[new title] Sequential injection vs. EPA tampering rules. Would this system qualify?

[teodor]

Ok I started a new thread on purpose.
Here is a citation of EPA Standards for Emissions From Natural Gas-Fueled, and Liquefied Petroleum Gas-
Fueled Motor Vehicles and Motor Vehicle Engines, and Certification Procedures
for Aftermarket Conversions

I. Aftermarket Conversions

1. Applicability

Summary of the proposal: It is the Agency's policy that, based on the
tampering provisions of section 203(a)(3) of the Act, aftermarket conversions
should not degrade the emissions performance of the vehicle being converted,
and that following a conversion a vehicle should still meet the emission
standards it was originally certified as meeting on any fuels it is capable
of using.
Under this policy any conversion which degrades the emissions
performance of the vehicle is considered tampering.


Here is citations out of the EPA clean air act section 203(a)3:
PROHIBITED ACTS

Sec. 203. (a) The following acts and the causing thereof are
prohibited-
(3)(A) for any person to remove or render inoperative any
device or element of design installed on or in a motor
vehicle or motor vehicle engine in compliance with regula-
tions under this title prior to its sale and delivery to the
ultimate purchaser, or for any person knowingly to remove or
render inoperative any such device or element of design
after such sale and delivery to the ultimate purchaser; or
(B) for any person to manufacture or sell, or offer to
sell, or install, any part or component intended for use
with, or as part of, any motor vehicle or motor vehicle
engine, where a principal effect of the part or component is
to bypass, defeat, or render inoperative any device or
element of design installed on or in a motor vehicle or
motor vehicle engine in compliance with regulations under
this title, and where the person knows or should know that
such part or component is being offered for sale or
installed for such use or put to such use;

So from all this I come to a conclusion that the galileo kit being for sale ... you know where... is illegal because it includes a device that simulates the oxygen sensor signal and another device that emulates the cylinder injector signal. This doesn't mean it is unsafe to use or anything like that... but that's another story. OR if does pass the emissions then it is legal?!

Anyhow - I am able to import from ... let's just say somewhere .. a sequential gas injection kit which does not bypass, defeat or render inoperative any devices in the engine - it has it's own control module and only takes signals from the original ECU without modifying them in any way. And will NOT degrade the emissions performance of the vehicle being converted - actually will improve them a lot.
So will this be legal or not?!

And my conclusion:
Those EPA acts are outdated and they should change them. Isn't their aim to protect the environment?! Why use imported gaspline when we could use home produced natural gas (at half price the gas) and be independent from the middle east and the most important part - run our vehicles cleaner! I don't see why a vehicle properly converted to CNG with a kit that has all the safety and emissions certificates in another country and with DOT certified unexpired tanks in good condition and this vehicle gets the same emissions or better then when running on gasoline after the conversion, should be considered illegal?!:

[echamberlain]

Re: The deal with non EPA conversions AGAIN!

These sound like questions to ask an attorney that specializes in EPA regulation.

[John Mitton]

Re: The deal with non EPA conversions AGAIN!

You forgot to include in your analysis Memorandum 1A. This is already discussed in the other thread.

http://www.cngchat.com/forum/showpost.php?p=9809&postcount=94

The only option for your sequential injection kit would be to take it to an EPA-approved testing lab, run the tests on a specific engine and then certify that engine with the kit. Assuming it passes you would need to do it again for other engines you wish to certify with it as well.

Passing emissions at your local smog facility with a 5 gas analyzer is not good enough for EPA. In fact, most states are going away with the tailpipe test because the OEMs have proven to EPA that the onboard diagnostics (OBDII) do a great job of sensing when emissions are out of standard. The smog station plugs into the OBD and if all looks good the vehicle passes.

Now, here is where you come in. You change the fuel and suddenly the calibrations the OEM did for his sensors no longer apply with your fuel (even with a "cleaner" fuel such as CNG, LPG, etc.).

EPA now needs to know that in a simulated drive on a dynamometer the emissions are within acceptable standards on your fuel. They also need to know that in a simulated aging of the vehicle (progressively killing the catalyst) the MIL will properly illuminate when emissions go over 1.5 times the baseline, and conversely that the MIL does not improperly illuminate either. The only way to do this is to run the tests, which generally cost around $30k - $50k and is something many of the now-nonconforming kit manufacturers have done before. They need to suck it up and do it again.

[josch]

Re: The deal with non EPA conversions AGAIN!

I think the EPA needs to suck it up and do all of the testing themselves (not tell you that a third party lab must do the testing), and use tax money to subsidize the majority of that claimed $30k-$50k cost for vehicular testing for the people of the US, and they should install test centers all over the US, several in every state, and do any other thing necessary to help streamline the conversion process of any alternative fuel to the US citizens. If they truly care about the clean air project, and our environment as much as they claim to, then this streamlined process would clean the air in the world MUCH faster than their current methodology of forcing so much red tape on people that most people just say screw-it, and just keep pumping gasoline. But I'm sure that there are JUST enough ridiculous morons heading up the EPA that they can't seem to figure this story problem out. It reminds me some old generic joke about 'how many _________(you fill in blank) does it take to change a light bulb', and you can clearly see that obviously a huge office like the EPA with all its people can't seem to figure out the REAL way to bring cleaner air, faster. At the rate we're going, we wont even make a dent on pollution til the year 2025 or so. (Just my stupid opinion by the way).

