Posts Tagged ‘ethanol’


E15 Will Make No Difference Now, Part II

September 7, 2010

Wonder when the EPA and the ethanol lobby are going to wake up?  If anyone ever bothered to read the RFS mandate in Section 202 of EISA 2007, which is driving all of this ethanol blending madness, they would find out that E10 or E15 is never mentioned in the act and that EISA 2007 is NOT A MANDATORY E10 law.  The RFS only deals with bio-diesel, E85 and flex-fuel vehicles.

So why all the  folderol over getting a waiver from the EPA for E15?  Because there is a huge problem buried in Section 202 (A) 2:  APPLICABLE VOLUMES OF RENEWABLE FUEL.  It is a hard coded table.  It outlines the volume of ethanol that must be produced and blended into gasoline by year:

Applicable volume of renewable fuel

Calendar year:                                   billions of gallons
2006 …………………………………………………………………… 4.0
2007 …………………………………………………………………… 4.7
2008 …………………………………………………………………… 9.0
2009 …………………………………………………………………… 11.1
2010 …………………………………………………………………… 12.95
2011 …………………………………………………………………… 13.95
2012 …………………………………………………………………… 15.2
2013 …………………………………………………………………… 16.55
2014 …………………………………………………………………… 18.15
2015 …………………………………………………………………… 20.5
2016 …………………………………………………………………… 22.25
2017 …………………………………………………………………… 24.0
2018 …………………………………………………………………… 26.0
2019 …………………………………………………………………… 28.0
2020 …………………………………………………………………… 30.0
2021 …………………………………………………………………… 33.0
2022 …………………………………………………………………… 36.0

Now keep in mind that the U.S. uses about 135-140 billion gallons of gasoline / year.  It has been in that range since the economic collapse started in 2008 and won’t likely rise in the foreseeable future unless the economy improves markedly.  If every drop of gasoline was E10, it would take, at most, 14 billion gallons of ethanol and the apparent advantage is that the refineries would only have to produce 126 billion gallons of gasoline so it appears we would use less oil, although nobody knows if that is actually true, since no one has done a large, statistically significant study of mileage before and after E10 is widely implemented.

Look at the table.  During 2012 the U.S. ethanol industry must produce more ethanol than can be put into all of the auto gasoline.  Clearly, after 2012 we are going to have ethanol coming out of our ears.  Are you beginning to understand why the RFS portion of EISA was clearly written for E85 and why the unintended consequences of the act are getting ugly?

So 2012 is the “Blending Wall” and in order for the ethanol industry to “delay” the blending wall while they try to get more taxpayer money out of Congress and state governments (which are going bankrupt, so not too likely) to add E85 infrastructure and get laws passed to force the auto industry to build more dinosaur “flex-fuel” vehicles, they figure the easiest way to delay the blending wall is to get the EPA to force gasoline companies to make E15 and force you to use it in your non flex-fuel vehicle.  And how long might that delay the blending wall?  Well, we would need 21 billion gallons of ethanol to take all of the gasoline E15, so the delay would be out to about 2016, maybe a four year delay, max.  But then we would still be at a blending wall.  Unless the U.S. starts making “Renewable Fuel”, which is E85, we are going to face a blending wall.

But it turns out there are a lot of niggling little details that need attention in order to actually implement the E15 waiver, if it is even granted.  The simple problems involve the EPA’s own set of rules about how they can go about raising the ethanol blending limit for non flex-fuel vehicles and they mainly involve a whole lot of testing.  That testing is beginning to indicate that E15 might be allowable in a range of cars, say 2007 and newer, perhaps 2001 and newer, but the testing won’t be finished for at least another couple of months, maybe more.  So the earliest that the EPA could grant some kind of waiver is looking like the end of 2010, leaving only two years until hitting the wall.

Now comes the real Gordian knot.  According to the API (American Petroleum Institute), the “evil foe” of the ethanol lobby, there are a few more hoops to jump through before you can actually foist E15 on an unsuspecting public.  They are outlined in this report.  The gist of the report is that it is going to take time, in some cases a long time, to implement E15, to say nothing of whether service stations are going to want to handle a new product with unknown liability, other than it will increase property damage.

I think the most ironic problem is that ethanol blending caps are built into a lot of state laws, as outlined in Appendix A of the report.  I live in Oregon, a mandatory E10 state.  The mandatory E10 law, passed in 2007 before the federal law passed, has infuriated a lot of our citizens.  But we are lucky in a way because embedded in that law is a 10% ethanol cap, so it is going to take a legislative change to remove the 10% limit, and this time we are prepared to fight, especially when you consider that the federal RFS mandate is supposed to be for “Renewable Fuel” which is E85.

