for a crisis to incentivize FFVs. It will be too late to act if they are suddenly needed to address a crisis. Instead, the country should plan ahead and build fuel diversity into the system now.” READ MORE

Excerpt from Growth Energy:

Growth Energy highlighted just some of the proven emissions benefits of biofuels like ethanol in its comment, while also noting that NHTSA’s proposed standards may violate the Energy Policy and Conservation Act (EPCA), in particular the law’s prohibition on using electric vehicles (EVs) as a “baseline” to set fuel-economy standards and the law’s focus on using domestic energy sources to address America’s energy challenges.

“In setting the CAFE Standards, NHTSA is directed by EPCA to consider, among other factors, ‘the need of the United States to conserve energy.’ Increasing the nation’s use of biofuels meets that goal, by both providing another source of fuel that reduces our demand for petroleum and by reducing greenhouse gas (GHG) and other emissions,” said Growth Energy in its comments. “To begin with, ethanol and other biofuels significantly enhance energy security because of their flexibility—they can be used in existing internal combustion engine (ICE) vehicles and fueled at existing gas stations. Consumers and operators of fleets around the country therefore have the ability to use more biofuels.”

To address its issues with the proposal, Growth Energy recommends that NHTSA remove EVs from its calculations in setting a baseline for the 2027-2032 CAFE standards; consider the GHG-reduction and energy security benefits of biofuels throughout the final rule; and preserve and expand its rules to allow for greater use of higher ethanol-blended fuels like E15 (15% ethanol), E85 (51%-85% ethanol), and other blends in between.

Read Growth Energy’s full comment here. The organization also expressed similar concerns to the U.S. Environmental Protection Agency (EPA) about its vehicle tailpipe emissions standards earlier this year. Learn more about Growth Energy’s actions on this topic at growthenergy.org/tailpipe-emissions. READ MORE