A draft notification mandating crash test and an in-service conformity, among other things, for conversion of BS-VI vehicles to auto LPG and CNG are completely unviable and impractical, the Indian Auto LPG Coalition (IAC) has written to the Ministry of Road Transport and Highways.


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In a statement, IAC said, "it has through the letter expressed its disagreement on a range of issues in the draft notification on the conversion of BS-VI vehicles to auto LPG and CNG".


Some of the areas of concern in the draft notification are persisting with a limited period for the validity of type approval and mandating of crash test, IAC said "adding going ahead with such proposals would not only perpetuate the uneven playing field which has long persisted for the retrofitment players vis-a-vis the OEMs but also majorly compromise on the long-term environmental objectives of the government."


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IAC said the government must allow the validity of type approval for perpetuity. "Anything short of that raises the cost prohibitively, thereby deterring the conversion kit makers and hampering the general growth of the auto retrofitment market."


It has been estimated that getting a renewal every three years, as is the rule today, can cost as much as Rs 10 crore for a type approval/ retrofitment kit player, a huge disincentive for everyone in the value chain.


"The mandating of crash tests for the retrofitted vehicles is completely unviable and impractical and is unheard of for the aftermarket globally, including European norms", it said.


The draft norms have proposed in-service conformity, applicable after three years. "However, unlike in the case of new vehicles wherein the owners compulsorily have to visit the authorised workshop for servicing for at least four years since the day of purchase, it would be inconceivable to expect the owner of a retrofitted vehicle to return to the retrofitter."


"Given that the vehicle has already served almost half its life, the imposition of this rule and, more importantly, the implementation of it would not be practically feasible", IAC said.


IAC said, "it is perplexing as to why the draft notification proposes to raise the bar high when until now, for earlier BS Norms, a kit was considered fit for retro fitment in any vehicle within a CC range of 25% irrespective of the CC of the vehicle." The draft proposes 7% for vehicles up to 1500 cc and 5% above 1500 cc.


"While we welcome the government's intent to pave the way for the conversion of BS-VI vehicles to auto LPG and CNG variants, the proposals so far in the draft notification have been disappointing, to say the least. These proposals are clear and very disproportionately biased towards the OEMs and away from auto retrofitment and conversion kit players," said Suyash Gupta, Director General, IAC.


He said most of retrofitment and conversion kit players are MSMEs who have been badly hit over the years due to the OEM-oriented, one-sided policy of the regulations.


"It has been estimated that 20 years back, there were more than a score of Kit Type Approval holders. Today, that number has come down to 3 to 4, illustrating the severity of the hit that these small businesses have taken and continue to take."


The draft, he said, "does not serve the cause of the broader clean mobility, economy-ecology balance, and making available, inexpensive vehicular fuel to common people."


"For a country which has more than 30 crore on-road vehicles, one of the largest in the world and repeatedly ranked as one of the most polluted, a policy shift to cleaner alternatives cannot be put off anymore. The ministry must do an immediate rethink," he added.


IAC is the nodal body for the promotion of Auto LPG in India. Members of the Coalition include the oil sector PSUs, private auto LPG marketers, kit suppliers and equipment manufacturers.


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