Evaluation of Measures to Mitigate Misfueling of Mid

- to High

- Ethanol Blend Fuels at Fuel Dispensing Facilities

Prepared for the American Petroleum Institute by:

Gilson Environmental LLC

33 Heather Ave. San Francisco, CA 94118 April 27 , 2010Table of Contents

Page

Introduction 1

Executive Summary

- Evaluation Matrix 4

Mitigation

Measure Title Page

1 Dispenser Labeling 6

2 Separate Island for Gasoline and Mid

- to High

- Ethanol

Blend Fuels 8

3 Refueling Attendant 13

4 Full Service Attendant with Dispenser Lockout 17

5 Cashier Fueling Permission with Dispenser Lockout 21

6 Vehicle Identification Card 24

7 Restricted Credit/Debit Cards 27

8 Large Diameter Dispensing Nozzle 31

9 RFID Option 1 36

10 RFID Option 2 39

11 Vehicle ID Option 1 43

12 Vehicle ID Option 2 46

13 Talking Dispenser 48

14 DMV Mailing 50

15 Nozzle Hand Warmers 52

16 FFV Identification Using a Web Site 54

17 FFV Identification Using a Smart Phone Application 57

18 Public Education Program 59

Notes 62- 1

-

Introduction This report investigates 18 measures identified for their potential to reduce the misfueling

of vehicles with mid

- to high

- ethanol blend fuels

. These measures are intended to provide a basis for further discussion and investigation by all impacted stakeholders into misfueling mitigation concepts. Therefore, this list should not be considered exhaustive

. There may be other effective approaches that should also be considered. I nclusion of a measure in this report in no way impl ies that API condones or supports the m easure or deems it to be advisable or feasible to implement.

Background Today’s U.S. vehicle fleet can be divided into two groups: non

- flexible fuel vehicles (“non

- FFVs”), which can use gasoline

- ethanol blends containing up to 10 vol% ethanol (“E10”); a nd, flexible fuel vehicles (“FFVs”), which have been designed to use any gasoline

- ethanol blend from neat gasoline to gasoline

- ethanol blend s containing up to 85 vol% ethanol ( “ E85 ” )

. DOE has projected that there are 8 million FFVs currently in use. 1

A C lean Air Act S ection 211(f) waiver application is now being reviewed by EPA to increase the percentage of ethanol in gasoline that non

- FFVs can use from 10 vol% up to 15 vol% (“E15 waiver”). Before a decision can be made, however, the Energy Independence and Security Act of 2007 (“EISA”) requires comprehensive test results that

demonstrate which vehicles in the fleet of non

- FFVs currently in operation are in fact compatible with the new fuel.

If a partial waiver for E15 is approved, EPA has indicated the non

- FFV portion of the U.S. vehicle fleet will likely be divided into two groups : (1) non

- FFVs manufactured prior to model year (“MY”) 2001 would be limited to the use of gasoline

- ethanol blends containing up to a maximum 10 vol% ethanol ( “ E10 non

- FFVs ” ) ; and, (2) non

- FFVs

manufactured in MY 2001 and later which EPA has indicated can use gasoline

- ethanol blends containing up to a maximum of 15 vol% ethanol ( “ E15 non

- FFVs ” )

. EPA estimates that in 2010, 37.6% (≈ 86 million) of the U.S. fleet of cars and trucks in operation are MY 2000 and older vehicles

. While the number of pre

- MY 2001 vehicles in use will decline in the future due to normal attrition and fleet turnover, they will

nevertheless constitute a sizeable fraction of the fleet at the onset of a partial waiver and their presence will likely linger for many years to come. 2

Operating certain non

- FFVs with gasoline

- ethanol blends containing more than 10% ethanol could cause drivability issues such as hard starting, hesitation, surging and stalling. Mid

- to high

- ethanol blend fuel can deteriorate elastomers and plastic parts i n fuel systems and lead to fuel leaks. These fuels can interfere with the operation of the emission control systems and release fuel system deposits that can foul fuel injectors. Use of fuels for which a vehicle was not designed can void the manufacturer ’s warranty. It should be noted that these issues also apply to non

- road equipment such as lawn equipment and marine engines.

A mid

- ethanol blend fuel refers to a gasoline

- ethanol blend fuel containing from 11 vol% to 30 vol% ethanol. A high

- ethanol blend fuel refers to a gasoline

- ethanol blend fuel containing up to 85 vol% ethanol. Not all mid

- ethanol blend fuels are legal to dispense pursuant to the Clean Air Act. While API strongly discourages the dispensing of these non

- compliant blends, they are being dispensed at a limited number of locations through so

- called “blender pumps”. Any federal efforts to mitigate misfueling of compliant fuel blends should also address misfueling of non

- compliant fuel blends.- 2

-

Misfueling

Should EPA decide to allow non

- FFVs to use mid

- ethanol blend fuels, fuel retailers may begin to sell these blends at fuel dispensing facilities around the country. It is reasonable to predict a scenario where one station dispenses one or more E10 blends, an E10+ blend, and an E85 blend as well as diesel fuel, which will increase the opportunities for

unintentional and intentional misfuelings. As noted above, automobiles can experience significant problems if fueled with the wrong fuel.

The impact of accidental and/or intentional misfueling of non

- FFVs with mid

- to high

ethanol blend fuels is an issue of significant concern. In the past, the prevention or minimization of misfueling has been addressed in an advisory way by public education programs focused on point

- of

- sale warnings/advisories, and/or in a preventive way through the use of unique dispensing nozzles and vehicle fueling ports. Unintentional misfuelings may be adequately addressed using advisory methods; however, a significant number of misfuelings that occur could be intentional and therefore may not be prevented by advisory methods. Reasons for intenti onal misfueling can include a favorable price comparison versus gasoline, a preference for ethanol products, real or perceived performance improvement due to higher octane number or a dismissal of potential incompatibility issues.

Misfueling Mitigation Measures The balance of this paper describes measures that potentially could be used to reduce or eliminate the refueling of vehicles with incompatible fuel. For each measure, the

discussion is broken down as follows:

Description

– A brief explanation of how a particular idea would work and what is involved to implement it.

Effectiveness

– A discussion of how well a particular measure might reduce misfueling and what factors may play a part in developing or sustaining an effective misfueling mitigation program.

Public and Fuel Dispensing Facility Owner/Operator Acceptance

– A review of how well the measure might be embraced by fuel dispensing facility customers, facility operators and others.

Feasibility

– A discussion of the practicality of implement ing a measure.

Cost

– An approximate cost to implement a particular measure.

Funding Sources

– A discussion of possible funding streams for implementation of a measure. Funding sources could include: federal, state, or local governments; fuel dispensi ng facility owners/operators; auto manufacturers; fuel providers; etc.

Pros and Cons

– Brief statements summarizing the expected positive and negative effects of implementing a measure.- 3

- Timeframe for Implementation

– The time required to see a signific ant impact from the measure if it were to be put into effect as described.

Many of the measures described in this paper must be implemented and enforced nationally to successfully reduce intentional misfuelings. Piecemeal implementation will

allow indivi duals to misfuel at non

- participating fuel dispensing facilities that are within driving range.

The draft preamble of EISA’s National Renewable Fuels Standard Program (RFS2)

stated that “the fuel manufacturer would have to ensure that the mid

- level blen d was only used in that particular subset of vehicles or engines to be able to legally manufacture and sell the fuel under the terms of the waiver.” Fortunately, this rationale was not incorporated into the final RFS2 rule, and it was decided that misfuel ing should be dealt with as part of EPA’s decision on the E15 waiver application. This rationale should not persist in the E15 waiver decision because it is an unfair and impractical burden to place on the fuel manufacturer. The obligated parties (i.e., refiners, blenders, importers) cannot and should not be held responsible for ensuring that consumers choose a compatible product when fueling their vehicle given the multitude of fuels mandated by the Federal

Government to be available to consumers.

Determining Vehicle Compatibility with Available Fuels A number of the misfueling mitigation measures described in this paper require fuel dispensing facility employees or motorists to determine the compatibility of specific

vehicles with available fuels. For FFVs, the easiest way to make a determination while standing by the vehicle is to look for special FFV badging or trim indicating that it can refuel with any available gasoline blend. Stickers posted inside the filler door that reference fueling with E85 or a yellow gas cap are other ways to determine if a vehicle is an FFV. Referring to the fuel section of the owner’s manual is the best way to confirm whether or not your vehicle is an FFV. However, should the non

- FFV fleet be divided by

EPA as a re sult of the E15 waiver approval, the task of determining compatibility will be made significantly more difficult.

Although not a mitigation measure itself, a key aspect of implementing many of the measures covered in this paper is an accurate listing of all makes and models on the road and their compatibility with available fuels. Such a list would be a critical reference for fuel dispensing facility employees and vehicle owners to enable identification of appropriate fuels for particular vehicles. Suc h information will also be needed for measures that require an electronic database.

All measures which are ultimately selected for implementation should be tied to a public education program (Measure 18). The program should explain misfueling, describe its negative effects, and inform motorists which fuels to use in their vehicles. All the mitigation measures described in this paper will be more effective if the public and facility operators understand the importance of using the proper fuel in each ve hicle.

In addition, the DMV Mailing (Measure 14) and the Website and Smart Phone FFV Identification (Measures 16 and 17) should be considered along with Measure 18, as they all disseminate information regarding what fuels are appropriate for what vehicl es

.- 4

-

Executive Summary

The following Evaluation Matrix of potential misfueling mitigation measures is provided as a summary of the various measures with relative and approximate gauging of effectiveness, customer acceptance, feasibility, cost and timeframe for implementation

– the key factors used to evaluate each of the mitigation measures discussed in the paper. The evaluations for each entry in the table are judgments based on information presented in the paper.

Except for the “Timeframe for Implemen tation,” the evaluation factors for each measure are classified as “High,” “Medium” and “Low”. The following is a brief description of the criteria used to assess each category:

Effectiveness

High

– There is a high probability that this measure will el iminate misfueling.

Medium

– The measure may reduce unintentional misfueling, but will not stop it.

Low

– The measure may not reduce intentional misfueling by itself.

Customer Acceptance

High

– There is a high probability that c ustomers will support the measure.

Medium

– Consumers admit the measure is beneficial but are otherwise indifferent.

Low

– The measure is not likely to be supported.

Feasibility

High

– The measure can be implemented without onerous requirements placed on any interested party.

Medium

– The measure is a good idea, but it will take a lot of work to implement it.

Low

– The measure places onerous requirements on one or more interested parties.

Cost

Low

– Less than $10 million nationwide ($10 millio n/162,000 3 facilities ≈ $62 per facility)

Medium

- $10 million to $1 billion nationwide ($62 to $6200 per facility) High

– More than $1 billion nationwide

Implementation Timeframe

Short

– A few mon ths up to a year

Medium

– One to three years Long

– More than three years- 5

- Misfueling Mitigation Measures

– Evaluation Matrix
Page

# Measure Effectiveness Customer Acceptance Feasibility Cost Timeframe for Implementation

6 Dispenser Labeling Low High High Low Short

8 Separate Islands for Gasoline and High

Ethanol Fuel s Low Low Low Medium

t o High Medium

to Long

13 Refueling

Attendant High Medium to High Low High Short

17 Full Service Attendant with Dispenser Lockout High Medium to High Low High Short

21 Cashier Fueling

Permission with Dispenser Lockout High Low Low Low Short

24 Vehicle Identification

Card Low Low to

Medium Low to

Medium M edium Medium

27 Restricted Credit/Debit

Cards Low Low Low Medium Long

31 Large Diameter Dispensing Nozzle High Low Low High Long

36 RFID Option 1 High Medium Low High Medium

39 RFID Option 2 High Low Low High Long

43 Vehicle ID Option 1 Medium Low Low High Long

4 6 Vehicle ID Option 2 Low Low Low Medium Long

48 Talking Dispenser Medium Low Low High Long

50 DMV Mailing Medium Medium Medium Low Medium

5 2 N ozzle Hand Warmers Medium High High Low Short

5 4 FFV Identification Using a Web Site Medium Medium High Low Short

5 7 FFV Identification Using a Smart Phone Application Medium Medium High Low Short

5 9 Public Education Program Medium Medium High Low to

Medium Short- 6

-

1. Dispenser Labeling

Description

Place one or more legible labels on each mid

- to high

- ethanol blend fuels dispenser describing the fuel grade. An additional label advising “For Use in Flexible Fuel Vehicles Only,” “For Vehicles Manufactured in or After Model Year 2001,” or some equivalent could also be conspicuously displayed to address unintentional misfueling.

Federal and state laws regarding fuel dispensing require that the fuel available from ea ch hose outlet be clearly marked in conformance with local regulatory requirements. This measure merely documents the most fundamental requirements that all fuel marketers

must meet to sell fuel.

Effectiveness

Dispenser labeling is the most basic and di rect means of advising customers about the

selection of available fuels. Motorists who are familiar with the differences between gasoline with 10% ethanol or less and mid

- to high

- ethanol blend fuels will be able to make an informed fueling choice.

