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Let’s not miss an opportunity and miss an opportunity – The decision between E85 and gasoline

both_ways2Over the last month or two, the debate over the merits of environmental benefits (including a reduction in greenhouse gas emissions) of E85 has become relatively intense, by media standards.

Perhaps the EPA’s proposal to modify the Renewable Fuel Standard led advocates on both sides of the dialogue to intellectually and emotionally wrestle with each other. Perhaps the apparent, albeit modest, growth of E85 stations and sales in the nation brought the supporters of E85 – corn growers, some environmentalists, and the detractors (primarily the oil industry and, again, some environmentalists) – out of the proverbial closet. Perhaps recent studies concerning the impact of E85 on GHG emissions – studies that, for the most part, suggest that using E85, when compared to gasoline or on its own, is a net plus in terms of reducing GHG emissions and several other pollutants – provided fodder for both proponents and opponents to take off the gloves.

Here’s what we know, or what we think we know: On balance, most government agencies that have been assigned to, or have assumed, the responsibility for measuring the overall impact of E85 on GHG emissions and pollutants, in addition to many independent think tanks (including universities), grant E85 positive marks, either on its own or as a fuel or when compared to gasoline. But the conclusions, to some doubters, are not conclusive. Ideologues or special interests aside, a handful of independent analysts working for reputable groups challenge the high marks granted to E85. The repartee is, at most times, more gentle and academically correct than that between intense E85 advocates and detractors. But the differences of views, while suggesting a clear tilt toward increasing the use of E85, should be discussed and responded to if consumers are to be easily convinced to make the switch from gasoline.

Let’s begin with the Argonne National Laboratory, a highly respected national research lab. It indicated late last year that its GREET (Greenhouse Gases, Regulated Emissions, and Energy Use in Transportation) Model estimated that the life cycle of GHG emissions from E10 (regular gasoline) was 439 grams per mile, and from corn-based E85, 341 grams per mile. Quite a difference! At relatively the same time, the Department of Energy indicated: “As with conventional fuels, the use and storage of ethanol blends can result in emissions of regulated pollutants, toxic chemicals, and greenhouse gases. However, when compared to gasoline, the use of high-level ethanol blends, such as E85, generally result in lower emissions levels. … Using ethanol as a vehicle fuel has measurable GHG emissions benefits compared with using gasoline. Carbon dioxide released when ethanol is used in vehicles is offset by the CO2 captured when crops used to make the ethanol are grown. As a result, FFVs [flex-fuel vehicles] running on ethanol produce less net CO2 than conventional vehicles per mile traveled.”

That’s a pretty strong statement!

The Congressional Budget Office’s recent estimates are a bit less enthusiastic. They are hedged with the institution’s usual and understandable caution, given its primary role in estimating alternate budgetary impacts of alternative policies. CBO’s June 2014 report on the RFS states: “Available evidence suggests that using corn ethanol in place of gasoline has only limited potential to reduce greenhouse gas emissions (and some researchers estimate that it could actually increase emissions).” A NASA sensor used by the Goddard Space Flight Center to test air quality above one ethanol refinery led to an obviously tentative and preliminary conclusion that ethanol refineries in the nation “could be releasing much larger amounts of ozone-forming compounds into the atmosphere than current assessments suggest.”

So what’s a guy to do (“guy” being a euphemism for both men and women)? First, understand that the enemy of the good is, indeed, often the perfect. Two, borrow and slightly amend Ambassador Abba Eban’s comments concerning securing peace in the Middle East: Let’s never miss an opportunity and subsequently miss an opportunity. After reviewing the non-advocacy literature, it seems clear that E85 has become a reasonable alternative to gasoline at the present time. It is not perfect. But it is perfectible to be sure and, indeed, it is being perfected both in the laboratory and from the production process through distribution to use in automobiles. Clearly, with respect to tailpipe emissions, E85 is now much better than gasoline.

Further, solid studies, like those from the Argonne National Laboratory, show that ethanol’s life cycle emission benefits are improving and are superior to gasoline. In this context, farmers are learning to better manage and increase efficiency in the growing of corn, thus reducing emissions related to land use. Several states, led by Colorado, now impose regulations that cut methane leakage in the supply chain. Alternative feedstocks (e.g., corn stover, cellulosic, natural gas, etc.) are on the horizon and offer the promise of an E85 that will be cheaper and result in significantly less emissions. Consumers will likely soon have choices among E85 feedstocks. This is good for the country. It will take place while electric and hydrogen vehicles improve their readiness for prime time and reach out to a larger share of the American market.

So visit your local, accessible, less-expensive, generally nice E85 fuel station and get rid of your addiction to oil and gasoline. Try E85! You will like it! While your humanity is being redeemed, urge key research agencies and think tanks to get together and work out their differences, something like the Manhattan Project. Agreeing on the value of alternative fuels in reducing emissions could well be as important in light of the specter of global warming and the increase of pollution as the invention of the atomic bomb.

From Philosophy About Truth To The Wisdom Of EPA Models About Emissions

Rereading Alfred North Whitehead, one of my favorite philosophers, provides the context for the current debate over the wisdom of using the EPA’s amended transportation emissions model (Motor Vehicle Emission Simulator, or MOVES) for state-by-state analysis. He once indicated that, “There are no whole truths; all truths are half-truths. It is trying to treat them as whole truths that plays the devil.”

I am uncertain about Whitehead’s skepticism, if treated as an absolute. However, it does give pause when judging the use of an amended MOVES model, based mostly on advocacy research by the nonprofit group, the Coordinating Research Council (CRC). The CRC is funded by the oil industry, through the American Petroleum Institute (API), and auto manufacturers.

