EPA Proposes New Compliance Options for Fuel Conversions

[John Mitton]

This just in from EPA...

EPA has just issued a proposal to amend the current alternative fuel conversion regulations. This proposal aims to clarify and streamline the compliance process for manufacturers of alternative fuel conversion systems, while maintaining strong environmental safeguards. Under the proposed approach, new compliance options would become available to many converters. The requirements would vary based on age of the vehicle or engine being converted.

Please visit our webpage http://www.epa.gov/otaq/consumer/fue...s/altfuels.htm to download a fact sheet about the proposal and a prepublication copy of the proposed rule.

[rtry9a]

Re: EPA Proposes New Compliance Options for Fuel Conversions

"EPA supports such innovation and encourages the development of clean aftermarket technologies that enable broader transportation fuel choices."

LOL, They must be living in a world of total delusion.

[younkin]

Re: EPA Proposes New Compliance Options for Fuel Conversions

What they are trying to do is too little too late, instead of making things easier they have intensified the problem. The only good I see in this is that they are admitting in a roundabout way that most vehicles on the road need no "EPA Certification" Blessing. This is what I have been saying all along. The problem now is that all of this EPA saber rattling has turned many away from converting. In the end those who really want to convert have already or will do it anyway regardless of the EPA or any other hurdle. Have a good weekend, Jim
801 427 2284
younkincng.com Blog

[cngsolutions]

Re: EPA Proposes New Compliance Options for Fuel Conversions

I strongly disagree, Jim. I think you are looking at this from a Utah perspective, where people have converted anything that rolls already. What this new rule would allow me to do is buy an "expired" Natural Fuels or Altech Eco system for a 2007 or 2008 truck, and install it. It will be legal as long as the testing when I am done shows that I have not made the emissions worse.

They systems will sell for a lot less (right John?), since they won't need annual recertification. The market will expand. Overall costs will go down, as more systems are sold. This is a big deal, and we need to write the EPA in support.

[younkin]

Re: EPA Proposes New Compliance Options for Fuel Conversions

What this new rule does is finially put on paper what a person should do with not new vehicles, they do not need to be certified, read the rules yourself, a CNG Conversion that does not "tamper" (cause a vehicle to run dirtier) is now as stated by the EPA as legal, this has been the case all along nation wide, they are just now putting it into words. This regulation helps clearify CNG Conversions nationwide, Jim

[Franz]

Re: EPA Proposes New Compliance Options for Fuel Conversions

I wrote a lengthy reply to this thread but I pulled it since it might have gotten me in a little hot water!

I for one am glad to see the regulations the way they are, it levels the playing field and weeds out the snake oil salesmen (but they still seem to find a way to proliferate anyway, dont they?) Everytime there is a need for a product or service, someone tends to find junk that fits the need and condemns the legitimate players as being gougers and the EPA for being too strict. Let them prove their product works the way it is advertised, and that it lasts more than the driveways length or 5 minutes, whichever comes first.

The rules are here for a reason, and we have ourselves to blame for the shape the industry is in today.

[younkin]

Re: EPA Proposes New Compliance Options for Fuel Conversions

Yes products stand or fall as people use them. The problem that happened a few years ago is that the EPA threats drove many underground and stopped most communication between the consumers and the installers. In most places the EPA question is moot now, since the failed programs of the current administration is bankrupting most of us, most people can barely afford to drive their cars let alone convert them.

[rtry9a]

Re: EPA Proposes New Compliance Options for Fuel Conversions

With respect Franz, I couldnt disagree more. You assume that the lawyers at the EPA know something about cng conversions... they dont. What we have here is an excellent example of the law of unintended consequences. The epa wrote very general laws involving importing exotic dirty emission/gas guzzling gasoline driven supercars, and killed legitimate cng conversions in the process. IMHO, their reliance on "not tampering" the electronics is the main culprit- those electronics are designed to control gasoline emissions on a market-wide level , which leaves chg out unless an engine was specifically designed to burn cng, which the small potential market cannot support. The only real exception these days is the GX at the OEM level.

[Franz]

Re: EPA Proposes New Compliance Options for Fuel Conversions

Point taken, but to counter;

Every automobile either manufactured in the US or imported into the US MUST meet the US emission standards at the time of introduction, and that includes any imported supercar. I am not worried about the lawyers, its the installer and home conversion tinkerer that bothers me. I have seen the aftereffects of shoddy workmanship, snake oil salesmen, minimum wage installers who might make a better wage at McDonalds but they cant work there since they cannot make a burger, but here they are, installing fuel systems! And again, I remind that we have seen such examples of workmanship (and I take that term with a strong tongue in cheek!) on this very forum.

