The Energy Independence and Security Act of 2007 (EISA07) included an expanded Renewable Fuel Standard (RFS2), which the EPA used to develop a final rule effective July 1, 2010. To comply with the RFS2 biofuel producers and importers must blend increasing amounts of biofuels into gasoline and diesel.

Petroleum refiners and importers then must acquire sufficient RINs to demonstrate compliance with RFS2 based on the amount of gasoline and diesel they produce and/or import. The RFS2 is complex with four nested volumetric mandates: total renewable biofuel, advanced biofuel, cellulosic biofuel and biomass-based diesel.

EISA07 was based on significantly greater gasoline demand projections, but the U.S. Energy Information Administration’s 2013 outlook for 2022 projects 25 percent lower demand vs. the 2007 outlook, when EISA07 was enacted. Cellulosic technologies were expected to develop within a few years of EISA07, but by the end of 2014, only one plant in the U.S. was producing cellulosic ethanol.

Declining gasoline demand, combined with increasing mandates, means we are approaching the limit of blending ethanol into gasoline (10 percent ethanol or E10) for widespread use. The EPA rushed through approval of an up to 15 percent ethanol blend (E15) without adequate testing. In addition to compatibility problems with E15, expanded use of another alternative fuel (E85), has not occurred due to poor consumer acceptance and significant infrastructure and cost challenges.

EISA07 also assumed declining domestic production of crude oil and far greater crude oil imports. Both of these assumptions have been completely reversed by the shale oil revolution and dramatically increased North American energy production – the U.S. is now the world’s leading oil and natural gas superpower.

The RFS is thus based on an economics and security perspective much different from the reality of today.

Contrary to claims, the EPA mandate for increased use of cellulosic biofuels is disconnected from reality. Though there was no commercial cellulosic production in 2010, EPA set the mandate for 2011 at 6.6 million gallons. There was no commercial production in 2011, either, yet EPA mandated 8.65 million gallons for 2012.

A total of 20,000 gallons were produced in 2012, but it was exported to Brazil and didn’t count toward RFS2 compliance (chart above).

The original target of one billion gallons set for 2013 was retroactively reduced in May 2014 to 810,185 gallons to reflect actual supply. In December 2014, the EPA announced that it would not release the 2014 target until 2015. With each passing year, EPA targets diverge further and further from actual production, creating expensive uncertainty for refineries busy meeting American fuel needs.

As biofuel mandates increase, the ethanol volume required for blending into gasoline will exceed 10 percent – known as the “E10 Blend Wall.” Declining gasoline demand accelerates and exacerbates the Blend Wall.

EIA demand projections for gasoline, E85 and combined ethanol consumption indicate RFS2 targets will not be met even if the cellulosic standard is waived —notwithstanding EIA’s optimistic projections about E15/E85 acceptance. The oil industry’s ability to supply gasoline (as limited by the E10 Blend Wall) does not meet EIA demand projections.

Economic Harm in 2015
$770 billion decrease in GDP
$2,700 decrease in Average Household Consumption
When the Blend Wall is Reached, NERA Found:
Maximizing biofuel blending alone does not ensure compliance.
Companies could comply by reducing the volume of fuel supplied to the domestic market

Source: NERA Economic Consulting

A study by NERA Economic Consulting buttresses the argument that the RFS2 is irretrievably broken. The study details the approaching ethanol Blend Wall, the point at which ethanol mandates under the RFS2 force more ethanol into the nation’s fuel supply than is safe for most motorists and their vehicles. According to NERA, continued implementation of RFS ethanol mandates by 2015 could:

  • Lead to fuel supply disruptions that ripple adversely through the economy.
  • Cause the cost of diesel to rise 300 percent and the cost of gasoline to rise 30 percent.
  • Decrease U.S. GDP by $770 billion.
  • Reduce worker take-home pay by more than $580 billion.

