November 2013 Question of the Month

Question of the Month: What are the key terms to know when discussing ethanol flexible fuel vehicles (FFVs) and their fueling infrastructure?

Answer: It is important to know how to “talk the talk” when it comes to FFVs. Becoming familiar with the terms below will help you better understand these vehicles and the associated fueling infrastructure so that you can ask the right questions and make informed decisions.

FFV: An FFV is a vehicle that has an internal combustion engine and can run on E85 (defined below), gasoline, or a mixture of the two. Except for fuel system and powertrain adjustments that allow the vehicles to run on higher ethanol blends, FFVs are virtually identical to their conventional gasoline vehicle counterparts; however, drivers can expect a slightly lower fuel economy when driving on ethanol compared to gasoline, depending on the ethanol blend.

Types of Ethanol
Ethanol can be categorized into two main types based on the feedstocks used for its production:

• Starch- and sugar-based ethanol: Produced from feedstocks like corn, wheat, milo, and sugarcane, starch- and sugar-based ethanol makes up the majority of all domestic ethanol production. In fact, corn is the most common ethanol feedstock in the United States. This type of ethanol is manufactured through dry- or wet-mill processing. More than 80% of ethanol plants are dry mills due to lower capital costs. Dry-milling consists of grinding corn into flour and fermenting the mixture, resulting in distiller grain and carbon dioxide co-products. Wet mills separate the starch, protein, and fiber in corn prior to processing these components into products, such as ethanol.
• Cellulosic ethanol: Produced from feedstocks like crop and wood residues, dedicated energy crops, and industrial and other wastes, cellulosic ethanol offers advantages over starch- and sugar-based feedstocks (e.g., no concerns with food versus fuel). Feedstock components include cellulose, hemicellulose, and lignin. Because it is more challenging to extract sugars necessary for ethanol production from these feedstocks, cellulosic ethanol is more difficult to manufacture than starch- and sugar-based ethanol. This type of ethanol can be produced through two conversion pathways:  
• Biochemical: Feedstocks are pretreated to release hemicellulose sugars and then undergo hydrolysis to break cellulose into sugars. Sugars are fermented into ethanol, and lignin is recovered and used to produce energy to power the process.
• Thermochemical: Heat and chemicals are added to feedstocks to create a mixture of carbon dioxide and hydrogen, also known as syngas. Syngas is then mixed with a catalyst to produce ethanol. 

Ethanol Blends
The following ethanol blends can be used in conventional gasoline vehicles (note model year restrictions for E15):

• E10: (10% ethanol, 90% gasoline) – E10 is classified as "substantially similar" to gasoline by the U.S. Environmental Protection Agency (EPA) and is legal for use in any gasoline-powered vehicle. More than 95% of the U.S. gasoline supply contains up to 10% ethanol to boost octane, meet air quality requirements, or satisfy the Renewable Fuel Standard (RFS2), which calls for 36 billion gallons of biofuels to be blended into transportation fuel by 2022. E10 must meet ASTM D4806 fuel specifications. ASTM International develops specifications for conventional and alternative fuels to ensure proper vehicle operation and safety.
• E15: (15% ethanol, 85% gasoline) – E15 is legal for use in model year 2001 and newer vehicles; however, there are several EPA and state agency requirements and regulations stations must adhere to when selling E15. Fuel producers that market E15 are required to individually register with EPA. While E15 does not qualify as an alternative fuel under the Energy Policy Act of 1992 (EPAct), it does help meet RFS2. E15 must meet fuel specifications laid out in ASTM D4806 and cannot be used in motorcycles, heavy-duty vehicles, off-road vehicles, or off-road equipment.

The following ethanol blends above E15 should only be used in FFVs due to material and compatibility issues associated with the high alcohol content of ethanol:

• Mid-level blends: Blender pumps (defined below) can create various other ethanol blends between E15 and E85 (also defined below). E20 (20% ethanol, 80% gasoline) and E30 (30% ethanol, 70% gasoline) are the most common blends selected. Mid-level ethanol blends must meet fuel specifications laid out in ASTM D7794. 
• E85: E85 is considered an alternative fuel under EPAct and can contain 51% to 83% ethanol, depending on geography and season. This variance in ethanol content is allowed to ensure proper starting and vehicle performance in geographic locations where cold temperatures can affect fuel properties. Though dependent on the blend, drivers can expect about 27% less energy per gallon than gasoline, resulting in a corresponding reduction in fuel economy, when using E85. E85 must meet ASTM D5798 fuel specifications.  

