MN Biofuels' Comments on the Proposed SAFE Vehicles Rule

  • Monday, 29 October 2018 15:21

The Minnesota Bio-Fuels Association provided the Environmental Protection Agency and National Highway Traffic Safety Administration with comments on the proposed SAFE Rule. The 515 page proposed rule, using fundamentally flawed assumptions, is aimed at rolling back progressively higher mileage and lower GHG tailpipe emission standards.

Given limited resources, MN Biofuels used its comments to focus the Agencies on (a) scientific evidence justifying the technology forcing function of the CAFE and tailpipe emissions rule, (b) availability of spark ignition engine technology which demonstrates the more aggressive standards can be attained and (c) role of mid-level blends of ethanol in enhancing engine performance so as to increase mileage and reduce emissions. In particular, the EPA can help match the mid-level ethanol blends to the high octane engines by using the same Clean Air Act authority the Agency used to facilitate the 1970's era transition from leaded fuel to unleaded fuel.

Read our entire submitted comments below:

The Minnesota Bio-Fuels Association (MBA) offers comments on three discrete provisions of the U.S. Environmental Protection Agency’s (hereinafter, the “EPA”) proposed The Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule for Model Years 2021–2026 Passenger Cars and Light Trucks.  Federal Register, Vol. 83, No. 165 (August 24, 2018) [hereinafter, “FR”] at 42986.

MBA is a nonprofit trade organization based in Minneapolis, Minnesota.  We are dedicated to supporting and representing the renewable biofuels industry in Minnesota, providing consumers with greater access to renewable biofuels and promoting biofuels for a greener and more energy independent Minnesota and America.

At the heart of MBA’s comments on the proposed SAFE rule is reliable and verifiable scientific and technical information. 

The (a) unique chemical and physical properties of ethanol (a renewable biofuel), which can boost spark ignition engine performance and thereby extend the number of miles attainable for each gallon of fuel, (b) time sensitive requirement for significantly reducing greenhouse gas emissions in the transportation sector, (c) role of technology forcing rules such as the proposed SAFE rule and (d) already existing high mileage spark ignition engine technology which can exceed 55 miles per gallon are a four factors that demonstrate the proposed SAFE rule should be revised to reflect the (a) most current information available from the Intergovernmental Panel on Climate Change and (b) role the proposed SAFE rule can play in forcing  greater efficiency in spark ignition engine technology with mid-level ethanol blends. 

Based on publicly available information, there is ample evidence to support the position that the proposed SAFE rule should, as an absolute minimum, mirror existing CAFE and tailpipe carbon dioxide emission standards for passenger cars or otherwise increase those minimum standards.

Ethanol, in particular, has some unique properties, especially as a mid-level blend, which can enhance the performance of already existing spark ignition engines as well as current and future engine designs optimized for mid-level ethanol blends.  These properties when combined with slight engine modifications, according to researchers at various reputable research laboratories in the United States, can further improve the efficiency of spark ignition engines and thereby increase the number of miles attained per gallon of fuel used while reducing the amount of greenhouse gas emissions per vehicle mile traveled.

We offer three points which, when taken in totality, support the appropriateness of the existing CAFE and tailpipe carbon dioxide emissions standards.

1.    Changes Needed in the Proposed SAFE Rule Given Dangers Posed by GHG Emissions

On its face, the underlying basis for critical calculations supporting the proposed rule includes fatal factual errors.  The EPA, for instance, cites the Energy Information Administration in support of its estimate of the number of barrels of fuel consumption associated with the proposed rule, FR at 42986, yet EPA provides no factual and rational basis for its assertion regarding global climate or, at best, fails to consider the most recent findings of the Intergovernmental Panel on Climate Change (IPCC) as well as the most recent report of the IPCC dated October 6, 2018.  Failure to incorporate these IPCC findings and related data means the EPA underestimates the danger posed by GHG emissions and the urgency needed for a more robust SAFE rule.

“Every extra bit of warming matters, especially since warming of 1.5 ºC or higher increases the risk associated  with  long lasting  or  irreversible  changes,  such  as  the  loss of some ecosystems,” said Hans-Otto Pörtner, Co-Chair of IPCC Working Group II.

