EPA seeks input on F-factor for E85 FFVs

By Erin Voegele | August 26, 2020

The U.S. EPA published notice on Aug. 26 requesting comment on sources and analytical approaches on which to base an EPA determination of an updated weighting factor (F-factor) for E85 flexible fuel vehicles (FFVs) for model years 2021 and later.

The notice explains that the F-factor for a given model year is used to weight the greenhouse gas (GHG) emission of an FFV operating on E85 with the GHG emissions of the vehicle operating on conventional gasoline when calculating the compliance value for that model year. The F-factor is also used in the corporate average fuel economy (CAFE) program for weighting the measured fuel economy of FFVs when operating on E85.

Starting with model year 2016, regulations for EPA's GHG program for passenger automobiles and light trucks describe how to determine the GHG value for FFVs that run on gasoline or on E85. The F-factor is used to weight the gasoline and E85 emissions values of the tested vehicle model together to determine the combined value to be used for the vehicle model in the fleet average calculations.

According to the EPA, the default approach is to use an F-factor of zero so that the carbon dioxide emissions value of the vehicle is measured when the vehicle is operated solely on gasoline. The alternative is to combine the gasoline and E85 carbon dioxide values together in a way that accounts for real-world use of E85 by using an alternative F-factor established by EPA.

The notice explains that EPA’s regulations establish two different approaches that can be used to determine the value of the F-factor. Under one approach, manufacturers may request that EPA determine and publish by guidance an appropriate value for the E85 F-factor, based on EPA’s assessment of the real-world use of E85, to be used fleetwide. Under the other approach, a manufacturer may submit data demonstrating the actual real-world use of E85 by its vehicles. EPA would determine whether the data is adequate and what an appropriate F-factor should be for the manufacturer.

CAFE regulations specify that beginning with model year 2020, an F-factor, once established by the agency, will also be used in CAFE to weight FFV fuel economy on conventional gasoline test fuel and E85 and determining the FFV’s model type fuel efficiency.

Within the notice, the EPA said it received a request in mid-2012 to establish an F-factor. The agency requested comment on its resulting F-factor determination in March 2013. EPA issued a final determination via a letter to auto manufacturers in November 2014 prescribing an F-factor of 0.14 applicable to 2016-2018 model year vehicles. In August 2019, the agency extended the use of the 0.14 F-factor to model year 2019.

EPA has since received a request from auto manufacturers to establish an F-factor for model year 2020 and later vehicles. The agency said it has not conducted a technical analysis to support the F-factor since 2014. In the letter extending the 0.14 F-factor through model year 2019, the EPA said it intended to develop a forward-looking analysis for model year 2020 and later based on the agency’s “assessment of real-world use of alternative fuel.”

The EPA said it’s intention was to update the methodology used to set the 2016-2018 F-factor, but noted there are at least two factors that must first be considered. First, the U.S. Energy Information Administration has made significant changes to the way it projects E85 usage in its annual energy outlook, which is an important input the EPA used to develop the 2016-2018 F-factor. Second, the COVID-19 pandemic has significantly changed market conditions for fuel usage, and the EPA said it uncertain how future market conditions will be affected.

“Given the potential impact that both of these factors have on the F-factor, and recognizing the need to provide certainty to the automakers for purposes of their planning for MY 2020, EPA has extended the use of the existing F-factor of 0.14 to model year 2020,” the agency said in the notice. “This provides the time necessary to request comment and consider further an appropriate methodology and related inputs as we move toward MY 2021 and beyond.”

The EPA also note that the 0.14 F-factor will remain in place beyond model year 2020 until the agency adopts a revised F-factor based on new data and updated methodology. In order to inform its approach to assessing an updated F-factor for model year 2021 and later, the EPA is requesting comments on the various data sources, analytical approaches, and potential alternatives to its draft methodology for assessing the F-factor in model years 2021 and later.

As part of that effort, the EPA has prepared a technical memorandum that includes an overview of the EIA’s renewable fuel and E85 projections, the agency’s currently methodology, historical E85 usage, related data such as FFV volumes, other data sources and further consideration of the issues. The memorandum also discusses technical information the EPA has received from the auto and ethanol industries.

The EPA is seeking comments on the appropriate sources of data for establishing an updated F-factor, the possibility and potential metrics of EPA developing its own E85 forecasting methodology, and the calculation methodology described in the memorandum.

Comments can be submitted on www.Regulations.gov under Docket ID No. EPA-HQ-OAR-2020-0104 through Oct. 26. Additional information is available on the Federal Register website.