Advanced BioFuels USA

(Advanced Biofuels USA)  As part of the recently proposed Tier 3 motor vehicle fuel and emission regulations, EPA included a very forward looking idea that could bring higher octane, higher ethanol gasoline to the marketplace.
However, Advanced Biofuels USA recommends the following changes to assure consumers get maximum fuel economy and climate change mitigation benefits from the EPA proposed higher octane, higher ethanol gasoline.

• 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 Tier 3 regulations should not require individual vehicle manufacturers to certify the availability of this fuel. Instead, EPA should use their 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 CO₂ reduction 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, “E30 capable/E30 optimized regular” fuel.

• EPA should also provide flexibility in the Tier 3 regulations 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 Tier 3 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.”
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.”  READ MORE and MORE and MORE (DomesticFuel.com)   Download Complete Advanced Biofuels USA Comments PDF    Download Press Release   Read all comments