MEMORANDUM

Subject: Estimating E0 Volume Sold in the U

. S . at marinas

From: Lester Wyborny , U.S. EPA, Office of Transportation and Air Quality

To: EPA Air Docket EPA

- HQ

- OAR

- 201 5

- 0111

All recreational marine engines are currently produced and certified to operate on both E0 and E10. The number of older marine engines that were certified to operate only on E0 is in the extreme minority. Demand for E0 among owners of recreational marine engines is driven primarily by concerns about potential wa ter contamination, the phase separation that occurs with ethanol blends, and the resulting engine damage. For smaller watercraft that are commonly trailered to launching sites, gasoline is generally purchased from retail stations that by and large only of fer E10. Thus to the degree that there are sales of E0 to owners of recreational marine engines, it will occur primarily at marinas.

Stakeholders have communicated to the EPA that various entities make non

- ethanol

blended gasoline (E0) for sale at marin as. EPA has also heard from stakeholders that many marinas receive requests from boat owners for E0 gasoline, and in many cases, the local suppliers try to satisfy the boat owners’ requests. Because EPA was unable to find a direct estimate, publicly available or otherwise, of the volume of E0 sold at marinas, we conducted an analysis to estimate E0 sold at marinas for purposes of determining the applicable standards under the RFS program

.

A number of U.S. marinas are represented by the Association of Marina Industries (AMI)

. According to AMI’s website ( marinaassociation.org/ ) , AMI represents several hundred marinas, boatyards, yacht clubs

, public/private mooring basins, partner associations and marine industry vendors and supplie rs across the U

. S

. and the world. The AMI webpage also states that 38 million gallons of fuel was sold from the marinas they represent in 2010.

In discussions with representatives from AMI, we were told that AMI represents 500

marinas in the U

. S

. and many of those marinas sell fuel, although some do not. The 38 million gallons of fuel sold at the marinas they represent includes both gasoline and diesel fuel, but the AMI did not know how much of each. Also, the 38 million gallon figure reported b y AMI is the result of a survey, and AMI did not know what fraction of total fuels sales at their marinas the 38 million gallons represents, because some marinas did not respond to the survey even though they

sell fuel. We asked AMI if there was a way for them to estimate the volume of gasoline sold at its marinas and AMI did not believe that there was any way to do that from the data that they had

on hand. AMI referred us to ValvTect, a company which markets additives for marine fuel at the

AMI member ma rinas

.

ValvTect produces additives designed to be blended into marine gasoline and diesel fuel. Their additives help to prevent corrosion, stabilize the fuels, provide some detergent qualities

, and help to control the effects of moisture , thus allowing the use of ethanol

- blended gasoline byboats if that is the fuel available . Their additives are blended into the E0 and ethanol

- blended

fuels used at 640 marinas across the US, out of the estimated 3000 marinas which sell fuels. At

the marinas w hich use their additives, both gasoline and diesel fuel s are marketed . S ome sell only a small amount of fuel, while others sell a significant amount of fuel. Valv Tect believes that the marinas at which their additives are used tend to be representative o f all marinas in the

U

. S

. and ValvTect estimated the volume of gasoline sold at those marinas is 50 million gallons

per year. ValvTect could not provide an estimate of the total volume of gasoline sold at all US

marinas. We estimated the total gasoline sold at all marinas by applying a ratio of 3000 to 640 to
the estimate d 50 million gallons of gasoline sold at the marinas that ValvTect sells its marine gasoline additives. Based on this methodology, we estimate that the t otal volume of marine gasoline sold in the U

. S

. is on the order of 248 million gallons.

In response to our questions regarding the amount of marine gasoline sold as E 0

, ValvTect replied that not all gasoline sold at marinas is E0. M arine gasoline is likely to contain ethanol when only gasoline blendstocks (rather than finished fuels) are available in the area, such as renewable blendstocks for oxygenate blending (RBOB) or conventional blendstock for

oxy genate blending (CBOB). Conver sely, finished gasoline which receives a 1 psi waiver and is simply splash blended with ethanol could be sold as E0

. Based on this information from ValvTect, we estimated the fraction of marine gasoline which is E0 versus E10.

We estimated the volume of marine gasoline sold in each state based on the number of

marinas in each state. Marinas.com provides the number of marinas in each state , which we

summarized in the table below

.

Estimated number of Marinas by State*

State # of

Marinas State # of

Marinas

Alabama 35 Montana UC

Alaska UC Nebraska UC

Arizona 1 Nevada UC

Arkansas 2 New Hampshire 15

California 468 New Jersey 438

Colorado 1 New Mexico UC

Connecticut 255 New York 900

Delaware 21 North Carolina 128

Dist. of Columbia 6 North Dakota UC

Florida 970 Ohio 243 Georgia 33 Oklahoma 1

Hawaii 19 Oregon 57

Idaho 1 Pennsylvania 33

Illinois 74 Rhode Island 153

Indiana 12 South Carolina 65

Iowa UC South Dakota UC

Kansas UC Tennessee 27Kentucky 34 Texas 67

Louisiana 19 Utah UC

Maine 277 Vermont 34 Maryland 428 Virginia 185

Massachusetts 394 Washington 303 Michigan 414 West Virginia UC

Minnesota 11 Wisconsin 151 Mississippi 18 Wyoming UC

Missouri 8 *The term UC means “under construction” meaning that data collection is incomplete

For some states

, information is not provided for the number of marinas and the website uses the term “under construction” (UC) to indicate this. It is likely that for most of these states, there are very few marinas in the entire state , or perhaps none, because they are states without a coastline

and contain few lakes. The exception to this is Alaska which has a very long coastline, although a very small population. Counting only those states for which Marinas.com p rovides a value,

there are a total of 6,301 marinas in the U.S.

To estimate the volume of marine gasoline which is E10 versus E0, we added up the number of marinas in predominantly Reformulated Gasoline (RFG) states, which includes California, Connecticut, Delaware, District of Columbia, Maryland, Massachusetts, New Je rsey, New York, and Rhode Island. While a substantial volume of conventional gasoline is sold in New York, this is offset by the many other states which include some RFG areas (but where RFG is not predominant)

, including Arizona, Georgia, Illinois, Indi ana, Kentucky, Louisiana, New Hampshire, Pennsylvania, Texas

, and Wisconsin . H owever, the RFG volume is either small relative to the total gasoline sold in these states, or these states have a fewer number of marinas. Using this method, we estimate that the volume of marine gasoline in predominantly RFG states is about half of the total marine gasoline sold. Thus, the volume of E0 is estimated to
be about half of the estimated 248 million gallons of marine gasoline sold in the U

. S

. , which we calculated t o be 1 24 million gallons. This volume of E0 is equivalent to about 128 million gallons of E10. Thus, the use of E0 rather than E10 at marinas reduces the nationwide total volume of ethanol consumed by about 13 million gallons.