16 CFR Part 306; Automotive Fuel Ratings, Certification and Posting; Project No. R811005 #00182

Submission Number:
John Hamlyn
Initiative Name:
16 CFR Part 306; Automotive Fuel Ratings, Certification and Posting; Project No. R811005
If the EPA has acknowledged ethanol damages engines why bother proposing new labeling rules for gasoline? The U.S. Environmental Protection Agency has publicly acknowledged that ethanol in gasoline can damage internal combustion engines by increasing exhaust temperatures and indirectly causing component failures. More labeling at the gas pump is not a suitable solution to the problem and in any event this rule should not exempt the U.S. Environmental Protection Agency's E15-approved label. The AMA believes this proposal will cause more confusion given the events surrounding the rollout of E15 into the marketplace. The AMA opposes 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, and can void manufacturers' warranties. The EPA has said that, "[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." I have five working 40+ year old motorcycles. Even e10 is not a suitable fuel for these machines. New labels will not do what it is intended to do -- keep users from misfueling with higher ethanol blended fuels. Another label on a blender pump that already has many labels will not be sufficient to avoid misfueling and could be easily overlooked. Help protect the 22 million motorcycles and all-terrain vehicles in America -- and the riders who depend on their safe operation -- from inadvertent misfueling. Give us access to the proper fuel for our machines.