Vehicle Manufacturers and E15

Auto manufacturers and models recommendations for E15 in non-flex fuel vehicles as of January 2015. Most vehicles on the road today aren’t recommended for operating on E15 by manufacturers.

E15 and your car

Source: and auto company contacts

1Accord, Civic, Crosstour, CR-V, CR-Z, Insight, Odyssey, Pilot; Acura: ILX, MDX, RDX, RLX, but not Ridgeline, TL, TSX
2C, CLA, CL, E, GL, GLK, M, S, SL, SLK, but not CLS, G, SLS AMG
3Avalon, Camry, Corolla, Highlander, iQ, Prius, RAV-4, Scion tC, Sienna, Venza; Lexus: CT200H, ES350, GS300/350, GS450H, IS250, IS350, LS460, RX350, RX450H, but not 4Runner, FJ Cruiser, Land Cruiser, Sequoia, Tacoma, Tundra, Yaris; Lexus: IS250C, IS350C, IS F, GX460, LX570
4Not Chevrolet City Express
5GL, M, S Sedan, SL, SLK, but not C, CLS, E, G, GLA, GLK, S Coupe, SLS AMG
6Not xB, FRS

Testing by the Coordinating Research Council (CRC), which has been the gold standard in vehicular research for the better part of a century, determined that millions of vehicles on the road today could suffer engine damage from using fuels containing higher levels of ethanol than for which they were designed. Likewise, a separate CRC study found that fuel pump systems could seize up or otherwise be damaged by higher-content ethanol fuel.

As a result, a number of groups are concerned about efforts to force increased use of E15 gasoline, fuel that contains up to 15 percent ethanol (compared to the standard grade used in the U.S. that contains up to 10 percent ethanol). These include automakers, AAA, the California Air Resources Board (CARB), and environmental non-profits. The stakes are high for consumers who could be left stranded on the roadside and/or stuck with potentially expensive repair bills.

EPA’S Seldom-on-time Rate With Ethanol Mandates

Under the Renewable Fuel Standard, EPA sets annual requirements for the amount of ethanol that refiners must blend into the nation’s fuel supply. Under the law the ethanol mandates for a given year are to be finalized by Nov. 30 of the preceding year. Since the law went into effect EPA has met that deadline just once (2011), and it appears the problem is worsening. In the graphic below, calendar icons represent each month the standards were late.

The RFS is broken

The RFS is indeed broken. In November the EPA basically agreed, announcing it was giving up on issuing ethanol-use requirements for 2014 with just a little over a month to go. Instead, the agency said it will complete the 2014 targets in 2015 “prior to or in conjunction with action on the 2015 standards rule.”

The agency’s inability to meet the RFS deadline – it hasn’t actually met the statutory deadline once in the past five years (though the 2011 rule was only nine days late, close enough to call it on time) – offers little hope that things will improve. The RFS is an example of topdown central planning that’s detached from reality and which has created distortions in the marketplace and uncertainty among those who’re obligated to operate under it.

What the RFS has become is an illustration of the pitfalls of government trying to mandate consumer behavior through a program whose goals have largely been achieved by surging U.S. energy production.

The Renewable Fuel Standard (RFS) is indeed broken. In November the EPA basically agreed, announcing it was giving up on issuing ethanol-use requirements for 2014 – already a year overdue – with just a little over a month to go in the calendar year. Instead, the agency said it will complete the 2014 targets in 2015 “prior to or in conjunction with action on the 2015 standards rule” – standards that also are late.

