NGVAMERICA COMMENTS ON TEXAS NGV SAFETY INSPECTION REGULATION
Late last month, NGVAmerica submitted comments to the Texas Department of Public Safety. As we noted last month in this newsletter, Texas has proposed amending its safety inspection requirements for motor vehicles to also cover CNG cylinders. Under the proposed rules, NGV owners would have to provide proof that their cylinders comply with federal motor vehicles safety standards and have not exceeded their useful life. The new requirements were called for in legislation (HB 2035) enacted last year. Under the proposal, owners must provide proof from a certified inspector or installer. This proof must be presented to the persons conducting the state safety inspection. NGVAmerica’s supported the proposed regulations incorporation of CNG cylinders into the inspection process. We believe it is important that states begin to track NGVs operating in their state and to incorporate information on NGVs into the registration process. Where feasible, states should establish safety checks for such vehicles (not all states have safety inspection programs). The Texas regulations by requiring proof that the cylinders actually meet federal safety standards should help prevent the use of non-compliant cylinders, including cylinders that have not been approved to operate at pressures used in the U.S. as well as out-of-date cylinders. We offered comments on ways the regulations could be less intrusive—for instance some of the information regulators want to see can be obtained simply by looking at labels already found on the vehicles in the case of OEM vehicles. Moreover, a separate inspection by a certified inspector or installer should not be necessary if the OEM or aftermarket conversion company has already provided written verification to the customer.