### August 1 7 , 2010

MEMORANDUM TO: Docket: EPA

- HQ
- OAR
- 2010
- 0448 FROM: Cheryl Caffrey , ASD, Mechanical Engineer SUBJECT: RFA Summary of Engine Manual Recommendations on Use of Fuel with 10% Ethanol Nonroad engines designs had little changed for decades so it is unclear when they may have been modified to account for ethanol blends. As nonroad engines began encountering ethanol in the marketplace in the early 1980’s, predominantly

in the Midwest regi on of the United States, manufacturers began to provide guidance to their consumers on the use of ethanol blends and/or began to make design changes to accommodate E10. Owner’s manuals and organization websites provide information to the user about fuel s pecifications for the engine. The following tables list owner manual references from 1988 to present. Table D.4

- 2 lists several owner manual references to the use of ethanol fuel between 1988 and 2000 and it illustrates the range of owner notifications on the use of ethanol from no comment to “up to 10%” to “Caution”.

Table 1 : Sample Fuel Specification Recommendations from Several Nonroad Owner Manuals 1988

- 2000 ENGINE MANUFACTURE DATE ON

SERVICE MANUAL FUEL SPECIFICATION RECOMMENDATION ON FUEL WITH ETHANOL

John Deere Front Mower with Kawasaki Overhead Valve 4 stroke Engine 1988 Gasohol is accepted if not more than 10% ethyl alcohol is in the blend To help keep water out of fuel, fill tank at end of day’s operation

Mercury Outboard 1997 IMPORTANT: Gasoline containing alcohol (ethanol or methanol) can cause a formation of acid during storage and can damage the fuel system. If the gasoline being used contains alcohol, it is advisable to drain as much of the remaining gasoline as possible from the fu el tank, remote fuel line, and engine fuel system. Polaris Snowmobile 1997 Your Polaris vehicle is calibrated to use non

- oxygenated fuel with a minimum pum p octane of 91 or higher (R+M)/2 method..... Oxygenated fuel containing a mixture of up to 10% ethanol can be used in your Polaris vehicle if these guidelines are followed: 1. When using lower than 91 octane oxygenated fuel, you will need to have your dealer make adjustments to your engine and/or fuel system

- Depending on your state and local regulati ons, your fuel supplier may or may not be required to display the type of fuel they are selling. In this case you should assume that you are using oxygenated fuels and purchase 91 octane or higher (R+M)/2 or have your dealer make the necessary adjustments2. If using oxygenated fuel containing ethanol, additional alcohol deicers or water absorbing additives are not required and should not be used. Bom badier Jet Boat DI 2 stroke engine 2000 CAUTION: The use of a fuel other than regular unleaded fuel can result in craft performance deterioration and damage to fuel system and engine components. Never experiment with other fuels or fuel ratios. Never use fuel containing alcohol, methanol or similar products including naphtha. 

### E thanol began increasing in distribution in 2002/2003. Herman and Associates performed a survey

of nonroad engine owner’s manuals for the Renewable Fuels Association in 2003 and summarized manufacturer recommendations on the use of ethanol at that time. The results differ slightly

between and within the recreational vehicle, small engine, marine and motorcycle industries. Examples of engine manufacturer fuel recommendations are listed in Table III.D.4

- 3 Note that these contain more detail than those ref erences in Table III.D.4

- 2. This may be due to several factors including the fact that more information was known about ethanol use in nonroad engines and the fact that ethanol use was beginning to increase. Table 2 : Examples from 2003 Summary Tables of Nonroad Engine Manufacturer Fuel Recommendations Manufacturer Fuel Recommendations Range of

Comments on Using Fuel with Ethanol Comments (Example)

Recreational Up to 5%,

Up to10% When using oxygenates, carburetor main jet must be one size larger

than for regular unleaded gas. Power Approved,

Up to 10%, N/A Never use gasoline containing methanol, gasohol containing more than

10% ethanol, gasoline additives, premium gasoline, or w hite gas. Refer to engine manual for gasoline recommendations. Uses Briggs & Stratton, Honda or Kohler Engines. Engine is certified to operate on unleaded gasoline intended for automotive use. Alcohol

- blended fuels (called gasohol, ethanol or methanol) can attract mo isture which leads t o separation and formation of acids during storage. To avoid engine problems, fuel system should be emptied before storage for 30 days or longer. Use fresh fuel next season. Marine Sport boats:

Do Not Use Outboards: Up to 10%, Do not Use, Gasoline containing alcohol, methanol (methyl), or ethanol (ethyl),

may cause wear and damage to bearings, cams, piston(s), piston rings, corrosion of metal parts, deterioration of rubber and plastic parts, starting, idling, and other engine performance problems. Gasoline containing alcohol may cause the following problems to yo ur outboard and fuel system: corrosion of metal parts, deterioration of elastomers and plastic parts, wear and damage of internal engine parts, starting and operating difficulties, vapor lo ck or fuel starvation. Adverse effects of alcohol are more severe with methanol and areworse with increasing content of alcohol. The use of a fuel other than regular unleaded fuel can result in craft performance deterioration and damage to fuel system and engine components. Never use fuel containing alcohol, methanol or similar products including naptha. Motorcycle Up to 10%,

