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Report to Congressional Requesters: 

June 2005: 

Gasoline Markets: 

Special Gasoline Blends Reduce Emissions and Improve Air Quality, but 
Complicate Supply and Contribute to Higher Prices: 

GAO-05-421: 

GAO Highlights: 

Highlights of GAO-05-421, a report to congressional requesters: 

Why GAO Did This Study: 

The Clean Air Act, as amended, requires some areas with especially poor 
air quality to use a “special gasoline blend” designed to reduce 
emissions of volatile organic compounds (VOC) and nitrogen oxides (NOx) 
and requiring the use of an oxygenate such as ethanol.  In less 
severely polluted areas, the Act allows states, with EPA approval, to 
require the use of other special blends as part of their effort to meet 
air quality standards.  

GAO agreed to answer the following: (1) To what extent are special 
gasoline blends used in the United States and how, if at all, is this 
use expected to change in the future? (2) What effect has the use of 
these blends had on reducing vehicle emissions and improving overall 
air quality? (3) What is the effect of these blends on the gasoline 
supply? (4) How do these blends affect gasoline prices?

What GAO Found: 

Although there is no consensus on the total number of gasoline blends 
used in the United States, GAO found 11 distinct special blends in use 
during the summer of 2004.  Further, when different octane grades and 
other factors are considered, there were at least 45 different kinds of 
gasoline produced in the United States during all of 2004.  The 11 
special blends GAO found are often used in isolated pockets in 
metropolitan areas, while surrounding areas use conventional gasoline.  
The use of special blends may expand because a new federal standard for 
ozone may induce more states to apply to use them.  To date, the 
Environmental Protection Agency (EPA) has generally approved such 
applications and does not have authority to deny an application to use 
a specific special blend as long as that blend meets criteria 
established in the Clean Air Act.  EPA staff told us that there had 
been recent congressional debate regarding EPA’s authority with regard 
to approving special gasoline blends but that the bills had not 
passed.  

EPA models show that use of special gasoline blends reduces vehicle 
emissions by varying degrees.  California’s special blend reduces 
emissions the most—VOCs by 25-29 percent, NOx by 6 percent compared 
with conventional gasoline, while also reducing emissions of toxic 
chemicals.  In contrast, the most common special gasoline blend (used 
largely in the Gulf Coast region) reduces VOCs by 12-16 percent and NOx 
by less than 1 percent compared with conventional gasoline.  The extent 
of reductions remains uncertain, because they rely, at least in part, 
on data regarding how special blends affect emissions from older 
vehicles, and these estimates have not been comprehensively validated 
for newer vehicles and emissions controls.  Regarding air quality, EPA 
and others have concluded that improvements are, in part, attributable 
to the use of special blends.  

The proliferation of special gasoline blends has put stress on the 
gasoline supply system and raised costs, affecting operations at 
refineries, pipelines, and storage terminals.  Once produced, different 
blends must be kept separate throughout shipping and delivery, reducing 
the capacity of pipelines and storage terminal facilities, which were 
originally designed to handle fewer products.  This reduces efficiency 
and raises costs.  In the past, local supply disruptions could be 
addressed quickly by bringing fuel from nearby locations; now however, 
because the use of these fuels are isolated, additional supplies of 
special blends may be hundreds of miles away.

GAO evaluated pretax wholesale gasoline price data for 100 cities and 
generally observed that the highest prices tended to be found in cities 
that use a special gasoline blend that is not widely available in the 
region, or that is significantly more costly to make than other 
blends.  There is general consensus that increased complexity, and 
higher costs associated with supplying special blends, contribute to 
higher gasoline prices either because of more frequent or severe supply 
disruptions or because higher costs are likely passed on at least in 
part to consumers.

What GAO Recommends: 

GAO is making four recommendations to EPA, including: (1) that the 
agency, with the Department of Energy and others, develop a plan to 
balance the environmental benefits of using special fuels with the 
impacts of these fuels on the gasoline supply infrastructure and (2) if 
warranted, that EPA work with other agencies to identify what statutory 
or other changes are required to implement this plan and request those 
authorities from Congress.   EPA declined to comment on the findings 
and recommendations.

www.gao.gov/cgi-bin/getrpt?GAO-05-421.

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact Jim Wells, 202-512-3841 
or wellsj@gao.gov.

[End of section]

Contents: 

Letter: 

Results in Brief: 

Background: 

Special Gasoline Blends Are Widely Used and Use May Increase in the 
Future: 

Special Gasoline Blends Reduce Emissions and Contribute to Improved Air 
Quality: 

Use of Special Gasoline Blends Has Made It More Complicated and Costly 
to Supply Gasoline: 

Areas That Use Uncommon Special Gasoline Blends Tend to Have Higher and 
More Volatile Gasoline Prices: 

Conclusions: 

Recommendation for Executive Action: 

Agency Comments and Our Evaluation: 

Appendixes: 

Appendix I: Scope and Methodology: 

Appendix II: GAO Contact and Staff Acknowledgments: 

Table: 

Table 1: Projected Emissions Reductions Resulting from Low-RVP, RFG, 
and CBG Gasoline Blends: 

Figures: 

Figure 1: Gasoline Supply and Demand, September 2004: 

Figure 2: Map of Key Pipelines and Refineries, 2004: 

Figure 3: Special Gasoline Blends--Summer 2004: 

Figure 4: Market Shares for the Various Gasoline Blends Used in 2001: 

Figure 5: Map of Areas Not Meeting New 8-Hour and Former 1-Hour Ozone 
Standard, 2004: 

Abbreviations: 

AQIRP: Air Quality Improvement Research Program: 

CBG: Cleaner Burning Gasoline: 

CO: carbon monoxide: 

DOE: Department of Energy: 

EIA: Energy Information Administration: 

EPA: Environmental Protection Agency: 

FIP: federal implementation plan: 

MTBE: methyl tertiary-butyl ether: 

NAAQS: National Ambient Air Quality Standards: 

NOx: nitrogen oxides: 

OPIS: Oil Price Information Service: 

RFG: reformulated gasoline: 

RVP: reid vapor pressure: 

SIP: state implementation plan: 

VOCs: volatile organic compounds: 

Abbreviations: 

Letter June 17, 2005: 

The Honorable James Jeffords: 
Ranking Minority Member: 
Committee on Environment and Public Works: 
United States Senate: 

The Honorable Barbara Boxer: 
United States Senate: 

In 2004, consumers in the United States used approximately 140 billion 
gallons of gasoline, an amount equivalent to approximately 10 percent 
of the world's total consumption of petroleum products. Despite 
significant improvements in vehicle emissions and fuel efficiency 
technology, gasoline use remains a major source of harmful pollutants 
such as volatile organic compounds (VOC) and nitrogen oxides (NOx), 
both of which can contribute to formation of ground-level ozone--a 
pollutant linked to a variety of health problems including aggravated 
asthma, reduced lung capacity, and increased susceptibility to 
respiratory illnesses like pneumonia and bronchitis.[Footnote 1] 
Vehicle emissions also contribute to smog and acid rain, which can 
reduce visibility and damage property. The Clean Air Act (the Act), as 
amended, provides a federal and state framework to address air 
pollution and its health consequences. Among other things, the Clean 
Air Act has required improvements in emissions controls on automobiles, 
power plants, and other significant contributors to pollution. Under 
the Act, the federal government establishes air quality standards for 
several pollutants, including ozone and carbon monoxide. States that do 
not meet these standards must develop plans to improve air quality and 
submit those plans to the Environmental Protection Agency (EPA) for 
approval. 

In 1990, the Clean Air Act was amended to require some areas with poor 
air quality to use "special gasoline blends"--blends of gasoline, 
designed to be cleaner burning. Specifically, the Act requires areas 
with the worst air quality to use "reformulated" gasoline, a special 
blend of gasoline designed to reduce emissions of VOCs and NOx. 
Reformulated gasoline also includes additives such as ethanol, which 
reduce emissions of carbon monoxide in some engines--these additives 
are called "oxygenates" because they increase the oxygen content of the 
fuel.[Footnote 2] In less severely polluted areas, the Act gives states 
the option of using reformulated gasoline or seeking EPA approval to 
require the use of other special gasoline blends as part of overall 
efforts to meet federal air quality standards. States applying for EPA 
approval to require the use of a special gasoline blend must 
demonstrate that even with the use of all reasonable and practicable 
options, additional emission reductions are needed to achieve federal 
air quality standards. States also must demonstrate that no other 
measures that would bring about timely attainment exist or that 
existing measures, such as state inspection and maintenance programs, 
are unreasonable or impracticable. Once EPA has determined that these 
criteria are met and has approved a state's application to use a 
special gasoline blend in a given location, that fuel becomes a 
requirement. 

Gasoline is a mixture of multiple components. With the exception of 
ethanol and some other additives, these components are produced from 
crude oil through a set of processes collectively known as refining. 
The types and amounts of components in gasoline can be adjusted for a 
number of reasons, such as improving engine performance or reducing 
emissions. As a general matter, special gasoline blends differ from 
conventional gasoline in at least one of three ways: a reduced tendency 
to evaporate, the addition of an oxygenate, or reduced levels of one or 
more chemicals--such as sulfur. In this report, "conventional gasoline" 
refers to the basic gasoline blend used everywhere that a special 
gasoline blend (e.g., reformulated gasoline, state special blends, 
etc.) is not. 

Whatever the blend, gasoline used in the United States is provided by 
some combination of U.S. refineries and/or imports of gasoline or 
components. Most gasoline produced in the United States is refined in 
one of four major refining areas located along the East Coast, West 
Coast, Gulf Coast, and Midwest. From a refining area or coastal 
terminal, gasoline is shipped through a network of pipelines, water 
barges, or trucks to large storage terminals, which may have tanks 
capable of holding hundreds of millions of gallons of gasoline. From 
there, it is distributed to retail outlets such as local gasoline 
stations by large over-the-road tanker trucks. 

Over the past several years, gasoline prices in parts of the United 
States have on several occasions experienced sudden, significant price 
increases. Some areas with unique gasoline blends, such as California 
and parts of the Midwest, have been especially hard hit. Some experts 
have attributed these price increases, in part, to special gasoline 
blends and have suggested that more uniform national gasoline standards 
could lead to lower or more stable gasoline prices while meeting air 
quality goals. Others, including some state governments, believe that 
special gasoline blends are an important tool that has enabled them to 
meet federal air quality standards at lower cost than other 
alternatives. 

In this context, we agreed to answer the following questions: 

1. To what extent are special gasoline blends used in the United States 
and how, if at all, is this use expected to change in the future?

2. What have EPA and others determined regarding the role of special 
gasoline blends in reducing vehicle emissions and improving overall air 
quality?

3. What is the effect of these blends on the gasoline supply in the 
United States?

4. How do these blends affect gasoline prices?

In answering these questions, we reviewed federal and state analyses of 
gasoline markets and the environmental effects of various special 
gasoline blends; examined the literature on gasoline supplies and 
prices; and analyzed wholesale gasoline price data for 100 cities and 
the national average. We interviewed a wide range of government 
officials and industry experts including federal officials at the EPA 
and the Department of Energy's Energy Information Administration; staff 
at state environmental offices; academic and industry experts; 
petroleum industry officials from companies involved in refining, 
terminal operations, and pipeline operations, as well as from large oil 
companies; and representatives of trade associations. We also conducted 
detailed examinations of markets in California, Louisiana, Texas, and 
New Jersey--states with large refining sectors and experience with 
producing and using special gasoline blends. Because many factors may 
affect gasoline prices at various times, only some of which are readily 
and consistently observable through available data, we agreed to report 
on prices and volatility but not to provide a definitive causal link 
between specific gasoline blends and prices. We conducted our work from 
June 2004 to May 2005 in accordance with generally accepted government 
auditing standards. For a more detailed discussion of the scope and 
methodology of our reiew, see appendix I. 

