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Technical Assessment of E15 Use in 1994-2000 Model Year VehiclesRicardo Inc.

September 2010

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E15 Fuel Waiver

� EPA is currently reviewing a 211(f) (4) waiver for E15 use in light duty motor vehicles

– 15% fuel ethanol, 85% unleaded gasoline

� EPA has stated that an approval of E15 may be limited to 2001 or 2007 model year (MY) and newer vehicles

� RFA believes that limiting the use of E15 to certain model year vehicles may prevent widespread availability / implementation

CAA section 211(f)(4), as revised: The Administrator, upon application of any manufacturer of any fuel or fuel additive, may waive the prohibitions established under paragraph (1) or (3) of this subsection or the limitation specified in paragraph (2) of this subsection, if he determines that the applicant has established that such fuel or fuel additive or a specified concentration thereof, and the emission products of such fuel or fuel additive or specified concentration thereof, will not cause or contribute to a failure of any emission control device or system (over the useful life of the motor vehicle, motor vehicle engine, nonroad engine or nonroad vehicle in which such device or system is used) to achieve compliance by the vehicle or engine with the emission standards with respect to which it has been certified pursuant to sections 206 and 213(a) of this title. The Administrator shall take final action to grant or deny an application submitted under this paragraph, after public notice and comment, within 270 days of the receipt of such an application.

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Ricardo E15 Technical Assessment

� Identify and review fuel system hardware changes occurring in 1994 – 2000 MY

� Review EPA emission and diagnostic regulation adoption and implementation

� Interrogate EPA emissions certification data to evaluate tailpipe emissions effects

� Study after treatment systems and vehicle calibration data from 1994 – 2000 MY

� Identify characteristics of E15 fuel blends that affect hardware durability

� Identify degradation mechanisms of fuel systems and evaluate E15 effect

� Procure and evaluate physical fuel system parts from focus model years

Figure 3.3: Typical ORVR Fuel System

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US Light Duty Vehicle Fleet

� RFA Engineering Assessment– 1994 – 2000 MY ~ 25%

� Current Assessment (US DOE & others)– 2001- 2010 ~ 63%

� 1994-2010 MY vehicles represent ~87.6% of all vehicles in use today

0

50

100

150

200

250

LDV LDT Total U.S. LD Fleet

Num

ber o

f Veh

icle

s [M

illion

s]

1994 - 2000 MY Vehicles2001 - 2010 MY Vehicles1994-2010 MY VehiclesU.S. Light Duty Fleet

U.S. Light Duty Fleet

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Top 25 Vehicle Platforms 1994 – 2000 MY

Vehicle Manufacturer

Platform 1994–2000 Total Sales

Vehicle Models

General Motors GMT400 5,444,489 C/K & SierraFord P1 5,214,189 F150Ford PN105/106 5,116,999 Ranger / ExplorerFord D186 5,019,201 Taurus, Sable, Continental

General Motors W 4,249,084Lumina, Century, Regal, Intrigue, Cutlass Supreme, Grand Prix, , Impala

General Motors GMT300 4,129,464 S-10 truck & BlazerChrysler AS-NS-RS 3,709,415 MinivansToyota MCV 3,422,500 Toyota Camry, Toyota Avalon, Lexu s ES300General Motors N 3,143,541 Skylark, Achieva, Alero, C utlass, Grand AmHonda CD-CG 2,924,467 Honda Accord, Acura CL, Acura TLHonda E 2,494,624 Honda Civic, Acura IntegraGeneral Motors J 2,347,693 Sunbird, Sunfire, CavalierChrysler BE-BR 2,213,043 Dodge Ram PickupFord Panther 2,163,162 Crown Victoria, Grand Marquis, CarFord CT120 2,060,523 Tracer, EscortChrysler ZJ-WJ 1,857,623 Jeep Grand CherokeeGeneral Motors H 1,849,275 LeSabre, 88, 88 Regency, LSS, Bonneville

Chrysler LH 1,808,011Concorde, LHS, 300, New Yorker; Dodge Intrepid; Eagle Vision

General Motors GMT800 1,741,202Silverado, Sierra, Suburban, Tahoe, Yukon, Yukon XL, Denali, Escalade

