From the EPA website: Overall, it is clear that the EPA’s primary goal in enforcing the legal prohibition on “tampering” should be to ensure unimpeded emission control of motor vehicles throughout their useful lives. EPA’s policy is to attempt to achieve this goal without imposing unnecessary trade restrictions in the automotive aftermarket.
I have long wondered why there was so much talk and emphasis on EPA certified conversions. They would say EPA Certification was the only “legal” way to convert to CNG. This refrain always seemed to come from those who actually sold or installed EPA conversions themselves. Everyone told me it was a matter of money. They said “follow the money”. Let’s try to do that.
At first, the EPA wanted cleaner air (the Clean Air Act)1. Then they found some cities that did not meet their “standards”2. They mandated that “Covered Fleets”3 should “convert” a certain percentage4 of their vehicles to AFVs (Alternative Fuel Vehicles). Having created a problem by this EPA mandate, they were now in a position to offer a solution. They offered to “Certify” conversions to GNC5. This would be good for fleets, if their conversions were approved by the EPA, it would make them eligible for federal and state rebates6 and incentives. What is an “EPA” certification? The EPA tests the CNG vehicle and uses DF (Factors of Deterioration)7 along with other tests to Ensure that the vehicle will continue to run clean throughout its useful life.8 This “useful life” ranges from 50,000 to 120,000 and up to 10 years9 whichever whatever comes first. EPA certified conversions for new vehicles only. They do not certify older vehicles10. That explains why the “EPA” conversions are all newer vehicles.
As fleet owners collected federal and state rebates, vehicle dealers collected their new car fees. At the same time, installers were able to collect inflated installation fees as fleet owners were collecting federal and state rebates.
(While researching this, I had an “aha” moment. What happens to federal and state rebates if a customer is not told about them or if the fleet being converted is for a non-profit corporation? I found out that the converter can sell the refunds to someone else).
Now can you see the money trail? First the mandate: “Clear the Air, convert the Fleets.” So the EPA offers a solution: We will “certify” (for a fee) CNG conversions that meet the requirement for federal and state rebates that require “EPA-certified conversions.” Fleets start converting with EPA certified conversions. New car dealers (who become exclusive providers) and EPA-approved conversion shops (who will receive inflated conversion fees) are also part of the money trail. This will give the end consumer of the EPA-certified vehicle the opportunity to go “green” and help the environment (and collect federal and state rebates).
You might think this is a win-win for everyone involved, but is it? What about the consumer? If you want to be “Green” you will have to make up a lot of “Green” to pay for that privilege. You will need to have a new vehicle (remember EPA “Certification” is for the life of the vehicle only) this vehicle would need to be a Ford or GM as these are the only EPA certified conversions available. You would also have to pay the inflated conversion price (since you will then receive federal and state rebates).
Oh, and by the way, there are more downsides for the consumer, your vehicle depreciates quickly. EPA certified conversions are mostly gas guzzler trucks and the expensive EPA conversion is only “certified” for the “life” of the vehicle. Also, there are no “in-use” tests, so who knows how long the vehicle will keep running clean?
Now let’s try another scenario. EPA gets out of the way. People convert not because of the rebates and mandates, but because it’s good for the environment and it’s affordable. For there to be widespread CNG conversions, people should be able to convert whatever they are driving. Of course, the conversions must be safe and clean. Many states have their own emissions programs that could test to verify that they are still running clean. Those who sell the conversion kits are already giving classes to certify the CNG installation and the safety of the tanks.
In the US, the conversion of vehicles to Natural Gas has basically stagnated. Many of the older CNG vehicles are out of service and new conversions are not keeping up. The EPA drumbeat alone has scared off many of GNC’s prospective customers. If the EPA’s true intent was “to ensure unimpeded emission control of motor vehicles… without imposing unnecessary restrictions on trade in the auto parts market,” they should take a different approach, one that shows people that the government can be a help and not a hindrance. There are so many positive aspects of the CNG conversion that both producers and consumers are ready and willing to take advantage of them if they have the freedom to do so.
(references not included due to editing, please email me if you want them, JY)