ACE submits comments to EPA on vehicle GHG emissions standards

In Washington, the American Coalition for Ethanol (ACE) set forth recommendations this week on how the Environmental Protection Agency’s (EPA) Revised 2023 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions Standards can and should place much greater emphasis on improving the quality of liquid fuel and the role low carbon, high octane ethanol can play in making significant GHG reductions in the near-term.

Below are a few excerpts from ACE CEO Brian Jennings’ written comments to EPA’s proposal:

“ACE members believe ethanol can and should be an even bigger part of the solution to climate change, but this depends upon the Administration’s willingness to engage us on ethanol’s role as a low carbon fuel through policies such as the Renewable Fuel Standard and the topic of this request for comments; how to reduce GHG emissions from future vehicles.

“Many leading ethanol producers are on a trajectory to both net-zero and net-negative lifecycle emissions in the not-too-distant future. If the overarching goal is net-zero emissions by mid-century, let’s start making progress right now by taking full advantage of the 15 billion gallons of domestically-produced ethanol available today as an affordable way to boost octane and meaningfully reduce GHG emissions from gasoline powered engines.”

ACE encourages EPA take the following steps during its final rulemaking to enable high octane fuel made with low cost, low carbon ethanol to play a role in helping automakers develop high-compression and fuel-efficient engine technologies to reduce vehicle GHG emissions:

Establish a minimum Research Octane Number (RON) rating for fuel in the range of 98 to 100 RON with 25 to 30 percent ethanol and provide automakers with a corresponding certification fuel for engine testing purposes. As part of this action, the Agency should finally phase-out the use of sub-octane blends (85 AKI).

Instead of putting its thumb on the scale to favor electric vehicles (EVs) through multipliers and compliance credits, EPA should establish a technology-neutral approach that also provides automakers with incentives to produce flexible fuel vehicles (FFVs) and vehicles designed to achieve optimal efficiency and reduced emissions on high octane ethanol blends.

Reinstate the 0.15 FFV multiplier or establish an incentive that is on equal footing with the EV credits in its proposal and establish a similar credit for vehicles designed to run optimally on midlevel blends of ethanol.

Adopt the latest GREET model assessment of the lifecycle GHG emissions of corn ethanol.

While outside the scope of this rulemaking, ACE also encouraged EPA to set the maximum statutory conventional renewable fuel volumes under the RFS in the 2021 and 2022 Renewable Volume Obligation (RVO) rulemaking and pursue every option at its disposal to ensure uninterrupted market access for E15. Further, ACE strongly discouraged EPA from retroactively reducing the RVO for 2020 as has been rumored.