Announcement

Collapse
No announcement yet.

EPA Revelations, Older Vehicles need not be Certified...

Collapse
X
 
  • Filter
  • Time
  • Show
Clear All
new posts

  • EPA Revelations, Older Vehicles need not be Certified...

    http://www.ngvc.org/pdfs/FAQs_Converting_to_NGVs.pdf

    In 1994, partially in response to growing interest by the major OEMs, EPA finalized emission certification requirements for gaseous fueled engines (including CNG vehicles) – the regulations became mandatory for OEMs and new vehicles effective MY 1997. EPA’s final rule also included provisions allowing aftermarket manufacturers the option of certifying their systems using the procedures for new vehicles but compliance was voluntary. Thus, EPA’s final rule indicated that aftermarket conversion manufacturers could continue to comply with Memorandum 1A’s “reasonable basis” requirement instead of going through certification. In late 1997, EPA issued an addendum to Memorandum 1A indicating that it intended to impose more stringent requirements on aftermarket conversions systems. These more stringent procedures became known as “Memorandum 1A - Option 3.” (Option 1 & 2 required certification to EPA or California regulations). The idea behind Option 3 was to increase testing requirement to ensure that no emission degradation was occurring and to transition the aftermarket industry to a point where all conversion systems had to undergo certification, just like new motor vehicles. The 1997 Addendum initially established a target date of Dec. 31, 1998 as the phase-out date for non-certified systems. EPA, however, subsequently issued several memorandums and guidance letter extending this date until April 1, 2002. As of April 1, 2002, Option 3 is no longer an acceptable means of demonstrating compliance with the anti-tampering provisions for most vehicles. Some exceptions exist with respect to certain older vehicles or high mileage vehicles, which are beyond their useful life (10 – 11 years old or 100,000 – 120,000 miles). However, the general rule is that certification to EPA or CARB regulations is now required for most newer vehicles. EPA can levy substantial fines for violations of the federal anti-tampering provisions.

    Retrofitting Pre-MY2003 Vehicles and Vehicles Beyond Their Useful Life As noted above, most retrofit system SVMs have no interest in – and do not maintain active certifications for - vehicles with high (or even medium) mileage due to technical complications caused by long-term operation on gasoline. Despite this, some people may still pursue conversion of their older vehicles to natural gas. The following discussion offers general guidance concerning EPA emissions laws and regulations for older vehicles:
    The U.S. EPA has indicated to NGVAmerica that its certification procedures really only are appropriate for vehicles which are within their useful life, which is roughly defined as 10 years or 120,000 miles, although the exact definition of useful life has changed over time. EPA guidance addresses this point but is less than clear. We have been told that future guidance will be far more extensive on this issue. For any pre-MY1999 vehicles or any MY vehicle with significant mileage (e.g. 100,000 for Tier 1, or 120,000 for Tier 2), current EPA guidance appears to indicate that retrofit system certification is not required although the general guidance of “Memorandum 1A” (i.e., you must have a reasonable basis to believe that the system will not increase the emission) still applies. For MY1999 to MY2003 vehicles that have not yet reached 120,000, EPA guidelines indicate that certification of the retrofit system IS required, which makes this option economically unfeasible. See EPA’s web site for further clarification on this issue including guidance on converting vehicles older than 10 years or beyond 100,000 - 120,000 miles.


    Buyer Beware: Today there a variety of non-certified systems that are sold on the Internet and/or offered by automotive shops. Consumers purchasing a non-certified system should be extremely cautious and obtain information from the person installing such systems to ensure that the equipment they use and the installation are legal and safe. As noted above, some non-certified systems can be legally sold if the vehicle is beyond its useful life.

    Jim Younkin 801 427 2284
    Last edited by younkin; 03-20-2009, 06:39 PM.
    Jim Younkin
    www.younkincng.com

  • #2
    Re: EPA Revelations, Older Vehicles need not be Certified...

    Well done!


    ?Innovation is driven by having access to things.? -- Gleb Budman, CEO of backblaze.com

    Comment


    • #3
      Re: EPA Revelations, Older Vehicles need not be Certified...

      My best guess is that the certification limitations from EPA don't mean a lot if local (county) regs require EPA certification to register a vehicle. The county regs take precedence if you want to drive, regardless if they are written intelligently or drafted by morons who know nothing.

      Comment


      • #4
        Re: EPA Revelations, Older Vehicles need not be Certified...

        Rry9a, What you say may be true but as Jacks Complaint proved even State Agency's are subject to the voters if their rules cause damages to the people in the State. The EPA is the "Club" that the EPA Hardliners are using to keep the Industry from growing so I feel that understanding their rules is important. Jim
        Jim Younkin
        www.younkincng.com

        Comment


        • #5
          Re: EPA Revelations, Older Vehicles need not be Certified...

          Since when does any Govt agency listen to citizens? They generally are a lot more interested in:

          1. maintaining their existence by abusing mandated niches whenever they can- by making petty rules and establishing dependencies with other agencies.

          2. growing larger/richer, generally by adding additional regulations and requirements whenever they can. Govt agencies never shrink in size once established, they only get larger and less efficient with time.

