August 17, 2010
MEMORANDUM
TO:		Docket: EPA-HQ-OAR-2010-0448
FROM:  	Cheryl Caffrey, ASD, Mechanical Engineer
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SUBJECT: 	RFA Summary of Engine Manual Recommendations on Use of Fuel with 10% 
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		Ethanol
   Nonroad engines designs had little changed for decades so it is unclear when they may have been modified to account for ethanol blends.  As nonroad engines began encountering ethanol in the marketplace in the early 1980's, predominantly in the Midwest region of the United States, manufacturers began to provide guidance to their consumers on the use of ethanol blends and/or began to make design changes to accommodate E10.  Owner's manuals and organization websites provide information to the user about fuel specifications for the engine.  The following tables list owner manual references from 1988 to present.   Table D.4-2 lists several owner manual references to the use of ethanol fuel between 1988 and 2000 and it illustrates the range of owner notifications on the use of ethanol from no comment to "up to 10%" to "Caution".   
   Table 1:  Sample Fuel Specification Recommendations from Several Nonroad 
                            Owner Manuals 1988-2000
                              ENGINE MANUFACTURE
                            DATE ON SERVICE MANUAL
FUEL SPECIFICATION RECOMMENDATION ON FUEL WITH ETHANOL
                            John Deere Front Mower
                 with Kawasaki Overhead Valve 4 stroke Engine
                                     1988
Gasohol is accepted if not more than 10% ethyl alcohol is in the blend
To help keep water out of fuel, fill tank at end of day's operation
                               Mercury Outboard
                                     1997
IMPORTANT:  Gasoline containing alcohol (ethanol or methanol) can cause a formation of acid during storage and can damage the fuel system.  If the gasoline being used contains alcohol, it is advisable to drain as much of the remaining gasoline as possible from the fuel tank, remote fuel line, and engine fuel system.

                              Polaris Snowmobile
                                     1997
Your Polaris vehicle is calibrated to use non-oxygenated fuel with a minimum pump octane of 91 or higher (R+M)/2 method.....
Oxygenated fuel containing a mixture of up to 10% ethanol can be used in your Polaris vehicle if these guidelines are followed:
   1.  When using lower than 91 octane oxygenated fuel, you will need to have your dealer make adjustments to your engine and/or fuel system
      -Depending on your state and local regulations, your fuel supplier may or may not be required to display the type of fuel they are selling. In this case you should assume that you are using oxygenated fuels and purchase 91 octane or higher (R+M)/2 or have your dealer make the necessary adjustments
2.    If using oxygenated fuel containing ethanol, additional alcohol deicers or water absorbing additives are not required and should not be used.
                              Bombadier Jet Boat
                              DI 2 stroke engine
                                     2000
CAUTION:  The use of a fuel other than regular unleaded fuel can result in craft performance deterioration and damage to fuel system and engine components.  Never experiment with other fuels or fuel ratios.  Never use fuel containing alcohol, methanol or similar products including naphtha.
      
      Ethanol began increasing in distribution in 2002/2003.   Herman and Associates performed a survey of nonroad engine owner's manuals for the Renewable Fuels Association in 2003 and summarized manufacturer recommendations on the use of ethanol at that time.  The results differ slightly between and within the recreational vehicle, small engine, marine and motorcycle industries.  Examples of engine manufacturer fuel recommendations are listed in Table III.D.4-3  Note that these contain more detail than those references in Table III.D.4-2.  This may be due to several factors including the fact that more information was known about ethanol use in nonroad engines and the fact that ethanol use was beginning to increase.
      
                Table 2:  Examples from 2003 Summary Tables of 
               Nonroad Engine Manufacturer Fuel Recommendations

Manufacturer Fuel Recommendations
Range of Comments on Using Fuel with Ethanol 
Comments (Example)
Recreational
Up to 5%, 
Up to10%
When using oxygenates, carburetor main jet must be one size larger than for regular unleaded gas.
Power
Approved, 
Up to 10%, 
N/A
Never use gasoline containing methanol, gasohol containing more than 10% ethanol, gasoline additives, premium gasoline, or white gas. Refer to engine manual for gasoline recommendations. Uses Briggs & Stratton, Honda or Kohler Engines.

Engine is certified to operate on unleaded gasoline intended for automotive use.

Alcohol-blended fuels (called gasohol, ethanol or methanol) can attract moisture which leads to separation and formation of acids during storage.  To avoid engine problems, fuel system should be emptied before storage for 30 days or longer.  Use fresh fuel next season.
Marine
Sport boats: 
Do Not Use
 
Outboards: 
Up to 10%,
Do not Use,  
Gasoline containing alcohol, methanol (methyl), or ethanol (ethyl), may cause wear and damage to bearings, cams, piston(s), piston rings, corrosion of metal parts, deterioration of rubber and plastic parts, starting, idling, and other engine performance problems.

Gasoline containing alcohol may cause the following problems to your outboard and fuel system: corrosion of metal parts, deterioration of elastomers and plastic parts, wear and damage of internal engine parts, starting and operating difficulties, vapor lock or fuel starvation.
Adverse effects of alcohol are more severe with methanol and are worse with increasing content of alcohol.

