Comments on the Draft Technical Assessment Report for Model Years 2022 – 2025 Greenhouse Gas Emission and Fuel Economy Standards Submitted by Minnesota and Illinois Growers

(Minnesota Corn Growers Association Minnesota Corn Research and Promotion Council and the Illinois Corn Growers Association) Early this year, the Minnesota Corn Research and Promotion Council approved a research grant to Defour Group LLC (D4) and Air Improvement Resource INC (AIR) to download the publically available OMEGA computer model developed by the US Environmental Protection Agency. Once downloaded, the researchers were asked to use that mode to, estimate the impact of a combination of high octane low carbon (HOLC) fuel and high compression engines (HCE) on the cost to consumers of complying with the 2022 – 2025 greenhouse gas emission standards. This study concluded that such technology could reduce the cost of the average MY 2025 vehicle by over $400.

The Draft Technical Assessment Report concerning these standards was the beginning of the agencies’ mid‐term evaluation process, which, among other things, is to consider “technical and other analyses and projections relevant to each agency’s authority to set standards as well as any relevant new issues that may present themselves.” We believe the research done by AIR and D4 is the kind of analyses the agencies intended to consider during the mid‐term review process, Therefore, these comments and the supporting attachments are hereby being submitted to the docket for your consideration.

One of the “relevant new issues” that has emerged since 2012 has been the potential to reduce greenhouse gas emissions by a combination of higher efficiency spark ignition engines and a high octane low carbon (HOLC) fuel such as a 25% ethanol – 75% gasoline blend called E25. As discussed in the TAR2, the Department of Energy (DOE) is conducting a program called Co‐Optima (Co‐Optimization of Fuels and Engines) that intended to determine “improving near‐term efficiency of spark‐ignition (SI) engines through the identification of fuel properties and design parameters of existing base engines that
maximize performance. The efficiency target represents a 15% fuel economy improvement over state‐of-the‐art, future light‐duty SI engines with a market introduction target of 2025 … By using low‐carbon
fuels, such as biofuels, GHGs and petroleum consumption can be further reduced.”

Co‐optimizing fuels and engines or the ongoing process of research and development of technologies in
the auto industry and the national laboratories clearly offer the potential to reduce greenhouse gas
emissions using methods and applications of technologies that were not comprehended in the original
rulemaking. Past evaluations3 indicate that a combination of higher compression engines and a lower
carbon fuel could achieve these standards at much lower cost than many of the strategies considered
for the 2017 – 2025 timeframe. Thus, it is essential to include detailed discussion of this concept,
including the results from industry research, DOE’s Co‐Optima program and other new information, in
the final version of this TAR. READ MORE/Download Comments Download study