|Received:||4/7/2008 3:41:54 PM|
|Agency:||Federal Trade Commission|
|Rule:||Automotive Fuel Ratings, Certification and Posting|
Comments:Because of our involvement in the trucking industry the potential for numerous types of new alternative fuels and blends requires that consumers know exactly what kind and percentage of fuel is being purchased. Specifically in regards to biodiesel, the proposed biodiesel blend percentages as noticed do not convey enough information to the consumer. This is especially critical for biodiesel blend in that the biodiesel being blended into petroleum has a wide range of cloud points dependent on the feedstock from which the biodiesel is refined from. Cloud point is an especially critical piece of information for the transportation industry in the cold season months since the temperature at which a fuel clouds directly relates to fuel filter plugging or Cold Filter Plugging Point (CFPP). The CFPP is the temperature of the fuel at which wax or other products form which prohibit fuel from passing through the fuel filter, thus starving the engine of fuel. As noted in the National Biodiesel Board's "Cold Weather Blending Study", biodiesel exhibits a 22 degree F cloud point spread dependent upon the feedstock of the biodiesel. The cloud points specific to each biodiesel dependent upon its feedstock directly impact the cloud point of the resulting biodiesel - petroleum blend depending upon the percentage of biodiesel in the blend; typically higher biodiesel percentages result in higher (warmer) final fuel blend cloud points. For transportation, knowledge of the fuel cloud point is critical since a truck may start in Texas in 75 degree weather only to end up later in Minnesota in 10 degree weather. In light of the insignificant cost of posting biodiesel blends, as demonstrated in this FTC notice, it is not a hardship upon the fuel retailer to note specific biodiesel blend levels contained in their fuel. We suggest that the decal notice biodiesel ranges in 5% increments such as "B5 to B10" or "B10 to B15". Anything greater than B20 can be labeled as described in the notice. We would suggest that the label be colored green instead of purple since the color green has historically been tied to diesel fuel to help distinguish it from gasoline at retail. To introduce another color into the traditional petroleum color scheme would be unwise. We do believe that the costs of the decals and installation quoted in this notice are accurate. The current price of the yellow octane decals is within the range of the price quoted for biodiesel blend decals in this notice. Octane decals, as with numerous other petroleum industry decals, are readily available from numerous suppliers across the U.S. We believe that the most significant aspect of the posting of biodiesel blend percentage is to help convey the temperature at which the biodiesel blend fuel begins to "cloud" and thus start to impose drive ability restraints upon equipment. FTC must also remember that fuel "travels" in that it is purchased in one part of the country and travels quickly into other parts of the country in which different ambient temperatures may exist. Optionally, biodiesel blend retailers could provide needed cloud point temperatures by posting the current cloud point of the fuel being dispensed.