Proving E15 okay for small engine equipment — mission not accomplished

By Kris Kiser

Dec. 1, 2009, marked yet another milestone for the outdoor power equipment industry when the Environmental Protection Agency (EPA) responded to a waiver request from Growth Energy asking the agency to allow for the use of up to 15 percent ethanol in gasoline. 

In response to the waiver request, the Outdoor Power Equipment Institute (OPEI) on its own — and as a member of The Alliance for a Safe Alternative Fuels Environment (AllSAFE), an organization that speaks on fuel-related legislation for more than 250 million Americans that own and operate more than 400 million products running on gasoline and ethanol fuel blends — petitioned the EPA to look at the long-term implications of increasing ethanol blends, and most importantly, to commit more time to the testing of products already in the field that will be subject to E15.

In EPA’s December response letter to Growth Energy, it stressed wanting to have “all necessary science to make the right decision.” And, while EPA indicated that newer automobiles should fare well on E15, it said the Department of Energy (DOE) is “going to complete testing of 19 vehicles for emission impacts of higher ethanol blends by August 2010.” EPA then ended the letter by acknowledging “fuel pump labeling issues to ensure consumers utilize the proper gasoline.”

There is a gaping hole in the EPA letter. What about the hundreds of millions of pieces of outdoor power equipment used by millions of consumers, such as utility vehicles, lawn mowers, chain saws, snow throwers, trimmers, blowers and other affected equipment, including boats, ATVs, motorcycles and snowmobiles? 

The EPA seems to suggest in its letter that a new E15 fuel will be approved for a sub-set of the automobile fleet, likely Model Year 2001 and newer, and that a legacy fuel (E0 to E10) will be left in the marketplace for everything else. What the letter does not detail is what steps will be taken to prevent misfueling of product or vehicles or what steps are likely to be taken to mitigate economic harm or safety issues likely to occur if misfueling occurs, resulting in product damage or failure. 

It’s important to remember that EPA’s previous attempt at bifurcating the fuel supply, offering both leaded and unleaded fuels via two separate pumps, was not completely successful. Even with education and physical barriers against misfueling at the fuel pump and on the automobile, misfueling still occurred with 13.5 percent of vehicles needing unleaded gasoline (based on EPA’s own misfueling study). With no physical barrier and a price differential that would encourage misfueling, the potential for physical harm to consumers must be addressed before bifurcation is considered. EPA has acknowledged that most consumers base their fuel purchasing decisions on price and not necessarily on what is labeled.

OPEI, as part of a diverse coalition of stakeholders — which includes the Natural Resources Defense Council, National Marine Manufacturers Association, Grocery Manufacturers Association, National Petrochemical and Refiners Association, and the Environmental Working Group — issued a joint statement following EPA’s December letter, stating, “This coalition has long urged EPA to deny the Growth Energy petition until independent, rigorous and verifiable testing can be conducted. As a result, these groups support EPA’s decision to not rush a hasty, ill-informed approval of the petition to allow more time for testing.”

But from OPEI’s perspective, the issue isn’t newer automobiles, it’s millions of product out in the field that are used in situations that could lead to safety issues for consumers — think boats stranded far from land with stalled engines or unintentional clutch engagement with a chain saw.  The bottom line is that current equipment is neither designed, built nor warranted for mid-level blends. And, not only is this a safety issue, but despite labeling, consumers will not blame the fuel for any product failure or injury, but the manufacturer of the product.

As OPEI pointed out in early 2009, previous DOE testing of a small sample size of legacy vehicles and small non-road engines with E15 fuels showed the following results:

Engine exhaust temperatures rose to an extent that may cause premature engine and equipment failure;
Safety hazards dramatically increased due to unintentional clutch engagement caused by high idle speeds;
Products were damaged to the point they could no longer operate; and
Numerous adverse operational issues arose — such as erratic engine and equipment operation, stalling of engines, and dramatic power reduction.

DOE’s own study shows that of the 28 engines tested, most had some significant problems with higher ethanol blends that the machines were not designed to operate on. To read OPEI’s own study of the DOE testing report, visit www.opei.org/ht/a/GetDocumentAction/i/1926.

What should Outdoor Power Equipment makers do at this point?

1. Tell Congress and the EPA to slow down. We need them to thoroughly test E15 on small engine product, especially legacy product, already on the market. Let them know the impact to your business and that the focus needs to broaden to include OPE, not just automobiles.

2. Make sure your leadership teams and marketing communications professionals are up to speed on the current landscape and look to OPEI for additional information on ethanol developments at www.OPEI.org and www.allsafe-fuel.org.

 Kris Kiser, an attorney, is executive vice president for the Outdoor Power Equipment Institute (OPEI). OPEI is the international trade association representing the $15-billion landscape, forestry, utility and lawn equipment manufacturing industry. He also currently serves as spokesman for the Alliance for a Safe Alternative Fuels Environment (AllSAFE) coalition. AllSAFE represents the manufacturers of automobiles, motorcycles, outdoor power equipment, ATVs, engines, boats and personal watercraft, specialty vehicles and snow mobiles.