Proposed Amendments to the Fuel Rating Rule, FTC File No. R811005 #547105-00020

Submission Number:
547105-00020
Commenter:
Michael Green
Organization:
POET
State:
SD
Initiative Name:
Proposed Amendments to the Fuel Rating Rule, FTC File No. R811005

All products available to consumers should have accurate, informative, and consistent labelling requirements. In this case, alternative fuel labels should give similar information to labels already used for other fuel options. For example, gasoline pumps give octane ratings. Most modern internal combustion engines have recommended octane ranges for best performance. This same information should be provided on alternative fuel labels. Gasoline and Diesel pumps have labels indicating what vehicles each fuel is intended for. There is no reason to do anything different for alternative fuel pumps. For instance, Low Sulfur Diesel pumps all have labels stating that the fuel is required to be used in model year 2007 and later Highway Diesel engines, unleaded pumps used to be labelled to distinguish them from leaded gasoline pumps, etc. Every engine is designed to be used with a specific fuel or range of fuels. There is no reason to treat alternative fuels any differently than we do the multitude of fuels already available at all US fueling locations. As long as the information is provided, consumers are smart enough to use the appropriate fuel for their engine. There is no need for a scare tactic labelling program to deter people from using alternative fuels. We just need to give these fuels the same level of labelling accuracy we have provided for other fuels for 30+ years.