Comment submitted by T. A. Kiefer

I am the copyright holder of the document submitted with comment 1jx-83ts-bg44 and I hereby grant permission to EPA to display it and make it available for download for purposes of supporting public participation in this comment process. The document is publicly available for download at http://wici.ca/new/wp-content/uploads/2013/03/Kiefer-Snake-Oil2.2.pdf . In addition I would like to submit these comments as to why ethanol should be removed from the nation's gasoline supply altogether in the interest of health, the environment, and fuel efficiency. These claims are supported by section 11.1 of the reference above and the several studies cited therein. Ethanol in gasoline: 1. does nothing to reduce tailpipe carbon-monoxide (CO) emission of US cars built since 1993 2. Increases NOx emisssion in low-aromatic fuels 3. Increases aldehyde emissions 4. Increases evaporative emissions (requires a standing EPA waiver) 5. Increases total lifecycle emissions of CO 6. Increases total lifecycle emissions of volatile organic compounds (VOC) 7. Increases total lifecycle emissions of PM10 particulates 8. Increases total lifecycle emissions of sulfur oxides (SOx) 9. Increases total lifecycle emissions of nitrogen (NOx) 10. decreases energy density of fuel 11. decreases MPG of all gasoline vehicles in the USA 12. increase the speed of percolation and contamination depth of ground plumes of spilled fuel (same as MTBE) 13. increases fuel miscibility with water, complicating ground water and open water cleanup of spills (same as MTBE) 14. should have resulted in an EPA surveillance program for ethanol soil and groundwater contamination just as was done for MTBE, and EPA is wrong to continue delaying this. 15. increases cost of fuel, harming the economy. A blue ribbon panel of experts commissioned by the EPA in 1999 recommended discontinuing the use of all oxygenates in gasoline. EPA needs to heed the science rather than the politics.