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Regulation of Fuels and Fuel Additives: Renewable Fuel Standard ...

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change gasoline sulfur levels, so emissions <strong>of</strong> sulfur dioxide <strong>and</strong> any resultant ambient<br />

concentrations <strong>of</strong> sulfate PM are not expected to change. Increased ethanol use is<br />

expected to increase NOx emissions, as described above. Thus, the possibility exists that<br />

ambient nitrate PM levels could increase. Increased ethanol is generally expected to<br />

increase VOC emissions, which could also impact the formation <strong>of</strong> secondary organic<br />

PM. However, some VOC emissions, namely exhaust VOC emissions, are expected to<br />

decrease, while non-exhaust VOC emissions are expected to increase <strong>and</strong> the impact on<br />

PM is a function <strong>of</strong> the type <strong>of</strong> VOC emissions.<br />

The formation <strong>of</strong> secondary organic PM is very complex, due in part to the wide<br />

variety <strong>of</strong> VOCs emitted into the atmosphere. Whether or not a specific gaseous VOC<br />

reacts to form PM in the atmosphere depends on the types <strong>of</strong> reactions that VOC<br />

undergoes, which in turn can depend on other pollutants present, such as ozone, NOx <strong>and</strong><br />

other reactive compounds. The relative mass <strong>of</strong> secondary PM formed per mass <strong>of</strong><br />

gaseous VOC emitted can also depend on the concentration <strong>of</strong> the gaseous VOC <strong>and</strong> the<br />

organic PM in the atmosphere. Most <strong>of</strong> the secondary organic PM exists in a continually<br />

changing equilibrium between the gaseous <strong>and</strong> PM phases. Both the rates <strong>of</strong> these<br />

reactions <strong>and</strong> the gaseous-PM equilibria depend on temperature, so seasonal differences<br />

can be expected.<br />

Recent smog chamber studies have indicated that gaseous aromatic VOCs can<br />

form secondary PM under certain conditions. These compounds comprise a greater<br />

fraction <strong>of</strong> exhaust VOC emissions than non-exhaust VOC emissions, as non-exhaust<br />

VOC emissions are dominated by VOCs with relatively high vapor pressures. Aromatic<br />

VOCs tend to have lower vapor pressures. As increased ethanol use is expected to reduce<br />

exhaust VOC emissions, emissions <strong>of</strong> aromatic VOCs should also decrease. In addition,<br />

refiners are expected to reduce the aromatic content <strong>of</strong> gasoline by 5 volume percentage<br />

points as ethanol is blended into gasoline. Emissions <strong>of</strong> aromatic VOCs should decrease<br />

with lower concentrations <strong>of</strong> aromatics in gasoline. Thus, emissions <strong>of</strong> gaseous aromatic<br />

VOCs could decrease for both reasons.<br />

Overall, we expect that the decrease in secondary organic PM is likely to exceed<br />

the increase in secondary nitrate PM. In 1999, NOx emissions from gasoline-fueled<br />

vehicles <strong>and</strong> equipment comprised about 20% <strong>of</strong> national NOx emissions from all<br />

sources. In contrast, gasoline-fueled vehicles <strong>and</strong> equipment comprised over 60% <strong>of</strong> all<br />

national gaseous aromatic VOC emissions. The percentage increase in national NOx<br />

emissions due to increased ethanol use should be smaller than the percentage decrease in<br />

national emissions <strong>of</strong> gaseous aromatics. Finally, in most urban areas, ambient levels <strong>of</strong><br />

secondary organic PM exceed those <strong>of</strong> secondary nitrate PM. Thus, directionally, we<br />

expect a net reduction in ambient PM levels due to increased ethanol use. However, we<br />

are unable to quantify this reduction at this time.<br />

EPA currently utilizes the CMAQ model to predict ambient levels <strong>of</strong> PM as a<br />

function <strong>of</strong> gaseous <strong>and</strong> PM emissions. This model includes mechanisms to predict the<br />

formation <strong>of</strong> nitrate PM from NOx emissions. However, it does not currently include any<br />

mechanisms addressing the formation <strong>of</strong> secondary organic PM. EPA is currently<br />

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