The document summarizes testimony from a House hearing on the EPA renewable fuel standard mandate. It discusses perspectives from various witnesses, including: - Dr. Jason Hill, who concluded that corn ethanol worsens air quality and has higher lifecycle emissions than gasoline. - NREL, who found no significant difference in emissions between E0, E15 and E20 fuels in most vehicles tested, though their analysis was limited. - Matthew Smorch of CountryMark, who said consumers don't want higher ethanol blends and the costs of infrastructure could burden gas stations. - Tim Reid of Mercury Marine, who presented evidence that E15 damaged boat engines in tests and did not meet manufacturer limits on emissions and reliability

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UCDC Public Policy 191A, Science and Technology Policy
Profs. D. Goldston and P. Windham
August 5, 2015

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The United States has an ongoing debate over the best methods for combating climate change
and how humans actually contribute to that change. A major focus area in this discussion is the
transportation sector, which contributes 27 percent of greenhouse gas emissions, “with half of all
transportation emissions coming from light-duty passenger vehicles” (Environmental Protection
Agency [EPA], 2015). To change that by using alternative fuel blends, i.e. ethanol, in gasoline is
already the most commercially viable and available option in today’s market. Automobile
manufacturers have already been committed to making significant progress increasing the fuel
efficiency of engines for a number of years now, so new options need to be explored. And although
speculation can be done to provide a path through policy for advanced biofuels alternative to ethanol,
America has already invested much and integrated large amounts of ethanol into our economy. It is
therefore my purpose today to examine the benefits or disadvantages to the policy and supply of
renewable fuels that we already have.
With regards to policy, Congress and governmental organizations must answer what impact the
technical restrictions of different ethanol blends have on the overall market feasibility of meeting the
volume targets mandated by the Renewable Fuel Standard (RFS). Also, how can policy address
concerns about human safety, environmental impact, and technology associated with ethanol blends
over 10 percent by volume? The best example of this debate in Congress is a recent, July 2015 hearing
by the House of Representatives Committee on Science, Space, and Technology, Subcommittees on
Energy and Oversight, “The EPA Renewable Fuel Standard Mandate.” As an additional source for
analysis, a report will be used from the National Renewable Energy Laboratory (NREL), “Comparative
Emissions Testing of Vehicles Aged on E0, E15, and E20 Fuels” (2012). When comparing the
arguments of many, the benefits of ethanol’s emissions reductions and increased fuel efficiency can
outweigh the costs, but only if a more ideal blend can be identified and integrated into the market and if
corn ethanol is used as a means to develop advanced biofuels like cellulosic ethanol.
The general market practice in America is to use ethanol as a renewable alternative to petroleum
products in passenger vehicles. Corn ethanol is presently being blended up to 10 percent by volume in
over 90 percent of America’s fuel supply, but the United States Environmental Protection Agency
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(EPA) has laid out a mandate of Renewable Volume Obligations (RVOs) which in the future will push
retailers to surpass this “blend wall”. Different sides of the ethanol controversy are concerned over
potential engine failures when using ethanol in higher percentages, the environmental impacts over the
entire lifecycle, and whether consumers really want more ethanol in their fuel.
The House Science Committee's hearing was led by Energy Subcommittee Chairman Randy Weber
(R-TX) and Oversight Subcommittee Chairman Barry Loudermilk (R-GA). Chairman Weber's purpose
for the hearing was to address the apparent inaccuracies of the EPA's projections on fuel usage, the
delay in all work done by the EPA, and the use of far too many mandates, in his opinion. The
Democrats countered this opinion overall with their continued concern for America's “heavy
dependence on foreign oil,” which holds the potential for catastrophe both for the economy and the
environment, they declare. The first witness called by the subcommittees was Matthew Smorch, the
Vice President of Supply and Strategy for CountryMark Cooperative Holding Corporation.
CountryMark cares about selling American fuel, serving the rural community as a Small Business
Refiner, and giving customers what they want. They are cautious as to any economic burden or
negative market impact that federal mandates could cause. In response to Subcommitte Chairman
Weber, Smorch testified that yes, he would consider his company to have “invested interest” in the
biofuels debate because the owners of the company are corn-growing farmers. Mr. Smorch notes his
qualifications for his role as a longtime businessman in the oil industry, with past experience at
Premcor’s refinery and at Amoco Corporation—owned by BP—and is an active member of American
Petroleum Institute (API) and a board member of American Fuel and Petrochemical Manufacturers
(AFPM).
