Comment Log Display

We appreciate the opportunity to comment regarding California’s
Advanced Clean Cars Midterm Review (Midterm Review).  This comment
relates to the greenhouse gas reduction programs (GHG Programs)
discussed in the Midterm Review.  Due to recent federal regulatory
action, we recommend that the Governing Board direct ARB staff to
revisit some of the Midterm Review’s conclusions.  In particular,
we recommend that staff be directed to assess whether California
could better achieve GHG reductions in the transportation sector
through the integration of mid and high blend ethanol strategies as
components of the Advanced Clean Cars Program (ACC Program).  

Staff Review of GHG Programs
ARB staff participated in the joint agency midterm evaluation of
federal passenger vehicle GHG standards and corporate average fuel
economy (CAFE) standards with the U.S. Environmental Protection
Agency (EPA) and the National Highway and Transportation Safety
Association (NHTSA).  The Midterm Review reflects the staff
recommendations that the ACC Program be maintained in its present
form, and that California continue to participate in the national
program through the deemed to comply provision.  However the report
states:

“These findings on the benefits to California are based on an
analysis assuming the existing national GHG standards. If the
stringency of the national GHG standards were substantially
changed, (…) these findings would likely be different. In that
event, California could revisit whether it would have to conduct a
new analysis to determine whether compliance with a new National
Program would be an appropriate approach under California’s LEV III
program to address California’s unique air quality challenges and
its mandates to achieve aggressive GHG reductions to protect public
health and the environment.”

Recent Federal Policy Developments 
On March 13th, EPA and NHTSA issued a Notice of Intention to
Reconsider the Final Determination of the Mid-Term Evaluation of
Greenhouse Gas Emissions Standards for Model Year 2022-2025 Light
Duty Vehicles.  While it was appropriate for the Midterm Review not
to forecast this development, EPA and NHTSA have now formally
announced the reopening of these federal GHG policies.  It is
therefore prudent for ARB to recognize the existence of a dynamic
federal regulatory landscape, and to revisit California’s
strategies accordingly.  The Midterm Review provides the Governing
Board and ARB with an immediate opportunity to begin designing
California’s GHG programs to be more self-reliant, and to continue
ensuring that these policies are informed by federal GHG policies.

Ethanol is a Proven Method to Reduce GHG’s
Low blend ethanol has supplied most of the GHG gases achieved by
California’s Low Carbon Fuel Standard (LCFS) to date.  Low blend
ethanol has also generated most of the renewable identification
numbers (RINs) under the federal Renewable Fuel Standard (RFS) and
most of the carbon credits under California's Low Carbon Fuel
Standard (LCFS).  There are substantial additional GHG reductions
that mid and high level ethanol can deliver to the state.

Flex fuel vehicles (“FFV’s”) are capable of utilizing high blend
ethanol, with the typical fuel blend in California being 85%
ethanol with 15% gasoline (“E85”).  Previously, FFV’s were a
consistent component of both the CAFE and federal passenger vehicle
GHG standards.  FFV’s received credit for improving fuel economy
and reducing GHG emissions based on the calculations of vehicle
mileage performance with E85.  However, the level of actual E85
fuel usage in FFV’s previously caused NHTSA and EPA to phase down
the credit value of FFV’s within the CAFE and GHG Standards.  This
lack of federal credit caused the automakers to reduce the number
of available FFV models.  In 2013, there were 157 models of FFV’s. 
In 2017, that number has declined to 52.  Paradoxically, the
decline in federal policy support for FFV’s corresponded with a
strong increase in demand for E85, and a new pressing policy need
for both FFV’s and E85 stations to facilitate the introduction of
mid level ethanol blends (MLEB’s) for next generation vehicles that
require high octane fuel.  

This policy imperative is well-expressed in a very recent “Summary
of High-Octane Mid-Level Ethanol Blends” authored by the National
Renewable Energy Laboratory and Argonne National Laboratory:

“Original equipment manufacturers (OEMs) of light-duty vehicles are
pursuing a broad portfolio of technologies to reduce CO2 emissions
and improve fuel economy. Central to this effort is higher
efficiency spark ignition (SI) engines, including technologies
reliant on higher compression ratios and fuels with improved
anti-knock properties, such as gasoline with significantly
increased octane numbers. Ethanol has an inherently high octane
number and would be an ideal octane booster for lower-octane
petroleum blendstocks. (…) Thus the legacy FFV fleet can serve as a
bridge by providing a market for the new fuel immediately, so that
future vehicles will have improved efficiency as the new fuel
becomes widespread. In this way, (High Octane Fuel) can
simultaneously help improve fuel economy while expanding the
ethanol market in the United States via a growing market for an
ethanol blend higher than E10.”

Thank you for your consideration of this comment.