THE EPA, CLEAN AIR, AND GASOLINE
The U.S. Environmental Protection Agency's June 11 proposals on gasoline composition tug refiners in two directions. They ease little of the uncertainty over fuel requirements in last year's Clean Air Act (CAA) amendments. Yet they may show EPA appreciates the complexity of its task.
EPA might have used the proposals to clarify its intentions in many crucial issues. For example, it might have described how and under what circumstances refiners can obtain waivers to the 2.7 wt % oxygen content mandate for gasoline sold during winter 1992-93 in 41 areas not meeting federal carbon monoxide standards. It might also have taken steps to keep the reformulated gasoline program from ballooning out of control at start-up in 1995. Under CAA, 87 areas with marginal ozone pollution problems can voluntarily submit to a reformulated fuel mandate that otherwise applies to just nine chronic ozone areas. EPA might further have described how it plans to certify reformulated fuels, which would help refiners figure out how to make them.
REGULATION NEGOTIATIONS
These and other CAA concerns appeared in a National Petroleum Council report to the secretary of Energy early this month. EPA may not have addressed them now because it is trying to develop CAA regulations through negotiations among refiners, environmentalists, ethanol and methanol producers, state and local officials, and others. The process makes political sense. But it has yielded proposals-such as cost-blind supply estimates in the oxygenate waiver process and fuel specifications stricter than those in the law-that stretch reason.
A technical bulletin just published by the Auto/Oil Air Quality Improvement Research Program should help refiners. The bulletin reports on modeling studies gauging effects of gasoline composition changes on ozone levels.
A conclusion: Aromatics reductions and oxygenate additions have "no clear effect on ozone formation." No surprise here. Everyone, except perhaps most gasoline consumers, knew Congress was pandering to alcohol makers when it stuck a 2 wt % oxygen mandate in its reformulated fuel prescriptions for ozone. But that's history.
Among other CAA compliance challenges, refiners now must plan for two jumps in oxygenate demand-one in 1992 for carbon monoxide and another in 1995 for ozone. One problem is supply, which won't, at reasonable cost, meet 1992 demand at mandated levels. Waivers are essential.
THE LOGISTICS PROBLEM
Another problem is logistics. Refiners must start soon to build the oxygenate production, distribution, and storage facilities they'll need not just in 1992 but also in 1995. But they don't know now whether they'll have to provide oxygenated, reformulated fuel to nine cities or 96 or some number in between. They won't know until EPA decides how to handle the CAA opt-in provision. Especially after the auto/oil research program's findings on gasoline oxygen content and ozone, EPA's decision should be easy. The agency must not let overanxious cities with marginal ozone problems strain oxygenate sup-plies and distribution capabilities, which will still be tight in 1995, by lurching into overextruded fuel remedies.
These issues are extremely complicated. As the auto/oil program demonstrates with each new technical bulletin, the chemistry of vehicle fuels and air pollution doesn't lend itself to the simple prescriptions favored by politics and enshrined in the CAA amendments. Under the best of circumstances, refiners will have trouble meeting their new requirements and deadlines, and the degree of their difficulty will be reflected in future gasoline prices. EPA must not make a bad law worse.
Copyright 1991 Oil & Gas Journal. All Rights Reserved.