• EPA should allow vehicle manufacturers that certify new vehicles to the “higher octane, higher ethanol content gasoline” level referenced in the proposed rulemaking also to certify that those vehicle are able to also operate on existing E10 or E15 fuels. These vehicles would be called “E30 Capable.”

• By building up the number of these “E30 Capable” vehicles that could get the same mileage with a lower cost fuel, the demand for E30 would increase. This demand would create a nationwide E30 infrastructure that would then allow for the marketing of “E30 Optimized” Vehicles designed to provide the fuel economy and GHG reductions necessary to meet 2022 CO₂ reduction standards.

• Since a higher proportion of lower cost ethanol is used to produce E30, the “higher octane, higher ethanol content gasoline” would probably not be priced above current 87 octane E10 regular. Therefore, it should not be referred to as “premium” fuel in final regulations or for purposes of marketing but rather should be labeled differently. For example, “E30 capable/E30 optimized regular” fuel.

In extended comments, Advanced Biofuels USA cautions that the “recipe” for these higher octane fuels must maintain current gasoline blend stock (BOB).

In addition to the “E30 capable” concept, Advanced Biofuels USA also suggests that, to provide a smooth path to making this “higher octane, higher ethanol content gasoline” available nationwide, EPA Tier 3 regulations should not require individual vehicle manufacturers to certify the availability of this fuel. Instead, EPA should use their authority under section 211 of the Clean Air Act to provide for the commercial availability of this “higher octane, higher ethanol content gasoline.”

In using the Clean Air Act authority to assure that “higher octane, higher ethanol content gasoline” is available nationwide, EPA should implement a reasonable phase-in schedule tied to manufacturer production plans required to meet 2017 and later EPA GHG requirements, according to the advocacy group. This schedule should be based on the “vehicles would not operate appropriately on other available fuels, and such a fuel would result in equivalent emissions performance,” information.

We see this transition from high petroleum percentage fuel to higher renewable percentage fuels complementing the engine design work done by Ford (EcoBoost) and GM (Ecotech) and others in their efforts to achieve the new 54.5 mpg fleet-wide CAFE standards.

—Advanced Biofuels USA’s executive director, Joanne Ivancic

Therefore, the comments explain, since these engine developments are being implemented for the sole purpose of meeting the 2022 EPA CO₂/NHTSA fuel economy standards while also providing enough power to compensate for the extra weight requirements of DOT safety standards, and are not being introduced for high performance reasons, engines using this integrated package of design features are as much emission control devices as the catalytic converters that caused EPA to issue lead elimination and sulfur reduction fuel control regulations to ensure lower HC, NO_x, and CO emissions.

BIO. Separately, the Biotechnology Industry Organization (BIO) in its comments on the proposal urged EPA to issue a final Tier 3 Motor Vehicle Emission and Fuel Standards rule that maximizes investment in and adoption of advanced biofuels.

Encouraging biofuels, including higher blends of ethanol and drop-in biofuels, would help meet EPA’s overall goal in this rulemaking to address the impacts of motor vehicles and fuels on air quality and public health. BIO believes that EPA should work to set the emissions test fuel to maximize investment and adoption of all biofuels, including higher ethanol blends and drop-ins, while also maximizing the level of octane in the US fuel supply.

—comments by Brent Erickson, executive vice president of BIO’s Industrial & Environmental Section