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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
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
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