Four-gallon minimum fuel mandate: EPA fails to meet deadline in response to congressional letter seeking answers

On Sept. 10, the U.S. House Committee on Science, Space and Technology sent a letter to the U.S. Environmental Protection Agency addressed to Administrator Lisa Jackson. The congressional letter is seeking answers from the EPA on its recent decision to mandate consumers purchase at least four gallons of fuel from certain blender pumps that dispense both E15 and E10 gasoline-ethanol blends. To date, no manufacturer has introduced a mass production motorcycle or all-terrain vehicle designed to operate on E15 fuel.

The letter had a Sept. 24 deadline to respond. To date, the EPA has not responded to the congressional letter.

As the American Motorcyclist Association previously reported, the EPA revealed the requirement to the AMA in a letter dated Aug. 1, responding to AMA concerns that E15 — a gasoline formulation that contains up to 15 percent ethanol by volume – could be put in motorcycle and ATV fuel tanks inadvertently when consumers use blender pumps. A blender pump dispenses different fuel blends through the same hose.

“With E15 gasoline, our members who make a concerted effort to fuel their motorcycles or ATVs with E10-or-less gasoline may be unknowingly refueling with residual fuel left in the hose,” Wayne Allard, AMA vice president for government relations, wrote in a June 20 letter to Jackson.

“Unlike an automobile or SUV with a large fuel tank, the residual fuel left in a fueling hose could be detrimental to the performance of motorcycle or ATV engines due to the small size of their fuel tanks and the higher concentration of ethanol that would, therefore, be present in the fuel,” Allard wrote.

“In addition, the use of E15 will lower fuel efficiency and possibly cause premature engine failure,” he wrote. “Use of E15 fuel voids many manufacturer warranties. In off-road engines, the effects can even be dangerous for users.”

Byron Bunker of the EPA National Vehicle and Fuel Emissions Laboratory responded to the AMA on behalf of Jackson.

“EPA requires that retail stations that own or operate blender pumps either dispense E15 from a dedicated hose and nozzle if able or, in the case of E15 and E10 being dispensed from the same hose, require that at least four gallons of fuel be purchased to prevent vehicles and engines with smaller fuel tanks from being exposed to gasoline-ethanol blended fuels containing greater than 10 volume percent ethanol,” Bunker wrote.

“Additionally, EPA is requiring that retail stations that offer E10 and E15 from the same hose and nozzle use additional labeling to inform consumers about the minimum purchase requirement,” Bunker wrote.

“Since motorcyclists and ATV users, as you suggest, have relatively small fuel tanks, they should pay careful attention to the labeling of blender pumps to ensure that an appropriate fuel is chosen, in this case E10 or E0,” he wrote.

The problem with the new EPA policy is that not all motorcycle and ATV gas tanks hold four or more gallons.

“Not only do we find it unacceptable for the EPA to mandate that our members buy minimum amounts of gas, but the EPA answer simply won’t work because of the sizes of many motorcycle and ATV gas tanks,” said Allard. “Furthermore, off-highway riders take containers of gas with them on their trips, and most times those containers are much smaller than four gallons.

“The EPA needs to come up with a better solution,” he said. “The EPA also needs to back an independent study to determine whether E15 is safe for motorcycle and ATV engines.”

The AMA has repeatedly expressed concerns to government officials and federal lawmakers about possible damage to motorcycle and ATV engines caused by the inadvertent use of E15 when the new fuel becomes widely available, and has asked that motorcycles and ATVs be part of any scientific study into the effects of E15.

In October 2010, the EPA approved the use of E15 in model year 2007 and newer light-duty vehicles (cars, light-duty trucks and medium-duty passenger vehicles). Then, in January 2011, the EPA added model year 2001-2006 light-duty vehicles to the approved list.

Riders should pay attention to this list because no motorcycles or ATVs are currently listed.

The AMA is concerned about E15 because it burns hotter than gasoline that contains a lesser amount of ethanol. In engines not designed to dissipate that extra heat, damage in the form of premature wear can result. Although this is a concern in all motorcycles, it’s particularly problematic for air-cooled engines found in many motorcycles and ATVs. Moreover, use of E15 may even void the manufacturer warranty.

Since the approved list includes many light-duty vehicles in use today, refineries, distributors, and fueling stations may choose to offer primarily E15 gasoline because of this action by the EPA. The new EPA policy should concern all motorcyclists and off-highway enthusiasts because this can affect the availability of gasoline with less or no ethanol (E10 or E0).

Please send a prewritten message to the EPA asking Jackson to respond to the congressional letter that seeks answers on the recent decision by the EPA to mandate consumers purchase at least four gallons of fuel from certain blender pumps that dispense both E15 and E10 gasoline-ethanol blends.