N/A Use only premium unleaded gasoline with a minimum pump octane

rating of 90 ((R+M)/2 method). If not satisfied with driveability or fuel economy when using an oxygenated fuel, switch back to regular unleaded gasoline or to a different brand. Use only unleaded gasoline, 92 pump octane minimum. Source: Herman & Associates, Washington, DC: Excerpts from Report on Fuel Recommendations for 2003 Model Year, Prepared for RFA


### In April , 2009, TCPalm posted the following on the internet regarding use of E10 in boat engines 1 

### : WHAT TO DO 1
- Avoid mixing regular fuel with E

- 10 fuel 2
- Frequently change fuel/water separating filters in fuel system. If none is installed, install one 3
- If it's an older boat, have a marina or service department arrange to clean the fuel tank 4
- If boat will not be used for some time, fill tank to about 95 percent capacity to leave for expansion

but reduce the chance for condensation. 5
- Never put E
- 85 in a fuel tank of a boat. 

### The article also stated that it's the older boats that are affected most by ethanol. Since ethanol is a solvent, it dissolves years of buildup off the inside of fuel tanks and fuel lines, in turn clogging up the fuel filters. In 2010, E10 is approximately 80% of the fuel distributed in the country . Owner manual samples were received from various industry stakeholders and are summarized in Table 3 . Th ey now indicate a general acceptance of E10 use, but no higher ethanol use, and marine manufacturers still caution against its use.

1 So urce: Doug Parylak, service manager, Manatee Marina, Port Salerno, http://www.tcpalm.com/news/2009/apr/17/ethanol

blended

- fuel

- leaves

- boaters

- fu mi ng/?print=1Table 3 : Owner Manual Recommendations from 2010, Small SI Engines Only

Engine Manufacturer Engine

Range Owner Manual Fuel Specifications
Kohler Nonhandhel

d Small SI Engines Gasoline/Alcohol blends

Gasohol (up to 10% ethyl alcohol, 90% unleaded gasoline by volume) is approved as a fuel for Kohler engines. Other gasoline/alcohol blends including E20 and E85 are not to be used and not approved. Any failures resulting from use of these fuels will not be warranted. Gasoline/Ether blends Methyl Tertiary Butyl Ether (MTBE) and unleaded gasoline blends (up to a maximum of 15% MTBE by volume) are approved as a fuel for Kohler engines

. Other gasoline/ether blends are not approved.

Honda Class I and

Class II Small SI Engines Refueling...

You may use regular unleaded gasoline containing no more than 10% ethanol (E10) or 5% methanol by volume. In addition, methanol must contain cosolvent s and corrosion inhibitors. Use of fuels with content of ethanol or methanol greater than shown above may cause starting and/or performance problems. It may also damage metal, rubber and plastic parts of the fuel system. Engine damage or performance pro blems that result from using a fuel with percentages of ethanol or methanol greater than shown above are not covered by warranty. If your equipment will be used on an infrequent or intermittent basis please refer to the fuel section of the STORAGE chapter (page 11) for additional information regarding fuel deterioration. ONAN Manufactur

er of Generators using Small SI engines FUEL RECOMMENDATIONS

Gasoline Generators

— Treat the engine of your Onan® or Camp PowerTMgenerator to a good grade of regular unleaded gasoline and it’ll purr in response. Gasohol (gasoline blended with alcohol) can be used if it contains the correct additive mixture percentages: • Ethanol Blend

— Not more than 10% ethanol. • Methanol Blend

— Not more than 5% methanol and must also cont ain solvents and corrosion inhibitors. Briggs and Stratton Class I and

Class II Small SI Engines Fuel Recommendations:

Fuel must meet these requirements:

- Clean fresh unleaded gasoline

- A minimum of 87 octane/87AKI (90 acron)- Gasoline with up to 10% ethanol (gasohol) or up to 15% MTBE (methyl tertiary

- butyl ether) is acceptable. CAUTION: Do not use unapproved gasoline, such as E85. Do not mix oil in gasoline or mofidy the engine to run on alternative fuels. This will damage th e engine components and void the engine warranty. Echo Handheld

engines (Small SI) Alternative fuels, such as E

- 15 (15% ethanol) or any fuels not meeting ECHO

requirements are NOT approved for use in ECHO 2

- stroke gasoline engines. Use of alternative f

uels may cause performance problems, loss of pow er, overheating, fuel vapor lock, and unintended machine operation, including, but not limited to, im proper clutch engagement. Alternative fuels may also cause premature deterioration of fuel lines, gaskets, carburetors and other engine components.
Fuel Requirements: Gasoline

– Use 89 Octane (R+M/2) (mid grade or higher) gasoline known to be good quality. Gasoline may contain up to 10% ethanol (grain alcohol) or 15% MTBE (methyl tertiary

- butyl ether). Gaso line containing methanol (wood alcohol) is NOT approved.

 References provided by members of the Engine Manufacturers Association 2010