November Question of the Month

Question of the Month: Which states have adopted the California Air Resources Board (CARB) aftermarket conversion certification requirements?

Answer: In the United States, all aftermarket conversion systems (except pure battery electric vehicles) must meet current applicable U.S. Environmental Protection Agency (EPA) standards. EPA instituted these standards to assure that a vehicle’s tailpipe emissions do not increase as a result of the conversion. For more information on EPA standards for vehicle and engine conversions, please refer to the EPA Alternative Fuel Conversion website (http://epa.gov/otaq/consumer/fuels/altfuels/altfuels.htm).

CARB has set its own standards for alternative fuel conversion systems, which are more stringent than those of EPA. Manufacturers that wish to sell aftermarket conversion systems for use in California must meet CARB standards and obtain approval from CARB. While EPA accepts all CARB certifications to meet their standards, EPA certificates of conformity and tampering exemptions are not required by CARB and cannot take the place of CARB certification.

In addition to impacting the sale and use of aftermarket conversion systems in California, the CARB conversion standards also impact some of the 13 other states that have adopted CARB’s overall motor vehicle emissions regulations. The table below shows the states that have adopted CARB’s vehicle emissions standards in whole or in part. It also indicates whether each state enforces EPA or CARB aftermarket conversion standards.

State	Conversion Standards Enforced
California	CARB
Connecticut	EPA
District of Columbia	EPA
Maine	EPA
Maryland	CARB
Massachusetts	EPA
New Jersey	CARB (but also accepts EPA)
New Mexico	EPA
New York	CARB
Oregon	EPA
Pennsylvania	CARB (but also accepts EPA)
Rhode Island	EPA
Vermont	EPA
Washington	EPA

For more information about CARB aftermarket conversion certification, please refer to the following resources:

·         CARB Alternative Fuel Retrofit Systems Program: http://www.arb.ca.gov/msprog/aftermkt/altfuel/altfuel.htm

o   This website links to a list of certified alternative fuel retrofit systems.

·         CARB Aftermarket Parts Database of Executive Orders:  http://www.arb.ca.gov/msprog/aftermkt/devices/amquery.php

o   This database includes information about conversion systems that have been granted exemptions to emissions control system-anti-tampering regulations by CARB.

Also refer to the following resources for information about the requirements in other states that enforce CARB conversion standards:

·         Maryland

o   Maryland Statutes, Environment Code 2-1101 through 2-1108 (http://mlis.state.md.us/)

·         New York

o   New York State Department of Environmental Conservation Regulations, Chapter III – Air Resources, Part 218 (http://www.dec.ny.gov/regs/2492.html)

·         New Jersey

o   State of New Jersey Department of Environmental Protection Memorandum on Aftermarket Conversion Systems for Alternative Fuels (see attached)

·         Pennsylvania

o   Pennsylvania Department of Environmental Protection, Bureau of Air Quality Policy on Clean Alternative Fuel Conversion Systems (http://files.dep.state.pa.us/AboutDEP/AboutDEPPortalFiles/RemarksAndTestimonies/NaturalGasVehicleConversionSystems/PCVConversionPolicyFinal.pdf)

For general information about conversion regulations, visit the Alternative Fuels Data Center Conversion Regulations page (http://www.afdc.energy.gov/vehicles/conversions_regulations.html). Also see the NGVAmerica Aftermarket Conversion Systems: EPA and CARB Regulations website (http://www.ngvc.org/gov_policy/fed_regs/fed_AfterMarket.html).

Clean Cities Technical Response Service Team

technicalresponse@icfi.com

800-254-6735