The National Marine Manufacturers Association submitted comments to the U.S. Environmental Protection Agency on Monday regarding the proposed labeling the agency has recommended to ensure that consumers do not mistakenly use E15 in their engines.
Gasoline with 15 percent ethanol has been approved for use in cars 2007 or newer, but not in older-model cars or boat engines. The NMMA and other industry groups are concerned that it will be easy for consumers to mistakenly use E15, which could cause damage to boat engines.
"The risk of misfueling is uniquely high in the recreational marine sector for a variety of reasons. ... For example, the overwhelming majority of recreational boats are towable and refueled at regular automotive gas stations - 95 percent of recreational boats are less than 26 feet in length. Boaters typically avoid fueling at marinas or on-water fuel docks because the premium paid for fueling at a marina can run between 75 cents and $1.50," the NMMA said.
The association also said many boaters use portable fuel tanks to fill their secondary marine equipment, such as generators, small-horsepower motors that power small vessels such as jonboats, and personal watercraft.
The EPA's proposal also fails to contemplate the risk of misfueling in cases in which portable fuel tanks are the primary mechanism to obtain fuel, the NMMA said.
Additionally, the EPA acknowledges that the "potential for misfueling incidents exist because consumers tend to choose the lowest-priced fuel and E15 may cost less than E10 since ethanol currently tends to be less expensive than gasoline."
The NMMA said the proposed label does not constitute a warning label for the following reasons: (1) it does not conform to American National Standards Institute warning label standards; (2) it does not identify the specific nature of the hazard; (3) it does not indicate clear or sufficient preventative action by the operator; (4) it is not "sufficiently strong enough" to capture the user's attention; and (5) use of the word "might" does not reflect the EPA's own conclusion that E15 will damage marine engines and equipment.
"NMMA would encourage EPA to test its proposed label to an audience of consumers in order to discern whether the label is communicating information effectively," the association said.
The NMMA also offered several recommendations for improving the proposed label.
In other E15-related news, another group filed suit against the EPA for its decision regarding E15.
On Monday, the National Petrochemical & Refiners Association joined with the International Liquid Terminals Association and the Western States Petroleum Association to ask a federal appeals court to overturn the EPA's decision.
"NPRA is taking this action because our members are committed to consumer protection and providing safe, efficient, affordable and reliable fuel to the American people," NPRA president Charles Drevna said in a statement. "The organizations challenging EPA's decision believe the agency has acted unlawfully in its rush to allow a 50 percent increase in the amount of ethanol in gasoline without adequate testing and without following proper procedures. As a result, we had no choice but to take this issue to court."