MBA is a nonprofit trade organization based in Minneapolis, Minnesota. We are
dedicated to supporting and representing the renewable biofuels industry in
Minnesota, providing consumers with greater access to renewable biofuels and
promoting biofuels for a greener and more energy independent Minnesota and
America.

The key foundation for our work is reliable and verifiable scientific and technical
information. MBA is especially interested in the chemical and physical properties of biofuels as well as their performance characteristics with respect to enhancing the
efficient operation of spark ignition engines.

Ethanol, a renewable biofuel, in particular has some unique properties, especially in a
mid-level blend, which can enhance the performance of spark ignition engines. These
properties when combined with slight engine modifications, according to researchers at
various reputable research laboratories in the United States, can further improve the
efficiency of spark ignition engines to increase the number of miles attained per gallon
of fuel used and thereby decrease the amount of greenhouse gas emissions per vehicle
mile traveled.

While our comments are narrowly tailored to address the relevance and importance of
ethanol, particularly mid-level blends, with respect to spark ignition engines and the
potential of the mid-level blends of biofuels to facilitate attainment of the CAFE
Standards and greenhouse gas (GHG) emissions reduction targets (hereinafter,
“Standards”), the premise is that the CAFE Standards remain intact. In other words, as
the U.S. EPA considers whether the light-duty vehicle greenhouse gas standards
previously established for model years 2022–2025 are appropriate under section 202(a)
of the Clean Air Act, we respectfully submit, the standards are appropriate as minimum
standards and that consideration should be given to the fact mid-level blends of ethanol
can assist automakers in attaining the Standards.

At FR 39553 we note the EPA sets forth various elements to be considered by the
Agency as well as “any comments, data, and information they [stakeholders] believe are
relevant to the Administrator’s reconsideration of the Final Determination” FR 39552.
Based on the diverse scope of information request, we offer three points which, when
taken in totality, support the appropriateness of the standards under consideration by
the EPA.

1. Appropriateness of Standards Given GHG Emissions
Given the challenges associated with GHG emissions, including from the transportation
sector, the Standards under consideration are appropriate as minimum standards. The
scientific literature is replete with sound, valid facts, information and analyses with
respect to the costs associated with greenhouse gas (GHG) emissions. Based on the
science, the social, economic and environmental costs associated with the continued use
of petroleum gasoline is profound.

By its own accounting, EPA determined the failure to curb GHG emissions could cost
the United States, in this century, $180 billion in economic losses. See, U.S. EPA, Climate
Change in the United States: Benefits of Global Action (2015). The report, which was peer
reviewed in scientific literature with a summary report reviewed by external experts, examines, for example, the costs to human health, infrastructure, water resources,
agriculture and forestry and ecosystems.

The use of biofuels, with at least 15% alcohol, is already available for automakers to
promote for use as a preliminary tool by which to further reduce tailpipe GHG
emissions. In Minnesota, for instance, even an additional one hundred million gallons
of biofuel use can indeed make a major impact in the reduction of GHG emissions as
demonstrated by the analysis conducted to assess whether E15, compared to E10 fuel
for spark ignition engines, has an impact on GHG emissions.

Greenhouse gas benefits in Minnesota – E15 Would Reduce 358,000 Tons Of CO2
Emissions Annually In Minnesota – Minneapolis, Feb 16 - Making E15 (gasoline
with 15 percent ethanol) the new regular unleaded fuel in Minnesota would
eliminate 358,000 tons of CO2 annually, according to a technical analysis by the
University of Illinois at Chicago.

In response to a query by the Minnesota Bio-Fuels Association, Dr Steffen
Mueller, principal research economist at the University of Illinois at Chicago,
said a gallon of E15 saves 1.26 g of CO2 equivalent (CO2e) per megajoule over
regular E10 (gasoline that contains 10 percent ethanol). CO2e includes carbon
dioxide, nitrous oxide and methane.

Annual gasoline consumption in Minnesota averages 2.4 billion gallons. Should all
2.4 billion gallons be converted to E15 from E10, CO2e savings in the state would
total 358,000 metric tons annually, Mueller said.
Using the U.S. Environmental Protection Agency's (EPA) greenhouse gas
equivalencies calculator, this would amount to eliminating 75,368 passenger vehicles
from Minnesota's roads annually.

The reduction in CO2e in Minnesota from using E15 is on top of the amount of CO2e
already eliminated by using E10. By comparing E15 to gasoline that contains no
ethanol, the CO2e savings would total 1.07 million metric tons annually in
Minnesota, Mueller said.