Limiting global warming would also give people and ecosystems more room to adapt and remain below relevant risk thresholds, added Pörtner.  The report [referring to the IPCC special report of 6 October 2018 on the impacts of global warming at ] also examines pathways available to limit warming to 1.5ºC, what it would take to achieve them and what the consequences could be.

“The good news is that some of the kinds of actions that would be needed to limit global warming to 1.5º C  are  already  underway  around  the  world, but they would need to accelerate,” said Valerie Masson-Delmotte, Co-Chair of Working Group I.

“The  report  finds  that  limiting  global  warming  to  1.5°C  would  require  “rapid  and  far-reaching” transitions  in  land,  energy,  industry,  buildings, transport [emphasis added],  and  cities.  Global net human caused emissions of carbon dioxide (CO2) would need to fall by about 45 percent from 2010 levels by 2030, reaching ‘net  zero’  around  2050.  This means that any remaining emissions would need to be balanced by removing CO2 from the air. 

“Limiting warming to 1.5ºC is possible within the laws of chemistry and physics but doing so would require unprecedented changes,” said Jim Skea, Co-Chair of IPCC Working Group III.

The decisions we make today are critical in ensuring a safe and sustainable world for everyone, both now and in the future, said Debra Roberts, Co-Chair of IPCC Working Group II.

“This report gives policymakers and practitioners the information they need to make decisions that tackle climate change while considering local context and people’s needs. The next few years are probably the most important in our history,” she said.  IPCC Press Release, 8 October 2018 (

Reaching and sustaining net -zero global anthropogenic CO2 emissions and declining net non-CO2 radiative forcing would halt anthropogenic global warming on multi-decadal timescales (high confidence). The maximum temperature reached is then determined by cumulative net global anthropogenic CO2 emissions up to the time of net zero CO2 emissions (high confidence ) and the level of non-CO2 radiative forcing in the decades prior to the time that maximum temperatures are reached (medium confidence). On longer timescales, sustained net negative global anthropogenic CO2 emissions and/or further reductions in non-CO2 radiative forcing may still be required to prevent further warming due to Earth system feedbacks and reverse ocean acidification (medium confidence) and will be required to minimise sea level rise (high confidence). {Cross-Chapter Box 2 in Chapter 1, 1.2.3, 1.2.4, Figure 1.4, 2.2.1, 2.2.2,,,} IPCC, SPM-5 (

Twelve Years or Less to Significantly Reduce GHG Emissions So As to Limit Adverse Effects to Americans and Life-Sustaining Ecosystems

D1.3. The lower the emissions in 2030, the lower the challenge in limiting global warming to 1.5°C after 2030 with no or limited overshoot (high confidence).  The challenges from delayed actions to reduce greenhouse gas emissions include the risk of cost escalation, lock-in in carbon-emitting infrastructure, stranded assets, and reduced flexibility in future response options in the medium to long-term (high confidence).  These may increase uneven distributional impacts between countries at different stages of development (medium confidence). {2.3.5, 4.4.5, 5.4.2}.  IPCC Summary for Policymakers, at SPM-24 (6 October 2018)  (

Given the threats posted by GHG emissions, including from the transportation sector, and the opportunities which currently exist to mitigate damages in a limited 12 year window of time per findings of the IPCC, the existing CAFE and tailpipe carbon dioxide emission standards for passenger cars should be used as the absolute minimum standards.  The scientific literature is replete with sound, valid facts, information and analyses with respect to the costs associated with greenhouse gas (GHG) emissions.  Based on scientific evidence and findings, the continued use of finite, carbon intensive petroleum as a transportation fuel presents the United States and the Global Community with an unsustainable situation and one that poses great harm, danger and risks to humanity and life sustaining ecosystems.

Ethanol, a renewable biofuel, is made from regenerative biomass.  The plants, which comprise biomass, remove and use carbon dioxide from the atmosphere as the plants grow.  Mature plants provide the renewable ingredients to make ethanol.  The release of GHG emissions from the combustion of renewable ethanol can be taken up by plants in a subsequent growing season.  See Argonne GHG Lifecycle Analysis, 2012.