Infrastructure
Low-level ethanol blends up to E10 have already been incorporated into the majority of the U.S. gasoline supply, and fueling stations that supply these blends are not required to update their fueling infrastructure. Ethanol blends above E10, however, do require specific ethanol-compatible equipment, including:

• Dispensers: E85 and blender pump dispensers require specialized metals and seals to perform with high concentrations of ethanol. Permitting authorities typically require all ethanol dispensers to be UL-listed for the ethanol blend dispensed.
• Hanging hardware: Hanging hardware, including hoses, nozzles, swivels, and breakaways used to dispense ethanol blends should use ethanol compatible materials. Permitting authorities typically require hanging hardware to be UL-listed for the ethanol blend dispensed.
• Storage tanks: EPA guidance allows underground storage tank (UST) manufacturers to provide a statement of compatibility for their products with specific biofuels blends. All tank manufacturers have issued statements of compatibility with ethanol blends. For a list of UST manufacturers and their ethanol-compatibility statements, please refer to the Clean Cities Handbook for Handling, Storing, and Dispensing E85 and Other Ethanol-Gasoline Blends (http://www.afdc.energy.gov/uploads/publication/ethanol_handbook.pdf)

Most stations that dispense mid-level blends also have the following:

• Blender pump: This type of fuel dispenser offers FFV owners a variety of ethanol-blended gasoline products between E15 and E85. Blender pumps draw fuel from two separate storage tanks (E10 and E85) and can dispense preprogrammed blends of those fuels. Blender pumps also may be used to dispense E15 legally. Note that blender pumps currently are offered only at select fueling stations and are mainly concentrated in the Midwest. The Alternative Fuels Data Center (AFDC) Fueling Station Locator (http://www.afdc.energy.gov/locator/stations/) includes details about E85 stations with blender pump availability. 

Additional information on FFVs, ethanol feedstocks, and infrastructure can be found on the AFDC Ethanol website (http://www.afdc.energy.gov/fuels/ethanol.html).


Clean Cities Technical Response Service Team
technicalresponse@icfi.com
800-254-6735

June 2013 Question of the Month

Question of the Month: What are the requirements for state and alternative fuel provider fleets under the Energy Policy Act of 1992 (EPAct 1992) and subsequent regulations and directives?

Answer:
EPAct 1992 mandates that certain state government and alternative fuel provider fleets in the United States acquire specified percentages of alternative fuel vehicles (AFVs) on an annual basis as they add light-duty vehicles (LDVs) to their fleets. Below we have described a number of means  beyond simply acquiring AFVs  by which these fleets may achieve compliance.

The U.S. Department of Energy (DOE) is responsible for overseeing compliance with these requirements, which were promulgated and published at 10 CFR Part 490 as the Alternative Fuel Transportation Program. Information about state and alternative fuel provider “covered fleets” (fleets subject to EPAct 1992 requirements) and the requirements associated with this compliance program are outlined below for each fleet type.

State Fleets
Covered Fleets
State government (including state agency and state university) fleets are considered covered fleets if all of the following conditions are met:

• They own, operate, lease, or otherwise control 50 or more light-duty vehicles (LDVs; vehicles with a gross vehicle weight rating of 8,500 pounds or less) within the United States and are not on the list of excluded vehicles. Excluded vehicles include emergency, law enforcement, and non-road vehicles;
• At least 20 of those vehicles are used primarily within a single metropolitan statistical area (MSA)/consolidated MSA (CMSA), based on 1980 census data. A list of covered MSA/CMSAs can be found online: https://www.afdc.energy.gov/vehiclesandfuels/epact/state/progs/dyn_msa.cgi; and
• Those same 20 vehicles are centrally fueled or capable of being centrally fueled, meaning they are capable of being fueled at least 75% of the time at a location that is owned, operated, or controlled by the fleet or is under contract with that fleet for fueling purposes.

The following resources may be used to determine whether a state fleet is covered:

• Decision Tree for State Government Fleets: http://www1.eere.energy.gov/vehiclesandfuels/epact/state_decision_tree.html
• State Government Fleet Compliance with the Energy Policy Act of 1992: Self-Audit Procedures: http://www1.eere.energy.gov/vehiclesandfuels/epact/pdfs/selfaudit_procedures.pdf  

Requirement
Like federal fleets regulated under EPAct 1992, a covered state fleet must acquire in a model year the number of AFVs that is equal to at least 75% of the fleet’s non-excluded LDV acquisitions.

