The Alliance for a Safe Alternative Fuels Environment (AllSAFE), which speaks for manufacturers on fuel-related legislation representing products that Americans own and operate, including chainsaws and lawnmowers, announced that it delivered official comments voicing concern to the Environmental Protection Agency (EPA) about Growth Energy’s fuel waiver application for E-15.
AllSAFE’s comments also address concerns over EPA’s expansion of the waiver request to include "bifurcating" the fuel supply, or allowing two fuels (E-10 and E-15) in the marketplace at one time via the 211(f)(4) fuel waiver process.
"AllSAFE’s comments clearly establish that E-15 has not been sufficiently tested and poses a hazard that could potentially bring physical endangerment to consumers," said Kris Kiser, spokesman for AllSAFE. "With the additional concern of a ‘bifurcated fuel’ supply, the 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, comments were requested by EPA on a potential "partial fuel waiver" that would in concept only apply to certain newer on-road vehicles. EPA’s "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 % of vehicles needing unleaded gasoline (based on EPA’s own misfueling study). With no physical barrier and a price differential that would encourage misfueling, the potential for physical harm to consumers must be addressed before bifurcation is considered.
In summary, AllSAFE recommends that the EPA deny the Growth Energy E-15 partial waiver request at this time.
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