Excluded Engines From US EPA Emission Standards

[wrightkiller]

   Take a look and see what you think?



http://www.epa.gov/otaq/imports/forms/3520-21.pdf


Also look here on page 44


http://www.epa.gov/oms/regs/techamendments/nprmamendmentsfr.pdf

[rmchambers]

interesting.  The first document seems to have checkbox for any of our favorite engines. stationary engines.

I guess the Indians read this second section because the wording for that label we thought was a BS label is very much like that specified in subpara 1048.20

Without reading the whole thing (and going into a coma) it looks like that one exclusion is written for us.

Robert

[twombo]

I think that is that SCOTT has been trying to tell us. The operative word is "stationary". It makes all the difference in the world.  Don't underestimate the Indians, they have an even more tedious bunch of bureauocrats toi contend with than we do!

Mike

[rmchambers]

It makes sense.  Too bad Mike Montieth bailed out on us because of the two approaches to compliance I think the stickeroid one is easier and cheaper than the egr/catalyst/timing/etc route that Mike is going with his GM90's.  If you're exempt you're exempt, and these engines are stationary by their nature (and the 3 kiloton concrete plinth they require  ) so it wouldn't be hard to prove the stationary aspect of compliance.

Robert

[twombo]

I really admire Mike's efforts. I kind feel like he really got dumped on overly hard. Nervous critters or those feeing threatened can lash out pretty visciously.. I figure we are critters like the rest,  and not exceptions to the rule.

As someone who was associated with the federal govt bureaucracy for most of my adult life, I think that  if it is exempt now it will be grandfathered in under most any set of circumstances. Remember what the US  Constitution says about Ex Post Facto lawmakingAarticle 1 Section 8 as I recall ( (right up ther with Bills of attainders (whatever the hell  THAT is))!!!??

Besides, the under 19 Kw, stationary, class of engines is, I'm sure, a very, very, small subset of CI powerplants in service. The under 19 Kw non-road  mobile stuff is huge by comparison... How many small Kubota tractors do you know of?? A bunch eh? Statistically, we are a SMALL blip. Even rampant bureaucracies have only so much interest in trivial pursuits!

That's my opinion for what it is worth.  Wyou know what they say about opinions... they are like a$$holes, everybody has one and they ALL stink!!

As for me, my EB300D Kubota is at the freight terminal for pickup this evening. The 160 amp alternator and charge controller are ready and I have  a welded up bed frame ready on shock  mounts ready for final drilling  and erecting the major sub assemblies.  I still have to turn up a big pulley to mount on the units flywheel for the Poly V belt.  I got some 6 inch diameter 6061 Aluminum that I can spin off a bunch of swarf to make a nice flat pulley. Unit even has a little control panel that has Start/Stop, glowplug, and vernier throttle built in. If it works for me pretty good, I have 3 or 4 neighbors (off the grid like myself) itching to have one for themselves.  I might have a pretty busy Spring up here on Finley Hill!! If not it will make a helluva water pump or log splitter.

Cheers, have a good week folks!

Mike

[mobile_bob]

i think where alot of folks go wrong in reading the epa rules is an understanding of how laws are written
in general

for instance i find an exclusion clause, and i am thrilled... but wait

i must do the following at the very least

1. determine whether or not this is the most current rendering of the applicable law, rule and subsection

if the subsection has been updated i must use the most current edition , then

i must read the whole section and search out all references, and then...

i must check and make sure there are no newer editions of the references.... then

i must comply with all sections, subsections, revisions, exceptions , blah blah blah.... and then....

i must hope that tomorrow there will be no further changing of the wording in "any" section that would change
the interpretation of the rule i am working toward. and then....

we have the whole issue of words having specific meaning,, and by specific meaning

"the legal system often times has various meanings for words that commonly only have one meaning in common use" and....

" laws are subjective, and there is a precept of law which takes into account " the intent of the law""

the bottom line is one is not likely going to succeed in finding an exemption from a single line of one page in the epa rules...

"one page giveth, another taketh away" or at least modifies what was given.

this is going to be relatively complex, and it is a moving target with ever changing rules that are both scheduled rule changes, and those that will be changed for
political reasons (unscheduled change).

what we need is to find an attorney that likes to get his hand greasy,  and get him hooked on listeroids

bob g