Fuels and Fuel Additives
E15: Survey Plan
- 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 have an EPA-approved compliance survey and to begin implementation of the EPA-approved compliance survey prior to E15’s introduction into commerce.
On May 4, 2012, the RFG Survey Association (RFGSA) submitted the "2012 E15 Compliance Survey Plan" on behalf of 71 companies for EPA approval. The RFGSA plan provides for a nationwide survey of industry compliance with E15-related requirements, including pump labeling and fuel specifications. It is similar in many respects to surveys conducted for other fuel regulatory programs. On May 23, EPA sent RFGSA a letter informing RFGSA that the 2012 E15 Compliance Survey Plan is sufficient to satisfy the survey requirements of the partial waivers and the E15 Misfueling Mitigation Rule (E15 MMR) for calendar year 2012.
With EPA’s approval of the RFGSA plan for 2012, every company that enrolls in the RFGSA plan meets the waiver condition for a survey plan for 2012 and any future year for which the survey is submitted and approved and the company is enrolled. (Under the E15 MMR, survey plans are submitted for approval each year for the following year.) Any company that wishes to enroll in the RFGSA’s E15 Compliance Survey program should contact RFGSA concerning the details of how to enroll (see here). Any company or group of companies may develop and submit a different survey plan for EPA approval, if the company or group so chooses.
Full implementation of an EPA-approved survey plan is a further condition of the E15 partial waivers. Failure to fully implement an approved plan means the E15 introduced into commerce by the plan’s submitter(s) or enrollee(s) is not covered by the partial waivers.
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Fuel and fuel additive manufacturers that enroll in RFGSA’s E15 Compliance Survey program must also register their E15 or ethanol for use in making E15 before introducing E15 into commerce (see here for more information about registering fuels). Fuel and fuel additive manufacturers must also submit a misfueling mitigation plan (MMP) to satisfy the E15 partial waiver conditions prior to introduction of E15 into the market (see here for more information about MMPs).
- RFG Survey Association E15 Compliance Survey Plan – 2012 Submission (PDF) (24 pp,1.6MB, May 4, 2012)
- Letter from EPA to RFGSA about E15 Compliance Survey – 2012 Submission (PDF) (2 pp, 948k, signed May 24, 2012)
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