Docket ID No. EPA-HQ-OAR-2019-0055
Comments of ClearFlame Engine Technologies
BJ Johnson, Co-Founder and CEO,
Rich Kassel, Director of Policy and Advisory Board member
May 16, 2022
ClearFlame Engine Technologies is pleased to present these comments1 in support of the U.S. Environmental Protection Agency’s Clean Trucks Plan and EPA’s proposal to reduce emissions of nitrogen oxides (NOx) and greenhouse gases (GHG) from our nation’s heavy-duty trucks and buses.2
Introduction to ClearFlame Engine Technologies:
Founded in 2016 as a Black- and Women-founded and led business, ClearFlame Engine Technologies is developing innovative technology to cost-effectively decarbonize the “hard-to- electrify” segments of the transportation sector—at scale, this decade. Our target markets include engines and vehicles in the long-haul trucking, agricultural, construction, and other nonroad diesel engine sectors that have useful lives that are measured in decades.
ClearFlame engines will provide owners and operators of these engines an opportunity to decarbonize their operations and eliminate their use of fossil fuels entirely, without significant infrastructure investments. ClearFlame engines will use home-grown, low-carbon, renewable fuels that are naturally low in particulate matter and NOx, such as ethanol - instead of the high- carbon petroleum diesel fuel that currently fuels these engines.
By eliminating the diesel fuel from the diesel engine, ClearFlame engines will eliminate the emissions of diesel particulate matter (PM) and NOx that increase asthma emergencies and threaten health in disadvantaged communities that live with disproportionate levels of diesel pollution, while also reducing GHG emissions in the near-term from these engines.
Perhaps most important, ClearFlame engines will maintain the efficiency, power, torque, and other performance characteristics of diesel engines that owners and operators require. In other words, ClearFlame engines preserve the positive operating attributes of diesel engines— and eliminate the negative environmental impacts of the diesel fuel. These attributes, along with the use of a readily-available, American-sourced, renewable fuel, will enable ClearFlame engines to be deployed at scale this decade, in both the highway and nonroad diesel markets.
Our concept has been validated and supported by investment from, and development partnerships with, leaders in the clean energy, renewable fuels, and OEM community. Our investors include the U.S. Department of Energy, Argonne National Laboratory, National Science Foundation, Clean Energy Ventures, Breakthrough Energy, John Deere, Mercuria, Harvard University, Stanford University, and others. Presently, we are doing field demonstrations of our first highway engine, a Cummins X15 that was jointly developed by Cummins and ClearFlame. We are also developing our first heavy-duty nonroad engine with John Deere, which should be in field tests on American farms later this year.
Summary of comments:
We strongly urge you to include Option 1 in your final Rule, which will reduce emissions of nitrogen oxides (NOx) more quickly and provide deeper reductions than Option 2.
As EPA knows, disadvantaged communities have suffered the health impacts of disproportionate levels of diesel exhaust for decades. These health impacts include increased asthma, bronchitis, cancer, heart disease, and premature death. These communities need NOx reductions as soon as possible.
More broadly, more than 127 million Americans, spread across 209 counties in 23 states and the District of Columbia, live in areas that either have not attained the 8-hour National Ambient Air Quality Standard for ozone or that are required to take ongoing steps to maintain their attainment of this standard.
For both of these reasons, we support Option 1. We are confident that we will be able to produce our engines at the NOx levels and on the MY 2027 timetable that has been proposed in Option 1.
As you update the Agency’s Phase 2 GHG standards for certain heavy-duty vehicles and as you develop EPA’s expected proposal for new Phase 3 GHG standards that will apply to all heavy- duty engines and vehicles, we strongly urge you to adapt EPA’s successful fuel-neutral, technology-neutral “systems approach” to reducing greenhouse gas (GHG) emissions from all of the nation’s heavy-duty engines and vehicles.
An innovation-driven, all-of-the-above approach will lead to more rapid carbon mitigation than pre-selecting particular technologies. The current Proposal includes provisions that reward BEVs and FCEVs that are not available to other technologies, including but not limited to ours. This approach will delay –and ultimately reduce – the overall GHG benefits of the program, an unintended consequence with real-world climate impacts.
