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Federal Document Clearing House
Congressional Testimony
June 14, 2000, Wednesday
SECTION: CAPITOL HILL HEARING TESTIMONY
LENGTH: 4870 words
HEADLINE:
TESTIMONY June 14, 2000 A. BLAKEMAN EARLY ENVIRONMENTAL CONSULTANT THE AMERICAN
LUNG ASSOCIATION, SENATE environment & public works clean
air, wetlands, private property, and nuclear safety ETHANO AND THE CLEAN AIR ACT
BODY:
June 14, 2000 Testimony of A. Blakeman Early,
Environmental Consultant to the American Lung Association, before the
Subcommittee on Clean Air, Wetlands, Private Property and Nuclear Safety, Senate
Environment and Public Works Committee, Good morning Mr. Chairman and members of
the committee. My name is Blakeman Earl) . I at.. an environmental consultant
appearing on behalf of the American Lung Association. I was invited to discuss
the benefits and problems associated with the use of ethanol in
gasoline under the Clean Air Act. While the American Lung
Association has been accused of being anti- ethanol, we consider our position to
be neither anti nor pro ethanol. Our view is that ethanol should be used in
gasoline when it can help provide useful properties to reduce
air pollution and it should be discouraged from being used if the result is
increased air pollution. Ethanol in Gasoline Helps Reduce
Carbon Monoxide (CO) Ethanol's greatest attribute is its ability to provide
oxygen to the fuel which can reduce carbon monoxide. Therefore, the ALA supports
the use of ethanol in the wintertime oxy-fuel program to help reduce unhealthy
levels of carbon monoxide. The oxy-fuel program is mandatory under the Clean Air
Act for areas that are classified "moderate" non-attainment for carbon monoxide.
But as you know, the air pollution effort against CO is being won and the number
of these areas is diminishing. This is due primarily to improvements in
emissions control equipment on new cars. Ethanol helps to reduce CO tailpipe
emissions from older vehicles. Ethanol Provides Clean Octane Ethanol is a good
source of octane and contains no aromatics and modest levels of
sulfur. These three attributes make it useful as a blending
component in gasoline. As a result, refiners use ethanol to
help achieve limits on toxic aromatics and sulfur in the RFG
program. We anticipate refiners will also use ethanol to help meet
sulfur limits in EPA's recently promulgated Tier II
sulfur limits for conventional gasoline which
begins in 2004. While ethanol can help achieve limits to aromatics and
sulfur, they do not guarantee that result, which is in part why
the ALA does not support mandatory use of ethanol in RFG. Looking at Figure B2,
taken from the Blue Ribbon panel report, you can see that the RFG sold in
Chicago in 1998 achieved among the smallest reduction of air toxics, despite the
presence of 10 percent ethanol. 1 Further, looking at the attached Figures 15,
16, and 17 taken from an analysis of 1996- 1998 gasoline
quality, you can see that sulfur levels in RFG sold in Chicago
in 1996 and 1997 were among the highest in the nation despite the use of
ethanol. However, in 1998 sulfur levels in Chicago dropped by
40 percent even though oxygen mandate was still being met with relatively the
same amounts of ethanol. 2 Ethanol can help lower sulfur level
but does not guarantee it. 1 Achieving Clean Air and Water, The Report of the
Blue Ribbon Panel on Oxygenates in Gasoline, September, 1999,
p. 43. 2 An Analysis of 1996-98 Gasoline Quality in the United
States, SAE 199-01-3584, October, 1999. The findings above demonstrate why the
ALA does not support mandating ethanol to achieve any other outcome besides CO
reductions in the wintertime. The ALA and many environmental organizations
supported a 2 percent oxygen requirement for RFG in the Clean Air Act Amendments
of 1990 based on the assumption at the time such requirement would guarantee
reductions of VOCs, and tonics. We now know we were wrong. Clearly, the best way
to obtain reductions of specific pollutants from gasoline is to
mandate them - set performance standards - and let refiners meet such
requirements however they choose to. Ethanol Increases Gasoline
Volatility Now let me turn to the problems caused by mandating ethanol in
gasoline. Quite simply the big problem with ethanol use in
gasoline is that it significantly increases volatility when
mixed in gasoline al levels above 2 percent by volume. Reducing
gasoline volatility during hot summer weather is one of the
most important strategies for improving summertime gasoline in
order to reduce smog. That is because with the advance of pollution equipment on
automobiles, evaporation of gasoline hydrocarbons is now a
greater contributor to smog in most areas than the tailpipe hydrocarbon
emissions. The volatility increases that ethanol causes in summertime can
overwhelm any benefit it provides in reducing CO tailpipe emissions,
sulfur dilution or aromatics dilution. That is why the ethanol
industry only talks about the tailpipe emissions benefit from ethanol in RFG.
