16 CFR Part 306; Automotive Fuel Ratings, Certification and Posting; Project No. R811005 #00425

Submission Number:
stephen mccarroll
North Carolina
Initiative Name:
16 CFR Part 306; Automotive Fuel Ratings, Certification and Posting; Project No. R811005
The introduction of 15% ethanol gasoline is a perfect example of a government agency's (EPA) being out of control and pursuing an agenda that is not in the best interest of the general public. Although ethanol has been touted as a "renewable" fuel, it is anything but that. It offers no net fuel-saving benefit whatsoever since it requires as much fuel to plant, fertilize, harvest and process the corn into grain alcohol as it produces. Ethanol is certainly no bargain. Although it typically sells for less than gasoline, a gallon of ethanol yields only 67% of its net energy, meaning about one-third fewer miles per gallon. On that basis, it has never been competitively priced. According to a study prepared by FarmEcon, ethanol E10 already added about $14.5 billion in automotive fuel costs during 2011 due to higher energy costs and negative effect on fuel mileage. This amounted to about 10 cents more for each gallon of U.S. gasoline. Ethanol tax credits (since discontinued), added another 4 cents/gallon. Ethanol (grain alcohol) is hygroscopic, meaning that it absorbs large amounts of water molecules that combine with petroleum to cause premature rust. It is also a powerful solvent that attacks rubber seals and plastic parts used in engine components, causing them to dissolve, stretch and wear out, or become dry and brittle. While EPA says tests show that E15 won't harm 2001 and newer vehicles, that claim is disputed. According to findings of the Coordinating Research Council and other organizations, as many as 5 million cars manufactured since 2001 could have engines damaged by running hotter fuel. Two (Toyota and Lexus), have put labels on gas caps warning that their engines are not designed to operate with E15, and that they won't be held responsible for damage caused by higher blend gasoline. A cautionary note from the National Automobile Dealers Association states that "If drivers mistakenly put E15 in their tanks and their vehicles aren't designed to burn it, they could risk damaging their engines. Car and truck owners may contact their dealership's service department to determine any fuel restrictions." Ethanol tends to dissolve and release corrosive matter (gunk) such as resins, varnish and rust which contaminates fuel and travels through marine engines to clog filters, carburetor jets and injectors. Since boats live in a water environment, and ethanol (alcohol) loves to absorb water, use of ethanol above E10 invalidates all marine warranties. A particularly troublesome issue for boat and fishing enthusiasts is ethanol decomposition of fiberglass gas tanks. The usual fix involves tank replacement, often a costly and time-consuming project, although lining or sealing a tank is sometimes possible for added protection. Furthermore, 15% ethanol will damage smaller sized gasoline engines (i.e. motorcylces, ATVs, yard and lawn equipment, etc... Using ethanol blends in 2-stroke engines such as mowers and chainsaws results in a low octane mix (lean fuel) which can destroy them. Referring to E10 ethanol, Rich Herder, owner of a lawnmower repair business in Westfield, New Jersey, reported to Popular Mechanics that "It's the biggest disaster to hit gasoline in my lifetime." He estimates that as much as 75% of his repair work results from use of the blend. Current consumption of 40% of U.S. corn for ethanol has already raised prices for livestock, dairy, poultry, eggs and other food industries that are passing cost hikes on to food consumers. Corn price volatility has more than doubled since RPS was enacted in 2007. Consumer food cost inflation, relative to all other goods, has risen to twice its 2005-2007 rate of increase as well due to sharp increases in corn, soybean and wheat prices. Corn prices have increased from $2.00/bushel in 2005/2006, to $6.00/bushel in 2011/2012. During these same periods, corn use for ethanol increased from 1.6 billion bushels to an estimated 5 billion, while feed-use corn declined from 6.2 billion bushels to an estimated 4.6 billion…and corn exports declined from 2.1 billion bushels to an estimated 1.7 billion. Most unfortunately, this escalating mandate-driven food price inflation puts heaviest burdens upon our poorest citizens at a time when a deflated job market has record numbers of these same populations on unemployment subsidies and food stamps. Ethanol offers no net fuel-saving benefit whatsoever since it requires as much fuel to plant, fertilize, harvest and process the corn into grain alcohol as it produces. Mandated ethanol use has prompted farmers to shift land use from balanced crop rotation practices in favor of an environmentally-costly emphasis on corn production. This irrigation and fertilization-intensive development has depleted aquifers, and has contaminated surface and subsurface water systems with nitrogen pollution. In addition, burning ethanol releases nitrogen oxide smog which causes respiratory diseases.