Increasing the amount of ethanol blended into the nation’s fuel supply is both scientifically justified and economically prudent, said the Renewable Fuels Association (RFA). In comments to the Environmental Protection Agency (EPA) regarding the adoption of E15 (15% ethanol blends), the RFA introduced previously non-submitted 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. Additionally, the RFA called on EPA to take the immediate interim step of moving to E12.

“Reducing America’s dependence of foreign oil requires a shift in how we fuel our vehicles,” said RFA President Bob 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.”

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).

Finally, the RFA recognizes that EPA has the authority to limit a waiver to on-road applications. The RFA wrote, “Thus, to the extent EPA believes there is insufficient evidence to determine whether E15 emissions will cause or contribute to nonroad vehicles and nonroad engines failing to meet emission standards required for certification, EPA should still grant a waiver for E15, but limit such waiver to motor vehicles and motor vehicle engines.”

“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.”

Recently, President Obama expressed his support for biofuels and the evolution of the industry to next generation technologies in a letter to the Governors’ Biofuel Coalition, writing:

“…the transition [to next generation biofuels] will be successful only if the first-generation biofuels industry remain viable in the near term, and if we remove long-standing artificial barriers to market expansion necessary for large volumes of advanced renewable fuels to find a place in America’s transportation fuels system.”

A complete copy of RFA’s comments are available at www.EthanolRFA.org.