How the EPA helps you to go Green by making Green (Older Vehicles need no Certification remix)

How the EPA helps you to go Green by making Green
(Older Vehicles need no Certification remix)

For over a year I have been researching CNG Automotive Conversions and their relationship with the EPA. Over that period of time I heard “all CNG Conversions needed to be EPA Certified” or they were illegal. At that point I started thinking that an EPA inspector was around every corner and that at any moment one would pop out from under a rock holding a badge and shout “you are under arrest”. Then I got real, if the EPA was so concerned with “tampering” why are they not busting all the Import tuners and other gross polluters? Well the simple fact is that the EPA has bigger fish to fry like American Honda Motor Company see below:

“American Honda Motor Company Clean Air Act Settlement”
American Honda Motor Co., Inc. (“Honda”) will spend $267 million to settle allegations that it violated the Clean Air Act by selling vehicles with disabled emission control diagnostic systems
http://www.epa.gov/compliance/resources/cases/civil/caa/amerhonda.html

Anyway back to my discoveries, this statement of “all CNG Conversions needed to be EPA Certified” or they were illegal, is false on its face, the EPA cannot and will not certify older vehicles. As stated below by Martin Reineman of the EPA :

From: Reineman.Martin@epamail.epa.gov
Sent: Thursday, April 02, 2009 1:43 PM

“NGVA is stating (see below jy)that our certification division cannot issue a certificate outside of a vehicle’s full useful life. That is correct. …. EPA has not published explicit guidelines….”

Yes the EPA can certify CNG Conversions for the useful life of a vehicle if the vehicles are new and you pay them enough Green(they also receive more Green back on every conversion sold by the converter). But to say every conversion needs certification is ludicrous. As you will see below the NGVA through correspondece with the EPA stated:
“The U.S. EPA has indicated to NGVAmerica that its certification procedures really only are appropriate for vehicles which are within their useful life, which is roughly defined as 10 years or 120,000 miles”,
As you can see they used the phrase “are appropriate” for vehicles which are within their useful life, and not “are required”.

The EPA is authorized to Certify New OEM Vehicles for their “Useful Life”, the EPA can also Certify CNG conversions for their “Useful Life”. By doing this they collect more Green by helping you to go Green. This is the extent of their authorization.

While we are on the subject of Certification what is the deal with Diesel kits? Do they need to be certified? According to the EPA’s definition of AFV’s below, Diesels need to be a 85% or more mix of Natural Gas to be classified as an AFV.

http://www.epa.gov/EPA-GENERAL/1994/November/Day-18/pr-111.html

Labeling Requirements for Alternative Fuels and Alternative Fueled Vehicles

\3\ “Alternative fuels” are defined as:
“[M]ethanol, denatured ethanol, and other alcohols; mixtures
containing 85 percent or more (or such other percentage, but not less than 70 percent, as determined by the Secretary [of Energy], by rule, to provide for requirements relating to cold start, safety, or vehicle functions) by volume of methanol, denatured ethanol, and other alcohols with gasoline or other fuels; natural gas; liquefied petroleum gas; hydrogen; coal-derived liquid fuels; fuels (other than alcohol) derived from biological materials; electricity
(including electricity from solar energy); and any other fuel the
Secretary determines, by rule, is substantially not petroleum and
would yield substantial energy security benefits and substantial
environmental benefits[.]”