With the supporters of increased ethanol use waging an aggressive campaign to defend the flawed RFS2, it has never been more critical to push forward the facts. This means telling the truth about ethanol’s appropriate role in the overall fuel picture, the performance of fuels containing higher levels of ethanol and the market’s tepid embrace of it and the fantasy of the EPA’s cellulosic biofuels mandate. Some key facts:

  • Contrary to some claims, ethanol is not responsible for lower U.S. oil imports. From 2008 through 2014, net imports have fallen by more than 6 million barrels per day while domestic oil production has increased by more than 3.5 million barrels per day. While ethanol production has increased by 328,500 barrels per day over that period, it is far too small to deserve credit for reduced imports.
  • Contrary to claims, ethanol is primarily an additive to gasoline, not a replacement for gasoline. It is only a replacement for gasoline when sold as E85 fuel. In 2012, only 100.2 million gallons of E85 were sold, meaning that as a fuel (rather than an additive), ethanol displaced just 50.7 million gallons of gasoline when you account for ethanol’s lower energy content. Context: The U.S. consumes about 352 million gallons of gasoline every day.
  • Some have suggested that requiring more production of higher ethanol-blend fuels like E15 and E85 can satisfy RFS mandates but these measures are expensive, temporary at best, and could have serious impacts on consumers and the broader economy.

    E85 has several limitations, for starters, only flex-fuel vehicles (FFVs) can use it, which becomes a logistical issue because there’s a lack of E85 pumps across the country – only about 2,500 retail stations out of more than 150,000 offer it. That’s not because “Big Oil” is blocking the sale of E85, but because there’s a lack of consumer demand (see chart). Next, there’s a mismatch between pump locations and FFVs, illustrated by a recent Department of Energy (DOE) Inspector General’s report that found DOE has been fueling its FFVs with regular gasoline instead of E85, eliminating many supposed environmental or cost benefits of having a fleet of cars that can use fuel containing up to 83 percent ethanol. And finally, E85 has not been cost competitive – just look at AAA’s website that tracks retail E85 prices.

    RFS supporters, desperate to avoid the blend wall suggest that E85 be “heavily discounted” to reach maximum sales, but the numbers have not added up: actual sales of E85 have never come close to the annual rate which would be needed and E85 is more costly on an energy-equivalent basis.

    Such arguments ignore ethanol market dynamics. Ethanol production has expanded and the U.S. has been a net exporter of ethanol since 2010. Trade flows of ethanol are responding to market signals, which appear to be placing a higher value on ethanol for its use as a low-level blend gasoline blendstock than as a high-level blend as a gasoline replacement (such as E85).

    As suggested by economic theory, it is entirely possible that markets would place a higher value on marginal ethanol (above what can be consumed in E10) as an export product. The economic law of supply and demand is at work, and it is not pointing to E85 being “heavily discounted” to gasoline containing 10 percent ethanol.

    Trying to come up with fantastical solutions to justify bad policies are just another distraction from the real problem: The RFS is fundamentally flawed and its ethanol mandates are broken. Rather than trying to push higher ethanol-blend fuels into the market, which the consumer isn’t demanding (E85) or which could harm engines (E15), we need the Congress to address the RFS with long-term and meaningful action.

    “…most cars on the road are not approved by their manufacturers for E15. Why would the city council use your engine as a guinea pig?” — Chicago Tribune
    E15 may damage your engine

    Chicago Mayor Rahm Emanuel and his allies on the city council deserve credit for putting a stop – for now at least – to an ill-conceived proposal that would mandate the sale of higher ethanol blend E15 fuel at city service stations. Ill-conceived because, as argued here and here earlier this year, the E15 requirement could be full of risk for consumers and small business owners – while mainly benefiting ethanol producers. Recently, AAA urged Chicago lawmakers to vote against the ordinance. Later, the Chicago Tribune editorialized:

    “The touted cost savings and environmental benefits are dubious. E15 produces less energy than regular gasoline, so vehicles would get fewer miles to the gallon on it. And the production of ethanol uses a great deal of energy. So why is the ethanol industry pushing this? Because it has a massive supply of ethanol and not enough demand for it. There is no natural market demand for this. Without a government mandate for more ethanol, more ethanol won’t get sold. … Aldermen, really. Why would you want to prop up an industry by creating a risk for your constituents? Stop this ordinance once and for all.”

