I thought pre 96 conversions were legal?

[younkin]

According to John Mitton pre 96 conversions are not illegal, will they too be unable to license their vehicles in Utah? See post below... Jim
" blueandwhiteg3
Join Date: Jun 2008
Posts: 5
Pre-1996 Vehicle Conversions & Legality

I understand that the topic of 'illegal' non-EPA approved conversions can be contentious and is not allowed here.

However, I would like to clarify something... would non-EPA certified conversions of older vehicles, e.g. pre 1996, be illegal? My understanding is that the EPA regulations relate to the sensors mandated in 1996 and newer vehicles.

I have an interest in exploring the possibility of a low-cost conversion of an older vehicle, but I do not wish to pursue this matter on the forum if it is illegal and contrary to forum policy.

Comments on this matter would be greatly appreciated.

Reply to
blueandwhiteg3

06-29-2008
John Mitton
Proprietor

Re: Pre-1996 Vehicle Conversions & Legality
Welcome to CNGchat.
My understanding is if the older vehicle has no OBD controls you are OK. Keep in mind, however the cost of the conversion vs. the remaining life of the vehicle to see if it will pencil out.

[Highmarker]

Re: I thought pre 96 conversions were legal?

Younkin,

You touch a good topic. If you read/watch Bill Gephardt's story on 2News:

http://www.kutv.com/content/gephardt...hILsCUwhA.cspx

The guy has a 1992 pickup truck that failed inspection because it wasn't EPA certified. I know that UHP did extensive research on this prior to issuing the mandate. But it would seem that there is a disconnect between '96 and newer vehicles versus pre '96 vehicles. It would seem that the best solution would be to "grandfather" those vehicles in. My dad has a 1963 Ford Falcon "Ranchero" that does not have seat belts. His vehicle still passes safety inspection because seat belts were not required in 1963. It would make sense that pre '96 vehicles would not be required to have EPA certified equipement on them, due to not having an OBDII system. This is something that the UHP should address.

[younkin]

Re: I thought pre 96 conversions were legal?

As we all know, at least those of us who have tried to make heads or tails of the EPA Regulations, at best they are hard to understand. I am not a Lawyer but I have taken Paralegal training and trying to decifer them is confusing. One definition "tampering" is causing a vehicle to pollute more than its new standards. If a kit is installed safely and doesn't pollute above its new standards I see no problem. Oh and while we are on the topic what about 66 and older, they don't even need Emission tests? Jim
[email protected]
801 427 2284

[Yroc]

Re: I thought pre 96 conversions were legal?

Yes, the hard to understand EPA regulations cause local counties to create safety regulations that are not logical. Requiring an EPA cert to pass a SAFETY inspection is bull, and does not make sense, since when does the EPA regulate safety??

Why does the EPA try so hard to stifle clean fuel vehicles? I thought they were to encourage clean air by setting standards that can be met? What a backwards political system we have!!

[John Mitton]

Re: I thought pre 96 conversions were legal?

Utah Highway Patrol included this grandfathering in of 2002 models or earlier. See the last page of this PDF:
http://cngchat.com/forum/showpost.ph...61&postcount=4

On the tampering issue EPA's policy for over a decade now has been to interpret Clean Air Act Section 203(a)(3) as any alteration from an original configuration of a vehicle or engine. It's all spelled out in this 1997 ruling:
http://www.epa.gov/Compliance/resour...le/admem1a.pdf

Finally, it is not the intent of the owners of this board to create any enemies. We simply want to maintain this as a reference for the promotion of legal natural gas vehicle activity and to influence public policy where necessary to further this purpose. If kicking EPA out of the alt fuel conversion regulatory environment is something you want to see happen then let's get our community around a congressional bill and make it happen.

[larrycng]

Re: I thought pre 96 conversions were legal?

We need some place that makes easy access to the statutes involved in CNG conversion. It then the responsibility of each user to do their own research to verify the statute, research other statutes to determine what is applicable and what is not. However the applicableablity and interpretation of the statutes is in best left, in my opinion to the lowest of the low -- laywers. that will keep up the mass confussion

Does the story of the 800 Lb Gorilla have any meaning.

Hang in there John.

Larrycng

[Franz]

Re: I thought pre 96 conversions were legal?

The law is and has been that it is illegal to render inoperative or defeat the emission control component of any OEM certified vehicle, UNLESS, the device has been tested and proven to either keep the emissions the same or to hopefully improve them.

The testing process will result in an EPA certificate, in 49 states, or in California, since they have legislative enforced air quality rules more strict than federal laws (CARB) an Executive Order (EO). Some states have adopted the California standard in some areas, most still stick with the basic EPA standard.

