The American Coalition for Ethanol is among the first commenters in response to the U.S. Environmental Protection Agency's efforts to reform regulations, as the group filed comments Wednesday in response to the agency's request for comments.
EPA posted to regulations.gov, http://bit.ly/…, a notice asking for public comment on its evaluation of existing regulations.
EPA Administrator Scott Pruitt issued an agency-wide memorandum on the implementation of President Donald Trump's executive order in March, requiring a regulatory reform task force and federal government program offices to seek public input on existing regulations. The federal agencies are required to report back to the task force by May 15.
ACE and its 500 members is asking the agency to take a look at a number of regulatory issues that affect the ethanol industry.
In its comments sent to EPA Wednesday, ACE called on the agency to make a number of changes to federal regulations.
The changes include:
-Change the Reid vapor pressure, or RVP, regulation to allow for year-round sale of E15 and higher ethanol blends.
"EPA's current interpretation of its evaporative emissions regulation handcuffs retailers in conventional gasoline areas of the country," ACE said in its comments. "These retailers want to sell E15 in the summer months because the fuel is less-emitting and lower cost than E10 and straight gasoline. This RVP limitation on E15 and higher blends is the most burdensome hurdle preventing more widespread use of ethanol nationwide."
-Update the lifecycle analysis of corn ethanol.
"Scientists at the U.S. Department of Energy have repeatedly calculated that the greenhouse gas emissions of corn ethanol are far lower than assumed by EPA in its original 2010 regulatory analysis under the RFS," ACE said. "In January, USDA released an independent analysis indicating corn ethanol GHG emissions are already 43% below 2005 baseline gasoline and 30% below EPA's estimate for corn ethanol in 2022. EPA has resisted updating the lifecycle analysis for corn ethanol because it is grandfathered under the RFS as being at least 20% better than baseline gasoline and cannot currently qualify as an advanced or cellulosic biofuel. What EPA fails to recognize is that state regulators and others working on low-carbon fuel programs use the agency's outdated analysis as an excuse to limit the GHG reductions allocated to corn ethanol."
-"Modify EPA's mistaken interpretation of Section 211(f) of the Clean Air Act. Starting in 2017, ethanol is a fuel additive (a 10% concentration of ethanol blended with gasoline) which automakers must use to certify new vehicles, yet EPA has without cause interpreted its 'substantially similar' law to limit the concentration of ethanol in fuel. We support comments to the agency by the Urban Air Initiative that EPA may not limit the concentration of ethanol in gasoline."
-Streamline the approval process for high-octane fuels such as E25 to E40.
"Red tape makes it complex, time-consuming and expensive for new high-octane fuel blends to receive approval by EPA," ACE said.
"We encourage the agency to streamline the fuel petition process and eliminate unreasonable criteria for approval of high-octane fuels. EPA rules regarding registration of new fuels and the approval process for new certification fuels currently discourage innovation and obstruct the ability for high-octane fuels (such as E25-40 blends) to compete in the marketplace."
-Adjust fuel economy, or CAFE, compliance to allow flex-fuel vehicles to utilize the same incentives that are provided to other alternative fuel vehicles. "Current CAFE rules provide incentives to automakers to build electric vehicles and other alternative fuel vehicles, but strongly discourage production of FFVs that are capable of operating on clean alternative fuel ranging from straight gasoline to 85% ethanol," ACE wrote.
-Discontinue the use of the "MOVES2014" emissions model until a new emissions study is conducted.
"States that are in non-attainment with air quality standards must use the EPA's motor vehicle emissions model (MOVES) in developing implementation plans," ACE said. "The MOVES model is supposed to estimate emissions from mobile sources at the national, county and project level for air pollutants, greenhouse gases and air toxics. When the Obama administration modified the MOVES model in 2014, it failed to rely upon real-world gasoline blend stocks and methods to predict the emission effects of higher ethanol blends."
Read ACE's comments here: http://bit.ly/…
Todd Neeley can be reached at firstname.lastname@example.org
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