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Can Fuel Efficiency Standards Be Met Cost-Effectively?
The Potential for High-Octane, Low-Carbon Fuels
November 13, 2017
Materials will be available at: www.eesi.org/111317cafe
Tweet about the briefing: #eesitalk @eesionline
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Fuel-Engine Co-Optimization with Ethanol for High Efficiency Engines
Robert L. McCormick
November 13, 2017
4
• Liquid fuels will make a substantial contribution in the market for decades to come
• High efficiency engines benefit consumers, support economic development, and protection of the environment
• Fuel-Engine Co-Optimization has identified renewable high-octane fuels that allow production of much more efficient engines
• An ASTM standard for a high octane (100 RON) test fuel to be used in high efficiency engines was developed by a broad industry stakeholder group
• These engines are based on known technology, but are not on the market today because low-cost fuel is not available
The Message
5
Goal: better fuels and
better vehiclessooner
Fuel and Engine Co-Optimization
• What fuel properties maximize engine performance?
• How do engine parameters affect efficiency?
• What fuel and engine combinationsare sustainable, affordable, and scalable?
• Are there optimal fuel and engine combinations – highest combined efficiency/GHG reduction?
6
Goal: better fuels and
better vehiclessooner
Fuel and Engine Co-Optimization
• What fuel properties maximize engine performance?
• How do engine parameters affect efficiency?
• What fuel and engine combinationsare sustainable, affordable, and scalable?
• Are there optimal fuel and engine combinations – highest combined efficiency/GHG reduction?
Up to 15% fuel economy improvement forboosted spark ignition and mixed mode
External Advisory Board
7
USCAR
David Brooks
American Petroleum Institute
Bill Cannella
Fuels Institute
John Eichberger
Truck & Engine Manufacturers Assn
Roger Gault
Advanced Biofuels Association
Michael McAdams
Flint Hills Resources
Chris Pritchard
EPA
Paul Machiele
CA Air Resources Board
James Guthrie
UL
Edgar Wolff-Klammer
University Experts
Ralph Cavalieri (WSU, emeritus)
David Foster (U. Wisconsin, emeritus)
Industry Expert
John Wall (Cummins, retired)
• EAB advises National Lab Leadership Team
• Participants represent industry perspectives, not individual companies
• Entire board meets twice per year; smaller groups meet on targeted issues
88Current fuels constrain engine design
9
• Fuel with adequate knock resistance is required to prevent engine knock
• Knock occurs when unburned fuel/air mixture auto-ignites – a small explosion in the engine
• Knock can cause engine damage
Engine Knock Limits Engine Efficiency
UnburnedFuel/Air
FlameFront
Piston
Burned Gas
SparkPlug Higher knock resistance:
oHigher research octane number (RON)
oHigher octane sensitivity (RON – MON)
oHigher evaporative cooling
oHigher flame speed
10
• Pump octane is the average of research octane (RON) and motor octane (MON) – also known as (R + M)/2o Two tests to cover the full range of engine operating conditions 80
years ago when this was introduced
• For modern technology engines, RON is the better measure of performance (knock prevention)
• There is no nationwide (ASTM) standard for minimum octane number in the United States – significant limitation on engine efficiency
What is Octane Number?
95MINIMUM OCTANE RATING
(R+M)/2 METHOD
HIGH OCTANE FUELPREMIUMPLUSREGULAR
RON 91 RON 93 RON 95 RON 100
MINIMUM OCTANE RATING(R+M)/2 METHOD
MINIMUM OCTANE RATING(R+M)/2 METHOD
MINIMUM OCTANE RATING(R+M)/2 METHOD
11
How Can Better Knock Resistance Enable Better Engines?
