July 29, 2016
By Nathan Vander Griend
The United States Environmental Protection Agency’s (EPA’s) mission is to protect human health and the environment. They are charged with delivering on that mission by using the best scientific information available. We can all agree that is an important mission, but have they written off ethanol as helping them achieve that mission?
To understand this issues it is first important to understand what is in your vehicle’s gas tank. When you pull up to most retail fuel pumps you commonly see unleaded, super-unleaded or premium, which almost always contain at least 10% ethanol blended into each gallon even though it isn’t always labeled as “contains up to 10% ethanol.” Depending on where you are at you may even see an option of E85 or 85% ethanol. No matter what your selection however all you know is it is gasoline and can contain a percentage of a non-petroleum fuel molecule called ethanol. But if 10% up to 85% of the gallons you are purchasing is a single ethanol molecule, what makes up the balance of the gallon? Remember, gasoline is not a molecule. Gasoline contains hundreds of molecules derived from petroleum. Some are ok, but some are highly toxic carcinogens that can lead to real health issues and negative environmental impacts.
Although it is scary to think that there are toxic carcinogens in your gas tank that are subsequently released out of your tailpipe and into the air we breathe, you should be able to breathe easy as there are standards in place for minimizing Mobile Source-Related Air Toxics (MSATs) and they can be found in Section 202(L)(2) of the Clean Air Act. In fact, in the Clean Air Act it states the Administrator shall, from time to time revise regulations using reasonable requirements to control hazardous air pollutants from motor vehicles and motor vehicle fuels to reflect the greatest degree of emission reduction achievable.
With the EPA’s mission being so clearly stated and a law in place that requires the reduction of MSATs, why has the EPA not enforced this law that would lead to the growth of ethanol, a cleaner burning, more sustainable and more economical fuel? Perhaps even worse than their inaction is their action in creating new, unnecessary roadblocks to further hinder the growth of ethanol in the fuel supply.
Reid Vapor Pressure
The first roadblock is the Reid Vapor Pressure (RVP) standard which requires the EPA to limit evaporative emissions of gasoline from June 1 through September 15 due to the increase in evaporation rates in warmer temperatures. The higher the RVP of a fuel, the worse its emission are. The maximum RVP of gasoline ranges from 7 to 9 psi, whereas the RVP of pure ethanol is 2. With the majority of fuel used in the U.S. today being a 10% ethanol blend or E10 the RVP is approximately 10 psi. In 1990 Congress amended the Clean Air Act to allow gasoline with 10% ethanol or E10 a “one pound waiver” of EPA’s evaporative emission limit. In other words, Congress gave the EPA the authority to allow the use of 10% ethanol or E10 during June 1 through September 15. In 2011 the EPA approved the use of 15% ethanol or E15 blends but did not extend the “one pound waiver” even though a 15% ethanol blend or E15 has a lower RVP. This single issue blocks the majority of the market from using ethanol blends beyond 10% or E10 for 4.5 months of the year.
Motor Vehicle Emissions Simulator
The next roadblock is the Motor Vehicle Emissions Simulator 2014 (MOVES2014) Model which was populated by the EPAct/V2/E-89 Fuel Effects Study. The final product, the MOVES2014 Model, is only as good as the information that goes into it, and the information that it is populated with from the EPAct/V2/E-89 Fuel Effects Study is engineered to create a roadblock for increasing ethanol usage. The model tells us that when you add more ethanol to gasoline, emissions will actually increase. Ethanol is 200 proof alcohol. In fact, some ethanol production facilities actually make a further purified product that ends up as beverage grade alcohol, whereas gasoline is considered toxic and can cause major health issues or death if breathed in or swallowed. The only way that it is possible for ethanol to cause toxic emissions to increase when added to gasoline is to engineer the source data, which is exactly what happened. When ethanol was added in the EPAct/V2/E-89 Fuel Effects Study, the base fuel was changed. In grade school science class, we learned that when you perform an experiment that you need constants and one variable to judge how each change to the experiment affects the outcome. Unfortunately, basic principles such as this were not used with this study. When ethanol was added, various other components in the fuel blend changed as well.
Corporate Average Fuel Economy
The next roadblock is the Corporate Average Fuel Economy (CAFE) regulations in the United States that first enacted by the U.S. Congress in 1975, in the wake of the Arab Oil Embargo, to improve the average fuel economy of cars and light trucks (trucks, vans and sport utility vehicles) produced for sale in the United States. Flexible Fuel Vehicles (FFVs) or vehicles that can run on either regular gasoline or up to an 85% ethanol blend or E85 received a credit under the CAFE regulations for their ability to be powered by a renewable energy source. In 2012 the EPA decided to phase out FFV credits due to higher ethanol blends not being readily available nationwide for use in the FFVs. Currently auto manufacturers are positioned to cease producing FFVs as a result of the phasing out of FFV credits in 2019. Without FFVs on the road, there is no legal market for higher level ethanol blends beyond 15% ethanol or E15 for automotive use.
The R Factor
The next roadblock is R factor the EPA uses for ethanol. First off, R factor is defined as the sensitivity of the fuel economy result to changes in fuel energy content. When R equals 1.0, the fuel economy change exactly tracks the energy density difference between the fuels. If R is less than 1.0, the fuel economy change is smaller than the change in energy density. Auto manufacturers remain unfairly penalized by the EPA by holding ethanol’s R factor at 0.6 or 40% less energy content, even when in their own EPAct/V2/E-89 study the R factor averaged 0.82 to 0.86 and other studies and test programs would show a 0.93 to 0.96 R factor.
The last roadblock is the EPA’s test fuel certification protocols. They fail to use non-biased testing protocols when evaluating ethanol blends by not utilizing fuels for testing purposes that are actually commercially available for purchase. This gives the EPA the ability to discredit ethanol’s ability to reduce toxic carcinogens in the air.
When understanding the mission and understanding the science, it still just doesn’t add up. The inaction in enforcement of the Clean Air Act, and the construction of unnecessary and significant roadblocks to limit the growth of ethanol usage is not only disturbing, but is truly producing negative health and environmental impacts to the country. The Renewable Fuel Standard (RFS) is set to fully managed by the EPA after 2022, and today it doesn’t seem like they are betting on ethanol.
Read the original story: Does the U.S. EPA Not Want Biofuels?