This, according to the EPA's greenhouse gas equivalencies calculator, is the same as
removing 225,895 vehicles from Minnesota's roads annually.
Dr Mueller's analyses were based on a life cycle basis which includes emissions
incurred during the production of ethanol including fuel feedstock origination (corn
growing), feedstock conversion at refineries and combustion in a vehicle.

Included in the analysis were land use change (LUC) requirements for feedstock
production. In his analysis, he said published studies on LUC emissions have shown
a significant reduction in the predicted magnitude of carbon emissions over time
and the downward trend is due to:
1) An evolving understanding of the elasticity of land transition and
yield-price relationships
2) Better understanding of ethanol co-product substitutions in animal feed
markets
3) Better understanding and data availability of global land types
4) Carbon adjustments during land transitions
Dr Mueller's analysis on E15 was arrived at using Argonne National Laboratory's
GREET (greenhouse gases, regulated emissions, and energy use in transportation)
model which incorporates detailed carbon stock factors for different ecosystems that
enable an exhaustive analysis of carbon emissions and sequestration from LUC. –
Argonne National Laboratory is managed by the UChicago Argonne LLC for the
U.S Department of Energy.

Put another way, automakers already have a stage one tool in the E15 fuel by which to
reduce GHG emissions in virtually the entire spark ignition engine rolling stock.
Further, to avoid undue burdens to humans and life-sustaining ecosystems, it is
imperative that the CAFE Standards and GHG reduction targets be maintained as
minimums. A number of significant analyses have been conducted in the realm of costs
associated with GHG emissions. See, for example, a report prepared by Citigroup.
According to Energy Darwinism II: Why a Low Carbon Future Doesn’t Have to Cost the Earth
(2015) (the “Report”), two energy scenarios were examined to provide an objective view
of the economic situation. One scenario is inaction (similar to the apparent basis for the
EPA estimated cost savings by not using biofuels) and the other involves an energy mix
with lower carbon alternatives (e.g., including biofuels).

In brief, the Report offers some metrics for each scenario. The projected lost global
Gross Domestic Product (GDP) from the impacts of climate change are pegged at $44
trillion over approximately the next 40 years.

Alternatively, the Report sets forth an action scenario based on a low carbon pathway
(e.g., renewable biofuels). The avoided costs of climate change under this scenario
range from one percent to four percent in the early years and between three percent and 10 percent in later years.
Given the many adverse effects associated with GHG emissions, it is imperative that
automakers be held to a minimum standard for fuel efficiency and GHG emissions as
reflected in the Standards. Furthermore, in addition to the technological innovations
automakers have used and continue to develop to meet or exceed the Standards,
automakers have yet to fully employ the GHG reduction benefits associated with the
use of renewable biofuels. Thus, the automakers have extended potential yet to be
tapped to meet and exceed the Standards.

2. Appropriateness of Standards Given the Availability of High Mileage Vehicles
Given the available vehicle technology which already delivers higher miles per gallon
and lower GHG emissions compared to vehicles manufactured just a few years ago, the
Standards under consideration are appropriate as minimum standards. The metrics
show:
...17% of projected MY 2016 vehicle production already meets or exceeds
the MY 2020 CO2 emissions targets, with the addition of expected air
conditioning improvements. This represents more than 2.5 million
vehicles being sold today. The number of MY 2016 vehicles meeting or
exceeding the 2020 standards is much higher than projections for earlier
model years. In previous reports, EPA projected that 11% of MY 2015
vehicles and 5% of MY 2012 vehicles could meet or exceed 2020 standards.
The MY 2016 vehicles that meet or exceed the MY 2020 standards are
largely non-hybrid gasoline vehicles. This is also a significant change from
the MY 2012 projections, where the majority of the vehicles meeting the
MY 2020 standards were hybrids.

Looking ahead, about 3.5% of projected MY 2016 production could meet
the MY 2025 CO2 emissions targets. Vehicles meeting the MY 2025 CO2
targets are comprised solely of hybrids, plug-in hybrids, electric vehicles
and hydrogen fuel cell vehicles. Since the MY 2025 standards are nearly a
decade away, there’s considerable time for continued improvements in
gasoline vehicle technology to occur. U.S. EPA, “Light-Duty Automotive
Technology, Carbon Dioxide Emissions, and Fuel Economy Trends” ES 10
(November 2016).