What I am worried about is a return to the late 80's - mid 90's mentality of converting anything that moves without any type of validation. Seen them, been there, shut them down. Just because parts bolt together and the engines runs does not guarantee the end result will be any cleaner than what it started out with. Even a more current technology mult- port sequential system one can buy from E-bay or Craigslist in its basic setup "get the engine running" table doesnt come anywhere close to meeting any emission standard. Tweaking a few values until it feels right, doesnt hesitate during accelleration, starts easy cold or hot, and the exhaust doesnt smell funny doesnt prove anything. I have worked emission labs and seen the junk brought in, the yelling when they fail the test, claims of being a paid off lackey of the EPA (I'm not, sorry!) and so on. Just ask any of the true accredited fuel system manufacturers of the steps they took to get their fuel systems certified and one can get a real idea of the true work done to get there. It isnt easy. It is not as simple as driving a vehicle to a corner smog station and get the tail pipe sniffed.

The EPA has recognized that advancements in technology but they are not willing, and I dont blame them, to take all controls off. If so, we might as well return to 2 bbl carburetors and leaded gasoline. Just remember, the EPA has to validate fuel line magnets, fuel polarizers, fuel ionizers, Ozone treatment filters, ultrasonic defragmenters, and a host of other things brought in. They are not dummies. I wouldnt want to be in their shoes. Not that I agree with all that goes on with the EPA, but sometimes they get things right.

Franz

[rtry9a]

Re: EPA Proposes New Compliance Options for Fuel Conversions

You hit the problem on the head... the problem is not tampering with electronics as the epa contends, it is meeting emission standards. If you leave the electronics that are tuned for gasoline, they will be less than optimal, or unusable, with cng.

I say simply if a cng conversion is safe and is as clean emission-wise as gasoline, it should be acceptable. The EPA is way off on this one. We need a solid supply of consumer friendly cng burning vehicles to get off of the foreign oil teat, and the EPA has made that next to impossible unless we want to drive a bus or a garbage truck around or pay converters much more than we need to for one of a lousy selection of "EPA approved" systems.

IMHO, epa will never get anything right until they separate politics from science.

[ajgiorgi]

Re: EPA Proposes New Compliance Options for Fuel Conversions

What about CARB? Anything new there? For example, being able to use an EPA kit in California? This whole thing CARB/EPA thing is ridiculous.

[twh_mn]

Re: EPA Proposes New Compliance Options for Fuel Conversions

You hit the problem on the head... the problem is not tampering with electronics as the epa contends, it is meeting emission standards. If you leave the electronics that are tuned for gasoline, they will be less than optimal, or unusable, with cng.

I say simply if a cng conversion is safe and is as clean emission-wise as gasoline, it should be acceptable. The EPA is way off on this one. We need a solid supply of consumer friendly cng burning vehicles to get off of the foreign oil teat, and the EPA has made that next to impossible unless we want to drive a bus or a garbage truck around or pay converters much more than we need to for one of a lousy selection of "EPA approved" systems.

IMHO, epa will never get anything right until they separate politics from science .

Well said!

[younkin]

Re: EPA Proposes New Compliance Options for Fuel Conversions

Some people say that CNG Conversions have slowed down in Utah due to bad or shoddy work on conversions, I have talked to a few people that were dissatified with their conversions but I have seen even more that are happy and have been saving money for a few years now. In my mind the best reason to convert is to get off foriegn oil, save money and run cleaner.
On another subject the supposed test group of converted vehicles that the EPA proports to have run "dirtier" is just a lie, I read and have the test, across the board the CNG conversions were equal or cleaner, this included aspirated and sequential systems. In a discussion with Marty R he admitted after looking at the test that this was the case. The EPA keeps bringing up this supposed "Dirty" test as a reason to overlook CNG Conversions. The reason there are fewer conversions in Utah and nationwide is due to a faltering economy, the government is taking our money and jobs, Jim
801 427 2284
blog younkincng.com

[younkin]

Re: EPA Proposes New Compliance Options for Fuel Conversions

New EPA regulations for AFV's

I have always felt that older vehicles need no certification, these new regulations prove this to be the case. I have added comments, I hope others will do the same, JY

From new EPA regulations for AFV's, I will add my comments in bold,


EPA has long recognized vehicle alteration for the purpose of clean alternative fuel conversion as a special case because while improperly designed or installed conversions can increase emissions, properly engineered conversions can reduce, or at least not increase, emissions.

