Advanced BioFuels USA

by Rachel Gantz (Renewable Fuels Association)  A high-octane, low-carbon fuel containing 20-40% ethanol used in optimized engines would be the lowest cost means of achieving compliance with fuel economy and greenhouse gas standards for model year 2021-2026 and beyond, Renewable Fuels Association (RFA) Vice President of Regulatory Affairs Kelly Davis will testify today at a public hearing in Pittsburgh.

The Environmental Protection Agency (EPA) and the National Highway Traffic Safety Administration (NHTSA) are holding today the third and final public hearing on their joint proposal for 2021-2026 fuel economy and greenhouse gas standards. As part of the proposal, the agencies requested comment on how high-octane fuels could facilitate engine efficiency improvements and reduced emissions under 2021-2026 fuel economy and tailpipe GHG standards for light-duty automobiles.

“Clearly, pairing advanced internal combustion engine technologies like high compression ratio and turbocharging with high-octane low carbon fuels would result in far greater fuel economy and emissions benefits than previously contemplated by EPA and NHTSA,” Davis will testify.

The proposal also highlights previous recommendations from the High Octane Low Carbon Alliance (HOLC), of which RFA is a founding member. “Consensus is building around the need for High Octane Low Carbon fuels to enable greater engine efficiency and reduced emissions. Automotive engineers and executives, government scientists, expert panels, and university researchers have called for a higher minimum octane rating for future fuels,” Davis will testify.

“Research by the Department of Energy and others has demonstrated that ethanol is an ideal source of octane for such high-octane fuel blends,” Davis will say. “A high-octane fuel (98-100 RON) could be produced today simply by blending 25-30% ethanol with existing gasoline blendstocks. However, due to the inertia of fuel and vehicle markets, this transition will not occur on its own. Action by the EPA is necessary to catalyze the development and introduction of high octane low carbon fuels into the consumer market, just as EPA action was required to eliminate lead, limit benzene, and reduce the sulfur content of our gasoline and diesel fuel,” she will testify.

In her testimony, Davis will also ask the agencies to use this rulemaking to establish the roadmap for increasing the minimum octane rating of gasoline to 98 RON and ensure automakers are afforded credit toward these fuel economy requirements for building engines that require these higher-octane fuels.

A copy of Davis’s prepared remarks is here.  READ MORE

TESTIMONY OF KELLY DAVIS
VICE PRESIDENT REGULATORY AFFAIRS, RENEWABLE FUELS ASSOCIATION
U.S. ENVIRONMENTAL PROTECTION AGENCY
PUBLIC HEARING
RE: Request for Comment – Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule for
Model Years 2021-2026 Passenger Cars and Light Trucks
(Docket No. EPA-HQ-OAR-2018-0283 and/or NHTSA-2018-0067)
Pittsburgh, PA
September 26, 2018

Good morning. My name is Kelly Davis and I am Vice President for Regulatory Affairs at the Renewable Fuels Association, or “RFA.” RFA is the leading trade association for America’s ethanol industry. Its mission is to advance the development, production, and use of fuel ethanol by strengthening America’s ethanol industry and raising awareness about the benefits of renewable fuels.

We appreciate the opportunity to share our thoughts on the Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule for Model Years 2021-2026 Passenger Cars and Light Trucks. If properly designed and implemented, we believe future Corporate Average Fuel Economy and Green House Gas standards can work in tandem with programs like the Renewable Fuel Standard (RFS) to advance the important policy objectives of reducing fossil fuel consumption and decreasing transportation-related emissions.

RFA was actively involved in the previous administration’s public process surrounding the mid-term review of 2022-2025 standards, and we were disappointed by the premature and seemingly predestined outcome of that process. It was apparent that the previous administration disregarded comments from RFA and many other stakeholders—including the automakers—that encouraged EPA to evaluate engines and fuels as integrated systems when assessing the efficacy of model year 2022-2025 fuel economy and GHG standards. Indeed, the fuels that we put in our engines can have as much impact on fuel economy and GHG emissions as the engine technologies themselves.

Thus, we were very pleased that the SAFE Vehicles proposal considers the important role that fuels play in determining engine efficiency and emissions. We believe this rulemaking offers a critical opportunity to advance fuel economy standards and reduce emissions by enabling the increased production and use of higher octane, carbon reducing liquid fuel options. The most recent science and research clearly shows that high octane, low carbon fuels– especially midlevel ethanol blends containing 20-40 percent ethanol–can enable auto manufacturers to meet more stringent CAFE and GHG standards, while providing consumers with affordable fuel choices.

We are encouraged that EPA and NHTSA have solicited comment on the “potential benefits… of considering the impacts of increased fuel octane levels available to consumers…” Further, we fully agree with the proposal’s statement that “Higher octane gasoline could provide manufacturers with more flexibility to meet more stringent standards by enabling opportunities for use of lower CO2 emitting technologies.” Consensus is building around the need for High Octane Low Carbon fuels to enable greater engine efficiency and reduced emissions. Automotive engineers and executives, government scientists, expert panels, and university researchers have called for a higher minimum octane rating for future fuels. These experts have clearly demonstrated that HOLC fuels would enable High Compression Ratio engines and other advanced internal combustion engine technologies, which in turn would improve engine efficiency and reduce emissions.

