clearing the air on vehicle conversions · 2018-12-08 · 1 e85 conversion kit meeting clearing the...

Clearing the Air on Vehicle Conversions

Vehicle E85 Conversion Kit Meeting April 15, 2008 • 1:00 pm — 4:00 pm

American Lung Association of Minnesota

Hosted by the American Lung Association of MinnesotaHosted by the American Lung Association of Minnesota Made possible, in part, by the Minnesota Department of CommerceMade possible, in part, by the Minnesota Department of Commerce

and the US Department of Energy Clean Cities and the US Department of Energy Clean Cities

Table of Contents

Thank You Invitation Agenda Presentations Tim Gerlach • Marty Reineman • Dennis Smith Ed Kulik • Rich Gunther • Chris Disher Additional Panelists: Victor Van Dyke • Dr. Bruce Jones Moderated Question & Answer Discussion Registrants Photo Summary

3 4 5

6‐33

34‐38

39‐42

43

Thank You

Our sincere appreciation to the Minnesota Department of Commerce and U.S. Department of Energy Clean Cities program for supporting this Clean Air Choice educational event.

We are also grateful to the National Renewable Energy Lab for providing the webinar link throughout the meeting.

Finally, without the excellent speakers and panelists and their willingness to participate, no meeting would have been possible. Their expertise provided insights into the complexities of the vehicle conversion certification process. We express our gratitude to these individuals and their organizations for dedicating their time and travel to this work.

Minnesota Clean Air Choice™ Team Minnesota Clean Air Choice™ Team Minnesota Clean Air Choice™ Team ——— 2008 2008 2008 American Lung Association of Minnesota • General Motors Corporation

Minnesota Corn Growers Association • Minnesota Soybean Growers Association Minnesota Department of Commerce • Minnesota Department of Agriculture National Ethanol Vehicle Coalition • US Department of Energy — Clean Cities

3

Event Postcard FRONT

BACK

4

Clearing the Air on Vehicle Conversions April 15, 2008 • 1:00 pm — 4:00 pm

American Lung Association of Minnesota 490 Concordia Ave • St. Paul, MN 55103

Mississippi Room

1:00 pm Welcome and Opening Remarks E85 and FFV status in Minnesota Tim Gerlach, American Lung Association of the Upper Midwest Update on Rules, Process and Kit Certifications

Marty Reineman, U.S. Environmental Protection Agency, National Vehicle and Fuel Emissions Laboratory

Bridging the Gap Dennis Smith, P.E., C.E.M., U.S. Department of Energy Update from E85 Flex‐Fuel Vehicle Manufacturer Ed Kulik, Ford Emissions Regulatory Planning Rich Gunther, General Motors Government and Alternative Fuel Fleets Update from E85 Conversion Kit Manufacturer Chris Disher, CFO Flex Fuel U.S.

Alternative Fuel Engine Certification Case Study: Propane Victor Van Dyke, Schwan’s Food Company Minnesota Center for Automotive Research Professor Bruce Jones, Automotive Engineering Technology Minnesota State University, Mankato 2:50 pm Break (10 minute) Moderated Question & Answer Experts

Mike Bull, Assistant Commissioner, Minnesota Office of Energy Security Panel to include: USEPA, USDOE, Ford, General Motors Corporation, Flex Fuel US, Schwan’s/Bi‐Phase, MSU‐Mankato

4:00 pm Adjourn

This Twin Cities Clean Cities event was made possible through a grant from the Minnesota Department of Commerce and support of the US Department of Energy Clean Cities.

CleanAirChoice.org • 651.227.8014

5

11

E85 Conversion Kit MeetingE85 Conversion Kit MeetingClearing the Air on Vehicle ConversionsClearing the Air on Vehicle Conversions

Hosted by the American Lung Association of the Upper MidwestHosted by the American Lung Association of the Upper Midwest

Made possible, in part, by the Minnesota Department of CommerceMade possible, in part, by the Minnesota Department of Commerce

and the US Department of Energy Clean Citiesand the US Department of Energy Clean Cities

22

33 44

E85 and FFVs E85 and FFVs Status in MinnesotaStatus in Minnesota

Tim GerlachTim GerlachAmerican Lung Association of the Upper MidwestAmerican Lung Association of the Upper Midwest

Illinois Illinois –– Indiana Indiana –– Iowa Iowa –– MinnesotaMinnesotaNorth Dakota North Dakota –– South Dakota South Dakota ‐‐ WisconsinWisconsin

651.227.8014 651.227.8014 •• CleanAirChoice.orgCleanAirChoice.org

6

5

Minnesota HistoryMinnesota History

E10 statewide, yearE10 statewide, year--around since 1997.around since 1997.19971997--98: Selected as national pilot market 98: Selected as national pilot market

by USDOE, Ford, NEVC, MN Corn, state by USDOE, Ford, NEVC, MN Corn, state agencies, ethanol producers, ALAMN.agencies, ethanol producers, ALAMN.

‘‘E85 TeamE85 Team’’ housed at/staffed by ALAMNhoused at/staffed by ALAMN~355 stations today . . . And counting!~355 stations today . . . And counting!

6

Our ApproachOur Approach

Personnel & funding focused on:Personnel & funding focused on:Assist retailers with grantsAssist retailers with grantsAssist in technical, marketing & troubleAssist in technical, marketing & trouble--shootingshootingPublic policy issuesPublic policy issuesBuild consumer awarenessBuild consumer awareness

Earned media (publicity)Earned media (publicity)Paid media (advertising) Paid media (advertising)

Investment: ~$9 millionInvestment: ~$9 million--plus over 9 yearsplus over 9 years

Print, Radio, TV, Billboards, Pro baseball & basketball, college hockey, special events & stunts, fuel give-aways, direct-mailings, wrapped vehicles, banners, parades, presenting anywhere and everywhere; race car sponsors, coupons, ultra-marathon runner, Twin Cities marathon water stop, school events, church events; Earth Day events, zamboni ads, bus ads, airport ads, online contests, conversions, dealer contests, fuel cards, state fair displays, frequent-use contests, etc.

7

Minnesota Clean Air Choice TeamMinnesota Clean Air Choice TeamMN Corn Growers AssociationMN Corn Growers Association

MN Soybean Growers AssociationMN Soybean Growers AssociationMN Dept of Commerce Energy DivisionMN Dept of Commerce Energy Division

MN Dept of AgricultureMN Dept of AgricultureGeneral Motors CorporationGeneral Motors Corporation

National Ethanol Vehicle CoalitionNational Ethanol Vehicle CoalitionUS Dept of Energy Clean CitiesUS Dept of Energy Clean Cities

American Lung Association of MNAmerican Lung Association of MNOthers have assisted including fuel producers, fuel suppliers, fOthers have assisted including fuel producers, fuel suppliers, foundations, fleets, oundations, fleets,

Ford Motor Company and several state and federal government entiFord Motor Company and several state and federal government entitiesties

8

355 stations . . . And counting!

7

9 10

MN E85 ObservationsMN E85 Observations

Local champions Local champions imperativeimperative to success to success Progress slower than expected Progress slower than expected –– QuickeningQuickeningMajor step: Major step: ‘‘ConvertingConverting’’ premium/premium/midgrademidgrade ––E85 now outsells those at most outletsE85 now outsells those at most outletsSource of fuel supply makes a big differenceSource of fuel supply makes a big differencePetroleum prices outweigh Petroleum prices outweigh allall other factorsother factors

11

Sources: MN Dept. of Commerce Energy Division; American Lung Association of MN; MN E85 Team –www.CleanAirChoice.org 12

0%10%20%30%40%50%60%70%80%

Very familiar Somewhatfamiliar

Neitherfamiliar norunfamiliar

Somewhatunfamiliar

Not at allfamiliar

Metro

Suburb

Rural

~85% of Minnesota motorists ~85% of Minnesota motorists claim claim ‘‘veryvery’’ or or ‘‘somewhatsomewhat’’

familiar with E85familiar with E85-- ALAMN survey, June ALAMN survey, June ‘‘0707

8

13 14

PoliticsPolitics

Biofuels have enjoyed biBiofuels have enjoyed bi--partisan support.partisan support.Unfortunately, this seems to be changing.Unfortunately, this seems to be changing.Urban Urban vsvs Rural; Republican vs. Democrat?Rural; Republican vs. Democrat?Commodity prices up = Backlash on Farmer? Commodity prices up = Backlash on Farmer?

