April
22, 2009 | Vol. 59, No. 10
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Dear PEI Member: Growth Energy and 54 ethanol manufacturers submitted the E15 application to EPA on March 6, 2009. The Clean Air Act calls for EPA to make a decision within 270 days of receipt, which is December 1, 2009. Section 211(f)(1) of the Clean Air Act makes it unlawful for any manufacturer of any fuel or fuel additive to increase the concentration of any fuel or fuel additive for use in motor vehicles manufactured after model year 1974 which is not "substantially similar" to any fuel or fuel additive utilized in the certification of any model year 1975 (or subsequent) vehicle or engine. Section 211(f)(4) of the Act provides that the EPA Administrator "may grant a waiver for a prohibited fuel or fuel additive if the applicant can demonstrate that the new fuel or fuel additive will not cause or contribute to engines, vehicles or equipment failing to meet their emissions standards over their useful life." EPA makes it clear in its notice that the effect of increasing the ethanol blend on existing (legacy) petroleum marketing equipment "is not a specific criterion by which to evaluate a waiver request under section 211(f)." However, EPA recognizes the potential problem with legacy equipment and "seeks comment on the effect of a potential waiver for ethanol blends above 10 percent and up to 15 percent on existing fuel programs" such as underground storage tanks and the petroleum marketing infrastructure. |
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If you are a distributor or installer of equipment, what practical problems do you anticipate from fire marshals and other code enforcing entities whose codes require equipment in petroleum service to be "listed" when it is clear that legacy equipment will not be listed for increased ethanol blends? PEI members are encouraged to respond to EPA with their comments. The comment period will be open for 30 days after the notice is published in the Federal Register, which is expected on or about April 22. Here is a link to the FR notice with details on how to respond: www.epa.gov/otaq/regs/fuels/additive/e15-increase.pdf. Please copy Bob Renkes (rrenkes@pei.org) with your responses. If you would rather PEI respond collectively for you, please direct your comments to Bob and he will include them, without attribution, as part of PEI's comments. For more information on the E15 request, go to www.epa.gov/otaq/additive.htm. INTRODUCING WIKIPEI WikiPEI is much like its famous cousin Wikipedia. It is designed to accept online editorial submissions and changes from visitors to the site. WikiPEI is moderated by PEI staff to restrict offensive language and derogatory comments about any person or product. The rest is up to you and others with an interest in the petroleum equipment and liquid handling industry. You can add new material or edit existing material on WikiPEI right now. It is available free of charge. There is no need to register. To get started, click the WikiPEI tab in the upper right hand corner of PEI's home page www.pei.org. PEI SEMINAR MAY 6 IN ATLANTIC CITY BRIEFLY NOTED DEATHS MEMBERSHIP APPLICATIONS ADMITTED TO PEI
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©2009
The TulsaLetter (ISSN 0193-9467) is published two or three times each month by the Petroleum Equipment Institute. Robert N. Renkes, Executive Vice President, Editor. Opinions expressed are the opinions of the Editor. Basic circulation confined to PEI members. |