AllSAFE To EPA: Deny Growth Energy E-15 Partial Waiver Request


The Alliance for a Safe Alternative Fuels Environment (AllSAFE), Alexandria, Va., which speaks for manufacturers on fuel-related legislation representing 400 million products including motor vehicles, has voiced its official concern to the Environmental Protection Agency (EPA) about Growth Energy’s fuel waiver application for E-15.


AllSAFE also is concerned because the EPA expanded the waiver request to include “bifurcating” the fuel supply, or allowing two fuels (E-10 and E-15) in the marketplace at one time.  


“AllSAFE’s comments clearly establish that E-15 has not been sufficiently tested and poses a hazard that could potentially bring physical endangerment to consumers,” said Kris Kiser, spokesman for AllSAFE. “With the additional concern of a ‘bifurcated’ fuel supply, the EPA has not evaluated all the complex issues, such as misfueling, which again, leads to permanent damage of non-road equipment and older vehicles and poses a risk of personal harm to the consumer. These concerns deserve a full evaluation through the proper section of the federal Clean Air Act and should not be insufficiently addressed through a fuel waiver request.”


The company asked the EPA to comment on the partial waiver concept that would be based on bifurcating the national production, distribution, blending and marketing of separate E-10 fuels (for non-road products and older automobiles) and then offering E-15 fuels for newer automobiles. If this was put into practice consumers would be faced with two fuel pumps at the station- one with E-10 and one with E-15.


“AllSAFE has strongly cautioned the EPA against such a measure since consumers could be confused and possibly use the wrong fuel, especially if they see that E-15 is cheaper and choose that blend rate to save money,” said Kiser.


AllSAFE pointed out that EPA’s attempt to offer leaded and unleaded fuels using two separate pumps was not completely successful. Even with education and physical barriers against misfueling, it still occurred with 13.5 % of vehicles needing unleaded gasoline (based on EPA’s own misfueling study).


With no physical barrier and a price differential that would encourage misfueling, the potential for physical harm to consumers must be addressed before bifurcation is considered, AllSAFE noted.


AllSAFE’s also noted that from a legal and public policy standpoint, the EPA cannot approve any partial mid-level ethanol fuel waiver until the EPA has completed a separate rulemaking process under section 211(c) to prevent misfueling.


In 2007, Congress expanded and strengthened Section 211(f)(4), which specifically directed EPA to only approve a fuel waiver if all non-road and on-road engines or vehicles would not be adversely impacted with regard to their applicable emission standards. Yet, Section 211(f)(4) does not create the legal authority for EPA to establish a “partial waiver” based on a bifurcated fuel concept, AllSAFE noted.


To read AllSAFE’s comments to the EPA, visit or




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