We strongly urge EPA to revise these provisions in its final rule to enable all technologies to qualify under these provisions, thereby sending a market signal that encourages all innovations that may achieve the same – or even greater – emissions benefits when upstream and other indirect emissions are considered, at greater speed, scale, and/or cost-effectiveness.
We strongly urge EPA to revise its definition of “Fuel” and other provisions that will be necessary to ensure that a ClearFlame engine can be certified and operate using any high-blend ethanol or biofuel, including E85 and E98.
The Proposal lists ethanol only as a blend option for gasoline. It is critical that EPA sends the right market signal here – that an ethanol-fueled compression-ignition engine can receive the appropriate EPA certification and any incentives that it qualifies for, by virtue of its emissions performance.
Our additional and more detailed comments follow.
EPA Should Finalize this Proposal and Draft Next Year’s GHG Proposal to Encourage Near- Term GHG Reductions at Scale, This Decade.
Earlier this year, we all read the latest warning from the Intergovernmental Panel on Climate Change that we cannot wait any longer to deeply decarbonize the entire economy and take steps to adapt to a changing climate.3 The IPCC’s message was clear: we need “urgent, more ambitious and accelerated action and, at the same time, rapid and deep cuts in greenhouse gas emissions. The quicker and further emissions fall, the more scope there is for people and nature to adapt.”4 In short, we need to deeply decarbonize all segments of our economy this decade in order to avoid the worst impacts of climate change.
At ClearFlame, we could not agree more. While electrification appears to be the fastest pathway to decarbonizing passenger cars, transit buses, school buses, and certain commercial delivery vehicles, we must concurrently accelerate our efforts to deeply decarbonize the engines and vehicles that will continue to run on liquid fuels for decades to come.
This Proposal—and next year’s expected proposal to reduce GHG emissions from all heavy-duty engines and vehicles—should encourage innovation that results in engines and vehicles that are dramatically lower in GHG emissions than the engines and vehicles they replace, and that can scale up this decade. Speed and scale matters – just as individuals cannot save enough for retirement by waiting until the last moment to invest in their future, we will not meet our societal responsibility by investing only in solutions that will not scale for many years to come.
Only by pursuing every pathway towards decarbonization at scale this decade—as a complement to longer-term electrification strategies—will we be able to address and meet the global challenge facing us.
EPA Should Maintain its Historic Fuel-Neutral, Technology-Agnostic Performance-Based Approach in the Proposal’s Final Rule and Next Year’s Expected Phase 3 GHG Proposal
For the reasons outlined above, a fuel-neutral, technology-neutral, “systems approach” is still critically necessary – both for this Proposal and for next year’s expected proposal to reduce GHGs from all heavy-duty engines and vehicles.
Here are just a few reasons why:
First, diesel engines will continue to emit a significant portion of the transportation sector’s NOx and GHG emissions inventories in 2050. Even in states that have adopted California’s Advanced Clean Truck Rule, up to 60% of the truck tractor sales market will still be diesel in 2035.5 These engines are likely to remain on the roads for decades thereafter. In other words, diesel engines that are sold in 2035 will still be in use deep into mid-century.
Second, EPA’s Heavy-Duty Highway Engine and Vehicle Rule of 20016 (the “2001 Diesel Rule”) showed that a fuel-neutral, technology-neutral, performance-based “systems approach” reduced emissions and related health harms at scale, faster and most cost-effectively that any approach that picked specific technology winners. Indeed, when the 2001 Diesel Rule was finalized, it was widely anticipated that NOx adsorbers would be the “technology winner” that would enable diesel engines to meet the NOx standard in that rule. A competing technology, Selective Catalytic Reduction (SCR), was considered impractical and unlikely to succeed, due to the logistical hurdles posed by the need for SCR-equipped engines to use urea to operate cleanly. By 2010, SCR had become the industry standard, and NOx adsorbers never reached widespread use in the heavy-duty truck market. The lesson from that rule is clear: despite pressure to anoint NOx adsorbers as the technology “winner,” the final Rule was drafted in a fuel-neutral, technology-neutral, performance-based manner, which enabled the market to innovate and then shift quickly to a technology solution that enabled implementation at scale, in the most cost-effective and fastest way possible, within a decade.
