Modifications to Fuel Regulations to Provide Flexibility for E15 and to Elements of the Renewable Identification Number Compliance System

May 9, 2019

Project Summary

In this proposed rule change, the Environmental Protection Agency (EPA) seeks comment on changes to rules governing sales of E15, a gasoline blend with up to 15% ethanol. Current rules designed to prevent ground-level ozone emissions limit gasoline retailers’ ability to sell E15 in the summer. The proposed rule change would effectively allow year-round sales of ethanol.

In this comment, the author shows how permitting year-round E15 sales introduces a number of environmental concerns that are inadequately addressed by the proposed rulemaking’s analysis. Specifically, the proposal’s exclusive reliance on EPA models and simulations of tailpipe emissions ignore alternative methodologies that more credibly reveal ethanol’s environmental impact on urban transportation emissions. Moreover, the proposal’s sole focus on tailpipe emissions does not address the numerous environmental problems associated with the lifecycle of ethanol production that would be aggravated by further ethanol expansion.

The comment concludes that EPA should expand its analysis to fully consider the environmental consequences of year-round E15 sales and use additional methodological approaches to measure those consequences. Rollout of more ethanol into the nation’s transportation fuel would only exacerbate the country’s environmental problems and would not further the Clean Air Act’s ultimate objectives of environmental protection.

Project Authors
Arthur R. Wardle

CGO scholars and fellows are occasionally invited to provide testimony to public hearings and legislative meetings. They also occasionally conduct independent analyses addressing government policies and proposals which are submitted to agencies as public interest comments. These testimonies and comments are designed to assist policymakers as they study and explore issues. The views expressed in testimonies and comments are those of the author(s) and do not necessarily reflect the views of the Center for Growth and Opportunity at Utah State University or the views of Utah State University.