The Urban Air Initiative (UAI), a coalition of state corn grower organizations, and the American Coalition for Ethanol, and the Clean Fuels Development Coalition filed comments last week opposing a proposed EPA rule they say would penalize ethanol for its lower carbon profile.

In a notice of proposed rulemaking, EPA is proposing to penalize the current Tier 3 test fuel that all automakers will use to meet carbon dioxide emission standards because it contains 10% ethanol. This Tier 3 test fuel lowers carbon dioxide emissions compared to the prior E0 test fuel from 1975. The EPA is creating this new penalty against ethanol by manipulating test procedures to inflate the tailpipe CO2 emissions of vehicles certified using E10. Since the penalty would presumably increase with higher ethanol volumes, this rule would be a major disincentive for automakers to transition to higher ethanol blends.

“EPA’s anti-ethanol bias is not limited to how it has badly mismanaged the Renewable Fuel Standard, it extends to the Agency’s proposal to artificially inflate CO2 emissions from vehicles being tested on E10 blends for ‘Tier 3 Test Fuel Procedures,’” said ACE CEO Brian Jennings.

State corn grower groups from Illinois, Indiana, Iowa, Kansas, Kentucky, Michigan, Missouri, Nebraska, Ohio, Texas and Wisconsin were also among the commenters.

UAI and others have been asking the EPA for years to recognize that test fuels need to represent what is actually being used in the market, and that fuels and vehicle must be viewed as an integrated system.