Third, it should not be a given that a BEV or FCEV will always be the lowest-GHG option or the lowest cost option to reach a particular GHG goal. Upstream grid emissions vary widely in the United States, and we are decades away from a grid that is 100% renewable. While we are impressed by the progress being made to electrify transit and school buses and other urban truck niches that operate on short routes and rely on a home base to recharge, significant questions about the ability of BEVs and FCEVs to meet the operating needs of long-haul fleets remain unanswered and are likely to remain so for years to come.
By opening the proposed BEV and FCEV provisions (e.g., sales-weighted averages of projected emissions) to all vehicles or vehicle/fuel systems that meet fuel-neutral, technology-neutral performance criteria, EPA will accelerate innovation, and the result will be deeper, more cost- effective GHG reductions across the entire heavy-duty vehicle market. Certainly, EPA should not pick technology “winners” by adopting any form of sales mandate when finalizing this Proposal or proposing next year’s expected Phase 3 GHG standards.
Recently, Gladstein, Neandross & Associates (GNA) published a white paper that found that the ClearFlame system could provide lower GHG emissions, lower total cost of ownership (TCO), and lower cost per mile than comparable BEV, FCEV, and other systems.7 Findings of the GNA study include:
- ClearFlame-enabled trucks are expected to have the lowest TCO when compared with diesel, natural gas, electric, and hydrogen platforms.
- ClearFlame’s cost per mile is expected to be substantially lower than electric and hydrogen platforms—40% less than electric and 30% less than hydrogen.
- ClearFlame engines can provide a quick and cost-effective path to substantial reductions of GHG and other tailpipe emissions compared to other sustainable fuels and technologies, whose practical challenges, such as cost, range, infrastructure, and fuel availability, have slowed adoption.
- ClearFlame engines are estimated to provide a 42% lifecycle carbon reduction compared with diesel, as well as approximately 22% lower GHG than BEVs, based on the national average grid mix.
This TCO analysis was conducted when diesel fuel’s national average was $3.48 per gallon in October 2021 (i.e., it predates our currently escalated fuel prices). The analysis found that ClearFlame-enabled trucks would have a lower TCO than diesel by $0.08 per mile, lower than natural gas by $0.09 per mile, lower than electric by $0.97 per mile, and lower than hydrogen platforms by $0.61 per mile.
The report also highlights the potential for even greater GHG reductions using other feed sources developed by the ethanol industry with lower carbon intensities. For instance, further improvement to ethanol production processes—such as utilizing more corn fiber and stover, or adding carbon capture to production facilities—would result in GHG emissions reductions of 69- 83% compared with diesel, depending on the region.
Considering these findings, we urge EPA to take a systems approach to certifying ClearFlame engines (or any other engine that can guarantee that a non-petroleum biofuel will be used throughout useful life). When an OEM seeks to certify a ClearFlame-equipped engine as a ZEV or near-ZEV, EPA should treat the engine and the fuel as a single system, thereby granting credit for that engine’s overall emissions performance, rather than just considering the engine’s tailpipe emissions. Similarly, EPA should consider the upstream grid or other emissions impacts on any BEV or FCEV systems. Doing this across the board will better reflect the real-world emissions benefit of all vehicle/fuel/power systems. Equally important, it will provide a market signal and incentive to the biofuels community to find ways to reduce the direct and indirect GHG impacts of their fuels in order to compete successfully with BEVs, FCEVs, and any other technologies that emerge.
We acknowledge that today’s systems approach may be more complicated than simply removing sulfur or choosing among a small number of competing emission control technologies. However, this approach is even more important now, given the wide range of potential upstream or indirect GHG emissions from all types of vehicles, whether fueled by electricity, hydrogen, biofuels, or diesel. Indeed, as we evolve towards a market that includes vehicles powered by all of these options, evaluating and integrating the full upstream, indirect, and other lifecycle emissions impacts of our full vehicle/fuel/power systems will become even more important to ensuring that real world emissions meet our environmental goals.