So just to wrap up, the EPA will certify your conversion system if your vehicle is new and you have enough Green, also EPA Certification is “appropriate” for those with enough Green but not “required”. Also Diesel/CNG assist conversions are not AFV’s. EPA Can not certify Diesel/CNG assist conversions. As I stated above my opinion is that the EPA Certifies New OEM vehicles and they Certify CNG Conversions for those with enough Green but that’s it. Read below for more information….

http://www.ngvc.org/pdfs/FAQs_Converting_to_NGVs.pdf

In FAQ’s Under the Heading
Federal Emissions Certification Processes and the Impact on “Conversion” System Availability NGV America stated:

In 1994, partially in response to growing interest by the major OEMs, EPA finalized emission certification requirements for gaseous fueled engines (including CNG vehicles) – the regulations became mandatory for OEMs and new vehicles effective MY 1997. EPA’s final rule also included provisions allowing aftermarket manufacturers the option of certifying their systems using the procedures for new vehicles but compliance was voluntary. Thus, EPA’s final rule indicated that aftermarket conversion manufacturers could continue to comply with Memorandum 1A’s “reasonable basis” requirement instead of going through certification. In late 1997, EPA issued an addendum to Memorandum 1A indicating that it intended to impose more stringent requirements on aftermarket conversions systems. These more stringent procedures became known as “Memorandum 1A – Option 3.” (Option 1 & 2 required certification to EPA or California regulations). The idea behind Option 3 was to increase testing requirement to ensure that no emission degradation was occurring and to transition the aftermarket industry to a point where all conversion systems had to undergo certification, just like new motor vehicles. The 1997 Addendum initially established a target date of Dec. 31, 1998 as the phase-out date for non-certified systems. EPA, however, subsequently issued several memorandums and guidance letter extending this date until April 1, 2002. As of April 1, 2002, Option 3 is no longer an acceptable means of demonstrating compliance with the anti-tampering provisions for most vehicles. Some exceptions exist with respect to certain older vehicles or high mileage vehicles, which are beyond their useful life (10 – 11 years old or 100,000 – 120,000 miles). However, the general rule is that certification to EPA or CARB regulations is now required for most newer vehicles. EPA can levy substantial fines for violations of the federal anti-tampering provisions. (causing a vehicle to exceed its OEM Emission Standards jy)

Thus, anyone who manufacturers, installs or sells a non-certified system runs the risk of being found guilty of tampering (causing a vehicle to exceed its OEM Emission Standards jy) and could face serous fines. The EPA certification requirements apply to all alternative fuel vehicle retrofit systems including natural gas, propane, methanol, ethanol and/or hydrogen retrofit systems. (See below for vehicles that are pre-2003MY and/or beyond their “useful life”).

Retrofitting Pre-MY2003 Vehicles and Vehicles Beyond Their Useful Life As noted above, most retrofit system SVMs have no interest in – and do not maintain active certifications for – vehicles with high (or even medium) mileage due to technical complications caused by long-term operation on gasoline. Despite this, some people may still pursue conversion of their older vehicles to natural gas. The following discussion offers general guidance concerning EPA emissions laws and regulations for older vehicles:

The U.S. EPA has indicated to NGVAmerica that its certification procedures really only are appropriate for vehicles which are within their useful life, which is roughly defined as 10 years or 120,000 miles, although the exact definition of useful life has changed over time. EPA guidance addresses this point but is less than clear. We have been told that future guidance will be far more extensive on this issue. For any pre-MY1999 vehicles or any MY vehicle with significant mileage (e.g. 100,000 for Tier 1, or 120,000 for Tier 2), current EPA guidance appears to indicate that retrofit system certification is not required although the general guidance of “Memorandum 1A” (i.e., you must have a reasonable basis to believe that the system will not increase the emission) still applies. For MY1999 to MY2003 vehicles that have not yet reached 120,000, EPA guidelines indicate that certification of the retrofit system IS required, which makes this option economically unfeasible. See EPA’s web site for further clarification on this issue including guidance on converting vehicles older than 10 years or beyond 100,000 – 120,000 miles.

Today there a variety of non-certified systems that are sold on the Internet and/or offered by automotive shops. Consumers purchasing a non-certified system should be extremely cautious and obtain information from the person installing such systems to ensure that the equipment they use and the installation are legal and safe. As noted above, some non-certified systems can be legally sold if the vehicle is beyond its useful life.

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: younkin@gmail.com or 801-427-2284

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