Strategies to Increase Engine Efficiency:• Increased compression ratio
• Greater thermodynamic efficiency
• Engine downsizing/downspeeding• Smaller engines operating at low-speed/higher load• Less friction at lower engine speeds
• Turbocharging• Recovering energy from the engine exhaust• Increase specific power allowing smaller engine
• Direct injection• Fuel evaporation cools the air-fuel mixture
All of these strategies can take advantage of more highly
knock resistant fuels (higher octane number, octane sensitivity,
heat of vaporization, flame speed, and other properties
12
• Developed by ASTM workgroup with members from the automotive, petroleum, biofuels and other industries
• Describes properties of fuels for high efficiency SI engines
• Standard serves as a platform to align fuel formulations for these future engine technologies
• Planned to serve as basis for commercial high octane fuel standard
ASTM Standard for 100 Research Octane Number Test Fuel
Benefits of Biomass-Sourced Fuel
14
Representative Tier 3 blendstocks
Co-Optima High Performing Boosted SI
Blendstocks Identified
15
• Ethanol has high RONo RON = 109
o Relatively low cost source of octane
• Other properties also benefit knock resistanceo Octane sensitivity
o Heat of vaporization
o Flame speed
• E25 blend would likely provide adequate RON for high efficiency engines
Ethanol Is Available Today
Low-Octane BOB Regular GasolinePremium Gasoline
16
Summary – The Message
• Liquid fuels will make a substantial contribution in the market for decades to come
• High efficiency engines benefit consumers, support economic development, and protection of the environment
• Fuel-Engine Co-Optimization has identified renewable high-octane fuels that allow production of much more efficient engines
• An ASTM standard for a high octane (100 RON) test fuel to be used in high efficiency engines was developed by a broad industry stakeholder group
• These engines are based on known technology, but are not on the market today because low-cost fuel is not available
High Octane Fuels, Making Better use of Ethanol
Brian WestFuels, Engines, and Emissions Research Center
EESI High-Octane Fuels BriefingWashington, DC
November 13, 2017
Work supported by DOE Office of Energy Efficiency and Renewable Energy
Ag/Auto/Ethanol Workgroup
18
Ethanol is a very effective octane booster
• ~2/3rd of octane benefit from first 1/3rd of ethanol volume percent
• U.S. EPA opened the door for a high octane ~E30 fuel in Tier 3 rule
– “…we allow vehicle manufacturers to request approval for … fuel such as a high-octane 30 percent ethanol … blend (E30) for vehicles … optimized for such fuel”
• Road fuel infrastructure for a mid-level ethanol blend is not trivial (but significantly less complex than many other alternatives)
– USDA Biofuel Infrastructure Partnership is helping grow number of stations capable of dispensing E25 and higher blends
Managed by UT-Battellefor the U.S. Department of Energy
D4806
80
85
90
95
100
105
110
0 20 40 60 80 100
Re
sea
rch
Oct
an
e N
um
be
rEthanol Content (vol %)
Data from Stein, et al., SAE 2012-01-1277
19
Industry and DOE Investing In Programs to Quantify Efficiency and GHG Benefits of High Octane Fuels
10
15
20
25
30
35
40
0 200 400 600 800 1000 1200 1400 1600 1800 2000 2200 2400
Brake Mean Effective Pressure (kPa)
92 RON (E0) CR10.1101 RON (E30) CR 10.1101 RON (E30) CR12
DOE Work supported by
• Vehicle Technologies Office
• Bioenergy Technologies Office
Industry Cost-Share, Funds-in, and Tech Support
• Ford
• General Motors
• Fiat Chrysler
• Coordinating Research Council
• Ag/Auto/Ethanol Workgroup
Thermal Efficiency of Ford EcoBoost
(data from Sluder, ORNL)
10
15
20
25
30
35
40
0 200 400 600 800 1000 1200 1400 1600 1800 2000 2200 2400
Bra
ke T
he
rmal
Eff
icie
ncy
(%
)
Brake Mean Effective Pressure (kPa)
92 RON (E0) CR10.1101 RON (E30) CR 10.1101 RON (E30) CR12101 RON (E30) CR13
Managed by UT-Battellefor the U.S. Department of Energy
20
A New High Octane Fuel Could Make Better Use of Ethanol’s Properties, Moving The U.S. Toward Multiple Goals
• Engine efficiency can be improved with increasing ethanol and octane rating
• E25-E40 blend in future vehicles can return equivalent “tank mileage” as E10 in today’s comparable vehicles
– Energy density penalty is linear with increasing ethanol concentration
– Power and efficiency gains are non-linear
– Volumetric Fuel Economy Parity means every gallon of ethanol displaces a gallon of gasoline
• Efficiency/fuel economy benefit to OEM is significant
– Can help U.S. Comply with Renewable Fuel Standard
– Legal to use in >20M legacy FFVs
100
MINIMUM OCTANE RATING
RON METHOD
HIGH
OCTANE
FUEL
PREMIUMPLUSREGULAR
20Managed by UT-Battellefor the U.S. Department of Energy
Today’s Octane Numbers
Future: New Regular?
21
A few example results
22
• Objective: Demonstrate High Octane fuel benefits at the vehicle level
• Late model vehicle with 2.0 liter, 4-cylinder, turbocharged GDI engine
• Efficiency gains of 5-10% demonstrated with high-octane mid-level blends
High Octane Vehicle Demonstration Supported by DOE Bioenergy Technologies Office and follow-on work by Ag/Auto/Ethanol
Cadillac ATS equipped with a 2.0 liter
turbocharged, direct-injection engine and
manual transmission
9.5:1 Production 10.5:1 Prototype
Piston Blank
Range bars denote max and min of multiple tests
250
300
350
400
24.0
25.0
26.0
27.0
Baseline E10 Downsped E10 Downsped E30
CO
2Em
issi
on
s (g
/mi)
Fue
l Eco
no
my
(E0
mp
g e
qu
ival
en
t)
E0_equiv mpg
CO2 g/mi
FTP(City Test)
Factory Setup 10.5:1 Compression Pistons, Downspeeding
-6.6%+8.5%
23
Ag/Auto/Ethanol Supporting Mini Cooper E25 Demonstration
• Vehicle Specs:
– 2.0 liter turbo GDI
– Factory pistons and drivetrain
– Why Mini? Owner’s manual calls out E25:
• Tier 3 E10 and “Tier 3 E25” fuels
• High-Octane E25 provides efficiency and performance gains
Property Test MethodTier 3 E10
Value
‘Tier 3 E25’
Value
Research
Octane NumberASTM D2699 92.3 98.9
Motor Octane
NumberASTM D2700 84.5 87.5
AKI (RON+MON)/2 88.4 93.2
Sensitivity RON-MON 7.8 11.4
*Acknowledgement to BMW for informal technical support
24
Downsizing experiments conducted with Mini Cooper on dynamometer using 2006 Dodge Charger test weight and road load.High-octane E25 on aggressive US06 test provides efficiency gain over regular E10.