Lab eling will not prevent misfueling by customers who intentionally wish to misfuel their vehicle. Inattentive or uninformed motorists could unintentionally refuel their vehicle with an incompatible fuel.

Public and Fuel Dispensing Facility Owner/Operator A cceptance

Customers expect and regulations require clear product labeling on dispensers, and it should be located where it can be easily seen and understood. Unclear labeling leading to confusion about what fuel is available may result in misfueling and will generate complaints and dissatisfaction.

Fuel dispensing facility owners and operators should readily accept efforts to clearly identify mid

- to high

- ethanol blend fuel dispensers. They will also support an additional advisory label if it does not i nterfere with other dispenser labeling.

Feasibility

Labeling of dispensers to describe fuel grades is currently done at all fuel dispensing facilities and is required by law.

New labeling on mid

- to high

- ethanol blend fuel dispensers may not be noticed by some drivers because of the numerous legally required labels and warnings already in place

. Caution should be given to the potential for information overload relative to adding labels to dispensers.- 7

-

Cost

At major brand fuel dispensing facilities, dispensers are labeled with product descriptions in a format that matches the design motif of the company. Independent brand operators

will use either custom

- made or generic labels. At all locations, the cost to label the dispenser for a mid

- to high

- eth anol blend fuel is no greater than for any other fuel. There is no incremental cost for labeling a high

- ethanol dispenser.

Labels in bulk are approximately one to two dollars apiece.

For four labels at a facility (two on each side of a single dispense r), at 162,000 fueling facilities, the nationwide cost of this measure is the following:

Cost = 4 labels x $2 each x 162,000 fuel dispensing facilities

= $1.3 million

Funding Sources

Generally speaking, fuel dispensing facility owners /operators will purchase their own

labels.

Pros and Cons

Pro

This measure advises motorists that mid

- to high

- ethanol blend fuel is available from designated nozzles. Additional labeling advising against using E85 in any non

- FFV and E15 in any

E10 non

- F FV can help prevent misfueling. This measure is the lowest cost misfueling mitigation measure.

Con

This measure does not prevent intentional misfueling. Distracted, inattentive, or uninformed motorists may not notice labels and could unintentionally misf

uel.

Timeframe for Implementation

By law, dispensers must be properly and clearly labeled before dispensing fuel. There will be no delay in labeling dispensers as mid

- to high

- ethanol blend fuel become

available.- 8

-

2. Separate Islands for Gasoline and Mid

- to High

- Ethanol Blend Fuels

Description

Dispensers for gasoline and low

- ethanol fuels (E10 or less) will be located on a separate pump island from the mid

- to high

- ethanol blend fuel products. Signs posted near vehicle entrances will indicate the p roducts available on each island.

Customers must know what fuel they plan to purchase as they drive into the fueling facility to choose the proper island.

Effectiveness

Customers wishing to purchase a mid

- to high

- ethanol blend fuel for their FFV can go to the island which offers only those products. Without additional controls, this measure does nothing to stop motorists with E10 non

- FFVs from intentionally misfueling at the

mid

- to high

- ethanol blend fuel island.

Public and Fuel Dispensing Facility Owner/Operator Acceptance

When first implemented, customers driving into fuel dispensing facilities may be

confused by the need to select a pump island with the fuel they wish to purchase. Motorists mistakenly choosing an island with fuels they cannot or do not wish to purchase will need to reposition their vehicle which will be an inconvenience. Any congestion generated by the reduced number of dispensers available at a facility for fuels in higher demand will not be well received.

Owners and operator s are not likely to support this measure because of the potential decreased utilization of existing dispensing equipment, increased congestion and inefficiencies at pump islands and cost. Any underground piping modifications will be expensive and are not likely to improve facility profitability.

Feasibility

This is a very restricting option relative to facility traffic flow and fuel dispensing

efficiencies. As mid

- to high

- ethanol blend fuels are more likely to begin at a low level of demand, this may n ot be a feasible measure in the near term.

At new facilities, the piping and product choices for each island could be designated prior to construction; however, future flexibility to change products could be limited.

The feasibility of this measure is dependent on product sales volumes. For example, if

the sales of mid

- to high

- ethanol blend fuel are low, the utilization of the island where it is offered will be limited. Use and congestion at other islands where the high volume

fuels are sold will be increased. At some locations it could be necessary to construct new fueling islands to accommodate the skewed traffic flow.- 9

-

Product sales volumes are price dependent. If the price of mid

- to high

- ethanol blend fuel drops below that of gasoline, the traf fic pattern at the fuel dispensing facility may change as customers opt for the less expensive fuel. If a single island is dedicated to a mid

- to high

- ethanol blend fuel it may generate considerable congestion. To address the situation

at facilities with more than two islands, the fuel dispensing facility operator would need to change the product offerings on the fueling islands. Operators who have re

- piped their facility may have more difficulty changing dispenser product offerings.

Fuel dispensing f

acility operators will not chose this misfueling mitigation measure voluntarily. Locking out some dispensers will cause congestion at the pump island and possibly reduce the volume of product sales. The cost to modify underground piping and the disruptio n to business during construction will make that option unattractive as well.

The ability of a fuel dispensing facility to comply with this measure is related to the number of pump islands at the location. The following table shows the breakdown of

fuel dispensing facilities with respect to their product throughputs and the number of pump islands:

Table 1

- Fuel Dispensing Facility Sales Volume and Island Demographics 4

Throughput Range, gallons/month 0

- 25,000 25,001

- 50,000 50,001

-

100,000 100,001

-

200,00 0 200,001

and up

Average Throughput, gallons/month 13,223 37,500 75,000 150,000 300,000

% of Facilities 4.7 14.1 45.7 31.3 4.2

No. of Islands 1 1 2 3 or more 3 or more

Table 2 shows the breakdown of the number of pump islands based on data in Table 1.

Table 2

– Pump Island Distribution

No of Islands Percent of Facilities

1 18.8

2 45.7

3 of more 35.5

Smaller fueling facilities with only one island will not be able to implement this measure and maintain an offering of high

- or mid

- ethanol blend fuel products. Single

- island facilities typically have low throughputs and do not need or cannot financially justify more dispensers. In addition, many single

- island facilities are located on small plots that

cannot accommodate more islands.

Facilities with two islands may find it difficult to implement the measure

– especially if the sales volume of one type of product is much greater than the other. Dedicating a single island at a two

- island facility to the majority of a facility’s throughp ut could cause congestion and lost sales during busy periods.- 10

-

Therefore, this measure is not feasible for stations with one or two pump islands. Based on the data presented in Table 2, little more than a third of U.S. fuel dispensing facilities

could c onsider dedicating a pump island to comply with this measure.

At existing facilities with three or more islands, the dispensers on each island typically offer access to all grades of fuel available. To implement this measure at the lowest cost, limiting access to specific dispensers or fuel grades on an island could be done by immobilizing individual dispenser controls. Single product dispensers could be disabled from operating and an out of service sign posted. For multi

- product dispensers, the fuel

se lection button or the nozzle interlock for an unapproved fuel could be blocked. Non

functioning fueling points could be marked out of service.

With this scenario, some of the dispensers on each island would be locked out and unavailable to dispense fuel. Underground piping would remain intact and changes in product offerings to provide for future fuels could be made by activating or disabling dispensers.

An alternative, higher cost method to offer low ethanol and mid

- to high

- ethanol blend fuels on separ ate dedicated islands would be to modify the underground piping at the facility. This approach would require breaking concrete, revising the underground product and vapor recovery piping configurations to realign fuel offerings according to

ethanol conten t, and then repaving the disturbed area. Such modifications would be costly to implement and disruptive to business during and after construction. Depending on the underground piping configuration and dispenser selection, the ability to make changes to p rovide for future product offerings could be limited.

Cost

Disabling Dispensers

The cost to implement this measure is considered to be in the medium range at facilities where dispensers will be disabled to prevent misfueling. A mechanic

can immobili ze a dispenser in a few minutes. Disabled dispensers and dispensers

with locked

- out fuel grades will need to be relabeled to show that they are out of service. Additional signage will be needed to identify the fuels available at each

island.

Assump tions for a typical three

- island facility locking out dispensers:

Dispenser mix: 6 two

- sided multi

- product gasoline dispensers, 3 two

- sided

mid

- to high

- ethanol blend fuel dispensers Number of dispensers to be disabled: 2 gasoline dispensers + 2 mid

- to high

ethanol blend fuel dispensers = 4 dispensers

Time for a mechanic to disable and re

- label a dispenser: One hour Average fuel dispensing facility maintenance mechanic’s wage = $16.65 per

hour 5

Contractor’s overhead markup on mechanic’s wage = 250%- 11

- Perce ntage of fuel dispensing facilities with 3 or more islands = 35.5% Number of fuel dispensing facilities = 162,000 Cost for dispenser signage and new signs to identify product offerings on each island = $500

Labor cost per station = 4 dispensers x 1 hr per dispenser x $16.65 per hour x 2.5 overhead markup = $166.50

Total average cost per facility = $166.50 labor + $500 signage = $666.50 (round to $ 700 )

Total nationwide cost = $700 per facility x 162,0 00 facilities x 0.355

= $40 million

Facilities with more dispensers and more than three islands will have higher costs to change fuel offerings between islands.

This cost does not include additional costs incurred due to refueling efficien cy reductions.

Repiping Facilities

The physical layouts of facilities with three or more pump islands vary considerably, and throughputs range from 100,001 to close to a million gallons per month. Consequently, the cost to implement this measure at thos e facilities could vary significantly. The cost to re

- pipe these facilities is high and could range from several hundred thousand to more than half

- a

- million dollars for larger sites. Expenditures of this magnitude simply to rearrange the underground pip ing configuration are not justified without an expectation of increased profitability.

Mid

- to High

- Ethanol Blend Fuel Dispensers

At the time of the writing of this document, there are no complete mid

- to high

ethanol blend fuel dispensers available that are listed by a nationally recognized third party testing laboratory such as Underwriters Laboratories. Fuel dispensing facility owners or operators will need to purchase listed dispensers to sell mid

- to high

- ethanol blend fuel products. Mid

- to high

- e thanol blend fuel dispensers cost approximately $19,000 plus installation. If this measure were implemented after facilities installed these dispensers, some of them could be taken out of service when the product offerings on islands are reassigned. For the dispensers removed from service, the investment in them is lost.

Funding Sources

Any modifications to dispensers and dispensing piping will be paid by the owner or operator of the fuel dispensing facility.- 12

-

Obtaining loan financing to make changes to piping configurations may be difficult for independent operators because financial institutions are reluctant to fund projects that do not have the potential for improving profitability.

Pros and Cons

Pro

Motorists who read, understand and follow the directions regarding the product offerings at each island will not misfuel their vehicles.

Con

Does not prevent intentional misfueling. Cannot be implemented at facilities with a single fueling island. Impractical at facilities with two fueling islands. Increased congestion because of fewer operational dispensers on each island. New signage will be required to identify product offering at each pump island. Will not be supported by facility owners and operators because of decreased

utilization of existin g dispensing equipment, increased congestion, and cost. Without additional controls on fueling activities, inattentive or uninformed motorists could unwittingly misfuel their vehicle if they drove up to the wrong

island.

Timeframe for Implementation

Sepa rating product offerings by disabling dispensers could occur within three months to a year of putting the measure into effect.

Separating ethanol fuel s or gasoline products between islands by repiping requires time for design, construction and financing. Modifications could take from one to three years or longer to implement.- 13

-

3. Refueling Attendant

Description

An attendant is stationed on the forecourt during operating hours. When a self

- service customer opts to refuel with a mid

- to high

- ethanol blend fuel, the attendant checks to see if the customer’s vehicle can use the fuel to be purchased. This will entai l either ensuring

it is an FFV or that the vehicle was manufactured in or after MY 2001. If is the vehicle can use the desired fuel, the refueling procedure continues uninterrupted. If the fuel to be purchased cannot be used in the customer’s vehicle, the attendant advises the customer

that the mid

- or high

- ethanol blend fuel chosen is not suitable for the vehicle and suggests an appropriate fuel. Should it be necessary, the attendant can explain that choosing an inappropriate fuel can possibly damage the vehicle’s fuel system, cause drivability problems, increase exhaust emissions above allowable levels and void the manufacturer’s

warranty.

The primary methods for determining that a vehicle is an FFV is to look for the flex fuel badging used on newer FFVs, a sticker on the inside of the fuel filler door or a yellow gas

cap. The attendant will be provided access to a directory of FFVs listed by make, model

and model

- year. Determining which vehicles are E15 non

- FFVs will be a challenge

because these v ehicles have no flex fuel badging.

Effectiveness

Stationing an attendant on the pump island to advise customers about fueling options is an effective way to minimize misfuelings with mid

- to high

- ethanol blend fuels. The

attentiveness of the attendants to vehicle traffic and consumer attitudes will directly correlate with the misfuelings prevented.

