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Posted on  

August 23, 2000

RFA, NCGA Urge EPA to Deny California Waiver from RFG Oxygen Standard


In a letter sent to U.S. Environmental Protection Agency (EPA) Assistant Administer Robert Perciasepe, the Renewable Fuels Association (RFA) and National Corn Growers Association (NCGA) reiterated their opposition to California’s request for a waiver from the federal reformulated gasoline (RFG) oxygen standard in light of the growing technical data demonstrating the air quality benefits of oxygenates such as ethanol.

“While I understand California s desire to remove MTBE from its gasoline supply as quickly as possible, the science demonstrates that oxygenates like ethanol do provide real air quality benefits that result in cleaner air for our citizens,” said Eric Vaughn, President of the RFA. “Using ethanol will maintain the air quality benefits of RFG without harming water supplies.”

“We show that the California predictive model under-predicts the contribution of on-road higher emitting vehicles to the NOx and VOC inventories. Our analysis demonstrates that non-oxygenated gasoline will increase VOC emissions while providing little if any NOx benefits,” the letter states. The analysis also examined the impact of non-oxygenated gasoline on off-road emissions, concluding NOx emission decrease slightly while VOC emissions increase significantly. “We conclude that for all reasonable attainment plans, the increase in VOC will increase ozone.”

“Our analysis continues to show that removing oxygenates from gasoline will have negative environmental consequences. That is why EPA should deny this waiver and begin the transition to ethanol in California,” said Lynn Jensen, President, NCGA.

The analysis, completed by the Colorado School of Mines, with Predictive Model and Emissions Weight Development provided by ICF Consulting and Environ International Corporation, concludes:

· The California Air Resources Board (CARB) has incorrectly accounted for the effect of higher emitting vehicles on the VOC inventory in its predictive model;

· CARB s purported NOx benefits for non-oxygenated fuels will not materialize in a world where refinery economics dictate fuel formulation decisions; and

· Switching from RFG2 to RFG3 without oxygen will increase VOC emissions from the on-road and off-road fleet and thus may increase ozone in Southern California. This finding is in direct contradiction to CARB s result.
 

 

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