By its own accounting, prior to the most recent findings of the IPCC, EPA determined the failure to curb GHG emissions could cost the United States, in this century, $180 billion in economic losses.  See, U.S. EPA, Climate Change in the United States: Benefits of Global Action (2015).  The report, which was peer reviewed in scientific literature with a summary report reviewed by external experts, examines, for example, the costs to human health, infrastructure, water resources, agriculture and forestry and ecosystems.

Ethanol fuel blends with at least 15% alcohol is already available in the marketplace and is being used as a precursor to mid-level blend fuels to immediately reduce tailpipe GHG emissions.  At FR 43464, EPA essentially asks how it can, per the Clean Air Act, make mid-level ethanol blends of, for example, 30% ethanol available?  The answer is found in the method by which the 15% ethanol blend was approved.

Using greater amounts of renewable ethanol in place of petroleum fuel can help reduce the dangers associated with GHG emissions since the renewable ethanol lowers GHG tailpipe emissions.  In Minnesota, for instance, even an additional one hundred million gallons of biofuel use can indeed make a major impact in the reduction of GHG emissions as demonstrated by the analysis conducted to assess whether E15, compared to E10 fuel for spark ignition engines, has an impact on GHG emissions.

Greenhouse gas benefits in Minnesota – E15 Would Reduce 358,000 Tons Of CO2 Emissions Annually In Minnesota –  Minneapolis, Feb 16 - Making E15 (gasoline with 15 percent ethanol) the new regular unleaded fuel in Minnesota would eliminate 358,000 tons of CO2 annually, according to a technical analysis by the University of Illinois at Chicago.

In response to a query by the Minnesota Bio-Fuels Association, Dr Steffen Mueller, principal research economist at the University of Illinois at Chicago, said a gallon of E15 saves 1.26 g of CO2 equivalent (CO2e) per megajoule over regular E10 (gasoline that contains 10 percent ethanol). CO2e includes carbon dioxide, nitrous oxide and methane.

Annual gasoline consumption in Minnesota averages 2.4 billion gallons. Should all 2.4 billion gallons be converted to E15 from E10, CO2e savings in the state would total 358,000 metric tons annually, Mueller said.

Using the U.S. Environmental Protection Agency's (EPA) greenhouse gas equivalencies calculator, this would amount to eliminating 75,368 passenger vehicles from Minnesota's roads annually.

The reduction in CO2e in Minnesota from using E15 is on top of the amount of CO2e already eliminated by using E10. By comparing E15 to gasoline that contains no ethanol, the CO2e savings would total 1.07 million metric tons annually in Minnesota, Mueller said.

This, according to the EPA's greenhouse gas equivalencies calculator, is the same as removing 225,895 vehicles from Minnesota's roads annually.

Dr Mueller's analyses were based on a life cycle basis which includes emissions incurred during the production of ethanol including fuel feedstock origination (corn growing), feedstock conversion at refineries and combustion in a vehicle.

Included in the analysis were land use change (LUC) requirements for feedstock production. In his analysis, he said published studies on LUC emissions have shown a significant reduction in the predicted magnitude of carbon emissions over time and the downward trend is due to:
        1) An evolving understanding of the elasticity of land transition and yield-price relationships
        2) Better understanding of ethanol co-product substitutions in animal feed markets
        3) Better understanding and data availability of global land types
        4) Carbon adjustments during land transitions

Dr Mueller's analysis on E15 was arrived at using Argonne National Laboratory's GREET (greenhouse gases, regulated emissions, and energy use in transportation) model which incorporates detailed carbon stock factors for different ecosystems that enable an exhaustive analysis of carbon emissions and sequestration from LUC. – Argonne National Laboratory is managed by the UChicago Argonne LLC for the U.S Department of Energy.