This reality of existing higher mileage vehicles is mirrored in, for instance, the “Best and
Worst Fuel Economy” roster of vehicles compiled by Consumer Reports. Interestingly,
some spark ignition hybrid five passenger vehicles actually deliver higher than window
sticker posted mileage. Some of these vehicles already use higher compression ratio engines and deliver upwards of 54 and 60 miles per gallon.
The lower GHG emissions per mile can be further reduced with the use of renewable
biofuels. See, for example, Michael Wang, Argonne National Laboratory,
“Well-to-wheels energy use and greenhouse gas emissions of ethanol from corn,
sugarcane and cellulosic biomass for US use” at 9, (December 2012) (comparing lifecycle
GHG emissions for petroleum and renewable biofuels produced from a variety of
renewable biomass sources and finding, e.g., ethanol made with corn starch is at least,
on average, 34% to 44% less than petroleum).

The new regular fuel (E15 with 15% renewable ethanol) is available in the marketplace.
As more auto manufactures support the use of this already U.S. EPA approved fuel for
2001 and newer vehicles, greater GHG emission reductions can be attained. Ample
evidence exists to conclude the Standards, as minimum performance standards, are
attainable and can perhaps be surpassed with the use of renewable biofuels.

3. Appropriateness of Standards Given Biofuels and Mid-Level Blends
Given the potential to match the fuel to new spark ignition engine technology, the
Standards under consideration are appropriate as minimum standards. Mid-level
blends of ethanol can further enhance the performance of spark ignition engines so as to
boost the number of miles which can be traveled per gallon of fuel while lowering GHG
emissions. The EPA must, however, consider and should facilitate the match between
mid-level blends of renewable biofuels and engines similar to what the EPA did in the
1970's when automakers where encouraged to transition from reliance upon leaded fuel
to the use of unleaded fuel.

Based on studies which commenced in 2013, researchers had announced some
preliminary findings regarding the role of mid-level blends of ethanol with respect to
boosting engine efficiency and driving down GHG emissions. Some excerpts from an
article published in Ethanol Producer Magazine underscore this point:
Brian West, deputy director of the Fuels, Engines and Emissions Research Center
at ORNL, offered a slight tweak to that perspective. “All we are talking about
doing, and I don't mean to make it sound easy, is just changing that ratio a little
bit,” he says, adding that the nation already has a gasoline and ethanol
infrastructure.” https://www.mnbiofuels.org/item/1426-e25-e40-for-the-masses
West is referring to the slight modification that could be made to engine compression
ratios so as to maximize the energy obtained from fuel. This small change, coupled
with the use of, for instance, E25 to E40 fuel (mid-level blend with 25% to 40%
renewable ethanol) could boost miles per gallon and decrease GHG emissions. The mid-level blend, comprised of renewable, low lifecycle GHG emission biofuels,
provides the proper level of octane so higher compression engines can attain peak
performance.

These key factors regarding mid-level blends, engine compression ratios and engine
performance to deliver more miles per gallon while reducing GHG emissions were
underscored in a more recent report. Put in more direct terms, the 2025 Standards are
achievable with the use of higher blends of ethanol. As we noted in July 2016, the
Department of Energy's 2015 Quadrennial Technology Review specifically identifies
ethanol blends from E25 to E40 and states these levels "would dramatically increase the
octane rating of finished gasoline."
https://mnbiofuels.org/media-mba/blog/item/1561-higher-ethanol-blends-could-hel
p-meet-2025-fuel-efficiency-goals.

The Review goes on to state: "Higher-octane fuel would enable downsizing,
downspeeding and charge air boosting of the engine to improve the fuel economy of
the vehicles.” Id. Further, the Department of Energy goes on to note that if all vehicles
had engines with high compression ratios and could use up to 40 percent ethanol,
petroleum usage per vehicle would be reduced by 30 percent while there would be a
149 million metric tons of annual GHG reduction.

In conclusion, given the challenges associated with GHG emissions, the progress
automakers are making in achieving the Standards and the vast potential that exists to
use mid-level blends of ethanol to boost miles per gallon while driving down GHG
emissions, we request the Administrator sustain and enforce the Standards.
Thank you for considering our comments. Should you have questions about our
comments, you can reach me by telephone at 612.888.9138, Ext. 101.

Respectfully submitted,
Timothy J. Rudnicki, Esq.
Executive Director