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.”

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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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