The end of the E15 comment period has provided a whirlwind of activity among the ethanol industry. Yesterday, the Renewable Fuels Association (RFA) along with many other ethanol and agricultural organizations, filed comments with the EPA. In their comments, the RFA introduced previously non-submitted data supporting a move to E15. However, although they support the adoption of E15, they also called on the EPA to take the immediate interim step of moving to E12.
Bob Dinneen, President of RFA said, “Reducing America’s dependence of foreign oil requires a shift in how we fuel our vehicles. Already agreed upon science and ongoing research make clear the move to up to E15 blends is warranted. In addition, existing statutes allow EPA to take an interim step by approving the use of up to 12% ethanol blends. In order to achieve the energy, economic and environmental goals of this country, increasing the use of domestically-produced renewable fuels like ethanol is essential. EPA has the authority, and now the science, to approve such a step.”
As mentioned by other waiver supporters, the science is there to support the increase to E15. The RFA noted six recently completed research projects from the Coordinated Research Council (CRC), the University of Minnesota, Minnesota State University, and the American Petroleum Institute (API) that confirm the safe and effective use of higher ethanol blends. A complete summary of these studies can be found in Section I, Subsection B of RFA’s written comments.
In addition, the RFA notes that EPA already has the authority to immediately move to E12 blends while considering the entire E15 waiver. Specifically, EPA has authority to define E12 blends are ‘substantially similar’ to fuels used in certified motor vehicles, such as E10. The basis for this conclusion is that the weight percentage of oxygen that EPA allows in oxygenated gasoline actually equates to an oxygen percentage that would be present in E12 blends. Since the voiced concerns regarding higher ethanol blends are largely based on the potential for increased oxygen content to cause issues with the engine, if oxygen content that would equate to 12% ethanol in gasoline is already allowed, EPA has the legal authority to make a substantially similar finding for such blends under Section 211(f)(1).
“The time for dragging our feet in achieving real energy self-reliance is over,” said Dinneen. “By increasing the use of ethanol, EPA can not only ensure the success of our energy and environmental public policy goals, but provide economic and job opportunities to tens of thousands of Americans. The science and the statute clearly give EPA the justification and authority to approve ethanol blends of E12 and up to E15. Administrator Jackson should follow the lead of President Obama and allow for increased ethanol use from all sources.”