Friday, April 13, 2012
It has now been three years since Growth Energy first filed the Green Jobs Waiver to move the nation forward with E15, and now we are on the verge of seeing the first E15 available to American consumers. But our work is not quite done and it is going to take the effort of the entire ethanol industry to clear these final steps to get E15 into the marketplace. We wanted to present the checklist of steps you and everyone in the industry need to take to get E15 into pumps near you.
In addition, we've scheduled a conference call to review this material with you and answer your questions. Join us on Tuesday, April 17 at 1 p.m. CDT.
When: Tuesday, April 17 at 1 p.m. CDT
Where: Teleconference (866.951.1151)
Director of Regulatory Affairs, Growth Energy
Compliance Survey — Deadline April 20
The EPA is requiring industry participation in an E15 implementation and compliance survey. Growth Energy and RFA have been working with the RFG Survey Association (RFGSA) to build a national survey that will meet EPA’s requirements. The RFGSA will conduct sampling in areas where E15 will be sold ensuring compliance with the requirements of the E15 partial waiver. The costs of this survey are going to be based on U.S. gallons of ethanol produced in conjunction with the number of participants who sign-up for the survey. It is very important that if you intend to sell ethanol into the E15 market that you sign up for this survey as the more participation – the lower the costs. The initial survey registration period has begun and will run from April 12 – April 20 to start the survey by May 1. It will not be legal to sell E15 into commerce until payment into the survey has been made. The registration has opened and is available here: http://www.rfgsa.org/programs_e15.html
Each ethanol producer must register their ethanol as a fuel additive to reflect 15% ethanol – even if you have previously registered for E10. This step makes your ethanol legal as a fuel additive for use in E15.
As part of EPA’s fuel additive registration form 3520-13 (found here: http://www.epa.gov/otaq/regs/fuels/forms/3520-13.pdf ), you must reference 2 important health effects components (Question #18 on the form, select E15 for Group Description and RFA-Growth Energy/API for Organizing Entity):
Growth Energy’s now-approved Tier I health effects testing – free to anyone who wishes to register the fuel.
Tier II testing done through the 211(b) Research Group at the American Petroleum Institute (API). API is charging those who have not paid to participate in the 211(b) research group for E10 to use their data for E15 – at a cost of $66,838. If you are unsure as to whether you have paid appropriately to API or have specific questions about the Tier II testing, you may contact Robin Tillery at API (Phone: 202-682-8484; email: email@example.com)
Once the form is completed and submitted, EPA has estimated that it takes approximately 2-4 weeks for approval.
Misfueling Mitigation Plan
Each company is required to submit a misfueling mitigation plan to be approved by EPA. These plans will outline the measures being taken to avoid consumer misfueling of E15. EPA has posted an approved template submitted by RFA (found here: http://www.epa.gov/otaq/regs/fuels/additive/e15/documents/rfa-model-e15-misfueling-mitigation-plan.pdf ) that can be used by anyone in the industry wishing to complete this requirement.
For EPA’s general information on E15 requirements please visit: http://www.epa.gov/otaq/regs/fuels/additive/e15/
We encourage you to register with EPA, submit your misfueling mitigation plans and sign up for the survey. If you have any questions, please contact Chris Bliley at Growth Energy at 202-545-4000 or firstname.lastname@example.org.