EPA Should Delay E15 Waiver Decision Until All Testing is CompleteBriefing Paper

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8.16.10

The Environmental Protection Agency (EPA) has indicated it may take action later this year toapprove higher levels of ethanol in fuel blends

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up to 15 percent

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even though criticalvehicle tests and environmental analyses mandated by the Clean Air Act have not yet beencompleted. While API and the industry support

EPA’s goal to increase ethanol use in

conventional vehicles, any EPA action this year would be premature and could threatenvehicle performance, void warranties, confuse consumers

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and possibly create a publicbacklash against renewable fuels.Higher levels of ethanol blends in gasoline have not yet been proven safe or effective, andit would be a mistake for EPA to act before all necessary testing is completed.

The EPA is considering a petition from ethanol producers to allow the sale of gasolinethat contains up to 15 percent ethanol (E15). EPA has announced it plans to take actionin September on a waiver request to allow higher levels of ethanol in gasoline for vehiclemodels 2007 and newer, and to make a determination in November for 2001-06 modelyear vehicles.

However, higher levels of ethanol have not been proven safe or effective according toindustry projections based on testing to date. Testing for engine and vehicle compatibilitywith E15 and testing of environmental issues associated with higher levels of ethanol ingasoline is scheduled for completion in 2011.

The Coordinating Research Council (CRC), a non-profit organization made up of theAmerican Petroleum Institute (API), the Society of Automotive Engineers (SAE) and agroup of automobile manufacturers, has defined and is conducting highway vehicletesting that is needed, both in terms of vehicle emissions issues and also in terms ofvehicle durability and consumer satisfaction.

Testing is also being conducted by the Department of Energy, the EPA and industry onthe compatibility and functionality of the gasoline station equipment (tanks and pumps)with E15. Potential problems with storage and/or dispensing equipment create additionalenvironmental risks associated with spills, leaks and consumer safety.

Sound science, environmental protection and consumer safety

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not politics

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must guidethis important decision.

Section 211(f) of the Clean Air Act mandates a detailed scientific review before newfuels, additives or fuel blends are introduced into commerce. EPA is in the midst ofcarrying out this review, including soliciting public comment from all stakeholders on theintroduction of mid-level ethanol blends. This review must be allowed to continue beforeany decisions are made.

In a July 2010 letter to the EPA Administrator, Chairman Waxman and Ranking MemberBarton

of the U.S. House Energy and Commerce Committee wrote, “

Given the importantpotential benefits of renewable fuels and the need to protect existing vehicles andengines, we support the Department of Ener

gy's

efforts to conduct the necessarycompatibility testing and your decision to await those test results.

”