EPA is proposing - Petroleum Equipment Institute

misleading characterization. For the final rule, when the planned analyses are completeand current analyses updated, we will provide a consistent cost-benefit comparison.3. Emissions, Air Quality, and Health ImpactsAnalysis of criteria and toxic emission impacts was performed relative to threedifferent reference case ethanol volumes, ranging from 3.64 to 13.2 billion gallons peryear. To assess the total impact of the RFS program, emissions were analyzed relative tothe RFS1 rule base case of 3.64 billion gallons in 2004. To assess the impact of today’sRFS2 proposal relative to the current mandated volumes, we analyzed impacts relative toRFS1 mandate of 7.5 billion gallons of renewable fuel use by 2012, which was estimatedto include 6.7 billion gallons of ethanol. 4 In order to assess the impact of today’sproposal relative to the level of ethanol projected to be used in 2022 without RFS2, theAEO2007 projection of 13.2 billion gallons of ethanol in 2022 was analyzed.We are also presenting a range of impacts meant to bracket the impacts of ethanolblends on light-duty vehicle emissions. Similar to the approach presented in the RFS1rule, we present a “less sensitive” and “more sensitive” case to present a range of thepossible emission impacts of E10 on recent model year light duty gasoline vehicles. Asdetailed in Section VII.C, “less sensitive” does not apply any E10 effects to NOx or HCemissions for later model year vehicles, or E85 effects for any pollutant, while “moresensitive” does.Our projected emission impacts for the “less sensitive” and “more sensitive” casesare shown in Table II.B.3-1 and II.B.3-2, showing the expected emission changes for theU.S. in 2022, and the percent contribution of this impact relative to the total U.S.inventory across all sectors. Overall we project the proposed program will result insignificant increases in ethanol and acetaldehyde emissions – increasing the total U.Sinventories of these pollutants by up to 30-40% in 2022 relative to the RFS1 mandatecase. We project more modest but still significant increases in acrolein, NOx,formaldehyde and PM. We project today’s action will result in decreased ammoniaemissions (due to reductions in livestock agricultural activity), decreased CO emissions(driven primarily by the impacts of ethanol on exhaust emissions from vehicles andnonroad equipment), and decreased benzene emissions (due to displacement of gasolinewith ethanol in the fuel pool). Discussion and a breakdown of these results by the fuelproduction / distribution and vehicle and equipment emissions are presented in SectionVII.4 RFS1 base and mandated ethanol levels were projected to remain essentially unchanged in 2022 due tothe flat energy demands projected by EIA.37