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EPA Pursuing Regulatory Changes for Aftermarket Conversion Systems

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  • EPA Pursuing Regulatory Changes for Aftermarket Conversion Systems

    EPA Pursuing Regulatory Changes for Aftermarket Conversion Systems
    In late June, the U.S. EPA released updated guidance for aftermarket conversion system manufacturers and took the first step toward adopting new regulatory procedures for approving such systems. The updated guidance mostly deals with issues unrelated to natural gas vehicles. Issues newly covered include guidance on flex-fueled vehicles and the use of biofuels. The most significant issue addressed for NGVs is a new policy statement of converting vehicles that are outside their useful life, i.e., vehicles that are either old (10 – 12 years) or have very high mileage (100,000 – 120,000 miles). The guidance unfortunately continues to articulate a policy that is less than clear. EPA previously stated that the only way manufacturers of systems for such vehicles can protect themselves from a tampering violation is to go through certification. The new guidance says that this policy has not changed but then goes on to imply that it might be sufficient to simply have test data demonstrating the use of such systems does not increase emissions.

    EPA also has indicated in the guidance that aftermarket conversion system manufacturers will be expected to use the agency’s Verify Data System to submit certification information for vehicles starting in 2010. Those persons certifying engines will continue to use the FileMaker information system for submitting data. The guidance also provides detailed criteria for combining different test groups and engine families. EPA guidance allows aftermarket conversion manufacturer some leeway to combine multiple test groups and also multiple engine families, thus saving costs and time.

    Also late last month, the EPA, as promised, released an outline of proposed regulatory actions that the agency is contemplating implementing. The proposal essentially has three components: (1) rules for new vehicles, defined as the current model year less one; (2) Intermediate Age Vehicles, and (3) Outside Useful Life Vehicles. Under the proposal, only those conversion systems intended for installation on relatively new vehicles would have to undergo certification (i.e., testing, submission of certification requests, pay certification fees). EPA also would codify the criteria currently used for combining multiple test groups, which essentially allows manufacturers to certify a number of different test groups upon a showing that they are sufficiently similar (e.g., same number of cylinders, same model year, same OEM, same basic catalysts construction). Under the proposal, Intermediate Age Vehicles could be converted without having to go through certification. EPA instead would approve the use of aftermarket conversion systems on such vehicles through a less demanding review process that would include test data submission, labeling requirements, publication of information on the internet, and auditing. Manufacturers of systems for Intermediate Age Vehicles would not receive a certificate, would not have to pay any fees, and, once they’ve gone through the approval process, could continue selling approved systems without expiration. Under the certification process, manufacturers must renew their certificates each model year.

    The EPA proposal responds to industry calls for greater flexibility for approving aftermarket conversions systems. Several states also have recently passed measures calling for EPA to modify its regulations to facilitate increased use of aftermarket conversion systems. NGVAmerica also has urged EPA to develop new procedures and has been working on legislative proposals that would direct the agency to be more accommodating to aftermarket conversion systems. We are pleased to see that EPA is moving forward with a regulatory proposal. EPA has indicated that it hopes to have a working draft notice completed this summer for review within EPA and other federal agencies. They expect to release a notice of proposed rulemaking in December of this year.

    For more information on this issue, contact Jeff Clarke at 202.824.7364 or [email protected]. EPA’s updated guidance is available at: http://www.epa.gov/dis/display_file.jsp?docid=20194&flag=1.

  • #2
    Re: EPA Pursuing Regulatory Changes for Aftermarket Conversion Systems

    still alot of gobley gook but it is a start you should not have to hire a legal team to try and comply

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