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Statement of Rick Podliska Deputy Director, Government Relations American Motorcyclist Association

Public Hearing for the 2014, 2015, and 2016 Standards for the

Renewable Fuel Standard Program

June 25, 2015

Members of the committee, thank you for the opportunity to provide comment on the U.S. Environmental Protection Agency’s proposed Renewable Volume Obligations rule for 2014,

2015 and 2016. My name is Rick Podliska

, and I am the American Motorcyclist Association’s deputy director of government relations.

The AMA urges the EPA to not increase, and, instead, to lower the proposed volumes when the final rule is issued Nov. 30. The proposed volumes would increase the r isk of inadvertent misfueling for motorcyclists and all

- terrain

- vehicle owners by forcing the widespread availability of higher

- ethanol fuel blends, such as E15.

The EPA proposal would increase the amount of ethanol from all sources in the nation’s fuel

s upply to 17.4 billion gallons in 2016, up from 15.93 billion gallons in 2014.

Those increases would come despite the EPA’s acknowledgement that the market cannot absorb these higher ethanol production rates.

The practical effect of the EPA’s action is that ethanol production will exceed the “blend wall,”

That means more E15 and less E10 on the market.

Moreover, the proposed rule calls the expan sion of the use of renewable fuels to meet the 2016 standards by:

 “... providing grants to retail owners, and locating stations offering E15/E85 closest to higher populations of vehicles that can use those fuels” and

 “Developing contractual mechanisms to ensure favorable pricing of E15 and E85 at retail compared to E10 to boost sales volumes”In other words, the EPA is proposing federal grants and price controls to increase amount of the

higher

- than E10 ethanol blended fuels into the marketplace. The AMA strongly disagrees with this approach.

Regarding E0 , the EPA discounts it and does not factor it in its scena rios. The EPA views E0 as a “constraint on the volume of ethanol that can be consumed...and expect(s) such volumes to be lower than they were in the past as the market strives to expand consumption of ethanol under the influence of the RFS program.” This sta tement contradicts the data from the federal Energy Information Administration shows that demand for E0 rose from 3.4 percent in 2012 to nearly 7 percent in 2014. Consumers want E0 for their motorcycles, ATVs, boats, lawn mowers and other equipment because it does not pose the risk of engine and fuel system damage.

Most importantly, the proposed rule mentions the likelihood of misfueling only once. The rule states: “...in June of 2011, the EPA finalized regulations to prevent misfueling of vehicles, engines , and equipment not covered by the partial waiver decisions.” This is the same misfueling mitigation plan that initially mandated a four

- gallon minimum fuel purchase to address the concerns raised by the AMA. It eventually was revised in 2013 to the current plan following our complaints, yet it is still easily misunderstood, misapplied or ignored by state governments and producers, distributors and vendors.

Indeed, the EPA has made it illegal for motorcyclists and ATV users to use E15 fuel

, an d yet seems to have little interest in the misfueling issue. It seems the EPA’s proposed rule does not consider the concerns of motorcyclists and ATV owners

, despite knowing that none of the estimated 22 million motorcycles and ATVs in use in the United States is approved to use E15 or higher ethanol blends.

Thank you for the opportunity to provide comments.