In its formal comments, the RFA stated, "The label shortcomings include leading, unscientific statements, confusing technical information and unwarranted warnings. The label as written will seriously impair long-term progress towards achieving the [image-nocss] country's stated goals for renewable fuels. It unnecessarily will promote skepticism and concern over any future broader approval for E15 and create the false perception that E15 is an inferior fuel."
As an alternative, the RFA proposed a label (pictured, black) to more accurately provide consumers with the information they need without unnecessary alarm. This label contains the four elements EPA has stated are required for a label: 1) an information component; 2) a legal approval component; 3) a technical warning; and 4) a legal warning.
In addition, the RFA opposes the use of the words "Warning," "Danger" or "Caution" as these are words reserved to alert consumers to possible physical danger. Such concern is not warranted with E15. The RFA also supports providing gasoline marketers some flexibility in determining the size, color, and shape of the label that would best suit their needs. The RFA remains opposed to having two labels, as is currently the case with a proposal from the Federal Trade Commission (FTC), and encourages the agencies to work in tandem on one label. It is RFA's belief that no label is needed for E10 blends.
In its comments, the RFA also takes the opportunity to once again challenge EPA's decision-making process in issuing a partial waiver while simultaneously offering suggestions that would lead to as widespread an introduction of E15 fuel as is possible.The RFA support the following recommendations: EPA should approve E15 for all automobiles and light-duty trucks. EPA's proposed label is misleading and inappropriate. Any E15 label must be clear, informative and factual. Gasoline marketers should have the flexibility to determine the color, size and shape of the E15 label. There must only be one E15 label. There is no need to label E10. EPA's proposed product transfer document (PTD) requirements are misplaced. Changes to the complex model must be made to accommodate E15. The 1-psi volatility tolerance should be extended to E15. RFA supports an effective consumer information outreach program. Click hereto view the full text of RFA's comments.
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