WASHINGTON, D.C. – Today, Growth Energy Senior Vice President of Regulatory Affairs Chris Bliley submitted written comments to the U.S. Environmental Protection Agency (EPA) on its proposed “Fuels Regulatory Streamlining Rule.” On behalf of the nation’s largest renewable fuel organization, Bliley welcomed the agency’s efforts to “reduce burdensome and duplicative requirements on fuels” while cautioning against changes that could negatively impact market access to higher ethanol blends such as E15 and E85.
“With E15 currently available at more than 2000 retail locations in 29 states and E85 available at more than 4000 locations, any update to the fuel regulations should first and foremost, do no harm to the availability of these fuels,” wrote Bliley, who urged the agency to fine tune its proposed definition of gasoline, which could inadvertently impose gasoline regulations on all ethanol blends beyond E15 including E85.
Bliley also called on the EPA to clarify language on blendstock for oxygenate blending (BOB).
“With E15 now approved for year-round sale, it makes little sense why E15 would have substantially different BOB requirements for E10 and E15,” wrote Bliley. “At a minimum, if downstream oxygenate blenders choose to add 15% ethanol, they should not incur any additional requirements of that as a fuel manufacturer or refiner. We believe that current recordkeeping from retailers and downstream blenders should satisfy EPA’s need for certainty with the fuel. Alternatively, we would ask that you work with retailers to simplify any BOB recertification, so that there are not any additional burdensome requirements added to the process to sell this fuel, nor are there any additional restrictions imposed on retailers choosing to offer the fuel.”
In addition, Bliley urged the agency to move ahead on efforts to limit the costs of a burdensome E15 sampling survey requirement under the misfuelling mitigation regulation, which costs ethanol producers and retailers more than a million dollars annually. Finally, Bliley called on the agency to follow through on the administration’s prior commitment to streamline labeling and remove infrastructure barriers to the sale of E15.
“In discussions last year, the EPA administrator committed to review of the E15 label as well as removing hurdles to the sale of E15 through existing infrastructure,” added Bliley. “E15 is approved for all 2001 and newer vehicles which represents more than 9 out of 10 cars on the road today and more than 95 percent of the vehicle miles traveled. American drivers have now driven more than 14 billion miles and fuel marketers have had millions of transactions with this fuel without any reported issues. Additionally, as it relates to retail infrastructure, nearly all underground storage tanks made in the last 30 years are compatible with ethanol blends up to 100 percent, and nearly all fuel dispensers made since 2008 are compatible with E15. It makes no sense why EPA should not make the fuel more available to consumers and remove these remaining restrictions.”
The comments submitted by Growth Energy build on oral testimony Bliley offered during the agency’s public hearing on the rule in late May. Growth Energy’s full written testimony is available here.