Fuels and Fuel Additives
E15: Misfueling Mitigation Plans
- Frequently Asked Questions
- Notices & Regulations
- E15 Registration
- Misfueling Mitigation Plans
- Survey Plan
The E15 partial waivers include conditions (listed here) requiring each fuel and fuel additive manufacturer subject to the waivers to submit to EPA a misfueling mitigation plan (MMP), for EPA’s approval, and to fully implement the EPA-approved MMP prior to introduction of the fuel or fuel additive into commerce as appropriate.
On March 2, 2012, the Renewable Fuels Association (RFA) submitted the “Renewable Fuels Association Model E15 Misfueling Mitigation Plan” (PDF) (20 pp, 96K, March 2, 2012 Model Plan) to EPA for review. RFA developed the March 2, 2012 Model Plan to help fuel and fuel additive manufacturers meet the misfueling mitigation conditions of the partial waivers. On March 15, EPA sent RFA a letter informing RFA that the March 2, 2012 Model Plan would generally be sufficient to satisfy the partial waivers’ requirements for an MMP. EPA also noted that any company that wishes to use the March 2, 2012 Model Plan must notify EPA in writing that the company seeks approval of the Model Plan for the company’s use in meeting the waiver requirements for an MMP. EPA indicated that it may seek additional information and/or misfueling mitigation measures as needed from companies requesting to use the Model Plan.
On June 15, 2012, EPA approved the first MMPs for individual companies. The companies whose plans were approved had notified EPA in writing that they wished to use the March 2, 2012 Model Plan. Before approving their requests, EPA sought more information about how E15 would be dispensed, particularly from blender pumps. After working with RFA and individual plan submitters, EPA determined that an addendum to RFA’s Retailer Handbook (PDF) (48 pp, 4.37MB), which is referenced in the Model Plan, provided the necessary information for EPA to approve the individual plan submitters’ MMPs. EPA sent approval letters to companies (see sample letter (PDF) (4 pp, 83K) ). A list of companies that have approved MMP submissions may be found here. The list is updated at least every two months.
Any other company seeking approval to use the March 2, 2012 Model Plan should send EPA a letter referring to the March 2, 2012 Model Plan posted on this website and indicating the nature of the company’s planned E15-related business (e.g., refiner, ethanol producer, oxygenate blender, retailer). The letter should be on company letterhead, signed by a company official and mailed to the following address:
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Director, Compliance Division
U.S. Environmental Protection Agency
1200 Pennsylvania Ave., N.W. (Mail Code: 6405J)
Washington, DC 20460.
In deciding whether to approve the March 2, 2012 Model Plan for a company, EPA may seek additional information and/or require additional misfueling mitigation measures, as appropriate, considering the company’s specific circumstances. EPA must approve a company’s submission of an MMP before the company may use it to demonstrate its compliance with the requirement for an MMP.
Since the March 2, 2012 Model Plan does not spell out the specific elements of a survey plan, companies that use the Model Plan must submit a survey plan for EPA approval and cannot introduce E15 into commerce until EPA has approved the survey plan and the plan has been implemented. For more information concerning E15 survey plan requirements, please see the E15 Survey Plan page.
- Fact Sheet: Approval of E15 Misfueling Mitigation Plans (PDF) (3 pp, 156K, EPA-420-F-12-030, June 2012)
- Sample Letter from EPA Approving Misfueling Mitigation Plan Submission (PDF) (4 pp, 83K, May 2012)
- List of Companies with EPA-Approved E15 Misfueling Mitigation Plans (PDF) (2 pp, 110K, August 2012)
- Renewable Fuels Association Model E15 Misfueling Mitigation Plan Submission (PDF) (20 pp, 96K, March 2, 2012)
- Letter from EPA to RFA about Model E15 Misfueling Mitigation Plan Submission (PDF) (2 pp, 830K, signed March 15, 2012)
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