EPA’s 'MOVES' could cripple higher ethanol blends

EPA's Mobile Vehicle Emissions Simulator relies on faulty, manipulated data, resulting in inaccurate emission increases and will cripple any hope of ethanol expansion, writes Dave VanderGriend. This column appears in the September issue of EPM.
By Dave VanderGriend | August 13, 2015

Anyone even remotely connected to the ethanol industry knows these are tough times. Having gone from being the hero of the 2007 Energy Security and Independence Act, which created the expanded renewable fuels standard (RFS), to being vilified by the petroleum industry and its friends in the press, we are running out of cards to play in a stacked deck, with the U.S. EPA as the dealer. The RFS is very important to our industry, but focusing on it alone, has caused us to take our eye off the dealer. The down card trumps everything in the deck and it’s called the MOVES model, which stands for Mobile Vehicle Emissions Simulator. 

Unfortunately, this model relies on faulty, manipulated data, resulting in inaccurate emission increases that will cripple any hope for ethanol expansion and the use of higher blends. And, this is taking place as the EPA gets closer to imposing tighter ozone controls, which could put another third of the U.S. into ozone nonattainment, and therefore under federal control. Once that happens, states have to develop a state implementation plan to tell the EPA how they plan to get back into attainment. Here is why the MOVES model matters: When states plug in higher ethanol blends, the model says ethanol raises emissions.

 How can this be? The basis for the MOVES model stems from fuel blending studies conducted by the EPA in a laboratory that, rather than looking at real world consumer fuels, used test fuels that became synthetic caricatures of how fuels are really blended. Even experts in a highly respected paper from the Society of Automotive Engineers said there was no justification for the EPA to conduct the fuel testing the way it did. 

 The Urban Air Initiative hired a reputable fuel blending consultant to test the model and our fears were confirmed. Data proves the MOVES model is biased against ethanol and blocks the goal of reducing toxic emissions and promoting a cleaner fuel. We have clear data to support that when simply adding ethanol to consumer E10 gasoline via splash blending, the result is a fuel with fewer toxic emissions. However, the manipulation of test fuels in the MOVES model tells a different story regarding ethanol.

 An analogy from the ethanol process illustrates what’s being done with the test fuels. If your yields are off and fermentation is underperforming, you might change the temperature, the enzymes and five other variables. But each change is made separately in order to identify the true influencing factor. The EPA did the exact opposite in its testing, changing many of the fuel components at once, while increasing ethanol. Each time emissions increased, the EPA blamed ethanol. That would be akin to blaming enzymes no matter what other changes you employed in your fermentation.

We must stop the MOVES model from being implemented, or all of the industry’s other initiatives will be undermined. States will have their hands tied and will simply not be allowed to approve higher blends. That’s why we are fighting back, and we need your help. The Energy Future Coalition and the attorneys general of Nebraska and Kansas joined UAI and its supporters to file legal action against the EPA to block the MOVES model from being enforced. We believe winning this legal battle is critical to the future of our industry. The most recent filing in U.S District Court calls on the EPA to develop a new model, reflecting real world consumer fuels and blending practices. If we splash blend on a consumer E10, we know vapor pressure decreases, particulate emissions are reduced, carbon emissions are lowered, and importantly, we give automakers the octane they need for the next generation of cars.

Waging this legal fight and communicating the health benefits of clean burning ethanol requires resources and support from all of you who want to open the market for higher blends.
Please visit us at www.urbanairinitiative.com and click on the “Get Involved” button to learn how you can help us ensure we have something to prime the pump with. 

Author: David VanderGriend,
CEO, ICM Inc.; President, Urban Air Initiative