Renewable fuels advocates say they understand that that rules establishing corporate average fuel economy (CAFE) standards benefit our national security by pursuing energy efficiency. Still, those advocates also say that pursuing efficiency must be done in a way that ensures a balanced approach to meeting the nation's energy needs, contending that a diversity of energy resources – especially those developed domestically – offers the greatest assurances of U.S. energy security.
Unfortunately, advocates argue, the rules proposed by EPA and the National Highway Transportation Safety Administration (NHTSA) setting greenhouse gas (GHG) and CAFE standards, which are set to be adopted later this summer, could cap and constrain U.S. biofuel production.
In comments recently submitted to the two agencies, the 25x'25 Alliance and a number of endorsing partners made it clear that they believe the standards proposed for 2017 and later model-year, light-duty vehicles "do not sufficiently incentivize the production of FFVs (flex fuel vehicles)," and "do not adequately value the greenhouse gas reduction potential of biofuels."
The groups are seeking changes to the proposed rules, arguing that as written, the new standards would conflict with the goals established in other national priorities, policies and legislation, including the federal Renewable Fuel Standard (RFS) and the Energy Independence and Security Act (EISA).
The diverse coalition of rural energy interests see the continued production of FFVs and the development of a range of advanced biofuels as critical to expanding the use of renewable fuels, which, in turn, will reduce greenhouse gas emissions and enhance air quality.
Representatives of a coalition of biofuel and farm groups have held several meetings in recent weeks with EPA, NHTSA and White House officials who are coordinating the promulgation of the CAFE/GHG rule. The coalition is pressing the administration to restore meaningful biofuel and FFV incentives in the final rule.
Last week, the group told NHTSA officials that under the proposed rule they had co-fashioned, EPA would eliminate a congressionally created statutory incentive designed to increase alternative fuel use. They were still awaiting a final response from the administration as of press time.
These advocates for a cleaner energy future contend that despite the many benefits of biofuels, which also includes enhancing our national energy security, the proposed rule does not ensure those benefits will be realized. They argue that the proposed rule, which effectively eliminates the statutory incentives that were adopted to promote the use of biofuels, also picks "favorites" by providing much more generous credits to other "advanced vehicle technologies," such as electric and plug-in hybrid vehicles."
The 25x'25 Alliance and its partners say there are ways to modify to the proposed rules so that they offer a level playing field for each vehicle technology, including FFVs, and recognizes the "lifecycle" benefits of ethanol in reducing carbon dioxide emissions.
The advocates for change have offered recommendations for EPA and NHTSA, including modifying the proposed rules to use either a "utility factor" put forth by the Society of Automotive Engineers, or an approach to evaluating technologies offered by the Alliance of Automotive Manufacturers.
The engineers' methodology, which is based on the range of a vehicle using the alternative fuel and calculating the daily mileage traveled, would determine the assumed percentage of operation on gasoline and the percentage of operation on the alternative fuel. It provides equity in the treatment of alternative fuels under the rule, while creating a sensible incentive for continued production of FFVs.
The manufacturers approach would maintain meaningful FFV credits in the rule by using E85 consumption in FFVs to calculate GHG emission reductions, creating a sensible incentive for continued production of flex fuel vehicles.
The groups also recommend that rather than simply measuring tailpipe emissions of carbon dioxide (CO2) emissions, the rule should add the life-cycle CO2 reduction benefits of ethanol to the CO2 compliance standards. By providing a multiplier showing life-cycle CO2 reduction for all blends containing biofuels, the calculations can take into account, at the very least, the recognized minimum life-cycle CO2 reduction of 20 percent for the biofuel portion of any fuel blend. It's a conservative recognition of ethanol's GHG benefits, given that future ethanol must meet the 50-percent GHG reduction required for "advanced" biofuels.
Coalition leaders are urging all stakeholders to review the comments and the underlying issue, contending that it is a matter of pursuing a clean energy future in a way that does not pose a risk to our rural and energy economies.