The use of a fuel other than regular unleaded fuel can result in craft performance deterioration and damage to fuel system and engine components.
Never use fuel containing alcohol, methanol or similar products including naptha.
Motorcycle
Up to 10%, 
N/A
Use only premium unleaded gasoline with a minimum pump octane rating of 90 ((R+M)/2 method).  
If not satisfied with driveability or fuel economy when using an oxygenated fuel, switch back to regular unleaded gasoline or to a different brand.

Use only unleaded gasoline, 92 pump octane minimum.
Source: Herman & Associates, Washington, DC:  Excerpts from Report on Fuel Recommendations for 2003 Model Year, Prepared for RFA

   In April , 2009, TCPalm posted the following on the internet regarding use of E10 in boat engines:

WHAT TO DO
1
- Avoid mixing regular fuel with E-10 fuel
2
- Frequently change fuel/water separating filters in fuel system. If none is installed, install one
3
- If it's an older boat, have a marina or service department arrange to clean the fuel tank
4
- If boat will not be used for some time, fill tank to about 95 percent capacity to leave for expansion but reduce the chance for condensation.
5
- Never put E-85 in a fuel tank of a boat.
      
      The article also stated that it's the older boats that are affected most by ethanol.   Since ethanol is a solvent, it dissolves years of buildup off the inside of fuel tanks and fuel lines, in turn clogging up the fuel filters.
      In 2010, E10 is approximately 80% of the fuel distributed in the country.    Owner manual samples were received from various industry stakeholders and are summarized in Table 3.  They now indicate a general acceptance of E10 use, but no higher ethanol use, and marine manufacturers still caution against its use.

       Table 3:  Owner Manual Recommendations from 2010, Small SI Engines Only
Engine Manufacturer
Engine Range
Owner Manual Fuel Specifications
Kohler
Nonhandheld Small SI Engines
Gasoline/Alcohol blends
Gasohol (up to 10% ethyl alcohol, 90% unleaded gasoline by volume) is approved as a fuel for Kohler engines. Other gasoline/alcohol blends including E20 and E85 are not to be used and not approved. Any failures resulting from use of these fuels will not be warranted.
Gasoline/Ether blends
Methyl Tertiary Butyl Ether (MTBE) and unleaded gasoline blends (up to a maximum of 15% MTBE by volume) are approved as a fuel for Kohler engines. Other gasoline/ether blends are not approved.

Honda
Class I and Class II Small SI Engines
Refueling...
You may use regular unleaded gasoline containing no more than 10% ethanol (E10) or 5% methanol by volume.  In addition, methanol must contain cosolvents and corrosion inhibitors.  Use of fuels with content of ethanol or methanol greater than shown above may cause starting and/or performance problems.  It may also damage metal, rubber and plastic parts of the fuel system.  Engine damage or performance problems that result from using a fuel with percentages of ethanol or methanol greater than shown above are not covered by warranty.
If your equipment will be used on an infrequent or intermittent basis please refer to the fuel section of the STORAGE chapter (page 11) for additional information regarding fuel deterioration.
ONAN
Manufacturer of Generators using Small SI engines
FUEL RECOMMENDATIONS
Gasoline Generators  --  Treat the engine of your Onan(R) or Camp Power(TM)generator to a good grade of regular unleaded gasoline and it'll purr in response.  Gasohol (gasoline blended with alcohol) can be used if it contains the correct additive mixture percentages:
:: Ethanol Blend  --  Not more than 10% ethanol.
:: Methanol Blend  --  Not more than 5% methanol and must also contain solvents
and corrosion inhibitors.
Briggs and Stratton
Class I and Class II Small SI Engines
Fuel Recommendations:
Fuel must meet these requirements:
 Clean fresh unleaded gasoline
 A minimum of 87 octane/87AKI (90 acron)
 Gasoline with up to 10% ethanol (gasohol) or up to 15% MTBE (methyl tertiary-butyl ether) is acceptable.
CAUTION: Do not use unapproved gasoline, such as E85. Do not mix oil in gasoline or mofidy the engine to run on alternative fuels.  This will damage the engine components and void the engine warranty.  
Echo
Handheld engines (Small SI)
Alternative fuels, such as E-15 (15% ethanol) or any fuels not meeting ECHO requirements are NOT approved for use in ECHO 2-stroke gasoline engines.  Use of alternative fuels may cause performance problems, loss of power, overheating, fuel vapor lock, and unintended machine operation, including, but not limited to, improper clutch engagement.  Alternative fuels may also cause premature deterioration of fuel lines, gaskets, carburetors and other engine components.

Fuel Requirements:
Gasoline  -  Use 89 Octane (R+M/2) (mid grade or higher) gasoline known to be good quality.  Gasoline may contain up to 10% ethanol (grain alcohol) or 15% MTBE (methyl tertiary-butyl ether).  Gasoline containing methanol (wood alcohol) is NOT approved.
       References provided by members of the Engine Manufacturers Association 2010
    
    

	