(It is telling that there is no mention of any other modification to any other vehicle such as speed equipment etc. the AFV (alternative fuel vehicle) industry seems to be unfairly singled out when it comes to “tampering” enforcement)

Furthermore use of alternative fuels can contribute to achieving other goals such as diversifying the fuel supply through use of domestic energy sources. Therefore, EPA has established policies through which conversion manufacturers can demonstrate that the conversion does not compromise emissions compliance.

(This statement is misleading, EPA certification is for new vehicles only, thus the statement “EPA has established policies through which conversion manufacturers can demonstrate that the conversion does not compromise emissions compliance” is generally misunderstood.)

It has proven challenging however to design an appropriate demonstration that ensures long-term compliance while not imposing overly burdensome testing and administrative requirements, especially for the small businesses that largely comprise the conversion industry.

(It has been not only burdensome it has never applied to all vehicles)

The existing compliance demonstration required of conversion manufacturers for a regulatory exemption from tampering involves obtaining a certificate of conformity.

(This is an demonstration to receive an exemption not a requirement)

This means that converters must (for the purpose of the demonstration) follow essentially the same rigorous certification process that EPA requires of original equipment manufacturers (OEMs). The certification requirements currently in place for all converters give EPA sufficient oversight from an emissions perspective but implementation can be problematic in certain conversion situations. The current regulations were finalized on September 21, 1994 (59 FR 48472) and are located in 40 CFR part 85, subpart F (‘‘the subpart F regulations’’). (CAA)

In the 15 years since these regulations were promulgated, experience has shown that the OEM-like certification program for aftermarket conversions is not an optimal mechanism for ensuring compliance with applicable emission standards, particularly for older vehicles and engines.

(It is not only “not an optiomal mechanism” it never has applied to older vehicles)

EPA has encountered several practical difficulties when using pre-production certification test procedures on older vehicles and engines. Similarly, certain aspects of the certification procedure are not well suited to aftermarket manufacturers. Some small conversion manufacturers, furthermore, have expressed concerns that the complexity of the certification process presents a barrier to entry into the alternative fuel conversions market. For all these reasons, EPA believes it is reasonable to modify the current certification requirement for clean alternative fuel converters seeking exemption from the tampering prohibition. The new program would expand compliance options to include less burdensome demonstration requirements that would nonetheless sustain EPA’s oversight and longstanding commitment to the environmental integrity of clean alternative fuel conversions.

(It is curious here that the EPA talks as if the older vehicles have been included in the EPA certification program all along, they never have been)

Today, EPA is proposing a new approach that streamlines the regulatory process and introduces new flexibilities for conversion manufacturers, while ensuring that converted vehicles and engines retain acceptable levels of emission control.

(As always even the new regulations allow for a one time check or report of emissions, in states that already have a CAA mandated SIP (state implementation plan) most vehicles are tested yearly for emissions.)

The revised program would also address the uncertainty some converters may experience in determining whether a conversion constitutes tampering that could result in liability. EPA proposes to amend the regulatory procedures in 40 CFR part 85, subpart F and part 86 to remain consistent with the CAA yet reflect the concept that it is appropriate to treat conversion requirements differently based on vehicle or engine age. The new program would facilitate age-appropriate testing and compliance procedures by placing alternative fuel conversions into one of three categories:


(1) Conversions of vehicles or engines that are ‘‘new and relatively-new’’ (hereafter referred to as ‘‘new’’ solely for the purpose of this preamble),4 (2)conversions of vehicles or engines that are no longer new (i.e., no longer ‘‘new and relatively-new’’) but that still fall within EPA’s definition of full useful life, ‘‘intermediate age vehicles’’, and (3) conversions of vehicles or engines that are outside EPA’s definition of useful life.

[mikecav19]

Re: EPA Proposes New Compliance Options for Fuel Conversions

Hi Folks,

I need some help from the CNG community. I am trying to find out information on the EPA and the changes that are taking place. I need it in my language. I checked out the link and I had a hard time deciphering anything at their website. So, here is what I want to find out: What changes are the proposed changes and WHEN will this take place? The When is the most important thing I am trying to find out.

From what I understand, it currently costs around $10,000 to convert a car (like a Ford Focus). With the new EPA stuff, it should reduce the costs to around $4,000 is what I heard. The car must be 2 years old. This price reduction is happening due to relaxing some of the requirements??? So, anybody know when/if this will happen?

Thanks! Mike C.