EPA Proposes to Streamline Approval Process for Fuel Conversion Systems
07 May 2010
The US Environmental Protection Agency (EPA) is proposing to make it easier for manufacturers to gain approval to sell fuel conversion systems. Conversion systems allow vehicles to run on alternative fuels; most conversions involve switching gasoline or diesel vehicles to operate instead on a gaseous fuel such as natural gas or propane; an alcohol fuel; or electricity.
The new options would reduce some economic and procedural impediments to clean alternative fuel conversions while maintaining environmental safeguards to ensure that acceptable emission levels from converted vehicles are sustained. The proposed rule would cover conversions of light-duty vehicles and heavy-duty highway vehicles and engines, and would apply to all clean alternative fuels.
While properly engineered conversion systems can reduce or at least not increase emissions, poorly designed systems can lead to much more pollution. Current EPA regulations require vehicle and engine conversion systems to be covered by a certificate of conformity to gain a regulatory exemption from potential tampering charges.
EPA evaluated this requirement and believes it is appropriate to introduce new flexibilities for all clean alternative fuel converters and expand the compliance options in certain conversion situations. Under the proposed approach, compliance requirements would vary based on age of the vehicle or engine being converted.All conversion manufacturers would need to demonstrate compliance with EPA requirements, but the requirements would differ among age categories. EPA expects the streamlined approach to result in a cost savings for many converters.
Key elements of the proposed rulemaking. The proposed compliance program would enable conversion manufacturers to qualify for an exemption when they demonstrate that the converted vehicle or engine satisfies EPA emissions requirements.The notification and demonstration requirements for new and nearly new vehicles and engines would remain very similar to current certification requirements.
The requirements for intermediate age vehicles and engines would involve testing and submission of data to show that the converted vehicle or engine continues to meet applicable standards.
EPA is seeking comment on three possible demonstration options for vehicles and engines that have exceeded their regulatory useful life.
| Overview of Proposed Program Elements | ||||||
|---|---|---|---|---|---|---|
| Vehicle/Engine Age | Conversion Manufacturer Requirement | Certificate Issued? | ||||
| Category | Applicability | Example for 20101 | Demonstration | Notification | ||
| New | MY ≥ current calendar year - 1 | MY 2009, 2010, 2011 and < useful life mileage | Exhaust, Evap, and OBD testing2 | Certification application | Yes | |
| Intermediate age | MY ≤ current calendar year - 2 and < useful life | MY 2001, 2002, 2003, 2004, 2005, 2006, 2007, 2008 and < useful life mileage | Exhaust and Evap testing + OBD attestation | Data submission3 | No | |
Outside useful life |
Exceeds useful life | MY2000 and older or > full useful life in mileage | Seeking comment on three options | Compliance application | No | |
| 1 This example is for Light-duty Tier 2 vehicles which have a useful life of 10 years or 120,000 miles. 2 Exhaust and Evap refers to all exhaust emission testing and all evaporative emission and refueling emission testing required for new vehicle certification, unless otherwise excepted. 3 EPA is proposing that the compliance notification process for intermediate age and outside useful life conversion would be an electronic submission of data and supporting documents. |
||||||
Outside useful life vehicles and engines. The outside useful life age category would cover vehicles/engines that have exceeded their regulatory useful life. The proposal seeks comment on three options for the outside useful life compliance demonstration, with the intent to finalize one demonstration requirement:
Manufacturers would submit a sufficiently detailed description to show that the conversion technology is technically sound and is applied according to principles of good engineering judgment.
Manufacturers would conduct testing as in the intermediate age program and submit data to show that either a) the converted vehicle or engine is able to meet standards applicable inside useful life, or b) emissions do not increase after conversion.
Manufacturers would submit a technical description as in Option 1, and also an OBD scan report from the converted vehicle or engine to show that the OBD system continues to function properly.
The notification requirement, as for the intermediate age program, would involve submitting the required information, data, and/or OBD attestations to EPA. Converters would be permitted further flexibilities for expanded test groups. No certificate would be issued, and annual re-certification would not be required.
EPA will accept public comments on this proposal until 23 July 2010.
Every little bit helps I guess...but that's what I think this is ---- a little, almost irrelevant (in the bigger scheme of things), bit.
Posted by: ejj | 07 May 2010 at 06:18 PM
If you know anything about this process you will know that for current model year vehicles and vehicles 1 year old there are no changes at all under this new policy.The same testing that is done for a new OEM vehicle on gasoline by the manufacturer is exactly what has to be done for a conversion system seeking certification. It is the new model vehicles where all the time and money are being spent on EPA and CARB certification. Let em do what ever they want with the older vehicles. Who cares! Most comapnies and individual car owners are not going to invest several thousand dollars to convert a vehicle that already has much of its useful life gone or may not even be worth the value of the conversion. Even with the existing tax credits it will never make much sense financially. Alt fuel conversions are not silver bullets. They don't make old tired vehicles some how ressurect. It's actually the opposite that is true. For a vehicle to be a good candidate for conversion it must be in very good mechanical and emissions realted condition.
Fleets need current model year vehicles that can be converted. The need the opportunity to drive them their full useful life on the alt fuel to recoup the investment in the conversion system. As good as alt fuels will be for our country, it still needs to make financial sense for the companies choosing this path.
The compliance, product development and testing necessary to satisfy EPA requirements takes months and 10s of thousands of dollars for each make, model and engine family. This policy change is not what America needs or what the industry needs. This is a token effort by the EPA to thwart the pressures currently being applied in Washington and what recently happened in the Utah legislature.
We need an overhaul of the regulations in the Clean Air Act that governs this type of conversion upgrade to a production vehicle. Then we need to make an across the country standard (eliminate CARB) so any citizen, reguardless of state of residency, can enjoy the same opportunity to drive an alt fuel vehicle. If that can happen we will see a surge in alt fuel activity across the country that can set us on the course to true energy independance.
Posted by: Jodyswv1 | 10 May 2010 at 09:24 AM