    The reasons for this view are pretty straight-forward – which we’ve underscored recently with a dash of humor:

    Potential vehicle damage – Research has shown E15 could damage engines and fuel systems in millions of vehicles on the road today. Automakers have warned that using E15 in vehicles that weren’t designed to use it could void warranties.

    E15 cartoon lady with ruined car

    The real-world impacts of pushing more E15 into the fuel supply could fall on consumers and the broader economy, according to a NERA Economic Consulting study. If Chicago imposes the E15 proposal, it could impact small businesses that own a number of the city’s service stations. One owner, Russell Garcia, made the point in a letter to the editor of the Tribune in October:

    “The idea of mandating the sale of E15 gasoline in Chicago is poor public policy. … (M)y businesses would be negatively impacted by this mandate, and my customers would be harmed too. E15 provides no cost savings. While E15 has a sticker price that is about the same as traditional gasoline, its poorer gas mileage makes it more expensive. Plus, the cost of retrofitting new underground tanks at my stations and my competitors’ would necessitate even higher gas prices.”

    Refueler, beware – E15 also poses potential risks in a number of other areas. For example, if you own a gasoline-powered leaf blower

    E15 broken leaf blower cartoon

    Or a snowblower

    E15 broken snow blower cartoon

    Or maybe a snowmobile

    E15 broken small engine cartoon

    The point being that E15 could foul up engines in all kinds of outdoor equipment. As the Tribune editorial noted:

    The biggest risk comes if equipment is stored for the season with fuel still in the tank. Ethanol tends to make rubber and plastic parts more brittle. Ethanol attracts water, which can increase corrosion in moving parts. A long winter in contact with this mix can compromise the equipment.Higher concentrations of ethanol in fuel can make small engines run hotter, which in turn can cause malfunctions. Many manufacturers of outdoor power equipment will not honor warranties if owners use E15 fuel. They strongly oppose diluting gasoline with more ethanol.

    E15 also poses potential risks for marine engines and motorcycles.

    The Tribune is right: Chicago officials should kill this proposal once and for all.

    Source: #ReapealtheRFS –

    U.S. policy on biofuels, and on corn ethanol in particular, is a widely-recognized contributor to food price inflation. Experts from across the political spectrum now recognize this fact, and many are now calling for an end to Federal subsidies and supports for the corn ethanol industry. Although NCCR continues to support incentives for advanced biofuels, such as cellulosic and others that hold promise for a future of greater U.S. energy independence, we oppose continuation of subsidies and supports for the mature corn ethanol industry. – NCCR

    “Through years of promoting ethanol as a solution to America’s energy issues, Congress has unknowingly worked to increase commodity prices on retailers throughout the supply chain. These subsidies have artificially increased the price of corn, which in turn has driven up costs for restaurants and the customers they serve.” – Rob Green, NCCR executive director

    We estimate the impact of the 2015 RFS mandates at 2011 levels of food purchases under two scenarios … For the average quick service restaurant, these input cost increases are the equivalent to $18,190 per restaurant in the first scenario and $2,894 per restaurant in the second scenario. For the average full service restaurant, the cost increases are $17,195 and $2,736 per restaurant, respectively. – PwC report for NCCR

    “Ethanol diverts a significant share of the US corn crop each year. And, by doing so, it makes corn prices higher than they otherwise would be.” – University of Missouri economist Pat Westhoff, via VOA News
    “The use of corn-based ethanol required by the federal Renewable Fuel Standard mandate has dramatically distorted the market and increased costs throughout the food supply chain. The RFS has had an adverse effect on the chain restaurant industry, which has witnessed marked increases in commodity prices and associated costs to the tune of billions of dollars a year.” – Rob Green, NCCR executive director
    “Chain restaurants aren’t all mega-corporations. Many are systems of small business franchises like the one my family owns. … The government picked winners and losers when they passed the RFS mandate. This mandate is costing me $20,000 to $30,000 per restaurant. It is blatantly unfair and we urge Congress to repeal it.” – Ed Anderson, Wendy’s franchise owner and NCCR member

    Source: #ReapealtheRFS –

    “Our interest is to protect the consumer; we’re trying to prevent the harm from happening in the first place. … EPA has acknowledged there will be mis-fueling with E15; there will be engine and product failure.This is the reason the outdoor power equipment, boating, UTV, snowmobile, auto, and motorcycle industries, as well as the American Automobile Association (AAA) and the Coast Guard, oppose this higher ethanol fuel. Our interest is in protecting our customers.” – OPEI President and CEO Kris Kiser

    Will this damage my lawnmower, boat, jet ski, snowmobile, or four-wheeler?