Results in Brief: 

Although there is no consensus on the total number of special gasoline 
blends used in the United States, we found that, in addition to 
conventional gasoline, at least 11 fundamentally distinct special 
gasoline blends were used during the summer of 2004 in parts of 34 
states and covering approximately one-sixth of all the counties in the 
United States. In the summer of 2001--the last year for which we had 
data--special gasoline blends accounted for slightly more than half of 
the total gasoline volume consumed in the United States, with the rest 
accounted for by conventional gasoline. When different octane grades 
and other factors are considered, there were at least 45 different 
blends of gasoline produced and handled by pipelines in the United 
States during the entirety of 2004. Special gasoline blends are often 
used in isolated pockets because these blends have generally been 
adopted in large metropolitan areas in response to severe air quality 
problems, while surrounding areas have generally continued to use 
conventional gasoline. Further, EPA's approvals of individual states' 
applications to adopt special gasoline blends have been made 
independently over time without consideration of the other fuels 
already in use in the region. For example, East St. Louis, Illinois, 
and St. Louis, Missouri (two cities in the same metropolitan area, 
which straddles two states and two EPA regions) separately applied to 
EPA and received approval for different gasoline blends. The use of 
special gasoline blends may continue to expand given that EPA recently 
finalized a more stringent federal standard for ozone and, as a result, 
another 138 counties across the United States are now out of compliance 
with the national air quality standard. To meet the new standard, it is 
likely that many more locations will apply to use special gasoline 
blends. To date, EPA has generally approved such applications and does 
not have authority to deny an application to use a specific special 
gasoline blend as long as that blend meets the environmental criteria 
established in the 1990 amendments to the Clean Air Act. EPA staff told 
us that there had been congressional debate regarding EPA's authority 
during consideration of recent energy legislation, but that its 
authority had not changed as of May 2005. 

Use of these special gasoline blends reduces vehicle emissions by 
varying degrees. California's special gasoline blend--the fuel 
formulated to reduce emissions the most--offers the greatest 
reductions. Specifically, EPA models how different gasoline blends 
affect emissions and estimates that California's blend reduces VOCs by 
25-29 percent and NOx by about 6 percent compared with conventional 
gasoline, while also reducing emissions of toxic chemicals and other 
substances. In contrast, the most commonly used special gasoline blend-
-one of the least stringent blends and used primarily in the Gulf Coast 
region--is estimated to reduce VOCs by about 12-16 percent and NOx by 
less than 1 percent compared with conventional gasoline. The extent of 
reductions remains unclear, however, because these estimates are based, 
in part, on data regarding how special gasoline blends affect emissions 
from older vehicles, and these data have not been comprehensively 
validated through testing on current vehicle types with newer emissions 
controls. In the case of oxygenates, there appears to be agreement that 
the addition of oxygenates reduces emissions from older vehicles. 
However, improvements in automobile technology in newer vehicles now 
automatically reduce emissions of carbon monoxide and other pollutants 
and, for these vehicles, may have negated many of the benefits of 
adding oxygenates to gasoline. Some studies have also found that use of 
ethanol can increase emissions of pollutants that can increase ozone 
levels. Regarding air quality, EPA and other experts have concluded 
that improvements in air quality seen in some parts of the country are 
at least partly attributable to the use of special gasoline blends. 
However, studies on the impact of individual emissions reduction 
efforts--such as special gasoline blends--are limited and incomplete, 
in part because of difficulty isolating the effect of gasoline blends 
from other factors that affect air quality such as weather and 
emissions from other sources. 

The proliferation of special gasoline blends has made it more 
complicated to supply gasoline and has raised costs, significantly 
affecting operations at refineries, pipelines, and storage terminals. 
At refineries, making these blends can require additional investment 
such as installing new processing equipment and the use of larger 
amounts of valuable components in the blending process--making it more 
costly to produce special gasoline blends. Once produced, different 
blends of gasoline must be kept separate throughout the shipping and 
delivery process, and the increased number of gasoline blends has 
reduced the capacity of pipelines and storage terminal facilities, 
which were originally designed to handle fewer products. For example, 
several pipeline companies reported that the capacity of their systems 
has been reduced because they have had to slow the speed of products 
through the pipelines in order to off-load special blends at specific 
locations, which raises the average cost of shipping gasoline. 
Similarly, storage terminals have not been able to fully utilize the 
volume of their storage tanks because the tanks were designed to handle 
fewer types of fuel and are often larger in size and fewer in number 
than necessary for handling smaller batches of special gasoline blends. 
Further, the proliferation of special blends has, according to several 
buyers from these wholesale markets, limited the number of suppliers of 
some of these fuels, posing challenges when traditional supplies are 
disrupted, such as during a refinery outage or pipeline delay. In the 
past, local supply disruptions could be addressed relatively quickly by 
bringing fuel from nearby locations; now, however, additional supplies 
of special gasoline blends may be hundreds of miles away. 

We evaluated pretax, wholesale gasoline price data for 100 cities and 
generally observed that the highest prices tended to be found in cities 
that use a special gasoline blend that is not widely available in the 
region or that costs significantly more to make than other blends. We 
also found high prices in cities that are far away from major refining 
areas or other sources of gasoline. For example, of the 100 cities we 
examined, most of the 20 cities with the highest prices used special 
blends of gasoline. The other cities with the highest prices used 
conventional gasoline year-round, but these are long distances from 
major refining centers or are located on or near a single smaller 
pipeline. For the period, December 2000 through October 2004, average 
prices in the 20 highest-price cities were between 14 and 41 cents per 
gallon higher than in the city with the lowest price. Further, 5 of the 
10 cities with the highest average prices were in California, which 
uses a unique gasoline that only a few refiners outside of the state 
make and is expensive to refine. In contrast, the lowest prices were 
typically found in cities that are close to major refining centers or 
that used gasoline widely available in their region. For example, among 
the 20 cities with the lowest prices, 8 used conventional gasoline--the 
most widely available gasoline blend--and 9 used 7.8 reid vapor 
pressure (RVP) gasoline--the most widely used special blend, largely 
used in areas close to the Gulf Coast refining center. The other three 
cities with the lowest prices--Houston, Birmingham, and Atlanta--used 
less common special blends but are all close to the largest refining 
area, the Gulf Coast and, therefore, have many more potential supply 
options than more isolated cities do. In addition, we found that prices 
tended to be more volatile in cities that used special gasoline blends. 
Specifically, 18 of the 20 cities with the most volatile prices used 
special blends of gasoline, while 17 of 20 cities with the lowest 
volatility used either conventional or 7.8 RVP gasoline. 

While prices for special blends tend to be higher than for conventional 
gasoline, available data did not allow us to attempt to isolate the 
effects of specific special gasoline blends on gasoline prices or to 
definitively establish a causal link between specific special blends 
and price volatility. Specifically, we did not have sufficient data to 
control for all other potential contributing factors--such as the 
distance from cities to the sources of gasoline supply, or specific 
features of these cities that might influence prices regardless of the 
blend of gasoline used. However, there is a general consensus among the 
studies we reviewed and the experts we spoke with that the increased 
complexity, and higher refining, transportation, and storage costs 
associated with supplying special gasoline blends, have contributed to 
higher gasoline prices overall and for specific special blends either 
because of more frequent or severe supply disruptions or because higher 
costs are likely passed on at least in part to consumers. Moreover, our 
findings are generally consistent with results of government, academic, 
and private studies, which found that the gasoline supply system is 
increasingly stressed and also found isolated pockets of higher and/or 
more volatile prices in cities that use special gasoline blends that 
are not widely used. 

To provide better information about the emissions and air quality 
impacts of using special gasoline blends, we recommend that the EPA 
Administrator direct the agency to comprehensively study how special 
gasoline blends affect the emissions from the vehicles that comprise 
today's fleet and use the results of this work to make appropriate 
modifications to the models that states use to estimate the emissions 
and air quality benefits of using them. In order to identify how to 
balance the environmental benefits of using special gasoline blends 
with the impacts that the use of these fuels have on the supply 
infrastructure and prices, we are recommending that EPA work with the 
states, the Department of Energy, and other stakeholders to develop a 
plan to balance these factors. If warranted by the results of this 
study, we are further recommending that EPA work with the Department of 
Energy and others to identify what statutory and other changes are 
required to achieve this balance and report these to Congress and to 
request that Congress provide the needed authority to the appropriate 
federal agency or agencies. 

We provided a copy of our draft report to EPA for comment. The agency 
did not comment on our findings or recommendations but did provide 
technical comments that we have adopted, as appropriate. 

Background: 

The Clean Air Act, as amended, provides the basic statutory framework 
for the role of the federal government and the states in managing air 
quality in the United States. Among other things, the Act authorizes 
EPA to set and enforce standards, referred to as National Ambient Air 
Quality Standards (NAAQS), for pollutants. EPA has subsequently set 
standards for six pollutants--ozone, particulate matter, carbon 
monoxide, nitrogen dioxide, sulfur dioxide, and lead. While carbon 
monoxide is directly emitted when various fuels are burned, ground- 
level ozone is formed when VOCs and NOx mix in the presence of heat and 
sunlight. As a result, emissions of VOCs and NOx are considered by EPA 
and the states in their efforts to reduce concentrations of ground- 
level ozone. Because heat and sunlight act as catalysts in the 
formation of ground-level ozone, high ozone levels are most prevalent 
in spring and summer. 

EPA sets and enforces the NAAQS to, among other things, reduce the 
negative health effects of air pollution. Each of the six pollutants 
covered by the NAAQS is known to cause a variety of adverse health and 
other consequences. For example, at certain concentrations ground-level 
ozone and carbon monoxide can, among other things, cause lung damage, 
eye irritation, asthma attacks, chest pain, nausea, headaches, and 
premature death. To enforce the standards, EPA evaluates monitoring 
data on air quality to determine whether local air quality meets 
federal standards--designating areas as in either attainment (if they 
meet the federal standards) or nonattainment (if they do not meet the 
federal standards) with each of the NAAQS.[Footnote 3]

Under the Act, states that contain areas in nonattainment with the 
NAAQS are required to identify how they will reduce emissions and 
improve air quality to meet them. For each pollutant, states are 
required to prepare a state implementation plan (SIP) and have the plan 
approved by EPA.[Footnote 4] States have choices in determining how to 
reduce emissions and meet air quality standards, determining, among 
other things, how much to reduce emissions from mobile sources such as 
automobiles compared with other sources of similar emissions such as 
power plants. Because use of gasoline in automobiles emits several 
chemicals, including carbon monoxide, nitrogen oxides, and VOCs, and 
because emissions from automobiles are often an important contributor 
to local air quality problems, the federal government and the states 
often focus on reducing automobile emissions. Whatever the planned 
reductions, states must identify an inventory of air emissions and 
demonstrate in their SIPs how they will achieve attainment in a 
specific time frame. States typically demonstrate this through modeling 
analysis that estimates how the various efforts in their SIPs will 
reduce emissions and improve air quality. 

The Act also provides authority to set standards and establish 
requirements for some programs specifically designed to reduce vehicle 
emissions. For example, using authority provided under the Act, EPA has 
required newer cars to meet more stringent emissions standards, and 
vehicle manufacturers have incorporated emissions-control devices such 
as catalytic converters and oxygen sensors to meet them. Further, the 
Act requires cars to have under-the-hood systems and dashboard warning 
lights that check whether emissions control devices are working 
properly. In addition, the Act requires that some areas--generally 
highly populated metropolitan areas--have programs for periodic 
inspection and maintenance of vehicles. These programs identify high- 
emitting vehicles, which sometimes have malfunctioning emissions 
control devices, and require vehicle owners to make repairs before the 
vehicles can be registered. 