15

Minnesota Ethanol Minnesota Ethanol –– Love It or Hate ItLove It or Hate It

Projected 2009:Projected 2009:~1 billion gallons of production (17 plants + 4)~1 billion gallons of production (17 plants + 4)InIn--State Use: ~270 million gallons State Use: ~270 million gallons ~$4.9 billion in economic impact to state~$4.9 billion in economic impact to stateImpact of 18,000+ jobs indirectly or directlyImpact of 18,000+ jobs indirectly or directly

Source: Minnesota Dept of AgricultureSource: Minnesota Dept of Agriculture

16

CleanAirChoice.org CleanAirChoice.org •• 651651--227227--80148014

American Lung AssociationAmerican Lung Associationof the Upper Midwestof the Upper Midwest

9

1717

Update on Rules, Process Update on Rules, Process and Kit Certificationsand Kit Certifications

Marty Marty ReinemanReinemanUnited States Environmental Protection AgencyUnited States Environmental Protection AgencyNational Vehicle and Fuel Emissions LaboratoryNational Vehicle and Fuel Emissions Laboratory

18

CERTIFICATION UPDATES for E85 ALTERNATIVE FUEL

CONVERTERS

Marty ReinemanU.S. EPA Office of Transportation and Air Quality

Compliance and Innovative Strategies Division

April 15, 2008

Presentation to:American Lung Association

19

Background

• Requirements for Aftermarket Fuel Converters described in 40 CFR Part 85 Subpart F

– References anti-tampering provisions in Clean Air Act 203(a)(3)– Requires fuel converters to obtain certificates of conformity to avoid anti-

tampering provisions of CAA• Since 2002 EPA has issued over 210 certificates for ~ 4700 light-duty

vehicle conversions to alternative fuels– All are for dedicated or dual fuel conversions of gasoline to LPG or CNG

• EPA guidance on aftermarket fuel conversions last updated in Feb 2006– Document at: www.epa.gov/otaq/cert/dearmfr/cisd0602.pdf– 0602 guidance also applies to ethanol, but many questions on gasoline to

ethanol conversions requires a revised guidance document• Webcast on May 3, 2007 presents information on how OEMs certify E85

FFVs– Document at:

http://www1.eere.energy.gov/cleancities/toolbox/webcast_presentations.html

20

Certifying Aftermarket Conversions to E85

• Aftermarket fuel converters are “small volume manufacturers” and do not conduct upfront full useful life durability testing– Assigned DFs used by fuel converters may not be representative given

they are based on OEM gasoline data• Aftermarket fuel converters do not have in-use testing requirements• Unlike LPG or CNG, ethanol uses the OEM fueling system• Thus the fueling system for aftermarket conversions must be

designed to be compatible with ethanol– OEM E85 FFV fuel systems are designed to address ethanol’s:

solvency of organic materials, galvanic corrosion of dissimilar metals, hydrocarbon permeation, and gasket and O-ring swelling

• Need to ensure component compatibility– If design differences between gasoline and ethanol fueled vehicles are

not understood and addressed, emission and performance problems may result over time

10

21

Addressing Component Compatibility Concerns for E85 Conversions

• Could use OEM components• Any one of the following would address compatibility concerns:

– Supply comparative part numbers of an OEM’s gasoline vehicle and the similar vehicle sold as an E85 FFV

• If part numbers are identical, it proves that for a particular vehicle, the gasoline vehicle was designed with E85 compatible parts

• Note – Some public databases may not agree with OEM part numbers– Conduct whole vehicle durability aging using EPA standard durability

testing protocols • Submission of passing emissions data based on these durability factors is

assurance the conversion meets emission standards for its full useful life– Submit an analysis demonstrating that the components in the gasoline

fuel system are E85 capable • Such an analysis could come from an OEM, a Tier 1 parts supplier to the

OEM, or an equivalent subject matter expert

22

Does Simply Extending the Base Vehicle Warranty Address Component Compatibility?

• Simply extending the base vehicle warranty does not completely address component compatibility issues– EPA has no authority to require fuel converters to provide

warranty coverage beyond what the CAA 8/80 (catalyst and ECU) and 2/24 (Performance Warranty) require

– CAA warranties remain in effect after the fuel conversion and the time/mileage limits do not reset at the time of the conversion

• OEM positions on E85 conversions and warranty coverage vary– One has issued a service bulletin stating the only E85 capable

vehicles are the E85 FFVs which they produce– Another states that converting gasoline vehicles to E85 may be a

type of tampering and they may deny warranty coverage

23

Items in New Guidance Letter -Clarification of Existing Policy

• Component compatibility– EPA requires all types of conversions to address component

durability. For example, the possible need to install hardened valves and valve seats for conversions to gaseous fuels.

• EPA does not certify conversion “kits.”– It is the interaction of the conversion kit and the OEM fueling

system and emission control system that determines if the fuel converted vehicle will meet its emission standards

• “Test group” specific certification still required• Component compatibility issues must be resolved with

EPA before conducting emission or OBD testing• EPA must approve which tests are to be conducted

before start of testing

24

New Guidance Letter Items Cont’d -Issues Assumed but not Explicitly

Stated Before

• EPA regulations allow use of equivalent or better measurement practices – EPA has approved use of a photo acoustic multigas analyzer

manufactured by Air Tech Instruments. This instrument, known as the Innova analyzer, is used by EPA and other OEM laboratories for measuring ethanol in E85 vehicle exhaust.

• Although small volume manufacturers are exempt from EPA’s in-use vehicle testing requirements, EPA has authority to require vehicles to be submitted for EPA testing. EPA is considering exercising this authority for fuel conversions.

11

2525

Bridging the GapBridging the Gap

Dennis Smith, P.E., C.E.M.Dennis Smith, P.E., C.E.M.United States Department of EnergyUnited States Department of Energy

Technology Deployment Manager & Clean Cities DirectorTechnology Deployment Manager & Clean Cities Director

26

U.S. Department of Energy:Update on E85 Vehicle

Deployment EffortsDennis A. Smith, PE, CEM

National Clean Cities Director &Vehicle Technology Deployment Manager

ALA MN – E85 conversions workshopApril 2008

Goal: Petroleum ReductionGoal: Petroleum Reduction

How to Achieve the Goal …

Redu

ce

Replace

Eliminate

Clean Cities Clean Cities A voluntary, locallyA voluntary, locally--based government/industry partnershipbased government/industry partnership

• Established in 1993 in response to the Energy Policy Act (EPAct) of 1992

• Companion program to the EPACT mandates requiring certain fleets to acquire AFVs (Federal, State, and Fuel provider fleets)

Mission: To advance the energy, economic, and environmental security of the U.S. by supporting local decisionsto adopt practices that contribute to the reduction of petroleum

consumption in the transportation sector.

12

Clean Cities Today: 86+ Active Coalitions in 45 States

National Renewable Energy Lab (NREL – Colorado) – Clean Cities Core program technical support , AFDC, technical communications,publications, Clean Cities Web sites, Hotline Response Service

Oak Ridge National Lab (ORNL - Tennessee)) – Federal Fuel Economy Guide, FuelEconomy.Gov websites, National Full Economy consumer education and outreach efforts

Brookhaven National Lab (BNL – New York) - BioMethane and Land fill gas recovery

Argonne National Lab (ANL – Illinois) - Emissions Modeling (GREET and AIRCRED) and Idle Reduction analysis

National Energy Technology Lab (NETL – Project Management and Regional coordination of key Clean Cities activities)

National Laboratory Support

Clean Cities Technology PortfolioClean Cities Technology PortfolioAlternative Fuels• Electricity• Ethanol• Propane• Natural Gas • Hydrogen• Biodiesel (B100)

Idle Reduction• Heavy-duty trucks• Transit/School Buses

Blended FuelsLow levels of alternative fuels with conventional fuels (B2, B5 and B20)

HybridsLight- and heavy-duty hybrids

Fuel EconomyMore Fuel-efficient vehicles, light weight materials, behavioral changes, vehicle maintenance initiatives, etc.

