Comments by AIAM on E15 EPA Petition

ARLINGTON, Va., July 20, 2009; The Association of International Automobile Manufacturers (AIAM) filed comments today with the Environmental Protection Agency (EPA) opposing a waiver request that would allow the ethanol content of gasoline to be increased from 10% (E10) to 15% (E15). The following statement was issued on behalf of Michael J. Stanton, President and CEO of AIAM, outlining the association's concerns:

"AIAM and its member companies have long recognized the importance of addressing climate change and have supported efforts to reduce greenhouse gas emissions while significantly increasing fuel economy. With so much progress made by government and industry in recent months to meet these goals, we believe it would be premature for EPA to approve the near-term distribution and sale of fuels containing more than 10% ethanol without further testing to prevent unintended negative consequences.

"The Clean Air Act requires producers of any new fuel or fuel additive to show that those fuels will not contribute to the failure of vehicles or engines to meet emissions standards. Most vehicles currently being driven by American consumers were not designed to operate on ethanol blends greater than E10. If EPA were to approve the sale of such fuels, we believe a range of problems would result that could jeopardize the control or reduction of automotive emissions.

"These problems include the potential for immediate harm to, or failure of, highly calibrated emissions systems that were not designed to operate on such 'mid-level' fuels as E15. Further, many vehicles today are equipped with onboard diagnostic (OBD) systems as part of an integrated emissions control system. Testing to determine how E15 may negatively affect the proper operation of OBD systems is insufficient at this time.

"The consequence of potential equipment malfunctions caused by the use of E15 extends beyond failure to sufficiently control emissions. It will also create a high risk of consumer dissatisfaction due to drivability problems which would needlessly damage product reputation and imperil customer satisfaction with dealer service. Such drivability problems may also tempt consumers to tamper with emission controls in an effort to improve performance. Owner satisfaction may be further jeopardized by the reduction of fuel economy they will experience as a consequence of switching from E10 to E15.

"Another issue yet to be sufficiently studied is the potential negative impact E15 would have on the fuel production, distribution and marketing infrastructure. In particular, EPA should fully evaluate how the addition of a new blend of fuel will affect service station storage and pump systems and the ability of customers to select the right fuel for his or her vehicle.

"AIAM and other industry groups whose products and customers would be affected by the introduction of E15 are working cooperatively with the Department of Energy and the Environmental Protection Agency to conduct the needed studies to assess the impacts of introducing mid-level ethanol blends to the market. These studies have been identified and stakeholders are moving ahead to fill gaps in current knowledge about the practical consequences of increasing the ethanol content in gasoline.

"To approve a waiver before these studies are completed would be premature. We encourage EPA to delay approval of the waiver until sufficient testing has been conducted."

AIAM submission to EPA (PDF)

Direct link: http://www.aiam.org/public/doclibrary/pressreleases/AIAM_E15Comments.pdf

About AIAM -- The Association of International Automobile Manufacturers, Inc. (AIAM) is a trade association representing 13 international motor vehicle manufacturers who account for 40 percent of all passenger cars and light trucks sold annually in the United States. AIAM provides members with information, analysis and advocacy on a wide variety of legislative and regulatory issues impacting the auto sector. The Association is dedicated to the promotion of free trade and to policies that enhance motor vehicle safety and the protection of the environment. Member companies include Aston Martin, Ferrari, Maserati, Honda, Hyundai, Isuzu, Kia, Mitsubishi, Nissan, Peugeot, Subaru, Suzuki and Toyota. For more information, visit our website at www.aiam.org .