1 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 prove d utilizing high ethanol blends can lead to sig nificant 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 marin e 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 b oating 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 stati ons — 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 a ppropriate 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 a mongst 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.2

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 mit igation 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.