Federal and State Actions Regulate Gasoline: 

The Act gives the federal government, through the EPA, primary 
authority for regulating the environmental impacts of gasoline 
use.[Footnote 5] For example, the Act sets minimum national standards 
for conventional gasoline, as well as requiring that certain gasoline 
blends formulated to reduce emissions be used in some areas with 
especially poor air quality. Specifically, for certain areas with long- 
standing and especially poor air quality, the federal government 
requires the use of special reformulated gasoline, commonly referred to 
as RFG. The amendments also require other areas to use special gasoline 
blends designed to reduce summertime ozone pollution and wintertime 
carbon monoxide pollution. 

The Act allows states or regions not required to use RFG to seek EPA 
approval to require use of other special gasoline blends to aid in 
improving air quality, provided that they do not violate minimum 
federal standards. In 2001, EPA studied the proliferation of gasoline 
blends and reported that several states had chosen special blends other 
than RFG for one or more of three reasons: (1) the states were not 
eligible to require RFG because their air quality was not bad enough, 
(2) the states wanted to avoid the RFG requirement to use an oxygenate 
and its added cost, (3) fuel suppliers and states believed that the 
other special blend would be less costly than RFG while meeting their 
need to reduce emissions. States seeking to use a special gasoline 
blend must obtain formal approval from EPA, generally the regional 
office with authority to review their SIPs. Specifically, under the 
Clean Air Act, section 211(c)(4)(C), EPA may approve applications by 
states to use special gasoline blends if the states demonstrate that 
the fuel is needed to reach attainment with federal air quality 
standards. 

In guidance issued in August 1997--after several of the special 
gasoline blends were approved--EPA clarified that they can approve a 
state gasoline requirement only if "no other measures that would bring 
about timely attainment exist," or if other measures are "unreasonable 
or impracticable." The guidance requires that states do four things in 
their application for approval of a new or revised SIP: (1) quantify 
the estimated emissions reductions required to reach attainment with 
the federal NAAQS for ozone; (2) identify possible control measures 
that could be used in place of special gasoline blends and provide 
emissions reduction estimates for those measures; (3) explain why those 
measures are "unreasonable or impracticable"; and (4) show that, even 
with use of all "reasonable and practicable" measures, additional 
emissions reductions are needed. As is the case with other new or 
revised SIPs, these applications are open for public comment, and EPA 
must consider those comments before making a decision. Once approved, 
states' special gasoline blends become federally enforceable 
requirements. 

Under some circumstances, EPA may temporarily waive special gasoline 
blend requirements, referred to as granting enforcement discretion, if, 
for example, the required special gasoline blend is not available due 
to a supply disruption. Over the past several years, EPA has waived the 
requirement to use these special gasoline blends on several occasions 
when it determined that overall supplies might become tight. We found 
that EPA has granted enforcement discretion on at least 23 occasions, 
allowing gasoline that did not comply with local requirements to be 
sold there. The causes of these supply disruptions included the 2003 
blackout in the Northeast, the series of hurricanes in Florida and the 
Gulf Coast in 2004, as well as refinery fires, pipeline breaks, and 
other infrastructure problems. Although there was one short waiver that 
applied nationwide following the terrorist attacks of September 11, 
2001, several of the other waivers were provided to local areas with 
particularly stringent gasoline formulations including St. Louis, 
Chicago/Milwaukee, Atlanta, Las Vegas, and Phoenix when there were 
supply shortages in these areas. 

All Gasoline Is a Blended Mix of Components Derived Primarily from 
Crude Oil: 

All gasoline is a blend of different components that are predominantly 
produced in refineries. The simplest refineries primarily separate the 
components already present in crude oil. More complex refineries also 
have the ability to chemically change less valuable components of crude 
oil into more valuable ones. Because of their ability to chemically 
alter components, complex refineries can increase the amount of 
gasoline yielded from a given amount of crude oil and reduce the amount 
of less valuable products. Although most refineries can process many 
types of crude oil, refineries are generally configured to run most 
efficiently when refining a specific type of crude oil into a specific 
group of products. 

Absent specific regulatory requirements, refiners blend several 
components derived from crude oil to produce a gasoline that achieves 
acceptable engine performance at the lowest cost. Two key aspects of 
gasoline affect engine performance: 

* Reid vapor pressure is a measure of gasoline's tendency to evaporate 
and also reflects the ease with which it ignites when the spark plug 
fires in a cold engine. To maintain engine performance, RVP must vary 
by season and region. Higher RVP is required in colder climates and 
seasons to allow an engine to start. 

* Octane number is a measurement of gasoline's tendency to ignite 
without a spark, commonly known as "knocking" in a running engine. Some 
high-performance and other vehicles require gasoline with a higher 
octane number. To satisfy these requirements and consumer demand, 
retailers in the United States typically sell three different octane 
grades of gasoline. 

Special gasoline blends developed to reduce pollution are generally 
adjusted in at least one of the following ways: 

* RVP is reduced during the summertime to reduce VOC emissions. 
Reducing the RVP of gasoline requires reducing the amount of very light 
compounds, such as butanes and pentanes, blended into the gasoline. 

* Toxics, their precursors, or other chemicals are limited so they are 
not released into the air when the gasoline is burned. Some of these, 
such as sulfur, naturally occur in crude oil while others, such as 
benzene, result from gasoline refining. 

* Oxygenates, chemical compounds containing oxygen to aide in 
combustion, are added to gasoline to improve environmental performance 
when the gasoline is burned, including reducing carbon monoxide (CO) 
emissions. The most commonly used oxygenates are MTBE and ethanol. 
Several states have banned MTBE as a result of concerns about 
groundwater pollution and have switched to using ethanol as an 
oxygenate where required. 

Gasoline Is Moved from Refineries to Consumers through a Complex, 
Shared Distribution System: 

Gasoline is shipped from U.S. refineries to consumers by some 
combination of pipelines, water barges, rail, and trucks to retail 
gasoline stations. Most of the country's refining capacity is located 
in the Gulf Coast, West Coast, East Coast, or Midwest with only a small 
amount in the Rocky Mountain states. As shown in figure 1, the Gulf 
Coast region supplies gasoline to all the other regions--of these, the 
Midwest and the East Coast are the most dependent on gasoline from the 
Gulf Coast. The East and West Coast markets have also imported gasoline 
from other parts of the world such as Canada, Europe, and the 
Caribbean. 

Figure 1: Gasoline Supply and Demand, September 2004: 

[See PDF for image] 

[End of figure] 

Several large pipelines travel inland from refineries in the Gulf 
Coast, East Coast, and West Coast, connecting these key supply centers 
to areas where gasoline is used. In general, these large pipelines 
provide the cheapest method for transporting large volumes of gasoline, 
and pipelines account for more than half of the gasoline shipments in 
the United States. Several of the major U.S. pipeline systems, such as 
the ones serving the Midwest and the East Coast, deliver gasoline and 
other fuels used in multiple states. Figure 2 shows the pipeline system 
and the major refineries in the continental United States. The largest 
concentration of pipeline capacity links the Gulf Coast refining region 
to the large consumer markets in the Midwest and East Coast, while 
fewer and smaller pipelines connect refining regions to the more 
sparsely populated states in the Rockies and parts of the West Coast 
region. 

Figure 2: Map of Key Pipelines and Refineries, 2004: 

[See PDF for image] 

[End of figure] 

At various points between refining and final retail consumption, 
gasoline is stored in large tanks, some holding hundreds of millions of 
gallons of fuel. In many cases, gasoline is stored in tanks at the 
refinery itself while awaiting shipping. In other cases, fuel is stored 
at terminal stations located along the pipeline that generally include 
multiple large tanks. A terminal station serves as a storage facility 
for gasoline and other petroleum products at places throughout the 
petroleum refining and transportation process. Some terminals are 
affiliated with pipelines and used as part of pipeline operations, such 
as for withdrawals or when pipelines converge. Other terminals are used 
to allow gasoline and other products to be loaded or off-loaded from 
barges or tankers. Still other terminals are used to hold gasoline 
before it is distributed, generally by trucks, to retail gasoline 
stations. In all of these locations, different gasoline blends must be 
stored separately, with only one fuel per tank at any given time. 

Ethanol that is added to gasoline cannot be shipped in pipelines with 
other petroleum products because of ethanol's tendency to absorb water. 
Instead, ethanol is shipped primarily by rail or trucks to terminal 
stations where it is "splash" blended--mixed in specific proportions as 
the fuel is added to the storage tank or tanker truck. The federal 
government and some states have considered requiring or expanding the 
use of ethanol to reduce consumption of oil and increase demand for 
agricultural products used to produce it, such as corn. 

Special Gasoline Blends Are Widely Used and Use May Increase in the 
Future: 

There were 12 distinct gasoline blends in use in the United States 
during the summer of 2004: 11 special gasoline blends and the 
conventional gasoline used everywhere a special blend is not used. When 
different grades of gasoline, special blends used in winter, and other 
factors are considered, the number of gasoline blends rises to at least 
45. New ozone standards and other factors may further increase the 
number or the use of special gasoline blends in the future, in part 
because EPA must approve any state's application to require use of a 
special gasoline blend as long as the proposed fuel meets EPA's 
environmental standards. 

Eleven Special Summer Gasoline Blends Were Used Mostly in Large Cities 
Creating Isolated Markets: 

Eleven special gasoline blends were used in the United States during 
the summer of 2004 in addition to conventional gasoline. The use of 
special gasoline blends is most prominent during the summer because 
special fuels are used predominantly to reduce summer ozone levels, and 
gasoline use is generally the highest during the summer. The 
requirement to use these fuels requires that all the fuel sold at 
terminals meet certain specifications at a certain date, which 
generally requires terminal operators to draw down their inventory of 
non-summer fuels in advance of filling their tanks with summer fuels. 
Special gasoline blends are primarily used in highly populated urban 
areas, and 34 states use a special gasoline blend in one or more areas. 
The 11 special gasoline blends in use during the summer of 2004 fell 
into the following categories: 

* Three different types of RFG used year-round, the federally required 
fuel used in areas with the worst air quality. RFG has very low RVP; 
reduced levels of benzene and other toxics; and contains an oxygenate. 
The type of RFG blend depends on the area of the country where the 
gasoline is used and the oxygenate selected. These blends are 
identified in figure 3 as "RFG North," "RFG North with ethanol," and 
"RFG South."

* Two types of California Cleaner Burning Gasoline (CBG) used year- 
round, also referred to as CARB. California CBG is formulated to meet 
the most stringent gasoline standard in the United States, including 
very low RVP and reduced levels of sulfur, benzene, and other 
chemicals. In general, the state of California does not require the 
addition of an oxygenate in areas not subject to federal RFG standards-
-identified in figure 3 as "CA CBG." Gasoline sold in areas also 
subject to the federal RFG standard must contain an oxygenate, 
identified as "RFG/CA CBG."

* In the summer, Arizona allows the use of either a gasoline blend very 
similar to RFG or a blend similar to CBG. The blend required in Arizona 
is identified as "AZ CBG."

* Three summer blends with various reductions in RVP. The federal 
government requires some areas to use 7.8 RVP gasoline[Footnote 6] and, 
in other areas, states have mandated the use of this blend. The other 
two low-RVP blends are state requirements. These blends are identified 
in figure 3 as "7.8 RVP," "7.2 RVP," and "7.0 RVP."

* One blend with reduced RVP and reduced sulfur content. The state of 
Georgia requires this blend for use in the Atlanta area, and it is 
identified in figure 3 as "7.0 RVP, 30 ppm sulfur."

* One blend of conventional gasoline with a minimum of 10 percent 
ethanol by volume, used year-round. The state of Minnesota requires 
this blend, which is identified in figure 3 as "Ethanol Mandate."

