WASHINGTON, Sept.
29, 2016 - A regulatory framework needs to be initiated immediately for
lower-carbon, higher-octane fuel such as ethanol, if EPA and other agencies
hope to fulfill the “ambitious goals” of the CAFE-GHG program, says Brian Jennings, executive vice president for the American
Coalition for Ethanol (ACE).
Jennings’ comments are in response to EPA’s Midterm Evaluation (MTE) Draft
Technical Assessment Report (TAR) for light-duty vehicle greenhouse gas
(GHG) emission standards for model years 2022-2025. EPA is coordinating the
evaluation with the National
Highway Traffic Safety Administration (NHTSA) and the California
Air Resources Board (CARB).
Through the MTE, which examined a wide range of issues relevant to the 2022-2025
standards, the EPA will decide whether the standards for model years
2022-2025, established in 2012, are still appropriate, given the latest
available data and information.
The model years
(MYs) 2017-2025 program builds on the success of the first phase of the
National Program for MYs 2012-2016 vehicles, EPA says.
Combined with the MYs 2012-2016 standards, EPA says that the final program will
result in MY 2025 vehicles emitting one-half of the GHG emissions of a MY 2010
vehicle.
According to EPA, light-duty vehicles are currently
responsible for nearly 60 percent of U.S. transportation-related petroleum use
and GHGs.
While EPA projects that manufacturers will comply with the
MYs 2017-2025 standards by using a wide range of technologies, the agency expects
that the majority of improvements will come from advancements in internal
combustion engines (ICEs), and says that manufacturers can meet the current
standards for MY 2022-2025 with conventional gasoline vehicles that use ICEs
with well-understood technologies.
However, ACE counters the analysis, saying that vehicle CO2
emissions are on the rise in the U.S. and will continue to get worse until EPA,
NHTSA and CARB deal with the impact fuel composition has on GHG
emissions.
“As the agencies work to determine whether the 2022-2025
model year CAFE-GHG standards set in 2012 are achievable, the fact that
vehicles now emit more GHG emissions in the U.S. than power plants needs to be
taken into consideration,” ACE says. “Lower fuel prices and consumer
preferences for larger, less fuel-efficient vehicles have clearly contributed
to an increase of GHG emissions despite the standards the agencies have set.”
CAFE stands for Corporate Average Fuel Economy.
ACE is encouraging the agencies to acknowledge the
“inescapable link” between fuels and vehicles and to create a pathway for
low-carbon, high-octane fuels like ethanol to help automakers comply with the
2022-2025 standards.
“Dirty and low quality (low octane) fuel will increase GHG
emissions, especially in the type of new engine technologies that are beginning
to dominate the marketplace,” ACE says. “On the other hand, cleaner and
higher-octane fuel will reduce CO2 tailpipe emissions and improve fuel economy.”
ACE cites
Chapter 1 of the mid-term TAR that states that the relationship between
improving fuel economy and reducing CO2 tailpipe emissions is “very direct and
close.”
While the CAFE-GHG standards have spurred advancements in internal
combustion engines, ACE says the agencies have not been proactive about
improving the octane composition of the fuel these new ICE technologies depend
upon in the real-world — and the goals of the CAFE-GHG program will go
unrealized until a compliance mechanism is established for higher-octane fuel.
“The agencies make an implicit admission that fuel octane is
an essential ingredient for successfully meeting the 2022-2025 CAFE-GHG
standards based on some of the testing and engine modeling in the TAR,” ACE
says, citing
a section of the TAR that says that “all of the turbocharged direct injection engines
described below have been developed using 93 octane.”
ACE says that the agencies’ dependence on high-octane fuel
in making predictions about meeting the standards seems to support its position
that a pathway needs to be established for low-carbon, high-octane fuels like
ethanol to help automakers comply with the 2022-2025 standards.
“If agency modeling relies upon high-octane fuel to test and
verify that future standards can be met, it is imperative that there is
real-world availability of these high-octane fuels. If high-octane fuels aren’t
available, the standards won’t be met,” ACE says.
ACE, which has been in talks with automakers, agricultural
organizations and government researchers to develop strategies and action plans
to accelerate the transition of North American transportation fuels to
higher-octane, lower-carbon renewable fuels such as ethanol, submitted its
comments to the agencies during the TAR 60-day comment period.
To read ACE’s comments, click
here.
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