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STATEMENT ON RE-REFINED OIL F O R 

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### EPA/NHTSA PUBLIC H E ARING ON PROPOSED HEAVY DUTY PHAS E

## 2 GHG STANDARDS AUGUST 

## 6, 2015 CHICAGO, ILLINOIS

Thank you for the opportunity to provide testimony concerning the proposed Heavy Duty Phase 2 greenhouse gas emission and fuel consumption standards published in the Federal Register on July 13, 2015. I am here on beha lf of Safety-Kieen Systems, Inc. of Richardson, TX and a number of other companies engaged in the "crad le to crad le'' recycling of used engine oil. These include Heritage
Crystal C lean of Elgin, IL, Vertex Energy of Houston, TX, Avista Oil of Peachtree, GA, and Pura l ube USA, Inc

., of Wayne, PA. Together, we collect, process , and refine used motor oil and, thereby, turn the most highly refined product made from crude oil into a renewable reso urce
. We note that the proposed new Phase 2 standards for fuel economy and GHG reductions from these vehicles look at a wide range of options and call for flexibility in how manufacturers meet the new standards using averaging, banking, and t rading (ABT). We recommend allowing the manufacturers of relevant vehicles to obtain credit for the significant greenhouse gas benefits associated with re-refined lubricating oil when such oil is supplied as original fill in the vehicle when sold

. Further, we would like to explore with the agencies how ABT mechanisms can be used to allow credit for re-refined oil supp lied during subsequent routine maintenance in the engines ofvehicles subject to the rule. Re
-refining used lubricating oil generates significant environmental and energy benefits and has been deemed by federal agencies and national research laboratories as an appropriate use for conserving crude oil, a non-renewab le resource. Our independent life cycle ana lysis, p ubl ished in an American Chemistry Society Journal after peer review, describes how the use of re-refined oil reduces greenhouse gas emissions, compared to the use of engine oil made from virgin crude. This analysis, conducted by Environ, a leading environmental consulting firm, estimates that production of re -refined engine oil generates 70% fewer GHG emissions than production of oil from virgin stock. So, for example, the total GHG savings from use of 50 million ga llons of re -refined oil is approximately 159,000 metric tons of C02e. That is equal to avoiding emissions from combustion of 15 million gallons of #2 fuel oil. Simply put, every 3 gallons of re -refined oil used avoids emissions equivalent to burning a gallon of diesel fuel. Our published analysis shows that even ifwe conservative ly include other factors such as emissions from collection of used oil, use of re-refined engine oil represents a 56% reduction in GHG emissions when compared to emissions attributable to production of lubricants from virgin oil. Thi s is because refining eng i ne oil from previously refined used oil is a more efficient process than refining compa rable engine oil from virgin crude

. Significant carbon reductions are achievable through use of re -refined oil to lubricate engines as original equipment and as part of maintenance of the vehicles. Allowing OEMs of medium and heavyduty vehicles to receive credit for these GHG savings will provide them with additional flexibility to achieve th e targets being set by EPA and DOT

. Further, allowing credits for initial fill and future

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. f: tJ£ 1-:G I maintenance will encourage more companies to use re-refined oil which studies show is preferable in terms of reducing greenhouse gas emissions. When the tota l life cycle benefits are factored in, the use of re-refined oil has benefits comparable to the use of low rolling resistance tires. Also, as in the case of low rolling resistance tires, the benefits last as long as the original equipment is properly maintained through future maintenance intervals on the vehicle (in the case of the tires used) or in the vehicle (in the case of the oil in the crankcase). For tires, proper maintenance includes proper inflation and successive use of similar low rolling resistan ce tires. The proposed rule could easily be adapted to allow credit for the use of re-refined oil with demonstrated reductions in GHG emissions through both the initial crankcase fill and also during the manufacturer's long-term recommended maintenance cycle. Credit for future maintenance could be provided on a tradab le basis allowing the manufacturer to buy GHG reduction credits each time the oil is changed using re-refined oil in the future maintenance cycle

. By allowing future tradable credit, the manufacturer would be given an incentive to promote use of re-refined oil in future oil changes through sales or re -refined oil to their own network of maintenance faci liti es as well as from third party vendors. The use of such re-refined oil would, in turn, help to reduce total GHG emissions from the operation of these vehicles. In calculating the GHG benefits we have only included the well to gate benefits from comparing the GHG emissions from manufacturing process for re-refined oil with that of manufacturing lubes from virgin crude. Several studies show significant additional benefit by diverting used oil to re -refining rather than combustion at the end of l ife. However quantification of the magnitude of those benefits are imprecise due to factors such as the choice of fuel combusted in place of used oil. Therefore, we have kept these additional benefits out of this analysis to ensure the robustness of our statements. We appreciate the opportunity to comment and ask that you consider this additional strategy for achieving the targets you have set. We would be delighted to answer any questions you may have

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Contact: B arry McCa be Safety ·Kleen Systems, A Clean Harbors Company Rich ardson , TX !?.i!'!Y,**M~.(:~** br.@?.!!.fety·**k!f~_±orn** 972.369

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