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RFA Seeks Certainty and Consistency in EPA Treatment of Flex Fuel Vehicles

October 26, 2020

EPA, Regulatory


In comments submitted today to the U.S. Environmental Protection Agency regarding emissions standard compliance calculations for Flex Fuel vehicles (FFVs), the Renewable Fuels Association supported the EPA’s new approach to maintaining some level of certainty for automakers in the absence of future guidance. At the same time, however, RFA called on the agency to provide a long-term floor and “more robust” E85 usage factors for future model years, given expected growth and the many benefits provided by ethanol flex fuels.


“Based on our discussion with automakers, it is clear that manufacturers will hesitate to invest in certain technologies, like FFVs, unless there is some assurance that those vehicles technologies will help enable CAFE and GHG standard compliance over multiple model years,” wrote Kelly Davis, RFA Vice President for Regulatory Affairs. “Fuel blenders and retailers also need multi-year certainty regarding the likely mix of light-duty vehicles so that they may appropriately direct their investments in wholesale and retail fuel infrastructure.”


Davis noted that restoring a more meaningful E85 usage factor for FFV production can help to level the CAFE/GHG playing field that currently favors battery electric, plug-in hybrid electric, fuel cell and compressed natural gas vehicles. “While we agree with EPA that automakers should be encouraged to produce vehicles that reduce petroleum consumption to improve energy security, save the U.S. money, and reduce climate change impacts, we believe incentives to stimulate the production of such vehicles should be constructed fairly and consistently.”


As part of its comments, RFA submitted an analysis comparing the number of E85 stations listed on the association’s crowd-sourced database ( to the number of E85 stations listed by the Alternative Fuels Data Center. The former lists just over 5,000 stations known to sell E85 today, while AFDC’s database only contains roughly 3,600. This is important because EPA relies on the overly conservative AFDC database to inform its projections of future E85 availability and station growth. RFA encouraged EPA to use the database to inform its future analyses.


Ken Colombini