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Arctic Leaf

From Philosophy About Truth To The Wisdom Of EPA Models About Emissions

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Rereading Alfred North Whitehead, one of my favorite philosophers, provides the context for the current debate over the wisdom of using the EPA’s amended transportation emissions model (Motor Vehicle Emission Simulator, or MOVES) for state-by-state analysis. He once indicated that, “There are no whole truths; all truths are half-truths. It is trying to treat them as whole truths that plays the devil.”

I am uncertain about Whitehead’s skepticism, if treated as an absolute. However, it does give pause when judging the use of an amended MOVES model, based mostly on advocacy research by the nonprofit group, the Coordinating Research Council (CRC). The CRC is funded by the oil industry, through the American Petroleum Institute (API), and auto manufacturers.

CRC was tasked by the EPA with amending MOVES and applying it to measure and determine the impact of vehicular emissions. The model and related CRC analysis was subject to comments in the Federal Register but the structure of the Register mutes easy dialogue over tough, but important, methodological disagreements among experts. Apparently, no refereed panel subjected the CRC’s process or product to critique before the EPA granted both its imperator and sent it out to the states for their use.

I am concerned that if the critics are correct, premature statewide use of the amended MOVES model will mistakenly impede development and use of alternative transitional fuels to replace gasoline, particularly ethanol, and negatively influence related federal, state and local policies and programs concerning the same. If this occurs, because of apparent mistakes in the model (and the data plugged into it), the road to significant use of renewable fuels in the future will be paved with higher costs for consumers, higher levels of pollutants and higher GHG emissions.

With some exceptions, the EPA has been a strong supporter of unbiased, nonpartisan research. Gina McCarthy, its present leader, is an outstanding administrator, like many of her predecessors, like Douglas Costle (I am proud to say that Doug worked with me on urban policy, way, way back in the sixties), Russell Train, Carol Browner, William Reilly, Christine Todd Whitman, Bill Ruckelshaus and Lee Thomas. No axes to grind; no ideological or client bias…only a commitment to help improve the environment for the American people. I feel comfortable that she will listen to the critics of MOVES.

The amended MOVES may well be the best thing since the invention of Swiss cheese. It could well help the nation, its states and its citizens determine the truths or even half-truths (that acknowledge uncertainties) related to gasoline use and alternative replacement fuels. But why the hurry in making it the gold standard for emission and pollutant analysis at the state or, indeed, the federal level, in light of some of the perceived methodological and participatory problems?

Some history! Relatively recently, the EPA correctly criticized CRC because of its uneven (at best) analytical approach to reviewing the effect of E15 on car engines. Paraphrasing the EPA’s conclusions, the published CRC study reflected a bad sample as well as too small a sample. Its findings, indicating that E15 had an almost uniform negative impact on internal combustion engines didn’t comport with facts.

The CRC’s study of E15 was, pure and simple, advocacy research. CRC reports generally reflect the views of its oil and auto industry funders and results can be predicted early on before their analytical efforts are completed. Some of its reports are better than others. But overall, it is not known for independent unbiased research.

The EPA’s desire for stakeholder involvement in up grading and use of MOVES to measure emissions is laudable. However it seems that the CRC was the primary stakeholder involved on a sustained basis in the effort. No representatives of the replacement fuel industry, no nonpartisan independent nonprofit think tanks, no government-sponsored research groups and no business or environmental advocacy groups were apparently included in the effort. Given the cast of characters (or the lack thereof) in the MOVES’ update, there’s little wonder that the CRC’s approach and subsequently the EPA’s efforts to encourage states to use the amended model have been and, I bet, will be heavily criticized in the months ahead.

Two major, well-respected national energy and environmental organizations, Energy Future Coalition (EFC) and Urban Air Initiative, have asked the EPA to immediately suspend the use of the MOVES with respect to ethanol blends. Both want the CRC/MOVES study and model to be peer reviewed by experts at Oak Ridge National Lab (ORNL), and the National Renewable Energy Lab (NREL). I would add the Argonne National Laboratory because of its role in administering GREET, The Greenhouse Gases, Regulated Emissions, and Energy Use in Transportation Model. Further, both implicitly argue that Congress should not use the CRC study and MOVES until the data and methodological issues are fixed. Indeed, before policy concerning the use of alternative replacement fuels is debated by the administration, Congress and the states both appear to want to be certain that MOVES is able to provide reasonably accurate estimates of emissions and market-related measurements, particularly with respect to ethanol and, as Whitehead would probably say, at least provide half-truths, or, as Dragnet’s Detective Jack Webb often said, “Just the facts, ma’am,” or at least just the half-truths, nothing but at least the half-truths.

