Unraveling the EPA Code
Following the Money Trail
By Jim Younkin
From EPA website: In general, it is clear that EPA’s primary objective in enforcing the statutory prohibition on “tampering” must be to assure unimpaired emission control of motor vehicles throughout their useful life. It is EPA’s policy to attempt to achieve this objective without imposing unnecessary restraints on commerce in the automotive aftermarket.
For the longest time I have been wondering why there was so much talk about and emphasis on EPA Certified Conversions. They would say that EPA Certification was the only “legal” way to convert to CNG. This refrain always seemed to come from those who actually sold or installed EPA conversions themselves. Everyone told me it was a money thing. They said”follow the money”. Let’s attempt to do that.
In the beginning the EPA wanted Cleaner Air (The Clean Air Act)1. Then they found some cities that did not meet their “standards”2. They mandated that “Covered Fleets”3 should “convert” a certain percentage4 of their vehicles to AFV (Alternative Fuel Vehicles). Having created a problem by this EPA mandate they were now in a position to offer a solution. They offered to “Certify” CNG conversions5. This would be good for the Fleets, if their conversions were EPA approved this would make them eligible for Federal and State rebates6 and Incentives. What is an “EPA” certification? The EPA tests the CNG vehicle and uses DF’s (Deterioration Factors)7 along with other tests to Guarantee that the vehicle will continue to run clean throughout its useful life.8 This “useful life” varies from 50,000 to 120,000 and up to 10 years9 whichever comes first. The EPA only Certifies conversions for new vehicles. They do not certify older vehicles10. That explains why “EPA” conversions are all newer vehicles.
As the Fleet owners collected the Federal and State rebates the Vehicle Dealerships collected their New Car fees. At the same time, the installers were able to collect inflated install fees since the Fleet owners were collecting the Federal and State rebates.
(As I researched this I had an “aha” moment. What happens to the Federal and State rebates if a customer is not told about them or if the Fleet being converted is for a Non Profit Corporation? I found out that the converter can sell the rebates to someone else.)
Now can you see the money trail? First the mandate: “Clean the Air, convert the Fleets”. Then the EPA offers a solution: We will “certify” (for a fee) CNG conversions which satisfy the requirement in the Federal and State rebates that require “EPA certified conversions”. The Fleets begin to convert with EPA Certified conversions. The new car dealers (who get to be exclusive suppliers) and EPA approved conversion shops (who will receive inflated conversion fees) are part of the money trail also. This will give the ultimate consumer of the EPA Certified Vehicle the opportunity to be “Green” and help the environment (and collect the Federal and State rebates).
You would think that this is a Win-Win for everyone involved, but is it? What about the consumer? If he wants to be “Green” he will have to come up with a lot of “Green” to pay for that privilege. He will need to have a new vehicle (remember the EPA “Certification” is only for the useful life of the vehicle) this vehicle would have to be a Ford or GM since these are the only EPA Certified conversions available. He would also have to pay the inflated conversion price (since he will then receive Federal and State rebates).
Oh and by the way there are more downsides for the consumer, their vehicle depreciates rapidly. The EPA certified conversions are mostly gas guzzling trucks and the expensive EPA conversion is only “certified” for the “useful life” of the vehicle. Also, there is no “in use” testing so who knows how long the vehicle will continue to run clean?
Now let’s try another scenario. The EPA gets out of the way. People convert not because of rebates and mandates but because it is good for the environment and it is affordable. In order for there to be widespread CNG conversions, people should be able to convert whatever they are driving. Of course, the conversions need to safe and clean running. Many states have their own Emission programs that could do the testing to verify that they remain clean running. Those who sell the conversion kits are already having classes to certify CNG installation and tank safety.
In the US the conversion of vehicles to Natural Gas has basically come to a stand still. A lot of the older CNG vehicles are being taken out of service and new conversions are not keeping up. The drum beat of EPA only has scared many would be CNG customers away. If the true intent of the EPA was to “assure unimpaired emission control of motor vehicles …without imposing unnecessary restraints on commerce in the automotive aftermarket” they need to take a different approach, one that will show the people that the government can be a help and not an obstacle. There are so many positives to CNG conversion that producers and consumers alike are ready and willing to take advantage of them if they are free to do so.
10) http://www.ngvc.org/pdfs/FAQs_Converting_to_NGVs.pdf (page 3 half way down: Retrofitting preMY2003 Vehicles)
About Jim: Jim Younkin is a mechanic with more than thirty years experience in automotive repair. His passions include car racing, mountain climbing, ice climbing, and CNG conversions. He enjoys sharing his passions and connecting with other of like mind. See more about Jim at http://www.younkincng.com
email: firstname.lastname@example.org or 801-427-2284