UAI: EPA keeping ethanol from its true lower carbon value

By Steve Vander Griend, Urban Air Initiative | June 03, 2020

In a world intent on lowering carbon emissions, any positive steps lowering CO2 should receive credit. Instead, a recent Notice of Proposed Rule Making (NPRM) issued by EPA actually proposes to penalize low carbon ethanol in a convoluted approach that would add CO2 emissions to an automobile manufacturer’s mileage and carbon emissions calculations. In this recent NPRM, which is now open for comments, EPA is proposing to add an additional 1.66% more CO2—and keep in mind that measuring CO2 per mile is the basis for calculating mileage and efficiency-- to the auto’s mileage results even though the new E10 fuel used for certification contains a lower carbon content, thanks to ethanol. Does this sound a little odd? It should!

The older certification fuel under what is termed in EPA-speak as “Tier 2” used a non-ethanol blended fuel, or E0. Newer, “Tier 3” fuel certification fuel includes E10 as a base fuel which has less CO2 per Btu than the older Tier 2 E0 certification fuel. Using EPA’s own vehicle testing data when they initially developed the Tier 3 tests, they compared 10 different vehicles and we noticed that all 10 vehicles had lower CO2 (carbon) per mile using E10 compared to E0. So how does this translate to a penalty that paints a distorted picture of ethanol and carbon and will be a significant deterrent to any automaker to design for higher blends?

As figure 1 clearly illustrates, the E10 fuel provides measurable reductions in CO2 emissions, and it is due to three contributing factors.

First, the EPA blended the E10 fuel similar to real world blending practices by increasing ethanol while decreasing aromatics. Lowering aromatic volumes lowers the carbon per Btu. Secondly, ethanol has less carbon per Btu than an average gallon of gasoline. These two actions of lowering aromatics and increasing ethanol accounts for most of reduced CO2 per mile with the E10 test fuel.

Lastly, there was also a slight fuel efficiency gain with E10 over E0. Meaning better mileage per Btu with E10 over E0. This, combined with the benefits of lowering aromatics with ethanol, and now you understand how E10 lowers carbon.

So how, you might ask, can EPA penalize ethanol blends in light of this data? The answer lies in the archaic testing protocols it uses that are based on certification fuels that do not contain 10% ethanol. Through a complex calculation of the fuel’s carbon content, volumetric efficiency, and actual mileage, somehow they are able to claims there needs to be an increase in carbon emissions. If this were to be the benchmark for ethanol, automakers will be penalized in their carbon emission ratings when using the standard E10 certification fuel. And, it would be a major disincentive for them to ever go to higher blends.

What we are seeing is history repeating itself: EPA has once again found a way to derail efforts to get to higher blends and to help ethanol capture its true value in terms of carbon reductions and octane benefits. So once again this is a call to arms, the Urban Air Initiative is preparing extensive comments on this proposed rule and welcome all in the industry to sign on with us. And we would be remiss not to do so because the ethanol industry has a great story to tell.

As oil refineries captured the octane benefits of ethanol, they in turn lowered the aromatic content of the fuel. How much has ethanol contributed to lowering aromatics? Based on gasoline volumes from 2019, we estimate that roughly 14 billion gallons of ethanol going into the US gasoline market displaced roughly 9 billion gallons of aromatics annually. This has a twofold benefit. First it lowers the toxic and particulate emissions by roughly 30 percent annually and second, it lowers overall carbon emissions.

This additional CO2 (carbon) reduction of lowering aromatics when adding ethanol is not included in EPA’s or DOE’s carbon models. As noted, these models look at how much carbon it takes to produce a unit of energy, not the carbon content in the energy produced. Some ethanol industry advocates promote ethanol lowering GHG by 40 percent, the Urban Air Initiative believes it is 50%. That is, when ethanol is credited for lowering aromatics by almost 9 billion gallons annually, there is roughly 1.3% less carbon per Btu with E10. This lowers ethanol’s carbon intensity by at least 10 gCO2/mj.

Not only is EPA imposing this 1.66% multiplier, recent articles by Union of Concerned Scientist and Green Car Reports are misinterpreting what it actually is. They believe that when automakers asked for this multiplier to be removed from the rule they were trying for another break in required GHG mileage. However in reality, the auto industry is simply asking that this unjustified penalty be removed and real world GHG emissions are measured.

EPA is ignoring the benefits of ethanol while also ignoring the benefits of lowering aromatics or raising octane. They are needlessly penalizing automakers, limiting ethanol, and ultimately harming the environment. This will all be captured in our comments and we urge everyone to join us as we push back on EPA’s attempts to limit ethanol.

Steve Vander Griend
Urban Air Initiative