In the final analysis though, we will be at the blending wall before E15 ever reaches the market, as I have predicted in past blogs.  It will be interesting to see the reaction of citizens when they can’t find ethanol free fuel anymore and the property damage increases and the economic impact to the aviation, marine and public safety industry spreads through an already fragile economy.



August 23, 2010

Here is an example of what is happening because of the unintended consequences of the federal RFS mandate in EISA 2007:

Aviators and the marine industry are finding it impossible to find a source of ethanol free fuel.  Of course the people who should really be worried are those in public safety who operate portable tools, but they never speak up because they are in government and until somebody dies because of ethanol blended fuel, they aren’t going to make waves.

What is ironic is the reaction of some Maine state legislators:

“Strang Burgess and Sen. Lisa Marraché, D-Waterville, discovered exactly that when they proposed a bill during the last legislative session to require retail dealers and distributors to offer nonethanol fuel. The bill stalled because “it wasn’t something we could fix at the state level,” Strang Burgess said.

It’s a federal issue, she said, driven by fuel standards.”

What “fuel standards”?  My guess is that some representative of the gasoline industry stated that at a bill hearing, but it is a lie.  I heard the same statement at public hearings in the state of Washington on a bill to protect the marine industry from the effects of ethanol blended fuel.

The question that the politicians from Maine should have asked is, “OK, show me the federal statute.”  While ethanol blending is being driven by the RFS mandate portion of EISA 2007, there is no federal statute that says all gasoline must be E10 in that act.  In fact E10 is never mentioned in the act, EISA 2007 is a corporate welfare act for E85 and flex-fuel vehicles.  Will somebody please read the act?


There are five active mandatory state E10 laws.  So if a state can pass a mandatory E10 law, it sure as hell can prohibit the blending of ethanol in premium gasoline used in the state!  And so can the EPA, and they may do exactly that in response to the E15 waiver.  We already know that there is property damage from E10 especially in the marine industry, so you can bet there will be more property damage if the EPA allows E15.  In order to minimize the damage the EPA would be wise to prohibit the blending of ethanol in all premium unleaded gasoline so those who must have ethanol free fuel can find it.


It Isn’t The Blending Wall We Should Be Worried About

February 6, 2010

New Math At The EPA

If you look at consumption statistics from the EIA you would find that the US consumed about 42 billion gallons of diesel and 136 billion gallons of auto gas in 2009.  Those stats show a decline in diesel usage and a tiny increase in auto gas usage over 2008, a year when both stats declined over 2007.  In 2009 the EPA mandated that 10.2% of that total consumption of 178 billion gallons of liquid hydrocarbon fuel be from renewable resources.  That would result in about 18 billion gallons of renewable fuel of which at least 10.5 billion gallons had to be fuel ethanol as outlined in the table in EISA 2007 (Section 202, page 31).  What is strange is that .6 billion gallons had to be “Advanced Biofuel” resulting in the total RFS requirement of 11.1 billion gallons.  So what was the other 6.1 billion gallons required by the EPA?

The EPA has just announced the 2010 standard.  The EIA 2010 projection is:  “Consumption of motor gasoline rises by 50,000 bbl/d, or 0.6 percent, and distillate fuel consumption increases by 80,000 bbl/d, or 2.1 percent.”  This would result in a diesel usage of  almost 43 billion gallons and an auto gasoline usage of  almost 137 billion gallons for a total of 180 billion gallons of liquid hydrocarbon fuel.  The EPA has set the renewable fuel mandate to be 8.25% or almost 15 billion gallons of renewable fuel.  Quite a drop don’t you think?  Of the total 12 billion gallons has to be fuel ethanol and .95 billion gallons has to be “Advanced Biofuel” for a total RFS mandate required by EISA 2007 of 12.95 billion gallons.  So what is the other 2.05 billion gallons of renewable fuel required by the EPA?  Anybody know?

Now here is the real problem, discounting the math which doesn’t obtain.  This year there was supposed to be 100 million gallons of cellulosic ethanol in that .95 billion gallons of “Advanced Biofuel” number according to the hard coded table in EISA 2007.  The EPA has lowered the quantity to 6.5 million gallons required.  Anybody noticing the huge difference! The change was made after 30 companies said they could not produce the required 100 million gallons.  Thirty companies couldn’t come up with 100 million gallons of cellulosic ethanol?

