16 CFR Part 306; Automotive Fuel Ratings, Certification and Posting; Project No. R811005 #00455

Submission Number:
Lawrence Theisen
Initiative Name:
16 CFR Part 306; Automotive Fuel Ratings, Certification and Posting; Project No. R811005
As a motorsports fan, with 40 plus years of experience, I have worked on many marine, off road vehicles, lawn and garden equipment and other hand held gasoline fueled equipment. Since the introduction of ethanol blended fuels I have seen degradation of fuel hoses, light metal carburetors and other materials exposed in the fuel systems to ethanol E10 fuel. Fuel hoses and plastic floats become brittle or spongy and break or split. Corrosion forms in the light metal carburetor passages and float bowls. This all adds up to starting and running problems and causes environmental pollution from leaks or fires. For many years to come we will always need 0 to E10 fuels for non road vehicle/motor sports use. I fully agree with the EPA that anything over E10 (i.e E15) be carefully labeled with warnings. I do not agree that the labels should be limited to 10% increments or they are a "Rounded" number in the normal sense of the term. E14 labeled as E10 will cause damage in the same way as E15, it will just take a little longer to happen. It would be safer for consumer use to label fuels in 5% increments and the fuel would be considered the next standard level of ethanol if it exceeded the lower level. This would effectivly have >0-10% ethanol blends called E10, >10% to 15% =E15, >15 to 20%=E20 and so on. As most consumers, I take any information provided by someone trying to sell me something with a grain of salt. I do my du diligence looking at other data and independent studies and reviews. As an educated consumer the more data the better so put more information on the pump label not less. I believe that mis-fueling is going to be a major issue with to many people who will be comparing prices only looking for the cheapest fuel. the only why to stop that is with pump nossle designs that will prevent mis-fueling.