Dr. Jason Hill was also present to testify for bioproducts and biosystems engineering, with
interests in the protection of the environment. Dr. Hill is very active in research at the University of
Minnesota, where he is a distinguished Associate Professor and receives grants from the U.S.
Department of Agriculture (USDA), the EPA, and the State of Minnesota Renewable Energy
Development Fund. Mr. Tim Reid was the representative from Mercury Marine, a recreational marine
engine manufacturer. Mr. Reid testified regarding his company’s goal of protecting boaters’ safety and
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economic investments, a goal that Mercury Marine shares with CountryMark.
In addition to these hearing witnesses, NREL will be used as a comparative argument in an
effort for fairness. NREL, in its efforts to produce scientific reports held to high standards of scientific
objectivity, cares about analyzing energy alternatives, the potential to improve fuel economy, and
seeing here if the high research octane number of ethanol might really represent the future of the
American transportation sector. NREL is funded by the U.S. Department of Energy (DOE) Office of
Energy Efficiency and Renewable Energy (EERE) as part of grants intended for infrastructure, health,
and renewable energy. It is their environmental awareness and caution for public health that likens the
values of NREL and Dr. Hill, though their conclusions may differ in the end.
There is a range of arguments to be made on the subject of ethanol, covering environmental,
mechanical, and economic terms. It is important first, though, to understand the technology that
contributes to the understanding of this debate. The EPA’s aim is to find alternatives that emit lower
levels of greenhouse gases than do the fossil fuels they replace. The focus for the EPA has been on
reducing carbon dioxide emissions without compromising fuel efficiency or safety of the engine, but
other toxic emissions and particulate matter also contribute to the studies (EPA, 2015). Other studies,
like Dr. Hill’s, focus on emissions including particulate matter (e.g. PM2.5), mono-nitrogen oxides,
ammonium, sulfur oxides, and general volatile organic compounds. These emissions are created when
fuel is combusted in the engine during use but also during the long production and refining process.
Additionally, ethanol is used as an oxygenate when blended with gasoline, and so the fuel burns hotter.
Since it is a different chemical composition, it can also react differently to engine components built for
gasoline. The main attraction, though, is that ethanol increases octane number, which is important for
fuel efficiency, one of EPA’s top two suggested methods for decreasing emissions from the
transportation sector.
Many organizations have done studies on the effects of ethanol in engines or studies on its
greenhouse gas emissions. Because fuel blending and the engine emissions control system are very
complex, the DOE recognized the need for a large scale study. NREL published a 2012 report,
“Comparative Emissions Testing of Vehicles Aged on E0, E15, and E20 Fuels,” which concluded that
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compared to the control, ethanol-free gasoline, no greater exhaust was produced using 15% and 20%
ethanol (E15 and E20, respectively) in any of the six vehicle models. In fact, four models out of six
actually showed increased emissions when aged, or run constantly, on E0, but NREL reported that the
difference between emissions from E15 were rather small. NREL writes that they have “statistical
confidence” and “95% confidence” in their conclusions for the 2009 cars, but their studies of the two
MY 2000 type vehicles did not provide statistical evidence or statistical significance to the effect of the
different fuels.
Dr. Jason Hill’s results sang a different tune. In summary, Dr. Hill concludes that the use of
ethanol fuel blends has harmed air quality, and corn ethanol's lifecycle emissions are worse than
gasoline. He predicts that this may be the case with cellulosic ethanol as well. He conducts ongoing
research at the University of Minnesota and has published numerous studies in collaboration with
various colleagues which compare corn ethanol, cellulosic ethanol, and gasoline effects on air quality.
The crux of Dr. Hill's conclusion is that lifecycle analysis is essential. For gasoline, this spans
extraction, refining, distribution, and finally combustion in engines; for ethanol, this spans growing,
fermentation, distillation, distribution, and final combustion. The outlook on corn ethanol changes
dramatically when you consider the entire process, Hill argues, because most fine particulate matter
and ozone emissions are created during production. Dr. Hill’s studies go further to establish “air
quality-related health costs” for each fuel category. He doesn't provide explanation for how he
monetized health risks, but corn ethanol has nearly doubled costs and cellulosic ethanol remains at
levels comparable to gasoline.
