Clean Vehicle Education Foundation
Proposed Amendments to the Fuel Rating Rule, FTC File No. R811005
Please see complete comments in the attached file. Comments on Fuel Rating Rule Review, R811005 Comment 1 This comment deals with the value (or energy content) of the fuel received by the public based on its composition and price. See section below “ Fuel Economy Decline with Increasing Ethanol Blend Level in Gasoline”. Based on the information provided in this section it is proposed that the labeling for Mid-Level Ethanol blends state the maximum percentage of ethanol that will be dispensed at the stated price. (e.g. maximum ethanol % of E30 or 30% ETHANOL Maximum. ) By this method the consumer will know lowest energy that may be received at the stated price. If the retailer provides a lower percentage of ethanol than the 30% in the example then the consumer would benefit from the increased energy content and therefore increased fuel economy. The consumer must know the relative energy content of the fuel in order to make an informed purchase decision. Comment 2 This comment relates to the section on labeling as noted below. The concern with fueling vehicles with blends higher than 10% Ethanol deals with the potential failure of the fuel system on the vehicle due to degradation of the elastomers and galvanic corrosion due to dissimilar materials used in its construction. It is well know by the automotive industry that vehicular fuel systems must be modified in order to safely accommodate ethanol blends higher than the existing 10%. It is proposed that the labeling noted below actually FOR FLEX FUEL VEHICLE USE ONLY CHECK OWNER’S MANUAL If and when the EPA may approve the wider use of ethanol blends up 15% Ethanol, it will only be for a subset of newer vehicles and may be restricted from use for other applications (e.g. off road engines).