To be most successful, attendants will need an up

- to

- date list of FFVs and printed training materials explaining why vehicles designed for E10 cannot use mid

- to high

ethanol blend fuels. Customers will also need to know the model year of their vehicle and appreciate the cautionary nature of the attendant’s messages.

This measure is not fool

- proof. It is possible for a vehicle to misfuel if the attendant does not notice it. If mandated, a government agency will need to oversee the program to assure that attendants are on duty and properly trained.

Public and Fuel Dispensing Facility Owner/Operator Acceptance

Customers who are unaware that they have chosen a fuel which is not intended for use in their vehicle should be appreciative of the guidance offered by the attendant and respond appropriately.

Customers intentionally planning to misfuel may be persuaded by the attendant that it is a

bad idea and opt for using a low

- ethanol fuel. Those who remain unconvinced may be prevented from misfueling if they respect the authority of the attendant.- 14

-

Vehicle owners who are dissatisfied with the procedure may decide to patronize fuel dispensing facil ities that don’t require screening by an attendant.

This measure will be opposed by fuel dispensing facility operators because of the cost of providing an attendant at the fueling island during business hours.

Any fees, taxes or additional costs for admi nistration and enforcement of this program will also be unpopular and opposed.

Feasibility

Fuel dispensing facilities that offer full

- service fueling, such as those located in Oregon and New Jersey, will need to make little adjustment to attendants’ duties. Attendants will need to monitor vehicle traffic and may need additional training to assure proper fuel

choices are made.

Fueling locations that do not offer full service will most likely need to add additional personnel as attendants.

Obser ving and assisting with vehicle fueling requires basic refueling and customer relation skills with specific training.

Except where full service is now required, the cost associated with adding personnel to station an attendant on the fueling island makes this measure very difficult for facility

operators to support.

Some fuel dispensing outlet operators might opt to halt mid

- to high

- ethanol blend fuel sales during periods when stationing an attendant on the pump island is not feasible. Examples of such periods are late

- night hours when overall fuel sales are low and locations where personnel safety is an issue.

Fuel dispensing facility operators will find this measure difficult to support because it is without

financial benefit to them.

It will be diff

icult to secure funding for the government agency that would administer and enforce this program.

Cost

The mean hourly wage rate for fuel dispensing facility attendants ranges from $7.33 to $13.53 per hour 6 . Additional costs to the employer include FI CA tax (7.65%), workers’ compensation (1% to 4%) and other benefit costs such as health insurance in some areas.

For this measure, we will assume that the average cost of an attendant to work at the fueling island is $10.00 per hour. Fuel dispensing faci lity hours of operation vary considerably, but we will assume that locations are open 18 hours a day, 7 days a week.- 15

-

The average annual cost per fuel dispensing facility to implement this measure is:

Average annual cost = $10/hour x 18 hr/day x 365 d ays/year

= $67,500

The annual nationwide cost to implement this measure is:

Annual nationwide cost = $10/hour x 18 hr/day x 365 days/year x 162,000

facilities 2

= $10.6 billion/year

The government agency implementing this program will need to add office staff for administration and inspectors in the field. The cost for this effort will depend on the level

of enforcement.

Funding Sources

Attendants are paid directly by fuel dispens ing facility operators from operating revenues.

Reimbursement of costs incurred by the agency implementing the program could come from a variety of sources.

Pros and Cons

Pro

Can be quickly implemented. If attendants are properly trained, customers r eadily accept the advisory, and customers provide the correct model year of their vehicle, misfueling is

eliminated. Most customers who mistakenly choose to refuel with a mid

- to high

- ethanol

blend fuel are likely to welcome receiving advice about using th e proper fuel for

their vehicle.

Con

If additional employees must be hired to provide an attendant at the island, facility overhead will significantly increase without any increased productivity. Requires on

- the

- island presence of an attendant whenever the fuel dispensing facility is open. Attendants must be trained to identify vehicles and to explain to customers why

the use of mid

- to high

- ethanol blend fuels in vehicles E10 non

- FFVs is discouraged. Some customers may react unfavorably to being advised not to use a particular

fuel.- 16

- At facilities with few mid

- to high

- ethanol blend fuel dispensers and low sales volumes for these products, an attendant’s time on the island will be

underutilized.

Custo mers wishing to intentionally misfuel may lie about the model year of their

vehicle. Some customers originally planning to purchase a mid

- to high

- ethanol blend fuel

for their FFV or E15 non

- FFV may opt for gasoline or low

- ethanol fuel to reduce

their fuel ing times.

Timeframe for Implementation

At facilities where full

- service attendants are currently on duty, potential misfueling with

mid

- to high

- ethanol blend fuels can be addressed as soon as personnel can be trained and

issued a list of FFVs and E15 n on

- FFVs.

Facilities without full

- service refueling will need to assess staffing levels. If current staff members cannot be reassigned to working on the forecourt, it will be necessary to hire and train new attendants. A new attendant can be on duty sh ortly after being hired and trained to assist with dispensing mid

- to high

- ethanol blend fuels.- 17

-

4. Full Service Attendant with Dispenser Lockout

Description

An attendant is stationed on the forecourt during operating hours. All mid

- to high

ethanol ble nd fuel dispensers are disabled from operating without permission from the cashier. When a customer opts to refuel with a mid

- to high

- ethanol blend fuel, the attendant checks to see if the customer’s vehicle can use the fuel to be purchased. This

will e ntail either ensuring it is an FFV or that the vehicle was manufactured in or after MY 2001. If the vehicle can use the desired fuel, the attendant signals the cashier to enable the dispenser and the refueling procedure proceeds normally.

If the fuel to be purchased cannot be used in the customer’s vehicle, the attendant advises the customer that the fuel is not suitable for the vehicle and suggests an appropriate gasoline grade. If necessary, the attendant will explain the negative effects of misfueling

. Should the customer ignore the attendant’s explanation and still wish to use mid

- to high

ethanol blend fuel, the dispenser will not work and a misfueling will be averted.

Mid

- to h igh

- ethanol blend fuel dispensers will need to be set up so that they a re locked out of service until authorized by the cashier.

The attendant will be provided a directory of FFVs listed by make, model and model

year. Determining which vehicles are E15 non

- FFVs will be a challenge because these

vehicles have no flex fuel ba dging.

Effectiveness

Mid

- to high

- ethanol blend fuels cannot be dispensed without express permission from facility employees. If the attendant is away from the fueling island, mid

- to high

- ethanol blend fuels cannot be dispensed. This measure provides an effective and essentially foolproof way to prevent misfuelings.

To be most successful, attendants will need an up

- to

- date list of FFVs and printed training materials explaining why vehicles designed for E10 cannot use mid

- to high

ethanol blend fuels . Customers will also need to know the model year of their vehicle.

A government agency will need to oversee the program to assure that fueling facilities are equipped with lockout dispensers and attendants are on duty and properly trained.

Public and Fuel Dispensing Facility Owner/Operator Acceptance

Customers who can legitimately use mid

- to high

- ethanol blend fuels in their vehicles and those customers who decide against using mid

- to high

- ethanol blend fuels after being

advised of the risks of mis fueling will not be aware that any dispensers have been

disabled.- 18

-

Any claims by individuals who are deprived of the opportunity to misfuel their vehicles will have little credibility and, indeed, any complaints could be testaments to the

effectiveness o f the method.

Customers who are dissatisfied with the procedure may decide to patronize fuel dispensing facilities that don’t require screening by the cashier.

This measure will be opposed by fuel dispensing facility operators because of the cost of

prov iding an attendant at the fueling island during business hours.

Any fees, taxes or additional costs for administration and enforcement of this program will be unpopular.

Feasibility

Fuel dispensing facilities that currently have a full

- service fueling o ption will need to make few adjustments to attendants’ duties. Attendants will need to monitor vehicle traffic and fuel choices near any mid

- to high

- ethanol blend fuel dispensers.

Observing and assisting with vehicle fueling requires only basic skills a nd minimal training.

Attendants will need to be able to communicate with the cashier or whoever controls dispenser refueling authorizations. If line of sight is not available or is impractical, the attendant could signal with a cell phone call or instant message to the cashier. Some stations are equipped with a two

- way intercom between the refueling islands and the cashier. It could be used by the attendant to request use of locked

- out dispensers.

If the attendant cannot communicate with the cashier t o enable the mid

- to high

- ethanol blend fuel dispenser, this method will not work.

Except where full service is now required, the cost associated with adding personnel to station an attendant on the fueling island makes this measure very difficult for fac ility

operators to support.

Some fuel dispensing outlet operators might opt to halt mid

- to high

- ethanol blend fuel sales during periods when stationing an attendant on the pump island is not feasible. Examples of such periods are late

- night hours when o verall fuel sales are low and locations where personnel safety is an issue.

Fuel dispensing facility operators will find this measure difficult to support because it is without

financial benefit to them.

It will be difficult to secure funding for the government agency that will administer and enforce this program.- 19

-

Cost

The mean hourly wage rate for fuel dispensing facility attendants ranges from $7.33 to $13.53 per hour. Additional costs to the employer include FICA tax (7.65%), workers’

compensa tion (1% to 4%) and other benefit costs such as health insurance in some areas.

For this measure, we will assume that the average cost of an attendant to work at the fueling island is $10.00 per hour. Fuel dispensing facility hours of operation vary

cons iderably, but we will assume that locations are open 18 hours a day, 7 days a week.

The average annual cost per fuel dispensing facility to implement this measure is:

Average annual cost = $10/hour x 18 hr/day x 365 days/year

= $67,500

The annual nationwide cost to add an attendant during business hours is:

Annual nationwide cost = $10/hour x 18 hr/day x 365 days/year x 162,000

facilities

= $10.6 billion/year

There may be additional cost s involved with locking out individual dispensers at a

location.

The government agency implementing this program will need to add office staff for administration and inspectors in the field. The cost for this effort will depend on the level

of enforcement.

Funding Sources

Attendants are paid directly by fuel dispens ing facility operators from operating revenues.

Reimbursement of costs incurred by the agency implementing the program could come from a variety of sources.

Pros and Cons

Pro

Can be quickly implemented. If attendants are properly trained and customer s provide the correct model year of their vehicle, misfueling is eliminated. Most customers who mistakenly choose to refuel with a mid

- to high

- ethanol

blend fuel will welcome receiving advice about using the proper fuel for their

vehicle.- 20

-

Con

If additio nal employees must be hired to provide an attendant at the island, facility

overhead will increase. Requires on

- the

- island presence of an attendant whenever the fuel dispensing facility is open. It may be impractical for attendant and cashier to communica te easily at some

locations. The extra degree of security created with a locked

- out dispenser may not be necessary with an attendant present. Attendant must be trained to identify vehicles and to explain to customers why the

use of mid

- to high

- ethanol ble nd fuels in vehicles designed for E10 is discouraged. Some customers may react unfavorably to being advised not to use a particular

fuel.

At facilities with few mid

- to high

- ethanol blend fuel dispensers and low sales volumes for these products, an atten dant’s time on the island will be

underutilized. Customers wishing to intentionally misfuel may lie about the model year of their

vehicle. Some customers originally planning to purchase a mid

- to high

- ethanol blend fuel

for their FFV or E15 non

- FFV may opt for gasoline or low

- ethanol fuel to reduce their fueling times.

Timeframe for Implementation

At facilities where full

- service attendants are currently on duty, potential misfueling with

mid

- to high

- ethanol blend fuels can be addressed as soon as personnel can be trained and

issued a list of FFVs.

Facilities without full

- service refueling will need to assess staffing levels. If current staff members cannot be reassigned to work on the forecourt, it will be necessary to hire and train new attendants. A new attendant can be on duty shortly after being hired and trained to assist with dispensing m id

- to high

- ethanol blend fuel s.- 21

-

5. Cashier Fueling Permission with Dispenser Lockout

Description

Mid

- to high

- ethanol blend fuel dispensers will be locked out of service and cannot be used until activated by the cashier. Signs on those dispensers wil l advise customers to see the cashier before proceeding. Customers must walk to the cashier and provide make

and model

- year information on their vehicle. Based on the information provided, the

cashier will determine what fuels are available to the custom er.

Cashiers will need to be provided with a directory of FFVs listed by make, model and

model

- year. Determining which vehicles are E15 non

- FFVs will be a challenge because these vehicles have no flex fuel badging.

Effectiveness

The success of this mea sure will depend on the ability of cashiers to quickly and correctly identify vehicles relative to the types of fuels they are able to use. If vehicle identification proves to be time consuming and causes delays or congestion around the cashier’s station, it will be difficult to implement this measure.

It is anticipated that after the first time a driver categorizes his vehicle, he will know how to quickly describe it for subsequent refuelings. As cashiers become familiar with vehicles, they can reduc e the inconvenience for customers and speed the refueling

process.

To be most successful, cashiers will need an up

- to

- date list of FFVs and be able to identify E15 non

- FFVs. The cashier will also need printed training materials explaining why vehicles E1 0 non

- FFVs cannot use mid

- to high

- ethanol blend fuels. Consumers will also need to know the model year of their vehicle.

