(July 2, 2013) WASHINGTON — Yesterday, the Renewable Fuels Association (RFA) submitted comments to the Environmental Protection Agency (EPA) responding to EPA’s proposed rule on Tier 3 Motor Vehicle Emission and Fuel Standards.

Bob Dinneen, RFA’s President and CEO, notes in the opening of the comments that “RFA supports a swift implementation schedule for the proposed changes in Tier 3 NPRM. We commend the agency for its efforts to reduce the sulfur content of our nation’s fuels and emissions of air toxics and particulate matter from our motor vehicles. In general, these proposed Tier 3 standards pertain to the refiners of gasoline and automobile manufacturers. However, there are a few areas of concern for ethanol producers.”

RFA’s comments highlight several areas of the proposal that are relevant to ethanol producers. Specifically, RFA offered the following recommendations in its comments:

1. Because denaturants are the sole source of sulfur in denatured fuel ethanol (DFE), the EPA should not require sulfur content batch reporting by DFE producers. Current practices of monitoring the sulfur content of denaturant and DFE are adequate.
2. Existing standards and specifications for “flex fuels” (i.e., 51-83% vol. ethanol) are sufficient and EPA should not subject these fuels to the same sulfur, RVP, and benzene standards applicable to gasoline.
3. E16-E50 blends should be treated as alternative fuels.
4. RFA supports the proposal to establish E15 as the certification test fuel beginning in 2017.
5. We support the proposal allowing vehicle manufacturers to request approval for an alternative certification fuel.
6. We support the proposal to limit approved denaturants for denatured fuel ethanol to natural gasoline, gasoline, and gasoline blendstocks for oxygenate blending (BOBs), however we would like to see an option for proposing  new denaturants in the future.
7. We agree that parametric limits on benzene, olefins, and aromatics in denatured fuel ethanol are unnecessary, as these substances are typically absent from DFE or are present at extremely low levels as a result of denaturing.
8. RFA does not support EPA limiting the amount of denaturant.
9. Denaturant manufacturers should be required to demonstrate compliance with the sulfur specifications enforced in the State of California.
10. EPA’s proposed certification fuel for flexible fuel vehicles may discourage FFV production due to potential difficulty in meeting NMOG+NOx standard bin levels.
11. RFA believes EPA should provide equal RVP treatment for E10 and E15.

For more specifics on each concern, please read the comments in full at EthanolRFA.org.