FE405 E15 Summary Presentation 15Sept10 V3

Technical Assessment of E15 Use in 1994-2000 Model Year Vehicles Ricardo Inc. September 2010

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RD.10/245605.1 © Ricardo plc 2010 2 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.

RD.10/245605.1 © Ricardo plc 2010 3 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

RD.10/245605.1 © Ricardo plc 2010 4 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

250

1994 - 2000 MY Vehicles 2001 - 2010 MY Vehicles 200 1994-2010 MY Vehicles U.S. Light Duty Fleet

150

100

50 Number of Vehicles [Millions] Vehicles Number of

0 LDV LDT Total U.S. LD Fleet U.S. Light Duty Fleet

RD.10/245605.1 © Ricardo plc 2010 5 Top 25 Vehicle Platforms 1994 – 2000 MY

Six automotive manufacturers sold over 87.5% of the vehicles in the 1994 – 2000 MY – General Motors, Ford, Chrysler, Toyota, Honda, Nissan Vehicle 1994–2000 Platform Vehicle Models Manufacturer Total Sales General Motors GMT400 5,444,489 C/K & Sierra Ford P1 5,214,189 F150 Ford PN105/106 5,116,999 Ranger / Explorer Ford D186 5,019,201 Taurus, Sable, Continental Lumina, Century, Regal, Intrigue, Cutlass Supreme, General Motors W 4,249,084 Grand Prix, , Impala General Motors GMT300 4,129,464 S-10 truck & Blazer Chrysler AS-NS-RS 3,709,415 Minivans Toyota MCV 3,422,500 Toyota Camry, Toyota Avalon, Lexus ES300 General Motors N 3,143,541 Skylark, Achieva, Alero, Cutlass, Grand Am Honda CD-CG 2,924,467 Honda Accord, Acura CL, Acura TL Honda E 2,494,624 Honda Civic, Acura Integra General Motors J 2,347,693 Sunbird, Sunfire, Cavalier Chrysler BE-BR 2,213,043 Dodge Ram Pickup Ford Panther 2,163,162 Crown Victoria, Grand Marquis, Car Ford CT120 2,060,523 Tracer, Escort Chrysler ZJ-WJ 1,857,623 Jeep Grand Cherokee General Motors H 1,849,275 LeSabre, 88, 88 Regency, LSS, Bonneville Concorde, LHS, 300, New Yorker; Dodge Intrepid; Chrysler LH 1,808,011 Eagle Vision Silverado, Sierra, Suburban, Tahoe, Yukon, Yukon XL, General Motors GMT800 1,741,202 Denali, Escalade General Motors Z 1,713,359 Saturn S-series CE-ZZE 1,499,056 Corolla, Celica Chrysler PL 1,380,013 Neon Ford VN 1,264,924 Econoline Ford CDW27 1,102,939 Mystique, Contour Nissan A 1,079,121 Maxima, I30 General Motors M/L 1,044,612 Astro, Safari Top 25 Vehicle Platforms from the Big 6 Manufacturers between 1994 and 2000 RD.10/245605.1 © Ricardo plc 2010 6 EPA Emission Regulation Evaluation

Figure 3.3: Typical ORVR Fuel System

Significant regulatory changes

Tailpipe Emissions Requirements by Model Year (1994 to 2000) Enhanced EVAP

Evaporative Emissions Requirements by Model Year ORVR

Model Year Class Vehicle Emission 1994 1995 1996 1997 1998 1999 2000 Improved materials Type Standards

5 Years Pre-Enhanced Evap LDV, LDT 100% 100% 80% Max. 60% Max. 10% Max. none none 50k Miles

10 Years Enhanced Evap LDV, LDT 20% Min. 40% Min. 90% Min. 100% 100% 100k Miles

10 Years ORVR LDV 40% Min 80% Min. 100% 100k Miles Evaporative Emissions Requirements by Model Year (1994 to 2000)

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.

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.

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 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 Filter Sectioned, 1998 Ford Taurus (ID# 6220C) A sectioned fuel filter from a 1998 Ford Taurus. The Fuel Rail and Injectors, 1998 Ford Taurus plated steel (ID# 6220C) filter has minor The fuel rail from a 1998 Ford Taurus. This exterior polymer fuel rail displays no signs of corrosion. corrosion. RD.10/245605.1 © Ricardo plc 2010 10 Fuel System Components Evaluation

Common Fuel System Materials

“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.”