16 CFR Part 306; Automotive Fuel Ratings, Certification and Posting; Project No. R811005
I have a 2009 Subaru Legacy with a "PZEV" four cylinder engine. This engine is tuned to run lean to obtain the EPA's PZEV certification. The car's catalytic converter failed at approximately 60,000 miles, again at just over 100,000 miles and was finally subject to a recall for a problem Subaru finally recognized as effecting the vehicle's emission system fleet-wide. As part of the repair, the ECU was "re-programmed" and my average fuel economy dropped from 28 to 24. This issue is directly related to the increased alcohol content in gasoline combined with stringent emissions regulations to obtain a PZEV certification. I also am a motorcyclist and, based on my personal experience and research, ethanol in amounts greater than 10% will void my vehicles' warranties and lead to earlier failure of components greatly increasing my cost of ownership. Ethanol is not compatible with the materials in my motorcycles' fuel systems. This leads to premature failure and possible fire if a fuel line should rupture and spray gas on a hot exhaust pipe. Labeling E15 on the pump will only confuse most consumers who can't understand the current labeling on gas pumps. This will lead to mis-fueling issues with vehicles incompatible with E15. Ethanol production has led to myriad other issues, including: The diversion of farm land to grow corn rather than other crops; the use of corn as a fuel rather than a food for humans and animals, leading to higher food prices; exhaustion of farm land that should rotate and lie fallow; the overuse of fertilizers that end up being washed into streams and rivers; the use of fossil fuels to grow crops to create ethanol to, supposedly, reduce emissions. Levels of ethanol in gasoline should not be increased above the current 10% available in most markets. There's just no reason to do it and many valid reasons against such a change. Thank you for considering my comments.