Range bars indicate max and min of multiple tests
2006 Dodge Charger dynamometer settings used with Mini Cooper vehicle to simulate downsizing
24.0
24.5
25.0
25.5
26.0
26.5
27.0
E10 E25
Fue
l Eco
no
my
(E0
-eq
uiv
.mi/
gal)
US06 Aggressive Driving Test2.0 Turbo GDI Mini Cooper
Tested at 4500 lb Dodge Charger Test Weight(downsize experiment)
3.6%
25
9.01
8.61
13.02
12.58
10.60
7.0
8.0
9.0
10.0
11.0
12.0
13.0
14.0
15
-80
mp
h E
lap
sed
Tim
e (
s)
E10-Mini
E25-Mini
E10-Charger
E25-Charger
E25-Charger withPower Module
Mini Cooper Dodge Charger Dyno Settings
Extreme downsizing can improve fuel economy at the expense of acceleration performance. Mini is 0.4s quicker with high-octane E25 than with E10.With Charger test weight, vehicle considerably slower; high-octane E25 again provides 0.4s quicker acceleration. Aftermarket “Power Module” increases boost, improves acceleration time by 2.4 s with HO E25 fuel.
E10 E10E25 E25 E25
2006 Dodge Charger dynamometer settings used with Mini Cooper to simulate downsizing
NM Engineering Power Module (PM) intercepts T–MAP sensor and increases boost. PM installed by previous owner; PM was disconnected for all tests except these final E25 WOT tests.
http://www.nm-eng.com/338/0/0/3128/nm648846-nm-eng-power-module.html
26
F150 EcoBoost* Currently Under Test*3.5L Turbocharged V6
Status
Baseline testing at ORNL with Tier 3 E10 and E25** Complete
Piston swap complete
– Mahle designed, fabricated, and delivered high-compression pistons (target +2.2 CR)
– More significant CR increase than previous experiments
• High Compression Experiments Underway
• Measurements planned
– Fuel Economy
– NMHC/NMOG, CO, NOx emissions
– PM mass (cold LA4)
– Acceleration
**Same fuels used in Mini Cooper
Work supported by Ag/Auto/Ethanol Workgroup
Ford F150 PistonsFactory 10:1 MAHLE 12.2:1
Ford F150 in ORNL Laboratory
27
Factory and High Compression Pistons for Ford EcoBoost Engine from MAHLE Powertrain
Factory 10:1 Prototype 12.2:1
28
F150 EcoBoost V6 Acceleration:
High Octane E25 Provides performance difference over regular E10 in baseline (factory) test condition
6.5
7.0
7.5
8.0
8.5
9.0
9.5
20 to 75 mph 15 to 80 mph
Acc
ele
rati
on
Tim
e (
s)
E10 E25
29
F150 EcoBoost V6 Particulate Matter:
Baseline tests show E25 provides statistically significant reduction in cold start particulate matter over regular E10.Cold portion of test generally produces ~90% of particulate matter in certification test
0
2
4
6
8
10
12
E10 E25
FTP
Co
ld-S
tart
PM
(m
g/m
ile)
Cold Start PM Baseline (Cold LA4) [mg/mile]
Range Bars Show min and max of three measurements
30
Summary• High-octane fuels can enable improved
vehicle efficiency (in vehicles designed for their use)
– Vehicle-level demonstrations have shown efficiency gains can more than offset lowered energy density of added ethanol
– Vehicle efficiency gains of up to 12% demonstrated
• Improved torque and power can provide performance improvement (or permit smaller engines)
– Legacy FFVs, turbo GDI engines (Mini Cooper) show improved acceleration, demonstrate potential for OEMs if fuel widely available
Managed by UT-Battellefor the U.S. Department of Energy
31
Contact Information
Brian WestDeputy Director
Fuels, Engines, and Emissions Research Center
(865) [email protected]
Managed by UT-Battellefor the U.S. Department of Energy
32
Acknowledgements
• DOE Vehicle Technologies Office
• DOE Bioenergy Technologies Office
• Ag/Auto/Ethanol Workgroup
– National Corn Growers
– Illinois Corn Marketing Board
– Missouri Corn Growers
• Industry Partners and National Lab Peers
• Fuels, Engines, Emissions Research Center (FEERC) colleagues
33
Backup Slides
Managed by UT-Battellefor the U.S. Department of Energy
34
1200 1600 2000 2400 2800 3200
IME
P
= data point
E30 (12:1)
87 AKI E0
101 RON E30
E0 (9.2:1)
E0 (12:1)
Engine Speed (RPM)
Recent Experiments Highlight Efficiency Benefits of High Octane Fuel for SI engines
• Engines can make more torque and power with higher octane fuel
• Ethanol is very effective at boosting octane number
