RFA tells EPA its air quality modeling and analysis is flawed

July 8, 2020 |

In Washington, in comments submitted Tuesday to the Environmental Protection Agency, the Renewable Fuels Association expressed support for the Agency’s proposal to determine that no additional measures are necessary to mitigate “potential adverse air quality impacts” associated with the Renewable Fuel Standard. However, RFA’s comments also challenged the flawed air quality modeling and analysis conducted by EPA to inform the proposed determination.

Earlier this year, EPA completed an “anti-backsliding study” to determine whether the RFS would adversely impact air quality. After considering the results of the study, the Clean Air Act requires EPA to either promulgate new regulations to mitigate any adverse impacts on air quality or to determine that no such measures are necessary.

In May, EPA proposed that no additional mitigation measures are necessary to mitigate adverse air quality impacts. While RFA supports that determination, the anti-backsliding study conducted by EPA often misrepresents ethanol’s air quality impacts.

According to multiple independent third-party reviews, the MOVES2014 model used by EPA to estimate the exhaust emissions of ethanol-gasoline blends is fatally flawed due to its use of manipulated input data and unreliable “adjustment factors” and equations. RFA’s comments recommend several options for improving EPA’s evaluation of emissions related to ethanol-blended fuels and the association offers to “…work constructively with the Agency to complete a more meaningful assessment of ethanol’s air quality impacts.”

Category: Policy

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