EPA Should Withdraw Erroneous Vehicle Emissions Model
Washington, D.C. January 25, 2017: Stakeholders including the states of Kansas and Nebraska joined the Urban Air Initiative (UAI) and the Energy Future Coalition as they petitioned the U.S. Environmental Protection Agency to correct the agency’s flawed models that limit the use of higher blends of ethanol.
According to UAI representatives, for years, the EPA has published inaccurate data claiming that ethanol increases emissions, even though ethanol’s pollution reducing qualities have been demonstrated repeatedly. The false information originated with EPA’s fuel effects study known as the “EPAct study” and its vehicular emissions computer model called MOVES2014. This information is critically important because it sets the tone for EPA’s institutional bias against ethanol, and it impacts federal and state fuel policies that limit ethanol’s growth in the market and impair the nation’s air quality.
The filing is a Request for Correction of Information and is part of an ongoing effort by UAI to challenge EPA’s emissions data as well as the biased testing protocols and procedures that produced the erroneous data. The petitioners filed their initial Request for Correction in 2015. EPA declined to review that filing due to pending litigation but invited the petitioners to submit a new request later.
UAI’s Request for Correction explains in detail the fundamental flaws in the design of the EPAct study that produced EPA’s inaccurate emissions estimates. The filing also sheds light on the origin of these design flaws—EPA’s collusion with oil industry employees in the design of the study, as revealed by emails and other documents UAI obtained through a Freedom of Information Act request and related litigation. UAI refutes EPA’s emissions estimates for ethanol with peer reviewed scientific studies showing that ethanol reduces the same pollutants that EPA says it increases.
UAI Director of Technical Programs Steven Vander Griend said the data and technical findings supporting the petition is the result of more than five years of research by UAI. “EPA could have modeled ethanol’s emissions effects by simply adding ethanol to commercial gasoline blendstocks (‘splash blending’), or mimicking real-world refinery practices,” he said.
“Instead, the designers of the EPAct study created novel fuels through an arbitrary “match blending” process in which they first adjusted the gasoline blendstock to hold constant certain arbitrary parameters. Adding insult to injury, BP, Chevron, and others with a clear incentive to limit ethanol were involved in the design of the fuel testing.”
UAI’s lawyers at Boyden Gray & Associates submitted the Request pursuant to EPA’s Information Quality Guidelines, which call on the agency to respond within 90 days. In the meantime, EPA’s MOVES Review Work Group is reviewing MOVES2014 in preparation for a revised vehicular emissions model to be issued as early as 2018. UAI’s detailed analysis of the defects in EPA’s emissions factors should inform EPA’s assessment of the current model and its development of a corrected model.
“EPA simply must model real-world emissions, and test fuels under real-world conditions. Match blending fuels in the laboratory can produce skewed results and when that testing is done by petroleum interests we know we are not getting fair or accurate data,” said Vander Griend.
The states of Kansas and Nebraska argue that in addition to limiting their ability to achieve the environmental benefits of higher ethanol blends, EPA’s flawed model also diminishes State revenues derived from Kansas and Nebraska’s agricultural industries, because it encourages all States to develop emission controls that limit the sale and consumption of ethanol in motor vehicle fuel.
Contact: Kim Trinchet