– 87 AKI E0 + 30% Ethanol = 101 RON Fuel
• Increased torque enables downspeeding and downsizing for improved fuel economy
– For future vehicles, engine and system efficiency can balance lower energy density of ethanol blends
In a high compression research engine, high-octane
E30 enables doubling of available torque compared
to 87 AKI E0 fuel
- Splitter and Szybist, ORNL
Constant Power
Best
Efficiency
35
12.5
12.6
12.7
12.8
12.9
13.0
13.1
13.2
13.3
E10 E30
Tim
e (
s)
15 MPH to 80 MPH WOT Acceleration Time(GMC Sierra FFV, 12 run average)
E10
Re
gula
r
RSP
0.45 seconds
High Octane
E30
Legacy FFVs Realize Performance Gain with High Octane Mid-Level Ethanol Blends
• Motivation: Measureable performance improvement in legacy FFVs could enable early adoption of “High Octane Fuel for Your FFV”
• Tested 4 “ethanol tolerant” FFVs– GMC Sierra– Chevrolet Impala– Ford F150– Dodge Caravan
• Prep and Baseline “wide open throttle” (WOT) test with Regular E10
• Prep and WOT test with ~100 RON E30
10.1 CR (factory)
100
MINIMUM OCTANE RATING
RON METHOD
HIGH OCTANE
FUEL
For your FFV
Work supported by DOE Bioenergy Technologies Office
Car and Driver FFV test shows 0.4 second
faster 0-60 mph time with E85
www.caranddriver.com/reviews/2014-chevrolet-silverado-v-6-instrumented-test-review
If half of FFVs on road today
filled up with E25 half the time,
nation would consume over half-
billion gallons more ethanol
• Report available:
– 3 of 4 FFVs show acceleration improvement with E30
• ORNL’s Sierra results with E30 similar to Car and Driver test with E85
http://info.ornl.gov/sites/publications/Files/Pub54888.pdf
Dean Drake
Defour Group
EESI Briefing
Rm. 106
Dirksen Senate
Office Building
Washington, DC
November 13,
2017
Viewing the Vehicle and Fuel as a System:
The Economic Implications of High
Octane Low Carbon Fuel
Not All Vehicles Will Be Battery Powered
Certain Models Will
Require Liquid Fuel
Much More Energy per
Pound than Electricity
• Enables longer range
• Provides power to
move more weight
Future Liquid Fuels Should be More Renewable and Cleaner
than Today’s Gasoline
Defour Group LLC ©2017 Slide 2
The U.S. Already Runs on Ethanol Blend Fuels
Ethanol: To 10% of Our Fuel in 10 Years
Today, Most Gasoline is 10% Ethanol (E10)
• RFS drove ethanol demand & production
• Refiners chose to make E10
– Gasoline blend stock octane lowered
– Ethanol added to blend stock at terminal
to replace that lost octane
• Finished fuel shipped to retailers
Our Fuel Infrastructure Designed for Ethanol
2.04.06.08.0
10.012.014.016.0
2005 2015Bill
ion
s o
f G
allo
ns
of
Eth
ano
l
Year
Defour Group LLC ©2017 Slide 3
87 Octane E10 is Less Expensive than 87 Octane E0 Gasoline
What Ethanol Blend Fuel is Best?
What We Learned from E10
Fully Using Ethanol’s High Octane Lowers Consumer Cost
We Can Do Better than E10
• Higher octane can enable high efficiency engines
• With more octane, compliance with standards is less expensive
A New Fuel is Best Implemented When:
• There is widespread support among diverse stakeholders
• The change is transparent to the public
Completing Research to Determine Optimum Blend Ratio
Defour Group LLC ©2017 Slide 4
Impact of High Octane Fuel on New Vehicle Cost
Fuel: 98 Research Octane Number (RON) E25
Vehicle: Meets EPA’s 2025 Model Year Standards
• Higher compression ratio engines
• Widely available E25 fuel
EPA’s OMEGA Model (Run by Air Improvement Resource)
• Simulated 2025 MY fleet
• Estimated overall costs of standards due to technology
– Fleet average: Savings of $436 per vehicle
– Buick Enclave SUV: $873 per vehicle
Findings Were Presented in SAE Paper 2017-01-0906
Defour Group LLC ©2017 Slide 5
Two Fuels Could Enable High Efficiency Engines
Today’s Premium Grade E10
• Could be refined to have desired properties
• Considerably more expensive than today’s regular grade E10
Future E25 Performance Grade Fuel
• Begins with regular E10
• More ethanol added to boost octane
• Should cost the same or less than today’s regular E10
Is E10 Premium Fuel an Economically Viable Option?
