Advanced Biofuels USA Submits Comments on CAFE Standards Midterm Review

September 30, 2016

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(Advanced Biofuels USA) Advanced Biofuels USA fully supports meeting the 2022 CAFE standards. It is our understanding that the key to vehicle manufacturers meeting these standards rests on the ability to use high levels of low cost octane to operate their advanced technology turbo-charged engines at the highest level of efficiency possible.

Advanced Biofuels USA recommends the following to assure manufacturers are able to produce the maximum fuel economy required by the 2022 CAFE standards, along with maximum climate change mitigation benefits, from higher octane, higher ethanol content fuel.

Advance Biofuels USA fully supports EPA’s recognition of the importance of higher octane, higher ethanol (in the range of E30) gasoline as a cost-effective way to allow manufactures to maximize the efficiency of smaller, more efficient engines that utilize high combustion pressures to meet 2022 EPA CO₂ vehicle emission standards.

To provide a smooth path to making this “higher octane, higher ethanol content gasoline” available nationwide EPA should use its authority under section 211 of the Clean Air Act to provide for the commercial availability of this “higher octane, higher ethanol content gasoline.”

In using the Clean Air Act authority to assure that “higher octane, higher ethanol content gasoline” is available nationwide, EPA should implement a reasonable phase-in schedule tied to manufacturer production plans required to meet 2017 and later EPA GHG requirements. This schedule should be based on the “vehicles would not operate appropriately on other available fuels, and such a fuel would result in equivalent emissions performance,” information.

EPA should allow vehicle manufacturers that certify new vehicles with the “higher octane, higher ethanol content gasoline” to also certify that those vehicle are able to also operate on existing E10 or E15 fuels. These vehicles would be called “E30 capable.”

By building up the number of these “E30 capable” vehicles that could get the same mileage with a lower cost fuel, the demand for E30 would increase. This demand would create a nationwide E30 infrastructure that would then allow for the marketing of “E30 Optimized” Vehicles designed to provide the fuel economy and GHG reductions necessary to meet 2022 CO₂reduction standards.

Since a higher proportion of lower cost ethanol is used to produce E30, the “higher octane, higher ethanol content gasoline” would probably not be priced above current 87 octane E10 regular. Therefore, it should not be referred to as “premium” fuel in final regulations or for purposes of marketing but rather should be labeled differently. For example, “Unleaded30” fuel.

EPA should also provide flexibility so that other renewable, negative GHG (as compared to petroleum) octane additives could be substituted for 30% ethanol when they are commercially available. In order to qualify, these additives should have to meet the applicable EPA regulations for fuel composition, aromatic content, and certification testing. This flexibility would promote competition in the biofuel marketplace that would result in the most sustainable low GHG solutions possible.

By adopting a flexible, market-based higher octane, higher ethanol content gasoline program, EPA would send a clear Demand Certainty Signal to markets and fuel providers. This clear signal will provide the currently missing certainty to the financial markets that will be needed to provide the capital for total-biomass ethanol and other advanced biofuel plants that will be needed to provide the “higher octane, higher ethanol content” which will drive the markets for efficient vehicles that will enable manufacturers to meet the 2022 CAFE standards.

This clear market signal would be the most effective way to meet EPA’s stated goal to, “provide a market incentive to increase ethanol use beyond E10 and enhance the environmental performance of ethanol as a transportation fuel by using it to enable more fuel efficient engines.”

Additional Specific Comments

EPA has the Authority under Section 211 of the Clean Air Act to Implement Nationwide Marketing of “Higher Octane, Higher Ethanol Content Gasoline”

Basis for Action under the Clean Air Act

Clean Air Act Section 211

The establishment of a higher fuel octane gasoline standard would reduce CO₂ emissions from direct injection/turbocharged/high compression engines below what they would be with lower octane, lower ethanol content gasoline. This reduction in CO₂ emissions, which have previously been determined by EPA to endanger public health and welfare as climate change inducing Greenhouse Gas (GHG) emissions, would come from two effects:

These engines would run at higher efficiency with the higher octane fuel meaning less fuel/mile would be used resulting in less CO₂ emissions/mile.

The increase from 10% to approximately 30% ethanol would decrease life-cycle GHG emissions when compared to the petroleum gasoline components it would replace. This decrease would become especially significant as proportion of total biomass (i.e. cellulosic) ethanol increases in accordance with the previously enacted Renewable Fuel Standard (RFS).

