CAN A VEHICLE BE CONVERTED TO OPERATE ON E85?
Response:
This is a common question 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, the conversion is extremely difficult. Below explains the reasoning. Be aware that Flex Fuel U.S. has obtained the only U.S. Environmental Protection Agency (EPA) approval for an E85 conversion kit. The Flex-Box Smart Kit™ is approved for the most popular Dodge vehicles: the Dodge Charger, Dodge Magnum, Chrysler 300 2wd and AWD 5.7L Hemi.
During the 1980’s and early 1990’s, 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 percent ethanol and 85 percent methanol.
The marketing program of these conversion companies 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 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 as good as
the original. A process to certify such after-market equipment was initiated
and ultimately, few if any conversion kits were able to qualify.
Today, 99.9 percent of the vehicles that are capable of operating on alternative
transportation fuels are produced by the original equipment manufacturers such
as Ford, 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 or 100,000 miles, something very few conversion companies
are able to accomplish. However, as you will read below, that might
be changing.
IS IT POSSIBLE TO CONVERT A VEHICLE THAT WAS DESIGNED FOR GASOLINE TO
OPERATE ON E85?
Yes. However, the only kit holds EPA certification is by FlexFuel U.S. You can find more information on this kit at www.flexfuelus.com. Technically speaking, converting a vehicle that was designed
to operate on unleaded gasoline only to operate on another form of fuel
that does not use the FlexFuel U.S. kit is a violation of the federal law and the offender may be subject to significant
penalties.
The differences in fuel injector size, air-fuel ratio, PCM calibrations,
material composition of the fuel lines, pumps and tanks are just a few
of the components that contribute to making an E85 conversion extremely
complex.
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 Memorandum 1A and mobile source emissions standards,
please visit the following Web pages:
