AllSAFE Comments on E-15 Fuel Waiver Application

Bifurcating the fuel supply would confuse consumers, according to the Alliance for a Safe Alternative Fuels Environment.

"E-15 has not been sufficiently tested and poses a hazard that could potentially bring physical endangerment to consumers," said Kris Kiser, a spokesman for the Alliance for a Safe Alternative Fuels Environment (AllSAFE), which speaks for some manufacturers on fuel-related legislation.

The group announced on July 16 that it submitted comments to the U.S. Environmental Protection Agency about Growth Energy's fuel waiver application for E-15.

Growth Energy and 54 ethanol producers have asked EPA to approve the use of ethanol blended with gasoline up to 15 percent. The organization says that increasing the blend of ethanol by 5 five percent will help boost the economy by creating jobs, increasing energy independence, enhancing car performance, and greening the environment.

AllSAFE's comments also expressed concern over EPA's expansion of the waiver request to include "bifurcating" the fuel supply — allowing two fuels (E-10 and E-15) in the marketplace at one time via the 211(f)(4) fuel waiver process.

Kiser added that, "With the additional concern of a 'bifurcated' fuel supply, EPA has not evaluated all the complex issues, such as misfueling, which again, leads to permanent damage of non-road equipment and older vehicles and poses a risk of personal harm to the consumer. These concerns deserve a full evaluation through the proper section of the federal Clean Air Act and should not be insufficiently addressed through a fuel waiver request."

In EPA's response to Growth Energy's waiver application, the agency requested comments on a potential "partial fuel waiver" that would in concept only apply to certain newer on-road vehicles. The "partial waiver" concept would be based on somehow bifurcating the national production, distribution, blending, and marketing of separate E-10 fuels (for non-road products and older automobiles) and then offering E-15 fuels for newer automobiles only.

In practice, consumers would now be faced with two fuel pumps at any given station—one with E-10 and one with E-15. "AllSAFE has strongly cautioned the EPA against such a measure since consumers could be confused and possibly use the wrong fuel, especially if they see that E-15 is cheaper and choose that blend rate to save money," said Kiser.

In its comments, AllSAFE pointed out that EPA's attempt to offer leaded and unleaded fuels via two separate pumps was not completely successful. Even with education and physical barriers against misfueling at the fuel pump and on the automobile, misfueling still occurred with 13.5 percent of vehicles needing unleaded gasoline (based on EPA's own misfueling study).

AllSAFE's comments also point out that from a legal and public policy standpoint, the EPA cannot approve any "partial" mid-level ethanol fuel waiver until EPA has completed a separate rulemaking process under section 211(c) to prevent misfueling.

AllSAFE is made up of national consumer, manufacturing, and gasoline retailer associations that consume gasoline and ethanol fuel blends. It speaks for manufacturers on fuel-related legislation representing 400 million products that over 250 million Americans own and operate, including recreational boats and marine engines, chainsaws, lawnmowers, motor vehicles, motorcycles, all terrain vehicles, snowmobiles, generators, and related vehicles and equipment.

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