The Environmental Protection Agency’s (EPA) announcement yesterday that it was delaying a decision on the waiver to approve 15% ethanol blends raised more questions than it answered.

Specifically, the Renewable Fuels Association (RFA) today sought more clarification from EPA on its apparent focus on vehicles model year (MY) 2001 and newer. Such a limitation could potentially limit once again the market for ethanol by excluding some 40% of the vehicle market and causing both consumer confusion and retailer unwillingness to offer the product.

In its letter, the EPA stated, “Although all of the studies have not been completed, our engineering assessment to date indicates that the robust fuel, engine and emissions control systems on newer vehicles (likely 2001 and newer model years) will likely be able to accommodate higher ethanol blends, such as E15.”The RFA wrote EPA Administrator Lisa Jackson today seeking more details on this apparent limitation to the waiver. In its letter, the RFA raised concerns about limiting any potential waiver to vehicles MY2001 and newer.

“…we are concerned about the Nov. 30 letter’s apparent announcement that EPA is considering approval of E15 only for vehicles model year (MY) 2001 and newer,” RFA President Bob Dinneen wrote. “Nowhere in previous public statements has EPA detailed any rationale for such a limitation. All of the data of which we are aware demonstrates no adverse effects of higher-level blends in any vehicles, regardless their vintage. In fact, research the Renewable Fuels Association (RFA) conducted with the State of Minnesota on 20% ethanol blends uncovered no issues with respect to materials compatibility or driveability in the older vehicles tested.”

Dinneen went on to highlight two specific areas of concern:

“First, it would effectively limit the use of E15 to just roughly 60% of the American passenger vehicle and light-duty truck fleets. Under this scenario, the increase in potential new market demand would be approximately 4.2 billion gallons, compared to the estimated market increase of 7 billion gallons for a full E15 implementation. As such, an allowance for E15 in only MY2001 and newer vehicles would do little to raise the “blend wall” or facilitate satisfaction of RFS volumetric requirements in the mid-term.

“Secondly, such a bifurcation would create unnecessary and burdensome requirements for fuel retailers, as well as confusion for consumers. It is unlikely that retailers would be willing to offer both an E15 blend for newer model vehicles and E10 or less for older models. This scenario could effectively result in no increase in ethanol use, despite an approval of higher level blends.”

In order to clarify these looming concerns, the RFA is asking EPA for more information:

“With these concerns in mind, I am requesting that EPA staff provide the proper documentation and rationale behind the perceived need for this potential bifurcation of the vehicle and fuel markets.

“The industry is heartened by the apparent positive reception the agency is giving to the move to higher level ethanol blends, but concerns and questions persist. Again, we applaud your agency’s diligent efforts on mid-level blends, commitment to sound science and focus on solutions for lifting the decades-old regulatory cap on E10 blends. I look forward to continuing the dialogue with EPA, addressing the issues raised in this letter, and moving America’s biofuels industry forward.”