A white paper from the Ben Franklin Shale Gas Innovation and Commercialization Center that takes a look at both Pennsylvania and federal regulations (hurdles) when it comes to converting vehicles to run on natural gas.

1. Regulatory
Hurdles
for
Natural
Gas
Vehicles
Developed
by
the
Shale
Gas
Innova3on
&
Commercializa3on
Center
November
2012
The
Shale
Gas
Revolu.on
is
now
firmly
entrenched
in
the
public’s
imagina.on
as
a
result
of
the
steady
decline
of
natural
gas
prices
from
above
$4.00/mcf
(mcf=thousand
cubic
feet)
to
$2.00/mcf
and
below.
At
the
same
.me,
oil
prices
have
spiked
and
remained
high,
typically
between
$85
and
$100
per
barrel.
This
has
caused
gasoline
prices
to
soar
above
$3.50
per
gallon
at
their
highest
point,
feeding
public
discontent
and
consterna.on
at
the
cost
of
driving
to
work
and
other
ac.vi.es.
Naturally,
the
public
has
prompted
its
leaders
for
solu.ons,
and
one
that
has
been
discussed
regularly
is
the
use
of
natural
gas
as
a
transporta.on
fuel.
At
current
prices,
consumers
might
save
up
to
60%
of
their
fuel
costs
and
spend
more
of
their
money
with
domes.c
producers
instead
of
foreign
oil
suppliers.
Despite
the
public
clamor
for
using
natural
gas
in
vehicles,
there
has
been
only
limited
progress.
As
could
be
expected,
this
has
led
to
some
frustra.on
and
a
search
for
solu.ons
ranging
from
infrastructure
spending
to
tax
credits
and
financial
incen.ves
to
adopt
the
technologies
associated
with
natural
gas
vehicles.
Unfortunately,
many,
if
not
all,
of
these
efforts
face
difficul.es
due
to
the
regulatory
framework
that
surrounds
vehicle
and
engine
technology
at
various
levels
both
in
government
and
industry.
Together,
they
form
the
coils
of
a
Gordian
knot
that
restricts
the
deployment
of
natural
gas
vehicles
and
other
types
of
alterna.ve
fuel
vehicles.
The
regula.ons
are
confusing
and
oVen
overlap.
They
can
also
add
considerable
expense
to
the
introduc.on
of
an
engine
technology.
The
purpose
of
this
paper
is
to
outline
the
regula.ons
in
a
coherent
manner
and
discuss
their
applicability
to
natural
gas
vehicle
development.
Some
important
terms
and
defini.ons
used
in
discussing
the
regula.ons
are
as
follows:
• NGV:
This
abbrevia.on
stands
for
Natural
gas
vehicle
and
is
used
frequently
in
the
literature.
• Dedicated:
A
dedicated
natural
gas
system
means
that
the
vehicle’s
engine
is
configured
to
only
run
on
natural
gas,
either
in
compressed
gas
or
liquid
form.
• Bi-­‐Fuel
and
Dual
Fuel:
In
common
parlance,
a
bi-­‐fuel
system
allows
the
operator
to
select
either
natural
gas
or
a
liquid
fuel
(gasoline
or
diesel)
as
the
vehicle
fuel,
while
a
dual-­‐fuel
system
uses
both
natural
gas
and
a
liquid
fuel
simultaneously
in
some
ra.o.
In
the
former
the
vehicle
runs
en.rely
on
natural
gas
or
liquid
fuel,
depending
on
the
choice.
This
op.on
allows
for
flexibility
in
choosing
the
fuel,
and
alleviates
the
problem
of
opera.ng
in
areas
without
natural
gas
fueling
sta.ons.
In
the
laer,
both
are
mixed
according
to
availability
or
some
opera.ng
constraint.
It
offers
flexibility
as
well—most
systems
will
run
on
diesel
alone—and
is
intended
to
provide
maximum
savings
in
heavy
use
situa.ons
where
natural
gas
op.ons
may
be
limited.
However,
in
many
cases
these
two
terms
are
used
interchangeably,
and
some
regula.ons
cite
the
exact
opposite
defini.on
for
each.
Thus,
the
defini3ons
are
not
fixed,
and
readers
should
review
the
context
and
situa.on
to
understand
which
defini.on
is
being
used
for
a
term.
1

2. • CNG
and
LNG:
These
terms
refer
to
the
two
basic
storage
systems
for
natural
gas
fuel.
Compressed
natural
gas
or
CNG
is
simply
natural
gas
stored
under
pressure,
so
that
more
fuel
may
occupy
a
smaller
space.
LNG,
or
Liquified
natural
gas
is
stored
as
a
liquid
and
converted
to
gas
just
before
use.
Most
applica.ons
use
CNG
systems
because
LNG
systems
require
complex
storage
systems,
cryogenic
temperatures,
and
high
pressure
compression
facili.es
to
manufacture
and
use.
On
the
other
hand,
LNG
does
maximize
the
energy
density
of
natural
gas
by
turning
it
into
a
liquid.
• Conversion:
This
term
refers
to
the
process
of
installing
a
cer.fied
natural
gas
fuel
system
into
an
exis.ng
vehicle
which
runs
on
a
liquid
fuel
system.
Conversions
generally
create
bi-­‐fuel
or
dual
fuel
vehicles,
but
can
also
create
a
dedicated
NGV.
Of
course,
vehicles
may
also
be
sold
new
with
any
type
of
natural
gas
fuel
system,
if
the
NGV
is
cer.fied
by
the
EPA
and/or
CARB,
depending
on
the
state.
• Mixer
or
Venturi
Systems:
These
are
simple
fuel
systems
which
introduce
a
natural
gas
stream
into
the
engine
fuel
system
at
a
constant
rate.
Some
debate
exists
as
to
whether
or
not
they
can
create
significant
savings
for
vehicle
operators.
• Sequen3al
Injec3on
Systems:
These
systems
introduce
the
natural
gas
into
the
engine
system
at
a
variable
rate,
determined
by
the
engine
computer’s
opera.ng
parameters.
They
are
more
sophis.cated
and
poten.ally
more
cost-­‐effec.ve
to
operate
than
the
simpler
Venturi
systems.
• CARB:
This
refers
to
the
California
Air
Resources
Board,
the
California
rule-­‐making
body
for
emissions
regula.ons,
whose
decisions
have
a
na.onal
impact.
Regula.ng
bodies
also
classify
vehicles
by
type.
Generally,
these
classifica.ons
are
based
on
the
vehicle
size
and
primary
use.
The
EPA
and
other
bodies
typically
use
the
following
broad
classifica.ons
to
describe
vehicle
requirements:
• Passenger
Cars
and
Light
Duty
Trucks:
Are
the
smallest
and
most
widely
used
vehicles
available
to
the
public.
In
general,
these
vehicles
are
rated
at
8500
lbs.
gross
vehicle
weight
or
less.
This
is
by
far
the
largest
category
of
vehicles.
