Ethanol and Regulatory Perspectives
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1 Ethanol and Regulatory Perspectives Coleman Jones Biofuel Manager, GM Powertrain February 4, 2013 Michigan Corn Growers Annual Meeting, Lansing, MI
2 WIDE RANGE OF TECHNOLOGY DRIVERs Technology Innovation Regulatory Demands AUTOMOBILE INDUSTRY Customer Requirements Energy Security Fuel Prices Climate Change
3 OUTLOOK FOR GLOBAL FUEL ECONOMY AND GREEN HOUSE GAS REQUIREMENTS CANADA Green Levy 6.6L/100km (35.5 mpg) in 2016 EUROPEAN UNION 130gCO 2 /km in 2015 (43 mpg) 95gCO 2 /km in 2020 (58 mpg) Local CO 2 taxation CHINA 6.9L/100km in 2015 (33.9 mpg) 5.0L/100km by 2020 (46.8 mpg Local taxation U.S. FEDERAL 35.5 mpg in mpg by 2025 Gasoline $3-4/gallon CALIFORNIA 80% CO 2 reduction by 2050 ZEV, PZEV rules MEXICO 10.8 km/l by 2015 INDIA 150 gco 2 /km by 2015 KOREA 140g/km (39.5 mpg) JAPAN 29% CO AUSTRALIA 190 gco 2 /km in gco 2 /km by 2024
4 US Fuel Economy Regs Automakers are regulated for fuel economy twice Once by EPA for CO2 emissions (grams CO2/mile) and standards are set Once by NHTSA for volumetric consumption (miles/gallon) First applied in 1978, now follows CO2 standards NHTSA allows fines to be paid in lieu of compliance (several manufacturers have historically paid fines) Under the CAA, EPA non-compliance penalties are untested, very large and punitive.
5 New EPA Standards Actual 2025 Requirement for Smart Sized Vehicle Electricity
6 EPA CO2 Flexibilities EPA CO2 requirements are very stringent but allow the use of available flexibilities that allow extra credit for favored activities Switching to low GHG potential refrigerants Improving air conditioning efficiencies Use of technologies that reduce real world consumption but are not completely evaluated during the test cycle (off-cycle) Alternative fuels have potential benefits Electricity is heavily favored (0.0 g/mi well to tank) E85 has reduced tailpipe CO2 emissions (~5%) CNG and diesel also have reduced tailpipe CO2 emissions (~20%) Mono-fuel vehicles capture the entire benefit Dual fuel CNG and PHEVs vehicles are presumed to use CNG or electricity as much as possible and receive high alternative fuel utilization rates Flexfuel vehicles are presumed to use gasoline
7 NHTSA & Alternative Fuels EPA and NHTSA address alternative fuels differently NHTSA s volumetric standard (MPG) must compensate for the lower energy content of alternative fuels relative to petroleum A 40 MPG vehicle will get 30 MPG on E85, this is no incentive Thus NHTSA only counts 15% of the volume of the alternative fuel A dedicated E85 gets: 30/0.15 = 200 MPG Running 50% E85: 1/(.5/40 +.5/(30/.15)) = 67 MPG Biodiesel and CNG have similar benefits This structure, with its 50% usage assumption, is a strong incentive and thus the total alternative fuel benefit was capped at 1.2 MPG Starting in 2015 the total benefit decays by 0.2 MPG until it reaches 0.2 MPG total in 2019, and 0.0 MPG in 2020 This benefit is mirrored in the EPA regulation through 2015 These NHTSA benefits can only be applied to the NHTSA obligation
8 EPA and Ethanol EPA uses actual tailpipe CO2 reductions to measure alt fuel benefits E85 is estimated to be 5% less than gasoline EPA has proposed to use actual use of alternative fuel as part of fuel economy calculation, beginning in 2016 MY Calculate a harmonic proportion of the two values Example: 222 gram CO2 = 40 mpg for gasoline, 211 gram CO2 = 42.1 mpg for E85, if 50% usage is assumed (NHTSA assumption) FE = 1/(0.5/ /42.1) = 41.0 mpg
9 What is Alt Fuel Usage? EPA presumes that E85 FFVs use 100% gasoline However, EPA has indicated that automakers are able to use the E85 certification CO2 emissions value to the extent that they can demonstrate that their FFVs actually use E85 This demonstration can be on an individual vehicle basis OEM must determine usage of a population of individual vehicles (Statistical sampling of the refueling behavior of individual vehicles ) This would be an intrusive approach Alternatively, demonstration can use a national average E85 use EPA outlined this approach in the preamble of the Final Rule
10 National Average E85 Use Basic Principal (Details are more complex) Total use of fuel ethanol in US Minus fuel ethanol used in gasoline (E10, etc) Yields amount used in E85 This ethanol volume is divided by total fleet of FFVs Yields E85 usage per vehicle A much simplified example: Assume there are 20 billion gallons of ethanol used in the US Of these 14 billion gallons are used in E10 This leaves 6 billion gallons of ethanol used in E85 This is roughly equivalent to 7 billion gallons of E85 If there are 21 million FFVs, on average each uses 333 gallons E85 per vehicle If this delivers half of the annual miles driven by these vehicles then the usage is 50% The OEM can take a 50% E85 usage credit or 0.5 * 5% = 2.5% in CO2 per vehicle
11 Ethanol GHG Comments and Result Request Requestor EPA Response SAE Calculation for Usage (Same as CNG and PHEVs) 25X25, ACE/CFDC Declined Use lifecycle CO2 benefits 25X25, Forest Groups, others Declined Utilize 0.15 divisor as in EPCA Use RFS2 Volumes 25X25, ACE/CFDC, Forest Groups, RFA 25X25, Alliance, ACE/CFDC, Growth Energy, NCGA, RFA Declined Declined E30 Growth Energy, ACE/CFDC Ignored Incorporate RFS2 Early Guidance Growth Energy, MN, NCGA, RFA 25X25, Alliance, Growth Energy Declined Maybe EPA plans to issue guidance, well in advance of each model year, but this guidance will be based on demonstrated E85 sales data from previous years, rather than projections of future E85 volumes.
