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  • EPA rule on conversions

    Everyone has or is discussing the issue of EPA certified vs. Non EPA certified kits. But, from what i can see no one has mentioned the statute or identified the rule itself. We should discuss the statute and 'how' it regulates the certification of kits. There is a lot of hearsay in the community with people passing along false and misunderstood ideas. A couple of issues that would be nice to have addressed with an actual statute would be:
    1. How are EPA certified kits protected in the statute?
    2. How are they regulated?
    3. What is the penalty for non-compliance?
    4. How are off-road vehicles affected?

    Lets for the very least mention statutes and begin a discussion on the laws found on the books. I'm sure most of the people on cng chat and the general public haven't spent the time to research the law, however they act like they are experts on the topic.

  • #2
    Re: EPA rule on conversions

    I posted some of the text of the "Clean Air Act" here:
    http://cngchat.com/forum/showthread.php?p=8786#post8786
    as you go down the thread you will see Memo 1A mentioned, I like others have looked at all the documents I can find and am still a little confused. In a nut shell the EPA wants "Clean Air", the clean air act puts forth regulations to get this accomplished. Where CNG and EPA or NonEPa kits come in is if an installed kit causes the vehicle to run dirtier than its origional standards. That is where Memo 1A came in, test the vehicle before and after the conversion to make sure it is clean.
    To answer you questions:
    1. How are EPA certified kits protected in the statute?
    I am not sure what you mean by "protected" but EPA kits have certifications for specific years and models and the company who sell the kit will give the consumer a certificate.

    2. How are they regulated?
    Companies can submit their conversions to get certified, others just sell their kit, someone buys it and puts it on and drives. Sometimes if your city has Emissions Programs the OBDII cars (95 and newer) may not pass whether the kits are approved or not, a person may be able to get a waver.

    3. What is the penalty for non-compliance?
    I have never heard of anyone getting fined, but thats just me?

    4. How are off-road vehicles affected?
    Off Road is Off Road, no regulations.....
    Jim Younkin
    www.younkincng.com

    Comment


    • #3
      Re: EPA rule on conversions

      alitmostanding has some very good quesitons. There are members of the website that have researched exactly what he is concerned about. As a moderator of this site, please lets keep this thread in line with what alitmostanding is asking. I can see this thread going off on a tangent. Let's stick with the facts and not speak from our own understanding.
      Jared.
      Mountain Green, Utah
      2003 CNG Cavalier
      2003 CNG Silverado 2500HD

      Comment


      • #4
        Some light reading attached

        All manufacturers must certify with EPA that their vehicles conform to the Clean Air Act. When you change the fuel originally certified by the OEM you are now a Manufacturer. So you have to re-certify your vehicle with the EPA just like the OEM did for his vehicle on his fuel.

        Fortunately EPA has provided in Memorandum 1A a simplified method for small-volume manufacturers (under 15,000 vehicles per year) to get their certifications done.

        The first attachment is a powerpoint overview from EPA regarding the process. The second document is more detail.

        The relevant federal statues are here:
        http://www.gpoaccess.gov/cfr/
        40 CFR Part 86 Subpart S (86.600 to End)
        40 CFR Part 85 Subpart F

        If I have some time I will try to parse thru the CFRs to pull out the relevant sections for this discussion and possibly start a new thread or static web page here at CNGchat to provide more info. But the two attachments to my post here are a great start.
        Attached Files

        Comment


        • #5
          Re: EPA rule on conversions

          EPA considers anything that disconnects or modifies anything that could affect emissions to be a violation of the Clean Air Act and require approval. If CNG could run in an unmodified gasoline engine then it would be easier, but you need to advance the spark for CNG more than engine monitoring systems for gasoline can on their own. The non-certified kits use tricks to advance the spark and inject CNG rather than gasoline, but don't or haven't proven to EPA's standards that they 1) don't increase emissions, and 2) don't cause false MILs, 3) turn the MIL on reliably when something goes wrong. You prove this by expensive independent laboratory tests which are submitted to EPA along with a lot of paperwork and a lot of money. It's only good for 2 years, so the companies who apply don't keep up certifications for conversion of 'old' engine systems. The main users of this method are shops that modify new cars for fleets (Baytech, etc.).