Public and Fuel Dispensing Facility Owner/Operator Acceptance

Customers are not likely to readily accept any procedure that is inconvenient and increases the time required to fuel their vehicle. Motorists who inadvertently choose to use an inappropriate fuel and are redirected to an appropriate fuel may be appreciative.

Customers who are dissatisfied with the procedure may decid e to patronize fuel dispensing facilities that don’t require screening by the cashier.

There is no benefit to fuel dispensing facility operators for this program. It will be considered an inconvenience to put into practice, it will not increase their business and it could end up costing them money depending on how it is financed by government. This measure can also result in exacerbating security concerns relative to distracting the cashier’s attention to other activities in need of monitoring at the facility.

Any fees, taxes or additional costs for administration and enforcement of this program will be unpopular.- 22

-

Feasibility

This measure is similar to the pre

- pay requirements now in effect at some locations. In general, customers are familiar with pre

- pay procedures and may be more likely to accept

this measure.

This measure is likely to be more effective if it is implemented over a wide area. If motorists wishing to intentionally misfuel can go to a nearby fuelling facility without

locked out d ispensers, the measure will be less successful.

Vehicles will end up occupying fueling spots longer because of the time required to establish vehicle identification. It could lead to congestion at the pump island during busy periods.

This measure will need to be assessed relative to its impacts on the security of the facility, its employees and its customers.

It will be difficult to secure funding for the government agency that will administer and enforce this program.

Cost

The cost to implement thi s measure at the fuel dispensing facility is low. No increase in staff will be necessary at locations where high

- ethanol sales volumes are low because the time spent on identifying vehicles will be relatively small. At locations with greater high

- ethanol sales volumes, devotion of more staff time to vehicle identification may be

necessary

– especially when the program is new. If the measure is successfully implemented, relatively few interactions between customers and cashiers will be needed.

Signs will need to be posted directing customers wishing to buy a mid

- to high

- ethanol

blend fuel to the cashier.

The government agency implementing this program will need to add office staff for administration and inspectors in the field. The cost for this effo rt will depend on the level

of enforcement.

Funding Sources

All costs related to fuel dispensing facility staff will be paid for by the facility owner or

operator.

Reimbursement of costs incurred by the agency implementing the program could come from a variety of sources.- 23

-

Pros and Cons

Pro

After learning how to describe their vehicle’s exact make and model, customers should be able to minimize the time requi red for this procedure on subsequent

visits. Fuel dispensing facility operators will appreciate having more foot traffic inside

their convenience store.

Con

Increases the time required to refuel a vehicle using a mid

- to high

- ethanol blend fuel dispense r which may increase congestion at the pump block during busy periods. Customers may object to the extra time and inconvenience involved in dealing

with the cashier. Some handicapped customers may find it difficult to travel to the cashier’s

location and b ack.

FFV owners and E15 non

- FFV owners will be forced to brave the elements to get to the cashier, potentially leading to frustrated customers and liability concerns in

the event of an accident. Cashiers or other facility employees will have to take time a way from other duties to identify vehicle. Customers may decide to patronize a different fueling location which does not require them to walk to the cashier. Some customers may be unsure of the exact MY of their vehicle which could delay or prevent their r efueling with mid

- to high

- ethanol blend fuel. Any fees or taxes levied to support the implementing agency will be unpopular. Enforcement of the program could be difficult

– especially in rural areas. Some customers originally planning to purchase a mid

- t o high

- ethanol blend fuel

for their FFV or E15 non

- FFV may opt for gasoline or low

- ethanol fuel to reduce their fueling times. Cannot be implemented at unmanned sites.

Timeframe for Implementation

This measure could be implemented rapidly. It could be put in place as soon as signs can be placed on high

- ethanol dispensers and cashiers are trained. Cashiers and facility personnel will need to be trained to look up vehicles on the list of FFVs, identify E15

non

- FFVs and be able to explain to customers why the procedure is necessary.- 24

-

6. Vehicle Identification Card

Description

Issue a vehicle identification card to owners or operators of FFVs and E15 non

- FFVs. The card would provide information identifying the vehicle (model year, make and model, licen se number and VIN) and the range of ethanol fuels that it can use. The card format could range from glossy paper stock to a plastic credit card with a magnetic stripe on the back encoding the vehicle information. When the vehicle is sold, the card would

be transferred to the new owner.

For new FFVs and E15 non

- FFVs, the card could be provided by the vehicle manufacturer and included along with the vehicle owner’s manual. Identification cards for existing FFVs and E15 non

- FFVs could be issued by the stat e air quality agency or the state’s department of motor vehicles (DMV). In each state, the DMV has records for

all vehicles on the road. It could send ID cards to all FFV and E15 non

- FFV owners in a mass mailing, with annual registration renewals or when ownership is transferred.

The card could be used on several levels. The most basic use would be to merely inform the vehicle owner or operator that the vehicle is an FFV or E15 non

- FFV. Many motorists may be unaware what fuels their vehicle can use an d the card would provide a reminder and confirmation that they can choose to purchase mid

- to high

- ethanol blend fuels. For vehicles not owned by an individual, such as rental cars, company vehicles, taxi cabs, etc., the card would inform the operator tha t the vehicle is an FFV or E15 non

FFV.

The next level of use of the ID card would be to integrate it into Measure 5 (Cashier Fueling Permission with Dispenser Lockout). Customers could show their ID card to the cashier as proof of driving an FFV or E15 non

- FFV, and they could proceed to refuel

with mid

- to high

- ethanol blend fuel.

If a formal program requiring motorists to provide vehicle identification before fueling were instituted by a state or local air quality agency, the administering body would be responsible for assuring that all FFV and E15 non

- FFV owners have ID cards.

Effectiveness

The ID card provides an accurate description a vehicle’s fueling capabilities and eliminates any uncertainty about whether it can use mid

- to high

- ethanol blen d fuel.

The ID card could be used fraudulently by transferring it to a different vehicle for the purpose of misfueling.

Public and Fuel Dispensing Facility Owner/Operator Acceptance

Acceptance by motorists of identification cards issued with new vehicl es would probably

be neutral

. Customers are likely to appreciate having a card that adequately notifies the m of the types of fuels their vehicle is intended to use.- 25

-

If existing FFV and E15 non

- FFV owners were required to go through an application

process or pay a fee in order to acquire an identification card to refuel with mid

- to high

ethanol blend fuels, such a program may not be well received. It is likely that most motorists would not bother to obtain a card, and they would simply avoid buying mid

- t o high

- ethanol blend fuels.

It is most likely that if an ID card were required to be presented to purchase mid

- to high

ethanol blend fuels, there may dissatisfaction with the program requiring use of an ID

card rather than with the card itself.

Feasibility

For new FFVs and E15 non

- FFVs, including a card identifying the vehicle and its fuel capabilities along with the owner’s manual and warranty information could be provided by the manufacturer. There are a half dozen auto manufacturers now offe ring FFVs, and there will be more in future. Any program requiring manufacturers to supply an ID card would need to be national in scope; otherwise manufacturers would oppose the idea

because it creates an additional documentation burden for them. It wou ld be difficult to make ID cards available only for individual states or selected local areas.

For FFVs and E15 non

- FFVs already on the road, an organization or government agency would need to issue vehicle documentation. Probably the easiest way to pro vide vehicle owners with ID cards for refueling is to go through the DMV. The DMV has information on all cars in use along with the owner’s name and address. To reduce mailing costs, the department could send out ID cards at the time annual registration tags are issued and when there is a change of ownership.

Each state DMV would need to develop an algorithm to identify FFVs and E15 non

FFVs in their database.

Cost

The cost to produce individual identification cards will depend on the cost to coll ect the required information and manufacture the card.

The key to keeping costs low would be to make the cards available through an existing distribution network. In the case of new cars, IDs could be included with operation and warranty documentation al ready included with vehicles. IDs issued by state motor vehicle departments could be included with registration and license renewal mailings.

Assuming a cost range of one to five dollars per card for a national program:

Cost = (8.05 million FFVs + 143 million E15 non

- FFVs) x ($1 to $5)

= $ 151 million to $ 755 million

Each DMV would have additional costs related to establishing a vehicle database and inserting an extra enclosure in their mailings.- 26

-

Funding Sources

The cost of including a vehicl e ID card with new cars would likely be borne by each auto

manufacturer.

The cost of issuing ID cards through a government agency, most likely the DMV, would be paid by the department itself. Those costs could be reimbursed by owners through registrat ion and annual licensing fees. Considering the potential air quality benefits of limiting misfuelings, a state or local air quality agency might be willing to finance the cost of implementing all or part of the program from their budget

Pros and Cons

Pro

Identification cards would provide accurate information to motorists advising them of the fueling capabilities of their vehicle. An enforceable program requiring customers to show a vehicle identification card before refueling with a mid

- to high

- eth anol blend fuel would effectively eliminate misfueling.

Con

A program requiring customers to show a vehicle identification card before refueling with a mid

- to high

- ethanol blend fuel would be unpopular because of

its inconvenience.

In certain circumstan ces, the card could be used fraudulently to allow misfueling. Identification cards can be misplaced or lost. Until a new card is issued, those motorists would not be able purchase mid

- to high

- ethanol blend fuel. Any ID card program that increases motoris ts’ registration or renewal fees would be unpopular. Each participating DMV would need to prepare and finance enclosures for mailing.

Timeframe for Implementation

ID cards provided by the DMV could be issued to all FFV and E15 non

- FFV owners one year aft er an ID program is approved and implemented. It could take auto manufacturers several model years to include cards with all new FFVs.

If an implementing agency other than the DMV must be established to enforce the use of ID cards to prevent misfueling, it could take several years to put the bureaucracy in place.- 27

-

7. Restricted Credit/Debit Cards

Description

Customers using a credit or debit card to pay for mid

- to high

- ethanol blend fuel purchases would be blocked from fueling unless their card had bee n pre

- approved.

Customers with FFVs or E15 non

- FFVs could speed their purchase of mid

- to high

ethanol blend fuels by providing vehicle information to their credit card company where it would be kept on file. At the time of sale, mid

- to high

- ethanol ble nd fuel purchases charged with a pre

- approved card would be automatically authorized and dispensing could start immediately. Credit card purchases of mid

- to high

- ethanol blend fuels without pre

- approval would be denied and those customers would have to p rovide their vehicle information to the cashier before being allowed to fuel. This program could be used in conjunction with Measure 5 (Cashier Fueling Permission with Dispenser Lockout).

Effectiveness

This program is effective because it blocks all credit cards that are not registered to allow the dispensing of E15 or E85. Misfuelings will be prevented when customers are forced to see the cashier to identify their car before refueling with mid

- to high

- ethanol blend fuels. The registration of vehicles is merely a convenience for those who choose to provide vehicle information up front to reduce delays while refueling.

Public and Fuel Dispensing Facility Owner/Operator Acceptance

Enthusiasm for this program may be limited at best. Credit card companies will need to agree to set up the vehicle registration program, and then customers will need to register their vehicle. This additional effort on the part of the credit card companies and fuel

customer s in order to make a gasoline purchase may not be well received. If there is a change to the customary fuel buying routine of first swiping the card, then making the fuel selection, customers may be puzzled and dissatisfied with the program.

There is no financial incentive for credit card companies, facility operators or vehicle

owners to embrace this measure.

Feasibility

This measure requires each credit card company to establish a new data file and registration protocol for designated fuel sales. Th e measure provides no benefit to the credit card company because currently the transaction fee is the same for any fuel purchase. The imposition of any additional charge to raise the transaction fee to incentivize the card company would most likely be rej ected by the fueling facility.

This measure would affect the current fuel purchasing protocol. Customarily, the fuel choice is made after a credit card is swiped at the dispenser and the use of the card for payment is approved. With this measure, a cust omer with a credit card not pre

- approved

for mid

- to high

- ethanol fuel purchases would be advised after the fuel choice is made- 28

-

that the sale was not approved. The credit card authorization would be cancelled at that

time.

Rather than swiping the card in the dispenser and then choosing the fuel grade, an alternative procedure would be to select the fuel first and then swipe the card. Prior to fueling, t he file in the credit card company’s database would be checked to determine if

mid

- to high

- ethanol blend fuel purchases were approved. Any non

- pre

- approved mid

- to high

- ethanol blend fuel purchases would be denied immediately and the transaction

terminat ed. Changing the sequence of operations for credit card transactions could be confusing for some customers.

In addition, the fuel dispensing facility would need to modify its dispenser software to

advise customers whose credit cards have been denied. Th is would be an expense without benefit to the operator.

Restricting the use of credit cards for the purchase of mid

- to high

- ethanol blend fuels will not take place unless it is part of a government mandate to reduce misfueling.