Put another way, automakers already have a stage one tool by which to reduce GHG emissions:  E15 (15% ethanol and 85% petroleum gasoline).  Per the EPA approved E15 fuel, virtually all spark ignition engine powered vehicles built since 2001 can use this lower carbon liquid transportation fuel.  The EPA, however, keeps the focus on 10% ethanol blend fuel, FR at 43040, rather than the already available “new regular” lower carbon fuel with 15% ethanol. The E15 is the precursor for and provides the pathway to mid-level ethanol blends.

To reduce additional burdens and costs to Americans and life-sustaining ecosystems, it is imperative that the proposed SAFE rule embrace, at minimum, the CAFE and GHG tailpipe emission reduction targets as currently set forth through 2025.

According to Energy Darwinism II: Why a Low Carbon Future Doesn’t Have to Cost the Earth (2015) (the “Report”), two energy scenarios were examined to provide an objective view of the economic situation.  One scenario is inaction (similar to the apparent basis for the EPA estimated cost savings by not using biofuels) and the other involves an energy mix with lower carbon alternatives (e.g., including biofuels). 

In brief, the Report offers some metrics for each scenario.  The projected lost global Gross Domestic Product (GDP) from the impacts of climate change are pegged at $44 trillion over approximately the next 40 years.

Alternatively, the Report sets forth an action scenario based on a low carbon pathway (e.g., renewable biofuels).  The avoided costs of climate change under this scenario range from one percent to four percent in the early years and between three percent and 10 percent in later years.

Given the many adverse effects associated with GHG emissions, it is imperative that automakers be held to a minimum standard for fuel efficiency and GHG emissions as reflected in the current standards.  Furthermore, in addition to the technological innovation’s automakers have used and continue to develop to meet or exceed the standards, automakers have yet to fully employ the GHG reduction benefits associated with the use of renewable ethanol.  Thus, the automakers have extended potential yet to be tapped to meet and exceed the Standards.

2.    Appropriateness of the Proposed SAFE Rule Given the Availability of High Mileage Vehicles

Given the available vehicle technology which already delivers higher miles per gallon and lower GHG emissions compared to vehicles manufactured just a few years ago, the standards proposed by SAFE are regressive.  Therefore, to continue a positive technical trajectory to provide benefits for Americans and the life-sustaining ecosystems, the proposed SAFE rule should incorporate the current CAFE and GHG tailpipe emission standards as the absolute minimums.  Consider, for example, the following reliable set of metrics:

...17% of projected MY 2016 vehicle production already meets or exceeds the MY 2020 CO2 emissions targets, with the addition of expected air conditioning improvements. This represents more than 2.5 million vehicles being sold today. The number of MY 2016 vehicles meeting or exceeding the 2020 standards is much higher than projections for earlier model years. In previous reports, EPA projected that 11% of MY 2015 vehicles and 5% of MY 2012 vehicles could meet or exceed 2020 standards. The MY 2016 vehicles that meet or exceed the MY 2020 standards are largely non-hybrid gasoline vehicles. This is also a significant change from the MY 2012 projections, where the majority of the vehicles meeting the MY 2020 standards were hybrids.

Looking ahead, about 3.5% of projected MY 2016 production could meet the MY 2025 CO2 emissions targets. Vehicles meeting the MY 2025 CO2 targets are comprised solely of hybrids, plug-in hybrids, electric vehicles and hydrogen fuel cell vehicles. Since the MY 2025 standards are nearly a decade away, there’s considerable time for continued improvements in gasoline vehicle technology to occur.  U.S. EPA, “Light-Duty Automotive Technology, Carbon Dioxide Emissions, and Fuel Economy Trends” ES 10 (November 2016).

This reality of existing higher mileage vehicles is mirrored in, for instance, the “Best and Worst Fuel Economy” roster of vehicles compiled by Consumer Reports.  Interestingly, some spark ignition hybrid five passenger vehicles with cargo carrying capacity actually deliver greater than 55 miles per gallon.  Some of these vehicles already use higher compression ratio engines and could be further optimized to use mid-level ethanol blends to further increase mileage by approximately five percent (Telephone conversation with technical engineer, 2017).

