EPA, NHTSA address high-octane fuels in CAFE/GHG rulemaking

By Erin Voegele | August 02, 2018

Representatives of the ethanol industry are applauding the U.S. EPA and U.S. Department of Transportation for addressing the potential of high-octane fuels in their proposed rule to set new fuel economy and tailpipe greenhouse gas (GHG) standards for model year (MY) 2021-2026 vehicles.

On Aug. 2, the EPA and DOT’s National Highway Traffic Safety Administration released a proposed rule to amend certain existing corporate average fuel economy (CAFE) and GHG standards for passenger cars and light trucks and establish new standards for MY 2021-2026. The rule is officially titled the “Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule for Model Years 2021-2026 Passenger Cars and Light Trucks,” also referred to as the SAFE Vehicles Rule.

The SAFE Vehicles Rule aims to replace CAFE/GHG standards put in place by the Obama administration. As part of a 2012 rulemaking, the EPA established MY 2017-2025 light-duty vehicle GHG standards and made a regulatory commitment to conduct a midterm evaluation (MTE) of the standards for 2022—2025. That review was originally completed in 2016. On Nov. 30, 2016, former EPA Administrator Gina McCarthy proposed to determine that the MY 2022-2025 standards remain as first established, and that rulemaking to change them is not warranted. The public comment period on that proposal was open through Dec. 30, 2016. On Jan. 12, McCarthy signed her determination to maintain the current GHG emissions standards for MY 2022-2025 light-duty vehicles. In March 2016, former EPA Administrator Scott Pruitt announced the EPA would reconsider the mid-term evaluations and McCarthy’s determination. The EPA opened a public comment period on the reconsideration in August 2017. Approximately one year ago, on Sept. 26, 2017, the agency held a hearing on the reconsideration. Growth Energy, the American Coalition for Ethanol and Renewable Fuels Association were among the organizations that testified at the event, stressing the importance of high-octane fuel blends. The proposed rule issued Aug. 2 is the result of the reconsidered MTE.

The proposed rule spans more than 1,200 pages. The EPA and NHTSA said they are seeking public comment on a wide range of regulatory options included the proposal, including a “preferred alternative that locks in MY 2020 standards through 2026.” The proposal also aims to withdraw a waiver that currently allows California to set more stringent CAFE/GHG standards.

Regarding high-octane fuels, the rulemaking states that stakeholders have suggested that mid-level high octane ethanol blends should be considered and that EPA should consider requiring mid-level blends to be made available at service stations. “Higher octane gasoline could provide manufacturers with more flexibility to meet more stringent standards by enabling opportunities to use lower CO2 emitting technologies (e.g., higher compression ratio engines, improved turbocharging, optimized engine combustion,” said the EPA in the rulemaking. The agency is specifically requesting comment on if and how it could support the production and use of higher octane gasoline consistent with Title II of the Clean Air Act.

The proposal also references previous recommendations made by the High Octane Low Carbon Alliance and the Fuel Freedom Foundation. “In meetings with HOLC and FFA, the groups advocated for the potential benefits high octane fuels could provide via the blending of non-petroleum feedstocks to increase octane levels available at the pump,” the EPA wrote in the rulemaking. “The groups’ positions on benefits took both a technical approach by suggesting an octane level of 100 is desired for the marketplace, as well as, the benefits from potential increased national energy security by reduced dependencies on foreign petroleum.”

The EPA is soliciting comments “on the potential benefits, or dis-benefits, of considering the impacts of increased fuel octane levels available to consumers for the purposes of the model. More specifically, please comment on how increasing fuel octane levels would play a role in product offerings and engine technologies.”

Geoff Cooper, executive vice president of the RFA, has spoken out following release of the proposed rule. “For far too long, the CAFE/GHG program has focused only the effects of engine technologies on fuel efficiency and emissions, while failing to recognize the important role that the fuels themselves play in determining efficiency and emissions impacts,” he said. “RFA has relentlessly advocated throughout the midterm evaluation process that the impact of fuel properties on efficiency and emissions must be considered, and we provided detailed information showing that high octane fuels can provide tremendous benefits. We are pleased to see that EPA’s proposal recognizes that high octane fuels can help enable more efficient engines and reduce GHG emissions, and we believe the agency should use its authority to include high octane low carbon fuels as an option available to automakers for meeting more stringent fuel economy and emissions standards in the future.”

Brian Jennings, CEO of ACE, commended the EPA for recognizing the benefits of high-octane fuels. “We are very encouraged EPA’s position on high octane fuel is evolving,” he said. “While previously taking fuel ‘off the table,’ EPA now appears to recognize it will need to increase the minimum octane of fuel to help automakers maintain engine efficiency and reduce greenhouse gas (GHG) emissions, going so far as to reference an octane level of 100 and a role for E30 blends.

“EPA concedes in the rulemaking that ‘higher octane fuel can provide auto manufacturers more flexibility to meet more stringent standards by enabling opportunities for use of lower CO2 emitting technologies’ and is seeking comments from the public on the ‘ideal octane level,’ the ‘benefits of increasing fuel octane,’ and specifically how higher octane fuel will play a role in ‘engine technologies and product offerings’ and “improvements to fuel economy and CO2 reductions,” Jennings continued.

“Some might argue EPA’s proposal to flatline the standards will lead to increased gasoline use and tailpipe pollution, but not if the final rule paves the way for E25-30 high octane fuel in future engines,” Jennings said. “Ethanol-enriched, high octane fuel in the 99-100 RON range would enable automakers to simultaneously reduce GHG emissions and improve fuel economy.”

Chris Bliley, vice president of regulatory affairs at Growth Energy, noted the proposal offers opportunity to the ethanol industry. “This proposal provides a valuable opportunity to highlight the benefits of high-octane, low-carbon fuels, such as mid-level ethanol blends like E30,” he said. “We look forward to participating in this discussion to show how ethanol blends can help automakers meet future GHG standards and provide immediate consumer benefits.”

A 60-day comment period will open on the proposal following its publication in the Federal Register. Comments can be submitted online at www.regulations.gov under Docket EPA-HQ-OAR-2018-0283. The NHTSA and EPA also plan to jointly hold three public hearings on the proposal in Washington, D.C.; Detroit, Michigan; and Los Angeles, California. The dates and locations of those hearings will be announced soon. Additional information, including a copy of the prepublication version of the proposed rule, is available on the EPA website.