High-octane, low-carbon fuels can help meet CAFE/GHG standards

By Erin Voegele | October 29, 2018

The comment period on U.S. EPA’s SAFE Vehicles Rule closed on Oct. 26. More than 100,000 comments were filed on the rulemaking, with those in the biofuel industry stressing that high-octane, low-carbon ethanol can help meet emissions standards. 

The U.S. EPA and U.S. Department of Transportation’s National Highway Traffic Safety Administration published the Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule for Model Years 2021-2026 Passenger Cars and Light Trucks (SAFE Vehicles Rule) in the Federal Register on Aug. 24, officially opening a 60-day comment period on the proposal. The EPA and NHTSA first released a pre-publication version of the proposed rule on Aug. 2. A hearing on the proposed rule was held Sept. 25.

In its comments, the American Coalition for Ethanol set forth recommendations for removing regulatory barriers restricting market access to high-octane midlevel ethanol blends. “We are grateful EPA and NHTSA are seeking comment on how fuel such as 100 E30 can help automakers meet CAFE-GHG standards,” said Brian Jennings, CEO of ACE. “We are also encouraged EPA’s position on high octane fuel is evolving. While the correlation between octane and fuel economy has been disregarded in previous rulemakings, the SAFE rule correctly recognizes that ‘gasoline octane levels are an integral part of engine performance.’

“…high octane fuel in the 98-100 Research Octane Number (RON) range comprised of 25 to 30 percent ethanol would benefit consumers and enable automakers to reduce GHG emissions and improve fuel economy,” Jennings continued. “Anything short of 98 RON E25 fails to maximize engine efficiency, GHG reductions, and consumer savings at the pump.

“Ethanol delivers the highest octane at the lowest cost, allowing automakers to benefit by continuing to develop high-compression engine technologies and other product offerings to achieve efficiency improvements and reduced emissions,” he said.

Within its comments, ACE asked the EPA and NHTSA to establish a minimum octane standard for fuel in the range of 98-100 RON with 25-30 percent ethanol, and provide automakers a corresponding certification fuel so they can test engines on the high octane fuel. ACE also recommends the 85 anti-knock index (AKI) used in some mountain states be phased out, and requests that CAFE-GHG compliance credits for flexible fuel vehicles (FFVs) be restored. In addition, ACE said EPA and NHTSA should consider new incentives for engines designed to achieve optimal efficiency on high-octane fuel. ACE also suggests the latest GREET model assessment of the lifecycle GHG emissions of corn ethanol be adopted.

The Renewable Fuels Association called on the EPA and NHTSA to use the rulemaking to advance high-octane, low-carbon fuels. “The agencies should support this transition by developing a minimum octane standard, coupled with the removal of regulatory barriers that impede the widespread introduction and sale of ethanol-based HOLC blends,” RFA wrote in its comments.

According to the RFA, research has found that high-octane, low-carbon fuel could improve vehicle efficiency and reduce carbon dioxide emissions by 4 percent to 10 percent in optimized high-compression engines, RFA noted in its comments. “High-octane fuel is the most cost-effective way for vehicle manufacturers to comply with the proposed standards. The available evidence demonstrates that increased engine compression ratios—enabled by high-octane fuel—offer the most economical means for manufacturers to increase fuel economy and reduce carbon dioxide emissions from light-duty vehicles,” RFA explained.

The RFA said ethanol-based high-octane, low-carbon fuels are the most economical way to raise octane in today’s gasoline market, and would also minimize refinery compliance costs and maximize the carbon dioxide emission reductions of a minimum octane standard. However, the RFA said the administration needs to eliminate regulatory barriers to midlevel ethanol blends.

Within its comments, the RFA said the agencies should approve a high-octane, low-carbon midlevel ethanol certification fuel, account for the energy conservation and renewable benefits of high-octane, low-carbon fuel in calculating compliance, and restore FFV credits.

“[High octane, low-carbon] fuel would enable cost-effective increases in vehicle efficiency, reduce CO2 emissions, and improve air quality. The agencies should support this transition with a minimum octane standard, coupled with the removal of regulatory barriers that impede the widespread introduction and sale of [high octane, low-carbon] blends,” RFA concluded.

Growth Energy reiterated support for the use of high-octane, midlevel ethanol blends to meet the fuel standards, regardless of where they are set. “The science behind the benefits of midlevel ethanol-blended fuels like E25 and E30 is well documented by national laboratories, automobile manufactures, and scientific institutions,” said Chris Bliley, vice president of regulatory affairs at Growth Energy. “Stable policies and access to market drivers will enable our industry to provide low-carbon, more affordable, high-performing, sustainable vehicle fuel solutions.”

Growth Energy said it will continue to encourage EPA and NHTSA to remove regulatory barriers to the adoption of high octane, midlevel ethanol blends like E25 and E30. This would include approving fuel blends like a 100 RON, E30 fuel for vehicle certification. It would also include requiring minimum octane standards, updating fuel economy formulas, re-establishing flex-vehicle credits, and ensuring year-round sales of E15 and higher blends by June 1, 2019, which would provide cleaner, more affordable fuel for our nation's drivers.