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Swede
Joined: 23 Feb 2006 Posts: 2 Location: Stockholm, Sweden
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Posted: Thu Feb 23, 2006 4:39 pm Post subject: Flextek conversion-system EPA certified? |
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Hello folks,
I'm new to this forum and usually i visit the Swedish ethanol forum at www.etanol.nu/forum/index.php to find info on ethanol related issues, but in this case someone here must know better.
According to this text http://en.wikipedia.org/wiki/E85, ( very good read btw) Flextek conversion-system is the only after market conversion-system availeble legally in the US,
| Quote: | Similarly, U.S. Federal law prohibits the manufacture of such conversion kits for sale in the U.S. unless they are EPA certified, by a ban that dates to when conversion kits for converting vehicles to use compressed natural gas was enacted to prevent the sale of such conversion kits due to concern about the safety of such conversion kits being released among the general public. This is despite the fact that such kits are nonetheless legal in all states, but CA, and most states even offer a tax break for converting your vehicle (See tax breaks.)
Still, there is one Brazilian after-market kit available legally in U.S. states not subject to emission controls that will nonetheless permit the conversion of 4, 6, or 8 cylinder engines to operate from fuels ranging from pure gasoline to a mix of gasoline and ethanol to pure ethanol, including E85. It operates by modifying the fuel-injection pulses sent to the fuel injectors when in 'A', or alcohol mode instead of 'G', or gasoline mode. (In 'G' mode, no modification to the fuel-injection pulses is performed.) This conversion kit modification serves to extend the control range over which the ECU can adjust the air-fuel ratio to achieve an oxygen sensor reading measured before the catalytic converter that falls within nominal stoichometric ideal combustion limits. The general belief is that this conversion kit operates in its 'A' mode simply through lengthening the individual pulse-widths of fuel-injection pulses, thereby increasing fuel flow per injection pulse by roughly 30%, whereas in 'G' mode, it acts simply as a straight pass through for fuel-injection pulses.
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Does that mean that it is certified by EPA? Or is it available legally some other way?
All answers are highly appreciated.
Best regards
/ Swede |
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BURNALCOHOL
Joined: 19 Oct 2005 Posts: 50 Location: Raymond,NE
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Posted: Tue Mar 28, 2006 6:57 pm Post subject: |
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Any and all conversions must pass a Federal EPA emissions test. The EPA does not certify convertion kits any more just the converted vehicle.
Months of E-mailing back and forth with the EPA I still don't know how or how much this test cost.
| Quote: | the EPA Federal Test Procedure for an individual's conversion costs $750.00. One can request a reduction of payment of down to 1% of the car's added retail value due to the conversion. A minimum fee may apply if the value added is not seen to be very high.
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The quote is the part that I added to Wikipedia. I never could get a respones from the EPA about if that was correct. I had a link to the sight I found it on but someone has deleted it off.
It also used to say:
In the case of vehicles or engines
which have originally been certified by
an original equipment manufacturer
(OEM) but are being modified to operate
on an alternative fuel, the cost basis for
the reduced fee amount is the value added
by the conversion, not the full
cost of the vehicle or engine.
Looks like I'll have to find that EPA sight again and go into Wikipedia and correct it. _________________ Jeremy Nicholls |
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hotrod
Joined: 19 Apr 2005 Posts: 872 Location: Colorado
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Posted: Tue Mar 28, 2006 10:04 pm Post subject: |
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| Quote: | | Flextek conversion-system is the only after market conversion-system availeble legally in the US, |
As far as dedicated conversion systems it is but there a several other options to accomplish the same thing on various car models.
There is a device called an SAF-C which is widely used by people to manually tune their cars. It works by tricking the stock ECU into believing the engine is receiving more or less air that it really is. The result is it can be used to force the stock ECU to run richer or leaner mixtures than the manufacture intended. There is no reason that this and any number of other systems intended for high performance tuning could not just as easily be used to add the necessary fuel for running E85.
Each family of cars have their own aftermarket tuning solutions available. On the Subaru WRX there are at least 7 including the SAF-C, there are 2 ecu reflash systems that will write a custom tune to the ECU, At least 2 software packages that allows some control over the ECU, at least one piggy back unit that over rides the ECU as directed by the tuner and at least one complete replacement ECU system. This is in addition to mechanical upgrades like I did to install larger injectors and not tell the ECU about it.
I would suggest that folks do a little research to see what tuning solutions are available for their car model, there is a solution for nearly any car that is popular in the high performance community.