The purpose of this law is to prevent people from removing catalytic converters, changing computer chips, changing engines, etc, in an effort to optain either real or percieved performance improvements. These "improvements" usually result in higher emission levels, something NO ONE wants, but by the frame of the conversations, no one cars about, they only want cheap fuel.

Around 15 years ago, Carroll Shelby released several titled frames from the early 1960 Shelby Cobra's with modern engines. Since the vehicles were licensed and titled as 1966 models, it was assumed that they were emissions exempt. What happened is that it was decided that they were in actuality, modern vehicle engine upgrades and would be required to be emission compliant. Everyone complained until a track test indicated that the modern engine upgrades outperformed the older engines, then they quietly went away.

From the EPA; Generally, every vehicle made in the US since the mid-late 1960's was emission certified. Early attempts at limiting emission production by putting sealed carburetors, locked distributors, electronic voltage regulators, better timing chains, and eventually fuel injection, was all in an attempt at limiting the ability of the consumer to tamper with their automobile.

In the early 1990's, the EPA field tested a large fleet of converted vehicles. Over 90% of them could not pass the same emission test as originally certified on gasoline. Those that did pass barely squeaked by and would have probably not passed a second time.

This discussion is not new, its been bantered about for the last 20 years that I am aware of. It has forced compliance from many product companies, or they simply could not produce. Its not a choice of "putting a company out of business for nefarious reasons", it a simple ruling that the vehicle AFTER conversion must be as clean as it was before conversion. Its not easy to do, trust me.

Franz

[Highmarker]

Re: I thought pre 96 conversions were legal?

I have to agree with Franz.

Just because natural gas burns cleaner than gasoline does not mean that it will ALWAYS burn cleaner in an automobile. Car manufacturers have come a long way on reducing the emssions of gasoline burning cars. These steps to "clean" the emissions of gasoline are doing gasoline emissions some good. But if you put natural gas in the same system, then the emissions are mostly likely compromised. To prove my point, I have attached an emissions readout of my 2001 Chevy Cavalier. Might I remind you that this is the 4th year running for the Cavalier. Notice the HC, CO, and NOx for gasoline and natural gas. The HC and CO for natural gas is just slightly under the gasoline readings. But the NOx is more than twice as the reading for gasoline. And this is an OEM.

It is not as easy as it may seem.

[larrycng]

Re: I thought pre 96 conversions were legal?

Interesting inspection report, and a few years old.

First the cut points are extremely high and unreal. If I had the CO2 and O2 readings, I would have a better idea of what is wrong - yes you are getting a diagnosis.

The gasoline is running a bit on the rich side, probably should be down below 0.4 closer to 0.2 which would increase the N0x. As CO drops N0x will increase. Ignition HC is good. The cng is also a bit rich, but the increase in N0x is doesn't seem to correlate unles there an advance in ignition timing when on cng.

I don't see any miliage reading that makes sense on the inspection report, but from the age of the vehicle, the CAT may need checking.

Granted I'm use to working with % and ppm on the measurements and not G/M, but the realitive numbers are not making sense. (there is no practical way to convert % and PPM to G/M)

From my own emission numbers on gasoline and LP, immediatly after conversion it went on the emission dyne for an Calif ASM. The HC and CO are almost the same, but the N0x readings droped 30%. These are representive of the numbers that I have seen if the proper equipment is installed correctly. Besides the vehicle are generally very clean today. The only gases I expect to change on a conversion is the N0x (decrease) and the CO2 (decrease). O2 should increase if anything. HC and CO in most cases are almost zero so unless there is an ignition proble (HC) or the mixture richen (CO), are off, they are not really a consideration.

I guess the bottom line, is that conversion or factory systems need to be monitored and properly maintained if we want to get the benefits of CNG or any other alternate fuel.

For what it is worth

Larrycng

[Highmarker]

Re: I thought pre 96 conversions were legal?

Larry,

The emissions test was performed in Arizona in June 2005. I purchased the vehicle in June 2007 at which time it had 51,000 miles on it.

[Franz]

Re: I thought pre 96 conversions were legal?

Emission analysis:

The HC at 0.03 while the standard was 0.8 is VERY clean. HC indicates unburned fuel. .04 grams per mile (not grams per horsepower mile) is pretty nice.

Carbon Monoxide is at .88 on a 12.0 standard. CO is a measure of fuel burned in an oxygen deficient environment, or excess fuel which is burned, not unburned fuel (HC). Again, that number is not bad.

NOx usually means too much air (lean condition), but it can also mean over advanced timing or high combustion chamber temps. .59 on a 2.0 standard still leaves plenty of room for degradation.

Since no combustion is perfect, there will always be residual fuel values present.

Personally, I dont see anything wrong or worth worrying about.