The Biden Administration’s Net Zero Plan Will Require Increased Use of Renewable Biofuels to Replace Petroleum Diesel—and this Proposal Can Help Achieve that Goal.
The Biden administration’s bold plan to reach net zero GHG emissions by 2050 will require many strategies to succeed.8
Given that diesel engines will be in widespread use until at least midcentury, it is clear that the Biden administration’s Net Zero plan cannot succeed without a significant shift from petroleum diesel to renewable liquid biofuels. Such a strategy is necessary as a critical complement to the Biden administration’s electrification strategies.
The White House recognizes the importance of a strong, comprehensive GHG strategy that includes aggressive action to replace petroleum diesel fuel with low-carbon, renewable biofuels. Indeed, the White House’s Net Zero plan assumes that we will need roughly a gigaton of GHG reductions by decarbonizing the liquid fuels that will still be used in 2050 as a complementary strategy to its ambitious electrification goal.
We estimate that this gigaton of GHG reductions is equivalent to approximately 90 billion gallons of diesel fuel or its equivalent. This is more than twice our annual highway diesel consumption. In other words, the Biden administration’s Net Zero plan anticipates that overall use of diesel fuel (or its renewable substitutes) will continue to grow for years to come, even as parts of the heavy-duty sector increasingly move towards electrification. Meeting this goal will require a tenfold increase in our use of renewable biofuels. Perhaps for this reason, President Biden recently said, “You simply can’t get to net zero by 2050 without biofuels.”9
By aiming to reduce the GHG emissions of the entire fuel/power/vehicle “system,” EPA’s Clean Trucks Plan can help ensure that the White House’s Net Zero plan will be successful. Such an approach will incentivize accelerated scaling of all low-carbon-fuel based solutions by sending the right market signal, rather than sending the signal that a future of targeted electrification in certain vehicle niches, combined with millions of diesel trucks and buses continuing to operate on petroleum diesel fuel, will somehow be sufficient to reach Net Zero.
To be clear, ClearFlame is committed to supporting all contributions to meeting our Net Zero goals. Thus, we share the administration’s excitement about the many promising developments in the electric vehicle industry recently, including in the light-duty vehicle sector and those segments of the heavy-duty sector that are the best candidates for electrification at scale, such as school and transit buses, urban delivery vehicles, and short-haul tractors.
But electric school buses, transit buses, grocery delivery vans, and package delivery trucks will not get us to the Net Zero goal. EPA’s GHG rules should contribute to the Net Zero goal by encouraging innovation that can decarbonize all heavy-duty vehicles and engines, not just those that are most appropriate for battery or fuel cell electrification.
In sum, EPA has had more than 50 years of success using a fuel-neutral, technology-neutral approach that rewards innovation, cost-effectiveness, and the ability to scale quickly. This approach has led to deeper emissions reductions, faster and more cost-effectively and at greater scale than any technology-specific federal or state program that has “picked winners.”
The Final Rule Should Explicitly Anticipate Ethanol-fueled Compression-Ignition Engines.
Ever since the first federal vehicle emission standards for heavy-duty engines were adopted, EPA has correctly assumed that compression-ignition engines would be fueled by diesel fuel. This assumption predates those first emission standards, and has been appropriate for more than a century. Indeed, most people simply call these engines “diesel engines,” and most people probably have never even heard the phrase “compression-ignition.” For most engines over this time, the diesel fuel powering these engines was a petroleum product; in recent years, biodiesel and renewable diesel has entered the fuel market, and those fuels have been integrated into EPA’s fuel and vehicle emissions regulatory architecture.