• Medium
Duty
Vehicles:
Are
used
in
a
variety
of
roles,
mostly
commercial,
and
are
typically
rated
between
8500
lbs.
and
14,000
lbs.
gross
vehicle
weight.
• Heavy
Duty
Vehicles
and
Trucks:
Are
large
commercial
vehicles
rated
at
over
14,000
lbs.
gross
vehicle
weight.
• Off-­‐Road:
This
term
refers
to
specialty
vehicles
that
are
not
intended
for
highway
use.
The
other
three
classifica.ons
all
represent
“on-­‐road”
vehicles
that
are
intended
to
travel
on
highways
and
streets
with
other
traffic.
Off-­‐road
vehicles
are
typically
special
commercial
and
industrial
vehicles
like
construc.on
or
mining
equipment.
They
are
regulated
separately
from
on-­‐road
vehicles.
2

3. In
addi.on
to
these
broad
classifica.ons
that
are
used
by
the
states
and
the
federal
government,
more
specific
classifica.ons
exist
within
these
broad
categories.
These
more
specific
classifica.ons
are
usually
based
on
engine
displacement
(size
or
capacity
of
the
cylinders)
and
engine
use.
For
example,
one
classifica.on
might
be
14
liter
and
larger
engines
for
heavy-­‐duty,
over-­‐the-­‐road
tractors
(typical
eighteen
wheel
tractor-­‐trailer
rig).
Natural
gas
vehicles
(NGV’s)
must
meet
and
adhere
to
regula.ons
and
standards
issued
or
used
by
the
federal
government,
na.onal
safety
bodies,
state
governments,
and
the
insurance
industry.
The
rules
vary
by
classifica.on.
Federal
and
National
Regulations
General
EPA
Regulations
The
Environmental
Protec.on
Agency
(EPA)
became
the
chief
federal
regulatory
body
with
jurisdic.on
over
engine
technology
and
fuel
by
virtue
of
its
role
in
the
1973
Clean
Air
Act
(Act).
The
Act
established
the
EPA
as
the
expert
agency
to
regulate
vehicle
and
engine
emissions
for
the
purpose
of
reducing
pollutants
like
sulfur
dioxide,
nitrous
oxide
(NOx),
lead,
and
par.culate
maer.
In
1973,
the
EPA
established
goals
and
standards
for
a
list
of
pollutants
and
forced
the
automo.ve
industry
to
adopt
various
technologies
to
decrease
emissions.
Among
these
were
the
advent
of
unleaded
gasoline
and
the
mandatory
use
of
cataly.c
converters.
Since
1973,
the
EPA
has
modified
its
exis.ng
standards
and
added
new
ones
in
order
to
con.nually
decrease
emissions
of
harmful
substances,
making
its
automo.ve
emissions
regula.ons
arguably
the
most
stringent
in
the
world.
It
has
also
required
that
all
engine
and
air
quality
technology
on
vehicles
meet
its
emission
standards.
All
vehicle
engines
(and
other
internal
combus.on
engines)
are
governed
by
one
of
the
EPA’s
vehicle
regulatory
regimes
and
must
adhere
to
its
specific
set
of
regula.ons.
All
engines
in
general
public
or
commercial
use
must
be
cer.fied
to
meet
these
standards,
and
no
changes
to
those
engines
may
be
made
without
EPA
approval
and
cer.fica.on
to
meet
emission
standards.
Otherwise,
the
modifica.ons
are
deemed
to
be
“tampering”.
Tampered
vehicles
may
not
be
sold
or
used
legally
in
the
United
States.
All
vehicles
must
have
EPA
cer.fica.on
to
operate
or
be
sold.
In
1997,
the
EPA
altered
its
cer.fica.on
policies
to
specifically
address
alterna.ve
fuels
and
the
new
engine
technologies
that
they
created.
The
purpose
was
to
encourage
the
use
of
alterna.ve
fuels
in
vehicles
that
held
the
promise
of
further
emissions
reduc.ons.
This
was
par.cularly
important
at
that
.me
as
the
EPA
began
to
consider
the
effects
of
carbon
dioxide
emissions
on
global
warming,
based
on
the
United
Na.ons
climate
studies
which
had
just
been
published.
Included
in
the
group
of
alterna.ve
fuels,
along
with
ethanol,
bio-­‐diesel,
other
bio-­‐fuels,
and
propane,
was
natural
gas.
At
the
.me,
it
was
not
seen
as
a
par.cularly
viable
fuel,
and
there
were
no
specific
parameters
included
in
the
regula.ons
for
natural
gas
use
or
NGV’s.
All
fuels
essen.ally
followed
the
same
set
of
regula.ons.
The
1997
regula.ons
spelled
out
a
cer.fica.on
process
for
alterna.ve
fuels.
They
reinforced
the
need
for
federal
approval
and
s.ll
prohibited
“tampering”
with
any
engine
to
alter
it
to
use
alterna.ve
fuels.
The
EPA
defined
tampering
as
any
modifica.on
or
altera.on
to
the
engine
that
might
change
its
performance,
behavior,
or
emissions
output
without
proper
EPA
cer.fica.on
or
verifica.on
that
this
was
not
the
case.
The
regula.ons
reiterated
prohibi.ons
against
tampering,
and
viola.ons
of
tampering
3

4. rules
can
result
in
substan.al
fines
and
other
penal.es.
Based
on
the
construc.on
of
the
regula.ons,
it
appears
that
any
par.cular
modifica.on
to
any
par.cular
engine
must
be
cer.fied
by
the
EPA
through
its
tes.ng
procedures
to
be
legal
for
use
on
roads
and
to
prevent
an.-­‐tampering
enforcement
ac.ons.
State
motor
vehicle
departments
were
charged
with
iden.fying
instances
of
tampering
through
their
vehicle
inspec.ons
processes.
Some
excep.ons
exist
to
these
regula.ons,
including
vehicles
and
engines
classified
for
“off-­‐road”
use,
which
were
not
intended
for
opera.on
on
highways.
By
defini.on,
any
type
of
conversion
to
natural
gas
use
on
an
exis.ng
engine
would
qualify
as
tampering,
if
the
conversion
were
not
cer.fied
for
that
par.cular
engine.
All
new
NGV’s
would
of
necessity
have
to
be
cer.fied
by
EPA
in
order
to
be
approved
for
sale
in
the
United
States,
and
cer.fied
by
CARB
in
states
that
adopted
CARB
emissions
regula.ons.
The
cer.fica.on
requirements
consist
of
tes.ng
on
the
engine
or
altered
or
converted
engine
performed
by
a
laboratory
that
can
perform
all
or
some
of
the
required
exhaust
and
evapora.ve
emissions
tes.ng
required
by
the
EPA.
The
EPA
maintains
a
list
of
laboratories
that
can
perform
all
or
part
of
the
tes.ng,
but
does
not
endorse
or
approve
test
laboratories.
EPA
may
perform
confirmatory
tes.ng
at
its
own
expense.