Compliance Methods
Covered state fleets may meet their requirements using multiple means through one of two compliance methods:

• Standard Compliance: Fleets can acquire the requisite number of new or used AFVs, convert conventional vehicles to run on an alternative fuel within four months of acquisition, or obtain AFV credits from other covered fleets. Covered fleets earn one credit for each light-duty AFV that is acquired beyond the fleet’s annual requirement for the model year. Credits earned by going beyond compliance are banked for future use. Credits may also be traded with other fleets. Covered fleets may also meet up to 50% of their AFV-acquisition requirements by purchasing biodiesel blends of at least B20 for use in medium- and heavy-duty vehicles. One credit toward compliance is earned for every 450 gallons of neat biodiesel (B100) or every 2,250 gallons of B20 purchased for use. Credits earned for biodiesel purchase for use may not be banked. In addition, a fleet may earn credits for its medium- and heavy-duty AFV acquisitions, but only after the fleet has met its light-duty AFV acquisition requirements.
• Alternative Compliance: Covered fleets may obtain a waiver from the AFV acquisition requirements of Standard Compliance by submitting and then implementing a DOE- approved plan to reduce the fleet’s annual petroleum consumption. The plan must result in petroleum reductions equal to what the fleet would have achieved if all its AFVs were running on alternative fuel all the time. The plan must also include a sufficient level of data and information to support the fleet’s compliance requirements, particularly information on fuel use. Alternative Compliance petroleum reduction methods include, among others, hybrid electric vehicle (HEV) use, alternative fuel use, reduction in vehicle miles traveled, idle-time reduction, and truck stop electrification.

For a summary of compliance methods, visit the following website: http://www1.eere.energy.gov/vehiclesandfuels/epact/compliance_methods.html.

Inclusion of Hybrid Electric and Plug-in Electric Vehicles
Currently, all-electric vehicles (EVs) and some plug-in hybrid electric vehicles (PHEVs) qualify as AFVs under Standard Compliance. DOE published a notice of proposed rulemaking in October 2011, pursuant to Section 133 of the Energy Independence and Security Act of 2007, that would allocate AFV credits for covered fleet acquisitions of the following vehicles:

• HEVs would receive one-half credit
• PHEVs (those that do not already meet the definition of an AFV) would receive one-half credit
• Fuel cell electric vehicles (those that do not already meet the definition of an AFV) would receive one-half credit
• Neighborhood electric vehicles would receive one-fourth credit

For more information on this proposed rulemaking, please see the proposed rule fact sheet (http://www1.eere.energy.gov/vehiclesandfuels/epact/pdfs/section_133_proposed_rule.pdf) and the full notice (http://www.gpo.gov/fdsys/pkg/FR-2011-10-31/pdf/2011-26761.pdf).

Alternative Fuel Provider Fleets
Covered Fleets
A covered alternative fuel provider is any entity that meets one of the following conditions:

• The entity’s principle business involves producing, storing, refining, processing, transporting, distributing, importing, or selling any alternative fuel (other than electricity);
• The entity’s principle business involves generating, transmitting, importing, or selling electricity at wholesale or retail; or
• The entity produces, imports, or produces and imports in combination, an average of 50,000 barrels per day or more of petroleum, and 30% or more of its gross annual revenues are derived from producing alternative fuels.

An alternative fuel provider is not covered if its principal business involves:

• Transforming alternative fuels into products that are not alternative fuels; or
• Using alternative fuel as a feedstock, or fuel, in the manufacturing of products that are not alternative fuels.

In addition to meeting this definition, alternative fuel provider fleets are also subject to the same conditions for inclusion as state fleets (see above). For example, if a fleet does not own, operate, lease, or otherwise control at least 50 non-excluded LDVs, then it is not considered a covered fleet.

The Decision Tree for Alternative Fuel Provider Fleets (http://www1.eere.energy.gov/vehiclesandfuels/epact/alt_decision_tree.html) may be used to determine whether an alternative fuel provider fleet is covered.

Requirement
A covered alternative fuel provider fleet must acquire in a model year the number of AFVs that is equal to at least 90% of the fleet’s non-excluded LDV acquisitions.

Compliance Methods
Covered alternative fuel provider fleets have the same options for achieving compliance as state fleets.

*           *           *

Additional information on state and alternative fuel provider requirements and compliance options, as well the annual reporting requirements, may be found on DOE’s EPAct Transportation Regulatory Activities website (http://www1.eere.energy.gov/vehiclesandfuels/epact/index.html). In addition, the online Clean Cities University course on Understanding EPAct-Regulated Fleets (http://www1.eere.energy.gov/cleancities/toolbox/university.html) provides an overview of state and alternative fuel provider requirements.


Clean Cities Technical Response Service Team
technicalresponse@icfi.com
800-254-6735