Proposed EPA Certification Rule Change

[afvman]

If anyone missed, but wanted to see the presentation by Marty Reineman from the Ann Arbor EPA office last week it's available...

EPA’s Conversion Policies Update. The archive is now online at: http://www.thirdthursday.net/7.15.2010%20presentations.html

Best,

Bill/afvman

[jblue]

Re: Proposed EPA Certification Rule Change

Thanks for the link Bill. Sure was nice to hear the comments on the useful life of vehicle on slide 7.

[jblue]

Re: Proposed EPA Certification Rule Change

.. and this Q/A @ 0:56:37:

Some aftermarket system sellers say no cert is required for vehicles over 120,000 miles. Is that true?


It is true that they are not certifying the product over 120,000 miles because the Clean Air Act does not allow us to issue something for that mileage. There is no standard that applies at that point when the vehicle is over 120,000 miles, but the ground rules for tampering, as in you cannot do anything to increase emissions, that last forever ... meaning that at 121,000 miles you obviously can’t take your catalytic converter off of your vehicle.

So over 120,000 miles what we’re doing is saying, do you have knowledge that whatever you’ve done and hopefully some level of proof or some kind of test that says I have made the vehicle no less clean.

I would think "no less clean" would be a slam-dunk for CNG conversions.

[ajgiorgi]

Re: Proposed EPA Certification Rule Change

I hope they make EPA kits legal in California.........me crossing my fingers. lol.

[larrycng]

Re: Proposed EPA Certification Rule Change

I went through the archive version of PERC web cast (and I will probably go through it again) and California still retains the right to set its own certification requirements. In the web cast, California is referred to as a "177" state; as are other states that follow CARB's requirements -- and I'm crying out loud.

As for the useful life question I was happy with the requirement to document that the vehicle is no less clean. Having been a SMOG instructor, I have a load of ASM test that were done in class over the years, so a couple of ASM tests on both petrol and LP will keep EPA off of my back. 270K miles is well outside the useful life of the old '97 460 LPG PU.

Larrycng

[John Mitton]

Re: Proposed EPA Certification Rule Change

Here is my commentary which we uploaded this evening (note public comments are due by end of day tomorrow)
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NaturalDrive Partners, LLC is an alternative fuel converter, having obtained multiple certificates of conformity over the past two years. We greatly appreciate the professionalism and courtesy extended us by the OTAQ staff in the review and processing of our applications. The following comments should not be construed as downplaying the value of the services provided by EPA to alternative fuel converters. That being said, here are our comments on EPA-HQ-OAR-2009-0299

1. While the proposed federal rulemaking is welcomed, we feel it is a pity that similar rulemaking is not being proposed in California. The “177 States” following CARB standards comprise over half the US population. Perhaps whatever motivation prompted EPA-HQ-OAR-2009-0299 will hopefully spill over to Sacramento soon. We would ask EPA to encourage its colleagues at the California Air Resources Board to consider adopting similar streamlining procedures.

2. EPA should not impose fees on alternative fuel converter certifications. The proposed rulemaking would exempt fees for intermediate vehicles -- why not the new vehicle category as well? CARB imposes no fees for processing of Executive Orders. We note EPA is “double-dipping” on alternative fuel converters owing to the fact that every vehicle we convert has already had federal certification fees paid on it by the OEM to begin with.

Apart from the above comments (esp. where we differ in opinion as to federal certification fees) we support the commentary provided by NGV America.

John Mitton, Partner
NaturalDrive Partners, LLC