    It sure will if you don’t pay attention. Generally, small engines are not designed to deal with the more corrosive E15 blend. And, as we mentioned in 2010, ethanol forms a brown goo when left in a fuel tank too long, which can clog fuel-system components. Two-stroke engines run hotter with an ethanol blend, which accelerates the potential damage. And ethanol can wreak havoc on fiberglass fuel tanks in older boats. Groups like the National Marine Manufacturers Association and Outdoor Power Equipment Institute have issued strong warnings to consumers to pay attention to their fuels or risk severe engine damage. Use a fuel stabilizer if the engine will sit for more than a few weeks without use; this will reduce the ethanol–water separation and potential gumming issues. Be careful to avoid using E15 in uncertified engines like these, at least until the subject is studied more thoroughly, and the engineering catches up to the fuel. – Popular Mechanics

    Are higher ethanol blends really that harmful to outdoor power equipment?

    Yes. You might be tempted to use a higher ethanol blended fuel since it may be less expensive. However, greater than 10 percent ethanol in outdoor power equipment can corrode metals and rubber and cause engines to break down more quickly. Most outdoor power equipment was not built, designed or warranted to run on fuel greater than E10, and using higher ethanol blends can damage or destroy it. In fact, using any fuel that contains more than 10 percent ethanol is illegal to use in outdoor power equipment.

    Also, the higher the ethanol blend, the lower the fuel economy. Ethanol contains 33 percent less energy per gallon than gasoline, so engines fueled with higher ethanol blended gas will attain fewer miles per gallon than those running on conventional gasoline (E10). This means you must fill your gas tank more frequently when using higher ethanol blended fuel. – OPEI

    “The higher the ethanol content, the more acute the effects.” – OPEI

    Manufacturers of outdoor power equipment and their engines say they will not honor the warranty of a product someone has been running with E15. The reason? Besides the above effects of ethanol, engines running even E10 gasoline run hotter. And with E15, the results can be dangerous, considering reports of “unintentional clutch engagement”—such as a powered-up chain saw that suddenly decides, because it’s running so hot, that you’ve pressed the button to start the chain. Manufacturers see a train wreck coming because their customers will ultimately blame them for problems. – Consumer

    “E15 is universally opposed by our entire industry because of the problems it causes. … Research has shown that using E15 can have harmful and costly consequences on small engines and outdoor power equipment. Most engines would have great difficulty in meeting both emissions and performance expectations with this type of alcohol range. … Most gas stations have tanks where the supplier puts the mixed gasoline into the storage tank and the pump pumps it up. Because alcohol separates from gasoline, consumers can get a higher mix of alcohol in their fuel. If you increase to 15%, the effect gets multiplied, so you might end up with double the alcohol you expected. That’s a problem.” – Brad Murphy of OPEI member Subaru Industrial Power Products

    Source: #ReapealtheRFS –

    Feed corn prices increase the cost of raising turkeys and other meat protein animals we raise for food. Consumers ultimately pay more for these added costs of raising meat and poultry. – NTF

    “Consumers have seen food prices increase faster than general inflation since the current RFS was enacted in 2007. Food affordability, which had been improving for decades, now is deteriorating.”

    “We saw how price spikes caused by this government mandate impacts turkey growers when corn prices reached almost $8 per bushel: U.S. turkey production declined by 9 percent, resulting in loss of rural jobs.”