Specific
tes.ng
procedures
depend
on
the
type
of
vehicle:
light
duty,
medium
duty,
heavy
duty,
off-­‐road,
etc.
In
general,
the
tes.ng
regimes
consist
of
specific
cycles
of
engine
loading
and
simultaneous
emissions
tes.ng.
For
on-­‐road
applica.ons,
the
tests
are
done
on
dynamometers
to
ensure
that
condi.ons
and
engine
loading
are
the
same
for
each
class
of
vehicles.
Hence,
emissions
from
vehicles
in
the
same
class
can
be
directly
compared
to
each
other
and
emission
standards
developed
for
that
class
as
a
whole.
Typically,
this
tes.ng
requires
over
1000
hours
of
dynamometer
tes.ng
as
reported
by
various
sources.
There
are
also
some
other
types
of
mechanical
and
chemical
tes.ng
that
are
incorporated
with
these
engine
loading
tests.
Thus,
cer.fica.on
requires
a
commitment
to
extensive
tes.ng.
Auto
and
engine
manufacturers
and
OEM’s
already
conform
to
this
system
with
each
new
product.
In
2011,
the
EPA
announced
that
it
would
streamline
its
regula.ons
with
regard
to
alterna.ve
fuel
conversions
on
exis.ng
vehicles,
in
par.cular
for
natural
gas
vehicles.
Up
to
this
point,
the
EPA
had
allowed
for
cer.fica.on
of
these
conversions
or
modifica.ons,
but
treated
them
in
the
same
way
as
exis.ng
vehicles
and
engines.
The
EPA
did
not
adopt
any
guidelines
or
default
posi.ons
that
were
based
on
the
theore.cal
expecta.on
that
natural
gas
and
some
other
alterna.ves
were
generally
cleaner
burning
fuels
and
would
likely
produce
fewer
emissions
when
introduced
into
engines.
The
EPA
placed
the
burden
of
proof
on
the
manufacturers,
requiring
them
to
show
emissions
met
standards
in
the
engine
loading
test
regimes
for
each
class
of
vehicle.
This
made
the
process
cumbersome
and
resulted
in
few
conversions
or
new
engines
being
cer.fied
for
any
alterna.ve
fuel.
This
included
natural
gas,
despite
the
existence
and
history
of
opera.on
of
proven
technology.
The
new,
streamlined
regula.ons
took
effect
in
2012.
The
primary
change
reported
was
to
classify
conversions
based
on
the
vehicle
age
and
apply
reduced
standards
for
cer.fica.on
to
older
vehicles.
The
age
based
categories
are:
• New:
vehicles
which
are
less
than
two
years
old.
• Intermediate:
vehicles
which
are
within
their
service
lives
but
more
than
two
years
old.
4

5. • Outside
Useful
Life:
vehicles
that
are
beyond
their
official
es.mated
service
lives.
Service
lives
are
reported
by
class
of
vehicle
and
engine
(light
duty
gasoline,
medium
duty
diesel,
etc.).
These
are
set
based
on
age
or
usage
(mileage
or
hours).
A
vehicle’s
service
life
is
typically
around
ten
years
at
average
use
for
the
class
(some
are
variously
reported
as
eight,
eleven,
or
twelve
years,
but
most
are
ten).
Thus,
to
use
the
streamlined
regula.ons
for
vehicles
of
moderate
age
(less
than
ten
years),
substan.ally
higher
use
than
average
for
the
class
is
required.
The
purpose
of
this
regula.on
is
to
reduce
the
amount
of
repor.ng
and
cer.fica.on
tes.ng
that
is
required
to
avoid
tampering
prohibi.ons,
par.cularly
with
older
vehicles
that
may
have
increased
emissions
anyway
due
to
age
and
wear.
This
may
signal
that
the
EPA
is
willing
to
accept
the
premise
that
natural
gas
will,
in
most
cases,
reduce
emissions
of
currently
regulated
substances
and
carbon
dioxide,
and
should
become
the
general
expecta.on
when
incorpora.ng
natural
gas
as
a
fuel.
The
new
regulatory
structure
is:
• New:
same
cer.fica.on
requirements
as
before.
• Intermediate:
reduced
amount
of
tes.ng
for
cer.fica.on.
However,
this
reduc.on
has
not
been
set,
and
no
exact
set
of
tes.ng
regula.ons,
procedures,
or
standards
are
in
place.
Apparently,
the
EPA
is
reviewing
any
submissions
in
this
category
on
a
case-­‐by-­‐case
basis
(if
any
have
been
submied
at
this
point)
to
determine
what
will
be
required
for
cer.fica.on.
• Outside
Useful
Life:
replacing
the
engine
tes.ng
regime
with
emissions
repor.ng
from
a
laboratory
or
operator
based
on
actual
vehicle
use.
Although
the
new
regulatory
procedure
establishes
a
streamlined
method
of
cer.fying
conversions
for
older
vehicles,
the
EPA
has
not
yet
clarified
the
tes.ng
procedures
for
each
age
classifica.on
under
the
new
regula.ons.
It
appears
that
both
regulators
and
manufacturers
are
confused
as
to
what
must
be
done
to
actually
achieve
cer.fica.on
for
a
conversion
of
an
older
vehicle
engine
system.
By
the
middle
of
2012
only
a
few
new
conversions
or
engines
had
been
cer.fied.
However,
for
conversion
on
vehicles
beyond
their
useful
lives,
the
EPA
has
been
willing
to
grant
waivers
for
par.cular
conversions
and
applica.ons
with
a
minimum
of
repor.ng
and
tes.ng.
Obtaining
these
types
of
waivers
may
be
highly
dependent
upon
the
situa.on:
engine,
age,
applica.on,
installer,
etc.
Other
Programs
and
Regulations
by
the
EPA
Another
category
to
which
different
standards
are
applied
is
vehicles
intended
for
Off-­‐Road
use.
These
are
primarily
vehicles
with
specialized
commercial,
industrial,
or
other
applica.ons,
for
example,
a
large
dump
truck
that
strictly
operates
in
a
quarry
or
open
pit
mine.
These
vehicles
and
engine
systems
are
evaluated
based
on
their
applica.on
or
use
profile.
Different
standards
for
emissions
apply
to
different
situa.ons,
but
most
must
s.ll
meet
some
regulatory
standards.
However
the
tes.ng
regimes
are
different
from
on-­‐road
vehicles.
This
afforded
the
EPA
the
ability
to
concentrate
its
regulatory
resources
on
classifica.ons
where
the
greatest
poten.al
for
improvement
lay.
Much
of
the
tes.ng
in
the
off-­‐road
category
is
done
through
repor.ng
from
independent
laboratories
or
the
operators.
Most
of
the
.me,
it
is
based
on
emissions
data
from
the
field.
The
Pennsylvania
Department
of
Environmental
Protec.on
5

6. (PADEP)
noted
that
standards
promulgated
for
non-­‐road
vehicles
and
engines
have
trailed
equivalent
standards
for
highway
vehicles
in
.me
by
about
four
years
because
the
popula.on
and
use
of
non-­‐road
engines
and
vehicles
is
less
than
highway
vehicles.
