Advanced Biofuels USA Signs on to Letter to EPA Urging the Agency to Adopt Volkswagen of America’s Proposal for Establishing the E85 Weighting Factor (“F factor”) for Model Year 2016-2025 Dual Fuel Vehicles.

by Joanne Ivancic (Advanced Biofuels USA) Advanced Biofuels USA signed on to a letter to the U.S. Environmental Protection Agency (EPA) urging the agency to adopt Volkswagen of America’s proposal for establishing the E85 weighting factor (“F factor”) for model year 2016-2025 dual fuel vehicles. The letter was signed by over 50 agricultural, conservation, clean city, public health and biofuel value chain partners who came together to stand up for the autos.
The letter explains that the guidance in the VW proposal "is critical to incentivize the continued production of flex fuel vehicles (FFVs) and to support the further advancement and deployment of biofuels into the nation’s liquid transportation fuel pool; fuels which are essential to reducing greenhouse gas (GHG) emissions and enhancing air quality."
It continues, "Providing enhanced incentives for FFVs would create parity with other alternative fuel vehicles and level the playing field for the sale of FFVs. It is therefore crucial that EPA provide the regulatory framework that encourages the continual introduction and expansion of FFVs as part of the overall advanced fuel vehicle technologies portfolio. FFVs will support the consumption of alternative transportation fuels in the marketplace and provide immediate GHG benefits. Without additional regulatory incentives to manufacture FFVs, automobile manufacturers may focus on other alternative vehicle technologies as a means to comply with the challenging 2017-2025 GHG and CAFE standards, resulting in fewer FFVs in the marketplace.
Furthermore, continuing to incentivize the production of FFVs helps facilitate successful implementation of the Renewable Fuel Standard (RFS) program. Increased use of E85 and midlevel blends in FFVs offers a readily available pathway for regulated entities to help meet the goals of the RFS."
And, "The use of E85 and midlevel ethanol blends in FFVs represents the most cost-effective and efficient way to help meet the ambitious new federal standards for reducing petroleum use and tailpipe emissions. Ethanol and other advanced biofuels facilitate CO2 emission reductions both within the vehicle, and, more importantly, throughout their production life cycle."
Advanced Biofuels USA, an educational nonprofit organization dedicated to promoting the understanding, development and use of advanced biofuels has long touted the benefits of high octane/high ethanol blends. See our white paper, New Engine Technologies Could Produce Similar Mileage for All Ethanol Fuel Mixtures (https://advancedbiofuelsusa.info/uploads/old/New-Ethanol-Engine-Tech-Revised-Aug-2012-Formatted.pdf) and our statements related to recent Tier 3 proposals available on our home page, www.AdvancedBiofuelsUSA.org.
Organizations signing on to this letter include:
25x'25 Alliance
Advanced Biofuels USA
Agricultural Retailers Association
American Coalition for Ethanol
American Council on Renewable Energy
American Farm Bureau Federation
American Seed Trade Association
Association of Equipment Manufacturers
Chicago Area Clean Cities
Clean Fuels Development Coalition
Clean Fuels Foundation
Clean Fuels Ohio
CoBank
Colorado Corn
CropLife America
East Tennessee Clean Fuels Coalition
Eastern Pennsylvania Alliance for Clean Transportation
Environment and Energy Study Institute
Ethanol Across America
FlexFuel Awareness Campaign
Genera Energy
Genesee Region Clean Communities, Inc.
Greater Indiana Clean Cities Coalition
ICM, Inc
Illinois Corn Growers Association
Illinois Renewable Fuels Association
Iowa Corn Growers Association
Iowa Renewable Fuels Association
Kansas Corn Growers Association
Kentucky Corn Growers
Las Vegas Regional Clean Cities Coalition
Maryland Grain Producers Association
Minnesota Clean Cities
Minnesota Corn Growers Association Missouri Corn Growers Association
National Association of Conservation Districts
National Corn Growers Association
National Farmers Union
Natural Resource Solutions
NC Clean Energy Technology Center
Nebraska Clean Cities Coalition
Nebraska Corn Board
Nebraska Ethanol Board
Nebraska Ethanol Industry Coalition
Nebraska Farmers Union
North Dakota Clean Cities
Northeast Ohio Clean Transportation Coalition
Ohio Corn & Wheat Growers Association
Renew the Earth
Sapp Brothers Petroleum
Schmitt Industries
South Carolina Clean Energy Business Alliance
Transportation Fuels Consulting
Urban Air Initiative
Virginia Clean Cities
READ MORE and MORE (Agi-Pulse) Download VW FFC F Factor Proposal Download letter EPA Response 11/12/2014

Excerpt from Agri-Pulse article: Along with issuing its year-overdue FFV guidance and its nearly year-overdue Renewable Fuel Standard volume requirements for 2014, (25x'25 Project Coordinator Ernie) Shea says, EPA needs to take a broader look at the increasing benefits from growing plant materials as feedstocks for both liquid transportation fuels and combined heat and power plants. Shea points to a series of recent studies showing that EPA has failed to account for the full benefits provided by replacing petroleum fuels with
biofuels.
Shea says that unfortunately, “EPA is not adequately synchronizing their decisions so that they work in harmony to deliver the benefits that the research community is showing us are possible.”
Thanks to new technology at all levels of the biofuels production process, Shea points out, “We’re delivering a much cleaner biofuel that is getting better and better compared to petroleum gasoline. Biofuels are getting cleaner while petroleum fuels, because they are now being produced from tighter, dirtier crude oil, are getting more carbon intensive. Their carbon intensity is going up while biofuels carbon intensity continues to go down.” But until EPA catches up with the latest science, he warns, “We’re missing out on the full benefits that biofuels can deliver to
the nation.”
To move biofuels forward, 25x’25 and its partner organizations will be meeting with EPA officials along with senior officials at USDA, DOE and the Department of Defense to discuss how greater availability of flex fuel vehicles can reduce greenhouse gas emissions while improving national security. READ MORE

Excerpt from EPA November 2014 Response: For the 2016-2018 model years, manufacturers of E85-fueled FFVs may use F=0.14 in the calculation described in 40 CFR 600.510-12(j)(2)(vi). A manufacturer’s use of F=0.14 is optional; manufacturers may continue to use the default value of F=0, thus not taking account of the E85 carbon-related exhaust emissions (CREE) value (or they may determine and seek approval for their own manufacturer-specific F factor, as described above). Manufacturers may continue to use F=0.14 through the 2018 model year. EPA will establish a value of F for model years 2019 and later in future guidance. The derivation of F=0.14 for model years 2016-2018 is described in the attachment to this letter, which includes a review of public comments received on the draft guidance. The 0.14 F factor may not be used beyond the 2018 model year. READ MORE