Who’s Afraid of the Big Bad (EPA) Wolf
After several meetings with the EPA along with my own research and numerous discussions with others in the CNG (Compressed Natural Gas) Conversion Industry, I have come to the conclusion that the EPA is not the Big Bad Wolf some people have made them out to be.
Opinions are as the saying goes “a dime a dozen”. Like most things and especially a new technology or a new way of doing things there are always many opinions. I have learned to take all opinions with a “grain of salt”; all opinions except my own, of course; it holds a little more weight with me.
Over the years I have personally owned over 50 vehicles, from a 21 Window VW Micro Bus to a Turbo Charged 5-cylinder Audi 5000. In all of that time I have never worried about whether or not any of these vehicles were “EPA Certified”. I have had to do emission tests and some safety inspections but no EPA anything. In my more than 30 years of automotive repair I have worked on thousands of vehicles in 3 different States doing anything from tune-ups to complete vehicle restorations. It wasn’t until last year (2008) that I had even heard of CNG and CNG conversions. As I researched this topic I became concerned about what people were telling me about the EPA hoops a person must jump through in order to have a supposed “legal” CNG Conversion and what EPA Certification really is.
As I searched forums and the internet I started hearing blanket statements like “All CNG Conversions must be EPA Approved” or “non-EPA CNG Conversions were not legal to drive on the streets”, and “the EPA will fine you $1000’s of dollars if you are caught converting or owning a ‘NON-EPA’ CNG Vehicle”. Over the past few years I know that this type of rhetoric has kept hundreds if not thousand’s of individuals from converting their vehicles to CNG because of fear of the EPA. An incongruity began to form in my mind. Why was it that CNG vehicles and CNG Conversions had come under so much more scrutiny than any other group of vehicles? I began to question the sources of these EPA Certification statements. Where were these statements coming from? Was it anyone who actually had any authority over me or were they just self appointed bullies and safety monitors? As I dug deeper a pattern arose, those raising the “EPA only” banner usually sold or developed “EPA Certified” CNG Vehicles or Systems. The EPA when asked about the EPA Certification of CNG Vehicles was unusually silent or ambiguous on the subject. Since I have a background in the legal field I noticed that there was something about the broad blanket statements about “EPA Certification” that didn’t seem right.
Over the next year I researched the EPA Code and website searching for the one rule stating that “All CNG Conversions must be EPA Certified”. It was nowhere to be found. It just didn’t exist.
As these false statements about the requirement for “EPA Certification” began to spread people began looking for EPA Approved Installation Stations and EPA Approved Technicians. There were none to be found. They just don’t exist. As I learned later, after numerous meetings with the EPA, the main purpose EPA Vehicle testing division is to Certify OEM (Original Equipment Manufacture) vehicles to meet Emission Standards for “the useful life (100,000 miles or 10 years)” of the vehicle.
In the late 90’s due to inefficient CNG conversion systems the EPA was tasked with “certifying” CNG Conversions. Since their testing procedures were for NEW OEM Vehicles, they used a similar standard for the CNG Conversions. The EPA can’t and never will certify anything other than new vehicles due to deterioration factors and the vehicles useful life.
What exactly is EPA Certification? It is a series of tests that show that a vehicle will continue to run clean for the specified time. It is not a guarantee or warrantee, it is just certificate given after a series of tests have been completed. While we are talking about EPA Certified CNG Conversions lets take note that any EPA certification expires beyond a specified time (the useful life of the vehicle). Just like any other vehicle, all CNG Vehicles need to be re-tuned, maintained and re-tested from time to time.
Aftermarket CNG System manufacturers go through stringent testing procedures since they build their systems for various vehicles. These companies use inputs from the vehicle’s own sensors and electronic control units. Most of the new generation of CNG kits have independent MAP (manifold absolute pressure) sensors, coolant temp sensors, natural gas pressure and temperature sensors. I would venture to say that these new generation systems can outperform most “certified” CNG Systems on the road today. In fact, if a person was to compare the components of a “Certified” and a “Non-certified” conversion system it would be hard to tell the difference.
- No CNG Conversion is required to have EPA Approval. Individual companies can choose to have their CNG System certified by the EPA.
- The EPA can only certify new vehicles (CNG or other) for the useful life of that vehicle.
- All EPA Certifications expire after the useful life of that vehicle.
So are you still afraid of the Big Bad EPA Wolf? I’m not, and hopefully you aren’t either. In a recent meeting with Marty R. from the EPA in the question and answer portion I asked why the EPA Certification sticker was not removed after the vehicles “useful life”. Marty responded that indeed no one recertified their vehicles. When I asked how many “Illegal CNG Conversions” had the EPA’s enforcement division prosecuted and fined the answer was “None, not a one”.
There is room for both EPA Certified and Non Certified conversions in this industry. It is not necessary to intimidate people with threats and lies. As we look to the future of the CNG Industry we all need to check our facts. Whether a manufacturer chooses to go through the process of EPA certification or decides to have their CNG component certified for safety through an independent testing lab and then train their installers to insure a safe and clean installation should be their own decision. We all want an alternative to gasoline that is safe and clean but we need to be proactive in verifying facts about what exactly is required and also in accomplishing verification of safe clean installations.
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