ALEXANDRIA, Va. - This week, NACS sent a letter to the Environmental Protection Agency (EPA) regarding its concerns about the "2017 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions and Corporate Average Fuel Economy Standards (CAFE)."

The proposed rules could make it "extremely difficult and expensive to satisfy the requirements of the Renewable Fuels Standard (RFS)" for gasoline retailers. The "proposed CAFE revisions could dramatically reduce the amount of motor fuel consumed in 2022 and beyond, creating a situation in which renewable fuels will be required to represent a significantly greater share of the market than originally anticipated."

The challenge to retailers is two-fold: equipment compatibility and consumer demand. "With the proposed CAFE revisions, the problem becomes exponentially more serious over the next 10 years. By 2022, to satisfy the RFS every gallon of gasoline must contain nearly 40% renewable fuels. This means that fuel retailers will be required to replace all of their fueling equipment. This will cost the industry billions of dollars."

After retailers invest an enormous amount of money in upgrading or replacing equipment, "only one in six consumers will drive vehicles capable of running on the mandated fuels: EIA projects only 16% of consumers will drive FFVs by 2035."

With more than half of convenience stores owned by individuals, the "burden for satisfying the RFS under the new CAFE standards will fall squarely on the small businesses that dominate the fuels retailing market and many will likely go out of business."

NACS urges the agency "to consider the implications of this proposed rule on other regulatory requirements already affecting not just the automobile industry but the fuels industry as well. NACS does not believe that improved efficiency, enhanced sustainability, national energy security and economic growth are mutually exclusive objectives. But if they are not pursued in a strategic, coordinated effort they can lead to unintended consequences that can derail progress towards all of the objectives."

For more on CAFE standards and the future of retail motor fuels be sure to pick up the upcoming March issue of NACS Magazine.