Defour Group LLC ©2017 Slide 6
E10 Premium vs E25 Performance Grade Fuel
Annual Gallons Consumed
2025 CAFE Standards
• Fleet average
• LD truck average (e.g., Enclave)
• Adjusted to reflect real world
Adjusted for Each Fuel in High
Efficiency Engines Using:
• Fuel energy density & miles
traveled per year from EPA
• Thermal efficiency of
fuel/engine combination
Fuel Prices for 2025 to 2055
Spot OPIS Prices in 2016 for:
• Ethanol
• Regular Blend Stock
• Premium Blend Stock
Blended and Adjusted to Retail
• Transportation costs
• Wholesale to retail markup
Extrapolated 2016 Prices to 2055
Using EIA Annual % Increases
Defour Group LLC ©2017 Slide 7
Tangential Questions
Is Their Enough Ethanol?
Due to declining fuel demand,
only modest increases in ethanol
production are required.
Do EIA’s Rates Change?
Ethanol volumes changes are minor.
Reductions in U.S. gasoline demand
likely offset by increased exports.
RIN Effects?
Most studies
suggest any effect
of RINs on 2016
prices are too small
to be measured
and impact after
2022 are unknown.
Is the Price of Premium Inflated?
Using spot wholesale prices as a
starting point eliminates most of the
price inflation.
Are Additional Infrastructure Costs Significant?
Match blending = minimal refinery & terminal
changes. New dispenser pumps work with E25.
Defour Group LLC ©2017 Slide 8
Compared to a 2025 MY Vehicle W/O High Efficiency Engine,
Average 2025 MY Vehicle Modified to Use High Octane Fuel
Cost Difference
Vehicle ($436)
Fuel ($154)
Total ($590)
E25 @ $2.322 Per
Gallon in 2025
Premium @ $2.542 Per Gallon
(With Competition)
Cost Difference
Vehicle ($436)
Fuel $1,325
Total $889
Premium @ $2.767 Per Gallon
(Without E25)
Cost Difference
Vehicle ($436)Fuel $468
Total $32
Saves $590 Costs $889 Saves $32
Link Between High Efficiency Engines and E25
$662 More than E25$1,479 More than E25
Defour Group LLC ©2017 Slide 9
Average 2025 MY Buck Enclave Using High Octane Fuel
Cost Difference
Vehicle ($873)
Fuel ($199)
Total ($1,072)
Premium @ $2.542 Per Gallon
(With Competition)
Cost Difference
Vehicle ($873)
Fuel $1,653
Total $780
Premium @ $2.767 Per Gallon
(Without E25)
Cost Difference
Vehicle ($874)Fuel $586
Total ($288)
Saves $1,072 Costs $780 Saves $288
Potential Savings Even Greater on Trucks
$785 More than E25$1,852 More than E25
Defour Group LLC ©2017 Slide 10
E25 @ $2.322 Per
Gallon in 2025
Conclusions
The Nation Already Runs on an Ethanol Blend Fuel – E10
The Ideal Blend May be Higher than 10%
• Ethanol offers plentiful low-cost octane
• Automakers want higher octane to comply with standards
Going From 10% to 25% Ethanol Creates a Fuel That:
• Has the octane of premium grade gasoline
• Costs less than today’s regular grade gasoline
High Octane Fuel Enables More Efficient Engines But
Today’s Premium Makes This Strategy Too Expensive
Defour Group LLC ©2017 Slide 11
Backup Slides
The Consumer Benefit of E10Defour Group Study Began May, 2014
Used Weekly OPIS Prices for:
• Regular gasoline blend stock
• Premium gasoline blend stock
• Fuel Ethanol
Considers:
• Octane
• Fuel energy density
• Transportation cost differences
• Charge cooling
Compares Cost of a Gallon of 87 Octane E10 vs E0
May, 2014 to May, 2017
Co
nsu
mer
Ben
efit
s Pe
r G
allo
n o
f E1
0
$0.05
$0.15
($0.05)
Benefit 10% of Ethanol in Gasoline
Defour Group LLC ©2017 Slide 13
$0
$5,000
$10,000
$15,000
$20,000
50% 50%0% 0%
BEVs
HEVs
Passenger Cars LD Trucks
Technology Effectiveness
Tech
no
logy
Co
st/V
ehic
le
How OMEGA Calculates Compliance Costs
Technology Cost Curves
Defour Group LLC ©2017 Slide 14
$0.00
$0.50
$1.00
$1.50
$2.00
$2.50
$3.00
$3.50
$4.00
2020 2060$0.00$0.50$1.00$1.50$2.00$2.50$3.00$3.50$4.00$4.50
2020 2060
Ret
ail P
rice
Per
Gal
lon
Regular BlendStock
Premium Blend Stock
Ethanol
Fuel Components Retail Fuel
Estimating Fuel PricesW
ho
lesa
le P
rice
Per
Gal
lon
E10 Premium
Mark-UpsHigh Low
E25Performance
E10 Regular
Defour Group LLC ©2017 Slide 15
Year Year
0
20
40
60
80
100
120
140
2015 2020 2025 2030 2035 2040 2045 2050 2055
Con
sum
pti
on (
Bil
lion
Gall
ons/Y
ear)
Calendar Year
No E25
E25
Total Gasoline+Ethanol
Total Ethanol (E100) Consumption by Scenario
AFCM2017
2016Ethanol
Requirements
2055Ethanol
Requirements
Is Their Enough Ethanol?
