Who is afraid of the Big Bad EPA Wolf II
(taking on the tampering question)
Like any other industry the Compressed Natural Gas Industry has evolved over time. Any country that has a significant number of CNG vehicles has, as a nation, openly promoted their development through government subsidies (handouts), informational programs and help with developing which CNG system brand is suited for any given group of vehicles and help in developing a CNG refilling station infrastructure.
It is not clear when the EPA got involved with CNG conversions or even why they did. It seemed to have stemed from a few complaints of OEM’s (original equipment manufacture) feeling put upon since they were required pay thousands of dollars to certify their new vehicles and the retrofit converters didn’t have to pay.
Today we have some CNG systems with EPA certification which cost $5000 to $10,000 more per vehicle than a comparable aftermarket non-cert system. Most government handouts in the form or rebates or tax credits for a CNG conversion are now linked to EPA certification. So you have the OEM’s and EPA Hardliner converters trying to get their way (lets spread the EPA certification pain) by spreading their myth that all CNG conversions need certification. This myth that all vehicles must be re-certified if the vehicle is modified in any way is a hurtful lie. All OEM’s must certify their vehicles, EPA Hardliners (those converters who install EPA certified systems) choose to certify, the EPA Hardliners do so to be able to receive government handouts, the OEM’s have no choice.
Unfortunately most retrofit CNG converters are small. For a time though in the 90’s some aftermarket CNG conversion companies were willing to jump through the EPA certification hoops expecting that the handouts would make up the difference. Nationwide companies with fleets of vehicles, (who were being mandated by the CAA (Clean Air Act) to clean their emissions) looked to CNG, it seem like a good fit and for a while and many OEM and retro-fitters were producing CNG vehicles EPA certified and non-certified. As the handouts dried up or the CAA mandates failed CNG vehicle production stopped (there were actually a few years where CNG vehicle production in the US was negative due to earlier CNG vehicles failing or going out of service).
As an overview CNG conversion will only grow in a positive fertile environment, if it is forced through government mandates as soon as the handouts dry up people loose interest. In 2008 as the price of gasoline skyrocketed many vehicle owners nationwide looked to Natural Gas as an alternative to high gasoline. Even though many wanted to convert to CNG only those areas who had the CNG fueling infrastructure already in place were able to flourish. Potential CNG conversions shops began sourcing CNG systems from all over the world, ultimately 1000’s of vehicles were converted nationwide. The most significant increase was in the state of Utah with its abundance of Natural Gas and filling infrastructure. Many factions within the state began to take it upon themselves to monitor CNG system installers and CNG product suppliers.
Since specific information about the CNG industry concerning installation and regulation was unavailable the vacuum was fill with assumptions and opinions. Most of these assumptions and opinions turned out to be just that. Many of these assumptions centered around the requirements and legalities surrounding CNG conversions themselves.
I will try to list a few statements and questions pertaining to CNG Conversions. Below are a few of my opinions.
- A vehicle owner may be subject to EPA CAA (clean air act) SIP’s (state implementation plan) which may require an Emission test if they live in a air quality “non-attainment” area.
- OEM vehicle manufacturers who sell new vehicles need EPA certification to insure that their vehicle will run clean for the useful life of the vehicle.
- A vehicle owner must register their cars in the respective states they live in, their may be safety or emission inspections depending on the state and location.
- Because of the CAA (clean air act) the EPA has been given the charge to set respective air standards, new vehicles need to meet these standards.
- Once a person purchases a vehicle they may modify it as they like, they also accept liability.
- Anyone working on a vehicle whether it is a mechanic or owner must take the responsibility of keeping that vehicle safe.
- There are many safety standards in place for automotive component manufacturers this includes all CNG conversion components.
- There is no nationwide certification/training/organization for the Automotive Industry let alone the Natural Gas Industry, it are self regulated.
- The EPA has given the power of regulation of vehicles for “in-use testing” to each state through SIP (State Implementation Plan) to monitor vehicles that are in Air Quality “non-attainment” areas, there is no monitoring in other areas.The EPA has given the power of regulation of vehicles for “in-use testing” to each state through SIP (State Implementation Plan) to monitor vehicles that are in Air Quality “non-attainment” areas, there is no monitoring in other areas.
- The myth that the EPA will fine or prosecute someone for“tampering”is just that a myth it has never happened.
- The EPA operates through“endangerment”findings, this gives them their authority to regulate vehicles only through a states SIP.
- Where there is no“endangerment”there is no regulation state or federal.There are no EPA police behind the bush’s.
- Even though in theory an individual vehicle may pollute in the end it is not against the law. States with SIP’s can refuse a non-compliant vehicle their license but there is no fine, that individual may register in an area that has no emission testing.
- In the end as soon as a vehicle is driven off the showroom floor they begin their road towards “tampering”in is strictest sense, the engine is burning through its “useful life”.
- Tampering is an ambiguous term used my many EPA Hardliners to scare vehicle owners and converters, tampering has to be proven, then there has to be a punishment that will be enforced. Ultimately tampering and its so called punishment is just a figment of some self serving persons imagination.
Lets just look at how ludicrous it is to think that the EPA while enforcing their CAA worries about an individual modifying their vehicle.
As I have explained it is up to each individual to maintain their vehicles, we are a free country. In the future I hope that CNG Conversions in the United States will move forward through Independent conversion shops using modern proven CNG systems. In the end Big Brother needs to stay out of they way and let American ingenuity and entrepreneurship take over.
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