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).
The E10 in use today and required in MA has cost me thousands of dollars in repairs to a pair of Yamaha HPDI outboards due to materials precipitating from the fuels and clogging filters. Increasing the ethynol content for marine engines will undoubtly cause severe and permanent damage to these engines. In fact, Yamaha states that these engines were designed for E10, but no higher. I have taken filter samples to a materials lab and have undisputable evidence that the material clogging filters is from the E10 fuel.
It's my understanding that E10 is mixed during delivery at the station. It's not difficult nor cost prohibitive to maintain the E10 blend for marine fuel docks while delivering E15 for automotive use.
I'm sure this isn't the first time you've heard the story and hope you will make the right choice.