By Wayne Allard The American Motorcyclist Association opposes the U.S. Environmental Protection Agency’s proposed Renewable Volume Obligations rule for 2014, 2015 and 2016. As an association that represents 214,000 motorcyclists nationwide, the AMA urges the EPA to not increase, and, instead, lower the proposed volumes when the final rule is issued on Nov. 30.  

The higher volumes of ethanol in the proposed rule would increase the risk of inadvertent misfueling for motorcyclists and all-terrain-vehicle owners by forcing the widespread availability of higher-ethanol fuel blends, such as E15.  

Those increases would come despite the EPA’s acknowledgement that the market cannot absorb these higher ethanol production rates. In a regulatory announcement released Aug. 6, 2013, “EPA Finalizes Renewable Fuel Standards,” the agency stated that it “does not currently foresee a scenario in which the market could consume enough ethanol sold in blends greater than E10.”  

The practical effect of the EPA’s action is that ethanol production will exceed the “blend wall,” the point at which no more ethanol can be mixed into the nation’s fuel supply without resulting in blends higher than 10 percent. That means more E15 and less E10 (and E0) on the market.  

In fact, the proposal calls for the changes needed to significantly expand renewable fuel use to include an increase in E15 use in model year 2001 and later vehicles and an increase of E85 use in flex-fuel vehicles.  

Moreover, the proposed rule calls for stakeholders to overcome market barriers to expand the use of renewable fuels to meet the 2016 standards by:  

• “Increasing the number of retail stations offering E15 and E85 through direct installation of new equipment or providing grants to retail owners, and locating stations offering E15/E85 closest to higher populations of vehicles that can use those fuels.”
• “Developing contractual mechanisms to ensure favorable pricing of E15 and E85 at retail compared to E10 to boost sales volumes.”  

In other words, the EPA is proposing federal grants and price controls to increase the amount of the higher-than-E10 fuels in the marketplace.  

The AMA strongly disagrees with this approach. Instead, the market should dictate demand and the consumer should choose the proper fuel for each vehicle.  

In the proposed rule, the EPA discounts E0 and does not factor it in its scenarios. The EPA views E0 as a “constraint on the volume of ethanol that can be consumed … and expect(s) such volumes to be lower than they were in the past as the market strives to expand consumption of ethanol under the influence of the RFS program.” Yet the federal Energy Information Administration found that demand for E0 rose from 3.4 percent in 2012 to nearly 7 percent in 2014. Consumers want E0 for their motorcycles, ATVs and other engines, because it does not pose the risk of engine and fuel system damage. Yet, the renewable fuels requirements have marginalized that product in favor of E10 or higher blends.  

Most importantly, the proposed rule mentions the likelihood of misfueling only once: “…in June of 2011, the EPA finalized regulations to prevent misfueling of vehicles, engines, and equipment not covered by the partial waiver decisions.” This is the same misfueling mitigation plan that initially mandated a 4-gallon minimum fuel purchase to address the concerns raised by the AMA. It was eventually revised in 2013 to the current plan, yet it is still easily misunderstood, misapplied or ignored by state governments and producers, distributors and vendors.  

With the misunderstood and unenforced misfueling plan and the proliferation of E15 in the marketplace, especially through blender pumps, motorcyclists and ATV riders face an increased risk of unknowingly fueling their vehicles with a blend higher than the federally approved E10.  

This is troubling, because the EPA has publicly acknowledged that ethanol in gasoline can damage internal combustion engines by increasing exhaust temperatures and indirectly causing component failures. The statements are found in a 2014 Federal Trade Commission rule proposal regarding a new label for pumps.  

Indeed, the EPA has made it illegal for motorcyclists and ATV users to use E15 fuel and yet seems to have little interest in the misfueling issue. It seems the EPA’s proposed rule does not consider the concerns of motorcyclists and ATV owners, despite knowing that none of the estimated 22 million motorcycles and ATVs in use in the United States is approved to use E15 or higher ethanol blends.  

Former U.S. Sen. Wayne Allard is vice president of government relations for the American Motorcyclist Association.  

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