As figure 3 shows, many areas using special gasoline blends are 
surrounded by regions that use conventional gasoline. In some cases, 
these areas are relatively large, as is the case for the state of 
California, where nearly all of the state uses the same fuel--RFG/CA 
CBG. In other cases, "islands" of special gasoline use can divide 
otherwise regional gasoline markets. For example, the St. Louis 
metropolitan area, which includes parts of two states[Footnote 7]-- 
Missouri and Illinois--uses three different fuels: one special gasoline 
blend required on the Missouri side, a different special gasoline blend 
required on the Illinois side, and conventional gasoline is allowed in 
the surrounding area. In some cases, special gasoline blends are used 
in only one area of the country. For example, California CBG, Arizona 
CBG, and the special blend used in Atlanta, Georgia, are not used 
anywhere else in the United States. Even relatively common special 
gasoline blends can create isolated markets if they are not used in 
nearby areas. For example, although 7.8 RVP is a relatively widely used 
blend, Pittsburgh, Pennsylvania, is the only city in its region that 
uses it. Similarly, the Chicago/Milwaukee area uses RFG North with 
ethanol, a gasoline blend used in the Northeast but not used elsewhere 
in the Midwest. 

Figure 3: Special Gasoline Blends--Summer 2004: 

[See PDF for image] 

Note: Unshaded areas (shown in white) are areas where conventional 
gasoline is used. 

[End of figure] 

Special gasoline blends accounted for more than half the gasoline 
consumed in the United States during the summer of 2001--the last year 
for which we had complete data. Figure 4 shows the relative consumption 
of the different gasoline blends then in use. Of the special fuel 
blends, RFG and 7.8 RVP blends together accounted for about 33 percent 
of the national gasoline market. California CBG and Arizona gasoline 
blends accounted for roughly 13 percent of total U.S. gasoline 
consumption. The remaining 6 percent of gasoline use was divided among 
four separate blends. 

Figure 4: Market Shares for the Various Gasoline Blends Used in 2001: 

[See PDF for image] --graphic text: 

Pie chart with eight items. 

Conventional: 48%; 
7.8 RVP: 13%; 
RFG Blends: 21%: 
* RFG North w/ ethanol: (3%); 
* RFG North (8%); 
* RFG South (10%); 
California gasoline: 13%: 
* AZ CBG (3%); 
* CA CBG (3%); 
* RFG/CA CBG (7%); 
7.0 RVP, 30 ppm sulfur: 2%; 
Ethanol mandate: 2%; 
7.2 RVP: 1%; 
7.0 RVP: 1%. 

Source: GAO analysis of EPA data. 

[End of figure]

Other Factors Raise the Number of Gasoline Blends Carried by Pipelines 
and Other Means to at Least 45: 

While we have reported that there are 11 special blends used or handled 
during the summer of 2004, additional factors increase the total number 
of gasoline blends sold in the United States throughout the year to at 
least 45. First, although this report focuses on summer gasoline 
blends, at least 3 special winter-only gasoline blends are required to 
be used in areas of eight states. Use of these fuels requires that fuel 
terminals in these areas transition from the fuel that they use in the 
non-winter season to the required winter fuel. These blends contain an 
oxygenate to address winter carbon monoxide pollution. Second, because 
of consumer demand, many gasoline stations sell gasoline in three 
octane grades--both premium and regular grades are refined and shipped 
to terminals, where they are blended together to make a midgrade 
gasoline. Therefore, each gasoline blend is effectively two fuels from 
the perspective of pipelines and terminals. As a result, pipelines, 
fuel terminals, and retail gasoline stations carry multiple variations 
of the gasoline blends previously discussed. Third, gasoline blends 
differ regionally and seasonally because differences in outside 
temperatures require different blends to maintain vehicle performance. 
The primary difference among these blends is RVP. Refiners produce 
gasoline with higher RVP in cold conditions to allow cars to start and 
gasoline with lower RVP during warm conditions to improve vehicle 
operation, even in areas that use conventional gasoline. As a result of 
these differences, refiners routinely ship different fuels to different 
regions and also ship different gasoline blends seasonally, but special 
blends tend to compound these variations. One official with a major 
petroleum company reported that there were at least 45 different grades 
of gasoline used in the United States. 

New Ozone Standard and Other Factors May Further Increase the Number 
and/or Use of Special Gasoline Blends: 

A new ozone standard and deteriorating air quality may lead to an 
increased number of special gasoline blends and/or more use of these 
blends in the future. In 2004, EPA issued a final rule implementing a 
new, more stringent federal air quality standard for ozone that led to 
the identification of 138 additional counties in nonattainment or 
maintenance as seen in figure 5.[Footnote 8] EPA officials that we 
spoke with did not have any indications that states were planning to 
submit applications to use special blends in these areas but 
acknowledged that gasoline is viewed as an effective emissions control 
strategy and said that they expect some states to consider doing so. 
Oil company officials told us that officials from some states had 
approached them to discuss using special gasoline blends. Because 
states must begin preparing SIPs for the recently designated 
nonattainment areas, and because several of those states already have 
chosen to use special gasoline blends, it appears likely that states 
may seek approval to use such blends in more areas. 

Figure 5: Map of Areas Not Meeting New 8-Hour and Former 1-Hour Ozone 
Standard, 2004: 

[See PDF for image] 

[End of figure] 

Several other factors could also affect the number or use of special 
gasoline blends. State MTBE bans could force more areas of the country 
to shift from their current blend to an ethanol blend. In June 2004, 
EPA identified 19 states that had bans on the use of MTBE either in 
place or scheduled to phase in, though some of these states did not use 
MTBE.[Footnote 9] Worsening air quality in areas such as Atlanta and 
Baton Rouge may require the gasoline used in these cities to shift from 
a special blend to RFG, reducing the number of fuels.[Footnote 10] In 
addition, a new federal standard for all gasoline--including special 
blends--that mandates reduced sulfur, promises to improve the 
effectiveness of catalytic converters already present in most vehicles 
and could aid some areas in meeting federal air quality standards, 
potentially reducing the need for these fuels in some areas. 

EPA Lacks Authority to Deny Requests to Use Special Gasoline Blends Due 
to Effects on Supply: 

During the course of our work, staff from EPA's Office of the General 
Counsel stated that EPA could not deny an application to require the 
use of a special gasoline blend that addressed the four elements 
outlined in EPA's 1997 guidance. They explained that EPA's 
determinations often deferred to states' evaluations in their 
applications that, under the Clean Air Act, section 211 (c)(4)(C), no 
other measures that would bring about timely attainment exist, or that 
existing measures, such as vehicle inspection and maintenance programs, 
are unreasonable or impracticable. Further, staff with EPA's Office of 
the General Counsel staff told us EPA could not reject an application 
on the basis of the potential impacts on gasoline supply or other 
regional effects on the gasoline market because such a rejection would 
be outside of EPA's current authority. Several of the special fuels in 
use during 2004 were approved prior to the issuance of the 1997 
guidance, and EPA officials reported that a variety of standards were 
used to evaluate applications. 

EPA's most recent effort to examine special gasoline blends is 
consistent with EPA's view that the agency does not have authority to 
reject a state's application based on regional supply impacts or costs. 
In 2001, EPA released a staff white paper, in response to a 
presidential directive, examining whether there were options to 
maintain or improve environmental benefits while also improving the 
supply of fuels, such as gasoline.[Footnote 11] In that report, EPA 
examined a number of options to reduce the number of fuels available 
for states to choose from--similar to a gasoline menu. That report 
concluded that these options were beyond EPA's statutory authority and 
would require legislative action to implement.[Footnote 12] The white 
paper also noted that it represented a first step in EPA's response to 
the directive, but that significant additional analysis and study were 
required. EPA staff told us that there had been congressional debate 
regarding EPA's authority during consideration of recent energy 
legislation, but that its authority had not changed as of May 
2005.[Footnote 13] In the study, EPA identified a number of changes 
that it would make to ease the seasonal transition between gasoline 
blends used during different parts of the year. Staff also said that 
little, if any, additional work had been done since the 2001 study, in 
part because of EPA's lack of authority to implement some of the 
actions outlined in the study. 

Special Gasoline Blends Reduce Emissions and Contribute to Improved Air 
Quality: 

Special gasoline blends reduce emissions--particularly those involved 
in the formation of harmful ground-level ozone--by varying degrees, 
depending on the blend. The extent of reductions remains unclear, 
however, because the estimates have not been comprehensively validated 
through testing on current vehicles and emissions controls. According 
to EPA and others, these special gasoline blends have contributed to 
improvements in air quality seen in some parts of the country. The 
extent of their contribution to improvements relative to that of other 
contributing factors, such as reductions in power plant emissions, is 
somewhat uncertain because of the difficulties in isolating the effects 
of individual emissions reduction efforts, such as special gasoline 
blends, from other factors that may affect air quality. 

Special Gasoline Blends Reduce Emissions, but the Extent of Reduction 
Remains Uncertain: 

Over the past 15 years, a wide range of studies by EPA and others have 
concluded that changes to the properties of gasoline can substantially 
reduce emissions from automobiles. For example, in 1996, EPA concluded 
that RFG and low-RVP blends can both significantly reduce VOCs but that 
RFG offers greater promise in reducing NOx, CO, and toxics. The Air 
Quality Improvement Research Program (AQIRP), funded by the auto and 
oil industries, analyzed gasoline properties in detail and 
comprehensively tested a variety of gasoline blends in a range of 
vehicles between 1989 and 1992. This effort produced data regarding how 
the use of various gasoline blends affect emissions from then-current 
vehicles and concluded that changing certain properties of gasoline, in 
particular reducing RVP and sulfur, was effective in reducing emissions 
of pollutants such as NOx, CO, and also hydrocarbons such as unburned 
fuel. According to EPA officials, using special gasoline blends is 
attractive to states because the blends can offer immediate emissions 
reductions from vehicles already on the road. 

EPA and others have used the results of these studies to develop models 
that provide detailed emissions estimates for several of the special 
gasoline blends currently in use. These models have been used by states 
in their SIPs to estimate the expected emissions from requiring the use 
of special gasoline blends instead of conventional gasoline.[Footnote 
14] As shown in table 1, the models estimate that special gasoline 
blends reduce emissions by varying degrees. California's gasoline--the 
blend formulated to reduce emissions the most--is estimated to provide 
the greatest level of emissions reductions, about 25-29 percent for 
VOCs and about 5.7 percent for NOx. RFG is estimated to provide about 
the same level of VOC reduction, a lower NOx reduction of about 0.7 
percent, but also a 10-20 percent reduction in CO. The special gasoline 
blend most commonly used in areas not using conventional gasoline-- 
gasoline with an RVP of 7.8--is estimated to reduce VOC emissions by 12-
16 percent and NOx by about 0.7 percent. In addition to the pollutants 
listed in table 1, RFG and California's cleaner burning gasoline also 
reduces emissions of some toxics such as benzene. 

Table 1: Projected Emissions Reductions Resulting from Low-RVP, RFG, 
and CBG Gasoline Blends: 

Gasoline blend: Low RVP: 7.8; 
Estimated emissions reductions[A]: VOC: 12 to 16%; 
Estimated emissions reductions[A]: NOx: 0.7%; 
Estimated emissions reductions[A]: CO: No effect. 

Gasoline blend: Low RVP: 7.2; 
Estimated emissions reductions[A]: VOC: 19 to 23%; 
Estimated emissions reductions[A]: NOx: 0.7%; 
Estimated emissions reductions[A]: CO: No effect. 

Gasoline blend: Low RVP: 7.0; 
Estimated emissions reductions[A]: VOC: 21 to 25%; 
Estimated emissions reductions[A]: NOx: 0.7%; 
Estimated emissions reductions[A]: CO: No effect. 

Gasoline blend: RFG: Federal RFG; 
Estimated emissions reductions[A]: VOC: 25 to 29%; 
Estimated emissions reductions[A]: NOx: 0.7%; 
Estimated emissions reductions[A]: CO: 10 to 20%. 

