BG&A filed three sets of comments on NHTSA and EPA’s Proposed Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule. It their notice of proposed rulemaking, the agencies requested comment on “the potential benefits and disbenefits of high-octane fuel” and “on if and how EPA could support the production and use of higher octane gasoline.” All of the commenters urged EPA to remove regulatory barriers to the sale of higher concentrations of high-octane ethanol in gasoline, but each filing responded to the agencies’ request in a different way.
On behalf the Illinois, Iowa, Kentucky, and Missouri Corn Growers’ Associations, BG&A urged NHTSA and EPA to accurately account for ethanol’s displacement of petroleum and its carbon neutrality in their calculation of fuel economy and greenhouse gas emissions. The Corn Growers’ comments explain that high-octane midlevel ethanol blends are the best available means to cost-effectively increase vehicle efficiency and reduce greenhouse gas emissions from light-duty vehicles.
On behalf of the Urban Air Initiative and several ethanol plants, BG&A urged EPA (1) to approve a midlevel ethanol certification fuel; (2) to correct the current fuel economy formula’s bias against gasoline test fuels with higher ethanol content; (3) to update its outdated interpretation of the Clean Air Act to remove an illegal barrier to higher concentrations of ethanol in gasoline; and (4) to expedite its rule to rationalize the RVP standards for gasoline blends with more than 10% ethanol.
BG&A also filed separate comments on the proposed SAFE rule’s Draft Environmental Impact Statement (EIS), on behalf of Urban Air Initiative. These comments highlighted the air pollution and greenhouse gas benefits of midlevel ethanol blends and responded to NHTSA’s inaccurate suggestion that it is always unsafe or inappropriate for blends above E15 to be used in conventional vehicles.