PUBLIC SUBMISSION | As of: November 20, 2009 Tracking No. 809f37bb Comments Due: July 20, 2009 |
Docket: EPA-HQ-OAR-2009-0211
Notice of Receipt of a Request for a Clean Air Act Waiver to Increase the Allowable Ethanol Content of Gasoline to 15 Percent
Comment On: EPA-HQ-OAR-2009-0211-0713
Notice of Receipt of a Clean Air Act Waiver Application To Increase the AllowableEthanol Content of Gasoline to 15 Percent; Extension of Comment Period
Document: EPA-HQ-OAR-2009-0211-2427
Comment submitted by D. Billing
In EISA 2007, Section 202, the Administrator of the Environmental Protection
Agency is directed "... to ensure that transportation fuel sold or introduced
into commerce in the United States (except in noncontiguous States or
territories), on an annual average basis, contains at least the applicable
volume of renewable fuel ... determined in accordance with subparagraph (B)" and
the table in subparagraph (B) lays out the ethanol production quota for each
year from 2008 until 2022:
Applicable
volume of
renewable
fuel
Calendar year: (in billions of
gallons):
2006
.............................................................................. 4.0
2007
.............................................................................. 4.7
2008
.............................................................................. 9.0
2009
.............................................................................. 11.1
2010
.............................................................................. 12.95
2011
.............................................................................. 13.95
2012
.............................................................................. 15.2
2013
.............................................................................. 16.55
2014
.............................................................................. 18.15
2015
.............................................................................. 20.5
2016
.............................................................................. 22.25
2017
.............................................................................. 24.0
2018
.............................................................................. 26.0
2019
.............................................................................. 28.0
2020
.............................................................................. 30.0
2021
.............................................................................. 33.0
2022
.............................................................................. 36.0
It is clear from the table that the implication for ethanol blending is not to
make E10. When a normal person reads the rest of the Act it is obvious that the
intent of the Act is to produce and distribute E85 for Flex-Fuel cars. All of
the tax incentives and corporate welfare offered is for E85. There is no
mention of E10 in the Act and it does not purport to be a mandatory E10 law.
It is common knowledge that ethanol in gasoline at the 10% level causes
widespread damage in the marine and small engine industry. Many people have
commented on that fact in this waiver NPRM and numerous articles in the media
bear this out. E10, or higher, is a hazard to public safety. With the
accelerating spread of E10 into all of the gasoline in the country, people's
lives will be at stake.
Look at the production demands for 2011 - 2013. The quantity of ethanol
demanded will take every drop of gasoline in the US E10. That is the "Blending
Wall". Allowing E15 will only delay the blending wall a year or two at most,
with the increased likelihood of much wider property damage and threat to public
safety. And after 2014 or 2015 only a massive increase in E85 production will
use the ethanol proposed.
When only E10 or E15 is made in the US, the product coming from refineries will
be blending product to make E10. It is called BOB. As the Director of the
Division of Air Resources, New York State Department of Environmental
Conservation said in his comment, "The petroleum based blendstock, in most
cases, would not qualify as gasoline or be legal to sell as gasoline." When
that obtains, the marine, aviation and public safety industry will not be able
to get the gasoline necessary for safe operation.
Is the EPA prepared for the liability and litigation that will ensue from their
decision to allow all of the gasoline in the country to go E10 or higher?
Liability will rest directly with the department since it is tasked with
implementing the deeply flawed RFS mandate.
The EPA should deny the waiver petition and immediately prohibit the blending of
ethanol in all premium unleaded gasoline in the country so that public safety
agencies, marinas and airports can get the fuel they need. How many people must
die because a generator, a pump, a chain saw, the jaws of life, etc. didn't
start or crapped out at the wrong moment. Ethanol blended gasoline may be made
to work in a computerized fuel injected car, but it has no business in any other
kind of engine and the ethanol and oil industry knows it.