The Urban Air Initiative (UAI), the Energy Future Coalition and the states of Kansas and Nebraska have petitioned the US Environmental Protection Agency to correct what they call the agency’s flawed models that limit the use of higher blends of ethanol.
According to UAI, the EPA has published inaccurate data for years claiming that ethanol increases emissions, even though ethanol’s pollution reducing qualities have been demonstrated repeatedly. UAI says that the false information originated with EPA’s fuel effects study—“EPAct study”—and its vehicular emissions computer model called MOVES2014. This information is critically important because it sets the tone for EPA’s institutional bias against ethanol, and it impacts federal and state fuel policies that limit ethanol’s growth in the market—impairing US air quality, according to UAI.
The filing is a Request for Correction of Information and is part of an ongoing effort by UAI to challenge EPA’s emissions data as well as the biased testing protocols and procedures that produced the erroneous data. The petitioners filed their initial Request for Correction in 2015. EPA declined to review that filing due to pending litigation but invited the petitioners to submit a new request later.
UAI’s Request for Correction explains in detail its view of the fundamental flaws in the design of the EPAct study that produced EPA’s inaccurate emissions estimates. The filing also sheds light on the origin of these design flaws—what UAI terms as EPA’s collusion with oil industry employees in the design of the study, as revealed by emails and other documents UAI obtained through a Freedom of Information Act request and related litigation.
UAI refutes EPA’s emissions estimates for ethanol with peer reviewed scientific studies showing that ethanol reduces the same pollutants that EPA says it increases.
UAI Director of Technical Programs Steven Vander Griend said the data and technical findings supporting the petition is the result of more than five years of research by UAI.
EPA could have modeled ethanol’s emissions effects by simply adding ethanol to commercial gasoline blendstocks (‘splash blending’), or mimicking real-world refinery practices. Instead, the designers of the EPAct study created novel fuels through an arbitrary “match blending” process in which they first adjusted the gasoline blendstock to hold constant certain arbitrary parameters. Adding insult to injury, BP, Chevron, and others with a clear incentive to limit ethanol were involved in the design of the fuel testing.—Steven Vander Griend
As outlined in the Request for Correction, the match-blending methodology resulted in unrealistic test fuels with key parameters outside the norm. For example:
Octane ratings. The E10 test fuels’ octane ratings were much higher than normal (between 90.6 and 94.7 AKI compared to the market average 88.3 AKI for regular gasoline, because EPA added pollution-causing high-octane hydrocarbons to the ethanol test fuels to artificially match T50 and T90 distillation temperatures, even though refiners reduce these costly additives before adding ethanol.
Distillation temperatures. Although the EPAct study purported to measure the effect of T50 and T90 on real-world emissions, the T50 values of the test fuels (165-240°F) were much higher than in the market (154.8–226.5°F), because EPA artificially elevated the T50 of the higher ethanol test fuels—the opposite of what happens in the real world.
Driveability. Because of the artificially high T50 values, one of the test fuels the ASTM driveability index maximum of 1250. Two test fuels fail to comply with today’s standard.
Aromatics. The range of aromatics levels in the test fuels (14.1–35.8%) was narrower and, on average, higher (25.6%) than in market fuels (21.4%), and exceeded design values by as much as 10%.
This is a story of data manipulated to produce a policy-driving scientific model whose results are precisely the opposite of what occurs in the real world. In the real world, blending ethanol into ordinary gasoline reduces harmful emissions produced when gasoline combusts in an engine. Ethanol accomplishes this salutary effect both by diluting the most harmful components in gasoline with its own clean octane and by lowering the temperature at which various proportions of the fuel mixture combust, which further lowers pollution.
These proven facts about ethanol’s emissions effects would have been confirmed by any study that simply added ethanol to an existing gasoline blendstock as occurs at refineries across the country, allowing ethanol to dilute the fuel’s hydrocarbon content and to lower its distillation profile.
Instead the EPAct study’s designers—which included employees of Chevron and BP—did the opposite. They artificially reversed ethanol’s beneficial effects, dumping in more of the most polluting fuel additives—high-boiling-point hydrocarbons—to elevate the distillation profile of the ethanol-gasoline blends, though not required by any law or private standard. As a result, the EPAct study unfairly attributes to ethanol the emissions effects of the hydrocarbons used to match the targeted distillation temperatures.—Request for Correction of Information
UAI’s lawyers at Boyden Gray & Associates submitted the Request pursuant to EPA’s Information Quality Guidelines, which call on the agency to respond within 90 days. In the meantime, EPA’s MOVES Review Work Group is reviewing MOVES2014 in preparation for a revised vehicular emissions model to be issued as early as 2018. UAI’s detailed analysis of the defects in EPA’s emissions factors should inform EPA’s assessment of the current model and its development of a corrected model.
EPA simply must model real-world emissions, and test fuels under real-world conditions. Match blending fuels in the laboratory can produce skewed results and when that testing is done by petroleum interests we know we are not getting fair or accurate data.—Steven Vander Griend
The states of Kansas and Nebraska argue that in addition to limiting their ability to achieve the environmental benefits of higher ethanol blends, EPA’s flawed model also diminishes State revenues derived from Kansas and Nebraska’s agricultural industries, because it encourages all States to develop emission controls that limit the sale and consumption of ethanol in motor vehicle fuel.