What are the key issues upsetting the critics like the EFC and the Urban Air Initiative? Apart from the pedigree of the CRC and the de minimis roles granted other stakeholders than the oil industry, the CRC/MOVES model, reflects match blending instead of splash blending to develop ethanol/gasoline blends. Sounds like two different recipes with different products — and it is. Splash blending is used in most vehicles in the U.S. and generally is perceived as producing less pollution.

Let’s skip the precise formula. It’s complicated and more than you want to know. Just know that according to the letter sent to the EPA by the EFC and Urban Air Quality on Oct. 20th, the use of match blending requires higher boiling points for distillation, and these points, in turn are generally the worst polluting aromatic parts of gasoline. It noted that match blending, as prescribed by the MOVES, results in blaming ethanol for increased emissions rather than the base fuel. There is no regulatory, mechanical or health justification for adding high boiling point hydrocarbons to test fuels for purposes of measuring changes in vehicle tailpipe emissions, when ethanol is part of the fuel mixture. Independent investigations by automakers and other fuel experts confirm that the use of match blending in the study mistakenly attributed increased emission levels to ethanol rather than to the addition of aromatics and other high boiling hydrocarbons, thereby significantly distorting the model’s emission results. A peer-reviewed analysis, which will be published shortly, found that the degradation of emissions which can result is primarily due to the added hydrocarbons, but has often been incorrectly attributed to the ethanol.

The policy issues involved due to the methodological errors are significant. If states and other government entities, as well as fuel supply chain participants, use the model in its present form, they will mistakenly believe that ethanol’s emissions and pollutants are higher than reported in study after study over the past decade. The reported results will be just plain wrong. They will not even be half-truths, but zero truths. Distortions in decision making concerning the wisdom of alternative transitional replacement fuels, particularly ethanol, will occur and generate weaker ethanol markets and opportunities to build a strategic path to renewables. The EPA, rather than encourage use of the study and the model, should pull both back and suggest waiting until refereed review panels finish their work.

Fuel Freedom Staff

Court upholds EPA’s E15 waiver

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The U.S. Circuit Court of Appeals for the District of Columbia has again ruled that outside groups don’t have legal standing to file a lawsuit against the EPA’s waiver allowing E15 into the marketplace.

E15 — a blend of up to 15 percent ethanol — was allowed by the EPA waiver four years ago, for all vehicles made in model year 2001 or newer.

The waiver had been challenged by the American Petroleum Institute and the Engine Products Group.

The court had previously ruled against a similar lawsuit filed by the Grocery Manufacturers Association, deciding the group also didn’t have standing.

Read more in Domestic Fuel magazine.

Arctic Leaf

API and ethanol — A musical match made from memory

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Every time I get depressed about the world — and there is plenty to get depressed about — API (American Petroleum Institute) issues a silly press release that, in its confusing presentation and content, brings back a romantic song from my past. Because of API, over the last few years I have been reunited with Berlin, Gershwin and Bernstein, etc.

API has done it again. Its press release accusing the EPA and the administration of playing politics with RFS guidelines concerning ethanol, a release published even before the EPA has released its amended proposals, is nothing short of clairvoyant. I knew API had strange powers and was funded by the oil industry that, itself, has often been accused of confusing magic with facts.

API’s most recent press release brought joy to my heart. Without recognizing that I was doing so, while trying to sleep, I started to remember, paraphrase and sing a memorable tune from a top-ten best song list, published in the early sixties, “What kind of fool am I” (Leslie Bricusse et al.) to hope for wisdom from API. It has often run counter to facts and analysis concerning the benefits and costs of alcohol fuels and instead reflected the organization’s support from its patron oil company, Medicis.