Consumer Information and Education

(tools, publications, and services)

13

Clean Cities Website ToolsClean Cities Website ToolsClean Cities

AFDC

Fuel Economy – in partnership with EPA

Alternative Fuels & Advanced Vehicles Alternative Fuels & Advanced Vehicles Data Center (AFDC) WebsiteData Center (AFDC) Website• Incentives and Laws• Refueling Station Locator• Technology Bulletins• E85 Fleet Toolkit

Incentives and LawsIncentives and Laws Technology BulletinsTechnology Bulletins• Technological breakthroughs, issues, and news

14

E85 Fleet ToolkitE85 Fleet Toolkit

• E85 handling and use handbook (recently updated)

• E85 refueling equipment conversion checklist

• Step by step guidelines for obtaining and installing new infrastructure

• Training materials for station operators

• Case Studies

E85 Retail Business Case: When and Why to SellE85 Retail Business Case: When and Why to Sell

• Developed in conjunction with NACS & other key fuel retailers

• Highlights challenging market that gasoline retailers are operating in.

• Shows how E85 can augment known tactics to be more competitive

• Analyzes E85 equipment as an investment• Tests the impact of various factors on payback for

E85 investment • Offers guidance for retailers to maximize

profitability and assess if E85 would be a good investment for them

Minnesota Case StudyMinnesota Case Study

• MN Department of Commerce tracks their E85 use very closely• 25% of all U.S. E85 stations are in Minnesota• Preliminary 2005 study yielded some very interesting

conclusions– Most effective consumer motivator was prominent price signage for less

expensive E85 (added 740 gal/month in sales)– Each additional FFV registered in a zip code led to a 4 gal/month sales

increase– 1 cent rise in gas price increased E85 sales 2 times more than 1 cent drop

in E85 price– Stations in urban, rich areas had greater E85 sales

• New project underway to update/expand original findings

Alternative Fuels HotlineAlternative Fuels Hotline• 1-877-337-3463• Available 9:00 a.m. – 6:00 p.m. EST• [email protected]

15

--Ethanol Goes Racing !Ethanol Goes Racing !-- Vehicle Road Tests with new emphasis Vehicle Road Tests with new emphasis

on Fuel Economy and Energy Securityon Fuel Economy and Energy Security-- Alternative Fuel Vehicle Maintenance Alternative Fuel Vehicle Maintenance

Advice and related Motor NewsAdvice and related Motor News

(airs weekly on PBS, SPEED, Armed Forces Network)(airs weekly on PBS, SPEED, Armed Forces Network)

MW Consults with DOE on advanced MW Consults with DOE on advanced automotive technology topics automotive technology topics ……Past Show Topics:Past Show Topics:

Vehicle and FuelTechnology Issues

Energy Efficiency &Renewable Energy

43

20 in 10/EISA Goals Cannot be MetSolely Through Expansion of E10 Gasoline

• Ethanol markets are not able today to absorb the ethanol volumes specified by the Energy Independence & Security Act (36B gallons)

• There are multiple paths being considered to significantly increase ethanol markets:– Path A: Saturate E10 markets – and significantly expand E85

markets at an accelerated pace– Path B: Certify “intermediate blends” of gasoline to use up to 15 or

20% ethanol (E15, E20) and let market forces drive ethanol supply distribution

• DOE is working with EPA and industry stakeholders to investigate the impact of Path B on the existing “legacy”fleet of vehicles and non-road equipment.

E85 Engine Optimization Efforts

• DOE recently made six awards to develop a production-intended, ethanol optimized engine for FFVs …

– Technologies Must be feasible and practical for near term commercialization

– Projects will run approximately 3 years– Each has at least 50% cost share– Over $6 million of DOE funds in year 1

16

• Certified (legal) conversion kits are available for numerous natural gas and propane powered vehicles today.

• Current Uncertainty with E85 & Plug-In Hybrid conversions• The Department does not support or encourage the use of non-

certified conversion kits. (They are Illegal !)• All systems must have EPA / CARB emissions certification and

must be compliant with US-DOT safety regulations • Conversions are much more difficult and complex than most

people realize (increasingly so in recent years)• Despite this, pirate kits are now available over the internet

(Many are Illegal and some could be Unsafe / Dangerous)

Vehicle Conversions

• Ethanol conducts electricity• The Galvanic corrosion potential between dissimilar

metals is not Trivial !• Materials Compatibility Issues for certain Elastomers

(gaskets & seals)• Different Fire-fighting chemicals and techniques

needed in case of leaks/spills • What are the implications for small engines, marine,

existing & older vehicles ?

Ethanol is Different from Petroleum Fuels(issues are similar to recent UL investigation)

47

med

ian

age

0

2,000,000

4,000,000

6,000,000

8,000,000

10,000,000

12,000,000

14,000,000

16,000,000

81 82 83 84 85 86 87 88 89 90 91 92 93 94 95 96 97 98 99 00 01 02 03 04 05 06 07

The Number of Older Vehicles on the road is Significant !

over 115 million

Light duty motor vehicle registrations by model year

(based on NREL analysis of R.L. Polk data)

Model year -

Average Age~10 years

over 115 million

-mill

ions

-

(PB/DAS Mar08)

• On-Road vs. Off-Road rules (racing and performance upgrades for the track may not be legal for fleets or the family car).

• Light Duty vs. Heavy Duty ? (Testing and compliance rules are very different, even though the engine may be the same).

• EPA or CARB ? (Numerous other states are adopting California standards).

Confused over Which Rules Apply to Your Situation? The answer may not be simple!

17

1) General Performance and Drivability2) Emissions Performance3) State & Federal Regulations4) Safety 5) Warranty & Service Implications6) Long Term Durability7) Consumer Trust and Confidence

Critical Issues that must be Addressed when modifying Vehicles:

50

51 52

18

54

55 56

19

57 58

59

1) Re-Educate yourself and others on the issues regarding E85 vehicle conversions.

2) Pay attention to the details ! It’s more complicated than most people realize.

3) Be as accurate and truthful as possible (When in doubt, ask for word-smithing help).

4) Avoid Internet hype and hysteria. 5) Let’s work together !

Moving Ahead:

20

Contact Information:Contact Information:Dennis A. Smith, P.E., C.E.M.National Clean Cities Director &Vehicle Technology Deployment ManagerU.S. Department of Energy (EE-2G)1000 Independence Avenue, SWWashington, D.C. 20585-0121Office: 202-586-1791Fax: 202-586-2476E-mail: [email protected]

6262

Update from E85 FlexUpdate from E85 Flex‐‐Fuel Fuel Vehicle ManufacturersVehicle Manufacturers

Ed KulikEd KulikFord Motor CompanyFord Motor Company

Ford Emissions Regulatory PlanningFord Emissions Regulatory Planning

6363

Clearing the Air on Vehicle Conversions

Presented at the Request of the American Lung Association and the State of Minnesota

Ed KulikApril 15, 2008

Ford Motor Company – Vehicle Environmental Engineering

6464

Our presentation is an overview of FordOur presentation is an overview of Ford’’s s perspectives when complying with the perspectives when complying with the Clean Air Act requirements and Clean Air Act requirements and certification of alternative fuel vehicles.certification of alternative fuel vehicles.

Included are areas of interest for vehicle Included are areas of interest for vehicle conversion companies:conversion companies:–– What one should be aware of when they What one should be aware of when they

are considering modifying a gasoline are considering modifying a gasoline vehicle to operate and be certified as an vehicle to operate and be certified as an EE--85 Flexible Fuel Vehicle.85 Flexible Fuel Vehicle.

21

6565

The United States Clean Air ActThe United States Clean Air Act

The Clean Air Act is a federal law, with national coverage, thatThe Clean Air Act is a federal law, with national coverage, thathas led to significant improvements in human health and the has led to significant improvements in human health and the environment in the United States.environment in the United States.

Included in the Clean Air Act are provisions for vehicles to be Included in the Clean Air Act are provisions for vehicles to be converted to run on alternative fuels and the EPAconverted to run on alternative fuels and the EPA’’s role.s role.

Converted vehicles must not result in an adverse impact to our eConverted vehicles must not result in an adverse impact to our environment nvironment [CAA Section 203].[CAA Section 203].This requirement is sometimes referred to as enforcement of the This requirement is sometimes referred to as enforcement of the tampering provisions.tampering provisions.

6666

Federal and California Emissions Federal and California Emissions Certification RequirementsCertification Requirements

In addressing the CAA provisions, both the US EPA and CaliforniaIn addressing the CAA provisions, both the US EPA and California Air Air Resources Board have authority and have developed alternative fuResources Board have authority and have developed alternative fuel el conversion certification requirements. The links below provide conversion certification requirements. The links below provide details.details.

