|Organization:||Nevada Department of Agriculture|
|Agency:||Federal Trade Commission|
|Rule:||Proposed Amendments to the Fuel Rating Rule; FTC File No. R811005|
Comments:We are commenting on the use of Infrared based Octane screening techniques, rather than the use of traditional octane testing engines. The Bureau of Petroleum Technology for the state of Nevada has been using IR screening methods for more than 10 years. Our program has never had the staff, the space, the budget or sample load to justify acquiring the engines for each of our testing labs in Reno and Las Vegas. Primarily, we use tabletop models that utilize a 'wand' dipped into a fuel sample, but we also have Zeltex 101XL portable analyzers. We use these for testing octane and for determining % ethanol. As a rule, we do all of our analysis in the lab after samples are returned by Weights & Measures inspectors. However, if the situation arose, the Zeltex units could be taken into the field. When we find a failure, we verify as follows: we have a standing agreement with the state of California labs that we will send them sufficient sample to be analyzed using engines. However, we would first resample a location to verify a failure before taking that action. In addition, so much of our fuel now contains a significant amount of ethanol that it's been some time since we've seen a failure.