Interpretation ID: nht87-3.37
TYPE: INTERPRETATION-NHTSA
DATE: 12/04/87
FROM: PAUL L. PETERSCHMIDT -- DIRECTOR, BIOMASS RESEARCH UNIVERSITY OF IOWA
TO: GEORGE PARKER -- ASSISTANT ADMINISTRATOR FOR ENFORCEMENT DEPARTMENT OF TRANSPORTATION
TITLE: NONE
ATTACHMT: ATTACHED TO LETTER DATED 03/24/89 FROM ERIKA Z. JONES -- NHTSA TO KEITH E. MADDEN, REDBOOK A33(2), CUSTOM REGULATIONS; LETTER DATED 02/03/89 FROM KENNETH E. MADDEN TO ERIKA Z. JONES -- NHTSA, OCC 3106
TEXT: Dear Mr. Parker:
This letter is in regard to importation of "Motor Vehicles and Motor Vehicle Equipment Subject to Federal Motor Vehicle Safety Standards" (P.L. 89-563 Sects. 108 and 114, 19 C.F.R. 12.80) and related to DOT Form HS 7, Item 7.
The vehicles involved in this request for importation would be classified (under Item 7) as being imported solely for the purpose of test and experiment. The purpose of this letter is to explain the objectives of our research program and the need for th is undertaking.
BACKGROUND
Brazil has in the order of 1.3 million vehicles on the road which are fueled by "neat" ethanol, which is also referred to as hydrous ethanol. The hydrous azeotropic product of ethanol distillation has to be dehydrated to the anhydrous form to be involve d in blending operations with gasoline in this country. The hydrous ethanol fuel for the Brazilian vehicles has a typical analysis of 95% ethanol and 5% water. Today the vast majority of the new over the road passenger vehicles and light trucks in Braz il are ethanol dedicated designs. The use of ethanol as the only fuel was inaugerated about ten years ago, and prompted by the lack of natural petroleum reserves in Brazil. The production of significant numbers of over the road passenger vehicles was in augerated in the early part of this decade, and the production rate has been increasing ever since. About 90% of Ford Brazil's over the road passenger car production models are ethanol fueled vehicles.
During this period (the decade of the 1980's) little, if anything has been done to evaluate these vehicles in the U.S. in terms of performance, economics, exhaust gas composition, emission controls, fuel economy-ambient problems, durability, the material s of construction to accomodate the ethanol fuel, maintenance, power trained design, fuel composition (there are no denaturants used in Brazil), cold weather starting, hot weather Reed vapor pressure problems, etc.
To our knowledge there has been practically no importation of these over the road ethanol vehicles primarily because of a lack of any comprehensive testing programs, and the lack of import approval by the EPA and the DOT. Also the provisions for either re-exporting the vehicles or destroying the vehicles after one year was an obvious deterrent. It is also significant that in the recent "Fuel Ethanol Cost-Effective Study" which was prepared by the National Advisory Panel on Cost Effectiveness of Fuel E thanol Production, published in November of 1987, the accompanying bibliography cited ten pages of references (125) and only one reference was a reference to Brazilian technology in ethanol vehicles. This one reference had to do with "Automotive Use of Alcohol in Brazil and Air Pollution Related Aspects. SAE Technical Paper 850390, February 1985." This University has been involved in research on the production economics of ethanol and utilization throughout this decade. In 1983 we were provided with a Ford-Brazilian designed prototype tractor (which was a modified 4600 design), one of seven in the world, which was ethanol fueled. We tested the unit under field operating conditions for approximately 20 months. The unit was considered a "dedicated" ethanol design and brought into this country by Ford Tractor operations at Troy, Michigan. The unit was equipped with a number of design features which enabled it to perform effectively in cold weather conditions. The tractor was placed on a research f arm operated by Pioneer Hi-Bred International near Iowa City and was used for farm tasks ranging from a feedlot operation through forage operation and silo filling.
The unit was heavily instrumented and a large body of information collected involving cold and hot weather operating characteristics, and its general economy of operation was compared to conventional diesel fueled units that were performing similar tasks . Because of the prototype nature of the test unit, data was not published as Ford Tractor Operations was considering the potential sale of the design in this country.