The ethanol industry often quotes last year's National Research Council study of
reformulated gasoline as finding that CO reduction credit
should be included for ethanol in EPA's complex model for RFG because CO
tailpipe emissions contribute to ozone formation. But they fail to acknowledge
what we believe to be a more important finding. The NRC report stated, "...the
increase in the evaporative emission from the ethanol-containing fuels was
significantly larger than the slight benefit obtained from the lowering of the
CO exhaust emissions using the ethanol-containing fuel." 3 The NRC also
acknowledged that ethanol increases BOX tailpipe emissions relative to
non-ethanol containing fuel. These NOX emissions also contribute to greater
ozone and particulate formation. 4 The bottom line: the reduction in CO tailpipe
emissions obtained by using ethanol in summertime gasoline are
not worth the increase in evaporation and the increases in NOX tailpipe
emissions from a smog contribution point of view. Incidentally, the increases in
evaporation do not just contribute to ozone formation. Since the
gasoline also contains toxic aromatics, such as benzene, these
will evaporate more readily along with the ethanol. While ethanol may dilute the
amount of benzene in a gallon of gasoline, the amount of
benzene that ends up in the ambient air due to increased evaporation from the
fuel may be greater than if the ethanol were not added at all. 3 Ozone-forming
Potential of Reformulated Gasoline, May, 1999, p. 158. 4
California Environmental Protection Agency Air Resources Board, Air quality
Impacts of the Use of Ethanol in California Reformulated
Gasoline, December, 1999. It is argued that if ethanol is
mandated in RFG, air quality is protected because refiners are required to limit
the volatility by the RVP limits of EPA's RFG regulations. Thus the impact of
ethanol on volatility is not a factor. This is not true. First, while it is
clear refiners can off-set the volatility effect of ethanol by blending it with
super low volatility blend-stock, we do not know what potential air quality
benefits may be lost by changing other parameters of the fuel to meet the RVP
limit. For instance, a refiner might actually increase aromatics because they
need a sulfur-free component that is low in volatility to help
off-set volatility increases from using ethanol. For example, turning back to
Table B2, if ethanol were required in RFG sold in Rhode Island where MTBE has
been used to provide oxygen, the significant tonics reductions achieved might
decline to the same level achieved in Chicago as refiners increase aromatics to
help off-set the volatility effect of the ethanol. Low Volatility RFG With
Ethanol Can Cause Increased Evaporation of Fuel Even RFG with low RVP that
contains ethanol may cause increases in evaporation compared to non-ethanol
containing RFG in two ways: through increased permeation of "soft parts" in auto
engines and also through co-mingling with ethanol free fuel. EPA in its Tier 2
Final Rule identified permeation as a problem that can increase evaporation of
gasoline. Essciitially, alcohol in fuels promote the passage of
hydrocarbons through the "soft products" in cars, such as plastic fuel tanks,
hoses, and "o" ring seals. As a result, all new cars subject to Tier evaporative
emissions requirements have to demonstrate that they are using materials that
resist the permeability effect by testing them with fuel containing 10% ethanol.
5 But of course this does nothing to protect the vehicles on the road today.
Only vehicles being made since approximately 1994 have been consistently using
alcohol resistant soft materials. How much will an ethanol- containing RFG
meeting RVP limits increase evaporation from vehicles on the road today?
