UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D C 20460
C::. '."LIANG
S ASSu3
\Lncli .11 I
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I UNITED SI \TES ENVIRONMENT \1. PRO'I ECTION AGENCY
WASHING PON. D C 20460
OITIC r or
ENfOKCI Mf.NT ANT)
C OMPLIAN'CE ASSURANCE
Scpteinbci 4. 1097
Addendum 10 Mobile Souice Enlbicemcnl Memoiandum IA
SUBJECT Turnpenny l~ nlbn.emcni Policv for Alternative fuel Afleimaiket Conveisions
A Pin pose The pin pose of this document is to ilanfy and levise the U S Enviioiimeninl
Protection Agency's (I.PA s)' uimpenng" cnloicement policy loi motoi vehicles and moloi
vehicle engines onginalls clesignecl 10 opeialc on gasoline 01 diesel fuel and subsequently
modified to operate exclusively 01 in conjunction \\ nh compiesscd natuial gas (CNG) 01 liquillccl
peuoleum gas (LPG 01 piopane). liereinaflei iclbiied to as ' alternative fuels" The pio\ isions of
this Addendum shall apply to all peisons sub)ect to the tampeimg piohibilion of Section 2()3(a)
of the Act Pot the puipose of this policv Addendum the lei in ' mainifaciuiei " will apply 10 any
peison who designs, pioduces. ancl/oi assembles components loi convening vehicles 01 engines
to opciate on alteinaiive luels anil is lesponsible foi complying with all applicable icqiinemenis
of this policy Addendum
B Background LPA's policy is and has been that any alteration fiom an ongmal configuialion
of a vehicle or engine as com lied under Tille II of the Aci may constitute lampenng undei
Section 203(a)(.i) Routine maintenance anil lepan of vehicles and engines lequnes the use of
replacement pans which may be non-ongmal 01 "afleimaikct" pans 01 systems EPA's Ol'fice of
En foi cement and Ciencial ( ounsel issued Mobile Souiec Enlbieemeni Memoiandum IA (Memo
I A) on June 25. 1974 to pi ovule guidance to coveiecl parlies regaidmg how ihe Agency intended
10 enloice ihe ' lampenng' piohibilion uiulei Section 203(d)( i) of the Clean An Aci (Act) with
respect to maintenance and the use ol aliennaikei pans
Memo IA pio\ ides, in pan. that the use ol an alieimarket pan. alieialion or add-on pan
will noi constitute tampering il the dealei has a "icasonable basis" to believe thai such acts will
not adversely dfleet emissions pei Ibimancc II also piovides specific pioceduies 01 options by
which the dealer would have a "reasonable basis ' One available pioceduic is emissions testing
performed in aecoulance with '40 C I"R S3" (subsequently icvised and meoipoialed undei 40
CFR Pan 86) demonsiiaimg compliance with emission standards foi the useful life of (he vehicle
01 engine An alternate option is that "a Pedeial. state 01 local environmcnt.il conliol agency
represents that a reasonable basis exists" based on testing done in accoiclance \\ith proccduies
specified by that agency Many vehicles convened Mom gasoline fueled to C NG 01 piopane
have iclied on ihe second option uiili/mg pioceduies established by California 01 Coloiado for
demonsiiaimg emissions compliance
EPA has iccenlly become awaic of federal emission test data geneiatcil undei a piogram
conducted by the National Renewable Lneigy Laboiatoiy (NREL) which mdicaie that a
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significant numbei o!'these vehicles inodillccl to run on alternative fuels may be exceeding one or
moie applicable fcdeial emission slandaids The mslalleis involved m the NRCL piogram had
attempted to comply with Memo IA hy using conveision systems ceiulled by the stale of
California undei the "California l-.xhaiM ("mission Slandaids and Test Pioceduies foi Systems
Designed to Conveit Motoi Vehicles Ceitilled loi 1991 and Lailiei Model Veais to Use
Liquefied Petioleum Gas 01 Naluial Cms I uels (pic-1994 California Piocedures) IIP A has
subsequently reviewed emission lest d.ila fioin othei souices which geneially substantiate the
NRELicsults
In icsponse to conceins raised by these data, the Agency conducted a public stakeholder
meeting on Fcbiuary 21. 1997. with icpresentalives of the affected mdustiies. icgulalory agencies
and mteiesled lleet operators fhe puipose of the meeting was to discuss these data and the
causes of the emission failures as well as to cxploie all available options to identify and remedy
the pioblems Many icasons weie piovided foi the emission pioblems. including inadequate
initial tesiing insufficient durability evaluations oveily hioad vehicle applicanon based on
limited testing, inadequate systems/pails specifications impiopei inslallaiion and fuel vai lability
