EPA Can Go Further than E15
The Urban Air Initiative submitted comments to the EPA supporting the agency’s proposal to make E15 available year round. While this is a critical step forward and needs to happen, UAI asked EPA to not stop at E15 and provided detailed analysis as to why the law allows higher blends to be made available under this rule. Several of Urban Air’s supporters joined these comments as well.
The way the rule is proposed, the Reid vapor pressure waiver (RVP) would only be extended to E15. It would take additional waivers in the future to access additional blends, a process that could take years.
In the comments filed, UAI explains why EPA’s 15% limit is based on a misinterpretation of another provision, the Clean Air Act’s sub-sim law. EPA interprets the sub-sim law to limit the concentration of ethanol in gasoline to no more than 15% ethanol. Yet since ethanol is now included in certification fuel, it does not need a sub-sim waiver anymore and higher blends should be allowed.
UAI also makes the case that EPA’s own testing shows higher blends including E20 have the same characteristics as E15, so there is no justification for the agency to limit the waiver. In fact, the higher the blend, the more vapor pressure is reduced and capping ethanol at 15% denies a range of environmental, energy, and economic benefits.
Again, UAI supports the expansion of year round E15, but believes the EPA can go further to remove unnecessary barriers limiting ethanol expansion. Providing access to mid-level blends like E20 and E30 would not only meet President Trump’s goal of helping farmers, it would give consumers the chance to choose a cleaner fuel that is better for the environment.
In addition to the comments filed by UAI and its supporters, UAI also joined comments by Farmers Union Enterprises, the National Farmers Union, and the Clean Fuels Development Coalition as well as several other organizations.