Ethanol-based high-octane, low-carbon (HOLC) fuel blends would enable cost-effective gains in fuel economy and significant carbon dioxide reductions, the Renewable Fuels Association (RFA) outlined in comments submitted Friday to the Environmental Protection Agency (EPA) and the National Highway Traffic Safety Administration (NHTSA). The agencies should support this transition by developing a minimum octane standard, coupled with the removal of regulatory barriers that impede the widespread introduction and sale of ethanol-based HOLC blends, RFA wrote in its comments responding to the agencies joint proposal for 2021-2026 fuel economy and tailpipe greenhouse gas (GHG) standards (called the Safer Affordable Fuel Efficient (SAFE) Vehicles Proposed Rule). As part of the proposal, the agencies requested comment on the pros and cons of increasing gasoline octane levels and potentially eliminating lower octane fuel blends. Research by government labs and automakers finds that HOLC fuel could improve vehicle efficiency and reduce carbon dioxide emissions by 4%-10% in optimized high-compression engines, RFA noted in its comments. High-octane fuel is the most cost-effective way for vehicle manufacturers to comply with the proposed standards. The available evidence demonstrates that increased engine compression ratiosenabled by high-octane fueloffer the most economical means for manufacturers to increase fuel economy and reduce carbon dioxide emissions from light-duty vehicles, RFA explained. In its comments, RFA is recommending that EPA and NHTSA should require the gradual phase-out of todays regular grade gasoline and replace it with a fuel-neutral higher-octane standard. The auto industry and petroleum refiners already support the idea of legislation to raise gasoline octane to 95 RON. But no legislation is necessary to enable more efficient vehicles: Congress has already provided EPA with authority to control octane levels under section 211(c) of the Clean Air Act, RFA explained. Ethanol-based HOLC blends are the most economical way to raise octane in todays gasoline market and would also minimize refinery compliance costs and maximize the carbon dioxide emission reductions of a minimum octane standard, RFA noted. However, the administration needs to eliminate regulatory barriers to midlevel ethanol blends, RFA explained. The Presidents decision to fix senseless restrictions on the Reid Vapor Pressure 1-pound waiver is a step in the right direction, but more must be done to enable HOLC fuel, RFA wrote. Among the actions required to facilitate growth in HOLC fuels:
- EPA should fix the erroneous fuel economy formula and approve a HOLC midlevel ethanol certification fuel;
- The Department of Transportation and EPA should account for the energy conservation and renewable benefits of HOLC fuel in calculating compliance; and
- The Department of Transportation and EPA should harmonize the national program by restoring the flex-fuel vehicle credits intended by Congress.