Probably a great deal. The Toyota Corporation presented test data to the
California Air Resources Board that showed a high RVP fuel increased evaporation
from gaskets, plastic fuel tubes and plastic gas tank material by 500, 1300, and
800 percent, respectively (See Tabs 1, 2, 3). Even if a fuel meeting RVP limits
caused permeation at a half or quarter of the rate of the non-complying fuel
tested, this would have a major adverse impact on vehicle evaporative emissions.
This concern is of special relevance to a renewable fuel mandate that would
apply in areas that are in non-attainment for ozone where conventional
gasoline is used. I will discuss this in a moment. 5 See
discussion at 64 Federal Register, 26084, May 13, 1999. Ethanol Fuel Can
Increase Volatility of Non-ethanol Fuels Finally, I must note the impact that
ethanol volatility can have through a mechanism referred to as "co-mingling".
Essentially when two fuels with the same RVP, one ethanol free and one
containing ethanol, are mixed together the volatility of the entire mix is
substantially raised. In a circumstance where consumers purchase ethanol free
fuel, use a portion and then purchase fuel with ethanol in it, even if the
ethanol blend is low RVP RFG, volatility can raise as much as 8/10ths of a pound
RVP 6 . In essence the adverse volatility effect of ethanol is not limited to
the absolute volume sold in a given market area. It can be greatly magnified,
depending how much consigners switch back and fords in purchasing the two types
of fuels. Whenever the volume of ethanol in the gas tank exceeds 2 percent, the
volatility of the entire tank-full of gasoline will be
increased. The "co-mingling" might occur between ethanol containing RFG and
conventional fuel among drivers who frequent the areas on the border between
non-RFG and RFG areas; among purchasers of ethanol- containing and ethanol-free
conventional gasoline in non- attainment areas for ozone; or
even within an RFG area where there is ethanol-free and ethanol containing RFG.
The volatility increases that could be caused by the permeation and co-mingling
effects of ethanol in RFG, under some conditions, could potentially offset the
entire lower volatility benefit of moving from Phase 1 RFG to Phase 2 RFG. 6
In-use Volatility Impact of Co-mingling Ethanol and Non- ethanol Fuels, SAE
940765, February 1, 1994. Ethanol Should Not Be Mandated in Summertime
Gasoline Used in Smoggy Areas All this leads the ALA to the
conclusion that ethanol should not be mandated for use in summertime
gasoline - RFG or conventional - in areas with smog problems.
To the extent that refiners are allowed to use ethanol in summertime on a
widespread basis, we must develop ways of calculating and off-setting the
adverse effect from increased evaporation that will occur either from
permeation, co-mingling, or both. For instance, California has lowered the RVP
of its Phase 3 CalRFG by one tenth of a pound in an effort to offset the
co-mingling effect. California is studying the need to provide a greater
off-set. If ethanol is mandated through a renewable fuel standard such as is in
Senator Daschle's S. 2053, which will triple the amount of ethanol in the
national fuel supply, appropriate measures need to be taken to protect areas
with smog problems. Congress should eliminate the one pound RVP waiver (Section
21 1 (h)(4)) currently available for corlventional gasoline
containing 10 percent ethanol sold in the summertime in areas that are
non-attainment for ozone. The RVP waiver for 10 percent ethanol fuel also should
be eliminated from use in areas designated as non-attainment under the eight-
hour National Ambient Air Quality Standard for ozone promulgated in July, 1997.