[teodor]

Re: The deal with non EPA conversions AGAIN!

I think the EPA needs to suck it up and do all of the testing themselves (not tell you that a third party lab must do the testing), and use tax money to subsidize the majority of that claimed $30k-$50k cost for vehicular testing for the people of the US, and they should install test centers all over the US, several in every state, and do any other thing necessary to help streamline the conversion process of any alternative fuel to the US citizens. If they truly care about the clean air project, and our environment as much as they claim to, then this streamlined process would clean the air in the world MUCH faster than their current methodology of forcing so much red tape on people that most people just say screw-it, and just keep pumping gasoline. But I'm sure that there are JUST enough ridiculous morons heading up the EPA that they can't seem to figure this story problem out. It reminds me some old generic joke about 'how many _________(you fill in blank) does it take to change a light bulb', and you can clearly see that obviously a huge office like the EPA with all its people can't seem to figure out the REAL way to bring cleaner air, faster. At the rate we're going, we wont even make a dent on pollution til the year 2025 or so. (Just my stupid opinion by the way).

AGREED!

I will read that memorandum and see what they say in there. But I would suggest instead giving a $3000 tax credit and stuff like that - just keep the money for their emission tests. I would agree to convert a car with that system (The system it self will have a sale price of not more then $1300 - $1400 that's without the tanks) and give it to them to test the car as long as they want to but I will not agree to pay that much money for just one specific car and engine model. After all thats why they test our emissions every year. If it is such a problem then just build a special test center for CNG vehicles and then whoever gets a car converted will just have to bring it to that center to get it certified for being safe, low emissions, road worthy and go there every year and pass the "special" emissions test for cng. I mean if the catalyst fails or the MIL comes one for what ever reason - real or fake, then the car will not pass emissions right so I don't see the problem with all that. They should try to make these car conversions more affordable - I mean not every one wants to drive a honda Gx or ford crown victoria or chevy cavalier or ford e350... What If you are a fan of let's say an Audi and want to use cheaper, cleaner fuel - you cant do anything about it because your audi can't be converted. Now If it was in Italy then that's another story. You just pay the shop and they convert your car oh and don't think that the conversion is not good because I lived in Italy for like 6 months - in Naples to be exact and there was NO SMOG at all because 95% of the car run on LPG or CNG. I have been in Los Angeles too - that seemed like the worst SMOG if ever seen although the strict california emissions! And don't forget that in Italy the cities are more populated then here. So since converting even with that kit that does not simulate any signals will still be illegal I think we need to do something and make them change their policy!

P.S. How about converting a non OBD II car, let's say a pre OBD II car like 1990 Vw jetta or something. Will that still be tampering? IF yes, then what about a pre 1975 car (which is exempt from emissions in california) or a car with carburettor that doesn't have any electronics?
If a pre 1975 car can be legally converted to CNG I will defenately do It and I am sure it will have 5 times more emissions then say an OBDII car converted ilegally but since we have to do it legally we have no choice. With the current gas prices and the price of CNG in utah if you pay $1700 for a conversion (850 for kit (don't want to specify which one) and about 800 for a good used unexpired tank) depending on the car MPG you will get your money back in 12000 - 15000 miles, which for me is about 4-5 months

[blackws]

Re: The deal with non EPA conversions AGAIN!

How about we just have the Congress do away with the EPA completely (we're tired of the BS and extra bureaucrats).

[teodor]

Re: The deal with non EPA conversions AGAIN!

Ok started reading that memorandum and in the begging of it it is written:
"The provisions of this Addendum shall apply to all persons subject to the tampering prohibition of Section 203(A) of the Act"
Like I said the conversion system (according to what is described in section 203(A) which I cited up there) will not tamper the engine system - will not give false signals to ECU, will not eliminate any devices such as Oxygen sensor, will not emulate signals for the injectors. In other words since there is no tampering then the memorandum does not apply. Am I right or wrong?

Well EPA is a good thing but they have to work on our problem a little more and get a better solution. I agree that they can't just let people do whatever they want to but they also cant forbid us to do something that is actually better for the environment.

[CNG4RD]

Re: The deal with non EPA conversions AGAIN!

I don't agree that our tax dollars should go into a black hole government bucket to be used on every joe-blow conversion kit someone dreams up.

I do believe that much of the concern about cng kits "degrading" some manufacturer's emission levels are way overblown and if not overblown are a complete reach of government power into our lives that we simply don't need or want.

