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Thread: Legal Toyota CNG conversion

  1. #1

    Default Legal Toyota CNG conversion

    I want to convert a Toyota pickup to run on CNG. While I used to be a Peterbilt mechanic, I think that safety and reliability dictate that I leave any conversion to a shop that does these regularly. I am a proponent of following the law in every way and have no interest in an illegal system.

    My question is this: Let's say I go to a shop and have them add a system such as a Prins or a Tomasetto along with a shiny new Lincoln tank with a 20-year life and approved piping to something like a 2008 Toyota Tundra truck that has something like 30,000 miles. Let's say that in choosing a shop, I exercise good judgment, look for experience, and avoid like the plague anyone who even remotely suggests adding an "emulator" or otherwise doing anything other than leaving intact my existing OBD II computer and monitoring devices. I would register the truck in Utah and drive it there with the possible exception of a few vacations. Of course I would have any needed safety inspections and emission tests at the intervals required by the state in which I register the truck. I have no interest in living in California and foresee no reason to register a truck there.

    Is this breaking the law? My understanding of the law is that with either criminal prosecution or civil penalties, something is legal unless there is a statute, code, or regulation that makes it illegal. Things can't be illegal "just because." For that reason, if this is illegal, I would be appreciative of a response such as, "This is illegal because [insert statute, code, or regulation cite here] says [insert what it says] and your proposed conversion would [insert how it violates the language of whatever statute, code, or regulation it would violate]."

    I'm grateful for any thoughts that will let me convert a truck and start buying fuel from people who don't shoot at Americans; I will also be grateful for thoughts that keep me from running afoul of the law.

  2. #2
    Join Date
    Oct 2007
    Mountain Green, Utah

    Default Re: Legal Toyota CNG conversion


    I applaud you for your diligence in abiding by the law (even if you don't know or fully understand the law). Don't worry, you'll be surprised but most of us don't understand the law either (thanks to the lawyers who don't use simple English). I think the answer that you are searching for is here:

    You will want to take a look at post # 22. There are three pdf files that contain the new EPA regulations regarding CNG conversions. If my understanding is correct, your 2008 Toyota Tundra would fall under Teir 2 and not require a certfication, but would need to pass the gas analyzer test.
    Mountain Green, Utah
    2003 CNG Cavalier
    2003 CNG Silverado 2500HD

  3. #3

    Default Re: Legal Toyota CNG conversion

    The new EPA 'clarification' doesn't really help you. It says you can install a conversion package on an older car if the system had already demonstrated compliance. I don't think any conversions from Tomasetto or Prins have done this. For a Tier 2 or 3 conversion to be available the certificate holder has to notify EPA that their package is available for older cars and according to the EPA website no one has done this yet. The EPA is still asserting a virtual stranglehold on CNG conversions, limited to those by NaturalDrive, BAF, Baytech, Impco, Go Natural, etc. If you want a EPA-approved conversion with no hassles, you'll have to pick one of these models and have it done at one of these shops.
    02 GX
    01 GX
    03 Crown Vic
    06 GX
    Home Fueler

  4. #4
    Join Date
    Oct 2008
    Springville Utah
    Blog Entries

    Default Re: Legal Toyota CNG conversion

    Free, are you saying that once a converter demonstrates that say a Technocarb is compliant for the intermediate and the outside useful life group that they can put these systems on any other vehicle? Four years ago Technocarb had numerous EPA Certs but got tired of jumping through all of the EPA hoops and suspended them. I was also under the impression that a person could get a "waver?" on a case by case basis, this would be an alternative to be able to drive a vehicle "legally" while proving it and working on the "compliance" issue.
    Jim Younkin

  5. #5

    Default Re: Legal Toyota CNG conversion

    I assume EPA would only accept previously certified kits for the engine groups they were originally certified for. Sounds to me like Technocarb would have to jump through the hoop of notifying EPA that they want to sell kits for tier 2 and 3 use. They have already demonstrated compliance, so it would just be a matter of notifying EPA. Don't know anything about a 'waiver' process or how long the waiver would last.
    02 GX
    01 GX
    03 Crown Vic
    06 GX
    Home Fueler

  6. #6
    Join Date
    Dec 2007
    Left Coast

    Default Re: Legal Toyota CNG conversion

    Will Technocarb still sell the conversion system for a specific year and model without warranty as to legality to Technocarb dealers ? If so, my understanding the converter would then go thru the abreviated certification and would become the SVM themselves.

  7. #7
    Join Date
    Oct 2008
    Springville Utah
    Blog Entries

    Default Re: Legal Toyota CNG conversion

    Here is a letter I got from Amy Bunker awhile ago, it helps to understand the intermediate group and outside useful life groups, Jim

    Hi Jim,

    Thank you for your email. The EPA alternative fuel conversion webpage
    has quite a bit of information that you may find useful.

