By BILL BRANDON
Bill Brandon is deeply engaged with the biofuels and materials industry and also has a deep understanding of engines and alternative fuels. His articles have been published in Biofuels USA and the Biofuels Digest. His present focus is on technology integration and deployment, urban and farm wastes to energy and vertical or City Farming. Bill is an architect by training and his design/build firm has been engaged in substantial residential additions and renovations in the DC metro area. His designs have incorporated aspects of building energy efficiency including early adapter status of passive solar, super insulation, underground structures and ground source heat pumps. He has also been engaged in furniture manufacturing, starting a molded plywood furniture business in Belize and it was there that he first became involved in bio-based products and bioenergy.
Bill Brandon will be moderating our upcoming professional networking event, “The Evolving Bioeconomy and Renewable Fuels,” Monday, June 22, 2015, 6 pm to 8 pm at the DC Convention Center, which is taking place before the U.S. Department of Energy Bioenergy 2015 Conference on June 23-24.
Our country has seen many transitions in travel technologies and fuels. In the first installment I reviewed our transition from 1) barley and oats for our horses and mules to high carbohydrate corn for higher energy and productivity. 2) The transition from corn to liquid fuels for internal combustion engines was next. These liquids were vegetable oils, ethanol, turpentine and petroleum wastes we now call gasoline. 3) We then transitioned from non-standard liquids to straight gasoline with a tetraethyl lead additive to give an octane boost and better performance. 4) We last transitioned from leaded gasoline to unleaded gasoline with aromatics and ethanol as octane boosters.
Fifth Transition: Movement from Unleaded Gasoline with Aromatics to Mid-Blend Ethanol for High Engine Efficiency
We now stand at the threshold of a fifth transition. (For electric vehicle enthusiasts, it is not Plug-In Electric Vehicles (PEVs). That will be the sixth transition.) The question today is whether U.S. Environmental Protection Agency (EPA) will continue its efforts toward a clean environment or cave into incumbent interests. The 1990 amendments to the Clean Air Act charged EPA to “reduce aromatics as much as possible”.
Today there is fast growing evidence that aromatics are a very serious health concern. Other articles are here, here and here. Aromatics are not only toxic when released as a volatile organic compound (VOC) but also are the primary source of ultrafine particulates (UFP) also called polycyclic aromatic hydrocarbons (PAH). UFPs are a growing point of concern as the medical community has discovered that these particulates (<.05 microns in size) are the real health concern. Organizations such as the Urban Air Institute, the American Lung Association, Energy Future Coalition and others have been active in calling out EPA’s failure to adequately regulate UFPs. Particulate matter <10 microns and < 2.5 microns is presently regulated by weight. Because of their small size UFP do not contribute much to weight of emissions but are the most prevalent by number. These (UFP) enter the atmosphere as aerosols. Aerosols are defined as solids or liquids <.1 microns suspended in a gas (air). They do not separate from this suspension quickly and are considered a ‘persistent’ contaminant. They can enter the body through the lungs, into the blood stream and eventually into individual cells. They are thought to contribute to Greenland’s dark ice that lowers reflectivity and advances ice melt. Gasoline is the biggest contributor to UFPs but diesel is also a significant contributor.
EPA’s Efforts to Date
Since its creation in 1970 under a Republican administration, EPA has achieved significant objectives. These are summarized below.
Clean Air Act and Amendments
Source: EPA Office of Mobile Sources
Renewable Fuel Standard and Amendments
Source: EPA Renewable Fuel Standards
Gasoline and Fuel Requirements under the Clean Air Act
Clean AND Green – What is the Difference?
The EPA has approved a surprising number of alternative fuels but has done little in the last 20 years to advance standards that push or reward fuels with low health issues (clean), low carbon content and low lifecycle greenhouse gas (GHG) emissions (green) or High Fuel Efficiency. Today as we debate what the future of the RFS II will be, we should keep one eye on the foundational principles of the EPA for health and air quality while keeping both eyes focused on some questionable trends in the advanced renewable fuel industry. The Department of Energy’s (DOE’s) BioEnergy Technology Office (BETO) research programs remain heavily biased toward thermal chemical and pyrolysis conversion technologies aimed at ‘drop-in’ fuels while practically ignoring new fuel molecules and microbiological conversion technologies, many of which consume CO2 as an input. DoE has invested a lot of money on these chemical conversion approaches with very little to show for it. Those that are able to produce some ‘drop-in fuels’, like Cool Planet Energy, produce fuel with significant amounts (20%) of aromatics. For all of its good qualities of being renewable and creating a valuable ‘bio-char’ for agriculture use, it should not be used as a fuel without removing the aromatics and olefins. Fuels that are ‘green’ are not necessarily ‘clean’.
