But when you talk about E30, now we are getting somewhere. E30 would be a 200% increase over E10, making RINS so cheap you’d never hear about RIN Prices again. States should be allowed to sell such a fuel, retailers should be allowed to sell it, and automakers should warrant their cars for it. Again, EPA is keeping all that from happening and with true regulatory relief could make the RFS irrelevant.”
Robert: You are legally capped by mandate, but there’s no cap in a free market that keeps you from selling more than 15 billion gallons if E85 demand was higher. To be clear, I would fully support a choice to put E30 in cars. But your statement above encapsulates my point. Every administration has their own policies. National goalposts can and will be moved on a regular basis. That’s why it’s best not to rely upon them.
Doug: Ok, point taken, so let’s come back to the regulatory barriers. We already talked about the barrier of EPA eliminating vehicle incentives to OEMs that cost taxpayers nothing. Next is the E15 vapor pressure rule which was granted because 15% ethanol was deemed to be “substantially similar” to 10% ethanol, and in fact has lower vapor pressure. It is a linear downward path that with volume eliminates the very evaporative emissions the controls were put in place for. But EPA did not extend the waiver to anything above E15, keeping intact a regulatory barrier that will make it extremely difficult to gain approval for higher blends. It only took 10 years to get year-round E15!
Then they threw in the provision that a blender pump is now a refinery and the pumps are fuel manufacturers. Another regulatory barrier is EPA’s outdated and extremely harmful emissions modeling that states are required to use and incorrectly attributes higher emissions to ethanol rather than aromatic compounds in laboratory tests that even automakers say are not realistic.
EPA has failed to regulate toxics as required under the clean air act which would reduce aromatic compounds used for octane and allow—not require—ethanol to compete IF they removed the volume limitations.
Permeating all of this is EPA’s woefully inaccurate and outdated life-cycle modeling that assumes a negative carbon footprint for corn ethanol when every other reputable model shows a huge gain in carbon benefits. The Departments of Energy and Agriculture have much more expertise in this field, yet EPA has kept this barrier in place. The list goes on—labeling, reporting, paperwork— everything the President told his agencies to do in terms of eliminating barriers and opening markets.
We recently helped produce a report called Gasolinegate detailing all of our concerns with EPA. It is on our website along with some other items of interest, including a detailed report on Mobile Source Air Toxics linked to gasoline. Our obstacle is EPA, plain and simple.”
Robert: Well, EPA is a federal, political organization. This really underscores the points I have been making, which are that you can’t keep relying on a federal policy to keep the ethanol industry in business. Ideally, it would compete based on price across the country. But if that’s not possible, then the states that produce nearly all the ethanol — the Midwest — need to take matters into their own hands and tilt the playing field in accordance with the benefits they receive for this industry and all its dependent industries.
Doug: I think in an odd way we are agreeing on more than we disagree. But I think it’s unfair to paint our farmers and ethanol producers as looking for handouts. Our farmers want to be able to sell their products; our ethanol producers want to be able to sell their products……until we truly have a free market. We are replacing 8 billion gallons of toxic aromatics in gasoline all over the U.S. so this is not simply a Midwest fuel.”
In closing, I would like to thank Doug for the respectful exchange of ideas.