–– http://www.arb.ca.gov/msprog/aftermkt/aftermkt.htmhttp://www.arb.ca.gov/msprog/aftermkt/aftermkt.htm–– http://www.epa.gov/otaq/cert/dearmfr/cisd0602.pdfhttp://www.epa.gov/otaq/cert/dearmfr/cisd0602.pdf

In addition to initial reIn addition to initial re--certification, alternative fuel conversions may be certification, alternative fuel conversions may be subject to comply with insubject to comply with in--use testing programs such as a state's inspection and use testing programs such as a state's inspection and maintenance program.maintenance program.

5050--State Applicability: Several states have adopted California emiState Applicability: Several states have adopted California emissions ssions requirements, therefore consideration of requirements, therefore consideration of wherewhere an alt. fuel conversion will be an alt. fuel conversion will be operated needs to be understood, and the appropriate compliance operated needs to be understood, and the appropriate compliance requirements requirements applied. applied.

6767

FordFord’’s Positions, as a Manufacturer of E85 FFVss Positions, as a Manufacturer of E85 FFVs

Ford strongly supports the use of renewable fuels, including ethFord strongly supports the use of renewable fuels, including ethanol, and is anol, and is committed to the increased availability of E85 FFVs, as demonstrcommitted to the increased availability of E85 FFVs, as demonstrated by ated by the vehicles we have on the road today and those we have committthe vehicles we have on the road today and those we have committed to ed to produce. produce.

We recognize E85 fuel conversions provide vehicle owners with thWe recognize E85 fuel conversions provide vehicle owners with the option e option of converting their existing vehicles to operate on higherof converting their existing vehicles to operate on higher--level ethanol level ethanol blends.blends.

Clean, robust conversions can help promote the use of ethanol.Clean, robust conversions can help promote the use of ethanol.–– However, we are concerned with the risk to ethanol acceptance, aHowever, we are concerned with the risk to ethanol acceptance, and a given nd a given

companycompany’’s reputation, if conversions are not properly handled. s reputation, if conversions are not properly handled.

Because of the complexity and confidentiality issues, OEMs, suchBecause of the complexity and confidentiality issues, OEMs, such as Ford, as Ford, are not in a position to provide detailed assistance to E85 convare not in a position to provide detailed assistance to E85 converterserters–– Many of the specific components, systems and durability processeMany of the specific components, systems and durability processes relied on to s relied on to

certify an E85 FFV are protected business confidential informaticertify an E85 FFV are protected business confidential information.on.

6868

What can we offer that may be helpful to What can we offer that may be helpful to E85 fuel converters?E85 fuel converters?

Understanding the complexity of the issue, we have developed a Understanding the complexity of the issue, we have developed a "generic "generic listlist““ of components and/or systems and processes that could be considof components and/or systems and processes that could be considered ered when developing an E85 FFV for certification.when developing an E85 FFV for certification.

The list offers some insight, based on our knowledge, of the typThe list offers some insight, based on our knowledge, of the types of es of components and processes that could be considered when a vehiclecomponents and processes that could be considered when a vehicle is to be is to be converted and recertified as an E85 FFV. converted and recertified as an E85 FFV.

Please note, this list should not be considered all inclusive. Please note, this list should not be considered all inclusive. –– It is ultimately up to the EPA and/or CARB to determine if the eIt is ultimately up to the EPA and/or CARB to determine if the emissions missions

requirements of E85 FFV conversions have been satisfied, and therequirements of E85 FFV conversions have been satisfied, and theconversion does not adversely impact the environment for the fulconversion does not adversely impact the environment for the full useful l useful life of the vehicle.life of the vehicle.

22

6969

The Scope of a generic list for consideration in The Scope of a generic list for consideration in converting/certifying an E85 FFVconverting/certifying an E85 FFV

Processes Processes -- in terms of EPA and CARB certification application and in terms of EPA and CARB certification application and testing protocol.testing protocol.

Components and systems information Components and systems information -- to help understand robustness to help understand robustness issues associated with full useful life compliance.issues associated with full useful life compliance.

Other Performance Considerations Other Performance Considerations

7070

Processes Processes –– to address emissions performance when to address emissions performance when operating on E85 (See EPA and CARB for Details)operating on E85 (See EPA and CARB for Details)Standard emissions tests to assure converted vehicles do not cauStandard emissions tests to assure converted vehicles do not cause adverse environmental se adverse environmental consequences at sea level and at altitude, including:consequences at sea level and at altitude, including:

–– Exhaust Testing: FTP, Cold FTP (20Exhaust Testing: FTP, Cold FTP (20°°, 50, 50°°), ), –– Evaporative Testing: 2 and 3 day SHED tests, Running Loss test,Evaporative Testing: 2 and 3 day SHED tests, Running Loss test, ORVRORVR–– Smog check, Inspection/Maintenance, Smog check, Inspection/Maintenance,

On Board Diagnostics:On Board Diagnostics:–– OBDII monitoring and diagnostic systems must continue be in compOBDII monitoring and diagnostic systems must continue be in compliance and new/unique components liance and new/unique components

may need to be addressed within the scope of OBDII. may need to be addressed within the scope of OBDII.

Durability: Durability: –– Emissions requirements include compliance for Full Useful Life (Emissions requirements include compliance for Full Useful Life (120,000 miles or 150,000 miles 120,000 miles or 150,000 miles

depending on the certification standards)depending on the certification standards)–– Deterioration Factors, used to address FUL compliance, should beDeterioration Factors, used to address FUL compliance, should be representative of a converted/add on representative of a converted/add on

system. system.

Labeling: Labeling: –– Permanently affixed label applied in the vicinity of the VECI toPermanently affixed label applied in the vicinity of the VECI to indicate that the vehicle is equipped with indicate that the vehicle is equipped with

a conversion system.a conversion system.–– Label applied to the OEM onLabel applied to the OEM on--board computer if a board computer if a reflashreflash is performed.is performed.

7171

Systems & components Systems & components -- robustness to E85 fuel, for robustness to E85 fuel, for full useful life, should be considered forfull useful life, should be considered for

Fuel tanksFuel tanksFuel pumpsFuel pumpsFuel lines, seals and filtersFuel lines, seals and filtersFuel rails. Fuel rails. Fuel InjectorsFuel InjectorsFuel blend Sensors Fuel blend Sensors Fuel level indicator, including circuitry to alternate polarity Fuel level indicator, including circuitry to alternate polarity for for corrosion protectioncorrosion protectionPiston ringsPiston ringsIntake and exhaust valves and valve seatsIntake and exhaust valves and valve seats

7272

Other Performance Considerations Other Performance Considerations Warranty requirements must be clear to the consumer: Warranty requirements must be clear to the consumer:

–– OEMs do not warrant the conversion or any consequential damage cOEMs do not warrant the conversion or any consequential damage caused by the conversion.aused by the conversion.–– It is important for the customer to understand where to turn wheIt is important for the customer to understand where to turn when an issue arises. n an issue arises.

If you operate your vehicle 50% or more of the time on E85, you If you operate your vehicle 50% or more of the time on E85, you may need to follow a may need to follow a different maintenance schedule which includes more frequent oil different maintenance schedule which includes more frequent oil and filter changes. and filter changes. The fuel pump may need to be upgraded to provide higher flow ratThe fuel pump may need to be upgraded to provide higher flow rates associated with es associated with operation on higher ethanol blends.operation on higher ethanol blends.Cold weather is a significant factor. Longer crank time, the poCold weather is a significant factor. Longer crank time, the potential for hesitation/rough tential for hesitation/rough running, or norunning, or no--start, can be negative consequences without careful engine recalstart, can be negative consequences without careful engine recalibration.ibration.Plastic fuel tanks Plastic fuel tanks -- may be permeable to highmay be permeable to high--level ethanol blends effecting evaporative level ethanol blends effecting evaporative emissions.emissions.Existing injector sizing may be insufficient for higherExisting injector sizing may be insufficient for higher--power demands and cold start control.power demands and cold start control.Fuel blend sensing system must be capable of detecting the perceFuel blend sensing system must be capable of detecting the percent of ethanol in the fuel.nt of ethanol in the fuel.Engine control calibration needs to adjust to varying ethanol coEngine control calibration needs to adjust to varying ethanol content.ntent.Emissions control for lowEmissions control for low--level blends of ethanol.level blends of ethanol.

–– Splash blends create a fuel mixture with a high vapor generationSplash blends create a fuel mixture with a high vapor generation capability that can overwhelm capability that can overwhelm conventional gasoline vapor emissions controls.conventional gasoline vapor emissions controls.

