Advanced BioFuels USA – The EPA E15 Ruling– No Need to Stop There. (2024)

by Doug Durante (Clean Fuels Development Coalition/Biofuels Digest)Go ahead, blend any amount of ethanol you want. And here’s why. -- ...The recent decision by the Biden Administration to provide an “emergency waiver” so E15 can continue to be sold during the summer months is of course good news but can’t help but leave a bad taste in our mouths. It is once again a kick-the can-down the road action driven by politics rather than common sense and practicality.

Just calling it an emergency waiver is an affront. How is it that the excuse to grant this waiver is that high gas prices and tight supplies justify it? Does that mean if gas was cheap they wouldn’t? Just once I’d like to see an EPA announcement that leads with the fact that the RFS and the ethanol it has unleashed is a low cost, high octane, low carbon fuel that has displaced more than 8 billion gallons of toxic aromatics, and this ruling is to the benefit of all consumers. With EVs in freefall, we are going to need that octane more than ever, which I’ll get to.

Instead, the agency stands by and makes little effort to correct mainstream media that reports they are lifting the “ban”, which is clearly a negative connotation and perpetuates the notion that the EPA is allowing a higher polluting fuel. It’s not unreasonable for a reporter, an elected official, or anyone else to ask, if this stuff was banned, why are you allowing it?

For starters, E15 is not and was never “banned”. Other than California, it is allowed to be sold anytime, anywhere—provided it meets the same vapor pressure limits of gasoline. E10, on the other hand, is provided a one pound waiver from that limit.

The ABCs of RVP

Under existing regulations, if the summer vapor pressure limit in any given area was, for example, 8 pounds pers square inch (psi), E10 would be allowed at 9 psi. E15could be usedbut only of it if it met the 8-pound standard—even though it is the same or lower RVP as E10. While it clearly makes no sense, it illustrates that there was no “ban”. The problem of course is that refiners would have to provide specialized sub-rvp gasoline so after the additional ethanol is added it did not exceed limits.

That is impractical for most refiners and the result is that retailers selling E15 have to stop selling in the summer months, hence the perception that it was banned.

By now we all know the lunacy of this– with no Rvp bump there is no rational reason to interpret the law the way EPA, refiners, and the courts have done. For 10% ethanol blends to get the one pound waiver and argue itonlyapplies to 10% is absurd. In fact, the authorizing language for the Rvp waiver is for gasoline containing 10% ethanol. Well, E15 contains 10% ethanol. What is more frustrating is that in a quirk of chemistry, the increase in vapor pressure peaks at just under 10% and then begins togo downas more ethanol is added. At 30% we would have a lower cost, high octane premium gasoline with no vapor pressure increase at all!

That high octane would allow automakers to easily increase compression to achieve the efficiency and reduced emissions we will never see from EVs. It is an illusion that EVs can provide meaningful near-term reductions in petroleum use or provide health benefits that the recent multi-pollutant rule promises. And these health issues are increasingly ignored due to the fixation on climate. Carbon may be killing the planet but it is killing people too.

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There are a couple of different approaches to resolving the Rvp issue. The first, and simplest, would be to have a nationwide standard that recognizes there is no negative difference to E15 and treat it the same as E10, everywhere, all the time. This has been denied by the courts and legislative efforts to date have not succeeded.

Frustrated after more than a decade of arguing this issue, 8 Midwest Governors said fine, if you are not going to extend the waiver then we reject it–all gasoline sold in our states must meet the same standard.Since refiners have set up their process to put out a sub-octane fuel and rely on ethanol to bring it up to specification (i.e. 87 octane minimum), this will force them to make the base gasoline low enough in vapor pressure that adding ethanol—any ethanol, be it 10 or 15%, meets the same final spec.

To clarify, what the Governors did was request EPA to opt their states out of the one-pound waiver, not to “allow” the sale of E15. The result, of course, is if the proper base gasoline is provided then there would be no limit to the sale of E15 This is not splitting hairs– it is an important nuance because if an ethanol blend can be sold as long as it does not exceed Rvp limits it should apply toanyblend. And this is where it gets exciting. This is a kick the door down, get out of the way path to truly higher blends.

Go Ahead– Blend Away.

Ethanol is an additive to gasoline. It is an approved additive in EPA certification fuel which, as the term implies, is used to certify emissions and efficiency. The late C. Boyden Gray, unquestionably one of the great legal minds in the fields of fuels and emissions, argued that once ethanol became an approved additive for the purpose of certification there is no restriction on how much ethanol can be blended with gasoline. In fact, he argued the burden of proof would be on EPA to demonstrate—afterthey did extensive testing—that there were negative emissions associated with such blends.

What all this means for ethanol is that retailers should feel free to blendanyvolume of ethanol they choose. Under the Governor’s request, all gasoline with ethanol would have to meet whatever the standard is for non-blended gasoline. Under a nationwide legislative fix all ethanol blends would be treated as E10 in terms of RVP. Either solution is better than where we are today, although a national solution would be preferable. Under both these scenarios, there seems to finally be the acknowledgement that we are talking about ANY/ALL blends greater than E10, rather than restricting this to just 15%. E15 could become the base gasoline nationwide.

While auto and government testing validate E30 as the optimum blend level, not limiting the Rvp issue to 15% is important because an orderly transition to an E30 fuel cannot happen overnight and splash blending up to an E20 or E25 may be a stairstep to E30. This is the scenario laid out in the Next Generation Fuels Actwhich has languished in Congress but is the best piece of legislation to come along since the RFS.

EVs will certainly have a role in future transportation, and they should. But I can fill the bed of a Ford E 150 with documentation that it is going to take more time than we are being told.

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With the largest motor fuel market in the world, for the US to allow itself to be captive to a 90% gasoline market is asinine. As we have pointed out many times, countries around the globe are using 20-30% blends and providing their citizens numerous benefits. We should be doing the same. READ MORE