A Message For EPA: Get Real on emissions and clean fuels!

NOXgateBy Doug Durante, Executive Director, Clean Fuels Development Coalition, special to The Digest

In the aftermath of revelations of how Volkswagon had their thumb on the scale as they cheated not just the EPA, but all of us who breathe the air, it raises serious and significant questions as to how we go about the business of protecting public health.

The VW scandal is significant in its implications. With their heavy reliance on diesel fuel, the Europeans are realizing they have not been meeting pollution reduction goals and have in fact exposed the public to harmful emissions. Studies by some European agencies indicate the so-called “clean diesel” vehicles may in reality emit 40 times more Nitrogen Oxides (NOx) than the controlled testing in the lab would indicate. Perhaps this explains the nearly off the charts pollution levels reported in Paris and in other European cities last year.

So how big of a deal is this? And what does it have to do with ethanol and biofuels? After all, EPA says the VW scam affects less than 1% of the cars on the road. Europe has a 50/50 diesel/gasoline mix while here in the U.S. light duty vehicles are almost all powered by gasoline. Well its a very big deal, and it has everything to do with fuels, vehicles, and how we assess environmental impacts because of how EPA goes about this.

Modelchart

EPA has rapidly reversed course and is now conceding that they need to road test all diesel (but not gasoline) vehicles under driving conditions as opposed to the methods they currently employ. That’s not enough. We don’t know what we don’t know and some studies suggest that in the U.S. EPA is failing to do its job by allowing as much as 30% of gasoline exhausts’ most toxic pollutants to go unidentified and thus unaccounted. And finally, it has to do with the value proposition of ethanol as it relates to being a key part of improving fuel quality.

Similar to its approach to diesel regulations, EPA has constructed an elaborate maze of rules and defective models that hide the truth about what gasoline contains (fuel composition), how that gasoline is actually combusted in a vehicle (driving conditions), and what really comes out of the tailpipe of light-duty internal combustion vehicles (real-world emissions).

Artificial fuel samples

Instead, EPA uses “artificial” fuel samples to certify vehicles and defective models to predict emissions. In recent years, real-world measurements of pollution plumes in major cities around the world have proven that EPA’s models’ appear wildly inaccurate, and that gasoline exhaust pollutants dominate urban environments. In fact, EPA’s models fail to account for a majority of the most lethal particle-borne air toxics that come almost exclusively from gasoline aromatic hydrocarbons that EPA refuses to regulate despite Congressional directives to do so.

The collective message to EPA from the public should be to get real! As in real world. They rely on computer models, estimates, guesstimates, spreadsheets, and incomplete science when we have real world data and more effective testing methods available to us like actually driving the vehicle and actually measuring emissions. Does anyone really feel like they get the mileage and efficiency in their personal vehicles that was posted on the window when they bought their car?

Rarely– that mileage was calculated under optimum, contrived conditions and reflects the same problems in methodology and approach we see the agency using in emission calculations. Many in the fuel industry and auto industries have been calling on EPA to re-assess the way they regulate fuels. To begin with, real world, or what we term as consumer fuels that actually find their way to your gas tank, should be the starting point.

The laboratory that re-creates “nowhere in the world” conditions instead of “real world”

Instead, EPA goes in to a laboratory, with controlled conditions and recipes that not only do not reflect what comes out of today’s gas pumps, but can be made to provide any result they want. Take ethanol, for example, a low-carbon, clean burning source of octane that is in most gasoline in the U.S. and what is known as E10. When ethanol is added to these laboratory fuels, lots of strange and often negative things happen.

Yet, when ethanol is added to finished, consumer gasoline that already contains ethanol, lots of positive things happen. Octane increases while aromatics and toxics are reduced. Carbon Monoxide, Sulfur, CO2, and Particulates go down. This is real, and splash blending ethanol onto finished E10 is the methodology and gauge EPA should use, because that is how it would most efficiently enter the market. (See figure 1, reprinted courtesy of the Urban Air Initiative)

Working with laboratory and unrealistic certification fuels provides unrealistic results. And EPA knows this– they simply will not change their approach. In fact, in a 2013 presentation to colleagues explaining how they blended fuels to calculate emissions, an EPA official noted in the actual presentation* that certain conclusions were reached by assuming all the variables in the fuel mix could be held constant, only to then say “Caution: Doesn’t work this way for real fuels”!!

This discrepancy between modeling and guesswork and real world results is nothing new, we went through this in the 1990s with reformulated gasoline (RFG) when California Air Resources Board and other models told us RFG with oxygenates like ethanol could not reduce ozone. Yet, time after time in city after city the real world results told a different story.

The folks at the Urban Air Initiative (UAI) seem to have it right– together with the states of Kansas and Nebraska they have challenged EPA to approve future fuels, like a higher content ethanol fuels such as an E30 ethanol blend that would clearly reduce aromatics and get real world emission reductions that can be measured and quantified.
UAI has also challenged them on their modeling, specifically the Motor Vehicle Emissions Simulator (MOVES) Model that could cripple ethanol expansion because it is based on faulty science and methodology. Other models that fail to recognize the significant increase in corn yields also de-value ethanol in GHG and CAFE regulations.

So the next time you encounter someone from EPA, tell them to Get Real! Embrace new data and open up the process so we can achieve what we all want which is to protect public health.

 

(*EPAct/V2/E-89:Testing, Results &Application in MOVES2013 Aron Butler, James Warila FACA MOVES Review WorkGroup April 30, 2013)

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