Similarly, EPA has historically assumed that ethanol would only be used in spark-ignition engines. Again, this has been the correct assumption for decades. Even within this Proposal, EPA considers the impacts of ethanol blends on the cost of emission control aftertreatment devices used in spark-ignition engines10 and discusses ethanol only in the context of current and proposed test procedures for spark-ignition engines.11
It is now time to update these assumptions, and to integrate the use of ethanol in a compression-ignition engine into the policy architecture that will govern future heavy-duty engines and vehicles. Thus, ClearFlame strongly urges EPA to finalize this Proposal in a way that explicitly anticipates that future compression-ignition engines may operate on high-blend ethanol fuels (e.g., E85 or E98).
As we have stated above, ethanol can play a major role in decarbonizing the hard-to-electrify segments of the highway and nonroad diesel engine and vehicle markets. In order for this to happen, EPA must remove any uncertainty surrounding whether or not ethanol can be used to certify future compression-ignition engines or whether this fuel must be used thereafter throughout the useful life of such future engines.
In addition, we ask EPA to add “ethanol” to the general categories of fuels that are included in the agency’s definition of “Fuel Type.”12 Currently, the Proposal lists gasoline blended with 10 percent ethanol as merely one example of a fuel grade with the gasoline fuel type, just as premium and regular gasoline are listed. Instead, we request that EPA adds an Ethanol fuel type to list of general categories of fuels, alongside diesel fuel, gasoline, and natural gas. Within this fuel type, we request that EPA include both E85 and E98 as fuel grades that can be used for certification and other purposes.13
As you finalize this proposal, we strongly urge EPA to finalize a rule that includes Option 1, and that reduces NOx emissions from new heavy-duty diesel engines by 90 percent, starting in MY 2027. As you update the Phase 2 GHG standards and develop the agency’s approach for next year’s expected Phase 3 GHG proposal, we strongly urge the agency to adapt the fuel- neutral/technology-neutral approach that has reduced diesel PM and NOx emissions so dramatically and cost-effectively over the past two decades to deeply reduce greenhouse gas emissions from all heavy-duty and nonroad diesel applications, not just those vehicles that are most ready for electrification. Towards that end, we ask that the final rule ensures that ethanol can be used to certify diesel engines that comply with the Clean Trucks Plan’s emission standards, and that ethanol will be listed as a fuel that can be used by these engines throughout their useful lives.
We are confident that adopting these approaches will help ensure a final rule that will meet the administration’s air quality, human health, and climate goals as quickly as possible – and more quickly and more cost-effectively than any approach that limits the technology choices in the marketplace and that hampers innovation by companies that are developing new approaches to emissions reduction. We are similarly confident that this approach will continue the agency’s long track record of success that has become the model for nations around the world—and that has enabled American businesses to be the world leaders in emissions reduction technology.
We look forward to working with the Agency towards a successful Clean Trucks Plan that improves air quality and health in disadvantaged and other communities across the country, and that decarbonizes all heavy-duty and nonroad engines and vehicles in years to come.
Thank you for the opportunity to provide this testimony.
1 These comments supplement the oral testimony provided to EPA at its virtual hearing on April 12, 2022, and a comment letter submitted by BJ Johnson into the ANPRM record dated February 20, 2022. The oral testimony is attached hereto as Appendix 1, and the February 20, 2022 letter is attached hereto as Appendix 2. Each document is hereby incorporated herein.
2 “Control of Air Pollution from New Motor Vehicles: Heavy-Duty Engine and Vehicle Standards,” Docket ID No. EPA-HQ-OAR-2019-0055 (hereinafter, the “Proposal)”. Abbreviations and acronyms used herein that are not defined shall have the meaning attributed to them in the Proposal. For additional information about ClearFlame or our comments, please contact BJ Johnson at firstname.lastname@example.org or Rich Kassel at email@example.com.
3 IPCC, Climate Change 2022: Impacts, Adaptation and Vulnerability, Working Group II Report to the Sixth Assessment of the Intergovernmental Panel on Climate Change, April 2022. (“Climate Change 2022”).
4 IPCC, Climate Change 2022, Frequently Asked Questions, accessed on May 15, 2022 at: https://www.ipcc.ch/report/ar6/wg2/about/frequently-asked-questions/keyfaq1
5 California’s Advanced Clean Truck Rule, which has been adopted by New York and other states, requires 55% of Class 2b-3 truck sales, 75% of Class 4 – 8 straight truck sales, and 40% of truck tractor sales to be zero-emission by 2035.