Gasoline blend: RFG: California CBG[B]; 
Estimated emissions reductions[A]: VOC: 25 to 29%; 
Estimated emissions reductions[A]: NOx: 5.7%; 
Estimated emissions reductions[A]: CO: Not estimated. 

Source: GAO analysis of EPA data. 

[A] Emissions reductions are based on reductions from conventional 9.0 
RVP gasoline projected to be in use in calendar year 2006. 

[B] EPA estimated VOC and NOx emissions reductions for California CBG 
and RFG CA/CBG (which includes an oxygenate) were the same for these 
pollutants; however, RFG CA/CBG would likely provide some reduction of 
CO, in addition. 

[End of table]

However, the extent of emissions reductions associated with various 
gasoline blends remains somewhat uncertain. GAO,[Footnote 15] the 
National Research Council, and others have identified concerns about 
the overall accuracy of emissions estimates. EPA has addressed some of 
the concerns about emissions estimates. In one effort to address 
concerns about the validity of emissions estimates, EPA sponsored a 
study that compared emissions estimates to measured emission data 
obtained between 1992 and 2001. The study looked at pollutant 
concentration data from tunnels and vehicle exhaust data collected from 
vehicles on roadways using special remote sensing devices at a limited 
number of sites using a limited range of gasoline blends. As a result, 
EPA found that the observed emissions data conflicted with emissions 
estimates; in some cases the testing data were higher than predicted, 
while in other cases it was lower. 

Despite this effort, EPA has not comprehensively studied how various 
gasoline blends affect vehicle emissions since the early 1990s--when 
the AQIRP comprehensively tested a variety of gasoline blends in a 
range of vehicles. Since then, there have been advances in emissions 
control technology. Consequently, to the extent that emissions from 
vehicles with newer emissions control technology differ from those of 
older vehicles, emission estimates may become less certain, especially 
as vehicles with the newer technology compose a growing portion of the 
U.S. fleet. EPA officials acknowledge that their efforts since the 
early 1990s to validate emissions estimates have not allowed them to 
fully validate how special fuel blends operate in a full range of 
vehicles of varying vintages and designs over their operating 
lifetimes. EPA officials told us that they believe such a detailed 
analysis would improve their understanding of how special gasoline 
blends affect emissions, but said that they have not had sufficient 
budgetary resources to collect the needed data to support such an 
analysis. 

In addition to these broad concerns, there is also controversy over the 
emissions benefits associated with special blends containing 
oxygenates, which were initially added to gasoline to reduce the 
emissions of carbon monoxide and other pollutants. However, although 
there appears to be agreement that oxygenated fuels help reduce 
emissions of CO from older vehicles, recent studies indicate that the 
emissions benefits for newer vehicles are questionable. For example, 
AQIRP, the National Science and Technology Council, and others have 
reported that improvements in emissions controls on newer vehicles, 
such as oxygen sensors and computer-controlled emissions systems, may 
now automatically reduce emissions of CO and other pollutants and may 
negate many benefits of adding oxygenates. Further, some experts have 
concluded that adding oxygenates to gasoline may increase emissions of 
NOx and VOCs and may contribute to increased levels of ozone. As a 
result, some states, including California, New York, and Georgia have 
requested waivers from EPA to allow them to use fuel that does not 
contain an oxygenate. The state of California stipulated in its waiver 
application that its fuel reduces emissions to a greater extent than 
federal RFG and that the oxygenate requirement has impeded its efforts 
to reduce ozone. To date, EPA has not granted any of these waivers. 
Recently, Congress and others have considered expanding the use of 
ethanol in gasoline for other reasons, including to benefit U.S. 
farmers and to reduce the country's reliance on foreign oil. 

Reduced Vehicle Emissions Have Led to Air Quality Improvements, but the 
Extent of Benefits Attributable to Special Gasoline Blends Is 
Uncertain: 

EPA and other experts have concluded that improvements in air quality 
in some parts of the country are at least partly attributable to the 
use of special gasoline blends. In 2004, EPA reported that ground-level 
ozone has decreased over the past 10 to 25 years and that these 
reductions resulted, at least in part, from emissions control programs 
that include requirements to use special gasoline blends. Further, EPA 
and other experts concluded that special gasoline blends, such as RFG 
and low-RVP blends, are effective strategies for states to use to 
reduce ozone pollution. In addition, a research effort funded by AQIRP 
found that reducing RVP decreased peak ozone in several cities and 
would continue to provide benefits for years to come. In addition, the 
National Research Council reviewed EPA data and found that average 
ozone levels dropped by about 1 percent coincident with reduced 
emissions of VOCs, NOx, and CO from on-road vehicles, which fell by 31 
percent, 2 percent, and 20 percent, respectively. Based on these and 
other data, the National Research Council concluded that improvement in 
air quality is likely attributable, at least in part, to recent 
improvements in gasoline properties.[Footnote 16]

Despite the conclusions that special gasoline blends have contributed 
to improved air quality, findings specifically linking air quality 
improvement to the use of special gasoline blends are limited and 
incomplete because of the inherent difficulties in isolating the 
effects of special gasoline blends from other efforts to improve air 
quality. Studies examining the effect of special gasoline blends on air 
quality noted that attributing a change in ozone levels to the use of a 
special gasoline blend would be difficult.[Footnote 17] In particular, 
experts from EPA, the National Science and Technology Council,[Footnote 
18] and the National Research Council have determined that relating 
trends in the levels of ground-level ozone to trends in emissions and 
to emissions-control policies can be challenging because of the 
confounding effects of other variables, including the effects of other 
control efforts and meteorological fluctuations. For example, the 
National Research Council noted that since the 1990s--when special 
gasoline blends became widely used--several other efforts to reduce 
emissions from vehicles have been made that could also explain changes 
in air quality, such as the addition of enhanced emissions-control 
systems and improvements in inspection and maintenance programs in some 
areas. During this time, EPA and the states have also undertaken 
efforts to reduce emissions from electric utilities, chemical 
manufacturing, and other stationary sources that could have contributed 
to the improvements. Further, because ozone is more readily created 
when VOCs, NOx, and CO react in sunny and hot weather, meteorological 
fluctuations affect the relationship between emissions and ozone 
levels. For example, EPA has identified cases where air quality 
improved, but the improvement was largely due to better weather (more 
air circulation, lower amounts of heat and sunlight, and other 
factors). According to the National Research Council and others, 
determining how much air quality improvement is specifically 
attributable to any specific emissions control program, including 
special gasoline blends, would require the collection of high-quality, 
long-term data on air pollution, on other control measures, and on 
weather. 

Use of Special Gasoline Blends Has Made It More Complicated and Costly 
to Supply Gasoline: 

The increasing numbers of special gasoline blends have made it more 
complicated and costly to supply gasoline, elevating the risk of 
localized supply disruptions. Producing special gasoline blends can 
require changes at refineries, making it more complicated and costly to 
produce gasoline. Special blends also add to the number of fuels 
shipped through pipelines, reducing the efficiency of the pipelines and 
raising costs. In addition, because the tanks at the fuel terminals 
were often built before the proliferation of blends, they are often too 
large and too few to efficiently handle the increased number and 
smaller size batches of special gasoline blends and, as a result, total 
storage capacity has fallen. Further, in some cases, the proliferation 
of blends has reduced the supply options available to some retailers, 
making them more susceptible to supply disruptions. 

Making Special Gasoline Blends Has Added Complexity and Costs at 
Refineries: 

Producing some special gasoline blends sometimes requires refineries to 
invest in additional refinery units, making their refineries more 
complex, or reducing their capacity to make gasoline. For example, 
producing cleaner-burning fuel with lower levels of toxic and other 
emissions, such as RFG or CBG, has required some refiners to install 
specialized units that remove sulfur and benzene during the refining 
process. Similarly, production of low-RVP gasoline requires that 
refiners leave out the lightest components typically included in 
conventional gasoline. Separating these components or converting them 
to ones that can be used in these blends may require additional 
refinery units. If the components are not immediately used in gasoline 
at that refinery, they may be stored, may be used in less valuable 
fuels such as diesel or jet fuel, or shipped to other refineries that 
can use these components. The removal and additional processing of 
these components can decrease the amount of gasoline a refinery can 
produce. For example, officials from one California refinery told us 
that their refinery could produce 12 percent more volume if it produced 
conventional gasoline rather than California gasoline because 
conventional gasoline uses more of the components that are typically 
generated in the refining process.[Footnote 19]

Adding refinery units and losing refinery capacity can increase the 
overall costs of refining gasoline. Manufacturing low-RVP fuel 
generally involved reducing the use of some components and, as a 
result, was less costly than the more significant changes needed to 
make the cleanest burning blends. Specifically, in 1996, EPA estimated 
that low-RVP blends cost 1-2 cents per gallon more to make than the 
conventional gasoline at the time. In contrast, in 2003, the Energy 
Information Administration (EIA), within the Department of Energy, 
estimated that blends formulated to meet the most stringent standards, 
such as oxygenated California gasoline, cost 5-15 cents more per gallon 
to make than the conventional gasoline required at the time and that 
RFG generally costs 2.5-4 cents more per gallon to make. 

In addition, the use of oxygenates in blends such as RFG further 
increases the complexity and cost of the refining process because 
refiners must either invest in equipment to produce oxygenates from 
crude oil (in the case of MTBE) or they must purchase these components 
from other sources. MTBE is generally less expensive than ethanol as an 
oxygenate but has raised water quality concerns. As described earlier, 
ethanol is generally shipped by truck or rail, stored separately from 
other gasoline components, and blended just before gasoline is sent to 
retail stations. The higher cost of purchasing ethanol during the 
period of our analysis, together with these separate handling 
procedures, adds to the total cost of making ethanol-blended gasoline. 
Additionally, because ethanol has a high RVP, more components must be 
removed from ethanol-blended gasoline than from MTBE-blended gasoline 
to meet specifications for RVP. Removing these components and 
reprocessing them or diverting them to other products increases the 
cost of making ethanol-blended gasoline. 

Shipping More Special Gasoline Blends Reduces Pipeline Capacity and 
Raises Costs: 

Shipping gasoline on a pipeline requires a great deal of coordination 
between refineries, pipelines, and terminal stations to maintain 
pipeline flows while fuels are being added and withdrawn. Pipeline 
operators told us that they develop schedules of when individual 
shipments (called batches) will occur at least 1 month in advance; 
however, some changes to this schedule may occur up to the date when a 
product is placed on the pipeline to adjust for, among other things, 
the need for more of a specific gasoline blend in some locations. On 
the day of shipment, pipeline operators precisely coordinate when 
refineries or other shippers add or "inject" fuel to the pipeline and 
when fuel is taken off of the pipeline along with other aspects of 
operating the system. Companies shipping fuel on the pipeline, may 
request to keep their products isolated from others (a segregated 
batch) or may choose to combine their product on the pipeline with 
other blends meeting similar or identical product specifications (a 
fungible batch). Because of the large number of gasoline blends and, 
because some shippers require segregated batches, the number of fuels 
shipped in pipelines has increased dramatically in recent years. For 
example, one pipeline company noted that in 1970 they shipped 10 
different products on their system over the entire year, whereas in 
2004 they shipped 128 (including distinct blends and segregated 
products).[Footnote 20]

The increased number of special gasoline blends has reduced the 
effective capacity of the nation's petroleum products pipeline 
infrastructure because the pipelines are generally operated at slower 
speeds to accommodate more and smaller batches of gasoline while 
keeping the different blends separate. The speed at which centrally 
controlled pumps move product along pipelines--typically between 3 and 
8 miles per hour--can be affected by a number of factors, including the 
volume of product relative to the pipeline capacity being shipped, the 
size of batches, and the availability of terminal storage along the 
pipeline route. Several pipeline operators told us that, prior to the 
introduction of special gasoline blends, they shipped many fewer 
products and much larger batches than they do now. Further, they said 
that shipping smaller volumes can require them to slow or stop the 
pipeline to allow shippers to inject or withdraw individual fuels at 
fuel terminals or other locations. Lost opportunities associated with 
reductions in the amount of fuel that the pipeline can transport serve 
to raise the average cost of moving gasoline. 