The
PADEP
also
noted
that
the
EPA
will
likely
require
non-­‐road
vehicles
and
engines
to
meet
cer.fica.on
standards
comparable
to
highway
vehicles
in
the
future.
In
terms
of
natural
gas
or
other
alterna.ve
fuel
conversions,
this
group
has
simpler
requirements.
To
cer.fy
a
conversion,
the
operator
or
manufacturer
must
submit
data
that
indicate
that
the
conversion
meets
the
applicable
standard
for
the
par.cular
off-­‐road
use
and
has
as
good
or
beer
emissions
profile
than
the
unconverted
system.
This
data
can
be
based
on
actual
use
or
specific
dynamometer
type
tes.ng.
The
EPA
states
a
preference
for
laboratory
gathered
results
over
self-­‐reported
ones,
but
is
open
to
accep.ng
either.
However,
the
regula.ons
imply
that
the
EPA
has
discre.on
in
accep.ng
or
rejec.ng
them
for
the
cer.fica.on.
The
EPA
would
also
seem
to
have
the
power
to
require
addi.onal
and
different
tes.ng
or
repor.ng
as
a
condi.on
of
cer.fica.on,
so
the
path
to
acceptance
of
off-­‐road
conversions
is
not
necessarily
clear.
No
sta.s.cs
were
reported
on
how
many
systems
have
been
approved
or
waivers
granted.
Another
program
that
may
provide
a
pathway
to
cer.fica.on
or
acceptance
of
natural
gas
conversion
is
the
Na.onal
Clean
Diesel
Campaign
(NCDC).
The
purpose
of
this
program
is
to
reduce
the
pollutants
associated
with
light
to
heavy
diesel
engine
use.
The
program
covers
a
broad
spectrum
of
issues
rela.ng
to
diesel
use
on
the
highway,
off-­‐road,
and
in
other
areas
such
as
rail
locomo.ves.
It
includes
programs
and
projects
related
to
policy,
strategy,
use,
fuel,
and
other
technology.
Tradi.onal
pollutants
of
concern
with
diesel
use
such
as
par.culate
maer,
sulfur,
and
nitrogen
oxides
are
listed,
but
the
program
has
been
updated
to
also
include
greenhouse
gases.
Natural
gas
would
seem
to
fit
the
EPA
defini.on
for
“cleaner
burning
fuels”
by
reducing
most
of
these
emissions
when
used,
but
it
is
not
men.oned.
There
is
also
no
men.on
of
natural
gas
conversion
technology
in
the
EPA’s
SmartWay
Technology
Program
or
the
technology
sec.on
of
the
NCDC
website,
which
list
technological
developments
to
reduce
diesel
pollutants.
At
present
there
seem
to
be
no
reports
of
natural
gas
technology
being
accepted
or
cer.fied
under
this
program.
Other
alterna.ve
technologies
such
as
hybrids
have
been
reported,
so
this
program
may
provide
a
viable
means
of
introducing
natural
gas
conversions
into
the
diesel
market,
poten.ally
with
more
straight-­‐forward
regula.ons
or
ones
that
beer
fit
NGV’s.
Another
area
where
introduc.on
might
be
possible
is
under
fuel
addi.ves.
The
EPA
does
not
regulate
to
any
great
degree
fuel
addi.ves
that
are
composed
solely
of
hydrogen
and
carbon.
Since
methane
(the
chief
component
of
natural
gas)
is
made
up
only
of
carbon
and
hydrogen,
it
would
seem
to
qualify
as
a
rela.vely
regula.on
free
fuel
addi.ve.
Hence,
some
Venturi
systems
for
natural
gas
delivery
to
engines
might
qualify.
However,
discussions
on
this
rule
seem
to
imply
that
there
is
a
limit
to
the
amount
of
fuel
addi.ve
that
can
be
introduced
before
it
is
considered
part
of
the
fuel
and
regulated
by
other
means.
There
is
also
no
discussion
as
to
whether
or
not
adding
systems
that
deliver
addi.ves
to
the
engine
cons.tutes
tampering.
EPA
Testing
and
Costs
6

7. The
EPA
outlined
its
tes.ng
procedures
and
costs
or
amounts
that
were
recoverable
from
manufacturers
or
OEM’s
looking
to
cer.fy
systems
in
2006
(based
on
rule-­‐makings
in
2002
and
2004).
These
costs
are
described
in
detail
in
a
memorandum
in
the
Federal
Register
(available
at
69
Federal
Register
26222,
or
at
hp://www.gpo.gov/fdsys/pkg/FR-­‐2004-­‐05-­‐11/pdf/04-­‐10338.pdf).
The
costs
are
based
on
the
type
of
engine
system
and
vehicle,
the
number
in
service,
and
other
factors.
Based
on
the
tables
in
the
above
referenced
Federal
Register
no.ce,
the
reported
costs
for
cer.fying
systems
range
from
$300,000
to
$3,000,000.
However,
various
reports
of
actual
costs
place
the
range
between
$200,000
and
$1,000,000.
These
are
s.ll
significant
costs
for
smaller
volume
applica.ons
of
engine
technology,
like
natural
gas
conversions.
While
a
Toyota
Camry’s
price
will
be
increased
only
a
few
dollars
per
vehicle
due
to
EPA
cer.fica.on
tes.ng,
the
same
tes.ng
might
add
$500
or
$1000
to
the
price
of
a
natural
gas
conversion
kit
with
the
poten.al
for
much
more
limited
sales.
To
address
these
cost
issues,
the
EPA
does
allow
fuel
converters
to
aggregate
engine
families
or
OEM
test
groups
and
test
for
cer.fica.on
over
the
en.re
group.
However,
prior
EPA
evalua.on
and
approval
of
the
combina.on
is
required.
The
combina.ons
would
allow
the
same
tes.ng
to
be
applied
to
several
engine
systems
at
once,
reducing
cost.
The
EPA
does
place
a
number
of
condi.ons
on
these
combina.ons,
including:
• They
are
similar
in
make
and
model
year.
• Engine
displacements
are
rela.vely
close
(<15%
apart).
• The
engine
configura.on,
design,
and
pistons
are
the
same.
• The
use
classifica.on
is
the
same
(light
duty,
medium
duty,
etc.).
• The
most
stringent
standards
of
any
part
of
the
group
are
met
by
all
components
of
the
group.
• Combus.on
cycles
and
engine
controls
are
the
same.
• They
all
have
the
same
method
of
air
aspira.on.
The
restric.ons
are
described
in
detail
at:
hp://iaspub.epa.gov/otaqpub/display_file.jsp?
docid=23319&flag=1
and
hp://iaspub.epa.gov/otaqpub/display_file.jsp?docid=23319&flag=1
From
the
lis.ng
of
approved
natural
gas
conversions,
it
appears
that
this
has
been
done
in
only
a
few
cases.