Defour Group LLC ©2017 Slide 16
Can Fuel Efficiency Standards Be Met Cost-Effectively?The Potential for High-Octane, Low-Carbon Fuels:
Legal and Regulatory Issues
Andrew Varcoe & Adam Gustafson
[email protected] [email protected]
202-706-5488 / 202-955-0620
Boyden Gray & Associates
Boyden Gray & Associates is a boutique litigation and public policy firm, continuing C. Boyden Gray’s decades of service as counselor to presidents, business leaders, legislators, and regulators on matters of constitutional law, regulatory policy, and international affairs.
Overview
1) A Window for Change. EPA has restarted its Mid-Term Evaluation (MTE) of 2022-25 standards for vehicles. EPA is considering how the standards relate to high-octane fuel.
2) Regulatory Opportunities: Fuel Volatility (Reid Vapor Pressure) Regulation. EPA should apply the same fuel volatility standard to higher-ethanol fuel blends that EPA applies to E10.
3) Regulatory Opportunities: Certification Fuel Approval. A new certification fuel would remove obstacles to designing engines optimized for mid-level ethanol blends.
4) Regulatory Opportunities: Other Issues. Obscure, but important.
A Window for Change
The Mid-Term Evaluation of EPA’s Greenhouse Gas Standards
and NHTSA’s Fuel Economy Standards
In 2012, EPA and NHTSA (DOT) finalized a joint rule requiring passenger cars and trucks to meet increasingly ambitious greenhouse gas and fuel economy standards from model years 2017 to 2025. EPA projected an increase from 35.5 mpg in 2016 to 54.5 mpg in 2025. EPA-420-F-12-051.
2012: EPA and NHTSA impose vehicle greenhouse gas and fuel economy standards from 2017 to 2025
Table 1 - Projected Fleet-Wide Emissions Compliance Targets under the Footprint-Based
CO2
Standards (g/mi) and Corresponding Fuel Economy (mpg)
2016 base
2017
2018
2019
2020
2021
2022
2023
2024
2025
Passenger Cars (g/mi) 225 212 202 191 182 172 164 157 150 143
Light Trucks (g/mi) 298 295 285 277 269 249 237 225 214 203
Combined Cars &
Trucks (g/mi) 250 243 232 222 213 199 190 180 171 163
Combined Cars &
Trucks (mpg) 35.5 36.6 38.3 40.0 41.7 44.7 46.8 49.4 52.0 54.5
Mid-Term Evaluation (“Reality Check”)
In conjunction with the 2012 EPA and NHTSA decision, EPA, NHTSA, and California agreed to complete a joint Mid-Term Evaluation (MTE) of the standards by April 2018 to determine whether those standards remain “appropriate.”
The Mid-Term Evaluation can be seen as a “reality check” on the feasibility and appropriateness of the standards.
In January 2017, EPA issued a “final determination” indicating that the existing standards remain appropriate.
In March 2017, EPA Administrator Pruitt and DOT Secretary Chao reopened this evaluation process. EPA intends to make a new “final determination” by April 1, 2018.
Mid-Term Evaluation (2017):Reconsideration by New Administration
Octane is a measure of the antiknock properties of a liquid motor fuel.
In its notice reopening the comment period (Aug. 21, 2017), EPA invited comment on (inter alia) “the impact of the standards on advanced fuels technology, including but not limited to the potential for high-octane blends.”
Mid-Term Evaluation (2017): New Focus on Octane
EPA Administrator Scott Pruitt (Aug. 2017):
“That 15 billion gallon cap [for conventional biofuels’ participation in the Renewable Fuel Standard program]—maybe it needs to be reset above that. I think we need to consider, as another example on a different topic, high octane with respect to CAFE standards.”
Audio: www.radioiowa.com/2017/08/11/epa-chief-production-levels-demand-matter-in-rfs-decision/.
Mid-Term Evaluation (2017): New Focus on Octane
EPA’s new focus on octane is significant:
Reducing regulatory barriers to higher-octane fuels could help auto manufacturers comply with standards over the long term -- lowering greenhouse gas emissions and increasing fuel economy, while reducing compliance costs.
Before such cost savings can be realized, the regulatory barriers will need to be removed.
Mid-Term Evaluation (2017): New Focus on Octane
“Ford supports the development and introduction of an intermediate level blend fuel (E16-E50), with a minimum octane rating of 91 anti-knock index (AKI) that increases proportionally as ethanol is splash-blended on top of the base Tier 3 gasoline emission test fuel.” Ford Motor Co., Tier 3 Comments (2013).
“GM supports the future of higher octane and higher ethanol content in order to provide a pathway to improved vehicle efficiency and lower GHG emissions.” GM, Tier 3 Comments (2013).
“[A] powertrain . . . optimized for a high-octane, mid-blend ethanol fuel . . . can simultaneously fulfill what the customer desires—performance and economy—while reducing the environmental impact.” Mercedes-Benz, Tier 3 Comments (2013).