23

7373

ClosingClosing

ItIt’’s safe to say, we all want our customers to have a s safe to say, we all want our customers to have a positive experience with our E85 Flexible Fuel vehicles.positive experience with our E85 Flexible Fuel vehicles.

Whether these E85 vehicles are new, used, or converted, Whether these E85 vehicles are new, used, or converted, appropriate measures need to be taken to help ensure a appropriate measures need to be taken to help ensure a good customer experience and that our US emissions good customer experience and that our US emissions requirements are met through the certification process. requirements are met through the certification process.

We believe a reasonable first step in the retrofit process We believe a reasonable first step in the retrofit process is to work constructively with our environmental is to work constructively with our environmental agencies (EPA and CARB) to understand the agencies (EPA and CARB) to understand the appropriate retrofit requirements.appropriate retrofit requirements.

7474

Thank you for your TimeThank you for your Time

7575

Update from E85 FlexUpdate from E85 Flex‐‐Fuel Fuel Vehicle ManufacturersVehicle Manufacturers

Rich GuntherRich GuntherGeneral Motors CorporationGeneral Motors Corporation

Government and Alternative Fuel FleetsGovernment and Alternative Fuel Fleets

76Page 76DoE/NREL/EPA Ethanol Conversion Webcast

Vehicle Changes for E85 Conversion

Coleman JonesClean Cities Webcast

03MY07

24


Conversion Types 1. Conversion where a Flexfuel vehicle of the same type exists

• An example is 2002-2007 GM pickups and utilities with 5.3 liter engines

• Flexfuel parts and calibrations have been engineered and are available

• Process involves swapping parts and installing software and calibrations – not as simple as it sounds

2. Conversion where no Flexfuel vehicle of the same type exists• This is the vast majority of the fleet• No flexfuel parts and calibrations exist• These parts, software, and calibrations would need to be

developed from scratch• Requirements determined• Suppliers identified• Parts validated• Software and calibrations developed


Vehicle System Changes for E85/Flexfuel

• Fuel storage and handling– Filler neck– Tank and associated parts– Fuel lines

• Engine hardware• Engine control system

– Engine controller– Control software– Control calibrations


Fuel Storage and Handling• Filler neck may need changing

– Material may not be compatible with ethanol– Leaks could result due to shrinkage or swelling– Leak will cause OBD system to set codes (check engine light)– Leak will cause vehicle to fail evaporative emissions

requirements• Flame arrester is generally added to filler neck

– E85 typically has lower vapor pressure than gasoline • Metal fuel tanks would have to be examined for E85

tolerance– Terne metal material (typical metal tank) is not compatible with

ethanol without special coatings– Corrosion and leaks can result– Leaks will cause OBD system to set codes – Leaks will cause vehicle to fail evaporative emissions

requirements


Fuel Storage and Handling• Seals and grommets need to be evaluated for compatibility

– Shrinkage, swell, or mechanical failure can lead to leaks, codes and evaporative emissions

• Fuel pump must be changed– Material changes, higher flow rate– Pump failures will lead to walk-homes– Inadequate pump flow, whether a result of not upgrading pump or

pump deterioration, will lead to diagnostic codes– Inadequate pump flow will lead to ineffective catalyst protection

routines, catalyst damage and emissions failures• Fuel sender is typically changed

– Corrosion resistance and mode of operation– Fuel sender failure leads to fuel gauge loss and, possibly, loss of

ethanol estimate and control diagnostic codes. • Vapor pressure sensor is typically changed

– Materials compatibility– Device required for evaporative emissions compliance

25


Fuel Storage and Handling

• Fuel lines are often changed– Polymer lines

• Polymer can be extracted into ethanol and precipitate at injector

• Fouled injectors lead to codes, uneven cylinder operation and emissions, loss of power…

– Metal lines can corrode• Leakage will cause evaporative emissions• Corrosion products can degrade and plug injectors• Degraded injectors lead to codes, uneven cylinder operation

and emissions, loss of power…


Engine Hardware• Fuel rails should be stainless steel

– Other materials lead to the same problems as fuel lines

• Fuel injectors are changed– Materials compatibility

• Winding insulation must be ethanol compatible to prevent shorts

• Corrosion resistance is very important to correct operation– Flow must be adequate

• Allows commanded flow• Enables rated power• Enables catalyst protection mode and thus required catalyst

life


Engine Hardware

• Valves and valve seats are usually changed– Wear of these components leads to valve seat

recession, – Valve seat recession, once valve lash is exhausted

will produce valve leaks, misfire, codes, emissions, valve burning, head replacement

• Piston rings are often changed– Ring wear lead to blow-by, loss of power codes,

emissions


Engine Control System• Engine controller

– Controller may need to be changed to have enough capacity to accept required software

– Controller may have to be changed to be compatible with fuel sender

• Fuel composition sensor may need to be added– This provides the ethanol composition to the controller so that

the correct calibrations can be used• If there is no fuel composition sensor control software to

determine ethanol concentration is needed.– The software must be able to distinguish between fuel and

hardware induced changes in air-fuel ratios to ensure diagnostic (OBD) compliance

26


Engine Control System

• Control calibrations– New calibrations are required to adjust fuel, spark, EGR, etc. for

the ethanol content– Variables are non-linear between E0 and E85– Special calibration revisions are required for cold and hot start– Depending on software architecture, special calibrations are

required for catalyst protection routines– Inadequate calibrations can lead to poor running, elevated

emissions, and vehicle and emissions systems durability issues.


Conclusion

• Developing a flexfuel or even a dedicated E85 vehicle is a major undertaking– Conversion to an existing flexfuel design requires extensive

swapping of parts often deep inside the vehicle– Conversion of a vehicle that has never been flexfuel requires

extensive engineering of new parts, finding suppliers, and validating the resulting hardware

• Software and calibration development will be a major undertaking requiring specialists to execute

• Conversions that do not include these elements will result in vehicles with significantly reduced life that will probably not be compliant for their useful life– Consumers will be dissatisfied with the product and, by

extension, with ethanol


• OBD = On Board Diagnostics• EGR = Exhaust Gas Recirculation

8888

Update from E85 Conversion Update from E85 Conversion Kit ManufacturerKit Manufacturer

Chris DisherChris DisherFlex Fuel U.S.Flex Fuel U.S.

Chief Financial OfficerChief Financial Officer

27

Chris DisherApril, 2008

E85 Conversion Business Clearing the Air

90

Our Company:

Flex Fuel U.S. is a pioneer in the manufacturing of ethanol conversion kits. The company’s kits enable gasoline-powered vehicles to run in flex fuel mode, any combination of E85 and gasoline can be used.

Based in Chicago, IL, the company’s management and technical team includes leading experts in digital fuel injection, custom automotive engineering, and automotive aftermarket distribution.

We are the first and only company to be certified by the EPA for E85 conversions.– Certification allows Flex Fuel US to legally sell conversion kits– U.S. patent awarded # 7630878– Auto manufacturer’s warranty is maintained– Patent protection and EPA Certification present significant barriers to entry for competitors

The Flex Fuel US E85 conversion system will produce the following benefits:– 1. Reduce the total cost of fuel for consumers with attractive payback– 2. Improve engine performance and extend engine life– 3. Reduce engine emissions and enhance air quality– 4. Reduce America’s dependence on foreign oil– 5. Provide consumers a choice in using renewable energy

91

E85 Conversion is a legitimate business:

1. Federal agencies, such as Homeland Security, DOE, EPA, and the Treasury Department, regard alternative fuels as an important part of our National Security, Environmental and Economic Agenda

2. Using E85 is the single most significant way motorists can reduce their greenhouse gas carbon footprint. The carbon dioxide emitted by fossil fuel cars such as a standard taxi is produced at a rate of one pound per mile. This can be reduced by 20-45%

3. The new Energy Bill provides for large increases in ethanol production and should reduce barriers to distribution at the retail level

4. The multi-billion dollar automotive aftermarket business is protected by law; ensuring that manufactures can market innovations without affecting vehicle original warranties.

