If the state of California moves to non-oxygenated fuels, the air quality benefits of oxygenates will be forfeited, resulting in diminished air quality, according to a new analysis completed by the Colorado School of Mines, with Predictive Model and Emissions Weight Development provided by ICF Consulting and Environ International Corporation. The analysis was completed for the Renewable Fuels Association and National Corn Growers Association.

The analysis documents the air quality benefits of oxygenates, particularly with respect to high emitting vehicles and off-road emissions. "Our analysis demonstrates that non-oxygenated gasoline will increase volatile organic compounds emissions while providing little if any nitrogen oxide benefits," said the groups in a letter to U.S. Environmental Protection Agency Assistant Administer Robert Perciasepe reiterating their opposition to California's waiver request.

According to the analysis:

• The California Air Resources Board has incorrectly accounted for the effect of higher emitting vehicles on the volatile organic compounds inventory in its predictive model;
• California Air Resources Board's purported nitrogen oxide benefits for non-oxygenated fuels will not materialize in a world where refinery economics dictate fuel formulation decisions; and
• Switching from reformulated gasoline to reformulated gasoline without oxygen will increase volatile organic compounds emissions from the on-road and off-road fleet and thus may increase ozone in Southern California. This finding is in direct contradiction to California Air Resources Board's result.

The analysis letter to EPA Administer Robert Perciasepe can be seen at the Renewable Fuels Association's web site: http://www.ethanolrfa.org/