API now contends that EPA is about to increase the renewable fuel targets for ethanol. Wow, a revolution! Call out the National Guard! To API, EPA’s action, if it occurs, would defy market place experience. E15 and E85 is not selling well. Oh, E15 and assumedly E85 is harmful to car engines. EPA’s assumed new rules would result in wasted resources and skew the market away from their favorite American-made product, gasoline (over 30 percent of which is not made in the U.S., but is imported). Not only would America be ruined but Adam Smith would turn over in his grave. Previous API releases indicate, in rather shrill tones, that ethanol is harmful to marriages, causes cigarette smoking and sexual dysfunction (just kidding).

It’s hard to respond to API’s release (or releases). Yes, the market for E15 and E85 has been relatively slow to develop, but API’s funders — oil companies — have been a, if not the, key factor causing the gap between demand and expectations. Not only has the industry tried to kill the chicken, it has also tried to kill the egg. Let me count the ways (sorry, Elizabeth Barrett Browning):

1. Oil company franchise agreements rarely allow the franchise to locate an E85 pump in their stations. If they do, many times, it must be situated apart from the other pumps in the side of the station. At the present time, there are only 3,354 E85 stations in the nation. So much for the supply side.

2. Oil companies have not been fans of open fuel legislation. They have used their lobbyists and their own political power to help kill it every time it comes up in the Congress. So much for their collective belief in consumer choice.

3. Until recently, the carmakers in Detroit — historically, the allies of the oil industry — have been slow to respond to consumer and policymaker interest in flex-fuel cars — cars that can use more than gasoline and the conversion of existing cars to FFV status. While Detroit is now producing more flex-fuel vehicles every year, the oil industry still remains a backbencher and a naysayer with respect to producing or supporting alternative fuels and conversion options, new or old. So much for competition.

4. API’s research concerning the impact of ethanol on vehicle engines, funded, again, mostly by the oil industry, has not qualified it for applause and extended readership regarding methodology or content. Its relatively recent analysis of E15 was panned, justifiably, by the EPA and other researchers because of insufficient sample numbers and lack of relevant sample characteristics. But it apparently did what it was supposed to do: put fear in the minds of drivers concerning ethanol use. So much for independent and thorough research.

5. API seems to suggest that the RINS subsidy built in to the RFS is anti-market and anti-God and country. Maybe we should look at all subsidies granted fuels by the U.S. government and complete something like zero-based budgeting process to see which ones fit the public interest and which ones primarily line the pockets of the receivers. Government help, whether direct or indirect, whether visible or imputed, should be premised on articulated and transparent public objectives and should not substitute for private sector resources which would be available without subsidy. In this context, the range of oil subsidies, now on the books, clearly needs review and justification. They far outweigh the dollars that assist newer ethanol companies. Given resource constraints, perhaps we should put oil and ethanol support on a transparent evaluation table, and, after a fair debate, allow the public to decide. Et tu, oil companies and API!

API is an easy target. They shouldn’t be. With uncertainty concerning demand and price of oil and its derivative gasoline, I would think its bosses from the oil industry would put them to work reviewing the nation’s future menu of fuels and possible partnerships with alternative fuel companies and advocates. Apart from possible pro-forma benefits, many Americans who view the oil industry and its representatives through negative filters might begin to change their mind and see the industry as increasingly pro-choice, better on the environment, pro-consumer and pro-security. Hope springs eternal. The oil industry, up to now, has been living in a fool’s paradise for a long time — cheap oil, high demand and income growth. It’s the American way. But, given a changing economy, tight oil and relatively slow and uneven U.S. and global growth, continued reliance on an old oil industry monopolistic model will cause nightmares for wise men and women. API, what’s my next song? How about “I Can Dream Can’t I” or “High Hopes!”?

Arctic Leaf

The game of checkers and corn-based ethanol

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Recent news concerning the use of corn waste or residual products to create commercially viable ethanol reminds me of a game of checkers. One jump forward, one jump backward, one move sideways. Depending how smart, bored or prone to crying the players are, the game often results in either a stalemate or a glorious victory, particularly glorious when it’s your grandson or granddaughter.