Simply pointing to past conversion failures in Arizona and other places where stupid companies tried to make a profit is just plain old fear-based propaganda and rhetoric. These past mistakes are simply a tool for big oil and control freaks to slow the acceptance of alternative fuels.

The only reasonable (and I think possible) solution is to dumb down emissions testing and let you road-certify any vehicle with a simple tail-pipe test. It is plain stupid to think you couldn't devise a reasonable (good-enough) emissions test for ANY emissions vehicle that would cost under 500 bucks per vehicle. Any talk about the thousand ways you could fool such a test is a failure to see the big picture, they would be missing the entire point.

I mean give me a break, we are talking about finding a solution for the masses not building a certification system that will catch every fringe fuel hacker on the road.

You don't solve macro problems with micro solutions. The government needs to quit micro managing and stop buying into and propagating the big-oil fear mongering that is in place only to boost their bottom line.

Environmentalists need to leave the emissions issue alone and quit cutting off their nose in spite of their face. Talk about not having then end in mind....

[younkin]

Re: The deal with non EPA conversions AGAIN!

Bottom line with tampering, if the car creates (degrades) more HC, CO, CO2, NOX, that the standard set for that year then it may be considered tampering by the EPA.

The devices that the EPA does not want taken off the cars (tampering)are Cats, EGR's, Air Pumps, etc. in other words devices that were added to the car to help the car run cleaner and be able to pass the emission requirements for that year.

The EPA wants cleaner air, that is their mandate. I want the same thing.

Personally, (as a mechanic for 30 years) when anyone makes a blanket statement and says that a (******) cng conversion will or will not cause a car to pollute more or that it will or will not conform to OBDII or Emission standards after the conversion how can they be truthful? No one can really say until the do a retest and know for sure.

[freedml]

Re: The deal with non EPA conversions AGAIN!

If the bottom line were it has to pass the test, we all wouldn't be so upset. But, according to their regulations, if you disable or bypass something it's still illegal even if it makes the car exhaust CLEANER!

[younkin]

Re: The deal with non EPA conversions AGAIN!

Freedml, In order to get your car licensed in the Countys that have Emissions testing then you need pass that Emissions test. In the Countys that have no Emissions testing I am not sure why there is a problem. As far as I know if any converted car can pass Emissions even if it is OBDII I am not seeing where there is a problem. An EPA Certified kitted car still has to pass Emissions and if it doesn't pass a person needs to find the problem like everyone else.

[freedml]

Re: The deal with non EPA conversions AGAIN!

If the technician is paying attention, he will fail such a car before doing the emissions test. The computer asks 'is this installed', 'is this operating'. If he answers 'yes' and he's lying, he could be in for big trouble. If you don't have inspections or tests then you will probably never get caught.

[younkin]

Re: The deal with non EPA conversions AGAIN!

I have been an Emission tester in Utah and California, when you said'"If the technician is paying attention, he will fail such a car before doing the emissions test. The computer asks 'is this installed', 'is this operating'. If he answers 'yes' and he's lying, he could be in for big trouble. " I assume you are talking about whether or not a vehicle has a Catalytic Converter? or EGR? or AIR System? etc. Those questions all have to do with Emissions Components, it will ask if it is Dual Fuel and you will have to test it on CNG also but when you install a CNG Kit you taking nothing off, you just add. If you kit is programmable then a good tech will be able to fine tune it to run clean at load, idle etc.

[teodor]

Re: The deal with non EPA conversions AGAIN!

If the bottom line were it has to pass the test, we all wouldn't be so upset. But, according to their regulations, if you disable or bypass something it's still illegal even if it makes the car exhaust CLEANER!

Like I said - I can import a kit that doesn't disable or bypass or simulate anything. It has it's own ECU and only takes signals from the main ECU (without modifying them in any way) in order to keep the system running properly. It is bi-fuel and is sequential gas injection with a common rail which is the best kit on the market (and the most expensive by the way although If I import it I can resell for under $1400! so it is not really expensive compared to the home made products). The gas is fed trough injectors which you mount on the intake and in order to do that you drill the intake at each cylinder and you screw the cng injectors. The car keeps the original injectors and whenever you switch to CNG the ECU of the CNG system reroutes the signal from the gas injectors to the cng injectors and vice versa. Nothing is simulated, removed or bypassed.

P.S. Non of the kits I know of when installing them would make you take off the catalytic, the EGR or the Air pump. Like younkin said when you are installing you are adding only you are not removing anything usually. And I agree that a bi fuel car has to be tested on both fuels for emissions. It's only fair that way.

[CraziFuzzy]

Re: The deal with non EPA conversions AGAIN!

Unfortunately, the only way for you to use the kits legally in the states, is to get them certified to EPA standards, or to CARB standards. If you can get such a good deal on them, why not get the certs and resell/install the kits here in the states? The market is desperate for certified conversion kits, and if these kits are as good as you claim, then they will sell like mad.