    I think that many of the questions you have posed are in response to
    text from the final rule fact sheet and proposed rule fact sheet.
    Please keep in mind that these fact sheets are only intended to provide
    a broad overview of the rule and do not cover compliance details found
    in the regulations. Also, please be aware that the final rule supersedes
    the proposal so to the extent information differs between the proposed
    and final rule fact sheets, information presented in the final rule
    prevails. For details about the final rule, please refer to the final
    rule preamble and regulations.

    The April 27th webinar materials are also posted on the website.
    Among other information this presentation contains links to the
    regulations in the Code of Federal Regulations (CFR).

    We appreciate your interest in simplifying EPA regulations for a general
    audience as well as your efforts to disseminate information about the
    new conversions regulations. Please note that while summary information
    can be helpful, it is essential for conversion manufacturers to read and
    understand the regulations. Attempts to abridge the regulatory language
    may convey incomplete or inaccurate information.

    The responses below generally include citations to regulations and other
    documents. The citations are shown in italics. Let me know if you have
    trouble with any of the links. If you have further questions, please
    contact us again.

    Thank you,

    (what exactly is the useful life of the vehicles?

    The full useful life refers to the period of time or amount of activity
    for which the original manufacturer must show that a vehicle or engine
    will continue to meet emission standards. The useful life period is
    specific to each set of emission standards and each vehicle or engine
    category, and useful life periods are updated periodically in EPA
    regulations. Thus, there is not an answer to your question that applies
    to all vehicles. The useful life of a vehicle or engine depends on the
    model year in which it was originally certified and whether the original
    manufacturer chose to participate in any available optional programs.

    “The CAA directs EPA to promulgate emission standards that are
    applicable for a vehicle or engine's “useful life” and to
    establish the useful life period through regulation. (CAA section
    202).The full useful life varies among pollutant standards and
    among vehicle or engine categories. (Regulations may also include
    optional standards such as in 40 CFR 86.1805-04(b) and (e).) For
    example, recent model year light-duty vehicles (cars and small
    trucks) generally have a useful life of 10 years or 120,000 miles,
    whichever comes first; recent model year heavy-duty chassis
    certified vehicles and medium-duty passenger vehicles generally
    have a useful life of 11 years or 120,000 miles, whichever comes
    first; and current Otto-cycle heavy-duty engines have a useful
    life of 110,000 miles or 10 years, whichever first occurs. For
    current diesel heavy-duty engines (also referred to as
    ``compression-ignition'' or ``diesel cycle''), there are different
    useful life definitions based on gross vehicle weight, pollutant
    being controlled, and test procedure, ranging from 10 years or
    110,000 miles, whichever first occurs, to 10 years or 435,000
    miles or 22,000 hours of engine operation, whichever first
    occurs.” 76
    FR page 19832-19833

    (who is considered a manufacturer, the CNG system supplier, the
    CNG system installer or the converted vehicle owner?)

    “Clean alternative fuel conversion manufacturer (or “conversion
    manufacturer” or “converter”) means any person that manufactures,
    assembles, sells, imports, or installs a motor vehicle/engine fuel
    conversion for the purpose of use of a clean alternative fuel.”
    40 CFR 85.502

    “The broad definition (… of conversion manufacturer …) is
    intentional because any of the listed entities could meet the
    applicable requirements for a conversion system and achieve
    eligibility for the tampering exemption. However, for any given
    test group or engine family, EPA expects that one entity will
    function as the “manufacturer” for purposes of qualifying for an
    exemption. Should none of the listed entities follow the subpart F
    regulations, then all could potentially be liable for a tampering
    violation. EPA’s definition of converter ensures that all listed
    entities take responsibility for the compliance requirements and
    remain potentially liable if the requirements of the rule are not
    met.” http://www page 10

    Manufacturers would submit a technical description (what exactly
    does this mean? Is there any criteria or example given?)

    The text directly below is an excerpt from the regulations in 40 CFR
    85.520. In addition, the final rule contains information about the
    outside useful life program on pages
    19850-19851. The April 27th webinar materials may also provide you with
    helpful information.

    85.520 (b)(3) You must use good engineering judgment to specify,
    use, and assemble fuel system components and other hardware and
    software that are properly designed and matched for the
    vehicles/engines in which they will be installed. Good engineering
    judgment also dictates that any testing or data used to satisfy
    demonstration requirements be generated at a quality laboratory
    that follows good laboratory practices and that is capable of
    performing official EPA emission tests.