    “Corn is the major ingredient in turkey feed and almost all livestock and poultry. Corn is the primary reason why one turkey company went bankrupt in 2012 and why the industry already has lost 750 jobs in the last 12 months.” “The RFS has destabilized corn and ethanol prices by offering an almost risk-free demand volume guarantee to the corn-based ethanol industry. Domestic and export corn users other than ethanol producers have been forced to bear a disproportionate share of market and price risk. Ethanol prices should reflect the fuel’s energy value relative to gasoline, not a corn price that is both inflated and destabilized by the inflexible RFS. As corn is syphoned off to ethanol, animal agriculture is losing jobs in rural America.”

    “The National Turkey Federation encourages pointed discussion of the RFS. Animal agriculture has long been suffering at the hand of this broken policy, especially feed costs in the turkey business. The RFS has caused an increase of $1.9 billion in feed cost alone for turkey farmers, as corn continues to be syphoned off to ethanol.”

    “RFS has been such a poorly managed mess, it’s time to drain the swamp. The RFS needs a fresh start in order to put in place a smarter policy on the mix of fuel and feed.”
    – Joel Brandenberger, NTF President
    “It’s safe to say RFS is hitting consumers, poultry producers, and farmers squarely in the pocketbook.”
    – Dr. Thomas Elam, president of FarmEcon, LLC, speaking on behalf of the NTF and the National Chicken Council

    Source: #ReapealtheRFS –

    “Thanks to the U.S. Environmental Protection Agency, there’s a new threat facing motorcyclists nationwide, and possibly all Americans. The danger is posed by a certain blend of motor vehicle fuel called E15, which may damage the engines of motorcycles, all-terrain vehicles, boats and powered equipment.” – Wayne Allard, AMA vice president for government relations

    … E15 could lower fuel efficiency and possibly cause premature engine failure for motorcycles and ATVs. – AMA

    … the U.S. Environmental Protection Agency’s decision to allow E15 into the marketplace would impact every American who owns motorcycles and ATVs, not to mention cars, lawnmowers, boats and snowmobiles. – AMA

    … the U.S. Department of Agriculture was subsidizing ethanol production from the start by providing grants to purchase special ethanol blender pumps. … Agriculture Secretary Tom Vilsack announced in 2011 that the USDA intends to install 10,000 blender pumps by 2016. [Rural Energy for America Program] REAP will be a key component to achieve the secretary’s goal and, thus, help grow the availability of E15 fuel. These special ethanol blender pumps will further limit access to E10-or-less fuel in rural areas. This will be a problem because rural areas tend to have an older “legacy” vehicle fleet than other parts of the country. Moreover, rural areas are the most vulnerable places for motorcyclists and users of small engine devices because options for regular gasoline may be few or even non-existent. The REAP will help one segment of the rural economy at the cost of other segments. Ultimately, the higher costs will have a negative impact on small rural economies. – AMA

    Automobile and motorcycle manufacturers must certify that the on-highway vehicles they produce will meet applicable U.S. EPA and National Highway Traffic Safety Administration emissions, fuel economy and safety requirements prior to selling the vehicles. The fuel that the vehicles must use for this requirement is called the “certification fuel.”

    Changing the certification fuel to E15 or E30 is at odds with the 22 million motorcycles and all-terrain vehicles currently in use, not to mention the legacy fleet of cars, boats, lawnmowers, generators and hundreds of millions of small engines in commerce today. None of these vehicles and engines is designed to operate on fuel with more than 10 percent ethanol. – AMA

    “When you have a type of fuel that, if inadvertently used, has the potential to damage engines and fuel systems and void a manufacturer’s new-vehicle warranty, you really should move with caution when it comes to putting that fuel in the marketplace. Issuing rules that allow the sale of E15 at gas stations without adequate testing to be sure it’s safe in motorcycles and ATVs, not to mention engines in boats and power equipment, just isn’t wise.” – AMA Board Chairman Maggie McNally

    100 percent of the 22 million motorcycles and all-terrain vehicles on the road and trail in the U.S. today are not designed to run ethanol blends higher than 10 percent, and many older machines favored by vintage enthusiasts have problems with any ethanol in the fuel. And yet the opportunity to misfuel and damage an engine with higher ethanol blends such as E15 is very real. It is time to set the record straight.

