Saturday, December 11, 2010

My Response to the EPA: E15 sign

The EPA recently granted a waiver request to allow the use of E15 in vehicles model year 2007 and newer. It published a proposed rule that is now open for public comment regarding how E15 will be labeled.

With the help of American Coalition for Ethanol -

I wrote the following and would like to share it with you all.

Air and Radiation Docket EPA-HQ-OAR-2010-0448, EPA, 

Subject: Comments on Proposed Rule on E15 Labeling (EPA-HQ-OAR-2010-0)
As an ethanol enthusiast, I use a 50/50 mixture of E85 fuel and gasoline in my non-flex fuel vehicle - 2005 Honda Civic. My car runs strong and I am substantially reducing green house gas emissions, while reducing my dependence on fossil fuels.

However, it is not good enough that I am just reducing carbon emissions. In effort to promote a sustainable future that reduces climate change, more people must use higher levels of high octane ethanol in their vehicles. As a result, E15 must be a necessary CHOICE at the pump! New studies show that E15 is completely SAFE for all gasoline engine vehicles, not just 2007 and newer vehicles. Stop adding artificial barriers that prevent customers from choosing ethanol!

Customers must have the right to choose ethanol, without fear and irrational linkages to problems that have no relation to the product. This is why the E15 warning sign should NOT be ORANGE!

Labeling policies should be fair; ethanol and other non-petroleum fuels should not be held to higher standards than petroleum-based fuels.

The color of the proposed label, orange, is typically used for warning or alarm, not informational use. EPA should follow the same guidelines as were used for labels on diesel pumps, and require only that the fuel be identified in a particular font size on a contrasting background.

I believe that the label should be in green and white, with white letter font on a green background and should read, "E15 is safe for all gasoline engine vehicles and helps to reduce green house gas emissions."

In the proposed label, the word "CAUTION!" presents an excessive tone of urgency. No such warning is required for any other fuel, and should not be required of E15.

The phrase "This fuel might damage other vehicles" is unwarranted, as EPA does not have the testing data to make such a statement. By stating that E15 “might” cause damage, EPA is essentially validating unsubstantiated claims of ethanol opponents.

Lastly, there should be an educational sign next to all E15 pumps that explain the BENEFITS of using E15, with regard to its high octane level and reducing carbon monoxides, carbon dioxide, and hydrocarbons. The EPA should also list its website and 1800-number on the sign for consumers.


Kai Nortey

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