16 CFR Part 306; Automotive Fuel Ratings, Certification and Posting; Project No. R811005
As a member of the American Motorcyclist Association, I am writing to express my 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." This proposal would cause even more confusion given the events surrounding the rollout of E15 into the marketplace. According to the EPA, ethanol can have significant negative impacts on engines, and most particularly on motorcycles and off-road vehicles. I oppose selling fuels that contain 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. The proposed labeling requirement will no-- keep users from inadvertent misfueling with higher ethanol blended fuels. It simply does not provide clear direction. 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. 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 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. 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.