At first glance, the Jan. 6 letter to three key federal energy and environment policymakers from 14 trade associations about possible early approval of a higher ethanol content in motor fuels might have seemed routine. But the communication included a summary of required midlevel ethanol tests that clearly showed how much work still needs to be done.
The group, which included the American Petroleum Institute, National Petrochemical & Refiners Association, petroleum product retailing and marketing associations, and manufacturers of automobiles, boats, and outdoor recreation equipment, expressed concern that the US Environmental Protection Agency might decide to prematurely raise the fuel ethanol limit to 15% from 10%.
"We urge EPA to base its decision on a complete and sound scientific record, and we urge [the US Department of Energy] to help provide this science by spending all the $15 million targeted for expanding and accelerating midlevel ethanol blends research in the 2010 appropriations bill," the 14 associations said.
Extend comments
"Moreover, EPA should reopen the E15 waiver comment period to allow public review of new test data prior to making a final decision on the waiver request," they told EPA Administrator Lisa P. Jackson, US Secretary of Energy Steven Chu, and Carol Browner, White House coordinator of energy, environmental, and global climate change policy.
The group's recommended tests are extensive. For light-duty vehicles alone, they include vehicle fuel storage and handling, onboard diagnostics, base engine durability, catalyst durability and deterioration, evaporative emissions' useful life, tailpipe and exhaust emissions, emission inventory and air quality modeling, and vehicle drivability and fuel volatility.
Some tests are already under way. The Coordinating Research Council is conducting a broad range of studies, the "Auto/Oil E10+ Test Program for Highway 'Non-FFV' Vehicles," funded by the oil and auto industries with DOE.
Just under way
"This test program was initiated in 2008 and, with a concerted effort and adequate funding, could be complete in 2011," Greco said in a Dec. 16, 2009, letter to Gina McCarthy, EPA's assistant administrator for air and radiation. Work is just getting started in studies of base engine durability and onboard diagnostic systems' false illuminations, he noted.
Recommended infrastructure tests in the Jan. 6 letter included underground storage tanks (USTs), dispensers, enhanced vapor recovery equipment, adhesives and seals, and sensors. For USTs alone, it indicated that fiberglass reinforced storage tanks manufactured before 1981 were not intended to store any ethanol, and those made in the 1980s and early '90s were built to store up to E10 only.
In his letter, Greco also cited the need for a comprehensive vehicle testing program including models from before 2004. He said, "It is important to protect consumers by evaluating the full range of short and long-term impacts of increasing the amount of ethanol blended into motor fuels."
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