Special to The Digest
Without question while the modern ethanol industry was built on legislation that provided incentives, market assurance, and other tools, the shift to the regulatory side of the equation has been a painful, foot dragging exercise that has resulted in many a lost opportunity. EPA’s actions have resulted in a death march to the finish line in terms of meeting our full potential as they have delayed major rulings, refused to acknowledge the best science, and failed to meet the intent of Congress.
However, we may have a unique and perhaps unprecedented opportunity for a do-over with the proposed fuel economy rule. While we take no position on exactly what the mileage standards should be, whatever they are we can get there faster and more efficiently by focusing more on fuel than simply assuming vehicle technology will magically save the day.
What role can high octane play?
What makes the current situation so intriguing is the fact that EPA seems to have stopped being tone deaf and recognized this reality and how octane may be the key to success. For years many of us have commented on various rulemakings and raised relevant issues that should be considered, only to have the agency dismiss them as being outside the scope of the rule. The current Notice of Proposed Rulemaking (NPRM) on fuel economy and ghg standards is throwing out a wider net and actually asking the key question of how do we get there, and what role can high octane play?
This is a refreshing and exciting opportunity for ethanol to present its job qualifications, and specific questions posed in the NPRM will make it impossible for the agency to dismiss it. This is like knowing the questions a prospective employer is going to ask you at the interview before you go in, and boy are we ready with the answers.
Think about it– How can high octane fuels help meet the goals of efficiency and low carbon? How can high octane fuels help automakers design more efficient vehicles? Can high octane fuels be offered at a lower cost to consumers? What regulatory barriers need to be addressed to facilitate high octane fuels in the marketplace? The answer is that ethanol can provide the highest octane at the lowest cost allowing automakers to produce high compression engines and achieve efficiency gains with reduced emissions. It opens the door for finally addressing the regulatory barriers that are all within EPA’s jurisdiction to address. In doing so they meet the Trump doctrine of deregulation while providing a boost to rural America and domestic energy.
A clear pathway for ethanol from all sources
And this isn’t just about corn ethanol. If advanced and cellulosic ethanol is ever going to develop it needs a market and right now there is no room at the inn for new gallons. However, with a removal of restrictions we would have a clear pathway for ethanol from all sources to access the 140-billion-gallon gasoline market. Keep in mind this is “clean” octane. The toxic compounds currently used by refiners are increasingly linked to everything from autism to asthma. Ethanol can replace the most lethal components in the oil barrel like benzene, a known carcinogen that the American Petroleum Institute acknowledged as far back as 1948 was unsafe at any level. Our fuel regulations have become so politicized in recent years we seem to forget that this is about protecting public health. The irony in that statement is that EPA acknowledged in 2007 that ethanol was a superior replacement for the toxic aromatics used for octane, but they took no action despite being directed to do so under the Clean Air Act Amendments of 1990. Their justification was that cheap oil and lack of ethanol supplies did not provide a cost benefit.
Well, guess what– that is first on our list of what EPA needs to which is to correct the cost benefit of increasing octane levels. Rather than oil being $19 per barrel and using pre RFS II ethanol volumes in their calculations, they now need to look at the reality of $80 oil and more than enough low-cost ethanol volume to meet all of our octane needs. That alone should get the job but if the rest of our regulatory wish list is addressed removing barriers then it should be no contest.
That list includes correcting EPA’s faulty lifecycle analysis that would present a dramatically improved carbon footprint, conducting a new study that was the basis for faulty emission models, addressing the inexplicable vapor pressure restriction on higher ethanol blends that actually lower vapor pressure, establishing a mid- level ethanol certification fuel, and removing ethanol volume limits that could restrict higher blends.
The goal of C AFE was to reduce petroleum consumption
And lest we forget the goal of the CAFE program to begin with was to reduce petroleum consumption. Ethanol, and the more the better, does that at every turn, be it in 10% blends or any other level. If automakers design vehicles to maximize ethanol’s high-octane content and thus achieve petroleum reductions, they need to be rewarded. EPA and the Department of Transportation (DOT) need to re-establish meaningful vehicle credits so when these vehicles are operating on higher blends they are rewarded.
Another reality EPA and the DOT need to accept is that the pace and contribution of electric vehicles is not what was initially projected when the high mileage standards were proposed. EVs may continue to develop and can certainly play an important role, particularly if the electricity used is derived from biomass and other renewable resources. But the 15-20 million cars we produce every year will largely be internal combustion engines and will require liquid fuels. Ethanol and gasoline working together can provide consumers with an efficient, healthier, and lower cost alternative.
What we need to recognize, and quite frankly we are not seeing it across the entire biofuels industry, is that this rule could be far more important to the future of the industry than anything we have dealt with in years. It is nothing short of astounding that almost 300,000 comments were filed with EPA concerning the Renewable Volume Obligation (RVO) rule. While not all of them were in favor, certainly the majority were. We need to get that same kind of fervor to EPA with regard to this rule, for the reasons we have outlined. The RVO, and for that matter even the RFS itself, offers no true path for growth. We simply must remove the roadblocks between here and there and the octane component of the fuel economy rule is the way to do that.
The High Octane Alliance
We recently formed a High Octane Alliance between the Urban Air Initiative, the National Farmers Union, the Farmers Union Enterprise, and the Clean Fuels Development Coalition to promote ethanol as the octane solution but all of us need to apply for the job. Like the 300.000 commenters on the RVO, we need to overwhelm EPA with the simple truth that high octane, from a domestic, low carbon, renewable, job creating, healthier fuel is the candidate right in front of them. (Visit www.CleanFuelsdc.orgfor information and assistance on submitting comments)