By Timothy J. Rudnicki, Esq
What the U.S. EPA does, sometimes, so does the Minnesota Pollution Control Agency (MPCA). At present, that means keeping the blinders on with respect to the science centered on E15 and its compatibility in fuel storage and dispensing systems. Unfortunately, the failure of Agencies to keep the focus on science also means restraining E15 from having widespread access in the marketplace even though E15 is a least cost method by which to immediately reduce greenhouse gas (GHG) emissions. To both the U.S. EPA and MPCA, I say, tear down those blinders and be open to empirical evidence.
Lately, at some White House briefings, the United States military has been underscoring the national security challenges presented by the continuing rise in GHG emissions and the concomitant climate change. The military, however, is also underscoring its expanding use of biofuels to provide a renewable source of energy for its operations and to decrease GHG emissions. What’s striking about this latest focus on biofuels by the U.S. military is its robust support for biofuels so as to reduce emissions of climate changing gases.
While the military’s focus on the GHG benefits of biofuels might come as a surprise to some, the GHG benefits of biofuels have been well studied and documented for more than a decade. To make the GHG benefits of ethanol a bit more parochial, if all the spark ignition engine transportation fuel (Regular gasoline with 10% ethanol) used in Minnesota were E15 rather than E10, we could cut annual GHG emissions by an additional 358,000 metric tons.
Another, but perhaps less practical, way to achieve the same reduction in GHG emissions is to pull slightly over 75,300 vehicles off Minnesota roadways for a year. Still another way to look at the GHG benefit E15 can provide is to recognize it would take at least 98, two megawatt wind turbines a year to displace the same amount of GHG emissions that E15 can displace in 2001 and newer motor vehicles on the road right here, right now.
So what are we waiting for? Why is the U.S. EPA and MPCA fixated on perpetuating the fictitious blend wall by restraining consumer access to E15 and maintaining the status quo for carbon intensive, finite fossil fuels? After sitting through hours of meetings with the MPCA, one reason for delay is because some agency staff think and feel that E10 is an illegal fuel and that E15 will start seeping out of all the underground storage tanks, pipes and dispensers. Perhaps those are good thoughts and feelings to have and from which to begin ascertaining the facts, but we need to ask, again, are those thoughts and feelings based on science, the evidence?
To better understand the science and evidence, we can turn to a new National Renewable Energy Laboratory (NREL) report released in May 2015, entitled E15 and Infrastructure (the “Report”). Here are some key findings in the Report:
"It is often stated that tanks cannot be used to store E15, but this assumption is incorrect as the majority of installed tanks can store blends above E10. For many decades, underground storage tank (UST) manufacturers approved their tanks for blends up to E100…"
"…there are UL (Underwriters Laboratories) testing standards available now for all gasoline–ethanol blends from 0% to 85% ethanol… Certain equipment types are typically UL listed—these include tanks, pipes, dispenser, hanging hardware, submersible turbine pumps, and shear valves."
"A review was conducted with each manufacturer to determine compatibility with ethanol blends. There is an extensive list of E15 and E15+ compatible equipment available in the appendices."
With respect to E10, the Report examined literature from the past 15 years to find out if “…there were any negative impacts during the multi-year deployment of E10 nationwide” and, based on extensive research, determined that “No incidents of E10 causing releases (also referred to as leaks) from UST systems were identified. None of the reviewed literature noted any association between E10 and any specific UST release. The EPA OUST’s Performance Measures’ data on UST releases were reviewed, and as E10 was deployed nationwide, the trend was fewer UST releases.”
Once again, the Agencies have put the burden of proof on E10 and E15. And E10 and E15 have met that burden and demonstrated, once again, they are effective and compatible with most of the fueling infrastructure. To the Agencies, now you have more evidence to support the facilitation of widespread access to E15. Now is the time to allow E15 to thrive in the marketplace so consumers can save at the pump, we can displace more carbon intensive petroleum and we can further drive down GHG emissions by using more homegrown, renewable biofuels.