The Renewable Fuels Association has submitted two comments to the U.S. Department of Energy in response to a request by the Office of Energy Efficiency &amp; Renewable Energy for information on Co-Optimization of Fuels and Engines (Optima). In the comments, authored by RFA Senior Vice President Geoff Cooper, the ethanol industry trade group states it agrees that &ldquo;co-optimization of future fuels and engines is an essential strategy for achieving national objectives related to energy conservation, carbon emission reduction, and energy security.&rdquo;
RFA indicated that a significant amount of work is already underway that complements the goals of Optima, including lifecycle energy and greenhouse gas analysis of ethanol and high octane fuels (HOFs); evaluation of tools to predict HOF exhaust emissions; infrastructure compatibility and cost analyses; development of standards and specifications; and other activities. The comments also pointed out several areas for further research and collaboration, including actual HOF emissions testing; refinery-level economic analysis; using flex-fuel vehicles as a &ldquo;bridge&rdquo; technology to HOFs; and further characterizing the properties of various octane sources.
With respect to the potential barriers to co-optimized fuels and engines identified by EERE, RFA said that existing regulatory barriers pose the most significant threat to the commercial introduction of HOFs. According to RFA, &ldquo;Federal regulatory barriers that must be addressed include: fuel volatility (RVP) regulations; Tier 3 regulations regarding certification fuels; new fuel registration requirements; treatment of biofuels and FFVs in determining compliance with 2017-2025 CAFE/GHG standards (e.g. &lsquo;R-factor&rsquo; and &lsquo;F-factor&rsquo; values); inconsistent boundaries and approaches to regulatory lifecycle GHG accounting; and tailpipe pollutant (i.e., non-GHG) emissions estimation. In addition, a number of state regulatory barriers need to be addressed to facilitate introduction of HOFs.&rdquo;
RFA stated the &ldquo;chicken and egg&rdquo; phenomenon was a substantial barrier to the deployment of co-optimized engines and HOFs, characterizing the phenomenon as one where &ldquo;automakers are hesitant to invest in manufacturing HOF-optimized vehicles until HOFs are substantially available in the marketplace, and&hellip;fuel producers are reluctant to invest in infrastructure to produce and distribute HOFs until HOF-optimized vehicles are substantially available.&rdquo; RFA said a primary objective of the renewable fuel standard (RFS) was to &ldquo;eliminate the &lsquo;chicken or egg&rsquo; fuel/engine situation by specifying biofuel volumes that must be consumed far in advance, providing substantial lead time for affected industries to implement plans.&rdquo; RFA stated that the EPA&rsquo;s &ldquo;unlawful reinterpretation of its statutory waiver authority and its reduction of RFS volume obligations has raised serious concerns about the future viability of the RFS as a tool for driving the transition to HOFs and optimized SI engines.&rdquo;
Read RFA&rsquo;s response to the request for information for Category 1: <a href="http://link.coremotivesmarketing.com/c/306/fc8db284df4efda93f1c0f30bd566e415c5c4b3b449ca938a4f583bac8216e50">here</a>.
Read RFS&rsquo;s response to the request for information for Category 2: <a href="http://link.coremotivesmarketing.com/c/306/fc8db284df4efda93f1c0f30bd566e415c5c4b3b449ca938ef8d4be62862fa37">here</a>.
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The Renewable Fuels Association has submitted two comments to the U.S. Department of Energy in response to a request by the Office of Energy Efficiency & Renewable Energy for information on Co-Optimization of Fuels and Engines (Optima).

RFA comments on DOE's Optima program

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