I sent yet another letter to the EPA today. This one was on the ruling that is expected soon from the EPA on raising the maximum allowable blend of ethanol from the current 10% to 15%.
This would seem to be a simple issue. After all, ethanol is renewable and is sourced in the U.S. So swapping ethanol for gasoline reduces our reliance on foreign and non-renewable oil. (As a plus, it also lowers emissions.)
But as with many things it is not quite so simple after all.
Firstly, growing the animal food-grade corn that is used to distill most U.S. sourced ethanol itself consumes petroleum.
Secondly, diverting this corn to an ethanol product can push up food prices.
Thirdly, vehicles using E15 will get lower mileage. (The energy content of E15 is less.)
Finally—and this is the biggy—no one seems quite sure what increasing the amount of ethanol in fuel will do to fuel systems and engines. Ethanol absorbs water and is a corrosive solvent. Not a problem if you don’t leave the fuel sitting for months and are driving a vehicle that was designed for higher ethanol content fuels. But what about older vehicles, marine engines, lawn mowers, etc.?
The EPA is conducting testing on the use of E15, but the plan is to issue a ruling before these tests are completed. (Don’t ask why. Well actually, there is one good reason: The corn lobby wants this badly.)
Our point to the EPA is that it is not fair to ask consumers to shoulder the risks associated with E15. At the very least, it should be offered as an option, not a requirement. And pumps with E15 should have a warning label so consumers choosing E15 are aware of the pros and cons.
My letter to the EPA:
September 28, 2010
Dear Administrator Jackson,
As you prepare to issue a ruling on the ethanol industry's request to raise the so-called ethanol blend wall to permit U.S. gasoline to be diluted with as much as 15% ethanol, up 50% from the present maximum level, we at Edmunds.com feel it incumbent upon us to point out that your decision immediately impacts consumers. We strongly believe that consumers should be given the opportunity and the education to make informed choices.
We recognize that ethanol has its benefits, most notably that it is a domestically produced renewable fuel that can help bolster national energy security and reduce our $500-billion-a-year dependence on imported oil.
However, a great debate exists regarding the impact of an E15 blend on many of the engines that would use it. Damage to those engines from a higher blend of ethanol – a corrosive form of alcohol – would impose a substantial burden on consumers. We find it surprising that the EPA is proposing to act on its "blend wall" ruling months in advance of the scheduled completion of tests of so-called mid-level blends by your own researchers as well as by the Department of Energy. Without this information, the issue of E15's impact can be debated but not resolved, and it is unfair to ask consumers to become the guinea pigs.
Consumers may also suffer a financial burden because ethanol is less efficient than gasoline, reducing the energy density of the gasoline it dilutes. In other words, it takes more ethanol to go the same distance as regular gasoline, and so consumers may have to buy more fuel if the ethanol concentration is increased.
Our strong recommendation is that your agency waits to make a final decision until all the test information is in next year. If you must issue a ruling now, then we believe that use of E15 ethanol could be permitted, but as an additional grade of motor vehicle fuel available as an option along with the present formulations rather than as their replacement.
We understand this could create an initial financial burden on retail fuel suppliers, who would have to have separate storage for the two fuels. But we note that the EPA is considering approving E15 for only post-2001 model year vehicles. That, too, would necessitate separate E15 and E10 pumps and storage. Our proposal is certainly no more onerous.
Providing the fuel as an option also would avoid penalizing those with older motor vehicles, as well as many motorcycles and non-vehicular equipment such as lawn mowers, snow blowers and emergency generators that must use gasoline but are clearly not designed to operate with higher levels of ethanol or other alcohol fuels. If consumers with these needs are not given any option other than E15, who will be responsible for the engine damage that they are likely to suffer?
If allowed at all, E15 should an option, not a replacement, and the EPA should plan to educate consumers on the pros and cons of ethanol so that informed choices can be made. Edmunds.com certainly plans to do its part to educate consumers.
Sincerely,
Jeremy Anwyl
Chief Executive Officer
Edmunds.com
