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Verbal Testimony of Michael Lewan

National Marine Manufacturers Association (NMMA)

Before the Environmental Protection Agency 

Renewable Fuel Standard Program: Public Hearing on the 2014, 2015, and 2016 Standards

Jack Reardon Center, Kansas City, KS 

June 25, 2015

My name is Michael Lewan and I am with the National Marine Manufacturers Association, which 

represents 1,400 businesses in the recreational boating industry. Our member companies provide an 

important recreational outlet for 88 million Americans, and we provide a significant economic boost to 

the country; supporting 650,000 jobs and $121 billion in annual economic activity.

NMMA and our member companies have strong reservations against the proposed RVOs.

Our engines are designed and calibrated to run on fuels up to 10 percent ethanol by volume, and by 

EPA’s own requirements are federally prohibited to run higher blends. 

And for good reason. In 2011, a DOE study of E15’s effects on marine engines proved utilizing high 

ethanol blends can lead to significant issues for marine engine consumers and can result in premature 

engine failure.

The EPA’s proposal threatens our engines. To meet the 2016 RVOs, 840 million gallons of excess ethanol 

will be needed at the expense of ethanol free fuel; the proposal estimates that E0 production will 

decline from 9.3 billion gallons to 130 million gallons. This, despite the fact that E0 demand doubled 

between 2012 and 2014—to the current 7 percent of the country’s fuel supply. 

E0 is the preferred fuel choice for marine engines. Particularly for our legacy fleet—of which there are 

still 16 million in use. The boating demand for E0 is real and it is not diminishing. 71 percent of the 9,000 

E0 locations are located in the top 20 states for boat registration. Many in the boating public seek out E0 

for its proven performance qualities—the RVO proposal would be denying these consumers choice at 

the pump. 

Additionally the proposal fails to guarantee that fuels E10 or lower are universally available at all retail 

service stations—where the vast majority of our consumers purchase fuel. Without the guaranteed 

availability of approved fuels, a station with a dedicated E15 hose is not required to additionally sell E10 

or lower blends. Such a scenario would leave consumers without appropriate alternatives. 

Finally, NMMA continues to have concerns over the EPA’s misfueling mitigation plan. A lone sticker on a 

gas pump is insufficient and ineffective; it does nothing to actually inform the consumers, not to 

mention it is easily lost amongst the signage, advertisements, and other labels common to a modern 

fuel pump. 

In absence of a stronger misfueling mitigation plan, the risk to misfueling increases as more E15 comes 

on the market—the onus to properly warn and educate consumers should rest with the EPA.
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NMMA strongly feels that the RVO proposal should be modified in a manner that reflects actual fuel 

consumption, specifically E0 demand, that guarantees the universal supply of approved fuels, and that 

contains an enhanced misfueling mitigation plan. 

We look forward to working with the EPA to achieve these common-sense goals. And, we will be 

submitting more substantial written comments along with today’s testimony.

Thank you.