The good news! The American-owned POET and the Dutch-owned Royal DSM opened the first facility in Iowa that produces cellulosic ethanol from corn waste (not your favorite corn on the cob), only the second in the U.S. to commercially produce cellulosic ethanol from agricultural waste, according to James Stafford’s recent article in OilPrice.com (Sept. 5).

The new owners jumped (note the analogy to checkers…my readers are bright) with joy. They announced, perhaps, a bit prematurely, that the joint project, called Project LIBERTY, is the “first step in transforming our economy, our environment and our national security.” After their press release, quick, generally positive, comments came from electric and hydrogen fuel makers, CNG producers, advocates of natural gas-based ethanol and a whole host of other replacement fuel enthusiasts. The comments reflected the high hopes and dreams of leaders of public interest groups, some in the business community, several think tanks and many in the government who see transitional replacement fuels reducing U.S. dependency on oil and simultaneously improving the economy and environment. Several were fuel agnostic as long as increased competition at the pump offered a range of fuels at lower costs to consumers and reduced environmental harm to the nation.

Ethanol from corn waste, if the conversion could be made easily and if it resulted in less costs than gasoline, would mute tension between those who argue that use of corn for ethanol would limit food supplies and provide consumers a good deal, cost wise. The cowboys and the farmers might even eat the same table. (Sorry, Mr. Hammerstein.)

Life is never easy. Generally, when a replacement fuel seems to offer competition to gasoline, the API (American Petroleum Institute — supported by the oil industry) immediately tries to check the advocates of replacement fuel. The association didn’t disappoint. It made a clever jump of its own with a confusing move…sort of a bait and switch move.

API’s check and jump is reflected in their quote to Scientific American. It indicated, in holier-than-thou tones, “API supports the use of advanced biofuels, including cellulosic biofuels, once they are commercially viable and in demand by consumers. But EPA must end mandates for these fuels that don’t even exist.” Wow, how subtle. API supports and then denies!

What a bunch of hokum! Given their back-handed endorsement of advanced biofuels, would API and its supporters among oil companies agree to end their unneeded government tax subsidies simultaneously with EPA’s reductions or ending of mandates? Would API and its supporters agree to add provisions to franchise agreements that would allow gas station owners or managers to locate ethanol from cellulosic biofuels in a central visible pump? Would API work with advocates of replacement fuels to open up the gas market to replacement fuels and competition? Would API agree to a collaborative study of the impact of corn-based residue as the primers of ethanol with supporters of residue derived ethanol, a study including refereed, independent evaluators, and abide by the results? If you answer no to all of these questions, you would be right. API, in effect, is clearly trying to jump supporters of corn-based residual ethanol and block them from producing and marketing their product. Conversely, if you believe the answer is yes to one or more of the questions, you will wait a long time for anything to happen and I will offer to sell you the Golden Gate Bridge and more.

The advocates and producers of cellulosic-based ethanol from corn waste (next move) were suggested by overheard advisors to API. These advisors from the oil industry cheered API’s last move and noted that a recent study in Nature Climate Change, a respected peer-reviewed journal, suggested that biofuels made from corn residue emit 7 percent more greenhouse gases in early years than gasoline and does not meet current energy laws. They wanted checkerboard pieces held by advocates of corn residue off the policy board.

Oh, but the supporters are wise! They don’t give in right away. They pointed to an EPA analysis which indicates that using corn residue to secure ethanol meets existing energy laws and probably produces much, much less carbon than gasoline. Studies like the one reported in Nature Climate Change do not, according to an EPA spokesperson, report on lifecycle changes in an adequate way — from pre-planting, through production, blending, distribution, retailing produce and use. Moreover, a recent analysis funded by DuPont — soon to open a new cellulosic residue to ethanol facility — indicates that using corn residue to produce ethanol will be 100 percent better than gasoline, concerning GHG emissions. (Supporters were a bit hesitant about shouting out DuPont’s involvement in funding the study. It is a chemical company with a mixed environmental record. But after review, supporters indicated it seemed like a decent analysis.)

The response of supporters and its intensity caused API and its advisors to withdraw their insistence, that the checkers of the advocates of corn based residue derived ethanol come of the board. Instead, they asked for a two-hour break in the game. The residue folks were scared. “API was a devious group. What were they up too?”

