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Someone clear the air, legal or not! {non-certified conversions in general}

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  • josch
    replied
    Re: Someone clear the air, legal or not! {non-certified conversions in general}

    Hey, that's great to see some real numbers to show a comparison. Thanks for sharing that. I'm still curious to see how different it might be if a guy really tried to force a dirty burn and see how high over the pass limits he could make it. I see your point though. Point taken.

    Leave a comment:


  • Highmarker
    replied
    Re: Someone clear the air, legal or not!

    Originally posted by josch View Post
    On your first point about them (the EPA) not being there to keep technology out of the market... Then please answer the question about why they let old certifications to expire every year? And why does the EPA's list of certified vehicles keep SHRINKING? This year there are LESS cars on it than I've seen in other years. If they really were about the people and not MONEY and allowing CNG to grow, then they shouldn't care about leaving old certifications intact. Then the list would be very big by now.

    Second point about your post I wanted to comment on:

    Don't forget that methane (CNG) is CH4 while gasoline is C8H18. There is 1/8th of the carbon atoms in a CNG molecule. I would think that being a much simpler hydrocarbon, this would equate to much less pollution even under a rich condition where there would be a lot of un-burned fuel going out the tailpipe. And even if a converted car was burning rich I would think the cat would melt-down and clog the exhaust, forcing the owner to address a rich condition of his CNG conversion. I would like to actually SEE somebody TRY to make a purposefully dirty CNG car to test the REAL quality of the emissions so as to challenge the EPA's claim that some CNG retros can burn dirtier than gasoline, because I don't buy that claim at this point. I mean, maybe the COs would be a little higher but would it be as high as gasoline? You still have a cat which is to convert CO to CO2 and help burn excess HCs. Also don't forget that the emissions from methane (CNG) is only like around 35% reactive to the Sun whereas gasoline emissions are 100% reactive to the Sun so much more O3 and smog is formed from gasoline emissions anyway. I just don't believe that even a dirty CNG car can be near as harmful as a clean gasoline car, or even close. If I had a 4-gas analyzer I would test this claim. Does anyone else with a 4-gas want to conduct a series of tests? I would help with it.
    josch,

    Here is your proof. Attached you'll find an emissions inspection that was performed on my 2001 CNG Cavalier in Arizona on June 10, 2005. It measured HC, CO, and NOx. May I remind you that this is an OEM vehicle in its fourth production year. As you can see the HC are only 0.01 g/m lower on CNG than on gasoline, the CO is only 0.03 g/m lower on CNG than on gasoline, and the NOx is just over twice as high on CNG than on gasoline. So the assumption that just because it is natural gas (you're using methane) is "cleaner" than gasoline (fewer carbon atoms) does not mean that burns cleaner. Natural gas is NOT 100% methane. There are other molecules that are included. If you don't know what you are doing, it is very easy to have CNG burning "dirtier" than gasoline. It is not as simple as you think.
    Attached Files

    Leave a comment:


  • John Mitton
    replied
    Testing exemptions

    Jim,
    The manufacturer is the one who certifies a specific retrofit configuration (computer/software + largely off-the-shelf CNG components) onto a specific Test Group (aka "engine family"). Whoever installs it must be authorized to do so by the manufacturer as the EPA application must include a signed statement by the manufacturer that processes and controls are in place to ensure all installs conform to the EPA certified configuration.

    As for on-road testing exemptions, we have found EPA to be helpful in providing these so long as you have a specific purpose with a reasonable time/mileage and scope to the test and a method to accumulate the relevant data obtained. Details on how to obtain these are attached.
    Attached Files

    Leave a comment:


  • younkin
    replied
    Re: Someone clear the air, legal or not!

    John, then you are talking about anyone who converts a vehicle, not someone who produces a kit or sells a kit? For some reason the word manufacturer is messing me up? Also did you need to get a waver to drive your Impala conversion around? If so how would a person go about getting one? Thanks, Jim

    Leave a comment:


  • josch
    replied
    Re: Someone clear the air, legal or not!

    Originally posted by Franz View Post
    Does one speed with little regard to the speed limit? Does one drive through red lights? Does one drive on the left side of the road...

    Just so you know, all of these are a regular part of Utah drivers daily routine

    Me coming from Washington State 4 years ago to live here, it took some time for me to adapt to this regular style of driving

    Leave a comment:


  • josch
    replied
    Re: Cert expiration, SVM limit

    Originally posted by John Mitton View Post
    From NGV America's newsletter today.
    There is hope that Congress can legislate sanity into what EPA can't figure out for themselves...

    NGVAmerica worked with Sen. Roger Wicker (R-MS) to assist the NGV conversion industry. Sen. Wicker introduced (S 3562), which extends the model year definition to allow future conversions of previously certified vehicles. Under current EPA regulations, a certification for an engine family must be recertified once the model year ends. This provision facilitates the conversion of previously certified vehicles, and is identical to a provision in legislation (S. 3281) introduced earlier this year by Sen. James Inhofe (R-OK).

    Also, younkin the SVM limit is 14,999 vehicles per year (combined all models).

    This is a very good sign and it gives me hope

    By the way, thanks for the .pdf as it was very informative as to EPA's cert procedure

    Leave a comment:


  • John Mitton
    replied
    SVM category

    Oh man, I have had a number of discussions with EPA about this According to EPA's interpretation of the Clean Air Act anyone who modifies a vehicle from its certified configuration is a "manufacturer" and yes, changing the fuel is included. So if you are one person modifying one vehicle you fall into the same category as GM, Toyota or anyone else in that your new manufactured vehicle configuration must go thru the conformity certification process.