General Motors Z 1,713,359 Saturn S-seriesCE-ZZE 1,499,056 Corolla, Celica

Chrysler PL 1,380,013 NeonFord VN 1,264,924 EconolineFord CDW27 1,102,939 Mystique, ContourNissan A 1,079,121 Maxima, I30General Motors M/L 1,044,612 Astro, Safari

Top 25 Vehicle Platforms from the Big 6 Manufacture rs between 1994 and 2000

� Six automotive manufacturers sold over 87.5% of the vehicles in the 1994 – 2000 MY

– General Motors, Ford, Chrysler, Toyota, Honda, Nissan

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EPA Emission Regulation Evaluation

Class Vehicle

Type

Emission

Standards

1994 1995 1996 1997 1998 1999 2000

Pre-Enhanced Evap LDV, LDT5 Years

50k Miles100% 100% 80% Max. 60% Max. 10% Max. none none

Enhanced Evap LDV, LDT10 Years

100k Miles20% Min. 40% Min. 90% Min. 100% 100%

ORVR LDV10 Years

100k Miles40% Min 80% Min. 100%

Model Year

Evaporative Emissions Requirements by Model Year

Evaporative Emissions Requirements by Model Year (1 994 to 2000)

Figure 3.3: Typical ORVR Fuel System

Tailpipe Emissions Requirements by Model Year (1994 to 2000)

� Significant regulatory changes

� Enhanced EVAP

� ORVR

� Improved materials

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After Treatment and Emissions Effects

� The primary effect of increasing the ethanol content in gasoline is the enleanment of the air-fuel ratio and the key issue is the ability of the vehicle’s engine management system (EMS) to compensate for it

– Increasing the ethanol content from E10 to E15 will not affect the air-fuel control in vehicles that have a switching oxygen sensor

� Studies by the Coordinating Research Council (CRC, Report No. E-87-1) have shown that vehicles with open loop adapted fuel trims have more consistent catalyst temperatures when using fuel blends between E0 and E20, which reduces the potential of catalyst degradation due to temperature

� Tailpipe Emissions - Assuming that the EMS can maintain a stoichiometric air-fuel ratio in the engine, the catalytic converter should be able to process the engine-out emissions into non-polluting species, with no change in this capability between E10 and E15

� Evaporative Emissions - Since vapor pressure of E15 is lower than E10, evaporative emissions related to vapor pressure would not increase and may, in some instances, decrease depending on the exact formulation of the gasoline source. Insufficient data exists to predict the effect of E15 on permeation based evaporative emissions – in some cases they may be lower than on E10.

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Fuel System Components Evaluation

� Evaluated components from end of life vehicles: fuel tank, fuel sender, fuel lines, fuel injectors

� Determined primary concern would not be ethanol related effects

– Greater impact from environmental effects such as weather, salt, etc.

Fuel Tank Assembly, 1997 Pontiac Grand Prix (ID# 6032C)A steel tank from a 1997 Pontiac Grand Prix. This tank had an interior coating and did not show internal tank corrosion. None of the internal components were observed to have corrosion. The external surface of the tank was corroded. The tank had a blue o-ring interface to the integrated fuel pump and level sensor assembly.

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Fuel System Components Evaluation

Fuel Tank Assembly, 1998 Ford Taurus (ID# 6220C) Fuel Line Bundle, 1998 Ford Taurus (ID# 6220C)Fuel lines from a 1998 Ford Taurus. These stainless steel lines did not show signs of internal or external corrosion.

Fuel Rail and Injectors, 1998 Ford Taurus (ID# 6220C)The fuel rail from a 1998 Ford Taurus. This polymer fuel rail displays no signs of corrosion.

Fuel Filter Sectioned, 1998 Ford

Taurus (ID# 6220C)

A sectioned fuel filter from

a 1998 Ford Taurus. The plated steel

filter has minor exterior

corrosion.

A fuel tank assembly from a 1998 Ford Taurus. This fuel tank is made of steel and has a coated interior. There is an o-ring interface to the integrated fuel pump and level sensor assembly. No corrosion was seen on internal components or on the fuel tank interior, but some external corrosion

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Fuel System Components Evaluation

Common Fuel System Materials

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Conclusion

“The analysis concluded that the adoption and use of E15 would not adversely affect fuel system components in properly engineered vehicles, nor would it cause them to perform in a sub-optimal manner, when compared to the use of E10.”

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