Larry |
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imprezarsc
Joined: 29 Jun 2005 Posts: 87
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Posted: Thu Mar 30, 2006 1:04 am Post subject: |
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Larry is right. There are many options to increase your fuel delivery. I still believe the most universal modification is a set of appropriately larger injectors. Larger fuel injectors are available for every make and model in existence. Often enough, it seems, another larger factory fuel injector can be used and the ECU doesn't have to be touched.
Just my .02 cents. _________________ http://www.grantouringlabs.com My ethanol conversion and tuning site. |
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BURNALCOHOL
Joined: 19 Oct 2005 Posts: 50 Location: Raymond,NE
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Posted: Thu Mar 30, 2006 2:00 pm Post subject: |
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I did ask the EPA about just changing the fuel pressure. The EPA considers that a conversion. Anything that modifies the original equipment or design. New ingector or higher fuelpressure or the Flextek converter are all considered the same. The EPA wants you to have the emmisions tested to certify the vehicle.
| Quote: | Does this converter violate the Clean Air Act ?
I can't comment on whether or not this device may be in violation of the
Clean Air Act since we have no FTP data to prove its emissions
performance. However, a portion of a manufacturer's Application for
Certification to EPA includes the type of fuel which must be used during
EPA testing and used during operation in the field after sale. The
fuel, and its delivery via the electronic fuel-control, is, therefore,
considered under the CAA , Title II, Sec. 203 (a) as "....an element of
design", the alteration of which is considered a violation under the
Act.
Is state I/M test data sufficient basis for approval ?
The only test-procedure recognized by EPA for to determine compliance is
the FTP.
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_________________ Jeremy Nicholls |
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specialgreen Site Admin
Joined: 10 Jul 2004 Posts: 259 Location: Minneapolis, Minnesota
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Posted: Thu Mar 30, 2006 6:32 pm Post subject: |
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I suspect that the legal status of the Flextek is:
It is legal to import and buy in the US.
It is legal to put onto your car, if you pay EPA to certify your modification.
If you don't pay the EPA to test and certify your car, and the EPA somehow determines your car to have been modified, then you should be prepared to be asked to return the car to its unmodified state (that is, remove the FlexTek), have the car certified as being "stock" again, and probably pay some kind of fine for your infraction. |
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BURNALCOHOL
Joined: 19 Oct 2005 Posts: 50 Location: Raymond,NE
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Posted: Wed Apr 05, 2006 8:46 am Post subject: EPA |
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The EPA has updated their "conversion guidence letter" do to all the inquiries they have received from myself and others.
http://www.epa.gov/otaq/cert/dearmfr/cisd0602.pdf
| Quote: | "A new question and answer number 41 was added to clarify that EPA's policy on alternative
fuels conversions applies to all fuel types, not just LPG and CNG which are the only fuel
types discussed in the previous guidance letter, CCD-05- 10. Since the issuance of CCD-05-
10, EPA has received inquiries about certifying alternative fueled vehicles which can be
designed to operate on ethanol (E-85) or vegetable oil."
41. Which fuel types require converters to obtain certificates of conformity from EPA?
Ans. EPA vehicle emission regulations are basically fuel neutral, meaning standards must be met regardless of fuel type. There are, however, differences in some of the test procedure requirements depending on the fuel type. For example, some of the evaporative emission requirements may be waived for LPG and CNG because they are closed fueling systems.
The test procedures in Attachment 2 were developed at a time when almost all the interest in aftermarket fuels conversions was based on converting gasoline vehicles to LPG or CNG. Subsequent to publication of EPA's policy on fuels conversions in August of 2002 and publication of updated guidance in October 2004, EPA has received inquires about converting gasoline fueled vehicles to ethanol (E-85) and converting diesel fueled vehicles to vegetable oil. Vehicles converted to operate on E-85 or diesel fuel must pass the appropriate standards for the fuel type used by the OEM when the vehicle was originally certified. EPA will determine which tests must be conducted and which procedures followed for certifying with a specific alternative fuel. |
It may not be much of a change, but at least it is a step in the right derection. Keep up the good work. Contact your local Goverment and express the need to make this process easier for individuals who want to convert their vehicles to E85. _________________ Jeremy Nicholls |
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B.A.Bowling
Joined: 15 Feb 2006 Posts: 6 Location: Baltimore, MD
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Posted: Wed Apr 05, 2006 7:38 pm Post subject: |
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Jeremy,
This is really good feedback from the EPA, thanks for taking the time to push the issue with them.
