U.S. & International Auto Makers Oppose E15 Fuel Waiver

Jul 20: Despite the recent support announced by 10 Midwestern governors supporting the proposal [See WIMS 7/17/09] that ethanol blending levels be increased from 10 to 15 percent (i.e. E15 Waiver), the Association of International Automobile Manufacturers (AIAM) filed comments to U.S. EPA opposing the waiver request. EPA extended the comment period by 60 days to July 20, 2009, on a waiver application submitted by Growth Energy and 54 ethanol manufacturers on March 6, 2009 [See WIMS 5/15/09].

Michael Stanton, President and CEO of AIAM, issued a statement saying, "AIAM and its member companies have long recognized the importance of addressing climate change and have supported efforts to reduce greenhouse gas emissions while significantly increasing fuel economy. With so much progress made by government and industry in recent months to meet these goals, we believe it would be premature for EPA to approve the near-term distribution and sale of fuels containing more than 10% ethanol without further testing to prevent unintended negative consequences.

"The Clean Air Act requires producers of any new fuel or fuel additive to show that those fuels will not contribute to the failure of vehicles or engines to meet emissions standards. Most vehicles currently being driven by American consumers were not designed to operate on ethanol blends greater than E10. If EPA were to approve the sale of such fuels, we believe a range of problems would result that could jeopardize the control or reduction of automotive emissions. These problems include the potential for immediate harm to, or failure of, highly calibrated emissions systems that were not designed to operate on such 'mid-level' fuels as E15. Further, many vehicles today are equipped with onboard diagnostic (OBD) systems as part of an integrated emissions control system. Testing to determine how E15 may negatively affect the proper operation of OBD systems is insufficient at this time.

"The consequence of potential equipment malfunctions caused by the use of E15 extends beyond failure to sufficiently control emissions. It will also create a high risk of consumer dissatisfaction due to drivability problems which would needlessly damage product reputation and imperil customer satisfaction with dealer service. Such drivability problems may also tempt consumers to tamper with emission controls in an effort to improve performance. Owner satisfaction may be further jeopardized by the reduction of fuel economy they will experience as a consequence of switching from E10 to E15.

"Another issue yet to be sufficiently studied is the potential negative impact E15 would have on the fuel production, distribution and marketing infrastructure. In particular, EPA should fully evaluate how the addition of a new blend of fuel will affect service station storage and pump systems and the ability of customers to select the right fuel for his or her vehicle. AIAM and other industry groups whose products and customers would be affected by the introduction of E15 are working cooperatively with the Department of Energy and the Environmental Protection Agency to conduct the needed studies to assess the impacts of introducing mid-level ethanol blends to the market. These studies have been identified and stakeholders are moving ahead to fill gaps in current knowledge about the practical consequences of increasing the ethanol content in gasoline. To approve a waiver before these studies are completed would be premature. We encourage EPA to delay approval of the waiver until sufficient testing has been conducted."

AIAM represents 13 international motor vehicle manufacturers who account for 40 percent of all passenger cars and light trucks sold annually in the U.S. Member companies include Aston Martin, Ferrari, Maserati, Honda, Hyundai, Isuzu, Kia, Mitsubishi, Nissan, Peugeot, Subaru, Suzuki and Toyota.

Similarly, the Alliance of Automobile Manufacturers (Alliance), representing 11 vehicle manufacturers including BMW Group, Chrysler Group LLC, Ford Motor Company, General Motors, Jaguar Land Rover, Mazda, Mercedes-Benz USA, Mitsubishi Motors, Porsche, Toyota and Volkswagen; also opposes the waiver. The Alliance said specifically, "The Alliance asks EPA to deny this waiver application, in whole and in part, because insufficient data are available to determine whether the proposed fuel blend(s) can satisfy the legal requirements under the Clean Air Act section 211(f)(4). The Alliance intends these comments to be read in conjunction with comments being submitted separately by the Alliance for a Safe Alternative Fuels Environment (AllSAFE), of which the Alliance is a member. The AllSAFE comments discuss more fully our concerns regarding the concept of a partial waiver. We incorporate the AllSAFE comments here by reference."

The Alliance said further in its details comments, "Historically, EPA has never allowed conventional vehicles to use gasoline blends with more than 10% ethanol. Until very recently, neither auto manufacturers nor others had a reason to design, test or warrant conventional vehicles (intended for the U.S. market) for use with higher ethanol blends. As a result, the public and private data bases are very limited. The application presents a serious concern for automakers and consumers. It is asking for approval of ethanol blends for which the vast majority of the current fleet and the near term future fleet have not been designed or validated. Flexible Fueled Vehicles (FFVs) can handle any ethanol blend from E0 to E85, and while their numbers are growing rapidly, they still represent a minority of the fleet."

In announcing their support for the waiver, the Midwest Governors indicated that allowing greater blending levels would increase demand for conventional ethanol, an entirely domestic energy source. Michigan Governor Jennifer Granholm, chair of the Midwestern Governors Association (MGA) said, “The Midwest has vast natural resources, the scientific know-how, and the skilled workforce necessary to lead the world in the production of climate-friendly biofuels. We must capitalize on these strengths in order to promote the use of low carbon fuels across the country.”

Access a release from AIAM (click here). Access AIAM's 35-page comment submission (click here). Access the detailed 76-page comments from the alliance (click here). Access the EPA Docket for the E15 Waiver for all documents to review all comments (click here). Access the release from the Governors (click here). Access additional information from EPA's website (click here).