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ACE Urges EPA to Develop a Technology-Neutral Approach When Finalizing Vehicle Emissions Standards

Sioux Falls, SD (July 6, 2023) – The American Coalition for Ethanol (ACE) urged the U.S. Environmental Protection Agency (EPA) to develop a technology-neutral approach when finalizing tailpipe emission standards for Model Years 2027-2032 light- and medium-duty vehicles to ensure meaningful reductions in greenhouse gas (GHG) emissions are achieved. While EVs accounted for just over 1 percent of all light-duty vehicles last year, and the EIA predicts they’ll comprise about 17 percent of all vehicle sales by 2030, EPA’s proposal effectively requires 60 percent of all vehicle sales to be battery electric vehicles (BEVs) only by 2030, ramping up to BEVs representing 67 percent of all vehicle sales just two years later (2032).
ACE CEO Brian Jennings submitted recommendations to discuss 1) the practical, technical and legal problems associated with arbitrarily regulating BEVs as the only solution to reduce GHGs from the transportation sector, and 2) how EPA can fix its proposal to develop a practical and achievable technology-neutral final rule.
Jennings referenced automakers’ skepticism over the feasibility of EPA’s proposed BEV transition and the dozens of factors the proposal relies on that are outside of the direct control of automakers and their suppliers, citing that “EPA itself lacks the jurisdiction to regulate or control complimentary polices needed to solve for many of these needs, such as securing foreign supplies of raw materials and minerals to make batteries, access to home and public charging infrastructure, state and local building codes, grid capacity and reliability, and perhaps most importantly, consumer preferences and fears associated with such a monumentally fast transition to BEVs.”
What’s more, EPA’s reliance upon non-binding company commitments and projections about BEV production does not make the proposal feasible. “Indeed, recently in setting final 2023 through 2025 renewable volume obligations (RVOs) for advanced biofuel, EPA specifically chose not to rely on the non-binding production capacity forecasts and commitments of prospective advanced biofuel producers,” Jennings said. “As a result, the final advanced biofuel RVOs are lower than desired by many of these prospective biofuel producers, but achievable in EPA’s view. Why would the Agency abandon that logic for this rulemaking and put all its faith in similarly non-binding commitments from BEV enthusiasts when proposing these ambitious tailpipe standards for vehicles?”
Further, “BEVs are not zero emission vehicles,” Jennings added. “They are zero tailpipe emission vehicles. EPA’s proposal conveniently ignores this reality by failing to account for the entirety of lifecycle GHG emissions associated with BEVs and the minerals/materials necessary to produce and power them.”
Instead, ACE implored EPA to rework its proposal to develop a more practical technology-neutral approach, giving much more consideration to replacing the fossil fuel-based gasoline powering internal combustion engines with a lower carbon and higher octane alternative, such as ethanol.
The comments state that EPA must address fuel quality and establish new certification fuel pathways to account for the tremendous benefits of high ethanol blends such as E15 and E85, as well as conduct a full lifecycle GHG emissions analysis based on the latest version of the GREET model, among other recommendations.
ACE’s comments also outline how ethanol and agriculture are part of the solution. The science is clear: agriculture is critical to reduce GHG emissions. In 2018, the Intergovernmental Panel on Climate Change (IPCC) found that 89 percent of the globe’s capacity to mitigate carbon emissions comes from agricultural soil carbon sequestration.
“Understanding the potential for climate-smart agriculture to help dramatically reduce the lifecycle GHG emissions of corn ethanol, ACE is proactively working to document the benefits climate smart practices have on the carbon intensity of corn ethanol in a scientifically irrefutable manner,” Jennings said. “The best way to unlock decarbonization opportunities from climate-smart agriculture is through clean fuel policy which stands up markets to help offset farmer cost of adoption.”
Jennings concluded by urging the agency to “reconsider its proposal, develop a technology-neutral approach to decarbonizing transportation fuel, and engage with ACE as we implement our project to ensure fair and accurate accounting for GHG reductions from climate-smart agriculture and ethanol.”
ACE’s full comments can be accessed here.
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