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    NACS, SIGMA Present Industry Concerns About Tier 3 Standards

    Associations urge EPA to maintain the current per-gallon sulfur caps.

    WASHINGTON, D.C. -- Two industry associations teamed up to voice their opinions to the Environmental Protection Agency (EPA) about its proposed Tier 3 Motor Vehicle Emission and Fuel Standards rule and urged it to maintain the current per-gallon sulfur caps.

    Proposed on March 29, Tier 3 standards are intended to reduce gasoline sulfur levels by more than 60 percent -- down to 10 parts per million in 2017. According to the EPA, reducing sulfur can provide "significant and immediate benefits by reducing emissions from every gas-powered vehicle on the road."

    However, in a letter to the EPA, NACS, the Association for Convenience & Fuel Retailing and the Society of Independent Gasoline Marketers of America (SIGMA) raised concerns regarding the EPA's proposal in light of the Renewable Fuel Standard (RFS) and Corporate Average Fuel Economy (CAFE) Standards.

    The RFS requires refiners to use 13.8 billion gallons of ethanol this year and 15 billion by 2015. Ethanol is typically combined with gasoline in a formula of up to 10 percent, which is referred to as the blend wall.

    "As with any policy imposing dramatic reforms on the motor fuels market, the proposed rule cannot be implemented in a vacuum. It should be considered in the larger context of the motor fuels industry in the United States, particularly the evolution of the RFS," the letter stated.

    According to NACS, the EPA proposal makes E15 the default test fuel for most non-flex fuel vehicles (FFV), though it is unlikely that E15 – a blend of 15 percent ethanol and 85 percent gasoline -- will gain significant market share in the near future. In addition, the proposal makes E80-83 the default test fuel for FFVs and does not account for the fact that certain jurisdictions contain caps on ethanol content in E85 below 80 percent or that ASTM International defines E85 as containing 51-83 volume percent ethanol.

    Further, the letter states that by developing specifications for high-octane fuels and specifically referencing E30, the proposal "could entrench ethanol's current role in the fuel supply," as it also requires other potential fuels of the future to petition the agency for approval as test fuels.

    NACS and SIGMA said they both support maintaining the current per-gallon sulfur caps of 80 parts-per-million (ppm) at the refinery gate and 95-ppm downstream.

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