The unit did go into production in Brazil and eight production prototypes are in an evaluation program by the Illinois DOT.
CURRENT SITUATION
The units we wish to import will be either the F-100 Ford pickup (upon which you already have specifications) or the F-1000, which is about 3.6 liters and somewhat comparable to the Ford "Ranger" produced in this country. It should be pointed out tha t Ford Brazil has, as of the first of July merged with Volkswagen in Brazil. They have formed a company named "Auto-Latino". The company does produce some gasoline fueled vehicles that are imported into this country under the name of the Volkswagon Fox . The manager of Volkswagen altered the executive responsibilities of several of the people with whom we had maintained liaison at Ford Brazil. It should also be pointed out that we made our original inquiries to Ford Brazil over two years ago regardin g the importation of their over the road vehicles and obtained the necessary clearances that we needed from that end but we did not follow through on our programming of a test project because of lack of funds. The following is the program that we will m anage in the testing of the three vehicles we request approval to import.
OBJECTIVES
The overall efficiency of the dedicated ethanol fueled vehicles has been continually improving -- to a point where a 3 to 4% increase in efficiency would balance out the difference in BTU values of gasoline versus ethanol. (Gasoline being approximately 110,000 BTU and ethanol being approximately 85,000 BTU). * The dedicated ethanol spark injection engine had traditionally been more fuel efficient than its gasoline counterpart.
* per U.S. Gallon
The objective of this test is three-fold:
1. To determine the efficiency of the Brazilian units and what improvements might be made by the use of fuel injection, and alternate fuel composition.
2. To determine the operational economics of the Brazilian vehicles as compared to similar gasoline fueled vehicles, using current gasoline prices and current ethanol production costs.
3. Evaluate the ambient effects (particularly cold weather) on vehicle operation (particularly engine starting) and classify them as to degrees of difficulty and outline corrective measures.
4. Evaluate alternate fuel compositions (i.e. use of detergents as a denaturant).
5. Evaluate emissions and determine the need (if any) for control procedures.
6. Evaluate the procedures for fuel handling and establishing compliance with BATF.
7. Evaluate potential customer acceptance.
8. Set a time frame (if possible) for on going research or commercial development.
TEST PROCEDURES
The units would be tested in an agricultural environment for a number of reasons, among which is to minimize the problems of fuel handling. Typical farmers today will have at least two or possibly three fuels in storage (gasoline, diesel and LPG). The arrangement would eliminate the need for service station type distribution in the area.
1. Data Loging. Each research vehicle would be equipped with a Omnidata data loger which would have a 16 channel input with a 64,000 character storage and would be capable of monotoring the performance of the vehicle for a 20 hour period which would no rmally encompass two weeks of anticipated activity. Although not all of the specific inputs have been defined those that would be monitoroed include: RPM of the crank shaft (tachometer), RPM of the output shaft from the transmission, ground speed of the vehicle, fuel consumption rate, coolant temperature, outdoor ambient, exhaust manifold temperature, intake manifold temperature, fuel temperature, real time and combustion air intake temperature (for carbonated units). These readings would be sampled an d loged every 10 - 20 seconds.
The data loger and the associated sensory equipment would be installed by the Automotive Technology Section of the Carroll branch of the Des Moines Area Community College (DEMAC). Every one or two weeks (depending on usage patterns) the data logers woul d be off loaded into a 1500 Zenith portable computer which is compatible to the data loger. This would be done at the Automotive and Agricultural Engineering Vocational Center at the Audubon Community High School in Audubon. The data from the Zenith un it would then be transfered to an IBM PC/AT at the Audubon Industrial Development Corporation for evaluation.
2. Fuel Analysis and Formulations. Preliminary arrangements have been made with a fuel alcohol plant, ADCII * at Hamburg, Iowa. This arrangement has been tentatively sanctioned by the BATF's regional office in Chicago. The hydrous ethanol fuel from t he ADCII would be sold to an ethonal fuels research company in the Audubon area which would have a permit from the BATF to do experimental research and evaluations of ethanol fuels. This would include analysis of denaturants that are inherent in the fue l prior to the cyclohexane or molecular sieve dehydration of the ethanol to the anhydrous form (which is the normal product sold by the Hamburg facility), detergents and other additives that would be incorporated in the fuel, which would then be evaluate d by the BATF to determine if these components would constitute a legal denaturant.
