August 07, 2020

Ann Mesnikoff

Test Fuel Fallacy: EPA Considers Another Handout to Automakers

The Trump EPA’s environmental rollbacks continue at a rapid clip, putting clean water, clean air, and our climate at risk. Even when EPA has a chance to do something procedural and get it right, the agency seems intent on getting it wrong.

A case in point is EPA’s proposal to finally update the gasoline it uses to test cars and trucks to comply with fuel economy and greenhouse gas emissions standards. For years, EPA has used a pure test fuel called indolene, which is not the same gasoline the public would find at the pump.

At first glance, this proposal should be a straightforward transition to more accurate vehicle fuel testing in a way that preserves the benefits of vehicle greenhouse gas and fuel economy standards. And in fact, that’s what EPA set out to do… until the auto industry asked for a giveaway.

I testified at EPA’s “virtual” phone in hearing in July. Here are the key points from my testimony:

In the proposal, EPA notes that the change in test fuels results in “small, but not insignificant, changes in the tailpipe emissions of CO₂ and in the fuel economy values that are calculated based on those CO₂ emissions.” EPA goes on to say that this “rule proposes to maintain the existing stringency and use the Administrator’s separate authority to modify the emission testing procedures under CAA 206(d). Under this authority, we have developed and are proposing to establish the numerical factors that will adjust emission test results and fuel economy calculations such that the test fuel changes do not on average increase or reduce the stringency of the existing CO₂ and fuel economy standards.”

The gist is: when you test vehicles with the new fuel, average results show 1.6% fewer emissions, without changing anything about the car. Emissions standards require car companies to get cleaner over time, not just appear cleaner. So, EPA initially planned to adjust the emissions standards to account for this discrepancy, ensuring vehicles continue to improve fuel efficiency and reduce greenhouse gas emissions.

The proposal includes the detailed explanation of testing to back up the need for an adjustment factor. Yet, at the request of the auto industry, documented in the record of meeting with the White House’s Office of Management and Budget related to this proposal, EPA “requests comment on whether the Agency should consider a regulatory approach where we require the use of Tier 3 gasoline certification fuel without any test procedure adjustment for CO_2.”

The automakers’ request is to effectively make vehicles appear cleaner and more efficient than they are with no change to the vehicle itself whatsoever. The request from the automakers should have been rejected as inconsistent with the science and the standards’ intent. Transitioning test fuel should not be an excuse for weaker standards.

This is part of a pattern with this EPA. ELPC strongly opposed the deeply flawed SAFE 2 rollback of greenhouse gas and fuel economy standards earlier this year. We joined partners in challenging the rule which replaced reasonable and achievable reductions of climate pollution and fuel consumption with a next-to-nothing set of standards. And even with this dramatic rollback in place, the auto industry is seeking another give-away through the change in test fuels. By asking EPA to consider excluding the science-based adjustment factor, automakers seek a means to make their vehicles look better on paper than they will perform for drivers in the real world.

Simply put, abandoning the adjustment factor is unacceptable. The implications of dropping the adjustment factor are significant for greenhouse gas pollution, but also for other pollutants as more fuel would be used, driving up toxic air pollution from refineries with real harm to environmental justice communities.

In sum, EPA must finalize a rule that includes the adjustment factor. Anything short of that is cheating the public and undermining even nominal climate action.

For another take on test fuels and auto industry giveaways check out this great blog here by Dave Cooke at the Union of Concerned Scientists.