If I read the statement correctly "Vehicles converted to operate on E-85 or diesel fuel must pass the appropriate standards for the fuel type used by the OEM when the vehicle was originally certified", the target standard is the level set when the vehicle was new operating on the original fuel type. So, for example, I am perfroming a MS conversion of a 1954 Ford F100 truck, as long as I meet or exceed the original emission specifications, and have it certified, that it will be legal to operate with E-85. I wonder what the HC/Nox levels were allowed for this vintage vehicle
I also see that they left the controlling hook in there with "EPA will determine which tests must be conducted and which procedures followed for certifying with a specific alternative fuel" statement. I am curious if just meeting the HC/Nox/CO levels with a 5-gas test at a local emission center is "suffcient" - would this show as a 'good faith' towards compliance for a particular conversion?
In a side note, this is interesting in that this comment should affect any change/modification that someone could potentially introduce. For instance, the application of Nitrous Oxide would affect fuel/air and resultant emissions. Also, if tampering with fuel pressure regulator is a potential violation unless it is re-certified, then this could be extrapolated to anyone who performs any type of induction-related modification, like new intake systems, exhaust headers, etc. - all can affect emission output concentration and should be subject to the same re-testing. A lot of these products use the terms "off-road and racing use only" to in order to market these items, but we know many are used on the street.
SEMA may also be an interesting organization to get involved with this, they apparantly have a lot of lobbying muscle with the government. I will give them a call (I am a member) to see what/if they are aware of this new conversion guideline letter.
- Bruce |
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specialgreen Site Admin
Joined: 10 Jul 2004 Posts: 259 Location: Minneapolis, Minnesota
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Posted: Wed Apr 05, 2006 8:39 pm Post subject: |
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| Quote: | a portion of a manufacturer's Application for
Certification to EPA includes the type of fuel which must be used during
EPA testing and used during operation in the field after sale. The
fuel, and its delivery via the electronic fuel-control, is, therefore,
considered under the CAA , Title II, Sec. 203 (a) as "....an element of
design", the alteration of which is considered a violation under the
Act. |
Hm, I wonder how many cars were tested with E-10 in 1990? My guess is that only those new models introduced since ethanol blends came on the scene, were tested using ethanol blends at all. Models tested in previous years were probably "grandfathered", possibly after the EPA satisfied itself that E-10 is generally cleaner-burning than gasoline.
| EPA wrote: | | Vehicles converted to operate on E-85 or diesel fuel must pass the appropriate standards for the fuel type used by the OEM when the vehicle was originally certified. |
Is that a change in policy? I thought I remembered reading that the previous language specified that the applicant had to prove that emissions using the new fuel or fuel system, were equivalent or better than the OEM fuel system, for a (simulated) ten-year test period. The "simulated ten-year test" was something only the EPA could evaluate. However, this languade might be interpreted to mean: hook up the car to the tester at your local auto mechanic, and if it is producing fewer emissions than the new OEM vehicle, then you're good to go. That would certainly be cheaper than a month of testing at the EPA. |
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BURNALCOHOL
Joined: 19 Oct 2005 Posts: 50 Location: Raymond,NE
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Posted: Mon Apr 10, 2006 3:29 pm Post subject: |
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| Quote: | | Is that a change in policy? I thought I remembered reading that the previous language specified that the applicant had to prove that emissions using the new fuel or fuel system, were equivalent or better than the OEM fuel system, for a (simulated) ten-year test period. The "simulated ten-year test" was something only the EPA could evaluate. However, this language might be interpreted to mean: hook up the car to the tester at your local auto mechanic, and if it is producing fewer emissions than the new OEM vehicle, then you're good to go. That would certainly be cheaper than a month of testing at the EPA. |
specialgreen,
That is how it was for in Memorandum 1A Option 3. Option 3 of the Memo 1A officially expired on March 31, 2002. All these laws are geared to auto makers and large companies for conversions to compressed natural gas (CNG) or liquefied petroleum gas (LPG or propane). Ethanol back then wasn't too cost effective so not to many people wanted to convert a car to it. Plus were could you find E85 station back then any way?
http://www.eere.energy.gov/afdc/afv/memo1a.html
Vehicle Programs and Compliance Guidance Letters:
http://www.epa.gov/otaq/cert/dearmfr/dearmfr.htm _________________ Jeremy Nicholls |
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