6 EPA, Heavy-Duty Engine and Vehicle Standards and Highway Diesel Fuel Sulfur Control Requirements, Regulatory Announcement, accessed on May 15, 2002 at https://nepis.epa.gov/Exe/ZyPDF.cgi/P1001CXZ.PDF?Dockey=P1001CXZ.PDF.
7 Gladstein, Neandross & Associates, ClearFlame TCO and Emissions Study, May 2022, summarized and accessed on May 15, 2022 at https://www.clearflameengines.com/press-release/independent-study-confirms-cost-savings-emissions-advantages-for-heavy-duty-trucks-running-clearflames-engine-modification-technology/. To download the full study, visit https://www.clearflameengines.com/white-paper/tco-study/.
8 The Long-Term Strategy of the United States: Pathways to Net Zero Greenhouse Gas Emissions by 2050, November 2021. Accessed on May 15, 2022 at https://www.whitehouse.gov/wp-content/uploads/2021/10/US- Long-Term-Strategy.pdf
9 Statement of President Joseph R. Biden, April 12, 2022. Accessed on May 15, 2022 at: https://www.whitehouse.gov/briefing-room/speeches-remarks/2022/04/12/remarks-by-president-biden-on- lowering-energy-costs-for-working-families/
10 See Proposal, at 17488.
11 See, e.g., Proposal at 17490, 17491, 17631, 17703, 17849, and 17866.
12 See Proposal, at 17724.
13 See Table 1 to Paragraph (b)(4) of Section 1036.530 – Reference Fuel Properties and related discussion. This table and discussion does list high-blend ethanol, but does not specify whether E98 can be used. This should be corrected in the final rule. See Proposal, pp. 17703-17704.
“Control of Air Pollution from New Motor Vehicles: Heavy-Duty Engine and Vehicle Standards”
Regulatory Announcement EPA-HQ-OAR-2019-0055
Testimony of ClearFlame Engine Technologies
Rich Kassel, Policy Director and Advisory Board member
Presented at the
April 12, 2022 Virtual Hearing
My name is Rich Kassel. I am Director of Policy and a member of the Advisory Board of ClearFlame Engine Technologies. Thank you for the opportunity to testify in support of EPA’s Clean Trucks Plan.
Founded in 2016 as a Black- and Women-founded and led business, ClearFlame is developing technology to cost-effectively decarbonize the “hard-to-electrify” segments of the transportation sector—at scale, this decade. By using home-grown, low-carbon, renewable fuels that are naturally low in particulate matter and NOx, such as ethanol - instead of the high- carbon petroleum diesel fuel, we aim to decarbonize engines used in long-haul trucking, agriculture, and other nonroad diesel engine sectors.
We strongly urge you to include Option 1 in your final Rule, which will provide faster, deeper reductions in the emissions of nitrogen oxides (NOx) that are critically needed in disadvantaged communities that suffer the health impacts of disproportionate levels of diesel exhaust.
Further, we strongly urge you to adapt EPA’s fuel-neutral, technology-neutral “systems approach” to reduce greenhouse gas emissions from all of the nation’s heavy-duty engines and vehicles, as you finalize this proposal and next year’s expected Phase 3 GHG proposal, which will together comprise the Clean Trucks Plan.
If you remember just one sentence from my testimony today, it’s this: Even in a moment of accelerating electrification in the transportation sector, a fuel-neutral, technology-neutral, “systems approach” is still critically necessary.
Here are 3 reasons why:
First, EPA has had more than 50 years of success using this approach, which rewards innovation and the ability to scale quickly and cost-effectively. Indeed, EPA’s Heavy-Duty Highway and Nonroad Diesel rules of 2000 and 2004 showed that such a “systems approach” reduced emissions and related health harms at scale, faster and most cost-effectively that any approach that treated the fuel and vehicle separately or that “picked specific technology winners.”1
As we evolve towards a market that includes vehicles powered by batteries, fuel cells, biofuels, and yes, even some petroleum, evaluating and integrating the full lifecycle emissions impacts of our full vehicle systems will become even more important to ensuring that real world emissions meet our environmental goals.
