The American Motorcyclist Association (AMA) is dissatisfied with EPA’s proposed solution to the risk of the fuel tanks of motocycles and ATVs being inadvertently supplied with E15, a fuel blend of 15 percent ethanol and 85 percent gasoline.

In October 2010, EPA’s partial waiver allowed the use of E15 in model year (MY) 2007 and newer light-duty motor vehicles. Previously, E10 was the highest ethanol blend allowed. In January 2011, the Agency extended the partial waiver to MY 2001 to 2006 light-duty motor vehicles. The sale of E15 is conditioned on the fuel or fuel additive manufacturer implementing a misfueling mitigation plan (MMP) for minimizing the potential of E15 being used in vehicles and engines not covered by the partial waivers.

Residual E15

In June 2012, the AMA wrote to EPA’s National Vehicle and Fuel Emissions Laboratory (NVFEL) about the possibility of motorcycle and ATV riders inadvertently misfueling because of residual E15 left in a blender pump hose used to dispense both E15 and E10. Motorcycles and ATVs are not currently approved for E15.

“Unlike an automobile or SUV with a large fuel tank, the residual fuel left in a fueling hose could be detrimental to the performance of motorcycle or ATV engines due to the small size of their fuel tanks and higher concentration of ethanol that would therefore be present in the fuel,” wrote the AMA. “In addition, the use of E15 will lower fuel efficiency and possibly cause premature engine failure. Use of E15 fuel voids many manufacturer warranties. In off-road engines, the effects can even be dangerous for users.”

4-gallon minimum

In an August 1, 2012, response to the AMA, the director of NVFEL’s Compliance Division wrote that the EPA has been aware of the potential for misfueling vehicles with small tanks under the E15 waiver. Accordingly, says the Agency, it is requiring, through MMPs, that retail stations either dispense E15 from a dedicated hose and nozzle or, in the case of E15 and E10 being dispensed from the same hose, require that at least 4 gallons of fuel be purchased to keep the concentration of E15 low for smaller fuel tanks. The Agency is also requiring that stations offering both fuels from the same nozzle use additional labeling to inform consumers about the minimum purchase requirements.

Mandate ‘unacceptable’

The AMA believes the 4-gallon minimum is not a solution to the problem.

“Not only do we find it unacceptable for the EPA to mandate that everyone–including our members–buy minimum amounts of gas,” wrote Wayne Allard, the AMA VP for government relations, “but the EPA answer simply won’t work because of the sizes of many motorcycle and ATV gas tanks and the fact that off-highway riders take containers of gas with them on their trips, and most times those containers are much smaller than 4 gallons.”

Allard added, “The EPA needs to come up with a better solution. The EPA also needs to back an independent study to determine whether E15 is safe for motorcycle and ATV engines.”