Do you know how many years the government has been throwing your tax dollars at cellulosic ethanol?  According to The Cellulosic Ethanol SiteModeling and experimental studies on dilute hydrolysis systems were carried out during the first half of the 1980s. DOE and USDA sponsored much of this work.”  The industry has said that a viable commercial cellulosic ethanol process is five years away for the last three decades and today they still say that “we are only five years away from a viable cellulosic ethanol process”.  And according to the above site your tax dollars are still being showered on them:  “In March 2007, the US government awarded $385 million in grants aimed at jumpstarting ethanol production from nontraditional sources like wood chips, switchgrass and citrus peels. Half of the six projects chosen will use thermochemical methods and half will use cellulosic ethanol methods.”  Apparently none of those 2007 grants produced much of anything since 30 companies can’t even make 100 million gallons of ethanol this year.

But the real crux of the problem is that after 2015 all of the increase in the ethanol mandate in EISA 2007 must be met by “Advanced Biofuels”, corn ethanol will be capped at 15 billion gallons.  In 2015, 6.5 billion gallons of “Advanced Biofuel” must be produced of which at least 3 billion gallons must be cellulosic biofuel (ethanol).  Never mind that the ethanol blending wall will be met no later than 2012, the true idiocy of the RFS mandate in EISA 2007 will be totally exposed when there is no way to get from 2015 to 2022.  Of course none of it will be needed unless the ethanol industry, Congress and the auto industry figure out how to move to E85 which was the whole point of EISA 2007 in the first place.  Read the act, it is a corporate welfare act for E85.  E10 is never even mentioned and there is no corporate welfare for E10, E15, ad nausea other than the blenders credit which actually pays for infrastructure upgrades for the oil distribution industry.


E15 Will Make No Difference Now

December 1, 2009

By delaying a decision about allowing E15 in our gasoline for at least another six months, the EPA has sealed its fate as a non issue in avoiding the blending wall, especially considering the conditions it is talking about, like allowing it only for cars made on or after 2001 and not allowing its use in the marine industry and small engines.  These kinds of special conditi0ns will severely limit the ability to deliver any significant amount of E15 in time to avoid the blending wall.

Clearly government bureaucrats don’t have a clue about gasoline distribution and delivery.  We have the same problem on the state level here in Oregon, a mandatory E10 state.  E10 is causing economic dislocation in the marine and aviation industry and poses a threat to the public safety industry.  We have exceptions in our law for all of those users, but it is permissive, i.e. they have to find the supply.  Suffice it to say not many outlets want to supply it because ethanol free gasoline cannot affect the delivery of any other grade of gasoline.  And there is the rub.

The vast majority of gasoline stations only have two tanks for gasoline, and maybe one for diesel.  The distributor supplies premium unleaded to one tank and regular unleaded to the other tank.  If the station supplies mid-grade it is blended in the modern three button pumps you see in most gas stations.  In Oregon, both grades must be E10.  Any station is “allowed” to sell ethanol free gasoline if they can find it, but if they choose to pump ethanol free premium, the mid-grade must still be E10.  Do you see the problem?  Two tank stations cannot pump any ethanol free gasoline in Oregon, even if they wanted to, and more than 90% of the gas stations in Oregon are two tank setups, plus branded stations wouldn’t be allowed to sell ethanol free premium, mid-grade E10 and regular E10 by their brander.  So practically nobody offers ethanol free gasoline unless the station is an oddball that had an additional tank and manifold for off road diesel or is an unbranded three tank station, both setups I have run into.  Out of more that 1600 stations, and the number is declining every year, less than 30 of them offer any ethanol free gasoline in Oregon, along with 43 marinas and 1 airport.

Lets see how this applies to the E15 waiver.  Remember, the vast majority of the gas stations in the country have only two gasoline storage tanks.  If the E15 waiver restricts E15 only to cars made on or after the 2001 model year, who will choose to pump the E15?  All of the two tank stations will have to choose, either E10 or E15.  They don’t have tanks to store both E10 regular and premium and E15 regular and premium.  Do you think any station outside a few major metropolitan areas that can reasonably target those chosen new car E15 customers will choose E15?  If they do they cut their clientele significantly while the station that chooses E10 can serve all comers, even though E10 causes property damage and is a threat to public safety.

There are a couple of other problems having to do with infrastructure compatibility and liability.  There is a knotty problem with U/L approval of pumps and there are problems with storage tanks.   So how many service stations in this economy are going to jump at the chance to pump E15 without U/L approval for their pumps and possibly damage their storage tanks?

And, so called, “Blender Pumps”, the darling of the ethanol industry right now because they can “dial a blend”, aren’t going to provide much relief either.  They have an even bigger problem with U/L because they can theoretically blend anything between E10 and E85 and they represent as big an infrastructure upgrade as E85 and in this economy how many stations can afford to replace all of their pumps with new more expensive blender pumps and hope one of their tanks can withstand E85?