As for the NOx being twice that of gasoline, we cannot compare apples to apples when oranges are in the mix. My guess is that the catalyst is a bit tired but not near worn out. The cats are typically sweet for gasoline based hydrocarbons, whereas CNG has Methane based hydrocarbons and if on a dedicated application, the cat formula is sweetened up for CH4. The NOx numbers can be dropped at the expense of increased HC/CO. I think you are balancing on the very thin line but not teetering over.

If you are serious about getting the numbers down, you might try replacing the O2 sensor and the cat, verifying the fuel system pressures and fuel map trim values, but I think you might be tossing dollars at a penny worry.

Franz

[Techie]

Re: I thought pre 96 conversions were legal?

I have to agree with Franz.

Just because natural gas burns cleaner than gasoline does not mean that it will ALWAYS burn cleaner in an automobile. Car manufacturers have come a long way on reducing the emssions of gasoline burning cars. These steps to "clean" the emissions of gasoline are doing gasoline emissions some good. But if you put natural gas in the same system, then the emissions are mostly likely compromised. To prove my point, I have attached an emissions readout of my 2001 Chevy Cavalier. Might I remind you that this is the 4th year running for the Cavalier. Notice the HC, CO, and NOx for gasoline and natural gas. The HC and CO for natural gas is just slightly under the gasoline readings. But the NOx is more than twice as the reading for gasoline. And this is an OEM.

It is not as easy as it may seem.

State of AZ hired an independent company to do all of the emission tests. To say the least, the people that work there and people who wrote their manuals are very technologically challenged and should not be permitted to check oil level in a lawnmower.

We need to look at how exactly your CNG/Gasoline Cavalier works. It uses a single gasoline PCM and an add-on CNG control module that monitors gasoline signals and pulses CNG injectors based on those signals.

CNG system has an effect on Long term and Short term memory trim values (also known as Block Learn and Integrator) as it has it's own variations and tolerances. When dual fuel systems are set up, to reduce emissions, the alt. fuel side is generally set slightly leaner. Block learn and Integrator do final adjustments and will richen the mixture after a certain criteria is met. It monitors Oxygen Sensor cross counts and fuel-on timer. In any case, a certain amount of time must be allowed for the adaptive memory to adjust and tailpipe readings to stabilize.

When State of AZ performs their emissions test, the first mistake they make is they turn off a warmed up engine. Any pre-conditioning that was there is now lost. A re-start will show poor output.

When fuels are switched, no time is allowed to pass before readings are taken. Since CNG is set leaner, you NOx reading will initially be higher, until fuel trims have re-adjusted and your cat converter has re-warmed up.

CNG is cleaner than gasoline. Any reading can be made look bad by an uneducated test technician and poorly written test manual and software.

In my opinion EPA makes many mistakes too, because their education is limited and arrogance knows no boundaries.

If set up correctly, both CNG and even LPG FUEL INJECTION systems burn cleaner than gasoline. (Running aspirated alt. fuel system on fuel injected gasoline systems is an exception - those modifications do not always work well and give CNG/LPG systems a dirty image.) They also do not produce particulate emissions nor do they emit sulfur oxide. Oil baron funded EPA backed by oil sponsored US government will not allow alternate fuels to prosper as they are looking to make a buck here and now. They could care less about future.

[CraziFuzzy]

Re: I thought pre 96 conversions were legal?

If set up correctly, both CNG and even LPG FUEL INJECTION systems burn cleaner than gasoline. (Running aspirated alt. fuel system on fuel injected gasoline systems is an exception - those modifications do not always work well and give CNG/LPG systems a dirty image.) They also do not produce particulate emissions nor do they emit sulfur oxide. Oil baron funded EPA backed by oil sponsored US government will not allow alternate fuels to prosper as they are looking to make a buck here and now. They could care less about future.

I think you highlighted an important fact here though. A large portion of the imported 'kits' i've seen, and even the technocarb kit that's on my Option 3 Expedition, are aspirated kits, with little-to-no fuel system management. These have a tendacy to swing the scale from rich to lean across various rpm and load conditions. Causing high CO/HC on the rich swings, and high NOX on the lean swings. You are correct that the only major inherent improvement in emissions from cng is in the lack of any sizable amount of particulate emissions. This, is my primary concern, as I live in a VERY particulate impacted area, and it will likely have the greatest affect on my health.

All that being said, I only bought the expedition for the fuel cost advantage, and emissions was not my goal. On my CV, emissions were only a deciding factor because it got me the carpool sticker.. ;-)

[MIK]

Re: I thought pre 96 conversions were legal?

Would it take an act of congress or is this some thing the president can do ?

[CraziFuzzy]

Re: I thought pre 96 conversions were legal?

Would it take an act of congress or is this some thing the president can do ?

I think right now the Congress will do anything the president wants anyways, so it's kind of a moot question.