The U.S. Environmental Protection Agency’s greenhouse gas emissions standards for 2023 and later light-duty vehicles should lay out the roadmap for an orderly transition to high-octane, low-carbon liquid fuels, the Renewable Fuels Association said in comments filed late Monday. The comments were submitted in response to EPA’s August proposed rule for 2023-2026 light-duty GHG emissions standards.

“Unfortunately, EPA’s proposal fails to recognize that the fuels we put into our engines can have as much—or more—impact on fuel economy and GHG emissions as the engine technologies themselves,” RFA President and CEO Geoff Cooper wrote. “We believe the proposal missed a critical opportunity to expressly solicit public comment on potential regulatory pathways for adopting high-octane, low-carbon liquid fuels as a means of improving fuel economy and reducing emissions from the light-duty vehicle fleet.”

RFA recommends the following course of actions:

• Require a transition to a higher minimum-octane gasoline (98-100 RON) for all new internal combustion vehicles.
• Establish parity and consistency in the regulation of fuel volatility for ethanol and gasoline blends.
• Approve a Mid-Level Ethanol Blend Certification Fuel.
• Reject the results of the EPAct/V2/E-89 Fuel Effects Study and suspend further use or development of the MOVES2014 model until a new emissions study based on appropriate test fuels is conducted.
• Update EPA’s Lifecycle Analysis of Corn Ethanol Greenhouse Gas (GHG) Emissions.
• Level the playing field for GHG emissions credit generation for all alternative fuel vehicles, including flexible fuel vehicles (FFVs).

“If our nation is to reach its goal of net-zero GHG emissions by mid-century, we’ll need both cleaner, more efficient cars and cleaner, more efficient fuels,” Cooper wrote.