On behalf of the Urban Air Initiative and a coalition of environmental organizations, renewable fuel producers, and farm boards, BG&A filed comments on Thursday, concerning EPA’s Proposed Renewables Enhancement and Growth Support Rule, which would regulate the sale of ethanol-gasoline fuel blends.

BG&A’s comments ask EPA to correct its erroneous interpretation of the “sub-sim” law, section 211(f) of the Clean Air Act. Contrary to the law’s plain meaning, EPA interprets it to confine the sale of gasoline-ethanol blends with more than 15% ethanol to vehicles that have been certified on E85. BG&A explains that EPA’s interpretation of the statute is unreasonable and subverts the structure of the Clean Air Act. By correcting its interpretation, EPA could expand the efficiency and pollution benefits of increased ethanol use to the entire vehicle fleet, greatly expanding the benefits of the Proposed Rule.

BG&A’s comments also ask EPA to correct several unnecessary features of the Proposed Rule that frustrate its stated objective of “facilitat[ing] further expansion of ethanol blended fuels.”

The comments are available here.