An open letter to the EPA regarding Mogas

The GAfuels Blog is written by two private pilots concerned about the future availability of fuels for piston-engine aircraft: Dean Billing, Sisters, Ore., an expert on autogas and ethanol, and Kent Misegades, Cary, N.C., an aerospace engineer and aviation journalist.

Dear EPA Administrator Lisa Jackson:

The RFS mandate in EISA 2007 is not a mandatory E10 law, but it will result in every drop of gasoline made in the U.S. being blended into E10 by the end of next year or early in 2012.  This is causing economic damage in the marine, aviation and public safety industries.  The recently announced E15 waiver will not delay the 2012 blending wall.

I hope your office is monitoring the progress of the class action lawsuit in Florida over the damage to the marine industry by the unintended consequences of the very flawed ethanol production quotas buried in EISA 2007.

In this article, “Negligent Failure to Warn Claim Survives Preemption Challenge in Marine Class Action Lawsuit”, please note the prominent excerpt: “This suit presents no obstacle to attainment of Congress’ objectives as contained in the [Federal Clean Air Act] and its amendments. If successful, plaintiff would obtain, among other things, an injunction requiring defendants to warn customers of the potential dangers of using blended gasoline in boats and requiring defendants to continue to make unblended gasoline available for purchase by boat owners in Florida. Defendants have cited to no law evidencing an intention by Congress to preempt Florida common law causes of action for property damage caused by defective design of unblended gasoline when used in boats or the failure to warn of possible damage if ethanol blended gasoline is used.  Furthermore, no irreconcilable conflict between the federal standards and the claims presented has been shown.”

Right there in the middle:  “…requiring defendants to continue to make unblended gasoline …”

During the E15 waiver comment period you were implored by the marine, aviation and small engine industries and individuals to prohibit the blending of ethanol in all premium unleaded gasoline.  Such a ban would completely preclude the need for this kind of legal action and the economic debacle that is coming, which may include loss of life when boats break down at sea or portable tools used in public safety fail or won’t start because of ethanol in gasoline.

You have granted the ethanol industry what it requested, a waiver for E15, now please grant the marine, aviation, antique/classic car and motorcycle owners, off-road recreational vehicle users, and small engine users the relief that they requested, by prohibiting the blending of ethanol in all premium unleaded gasoline.

May I remind you that renewable fuel is defined in EISA 2007 as E85; E10 is never mentioned in the act.  The RFS mandate in EISA 2007 was never intended to become a mandatory E10 law.

Respectfully yours,

Dean Billing
Sisters, OR


  1. says

    Response From The FAA 11/12/2010

    I received an answer to my letter to FAA Administrator Babbitt from an assistant named Dorenda D. Baker, Director, Aircraft Certification.

    The crux of the letter is don’t worry, be happy, the FAA and EPA are working on it:

    “The FAA has been coordinating very closely with the EPA on this and other issues relating to aviation fuel. We have advised EPA of our concerns with the use of ethanol as a fuel or fuel additives in aircraft. We will continue this dialogue with the EPA, along with aviation advocacy groups such as the Experimental Aircraft Association and the Aircraft Owners and Pilots Association, regarding the use of ethanol in autogas.”

    Draw your own conclusions. (My conclusion, we are screwed, they are doing nothing … but they are “concerned”.)

  2. Jack Bone says

    Mr. Reiley,

    This whole ethanol thing is just a big scam. Ethanol is NOT a renewable fuel, and actually costs more to produce than our current fuels. The diesel required to cultivate the land, plant, spray, harvest, and transport the corn, and the energy required to distill the grain alcohol from this corn is actually much much more costly. The addition of alcohol to the fuel decreases it’s British Thermal Unit (BTU) output per gallon (FACT), therefore miles per gallon decrease, so what is the point? It’s just another goverment pork program that won’t last. It is not sustainable.

    I would love an inexpensive, and clean fuel just as much as the next person, but this is just not it. Ethanol should be consumed, not combusted!


  3. Dennis Reiley says

    The ones at fault for this serious problem are the manufacturers of marine and aviation engines; not to mention the aircraft and small boat builders. They should have read the writing on the wall when leaded fuels were banned from automotive use.

    Way back then all engines should have been modified to take mogas, including E-10. Plus aircraft and boats should have had tankage installed that would not corrode when ethanol fuels were used. Instead they continued blindly and blithely on designing their products to use an outmoded and eventually extinct fuel.

    Now both industries are complaining about how unfair and costly converting over will be. Apparently thirty years is insufficient time for them to adapt to obvious changes. I would call it gross incompetence. It is not just the manufacturers but everyone who uses marine and aviation equipment that is to blame for not opening their eyes and taking a good hard long look at what the future would look like.

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