    85.520 (b)(6)(i) You must describe how your conversion system
    complies with the good engineering judgment criteria in 85.520
    (b)(3) and/or other requirements under this subpart or other
    applicable subparts such that the conversion system qualifies as a
    clean alternative fuel conversion. The submission must provide a
    level of technical detail sufficient for EPA to confirm the
    conversion system's ability to maintain or improve on emission
    levels in a worst case vehicle/engine. The submission of technical
    information must include a complete characterization of exhaust
    and evaporative emissions control strategies, the fuel delivery
    system, durability, and specifications related to OBD system f
    unctionality. You must present detailed information to confirm the
    durability of all relevant new and existing components and to
    explain why the conversion system will not harm the emission
    control system or degrade the emissions. EPA may ask you to supply
    additional information, including test data, to support the claim
    that the conversion system does not increase emissions and
    involves good engineering judgment that is being applied for
    purposes of conversion to a clean alternative fuel.

    Amy Bunker
    Compliance and Innovative Strategies Division
    Office of Transportation and Air Quality
    U.S. Environmental Protection Agency
    2000 Traverwood
    Ann Arbor, MI 48105
    Jim Younkin

  8. #8
    Join Date
    Aug 2007
    Saratoga Springs, UT

    Default Re: Legal Toyota CNG conversion

    As the above posts indicate, your 2008 Tundra falls under the Intermediate Life category with EPA, so essentially whoever performs the conversion would need the following -- which could be used for other 2008 Tundras as well once the hurdle is crossed:

    1. A tailpipe test in a recognized laboratory showing the vehicle still meets the standard it did on gasoline.
    2. Engineering analysis and scan tool report showing that the OBD II system will still function properly as OEM designed.

    Here is the problem, however...
    Unlike GM or Ford, Toyota's PCM and OBD II diagnostic entry window and threshold information is very difficult to come by. So it is going be tough for anyone to calibrate the OBD monitors for the new fuel without setting false MILs (malfunction indicator lamp aka "check engine light"). I know firsthand because a friend of mine converted his 2008 Tundra with a "universal" CNG kit, and even with the illegal O2 spoof devices his MIL is illuminated all the time. Worse yet, almost every light on the dash is always illuminated too, even the 4x4 warning lamp.

    I wish there were a better answer, both technically and legally. But the reality of the situation is that since 1995 all light duty vehicles are equipped with OBD monitors and millisecond on-the-fly stoic calibrations along the torque curve so as to ensure maximum fuel economy with minimum emissions. When you change the fuel to CNG or anything else these calibrations must be modified from what the OEM designed on his fuel to something similarly robust on your fuel.

  9. #9

    Default Re: Legal Toyota CNG conversion

    Thanks all. As sometimes happens, I now have more questions than answers.

    First, I have looked at the legal summaries provided. They seem to have a lot of detail telling a shop how to get certified. I can think of reasons, such as clean fuel tax credits, that would cause them to want certification. But if the car owner is willing to forego tax benefits, is there a law that requires certification? If there is, I haven't found it.

    Second, to John: I appreciate hearing about your friend. Do you know if his conversion was fumigated or sequential? From what I hear, the former almost guarantees check engine light ("CEL") warnings. I can confirm from the times I have not fully tightened the gas cap on my Toyota that when you get a CEL, it triggers warnings from everything including the normal warnings you'd expect along with warnings on the skid control and antilock brakes.

  10. #10
    Join Date
    Aug 2007
    Saratoga Springs, UT

    Default Re: Legal Toyota CNG conversion

    The provision against changing the fuel without obtaining EPA certification dates back to 1997 with the attached Mobile Source Memorandum 1A. It mostly cites Section 203(a) of the Clean Air Act and provisions for tampering with a certified emission system. It's also interesting to read this 1997 document in which in summary EPA proposed to streamline the certification process for alt fuel vehicles and engines; this streamlining finally came about in 2011, and even then you must get a vehicle to a lab.

    Also attached are guidance letters from EPA to alt fuel converters in 2006 and 2009 which further clarify EPA's policies against tampering when converting a vehicle or engine to run on alternative fuels. And then, as provided in the above posts EPA published new regulations to streamline the process for vehicles older than 2 model years (new vehicle certification requirements were left largely unchanged other than removing the cert expiration).

    In 2010 Utah enacted House Bill 70 which provided much-needed safety requirements for NGVs while at the same time on the surface seemed to provide that the installer and the Utah Division of Air Quality could certify to the owner that the vehicle meets emission standards using test equipment widely available in the state. Note, however, that the bill section 4(a)(i) includes the requirement for the vehicle to meet federal standards as well so we are back to reliance on EPA's regulations.

    EPA sent the attached letter to Governor Hebert expressing concerns that HB 70 is inconsistent with federal law. I don't know what the response was from the state to EPA regarding this.

    My friend's Tundra conversion was sequential injection, but still had all of the OBD problems discussed above.

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