In 1990, the Clean Air Act mandated that toxic lead be removed from our transportation fuels. To replicate the octane-boosting qualities of lead, the petroleum-based aromatics group - benzene, toluene, ethylbenzene and xylene (BTEX) was chosen as an alternative by the oil industry. Just as lead was removed from the fuel supply, it was replaced with aromatics, needlessly exposing another generation of children to toxic chemicals in the fuel supply. Benzene is a known carcinogen, and toluene and zylene convert to benzene upon combustion, contributing to the formation of particulate matter (PM) and ozone, both potent greenhouse gases. With rising concern over the health impacts of aromatics, Senators Daschle, Dole and Harkin introduced and helped pass the "Clean Octane" amendment to the Clean Air Act Amendments in 1990, which called for the use of "benign additives to replace the toxic aromatics that are now used to boost octane in gasoline".

Unfortunately, over 20 years later, gasoline still contains at least 20 percent volume of aromatics. Research in the last decade has shown that these compounds are especially harmful to our nation’s children, and have been linked with higher rates of autism, asthma, behavioral disorders, infant mortality, and cancer. Those living in the urban core are especially vulnerable, due to their close proximity to congested roadways and also refineries producing aromatics.

The Energy Policy Act of 2005 , and its Renewable Fuel Standard (RFS), requires the blending of alternative fuels into our transportation fuels which helps reduce exposure to toxic aromatics. Not only does the full volumetric requirement of the RFS support complementary EPA policies, it helps to protect the health and safety of humans in the environment. However, last November, for the first time since the RFS was signed into law in 2005, the EPA proposed lowering the renewable volume obligations (RVOs), from 18.15 billion gallons to 15.21 billion gallons. The proposed rule also includes a reduction in the advanced biofuels category by 1.55 billion gallons. The EPA said an unanticipated decrease in gasoline consumption and limitations in the distribution of higher ethanol blends such as E85 (85 percent ethanol, 15 percent gasoline) warrant the reduction in the RFS. After several months of intense debate from the biofuels industry, farmers, environmental groups, the petroleum industry as well as comments from members of the House and Senate, the EPA’s public comment period for the 2014 RVOs closed on January 28. Thousands of comments had been submitted.

In its comments , together with the Clean Fuels Development Coalition , EESI warns of the negative consequences inherent in reducing the total amount of biofuels from our fuel supply. They include:

  • A chilling effect on the nascent advanced biofuels industry that could provide regionally appropriate, homegrown fuels across the United States because of the market uncertainty with reduced RVOs.
  • An increase in the dependence on unhealthy petroleum and aromatics, compounds that are mutagenic, carcinogenic and tetratogenic. An increase in secondary compounds formed from the incomplete combustion of gasoline, such as polyaromatic compounds (PAHs), particulate matter (PM2.5 and PM10), ozone and other harmful compounds.
  • An increase in greenhouse gases (GHG), the primary driver of climate change. Other advanced biofuels, including biodiesel, result in large reductions in GHG emissions and other pollutants. For example, cellulosic ethanol could reduce GHG emissions by up to 87 percent.

In giving credence to the so-called "blend wall," EPA could roll back this successful regulatory tool and the significant progress it has made to date. Congress’ long-term, bipartisan commitment to renewable fuels has made RFS the single most important investment and driver in the biofuels industry. Today, the industry is at a turning point. Public opinion polls have shown that consumers are ready to purchase higher blends of ethanol, and 160 commercial-scale advanced biofuels projects are planned, or recently completed, representing nearly $5 billion in private investment as well as billions in public investment. Additionally, the advent of direct fuel injection technologies in our cars will necessitate higher octane fuels – but this should come from biofuels rather than toxic aromatics. Advanced feedstocks, and their fuel applications, are growing with steadily increasing commercial production underway. Advanced technologies cannot be divorced from first-generation ethanol, which has itself made immense efficiency gains. Corn ethanol has already met the 20 percent GHG reduction target set for 2020, and could soon reach 50 percent less GHG emissions as compared to gasoline. Maintaining the full volumetric requirement of the RFS is critical not only to the industry, but to the health and safety of our most precious resource - our children.

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