    The bottom line for the AMA is this: Motorcyclists simply want safe fuels available at all fuel retailers and measures employed by retailers to ensure they cannot inadvertently put unsafe fuels in their tanks. – AMA

    “It really doesn’t do much good to have laws and rules telling refiners to create volumes of ethanol-gasoline blends that consumers won’t buy.” – Wayne Allard, AMA vice president for government relations

    “Restoring the balance between food and fuel crops is long overdue.” – ABA President & CEO Robb MacKie

    “As American consumers continue to cope with a period of pro-longed economic turmoil, and U.S. food, beverage and consumer products makers from farm to fork struggle with record high commodity prices, we believe it is EPA’s duty to grant a waiver for the applicable volume of corn ethanol required by the RFS.”

    “Congress should adopt an energy policy that, while promoting sustainable, domestic, and affordable energy sources, does not lead unnecessarily to increased food prices.”

    “In total, corn is used in 75 percent of the food on supermarket shelves. Losses in grain yields, therefore, have a severe impact on U.S. food production for both domestic consumption and exports such as corn, soybean, and meat products.”

    “It’s not just corn – food-to-fuel policies create a ripple effect for all agricultural products, also increasing prices for basic staples like bread, eggs and milk.”

    “[W]ithout a high biofuels mandate, the market more easily adjusts to short-supply situations because ethanol producers will, at some corn-price level, also reduce corn usage. Conversely, high biofuels mandates create inflexibility in markets, the study says, and “any required adjustment in demand (for corn) would occur outside the ethanol industry” (e.g., feed, livestock/poultry, food).” – American Meat Institute

    “The corn-based ethanol mandate impacts the baking industry twofold: First, the government mandate to grow corn for fuel instead of food drives farmers to move away from planting wheat; second, the wheat market typically follows the much larger corn market, and when corn prices rise due to government created demand for ethanol, wheat prices rise as well. With an estimated 40 percent of the corn crop needed to satiate demand for the corn-based ethanol mandate, there is little doubt that the mandate impacts corn prices and supplies, which will also impact the wheat market. ABA once again calls on Congress to stand with consumers and repeal the corn-based ethanol mandate.” – American Bakers Association (ABA) President & CEO Robb MacKie

    Due to the 2005 and 2007 corn-based ethanol mandates, wheat could not (and cannot) compete for finite acreage against other biofuel crops. With the addition of E15, estimates show that corn acreage may need to increase to as much as 110 million acres in order to meet demand. With increasing ethanol mandates due to the RFS2, and with the inability of second generation biofuels to come online quickly to relieve pressure on the demand for corn-based ethanol, corn will continue to win the battle over finite farmland in the and drive food prices both domestically and internationally – Comments to the House Energy and Commerce Committee

    “The corn-based ethanol program and the Renewable Fuel Standard (RFS) continue taking their toll on the baking industry and consumers. Corn-based ethanol has accelerated the decrease of wheat acreage in the U.S. over the past 30 years and tightened food supplies around the world.” – ABA President & CEO Robb MacKie

    Source: #ReapealtheRFS – a href=””>

    With nearly 13 million registered boats (and nearly 16 million boats in the field) and 70 million boaters nationwide, the recreational marine industry is a major consumer goods and services industry that contributed $30.5 billion in new retail sales and services to the U.S. economy in 2009 and generates nearly 340,000 jobs nationwide. … NMMA strongly opposed – and continues to oppose – the granting of a “partial” or “conditional” waiver for E15 or any other ethanol blend level over ten percent ethanol (“E10”) because it will substantially increase public confusion and lead to persistent misfueling and consequent engine performance failures, emissions control failures, and consumer safety concerns. – NMMA Comments to the U.S. Environmental Protection Agency

