|Organization:||Suncor Energy USA|
|Agency:||Federal Trade Commission|
|Rule:||Proposed Amendments to the Fuel Rating Rule; FTC File No. R811005|
Comments:Suncor Energy USA supports amending the rule allow the use of infrared test methods as an additional option for octane testing. Infrared analyzers are widely used to determine the octane rating of gasoline as well as gasoline-ethanol blends and may provide an advantage to octane engine test methods. Since properly calibrated infrared analyzers provide more reliable results due to reduced variability in test measurements, use of these methods may result in enhanced quality control and better consumer protection. Allowing these methods to be used is important for providing additional flexibility for meeting FTC octane certification requirements. For these reasons, we suggest that the Commission add a new option to §306.5 Automotive fuel rating allowing the use of infrared octane analyzers as an alternative methodology.