In announcing its decision to allow E15 for just a portion of the vehicle fleet, the Environmental Protection Agency also unveiled a proposed label to "educate" drivers about the fuel and its appropriate use. As many are aware, the RFA has been critical of EPA's failure to follow the science to its end and approve E15 for all vehicles, thus eliminating the need for a label for vehicles. Nevertheless, EPA made this decision and we are stuck with the need for a label. And the label EPA has proposed simply won't work.
For years, the ethanol industry has worked to take labels off from gasoline pumps. A gallon of gasoline contains scores of ingredients, none of which require a label. For instance, MTBE was a product blended into gasoline to add oxygen. But as it turned out, it polluted groundwater and is suspected to be a carcinogen. No warning label was ever required. Yet, for many, the thought of using ethanol warranted a warning for the general public. Where labels were required – by some states and in the case of E85 and other higher level blends made for a certain subset of vehicle – it has been our mission to ensure the label educates rather than alarms consumers.
We fully agree that given EPA's decision to segment the vehicle market for E15, a proper label is required. The label EPA has proposed is anything but proper.
The most troubling portion of the proposed label is the wording itself. EPA appears to have gone out of its way to unduly alarm consumers about the impacts of E15 on vehicles they have not approved. The proposed label appropriately spells out that E15 can be used in 2007 and newer vehicles only. Fair enough. But then, EPA would go on to say "This fuel might damage other vehicles." Not only does this unduly alarm someone driving a 2006 Chevy Malibu and unnecessarily connote negative perceptions about the efficacy of ethanol as fuel, but it is not based on a single shred of scientific evidence. In none of the testing done by the Department of Energy did any vehicles show damage. This is a gratuitous warning that is unnecessary for an educational label of this nature.
Only slightly less troubling is the Halloween orange color EPA has chosen for its proposed label. While something eye-catching is needed to capture consumer attention, it should not scare the consumer. It has been the experience of the industry that green and yellow colors work just as effectively without causing the same kind of alarm as road construction orange.
These are just a few observations for EPA as it holds its public hearing on the issue. The RFA will have more in depth analysis in its public comments that will be submitted.
During the announcement of its decision, EPA also made clear it was going to be up to the industry to make sure consumers were educated about which vehicles were approved to use E15. As such, we sincerely hope it takes the criticisms proved by an industry familiar with similar labeling initiatives in the past.