Other
National
Regulations
and
Standards
In
addi.on
to
the
EPA
emissions
regula.ons,
several
other
na.onally
based
standards
apply
specifically
to
natural
gas
conversions.
All
converted
vehicles
must
s.ll
meet
all
safety
requirements
used
by
the
automo.ve
industry
and
na.onal
and
state
transporta.on
authori.es.
For
the
most
part,
natural
gas
conversions
do
not
affect
the
structural
integrity
or
crash-­‐worthiness
of
the
car,
so
the
bulk
of
these
regula.ons
pertain
to
the
vehicle
and
not
the
fuel
system.
There
should
be
no
problem
for
conversions
mee.ng
these
regula.ons
and
standards
if
the
original
vehicles
did
in
the
first
place.
7

8. There
are
a
few
regula.ons
and
standards
that
do
apply
specifically
to
natural
gas
conversions.
The
most
important
ones
are
the
standards
for
the
storage
tanks
or
pressure
vessels
that
hold
the
natural
gas.
Because
the
gas
is
under
pressure
and
is
flammable,
the
vessels
must
meet
accepted
safety
standards
in
these
areas.
The
two
most
important
are
ANSI
NGV2
and
FMVSS
304.
The
ANSI
NGV2
standard
ensures
the
safety
of
gas
cylinders
and
the
FMVSS
304
standard
is
used
by
OEM’s
to
ensure
that
their
components
meet
the
same
safety
standards
as
other
vehicle
components.
A
related
standard
is
ISO
11439,
which
is
a
more
comprehensive
standard
for
gas
cylinders.
Mee.ng
it
does
not,
however,
ensure
that
the
cylinders
can
be
used
in
vehicles.
NGV
conversions
should
meet
both
the
ANSI
NGV2
and
FMVSS
304
standards.
In
addi.on
to
the
requirements
for
gas
cylinders,
conversion
systems
must
also
meet
the
NFPA-­‐52
standard.
This
standard
is
promulgated
by
the
Na3onal
Fire
Preven3on
Associa3on
(NFPA)
and
is
designed
to
ensure
that
vehicle
components
meet
an
appropriate
level
of
fire
safety.
NFPA
is
a
subsidiary
of
ANSI,
and
most
Society
of
Automo.ve
Engineers
(SAE)
cer.fied
mechanics
should
be
familiar
with
the
standard
and
how
it
is
met.
Much
of
this
regula.on
concerns
the
installa.on
of
the
conversion.
It
also
relates
to
basic
design
issues
that
contribute
to
fire
protec.on.
Installa.on
is
also
a
regulatory
issue.
The
EPA
specifies
that
cer.fied
systems
must
also
have
cer.fied
installa.ons
in
order
to
be
valid.
In
prac.ce
there
is
no
system
run
by
the
EPA
to
ensure
installers
have
creden.als
for
cer.fica.on.
If
cer.fied
systems
have
been
installed
according
to
the
direc.ons
of
the
manufacturer,
they
are,
for
all
intents
and
purposes,
considered
properly
installed
and
not
tampering.
The
rules
governing
proper
installa.on
are
laid
out
by
the
SAE
and
the
OEM’s
and
other
manufacturing
organiza.ons.
A
list
of
other
important
regula.ons
and
advisories
can
be
found
at:
hp://www.nexgenfueling.com/t_codes.html
So
far,
manufacturers
offer
few
conversions
that
have
been
cer.fied
by
the
EPA
and
approved
for
use
in
on-­‐road
vehicles
within
their
useful
lives,
so
there
is
lile
data
on
how
these
other
regula.ons
have
been
met.
Up
to
this
point,
there
have
been
no
reports
of
widespread
failures
or
non-­‐compliance
with
automo.ve,
gas
storage,
or
fire
preven.on
standards.
Most
of
the
installa.ons
have
been
with
vehicles
classified
under
off-­‐road
use
or
beyond
their
useful
lives.
With
respect
to
these
vehicles,
lile
public
data
is
available
on
performance,
failure,
or
issues
of
compliance.
Private
data
likely
does
exist
but
is
difficult
to
find
or
not
widely
available.
Since
there
are
no
reports
of
widespread
failure
or
difficulty,
it
can
be
assumed
that
the
conversions
or
system
installa.ons
with
these
vehicles
has
been
largely
sa.sfactory.
State
Regulations
Sec.on
177
of
the
Clean
Air
Act
requires
that
states
adopt
one
of
two
emissions
regimes
for
new
cars:
the
federal
regula.ons
or
those
used
in
California
and
promulgated
by
CARB.
States
cannot
require
8

9. vehicles
to
meet
regula.ons
that
differ
from
the
federal
or
CARB
standards.
Thus,
the
California
regula.ons
are
of
par.cular
note.
CARB
The
California
Air
Resource
Board,
or
CARB,
was
designated
as
the
state’s
agency
to
regulate
vehicle
emissions.
California
was
granted
a
waiver
by
the
EPA
to
develop
its
own
regula.ons,
as
long
as
they
met
certain
basic
standards
demanded
by
the
EPA.
California
was
eager
to
impose
regula.ons
on
a
quicker
.me
table
to
address
specific
issues
facing
the
state.
These
primarily
concerned
the
air
quality
and
smog
in
Southern
California
communi.es,
the
preserva.on
of
the
state’s
natural
resources,
and
the
preven.on
of
future
problems
in
other
metropolitan
areas.
Growth
and
significant
automobile
use
in
the
state
prompted
a
more
comprehensive
and
determined
approach
than
in
other
states
and
at
the
EPA,
where
Congressional
oversight
and
na.onal
priori.es
dictated
a
more
measured
approach.
Using
the
waiver,
California
produced
a
set
of
regula.ons
on
its
own
that
were
more
stringent
than
exis.ng
and
proposed
EPA
emissions
regula.ons.
As
a
result,
other
states
were
given
the
op.on
of
adop.ng
the
CARB
standards
or
the
EPA
standards
as
the
basis
for
their
emissions
regula.ons.
Fourteen
states,
including
Pennsylvania,
have
adopted
the
CARB
standards,
at
least
in
some
form.
CARB
requires
cer.fica.on
of
vehicles
and
engine
systems
in
much
the
same
manner
as
the
EPA.
As
with
the
EPA,
there
are
excep.ons
for
off-­‐road
uses
and
applica.ons
that,
at
the
beginning
of
2012,
only
require
repor.ng
of
emissions
rather
than
a
formal
cer.fica.on
process.
CARB
also
requires
alterna.ve
fuel
conversions
to
follow
the
same
cer.fica.on
process
as
engines
and
related
technology.
The
CARB
regula.ons
have
not
been
streamlined,
so
there
are
no
limited
regulatory
or
cer.fica.on
regimes
based
on
the
age
of
the
vehicle
or
system.
Hence,
CARB
cer.fica.on
will
be
harder
to
achieve
in
some
circumstances
for
alterna.ve
fuel
conversions.
The
costs
for
CARB
cer.fica.on
are
comparable
to
EPA
cer.fica.on,
if
somewhat
higher.
