A model E15 misfueling mitigation plan (MMP) developed by the Renewable Fuels Association (RFA) to serve as a template in obtaining E15 partial waivers was approved by the EPA and is now being used by ethanol manufacturers to satisfy their MMP requirements.
In January 2011, the EPA partially approved a waiver request from 54 ethanol manufacturers to increase the allowable percentage of ethanol in ethanol-gasoline blends to up to 15 percent for model 2001 and newer cars, light-duty trucks, and SUVs. The Agency followed in June 2011 with a final rule intended to provide some assurance that consumers would be properly informed of E15 service station pumps to avoid misfueling. In March 2012, the EPA told the RFA that its model E15 MMP would generally be sufficient to satisfy the E15 partial waivers’ requirement for an MMP. In May 2012 the EPA approved the first MMP submissions from companies to satisfy the MMP requirement.
Three MMP requirements
The RFA’s model MMP is intended to reduce the potential of E15 being used in engines, vehicles, and equipment for which waivers have not been granted. The model MMP addresses the following three waiver conditions:
- Labeling. Reasonable measures for ensuring that any retail fuel pump dispensers that are dispensing a gasoline produced with greater than 10 volume percent ethanol and no more than 15 volume percent ethanol are clearly labeled to ensure that consumers do not misfuel the waivered gasoline-ethanol blend into vehicles or engines not covered by the waiver.
- Product transfer documents. Reasonable measures for ensuring that product transfer documents accompanying the shipment of a gasoline produced with greater than 10 volume percent ethanol and no more than 15 volume percent ethanol properly document the volume of ethanol.
- Survey. Participation in a survey of compliance at fuel retail dispensing facilities. This section of the model MMP also describes additional retailer education and outreach efforts to support the survey.
The EPA also requested that the companies provide information about the potential use of blender pumps for dispensing E15. Along with several other companies, the RFA responded by submitting an addendum to its Retailer Handbook (which is referenced in the Model MMP), which describes several configurations of pumps and suggests strategies for providing appropriate ethanol concentrations and clear labeling for E15.
The RFA’s Model E15 Misfueling Mitigation Plan and related information on EPA’s E15 regulatory activity are at http://www.epa.gov/otaq/regs/fuels/additive/e15/e15-mmp.htm#plan.