Flawed Fuel Testing

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It’s not just who is working in the EPA/OTAQ offices that raised a red flag from our research. It’s also the technical data that shows the nation has been exposed to decades of flawed test fuels and flawed driving tests, which in turn means flawed emissions results and mileage claims. EPA/OTAQ has the unique ability to determine the outcome of tests, experiments, and studies.

It is simple logic really. You don’t use the producer of a toxic fuel to be your consultant and tell you how to produce test fuels. You also don’t ask them which product they would like you to use, or how they would prefer the fuel be tested. This information came from EPA emails obtained by the Urban Air Initiative through a Freedom of Information Act (FOIA) request.[1]

For example, emails between the EPA and the oil industry show that EPA asked oil industry employees what test fuels they would “prefer to see tested” and then revised the test fuels in response to their input. The EPA also threw out three test fuels after preliminary results showed that ethanol lowered emissions of nitrogen oxides and other pollutants and otherwise altered its slate of test fuels to downplay ethanol’s positive effects.[2]

The emails show that the EPA relied heavily on oil industry employees from Chevron and BP to design the test fuels in a large-scale fuel effects study known as the EPAct vehicle study. This is important because the EPA used the results of the EPAct study to update its vehicular emissions model, MOVES2014. All states must use this emissions model to develop and implement plans for compliance with EPA’s air quality standards.

The process of simply adding ethanol to base gasoline is called splash blending. This is what happens in the “real” world and it is what should happen during fuel testing. However, when this is done, the results are not favorable to the oil industry. Simply adding ethanol to gasoline improves gasoline in every way. It lowers carbon, reduces common air pollutants for smog formation, lessens CO2 emissions, reduces sulfur content, and provides clean octane as a replacement for toxic aromatics. This was the exact intent of the Clean Air Act octane amendments.[3]

Instead of using this splash blending method, match blending test fuels is the common process. It was used in MOVES Model testing and skews results. In studies with match blended fuels, aromatics are often increased when adding ethanol to the test fuel. The increase in emissions is then blamed on ethanol, when the aromatics are the true culprit.[4]

By certifying vehicles on gasoline formulations that do not exist, these vehicles then go out into the real world and fall short of standards. Of course, it is not the gasoline maker that is blamed, it is the automaker. The media and public have been so misled on emissions, the related health threat, and the higher cost of gasoline caused by not using more ethanol and fewer aromatics that the auto industry has finally weighed in on the flaws in the fuel testing approach.[5] In a Society of Automotive Engineers (SAE) paper they went on the record to complain that “no one would ever make fuel in that manner.”[6] The auto industry has been ready for many years to implement wide-scale use of higher blends of biofuels with the flex-fuel vehicles. But distortion in the media and public perception controlled by billion-dollar oil industry marketing campaigns and lobbyists have slanted the market to the point that the auto industry can’t promote the benefits of higher octane.

There are also legal implications of the EPA’s reliance on the oil industry to design the EPAct study.[7]

  • The EPA’s consultation with a group of oil company employees about the test fuel parameters violated the requirement of the Federal Advisory Committee Act and the EPA’s Scientific Integrity Policy that such committees be balanced, that they be publicly announced and that their meetings be open to the public.
  • The EPA’s exclusive reliance on oil industry employees with an incentive to generate results favorable to petroleum and unfavorable to ethanol violated the objectivity requirement of the Agency’s Information Quality Guidelines. It also violated the EPA’s Scientific Integrity Policy, which requires all employees, including scientists and managers, to “[a]void conflicts of interest and ensure impartiality.”
  • The EPA’s reliance on oil industry consultants was in violation of the Scientific Integrity Policy’s requirement that scientific findings be “generated and disseminated in a timely and transparent manner.”
  • The EPAct study contributed directly to the emissions factors in the EPA’s new vehicular emissions model, MOVES2014, which each state must use in constructing implementation plans for compliance with EPA’s air quality standards. The EPA’s unlawful reliance on the oil industry to design the EPAct study compounds the agency’s failure to give the public notice and an opportunity to comment on the MOVES2014 Model, as required by law.

Not only is the science EPA used inaccurate, so is the data it used to compare the cost of aromatics and ethanol. As revealed in a Senate EPW Committee report, the EPA manipulated key cost-benefit analyses and emissions modeling tests to make ethanol appear to be more costly than toxic aromatics. Further, EPA/OTAQ used these efforts to pin the emissions from aromatics on ethanol.[8]

Between the “Revolving Door” at EPA and the flawed fuel testing uncovered through FOIA emails, it’s clear that the system we have today is not working. The public should not suffer at the expense of Big Oil trying to limit competition and protect market share. In our next section, we will discuss what can be done to change the system, reduce toxic aromatics and improve the air we breathe.

Click here to the next section, What We Can Do

Footnotes:

[1] Boyden Gray & Associates, “fixourfuel.com,” May 4, 2018 , page 2
https://fixourfuel.com/wp-content/uploads/2018/06/Memo-re-EPAct-Emails-20180504c.pdf

[2] Steve VanderGriend, Request for Correction of Information submitted on Behalf of the State of Kansas, the State of Nebraska, the Energy Future Coalition, and Urban Air Initiative Concerning EPA’s EPAct/V2/E-89 Fuel Effects Study and Motor Vehicle Emissions Simulator Model (MOVES2014), filed Jan. 19, 2017
https://fixourfuel.com/wp-content/uploads/2017/01/Jan-2017-Request-for-Correction-MOVES2014.pdf

[3] Boyden Gray & Associates, “fixourfuel.com,” May 4, 2018
https://fixourfuel.com/wp-content/uploads/2018/06/Memo-re-EPAct-Emails-20180504c.pdf

[4] Steve VanderGriend, Request for Correction of Information submitted on Behalf of the State of Kansas, the State of Nebraska, the Energy Future Coalition, and Urban Air Initiative Concerning EPA’s EPAct/V2/E-89 Fuel Effects Study and Motor Vehicle Emissions Simulator Model (MOVES2014), filed Jan. 19, 2017
https://fixourfuel.com/wp-content/uploads/2017/01/Jan-2017-Request-for-Correction-MOVES2014.pdf

[5] Steve VanderGriend, Understanding the Emission Benefits of Higher Ethanol Blends: EPA Modeling Fails to Tell the Whole Story
https://fixourfuel.com/wp-content/uploads/2017/06/Understanding-Emissions-SVG.pdf

[6] James Anderson and Timothy Wallington, Ford Motor Company; Robert Stein, AVL Powertrain Engineering Inc.; William Studzinski, General Motors Co., Issues with T50 and T90 as Match Criteria for Ethanol-Gasoline Blends https://www.sae.org/publications/technical-papers/content/2014-01-9080/

[7]Steve VanderGriend, Request for Correction of Information submitted on Behalf of the State of Kansas, the State of Nebraska, the Energy Future Coalition, and Urban Air Initiative Concerning EPA’s EPAct/V2/E-89 Fuel Effects Study and Motor Vehicle Emissions Simulator Model (MOVES2014), filed Jan. 19, 2017
https://fixourfuel.com/wp-content/uploads/2017/01/Jan-2017-Request-for-Correction-MOVES2014.pdf

[8] Boyden Gray & Associates, Increasing Consistency and Transparency in Considering Costs and Benefits in the Rulemaking Process, ID No. EPA-HQ-OAR-2018-0107, June 13, 2018
https://docs.google.com/viewerng/viewer?url=http://boydengrayassociates.com/wp-content/uploads/2018/08/UAI-Comments-on-Increasing-Consistency-of-Cost-Benefit-Analysis-through-MOVES2014-ANPR.pdf