Generally,
mee.ng
the
CARB
standards
also
means
mee.ng
the
EPA
standards,
so
the
EPA
usually
accepts
CARB
cer.fica.on
as
a
basis
for
EPA
cer.fica.on.
This
is
part
of
the
working
agreement
between
EPA
and
California.
However,
there
appears
to
be
some
increase
in
cost
to
obtain
both
the
EPA
and
CARB
cer.fica.ons,
even
under
a
consolidated
tes.ng
regime.
Cost
reports
indicate
that
this
amounts
to
a
25%
to
35%
increase
in
cost.
This
means
that
full
cer.fica.on
costs
may
range
from
$300,000
to
$1,400,000
for
conversions
or
new
engines.
The
likely
reason
for
this
is
that
CARB
requires
aging
emissions
controls
for
the
life
of
the
vehicle,
which
would
add
to
tes.ng
and
development
costs.
Pennsylvania
The
Commonwealth
of
Pennsylvania
adopted
the
CARB
standards
in
2004
for
heavy
duty
trucks
(beginning
with
the
2005
model
year),
defined
as
vehicles
rated
at
over
14,000
lbs.
gross
vehicle
weight.
Passenger
cars
and
light
duty
trucks,
defined
as
vehicles
rated
below
8500
lbs.
gross
vehicle
weight,
were
brought
under
CARB
rules
in
2006
(beginning
with
the
2008
model
year).
Pennsylvania
does
list
a
number
of
excep.ons
to
the
CARB
standards,
based
on
off-­‐road
use,
emergency
vehicles,
military
vehicles,
and
other
special
circumstances,
which
are
iden.cal
to
exemp.ons
allowed
by
CARB.
In
short,
vehicles
rated
below
8500
lbs.
gross
vehicle
weight
or
above
14,000
lbs.
gross
vehicle
weight
must
meet
CARB
standards.
All
other
vehicles
must
meet
federal
emissions
standards
including
all
alterna.ve
fuel
9

10. conversions
and
related
modifica.ons.
In
Pennsylvania
CARB
standards
apply
to
new
vehicles.
Pennsylvania
defined
“new”
vehicles
as
those
with
less
than
7500
miles
on
the
odometer.
Vehicles
with
more
mileage
are
covered
under
EPA
regula.ons
instead.
The
regula.ons
regarding
Pennsylvania
emissions
are
found
in
Title
25
Chapter
126,
Subchapter
D
(light
duty
vehicles)
and
Subchapter
E
(heavy
duty
vehicles).
Late
in
2011,
Pennsylvania
developed
a
policy
document
to
encourage
more
alterna.ve
fuel
conversions.
This
was
done
in
response
to
public
interest
in
natural
gas
vehicles,
prompted
by
par.cularly
low
local
pricing
for
natural
gas
as
a
result
of
the
Marcellus
Shale
explora.on
and
extrac.on.
In
addi.on,
Pennsylvania
did
not
adopt
13
CCR
(California
Code
of
Regula.ons)
§2030,
which
relates
to
aVermarket
conversion
systems
for
alterna.ve
fuels.
As
a
result,
PA
DEP
determined
that
aVermarket
natural
gas
conversion
kits
for
light
duty
trucks
and
cars
must
have
either
CARB
or
EPA
cer.fica.on.
Therefore,
a
vehicle
conversion
would
be
valid
if
it
was
cer.fied
at
EPA
and
not
by
CARB
or
vice
versa.
This
was
intended
to
open
the
market
to
more
conversion
kits
and
engine
technology
whose
manufacturers
may
not
have
had
the
funds
to
cer.fy
under
both
systems.
Heavy
duty
vehicles
operate
under
similar
regula.ons:
new
vehicles
require
CARB
systems
and
those
with
over
7500
miles
require
EPA
or
CARB.
For
medium
duty
vehicles,
there
are
presently
no
specific
regula.ons,
so
only
EPA
cer.fica.on
is
required.
All
newly
.tled
heavy-­‐duty
and
light-­‐duty
vehicles
in
Pennsylvania
must
be
CARB
cer.fied,
so
new
natural
gas
vehicles
will
need
to
be
CARB
cer.fied.
This
probably
poses
few
problems,
since
new
natural
gas
vehicles
will
generally
come
from
OEM’s
that
must
cer.fy
the
vehicles
in
order
to
sell
them.
Conversion
kits
for
vehicles
with
over
7500
miles
may
be
either
CARB
or
EPA
cer.fied.
In
addi.on,
all
new
heavy-­‐duty
and
light-­‐duty
vehicles
.tled
in
Pennsylvania
must
have
CARB
cer.fica.on
for
their
engine
technology.
Cer.fica.on
is
required
for
new
vehicles
to
obtain
a
Pennsylvania
.tle
regardless
of
whether
or
not
they
were
previously
.tled
in
another
state.
This
also
applies
to
new
vehicles
that
have
been
converted
for
natural
gas
use;
they
must
obtain
a
new
.tle
and
meet
CARB
requirements.
While
emissions
regula.ons
are
handled
by
the
PA
DEP,
the
Pennsylvania
Department
of
Transporta.on
oversees
other
regula.ons
with
respect
to
motor
vehicles,
including
.tling
and
vehicle
safety
inspec.on.
Pennsylvania
does
not
typically
require
re-­‐.tling
for
vehicles
that
undergo
significant
engine
repair
or
change.
However,
alterna.ve
energy
conversions—including
those
for
natural
gas
systems—are
considered
significant
enough
so
as
to
cons.tute
a
re-­‐building
of
the
vehicle
and
require
a
new
.tle.
This
new
.tle
for
the
vehicle
is
referred
to
as
a
modified
.tle.
Owners
must
apply
for
permits
to
obtain
modified
.tles
(This
is
the
same
process
to
obtain
Reconstructed,
TheV,
and
other
types
of
specialty
.tles),
and
modified
.tle
vehicles
must
undergo
a
different
inspec.on
regime
than
regularly
.tled
vehicles.
Hence,
adherence
to
cer.fica.on
requirements
is
likely
to
be
more
of
an
issue
under
these
circumstances.
These
inspec.ons
must
also
be
done
at
inspec.ons
sta.ons
cer.fied
for
modified
vehicles,
and
only
a
frac.on
of
inspec.on
sta.ons
are
cer.fied.
New
vehicles
must
meet
CARB
standards,
and
older
vehicles
(as
previously
defined)
may
meet
EPA
or
CARB
standards
to
obtain
a
.tle.
There
are
no
reports
of
difficul.es
in
this
process
at
present,
but
issues
may
arise
as
more
conversions
are
made,
inspected,
and
.tled.
Pennsylvania
also
does
not
relax
.tling
requirements
with
age,
as
many
other
states
do,
so
most
PennDOT
.tling
regula.ons
will
fully
apply
to
any
vehicle
that
requires
one.