There is one further small wrinkle in this scenario nobody addresses, and that is the refinery product used to make ethanol blended gasoline called BOB.  Somebody needs to do some serious research on whether one BOB can be used for multiple blending levels.  I hear conflicting reports about this problem but gasoline refining is an opaque business and I haven’t seen anybody with knowledge discuss it.  I brought it up with the only refinery representative I know and he said information about BOB was confidential.

On top of that we are months away from any decision and the clock is ticking.  Next year more than 12 billion gallons of ethanol must be blended with gasoline, enough to take at least 120 billion gallons of gasoline E10.  That would take 88% of all of the gasoline consumed this year E10, but gasoline consumption is declining so that number may actually be closer to 100%.  Whenever the E15 decision is made it is going to take months if not years to figure out the logistics of which stations are going to take the risk to pump E15, and actually get product delivered.  By that time the ethanol industry will be up against the blending wall again.  Time is of the essence and time is running out.

Of course the whole scenario is absurd.  Anyone who has actually ever read the federal RFS mandate in EISA 2007 knows that it has nothing to do with E10 or E15 or even E20 or E30.  They are never mentioned in the act.  The only ethanol blending level that is mentioned is E85 and copious amounts of your tax dollars are offered to any taker that will invest in E85 infrastructure, supply and delivery or make flex-fuel vehicles and sell them.  It is a giant corporate welfare act for E85.  You get nothing more than the blenders credit for any other level.

So explain to me again how E15 is going delay the blending wall and save the ethanol industry.  The only thing that might save the ethanol industry is to invest in E85 delivery infrastructure and design and build E85 only engines, ones that use ethanol efficiently.  Flex-fuel vehicles are dinosaurs already.  They are neither efficient gasoline powered cars, nor efficient E85 cars.  They are nothing more than a computer controlled Rube Goldberg contraption.


Mythbusters: E10 Reduces Our Dependence On Foreign Oil

August 10, 2009

It has been said over and over, ad infinitem, “E10 reduces our dependence on foreign oil.”  That should be ad nauseum, because there is no evidence whatsoever that it does or has.  It was stated repeatedly by the ethanol lobby and the ethanol booster politicians in Oregon in 2007 when the state passed its mandatory E10 law.  Strangely nobody questioned the premise, they still don’t, even after there was widespread anecdotal evidence right after implementation of E10 statewide, that it wasn’t true, or at the very least wasn’t provable.


Go ahead Google all you want.  Nobody has ever done one.  Oregon sure as heck didn’t do one.

And this is the key problem.  It appears that a lot of cars see mileage decreases in excess of the predicted 1 – 3% that all of the ethanol boosters say should happen.  If it did then they could rightly claim that E10 is reducing gasoline usage by maybe 7%.  But drivers are reporting mileage losses in excess of 10%, sometimes more than 30%.  If that is the case we may actually be using more gasoline under our mandatory E10 program than before the program.  So much for reducing our dependence on foreign oil.

So why could this be happening?  There is a very probable explanation, perhaps somewhat complicated, but it makes sense.  It dates back to the technology used by car manufacturers to meet the U.S. Clean Air Act requirements for 1981.  The new cars switched to sophisticated computer controlled electronic fuel injection systems.  Since that time there have been a number of versions of the fuel control and pollution control systems, the latest being Technology Class 5 vehicles manufactured from 1996 on, which are classified as Low Emission Vehicles (LEVs).  These hi-tech engine control units (ECUs or PCMs) are software programmed to control fuel injection and timing to provide optimum engine operation while minimizing tail pipe pollution levels in conjunction with pollution control devices such as the catalytic converter.  However the software algorithms and adaptive range capabilities for dealing with gasoline additives, such as ethanol, are proprietary.

Before 2006 there were no states with mandatory E10 laws and the highest ethanol blending levels were about 3% for certain areas with winter CO air quality problems.  It is doubtful that any of the ECUs had parameter tables, called fuel maps, that understood what was going on when 10% ethanol was put in the gas tank with its vastly increased oxygen level.

According to this old report, (read the Technical Issues Section starting on Page 3), different ECUs may produce different results on higher ethanol blends.  In fact the latest ECUs may be programmed for very narrow oxygen bands:

“In certain vehicles, the oxygen sensor could have a limited ability to transmit voltage, and could be unable to transmit voltage levels commensurate with the level of oxygen present in the fuel (Cagle 1999).
NOx emissions may be elevated due to the PCM’s inability to compensate for higher oxygen levels. The argument further maintains that ULEVs and other future technology vehicles will require an air/fuel trim within a very tight range to achieve emissions compliance.”