It is broadly understood that internal combustion engines will continue to serve as the predominant propulsion technology for light duty vehicles through 2025 and beyond. It is also well understood that there is significant room for further technology advances and efficiency gains in internal combustion engine technology.

That’s where the importance of fuel properties comes into play. Most of the engine technologies that lead to greater efficiency and lower emissions are enabled by higher octane fuels. As stated by Dan Nicholson, GM’s vice president of global propulsion systems, “Higher octane is necessary for better engine efficiency. It is a proven low-cost enabler to lower CO2; 100 RON fuel is the right fuel for the 2020-2025 timeframe.” For example, high-compression ratio technology (which EPA estimates will comprise 44% of the market by 2025) demands higher octane fuel to limit premature fuel ignition in the cylinder (otherwise known as “engine knock”).

Research by the Department of Energy and others has demonstrated that ethanol is an ideal source of octane for such high-octane fuel blends. Not only does ethanol offer an extremely high-octane number (109 RON, 108-119 “blending octane”), but it also features an unrivaled heat of vaporization temperature and extremely high octane sensitivity. These attributes make ethanol a highly attractive component for the high-octane fuel blends of the future.

Clearly, pairing advanced internal combustion engine technologies like high compression ratio and turbocharging with high-octane low carbon fuels would result in far greater fuel economy
and emissions benefits than previously contemplated by EPA and NHTSA. Further, research shows that using a high-octane low carbon mid-level ethanol blend in optimized engines would be the lowest cost means of achieving compliance with CAFE and GHG standards for MY2022-2025 and beyond.
A high-octane fuel (98-100 RON) could be produced today simply by blending 25-30% ethanol with existing gasoline blendstocks. However, due to the inertia of fuel and vehicle markets, this transition will not occur on its own. Action by the EPA is necessary to catalyze the development and introduction of high octane low carbon fuels into the consumer market, just as EPA action was required to eliminate lead, limit benzene, and reduce the sulfur content of our gasoline and diesel fuel.

In closing we respectfully ask that EPA and NHTSA use this rulemaking as an opportunity to establish the roadmap for increasing the required minimum octane rating of gasoline to 98 RON and ensure that automakers are afforded credit toward compliance with CAFE and GHG requirements for building engines that require these higher-octane fuels.

Thank you.

Ethanol Groups Testify on SAFE Vehicles Rule (Energy.AgWired.com)

Ethanol groups testify on the benefits of high-octane fuels (Ethanol Producer Magazine)

Excerpts from Energy.AgWired.com:  Growth Energy Vice President of Regulatory Affairs Chris Bliley testified at the Michigan hearing and discussed the benefits of high-octane, midlevel ethanol fuel blends in improving octane and lowering greenhouse gas and criteria pollutant emissions. “Ethanol has a very high-octane number, has a lower carbon content than the gasoline components it replaces, and has many other benefits that assist in combustion to increase engine efficiency and reduce both greenhouse gas and tailpipe criteria pollutant emissions,” said Bliley in his testimony.

American Coalition for Ethanol (ACE) CEO Brian Jennings also emphasized how ethanol-enriched, high octane fuel blends between 25 and 30 percent (in the 99-100 RON range) would enable automakers to simultaneously reduce greenhouse gas (GHG) emissions and improve fuel economy at the hearing in Pittsburgh. “Research indicates the use of 98 to 100 RON fuel containing at least 25 percent ethanol results in 3 to 9 percent efficiency gains in high-compression engines which are beginning to dominate the marketplace,” said Jennings.

Renewable Fuels Association (RFA) Vice President of Regulatory Affairs Kelly Davis also provided testimony at the Pittsburgh hearing. “Clearly, pairing advanced internal combustion engine technologies like high compression ratio and turbocharging with high-octane low carbon fuels would result in far greater fuel economy and emissions benefits than previously contemplated by EPA and NHTSA,” Davis said. READ MORE

Excerpts from Ethanol Producer Magazine:  In his testimony, Brian Jennings, CEO of ACE, emphasized how ethanol-enriched, high-octane fuel blends of 25-30 percent ethanol—in the 99-100 RON range—would enable automakers to simultaneously reduce GHG emissions and improve fuel economy.

“Research indicates the use of 98 to 100 RON fuel containing at least 25 percent ethanol results in 3 to 9 percent efficiency gains in high-compression engines which are beginning to dominate the marketplace,” Jennings said.

“Increasing the content of ethanol in gasoline is but one way to produce high octane fuel,” he continued. “We recognize refiners prefer 95 RON where additional octane is petroleum-derived and ethanol content is capped at 10 percent. Ultimately, however, EPA needs to weigh benefits and costs. In some wholesale markets today, unleaded gasoline costs nearly one-dollar-per-gallon more than ethanol.

“Not only will 98 to 100 RON fuel containing 25 to 30 percent ethanol save consumers compared to the premium-priced octane level being advocated by oil refiners, it is a more cost-effective approach for automakers to achieve meaningful efficiency gains and emission reductions,” Jennings said.

A 60-day public comment period on the SAFE Vehicles Rule opened Aug. 24. Comments can be filed online at www.reglations.gov under Docket No. EPA-HQ-OAR-2018-0283 and/or NHTSA-2018-0067 through Oct. 23. Addition information and a full copy of the SAFE Vehicles Rule is available on the Federal Register website.   READ MORE