When the game started again, both supporters and opponents pulled out lots of competing studies, before they made their moves. The only things they agreed on was that the extent of land use devoted to corn, combined with the way farmers manage the soil and the residue, likely would significantly affect GHG emissions. Keeping a strategic amount of residual on the soil would help reduce emissions.

Supporters of corn-based residue argued for a quick collaborative study that might help bridge the analysis gap. But they wanted a bonafide commitment from API that if corn-based residual, derived ethanol, proved better than gasoline, it would support it as a transitional replacement fuel. No soap! The game ended in a stalemate.

Based on talking to experts and surveying much of the literature, I believe that the fictional checkers game tilts toward corn residual derived ethanol, assuming significant attention is granted by farmers to management of the soil and the residue. Whether corn residual-based ethanol becomes competitive as a transitional replacement fuel will be based mostly on farmer intelligence, consumer and political acceptance and a set of even playing field regulations. It, as well as natural gas-based ethanol, as I have written in previous columns, are worthy of a set of demonstration efforts. The nation will have an extended wait until electric and hybrid cars make a big dent regarding the share of the total number of cars in America. We have a moral obligation to do the best we know how to do to lower GHG emissions and other pollutants. We shouldn’t let the almost perfect in our future reduce the possible good now.

Arctic Leaf

Make love, not war — a national dialogue on alternative fuels

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Remember the passion, the commitment and vigorous national dialogue concerning the Vietnam War, the civil rights movement and the women’s movement? No matter how one viewed the issues involved or whether one was pro or con with respect to each initiative, most of the nation, even if only watching the 6 p.m. and 10 p.m. news, seemed involved, to some extent, emotionally and many intellectually.

Given the concern many Americans seem to have for the future of the environment, the nation’s security problems and the sluggish economy (not to mention shrinking pocketbooks), why haven’t we been able to replicate the intense passions and commitments of the ‘60s and early ‘70s with respect to the muted debate over alternative transitional fuels. Very few articles in the press or on cable and TV headline the wisdom of efforts to reduce America’s dependence on gasoline through providing increased consumer choices at the pump. Those that do approach headline or first-tier status suggest, generally, often without hard analysis, that increased oil and gas production (Saudization of America) will grant the U.S. oil independence, forgetting the global nature of the oil market. The media has not focused on the costs of continued reliance on imported oil and the very restricted American vehicular fuel market limiting consumers, by and large, to costly, dirty gasoline. In-depth coverage of alternative non-renewable fuels as substitutes for gasoline and as transitional fuels before renewables are ready for prime time is rare and most times, more opinion than fact. Even the venerable New York Times rarely covers alternative transitional fuels in the context of an overall assumed national commitment to “wean” the nation off of gasoline.

Why haven’t the public and the media become involved in a real dialogue concerning the benefits and costs of alternative fuels versus continued reliance on gasoline?

I think it’s a bit of a chicken-and-egg question. Recall the intense TV coverage of Bull Connor’s vicious attack using dogs and high pressure hoses on kids in Alabama and the nobility of Martin Luther King Jr.’s 1963 speech on the mall? Both gripped us and made civil rights a moral issue. Remember TV’s extensive coverage of the marches by mostly young but also many older folks opposing the Vietnam War? And who could forget the photo of the little girl walking alone on the highway with her clothes burned off from a napalm attack and the many movies portraying G.I. casualties? It was difficult to stay neutral concerning the war, particularly if our kids or the neighbor’s kids were involved. Finally, while some Americans disagreed with them, the women’s movement had visible charismatic leaders like Gloria Steinem, Bella Abzug and Betty Ford, who had a knack for getting on TV and in newspapers to champion the need for women’s equality. Over time, they reached many of us, and if we didn’t join the movement, we argued for its success.

President Obama’s State of the Union speech was greeted with popular applause when he said we must get off of oil, but the line concerning the need to wean us off oil seem to have a shelf life of 24 hours…or maybe 48 hours. It clearly didn’t move the needle much in public interest and the public’s attention understandably turned to more media-friendly issues, such as Washington’s dysfunctional character, the budget, the debt ceiling and the Middle East.