5. The EPA provides guidance to alterative fuel converters on requirements for emissions certifications. EPA objectives include increasing certifications for renewable fuels including E85

92

E85 Conversion is a legitimate business (con’t):

6. Federal and State agencies recognize the benefits of alternative fuel conversions and provide for tax credits and incentives for conversions

7. Government fleets are required to use alternative fuel vehicles

8. Major automotive service suppliers look forward to selling and installing conversion kits. For example, AAMCO automotive specialists plan to install certified kits in their retail outlets with support of their marketing and corporate installer training programs

9. Limousine and cab companies want to serve corporate accounts with “Green”agendas. E85 vehicles can provide a competitive advantage

10. Consumers prefer to reduce their spending on foreign oil and spend their money on US based businesses

28

93

Ethanol is the leading alternative fuel…

Ethanol is a centerpiece of Energy plan calling for a 20% reduction in gasoline by 2017

The Energy Bill enables gas retailers to sell E85 without oil company interference

Federal and state legislation offers incentives for alternative fuels; Illinois has an 80% rebate program

Rapid expansion of refinery and pump capacity is occurring- 70 new plants under construction

Elected Officials are adopting a fight against global warming and foreign oil dependence

Automaker investments introducing flex fuel vehicles have stirred interest in bio fuels

Unbiased research is emerging supporting positive benefits of ethanol

Ethanol is being adopted in the racing market over racing gas e.g. 2007 Indy 500

94

Technology is proven, EPA approves first conversion!

Member MemoTo: NEVC Board and Members

From: Phil Lampert, Executive Director

Date: 10/09/2007

Re: Conversion Kit for Certain Fleet Vehicles

NEVC Board and Members:

For the first time ever, the Environmental Protection Agency has granted its certification for an automobile conversion kit, allowing non-flexible fuel vehicles to safely and efficiently run on E85. Now, such fleet vehicles as the Ford Crown Victoria, Mercury Grand Marquis and Lincoln Town Car can legally be equipped with a Flex-Box Smart Kit (TM) and fueled with E85 by fleet operators. Developed by Chicago-based Flex Fuel U.S., an NEVC member and pioneer in ethanol conversion systems, the compact conversion unit easily mounts in the engine compartment and continuously monitors engine and emission controls and delivers supplementary fuel injection to allow the vehicle to operate at optimal performance no matter what fuel blend is in the tank.

To visit the official website of Flex Fuel U.S., go to www.flexfuelus.com.

95

The Flex Box Smart Kit is delivered

Flex fuel conversion kit designed to allow gasoline powered vehicles to also operate on any combination of ethanol and gasoline

Benefits; – Savings at the pump and fuel economy delivered; 10-15% net savings on total cost of fuel– 10% improvement in horsepower and torque – Improved emissions; e.g. CO2

EPA certification assures factory warranties are maintained

Technology includes patented supplemental fuel injection system with proprietary software

Simple installation, passive operation, minimal maintenance

96

FLEX BOX SMART KIT U.S. Patent No: 7,349,790

29

97

Flex Fuel U.S., HEMI Charger E85 Conversion

Flex Fuel U.S., Chicago Police Interceptor E85 Conversion

Flex Fuel U.S. Control Module Installed on Charger

Component Parts Installed on Police Interceptor

98

A Vision for the Ethanol Conversion Industry- Fix the Legacy Fleet and arrest Global Warming

241 Million vehicles are on the road today; 1/2 could be converted

National renewable fuel standards and ethanol production and distribution goals (7X increase to 36 Billion gallons) are met

Cellulosic sources supplant corn as the feedstock for ethanol

National demand for ethanol could be met with conversion systems

CO2 reduction from conversion would be enormous; up to 100 million tons/year or more – Typical vehicle produces 1 pound of CO2/ mile- over 6 tons/year– 20-45% reduction in fossil CO2 with ethanol- 2 tons/year per vehicle, 33% reduction

Dramatic reductions in greenhouse gasses, independence on foreign oil viable in this decade

With cellulosic ethanol available, and higher conversion market penetration, CO2 emission reductions could reach over 500 million tons annually in the US alone through conversion. About 10% of the total requirement to arrest Global Warming

99

2006 U.S. LT. DUTY VEHICLE SALES 16.7 Million

2006Total GasolineVehicle Sales

15,163,83490%

2006Total Flex FuelVehicle Sales

954,9296%

2006Total Diesel

Vehicle Sales660,188

4%

100

120 Million Lt. Duty Vehicles Produced 2000 -2006

TotalDomestic truck

Sales55,810,061

46%

TotaLImport Truck

Sales7,437,196

6%

TotalDomestic Car

Sales43,240,874

36%

TotalImport Car

Sales14,122,612

12%

30

101

The Market is Excited about our Product

Includes Fleet customers, performance, greenies, and general consumers

We intend to serve Fleet customers first followed by performance & greenies, general consumer market will be addresses as we develop kits for this more complex market

Fleet customers believe Green Vehicles will provide socially conscious, competitive advantage

Flex Fuel US has signed a non-exclusive contract with AAMCO to sell and install kits nationally

The City of Chicago is expanding its program after successful pilot on a Police Car

Limo Companies are also piloting our kits and have ordered more kits

Limo conversion companies will also offer aftermarket conversions for their customers

Pilot kit recently delivered to the Department of Energy

102

Flex Fuel Corporate Headquarters & Distribution Center

103

Flex Fuel Center for Emissions & Performance Engineering

Manteno, Illinois

104

Roush Vehicle Emissions Laboratory, EPA Certified

Testing vehicle emissions for over 24 years

Recognized world wide for their engineering and technical skill

Roush Labs are EPA Certified

Used more often by OEM’s for emissions testing then any other emissions lab

Over 40 alternative fuel conversion certifications

31

105

Recap: Flex Fuel US Milestones:

In October of 2007, first EPA certification to ever be awarded for an E85 conversion

In 2007 Flex Fuel US signed a contract allowing AAMCO to sell and install conversion kits in over 800 retail outlets. The installed cost of the kit for fleets is under $1,500; installation in less than two hours.

The City of Chicago, and a leading limousine services company are piloting Flex Fuel US kits. Both plan to expand the program once EPA approvals are received and production kits are available for sale.

DOE piloting kit with Oak Ridge Labs.

In January of 2008, the US patent office granted Flex Fuel US a patent for the technology. New applications for the kit have been developed, passed emissions requirements, and await certification– Dodge Charger– Ford F150

Warehouse, R&D facilities, and front & back office are operational in Chicago and Manteno, IL

Streamline process with Roush Laboratories for independent testing

Now seeking strategic equity partner for commercialization and expansion

106

Contact information

Mitch Sremac, Chief Executive Officer

Chris Disher, Chief Financial Officer– Flex Fuel U.S. LLC

– 5820 North Northwest Highway– Chicago, IL 60068

– (773) 763-7900– [email protected]– [email protected]

– www.flexfuelus.com

107107

Alternative Fuel Engine Alternative Fuel Engine Certification Case Study: PropaneCertification Case Study: Propane

Victor Van DykeVictor Van DykeSchwanSchwan’’s Food Company/Bis Food Company/Bi‐‐PhasePhase

108108

SchwanSchwan’’s Home Service s Home Service Fleet OperationsFleet Operations

1978 1978

Marvin Marvin SchwanSchwan was faced with the threat of fuel shortageswas faced with the threat of fuel shortages

Profitability decreasedProfitability decreased

Conversion of fleet to propaneConversion of fleet to propane

29 years later 29 years later

Over 5,000 mediumOver 5,000 medium‐‐duty trucks nationwide run on clean duty trucks nationwide run on clean burning propaneburning propane

90% of the fleet operates on propane90% of the fleet operates on propane

35 million gallons of propane per year35 million gallons of propane per year

120 million driven miles per year120 million driven miles per year

32

109109

LPEFI by BiLPEFI by Bi‐‐PhasePhase

Direct replacement of gasoline EFIDirect replacement of gasoline EFINo physical engine changesNo physical engine changesNo engine electronic management modificationsNo engine electronic management modifications

Engine Life CycleEngine Life Cycle ‐‐ Evaluating LPEFIEvaluating LPEFI®® advantagesadvantagesPerformancePerformance –– Improved cold weather operation Improved cold weather operation and throttle response and throttle response EmissionsEmissions –– Meets and exceeds EPA standardsMeets and exceeds EPA standardsDesignDesign –– Simple and robustSimple and robustInstallationInstallation –– Quick and simpleQuick and simple

110110

The CertificationThe Certification

0

2

4

6

8

10

Gra

ms/

BH

P H

r

BPT GM EPA

2007 8.1L engine Certification

Comaprison to EPA CFF ULEV Standard

NMHCCONox

BPT 8.1 L Propane BPT 8.1 L Propane engine is certified to engine is certified to Clean Fuel Fleet Ultra Clean Fuel Fleet Ultra Low Emission Vehicle Low Emission Vehicle level.level.

