Memorandum 

To: Docket

From: Barry Garelick, OTAQ/OAR

Date: June 16, 2011

Subject: Labeling for E85, mid-and high-level ethanol blends, and
blender pumps

There are currently about 2,300 E85 pumps and 215 blender pumps
dispensing mid- and high-level gasoline-ethanol blends (typically E20 or
E30 and above).  Both E85 and blender pumps generally have labels or
other signage that clearly identifies mid- and high-level ethanol blends
as such and indicates which nozzle or selector button dispenses those
higher blends.  Labels for these pumps also typically make clear that
mid- and high-level gasoline-ethanol blends are for flex-fuel vehicles
(FFVs) only.  This portion of the label reflects that introduction of
these blends into commerce for use in any other vehicles is prohibited
under the Clean Air Act unless and until the particular blend receives a
waiver and is registered under the Act.  In addition, misfueling or
causing misfueling of other vehicles with mid- and high-level blends may
constitute or cause tampering with vehicle emission controls, which is
also prohibited.  EPA has previously advised that retail stations
selling mid- and high-level blends may reduce the risk of a violation by
clearly marking the pumps dispensing those blends as for FFVs only. 

Below are some photographs of E85 and mid-level blender pumps that
illustrate that the various blends are clearly labeled, that the pumps
differentiate between conventional gasoline and mid- and high-level
ethanol blends, and that the labels generally communicate that the mid-
and high-level ethanol blends are for FFVs only.  The photographs were
taken as part of the first comprehensive survey of ethanol blender
pumps. 

 The estimate for the number of E85 pumps is based on information
contained at this site:   HYPERLINK
"http://www.afdc.energy.gov/afdc/fuels/stations_counts.html" 
http://www.afdc.energy.gov/afdc/fuels/stations_counts.html  

   The estimate for the number of blender pumps is based on information
compiled by the Department of Energy, and is located here:   HYPERLINK
"http://www.afdc.energy.gov/afdc/technology_bulletin_0210.html" 
http://www.afdc.energy.gov/afdc/technology_bulletin_0210.html 

  PAGE   \* MERGEFORMAT  4 