Second, diesel engines will continue to emit a significant portion of the transportation sector’s NOx and GHG emissions in 2050. Even in states that have adopted California’s Advanced Clean Truck Rule, up to 60% of the truck tractor sales market can still be diesel in 2035.2 These engines are likely to remain on the road for decades.
Third, the Biden administration’s Net Zero plan3 assumes roughly a gigaton of greenhouse emissions reductions will be needed by decarbonizing the liquid fuels that will still be used in 2050 as a complementary strategy to its ambitious electrification goals. A fuel-neutral, technology-neutral approach that rewards innovation across all fuels and technologies will help EPA’s Clean Trucks Plan contribute to ensuring that the Net Zero plan is successful.
We look forward to working with the Agency towards a successful Clean Trucks Plan that improves health in disadvantaged and other communities across the country, and that decarbonizes all heavy-duty engines and vehicles.
Thank you for the opportunity to testify today.
1 Indeed, when the Heavy-Duty Highway Diesel Rule was finalized in 2001 (the “2001 Rule”), it was widely anticipated that NOx adsorbers would be the “technology winner” that would enable diesel engines to meet the NOx standard in that rule. A competing technology, Selective Catalytic Reduction (SCR), was considered impractical and unlikely to succeed, due to the logistical hurdles posed by the need for SCR-equipped engines to use Urea to operate cleanly. Today, SCR is the industry standard, and NOx adsorbers are not in widespread use in the heavy-duty truck market. Luckily, despite pressure to anoint NOx adsorbers as the technology “winner,” the final 2001 Rule was drafted in a fuel-neutral, technology-neutral, performance-based manner, which enabled the market to shift quickly to a technology solution that enabled implementation at scale, in the most cost-effective and fastest way possible.
2 California’s Advanced Clean Truck Rule, which has been adopted by New York and other states, requires 55% of Class 2b-3 truck sales, 75% of Class 4 – 8 straight truck sales, and 40% of truck tractor sales to be zero-emission by 2035.
3 The Long-Term Strategy of the United States: Pathways to Net Zero Greenhouse Gas Emissions by 2050, November 2021. Accessed on May 15, 2022 at https://www.whitehouse.gov/wp-content/uploads/2021/10/US- Long-Term-Strategy.pdf
ClearFlame Comments on Advance Notice of Proposed Rulemaking February 20, 2020
February 20, 2020
Andrew Wheeler, Administrator
U.S. Environmental Protection Agency
Air and Radiation Docket and Information Center EPA Docket Center, EPA WJC West Building
1301 Constitution Avenue, N.W. Room 3334 Washington, D.C. 20004
Attention: Docket ID No. EPA-HQ-OAR-2019-0055
Re: 30-day comment deadline extension request – Control of Air Pollution from New Motor Vehicles: Heavy-Duty Engine Standards
In response to EPA’s call for comments on the proposed Clean Truck Initiative, ClearFlame Engines Inc. submits the following comments to encourage the inclusion of compression-ignited, ethanol-fueled heavy-duty engines in the CTI. This supports a transition to a low-cost, low-carbon, biofuel (ethanol) while also retaining the high thermal efficiency of “Diesel cycle” (compared to spark-ignited) engines. This will be especially important for intercity, heavy-duty, commercial trucks as well as construction, agricultural and power generation equipment (for which liquid fuels will be a continuing necessity).
It is important to note that the EPA recognized back in 2001 the importance of regulating “a heavy-duty engine and its fuel as a single system”. This is a critical insight as the emissions issues associated with heavy duty diesel engines are more a function of the fuel than the engine’s compression ignition combustion system itself. Further, the recognition that fuel plays a critical role in the composition of exhaust (and therefore the availability of strategies for aftertreatment and control) is critical to the cost and effectiveness of regulations.