    Here is where the "small volume" status kicks in. If you, the manufacturer, produce less than 15,000 vehicles per year they have a number of breaks for you that the large OEMs don't get, including:
    • No in-use testing requirements (i.e. no need to run up 120,000 miles on the test vehicle -- instead they assign you ridiculously high deterioration factors which have not been updated in years )
    • No cold-start CO testing
    • Significantly reduced fees

    See slide 6 of the attached presentation EPA made last year.

    The number of vehicles to qualify for SVM status is the sum total of all that the manufacturer either produced himself or assigned others to do for him (eg. sold kits to and paid fees for).
    Attached Files

    Leave a comment:


  • younkin
    replied
    Re: Someone clear the air, legal or not!

    John, you stated "Also, younkin the SVM limit is 14,999 vehicles per year (combined all models)." but is that 1 to 14,999 ? Also is that a company that produces kits or installs kits? Also where does an individual installing or producing a kit come in? Jim

    Leave a comment:


  • cngbuck
    replied
    Re: Someone clear the air, legal or not!

    There are so many points of view on this site, you may leave more confused than when you started.

    Leave a comment:


  • Curtis
    replied
    Re: Someone clear the air, legal or not!

    Originally posted by Franz View Post
    I think Curtis meant EPA, not the DOE (Department of Energy).

    Franz
    Actually the subject of illegal kits on Ebay and illegal conversions were mentioned by EPA and DOE at the conference. We had all the initials running around that week. Just let it be known that the government is aware of and monitoring the situation, cooking up new legislation to address the situation (John mentioned one such initiative).

    EPA is the enforcement arm and probably the only one you'd have to watch out for. With alternative fuels coming into the spotlight, and conversions becoming such a hot topic, it's going to be more closely enforced. It's kinda like the smog shops that would "Pass" your old junker, even though there was no way it would legally pass... until they came out with the Smog-Only stations. I know a few smog shop owners that ended up in jail over that one.

    It's a great time to become a legit conversion company... and a bad time to open up an illegal one.

    Leave a comment:


  • Franz
    replied
    Re: Someone clear the air, legal or not!

    Summit racing and other websites and brick and mortar stores that sell parts destined for off road or high performance MUST and most of them do indicate that their items are either certified for road use (CARB EO #'s) or not legal for road use ("Note: This item is NOT legal for on the road use!")

    California is the most aggressive state about air quality. I do a lot of work with clients there and they are all VERY concerned about the ARB Air Quality enforcement officials. They carry quite a bit of enforcement authority and it is difficult to battle them.

    Why California? Just look at the air quality in LA. Yes, I know, there is lots of talk about cows, trains, boats, and other polluters, but its the cars I am concerned about, especially after reading the above posts.

    Does one speed with little regard to the speed limit? Does one drive through red lights? Does one drive on the left side of the road (oops, sorry, here in the US?). Is one required to have a drivers license before they can drive? The law is there to protect the public, and the same can be said for the emissions systems. We only have ourselves to blame for the mess we are in. For too many years, we have considered ourselves "above the law", or "I am only one person, it doesnt apply to me", or "why dont they go after them instead of me?". We (the industry) has had ample chance to clean up our act and the government has given us more than a few opportunities to follow along, until, finally, in 2004, all the previous exemptions or exceptions were rescinded.

    Instead of fighting the system and seeing what the installer can get away with, we should be teaming to improve the situation.

    Enough said, I'm taking a break.

    Franz

    Leave a comment:


  • John Mitton
    replied
    Cert expiration, SVM limit

    From NGV America's newsletter today.
    There is hope that Congress can legislate sanity into what EPA can't figure out for themselves...

    NGVAmerica worked with Sen. Roger Wicker (R-MS) to assist the NGV conversion industry. Sen. Wicker introduced (S 3562), which extends the model year definition to allow future conversions of previously certified vehicles. Under current EPA regulations, a certification for an engine family must be recertified once the model year ends. This provision facilitates the conversion of previously certified vehicles, and is identical to a provision in legislation (S. 3281) introduced earlier this year by Sen. James Inhofe (R-OK).

    Also, younkin the SVM limit is 14,999 vehicles per year (combined all models).

    Leave a comment:


  • Franz
    replied
    Re: Someone clear the air, legal or not!

    I think Curtis meant EPA, not the DOE (Department of Energy).

    Franz

    Leave a comment:


  • josch
    replied
    Re: Someone clear the air, legal or not!

    Originally posted by Curtis View Post
    Trust me whenI say that the DOE has these illegal kit sellers & installers squarely in their sights... It was the subject of a DOE briefing at the Big Sky Conference... But let the uninformed remain blissfully unaware.
    What does the kit seller have to do with it? He is just selling kits. That is not a crime. It is ultimately the installer who decides whether his universal kit he bought will be installed in a 'legal' or 'illegal' environment. The seller has 0 to do with this. He has no idea what the kit is going on to, and he shouldn't care. That is not his job. No more than it is Summit Racing Equipment's job to care about what their 95% of all inventory that is not EPA approved goes on to. The EPA can't tell you what you can and can't buy or sell. Go check out their website: http://www.summitracing.com/ and you'll be surprised how dirty you can make your car run with parts that are PERFECTLY LEGAL to go buy today. This website of theirs has been up and running, selling speed parts for MANY YEARS, and before they even had a website, they had been selling speed parts for many many years before that, along with a handful of other companies like Jegs and PAW, etc. Perfectly legal. As much as some people like to think that the law prohibits you from buying or selling this stuff, I'm sorry, that is simply just not true.

    Leave a comment:


  • younkin
    replied
    Re: Someone clear the air, legal or not!

    I am confused, is a small volume manufacturer (SVM) anyone who manufactures kits or is it anyone who installs kits? How many is a Small Volume? Just wondering? Also do we have to add DOE now to our list of alphabet agencies we are supposed to be worried about?

    Leave a comment:

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