For years the ethanol industry has faced a technical barrier to expanding the E15 market -- namely so-called Reid Vapor Pressure limits in the Clean Air Act that seasonally limit ozone-depleting emissions in areas of the country considered to be in non-attainment of those ozone standards.
When the U.S. Environmental Protection Agency in 2011 granted CAA fuel waivers to allow for the use of E15 in vehicles model year 2001 and newer light-duty vehicles, it required E15 to have a RVP of no higher than 9 pounds per square inch from May 1 to Sept. 15. Essentially, E15 does not have the same waiver as E10 although the fuels are nearly identical.
The RVP for E15 has limited gasoline retailers as to when and where they can sell the fuel.
When gasoline evaporates volatile organic compounds, or VOCs, enter the atmosphere and lead to ozone formation. That problem is compounded during warmer months.
In a letter to Christopher Grundler, director of EPA's office of transportation and air quality, the Renewable Fuels Association Tuesday asked the agency to consider changing the Clean Air Act provision to clear the way for E15 -- which would be a critical step toward the biofuels industry cracking the E10 market and achieve industry expansion called for in the Renewable Fuel Standard.
"Partially as a result of EPA's establishment of the 1-psi RVP waiver, renewable fuels are blended in nearly every gallon of gasoline sold in the country today. The waiver has indeed served its purpose, and we are writing today to ask EPA to effectively eliminate the relevance of the 1-psi RVP waiver," RFA President and Chief Executive Officer Bob Dinneen said in a letter to EPA. "The agency should use its authority to mandate that refiners market lower-RVP blendstocks for conventional gasoline in the summertime (i.e., 8.0 psi in attainment areas) thereby allowing retailers to market a full spectrum of renewable fuel blends appropriate for use in a range of vehicle technologies."
Dinneen said E15 has not caught on in the gasoline market because the current RVP waiver is "now having the perverse effect of discouraging greater ethanol use in today's gasoline market, and it is obstructing the successful implementation of important fuel and carbon reduction policies enacted since then, including the Renewable Fuel Standard."
Dinneen said gasoline markets have changed since the RVP waiver was put into effect.
"Today, E10 blends represent more than 95% of total gasoline sales in the United States," he said in the letter. "Marketers no longer are faced with the challenge of finding appropriate blendstocks for E10. Rather, marketers wishing to increase their use of renewable fuels beyond E10 are faced with the same dilemma E10 marketers faced 30 years ago.
"The agency has made it clear that it does not believe it has the statutory authority to extend the 1-psi RVP waiver to gasoline blends containing more than 10% ethanol. While there remains disagreement with EPA's conclusion on that issue, another option available to the agency would be the effective elimination of the 1-psi volatility waiver's relevance by mandating lower-RVP summertime conventional gasoline blendstocks for mixing with all ethanol blends.
"Effectively removing the relevance of the 1-psi waiver for E10 would result in improved air quality and reduced potential ozone formation. Modeling conducted by Air Improvement Resource, Inc. using EPA's MOVES2014 tool indicates elimination of the waiver would reduce carbon monoxide emissions by nearly 16,000 tons per month in the summertime (0.9%), nitrogen oxide emissions by more than 700 tons per month (0.4%) and volatile organic compounds by approximately 1,850 tons per month (1.2%).3 The economic value of these emissions reductions alone would offset any negligible increase in refining costs."
Back in September 2014 the RFA asked EPA Administrator Gina McCarthy to grant E15 the same waiver, noting most retailers are, according to the letter, "faced with a hopeless decision every spring: stop selling E15 during the summer volatility control season, or secure the appropriate low-RVP gasoline blendstock. For most retailers, neither of these options are acceptable business decisions."
Read the new RFA letter here, http://tinyurl.com/…
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