On the flip side, fuels that are ‘clean’ are not necessarily ‘green’. Methane or compressed natural gas (CNG) is a clean fuel, that is with low amounts of controlled emissions, but it is not a low carbon or green fuel. Even discounting methane seepage from extraction and transport, methane does not burn completely in an internal combustion engine. Significant amounts of methane are released after combustion. This can be greatly mitigated by adding 8% hydrogen to the CNG.
Common sense would suggest that we should promote fuels that are 1) clean, without adverse health effects, 2) low in GHG emissions, both in its life cycle and tail pipe emissions and 3) capable of high thermal efficiencies to advance Corporate Average Fuel Economy (CAFÉ) standards. The government’s effort to put CAFÉ responsibility on vehicle manufacturers is misguided. Why make a poor ‘legacy fuel’ when we know better ones exist? DoE’s emphasis on ‘bio-crude’ oil that can go into existing refineries and distribution systems would appear to be influenced by the oil industry’s affinity for legacy fuels.
A Set of Complex Regulations
Today, government regulations, administered by EPA, are a dysfunctional set of sometimes contradictory or sometimes significantly biased rules. Our present fuel system is complicated. Not only are there specialized fuels like CNG, hydrogen and dimethyl ether DME, a diesel substitute that does not create UFP (see link), there also is diesel and a complex structure of requirements for gasoline and ethanol blends.
See map below.
E15 (or E30), however, is not included in the 1-psi waiver that E10 has. While the rule has no basis in science as E15 will have the same RVP as E10 or a little bit less, this rule is inhibiting adoption of E15 by choice in the Midwest ethanol belt where E15 is most economical and accepted. This year Senators Grassley and Paul have submitted a bill to the Senate and Congressmen Rod Blum, Ken Buck, Collin Peterson and David Young have submitted the same bill to the House to include E15 in the RVP waiver.
The Need to Transition from Legacy Fuels to Modern Fuels
Science and auto manufacturers tell us that we need higher-octane fuel to reach high CAFÉ efficiencies with commensurate performance and vehicle size. The Ford Motor Company has submitted data to the EPA in 2014 indicating that E30 blends can result in increased engine efficiency. Ford engineers represent that a vehicle optimized to run on E30 can have a 3% increase in MPG even though there is a 10% decrease in BTU content. There has been a growing interest in benefits of higher ethanol blends of E30-40. This brings up the ‘battle of the blends’ with the oil companies, who would not be pleased with loosing additional market share.
The recently approved tier 3 rules for gasoline and cars has some good changes but often represents a tepid approach that still largely represents trying to ‘manage’ emissions and sees the future through ‘the rear view mirror’. The EPA begins with the assumption that E10 has become the ‘standard fuel’ and that E15 will become prevalent in the future “reflecting a mix of E10 and E15 in 2017 and E15 only in 2030.” Why not 75% E10 and 25% E30? This represents the same ethanol volume as 100% E15. The RFS II calls for volumes equal to an E15 Blend by 2018 or 2019. Consistent with this viewpoint, tier 3 rules contain a positive change to move away from indolene (E0, and an 93 octane) as a test fuel for auto manufacturers’ certification purposes to use E15 ( and an 87 octane rating) by 2017. The EPA explains that it is “proposing to update our federal test fuel to better match today’s in-use gasoline and also to be forward looking with respect to future ethanol and sulfur content.” The rules would LOWER octane to “match regular grade gasoline, except for premium-required vehicles” and “adjust distillation temperatures, aromatics and olefins to better match today’s in-use fuel requirements beginning in 2017.” EPA states that these tier3 rules will reduce emissions.
