Urban Air Initiative Leads Effort to Update EPA Lifecycle Assessment As Key to the RFS

Washington, D.C., July 11, 2016: The Urban Air Initiative (UAI) was joined by six other organizations today calling for the US Environmental Protection Agency to revise its lifecycle assessment of ethanol and increase the volumes allowed under the Renewable Fuel Standard.

The Energy Future Coalition, the Governors’ Biofuel Coalition, the Clean Fuels Development Coalition, the Nebraska Ethanol Board, the 25x’25 Alliance, and the Nebraska Ethanol Industry Coalition all signed on to UAI’s comments. They argue that in the Proposed Rule EPA continues to ignore new science concerning ethanol’s lifecycle emissions of greenhouse gases (GHG) and other pollutants. EPA last conducted a lifecycle analysis of ethanol in the 2010 Regulatory Impact Analysis accompanying EPA’s 2010 Renewable Fuel Standard (RFS) Rule. Six years later, EPA continues to rely on this 2010 analysis to assess the costs and benefits of its annual standard, and to approve fuel pathways petitions for ethanol plants under the RFS.

EPA admits that it has not quantified benefits and costs for the 2017 proposed standard, according to UAI President David VanderGriend. “This omission is significant, because EPA’s partial waiver of the renewable fuel blending levels set by Congress diminishes the GHG, air quality, and health benefits of the RFS. And, EPA is required to use the best available techniques to quantify anticipated present and future benefits and costs as accurately as possible,” said VanderGriend.

The commenters contend that if EPA did use the best available science it shows that blending ethanol into gasoline has reduced emissions of GHGs and other air pollutants far more than EPA projected in 2010. EPA’s ethanol emissions estimates were inaccurate when they were published six years ago, and they have only become more inaccurate in the intervening years as ethanol production has become cleaner and gasoline has become dirtier. EPA’s reliance on erroneous lifecycle estimates downplays the costs of its partial waivers of the blending levels.

“Opening the door for higher ethanol blends not only reduces greenhouse gas emissions but reduces a wide range of pollutants that pose a significant health risk,” said VanderGriend. “We urge EPA to correct its analysis of the comparative lifecycle pollution effects of ethanol and gasoline and conduct a new cost-benefit analysis in light of the best available science. After doing so we believe EPA should allow the full amount of ethanol blending as called for in the RFS.”