Proposed Amendments to the Fuel Rating Rule, FTC File No. R811005 #547105-00011

Submission Number:
547105-00011
Commenter:
Gill
State:
NC
Initiative Name:
Proposed Amendments to the Fuel Rating Rule, FTC File No. R811005

1. Warning Statement Posted on Fuel Label 2. a. The FTC's proposed warning statement for Alternative Fuels containing ethanol, "MAY HARM SOME VEHICLES," is a gross misrepresentation of the fuel, and discourages the use of the fuel, which is the exact opposite of the intended purpose of the American Energy Independence and Security Act. Ultimately, it will only confuse the consumer. Furthermore, this same statement could be posted on every fuel pump in the United States and be equally true, for diesel will harm some engines (e.g. gasoline engines), gasoline will harm some engines (e.g. diesel engines), and so on. b. Growth Energy recommends instead to post, "For Flex Fuel Vehicles Only" on the label of Alternative Fuels containing ethanol. This clear and concise warning statement will protect against mis-fueling while not discouraging the use of Alternative Fuels containing ethanol. 3. Fuel Label Color a. The FTC's proposed label for Alternative Fuels containing ethanol is orange in color, a color that is often used for warning purposes, and which further portrays a negative image of the fuel. When combined with an inappropriate warning statement, it will all but ensure that very few consumers ever choose to use either E85 or Mid-Level Ethanol Blends. b. Growth Energy recommends a dark blue label with white lettering. 4. Octane Disclosure should be Posted on Fuel Label a. The FTC's proposed label for Alternative Fuels containing ethanol does not include an octane rating requirement. b. Growth Energy recommends a similar octane posting requirement to that of unleaded gasoline. Alternative Fuels containing ethanol also need to have the octane level posted. Flexible Fuel Vehicles are, like conventional engines, dependent on an adequate octane level to prevent engine damage from occurring. Posting the octane rating ensures that consumers can choose the right octane level for their engine. 5. Ethanol Concentration Should be Posted on Fuel Label a. The FTC's proposed label for Alternative Fuels containing ethanol does contain the concentration of ethanol, however, in a couple of the cases, the proposed labels state a wide range of ethanol. It is important to the consumer that the ethanol concentration stated is within a tighter range. b. Growth Energy recommends the following labels to cover all blends of Alternative Fuels containing ethanol likely to be dispensed at retail stations: i. 20% volume Ethanol (±2% Ethanol) ii. 30% volume Ethanol (±3% Ethanol) iii. 40% volume Ethanol (±4% Ethanol) iv. 50% volume Ethanol (±5% Ethanol) v. 60% volume Ethanol (±6% Ethanol) vi. 70% volume Ethanol (±7% Ethanol) vii. 80% volume Ethanol (±8% Ethanol)