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Will E15 Solve E10 Blendwall Problem —and When? August 1, 2013 PRX • Bill Hudson

Will E15 Solve E10 Blendwall Problem —and When? August 1, 2013 PRX • Bill Hudson. DOE Error #1. Unrealistic Annual Applicable Volumes.

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Will E15 Solve E10 Blendwall Problem —and When? August 1, 2013 PRX • Bill Hudson

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  1. Will E15 SolveE10 Blendwall Problem—and When? August 1, 2013PRX • Bill Hudson

  2. DOE Error #1. Unrealistic Annual Applicable Volumes. What was once thought of as a long term “mandate” has become—per its own cellulosic waiver provisions— an Arbitrary Annual Rule, which threatens each year to incentivize vast amounts of sugar ethanol imports

  3. DOE Error #2. MoGas Forecast in 2007 was 15-20% too high, bringing E10 Blendwall into play now, rather than a few years from now.

  4. PRO. EPA will not waiver the annual Applicable Volumes of RFS. Refiners will be forced, en masse, to make E15 (and its matching BOB) the standard fuel in the distribution system; Fuel retailers will be forced, en masse, to offer E15 to the public. CON. EPA will need to compromise (volume or timing) due to the fuel retailing system and its existing regulations Some 90 laws in 30 states require change for E15; Majority of carmakers have not changed engine warranties to cover E15; Dispensers in large share of stations may not be compatible with E15; Owners of all 600,000+ Underground Storage Tanks must demonstrate compatibility with E15 to EPA, per (90-page) Notice of Proposed Rulemaking (2-15-12), not scheduled to be Final Rule before Feb-2014. E15 to the Rescue — and When?

  5. E15 Timing affects PRX forecasts of corn demand 2014-2016.

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