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RFA Responds to EPA’s Proposed Changes to E15 Label and UST Regulations

April 19, 2021

E15, EPA


The Renewable Fuels Association today responded to proposed changes by the U.S. Environmental Protection Agency to E15 fuel dispenser labeling requirements and underground storage tank regulations to accommodate the safe storage of E15 and other higher blends.


“RFA is supportive of many of the changes proposed by EPA, and we hope President Biden’s administration moves swiftly to finalize the key elements of this rule,” said RFA President and CEO Geoff Cooper. “EPA’s proposal would help to remove two crucial impediments that have prevented E15 from spreading more rapidly in the marketplace.”

In comments to the EPA, RFA Vice President of Regulatory Affairs Kelly Davis noted the trade association “believes that with a few modest revisions, the labeling modifications and UST compatibility provisions proposed by EPA will result in expanded availability and use of E15, a cleaner, more affordable fuel blend that improves our nation’s energy efficiency, air quality, energy security, and resiliency to climate change.”


With regard to E15 labeling, RFA noted that data from EPA and EIA confirm that more than 95% of vehicles on the road today are legally approved by EPA to use E15. Thus, the association argues, the label should be modified to better reflect the increasingly small share of vehicles and equipment for which E15 is not approved.


“While RFA continues to question the long-term need for an E15 pump label, we currently support the first of the two options co-proposed by EPA (i.e., modifications to the existing label),” Davis wrote. “We believe a modified label represents a reasonable ‘middle ground’ between stakeholders who support the complete elimination of the label and those who support retaining the current label design.” RFA’s preference is for a black-and-white label without unnecessarily alarmist language.


Further, RFA believes EPA should clarify that its mandatory E15 label preempts the ability of state and local governments to require duplicative and redundant E15 dispenser labels.


In its comments on underground storage tanks, RFA strongly supports EPA’s proposed changes to underground storage tank compatibility requirements, while recommending EPA reconsider the potential exemption from this requirement for USTs storing fuel for emergency power generators and other off-road fuel. In addition, RFA argued that EPA should slightly shorten the time allowed for states to submit revised State Program Approvals adopting these changes to federal UST regulations, from three years to two years.


Ken Colombini