Cost

The program would be administered by each credit card company. They would need to set up or gain access to a database of FFVs and match that data with information supplied by motorists. Registration of cardholders could be done on

- line or by mail. The cost to

administer this program will depend on individual credit card companies’ data processing capabilities and the number of credit card holders eligible to make mid

- to high

- ethanol blend fuel purchases. There are numerous factors, which could vary widely, that are

inv olved in determining the cost to administer the credit card portion of this measure. The cost for implementing the credit card portion of this measure is based on the following assumptions:

The cost to issue each credit card arbitrarily set at $5 each

8.05 million light

- duty FFVs in use

143 million light

- duty E15 non

- FFVs in use

Cost to implement the new credit cards = $5 per card x 151 million vehicles

= $ 755 million

This figure does not take into account vehicle turnover.

New dispensers will most likely be installed to dispense mid

- to high

- ethanol blend fuels and they could be equipped with displays, card readers and software that, along with a point

- of

- sale controller, could identify and enable refueling with registered c redit cards. The cost of upgrading or reprogramming a recent mid

- to high

- ethanol blend fuel dispenser would depend on the existing software capabilities.- 29

-

The cost for fuel dispensing facilities to accommodate restricted credit and debit cards will dep end on the incremental cost to modify dispensers and the cost for a POS

controller.

The costs for this measure at fuel dispensing facilities are based on the following assumptions:

162,000 fuel dispensing facilities in U.S.

Incremental cost for hardwar e and software to allow one dispenser to process restricted credit cards = $1000

Cost to implement measure at all fueling facilities = 162,000 facilities x $1000 per facility

= $160 million

For six mid

- to high

- ethanol blend f uel dispensers at each facility, the cost for this

measure would be:

6 dispensers / facility x $160 million = $960 million

Total cost for measure ( 6 dispensers per facility) = $ 755 million + $960 m illion

= $1

. 72 billion

Considering fueling facility demographics as shown in Measure 2, the average

number of mid

- to high

- ethanol blend fuel dispensers per fueling facility will be

less than six and the cost of this measure will be less than one billion dollars.

Funding So urces

The cost of the registration program would be borne by the credit card company. Unless the program is mandated by a government agency, it will not be implemented by the credit card company. If a fee or charge were levied on the cardholder or the r etailer, the program would be rejected.

Any costs related to changes of the credit card processing software at fuel dispensing facilities would be borne by the fuel dispensing facility operator.

Pros and Cons

Pro

Speeds the refueling process for motor ists who have enrolled their vehicle with their credit card company.- 30

-

Con

Customers could use their credit card to intentionally or unintentionally misfuel

another vehicle that is not registered with the credit card company. Any change to the routine of swiping a credit card and then choosing a fuel grade before refueling could be confusing. There is no incentive for a credit card company to participate in this measure. There is no incentive for the fuel dispensing facility to participate in this measure if there is any additional cost to them. Customers who have not registered their vehicle may take their business to other fuel dispensing facilities that will not block their credit card purchases. Collection of vehicle information for credit card regist ration could be considered an intrusion of privacy. Veracity of the customer’s claim about their automobile will not be verifiable by the credit card company. Customers will need to register their car on every credit card they foresee themselves using to purchase fuel, which may be burdensome. Registered customers with an approved credit card who own more than one vehicle may still accidentally misfuel a vehicle not intended to use mid

- or high

ethanol blend fuels.

Timeframe for Implementation

Implementation will depend on how quickly credit card companies adopt the program, how swiftly upgrades are made to mid

- to high

- ethanol blend fuel dispensers and how rapidly customers register their vehicle information with credit card companies. It is

l ikely that the rollout of this program would be slow and incomplete.- 31

-

8. Large Diameter Dispensing Nozzle 7

Description

Outfit all high

- ethanol blend fuel nozzles with a large

- diameter spout that cannot fit through the restrictor plate in the fill neck of unleaded gasoline

- powered motor vehicles

manufactured since the mid

- 1970s. Mid

- ethanol blend fuel nozzles would be exempt from this measure to prevent the refueling of an E15 non

- FFV with E85.

This measure would require the replacement of existing 13/16 inch diameter nozzle spouts used on high

- ethanol blend fuels with a 15/16 inch spout diameter. The larger diameter spout would be the same size as the spout formerly used for leaded gasoline.

New FFVs would be equipped with fill neck restrictor pla tes that can accommodate the larger spout diameter. The restrictor plates on existing FFVs would be retrofitted to allow the use of the larger spout s.

This program would need to be implemented on a national basis by EPA with local

administration and enforcement delegated to individual states.

Effectiveness

The larger diameter nozzle proposed for this measure will not fit through the restrictor plate on any non

- FFV . Unless an individual decides to introduce a high

- ethanol blend

fuel into a non

- FFV u sing a gas can, misfueling should be eliminated by this measure when it is fully implemented.

The program is dependent on the fill neck restrictor plates of all FFVs being large enough to accommodate the larger nozzle spout. The nozzle spouts for high

- ethanol blend fuels will not be changed to the larger diameter until all new FFVs can fuel with them. The program to retrofit existing FFVs with larger diameter restrictor plates would probably be done during the same period. Until the time the larger no zzles are installed, the program will do nothing to reduce misfueling.

Some motorists may claim that they do not plan to purchase high

- ethanol blend fuels and that they should be able to opt out of the program. Any FFVs that are not converted

would not a ffect the misfueling rate, but those vehicles would not be able to be fueled with a high

- ethanol blend fuel even if the owner wishes to do so.

Public and Fuel Dispensing Facility Owner/Operator Acceptance

Vehicle owners required to pay for retrofitting t he fill neck on their FFV to accommodate a larger nozzle spout may resist this program.

Aside from cost considerations, many motorists may claim that they do not intend to purchase high

- ethanol blend fuel and, consequently, do not need to modify their vehicle’s

fill neck.- 32

-

Owners of older FFVs will argue that the cost of modifying the restri ctor plate is unreasonable considering the value of the vehicle.

Programs involving modifications of existing FFVs , such as vehicle recalls, often result in unanticipated consequences.

Each state would need to establish a rule regarding the sale of used FFVs with an unmodified restrictor plate to specify whether the former owner or the new owner is responsible for making and paying for the upgrade. For older FFVs, the cost of the modification could be significant compared to the value of the vehicle.

Fe asibility

The cost and effort to modify equipment to comply with this measure may make it difficult and unpopular to implement.

This program needs to be rolled out nationally to work with maximum effect. If it were adopted on a state

- by

- state or local basis, FFVs with unmodified fill necks coming from areas without the program would not be able to fuel with high

- ethanol blend fuels.

New FFVs would be manufactured with the larger restrictor plate in the fill neck. This modification may affect the fun ction of the onboard refueling vapor recovery (ORVR)

system on some FFVs . Manufacturers will probably change the restrictor dimension when the fuel systems are redesigned for new models over several years.

Enlarging the restrictor plate opening on exist ing FFVs is not advised. At this time there is no approved method for opening up the restrictor opening nor is there any restrictor replacement kit available. There is concern that after modifying the restrictor plate, the fill neck area may be damaged o r modified in such a way that dispensing nozzle operation may be adversely affected.

About two

- thirds of FFVs have fill pipes that can be removed and replaced without replacing the fuel tank. In the remaining FFVs , it will be necessary to replace the f ill

neck and fuel tank.

The fill neck area where existing restrictor plates are located contains gasoline vapors that are arguably in the flammable range. Replacing or modifying any part in the fill neck without draining the fuel tank and taking appropri ate precautions presents a safety

and health hazard.

There may be problems with smaller unleaded gasoline spouts fitting loosely in the enlarged restrictor opening and falling out during hands

- off refueling or upon automatic shutoff engagement. This situ ation may take place when fueling a FFV with any fuel

until the changeover to the larger spouts for high

- ethanol blend fuels is implemented. After the changeover, mid

- to low

- ethanol fuel dispensers will continue to use nozzles with small spouts

, and FFVs may continue to experience refueling difficulties with those

fuels

.- 33

-

Federal law prohibits manufacturers and dealers of motor vehicles and persons who repair or service motor vehicles from removing or rendering inoperative a gasoline nozzle restrictor pla te which is required to be on new motor vehicles (40 C.F.R. Section 80.24(b)). The effect of this section of the law on this mitigation measure should be investigated to assure that any proposed changes to vehicle fill necks are in compliance

with this re gulation.

Fueling location operators will need to change nozzle spouts on high

- ethanol blend fuels to the larger size. Unless the existing nozzle is worn out, changing the spout or the entire nozzle body will be an additional maintenance expense. There is no financial incentive for them to make the change. The financial picture may change as the demand for mid

to high

- ethanol blend fuel increases. Fuel customers will make a purchase whether it is high

- ethanol blend fuel or gasoline. Making a nozzle c hange only adds to overhead.

To maximize program effectiveness, there must be a mandate that all high

- ethanol blend fuel nozzles need to be changed to the larger diameter spout. In addition, all FFVs need to have the larger restrictor plate opening.

Cost

The costs for this measure are based on the following assumptions:

162,000 fuel dispensing facilities in U.S.

8.05 million light

- duty FFVs in use $160 is the typical retail cost of a conventional E85 nozzle See Note 8 for fuel tank replacement costs

Cost to replace one nozzle in high

- ethanol blend service at each fuel dispensing facility in

the U.S.:

162,000 locations x $160 per nozzle = $26 million

Cost to convert the restrictor plate on existing FFV fuel tanks to accommodate larger spout nozzle s:

The fill pipes on two

- thirds of existing FFVs can be changed without replacing the fuel tank. The remaining one

- third of these vehicles will need new fill pipes

and fuel tanks.

Cost = ( 8.05 million vehicles x 2/3 x $258) + ( 8.05 million vehicles x 1/3 x $550)

= $3 billion

The total cost to implement this measure at all fuel dispensing facilities nationwide is:

$26 million + $3 billion = $ 3 billion- 34

-

Funding Sources

The cost of installing nozzles with larger spouts would be borne by the fuel dispensing facility operator.

Any modifications to existing vehicle fuel tanks would be paid by the vehicle owner. There is a possibility that the ethanol industry or DOE might subsidize the cost of modifications to existing FFVs to motivate conversion, but is unlikely under any scenario

that the vehicle manufacturer would cover the cost. Keeping in mind the considerable cost for the program and the financial condition of the a uto industry, manufacturers are not presently in a position to cover the retrofit cost of this measure.

EPA’s administrative costs and the costs of setting up a nozzle inspection program in each state could be paid by federal funding. Without federal fun ding, each state would need to finance the enforcement program on its own.

Pros and Cons

Pro

When all FFVs are fitted with a larger restrictor plate and all high

- ethanol blend fuel dispensers have larger nozzle spouts , there is a high probability that

m isfueling will be eliminated.

Con

The high expense and effort required to modify the restrictor plates of all FFVs on the road may make this an unpopular approach to reducing misfueling. Motorists may balk at the cost of modifying older FFVs that may be near the end

of their useful life. Implementation will take more than three years at a minimum and during that period no misfuelings will be averted. Nozzles with the smaller spout diameter may have difficulties refueling some FFVs with the larger diamet er restrictor openings. This situation would occur for high

- ethanol blend fuels during the changeover period when restrictor plates are being enlarged. Customers with FFVs fueling with mid

- to low

- ethanol fuel may experience this difficulty indefinitely. Using nozzles with small diameter spouts when refueling FFVs equipped with larger restrictor plates may increase refueling emissions. A small subset of older vehicles with larger

- diameter fill necks that were designed to operate on leaded gasoline will be able to misfuel with high

- ethanol blend

fuels. Some existing FFV owners may try to extract the narrow restrictor on their own giving rise to safety concerns with related to the extraction process and increased concern regarding the dispensing nozzle ope ration being adversely affected

.- 35

-

Timeframe for Implementation

The lead time for making restrictor plate changes to all new FFVs is not less than three full model years after the decision to make the modifications is made. The three

- year period allows m anufacturers to make the restrictor plate modification at the same time as

model

- year changes are made to fuel systems in their vehicles. The modification of the restrictor plates for FFVs that are on the road would likely be made in the same

timeframe as that for new FFVs

.

Implementation will require changing high

- ethanol blend fuel nozzles at every facility. The changeover to larger dispenser spouts on high

- ethanol blend fuels would be done when all new vehicles come equipped with the larger restrictor plate.

The establ ishment of an agency in each state to enforce the program would take place during the restrictor plate changeover period.

Considering the lead time needed for design changes to FFVs, implementation of this program would take at least four years.- 36

-

9. RFID Option 1 9

Description

Lock dispensers out of operation for mid

- to high

- ethanol blend fuels unless actuated by a radio frequency identification (RFID) tag carried by customers.

Participating motorists would provide data identifying their vehicle as a F FV or E15 non

FFV and possibly credit information which would be imbedded in an RFID tag. When purchasing mid

- to high

- ethanol blend fuel, waving the tag in front of a designated area on a high

- ethanol dispenser will initiate flow. The tag would be small enough to fit on a key chain and work similarly to Mobil SpeedpassTM technology which has been used for a number of years.

The dispenser is equipped with an RFID reader that can pick up data stored on the tag.

The reader is connected to a central datab ase that can authorize use of the dispenser.

