Expanding beyond E10 is essential if the goals of the Renewable Fuels Standard as passed by Congress are to be successful.  Providing for the use of E15 blends is a step that is required, along with the continued expansion of higher level blend infrastructure.  The importance of EPA’s current considerations of E15 blends cannot be understated, and that is why we share some of the concerns outlined by members in this letter.

We agree with the Chairmen and Ranking Members that there are important questions that EPA must address.  Specifically, we have long sought the same information that these members are seeking about any testing EPA has on the effects of E15 on vehicles older than 2001.  The Agency’s apparent decision to limit potential E15 use to vehicles 2001 and newer before any testing is finalized seems to be a political rather than scientific predetermined outcome.

We also agree that there are challenges with market confusion should EPA limit an E15 waiver to newer vehicles only.  Such a decision needlessly limits the benefits of increasing ethanol use to 15%, but also creates potential headaches for gasoline marketers and consumers alike.  That is why, in part, the RFA joined with leading gasoline marketing and retailing trade associations to support the Renewable Fuels Marketing Act introduced by Reps. Mike Ross of Arkansas and John Shimkus of Illinois.

These concerns, together with the repeated calls for delay in E15 testing by Big Oil and some on Capitol Hill, have prompted the RFA to join with the National Corn Growers Association and the American Coalition for Ethanol to urge EPA to allow for the use of E12 immediately.  Current fuel stacking rules already enforced by EPA allow for the blending of up to 12% oxygenate (ethanol is by definition an oxygenate) in a gallon of gasoline.  As such, E12 blends and the corresponding ~3 billion gallons of new potential market demand

Significant testing has already occurred to assess the safety of higher level ethanol blends.  Those results from the Department of Energy and other academic and private testing institutions all show that there are no significant issues with the use of E15 in all vehicles.

Ultimately, we believe the science demonstrates the efficacy of ethanol blended fuels.  As such, this becomes a question of priorities.  While millions of gallons of oil pollute the Gulf and now are polluting the waterways of Michigan, the nation should be looking to increase its investment in and use of renewable alternatives like ethanol.  Calls from Big Oil, the obstructionist environmental community, and some members of Congress for additional testing beyond what is required by law are more hindrance and stalling tactics than genuine concern.  If we had spent half as much time testing deep water oil drilling technology as we have ethanol blends, we likely wouldn’t have the disaster we have today.