Anti-Vietnam sentiments, civil rights and women’s rights were internalized by a relatively large, but still a minority, sector of the public. Participants in the effort to secure change viewed the three issues as affecting them personally and, for the most part, crossed class and caste lines, a fact that was deepened by the draft with respect to Vietnam. Although none of the three probably could have secured a majority vote,if placed on the ballot initially, they each grabbed the attention of most Americans over time.

Looking back, clearly the sustained involvement of a relatively cohesive minority of the public led by aggressive leadership created significant political and policy reforms. Issues were cast in terms Americans could easily understand — securing justice, freedom and a better America. They created a strong moral underpinning to proposed actions. Ultimately, grassroots support convinced key elected leaders that they could move positively without retribution to secure respective agendas.

Enveloping alternative fuels and the monopolistic gasoline markets in moral tableaux will not be easy. The issues involved are complex and don’t, without effort, engage people for more than short periods of time. They are tough to convert to brief TV or cable spots. Try going to a dinner party and raising moral variables around the reality of limited choices of consumers at the pump. Yawn…don’t expect a return invitation! Similarly, the fact that low-income households pay nearly 15% of their income for gasoline and are therefore limited concerning purchase of other basic goods does not easily translate into visual and visceral understandable, personal moral pictures. Similarly, despite the data showing increasing harm to the poor regarding the journey to work and constrained housing choices caused by high costs of gasoline, aggregate statistics blur individual problems. The economy’s overall sluggishness and its impact on most Americans, except the very affluent, divert focused attention. Happily, there is no Bull Connor, and your neighborhood gasoline station owner is often from the community. It’s difficult to make him or her an ogre. He or she is generally a hard-working individual and is struggling to make ends meet. Even the most vigorous advocates of alternative fuels and open fuel markets have yet to figure out how to vividly personalize the negative impact of the constraints imposed on the market by the oil industry on consumers, particularly low income consumers. Black hats and mustaches (whether painted in graphics or narratives) to describe the oil industry’s leadership, hasn’t worked well. Where is Norman Rockwell when we need him?

The phrase “we need all of the above” is used often in a bipartisan way by our political leaders to describe the nation’s energy strategy. The phrase may well be true, but it is difficult to get excited about it. Try it on your husband, wife or significant other tonight and see if it motivates a meaningful response. “Hey, honey, there is a meeting tonight of people interested in energy reform. The expansion of alternative fuel choices will be at the center of a strategy to grant priority to all our energy sources — coal, oil, natural gas, bio fuels, derivatives of each. It’s important. Do you want to go?” Probable response: “Are you serious? You were so romantic when I met you. What happened?”

The messages related to Vietnam, the civil rights movement and the women’s movement, at the time, were simplified into understandable, often emotional, terms. They were complemented by extensive media coverage and by strong moral certitude of both presenters and listeners. Parsed words and nuanced sentences were not often needed to convince folks to join the causes. The coalitions that were created put in hard work and lots of sweat equity to build and generate grassroots efforts. But the people were out there waiting to be recruited. While members might have disagreed on strategic policy options, they were generally together on broad objectives.

The effort to secure alternative transitional fuels and open up the gasoline market does not lend itself easily to the type of grassroots initiatives generated in the ‘60s and early ‘70s. The messages and data used to support them are seen as too complicated and, frankly, confusing to potential grassroots participants. In this context, the oil industry and its captive groups like the American Petroleum Institute (API) have big budgets and have seen fit to use their resources seemingly to confuse and distort information concerning gasoline and alternative fuels.

I am not sure a passionate grassroots movement can be created to support alternative fuels. At best, it will be difficult. But, democracy works in many ways. Progress is being made in forging working alliances among advocates of alternative fuels and leaders in the business, environmental, public sector and academic communities. Their ability to form sustainable, strong alliances will increase their likely ability to influence public policy concerning transitional fuels and open fuel markets. Building public understanding, combined with political acuity and a willingness to reach out to varied groups, will increase the odds of success in winning political, legislative and statutory support. Much will depend on their collective willingness to depart from traditional divisive ideological and institutional focus. Their leadership, borrowing the rhetoric from the Vietnam War, will probably have to learn how to make love, not war, in developing a collaborative agenda.