WASHINGTON – In comments submitted Thursday to the Environmental Protection Agency (EPA) and National Highway Transportation Safety Administration (NHTSA), the Renewable Fuels Association (RFA) encouraged the agencies to consider the beneficial impacts of high-octane, low-carbon (HOLC) fuels on fuel economy and GHG emissions as they reconsider the previous administration’s Final Determination of the appropriateness of 2022-2025 CAFE and GHG standards under the Midterm Review. RFA’s comments also underscored that EPA has the authority and responsibility to regulate minimum gasoline octane ratings, and urged the agencies to undertake other actions that would facilitate broad commercial adoption of HOLC fuels.
“We were very encouraged to see EPA specifically ask for comment on the ‘potential for high-octane blends’ in the notice announcing the reconsideration of the last administration’s Final Determination,” said RFA President and CEO Bob Dinneen. “Throughout the entire Midterm Review process, we have urged EPA and NHTSA to recognize that the fuels Americans put in their engines have a significant impact on fuel economy and GHG emissions. But until now, the agencies had largely ignored the impacts of fuels and focused only on the engine technologies that will be necessary to meet 2022-25 standards. The bottom line is that EPA has the statutory authority to create a regulatory framework that will pair high-octane, low-carbon fuels with high compression ratio engines, resulting in greater fuel economy and emissions benefits. Such fuels can serve as an important tool for complying with increasingly stringent future fuel economy and tailpipe GHG standards.”
In its comments, RFA highlighted the fact that the use of an ethanol-based HOLC in optimized engines would be the lowest cost means of achieving compliance with CAFE and GHG standards for MY2022-2025 and beyond. The RFA also pointed out that EPA retains broad authority to regulate gasoline octane levels because it is well understand that octane levels affect emissions and air quality. The comments also recommend several additional steps EPA should take to help facilitate the widespread commercial use of HOLC fuels.
Further, the RFA comments include a new literature review of ethanol use for high octane fuels by global automotive engineering firm Ricardo Inc. The Ricardo report, which reviewed scores of studies and analyses by automakers, government researchers, and academia, found broad consensus around the efficiency and emissions benefits related to using an ethanol-based HOLC fuel.
To view RFA’s public comments, visit here.