In making this determination to require higher octane, higher ethanol content gasoline, it is also important to recognize that these interrelated engine design features (the Ford Ecoboost is an example) are being implemented for the sole purpose of meeting the 2022 EPA CO₂/DOT mpg standards while also providing enough power to compensate for the extra weight requirements of DOT safety standards, and are not being introduced for high performance reasons. Therefore, engines using this integrated package of design features are as much emission control devices as the catalytic converters that caused EPA to issue lead elimination and sulfur reduction fuel control regulations to ensure lower HC, NO_x, and CO emissions.

“R” Factor Requirement

In order to provide equality in EPA fuel economy calculations for higher octane, higher ethanol fuels, the “R” fuel energy content factor should be set at “1.” This change is necessary since EPA has previously recognized that the engine technology used to set the “R” in the 1970s has reached levels of efficiency not envisioned at the time and as a result the factor does not represent the current reality.

Gasoline Blend Stock Requirements for Higher Octane, Higher Ethanol Fuels

In order to provide consistent octane in the E30 range blended fuel as well as consistency with the other commercial grades of ethanol blended fuels offered, E10 and E15, the octane of the current gasoline blend stock (BOB) shall be maintained.

Use of this gasoline feedstock would also allow the production of a Higher Octane, Higher Ethanol Fuel blend with the current rack mixing approach thereby not requiring any additional fuel system infrastructure costs.

Allow Optional Renewable Higher Octane Additives

While biomass, cellulose/hemicellulose/pectin, (“cellulosic ethanol” in RFS2) derived ethanol is the current primary octane enhancing component foreseen for Higher Octane, Higher Ethanol Fuel, other biofuel derived additives could be used provided the following four criteria are met:

Life Cycle GHGs of the alternative additives are within 110% of industry wide life-cycle GHG emissions of the biomass ethanol used at the time of the introduction of the alternative additives.

The composition of the bio-base fuel components do not exceed EPA or CARB, whichever is lower, aromatic or other fuel composition standards in effect at the time of their introduction.

The use of such fuel components would not materially effect the cost of vehicle certification testing procedures.

The use of such fuel components would not materially affect any fuel system or engine components of the vehicles in which they are used.

A Real-World Example of How the Performance Benefits of High Octane High Ethanol Fuel Can Result in Purchases of More Efficient Vehicles

A recent study done by Air Improvement Resource (AIR) under a research grant by the Minnesota Corn Research and Promotion Council used EPA's OMEGA model to calculate what per vehicle savings would have been realized if EPA had included high compression engines and high octane low carbon fuel (in this case, E25) as a technology package in the Technical Assessment Report.

This study presented results that showed higher ethanol blends had a greater positive effect on emissions and performance under heavy load conditions. While the study calculated that on average vehicles were only driven in these conditions for about 20% of total miles, it is important to note that these conditions use a disproportionate share of energy in overcoming vehicle inertia. So when looking at total fuel use for a trip, the heavy load miles, while only 20% of the total, may use up to 40% or more of the trip's fuel. Especially, if those heavy load conditions included non-planned mergers and lane changes on Interstate highways. Therefore, any improvements in heavy load fuel economy will also be disproportionately positive.

To demonstrate this effect, if fuel economy during freeway merge and other high load conditions improves from 5 mpg to 7.5 mpg with the use of E25, that is a 50% fuel economy improvement while the same 5 mpg improvement during steady state cruise at 30 mpg is only a 16.6% improvement. (These mileage figures are representative of a current average US vehicle.) To measure the impact of these mileage improvements consider a 100 mile trip with 20% (20 miles) in the heavy load mode and 80% (80 miles) in cruise. This is a daily commute from the external suburbs of metropolitan areas such as Washington DC, Atlanta, Houston, or Chicago. At the end of the 100 miles 1.3 gallons were saved in the heavy load mode due to high ethanol content (2.7 gallons instead of 4 gallons) while only .4 gallons were saved over 4 times the distance (2.9 gallons instead of 3.4 gallons). In fact to equal the fuel savings of 1.3 gallons would require 280 miles of cruising.

Therefore, while the fuel savings of high ethanol content fuel combined with higher compression engines are primarily limited to high load driving conditions these fuel economy improvements represent the majority of fuel economy gains that can be accomplished with vehicle and engine technology that will be in production through 2022. Furthermore, and more important, the use of higher ethanol content fuels could produce these improvements without additional vehicle costs since the increased octane would allow engines such as the Ford EcoBoost to perform at the maximum efficiency already designed and programmed into them.