Isobutanol: Now on the Radar for USA COMMENTS DUE April 30, 2018

by Jess Hewitt (Biofuels Digest/Lee Enterprises Consulting) The Environmental Protection Agency (EPA) has opened a comment period for the registration of the use of Isobutanol in gasoline. Why is this important? Because since the states banning of the use of MTBE and other ethers in underground tanks, this is the only oxygenate, other than ethanol, allowed to be used in commerce. This is a significant event as it will allow the US consumer to choose oxygenates.

Many parts of the United States are classified as non-attainment areas, or opt-in areas, for pollution. They have rules that require the use of Reformulated Gasoline (RFG). In these RFG areas, no gasoline can be sold in commerce unless it contains an oxygenate. For many consumers, this means that if they want to buy an ethanol-free gasoline, they are limited to buying very small containers of conventional gasoline – at a cost of up to $28 per gallon.

In a modern car, the fuel system is sealed. When one opens the fuel door, they will see the warnings on the filler cap: “Caution, Remove Slowly, Fuel Spray May Cause Injury. Tighten until Cap Clicks.” These warnings are necessary because the fuel systems in modern cars run in a vacuum condition to prevent atmospheric moisture from coming in contact with the gasoline. Thus, when we hear the “clicks” on the gas cap, it is confirmation that the cap has sealed the fuel filler tube and that the system can now remove the air and create a vacuum. That’s also why we may hear the “swish” sound of air entering the tube when we remove the cap.

The National Marine Manufacturer’s Association (NMMA) has been studying these issues and testing solutions: In 2015, they endorsed the use of gasoline using isobutanol over any ethanol-based gasolines. They did this at about the same time as the government allowed the sale of E15, a gasoline blend with 15% ethanol.

Back to the Future

Essentially, as a nation, we are regressing back ten years to a time when the USA had a choice of oxygenates. Many oxygenates had long names, but were known by their initials – MTBE, ETBE and TAME. At that time, using ethanol as an oxygenate rendered the gasoline mixture a “gasohol.”

The ethers that were in use in 2007 are still legal today by federal standards. However, states have outlawed their use in underground storage tanks. Isobutanol has not been outlawed and it meets federal standards. And, isobutanol is available in renewable and non-renewable versions.

I don’t believe the EPA will have any problem registering the Isobutanol based gasoline. However, they are asking for public comments. Every person, and company, has the right to provide comments about the questions raised by the EPA:

The EPA has invited all comments, stating that “we are seeking public comment regarding any issues we should take into consideration for this registration and any supplemental actions we should consider under the Clean Air Act to further protect public health and welfare.” Thus, anyone can offer any other comments on the issues.

I expect to see some comments about the need for refiners and blenders to produce the gasoline blendstock called Reformulated Gasoline Blendstock for Oxygen Blending (RBOB) that can be blended with ethanol or isobutanol. Ten years ago, when refiners created the RBOB, they produced a “Product Transfer Document (PTD)” that would allow blending of any alcohol oxygenate. But since the switch to ethanol, many refiners and blenders created an exclusive RBOB that could only be used with ethanol.

I find it difficult to believe that refiners are making RBOB exclusively for use with ethanol. However, it is happening and our anecdotal survey of refiners says that many will not change their PTD to allow use of Isobutanol.

When asked why they will not create gasoline blendstock for Isobutanol the answers are almost always the same, and some are surprising:

These factors will weigh down the use of Isobutanol in the short term and the blending might stay where it is now – downstream of the petroleum terminal delivery system.

Much Isobutanol is blended into gasoline outside of the terminal system by a combination of gasoline retailers and oxygenate blenders. Currently, Gulf Racing Fuels is making an off-road Isobutanol-gasoline mixture for boats called “Gulf Marine”. Due to the factors listed above, the fuel is splash blended on petroleum transporters to get it to the retailer.

Retailers understand that there is a demand for this product and the price is nearly completely inelastic – for a small segment of the marketplace. Consumers who want ethanol-free fuel are given the choice of a quart of pure gas at a hardware store that sells for the equivalent of $28 per gallon, or they can find a gasoline retailer who offers an Isobutanol-blended gasoline for about $4-5 per gallon. The market is proven, but retailers are stymied by the lack of infrastructure to blend the gasoline.

There will be much discussion about Isobutanol-blended gasoline going into pipelines. Remember that pipelines approved the transportation of gasoline with non-hygroscopic alcohols more than ten years ago. However, the pipeline has to deliver the fuel into a tank at the terminus of the pipeline and if that tank has RBOB dedicated to ethanol then no Isobutanol-blended gasoline can enter the tank. So, although pipelines can carry the blend they don’t have anywhere to deliver it.

Gasoline Retailers: Mixing Ethanol and Isobutanol is a No-no

One of the other reasons that the new gas will be limited in distribution is the EPA’s no blend rule. The EPA will not allow ethanol and isobutanol gasolines to be mixed together at any point prior to retail purchase. Any gasoline retailer using what is commonly referred to as a “blender pump or dispenser” will not be able to offer a midgrade product if ethanol-based gasoline is also offered. You see, in most gas stations three grades of gasoline are offered, regular, mid-grade and premium. There are only two storage tanks and one contains regular and the other contains premium. The dispenser mixes the two together to make the mid-grade gas.

This means that any retailer who offers a premium isobutanol gasoline alongside an ethanol-based regular gas cannot produce a mid-grade combination due to the EPA restriction. Most retailers simply turn off the blender make the mid-grade 100% premium and price it accordingly.

I believe the outcome will be that EPA requires Tier 2 and 3 testing of the gasoline additive. Major industry groups will align themselves on one side or the other and this issue may well see opposing members agreeing with their historic foes. I believe that consumer demand will become apparent to the EPA which will hopefully cause reconsideration of the restrictions on the use of this fuel. As the legislation is founded in rules legislation, the EPA may be limited as to what they can do. I do not believe that the EPA will be able to change the PTD rule, despite the likelihood that any gasoline blendstock that qualifies ethanol for blending could also produce a gasoline within specification for isobutanol. READ MORE