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Fuels and Fuel Additives

E15: Misfueling Mitigation Plans

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The E15 partial waivers include conditions (listed here) requiring each fuel and fuel additive manufacturer subject to the waivers to submit to EPA a misfueling mitigation plan (MMP), for EPA’s approval, and to fully implement the EPA-approved MMP prior to introduction of the fuel or fuel additive into commerce as appropriate.

On March 2, 2012, the Renewable Fuels Association (RFA) submitted the “Renewable Fuels Association Model E15 Misfueling Mitigation Plan” (PDF) (20 pp, 96K, March 2, 2012 Model Plan) to EPA for review. RFA developed the March 2, 2012 Model Plan to help fuel and fuel additive manufacturers meet the misfueling mitigation conditions of the partial waivers. On March 15, EPA sent RFA a letter informing RFA that the March 2, 2012 Model Plan would generally be sufficient to satisfy the partial waivers’ requirements for an MMP. EPA also noted that any company that wishes to use the March 2, 2012 Model Plan must notify EPA in writing that the company seeks approval of the Model Plan for the company’s use in meeting the waiver requirements for an MMP. EPA indicated that it may seek additional information and/or misfueling mitigation measures as needed from companies requesting to use the Model Plan.

On June 15, 2012, EPA approved the first MMPs for individual companies. The companies whose plans were approved had notified EPA in writing that they wished to use the March 2, 2012 Model Plan. Before approving their requests, EPA sought more information about how E15 would be dispensed, particularly from blender pumps. After working with RFA and individual plan submitters, EPA determined that an addendum to RFA’s Retailer Handbook (PDF) (48 pp, 4.37MB), which is referenced in the Model Plan, provided the necessary information for EPA to approve the individual plan submitters’ MMPs. EPA sent approval letters to companies (see sample letter (PDF) (4 pp, 83K) ). A list of companies that have approved MMP submissions may be found here. The list is updated at least every two months.

On February 7, 2013, EPA approved a new blender pump configuration, submitted by the Renewable Fuels Association (RFA), for general use by retail stations that wish to dispense E15 and E10 from a blender pump with a common hose and nozzle. Blender pumps, or multiple-grade dispensers, are fuel dispensers that dispense multiple gasoline-ethanol blended fuels (e.g. E10, E15, and E85) typically through a common hose and nozzle. When two different gasoline-ethanol blended fuels are dispensed from the same hose and nozzle, residual fuel from a prior fueling of E15 may be commingled with a subsequent fueling of E10, resulting in the inadvertent misfueling of vehicles not covered by the E15 partial waivers with fuels containing greater than 10 volume percent ethanol.

In an effort to address this potential misfueling issue, EPA approved an industry-submitted configuration that requires a minimum purchase of four gallons from blender pumps that dispense both E10 and E15 from the same hose and nozzle. Such an approach would prevent misfueling by diluting any residual E15 left in the hose from the previous sale of E15. However, groups representing motorcycle owners and lawn mower manufacturers objected to this configuration because their products have gas tanks that are normally two gallons or smaller. In response to these concerns, RFA developed and proposed a new configuration for EPA approval that retail stations may use as an alternative to the currently approved configurations. See the revised addendum to the RFA Retailer Handbook (PDF) (3 pp, 513MB, February 2013).

Retail stations that wish to use this new configuration must provide a fuel pump with at least one dedicated hose and nozzle dispensing a gasoline-ethanol blended fuel containing no more than 10 volume percent ethanol (i.e. E10 or lower). These retail stations must also prominently affix a new label to its blender pumps which says “Passenger Vehicles Only. Use in Other Vehicles, Engines and Equipment May Violate Federal Law.” Passenger vehicles in this context do not include nonroad vehicles, engines, and equipment (e.g. marine engines, motorcycles, ATVs, lawnmowers, etc.). Retails stations must also post additional signage informing consumers of the availability and location of the dedicated E10 (or lower) fuel pump.

EPA believes that this new configuration is suitable for dispensing E15. Since retail stations using this new configuration would re-direct customers with vehicles, engines, and equipment not covered by the E15 partial waivers to a dedicated fuel pump that exclusively dispenses E10 or fuel containing less than 10 percent ethanol by volume, those customers would not inadvertently misfuel their vehicles, engines, and equipment from a hose that dispensed both E10 and E15 from a blender pump. Therefore, EPA has approved the configuration for general use.

A retail station that wants to sell E15 from blender pumps can now choose from any of the three approved configurations, based on its own assessment of what would work best for that station and its customers, or it may submit a different approach for EPA approval. Companies that already have previously approved MMPs may use this new configuration without notifying EPA. Companies that newly seek approval to use the March 2, 2012 Model Plan may choose from any of the three approved configurations. These configurations are discussed in the sample approval letter (see here) and RFA’s Retailer Handbook (see here).

Any other company seeking approval to use the March 2, 2012 Model Plan should send EPA a letter referring to the March 2, 2012 Model Plan posted on this website and indicating the nature of the company’s planned E15-related business (e.g., refiner, ethanol producer, oxygenate blender, retailer). The letter should be on company letterhead, signed by a company official and mailed to the following address:

    Director, Compliance Division
    U.S. Environmental Protection Agency
    1200 Pennsylvania Ave., N.W. (Mail Code: 6405A)
    Washington, DC 20460.

In deciding whether to approve the March 2, 2012 Model Plan for a company, EPA may seek additional information and/or require additional misfueling mitigation measures, as appropriate, considering the company’s specific circumstances. EPA must approve a company’s submission of an MMP before the company may use it to demonstrate its compliance with the requirement for an MMP.

Since the March 2, 2012 Model Plan does not spell out the specific elements of a survey plan, companies that use the Model Plan must submit a survey plan for EPA approval and cannot introduce E15 into commerce until EPA has approved the survey plan and the plan has been implemented. For more information concerning E15 survey plan requirements, please see the E15 Survey Plan page.

If you have questions or request information, please contact the appropriate support or help line found on the Support & Help page.

Please visit EPA's Transportation and Air Quality web-based repository of mobile source documents, Document Index System (DIS). This searchable repository contains regulations, Federal Register notices, policy letters, and guidance documents.

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