An 87 octane gasoline with 15% ethanol will allow some aromatics to be removed from the blend stock but will not promote efficiency. If auto manufacturers move to requiring ‘premium gasoline’ to reach CAFE standards, it will reduce these theoretical emission reductions because aromatics would be needed to increase octane. There is an argument to be made that a more rapid introduction of an E30 high performance regular will reduce emissions faster than a universal use of an E15 fuel. Allowing E30 to become the dominant fuel by 2030 with E10 and E15 available (which would allow the RFSII standard to be met); increased engine efficiency and faster inclusion of ethanol and quicker reductions of aromatics will result in lower emissions sooner. All of the benefits that EPA points to will be there but on a faster time schedule and to a greater extent. EPA’s statement says it all …”to better match today’s in-use fuel requirements.” It is not forward thinking.
Who is the Ring Master Here?
There are many confusing and contradictory aspects to EPA’s actions and these tier 3 rules. The artificial ‘blend wall’ has been hit. Importantly, the EPA appears to have made ‘a deal with the devil’ for a 15 year ‘forward looking policy’ that has oil companies giving up another 5% market share while EPA is blocking future mid-level E30-40 blends that would promote higher thermal efficiencies and further reducing emissions. The best way to reduce vehicle emissions and GHGs is to stop using so much fuel. As with DoE’s BETO program, oil companies appear to be having significant influence. One has to wonder who is calling the shots”? here.
The EPA has released an updated version of the MOVES (MOtor Vehicle Emissions Simulator) computer modeling system used for a variety of studies and predictions. Fuel is one segment of this model and E30 has been added to the MOVE 2014 version. EPA went to a Chevron consultant to write an E30 fuel specification that included adjusting distillation temperatures. Here we get into the weeds a bit as the consultant used a ‘match blend’ method while all actual blending is a ‘splash blend’ technique. The ‘match blend’ method used by the Chevron consultant required adding and subtracting molecules to bring the blend up to a petroleum RVP specification through distillation temperatures. To accomplish this, aromatics were added to the blend stock. This resulted in poor emission data for the E30 blend BUT it was not a result of the ethanol but the adjusted blend stock with unnecessarily added aromatics. The EPA was immediately criticized by many including an SAE (Society of Automotive Engineers) report sponsored by GM and FORD. Any study based on this new MOVE modeling system will be inaccurate for E30 fuels.
GM specifically has been pressuring EPA for a method to certify E30 compliant vehicles. The EPA has thrown a meaningless bone to auto manufacturers. They say “…by allowing vehicle manufacturers to request approval for an alternative certification fuel (E30). This could help manufacturers that wish to raise compression ratios to improve vehicle efficiency, as a step toward complying with 2017 and later light-duty greenhouse gas and CAFÉ standards. This in turn could help provide a market incentive to increase ethanol use beyond E10 by overcoming the disincentive of lower fuel economy associated with increasing ethanol concentrations in fuel, and enhance the environmental performance.” How can EPA reconcile this statement with their approval and continued support of the MOVE 2014 test methodology for E30 that would make a logical and economical blend for E30 illegal?
Action is Needed
The next 18 months will be important to the RFS and the future of fuels that we will use. Congress may take some action and the EPA under Obama will finalize some rules. Public comment is open for the proposed RFO (renewable fuel obligation) rules until July 27. Many proponents of the RFS believe we should just ‘stay the course’ with more timely and better administration by EPA. The oil industry is lobbying for the repeal of the RFS. Most believe that improvements can be made (although the political climate suggests nothing constructive could be accomplished). James Stock, Member of the President’s Council of Economic Advisers from 2013-2014, has published a paper through Columbia University’s Center for Global Energy Policy suggesting different strategies concerning the RFS. While suggesting possible administrative and legislative changes, his bottom line is that we should employ an aggressive approach to introducing biofuels into the market. This approach is ‘molecule agnostic’ yet science can tell us what are the better molecules. If we were to focus on the more desirable molecules and blends, regardless if they were renewable or not, we would see a variety of advantages. It was 50 years between 1923 with tetraethyl lead being introduced and starting the fourth transition for automobile and fuel. This strategy for unleaded gasoline took just 5 years to start and to implement. It has now been 45 years since we started transition 4 of legacy fuels. It is time we talked about transition 5 to modern fuels with attention to health issues, GHG emissions and fuel efficiencies. Such a change should include participation of the petroleum industry.