Motorists without an RFID tag would have to go to the cashier and identify their vehicle before receiving permission to fuel.

The electronic database for identifying approved vehicles would be maintained at a

central location.

To be effective his program should be conducted in conjunction with Measure 5 (Cashier Fueling Permission with Dispenser Lockout).

Effectiveness

This program may be effective only because it blocks fueling for all vehicles that are not equipped with an RFID tag. Misfuelings will be prevented when customers without an RFID tag must see the cashier to identify their car. The registration of FFVs and E15

non

- FFVs is merely a convenience for those who chose to provide vehicle informati on up front to reduce delays while refueling.

Public and Fuel Dispensing Facility Owner/Operator Acceptance

RFID technology has been successfully used and is accepted by the public. Motorists who are willing to register their vehicle will find the syste m quick and easy to use.

Unless fuel dispensing facility operators see the installation of RFID readers on high

ethanol dispensers as a way to attract customers, they will not endorse this measure. The expenditure for the card reader on each high

- ethanol dispenser is significant and will not be recouped in extra business or profit.

Feasibility

RFID technology has been proven to work with programs such as the Mobil SpeedpassTM.- 37

-

The modest cost for the customer’s tag should not deter motorists interested in the

convenience. Cust omers not interested in purchasing a tag will have to identify their

FFV or E15 non

- FFV to the cashier or purchase low

- ethanol gasoline.

Cost

The costs for this measure are based on the following assumptions:

8.05 million light

- duty FFVs in use (assumin g that all FFV owners participate)

143 million light

- duty E15 non

- FFVs in use (assuming that all E15 non

- FFV owners participate) 162,000 fuel dispensing facilities in U.S. Cost of a customer tag = $3 to $5 Cost of a RFID reader (one per dispenser) = $3,000 to $5,000 Cost of a central controller (one per facility) = $10,000 to $20,000

For a nationally implemented program with this measure, the startup costs are the following:

Handheld tags

Cost = 151 million vehicles x ($3 to $5 per vehicle)

= $ 453 million to $ 755 million for existing vehicles

This figure assumes that all existing FFV and E15 non

- FFV owners will purchase a tag. The ongoing cost of new vehicle owners buying tags is not accounted for

here.

Facility costs

Dispenser modifications for an RFID reader assume one dispenser per facility and one central controller per facility.

Cost = 162,000 locations x [($3000 to $5000/dispenser) + ($10,000 to $20,000/location)]

= $2.1 bill ion to $4 billion

Funding Sources

Motorists would pay for the cost of the RFID tags. Modifications to dispensers would be paid by fuel dispensing facility owners or operators.- 38

-

Pros and Cons

Pro

The tag provides an easy way for motorists to prove t hat they have an FFV or E15

non

- FFV and purchase mid

- to high

- ethanol blend fuels without delays in the fueling process. No delay in refueling means less congestion at busy locations. Cashiers will spend less time identifying vehicles.

Motorists who do not intend to purchase mid

- to high

- ethanol blend fuels do not need to purchase a handheld tag.

Con

Unless tags are generic and simply identify a vehicle as an FFV and E15 non

FFV, customers must take the time to register their vehicle information and then wait to receive their RFID tag. A customer could lose the RFID tag. A lost tag could be used by an unauthorized user to purchase mid

- to high

- ethanol blend fuel fraudulently. Retailers will not want to make the expenditure necessary to upgrade their dispe nsers to accept RFID. If the tags contain vehicle make and model information, software with the list of

FFVs and E15 non

- FFVs must be kept up to date.

Timeframe for Implementation

Initiation of this measure is limited by the time required to modify dispe nsers and issue tags to motorists. Implementation time would be approximately three years.- 39

-

10. RFID Option 2 9

Description

Lock dispensers out of operation for mid

- to high

- ethanol blend fuels unless actuated by a special RFID tag mounted on FFVs and E15 non

- FFVs.

FFVs and E15 non

- FFVs would be outfitted with a ring

- shaped RFID tag permanently

mounted around the fuel inlet. The ring provides data identifying the vehicle and its fuel capability when near an RFID reader. Dispensing nozzles on mid

- to high

- ethanol blend fuels would be equipped with a reader located on the nozzle spout that can pick up information from the ring tag. The information collected from the circular tag is transmitted wirelessly by the reader to a central controller that enabl es vehicles with a tag to fuel. The reader has a reception range of only several inches and can be attached to existing nozzles.

The RFID ring tag mounted on new and existing vehicles requires no power or battery to operate. The reader on the nozzle use s a battery that has a life of approximately four

years.

New vehicles will be equipped with tags at the factory. Existing FFVs and E15 non

FFVs would be outfitted with tags through a retrofit program.

The operation of the system would be passive as f ar as the customer refueling a vehicle is concerned. Customers with vehicles that are not outfitted with a tag would be blocked from fueling mid

- to high

- ethanol blend fuels and have to identify their car to the cashier before refueling.

Effectiveness

This program is effective because it blocks fueling for all vehicles that are not equipped with an RFID tag. Misfuelings are prevented when customers without an RFID tag see the cashier to identify their car. The effectiveness of the program is dependent on the diligence of cashiers to block E10 non

- FFVs from refueling with mid

- to high

- ethanol

blend fuels.

This measure needs to be implemented by national government mandate. State

- by

- state application would limit the number of intentional misfuelings av erted

– especially in areas within easy driving distance of non

- participating states.

Some motorists may claim that they do not plan to purchase mid

- to high

- ethanol blend fuels, and that they should be able to opt out of the program. Any FFVs and E15 non

FFVs that are not converted would not affect the misfueling rate, but they could not be

fueled with a mid

- to high

- ethanol blend fuel unless they identify their vehicle to the

cashier.- 40

-

Public and Fuel Dispensing Facility Owner/Operator Accepta nce

The operation of the RFID system will be transparent to FFV and E15 non

- FFV owners as no input from them is required during refueling.

Public acceptance of the retrofit program would depend on the cost and inconvenience of installing RFID tags on e xisting vehicles.

The measure is merely a convenience for FFV and E15 non

- FFV owners to reduce delays while refueling with mid

- to high

- ethanol blend fuels. Owners of E10 non

- FFVs will see no personal benefit and may resist any efforts to make them pay for any part of the

program.

RFID technology has been successfully used and is accepted by the public. The tags could be programmed with additional information to identify the vehicle for credit purchases.

Feasibility

This program will not be worthwhi le unless a large number of fuel dispensing facilities and vehicles participate. To be effective it needs to be instituted as a national program by

a government agency.

For motorists whose vehicle is equipped with the RFID tag, the fueling experience w ill

be no different than normal.

Cost

The costs for this measure are based on the following assumptions:

8.05 million light

- duty FFVs in use

143 million light

- duty FFVs in use 162,000 fuel dispensing facilities in U.S.

The cost of a customer ring tag is $50 to $75 The cost to install the ring tag: 0.5 hour labor x $25/hr = $12.50 The cost of a RFID reader (one per nozzle) is $500 The cost of a central controller (one per facility) is $10,000 to $20,000.

For a nationally implemented program with this m easure, the startup costs are the following:

Ring tags for FFVs and E15 non

- FFVs

Cost = 151 million vehicles x [($50 to $75 per vehicle) + $12.50 installation]

= $ 9.4 billion to $ 13 .2 billion for existing vehicles- 41

- This is a conservati ve figure that does not cover vehicles manufactured after implementation of the program.

The cost for ring tags on new vehicles will be included in the purchase price. The incremental cost for tags and their installation should be less than for the re trofit

case cited above.

Facility costs

Nozzle RFID reader for one nozzle and central controller to accept information from the reader at each gasoline dispensing facility nationwide.

Cost = 162,000 locations x [($500/dispenser) + ($10,000 to $20,00 0/location)]

= $1.7 billion to $3.3 billion

Funding Sources

Each individual vehicle owner will pay the cost for the ring tags and their installation. Facility operators will be responsible for nozzle and central controller costs.

Pros and Cons

Pro

The use of the RFID identification system will be transparent to motorists whose vehicles are equipped with a tag. Cashiers will spend less time identifying vehicles.

Con

Owners of existing FFVs and E15 non

- FFVs will need to have a tag installed on their vehicle or go to the cashier for permission to fuel with a mid

- to high

- ethanol

blend fuel. If the owners of existing FFVs and E15 non

- FFVs must pay for installing tags on their vehicles, they may oppose the program.

If all vehicle owner s end up paying for the installation of tags on FFVs, E10 non

FFV owners may resist the program because it is of no benefit to them.

Some owners of FFVs and E15 non

- FFVs will claim that they do not expect to purchase mid

- to high

- ethanol blend fuel and wil l resist paying to put a tag on

their vehicle. Any increase in the price of new cars related to the cost of installing RFID tags will not be well received by manufacturers or buyers. Retailers will not want to upgrade their dispensers to accept RFID becau se it is an expense without benefit to them. There is no benefit to the customer or the facility operator if pre

- payment for cash transactions is required.- 42

- The software with the list of FFVs and E15 non

- FFVs must be kept up to date.

Timeframe for Implemen tation

Implementation will progress as more vehicles

– existing and new

– are equipped with tags and fuel dispensing facilities install RFID readers. Installation of tags on new vehicles will probably take two to three model years before all production is included. Fuel dispensing facilities will probably put off installing readers until the end of the allowable phase

- in period. Reader and tag installation deadlines will likely match the

new vehicle installation schedule.- 43

-

11. Vehicle ID Option 1

Description

Before being allowed to refuel, customers choosing a mid

- to high

- ethanol blend fuel must enter information about their vehicle on the dispenser keypad or touch screen. Motorists would provide year, make and model input, and if the vehicle is identified as an

FFV or E15 non

- FFV, fueling with the mid

- to high

- ethanol blend fuel can commence.

The dispenser is equipped with a display that is connected to a database that can identify

FFVs and E15 non

- FFVs, and provide a permissive signal to ena ble the dispenser. Older dispensers without displays will need to be replaced with a new dispenser capable of displaying messages.

Effectiveness

The effectiveness of this program is limited by the truthfulness of customers entering

their vehicle informa tion. Customers who wish to misfuel can intentionally enter data for

a known FFV or E15 non

- FFV and proceed with refueling.

Customers who unintentionally try to misfuel will be prevented from introducing the wrong fuel in their vehicle.

Dispensers will need to be equipped with touch screens to allow data entry by motorists. These dispensers will need to be PCI DSS (Payment Card Industry Data Security Standard) compliant to protect personal and credit card information. The back office

controller will st ore the vehicle database, process data inputted by customers and provide the permissive signal allowing mid

- to high

- ethanol blend fuel sales.

Without comprehensive implementation of this measure over a wide area, it will be

ineffective if non

- participat ing areas are within driving distance.

Public and Fuel Dispensing Facility Owner/Operator Acceptance

Customers will most likely not appreciate the extra time required to enter their vehicle information. Motorists regularly using mid

- to high

- ethanol ble nd fuels, which require more frequent refueling than gasoline, will be more inconvenienced by the vehicle verification process.

Feasibility

The measure does not provide any incentive to the facility owner or to the customer to make the change. Unless ma ndated by a government agency, it’s unlikely that facility operators will express any interest in supporting this measure.- 44

-

Cost

Dispenser software will need to be modified to query motorists wishing to purchase mid

to high

- ethanol blend fuels. The database for vehicle identification will be centralized. Assumptions for estimating the cost for a single high

- ethanol dispenser at each fueling facility:

Number of fueling facilities = 162,000

PCI DSS

- compliant dispenser display = $2500

Communicat ion pathway (wiring from island to building) = $3000 Back office point

- of

- sale controller = $25,000

Cost = 162,000 facilities x ($2500+$3000+25,000)
= $5 billion

Funding Sources

The cost to modify dispensers will be borne by facility ow ners.

Pros and Cons

Pro

There is a high probability that this measure will prevent unintentional misfueling by preventing customers from refueling with inappropriate fuels.

No direct cost to the motorist.

Con

Operators will need to upgrade or replace mid

- to high

- ethanol blend fuel dispensers to provide a display screen. A customer wishing to intentionally misfuel can enter erroneous vehicle

information. Increases the time required to refuel a vehicle using a mid

- to high

- ethanol blend fuel dispenser which may increase congestion at the pump block during busy periods. Customers may object to the extra time required to enter data to refuel with mid

to high

- ethanol blend fuels. Using the keypad as an interface to enter vehicle information may be awkward or frustrating for some motorists.

The software with the list of FFVs and E15 non

- FFVs must be kept up to date. Dispensers, especially new ones, will probably have a useful life longer than this measure will remain in effect. To remain in service, those dispensers will need to be reprogrammed or upgraded in the long term.- 45

-

Timeframe for Implementation

The measure could be implemented on a station

- by

- station basis as soon as dispensers are purchased or modified to use the display to screen mid

- to high

- ethanol blend fuel sales.- 46

-

12. Vehicle ID Option 2

Description

Before being allowed to refuel with a mid

- to high

- ethanol blend fuel, the display on the dispenser will ask motorists if their vehicle is an FFV or E15 non

- FFV. The answer is limited to “y es” or “no”. Those responding “yes”, indicating that they intend to refuel a

FFV or E15 non

- FFV, will be allowed to begin refueling. Those responding “no” will be advised to select an appropriate low

- ethanol fuel. There will be a statement advising

cust omers unsure if they have an FFV or E15 non

- FFV to answer “no”. There will be no

other verification of vehicles.

