Rule change should expand market for natural gas vehicles

ANN ARBOR, Michigan . . . EPA’s proposal to streamline the process for certifying
natural gas vehicle aftermarket conversions is one of the most important steps government can take to expand the use of non-petroleum fuels, NGVAmerica told the agency today.

Natural gas vehicles can play an important role in increasing energy security, creating U.S. jobs, providing cleaner air and reducing greenhouse gas emissions—while generating economic benefits for consumers, said Jeff Clarke, General Counsel and Director of Regulatory Affairs for NGVAmerica.

“We commend EPA for recognizing that its regulations as currently written are not a good fit for aftermarket conversions,” said Clarke in his oral statement made during today’s hearing on the agency’s proposed rule changes. “It has been a long time in coming and is welcomed.”

Clarke told the agency that the industry continues to support certification requirements, but that the existing regulations are unduly restrictive.

“Until there are sufficient numbers of original equipment manufacturers’ products available in the marketplace, our industry will continue to need aftermarket conversions to help us grow, to help us justify the necessary investments in fueling stations, and to help us increase market penetration. Conversions fill a void unmet by original equipment manufacturers and demonstrate consumer demand for new applications.

“Conversions also provide a ready means of addressing the emissions and fuel consumption of medium and heavy duty vehicles that will continue to be in operation for many years to come.”

Under the proposed rulemaking, the agency would approve systems for use on vehicles older than two years, but would not require the more extensive and expensive Certificate of Conformity for these vehicles. In addition, the agency has also proposed three potential options for engines that have exceeded their regulatory useful life.

In supporting the proposed rule changes, Clarke provided the following specific
recommendations:
Warranty: EPA should unequivocally state that converting a vehicle does not void the
original equipment manufacturers warranty. “The latest guidance gives the impression
that the agency has backed away from this,” says Clarke.

Certification fees: The EPA should allow aftermarket manufacturers to pay the
certification fees at the end of each quarter or annually based on the total number of vehicles sold. Manufacturers now are required to pay the fees based on expected sales, which ties up capital.

Vehicles two years or older: The agency should specifically state that manufacturers can seek both a Certificate of Conformity for the new vehicle and approval for converting this vehicle after two years.

Bench testing for heavy-duty vehicles. The requirement to use bench testing for heavyduty vehicles is too restrictive and manufacturers should be able to use chassis testing that has been approved by EPA. This would help lower the costs of complying with the regulations.