Comments on New Proposed AFV EPA Regulations

From new EPA regulations for AFV’s, I will add my comments in bold,

EPA has long recognized vehicle alteration for the purpose of clean
alternative fuel conversion as a special case because while improperly designed or installed conversions can increase emissions, properly engineered conversions can reduce, or at least not increase, emissions.

(It is telling that there is no mention of any other modification to any other vehicle such as speed equipment etc. the AFV (alternative fuel vehicle) industry seems to be unfairly singled out when it comes to “tampering” enforcement)

Furthermore use of alternative fuels can contribute to achieving other goals such as diversifying the fuel supply through use of domestic energy sources. Therefore, EPA has established policies through which conversion manufacturers can demonstrate that the conversion does not compromise emissions compliance.

(This statement is misleading, EPA certification is for new vehicles only, thus the statement “EPA has established policies through which conversion manufacturers can demonstrate that the conversion does not compromise emissions compliance” is generally misunderstood.)

It has proven challenging however to design an appropriate demonstration that ensures long-term compliance while not imposing overly burdensome testing and administrative requirements, especially for the small businesses that largely comprise the conversion industry.

(It has been not only burdensome it has never applied to all vehicles)

The existing compliance demonstration required of conversion manufacturers for a regulatory exemption from tampering involves obtaining a certificate of conformity. (This is an demonstration to receive an exemption not a requirement) This means that converters must (for the purpose of the demonstration) follow essentially the same rigorous certification process that EPA requires of original equipment manufacturers (OEMs). The certification requirements currently in place for all converters give EPA sufficient oversight from an emissions perspective but implementation can be problematic in certain conversion situations. The current regulations were finalized on September 21, 1994 (59 FR 48472) and are located in 40 CFR part 85, subpart F (‘‘the subpart F regulations’’). In the 15
years since these regulations were promulgated, experience has shown that the OEM-like certification program for aftermarket conversions is not an optimal mechanism for ensuring compliance with applicable emission standards, particularly for older vehicles and engines.

(It is not only “non an optiomal mechanism” it never has applied to older vehicles)

EPA has encountered several practical difficulties when using pre-production certification test procedures on older vehicles and engines. Similarly, certain aspects of the certification procedure are not well suited to aftermarket manufacturers. Some small conversion manufacturers, furthermore, have expressed concerns that the complexity of the certification process presents a barrier to entry into the alternative fuel conversions market. For all these reasons, EPA believes it is reasonable to modify the current certification requirement for clean alternative fuel converters seeking exemption from the tampering prohibition. The new program would expand compliance options to include less burdensome demonstration requirements that would nonetheless sustain EPA’s oversight and longstanding commitment to the environmental integrity of clean alternative fuel conversions.

(It is curious that the EPA talks as if the older vehicles have been included in the EPA certification program all along, they never have been)

Today, EPA is proposing a new approach that streamlines the regulatory process and introduces new flexibilities for conversion manufacturers, while ensuring that converted vehicles and engines retain acceptable levels of emission control.
The revised program would also address the uncertainty some converters may experience in determining whether a conversion constitutes tampering that could result in liability. EPA proposes to amend the regulatory procedures in 40 CFR part 85, subpart F and part 86 to remain consistent with the CAA yet reflect the concept that it is appropriate to treat conversion requirements differently based on vehicle or engine age. The new program would facilitate age-appropriate testing and compliance procedures by placing alternative fuel conversions into one of three categories:

(1) Conversions of vehicles or engines that are ‘‘new and relatively-new’’ (hereafter referred to as ‘‘new’’ solely for the purpose of this preamble),4 (2)conversions of vehicles or engines that are no longer new (i.e., no longer ‘‘new and relatively-new’’) but that still fall within EPA’s definition of full useful life, ‘‘intermediate age vehicles’’, and (3) conversions of vehicles or engines that are outside EPA’s definition of useful life.

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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This entry was posted in Automotive, CNG conversions, EPA, Government, Green, Palin, Regulation, Uncategorized and tagged . Bookmark the permalink.

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