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). In the comments, authored by RFA Senior Vice President Geoff Cooper, the ethanol industry trade group states it agrees that “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.”

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 “bridge” 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, “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. ‘R-factor’ and ‘F-factor’ 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.”

RFA stated the “chicken and egg” phenomenon was a substantial barrier to the deployment of co-optimized engines and HOFs, characterizing the phenomenon as one where “automakers are hesitant to invest in manufacturing HOF-optimized vehicles until HOFs are substantially available in the marketplace, and…fuel producers are reluctant to invest in infrastructure to produce and distribute HOFs until HOF-optimized vehicles are substantially available.” RFA said a primary objective of the renewable fuel standard (RFS) was to “eliminate the ‘chicken or egg’ fuel/engine situation by specifying biofuel volumes that must be consumed far in advance, providing substantial lead time for affected industries to implement plans.” RFA stated that the EPA’s “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.”

Read RFA’s response to the request for information for Category 1: here.

Read RFS’s response to the request for information for Category 2: here.