The increased number of fuels and fuel types shipped on pipelines has 
also increased losses and costs associated with mixing of fuels. Two 
types of fuel mixtures occur at the interface between batches on 
pipelines: downgrading and transmix. Downgrading occurs when two 
similar fuels mix, but the resulting mix no longer meets the more 
valuable product specification. For example, if a high-and regular- 
octane gasoline are mixed, then the downgraded gasoline may be sold 
only as lower-priced, regular gasoline. Transmix results when two 
dissimilar fuels mix and the fuel cannot be used without reprocessing. 
For example, if diesel fuel and gasoline mix, the transmix must be 
processed to separate the fuels into usable products. Similarly, 
because MTBE is banned in some areas, if gasoline blends containing 
MTBE come in contact with other fuels, the mixed fuel is considered 
transmix and must be reprocessed to remove the MTBE before it can be 
used. To minimize losses associated with downgrades and transmix and 
still maintain efficiency, pipelines generally set a minimum batch 
size. Several pipeline operators reported that they have witnessed 
increased losses and costs due to downgrades and because more fuel 
requires reprocessing as the number of special gasoline blends has 
increased. 

In addition, according to some pipeline company officials, because some 
gasoline blends are only used in one city or only in some areas served 
by a pipeline, shippers incur additional costs if these gasoline blends 
are not taken off the pipeline at the right location. For example, one 
pipeline operator told us that RFG with MTBE shipped in Midwest 
pipelines cannot be used without costly reprocessing if it is shipped 
past certain points on these pipelines because no regions beyond these 
points allow the use of RFG with MTBE. In some instances, the pipeline 
may need to be slowed, or even stopped, to allow a special gasoline 
blend to be taken out of the pipeline. 

Increased Numbers of Gasoline Blends Reduce Terminal Storage: 

The increased number of petroleum products generally, including special 
gasoline blends, and the need to keep them separated, has reduced the 
storage capacity of some gasoline terminals which can create 
difficulties during periods when gasoline supplies are disrupted. To 
ensure product quality, special gasoline blends must be stored in 
separate tanks. Several terminal operators told us that their terminals 
were built before the proliferation of special gasoline blends and were 
designed to handle fewer, but larger, batches of gasoline. Terminal 
operators told us that, because many of the special gasoline blends are 
shipped in smaller batches, the tanks used for these blends are often 
not filled to capacity. One terminal operator told us that some new 
storage tanks had been built in recent years. This operator went on to 
say that adding new storage capacity at existing terminals is often 
either prohibitively expensive or extremely difficult because of space 
limitations and the need to obtain federal, state, and local regulatory 
approvals. One terminal operator told us that the company has chosen 
not to carry one or more gasoline blends used in its area because the 
company's existing tanks were insufficient and building additional tank 
capacity was too costly. For these same reasons, it is often difficult 
to build new terminals. In addition to the complexity of these factors, 
terminal operators told us that the proliferation of special gasoline 
blends also raised their costs by reducing their ability to fully 
utilize their existing tanks, which cost them the opportunity to store 
additional fuels, or by forcing them to make additional investment to 
build more tanks, or both. 

In addition, terminal operators told us that reduced storage capacity 
at their facilities, combined with the increased number of fuels in the 
pipeline system, has made it more difficult to maintain adequate 
stockpiles of some gasoline blends. Several pipeline operators said 
that the interval between when a fuel is available from the pipeline 
may be 10 days or longer if capacity is not available on the pipeline-
-requiring that many days' worth of fuel to be stored at the terminal. 
Increasing demand for gasoline combined with this longer period between 
shipments, and limited terminal storage, increases the likelihood that 
some areas will run out of gasoline while waiting for a shipment. One 
pipeline operator said that the terminals that they served did not run 
out of gasoline from 1995-1996, but that now one terminal per month 
runs out of fuel. One terminal operator explained that running out of 
gasoline can be very harmful to their business because terminal 
operators rely on retailers and independent gasoline tanker trucks to 
regularly visit their stations--visits that may not occur if their 
supplies are inconsistent. In addition, the operator told us that, when 
tanks are pumped dry and later refilled, they can release up to 1 ton 
of VOCs, which contributes to pollution. While the terminal operators 
we spoke with said they are generally able to maintain sufficient 
gasoline storage, they can run short of some fuels when demand is high 
or pipeline deliveries are delayed or interrupted. One operator noted 
that they increase their wholesale gasoline prices as their available 
supplies fall in an effort to reduce their sales and retain some 
gasoline for sale and avoid running out. The terminal operators we 
interviewed did not provide us data on the number of instances when 
they ran out of gasoline, but they said that the number has 
significantly increased in recent years. 

Special Blends Limit Supply Options in Wholesale Markets When Local 
Supply Disruptions Occur: 

According to operators of independent retail gasoline stations that buy 
from the wholesale markets, they have more limited supply options as a 
result of the presence of special gasoline blends. According to an 
industry representative, some gasoline retailers affiliated with, or 
owned by, large oil companies (so-called "integrated" oil companies, 
such as ExxonMobil and ChevronTexaco) receive their gasoline--referred 
to as branded gasoline--only from these companies, generally paying 
slightly more for it. However, other companies that are not affiliated 
with these integrated oil companies, referred to as independent 
retailers, typically purchase gasoline from a variety of suppliers 
including, but not limited to, integrated oil companies and typically 
purchase gasoline at the lowest price available from nearby fuel 
terminals. As a result of this and other factors, independent retailers 
said that they generally sell gasoline at a lower price than branded 
gasoline stations. According to some, the introduction of special 
gasoline blends may increase the market power of some refiners. In its 
2001 white paper, EPA noted that the development of special blends 
limits competition in the refining sector because some blends are 
small, and only a few refiners may choose to make some blends. 
Consistent with this view, independent retailers told us that they have 
had fewer choices in some markets near where special gasoline blends 
are required because some refineries and fuel terminals no longer sell 
gasoline for those markets, and that they have tended to pay higher 
prices in those areas. For example, one large independent retailer 
operating retail gas stations on the East Coast told us that the number 
of refineries producing gasoline for the market they serve fell from 12 
to 3 after the introduction of special gasoline blends--leaving the 
retailer with fewer options to identify the lowest cost supplies. 
Special gasoline blends have also complicated the ability of some large 
entities to enter local gasoline markets. Officials with a large 
company that has entered several local gasoline markets across the 
country as an independent retailer told us that obtaining sufficient 
supplies at reasonable prices is more difficult in markets where 
special gasoline blends are used and that limited supply options have 
reduced the company's ability to enter and compete in some of these 
markets. 

The plight of independent retailers is particularly pressing when 
traditional supplies are disrupted. The independent retailers that we 
spoke with said that their prices generally increase first and that 
they may not have access to fuel supplies provided to branded retailers 
if supplies are disrupted. Before special gasoline blends, these 
independent retailers were able to truck fuel in from nearby cities or 
neighboring states, however, because some gasoline blends may not be 
used anywhere else, or they may only be used hundreds of miles away, 
this is a more difficult and costly option today. For example, several 
industry officials noted that, if supplies of California gasoline are 
disrupted, they would expect prices to rise and that it could take 
weeks for additional supplies to arrive. They said that nearby 
suppliers capable of blending California's gasoline blend are generally 
operating close to their full capacity. In the event that these 
supplies are disrupted, additional supplies generally come from Western 
Canada, the Gulf Coast, the Caribbean, or farther away, because there 
are only a few refineries capable of making this special gasoline blend 
and, as a result, supplies could take 3 weeks or more to arrive. 

Areas That Use Uncommon Special Gasoline Blends Tend to Have Higher and 
More Volatile Gasoline Prices: 

Among the 100 cities we examined, the highest wholesale gasoline prices 
tended to be found in cities that used a special gasoline blend not 
widely available in the region or that is more costly to make than 
other blends. Cities that are far away from major refining centers or 
other sources of gasoline also tended to have high prices. Prices also 
tended to be more volatile in cities having one or more of these 
characteristics. Other studies have also found higher and/or more 
volatile prices in some cities that use special gasoline blends. 
Greater complexity and higher refining, transportation, and storage 
costs associated with supplying special gasoline blends have likely 
contributed to increased gasoline prices overall, and for specific 
special blends, but it is not possible to conclusively determine the 
extent to which special gasoline blends have caused the higher prices 
and greater volatility found in specific cities. 

We Found Higher and More Volatile Gasoline Prices in Cities That Use 
Special Blends: 

We examined data from 100 selected cities to determine how prices 
varied across areas that use special gasoline blends versus 
conventional gasoline and found that, with some exceptions, the highest 
and most volatile gasoline prices tended to be found in cities that 
used special gasoline blends that are uncommon or particularly 
expensive to make, or in cities that are long distances from major 
refining areas. Each of these factors tends to isolate a city from the 
overall gasoline market by limiting the available supplies of gasoline 
from other areas in the event there is a supply shortfall in that city. 

With regard to special gasoline blends, the data show that most of the 
20 cities with the highest average prices over about the past 4 years 
(December 2000 through October 2004) used special gasoline blends, most 
of them formulated to meet stringent emissions standards. In many 
cases, these cities used a fuel that is not widely used outside their 
area, or in some cases is unique to that city or state. For example, 
the five California cities in the data set are all in the top 20 cities 
with respect to gasoline prices. California's gasoline is the cleanest- 
burning gasoline and, in order to make it, California's refineries have 
invested substantial capital in new refining processes. Further, only a 
few refineries outside of California routinely make California 
gasoline, the closest of which is in Northern Washington. The 
uniqueness of California's gasoline has been noted by many sources as 
likely contributing to California's high gasoline prices relative to 
the rest of the country. For the period we examined, the five cities we 
looked at in California had average prices ranging from about 24 to 26 
cents per gallon more than the city with the lowest price (Meridian, 
Mississippi), which uses conventional gasoline and is located near the 
large refining center in the Gulf Coast. The table in appendix II shows 
the price data and gasoline blend types for each of the 100 cities we 
evaluated. Some of the cities with the highest prices used conventional 
gasoline year-round, but most of these are far from major refining 
areas or are located on or near a single smaller pipeline. Average 
prices in these top 20 cities were between 14 and 41 cents per gallon 
more than in the city with the lowest price. 

Using ethanol as an additive to gasoline is associated with higher 
wholesale gasoline prices. To evaluate this, we examined national 
average prices for gasoline blends containing ethanol. For example, for 
the nation as a whole, average prices for conventional gasoline with 
ethanol were about 4 cents per gallon higher than conventional without 
ethanol over the time period we analyzed. The switch to using ethanol, 
as opposed to MTBE, was also associated with higher gasoline 
prices.[Footnote 21] For example, in the years 2001-2003, during which 
California phased out MTBE and phased in ethanol, the average summer 
price of gasoline with ethanol was between about 4 and 8 cents per 
gallon more than the price of gasoline with MTBE. Similarly, over the 
period 2001-2004, the average summer price for federal reformulated 
gasoline with ethanol was between about 6 and 13 cents per gallon more 
than for federal reformulated gasoline with MTBE. 

In contrast to the highest-priced cities, the 20 cities with the lowest 
average wholesale gasoline prices over the period typically used common 
gasoline blends and/or were located near a major refining center--most 
often near the Gulf Coast, the largest refining center in the country 
in terms of both numbers of refineries and total refining capacity. For 
example, among the 20 cities with the lowest prices, 8 used 
conventional gasoline--the most widely available gasoline blend. 
Conventional gasoline is used extensively across the United States, and 
most cities that use it are surrounded by areas using the same 
gasoline. Another 9 cities with the lowest prices used 7.8 RVP 
gasoline--the most widely used of the special blends and the one 
formulated according to the least stringent emissions standards. Most 
of the 7.8 RVP gasoline is used in areas close to the Gulf Coast 
refining center. In addition, refiners told us that making 7.8 RVP 
gasoline is simpler and less costly than some of the other blends, so 
it may be more available from refineries in the event of a local supply 
shortfall. The other 3 cities with the lowest prices used less common 
special blends but are all close to the largest refining center, the 
Gulf Coast and, therefore, have many more potential supply options than 
more isolated cities do. 