Background on Octane: Industry Observations
EPA in 2014:
“[A] higher octane, higher ethanol content test fuel:
“could help manufacturers who wish to raise compression ratios to improve vehicle efficiency as a step toward complying with the 2017 and later light-duty greenhouse gas and CAFE standards.
“could help provide a market incentive to increase ethanol use beyond E10.
“could . . . enhance the environmental performance of ethanol as a transportation fuel by using it to enable more fuel efficient engines.”
Tier 3 Final Rule, 79 Fed. Reg. at 23528-29 (2014).
Background on Octane: EPA Observations
Urban Air Initiative comments (Oct. 2017):
The auto-industry needs high-octane fuel to meet the emissions and fuel economy standards. EPA understands that high-octane fuel can be a tool for future compliance. But EPA has not yet removed regulatory barriers that prevent automakers and consumers from using high-octane fuels in the most optimal fashion.
To enable cost-effective compliance with the standards, EPA must act to remove outdated and counterproductive barriers to high-octane fuel use.
Background on Octane:Mid-Term Evaluation (2017)
Auto Alliance comments (Oct. 2017):
“[T]he Alliance has long advocated transition to a higher-octane gasoline (minimum 95– 98 RON). There are several ways to produce higher-octane grade gasoline, and the Alliance does not advocate any sole or particular pathway. Higher-octane gasoline enables opportunities for use of key energy-efficient technologies, including higher compression ratio engines, lighter and smaller engines, improved turbocharging, optimized engine combustion phasing/timing, and low-temperature combustion strategies.”
Background on Octane:Mid-Term Evaluation (2017)
Regulatory Opportunities:Fuel Volatility Regulation
EPA should apply the same fuel volatility (Reid Vapor Pressure) standard to higher-
ethanol fuel blends that EPA applies to E10.
Reid Vapor Pressure (RVP) is a measure of fuel volatility.
The Clean Air Act’s 1 psi (pound per square inch) waiver provision “loosens” the regulatory Reid Vapor Pressure (RVP) requirement for all “fuel blends containing gasoline and 10 percent denatured anhydrous ethanol.”42 U.S.C. § 7545(h)(4).
In the past, EPA has interpreted this statutory “RVP waiver” provision to apply only to gasoline with 9-10% ethanol (E9-E10). 40 C.F.R. § 80.27(d)(2). This historical interpretation is in tension with the text of the statute.
Reid Vapor Pressure (RVP) Relief
The text of the law is best read to apply “all fuel blends containinggasoline and 10 percent denatured anhydrous ethanol,” id.§7545(h)(5) – including ethanol blends above 10% (E15, E25, etc.).
This interpretation is supported by (1) the statute’s reference to “all fuel blends…”, as well as by (2) the statute’s affirmative defense for cases where “the ethanol portion of the fuel blend does not exceed its waiver condition under” a separate provision that could be used to authorize the use of higher-ethanol blends. Id.§ 7545(h)(4).
If Congress had wanted to limit the RVP waiver to blends no higher than 10 percent ethanol, Congress would have said so. That would have required different statutory language.
Reid Vapor Pressure (RVP) Relief
EPA acted several years ago to authorize the sale of E15 in the marketplace.
E15 is penetrating the marketplace, and is becoming available at more and more U.S. gas stations. As Growth Energy notes, more than 1,000 stations across the country are currently offering E15 to consumers.
Yet EPA’s past interpretation of the RVP waiver law imposes a major obstacle to E15 sales. Every June (except in so-called RFG areas), convenience store owners and other fuel retailers are required to restrict the sales of E15 to flex-fuel vehicles. When summer driving season starts, many store owners’ E15 sales “drop like a rock.”
Reid Vapor Pressure (RVP) Relief
EPA’s past interpretation of the RVP waiver statute is counterproductive.
E15 and other midlevel blends have lower RVP (i.e., lower volatility) than E10. As EPA has said, “the addition of ethanol to gasoline” above 10 percent ethanol “decreases blend volatility.”
Reid Vapor Pressure (RVP) Relief
EPA Administrator Scott Pruitt:“With respect to the [RVP] issue, we are looking internally [at allowing] E15 to be sold throughout the year, a national waiver if you will . . . I very much hope that we can get there, it's just a matter of if the statute permits it or not.” [May 2017*]
“… I have directed EPA to actively explore whether it possesses the legal authority to issue such a waiver. The Agency would welcome the opportunity to work with Congress on this important issue, including issuing definitive analysis on the Agency’s authority to issue a nationwide RVP issue for E15.” [Oct. 2017**]
* https://www.agri-pulse.com/media/podcasts/76-daily-voice/play/8286-pruitt-has-hope-on-e15-waiver
** https://www.grassley.senate.gov/sites/default/files/101917%20EPA%20to%20Participants%20in%20Hill%20Meeting.pdf
EPA Is Reviewing the RVP Relief Issue
Regulatory Opportunities:Certification Fuel Approval
A new certification fuel would remove regulatory obstacles to designing engines optimized for mid-level ethanol blends.
Certification Fuel Approval
A certification fuel (or test fuel) is used to “certify” (that is, to test) vehicles for compliance with fuel economy and emissions requirements.