2008 EPA standard is 2008 EPA standard is dramatically reduced dramatically reduced to a NOx level 5 times to a NOx level 5 times lower then before. lower then before. Preliminary tests show Preliminary tests show 08 BPT 8.1L propane 08 BPT 8.1L propane engine will meet the engine will meet the new requirements.new requirements.

111111

Minnesota Center for Minnesota Center for Automotive ResearchAutomotive Research

Dr. Bruce JonesDr. Bruce JonesAutomotive Engineering TechnologyAutomotive Engineering Technology

Minnesota State University, MankatoMinnesota State University, Mankato

112112

Thank You!Thank You!If we may ever be of service, please contact

your local American Lung Association.

Minnesota Clean Air ChoiceMinnesota Clean Air Choice™™ Team Team –– 20082008

American Lung Association of Minnesota • Minnesota Corn Growers Association Minnesota Soybean Growers Association • Minnesota Department of Commerce

Minnesota Department of Agriculture • General Motors Corporation National Ethanol Vehicle Coalition • US Department of Energy – Clean Cities

800.LUNG.USA 800.LUNG.USA ‐‐ CleanAirChoice.orgCleanAirChoice.org

33

DISCLAIMER: Notes contained below are a best attempt at recording the discussion. These are not intended as direct quotations of individuals or organizations involved and should not be stated as such. Any errors belong to the note taker. In the event of error, we will promptly issue corrections to attendees. Phone: (651) 227-8014

Moderated Q&A Session with Experts, Audience and Webcast Participants

Clearing the Air on Vehicle Conversions – April 15, 2008 American Lung Association of the Upper Midwest – St. Paul, Minnesota

Q: Directed to OEM: What about retailers beginning to market mid-level blends (E20, E30, E50, etc…) to gasoline-only vehicle drivers? GM/Gunther- We do not agree with this. The fuels haven’t been tested and we’re very nervous about people doing this. We prefer the FFV approach. Recently, I recall reports out of (Australia) of mid-level blends in gasoline vehicles and a 40% failure rate on the catalytic converters. Ford/Kulik: All gasoline vehicles are certified to run on E10 and below. We know programs are underway to test E20 in gasoline-only vehicles. USDOE/Smith: Intermediate blends (I-blends) are also a concern for UL certification of dispensers. Like E85 dispensers, they are under waiver with local jurisdiction. ALAUM/Gerlach: Minnesota Weights & Measures are taking blender pumps on case-by-case basis. No prohibition against selling mid-level blends into FFVs, but the mid-level blends must be labeled for FFVs only. Q: What was nature of catalytic failures seen in other country/s? GM/Gunther: We can get back to you on this information. Q: Are there countries we can look to for how conversions should be done? Flex Fuel US/Disher: Brazilian kits just change the amount of fuel that goes into the engine. We don’t agree with this strategy. You need computer programming changes to determine exact amount of fuel at a given time …We are not aware of any material problems in countries like Brazil. Studies and other information made available from OEMs and others would help speed up the process. USEPA/Reineman: Personally, I’ve always been curious about the Brazilian situation, but we are busy enough attempting to monitor the US situation properly. GM/Gunther: Brazil has had flex fuel technology longer and their fuel program was mandated by government. Today, ethanol fuels are at 100% of pumps in Brazil . . . but, remember, Brazil is very different in many ways from US. They have used E100 (no cold concerns) at times and vehicles with gasoline side tank for cold starts. NREL/Clark: Fuel in Brazil is different and can be hydrous ethanol. This would definitely have an affect on some materials used in US. USDOE/Smith: Brazil is a different animal, vehicles don’t have onboard diagnostic regulations, levels of emissions are different in Brazil, different types of ethanol that might not work here. Q: With mid-level blends, how do they address fuel quality issues like vapor pressure?

34


NREL/Clark: They don’t. No ASTM standards exist for any mid-level blends. Q: Could conditional certification be granted to those in the process of testing this? USEPA/Reineman: If the manufacturer has submitted appropriate documentation and applications for certification, then, EPA reserves the right to test vehicle at EPA lab. Regulations allow manufacturer to request conditional certification contingent on manufacturer passing confirmatory test at EPA lab. This was largely done to accommodate time challenges of European or Japanese manufacturers as it could take months to get vehicle into US. EPA came up with conditional certification equal to regular certification but it is not applicable to durability testing for conversions. Whole vehicle aging process required by the regulations takes several months; I don’t think it applies to this process. Q: Are Schwans’ LPG conversions federally and CARB certified? Schwans/BiPhase/VanDyke: We have both CARB and federal certifications. Q: To GM: You spoke about concerns GM has uncovered recently with rings and valves with E85. Did GM know there was an issue previously or are you making changes going forward with new vehicles? GM/Gunther: I am not a production guy. I do know changes to the upcoming 2009 4 cylinder FFV have been made and everything they build will be that way from now on. Q: What about 3.5L fleet engine program? GM/Gunther: I am not sure, Coleman Jones is the fellow that we should connect with on the specifics. Q: What is the status of Flex Fuel US Certification? Flex Fuel US/Disher: We were granted Lincoln Towncar and Crown Vic based on Roush testing. EPA had different lab, bar was set differently and we missed by a couple of grams of emissions. We are now trying to get that certification back. The 2006Dodge Charger, completed by Roush, is ready for the EPA lab now and we are working on some other details. Our F150 is working and our testing is completed. Dodge and F150 emissions are much better than on gasoline. It is a complex issue and process. Q: Victor is dealing w/dedicated vehicles, is Flex Fuel US looking at a dedicated E85 system? If so, can you comment on that? Flex Fuel US/Disher: Dedicated is not very practical unless you live in MN w/E85 so well established. There is no flexibility when you cannot use gasoline, so we have no plans for a dedicated system. Our system handles all blends extremely well.

35


USEPA/Reineman: We know of one company that has a dedicated E85 product. Nothing in regulations prevents this. EPA has questions about how to confirm dedication to E85, nozzle sizes of gasoline versus E85 misfuelings, etc. EPA wants to understand the consequences of that and the potential emissions impact. Q: You voiced concern about dedicated E85 vehicles, what assurance do you have that a regular vehicle won’t fill will E85 instead of gas? USEPA/Reineman: EPA is concerned with that because we do believe that there are consequences, a variety of consequences resulting from consumers self-resolving problems (adding in more gasoline to dilute the alcohol content). OEMs would say it is a warranty issue. ALAMN/Gerlach: Early on in the E85 pilot market, many of us were concerned about misfueling. The reality is that consumer misfuels at service stations are not uncommon with gasoline into diesel, E85 into gasoline vehicles, etc. But, it really has not been the problem we thought it might be. The best defense for us in our role of setting up stations is to ensure the fuel and dispenser are very clearly marked. Q: When you look in your crystal ball what do you see in the future? From a fleet perspective, more FFV availability is great. Filling niche applications w/conversions would be ideal for many of us fleet managers. USEPA/Reineman: Honestly, the EPA has enough homework to do with issues right now and in answering complexities with certification. I answer from the perspective of our concerns of people selling unapproved systems online and in EPA’s role of answering the federal laws. I am not a marketing person, but if companies were pursuing certification, I imagine they would be looking at the economics, aggressiveness of OEM FFV production, that sort of thing. USDOE/Smith: I look at this as similar to what happened after the Energy Policy Act of 1992 mandated alt fuel vehicles…conversions popped up flooding markets w/cheap stuff that didn’t meet regulations. It is tough for companies to compete and it took some time to sort out. Now, there are a half dozen companies that do natural gas and propane conversions. We hope the truth gets told. As a fleet person, if approached by a conversion company, you need to ask questions, ask for a copy of EPA certifications. Schwans/BiPhase/VanDyke: With alternative fuels, the only thing that matters is a business that makes sense in dollars. Fleets need to save money by using the new fuel. And, will the investment made in certifications, materials, and kits result in return on investment? Go back to basics and make sure your model creates wealth and money advantages. Consumer market is a totally different ballgame, but fleets need dollars and cents behind it. Everything else will fall into place.

