Can a vehicle be converted to operate on E85?

Response:

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 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 U.S. Environmental Protection Agency (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 aftermarket 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.

IS IT POSSIBLE TO CONVERT A VEHICLE THAT WAS DESIGNED FOR GASOLINE TO OPERATE ON E85?

Yes. However, there are no conversions 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 percent ethanol.

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. Additionally, the production of vehicles by auto manufacturers that are capable of operating on unleaded gasoline or E85 (flexible fuel vehicles) at little or 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.