It is doubtful then that any ECUs, or PCMs, built before 2006 have fuel maps that take into account 10% ethanol in fuel.  The report also states that the problems may be worse for earlier versions of ECU / pollution control systems.

Is this why many cars are seeing a much worse mileage decrease than is predicted by the 3% loss of energy in a 10% ethanol blend?


EISA 2007 Is A Hazard To Public Safety

July 20, 2009

Who will be the first human casualty of the unintended consequences of EISA 2007

Today is the last day to comment on the E15 waiver request that is before the EPA.  I have learned a few things from those comments, none of them bode well.

I wonder if anyone at the EPA actually understands the federal RFS mandate.  You would think they should because they are the federal department tasked with implementing the mandate.  Anyone with an ounce of sense would look at the ethanol production quota table in Section 202 and instantly recognize that the Act was designed to produce and distribute E85.  The production demands are so large that by 2011 – 2012 there will be enough ethanol produced to take every gallon of gasoline in the U.S. E10 and all of the tax incentives and corporate welfare built into the Act are for E85, E10 is never mentioned.

So what happens when all of the gasoline in the U.S. is E10.  Something very interesting.  The Director of the Division of Air Resources, New York State Department of Environmental Conservation commented:  “E10 is not simply ethanol added to finished gasoline. Since most gasoline at retail contains ethanol, the industry factors the addition of ethanol into the formulation of the petroleum-based portion of the final blend. The chemical properties of ethanol and its dilution impact allow refiners to produce a petroleum-based blendstock which when combined with a specified amount of ethanol (or other oxygenate) results in a final blend with the desired legal and market properties.  The petroleum based blendstock, in most cases, would not qualify as gasoline or be legal to sell as gasoline.  For RFG this blendstock is RBOB. For conventional gasoline it is CBOB, and for California RFG it is CaRBOB.”

Does anyone at the EPA understand that there won’t be any ethanol free finished gasoline available for those engine applications that cannot run on ethanol belended gasoline?  Do they understand what will happen to the marine industry, aviation industry and public safety organizations that rely on small engines for their pumps, generators and portable tools?  Is the EPA prepared for the liability and litigation that will ensue from their decision to allow all of the gasoline in the country to go E10 or higher?  Liability will rest directly with the department since it is tasked with implementing the deeply flawed RFS mandate.

My final comment to the EPA for the E15 waiver can be read here.


Ethanol Free Gasoline Will Probably Disappear

June 28, 2009

There is a chilling comment in the E15 waiver process that is now before the EPA that indicates that it is likely that ethanol free gasoline will essentially disappear as we know it.  Maybe there will be small amounts available in drums just as leaded and special racing fuel is now but it will be prohibitively expensive.

This is what the Director of the Division of Air Resources, New York State Department of Environmental Conservation stated in his comment:      (Comments in italics are my comments)

“E10 is not simply ethanol added to finished gasoline.  Since most gasoline at retail contains ethanol, the industry factors the addition of ethanol into the formulation of the petroleum-based portion of the final blend.  The chemical properties of ethanol and its dilution impact allow refiners to produce a petroleum-based blendstock which when combined with a specified amount of ethanol (or other oxygenate) results in a final blend with the desired legal and market properties.  The petroleum-based blendstock, in most cases, would not qualify as gasoline or be legal to sell as gasoline.  For RFG (Reformulated Gasoline, the really clean stuff required in certain areas) this blendstock is RBOB.  For conventional gasoline it is CBOB, (this is what is coming down the Olympic pipeline to Washington and Oregon) and for California RFG it is CaRBOB.”

What this means is that not only will 91+ AKI premium unleaded disappear as we knew that it would, but 89 AKI CBOB used for making 91+ AKI premium E10 cannot be used for aircraft with the EAA STCs, low compression Petersen STCs, nor the 85 HP Rotax engines because it is not “legal” gasoline.  Essentially nobody will be able to order any ethanol free gasoline product.  Neither will the marine industry be able to find any legal ethanol free gasoline.

Please realize that the ethanol blendstock is cheaper to make for the refineries and results in more gasoline product because the AKI is lower, so they have a huge incentive to make this stuff.  We also know from the testimony of WSPA in the Washington state public hearings, for a marine protection bill, that CBOB is the only gasoline product that is going to be available at the terminals in short order in Washington.  It is already the only product delivered to Oregon since we are a mandatory E10 state.  We know that the only ethanol free product coming into Oregon is by barge from somewhere else, other than the Washington refineries.


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