The Concerns of the aflected industnes and Heels subject to seveul altei native fuel siaunoiy
mandates were also discussed
The most significant conclusion icached at thai meeting, and Horn extensive data icvicw
and discussions subsequent to that meeting, was that the pie-1994 California and Coloiaclo
proceduies as cuiienlly structuied do not piovide an adequate dcmonsliation or assuiancc that a
vehicle 01 engine modified to opeiate on an alternative fuel using an alleimaiket comeision
system will comply with the applicable emission slandaids foi Us useful life As a lesull of the
above and in light of the numbei ol vehicles and engines thai may be convened to alternative
fuels m the neai fuluie. LPA believes it is appiopiuiie to issue this Addendum to Memo I A (tins
Addendum) to piovide additional guidance to the legulaled community, including manufacturers
and mslalleis of alternative fuel conveision systems
C Revised Policy l.ffeclive immediately. I.PA will no longei accept a repiesentalion based on
the pre-1994 California Piocedures foi alternative fuel conveision systems or on the lesl
proceduies undei Coloiado Regulation No 14 in effect pnoi lo the dale of this Addendum as a
"reasonable basis" undei paiagiaph 3(c) of Memo 1A Consequently, any futuie installation of
an alternative fuel conveision system. 01 the modification of any moloi vehicle 01 moloi vehicle
engine in compliance with Title II of the C lean Air Act to operate exclusively 01 m pan with an
allei native fuel. 01 the causing thereof, may constitute lampeimg under Section 2()3(a) of the Act,
wheie the installer or manufaciuiei has iclied exclusively on a lepieseniation by Coloiado or
California, as described above, thai a icasoiiablc basis exists in accoidance with paiagiaph 3(c) of
Memo IA effective immediately, the "le.isonable basis " undei paragiaph 3 of Memo I A that
EPA agiees may be iclied on by any peison including a manufactmei mstallei 01 operatoi. when
convening, or causing the conveision of a moloi vehicle 01 niotoi vehicle engine to opeiale on
an altei native fuel is limited lo one of the thiee options listed below
I A I etleial Certificate undei 40 C 1 R Pan 86 demoiislialmg compliance with the
applicable slandaids 01 undei 40 C 1 R Pan NS demonsiiaiing compliance with Clean Kiel Heel
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standauls for each engine lamily to be convened in accoidance \\ilh 40 CTK Pun S3. Subpan f.
or
2 A Rciiofil System CciliUcalion under ihe 'California CcitiUcalion and Insiallation
Proceduics For Alternative I'uel Reiiofu Systems Ibi Vloioi Vehicle5. Corn lied foi 1994 and
Subsequeni Model Veins" lor a conversion system installed and lesled under the above
procedures on a vehicle 01 engine from a "50-staie engine family" for use nationwide, or Ibi a
conversion system installed and tested undei the above pioceduics on a vehicle 01 engine from a
"California engine family" loi use in California onlv. 01
.1 Until Decembci 31. I99S. the use ol an aliein.iii\e fuel conversu)ii system
designed, tested and installed on a single engine lamily. 01 multiple engine families as punidcd
undci paragiaph b (4) below, if testing is completed by Maich 31. I99S. as follows
a With the alternative fuel conveision system installed on the ceitilled
engine family, the manufactuici shall peilbim. or cause the peilbimance ol. one fedeial emission
test while opeiatmg with the aheinative fuel and one lest with the onginal ceiiillcaiion fuel if
dual fuel operation is letamcd. in accoidance with the applicable test piocecluies undei 40 (. TR
Part 8ft 01 Pail SS Ibi thai class and model veai vehicle 01 engine PIIOI to testing, the vehicle or
engine shall be opeiated \\ith the conveision system installed loi at least the numbei of miles 01
houis equal to the seivicc accumulation penod needed (o stabili/e the emission contiol system
specified by the onginal manufacluici in us cerlillcate application submitted to l.PA I.PA
encouiages m.inulaciuiei.s to conduct at least one baseline emission test \\ nh the ceitillcation fuel
pnoi to conveision to ascertain that the vehicle 01 engine meets the applicable standards
b (I) With the application of an appropriate detenoiation factoi (Dl ) to the
above test icsults. the vehicle or engine shall meet the applicable fedeial exhaust emission
standaids to which the vehicle 01 engine was ongmally certified The Dl" shall be determined