A Need for GOOD Government Regulations and Standards
It is important to recognize that our whole vehicle fuel system is based on mandates. The under-informed may say there is a mandate for ethanol use. Actually the opposite is more true; there is a mandate for petroleum use. We have mandates for Reid vapor pressure (RVP), minimum octane, maximum aromatics, sulfur content, etc. The RFS II is a mandate for renewable sourced fuel with volumetric set asides for fuels with lower life cycle GHG emissions. For comparison purposes, these are based on average 2005 gasoline. While renewable sourced fuels are required to get better with increased volumes, petroleum fuels do not need to do this. In fact petroleum fuels have gotten worst.
The RFS II ends in 2022. What will follow? It is time to start talking about it.
A Proposal for a Carbon-Light Approach to a Modern Fuel
Concentrating on DME (DiMethyl Ether, a diesel substitute), mid-blend E30-40 ethanol, CNG/hydrogen blend and hydrogen for fuel cells would result in high thermal efficiencies with low ultrafine particulate emissions. All of these fuels can be made from both fossil resources and through biofuel approaches. Technologies to do all of this are presently available at least at commercial demonstration scales. Establishing phase out schedules over a 20 years or so for legacy fuels would be similar to the introduction of transition 4 unleaded fuels and vehicles in 1975.
A variety of strategies could be employed but extending the use of aromatics should not be one of them. A standard hydrocarbon blend stock without aromatics and potentially with about 5% isobutanol could be sold. This blend could be shipped through pipelines; the isobutanol would give a bit of octane boost and this blend stock could be sold for off road use like lawnmowers. When blended with ethanol, the butanol would stabilize the blend, reduce RVP and allow petroleum refiners a more profitable ‘crack ratio’ for hydrocarbon components. EPA would need to get behind the idea of certifying the blend stock rather than the final fuel. Blend stock (presently about 84 octane) is not officially a fuel because it does not meet minimum specifications. The issue of certification really surrounds the soup of molecules that is the petroleum /butanol component as the adding of ethanol would be a known and predictable modification.
Replace “RINS” to “GINS” to Account for Greenhouse Gas Values for All Fuels?
If we were to adopt a ‘carbon light’ strategy and move to eliminate aromatics to limit ultrafine particulates, and reduce GHGs without overt preferences to renewable or fossil sources, we could change the playing field. John Stock suggested attaching GHG values to RINs. Why not replace them with ‘GINs’ (GHG Intensity Number) applied to all fuels. The Supreme Court has ruled that the EPA has the authority to regulate GHGs; why don’t we do it? Tar sand fuels would be less desirable but Enhanced Oil Recovery (EOR) methods that sequester CO2 would generate more valuable GINs. Field conversion of methane to DME would be encouraged. The average GIN’ value should be mandated to improve over time and market incentives for production could be accomplished through GIN trading values.
The present RIN trading mechanisms could be improved and made more transparent by adopting a ‘future bid’ format similar to government chartered electrical grid capacity markets. If the required average GIN value were 10 and you wanted to produce a fuel with a GIN value of 8, you would need to buy an equivalent amount of GINs with a value of 12 or half the equivalent amount of GINs with a value of 24. If appropriate valued GINs were not being produced, producers could ‘buy’ virtual GINs from an EPA charted corporation that would handle all transactions and to be replaced by real GINs in the near future. An appropriate price setting structure would assure future market growth and ‘future contracts’ could be issues to allow GIN values to be incorporated into financing balance sheets for new production. Gins would not be based on some generalized assumptions but based on data from individual producers. A corn ethanol producer that could demonstrate improved efficiencies would get a higher GIN value per gallon than one who had not made such improvements. This higher GIN value would go to producers as incentives.
There is a role for government here as there was in 1970 with the first Clean Fuels Act. That legislation mandated a fuel type that impacted the incumbent oil companies. Simply following the 1990 CAA amendments for reduced aromatics and enforcing methane emission standards could do it again. It seems that Oil companies must be forced to adapt and they can do it again while setting the table for when fossil fuels reach ‘peak price’. We of course have seen incumbent interest’s money and false analysis before. The 1920 election was a big election for incumbent influence and bad policies. We got 50+ years of poisonous leaded gasoline from that outcome. Will 2016 be another such election?
This article is part two of a two part series on the history of biofuels. Read part one here.