We found similar results with regard to the volatility of gasoline 
prices.[Footnote 22] For example, 18 of the 20 cities with the most 
volatile prices used special blends of gasoline, and many of these 
cities were also among the highest-price cities. In contrast to the 
cities with relatively high price volatility, 17 of 20 cities with the 
lowest volatility use either conventional or 7.8 RVP gasoline. However, 
while prices for special blends tend to be higher and more volatile 
than prices for conventional gasoline, available data did not allow us 
to attempt to isolate the effects of specific special gasoline blends 
on gasoline prices or to definitively establish a causal link between 
specific special blends and price volatility. Specifically, we did not 
have sufficient data to control for all other potential contributing 
factors--such as the distance from cities to the sources of gasoline 
supply, or other specific features of these cities that might influence 
prices regardless of the blend of gasoline used. 

Other Studies Have Found Similar Results: 

We reviewed the literature associated with special gasoline blends and 
gasoline prices and found a number of studies done by government, 
academic, and private entities. The results and conclusions of these 
studies were largely consistent with our findings. For example, a 
recent EPA study found that high prices and price volatility are most 
acute in isolated markets, particularly those using special gasoline 
blends.[Footnote 23] The study also pointed out that some states had 
adopted specific gasoline blends in an attempt to use a blend that had 
a lower refining cost than federal reformulated gasoline. EIA also 
studied these blends and concluded, among other things, that the 
increasing number of distinct gasoline blends has reduced the 
flexibility of the supply and distribution system to respond to 
unexpected changes in supply and demand for gasoline. EIA further 
pointed out that, in some cases, states have chosen low RVP gasoline 
blends in an attempt to achieve lower gasoline prices than if they had 
used federal reformulated gasoline, and they inadvertently may have 
added strain to the distribution system, leading to greater potential 
for price volatility. A number of other academic and private studies 
found similar results. 

Special Gasoline Blends Contribute to Higher and More Volatile Prices, 
but Available Data Are Insufficient to Control for all Other Factors: 

There is a broad consensus among the experts and others we spoke with 
that the proliferation of special gasoline blends have contributed to 
increased and more volatile gasoline prices. The studies we reviewed 
also came to similar conclusions. Further, the greater complexity and 
higher refining, transportation, and storage costs associated with 
supplying special gasoline blends have almost certainly resulted in 
increased prices or volatility, either because of more frequent or 
severe supply disruptions, or because higher costs are likely passed 
on, at least in part, to consumers. For example, depending on the 
pipeline company, costs associated with downgrades or transmix are 
recovered from customers. At least part of these costs are, in turn, 
likely to be passed down the supply chain and eventually to consumers 
of gasoline. Similarly, the costs incurred to install new processes to 
make special gasoline blends are likely passed on, at least in part, to 
consumers because refining companies would not make these investments 
without a reasonable expectation of a return on their money. 

While it is, therefore, almost certain that special gasoline blends 
have been a contributing factor to higher gasoline prices, it is not 
possible with the data available to us to conclusively determine the 
extent to which these blends have caused the higher prices and greater 
volatility found in specific cities or to rule out other potentially 
contributing factors. Such other factors may include specific supply 
infrastructure problems in or around these cities that would impact 
gasoline prices regardless of the blend. For example, state and 
industry officials in California told us that marine terminals for off- 
loading gasoline and other petroleum products are in short supply in 
California, which constrains the ability of suppliers in the state to 
receive these products from outside the state in the event of a local 
supply shortfall. These constraints would potentially contribute to 
higher gasoline prices regardless of which blend is used. Another 
potential factor that might influence gasoline prices independently of 
gasoline blends is the level of competition in the petroleum products 
industry. For example, in a recent GAO report, we found that oil 
company mergers had contributed to a 1 to 2 cent per gallon increase in 
conventional gasoline prices in the 1990s and as high an increase as 7 
cents per gallon for California's special gasoline blend. In addition, 
there may be other such factors at play that we do not observe, so we 
cannot definitively determine the precise extent to which observed 
prices are the result of the proliferation of special gasoline blends. 

Conclusions: 

Special gasoline blends have reduced emissions and helped contribute to 
improved air quality in some parts of the country. Using special 
gasoline blends to achieve air quality standards is attractive to 
states; the blends offer immediate reductions in emissions from all 
vehicles already on the road by varying degrees. Unfortunately, EPA's 
knowledge about the emissions generated when special gasoline blends 
are burned is outdated. Much has changed regarding vehicle and 
emissions control technologies since special gasoline blends, including 
those with ethanol, were last comprehensively tested in automobile 
engines. However, EPA and the states continue to rely on models built 
largely around these dated findings when evaluating whether to allow 
states to use special blends as a component in their efforts to improve 
air quality. Given the significant changes in vehicles and fuels, EPA 
should have better information about how the current fuels affect the 
vehicles currently on the road. In addition, Congress should have 
better information regarding the effectiveness of these blends, 
particularly those containing oxygenates such as ethanol, to aid in 
setting policy on fuel blends and the use of oxygenates. 

Although special blends have helped reduce emissions and improve air 
quality, the introduction of these blends appears also to have divided 
the gasoline market, converting what had been closer to a single 
national commodity market, into islands of smaller and more local 
markets for blends of gasoline that are typically not interchangeable. 
Because of octane, seasonal, and other differences, each additional 
special blend that is added can require pipelines and fuel terminals to 
handle several additional blends. Overall, this transformation of the 
gasoline market has complicated the supply infrastructure, increased 
production and delivery costs, and reduced the availability of 
gasoline, in some cases. The impacts of the proliferation of special 
gasoline blends are most evident when there is a disruption in the 
supply chain, such as when a refinery or pipeline is shut down. In 
these instances, localities using a blend different from the gasoline 
used in nearby areas must seek replacement supplies from farther away, 
leading to delays that likely cause higher and longer price spikes 
until these supplies arrive. Overall, it is likely that gasoline prices 
are higher now than they would be if gasoline were closer to a single 
commodity. 

In light of the opposing effects of environmental benefits and negative 
market implications, an ideal policy for approving the use of special 
gasoline blends would balance these effects. However, each decision 
involves trade-offs that all stakeholders may not value equally. 
Specifically, different stakeholders may attach varying degrees of 
importance to the environmental benefits or the impacts on gasoline 
supply infrastructure. Further, individual state actions that impact 
the entire regional supply infrastructure may not fully take those 
impacts into account or, in some cases, even accurately predict the 
impact on their own gasoline supply. With the 8-hour ozone rule and 
other regulatory changes likely to lead to more applications to use 
special gasoline blends, balancing the emissions effects of specific 
gasoline blends against the implications for supply and price will be 
even more important in the coming years. While EPA is currently 
authorized to approve state applications to use special gasoline 
blends, the agency cannot effectively weigh environmental and supply 
considerations because it does not have authority to deny state 
requests to use these blends on the basis of regional supply or price 
considerations and because its information on the environmental 
benefits is dated. 

Recommendation for Executive Action: 

To provide a better understanding of the emissions impacts of using 
special gasoline blends and these blends' impacts on the gasoline 
supply infrastructure, we recommend that the EPA Administrator direct 
the agency to take the following four actions: (1) work with states and 
other stakeholders to comprehensively analyze how various gasoline 
blends affect the emissions of vehicles that comprise today's fleet, 
including how overall emissions are affected by the use of ethanol and 
other oxygenates; (2) use this updated information to revise the 
emissions models that states use to estimate the emissions and air 
quality benefits of these fuels and provide this information to 
Congress; (3) work with states, the Department of Energy, and other 
stakeholders to develop a plan to balance the environmental benefits of 
using special gasoline blends with the impacts on gasoline supply 
infrastructure and prices, and report the results of this effort to 
Congress; and (4) work with the states, the Department of Energy, and 
any other appropriate federal agencies to identify what statutory or 
other changes are needed to achieve this balance and report these 
findings to Congress and request that Congress provide these 
authorities to the appropriate federal agency or agencies. 

Agency Comments and Our Evaluation: 

We provided a copy of our draft report to EPA for comment. The agency 
did not comment on our findings or recommendations but did provide 
technical comments that we have adopted, as appropriate. 

As agreed with your offices, unless you publicly announce the contents 
of this report earlier, we plan no further distribution until 30 days 
from the report date. At that time, we will send copies to other 
appropriate congressional committees and the Administrator of EPA. We 
also will make copies available to others upon request. In addition, 
the report will be available at no charge on the GAO Web site at 
[Hyperlink, http://www.gao.gov]. 

If you or your staff have any questions about this report, please 
contact me at (202) 512-3841 or [Hyperlink, wellsj@gao.gov]. Contact 
points for our Office of Congressional Relations and Public Affairs may 
be found on the last page of this report. GAO staff who contributed to 
this report are listed in appendix II. 

Signed by: 

Jim Wells: 
Director, Natural Resources and Environment: 

[End of section]

Appendixes: 

Appendix I: Scope and Methodology: 

To determine the extent to which special gasoline blends are used in 
the United States and how, if at all, this use is expected to change in 
the future, we reviewed related literature, reviewed data on the use of 
these fuels, and interviewed government and other officials. 
Specifically, we reviewed reports on the presence and use of special 
gasoline blends by the Environmental Protection Agency (EPA), the 
Energy Information Administration (EIA), and others. We also examined 
data on the use of special gasoline blends provided by EPA, ExxonMobil 
(a commonly mentioned source of information on use of special gasoline 
blends), the Oil Pipeline Information Service, state environmental 
agencies and others. In addition, we interviewed federal and state 
government officials, academic and industry experts, and industry 
officials. Specifically, we interviewed officials with the EIA and EPA 
in Washington, D.C., as well as officials with EPA's Office of 
Transportation and Air Quality in Ann Arbor, Michigan, and officials in 
each of the 10 EPA regional offices. We also interviewed 
representatives from industry trade associations including the American 
Petroleum Institute, the Renewable Fuels Association, the National 
Petrochemical Refiners Association, the Association of Oil Pipelines, 
the National Association of Convenience Stores, the Alliance of 
Automobile Manufacturers, and the Society of Independent Gasoline 
Marketers and with representatives from the National Governors 
Association. In addition, we interviewed academic and industry experts, 
and industry officials from companies involved in refining, terminal 
operations, and pipeline operations, as well as from large oil 
companies. We also conducted site visits in California, Louisiana, New 
Jersey, Pennsylvania, and Texas--states with large refining sectors 
and/or organizations with experience with producing and using special 
gasoline blends. 