cithci based on full useful life duiabilily testing, piedictions based on engincenng iiidgcinenl Ibi
a similar light duty vehicle 01 heavy-duty engine with a similai emission eontiol system using the
same alteinative luel conveision svslem 01 dcteimined in accoidance with the appiopnale
protocol contained in the Deal iVIaniil'actuici" leliei ol Septembei 27. 1995 - Assigned
Delciioiation I actois Ibi (iaseoiis.-1-uclcd Vehicles and l.ngmcs. idcnlilled as C'D-95-14 I 01
heavy-duty engines with altcitieatment (sm.li as a catalyst) the detenoiated emissions aie
calculated by nnilnph ///«• the Dl" with the exhaust emission results Toi heavy-duty engines
without afleitieatment. the detenoiated emissions aie calculated by entiling the Dl with the
exhaust emission icsults l"-oi a vehicle 01 engine convened and tested pnor to accumulating 50%
of its useful life.'the manufacturer shall apply the full Dl' I 01 a vehicle or engine com cued and
tested subsequent to accumulating 50% ol its full useful lile apply a Dl" that is the midway point
between no Dl' and the full Dl I 01 example, an additive Dl- of I 0 may become 0 5 and a
multiplicative DT of 2 0 may become 15 I 01 a \ehicle or engine convened and lesled
subsequent to accumulating its full useful life, apply no D1-"
(2) l-'oi heavy-duty engines used in vehicles with a gross vehicle
weight latmg (GV\VI<) less than 01 equal to 10.000 Ibs. the manufactuici may demonstiaie
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compliance with llic applicable light-duly tiuck siandaids in accoidance wiih the preceding
paiagiaph
(3) In lieu of engine dvnamomctei testing Ibi on-liiglivvay heavy duly
vehicles with a GVWR less than 01 equal 10 14 000 Ibs. llic manulactuier may conduct two 01
three emission tests as descnbed below in accoidance with the most ciiiieni amendments to
"Caliloima Lxhausl Emissions Siandaids and Test Pioceduies Ibi I98X and Subsequent Model
Passengei Cais. Light-Duty Tiucks and Medium-Duty Vehicles" These shall consist of one
baseline test using the ceililicaiion fuel pnoi to conversion, one test afici conveision with the
alternative fuel and one test al'lei conversion with the ceitillcalion fuel il'the vehicle is intended
to be dual lucl The two tests al'lei conveision shall not lesult in any exhaust emissions that
exceed I 10 times any ol'lhe baseline emission levels In the case ofpuie CNG opeiation. the
altei conversion NMI 1C emissions shall not exceed 0 9 limes the Tl 1C emissions before
conveision l-or heavy-duty vehicles opeuiling on a miMuie ofCNG and eilliei diesel fuel or
gasoline, the comcision system maiuiraetuioi should contact I.PA's Mobile Souice Unlbicement
Bianch to deleimine the appiopiKile latio ol'NMI 1C emissions al'lei conveision to 111C
emissions be Ibi c conveision
(4) \Vnh lespecl to light duty vehicles light duty trucks. 01 heavy-duty
engines meeting the leqiinemenls ol paiagiaph (2) above the above demonslialion may be
applied as a icasonable basis loi up to a nuiMiiuim ol'lluee additional light duly engine families
to thai tested piovidcd
A The icsulls fiom testing done in nccoidance \\ith the above pioceduies
demonsliate compliance with low emission vehicle (LLV) 01 moie siiingeni emission standaids
nuclei 40CI:R * SX 104
H The additional engine families have engine displacement eqiiiil to. 01
within 0 8 Ineis (50 C ID) less than the engine tested.
C The additional engine families compnse vehicles equal to 01 less than the
gross vehicle weight of the vehicles coveied by the engine family tested, and
D The additional engine families are equipped with the same catalytic
convenei type (i e beaded vs monolith. OC vs OC/'RC ) and the same piimaiy emission contiol
technology (eg IXiR An Inieclion LTI vs caibuietoi closed loop vs open loop) as the engine
family tested
(5) Option 3 of this policy is not available Ibi conveision of California
only engine families
(6) An alternative fuel conveision system that degiades a closed loop
feedback system to a continuous non-feedback open loop system is not allowed nuclei this option
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(7) C ompliance \\ nh ihis policy may he dcmonsuaiccl bused on
existing daia piovided such daia me the lesuli of testing in accoidance with ihe procedures and
protocols specified heiem
(8) Demonsuaiion \viih ihe Cold CO reqimements under 40 C"I:R Part
86 Subpait C is not lequued undei Option 3 oflhis policy
(9) The Ceiiilicalion Shon Test requiicmenls nuclei 40 C I'R Pan 86.