The waiver could be retained for ethanol- containing gasoline
sold in areas that do not have smog problems. This also happens to be the region
of the country where much of the ethanol is currently produced. Given what I
have described today, refiners must at a minimum meet the same RVP limits that
apply to ethanol-free conventional gasoline so that higher
volatility ethanol-containing gasoline does not contribute to
increased smog in areas that already have unhealthy levels of smog. This, of
course, would not prevent the evaporative effects caused by co-mingling that I
described previously. It would encourage refiners to avoid selling
ethanol-containing gasoline in areas with smog problems during
the designated ozone season because meeting lower volatility limits would
increase refining costs. Of course, during the rest of the year refiners would
be free to sell ethanol-containing gasoline in these areas, as
no RVP limits apply. Congress should also modernize the anti-dumping provisions
for conventional gasoline in Section 211 (k)(8) to prevent
increases in aromatics and other air pollution increasing constituents as they
modify RFG. The ALA suggests substituting 1999 for the current 1990 baseline as
a simple means of up-dating this provision to protect conventional
gasoline. Ethanol Increases NOX and Particulates Most test data
show that ethanol in RFG increases NOX tailpipe emissions. In California, the
Air Resources Board asserts that these NOX increases are converted in the
atmosphere to particulate poiiu ion, thus making it more difficult to achieve
the PM-1C National Ambient Air Quality Standard 7 . The ethanol industry asserts
that ethanol in RFG actually reduces particulate emissions based on a test
conducted by the Colorado Department of Health and Environment. Since this test
involved higher RVP winter time fuel and wintertime temperatures, the ALA sees
it as supporting the use of ethanol in wintertime oxyfuel, but not useful in
judging the benefits of ethanol in RFG. We believe that the NOX increases from
ethanol in RFG add to the body of evidence indicating mandatory ethanol use in
RFG may increase rather than decrease air pollution levels from fuel. 7 Letter
from Michael P. Kenney, Executive Officer, California Air Resources Board to
Robert Perciasepe, Assistant Administrator of U.S. Environmental Protection
Agency, February 7, 2000. Ethanol Use in Gasoline and RFG Will
Grow Much discussion has been generated about mandating the us of ethanol in
gasoline for air quality reasons, which the ALA opposes.
However, we do believe there will be a large role for ethanol in
gasoline without any mandate for one simple reason: octane.
Assuming that MTBE is either phased down or eliminated from
gasoline, which the ALA supports, refiners face a dramatic
shortage in clean octane even if every MTBE plant in the nation is converted to
produce iso- octane or allylates, the most logical substitutes for MTBE. This is
because MTBE plants converted to produce iso-octane or alkylates lose about 30%
volume and produce a product that contains 15 percent less octane per gallon.
This octane shortage is magnified by EPA's Tier 2 low- sulfur
gasoline standard which will be in full effect in 2006. Refiners will
lose modest amounts Of Octane in conventional gasoline, as they
treat it to reduce sulfur in order to meet the new 3G ppm
sulfur average requirement. As a result of these two impacts, a
rough calculation h dica.es iliat demand for ethanol needed to supply octane in
gasoline should increase to 3.4 to 3.8 billion gallons per year
by 2006, depending upon whether MTBE is totally eliminated from
gasoline.(See Tab 4 and Tab 5) This is at least twice the
baseline volume of ethanol projected by the Department of Agriculture to be
produced in 2006. 8 Should Congress fail to lift the oxygen mandate for RFG so
that all the octane currently provided by MTBE be replaced by ethanol in order
to simultaneously meet the oxygen requirement, the demand for ethanol would
reach 4.6 billion gallons per year in 2006. This would appear to exceed the
ability of the ethanol industry to supply ethanol, based on a study conducted
for the Governors's Ethanol Coalition. 9 (See Tab 6) Such an outcome would
undoubtedly lead to shortages, price spikes, and disruptions which could only
lead to reductions in the air quality benefits provided by the RFG program. 8
U.S. Department of Agriculture, Economic Analysis of Replacing MTBE with Ethanol
in the United States, March, 2000. 9 John Urbanchuk, Ability of the U.S. Ethanol
Industry to Replace MTBE, March 20, 2000. Clearly, we will need large increases
of ethanol in gasoline, as we phase out MTBE. From an air
quality perspective, it is best to set air quality performance requirements for
gasoline and allow refiners to use ethanol when and where they
need to while meeting performance requirements, taking into account evaporation
effects from permeation and co-mingling. Should Congress decide to mandate
ethanol in gasoline, we urge that additional air quality
protections be put in place that would encourage ethanol use in ways that
benefit air quality and not add to the air pollution burden.
LOAD-DATE: June 15, 2000, Thursday