The makeup of the test fuel thus determines the kinds of engines that car companies are able to design, build, and sell.
The makeup of the test fuel also determines the kind of fuelthat may lawfully be sold.
Certification Fuel Approval
When EPA approves a certification fuel, manufacturers are free to design engines optimized to use the certification fuel, and thus to be tested by EPA using that fuel.
Approval of a mid-level ethanol certification fuel would remove regulatory obstacles to designing engines optimized for mid-level blends. Such fuels and such engines would help manufacturers comply, cost-effectively, with GHG and fuel economy standards over the long term.
Regulatory Opportunities: Other Issues
Technical, Obscure, and Important
The R-Factor:Fixing EPA’s Formula
for Fuel Economy Certification
R-Factor (Used to Calculate Fuel Economy)
EPA should repeal and replace its outdated fuel economy formula. EPA has admitted that part of that formula – the R-factor – is erroneous and that it unfairly penalizes ethanol blends.
The R-factor error creates a disincentive for the deployment of high-efficiency engines that require higher octane ratings and utilize higher ethanol content.
R-Factor (Used to Calculate Fuel Economy)
The R-factor is intended to ensure that fuel economy testing on today’s fuel is equivalent to fuel economy testing in 1975, by adjusting for the lower energy content of ethanol. As EPA has acknowledged, the current EPA-mandated R-factor of 0.6 is erroneous, and fails to achieve its statutory purpose.
The auto industry has asked EPA to correct the R-factor to 1.0. In response, EPA has acknowledged that the current R-factor is wrong, suggesting that a corrected value might lie “between 0.8 and 0.9.”
R-Factor (Used to Calculate Fuel Economy)
EPA has not yet acted to fix the R-factor problem.
However, EPA could solve the R-factor problem for any new certification fuel (for example, a new midlevel ethanol blend fuel) by approving a new fuel economy formula for the new fuel.
Lifecycle Analysis:What Are the Real-World Greenhouse Gas Impacts
of Corn Ethanol?
Three federal agencies have analyzed the lifecycle GHG impacts of corn ethanol. EPA’s analysis from 2010 needs updating, and is in conflict with more recent analyses from DOE and USDA.
Outdated lifecycle analyses could have adverse trade impacts. Other countries might mistakenly award U.S. ethanol inadequate “credit” for GHG benefits.
Outdated lifecycle analyses could skew policy discussions, leading stakeholders and commenters to misapprehend the GHG benefits of U.S. ethanol production and current agricultural practices.
Lifecycle Analysis: Outdated Models Can Skew Trade and Policy Discussions
Emissions Model Reform:What Are the Real-World
Air Quality Impacts of Ethanol Blends?
EPA Vehicular Emissions Models: Why Do They Matter?
• EPA’s vehicular emissions model, MOVES2014a (“MOVES” = “MOtor Vehicle Emission Simulator”), estimates the pollution produced by a given fleet of vehicles running on fuel with defined parameters.
• States that are in “nonattainment” with EPA air quality standards must develop state “implementation plans” (SIPs), which show how those states will “attain” the standards. SIPs which can include vehicle and fuel policies. EPA requires “nonattainment states” to use MOVES in developing SIPs.
• Errors in the model can limit a state’s compliance options.
MOVES2014a: Three big problems
Because of the following defects, MOVES2014a erroneously reports that higher ethanol concentrations increase emissions:
1) Tailpipe Emission Factors. MOVES2014a relies on a flawed study that failed to control for the confounding variables that resulted from its match-blending methodology.
2) Evaporative Emission Factors. MOVES2014a’s “fuel adjustment” for ethanol’s permeation emissions is wrong; the model relies on studies systematically biased against ethanol.
3) Default Fuel Parameters. MOVES2014a requires states to use default parameters that contradict real-world market surveys.
These errors make it harder for states to use ethanol as a tool to improve air quality.
To correct the model’s errors:
Urban Air Initiative (UAI) filed a Request for Correction of Information (together with Kansas, Nebraska, and the Energy Future Coalition), asking EPA to fix its mistaken emission estimates for ethanol. EPA’s current target due date is November 30, 2017.
UAI is participating in EPA’s MOVES Review Work Group to advise EPA on the MOVES model’s errors and to suggest corrections for a revised model to be issued as early as 2018.
MOVES2014a: Next Steps
Overview
1) A Window for Change. EPA has restarted its Mid-Term Evaluation (MTE) of 2022-25 standards for vehicles. EPA is considering how the standards relate to high-octane fuel.
2) Regulatory Opportunities: Fuel Volatility (Reid Vapor Pressure) Regulation. EPA should apply the same fuel volatility standard to higher-ethanol fuel blends that EPA applies to E10.
3) Regulatory Opportunities: Certification Fuel Approval. A new certification fuel would remove obstacles to designing engines optimized for mid-level ethanol blends.
4) Regulatory Opportunities: Other Issues. Obscure, but important.
Thank you.
Andrew Varcoe & Adam Gustafson
202-706-5488 / 202-955-0620
Can Fuel Efficiency Standards Be Met Cost-Effectively?
The Potential for High-Octane, Low-Carbon Fuels
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