All the Wrong MOVES

FROM THE FEBRUARY ISSUE: EPA's MOVES model contains serious flaws and could heavily impact the industry as EPA conducts anti-backsliding study.
By Dave VanderGriend | January 20, 2020

Some years ago, Tom Cruise played a talented young athlete in a movie called “All the Right Moves.” Well, we’re not in Hollywood and this isn’t a movie where we get to write the script. What is playing out in front of the ethanol industry is the reality of all the wrong MOVES—the Mobile Vehicle Emissions Simulator (MOVES) model. This U.S. EPA model is part of a perfect storm forming that could send ethanol further backwards after a year of low prices, shrinking markets and a constant erosion of the Renewable Fuel Standard.

A key provision of the RFS was a required anti-backsliding study that was viewed as a firewall to ensure ethanol and other renewables would not lead to a deterioration, or backsliding, of clean air standards. So once again our fate is in the hands of EPA, which is currently conducting this study, relying heavily on the MOVES model and the seriously flawed data that was used to create it. This model indicates ethanol blends increase various emissions, creating a triple threat to future ethanol use. First, states are required to use this model when developing state implementation plans (SIPs) to comply with federal clean air standards. Second, this model will be used by EPA to establish ethanol volumes post-2022 when the RFS becomes largely discretionary. And third, the anti-backsliding study will be the justification for a permanent reset of RFS volumes.

At the Urban Air Initiative, we have conducted numerous studies challenging EPA data that went into this model, including comments we filed back in 2017.

Certainly, models are needed to assist states to make the right fuel choices, but those models are only accurate to the extent the data inputs are accurate. And the problem lies in the fact that the test fuels and procedures were designed by the petroleum industry. That is akin to asking Chevy to rate Fords, or having Coke design a taste test for Pepsi.   

But this is fixable. We need parity in fuel blending and testing. EPA is required to use the best available science and is simply not doing so. All the affected parties need to be involved in the process, which means oil, ethanol and automakers. We are working with these stakeholders on a fuel blending guide that will be completed later this year. It’s a step toward creating consistency in fuel testing.

Yet the ramifications of faulty and flawed emissions data cannot be overstated. Deliberations over SIPs are taking place right now in areas like Colorado’s Front Range where they are considering elimination of any ethanol blend. Congressionally mandated studies are being prepared. And the post-2022 RFS requirements are being developed.

We have all worked too hard for too long in our industry to be considered a dirty fuel and let this storm take shape. Our governors can play a key role, given that states are responsible for complying with clean air standards. Let’s communicate to these state leaders that ethanol is the clean air choice and tell EPA to make the right MOVES and fix its models.

Author: Dave VanderGriend
President, Urban Air Initiative
CEO, ICM Inc.
316.796.0900
davev@icminc.com