Subpart O is not icqiiued nuclei Option 3 of this policy
(10) The evapoialive emissions lequnemcius under 40 CTR 86 094-8(b)
and 86 094-9(b) die not lequired undei Option 3 oflhis policy
c The manuraciuiei ol'the comcision system shall specify all pan
numbcis/calibialions associated with that lonveision system and piovide all Mich mCoimalion.
specifications and installation iec|iinemcnis. including a peimanent conversion system label
which appropilately identifies the conversion system with reasonable specificity, with each
system that is sold 01 piovided Ibi installation
d In oidei to demonsuaie thai it has a leasonable basis to beliexe thai us
conveision system will not adversely a fleet emissions ovei the usclul lile ol'the vehicle 01
engine, the conveision system manulactuiei should leiam lecoids including but not limned lo all
emission lest data including test icsults. descnplion of vehicles and/or engines modified, all
mamlcnance and modifications pcrlbi med. laboiatoiy data sheets, identillcation ol'tcst
laboratoiy. lesi dates, lest peisonnel and te>t pioceduies lollowed. engine families tested, data to
suppon additional engine family coveiage if applicable VIN's. vehicle and engine mileage
and/oi age as applicable, fuel specifications, conveision system part numbeis and calibianons.
durability proceduics followed including all duiabilily data and all calculations and cngmeeimg
analyses pcilbnned lo dcteimmc Compliance with the above iec|uiiements
e In oidei to meet the lequnemenis ol this policy, any installation of a
conversion system designed and tested in accoidance with the above shall be done in accoidance
with the applicable pan numbeis/calibialions installed on the \ehicle or engine that was tested.
completed in accordance with manufactmers specifications and/oi instructions and the
conversion system label affixed to the vehicle 01 engine The system shall only be installed on a
vehicle or engine of the same engine family as that tested 01 as permitted undei paiagiaph 3 b (3)
above
f In suppoil of an appiopnale installation, the mstallei should iclain iccords
of each vehicle 01 engine convened in accoidance \\ilh ihe above, including the VIN. make and
yen i of each vehicle 01 engine so modified, ihe name ol the mstallci. ihe dale of installation and
a copy of the irumuliiclmci's 01 maikcier'-s/disliibuioi's icpiescnlaiion that ihe conveision system
has been dcmonsnaled on thai engine family to mccl the icquuemenls oflhis policy
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g In suppoil of any maikciei's 01 diMiibutoi "s compliance wuh the
requnemenis of ilus policy, such panics .should iciain tceoids ol'ciich convcision sysiem sold 01
clisliibutcd. copies of ihe icprcscnuilion 1'ioni the nianufacluiei thai ihc system meets this policy
and records ol'sales lo others including the name ol'lhe puichaseis. pail numbeis. dales of sales
and the numbers of systems sold
h Coloiado has indicated that it will icvise its admmislialivc proceduies
unclei Coloiado Regulation No 14 to require that convcision system manufactuieis conduct
testing in actoidance with opuon 3 oftlns Addendum in oidei lo receive a Coloiado Letter of
Certification Consequently, until Decembei 3 I 1998. 11 PA will not consider as tampering the
sale and installation ol'a conversion system in Coloiado puisuant to a Coloiado Letlei of
Ccilificalion issued aflei the above-iefeienced adminisiialive pioceduie revisions have been
made by Coloiado. piovided testing in suppoit ol'lhe Leltei of C'eilillcalion is done in accoidance
with option 3 of this Addendum and is completed by Mutch 31.1998
D ConiJuMon LPA believes that the maMinum degiee ofassuiance that xehicles or engines
modified lo opeiate on alternative fuels will meet emissions standaids thioughoui then useful life
can only be achieved thiough full eeilificaiion demonstialion m accoidance with 40 CTR Pans 86
01 88 llowevei. the cost and lime associated with such a demonstiation may be piohibilive foi
some conveision system manulaciuieis in the shoit leim and may not piovide sufUcienl
equipment loi lleets (.uiienlly subject to vaiious altei native fuel mandales to comply with those
mandates In addilion KPA will be attempting lo implement vaiious procedures lo siieamlme
fcdeial ceinlleaiion for aliernative fuel vehicles anil on-highway engines, but n is likely that
implementation of those piocedines will take some lime In the mteiim. ihe pioceduies and
requnemenls outlined in option 3 above should allow altei native fuel convcision system> to be
developed and evaluated moie quickly and at lcs>, cost while piovidmg a leasonable assin.incc
lhal emissions will not be detenoialed Aftei Decembei 31. 1998. maiuifactuieis. maikeleis and
mslalleis must ulili/c cquipmenl winch meels the icquiiemenls of option I or option 2 above to
be coveted by the non-tampei ing policy ol Memo I A
T.PA will be levtewmg Memo IA moie ihoioughly in the near fumie lo dclcimine if
addmonal changes aie lequired loi olhei vehicle or engine modifications, pails 01 systems Any
questions icgardmg this inlet mi policv should be dnecled to the Mobile Souiee Lnfoicemeni
Branchai(202)564-2255
IJiucoC Buckhcil Duecioi
An linlbicemenl Division
Ofllce of rnloicemeni and Compliance A*,suiance
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