The National Corn Growers Association today submitted comments to the Environmental Protection Agency’s (EPA) proposed rule on Vehicle Test Procedure Adjustments for Tier 3 Certification Test Fuel. The proposed rule would change vehicle emission test procedures following the update in test fuel from E0 to E10 fuel and would have the effect of discouraging lower carbon fuels such as higher ethanol blends.
“Lower greenhouse gas (GHG) emissions from vehicles and improved fuel economy benefit consumers, our environment, and our energy security. Just as updating the test fuel from E0 to E10 reduced GHG emissions by blending cleaner, renewable ethanol with gasoline, E15 and future fuels that blend more ethanol will further reduce emissions and improve fuel economy when used with optimized engines.
“Vehicle test procedures for E10 certification fuel must not create impediments to low carbon fuels, such as E15 and higher blends and the vehicle technologies that help reach our mutual goals of lower GHG emissions and improved fuel economy,” NCGA President Kevin Ross wrote in the organization’s comments.
EPA is proposing to add carbon emissions to vehicle test results when less carbon was emitted from the vehicle tailpipe. Rather than penalizing lower carbon fuel through the proposed test procedure adjustment, EPA should support greater use of low-carbon fuels and consider how vehicles and fuels work as a system to reduce carbon and other tailpipe emissions.
NCGA’s comments urged EPA to take into account the following points:
- NCGA believes actual tailpipe carbon emissions, regardless of the test fuel, must continue to be the only measure of vehicle emissions performance in vehicle testing. CO2 test adjustments, such as those in the proposed rule, needlessly complicate vehicle test procedures now and in the future.
- NCGA supports stringency in the GHG and Corporate Average Fuel Economy (CAFE) standards. Stringency is best maintained through the GHG and CAFE regulations and the Administrator’s authority to adjust the stringency of the standards, not by adjusting emission test results.
- Separate from the change in certification fuel, NCGA has supported updating the R-factor in the fuel economy formula to better reflect modern engine technologies. While the proposed Ra factor of 0.81 is an improvement from the current 0.6 R-factor, we believe EPA should set this factor at or near 1.0 to support lower-carbon fuels and provide renewable ethanol equitable treatment compared with other alternative fuels and encourage lower carbon certification fuels.