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  1. #1
    Registered User Shanghied Again's Avatar
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    Shanghied! 2004 Donzi 33 ZX
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    Feb 2002
    Toms River NJ

    We Need Your Vote Nmma Against 15% Ethanol "now"

    The U.S. boating industry needs your help in PREVENTING THE EPA FROM ALLOWING AN INCREASE IN THE AMOUNT OF ETHANOL in gasoline.
    Act Now
    On March 6th, 2009 a new pro-ethanol lobbying organization called Growth Energy aligned with 54 ethanol manafactures and formally requested that the Environmental Protection Agency (EPA) allow an increase of ethanol blend levels in gasoline to 15 percent (E15) As is required by law, the EPA on April 21 published a Notice for Comment in the Federal Register, beginning a 30-day public comment period that will close May 21, 2009.
    Failure to stop momentum at this stage will almost certainly cause all engine companies and thier suppliers to redesign and re-engineer product lineups at a time when all of us can least afford it.

    . Marine engines have not been tested with ethanol blends above E-10
    . Some marine engines have experienced issues using E10, and additional problems would certainly be anticipated with higher levels of ethanol blends.
    . Let the data tell the story! Tell the EPA to deny the E15 waiver until adequate testing has been conducted.

    Beat them at their own game
    Ethanol advocates are mobilizing forces to submit 20,000 favorable comments to the EPA, requesting that the agency grant a waiver for E15.

    There are 18 million boats currently in operation in the U.S., and none of them has been designed, certified or warrantied to run on anything above E10, the current maximum legal blend level.
    Boaters know that increased ethanol blends will cause performance problems with their boats and engines, increase maintenance costs, potentially pose safety risks and increase air pollution.
    And yet, neither EPA nor any other federal agency has performed a single test regarding the impacts of E15 on marine engines, fuel systems or components. Marine engines and fuels systems are not designed, calibrated or certified to run on anything above 10 percent ethanol. We ask you to support a science-first approach and urge the EPA to deny the ethanol industry's E15 Waiver request until independent and comprehensive scientific testing is completed on a full range of marine engines and other products.

    Once again, go to to submit your comments to the EPA .

    For more information, contact NMMA Legislative Director Mat Dun at [email protected] or call (202) 737-9760

    Mercury Marine joins the National Marine Manafactures Association in urging you to participate in this effort.

    Typhoon Service center also stands behind Mercury Marine and the NMMA to help make sure E15 will not be used until further testing!
    Last edited by Shanghied Again; 05-02-2009 at 03:57 PM. Reason: better header

  2. #2
    Registered User Shanghied Again's Avatar
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    Shanghied! 2004 Donzi 33 ZX
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    Feb 2002
    Toms River NJ
    Below this was my vote.
    May 2, 2009

    [recipient address was inserted here]

    Dear [recipient name was inserted here],

    Docket ID No. EPA-HQ-OAR-2009-0211

    I am writing to strongly urge EPA to deny the petition submitted on March 6, 2009 by Growth Energy and 54 ethanol manufacturers requesting a waiver under Clean Air Act Sec. 211(f)(4) to allow ethanol-gasoline blends containing up to 15 percent ethanol by volume (E15). There is insufficient data to justify approving any increase in the ethanol blend limit, particularly for marine engines and recreational vessels for which there has been literally no testing done by EPA or the Department of Energy regarding durability, performance concerns, or emissions concerns associated with higher ethanol blends.

    It is well-known that for marine and other small gasoline-powered engines that are designed, calibrated, and certified to run on not more than E10, higher concentrations of ethanol in fuel pose serious problems, including
    (1) Performance issues, such as drivability (i.e. starting, stalling, fuel vapor lock); (2) increased water absorption and phase separation of gasoline and water while in tank; (3) fuel tank corrosion, leading to oil/fuel leaks; (4) increased emissions, because the ignition of E15 creates a higher temperature than straight gasoline or E10; (5) damage to valves, push rods, rubber fuel lines and gaskets. All of these concerns raise significant safety issues with any increased ethanol blend, particularly for boaters who operate in harsh marine environments, often miles from shore.

    EPA must thoroughly and comprehensively test recreational marine engines, fuel systems and components and demonstrate that E15 will not defeat marine engine air emissions devices, poses safety risks to boating consumers, bring engines out of warranty, or otherwise damage the more than 18 million recreational boats currently in operation in the United States prior to approving E15. To date, such testing has not been conducted, nor will it be conducted prior to the waiver deadline of December 31, 2009.

    Additionally, EPA should not approve a "partial" or "conditional" waiver allowing E15 or other increased ethanol blends for only certain vehicles.
    This will cause enormous consumer confusion, misfueling, and put consumers and their products at risk. There is clearly insufficient scientific and technical data to justify granting the Growth Energy petition at this time. Again, EPA should deny this waiver petition unless and until sufficient testing is completed, and until it is affirmatively demonstrated that higher ethanol blends will not damage marine engines, their air emissions devices, or pose safety risks to consumers.


    Frank Civitano

    This is very easy to vote on line.

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