16 CFR Part 306; Automotive Fuel Ratings, Certification and Posting; Project No. R811005
As a motorcyle enthusiast and car owner, I am writing to express my concerns about the Federal Trade Commission's proposed rule to provide requirements for rating and certifying ethanol blends and requirements for labeling blends of more than 10 percent ethanol. The FTC's rule proposal to provide requirements for rating and certifying ethanol blends and requirements for labeling blends of more than 10 percent ethanol is inadequate and misleading to the point of endangering the public. This rule exempts the U.S. Environmental Protection Agency's E15-approved label. This rule is for an additional label to be placed on the fuel pump "in response to the emergence of ethanol blends as a retail fuel and the likely increased availability of such blends." With this rule, it only means gasoline with higher blends of ethanol will emerge into the marketplace. The American Motorcyclist Association (AMA) believes as I do that this proposal will cause even more confusion given the events surrounding the rollout of E15 into the marketplace. I am opposed to E15 and any fuel containing more than ten percent ethanol because it can cause engine and fuel system failure to your motorcycle or all-terrain vehicle, as well as many other gasoline-powered vehicles (e.g., cars, trucks, power equipment, et al.), and can void manufacturers' warranties. Furthermore, the U.S. Coast Guard has stated their opposition to E15 in boats due to risks of fuel system degradation and fires. According to the EPA, "[e]thanol impacts motor vehicles in two primary ways. First ... ethanol enleans the [air/fuel] ratio (increases the proportion of oxygen relative to hydrocarbons) which can lead to increased exhaust gas temperatures and potentially increase incremental deterioration of emission control hardware and performance over time, possibly causing catalyst failure. Second, ethanol can cause materials compatibility issues, which may lead to other component failures." "In motorcycles and nonroad products [using E15 and higher ethanol blends], EPA raised engine-failure concerns from overheating." The proposed rule provides no direction on where on the pump the label should be located. I am opposed to the FTC proposal of such labels being rounded to the nearest factor of 10. How will this accurately inform the consumer of the type of fuel called for by the vehicle owner's manual? Will a fuel containing 11 percent to 14 percent ethanol be labeled as 10 percent ethanol? Is the FTC aware that manufacturers' warranties are valid only for the use of fuel containing 10 percent ethanol by volume or less? Help protect 22 million motorcycles and all-terrain vehicles in America -- and the riders who depend on their safe operation -- from inadvertent misfueling. The loser in any inadvertent misfueling event is the motorcyclist and ATV riders, car owners, boat owners, etc., ... in other words, the American public. Thank you for your time to gather public opinion and reconsideration of fuel labeling and marketplace deployment of fuels with greater than 10% ethanol.