The next testimony from Tim Reid of Mercury Marine brings to light the concerns of a “legacy
fleet” of boats in the water today that are up to 40 years old and have little to no capability for being
adjusted for more oxygenated fuels. Because ethanol acts as a fuel oxygenate, “this additional oxygen
makes the fuel burn hotter, and the high temperatures can reduce the strength of metallic components”
or cause issues with chemical interactions. Mr. Reid cites a DOE, NREL and Volvo Penta study that
tested how marine engine reliability, when run on E15, exhibits certain damage and emissions
degradation that exceeded manufacturer limits. He provided photos at the hearings of the damaged boat
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engines. Mr. Reid then sites a study by DOE, NREL, and Mercury Marine on emissions, performance,
and durability during 300 hours of endurance tests. Results on the three different types of engines
showed only one completing the test without failure and showed poor run quality and increased
emissions across the board. Even the one engine that completed the test displayed carbon deposit
buildup and deterioration of the fuel gasket. Deteriorated engine components or fuel lines can cause
risky engine failure out on the water or an explosion from leaked gasoline. This is why boats have
never been approved for any fuel over the 10 percent ethanol.
On a side note, represented by similar technology studies, CountryMark’s Matthew Smorch
gives economic evidence as to the desires of the consumer market. He emphasizes that CountryMark
“started selling renewable fuels long before being required to do so by the Renewable Fuels Standard.”
CountryMark will continue to support blending “as long as it is accepted by consumers and is
economically competitive.” Mr. Smorch says consumers don’t want more ethanol in their fuel;
customers actually started asking for ethanol-free gasoline, E0, when CountryMark started trying to sell
higher blends such as E85, a blend that is up to 85% ethanol by volume. The blend wall is real, Mr.
Smorch says, and concludes that the EPA needs to make “a balance between corn growers and the
reality of the blend wall.”
Mr. Smorch clearly details the costs that a typical retailer (unowned by CountryMark) might
experience if they had to install infrastructure for E85 or blender pumps. He makes it clear that the
retailers’ margins are only a few pennies per gallon, and fuel sales are less than half a million gallons
per year in rural areas where CountryMark has their Midwest consumer base. Infrastructure costs could
be over $80,000 per station—a sizable sum.
Environmental Analysis
Each side has presented the scientific evidence for their stance on allowing higher blends of
ethanol into the market, but each has certain weaknesses as well as strengths. Dr. Hill’s main weakness
is perhaps his utter dismissal of the criticism of his work. Congressman Alan Grayson, Subcommittee
on Energy Ranking Member (D-FL), questioned Dr. Hill on his thoughts of the Renewable Fuels
Association’s (RFA) review of his studies. “Oh, they don’t do research,” was Dr. Hill’s reply. He
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dismissed the criticism because it was from a lobbying group, and because he “did not consider that in
any way scholarly research.” He incredibly argued that “those are not studies.”
Rep. Grayson continued on to bring up the DOE model, “considered to be very good with
regard to lifecycle emissions analysis… [that] shows no increase in PM2.5 [fine particulate] emissions or
other criteria pollutants when gas is 10 percent corn ethanol.” Hill corrected the Congressman,
explaining that the DOE model is only for tailpipe emissions, and by concluding that correlation does
not equal causation, the emissions drop is from other sources, “not due to the increased use of ethanol.”
In my opinion, Dr. Hill is not taking criticism seriously, and I do not think it reflects well on his
scientific reliability. The RFA, though created to promote ethanol, brings up a valid concern, that Hill
makes certain assumptions that may not be true. If RFA can provide real world data that they feel does
contradict Hill’s assumptions, that should at least be considered by the agencies or Congress when
making policy.
