The Fuel Economy Rule: An EPA That Won’t See, Hear, or Speak to the Facts

August 26, 2021

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by Doug Durante (Clean Fuels Development Coalition/Biofuels Digest) The release of the highly anticipated revision of the Safe Affordable Fuel Efficient Vehicle (SAFE) proposed rule this month was, for the biofuels industry, yet another poke in the eye as the EPA totally ignored reality and continued their long history of taking every opportunity to not help the most successful alternative fuel in history. An overstatement? Not by a long shot, and I’ll come back to that.

But let’s look at what happened. First of all, we get it. The administration wants to electrify everything. Yeah, ok, right, fine, sure. But can we put the EV discussion in perspective? While they work out the myriad of issues and challenges any new fuel would encounter like cost, infrastructure, recharging, battery life, cost, battery disposal, mineral mining and depletion, cost, range, consumer choice, –did I mention cost? —and other challenges, we will be burning hundreds of billions of gallons of gasoline containing billions of gallons of carcinogenic benzene.

With somewhere between 12 and 18 million new cars sold every year, the majority by far over the next decade will be internal combustion engines fueled by that gasoline. And, those cars will remain on the road for a dozen years at least. So here we have a rule whose two objectives are to reduce GHG carbon emissions and achieve greater miles per gallon. By raising octane as part of a more realistic strategy we have a product in ethanol that will –guess what —reduce carbon emissions and achieve greater miles per gallon. Silly us, thinking we would be relevant to this rule.

This rule was unveiled in concert with an executive order that established “goals” for EV production. It has no teeth, no funding, no force of law.

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It is clear that any meaningful efficiency gains and CO2 reductions from this rule as proposed are decades out, ethanol reduces GHG by 50% today.

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Secondly, while much of the noise surrounding EVs is political, there are here and now health impacts that EPA has and continues to avert their eyes whenever we present them with information.

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In the ensuing 7 months CFDC and others have been meeting with Administration officials providing current, credible information as to how both emission and efficiency goals can be met by increasing the minimum octane standard in U.S. gasoline if they enforce existing toxic controls. We have provided extensive documentation on aromatics used for octane and how they are not only the highest carbon component in gasoline but also the primary source of fine particulate matter. So, by reducing these compounds and replacing them with low carbon clean octane, automakers are able to increase compression and –wait for it—emit less carbon and get better mileage.

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Moreover, the Administration’s pledge to address environmental justice would immediately be furthered because the inner-city residents who have higher rates of just about everything bad in terms of health are breathing this fine PM. EPA has admitted their models do not accurately capture secondary organic aerosols as carriers of particulates, but they continue to fixate on evaporative emissions. Tailpipe emissions are four times more reactive in forming ozone, and those tailpipe emissions are greatly reduced with ethanol due to its oxygen properties that increase combustion.

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All we were asking in all our meetings and in this correspondence was to give us a chance to make this case by soliciting comments in the proposed rule. EPA could have at least made note of and acknowledged they had been getting lots of input on octane and that it could play a role in fuel economy. Not only did they not do this but the salt in the wound is that the Trump EPA– not exactly known as stewards of the environment—did just that when they worked this rule.

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Hydrogen, green gasoline, and other fuels come and go while ethanol withstood prejudice and flat-out obstruction to emerge as not only the best, but essentially the only thing that actually worked. Ethanol has displaced 10% of the gasoline in the U.S. There is no one close—there aren’t even any honorable mentions.

EPA’s own data documents the reduction in aromatics as ethanol has gone from fringe player to a key part of the fuel mix. It has been enormously effective in eliminating carbon monoxide and ground level ozone.

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The bottom line is that this rule, if it is finalized, requires an annual increase in efficiency through 2026, then the post 2026 period will need another rule. It denies automakers all the tools to affordably achieve the required reductions in emissions and gains in efficiency. More importantly to all of us who breathe, it completely and totally ignores the health impacts of continuing to use high carbon toxic aromatics for octane.

