The National Corn Growers Association submitted comments this week to the U.S. Environmental Protection Agency on the 938-page Tier 3 Motor Vehicle Emission and Fuel Standards Proposed Rule. In these comments, NCGA commended the agency on the proposed Tier 3 motor vehicle emission standard and fuel rule, which will reduce pollutants from the on-road light-duty motor vehicle fleet for many years to come.
The association also commended the agency on its recognition of the benefits of ethanol in transportation fuel, and its continued support for the Renewable Fuel Standard regulation, which is significantly reducing greenhouse gas emissions and improving energy security in the United States through the use of domestically produced ethanol.
To read the full comments as submitted, please click here.
The comments NCGA submitted are based upon two main principles.
First, the RFS volumes of biofuels in the future should be met in order to preserve the 150 million metric tons of annual CO2 equivalent emission reductions attributed to the RFS 2 program by EPA. The comments explain that:
"These emission reductions are directly dependent on the volume of biofuels and not on the fuel economy of the light-duty on-road motor vehicle fleet. The volume of biofuels is in turn dependent on having vehicles that are flexible-fuel capable and those certified on high octane mid-level blends plus a retailer infrastructure offering energy-competitive pricing. The Tier 3 proposal thus has a direct bearing on the availability of vehicles to implement the RFS."
Second, ethanol blends above E10 should be splash-blended to increase octane above the level of 87 AKI. In the comments, NCGA explains, "This will open up higher-octane-value fuels (not higher-priced "premium" grade fuels) to be widely used by the motoring public and by the automakers in meeting the 2017 and Later Model Year Light-Duty Vehicle GHG Corporate Average Fuel Economy Standards."
The comments express support for EPA's approach toward establishing E15 as the new certification fuel for 2017 and later non-flexible fueled light duty vehicles, EPA's specifications for lower sulfur levels for in-use gasoline and of EPA's recognition that a high-octane mid-level ethanol blend could help automakers achieve the 2017 and later GHG emission standards and CAFE standards.
The comments did note that while NCGA is "generally supportive of establishing new certification fuel requirements for FFVs, we are concerned that the proposed approach would inhibit the future development of FFVs and the development of dedicated vehicles designed for the exclusive use of a high-octane mid-level ethanol blend. Both FFVs and high octane utilizing vehicles are critical to ensuring that the 150 million metric tons of GHG emission reductions from the RFS volumes are attained."
To read the full Tier 3 Motor Vehicle Emission and Fuel Standards Proposed Rule, click here.