National
Ethanol Vehicle Coalition
Report
Conversion Equipment
May 2002
Can a
vehicle be converted to operate on E85?
This is a common question that is asked of the National Ethanol Vehicle
Coalition. Unfortunately, there is no simple answer. In the strictest sense,
yes, a vehicle that was designed to operate on unleaded gasoline only could
be converted to operate on E85. Realistically, no, a vehicle cannot be
converted to operate on E85. Here’s why!
During the 1980s and early 1990s, many small companies were formed that were
altering gasoline powered vehicles to operate on other forms of fuels such
as propane, compressed natural gas, 85% ethanol, and 85% methanol. The
marketing program of these conversion company’s was based on the premise
that it was cheaper to operate a vehicle on alternative fuels. However, the
vehicles being converted were engineered, designed and built to operate on
unleaded only. Shortly after the emergence of the “conversion firms” the
U.S. EPA determined that when converted from gasoline to another form of
fuel, the exhaust emissions from these converted vehicles were often much
“dirtier” than prior to conversion. See explanation regarding EPA Memo 1A.
The use of alternative fuels in the transportation sector has been built
around the objectives of using cleaner, non-gasoline based components.
Based on the federal authority provided to the EPA through the Clean Air Act
Amendments of 1990, the EPA implemented regulations that required the
exhaust emissions from vehicles converted to run on alternative fuels be “as
clean as the exhaust emissions of the original gasoline equipment.” That is,
if Ford Motor Company manufactured a vehicle to meet federal emissions
standards on gasoline, a company converting that vehicle to operate on
propane, must be able to certify that the emissions from the converted
vehicle was a good as the original. A process to certify such aftermarket
equipment was initiated and ultimately, few if any conversion kits were able
to qualify.
Today, 99.9% of the vehicles that are capable of operating on alternative
transportation fuels are produced by the original equipment manufacturers
such as Ford, Honda, General Motors, and DaimlerChrysler. Engineers from
these companies are able to design and build vehicles that meet the EPA
exhaust emission standards. These companies also are required to warranty
the exhaust emissions from these vehicles for 10 years of 100,000 miles,
something very few conversion companies are able to accomplish.
Is it possible to convert a vehicle that was designed for gasoline to
operate on E85? Yes. However, there are no conversion or aftermarket parts
that have been certified by the EPA as meeting the standards to maintain
clean exhaust emissions. Technically speaking, converting a vehicle that was
designed to operate on unleaded gasoline only to operate on another form of
fuel is a violation of the federal law and the offender may be subject to
significant penalties. No aftermarket conversion company has taken the
initiative to certify an E85 kit that would allow a gasoline vehicle to
operate on 85% ethanol.
The differences in engine size, fuel injector size, air-fuel ratio, PCM
calibrations, OBD, material composition of fuel lines, fuel pumps, and fuel
tanks, and other part issues among the millions of vehicles on the nation’s
highways, all contribute to making an E85 conversion extremely complex.
Additionally, the production of vehicles from the original equipment
manufactures that are capable of operating on unleaded gasoline or E85, (ie.
Flexible fuel vehicle) at no additional cost over the gasoline only model,
provide little incentive for a conversion company to undertake the very
expensive and time consuming task of aftermarket certification.
U.S. Department of Energy - Energy Efficiency and Renewable Energy
Clean Cities - Alternative Fuels Data Center
A History of
Memorandum 1A
In June 1974 the U.S. Environmental Protection Agency (EPA) issued Mobile
Source Enforcement Memorandum 1A (Memo 1A). The original purpose of Memo 1A
was to enforce the tampering prohibitions under Section 203(a)(3) of the
Clean Air Act with respect to maintenance and use of aftermarket parts. Memo
1A and its subsequent revisions also outline procedures for converting
vehicles to operate on alternative fuels while still complying with the
Clean Air Act's tampering prohibitions and ensuring that emissions are not
degraded through the conversion process. Below is a timeline and information
about subsequent revisions to Memo 1A.
In the mid
1990s, testing determined that some vehicles that had been converted to
operate on alternative fuels, specifically propane and natural gas, produced
emissions that were worse than those of baseline gasoline vehicles. EPA
issued an Addendum to Memorandum 1A in September 1997, requiring more
stringent emissions testing for alternative fuel vehicle (AFV) conversions.
The addendum specified three options through which a manufacturer can
demonstrate that it has a "reasonable basis" to believe that its aftermarket
part, vehicle add-on, or alteration to the vehicle would not adversely
affect vehicle emissions performance. In order to promote initial growth of
the alternative fuels industry, Option 3 outlined less stringent
requirements than obtaining a Federal Certificate of Conformity required
under Option 1 or the California Air Resources Board retrofit system
certification required under Option 2.
Due to comments received from industry, and concerns about the testing
process and timeline, EPA issued a Revision to the Addendum to Memo 1A in
June 1998. The revision clarified certain points and extended the timeline
for performing conversions according to the guidelines specified under
Option 3 to June 30, 2000. Additional concerns from the small alternative
fuels industry related to the costs of "full certification" under Options 1
and 2 led to another extension of Option 3, which was issued in May 2000 and
extended the deadline for performing conversions without full certification
to December 31, 2001. Finally, on January 24, 2002, EPA extended Option 3
through March 31, 2002 in order to allow time for a new set of certification
procedures for fuels converters to be fully developed by EPA.
Following these three extensions, Option 3 of the addendum to Memo 1A
officially expired on March 31, 2002. Option 3 had permitted the use of
alternative fuel conversion systems or "kits," which were designed for
specific engine families, provided that the aftermarket conversion company
performed satisfactory emission testing demonstrating that the converted
vehicles conformed with EPA emissions standards. Options 1 and 2 remain in
effect, and EPA now certifies converted vehicles, rather than conversion
systems or "kits." For more information about current conversion
certification procedures, please see Conversions 101.
For more information about Memorandum 1A and mobile source emissions
standards, please visit the following Web pages:
• Light-Duty Vehicle and Engine Emission Certification
• Vehicle Standards and Regulations
• A Guide to the Emissions Certification Procedures for Alternative Fuel
Aftermarket Conversions (PDF 2 MB) Download Acrobat Reader. (This document
should be referred to for historical and background purposes only.)
• Mobile Source Enforcement Memorandum No. 1A: Interim Tampering Enforcement
Policy (PDF 292 KB)
• Addendum to Mobile Source Enforcement Memorandum 1A (PDF 32 KB)
• Revision to Addendum to Mobile Source Enforcement Memorandum 1A (PDF 380
KB)
For a list of vehicle capable of operating on E85, please follow this link:
http://www.e85fuel.com/e85101/flexfuelvehicles.php
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