    The Department of Energy’s National Renewable Energy Laboratory has tested the effects of E15 gasoline on some standard marine engines, and the majority of these engines suffered significant damage or exhibited poor engine runability, performance, and difficult starting – none of which is acceptable on a boat at sea. – NMMA Letter

    … we have determined that e15 blends of ethanol would cause considerable damage to the 7.5 million outboard engines in use in this country today. This damage is unnecessary and can be avoided by freezing the ethanol content of gasoline at 10% by volume. NMMA has never been anti-ethanol. We are simply opposed to fuel blends that will ruin our engines and place lives at risk. –Thomas J. Dammrich, President NMMA

    There is a significant amount of technical and anecdotal information that concludes that the introduction of E10 into the gasoline supply has caused significant damage and failure to boats. Although boat and engine manufacturers have adjusted and now design equipment to run on E10, the introduction of E15 will result in:

    • Damage to rubber parts;
    • water contamination in the fuel system due to ethanol’s hygroscopic properties;
    • increased water absorption and phase-separation of gasoline and water while in tank;
    • corrosion of fuel system components and fuel tanks;
    • higher exhaust gas temperature due to enleanment;
    • performance issues, such as drivability (i.e. starting, stalling, fuel vapor lock);
    • damage to valves, push rods, rubber fuel lines and gaskets.
    • – Minnesota Testimony, NMMA

    Currently, there are nearly 13 million registered recreational boats in operation in the U.S. No gasoline marine engine – or any other marine equipment including gasoline generators – currently in the field was designed, calibrated, certified or is warranted to run on anything over 10 percent ethanol.

    EPA’s own “engineering judgment,” as well as all available data (supported by these two new studies), strongly suggests that all of the 12.8 million registered boats on the water today (with the exception of approximately 260,000 diesel-powered boats and the roughly 430,000 registered non-motorized craft) may be negatively impacted by any gasoline with more than a 10 percent ethanol blend. – NMMA Petition to EPA

    The Renewable Fuels Standard must be revised to prevent the damage that ethanol blends above the 10% level will cause to engines of all types. … Unless the renewable fuels mandate is changed, it is likely that EPA would require 35%-40% ethanol in gasoline by the year 2022. Every time EPA changes the percentage of ethanol in gasoline, engines have to be recalibrated and engine designs changed. – NMMA Policy Brief

    1. NERA Economic Consulting, “Economic Impacts Resulting from Implementation of RFS2 Program”
    2. Coordinating Research Council, “Intermediate-Level Ethanol Blends Engine Durability Study”
    3. Coordinating Research Council, “Durability of Fuel Pumps and Fuel Level Senders in Neat and Aggressive E15”
    4. Rep. Sensenbrenner, “E15 Automaker Responses”
    5. AAA, “New E15 Gasoline May Damage Vehicles and Cause Consumer Confusion”
    6. Environmental Working Group, “Senators Seek to Block Higher Ethanol Blend”
    7. National Academy of Sciences, “Potential Economic and Environmental Effects of U.S. Biofuel Policy”
    8. Stanford University, Center for Food Security and the Environment
    9. Food and Agriculture Organization of the United Nations, “OECD-FAO Agricultural Outlook 2012-2021”
    10. World Bank Policy Research
    11. Schornagela, Niele, Worrell, and Böggemann, “Resources, Conservation and Recycling; Water accounting for (agro) industrial operations and its application to energy pathways”, December 2011.
    12. The National Academy of Sciences, “Potential Economic and Environmental Effects of U.S. Biofuel Policy”
    13. Energy Tomorrow, Bob Greco Blog
    14. Energy Tomorrow Blog, Mark Green, “The RFS is Broken”
    15. Energy and Power Subcommittee, House Committee on Energy and Commerce, “Overview of the Renewable Fuel Standard: Government Perspectives,” June 2013