Kansas and Nebraska Challenge EPA on Ethanol Emissions Model

On December 5, the state of Kansas, the state of Nebraska, the Energy Future Coalition and the Urban Air Initiative filed suit against the Environmental Protection Agency (EPA).  The suit is asking for the D.C. Court of Appeals to review EPA’s MOVES2014 model, a tool which states are tasked with using to model the contribution of various emissions to air pollution.  The problem with the model, according to the Kansas and Nebraska Attorney Generals, is that the model was built on poorly-done studies of vehicle emissions that don’t reflect real-world fuel blending conditions.  From these studies, EPA had concluded that an increase in ethanol volume in fuels causes an increase in toxic emissions. Kansas Attorney General Derek Schmidt commented on the reason for the suit, stating, “EPA’s requirement that states use this faulty model was unlawfully adopted without notice and opportunity for comment. This is an example of the EPA imposing its will on the states rather than working cooperatively toward the shared goal of cleaner air. We are asking that this model be rejected and replaced with a model that more accurately reflects the true emission effects of ethanol.”

In a previous letter to EPA, the Energy Future Coalition and the Urban Air Initiative asked the agency to include Department of Energy labs in their peer-reviewed fuel testing process, and to exclude the MOVES model from state assessments of air quality impacts from ethanol.  The problem, according to their letter, is that the underlying studies used to build the model don’t use real-world conditions, which has the consequence of worsening the emissions profile of ethanol-blended fuels. When ethanol is “splash-blended” with gasoline, as it is at the refinery, it lowers the overall toxicity of emissions.  According to the two groups, EPA’s studies were conducted using a method called “match blending,” which artificially controls certain fuel parameters, and is not reflective of what happens at refineries.  These findings are backed-up by a November paper in the peer-reviewed journal, Society of Automotive Engineers (SAE).  According to the paper, not only does the use of match blending cause the emissions profile to be worse than in splash blending, but this is “primarily due to the added hydrocarbons, but has often been incorrectly attributed to the ethanol.”

EPA claims the study is sound, and states that “the fuel effects study was subjected to review and comment by many technical experts external to EPA during its design, and it underwent a rigorous independent peer review after data analysis was completed.”

For more information see: 

Schmidt challenges EPA ethanol emissions model, Kansas City Kansan 

How Is Gasoline Blended?  Two Groups Ask EPA to Consider This Important Detail, EESI