Proposed Amendments to the Fuel Rating Rule, FTC File No. R811005 #547105-00056

Submission Number:
547105-00056
Commenter:
Michael Giambalvo
Organization:
Phibro
State:
NJ
Initiative Name:
Proposed Amendments to the Fuel Rating Rule, FTC File No. R811005

1) 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. 2)Posting of "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) 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. a dark blue label with white lettering is better. 4) The FTC's proposed label for Alternative Fuels containing ethanol does not include an octane rating requirement. Post 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) Octane Disclosure should be Posted on Fuel Label, The FTC's proposed label for Alternative Fuels containing ethanol does contain the concentration of ethanol, It is important to the consumer that the ethanol concentration stated is within a tighter range. 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)