Dr. Jason Hill is, though, coming from a “purely scientific” perspective, because he has no
financial stake in whether this produces a market or not. His works “have not been sponsored by
anyone other than competitive federal grants,” he testifies. This is a strength in his testimony. His
references include a total of seven separate reports that he worked on relevant to his testimony at this
House Science hearing, so he certainly has done a large volume of research. He makes a good argument
against the corn and corn ethanol industries which could very well be glossing over the real negative
environmental impacts of their product. On the other hand, Hill generalizes the fuel categories as
gasoline conventional, gasoline hybrid, corn grain ethanol, and corn stover ethanol. Hill seems to have
neglected to account in his testimony for various levels of ethanol blends, though he does state when
questioned that this is a deciding factor when considering the effects of the fuel. His report seems
incomplete if he does not recognize that different percentage blends yield different results. Thus,
Congressmen weren’t then given the whole picture with respect to ethanol options.
To account for commonly suggested mid-level ethanol blends was the purpose of NREL’s
report. However, the government laboratory is not flawless either. When analyzing NREL’s report, it
would perhaps be more useful to Congress to see the comparison to gasoline with 10 percent ethanol by
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volume, E10, which NREL failed to do. Then, Congress and scientists could judge the relative effects
from a more realistic baseline, considering that E10 is what is already sold at 90% of stations in
America today. It is clear that there isn’t a linear correlation between percentage blend and emissions,
so a representative shouldn’t be left trying to extrapolate and assume. Also, NREL did not measure any
particulate matter emissions, which is generally agreed by scientists to cause public health issues.
To continue the environmental analysis of the debate, the Congress might take Dr. Hill’s
research as only a supplement to studies that analyze more emissions than he does, that use real world
data in comparison to his assumptions, or that analyze a more specific variety of blends to represent
market possibilities. Or the government could request that he do more specific research that better
factors in these questions. NREL, in comparison, might repeat its study, fix the mechanical issues, and
compare emissions results to the market standard E10. Analyzing the impacts of the environment is a
complex task, and it doesn’t seem that either the testimony or the report can completely answer our
questions.
Mechanical Analysis
The national lab then turns to mechanical concerns. As a strength, the laboratory took pains to
find three very similar vehicles, based on a number of requirements, to properly compare three systems
of the same type on three separate fuels, and the E0 and E15 test vehicles were purchased new.
Reviewing the test procedure leads me to have some confidence in their methods.
The test vehicles for E20, on the other hand, were not purchased new. Testing for E20 was
approved after the study had already gotten underway, so the labs had to attempt to locate vehicles with
low mileage and a trouble-free history according to Carmax. This could still have led to statistically
significant and scientifically sound results, but the report identifies some vehicles experiencing
“significant operational problems and failures”. This led them to restart testing using spare vehicles that
could complete the tests. It leads me to question whether the vehicles had issues because they were not
new or if the E20 fuel caused the problems. The reliability of the results of the E20 testing was
therefore weakened.
Mercury Marine also testifies with mechanical concerns. As a strength, their tests conducted are
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considered “typical”, Mr. Reid says, in that the marine engines had not experienced extraordinary
stress. They also tested three different kinds of engines, which is a good variety. Mr. Reid has an
engineering background—he holds a Bachelor’s and Master’s degrees in Mechanical engineering—and
a background in engine technology, which makes him a valid scientific source. He is able to provide
undeniable evidence of damage caused by the ethanol fuel blends over 10% by volume. Weaknesses in
Mr. Reid’s testimony only exist because he failed to mention what he will admit when you talk to him
personally. In Brazil, where Mercury Marine sells and provides warranties for engines, the fuel used is
the “local fuel”, 27% ethanol. Also, Mr. Reid is essentially saying that boaters just grab whatever fuel
line is close to them, and they have no idea what they're putting into their boat. It is presumptuous to
assume that Mercury Marine’s clients, who have invested heavily in their boats, are not paying
attention to their fuel.
Economic Analysis
This brings up the topic of economics. To analyze the testimony presented for ethanol in
economic terms, strengths and weaknesses can be identified for Mr. Smorch’s simple, straightforward
presentation. Mr. Smorch uses simple math in relation to sales that Congress must have understood
easily, and this is a strength. He also repeats again and again how they have been blending alternative
fuels long before they were required to, leaving a positive impression that they have significant
experience analyzing customer demand.