To document what EPA and others have determined regarding the role of 
special gasoline blends in reducing vehicle emissions and improving 
overall air quality we reviewed related literature, interviewed 
federal, state, and other officials, and examined emissions estimates 
provided by EPA. Specifically, we examined reports on the emissions 
impacts of special gasoline blends done by EPA, the Auto/Oil Air 
Quality Improvement Research Program (AQIRP), National Research 
Council, state environmental agencies, and others. In addition, we 
interviewed federal and state government officials, academic and 
industry experts, and industry officials. Specifically, we interviewed 
federal officials at EPA and EIA, staff at state environmental offices, 
researchers associated with the National Academies of Science and the 
National Research Council, representatives from industry trade and 
health advocacy associations, including the American Petroleum 
Institute, the Renewable Fuels Association, the National Petrochemical 
Refiners Association, the Association of Oil Pipelines, the National 
Association of Convenience Stores, the Alliance of Automobile 
Manufacturers, the Society of Independent Gasoline Marketers, and the 
American Lung Association. In addition, we interviewed academic and 
industry experts, and industry officials from companies involved in 
refining, terminal operations, and pipeline operations, as well as from 
large oil companies. To assess the reliability of emissions analyses, 
we reviewed the analyses' overall design and methodologies, including 
assumptions and inputs to modeling. Automobiles emit a number of 
harmful pollutants; however, some have been identified as potentially 
more significant than others. The Clean Air Act authorizes EPA to 
mitigate potentially harmful concentrations of major criteria 
pollutants, including carbon monoxide (CO), nitrogen dioxide (NO2), 
sulfur dioxide (SO2), ozone (O3), particulate matter (PM) and lead 
(Pb). GAO focused its analysis on VOC, NOX--important precursors to 
ozone--and CO emissions because the transportation sector is 
responsible for a large fraction of VOC, NOx, and CO emissions in the 
United States and, as a result, the Clean Air Act and EPA have 
specified the reduction of these pollutants through fuel control 
programs. 

To identify what effects, if any, special gasoline blends have on 
gasoline supply in the United States, we examined literature reporting 
on the effects of special gasoline blends on gasoline supply, 
interviewed government officials and a wide cross section of industry 
participants. Specifically, we interviewed agency officials with EPA, 
EIA, the Federal Trade Commission, and state regulatory agencies. In 
addition, we interviewed representatives from industry trade 
associations, including the American Petroleum Institute, the Renewable 
Fuels Association, the National Petrochemical Refiners Association, the 
Association of Oil Pipelines, the National Association of Convenience 
Stores, the Alliance of Automobile Manufacturers, and the Society of 
Independent Gasoline Marketers. We also interviewed petroleum industry 
officials from companies involved in refining, terminal and pipeline 
operations, and marketing, including interviews with senior industry 
officials from several integrated oil companies such as ExxonMobil, 
ChevronTexaco, five operators of large pipeline systems that carry 
multiple gasoline blends, several operators of terminals, and three 
large independent marketers of gasoline that buy wholesale gasoline and 
sell it to retail customers. We also conducted site visits in 
California, Louisiana, New Jersey, Pennsylvania, and Texas--states with 
large refining sectors and/or organizations with experience with 
producing and using special gasoline blends. 

To determine how these blends affect gasoline prices, we examined the 
literature on gasoline prices, interviewed industry officials and 
experts, and analyzed wholesale gasoline price data. We reviewed 
reports on the use of specials gasoline blends and gasoline prices done 
by EPA, EIA, and others. We also interviewed government officials and 
industry experts including federal officials at EPA and EIA; staff at 
state environmental offices; academic and industry experts; petroleum 
industry officials from companies involved in refining, terminal 
operations, and pipeline operations, as well as from large oil 
companies; and representatives of trade associations. 

In addition, we evaluated data on wholesale gasoline prices in 100 
cities provided by the Oil Price Information Service (OPIS), as well as 
data on national average prices[Footnote 24] from the same source-- 
these national data covered all the terminals in the country for which 
OPIS collects data. The data were weekly average prices from terminals 
selling gasoline at wholesale and covered the period from December 2000 
through October 2004. In choosing which cities to evaluate, we first 
selected all cities on major pipelines. Then we selected the largest 
cities in each state and in each contiguous area that used a special 
gasoline blend. In so doing, we chose at least one such city from each 
contiguous area in the United States that we determined used a special 
blend of gasoline. Then, we chose cities in areas that use conventional 
gasoline, using similar criteria--every conventional-gasoline city 
chosen was the largest city in its respective state that was on a major 
pipeline. We did not estimate an econometric model to try to isolate 
the effects of specific special blends because we felt we lacked 
sufficient data to control for all other potential contributing 
factors--such as specific features of these cities that might influence 
prices regardless of the blend of gasoline used or the degree of 
competitiveness in the gasoline supply industry. Instead, we ranked the 
100 cities according to the mean of their gasoline prices to determine 
if there were consistent patterns with respect to areas that use 
special gasoline blends versus areas that use conventional gasoline. To 
calculate the mean, we first created price differentials between each 
week's price in each city and the price per gallon of West Texas 
Intermediate crude oil--a commonly used benchmark for world crude oil 
prices. These crude oil prices came from Platts, a common source for 
crude oil and petroleum product prices. For each city, we performed a 
statistical test comparing the average prices between each city and two 
comparison cities in Texas[Footnote 25].: 

We also ranked the cities according to the standard deviations of their 
prices over time and looked for similar patterns. To calculate the 
standard deviations, we again created price differentials between each 
week's price in each city and the price per gallon of West Texas 
Intermediate crude oil. Creating a differential between gasoline and 
crude oil prices controls for some volatility in gasoline prices that 
is caused by changes in the price of crude oil, the fundamental raw 
material input in gasoline. Then, we calculated the standard deviation 
over time for each city for these price differentials. The standard 
deviation is a common measure of the variability of data and, in this 
case, is a measure of how much the prices in each of the cities varied 
over time, controlling for crude oil prices. For each city, we 
performed a standard test for statistical significance of the 
difference of the variability between that city and the city with the 
lowest standard deviation.[Footnote 26]

[End of section]

Appendix II: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Jim Wells (202) 512-3841: 

Staff Acknowledgments: 

In addition to the individual named above, Mark Bondo, Jon Ludwigson, 
Kristen Massey, John Mingus, Cynthia Norris, Frank Rusco, Barbara 
Timmerman, and Kim Wheeler-Raheb made key contributions to this report. 
In addition, important contributions were made by Diane Lund, Dawn 
Shorey, and Mary Welch. 

(360504): 

FOOTNOTES

[1] Research by EPA and others has shown that high levels of air 
pollution are correlated with these and other health effects. However, 
there is insufficient research linking health effects to the use of 
specific special gasoline blends and, as a result, this report does not 
address the health effects of special gasoline blends. 

[2] There are two oxygenates commonly in use. Methyl tertiary-butyl 
ether (MTBE) is derived from crude oil and was the most common 
oxygenate additive until recent years, when it was found to contaminate 
ground water supplies, and has since been banned in a number of states. 
In its place, ethanol has increasingly been used as an oxygenate. 

[3] In some cases, such as when air quality data are insufficient, EPA 
may not be able to designate an area as being in attainment or 
nonattainment. In these cases, EPA designates the area as 
"unclassifiable."

[4] In the event that a state does not develop an EPA-approved SIP, EPA 
may develop a federal implementation plan (FIP). 

[5] Before 1990, fuel requirements were much simpler, with only limits 
on volatility in the summer months to control ozone formation. The 
state of California chose to more stringently regulate gasoline 
formulations before the federal government. Because California 
regulated gasoline formulations prior to the specific authority 
provided to the EPA, California may continue to require more stringent 
fuel formulation requirements without EPA approval, but must at least 
meet (or exceed) the other federal requirements. 

[6] RVP values throughout this report are measured in pounds per square 
inch at 100ºF, the standard industry measure. 

[7] Each state is overseen by a separate EPA regional office; Missouri 
is overseen by EPA region 7 and Illinois is overseen by EPA region 5. 

[8] The new standard measures ozone levels averaged over 8 hours, while 
the prior standard measures these levels over 1 hour. 

[9] These states are, with phase-in year in parentheses, California 
(2003), Colorado (2002), Connecticut (2000), Illinois (2004), Indiana 
(2004), Iowa (2000), Kansas (2004), Kentucky (2006), Maine (2007), 
Michigan (2003), Minnesota (2000), Missouri (2005), Nebraska (2000), 
New Hampshire (2007), New York (2004), Ohio (2005), South Dakota 
(2001), Washington (2004), and Wisconsin (2004). 

[10] EPA determined that these cities are required to use RFG; however, 
the states sued, and the lawsuit was in the courts as of April 2005. 

[11] The directive was issued as part of the President's National 
Energy Policy Report issued on May 17, 2001. 

[12] According to EPA staff, Congress considered providing additional 
authority in legislation after the release of this report; however, 
those bills did not pass. As of April 2005, new legislation passed by 
the House of Representatives, but not yet passed by the Senate, would 
limit the number of gasoline blends, but this bill has not yet become 
law. 

[13] In April 2005, the U.S. House of Representatives passed a bill, 
H.R. 6, which, among other things, limited the expansion of special 
gasoline blends and requires EPA and DOE to examine the issue and 
present options to Congress. As of May 2005, no comparable bill had 
passed the Senate. 

[14] Excluding California, which uses the Motor Vehicle Emissions 
Inventory. 

[15] GAO, Air Pollution: Limitations of EPA's Motor Vehicle Emissions 
Model and Plans to Address Them, GAO/RCED-97-210 (Washington, D.C.: 
Sept. 15, 1997). 

[16] Other possible reasons for the improvements include the advent of 
more stringent standards for vehicles that gradually replace old 
vehicles built to more lenient standards than current models; and 
maturation of new-vehicle emissions-control hardware and software as 
field experience accumulated. 

[17] David Stikkers, "A Retrospective Study of Reformulated Gasoline 
Use in Chicago," Environmental Informatics Archives. 1 (2003): 282-294. 

[18] The National Science and Technology Council is composed of 
representatives from several federal agencies charged with coordinating 
science and technology policies across the federal government. 

[19] While the switch from conventional gasoline to a special gasoline 
blend has led to reductions in refining capacity, all other things 
equal, refiners, in investing in new processes to make the special 
blends, have also typically increased the capability of their 
refineries to convert less valuable components to more valuable ones, 
thereby increasing their capacity. 

[20] Many of the pipelines that transport gasoline also ship other 
petroleum products such as diesel fuel, jet fuel, and propane--some of 
which also require multiple, although fewer, formulations. Recent 
regulations that will require lower levels of sulfur in some diesel 
fuels will further increase the number of fuels moving through the 
pipeline infrastructure and may cause other complications in 
maintaining fuel quality and are expected to have similar effects as 
special gasoline blends. 

[21] As discussed in this report, the switch to ethanol from MTBE has 
largely been the result of MTBE's tendency to contaminate ground water 
sources. 

[22] We measured volatility for each city as the standard deviation 
across time of the city price minus the price of West Texas 
Intermediate crude oil--a widely used benchmark for crude oil, the 
principle physical input into gasoline. A more detailed description of 
our methodology can be found in appendix I. 

[23] EPA Staff White Paper, Study of Unique Gasoline Fuel Blends 
("Boutique Fuels"), Effects on Fuel Supply and Distribution and 
Potential Improvements, EPA420-P-01-004, Office of Transportation and 
Air Quality, U.S. Environmental Protection Agency: October 2001. 

[24] Wholesale prices are the prices reported by fuel terminals and did 
not include any relevant taxes. According to OPIS, in some cases fuel 
terminals may have reported tax credits available for ethanol fuels in 
the prices that they reported, but they acknowledge that past reporting 
may be inconsistent in this regard. 

[25] Specifically, we performed a sign test. See, for example, R.V. 
Hogg and A. T. Craig, Introduction to Mathematical Statistics. 4th ed. 
(New York: Macmillan, 1978): 312-314. We use the sign test because it 
tests the equality of matched pairs of observations without imposing 
further assumptions on the underlying distributions. The results of 
this test showed that all the highest 20 city prices were statistically 
significantly greater than in the low price comparison city. 

[26] H. Levene, "Robust tests for equality of variances," ed. I. Olkin, 
Contributions to Probability and Statistics (Palo Alto: Stanford 
University Press, 1960): 278-292. We use the Levene test because the 
conventional F test is very sensitive to the assumption that the data 
are drawn from a Normal distribution, an assumption that does not 
necessarily hold for the gasoline price data. This test indicated 
statistical significance for the difference between the variances of 
most of the highest volatility cities compared to the lowest volatility 
city. 

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