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Ozone-Forming Potential of Reformulated Gasoline (1999)

Chapter: Appendix B Letter from Senator Lugar

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Suggested Citation:"Appendix B Letter from Senator Lugar." National Research Council. 1999. Ozone-Forming Potential of Reformulated Gasoline. Washington, DC: The National Academies Press. doi: 10.17226/9461.
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Appendix B
Letter from Senator Richard G. Lugar

Suggested Citation:"Appendix B Letter from Senator Lugar." National Research Council. 1999. Ozone-Forming Potential of Reformulated Gasoline. Washington, DC: The National Academies Press. doi: 10.17226/9461.
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Dr. Stephen Rattien

Executive Director

Commission on Geosciences, Environment and Radiation

National Research Council

2100 Constitution Ave. N.W. Washington, D.C. 20418

Dear Dr. Rattien:

I understand that the Environmental Protection Agency has requested an evaluation of "whether the existing data is sufficient to show that adding ethanol to RFG on the basis of reactivity would not adversely impact the in-use environmental. benefits of the RFG program" and that it has also requested your advice on what additional information would be necessary to allow such a determination to be made. EPA's request is related to a proposal for fuel certification which I discussed at a meeting with Assistant Administrator Mary D. Nichols in November, 1993.

On September 28, 1995 I convened a hearing of the Senate Committee on Agriculture, Nutrition and Forestry on the role of ethanol in the reformulated gasoline program. At that hearing, I discussed EPA's proposal for a National Academy of Sciences (NAS) study with Administrator Carol Browner. Our Committee hearing was called to discuss the restraints which current EPA policies place on refiners who wish to use ethanol blends in reformulated gasoline and the effect of reduced ethanol use on the farm economy and on deficiency payments. Under the RFG program, the EPA Judges fuel blends solely by their total mass of emissions of volatile organic compounds ("VOCs"). Since the addition of ethanol to gasoline increases volatility—and thus increases "evaporative" VOCs—it is difficult for regular ethanol blends to qualify absent the use of special low RVP Gasoline which is more expensive and unavailable in many markets.

However, if one considers the actual ozone forming potential of ethanol blends and not Just their mass of emissions, a case can be made that certain ethanol blends may produce reductions in VOCs which are just as great as those produced by qualifying nonsthanol blends. Because 10% ethanol blends have greater oxygen content, they may emit fewer exhaust VOCs than non-ethanol

Suggested Citation:"Appendix B Letter from Senator Lugar." National Research Council. 1999. Ozone-Forming Potential of Reformulated Gasoline. Washington, DC: The National Academies Press. doi: 10.17226/9461.
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blends. And since exhaust VOCs are believed to have a greater propensity to form Ozone than evaporative VOCs, the greater reduction in exhaust VOCs achieved by certain ethanol RFG blends may counterbalance their greater mass of evaporative VOCs. Furthermore, because of the additional oxygen, these blends may contain less carbon monoxide than non-ethanol blends, further reducing their tendency to form ozone since carbon monoxide is a recognized precursor of ozone.

I have proposed that EPA establish a procedure to certify ethanol blends as equivalent to non-ethanol blends under section 211 (k) (4) (B) of the Clean Air Act, but EPA has so far refused to do so bemuse it is unsure clot there is an appropriate methodology for making the comparison.

I hope that the NAS Study will have a practical aim; that is, it will help to determine, in light of the best available information, the procedures (i.e., the data and analysis) by which the equivalency of two blends could be determined with a reasonable degree of certainty. To the extent that additional information or studies are necessary before such procedures can be developed or implemented, I also hope that NAS will identify the additional information and analyses which would be needed and Chat it would work with the EPA and with ocher concerned parties to ensure that it is provided.

The NAS study is critical to the implementation of the Clean Air Act in a manner that allows renewable fuels to play an important role in the reformulated gasoline program. I therefore Join EPA in urging the National Academy of Sciences to undertake this effort and I urge that it be completed at the earliest possible date. If you have any questions, please contact me or Jeff Burnam of my staff at 202-224-7443.

RGL/jbj

Suggested Citation:"Appendix B Letter from Senator Lugar." National Research Council. 1999. Ozone-Forming Potential of Reformulated Gasoline. Washington, DC: The National Academies Press. doi: 10.17226/9461.
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Page 223
Suggested Citation:"Appendix B Letter from Senator Lugar." National Research Council. 1999. Ozone-Forming Potential of Reformulated Gasoline. Washington, DC: The National Academies Press. doi: 10.17226/9461.
×
Page 224
Suggested Citation:"Appendix B Letter from Senator Lugar." National Research Council. 1999. Ozone-Forming Potential of Reformulated Gasoline. Washington, DC: The National Academies Press. doi: 10.17226/9461.
×
Page 225
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The Committee on Ozone-Forming Potential for Reformulated Gasoline was asked whether the existing body of scientific and technical information is sufficient to permit a robust evaluation and comparison of the emissions from motor vehicles using different reformulated gasolines based on their ozone-forming potentials and to assess the concomitant impact of that approach on air-quality benefits of the use of oxygenates within the RFG program. As part of its charge, the committee was asked to consider (1) the technical soundness of various approaches for evaluating and comparing the relative ozone-forming potentials of RFG blends, (2) technical aspects of various air-quality issues related to RFG assessment, and (3) the sensitivity of evaluations of the relative ozone-forming potentials to factors related to fuel properties and the variability of vehicle technologies and driving patterns.

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