In short, lower GHG emissions per mile can be achieved with the use of renewable ethanol.  See, for example, Michael Wang, Argonne National Laboratory, “Well-to-wheels energy use and greenhouse gas emissions of ethanol from corn, sugarcane and cellulosic biomass for US use” at 9, (December 2012) (comparing lifecycle GHG emissions for petroleum and renewable biofuels produced from a variety of renewable biomass sources and finding, e.g., ethanol made with corn starch is at least, on average, 34% to 44% less than petroleum).

The new regular fuel (E15 with 15% renewable ethanol) is available in the marketplace.  As more auto manufactures support the use of this already U.S. EPA approved fuel for 2001 and newer vehicles, greater GHG emission reductions can be attained.  Ample evidence exists to conclude the current standards for through vehicle model years 2025 should serve as minimum performance standards since they are attainable and can be surpassed with the use of mid-level renewable ethanol blends.

3.    Appropriateness of the Proposed SAFE Rule Given the Availability of Ethanol Generally and Mid-Level Ethanol Blends in Particular

Given the potential to match the renewable fuel to new spark ignition engine technology, the proposed SAFE Rule should use the CAFE and GHG tailpipe emission standards as minimum standards.  Mid-level blends of ethanol can further enhance the performance of spark ignition engines so as to boost the number of miles which can be traveled per gallon of fuel while lowering GHG emissions.  The EPA must, however, consider and should facilitate the match between mid-level blends of renewable ethanol and engines similar to the manner in which the EPA handled the 1970's transition from leaded fuel to the use of unleaded fuel.  This approach addresses the EPA issue raised at FR 43464.

Based on studies which commenced in 2013, researchers had announced some preliminary findings regarding the role of mid-level blends of ethanol with respect to boosting engine efficiency and driving down GHG emissions.  Some excerpts from an article published in Ethanol Producer Magazine underscore this point: 

The deputy director of the Fuels, Engines and Emissions Research Center at ORNL, offered a slight tweak to that perspective [referring to the slight modification that could be made to engine compression ratios so as to maximize the energy obtained from fuel ]. “All we are talking about doing, and I don't mean to make it sound easy, is just changing that ratio a little bit,” he says, adding that the nation already has a gasoline and ethanol infrastructure.”

This small change, coupled with the use of, for instance, E25 to E40 fuel (mid-level blend with 25% to 40% renewable ethanol) could boost miles per gallon and decrease GHG emissions.  The mid-level blend, comprised of renewable, low lifecycle GHG emission ethanol, provides the proper level of octane so higher compression engines can attain peak performance.

These key factors regarding mid-level ethanol blends, engine compression ratios and engine performance to deliver more miles per gallon while reducing GHG emissions were underscored in a more recent report.  Put in more direct terms, the existing 2025 standards are achievable with the use of higher blends of ethanol.  The Department of Energy's 2015 Quadrennial Technology Review specifically identifies ethanol blends from E25 to E40 and states these levels "would dramatically increase the octane rating of finished gasoline."

The Review goes on to state:  "Higher-octane fuel would enable downsizing, downspeeding and charge air boosting of the engine to improve the fuel economy of the vehicles.”  Id.  Further, the Department of Energy goes on to note that if all vehicles had engines with high compression ratios and could use up to 40 percent ethanol, petroleum usage per vehicle would be reduced by 30 percent while there would be a 149 million metric tons of annual GHG reduction.


Given the (a) urgent need to rapidly and significantly decrease GHG emissions in the transportation sector so as to stabilize the climate consistent with the emission reduction targets called for in the scientific evidence from the Intergovernmental Panel on Climate Change, (b) actual progress automakers are making in already achieving and exceeding the aggressive 2025 mileage and GHG tailpipe emission reduction standards and (c) documented scientific evidence which demonstrates that additional fuel efficiency can be achieved with the use of mid-level blends of ethanol, we respectfully request the EPA sustain and fully enforce the existing CAFE mileage and GHG tailpipe emission standards.

Thank you for considering and incorporating our comments in your assessment of the proposed SAFE rule and in supporting, upholding and enforcing the current CAFE mileage and GHG tailpipe emission standards though 2025.