In comments submitted today to the U.S. Environmental Protection Agency (EPA), Department of Transportation’s National Highway Traffic Safety Administration (NHTSA), and California Air Resources Board (CARB), the American Coalition for Ethanol (ACE) called for a federal pathway to be established enabling automakers to meet future CAFE-GHG standards with high-octane, low-carbon fuels like ethanol.

Comments were due to the agencies today on the draft Technical Assessment Report (TAR) of the 2022-2025 model year CAFE-GHG standards.  EPA, NHTSA, and CARB are conducting a Mid-term Evaluation (MTE) of the program, trying to determine if the standards which were originally set in 2012 remain appropriate.

“ACE has been in dialogue with automakers, agricultural organizations, and government researchers to develop strategies and action plans to accelerate the transition of North American transportation fuels to higher-octane, lower-carbon renewable fuels such as ethanol,” said ACE Executive Vice President Brian Jennings. “If the agencies hope to fulfill the ambitious goals of the CAFE-GHG program going forward, a regulatory framework needs to be initiated immediately for lower-carbon, higher-octane fuel such as ethanol.”

ACE’s comments are summarized by the following three points:

  1. Vehicle CO2 emissions are on the rise in the U.S. and will continue to get worse until EPA, NHTSA, and CARB deal with the impact fuel composition has on greenhouse gas (GHG) emissions.  We encourage the agencies to acknowledge the inescapable link between fuels and vehicles and create a pathway for low-carbon, high-octane fuels like ethanol to help automakers comply with the 2022-2025 standards.
  1. While the CAFE-GHG standards have spurred advancements to internal combustion engines (ICEs), the agencies have not been proactive about improving the octane composition of the fuel these new ICE technologies depend upon in the real-world.  The goals of the CAFE-GHG program will go unrealized until a compliance mechanism is set in motion for higher-octane fuel.
  1. Automobile engineers and U.S. government scientists who have researched engine technologies and fuel properties agree that ethanol is a low-cost, low-carbon, high-octane fuel that delivers the GHG and engine efficiency benefits necessary to accomplish the goals of the CAFE-GHG program.

ACE also submitted comments encouraging the agencies to restore meaningful credits for Flexible Fuel Vehicles (FFVs) and consider the establishment of a new incentive for engines optimized for high-octane, low carbon fuels.  Finally, ACE urged that fixes be made to the MOVES2014 model and R-factor, and that the goals of the CAFE-GHG program and Renewable Fuel Standard are harmonized.