Clean Fuel Fleet Program

Clean Fuel Fleet Program

Frequently Asked Questions

Q. What is a vehicle's emission certification standard?

A. Since the mid- 1970's, the Clean Air Act has required that all vehicles sold in the U.S. meet a federal emissions standard for three pollutants: hydrocarbons, carbon monoxide, and nitrogen oxides. U.S. EPA has been the agency in charge of enforcing the federal emissions certification program. With improved emission control technologies and cleaner fuel, these emission standards have become more stringent over time. The CFFP requires fleets to acquire lower-polluting vehicles certified to emissions standards that are more stringent than the standards in effect for the general vehicle population. Vehicles certified to the CFFP standards are over 70% cleaner than the vehicles certified to the current "base" federal standard.

Q. What are the CFFP emission standards?

A. The CFFP emission standards include four tiers of emission levels. These include the Low Emission Vehicle (LEV), Inherently Low Emission Vehicle (ILEV), Ultra-Low Emission Vehicle (ULEV) and the Zero Emission Vehicle (ZEV) standards. All four of these standards are progressively more stringent than the "base" standards applicable to the general vehicle population.

Q. Do I have to certify the vehicles for the CFFP?

A. No. The auto or engine manufacturers have to do the certifying through U.S. EPA's program. A vehicle/engine will already be certified to an emissions standard when it is available for sale, per federal law.

Q. Are conversions allowed in the program?

A. In lieu of acquiring a new vehicle, an existing conventional vehicle may be converted to operate with a clean fuel (e.g., natural gas, propane) for compliance of the program. The conversion system must also be certified to one of the federal low emission standards as does a new vehicle. Unlike original equipment manufacturer vehicles, conversions currently are not required to be certified to an emissions standard. Be sure that, for compliance of the CFFP, a conversion system is certified to one of the CFFP standards.

Q. I see that 30% of my light-duty vehicles that are "new to the fleet" must be clean fuel vehicles in model year 1999. What does "new to the fleet" mean?

A. The CFFP affects vehicles that are acquired for the fleet during a given model year. "New to the fleet" means acquiring either a new or used vehicle, provided the vehicle does not meet any of the exemption criteria. For a "used" vehicle, keep in mind that any vehicle manufactured in model year 1998 or earlier, prior to the effective date of the CFFP, is exempt and does not count as a vehicle that is "new to the fleet" to which the percentages are applied.

Q. What if I lease my vehicles, am I exempt?

A. No. Leased vehicles are equally subject to the requirements of the CFFP. It does not matter what arrangement you have in acquiring your vehicles, either through purchase or lease. The fact that you acquire vehicles for the fleet makes them subject to the CFFP, provided they are not exempt.

Q. What fuels are certified for the program?

A. This is a common source of confusion. Fuels are not certified to emissions standards, vehicles and engines are. A fleet subject to the CFFP has to acquire vehicles that are certified to one of the federal low emission standards (CFFP standards). The program is actually fuel-neutral. Any fuel, whether it be natural gas, propane, ethanol, electricity, gasoline, diesel, or hydrogen, is eligible to be used by the auto or engine manufacturer to certify the vehicle/engine to one of the CFFP standards.

Q. What is the difference between a "clean fuel vehicle" and an "alternative fuel vehicle?"

A. "Clean fuel vehicle" is a term pertaining to the CFFP. It is a vehicle that meets one of the four federal low emission certification standards. The fuel that that particular vehicle operates with in meeting a low emission standard is a "clean fuel." A clean fuel vehicle may operate with an alternative fuel, such as natural gas, propane, or ethanol, or a conventional fuel (e.g., gasoline or diesel). An alternative fuel vehicle is a vehicle that operates with an alternative fuel, in the true sense of the term, such as natural gas, propane, ethanol, or electricity. An alternative fuel vehicle does not use gasoline or diesel. In terms of the current federal requirements, an "alternative fuel vehicle" pertains to the U.S. Department of Energy's Energy Policy Act fleet program, which requires affected fleets to acquire alternative fuel vehicles.

Q. How can a gasoline or diesel vehicle be called a "clean fuel vehicle," aren't these fuels less clean than alternative fuels?

A. In general, the inherent properties of alternative fuels result in lower emissions than gasoline- or diesel-powered vehicles. But the Clean Air Act includes requirements, already in effect, that has resulted in cleaner-burning gasoline and diesel fuel, including the gasoline and diesel fuel sold in the Chicago area. These requirements have essentially narrowed the emissions gap between alternative and conventional fuels. In engineering a vehicle or engine to meet one of the CFFP standards, the manufacturer may rely more upon the cleaner-burning properties of a fuel and make few, if any, emission-related changes to the engine; make improvements to an engine's emission control components and rely less upon the emission reductions from the properties of the fuel; or a combination of both. The goal of the CFFP is to reduce emissions. Whether these emission reductions are a result of the type of fuel, advanced vehicle emission controls, or perhaps both is entirely up to the manufacturer in designing a vehicle/engine to meet the CFFP standards.

Q. Why are the words "clean fuel" in the title of the program if what I have to pay attention to is the emission certification standard when acquiring vehicles?

A. This is a fair question to ask. Perhaps a better name for the CFFP is the "Fleet Low Emission Vehicle" program. But in the context of the CFFP, a fuel is a "clean fuel" if it is used by the manufacturer to certify a vehicle or engine to one of the CFFP standards. For example, a pickup truck may meet a CFFP standard with fuel X but a larger delivery vehicle may not. In this case, fuel X is a "clean fuel" for only the pickup truck. In the CFFP, a fuel is not a "clean fuel" in general terms, but only on a vehicle-by-vehicle basis.

Q. How do I identify a "clean fuel vehicle" that would comply with the CFFP?

A. A vehicle or engine comes with an emissions label containing the emission standard. The emissions label is usually called the "Vehicle Emission Control Information" or "Important Vehicle Information" label. This label may contain the manufacturer logo and is typically located on the underside of the hood or on the cowling in front of the engine. Look for a phrase such as "This vehicle conforms to U.S. EPA regulations and applicable to Natural Gas fueled 1999 model year new ULEV and ILEV clean fuel fleet program light-duty trucks..." If you see at least one of the four CFFP emissions standards (e.g., ULEV, ILEV) and possibly the words "clean fuel fleet program" on the label, then you know this vehicle complies with the CFFP. The wording may differ by manufacturer, but should be fairly consistent overall. Check with your dealer, leasing company, or manufacturer fleets sales representative about verifying a vehicle's compliance with the CFFP.

Q. What should I do first if my fleet is subject to the program?

A. The Illinois EPA is accepting fleet registrations. To receive a registration form, please call Darwin Burkhart at the Illinois EPA at (217) 524-4343. Also, call Darwin if you have questions or are unsure if your fleet is covered by the program.

Q. Will there be any reports to file once the program is underway?

A. Fleet owners/operators subject to the program will have to turn in an annual report within 3 months after the end of a model year (by November 1 of each year). The Illinois EPA will provide registered fleets an annual report to complete closer to the end of the first model year subject to the CFFP (approx. Summer 1999). Also, forms will become available for fleets interested in setting up, accumulating, and marketing credits in the CFFP credit program.

Q. Where can I find the rules for the CFFP?

A. The Illinois CFFP rules are codified in 35 Ill. Adm. Code Part 241. You may contact Darwin Burkhart for a copy of the rules or any summaries.