A high-octane, low-carbon ethanol blend in optimized engines would be the lowest cost means of achieving compliance with fuel economy and greenhouse gas (GHG) standards for model year (MY) 2022-2025 and beyond, Renewable Fuels Association President and CEO Bob Dinneen testified today at an Environmental Protection Agency public hearing in Washington, D.C., on the agencys Midterm Evaluation (MTE) of light-duty vehicle greenhouse gas standards. In March, EPA and the National Highway Traffic Safety Administration (NHTSA) jointly announced it was inviting stakeholders to comment on its reconsideration of the standards previously established for MY2022-2025 light-duty vehicles. For the first time in the MTE process, EPA explicitly invited comment on the important role that fuel properties, especially octane rating, can play in facilitating compliance with the long-term fuel economy and GHG emissions standards. It is broadly understood that internal combustion engines will continue to serve as the predominant propulsion technology for light duty vehicles through 2025 and beyond, Dinneen testified. But thats where the importance of fuel properties comes into play. Most new and emerging internal combustion engine technologies are enabled by a high-octane, low-carbon fuel blend. For example, high-compression ratio technology (which EPA estimates will comprise 44% of the market by 2025) demands higher octane fuels to limit premature fuel ignition in the cylinder, he said. Dinneen pointed out that ethanols unique propertieshigh octane rating, low lifecycle carbon emissions, high octane sensitivity, and high heat of vaporizationmake it a key component for the high octane fuels that will enable more efficient internal combustion engines. These attributes make ethanol a highly attractive component for the high-octane fuel blends of the future, he said. Further, research shows that using a high-octane low carbon, mid-level ethanol blend in optimized engines would be the lowest cost means of achieving compliance with CAFE and GHG standards for MY2022-2025 and beyond, Dinneen told EPA officials at the hearing. Indeed, there is a growing chorus of voices calling for a transition to higher-octane fuels to enable low-cost engine technologies that will meaningfully increase fuel economy and reduce emissions in the mid-term. We urge EPA to heed this call as the agency revisits its Final Determination, he noted. A high-octane fuel (98-100 RON) could be produced today simply by blending 25-30% ethanol with existing gasoline blendstocks. However, due to the inertia of fuel and vehicle markets, this transition will not occur on its own. Action by the EPA is necessary to catalyze the development and introduction of high-octane, low carbon fuels into the consumer market, just as EPA action was required to eliminate lead, limit benzene, and reduce the sulfur content of our gasoline and diesel fuel, Dinneen testified. In his testimony, Dinneen urged EPA to ensure its revised Final Determination: --treats future engines and fuels as integrated systems; --fully accounts for the findings of DOEs Co-optima research initiative; --includes a robust cost-benefit analysis of various CAFE/GHG compliance pathways, including the use of high-octane low-carbon fuels in optimized engines; and --lays out the regulatory roadmap to broad commercial introduction of high-octane, low carbon fuels in advanced internal combustion engines. If properly designed and implemented, we believe future corporate average fuel economy and GHG standards can work in tandem with programs like the Renewable Fuel Standard to advance the important policy objectives of reducing fossil fuel consumption and decreasing transportation-related emissions, Dinneen added. Additionally, RFA recently filed comments with NHTSA on its environmental impact statement of the MTE, and included a literature review of ethanol use for high octane fuels by global automotive engineering firm Ricardo Inc. Dinneens testimony, as prepared, is here.