36


Q: Just a clarification on the Permeation issue mentioned earlier. Could you define permeation for the audience – and, isn’t it true that E85 lowers permeation emissions? NREL/Clark: Permeation is the migration (molecular level) of fuel components through, primarily, the elastomers, plastics in the vehicle fuel system. Yes, E85 performs well in lowering permeation emissions. Ethanol in low-level blends can increase permeation to a point where vehicle will fail evaporative emissions standard. E85 performs better than E10. Q: For ethanol advocates in the audience, might we say the aromatics and other gasoline components are to blame in permeation? NREL/Clark: Well, no . . . that’s not exactly accurate. Flex Fuel US/Disher: From a permeation standpoint, E85 reduces permeation rate compared with E10 and gasoline. NREL/Clark: Worst case is around E25 GM/Gunther: This is one issue in which CARB rules restrict sales of E85-capable vehicles. It is being hotly debated in several states. Q: Doesn’t the Code of Federal Regulations require that when a car is certified for gasoline that the car also be certified to the highest level of ethanol on the roads? USEPA/Reineman: Actually the OEMs have had to because of concern of evaporative emissions. OEMs design gas vehicles to take into account that E10 may be used. Testing is done on a gas vehicle using straight certification fuel. The test gasoline used, is a special standard fuel differing from real gasoline. It has been around since earliest emission tests. There has been discussion of making the test gasoline (indolene) more representative or real-world fuel. Q: I am a representative of the SAE committee that is looking for members to help develop standards for FFV and potential conversions. Are any of you interested in serving on this committee for new standards? Contact [email protected] THANK YOU, Mr. Horne, for bringing this to our attention – We will make certain to list this in the meeting notes. Q: Considering all the misconceptions with biofuels – let alone conversion issues, do any of you plan to offer training to mechanics? Flex Fuel US/Disher: Mechanics haven’t had training yet, but Flex Fuel US has a package of training for those installing our products. It most definitely will include information on addressing some of the misconceptions as well as how to install the system.

37


MSU/Jones: Misconceptions exist with any alt fuel. We have a student that is now finishing up doctoral thesis technician training. We have worked a long time with our coworkers, young people and others on perceptions, how much they know about ethanol. We know most consumers get their information from mechanics/technicians. We are working with the technician certification association on auto service excellence, tests for certified alt fuels, etc. Education and training is always important and it never really stops. Ford/Kulik: From Ford’s perspective, Ford has alerted service departments so they understand that a converted vehicle could come in. We still have a long way to go. Q: What can federal/state governments do to facilitate conversion certifications? USEPA/Reineman: Change the regulations. (I) didn’t create the process, but I must deal with it. There has been some discussion about the possibility of EPA officially changing required testing that OEMs must meet. There is no “get out of emissions control for free.” Certification process is complex, and it’s a hard fit for a small business person. There is pressure from politicians and requests to accommodate concerns of the small businesses involved. The Clean Air Act is tough. Our options are extremely limited, but we think we’ve done a good job so far in trying to accommodate all parties. To go beyond would require changes in the regulations. GM/Gunther: I don’t see this getting easier Flex Fuel US/Disher: First, the federal regulations never anticipated E85 ethanol conversions. This is new on scene. Good practices in commercial and federal worlds must exist. We need to follow certain rules and we need to understand, up front, what the plan is before our investments are made. Ahead of time, we need a clear dialogue with EPA on test plan required and we need their cooperation in looking for ways to streamline. We need total transparency. Closing Items: MSU-Mankato/Dr. Jones: More research is needed to develop the use of these fuels, engines and materials. Audience: I have noticed the federal websites are not always updated with the most recent information or updated quickly . . . with issues such as the fuel handling guidelines, etc. Please do what you can to draw attention to this fact. ADJOURN: 4:05 pm

38


American Lung Association of Minnesota • St. Paul, MN

Registrants Giedrius Ambrozaitis Alliance of Auto Manufacturers Email: [email protected] David Babcock City of Minneapolis Alison Chandler American Lung Association of MN Email: [email protected] Marilou Cheple MN Department of Commerce Email: [email protected] Chris Disher Flex Fuel US Email: [email protected] Diane Droeger MN Pollution Control Agency Email: [email protected] Penny Fena American Lung Association of MN Email: [email protected]

Tim Gerlach American Lung Association of MN Email: [email protected] Rich Gunther General Motors Corporation Email: [email protected] Ken Hemp MN Department of Natural Resources Email: [email protected] Bruce Jones Minnesota State University‐Mankato Email: [email protected] Ed Kulik Ford Motor Company Email: [email protected] Fran Kurk MN Pollution Control Agency Email: [email protected]

39



Registrants (Continued)

Dick Livermore City of Minneapolis Email: [email protected] Dick Logan General Motor Corporation Email: [email protected] Riley Maanum MN Corn Growers Association Email: [email protected] John Mages MN Corn Growers Association Kelly Marczak American Lung Association of MN Email: [email protected] Lindsey McKenzie American Lung Association of SD Email: [email protected] Robert Moffitt American Lung Association of MN Email: [email protected]

Tim Morse MN Department of Administration Email: [email protected] Ron Mundahl City of Saint Paul, Public Works Email: [email protected] Emily Nelson American Lung Association of MN Email: [email protected] Joey Nelson Snell Motors Mankato Email: [email protected] Sandy Neren Messerli Kramer Email: [email protected] George Paulson Met Council Marty Reineman USEPA National Vehicle & Fuel Emissions Email: [email protected] 40



Registrants (Continued) Al Roy Met Council Elizabeth Sheridan MN Pollution Control Agency Email: [email protected] Dennis Smith US Department of Energy Email: [email protected] Mitch Sremac Flex Fuel US Email: [email protected] Brian Steffensmeier Snell Motors Mankato Ethan Taylor Missouri Corn Growers Association Email: [email protected] Lisa Thurstin American Lung Association of MN Email: [email protected]

Victor Van Dyke Schwan’s Food Company/Bi‐Phase Email: [email protected] Alan Watt Intelligent Ethanol Systems Email: [email protected] Linc Wehrly USEPA National Vehicle & Fuel Emissions Email: [email protected] Tim Werner Roush Emissions Lab Email: [email protected] Sharon Wieland ND Corn Growers Association Bill Yoder GM North Central Region Phil Younger Renew E85 LLC/Utica Energy Email: [email protected] 41



Registrants (Continued)

Webinar participants Wendy Clark National Renewable Energy Laboratory Email: [email protected] John DeRosa American Lung Association of IL Email: [email protected] Gerry Harrow National Renewable Energy Laboratory Email: [email protected] Doug Horne DBHORNE LLC Email: [email protected]

Matt Marcum American Lung Association of IL Email: [email protected] John Rodgers American Lung Association of IL Email: [email protected] Angela Tin American Lung Association of IL Email: [email protected] John Thomas Oak Ridge National Laboratory Email: [email protected]

42



Victor Van Dyke (right) of Schwan’s Food Company provided “lessons learned” from his experience with propane conversions.

Dr. Bruce Jones (left), Professor of Automotive Engineering Technology at MN State University, Mankato, was a member of the panel & provided his insights on conversion kit issues.

More than 50 E85 advocates participated in the meeting.

Panelists responded to questions posed by the audience.

Minnesota Clean Air Choice Team — 2008 American Lung Association of Minnesota • General Motors Corporation

Minnesota Corn Growers Association • Minnesota Soybean Growers Association Minnesota Department of Commerce • Minnesota Department of Agriculture National Ethanol Vehicle Coalition • US Department of Energy — Clean Cities

800.LUNG.USA CleanAirChoice.org

The parking lot was filled with clean fuel vehicles including a variety of FFVs, Hybrids and a propane truck.

Tim Gerlach of the American Lung Association (Top Left) started the presentations; followed by Marty Reineman of the USEPA (Top Center), Dennis Smith of the USDOE (Top Right), Ed Kulik of Ford Motor Company (Bottom Left), Rich Gunther of General Motors Corporation (Bottom Center) & Chris Disher of Flex Fuel US (Bottom Right).

Thanks to the MN Department of Commerce, the US Department of Energy Clean Cities, National Renewable Energy Laboratory and the MN Clean Air Choice™ Team, for making this meeting a success.

43

Clean Air Choice™

For more information on biofuels, contact your local Lung Association

or visit CleanAirChoice.org.

Illinois • Iowa • Minnesota North Dakota • South Dakota • Wisconsin

Improving Life, One Breath at a Time

44

clearing the air on vehicle conversions · 2018-12-08 · 1 e85 conversion kit meeting clearing the...

Documents