Urban Air Initiative calls new EPA emission models flawed

By Urban Air Initiative | October 22, 2014

A computer model that states use to assess mobile source emissions is seriously flawed, according to an analysis by Urban Air Initiative and could effectively block access to the market for higher ethanol blends.

The Motor Vehicle Emissions Simulator (MOVES) and other modeling tools are used by states to demonstrate to the U.S. EPA how they plan to maintain air quality standards or in some cases come into compliance for various pollutants. Because of the methodology used by EPA, using more ethanol is shown to increase particulate emissions rather than correctly identifying aromatics and other high boiling hydrocarbon compounds added to test fuels as the cause.

With the publishing of the model in the Federal Register, a letter from the Energy Future Coalition and Urban Air Initiative has been sent to EPA Administrator Gina McCarthy. The letter cites specifics as to why the models are flawed and requests an immediate suspension of their use. http://urbanairinitiative.com/wp-content/uploads/2014/10/EFC-UAI-letter-to-EPA.pdf

“Ethanol blends can be created in one of two ways – by adding more ethanol to a product approved for commercial use, such as E10 (“splash blending”), or by adjusting the gasoline blendstock first to match certain selected parameters (“match blending”), wrote UAI and EFC. “Many tests of splash-blended ethanol have shown that it reduces pollution, but this study used match blending instead – despite the fact that nearly all U.S. gasoline is produced by splash-blending 10 percent ethanol.”

The groups contend that Office of Transportation and Air Quality models have been contradicted by numerous studies which show splash blended ethanol with a fixed consumer-grade gasoline blendstock substantially reduces vehicle exhaust emissions, including the most dangerous PM, air toxics, and brown and black carbon. The letter also noted that these problems in EPA methodology are recognized by fuel experts in the auto industry, the Department of Energy’s National Renewable Energy Laboratory, and numerous others independent of the ethanol industry.

“In short, the conclusions of both the EPAct study and the MOVES2014 model about the air quality impacts of ethanol are clearly and demonstrably false, and they should be withdrawn as a matter of scientific integrity. Fuels experts at DOE’s national laboratories should be engaged in a further peer review, and guidance should be provided to the states to refrain from using the MOVES2014 model for assessing the air quality impacts of ethanol blends,” wrote the two groups.

“It defies logic that adding ethanol, which contains no benzene and virtually no toxic compounds could cause a fuel to produce higher particulate emissions. If the EPA model stands by that position then no state would look favorably on higher ethanol blends,” said UAI President David VanderGriend.

“This continues a troubling pattern by EPA of throwing roadblock after roadblock in front of higher ethanol blends,” VanderGriend said.

He cited a litany of issues the UAI and Energy Future Coalition efforts have brought to EPA’s attention through comments and in correspondence, including:

- EPA’s rules deny ethanol’s role in reducing transportation’s carbon footprint, and effectively eliminate FFV credits;

- EPA’s refusal to extend the one pound waiver to E10+ blends blocks meaningful E15 commercialization;

- EPA refuses to recognize and regulate PAH-borne UFPs and SOAs predominantly caused by gasoline aromatic compounds, and refuses to enforce the mandatory Mobile Source Air Toxics provisions in the Clean Air Act;

- EPA refuses to open the door to higher octane gasoline that the automakers say they need to comply with fuel economy and carbon rules;

“They have bought into the oil company position that ethanol should be limited to E10 and have, quite bluntly, selectively enforced laws,” said VanderGriend. “And to add insult to injury, the federal government’s own studies out of the DOE labs suggests a nationwide E30 program would be the most efficient and effective means to meet the goals of CAFE, the RFS, Tier 3, and greenhouse gas rules.”

“To now release a model that is based on faulty assumptions and bad fuel science further slams the door on ethanol. We intend to keep asking EPA to justify these actions when they repeatedly indicate they support ethanol and biofuels. We simply want access to the market so we can provide consumers with choice and a cleaner, healthier alternative.”