10

11. Titling
informa3on
is
available
at:
hp://www.dmv.state.pa.us/pdouorms/fact_sheets/Modified_Vehicle.pdf
and
hp://www.dmv.state.pa.us/pdouorms/mv_forms/mv-­‐426B.pdf
The
EPA
enforces
an.-­‐tampering
regula.ons,
but
states
are
responsible
for
enforcing
.tling
requirements,
including
CARB
cer.fica.on
and
obtaining
modified
.tles
for
converted
vehicles,
as
well
as
other
state
regula.ons
such
as
safety
and
emissions
inspec.ons.
States
have
tended
to
focus
on
required
individual
emissions
tes.ng
and
other
safety
inspec.on
issues.
For
the
most
part,
states
have
not
rigorously
checked
engine
modifica.ons
of
any
kind
against
EPA
and
CARB
cer.fica.ons.
Because
of
this,
uncer.fied
conversions
have
been
made
and
are
in
use
throughout
the
country.
Based
on
the
number
of
cer.fied
systems,
the
percentage
of
uncer.fied
conversions
is
probably
rela.vely
high.
Part
of
this
is
due
to
the
rarity
of
these
conversions,
par.cularly
with
respect
to
other
inspec.on
issues.
However,
as
natural
gas
and
other
alterna.ve
conversions
gain
popularity,
there
will
be
more
opportunity
for
enforcement,
and
it
will
become
a
more
significant
enforcement
issue.
With
media
and
public
aen.on
on
these
conversions,
some
states
have
already
issued
leers
and
memoranda
clarifying
their
posi.ons
and
direc.ng
enforcement
officers
to
obtain
cer.fica.on
documenta.on
on
conversions
and
altera.ons.
This
includes
Pennsylvania.
Therefore,
cer.fica.on
will
become
much
more
important
in
the
near
future.
Insurance
Regulation
In
addi.on
to
the
public
regula.on,
there
will
likely
be
some
private
regula.on
of
natural
gas
vehicles,
primarily
from
the
insurance
industry.
In
order
for
operators
to
use
natural
gas
vehicles,
especially
for
on-­‐road
use,
there
must
be
some
means
of
insuring
them
against
loss.
The
insurability
of
natural
gas
vehicles
depends
upon
the
risks
associated
with
their
use.
If
there
are
too
many
risks,
the
premiums
must
be
set
very
high
(if
at
all),
which
will
make
the
cost
of
opera.ng
a
natural
gas
vehicle
prohibi.ve.
At
present
there
is
very
lile
loss
data
available
for
natural
gas
vehicles.
Most
that
are
used
exist
in
fleets
in
limited
use.
As
a
consequence,
insurance
companies
will
have
to
make
es.mates
of
poten.al
risks
and
losses
in
order
to
assign
premiums.
At
this
.me,
few
if
any
insurance
companies
have
official
posi.ons
on
natural
gas
vehicles,
other
than
that
they
must
fall
within
the
normal
governing
regula.ons
on
safety,
emissions,
and
other
aspects
of
opera.on
(EPA,
DOT,
State,
and
other
applicable
laws
and
regula.ons).
It
is
likely
that
vehicle
conversions
that
are
not
cer.fied
under
the
EPA
and
CARB
are
not
insurable.
Likewise,
an
insurance
company
would
almost
certainly
require
that
other
standards
like
ANSI
NGV2
and
NFPA
52
be
met
to
make
an
NGV
insurable.
Beyond
that
and
absent
other
data
on
losses,
most
insurance
companies
would
rate
a
converted
vehicle
in
the
same
way
as
the
un-­‐converted
or
tradi.onal
fuel
(gasoline
or
diesel)
vehicle.
Some
may
not
wish
to
rate
or
insure
the
vehicles
at
all,
ci.ng
the
unknown
risks
associated
with
the
technology
as
far
as
losses
and
safety
concerns.
Since
most
natural
gas
vehicles
in
use
are
presently
part
of
fleets,
they
are
most
likely
insured
by
commercial
insurers.
These
insurers
typically
use
different
parameters
to
assess
risk
than
retail
insurers
and
can
be
more
flexible
in
the
types
of
assets
they
insure,
11

12. their
ra.ng
procedures,
and
risk
management.
Other
natural
gas
vehicles
are
classified
as
off-­‐road
use
and
would
be
insured
under
different
ra.ng
structures
that
primarily
take
into
account
the
special
circumstances
of
their
use,
or
they
might
not
be
insured
at
all.
On
the
other
hand,
insurance
companies
are
able
to
respond
much
more
quickly
to
changes
in
informa.on
than
regulatory
bodies,
which
require
some
level
of
consensus.
Insurance
companies
may
react
quickly
to
new
data
on
losses
and
change
ra.ngs
posi.vely
or
nega.vely
as
experience
demonstrates.
An
example
of
this
in
the
alterna.ve
vehicle
market
is
the
ra.ng
structures
for
hybrids
and
electric
cars,
which
are
currently
in
a
state
of
flux.
When
they
were
introduced,
these
cars
received
comparable
ra.ngs
to
other
cars
of
their
size.
As
.me
went
by,
and
insurers
gained
accident
and
use
data
on
these
cars,
and
new
risks
were
iden.fied
which
must
now
be
included
in
their
ra.ngs.
The
baeries
in
hybrids
and
electric
cars
were
prone
to
damage
in
certain
types
of
accidents.
Once
damaged
the
baeries
had
to
be
replaced—which
turned
out
to
be
an
expensive
proposi.on.
As
a
result,
a
higher
propor.on
of
these
vehicles
are
totaled
aVer
accidents
than
comparable
cars
with
only
internal
combus.on
engines.
Damaged
baeries
can
produce
and
leak
hydrogen
gas,
which
can
cause
fires
in
the
vehicles
and
damage
adjacent
property.
Insurers
are
now
trying
to
include
the
cost
of
these
extra
losses
in
the
premiums
for
these
types
of
cars.
The
same
may
ul.mately
be
true
for
natural
gas
vehicles.
Therefore,
it
is
possible
that
natural
gas
vehicle
ra.ngs
could
change
drama.cally
once
experience
with
them
has
iden.fied
all
of
the
risks,
and
operators
must
be
aware
of
this
possibility.
Conclusions
The
combina.on
of
EPA
and
CARB
regula.on
presents
OEM’s
and
manufacturers
of
natural
gas
engine
and
vehicle
technology
with
a
confusing
and
daun.ng
set
of
obstacles.
To
date,
only
a
few
natural
gas
solu.ons
have
been
approved
under
EPA
or
CARB
regula.ons
for
use
in
on-­‐road
circumstances.
Those
that
have
are
typically
the
more
popular
engines
makes
and
models
that
will
achieve
the
largest
market
penetra.ons.
Helping
to
drive
this
concentra.on
is
the
fact
that
most
natural
gas
vehicles,
new
or
converted,
are
part
of
vehicle
fleets,
which
are
usually
comprised
of
more
popular
makes
and
models.
Despite
the
small
number
of
approved
solu.ons,
there
are
a
fairly
large
number
of
manufacturers
making
products.
