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| Prepared Witness Testimony The Committee on Energy and Commerce W.J. "Billy" Tauzin, Chairman -------------------------------------------------------------------------------- Issues Concerning the Use of MTBE in Reformulated Gasoline: An Update. Subcommittee on Oversight and Investigations November 1, 2001 1:00 PM 2322 Rayburn House Office Building -------------------------------------------------------------------------------- Mr. A. Blakeman Early Environmental Consultant American Lung Association 1726 M Street, NW Suite 902 Washington, DC, 20006 -------------------------------------------------------------------------------- Mr. Chairman, my name is A. Blakeman Early. I am pleased to appear today on behalf of the American Lung Association to discuss the use of MTBE in Reformulated Gasoline (RFG). The American Lung Association has long been a supporter of the use of RFG as an important tool that many areas can and should use to reduce unhealthy levels of ozone. Clean Fuels Help Reduce Smog As has been demonstrated in California, �clean� gasoline can be an effective tool in reducing car and truck emissions that contribute to smog. Based on separate cost effectiveness analyses conducted by both the U.S. EPA and the State of California, when compared to all available control options, reformulated gasoline (RFG) is a cost-effective approach to reducing the pollutants that contribute to smog.1 Compared to conventional gasoline, RFG has also been show to reduce toxic air emissions from vehicles by approximately 30 percent.2 The American Lung Association Supports the Phase Out of MTBE in All Gasoline As a member of the Blue Ribbon Panel on Oxygenates in Gasoline, the American Lung Association learned of the significant threat that MTBE poses to the nation�s water supplies. We also came to understand that the continued use of MTBE in RFG would contribute to the undermining of public support for the RFG program. Based on these two factors, we have supported the Blue Ribbon Panel recommendation that MTBE be phased out of all gasoline, not just RFG. We believe there is a broad consensus in support of the MTBE phase out. Elimination of the Oxygen Mandate in RFG Must Accompany any MTBE Ban If Congress were to ban MTBE and not eliminate the oxygen requirement for federal RFG a de facto ethanol mandate would be created. In essence, all RFG in the nation would be required to contain a minimum of 5.7% by volume ethanol (2% by weight oxygen). The American Lung Association firmly believes that mandating ethanol in summertime gasoline will contribute to increases in smog regardless of whether the fuel is RFG or conventional gasoline. Quite simply the big problem with ethanol use in gasoline is that it significantly increases volatility when mixed in gasoline at 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 contributes more to smog in most areas than do 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 a 1999 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 NOx 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 do not outweigh 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. 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 offset volatility increases from using ethanol. More of Mr. Early's testimony |
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