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PRX Bulletin: EPA Releases Draft Technical Assessment Report for CAFE Standards of 2022-2025, with No Problems Foreseen in Increasing Standards from 38.3 mpg in MY 2021 to 46.3 mpg in MY 2025
 
Produced by Bill Hudson

"Today's draft report shows that automakers are developing far more technologies to improve fuel economy and reduce greenhouse gas emissions, at similar or lower costs, than we thought possible just a few years ago.  And they are adopting these fuel-saving technologies into their fleets even faster than anticipated," said Janet McCabe, acting assistant administrator for EPA's Office of Air and Radiation, in an e-mail to EPA news subscribers.  "This is simply great news for consumers, manufacturers, workers and the climate."
 
The e-mail explained the regulatory background of the report: "The U.S. Department of Transportation (DOT), the U.S. Environmental Protection Agency (EPA), and the California Air Resource Board (CARB) today took the first step in the mid-term evaluation of the National Program for greenhouse gas emissions and fuel economy standards for light duty cars and trucks by releasing a draft Technical Assessment Report (TAR) for public comment.  The release of the TAR delivers on a commitment that EPA made in 2012 as part of the rulemaking establishing a National Program for the 2017-2025 period.  The draft TAR covers model years 2022-2025.

The draft TAR shows that automotive manufacturers are innovating and bringing new technology to market at a rapid pace, and that they will be able to meet the MY 2022-2025 standards established in the 2012 rulemaking with a wide range of cost-effective technologies.  Moreover, it indicates that these standards can be achieved by relying primarily on advanced gasoline vehicles.  The report also shows that manufacturers will be able to meet the stricter standards at similar or even a lower cost than was anticipated in the 2012 rulemaking, with substantial savings on fuel costs for consumers.
 
In recent years, and responding to the standards established in the National Program, automakers have been rapidly adopting fuel-efficient technologies like turbo charging, engine downsizing, more sophisticated transmissions, vehicle weight reduction, aerodynamics, and idle stop-start, along with improved accessories and air conditioning systems.  There are over 100 car, SUV, and pick-up truck versions on the market today that already meet 2020 or later standards, suggesting that automakers should be well-positioned to meet future average standards through additional application of those technologies.
 
While the Draft TAR analysis focuses on the MY 2022-2025 standards, the report also shows that auto manufacturers over-complied with the standards for each of the first three years of the program, and in 2014 outperformed the standards by 1.4 miles per gallon.  This occurred during a period during which the automotive industry has seen six consecutive years of sales increases and a new all-time sales record in 2015, reflecting positive consumer response to vehicles complying with the standards.

Today's draft report is the first of several steps the agencies will take as part of assessing the standards for new vehicles in the 2022-2025 model years (MY).  The report itself is not a rulemaking and does not change any of the existing requirements under the existing National Program."
 
For more information on the announcement, including the Executive Summary and full 900-page report
 
PRX Comment #1. The cheerful conclusion of the draft TAR, that the 46.3 mpg targets could be achieved by gasoline powered vehicles, with little need for electrics, was not expected. In fact, PRX last winter (at the request of the NCGA) had presented a snapshot assessment of corn availability in 2030 to the Ag-Auto-Ethanol Working Group, on the group's assumption that high compression engines using E-25 would be a main way that the 46.3 mpg target could be achieved.
 
The draft TAR makes little reference to this E-25 avenue. In fact, in the entire 900 pages, the only mention I could find of ethanol (and its higher octane advantage) was in Chapter 9, under "Alternative Fuel Infrastructure":
 
"9.4 To the extent that some manufacturers produce alternative fueled vehicles in the coming years, sufficient fueling infrastructure will continue to be needed for purchasers of those vehicles. For the two largest alternative fuel vehicle segments, CNG and E85, fueling infrastructure has continued to grow to support vehicle fleet growth. Numbers of CNG stations have continued to rebound from a decline during the recent recession years, increasing each year since 2009 and reaching an all-time high of over 1,600 stations currently, over 900 of which are available to the public. (The remainder of current CNG stations provide fuel to dedicated fleets of vehicles, usually heavy-duty vehicles, and are not available for fueling light-duty CNG vehicles). The number of gasoline stations that provide E85 has increased from under 800 stations in 2006 to over 3,100 stations today, over 2,800 of which are available to the public.76 Also, the U.S. Department of Agriculture's Biofuels Infrastructure Partnership now underway could increase the number of E85 stations.77
 
9.5 In aggregate, the status of alternative fuel infrastructure could be characterized as sufficient, growing, or robust. Moreover, the agencies' initial assessment for this Draft TAR is that the MY2022-2025 standards can be met largely through continued advancements in gasoline vehicle technologies, with the only alternative fuels needed to meet the MY2022-2025 standards being a very small fraction of PEVs (see Chapters 12 and 13). As a result, infrastructure does not present a barrier for alternative fuel vehicles to be used in meeting the 2022-2025 national program GHG and CAFE standards. Of course, the agencies recognize that, apart from the standards, auto manufacturers may decide to pursue alternative fueled vehicles for other reasons, such as market demand."
 
PRX Comment #2. Although we have mentioned the possibility of 50-70% acceptance of E-25 as a future possibility to meet CAFE standards, we have NOT made this possibility a part of our Blue Sky forecast through 2025. We will have to await discussions by the Ag-Auto-Ethanol Working Group before commenting further.
 
PRX Comment #3. We have indeed foreseen a greater usage ahead for blends above E10, such as E15 and E85, and have thus raised our demand estimate of corn ethanol above 17 billion gallons in 2025 in the current Blue Sky #42. This probability seems generally supported by the new TAR, and also by unfolding events with current higher D6 RIN prices and the passing of these on into the gasoline distribution system.
 
Full review of this subject ahead at the PRX seminar of August 18-19 in Kansas City. Early bird registration is here. View the agenda here.     
 
Bill
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Bill Hudson
The ProExporter Network