Mr. Smorch’s significant weakness is that he only provided data comparing E85. He doesn’t
present all the options. The whole story is that only a very limited amount of cars can even run on E85,
which would account for low E85 sales at any gas station. His graph also skews the perspective so you
don’t realize how small the percentages are: “on average, E0 sales make up 2.3% and E85 sales make
up 0.35% of total gasoline sales” at CountryMark. What is the average at the specific gas stations that
sell E85 though? He doesn’t clarify. It is an unfair comparison. Out of 211 gas stations in Indiana, 109
are branded CountryMark, and 16 of those sell E85—15% of CountryMark’s retail stations, and Mr.
Smorch says this is “a large percentage”. Indiana has 600,000 Flex Fuel Vehicles (FFVs) out of 3
million passenger vehicles (20%), and these are the only vehicles that can run on E85. E15 has just
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begun to come on the market, but it is not uncommon to find in the Midwest. But CountryMark
apparently has “no experience” with this option besides judging it as more expensive—another
weakness. How can they judge the E15 market demand and how it would affect supply costs as a result
of demand?
When listening to all the economic, mechanical, and environmental arguments, how should
each issue affect policy decision-making? NREL presents the EPA’s RFS, which “mandates the use of
36 billion ethanol equivalent gallons per year of renewable fuel by 2022,” a path they see to cutting
emissions through introducing higher blends into the marketplace. NREL performed the comparative
study to test environmentally whether the suggested E15 or E20 blends would be a sufficient
replacement to the current market standard, but did not make comments on the government mandate.
Dr. Hill, on this front, staunchly argues that the RFS has not done its duty to reduce negative
environmental impacts from the transportation sector because it is “met almost entirely with corn grain
ethanol”. EPA is implementing the RFS even though their own reports find that it is increasing PM2.5
and ozone emissions and causing many more premature deaths, he says; the RFS shouldn't support corn
ethanol at all. Improvements could make the production process more efficient over the years, but Hill
predicts that it simply wouldn't be enough. What Dr. Hill suggests to Congress is to focus on fuel
efficiency, electric vehicles, promote public transportation, and upgrading infrastructure in the
transportation sector to make the biggest changes for air quality. These are all very valid alternative
options, and nothing that Congress and the Administration haven't begun work on already.
To deal with mechanical concerns, the EPA has only approved E15 as a blend higher than the
standard 10% ethanol only in model year 2001 and newer cars and not in older or small engines.
Mercury Marine says their restrictions are not enough. Their concern reflects the company values
because as an engine manufacturer, of course they should be worried if their product is going to be
damaged or pose a safety risk for their customers. Mr. Reid admits that he's not an expert on the social
implications of these issues, but he does make his own general claims about the RFS. “The problem is
the variability of fuel,” Mr. Reid says, that’s what makes misfueling such a concern. This is encouraged
by the RFS mandating higher volumes of ethanol in the market, and retailers will comply by providing
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any variety of different blends. Mr. Reid proposes that “we must freeze the ethanol content of gasoline
at its current level of 10% by volume”, for the RFS's path is “nonsensical” and “ill-advised.” Mercury
Marine, like many concerned parties, is not anti-ethanol, just anti-engine-failure.
In my opinion, the concerns expressed by boaters are valid, just as they could be expressed by
motorcyclists, chain saw producers, etc. It is not as incriminating an argument against using ethanol as
a renewable fuel option as they would have Congress believe, though. I support what Rep. Eric
Swalwell (D-CA) and Rep. Daniel Lipinski (D-IL) came back to Mercury Marine with, and that is that
this is “more of an education issue than a matter of the RFS”, not an availability issue. Rep. Lipinski,
echoing Rep. Swalwell, questioned Mr. Reid to see if he’d ever heard of a station selling just high-level
blends of ethanol, or just E15 and no option of E10. The point they make here is that allowing higher-
level blends is just providing the option for consumers. Approximately 1% of American fuel
consumption is for recreational boats, since 2012. “To condemn an entire law or standard based on a
population that is only 1%,” says Rep. Swalwell, “may be going too far?” It’s not to say it does not
affect a large quantity of people, but it is one small aspect to account for, rather than throw the whole
RFS out.
