16 CFR Part 306; Automotive Fuel Ratings, Certification and Posting; Project No. R811005 #00330

Submission Number:
Eoin Davis
Initiative Name:
16 CFR Part 306; Automotive Fuel Ratings, Certification and Posting; Project No. R811005
I support the proposed label revisions which would warn consumers to use certain ethanol blends only in Flex-Fuel Vehicles, and to warn of possible damage to other vehicles. I cannot tell, however, whether such labeling would, under this proposed rule, apply to all gasoline which actually containes more than 10% ethanol (by volume), or whether there are circumstances under which fuel with between 10 and 15% ethanol could be marketed without these warnings. Thus, I clarify my comment to express my support for labeling ALL gasoline which actually contains more than 10% ethanol as being for use in FFVs only. I also agree with the labeling change which would more precisely identify the amount of ethanol in various gasoline-ethanol blends above 10% ethanol (within 10 percentage points as I understand the current proposal). While I prefer a tighter window than 10 percentage points, I can live with that wide an allowance for now. My support for this provision is two-fold. First is the late-model, emissions-controlled motorcycle for commuting roughly 80 miles per day. It is extremely fuel efficient, returning me 70 to 75 mpg, but the manufacturer warns most strongly against the use of ethanol blends greater than 10%. I do not wish to have this vehicle slowly destroyed by surreptitious inclusion of too much alcohol in the fuel I purchase. My household's automobile also warns of warranty denial if more than 10% ethanol is used. It is not right for either EPA or FTC to allow that to happen if simple labeling would allow me to avoid it. Secondly, I believe there is opportunity for the willing and dedicated hobbyist to improve thermodynamic efficiency of their engines _without_ compromising emissions performance, by tuning them expressly for higher alcohol content fuels. Such tuning would in my view include increased compression ratios, necessitating a higher anti-knock index. At present, it is almost impossible for a consumer to determine how much alcohol is present in a fuel blend above 10%, and therefore it is marginal at best to attempt such improvements. Having an octane rating (AKI) on the label along with the alcohol content would be extremely beneficial to anyone wishing to mitigate or potentially even reverse the increased fuel usage by engines designed for straight gasoline but operating on alcohol blends. Concerning the IR test method for establishing octane rating, I agree with approving the method, but I do not agree with the lack of engine testing as the 'referee test' for conflict or dispute resolution. I support allowing the IR technology because of my hope that it will increase testing and compliance, and reduce poor-quality gasoline. Although fraud may remain, hopefully it will also help my home state of Arizona's Bureau of Weights and Measures to improve compliance inspection presence, and thus deter fraud. I think the FTC should retain engine testing as the 'referee test,' however, because in the end the goal is to provide consumers with a level of assurance of actual in-use knock resistance. Performance in engines is the goal, and is therefore the standard against which the IR testing has been validated. Furthermore, it concerns me that the potential to 'game' an IR-only compliance system would be far easier than 'gaming' engine testing. I can envision a number of ways to manipulate an infra-red signature, so it appears to me that an unscrupulous operator would find it trivial to make their fuels pass IR testing, while remaining distinctly deficient in actual use in engines. Therefore, I urge you to reconsider the elimination of engine testing (ASTM D2699 and D2700) altogether when IR testing is used. Thank you for considering my comments, and for improving the labeling and transparency of motor fuels for us.