Thank you for taking a proactive approach on E15 implementation in the wake of the state
budget providing funding for the rulemaking and the signing of AB 30 into law.
As we have mentioned in numerous verbal and written comments, ethanol has been the leading
source of carbon reductions historically in the state’s LCFS with just E10 and E85. E15 will
continue that trend.
E15 is currently sold in 34 states at nearly 4,500 sites and has powered more than 160 billion
miles driven nationwide.
With the right approach, California can become the leading market in E15, which is why getting
this right—for consumers, retailers, and the environment—is critical. We believe part of that
approach is providing written guidance, giving fuel retailers and the entire supply chain
confidence that they can offer E15 without concern over ambiguous regulation.
We are glad to see the clarification that CARBOB can be blended with up to 15% ethanol. That
is important for retailers to have that certainty and clarity.
We would encourage CARB to work with the other agencies involved to ensure timely
implementation of AB 30 and to operate under the intent of the law: allow the sale of E15 in the
state and simultaneously address regulatory questions on methods of sale, equipment
approvals, and labeling.
We encourage CARB to follow a regulatory path that mirrors E10 and California Reformulated
Gasoline, as E15 is a viable option for nearly all passenger vehicles on the road today as
opposed to alternative fuels.
Additionally, E15 is defined by the U.S. EPA in 40 CFR § 1090.80 as “gasoline that contains
more than 10 and no more than 15 volume percent ethanol.”
Due to the high rate of equipment and vehicle compatibility with E15 –in addition to California
regulations such as the permanent closure of single walled underground storage tanks— a vast
majority of retail infrastructure is able to store, handle and dispense E15 safely.
Can you clarify the scope and content of the survey CARB is conducting to determine whether
E10 certified vapor recovery systems can be certified for E15? E.g. – Are you requesting
information from equipment manufacturers? Or are you conducting additional tests? Are you
able to
Misfuelling Mitigation Plans are important and required by the EPA. Along with the label required
by 40, CFR, § 1090.1510, MMPs have other minor labeling requirements when E15 is being
dispensed from the same hose and nozzle as other gasoline products. Issues and questions
regarding misfuelling are already addressed thoroughly by federal requirements. A national
survey is deployed through RFGSA that actively assesses clarity for the consumer and
adherence to federal labeling requirements.
Growth Energy’s Comments (AS PREPARED)
CARB E15 Implementation Workshop
Dallas Gerber – Director of State Government Affairs
Reid Wagner – Technical Director of Market Development