16 CFR Part 306; Automotive Fuel Ratings, Certification and Posting; Project No. R811005
I am a member of the American Motorcyclists Association, as well as multiple motorcycle and car enthusiast groups. I am writing to express my disheartened, and dissatisfied 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. 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." I have several issues with this seemingly lacking solution to a potentially hazardous, and vehicle-damaging problem. This proposal would cause even more confusion given the events surrounding the rollout of E15 into the marketplace. The AMA opposes E15 and any fuel containing more than 10 percent ethanol, because it can cause engine and fuel system failure on motorcycles or all-terrain vehicles, and can void manufacturers' warranties. Furthermore, many automobile manufacturers recommend avoiding E15 if possible, which could be interpreted as E15 being damaging in some way to not only small, but automotive engines (which has been proven). 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." --- Overheating is a already a well-known issue for motorcycles, hence their allowance to use the HOV or "carpool" lane on highways. Furthermore, many motorcycles are now being manufactured with plastic compound fairings, which when exposed to high temperatures, are prone to melting, warping, and cracking. Unfortunately, I do not believe this new label will do what it is intended to do --- keep users from inadvertent misfueling with higher ethanol blended fuels. It simply does not provide clear direction. People commonly 'push' instead of 'pull' the door at the gas station by overlooking a clearly displayed "PULL" label in front of their field of view - why would they pay now closer attention at the gas-pump when so many will be unaware of label changes? Another label on a blender pump that already has many labels will not be sufficient to avoid misfueling and, as stated, could be easily overlooked. The proposed rule provides no direction on where on the pump the label should be located. Moreover, the FTC is proposing that the label be rounded to the nearest 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? The proposed rule does not address the central issue that real-world motorcyclists face, and that is that no motorcycle currently on the road is approved for any fuel with higher than 10 percent ethanol, and the risk of inadvertent misfueling is tremendous once higher blends are available at the pump. This is truly a decision that can have damaging effects on motorcycles engines (and other vehicles'). Help protect 22 million motorcycles and all-terrain vehicles in America -- and the riders who depend on their safe operation -- from inadvertent misfueling. All we want is safe access to fuel for our motorcycles and ATVs. Thank you for your time and opportunity to comment on this important issue.