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Regulation of Fuels and Fuel Additives: Renewable Fuel Standard ...

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We base our estimates <strong>of</strong> fuel quality on non-exhaust VOC <strong>and</strong> benzene<br />

emissions on the EPA MOBILE6.2 model. The one exception to this is the effect <strong>of</strong><br />

ethanol on permeation emissions through plastic fuel tanks <strong>and</strong> elastomers used in fuel<br />

line connections. Recent testing has shown that ethanol increases permeation emissions,<br />

both by permeating itself <strong>and</strong> increasing the permeation <strong>of</strong> other gasoline components.<br />

This effect was included in EPA’s analysis <strong>of</strong> California’s most recent request for a<br />

waiver <strong>of</strong> the RFG oxygen requirement, but is not in MOBILE6.2. 84 Therefore, we have<br />

added the effect <strong>of</strong> ethanol on permeation emissions to MOBILE6.2’s estimate <strong>of</strong> nonexhaust<br />

VOC emissions in assessing the impact <strong>of</strong> gasoline quality on these emissions.<br />

No models are available which address the impact <strong>of</strong> gasoline quality on PM<br />

emissions. Very limited data indicate that ethanol blending might reduce exhaust PM<br />

emissions under very cold weather conditions (e.g., -20 F to 0 F). Very limited testing at<br />

warmer temperatures (e.g., 20 F to 75 F) shows no definite trend in PM emissions with<br />

oxygen content. Thus, for now, no quantitative estimates can be made regarding the<br />

effect <strong>of</strong> ethanol use on direct PM emissions.<br />

Table VIII.A.1.b-1 presents the average per vehicle (2012 fleet) emission impacts<br />

<strong>of</strong> three types <strong>of</strong> RFG: non-oxygenated, a typical MTBE RFG as has been marketed in<br />

the Gulf Coast, <strong>and</strong> a typical ethanol RFG which has been marketed in the Midwest.<br />

84 For more information on California’s request for a waiver <strong>of</strong> the RFG oxygen m<strong>and</strong>ate <strong>and</strong> the Decision<br />

Document for EPA's response, see http://www.epa.gov/otaq/rfg_regs.htm#waiver<br />

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