On Monday, Boyden Gray & Associates filed comments on behalf of Urban Air Initiative urging EPA to correct its erroneous modeling of ethanol’s effect on gasoline emissions. The comments came in response to EPA’s Advanced Notice of Proposed Rulemaking on Increasing Consistency and Transparency in Considering Costs and Benefits in the Rulemaking Process.
EPA acknowledged that “any assessment of costs (and benefits) is limited by the state of scientific and economic modeling,” and “solicit[ed] comment on potential approaches that would provide improved consistency and transparency” in its cost-benefit analysis.
In response, Urban Air Initiative’s comments suggest that “EPA should take steps to better ensure that scientific models used to assess costs and benefits are based on robust and accurate science.” In particular, Urban Air Initiative urges EPA to update its vehicular emissions model, MOVES2014, which contains errors that BG&A has documented at length in a Request for Correction of Information submitted on behalf of UAI and the states of Kansas and Nebraska. As a result of these errors, the model is biased against ethanol and conflicts with the best available science.
UAI’s comments point out that MOVES2014 will affect EPA’s cost-benefit analysis and regulatory approach in many important agency actions, including an “anti-backsliding” study of the environmental effects of the Renewable Fuel Standard. If EPA relies on an inaccurate emissions model for such actions, they will be legally vulnerable.
BG&A’s comments are available here.
The Request for Correction of the MOVES2014 model is available here.