Most
adver.se
that
they
are
only
intended
for
off-­‐road
applica.ons
in
the
U.S.,
a
less
burdensome
alterna.ve
to
on-­‐road
cer.fica.on.
Many
are
also
installed,
par.cularly
with
heavier
duty
applica.ons,
on
vehicles
that
are
beyond
their
normal
service
lives,
for
which
waivers
from
cer.fica.on
are
easily
obtained.
For
most
of
the
manufacturing
companies,
the
bulk
of
their
sales
come
from
foreign
countries,
where
cer.fica.on
and
approval
regula.ons
are
typically
less
intensive,
depending
on
the
exact
country.
The
cost
and
complexity
of
cer.fica.on
will
likely
prevent
many
new
entrants
over
the
next
few
years,
as
manufacturers
concentrate
on
the
popular
models
and
niche
applica.ons.
This
situa.on
is
analogous
to
drug
regula.on,
where
drug
makers
concentrated
on
widespread
illnesses
and
afflic.ons
like
diabetes
and
ignored
diseases
with
smaller
popula.ons
because
the
chances
of
recouping
the
development
and
regulatory
costs
at
reasonable
sale
prices
were
much
beer
with
larger
markets.
The
bulk
of
the
market
in
the
U.S.
will
likely
be
with
conversions
of
older
vehicles
that
are
beyond
their
service
lives,
since
there
is
less
scru.ny
and
an
easier
regulatory
framework.
12

13. It
is
unlikely
that
this
situa.on
will
change
in
the
next
several
years.
The
current
year,
2012,
is
a
na.onal
elec.on
year
and
features
what
will
probably
be
two
widely
different
approaches
to
regula.ng
natural
gas
vehicles.
With
this
uncertainty,
it
is
unlikely
that
the
EPA
and
other
government
agencies
will
embark
on
any
substan.al
changes
in
policy
regarding
a
charged
topic
like
energy
use
and
consump.on.
The
regula.ons
will
probably
remain
the
same,
and
the
new
streamlined
versions
will
probably
not
be
clarified
un.l
2013
or
2014.
Furthermore,
should
the
elec.on
yield
a
President
and
Congressional
majori.es
more
sympathe.c
to
natural
gas
vehicle
use,
there
will
s.ll
undoubtedly
be
other
issues
of
higher
priority
to
address
in
2013,
puwng
off
any
reform
of
natural
gas
vehicle
technology
cer.fica.on
un.l
the
end
of
2013
or
2014.
Another
risk
is
that
regula.ons
could
become
more
stringent,
depending
on
poli.cal
direc.ons.
The
EPA
could
expand
the
number
of
compounds
that
it
currently
regulates
for
vehicle
emissions.
Of
par.cular
interest
to
companies
manufacturing
or
contempla.ng
using
NGV’s
is
unburned
methane.
Methane
is
a
potent
greenhouse
gas
and,
therefore,
may
become
a
target
of
regula.on.
Natural
gas
fuel
systems
and
engines
may
have
to
cer.fy
that
they
do
not
emit
significant
amounts
of
methane
from
opera.on.
These
facts
will
require
that
most
manufacturers
with
natural
gas
technology
work
with
an
OEM
or
strategic
partner
familiar
with
the
EPA
and
CARB
processes
for
engine
technology
or
remain
focused
on
off-­‐road
and
older
vehicles
for
conversion.
One
poten.al
bright
spot
is
that
industry
and
insurance
regula.on
may
quickly
adapt
to
this
market
and
set
the
standard
for
installa.ons.
Since
the
regula.ons
are
confusing
both
for
those
following
them
and
enforcing
them,
industrial
prac.ces
and
insurance
underwri.ng
may
begin
to
gain
weight
as
standards
and
influence
the
regulatory
interpreta.ons,
providing
an
organic
means
of
developing
a
posi.ve
regulatory
framework
to
develop
the
market
opportunity.
The
regulatory
factors
discussed
above
will
slow
and
probably
cap
the
penetra.on
of
natural
gas
solu.ons
in
transporta.on.
The
requirements
of
the
cer.fica.on
process
mean
that
most
manufacturers
will
sell
to
off-­‐road
niche
markets
in
the
U.S.
or
manufacture
for
fleets
and
popular
vehicle
types
while
pursuing
foreign
sales
in
La.n
America,
Poland,
and
other
places
that
are
developing
shale
gas
resources.
The
regula.ons
also
place
a
bias
on
new
vehicles
that
must
be
qualified
regardless
of
fuel
type.
This
will
favor
OEM’s
who
will
manufacture
natural
gas
vehicles
for
fleet
applica.ons
at
the
expense
of
conver.ng
exis.ng
vehicles
and
fleets.
For
the
near
future,
natural
gas
vehicles
will
remain
a
small
part
of
the
market
but
an
expanding
one,
despite
the
cost
savings
and
other
benefits
rela.ve
to
diesel
fuel
and
gasoline.
However,
if
this
limited
use
produces
savings,
beer
emissions,
and
the
poten.al
for
beer
energy
security,
public
pressure
will
likely
force
policy
to
more
readily
accommodate
natural
gas
vehicles,
and
more
op.ons
will
become
available.
This
will
allow
natural
gas
vehicles
to
expand
into
all
of
the
markets
where
their
use
makes
sense.
Paper
Authored
by:
The
Shale
Gas
Innova.on
&
Commercializa.on
Center
(www.sgicc.org)
Mr.
Brian
Krier,
Energy
Programs
Manager,
Ben
Franklin
Technology
Partners
of
Central
and
N.
PA
(CNP)
13

14. 115
Technology
Center
Building
University
Park,
PA
16802
For
ques.ons,
contact
Bill
Hall,
SGICC
Director
at
either
814-­‐933-­‐8203
or
billhall@psu.edu
References
EPA
regula.ons
on
alterna.ve
fuel
conversions:
hp://epa.gov/otaq/consumer/fuels/aluuels/
aluuels.htm
Na.onal
Clean
Diesel
Campaign:
hp://epa.gov/cleandiesel/index.htm
EPA
Guidance
to
fuel
converters:
hp://iaspub.epa.gov/otaqpub/display_file.jsp?docid=23319&flag=1
EPA
Vehicle
Fuel
Emissions
Lab:
hp://ofmpub.epa.gov/otaqpub/display_file.jsp?docid=26974&flag=1
Loca.on
of
Regula.ons
in
the
U.S.
Code:
42
USC
Sec
7522
(a)(3)
Natural
Gas
Vehicles
for
America
Trade
Group:
www.ngcv.org
Conversion
Kit
Resource:
www.skycng.com
California
Regula.ons:
www.arb.ca.gov
Pennsylvania
Clean
Vehicles
Program:
hp://www.dep.state.pa.us/dep/deputate/airwaste/aq/cars/
cleanvehicles.htm
Pennsylvania
Portal
for
Natural
Gas
Vehicles:
hp://www.portal.state.pa.us/portal/server.pt/
community/act_13/20789/natural_gas_vehicle_program/1157504
14