The software on mid

- to high

- ethanol blend fuel dispensers will need to be modified to ask customers about their vehicles before enabling fu eling.

For motorists who are unsure if they have an FFV or E15 non

- FFV, a third option could be made available. Those indicating “not sure” or “I don’t know” would be prompted to look for “flex fuel” trim on the vehicle or advisory stickers on the fuel d oor. They could also be asked to look in the owner’s manual which provides a discussion of acceptable fuels. Alternatively, they could ask the cashier for information about their vehicle to

determine if it is an FFV or E15 non

- FFV. This procedure would b e the same as

described in Measure 11.

Effectiveness

The effectiveness of this program is limited by the truthfulness of customers answering the question about their vehicles. Customers who wish to misfuel can intentionally say

that their vehicle is an FFV or E15 non

- FFV and commence refueling.

Customers who un intentionally try to misfuel will be prevented from introducing the wrong fuel in their vehicle.

Public and Fuel Dispensing Facility Owner/Operator Acceptance

The extra time required for a customer to answer the single question about their vehicle will take just a few seconds and should not significantly delay refueling.

Motorists who do not know if they have an FFV or E15 non

- FFV may have difficulty

determin ing how to answer.

Feasibility

This program can be instituted on a facility

- by

- facility basis although it will not provide real reductions in misfuelings unless a significant number of locations are involved.

Unless mandated by a government agency, it ’s unlikely that facility operators will express any interest in modifying their dispensers. The measure does not provide any incentive to make the change.- 47

-

Cost

Upgrading a facility to provide for the “yes/no” option and the additional guidance for

cust omers who are unsure of the fuel needs of their vehicle may require the installation of

a new server to accommodate new software. For this estimate it is assumed that the existing display with defined

- purpose buttons on each dispenser will be a satisfactor y interface for communicating with customers.

Number of fueling facilities = 162,000 Back office server and software = $2000

Cost = 162,000 facilities x $2000 per server = $320 million

The installation of touch screen displays and more sophi sticated software will increase the cost of this option.

Funding Sources

The cost to revise equipment will be paid by the fuel dispensing facility operator.

Pros and Cons

Pro

The question to determine if a vehicle is an FFV or E15 non

- FFV can be answered quickly and will not delay refueling. The software revision for this measure will not need to be upgraded after it is

installed.

Con

Anyone intending to intentionally misfuel can simply do so by answering “yes” to the question.

Some customers will not be able to identify their vehicle which can delay refueling. Facility operators will not see any benefit to this program without any increase in

traffic or revenue.

Timeframe for Implementation

Implementation of this measure is limited by the ti me required to install any new hardware necessary to question customers about their vehicles’ fuel needs.- 48

-

13. Talking Dispenser 10

Description

When a mid

- to high

- ethanol blend fuel nozzle is lifted from its dispenser, a short audio/video presentation plays on a multi

- media display screen. The presentation advises

the customer that he has chosen a mid

- to high

- ethanol blend fuel that is designed for use

with FFVs and E15 non

- FFVs only. The presentation could go on to mention that misfueling can cause possible engine and fuel system damage.

An additional feature could be to ask the customer at the end of the video to confirm that

he wants the mid

- to high

- ethanol blend fuel that was chosen before enabling the dispenser to operate.

API members will most likely want to prepare and display their own presentations. Independent operators would probably welcome a generic message they could play without special preparation. API could develop a short presentation and make it available for general use.

Effectiveness

The mid

- to high

- ethanol blend fuel presentation provides a quick alert which can grab

the attention of customers.

Customers are presented with numerous messages while purchasing fuel. Some people will ignore the message on the dispenser screen

– especially if they are distracted by

other stimuli.

Motorists may ignore the presentation after hearing it several times. If those individuals are not misfueling, it will not make any difference.

Public and Fuel Dispensing Facility Owner/Operat or Acceptance

A video message is an unobtrusive way to advise motorists about mid

- to high

- ethanol blend fuels. Those who are not interested in watching will ignore it.

The presentation could become irritating to some customers after multiple viewings.

Feasibility

Video displays are very expensive but are becoming more common on new and recently installed dispensers. Playing the misfueling message videos will displace other video messages intended to promote sales.

Cost

Some recently made dispensers may have multi

- media screens and will not need any upgrading to display the mid

- to high

- ethanol blend fuel presentation. Many dispensers- 49

-

installed in the last three to five years without a display screen may be upgraded for approximately $5,000. Dispen sers that cannot be retrofitted with a display screen must be replaced with a new dispenser that has a screen. This would be prohibitively expensive and would most likely pose a threat to the economic viability of the facility.

If the display will be used to ask customers if they have an FFV, it may be necessary to install a central controller to accept vehicle information. The cost of a controller located at a fuel dispensing facility is between $10,000 and $20,000.

This estimate does not consider the l oss of sales due to replacing promotional messages.

Funding Sources

The cost to purchase new dispensers or revise dispenser software will be paid by the fuel dispensing facility owner.

Pros and Cons

Pro

Provides an easy way to communicate with customers. By confirming that the customer really wants to purchase a mid

- to high

- ethanol blend fuel, unintentional misfueling can be minimized.

Con

Customers can ignore the message. The presentation does not prevent intentional misfueling. Dispenser l ife can range up to 15 years, so it may remain in operation after the message on the video is no longer relevant. Updating the message may be difficult if the prevailing video format changes. Facility operators will not be enthusiastic about replacing pro motional messages with misfueling messages. Independent dealers may see no reason to make an expenditure which has no

direct benefit to their sales.

Timeframe for Implementation

Once the fueling presentation is ready, the time to initiate this measure is limited by the

number of video

- ready dispensers.- 50

-

14. DMV Mailing

Description

Each state’s department of motor vehicles (DMV) annually sends out a registration renewal notice and a license tag to the owner of each motor vehicle. A customized message in either or both mailings would advise the owners of all registered vehicles

what fuels are appropriate for their particular vehicle and why misfueling is discouraged.

To control costs, mailings could be focused on those states with the largest number of fuel dispensing facilities or mid

- to high

- ethanol blend fuel dispensers. Automo bile associations would work with each selected DMV to implement the advisory program for motorists. These associations could offer suggested wording for the advisories and provide states access to a database of FFVs and E15 non

- FFVs.

Each DMV maintain s a comprehensive database of all vehicles in the state. Merging the two databases would allow motorists to receive a fueling advisory in the mail pertinent to

their vehicle.

Effectiveness

This measure provides direct contact with every vehicle owner in a state over the course of a year. For owners who have heard about mid

- to high

- ethanol blend fuels or are interested in using them, the information in the advisory will help them make a more informed choice when purchasing fuel.

Fueling information wil l not be conveyed if the message in the mailing is overlooked or ignored.

If the vehicle owner/operator is not the opener of the mailing, they may not be made aware of the information in the DMV mailing. If the advisory is mailed with the license

renewal notice, this is less likely to happen.

Public and Fuel Dispensing Facility Owner/Operator Acceptance

Acceptance of this program should be high because it provides fueling information in a

non

- confrontational and easy to understand way.

Feasibility

This program requires contacting and working with each state DMV. The effort could be time consuming because it will require convincing the agency that the program is worthwhile. In addition, it may require the agency to establish a new mailing procedure.

Cost

The cost to implement the program will vary between states. API could initiate the process and provide information for setting up the program. If the new advisory is- 51

-

included with existing mailing materials without increasing postage, the increme ntal cost to the agency should be small. There may be some additional administrative costs associated with setting up the mailing system to send appropriate messages to owners of

FFVs and +E10 non

- FFVs.

Assuming a national vehicle population of 228 milli on vehicles 11 and an estimated cost range between one mil and four cents per enclosure:

Cost = 228 million x ($0.001 to $0.04)

= $228,000 to $9 million

Funding Sources

The cost of mailing out advisories would be assumed by the DMV. The advisory would be included along with other information that is customarily sent in mailings and should not trigger the need for additional postage. Mailing costs could be reimbursed by owners through registration and annual licensing fees.

If funding is an issue, the state air quality agency might consider the potential reduction in emissions from minimizing misfueling worth funding all or a portion of the cost of the advisory program

.

Pros and Cons

Pro

Accurate fueling information reaches a majority of vehicle owners. Costs could be controlled by focusing mailings on states with a significant

number of facilities that offer mid

- to high

- ethanol blend fuels. State air quality agen cies might support providing information on misfueling to all registered owners.

Con

The fueling advisory in the DMV mailing could be overlooked or ignored when the motorist opens the envelope. Each DMV needs to contacted and worked with individually.

Ow ners may not share the fueling information from the DMV with other vehicle drivers, so refueling information would not necessarily reach every person who

refuels.

Timeframe for Implementation

The implementation time for sending out the first advisories i n each state is dependent on how quickly the DMV can revise their mass mailing process. Notification of each owner will occur within one year of the first mail out.- 52

-

15. Nozzle Hand Warmers

Description

Provide distinctive dispensing nozzle hand warmers or nozzle grips

- in addition to the labeling on dispensers

- to inform customers that they have chosen a mid

- to high

- ethanol

blend fuel. Hand warmers for each mid

- to high

- ethanol blend fuel could be a different color than those used for conventional gasoline grades. If the colors of hand warmers were standardized among all dispensing facilities, motorists could be confident that they have chosen the desired grade of fuel based on the color of the hand warmer.

Another approach is to use n ozzle grips that have a surface or texture that provides a different tactile sensation (such as a corn cob

- like feel) compared to gasoline nozzles. The intent is to prevent inadvertent misfueling by making mid

- to h igh

- ethanol blend fuel dispensing a different experience than gasoline dispensing.

This measure is appropriate for E85 nozzles because they are not used with uni

- hose dispensers for gasoline with an ethanol content of 10% or less. If E15 is offered alo ng with gasolines with an ethanol content of 10% or less, a single uni

- hose nozzle will not be able to display the mid

- to high

- ethanol blend color on the hand warmer.

Effectiveness

The different hand warmers and nozzle grips should alert motorists unint entionally trying

to fuel with a mid

- to high

- ethanol blend fuel. The range of available hand warmer colors and the lack of a standard color code for various fuels and gasoline grades can diminish the effectiveness of using color to alert customers. A no zzle grip with a different feel

would be noticeable to most customers.

Public and Fuel Dispensing Facility Owner/Operator Acceptance

Distinctive hand warmers and nozzle grips are non

- controversial and would be appreciated by customers who otherwise might not have noticed that they have mistakenly chosen a mid

- to high

- ethanol blend fuel.

Feasibility

Different hand warmers or nozzle grips for mid

- to high

- ethanol blend fuels and gasoline grades are quick and easy to install. If a standardized color co de were adopted, a pubic information program would be needed to educate the public to look for and identify the colors for different products.

Uni

- hose dispensers offering more than one product through a single nozzle will not be able to display a unique hand warmer color for each grade.- 53

-

Cost

The retail cost of a hand warmer ranges from $5 to $11 depending the nozzle model and quantity purchased. The cost to install one hand warmer on one mid

- to high

- ethanol blend fuel nozzle nationally at each fuel ing location is the following:

Cost = 162,000 locations x ($5 to $11 per nozzle)

= $800,000 to $1.6 million

Between six and twelve different colored or textured hand warmers can be installed at a fuel dispensing facility and the mitigation measure will still be considered low

- cost.

Hand warmer and nozzle grip life is similar to nozzle life

– approximately 6 to 18 months depending on use and abuse.

Funding Sources

The cost for installing hand warmers will be paid by the fuel dis pensing facility operator.

Pros and Cons

Pro

Calls attention to mid

- to high

- ethanol blend fuel s even if the customer fails to read signs. Standardized colors for hand warmers at all facilities would make choosing fuels

easier and reduce unintentional misfueling Easy to install and replace when worn out.

Con

Distracted or inattentive customers may not notice any difference. Does not prevent intentional misfueling.

Timeframe for Implementation

Hand warmers and nozzle grips can be quickly installed and replaced in the course of a

few minutes.- 54

-

16. FFV Identification Using a Web Site

Description

Develop a computer

- accessible web site that can be used to identify FFVs. The website

would not need to track non

- FFVs because a customer only need know their vehicle’s model year to determine whether E10 or E15 is appropriate. After providing year, make and model information or the VIN, the website would indicate which fuels a particular vehicle could use. The website could also provide information on m isfueling. The FFV database and website would be developed by programmers.

