RFA Comments on Proposed Tier 3 Rule

The Renewable Fuels Association (RFA) submitted comments to the Environmental Protection Agency (EPA) last week regarding the proposed rule on Tier 3 Motor Vehicle Emission and Fuel Standards.

Kelly Davis, RFA Director of Regulatory Affairs, says they support the timely implementation of the Tier 3 standards especially the proposal to establish E15 as the certification test fuel beginning in 2017. “We really hope that these don’t get held up,” she said. “The E15 certification fuel is something the industry has been waiting on a long time, including the automotive industry, to more reflect what’s really in the marketplace.”

However, there are a few areas of concern for ethanol producers. “We will accept the 10 part per million sulfur limit but we don’t want to have to be in what they call the refinery program that requires the amount of testing and expertise for the batch testing facility,” Davis explained, since denaturants are the sole source of sulfur in denatured fuel ethanol (DFE).

Davis says RFA also believes that existing standards and specifications for “flex fuels” are sufficient and EPA should not subject these fuels to the same type of standards applicable to gasoline, since they are concerned that may discourage FFV production due to potential difficulty in meeting NMOG+NOx standard bin levels. RFA also commented EPA should provide equal RVP treatment for E10 and E15 and that E16-E50 blends should be treated as alternative fuels.

Kelly explains the more technical details of RFA’s comments on the proposed rule in this interview: Interview with RFA's Kelly Davis

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