* or ADC-II
An analysis of performance of the U.S. fuel would be compared against the performances of the Brazilian fuel composition. To the extent possible an attempt would be made to emulate the conditions and analysis of the Brazilian produced hydrous ethanol fu el.
3. Maintenance Analysis. Periodically the units would be returned to the Automotive Technology Section of the Carroll Branch of DEMAC. Specialized personnel teaching courses in automotive technology will compare maintenance requirements with those tha t have been experienced by the Brazilian producers of the units.
Particular attention would be given to the cold weather operating conditions to determine if the lower temperatures being experienced in Iowa would have any unusual effect upon normal engine performance.
At the time the vehicles are acquired the Brazilian Manufacturer will recommend a package of spare parts that will be imported with the vehicles.
4. Emissions Testing. Equipment is being secured to enable emissions testing. This equipment was designed for conventional gasoline fueled vehicles. It is not known if this will be adequate to provide the necessary data for the EPA. It may be necessar y to ship emission samples to the University for a more detailed quantitative and qualitative analysis, particularly in regard to aldehydes. To our knowledge there is no testing equipment currently available that is designed specifically for ethanol fue led vehicles.
DESIGN MODIFICATIONS
It is anticipated that some modification for cold weather starting of these vehicles may be necessary. This is in an area in which the University of Iowa has gained considerable experience in its research work with Ford Tractor Operations, which include d a combination of block heaters, preheated intake air (which is passed over the exhaust manifold), fueled heaters, propane starting fuel plus a number of other design alternatives with which we are aware. In addition one of the units should possibly be factory equipped with a fuel injection system. It is anticipated, however, that the fuel injection may have to be a retrofit, and this eventuality has already inaugerated a search for appropriate hardware. We also have the advantage of using the Centr al Scientific Research Laboratory on alternative fuels in Ford-Dearborn for design-engineer counsel.
SELECTION OF SPECIFIC SITES FOR VEHICLE TESTING
It has been understood by all concerned that this test program is not being inaugerated for publicity purposes or to sell some sort of public relations image. The units will be tested in an environment that is strictly rural. Although it will be known i n the small community of Audubon that these tests are taking place, there is no intention to encourage public demonstration of these vehicles during the test period, other than what is unavoidable. The location of the units will be selected by a three m an committee that are all Audubon area locals who are either farmers, or have local business interests.
The units are to be used in the same pattern and to perform the same tasks as would be typical for a light weight pickup employed on the farm -- which would include hauling small loads, and farm to city to school travel. It is anticipated that the vehic les would be housed each night on the farmstead. The vehicle operators would carry their own insurance on the vehicle, although the licensing and ownership would be considered as part of the state vehicle fleet titled to the University of Iowa and would carry a state licensing, the latter to be sanctioned through the Vehicle Registration of the Motor Vehicles Division of the Iowa DOT.
TAXES.
There would be no state tax on the ethanol fuel used in the vehicles as this activity would be considered as "in the public service". As mentioned, the vehicles would be owned by the University of Iowa as test and research vehicles.
SUMMARY.
There is a large body of knowledge on the operation and economics of dedicated, ethanol fuel over the road vehicles that has never been scientifically evaluated. There are over a million of these vehicles on the road in Brazil.
This University has, for most of the decade, been involved in evaluating the technical and economic aspects of ethanol produced from corn and ethanol utilization. This University has also done much work in corn utilization in general.
The principle objectives of this project is to establish, using state-of-the-art production -- engineering design, where ethanol fueled vehicles are -- in terms of economic and technical viability. And do these vehicles represent an alternate transporta tion concept, that this country should consider as a partial solution to our over production of corn, as a means of providing some improvement in our balance of payments, and improve our national security by reducing our dependence on imported oil.
We respectfully request your approval of our undertaking.
Sincerely,