CRC was tasked by the EPA with amending MOVES and applying it to measure and determine the impact of vehicular emissions. The model and related CRC analysis was subject to comments in the Federal Register but the structure of the Register mutes easy dialogue over tough, but important, methodological disagreements among experts. Apparently, no refereed panel subjected the CRC’s process or product to critique before the EPA granted both its imperator and sent it out to the states for their use.

I am concerned that if the critics are correct, premature statewide use of the amended MOVES model will mistakenly impede development and use of alternative transitional fuels to replace gasoline, particularly ethanol, and negatively influence related federal, state and local policies and programs concerning the same. If this occurs, because of apparent mistakes in the model (and the data plugged into it), the road to significant use of renewable fuels in the future will be paved with higher costs for consumers, higher levels of pollutants and higher GHG emissions.

With some exceptions, the EPA has been a strong supporter of unbiased, nonpartisan research. Gina McCarthy, its present leader, is an outstanding administrator, like many of her predecessors, like Douglas Costle (I am proud to say that Doug worked with me on urban policy, way, way back in the sixties), Russell Train, Carol Browner, William Reilly, Christine Todd Whitman, Bill Ruckelshaus and Lee Thomas. No axes to grind; no ideological or client bias…only a commitment to help improve the environment for the American people. I feel comfortable that she will listen to the critics of MOVES.

The amended MOVES may well be the best thing since the invention of Swiss cheese. It could well help the nation, its states and its citizens determine the truths or even half-truths (that acknowledge uncertainties) related to gasoline use and alternative replacement fuels. But why the hurry in making it the gold standard for emission and pollutant analysis at the state or, indeed, the federal level, in light of some of the perceived methodological and participatory problems?

Some history! Relatively recently, the EPA correctly criticized CRC because of its uneven (at best) analytical approach to reviewing the effect of E15 on car engines. Paraphrasing the EPA’s conclusions, the published CRC study reflected a bad sample as well as too small a sample. Its findings, indicating that E15 had an almost uniform negative impact on internal combustion engines didn’t comport with facts.

The CRC’s study of E15 was, pure and simple, advocacy research. CRC reports generally reflect the views of its oil and auto industry funders and results can be predicted early on before their analytical efforts are completed. Some of its reports are better than others. But overall, it is not known for independent unbiased research.

The EPA’s desire for stakeholder involvement in up grading and use of MOVES to measure emissions is laudable. However it seems that the CRC was the primary stakeholder involved on a sustained basis in the effort. No representatives of the replacement fuel industry, no nonpartisan independent nonprofit think tanks, no government-sponsored research groups and no business or environmental advocacy groups were apparently included in the effort. Given the cast of characters (or the lack thereof) in the MOVES’ update, there’s little wonder that the CRC’s approach and subsequently the EPA’s efforts to encourage states to use the amended model have been and, I bet, will be heavily criticized in the months ahead.

Two major, well-respected national energy and environmental organizations, Energy Future Coalition (EFC) and Urban Air Initiative, have asked the EPA to immediately suspend the use of the MOVES with respect to ethanol blends. Both want the CRC/MOVES study and model to be peer reviewed by experts at Oak Ridge National Lab (ORNL), and the National Renewable Energy Lab (NREL). I would add the Argonne National Laboratory because of its role in administering GREET, The Greenhouse Gases, Regulated Emissions, and Energy Use in Transportation Model. Further, both implicitly argue that Congress should not use the CRC study and MOVES until the data and methodological issues are fixed. Indeed, before policy concerning the use of alternative replacement fuels is debated by the administration, Congress and the states both appear to want to be certain that MOVES is able to provide reasonably accurate estimates of emissions and market-related measurements, particularly with respect to ethanol and, as Whitehead would probably say, at least provide half-truths, or, as Dragnet’s Detective Jack Webb often said, “Just the facts, ma’am,” or at least just the half-truths, nothing but at least the half-truths.

What are the key issues upsetting the critics like the EFC and the Urban Air Initiative? Apart from the pedigree of the CRC and the de minimis roles granted other stakeholders than the oil industry, the CRC/MOVES model, reflects match blending instead of splash blending to develop ethanol/gasoline blends. Sounds like two different recipes with different products — and it is. Splash blending is used in most vehicles in the U.S. and generally is perceived as producing less pollution.

Let’s skip the precise formula. It’s complicated and more than you want to know. Just know that according to the letter sent to the EPA by the EFC and Urban Air Quality on Oct. 20th, the use of match blending requires higher boiling points for distillation, and these points, in turn are generally the worst polluting aromatic parts of gasoline. It noted that match blending, as prescribed by the MOVES, results in blaming ethanol for increased emissions rather than the base fuel. There is no regulatory, mechanical or health justification for adding high boiling point hydrocarbons to test fuels for purposes of measuring changes in vehicle tailpipe emissions, when ethanol is part of the fuel mixture. Independent investigations by automakers and other fuel experts confirm that the use of match blending in the study mistakenly attributed increased emission levels to ethanol rather than to the addition of aromatics and other high boiling hydrocarbons, thereby significantly distorting the model’s emission results. A peer-reviewed analysis, which will be published shortly, found that the degradation of emissions which can result is primarily due to the added hydrocarbons, but has often been incorrectly attributed to the ethanol.

The policy issues involved due to the methodological errors are significant. If states and other government entities, as well as fuel supply chain participants, use the model in its present form, they will mistakenly believe that ethanol’s emissions and pollutants are higher than reported in study after study over the past decade. The reported results will be just plain wrong. They will not even be half-truths, but zero truths. Distortions in decision making concerning the wisdom of alternative transitional replacement fuels, particularly ethanol, will occur and generate weaker ethanol markets and opportunities to build a strategic path to renewables. The EPA, rather than encourage use of the study and the model, should pull both back and suggest waiting until refereed review panels finish their work.