Unraveling the EPA Code Part II
A Meeting with Marty
By Jim Younkin
In the last few days I have met movers and shakers in the CNG industry, they are not bureaucrats, investors or salesmen. They are men with vision and principle. JY
It was almost surreal. I had been invited to participate in an EPA and UDAQ (Utah Department of Air Quality) Panel Discussion about CNG (Compressed Natural Gas) conversions in Utah, I was actually on the Panel, and I was finally at the round table. I made it a point to be there early. I was the first participant to arrive. Marty Reineman was walking around getting used to his surroundings. Marty is a little younger than me and looked to me like a thinker. As I was watching everyone Diane Neilson’s assistant Cheralyn came into the room, she had the some refreshments in her trunk so I offered to help. As we came back into the room others began to show up. As I looked around I noticed there were people I already knew and others I had seen before but never met.
I introduced myself to Marty and found out that I would be seated next to him during the discussion. Others that I met for the first time at the meeting were the owners of Go Natural, Scott Brandeberry from Lancer motors and Craig Wright with CNG Interstate (formally CNG Outfitters). I had been looking forward to meeting Craig. For over a year his CNG website had been at the top when searching for CNG information on the internet. Others that I already knew at the roundtable were Mike Millet, the chairman of CCATS (Certified CNG Automotive Technicians for Safety). I had met Mike in January; we had both been instrumental in forming CCATS as a direct response to the UHP ruling that all CNG conversion must be EPA Certified in order to pass a Utah State Safety Inspection. (This rule was later overturned) Some of my associates who were also on the panel were Tai Robinson with Intergalactic Hydrogen, Randy Leiber and Aaron Stuart with The CNG Store, Robin Erickson of Clean Cities Coalition Utah, Blair Barton of Ashton Motors and Dana Curdiff with Utah County Emissions.
Dianne Nielson welcomed us and gave everyone at the round table a chance to introduce themselves. The group was made up of a few politicians and bureaucrats but for the most part it was CNG converters and CNG business owners. It was a good mix of the EPA hardliners and Independent Converters like me. We ranged from John Mitton to Tia Robinson. There were about 25 participants at the round table.
The first part of the meeting was taken up by Marty Reineman and his assistant Amy Bunker as they explained their proposed revision of the EPA Code covering CNG conversion certifications. Marty went through a slide presentation he had given in Florida earlier in the year, they were general questions about alternative fuel conversions. Among other things he stated that not all AFV (alternative fuel vehicles) will run clean, successful AFV programs in other countries are not necessarily all “clean and safe” and State IM testing alone may not insure that an AFV is low-emitting. He went on to explain that some of the EPA’s concerns about the current process include, the EPA’s “test group” certification does not always fit the converters business model, current EPA Certification requirements may drive some conversion activity underground and the current EPA Certification processes were never designed for higher mileage, older vehicles (beyond useful life). Marty then went on to explain their “Guidance Letter” concerning AFV’s signed 6-20-09. Some of the highlights of the guidance letter were
(1) New allowances for combining OEM test groups
(2) How to access the EPA Verify Data Entry Program
(3) Instructions for finding EPA documents, e.g. certificates and OEM applications for certification on the internet
(4) Information on converting vehicles outside their useful life
To me the next slide “Current Status on Outside Useful Life (OUL) Conversions was most important to moving CNG conversions forward.
Here are the bullet points.
(1) The OUL program is in transition
(2) At present, certification is the only assurance that protects fuel converters from a tampering violation but certification may not be appropriate for OUL (vehicles)
(3) There is a policy gap for OUL Converters
(4) OUL Converters may reduce risk of a tampering charge by documenting (through reliable testing) that the conversion did not increase emissions
Marty went on to say that these new regulations (to be finalized 12/2009) will clarify and streamline the process, ensure fuel conversions are clean, reduce current reporting requirements and maintain EPA oversight and enforcement authority.
In this new CNG Conversion regulation proposal they divided vehicles to be converted into 3 groups:
1) New OEM Vehicles
2) Older vehicles still within their useful life (called intermediate) more than 2 years old
3) OUL vehicles (all vehicles not in the first two groups)
In the intermediate group the testing and reporting will be less stringent and costly. This translates to savings for the EPA and the converter. This group will have web based notification in lieu of certificates also the applicability groups will be broader than new vehicles.
The OUL conversions will need to be 3-gas tested after the conversion to ensure emission standards. This documentation should be given to the car owner and kept with the vehicle. At some point the EPA may require the test results to be supplied upon request.
After Marty’s and Amy’s presentation we took a break. After the break we had a Question/Answer period. There were some questions but mostly people were expressing their frustrations. I personally asked if the current EPA certifications expired after the vehicle’s “useful life”? The answer from Marty was”yes, they do expire”.
As Marty was talking and explaining, we could all sense his concern and frustration over the current EPA Certification Regulations. His job is to insure that all vehicles continue to run clean, but he is not an enforcer, he is an engineer. As the CNG conversions continue to roll out, as an industry, we all need to work together and help Marty and make sure all CNG Conversions are Emission compliant. The EPA does not have the manpower to monitor every conversion. Through training and public meetings we can all help the EPA and move the CNG industry forward together.
I believe that this meeting was groundbreaking. I feel that Dianne’s desire to move CNG conversions forward will telegraph to other parts of the United States. Up until now all of these meetings were with big business and EPA hardliner companies. In this meeting there were independent converters who had over the last year and a half converted more vehicles to CNG than had been in the whole US during the previous 5 years. This was accomplished through entrepreneurship and training. Utah is poised to be a world leader in CNG Conversions, we just need to step up and take our place in history.
US EPA Office of Transportation and Air Quality Compliance and Innovation Strategies Division
Department of Environmental Quality-Air Division
Dianne R. Nielson, Ph.D.
State of Utah
Dianne Nielsons assistant,
801 427 2284
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: email@example.com or 801-427-2284