Recent claims from some marine engine manufacturers that E15 ethanol blends will ruin marine engines are meant solely to incite fear and not meaningful discussion. A meaningful discussion would note that E15 is illegal for use in marine engines, that the testing being cited is not comprehensive, and that the ethanol industry has repeatedly extended olive branches to work on the concerns boaters and others have raised. As ethanol blended fuel has become more ubiquitous across the nation, the Renewable Fuels Association has worked diligently to inform all potential users about the characteristics of the fuel. That includes passenger vehicle owners, boaters, lawn equipment users, and more. In fact, in many cases, the RFA has provided more information than is likely necessary for the safe, effective, and legal use of ethanol blends. This is especially true of the marine engine community. The RFA has always listened to the concerns of the marine and small engine community. We appreciate that marine engines may face unique challenges with operating environment and fuel storage concerns. That is why the RFA has responsibly and repeatedly made efforts to educate boat owners on the proper use and storage of ethanol blends. Because of this good faith effort, the recent touting by Mercury Marine and other marine engine lobbyists of their testing that purports to show their engines failing on E15 blends seems to run counter to what had been a constructive dialogue. The testing being touted is not definitive nor is being presented in full context. Lets review the context. First, it must be noted that it is illegal to use E15 in a marine engine from Mercury or anyone else. The RFA believes the EPAs labeling and misfueling mitigation plans clearly presents the information consumers need to use E15 legally and appropriately. We also believe that consumers are savvy enough to know what is right and what is wrong for their equipment. Beyond this important point, the testing and the promotion of the results are incomplete. From a purely statistical point of view, the small number of engines included in the study precludes making any definitive statements about the effect of E15 on all marine engines. It is also quite relevant to note that one of the engines tested on E15, a marine motor from Volvo, did not fail. More to the point, however, is that marine engines are made to run on a certified fuel containing no ethanol. These engines are built to run on old fashioned gasoline. So, it should come as no surprise that a 15% increase in the amount of ethanol in the fuel would cause some abnormalities in the functioning of engines not designed for cleaner alternative fuels. The point here is that the results being touted are not a surprise to anyone. Rather, they underscore the need for marine engine manufacturers to update their engineering to produce motors designed for at least E10. As designed, these engines are optimized for gasoline (E0) but can, and often do, run on E10. In fact, Mercury Marine makes that point very clear on its website noting, Fuels containing up to 10 percent ethanol are considered acceptable for use in Mercury engines. By modernizing engine designs to be optimized for at least E10, such engines could handle E15 with ease. This technology is by no means foreign to Mercury or other marine engine makers. Currently, Mercury Marine sells certain models in Brazil where the fuel contains as much as 25% ethanol. While regulations in Brazil are different, it highlights the point that the engineering acumen not only exists, but is being put to use. The RFA has fully supported the path taken by EPA with respect to E15 and small and marine engine platforms. We appreciate their unique concerns. That is why we continue to supply updated materials for the proper use and storage of ethanol blends for these kinds of engines. Like it or not, however, higher level blends of ethanol will be fuels in the future. We would enthusiastically embrace a constructive relationship with marine engine makers to ensure the engines they are building for the future anticipate changes in fuel blends rather than having to react with opposition when blends change.