Energy Subcommittee Chairman Randy Weber (R-TX) is the most concerned about how the
RFS may be “hijacking economic growth”. He argues that the EPA's projections of American fuel use
and reliance on foreign oil are outdated since Congress passed the Energy Policy Act establishing the
RFS in 2005, and these mandated blends are causing confusion for customers. So Rep. Weber turns to
Mr. Smorch. CountryMark, as it looks to policy for economic protection, supports the EPA when it
“mirrors [real] ethanol consumption” in its 2014 and 2015 proposals and accounts for the E10 blend
wall. “E10 should be the maximum for several reasons”, Mr. Smorch says, including the establishment
of economic compromise between refiners and consumers, and the prevention of the need to invest in
costly new infrastructure. CountryMark claims the ethanol increases currently proposed by EPA are
unfeasible to attain with the lack of consumer acceptance or demand. If the market sticks to the 10%
ethanol blend wall, farmers’ investments are protected, because this “still meets over 90% of the
original goal for corn-based ethanol”.
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Conclusion
Everyone agrees that the RFS law needs to be revisited and changes need to be made. Although
some are thrilled with the progress that America has made with biofuels in the past decade, many
representatives and witnesses are less than impressed. Republicans and Democrats agree together that
the biofuel industry needs to diversify and focus on fuels like cellulosic or algal-based rather than
continue to rely on corn ethanol. Many spoke to the fact that the RFS’s complete success is debatable in
its goals for energy independence, cleaner air, and defeating terrorism. The environmental impacts from
today’s corn ethanol are clearly not ideal. I believe the main challenge in solving the ethanol debate—
to use or not to use?—will be bringing Republicans and Democrats together to identify exactly which
emissions are the most concerning for public health. Then, those emissions can be analyzed from fuel
blends across the entire lifecycle, just as Dr. Hill’s studies promote, but without neglecting the whole
range of chemicals. My values are centered in environmental protection, which would rather see some
companies bend and shoulder some economic burdens if America can eventually have an economy
based solidly on renewable and green fuels.
Finally, I feel that the consumer market cannot be fully understood for what consumers want if they
are not allowed a full range of options, and if they are not educated as to the wide range of issues on the
subject. It is then that the EPA’s mandates can be fully finished, and then that refiners, blenders, and
retailers will be able to act based on solid real world data to provide for a market. This real world data
will be the actual consumer responses once these conditions of options and education are fulfilled. The
decisions in the market will need to be backed by policy guided by the specific environmental concerns
and action plans, agreed upon by Congress and scientists, as was just discussed above. The Renewable
Fuel Standard has potential, if Congress can figure out how to guide the Environmental Protection
Agency so that no producer base is alienated or over-regulated and so that their ultimate goals for
advanced biofuels are not lost from sight.
Corn ethanol has been proposed as a promising renewable alternative fuel for many years, but the
reality is that it presents a variety of mechanical, environmental, and economic issues. After countless
studies have been done, the Congressmen are listening to concerns of constituents and engine
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manufacturers, like Mercury Marine, that ethanol may be decreasing their fuel economy or causing
damage to a variety of types of engines. They’re listening to scientists, like Dr. Jason Hill, concluding
that the emissions from ethanol may be impacting public health. Government studies, from places like
the National Renewable Laboratory, try to tackle the complex issue of impacts at so many different fuel
blend levels. On the other hand, some constituents are concerned that the oil industry may be
“conspiring” or that their national security is at stake due to American dependence on foreign oil. It is
with these concerns in mind that hearings like this have been held on the Renewable Fuel Standard
mandate by the House Science Subcommittees on Energy and Oversight.
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Works Cited
Environmental and Energy Study Institute. (2015, June). High Octane Fuels: Challenges &
Opportunities. Washington, DC: Jessie Stolark.
The EPA Renewable Fuel Standard Mandate: Hearings before the Subcommittees on Energy and
Oversight, Committee on Science, Space, and Technology, House of Representatives, 114th
Cong.
(2015).
U. S. Environmental Protection Agency (2015a, May 7). Sources of greenhouse gas emissions. EPA's
Climate Change Division within the Office of Air and Radiation. Retrieved July 20, 2015, from
http://www.epa.gov/climatechange/ghgemissions/sources/transportation.html
Vertin, K., Glinsky, G., and Reek, A. (2012, August). Comparative Emissions Testing of Vehicles Aged
on E0, E15, and E20 Fuels. National Renewable Energy Laboratory, Office of Energy Efficiency and
Renewable Energy. Retrieved on August 6th
, 2015, from http://www.nrel.gov/docs/fy12osti/55778.pdf
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