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| RFG with low RVP that contains ethanol will 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. Essentially, alcohol in fuels promotes 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 2 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 Motor Corporation presented test data to the California Air Resources Board (CARB) that shows 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. Toyota has also submitted additional data to CARB that shows new vehicles designed to be �alcohol resistant� may allow increases of evaporative emissions by 10 to 15% when using RFG with ethanol. 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 RVP6. 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 consumers switch back and forth 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. Aside, from the adverse air quality impacts of mandating ethanol in RFG, we believe that there may also be disruptions in RFG supply with attendant price spikes that will undermine public support for RFG. Although the ethanol industry is going to great pains to demonstrate it can supply all the oxygen needed in RFG across the nation, the simple fact remains that most ethanol is made in the mid-west and would be used in RFG areas thousands of miles away. Because ethanol must be separately transported and stored from RFG until it reaches wholesale or retail outlets, an entirely new infrastructure will be required under an de facto ethanol mandate. It is inevitable that this new infrastructure will fail at times. Such failures will cause price spikes and calls for the elimination of RFG or broad waivers. Areas that have opted in to RFG may opt out of the RFG program. We may even see a proliferation of more �clean� fuels that simply seek to avoid the ethanol mandate as some areas have sought to avoid MTBE in RFG. An MTBE Phase Out Must Include Provisions to Prevent �Backsliding� in Toxic Emissions Reductions from RFG The Blue Ribbon Panel found that the use of MTBE helped refiners achieve a greater reduction in air toxics from RFG than the minimum required by law. Clearly MTBE, if nothing else, dilutes the toxic components of gasoline. We want to be sure that refiners, in complying with the MTBE phase-out, do not substitute toxic components that degrade the air toxics emissions reductions currently achieved. The American Lung Association supports Congress enacting an anti-backsliding provision that locks in these air toxics reduction benefits. Such a provision should be based on the average toxics reduction performance achieved in 2000 and 2001 RFG. The refining industry argues that the Mobile Source Air Toxics (MSAT) rule issued by EPA under section 202(l) of the Clean Air Act serves this purpose and new legislative requirements are not required. We disagree. The MSAT rule uses outdated years to lock in past performance. Refiners are held to their performance based on an average of 1998,1999, and 2000. However, in the RFG program Phase II of the toxics program did not start until 2000. Phase II initiated additional statutory reduction in air toxics reductions. Refiners outperformed prior years in response to the Phase II mandate. The attached chart demonstrates the difference achieved between 1998,1999 and 2000. On a nationwide basis refiners produced Phase II RFG in 2000 that was 16 percent lower in air toxics than Phase I RFG produced in 1998 and 1999 (See Tab 4,5). We have little reason to believe refiners achieved lower air toxics reductions on average in 2001 than they did in 2000. As a matter of public policy we urge Congress not to take a step backwards by allowing Phase I years to be used as a measure of toxics performance in an anti-backsliding regime. Second, under the MSAT rule, if an existing refiner of RFG produces additional volumes of RFG above its 1998-2000 levels, those volumes of RFG need only meet the legal minimum for Phase II RFG of 21.5 % reduction from baseline gasoline. We believe this element of the MSAT rule has the potential of significantly degrading air toxics reductions of RFG over time, as the MTBE phase out causes shifts in production among refiners that are very difficult to predict, especially on a regional basis. Any anti-backsliding provision must require that RFG refiners must produce new RFG that meets on average the same average toxic performance that old volumes of RFG must meet One more page (I promise) |
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