The EPA has authority to define E12 (12% ethanol/88% gasoline) blends as "substantially similar" to fuels used in certified motor vehicles. 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 12% ethanol blends. Ethanol as a fuel additive is an oxygenate. Including ethanol raises the oxygen content of gasoline, and, according to the group, makes for a cleaner, more complete combustion of gasoline.
Much of the concern being raised has to do with the amount of oxygen in gasoline as a result of increased ethanol use and increased combustion temperatures, the RFA said; however, it is likely that fuels containing oxygen levels equal to those in E12 have been in the marketplace since the early 1990s. A complete explanation of the already provided statutory authority the EPA has to approve E12 can be found in RFA's official comments (click here).
"Considering this and the authority given to EPA in the Clean Air Act, EPA should acknowledge that it has already permitted E12 blends in terms of equivalent oxygen content and that, such blends are 'substantially similar' to certification fuels under its interpretation," the group said.
"We need not wait until EPA decides on the formal E15 waiver request to increase the amount of ethanol we use," said RFA president Bob Dinneen. "This interim and legally supported step of approving E12 blends would provide an immediate boost to America's ethanol producers and provide gasoline marketers the flexibility they need to meet the requirements of the Renewable Fuels Standard and capitalize on the cost savings associated with increased ethanol blending."
In comments to the EPA regarding the adoption of E15, the RFA introduced additional data supporting a move to E15. The official E15 waiver request is not a mandate, but rather provides gasoline marketers and retailers the ability to sell everything from E0 to E15.
"Reducing America's dependence of foreign oil requires a shift in how we fuel our vehicles," said Dinneen. "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."
RFA noted six recently completed research projects from the Coordinated Research Council (CRC), the University of Minnesota, Minnesota State University and the 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.
API, however, issued the following statement concerning the RFA's call for approval of E12 gasoline blends: "RFA's call for approval of E12 is premature. RFA fails to note there is a large-scale cooperative government/industry research effort underway seeking to better understand the impacts of intermediate ethanol blends. The API study, which is incomplete, is one part of that effort. The last field phase has not been conducted. Ethanol is a valuable blending component in gasoline, but no risks should be taken in using it at higher blend levels in hundreds of millions of internal combustion engines, including those that power most of America's cars and trucks, until all relevant research is completed and reviewed."
Click here for the EPA's Fuels & Fuel Additives page.Meanwhile, AAA, the nation's largest consumer automobile club, is calling for the EPA to reject the petition to increase the permissible content of ethanol blended in gasoline to 15% from the currently allowed 10%.
"While AAA supports the integration of alternative fuels into the nation's fuel supply, additional data is needed on the potential impact associated with the use of E15 gasoline over time on the country's vehicle fleet," said AAA vice president of public affairs Kathleen Marvaso. "Therefore, AAA is opposed to increasing the ethanol content in gasoline to 15% without unbiased, objective research first proving that E15 will not damage engine systems and component parts, compromise vehicle performance and fuel efficiency, or increase vehicle emissions."The association identified the following areas of concern: Potential negative impact on vehicle exhaust emissions. Degradation of engine operability in cold startup conditions. System component damage. Older vehicles are not designed to run on ethanol and would unquestionably experience poor drivability and reduced engine reliability. Catalytic converters could be impacted by the increased temperatures caused by the higher alcohol content in the fuel. Vehicle warranty and service agreement issues. E15 will reduce the fuel efficiency of the vehicles in which it is used. Click hereto view more details of AAA's areas of concern.
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