Vehicle manufacturers and other sources provide listings of FFVs, but a single up

- to

- date inventory for all FFV manufacturers does not seem to be available at this time. One prob lem in putting together a combined listing of all FFVs on the road is that in some cases there are subtle differences in the models and engine types shown among different sources. Part of the difficulty is that for some models the basis for determining if a vehicle is an FFV is to check the eighth digit of the VIN. Asking facility cashiers to have customers produce the VIN for their vehicle is an impractical and decidedly unpopular way to determine if a vehicle can refuel.

At locations with Internet acc ess, the application would be an easy way for a cashier to

check whether a customer’s vehicle is an FFV. The URL for the website would be made available to facilities. It could also be accessed by doing a Google search. Of course, a printout of the web site listing could be used as reference.

Individuals would probably use the program or application only once to determine if their

own vehicle was an FFV. The site could see additional use if one wanted to know if a rental or company car could use mid

- to high

- ethanol blend fuels. The site must be kept

current to reflect the latest vehicle models . There must be a designated website master to

assure continued maintenance of the site.

This measure is key to identifying FFVs for many of the other measure s in this paper.

Effectiveness

Access to a website can provide a quick and effective way of identifying FFVs.

Public and Fuel Dispensing Facility Owner/Operator Acceptance

The identification program may have limited application to individual motori sts because they will probably use the program only once or twice to determine their personal vehicles’ fueling capabilities.

Fuel dispensing facility cashiers will probably use the website frequently and find it helpful.- 55

-

Feasibility

The development of the website and database would be relatively simple and straightforward for a website programmer . There must be a designated website master to

assure continued maintenance of the site.

Cost

The cost to develop a database and a web site with an interf ace to access the information will depend on the website design. The FFV database would be relatively simple to design and set up.

Here are some typical costs for a 15

- page web site:

Set up and maintain domain name

- $10 to $35 per year. Hosting

- $150 to $250 per year depending on traffic and website feature. Web site design and graphics development

– 60 to 150 hours of computer time at $50/hour.

Cost = $50/hr x (60 to 150 hours)

= $3,000 to $7,500

Maintenance

- $500 to $1,200 pe r year depending on the number of updates.

Summary

First

- year cost range is about $3,700 to $9,000.

The annual operating cost is about $700 to $1,500.

This cost does not include the salary of the d esignated website master to assure continued

maintenance of the site.

Funding Sources

An automotive group such as the Alliance of Automobile Manufacturers could easily combine information on FFVs from its members, but including data on FFVs made by

non

- members could possibly be an issue. An organization representing the interests of

motori sts, such as AAA, is also another potential web host.- 56

-

P ros and Cons

Pro

On

- line applications provide a simple

- to

- use way of determining if a vehicle is an

FFV. Web sites can be accessed in the field by smart phones anywhere there is a Wi

- Fi

or cell phone signal. Cashiers at fuel dispensing facilities could use a laptop computer with a wired or

Wi

- Fi connection to quickly access FFV information. Relatively low cost of developing applications.

Con

Needs to be kept up

- to

- date with the latest vehicle models.

Potential users would need to be made aware of its existence.

Timeframe for Implementation

The development of a web site can take from one to three months depending on the complexity of the program.- 57

-

17. FFV Identification Using a Smart P hone Application

Description

Develop smart phone applications that can be used to identify FFVs. The application

would not need to track non

- FFVs because a customer only need know their vehicle’s model year to determine whether E10 or E15 is appropriate . After providing year, make and model information or the VIN, an application would indicate which fuels a particular vehicle could use. Programmers would develop the application.

Vehicle manufacturers and other sources provide listings of FFVs, but a s ingle up

- to

- date inventory for all FFV manufacturers does not seem to be available at this time. One problem in putting together a combined listing of all FFVs on the road is that there are subtle differences in the models and engine types shown among dif ferent sources. Part of the difficulty is that in some cases the basis for determining if a vehicle is an FFV is to check the eighth digit of the VIN. Asking facility cashiers to have customers produce the VIN for their vehicle is an impractical and deci dedly unpopular way to determine if a

vehicle can refuel.

The smart phone application would be an easy way for a cashier to check whether a customer’s vehicle is an FFV. The applications would be made available for free. Of course, a printout of the we bsite listing could be used as reference.

Individuals could download the application, but would probably use it only once to determine if their own vehicle was an FFV. The application could see additional use if one wanted to know if a rental or company car could use mid

- to high

- ethanol blend fuels. The applications must be kept current to reflect the latest vehicle models.

Effectiveness

Access to a handheld smart phone application can provide an effective way of identifying

FFVs.

Public and Fuel Dispensing Facility Owner/Operator Acceptance

The identification application may have limited application to individual motorists because they will probably use the program only once or twice to determine their personal vehicles’ fueling capabilities.

Fu el dispensing facility cashiers will probably use the application frequently and find it helpful.

Feasibility

The development of the computer program and smart phone applications would be relatively simple and straightforward for a professional programmer.- 58

-

Cost

Each smart phone operating system (Apple iPhone, RIM Blackberry, Simbian, Google Android, Windows M obile, etc.), which provides a standardized interface and platform for various smart phones, will require the development of a separate program. The application program could be developed for one or two systems. Traffic on for the applications could be m onitored for a period of time to determine if it is advisable to develop the application for other systems.

The cost to develop a smart phone application seems to have a wide range and is dependent on the application’s design. Development costs for a sim ple application can apparently range from $10,000 to $50,000 although one would expect that there would be carryover between operating systems. These figures seem high for an application that merely provides access to a static database.

Funding Sources

An automotive group such as the Alliance of Automobile Manufacturers could easily combine information on FFVs from its members, but including data on FFVs made by

non

- members could possibly be an issue. An organization representing the interests of

motori sts, such as AAA, is also another potential web host.

Pros and Cons

Pro

Smart phone applications provide a quick and easy way to determine if a vehicle

is an FFV. Smart phone applications are accessible anywhere there is a cell phone or Wi

- Fi signal.

Con

Applications need to be kept up

- to

- date with the latest vehicle models. Cost of developing and maintaining applications. Potential users would need to have a smart phone and be made aware of the existence of the application.

Timeframe for Implementation

The development of an application can take from a few weeks to a several months depending on the complexity of the program.- 59

-

18. Public Education Program

Description

The purpose of a public education program is to educate drivers abou t using the proper fuel for their vehicles. The program would not necessarily target those who intentionally

misfuel with mid

- to high

- ethanol blend fuels, but misfueling rates should go down as

motorists learn about what fuels are suitable for their vehi cles. The messages to all drivers would be directed at identifying and choosing the right fuels for your vehicle.

Public education is a key part of many of the other measures described in this document. Details specific to any of those measures could be incorporated into this program.

At first the program would be focused on states that have the most facilities that offer

mid

- to high

- ethanol blend fuel s. As mid

- to high

- ethanol blend fuels become more widespread, the program could be broadened and ma de available regionally or nationally. The following formats could be used to get the message out:

TV Public Service Announcements

– Short ads showing which vehicles can use

mid

- to high

- ethanol blend fuels should be run on broadcast television or cabl e stations.

To attract viewers, use well

- known celebrities

– especially those with an

automotive connection

– to put the message across. Such PSAs will most likely get considerable interest from audience segments that ordinarily might not pay

much a ttention to the finer points of fueling. PSAs with appeal may also undoubtedly end up on YouTube and be seen by an even broader audience.

Signs and posters in fuel dispensing facilities

– Signs of various sizes would be designed to identify mid

- to hi gh

- ethanol blend fuels. Other signs or posters would help identify FFVs and educate about non

- FFVs. For example, posters

could direct motorists to look inside the fuel door to see if there is a sticker or yellow gas cap identifying the vehicle as a FF V.

Handouts

– Prepare small handouts that can be available at fuel dispensing facilities to identify mid

- to high

- ethanol blend fuels. The handouts can also be used to explain why certain measures have been put into place to prevent misfueling and th e risks of using mid

- to high

- ethanol blend fuels in E10 non

FFVs. The handouts can also be made available at other automotive related locations to promote proper fueling.

Nozzle advertising

– A notice posted on the nozzle informs the customer that it is

for a mid

- to high

- ethanol blend fuel. An example of this type of system is the

Nozzle TalkerTM.

Credit card inserts

– Small notices discussing misfueling could be placed in credit card bills. Oil company credit cards may be the most focused audience, although major credit cards could include the inserts for consumers who have charged- 60

- gasoline purchases in the past. The inserts will have to compete for attention

from other adver tisements, offers and promotional materials.

API member companies will probably want to produce their own signs and posters that are consistent with their marketing programs. Independent fuel distributors and dealers will use custom or generic signs.

Ef fectiveness

Public education is probably the best and most efficient way to inform motorists that misfueling is not in their best interest. The effectiveness of the program will depend on effective messaging, the means of conveying the messages and the w idespread and comprehensive nature of the education program.

Public and Fuel Dispensing Facility Owner/Operator Acceptance

A public education campaign focused on presenting information that informs the motoring public about fuel choices and the reasons t hat misfueling is unwise will be viewed positively. If the program is entertaining, it will attract public interest, but if it is just facts and a listing of FFVs, the general public may not pay much attention to it.

Feasibility

Public information and advertising are well accepted methods of presenting information.

Cost

The cost of a public education program will depend on the message format and how widely it is distributed.

Funding Sources

Just about any public or private entity with an interest i n reducing misfueling could prepare and promote a public information campaign. There is no reason why more than one organization could not mount an individual or joint promotional effort. It will be critical, however, that there is some amount of consist ency in the messages.

Pros and Cons

Pro

Provides accurate information to a wide audience on fuel choices to reduce misfueling.

Con

Broadcast media messages have a limited life and need to be kept fresh to retain

their effectiveness. The same is true for signs and posters.- 61

- The public is blasé about vehicle refueling practices. Unless a public information program can grab their attention

– even momentarily

– it will be displaced by other messages with more appealing content.

Timeframe for Implementat ion

Signs and posters for use in fuel dispensing facilities can be prepared, approved, printed

and distributed in the course of several months.- 62

-

Notes

1. EIA, Supplemental Tables to the Annual Energy Outlook 2010, Table 58. Light

- Duty

Vehicle Stock by Technology Type, http://www.eia.doe.gov/oiaf/aeo/supplement/supref.html

2 . US Environmental Protection Agency, MOVES2010 Mobile Source Emissions Inventory Model, March 2, 2010 http://www.epa.gov/otaq/models/moves/index.htm

3. Facility data is from NPN (National Petroleum News) 2009 facility survey.

4

. The basis for estimating the distribution of the number of islands at fuel dispensing is based on information presented in Section III A of the CARB study entitled “Enhanced Vapor Recovery Technology Review”, September 2002. http://www.arb.ca.gov/vapor/archiv e/2002/arc2002.htm

The number of islands for each category of facilities was arbitrarily assigned based on throughput. Few facilities with throughputs of less than 50,000 gallons per month are unlikely to have more than one pump island. Likewise, relati vely few facilities with throughputs less than 100,000 gallons per month are likely to have more than two pump

islands.

5

. Hourly mean wages for mechanics at gasoline stations are based on figures from “Occupational Employment and Wages, May 2008”, Burea u of Labor Statistics, http://www.bls.gov/oes/current/oes493023.htm

.

6. The annual wages for service station attendants is $7.33 an hour for the 10 th percentile and $13.53 per hour for the 90 th percentile of the cohort. The average hourly cost to fuel dispensing facilities for service stations attendants is arbitrarily assumed to be $10.00 an hour including the employer’s FICA contribution and other benefits. Based on national figures compiled by the Bureau of Labor Statistics for May 2008. http://www.bls.gov/oes/current/oes536031.htm

7. Information in this section is based in part on a November 6, 2009, conversation with

Harold Haskew, Harold Haskew and Associates.- 63

-

8. Fuel system (i.e., tank, filler neck and appurtenances) replacement costs based on a 2002 GMC Sierra pickup. Costs are considered typical for other makes and models

Cost of fuel tank replacement:

Par ts

Fuel tank $292

Filler neck 61

Hardware Lock ring 20 Fuel tank strap 38

Hoses and connectors 39

Total parts $450

Labor for draining old tank, removal and replacement:

2 hours x $50/hr = $100

Total parts and labor tank replacement $450 + $100 = $550

Cost for replacing fill neck only : (Remove fuel tank, replace fill neck, reinstall fuel tank)

Filler neck $61 Lock ring 20 Fuel tank strap 38

Hoses and connectors 39 Total parts $158

Labor for draining tank, removal and reinstallation:

2 hours x $50/hr = $100

Total parts and labor for fill neck replacement $158 + $100 = $258

9. Based on a November 9, 2009, conversation with Pete Moyer of Orpak USA and a November 10, 2009, co nversation with Kevin DeVinney of Gilbarco.

10. Based on a November 10, 2009, conversation with Kevin DeVinney of Gilbarco.

11. Based on the total number of on

- highway registered vehicles in 2007.
EIA, Supplemental Tables to the Annual Energy Outlook 2010, Table 58. Light

- Duty Vehicle Stock by Technology Type, http://www.eia.doe.gov/oiaf/aeo/supplement/supref.html