          The State and County CNG regimes are excellent cases in point, the EPA even more so. We are lucky to have a Governor in Utah who understands cng advantages, and helped keep a few of these petty bureaucrats somewhat in check. You really think the recent PSC change came from our letters, or from the governor's leverage and threat to abolish their cushy jobs?
          Last edited by rtry9a; 03-21-2009, 12:34 PM.

          Comment


          • #6
            Re: EPA Revelations, Older Vehicles need not be Certified...

            I was in a conversation this morning and the question came up about what is a "useful life". The term of 120,000 miles was bantered about but many newer vehicles are exceeding this by a considerable margin and they will probably move that number further out, like to 150,000 and further. Also in discussion is the question about a repower, or installing another engine in an existing chassis that has reached the end of its useful life.

            The general consensus is that if the vehicle is repowered, its useful life could begin over again, based on the vehicles capability to produce emissions based on engine wear, not on the vehicles odometer.

            FYI

            Franz

            Comment


            • #7
              Re: EPA Revelations, Older Vehicles need not be Certified...

              Franz, Who did you have a conversation with? Also was I correct in assuming that vehicles that are beyond their useful life can be converted to CNG using a non EPA Kit?
              Jim Younkin
              www.younkincng.com

              Comment


              • #8
                Re: EPA Revelations, Older Vehicles need not be Certified...

                Hey Jim,

                Nice writeup! I know I have talked with you off and on about this subject as you've been researching it, and am excited to see that you are helping to put it into plain English so the average guy can interpret the rules as they are. They (Government agencies in general), like to use the art of confusion in many cases, to cause people to not understand how their rules work, so that they can make people do certain things w/o even necessarily having concrete ground to do it on.

                My question now is, my 1996 OBD-II rig has 115,000 miles on it now, and I feel it is outside of it's 'usable' life, and I have no grounds to believe that it would burn unclean on CNG. So if this is the case, then can I NOW say on this forum what brand CNG kit that I purchased for my rig if it is not illegal, without getting the standard edited post saying: *REFERENCE TO ILLEGAL KIT REMOVED*???

                Well, let me try it here:

                I bought my NON O2-emulated, completely CLOSED LOOP (including factory PCM in loop), CNG kit from a dealer in Utah State, up North, called......

                drum roll.. more drum roll...{reference to uncertified kit removed}
                Last edited by John Mitton; 03-24-2009, 08:56 AM.

                Comment


                • #9
                  A note on our Terms of Service

                  We have restored josch's post after removing reference to his non-EPA-certified kit. The manufacturer of this product will not be promoted here, regardless if the system is destined for a 115,000 mile vehicle or a 100 mile vehicle.

                  http://cngchat.com/index.php?pid=9#furtheringillegal

                  Comment


                  • #10
                    Re: EPA Revelations, Older Vehicles need not be Certified...

                    This link was provided to the EPA's website, and is one of the best resources I have found for tying together loose ends about conversions:

                    http://www.epa.gov/otaq/cert/dearmfr/cisd0602.pdf

                    Look at question and answer #24, among others.

                    Franz

                    Comment


                    • #11
                      Re: EPA Revelations, Older Vehicles need not be Certified...

                      Still trying, after all this time, to figure out what makes a given 'kit' itself, apart from the vehicle, legal, or illegal. I don't think DOT has anything to do with it, other than with cylinders themselves. I know in other countries, most kits have an approval called ISO that deems them as meeting a standard that declares them as safe, but here in the US, what would EPA have to do with the kit's safety? So then, what makes the kit legal or illegal? And if EPA is not a matter of safety, and only emissions, then the kit itself must be legal to buy all by itself, and if you put that 'legal' (not illegal) kit onto a car legally, following these rules that EPA has laid out, then what makes the system 'illegal', especially if the kit was installed according to NFPA-52 standards for safety? And should we urge DOT to extend out their testing regulations to include 'kits', and not just cylinders so as USA has some quality control like the ISO standard to insure that 'kits' all by themselves are safe by themselves?

                      Maybe I should make this a new topic for discussion?

                      Comment


                      • #12
                        Re: EPA Revelations, Older Vehicles need not be Certified...

                        ISO 15500 has standards regarding individual automotive CNG system components (injectors, regulators, fittings, etc.) but not complete systems (as far as I can tell). The EPA doesn't approve components OR kits, they only process the paperwork once a modified engine has passed the required testing at an independent lab.
                        02 GX
                        01 GX
                        03 Crown Vic
                        06 GX
                        Home Fueler

                        Comment


                        • #13
                          Re: EPA Revelations, Older Vehicles need not be Certified...

                          Originally posted by freedml View Post
                          ISO 15500 has standards regarding individual automotive CNG system components (injectors, regulators, fittings, etc.) but not complete systems (as far as I can tell). The EPA doesn't approve components OR kits, they only process the paperwork once a modified engine has passed the required testing at an independent lab.
                          Taking this is one step further, check out NFPA 52 section 4.3.1 (7). This section indicates that the components need to be approved or listed. I have been told that this means the components needed to be tested and "approved/listed" by a group like CSA or UL. I have posed this question to a rep from one of bigger kit manufacturers and no answer.

                          Although this is not an EPA issue it is a safety issue. I would like know what are the differences and/or similarities between NFPA and the for the most part internationally accepted standard such as the ISO standards and specifically 15500

                          Just another question

                          Larrycng

                          Comment

                          Working...
                          X