ClearFlame Engines believes that there are currently three choices before us: 1. Continue to focus on the use diesel fuel (petroleum, bio or renewable) and incur ever-increasing costs and decreasing returns from aftertreatment system technology, materials, complexity and durability; 2. Change to an electrified drivetrain (battery or fuel-cell) that will increase cost even more than diesel aftertreatment, reduce cargo carrying capability, reduce productivity and require massive infrastructure; Or, 3. Retain the engine performance and simple liquid-refueling enjoyed by diesel users today, but change the fuel to one that is renewable, low-carbon, domestic, and no more expensive than petroleum diesel fuel.
This third alternative is a new technology, and many people are unaware that it is even possible. It is a recent development which has been supported by the Department of Energy, the National Science foundation and the Department of Agriculture among other Federal agencies. It is currently being effectively demonstrated at Argonne National Laboratory. Clearly, something that does not drive costs higher and retains much of today’s existing infrastructure investment, but that is very effective in achieving near-zero NOx and particulate matter, should be part of any Clean Truck Initiative.
Benefits of Ethanol Heavy-Duty Engines:
Changing from petroleum diesel fuel to ethanol can help meet and exceed the requirements of the RFS while simultaneously freeing heavy-duty diesel (compression ignition) engines from smoke-limited, lean
operation. This change enables a stoichiometric calibration using soot-free “Clear EGR” (as opposed to excess air) for load management and maintenance of higher exhaust temperatures consistent with fast “light-off” of 3-way catalysis. Elimination of DEF/SCR results in dramatic simplification of the aftertreatment system, generating cost savings that are far larger than the cost of changes needed to optimize the engine to operate on ethanol – creating a net cost reduction to achieve far lower emissions. Further, low PM “blow-by” may allow sealed crankcases to further reduce emissions. Finally, note that these changes to not compromise the engine architecture, and so all of the performance and practicality benefits of the diesel engine design are maintained.
These benefits are critical to EPA’s CTI goals, and promoting the use of ethanol in “diesel” engines in the U.S. as part of the CTI will position the U.S. as a leader in clean engine technology, and create export markets for U.S.-produced ethanol engines and U.S.-grown ethanol. Further, recognizing a next generation “engine-fuel system” change from (compression ignition - diesel fuel) to (compression ignition - ethanol fuel) - as part of the CTI can immediately speed its adoption and the resulting benefits in reducing criteria pollutants. There would be no need to discuss separate standards between EPA and CARB as this technology can easily and quickly reach the CARB desired .02g/Hp-Hr NOx without requiring substantially higher costs or development of additional complex aftertreatment hardware.
Reducing Emissions via Increased Biofuels Usage:
Historically, the unattractive aspect of biofuels has been that they are used as “blend stocks” – displacing 5, 10, 15, 20 or even 30% of petroleum used – but leaving 70, 80, 85, 90, or 95% of petroleum still in place. Moving to the use of 100% biofuel and effective aftertreatment enables combustion engines to achieve the pollution reduction and sustainability goals of the cleanest alternatives (like battery electric and hydrogen fuel cells). At the same time, the barriers to adoption for an “engine-fuel system” improvement are so much lower than those for electrification, that speed of adoption alone will more than offset any remaining differences in emissions of any kind – criteria or CO2. As a result, biofuels should be an important complement to electrification in the CTI, as a means of simplifying user adoption of low-emissions alternatives.
The above summarizes the need for the EPA to give stronger consideration to the use of bio-fuels – specifically ethanol – as a fuel for heavy-duty diesel engines as a way to achieve the NOx reductions desired. To date, regulators have been unaware of the possibility and practicality of the alternative proposed here, so ClearFlame hopes this information will encourage EPA to integrate the benefits of heavy-duty ethanol systems in the CTI. The levels for allowable NOx (as well as PM) need not change from those discussed as they can be obtained with what is described as an “engine-fuel system” improvement. Successful regulation must consider costs to implement and while historic alternative solutions have increased costs, the proposed “engine-fuel” improvement can be seen to reduce costs – drastically aiding in adoption and accelerating realization of benefits.
CEO, ClearFlame Engines, Inc.