          If you're driving in an area without regular smog checks then you'll probably never get fined for a non-EPA conversion. You also probably won't get the rebates or tax credits. The penalties are oriented toward 'small manufacturers' so it's unlikely they'd be interested in an individual that modified his car. Someone who does it as a business for other people would be a more likely target.
          02 GX
          01 GX
          03 Crown Vic
          06 GX
          Home Fueler

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          • #6
            Re: EPA rule on conversions

            Like Uintah Fireplace for example....

            Comment


            • #7
              Re: EPA rule on conversions

              Alitmoststanding et al,

              Several references have been made to the infamous "Memorandum 1A". Having struggled thru all it's iterations I've condensed a 'one pager' from a 1996 NREL study that summarizes the salient points (gap at .032").

              Also included are their Conclusions which are still relevant today.

              B/R,

              afvman/Bill
              -------------------------------------------------------------------------
              Emissions Standards for Aftermarket Conversions

              In 1974, the U.S. Environmental Protection Agency (EPA) issued Mobile
              Source Enforcement Memorandum No. 1A, which states the agency’s interim policy with regard to enforcing the "tampering” prohibition of the Clean Air Act. The primary objective of this memorandum was to ensure unimpaired emission control of motor vehicles throughout their useful lives. This memorandum, in effect, states that aftermarket conversion of vehicles to an alternative fuel will not be considered "tampering” if the installer has a “reasonable basis” for knowing that such modifications will not “adversely affect” emissions performance. As a result of increased aftermarket conversion activity, an additional fact sheet was issued by EPA on March 4, 1993, stating that a “reasonable basis” may include certification of the conversion kit by the California Air Resources Board, or the Colorado Department of Health (for high altitude areas), or by performing other Federally recognized test procedures. All vehicles included in the Federal conversion program were required to conform to these criteria.

              In 1994, EPA established new certification standards for aftermarket conversions. (“Standards for Emissions From Natural Gas-Fueled, and Liquefied Petroleum Gas-Fueled Motor Vehicles and Motor Vehicle Engines, and Certification Procedures for Aftermarket Conversions,” Federal Register, September 1994). In order for a conversion to count as a “clean fuel vehicle” and be eligible for EPA’s fleet program, or for a state to claim emissions benefits, the converter must certify the converted vehicle to these new standards. Vehicles can still be converted under Memorandum No. 1A, but they cannot then be used for claiming emissions benefits.


              Conclusions
              Aftermarket conversions can play an important role in the transition to the more widespread use of alternative fuel vehicles. In this program, they have been successful in helping the Federal government meet the vehicle acquisition requirements of EPACT, establishing infrastructure, and increasing the displacement of imported oil. The disappointing emissions performance to date of these closed-loop feedback kits, however, raises the question of their overall emissions contribution to the environment. This is especially important when considering converting the latest model year vehicles, which have been certified to the lower (Tier 1) emissions standards. In addition, some existing kits are less advanced and less expensive than the ones tested, and the literature shows that these generally have worse emissions performance1. With the relatively widespread availability of OEM vehicles in the 1996 model year, this program is now being phased out.

              For more information on CNG and LPG conversions, call the National Alternative Fuels Hotline at 1-800-423-1DOE and ask for our booklet titled “Facts about CNG and Propane Conversions,” or visit our site on the World Wide Web at http://www.eere.energy.gov/afdc/

              Comment


              • #8
                Re: EPA rule on conversions

                Originally posted by freedml View Post
                If you're driving in an area without regular smog checks then you'll probably never get fined for a non-EPA conversion. You also probably won't get the rebates or tax credits. The penalties are oriented toward 'small manufacturers' so it's unlikely they'd be interested in an individual that modified his car. Someone who does it as a business for other people would be a more likely target.
                It's up to the EPA to decide who they target.
                Jared.
                Mountain Green, Utah
                2003 CNG Cavalier
                2003 CNG Silverado 2500HD

                Comment


                • #9
                  Re: EPA rule on conversions

                  They can't afford to target individuals. It would cost them more than the $10,000 fine just to investigate let alone prosecute. A budget-minded EPA manager would go after businesses first and probably never go after individuals. Just like in-person IRS audits have dwindled in the last 10 years. It doesn't make sense to go after someone when the likely gain is less than it costs to investigate.
                  02 GX
                  01 GX
                  03 Crown Vic
                  06 GX
                  Home Fueler

                  Comment

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