12 Future Flexfuel Credits? A 50% credit on a 222 gram per mile (40 MPG) car gives 217 grams per mile (41 MPG) Pitfalls with this approach Cars are designed many years in advance so decisions about 2017 cars are happening now What will the credit be in 2017 and following years? That depends on how much ethanol is used and how much ethanol EPA decides has been used in base gasoline Size of future FFV fleet is also a factor Automakers are facing stringent fuel economy standards The average car fuel economy for 2018 is 38.8 mpg The car fleet is diverse Compliance and product plans are being developed now
13 Octane, Ethanol, Certification, and Implementation
14 Octane Octane is a measure of the resistance of a fuel to auto-ignition due to heat and pressure Octane is measured using two test methods developed in the 1920s Hot and fast Motor Octane Number (MON) Cool and slow Research Octane Number (RON) Component RON MON AKI Ethanol Iso-Octane N-Pentane Toluene Modern, smaller engines respond best to RON
15 Octane Octane is related to molar percent not volume percent Ethanol is light compared to gasoline This means that small volumetric amounts of ethanol deliver large improvements in blend octane Compoun d Latent Heat of Vaporizatio n Volume Adjusted LHV Gasoline Ethanol Methanol Heat of vaporization The evaporation of fuel produces a cooling effect This is most effective for direct injection engines The cooling allows the fuelair charge to tolerate more temperature and pressure before knocking
16 Research Octane Changes with Ethanol Ethanol significantly increases the octane of gasoline, Particularly at lower addition rates Particularly with lower octane gasolines US Regular Grade Application of Anderson & Kramer s method, et al, Energy & Fuels, 2010, 24,
17 Research Octane Changes with Ethanol For direct injected engines the charge cooling effect can add to already present chemical octane Extrapolation, not demonstrated Unlike chemical octane, the apparent octane that results from charge cooling should be proportional to the amount of ethanol added Applying the findings of Milpied & Jeuland, et al, SAE 09PFL-0471, to Anderson & Kramer s method US Regular Grade
18 Higher Octane Gasoline Increased fuel octane can be used to increase efficiency by: Increasing compression ratio leading directly to efficiency improvements Increasing boost of turbocharged engines If the engines are fully optimized for the new fuel, improved efficiencies are possible This is not a flex fuel engine that can operate on current base gasoline Greater improvements are possible if very high load cycles are used These cycles are not currently relevant to real world driving or regulatory test cycles It is possible that some hybrids could take better advantage of the fuel
19 Efficiency Improvements These depend on equipment characteristics Engine Direct Injection? Turbocharging? Bore? Structure? Engine speed? Vehicle Downsized engine Downsized vehicle to match True optimization is a long road
20 What Is Right Ethanol Level? Ethanol has diminishing returns for octane enhancement Growth Energy proposed E30 in their comments to CARB The UL mid-level dispenser is certified to E25 Some automakers do not want to go very high E30, even with E15 for waived vehicles, will not distribute the RFS2 E85 or nonethanol renewable fuel usage is required
21 Mis-Fueling Vehicles have to be protected against all market fuels Historically, knock protection was done by using knock sensors and retarding spark, quick and effective Spark retard results in power and fuel economy losses With engines fully optimized to a new medium ethanol, high octane fuel, spark retard will not provide protection Performance Management will be required This would be much more intrusive than retarding spark Reduced throttle, No boost, Forced downshifts Mis-fueling with regular unleaded will produce noticeable performance deterioration A fully optimized engine may have only limp home capability on conventional gasoline
22 How to Implement a New Fuel? Certification Fuel Optimized Vehicles Guaranteed Supply Universal Retail Availability Regulatory Barriers Mis-fueling Control Equipment Upgrades
23 Pending LEV 3 Rules Will Drive Manufacturer Fleet NMOG Requirements Substantially Lower 50K LEV II NMOG (only) Fleet Average (g/mi) California LEV II and LEV III Fleet Averages by Model Year LDT 2 PC/LDT Axes don t ratio directly LEV 2 Based on 50k Std LEV 3 Based on 150k Std K LEV III NMOG + NO X Fleet Average (g/mi)
24 LEV 3 Fuel Requirements Challenge the Viability of FFVs Going Forward 50K LEV II NMOG (only) Fleet Average (g/mi) California LEV II and LEV III Fleet Averages by Model Year LEV (0.07 NO X) ULEV 2 /B (0.07 NOX) LDT 2 PC/LDT 1 SULEV (0.02 NOX) Majority of FFVs certified here Axes don t ratio directly: LEV2 = LEV160 ULEV2 = ULEV125 SULEV2 = SULEV30 LEV 2 Based on 50k Std. LEV 3 Based on 150k Std LEV ULEV ULEV ULEV SULEV 3 30 SULEV K LEV III NMOG + NO X Fleet Average (g/mi)
25 We should all be concerned about the future because we will spend the rest of our lives there. Charles Kettering 29 Aug Nov 1958 Everything BEGINS & ENDS with GREAT PRODUCTS
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