WASHINGTON – NACS, along with SIGMA, sent
a letter to the Environmental Protection Agency (EPA) yesterday commenting
on the agency’s proposed Tier 3 Motor Vehicle Emission and Fuel Standards rule
(Proposed Rule) and urging it to maintain the current per-gallon sulfur caps.
NACS also commented on other provisions of the proposed rule that change to
test fuel specifications.
The letter incorporated industry concerns for the EPA’s
proposal on the sulfur cap and test fuel specification changes, in light of the
Renewable Fuel Standard (RFS) and Corporate Average Fuel Economy Standards
(CAFÉ).
“As with any policy imposing dramatic reforms on the motor
fuels market, the Proposed Rule cannot be implemented in a vacuum. It should be
considered in the larger context of the motor fuels industry in the United
States, particularly the evolution of the RFS,” the letter stated.
The letter noted the following:
(1) The
proposal makes E15 the default test fuel for most non-flex fuel vehicles (FFV),
though it is unlikely that E15 will gain significant market share in the near
future. “To the extent making E15 the default test fuel for non-FFVs may pose a
problem should those vehicles ultimately run on E10, the Agency should consider
delaying designating E15 as the default test fuel and instead make E10 the test
fuel until E15 is more widely available and utilized.”
(2) The
proposal makes E80-83 the default test fuel for FFVs and does not account for
the fact that certain jurisdictions contain caps on ethanol content in E85
below 80% or that ASTM defines E85 as containing 51 – 83 volume percent
ethanol. “The final rule should accommodate fuels that will actually be in the
market.”
(3) By
developing specifications for high-octane fuels and specifically referencing
E30, the proposal “could entrench
ethanol’s current role in the fuel supply,” as it also requires other potential
fuels of the future to petition the agency for approval as a test fuel.
“Ethanol may be the octane of choice at present, but EPA should allow for and
encourage new fuels to come to market rather than impose artificial impediments
to innovation.”
Finally, NACS and SIGMA said they both support maintaining
the current per-gallon sulfur caps of 80 parts-per-million (ppm) at the
refinery gate and 95-ppm downstream.
“Pipeline transport inevitably introduces the potential
for sulfur contamination of the gasoline being shipped through multiproduct
pipelines,” the letter concluded. “In addition, various gasoline additives also
contain varying levels of sulfur which contribute to the overall sulfur content
of gasoline. If the final rule requires
further reductions below the current sulfur cap standards, it could result in
higher capital costs for refineries, which inevitably are passed down to retailers
and consumers through higher prices. The
final rule should take every step possible to mitigate the adverse effect it
may have on fuel prices. Therefore, NACS
and SIGMA support maintaining the current per gallon sulfur caps.”