The EV vision may or may not become a reality. But as advocates point to even the most optimistic scenarios of a 40-50% market share in a decade, they are intellectually dishonest to not acknowledge gasoline isn’t going away.

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What a sad irony that as this proposed rule to reduce oil use is introduced, the Biden Administration called on OPEC to pump more oil to lower gasoline prices. If EPA opened the pathway to higher ethanol blends, we would save billions of barrels of oil, and produce that fuel here at home. Higher ethanol blends represent zero cost to the federal government and would provide stunning economic benefits in terms of health care savings, jobs, increased tax revenue, and balance of trade. If cellulosic ethanol is ever going to be widely available, where is that ethanol going to go if we do not have higher blends?

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There are whispers throughout the Administration that they are hesitant to do anything that could be perceived as prolonging or supporting gasoline for fear of upsetting many in the environmental community.

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While we don’t expect the agency to insert a higher minimum octane standard in the rule at this point, at least in a preamble or introductory statement admit we need to focus on liquid fuels as transition to EVS and that the agency intends to aggressively address this in a future rulemaking on octane. EPA has announced they plan to develop a fine PM rule soon — that would be a good place to start. READ MORE

EPA Dismissed Biden Officials’ Criticism of Auto Emissions Plan (Reuters)

EPA Faces Environmental, EV Sector Calls To Tighten Vehicle GHG Plan (Inside EPA)

Ethanol Blog: 8 Things Ethanol Groups Want From EPA on GHG Emissions Standards (DTN Progressive Farmer)

New Proposed Federal Greenhouse Gas, Vehicle Efficiency Standards: A Missed Opportunity to Address Climate Change Now (Solutions from the Land)

EPA Vehicle GHG Hearings Showcase Industry Splits On EV Credits (Inside EPA)

RFA Testimony to EPA Calls for Inclusion of High-Octane Low-Carbon Fuels (Renewable Fuels Association)

Testimony of Geoff Cooper, President and CEO, Renewable Fuels Association (Renewable Fuels Association)

Biofuels Groups Eye Long-Term Vehicle GHG Rule As Venue For Sector (Inside EPA)

Excerpt from DTN Progressive Farmer: Here are eight actions ethanol groups asked EPA to take:

-To provide a statement in the final rule of EPA's intent to consider adopting a high-octane fuel standard as part of a future rulemaking.

-Take action to encourage the use of E15 and E85 in the current vehicle fleet.

-To require a minimum octane standard.

-To approve a high-octane, midlevel ethanol fuel for vehicle certification such as the 98 to 100 research octane number, or E25 to E30.

-Establish Renewable Fuel Standard volumes for 2021, 2022 and beyond to encourage the use of low-carbon biofuels.

-To provide a solution to Reid vapor pressure on ethanol blends above E10, after a court recently ruled the EPA's rulemaking allowing year-round E15 sales was unlawful.

-Adopt the latest Department of Energy GREET model on the lifecycle GHG emissions of ethanol and other transportation fuels.

-Establish a technology-neutral approach to provide automakers with incentives to produce flexible-fuel vehicles and vehicles designed to achieve optimal efficiency and reduced emissions on high-octane ethanol blends. READ MORE

Tags

Corporate Average Fuel Economy (CAFE) standards Safer and Affordable Fuel Efficient Vehicles (SAFE) Regulations-Federal public comments EPA (Environmental Protection Agency) octane octane price/value High Octane Fuel (HOF) High Octane Fuel Standard High Octane Gasoline (HOG) High Octane Vehicles (HOV) Electric Car/Electric Vehicle (EV) internal combustion engine (ICE) GHG (Greenhouse Gas Emissions) health benefits public health policy environmental policy Transportation Fuels Policy aromatics Clean Air Act (CAA) particulates compression ratios mileage environmental justice/socially inclusive oxygenate White House gasoline price Cellulosic ethanol Trade Policy Engine Development Sustainability

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