“Fueled for Thought,” By Joe O’Brien, Source North America

In October, President Trump directed the U.S. Environmental Protection Agency (EPA) to begin a rulemaking that will allow year-round sales of E15 across the country. With its attractive price-point (E15 usually sells for less than E10), this ethanol blend presents an opportunity to capture new revenue on the forecourt. What does the future hold for this ethanol blend? Let’s take a look at four issues surrounding its potential adoption.

 

Discord over year-round E15 persists within the industry

The expansion of E15 thus far has been characterized by strong points of view from ethanol, petroleum and small-engine groups. Concerns originally centered around equipment damage that could result if users mistakenly fuel incompatible engines with E15. In fact, several major U.S. oil refiners including Valero Energy Corp., Marathon Petroleum and Andeavor (then Tesoro Corp.) initially refused to sell E15, citing such concerns.

Secondarily, E15 represents an important playing card in the pursuit of Renewable Fuel Standard Program reform. In a September letter to President Trump expressing opposition to the RVP waiver for E15, the American Petroleum Institute and the American Fuel & Petrochemical Manufacturers trade association write “Meaningful reforms to the Renewable Fuel Standard (RFS) are integral in any discussion about E15.” Year-round E15 is a lucrative prize for the ethanol industry. But for the oil industry, the unilateral policy change essentially strips them of a bargaining chip. Further, some opponents have suggested that the EPA doesn’t have the legal authority to issue the E15 RVP waiver without action from Congress.

 

Truth in labeling is critical

Currently, stations that sell E15 must have an EPA-approved E15 label affixed to the dispenser and they must adopt an EPA-approved Misfueling Mitigation Plan (available free from the Renewable Fuels Association). But with efforts to re-brand E15 as Unleaded 88 underway, concerns about end-user fueling errors are growing.

“The use of non-specific product names for E15 blends not only misleads consumers into believing they are purchasing midgrade E10, but doing so at a price far below that of regular unleaded sold at the competing retailer across the street,” the Petroleum Marketers Association of America (PMAA) said in an announcement to its members. Given that fuel price is the primary influencer in a consumer’s selection of where to fuel, it is a reasonable concern that E15’s price will have similar influence on consumers’ fuel selection at the pump. In pursuit of improved transparency of labeling and marketing of E15, PMAA sent a letter to the Federal Trade Commission requesting the agency examine E15 labeling on fuel dispensers and price signs.

 

Compatibility and compliance considerations require planning for new adopters

Ethanol blends may impact the performance of materials used within a fueling system. Although fueling equipment manufacturers have upgraded materials to develop products compatible with blends up to E25 or with blends up to E85, materials used in pre-existing equipment should be re-evaluated.

For instance, the EPA said in a Technical Compendium that the agency “thinks that pipe dope used prior to 2007 is probably not compatible with ethanol blends greater than 10 percent.” In addition, many UST systems installed since 2007 used less expensive pipe dope that is only compatible with E10. Accordingly, an owner or operator looking to store ethanol blends greater than 10 percent in a system not specifically installed for that purpose “will presumably need to modify each threaded connection point where pipe dope seals the threads.” Station operators who are considering adding E15 to their product mix need to be aware of this and modify their systems accordingly. Reference the EPA’s Underground Storage Tank Technical Compendium about the 2015 UST Regulations for additional guidance about pipe dope.

According to the U.S. Department of Energy’s “Handbook for Handling, Storing and Dispensing E85 and Other Ethanol Blends,” the EPA requires fuel site operators to also have a dispenser dedicated to selling E10 or less, and they must follow approved dispenser and hose configurations for E15. Operators storing E15 in underground storage tanks also need to follow these steps:

  • Notify their implementing agency (usually a state office) 30 days prior to switching fuels to store an E10+ blend
  • Demonstrate compatibility through either a nationally recognized, independent testing laboratory certification or listing for the equipment used for the fuel stored, or demonstrate approval from the equipment or component manufacturer for use with the fuel stored. A statement affirming compatibility must be in writing and list the specific ranges of biofuel blend with which the equipment or component is compatible. The Petroleum Equipment Institute compiled a UST Component Compatibility Library. Visit PEI’s Compliance & Funding page (on the Resources tab) for compliance letters from equipment manufacturers.

Implementing agencies may have other options for demonstrating compatibility, and additional requirements may apply.

 

There are financial considerations to be made when deciding whether to blend E15 at the fuel site or have it delivered as E15

As E15 began to be offered, the typical marketer would use a device in the dispenser to blend E10 from one tank and E85 from another tank, requiring a sophisticated blend ratio to account for the ranges in the percentages of ethanol mix, particularly for the E85 portion. This is still by far the most prevalent method for dispensing E15. Today, some marketers who are serious about offering E15 in their product portfolio have opted to install a separate tank dedicated to E15 and they have the product delivered to their site from the fuel terminal. In a scenario where E15 is not allowed for year-round sales, a dedicated E15 tank would have to be properly shuttered for the period it is not allowed to be used. The option that the fuel site operator selects will have consequences for the relevant parts of the fueling system on the site, likely requiring equipment upgrades.

 

Conclusion

While several major retail fuel chains have added E15, or have announced plans to do so, some entities are deferring action until later. For example, Bloomberg recently reported that Marathon was considering a plan to introduce E15 to its stations in Minnesota, which has the highest number of E15 fueling locations in the United States. The refiner later downplayed these plans, saying the company would postpone a decision about E15 until after the EPA completes the rulemaking.

That notwithstanding, early adopters will position themselves to attract new customers. Barring any legal challenges, the EPA plans to introduce the final rule by May 2019. Station operators who are thinking about adding E15 to their fuel site should contact their state and local authorities to review the regulations for their area and consult with a trusted equipment supplier or technician who can help evaluate what preparations are needed.

 

Joe O’Brien is Vice President of Marketing at Source North America Corporation. He has more than 20 years experience in the petroleum equipment fuel industry. Contact him at jobrien@sourcena.com or visit sourcena.com to learn more.

 

 

 

Links:

1: Letter, https://www.api.org/~/media/Files/News/Letters-Comments/2018/API-and-AFPM-letter-to-POTUS-9-25-18.pdf

2: Misfueling Mitigation Plan, https://www.epa.gov/sites/production/files/2015-09/documents/rfa-model-e15-misfueling-mitigation-plan.pdf

3: EPA’s Underground Storage Tank Technical Compendium about the 2015 UST Regulations, https://www.epa.gov/ust/underground-storage-tank-ust-technical-compendium-about-2015-ust-regulations#compatibility

4: Handbook for Handling, Storing and Dispensing E85 and Other Ethanol Blends, https://www.afdc.energy.gov/uploads/publication/ethanol_handbook.pdf

5: UST Component Compatibility Library, https://www.pei.org/ust-component-compatibility-library

6: Bloomberg, https://www.bloomberg.com/news/articles/2018-10-19/marathon-is-said-to-weigh-selling-high-ethanol-gas-in-minnesota