Author Topic: Testing import exception  (Read 919 times)

Tanman

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Testing import exception
« on: January 22, 2019, 05:56:00 PM »
Has anyone successfully imported an Indian or Chinese horizontal under the "testing" exemption outlined in the EPA import guidelines? I was looking around the forum at a post from 2007 and there was also mention of an "emergency" use exception.
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ajaffa1

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Re: Testing import exception
« Reply #1 on: January 22, 2019, 08:22:33 PM »
Hi Tanman, the US EPA rules don`t apply here in Australia. I recommend you contact Gary at DES, aka Dieselgman, he has experience of importing these engines from India. I don`t believe he is able to import whole engines anymore. I remember reading somewhere that it is OK to import engines manufactured before the current EPA rules came into place. Another option might be to import a kit of `Spare parts` and assemble it yourself. Expect to be shocked at the shipping charges.

Bob

38ac

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Re: Testing import exception
« Reply #2 on: January 23, 2019, 01:24:21 AM »
Importing one engine yourself is a heck of an expensive way to get one but to each his own. A testing engine is no more legal to operate in less than actual  controlled tests than any other non conforming engine.  There are plenty of Listeroids around for sale. No reason to jump through hoops realy.
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Tanman

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Re: Testing import exception
« Reply #3 on: January 23, 2019, 03:15:50 PM »
Thanks you for the input 38ac, I'll just keep my eyes open. It just seems like one only comes up for sale every other year in my tri-state area and never for a super great deal. Any suggestions on where to look besides craigslist and eBay?
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Chinese 1115-8KW stamford
96 Suburban 6.5 turbo

38ac

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Re: Testing import exception
« Reply #4 on: January 23, 2019, 05:12:57 PM »
Tri state is Cincinnati area to me?  You should be able to find a used single in the 1500 range. I have several parts kits and one preban 8/1
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Tanman

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Re: Testing import exception
« Reply #5 on: January 23, 2019, 05:29:30 PM »
I'm in SE Minnesota, so WI, IA, MN (and North west IL).
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Chinese 1115-8KW stamford
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38ac

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Re: Testing import exception
« Reply #6 on: January 23, 2019, 08:22:07 PM »
My early years were in Freeborn County MN. I turned down a running 6/1 Lister CS for $1800 that was located in Mankato about 2 years ago because I didn't want to travel that far to get it. Beside the places you mentioned watch Engine Ads on Smok Stak, go to the Portland engine show, go to the show at Rollag MN, go to the show at Edgar WI. Subscribe to Gas Engine Magazine. People are spoiled by cyber marketing but A lot of the guys that have stuff are not into it and you have to shop the old fashioned way.
« Last Edit: January 23, 2019, 08:24:09 PM by 38ac »
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Tanman

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Re: Testing import exception
« Reply #7 on: January 24, 2019, 04:39:12 AM »
Thank you! I would have never thought of or found some of those places to look! I guess it's one of those things where you don't know what you don't know. Thank you for bridging the generation gap there for me! By the way I was born in Worthington just a little ways west of Freeborn county and now I live in Olmstead county just to the NW of Freeborn, small world.

« Last Edit: January 24, 2019, 04:42:29 AM by Tanman »
Yanmar L100-5KW set
Chinese 1115-8KW stamford
96 Suburban 6.5 turbo

Tanman

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Re: Testing import exception
« Reply #8 on: January 24, 2019, 03:09:00 PM »
My early years were in Freeborn County MN. I turned down a running 6/1 Lister CS for $1800 that was located in Mankato about 2 years ago because I didn't want to travel that far to get it. Beside the places you mentioned watch Engine Ads on Smok Stak, go to the Portland engine show, go to the show at Rollag MN, go to the show at Edgar WI. Subscribe to Gas Engine Magazine. People are spoiled by cyber marketing but A lot of the guys that have stuff are not into it and you have to shop the old fashioned way.

I just spoke with my father and he told me my great grandfather and grandfather went to those shows often. My great grandfather even won one of the tractor shows! I never knew that before, I guess old iron is in my blood and I never even knew it!
Yanmar L100-5KW set
Chinese 1115-8KW stamford
96 Suburban 6.5 turbo

38ac

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Re: Testing import exception
« Reply #9 on: January 24, 2019, 05:18:34 PM »
I  just remembered that a couple years ago I sold some Bamford parts to an Amish fellow who lived not far from you, as I remember Spring Valley but I may be off there.  His last name is Swartsntruder or something very similar to that. Anyway the Amish are a good place to require. Ask an older one about a fellow in the area who owns a Z2 Bamford and he will likely now where to send you. Just dont act anxious about buying or the price will go up accordingly if he knows of one for sale.
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Tanman

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Re: Testing import exception
« Reply #10 on: January 31, 2019, 02:52:15 PM »
The EPA just got back to me. This is what they said:

Sorry for the late response due to the shutdown. Below is the regulation for applying for a testing exemption for a nonroad engine. In the attachment (more so for motor vehicles) this will provide information on the layout of the application letter.
 
 
§1068.210   What are the provisions for exempting test engines/equipment?
(a) We may exempt engines/equipment that you will use for research, investigations, studies, demonstrations, or training. Note that you are not required to get an exemption under this section for engines that are exempted under other provisions of this part, such as the manufacturer-owned exemption in §1068.215.
(b) Anyone may ask for a testing exemption.
(c) If you are a certificate holder, you may request an exemption for engines/equipment you intend to include in test programs over a two-year period.
(1) In your request, tell us the maximum number of engines/equipment involved and describe how you will make sure exempted engines/equipment are used only for this testing. For example, if the exemption will involve other companies using your engines/equipment, describe your plans to track individual units so you can properly report on their final disposition.
(2) Give us the information described in paragraph (d) of this section if we ask for it.
(d) If you are not a certificate holder, do all the following things:
(1) Show that the proposed test program has a valid purpose under paragraph (a) of this section.
(2) Show you need an exemption to achieve the purpose of the test program (time constraints may be a basis for needing an exemption, but the cost of certification alone is not).
(3) Estimate the duration of the proposed test program and the number of engines/equipment involved.
(4) Allow us to monitor the testing.
(5) Describe how you will ensure that you stay within this exemption's purposes. Address at least the following things:
(i) The technical nature of the test.
(ii) The test site.
(iii) The duration and accumulated engine/equipment operation associated with the test.
(iv) Ownership and control of the engines/equipment involved in the test.
(v) The intended final disposition of the engines/equipment.
(vi) How you will identify, record, and make available the engine/equipment identification numbers.
(vii) The means or procedure for recording test results.
(e) If we approve your request for a testing exemption, we will send you a letter or a memorandum describing the basis and scope of the exemption. It will also include any necessary terms and conditions, which normally require you to do the following:
(1) Stay within the scope of the exemption.
(2) Create and maintain adequate records that we may inspect.
(3) Add a permanent label to all engines/equipment exempted under this section, consistent with §1068.45, with at least the following items:
(i) The label heading “EMISSION CONTROL INFORMATION”.
(ii) Your corporate name and trademark.
(iii) Engine displacement, family identification, and model year of the engine/equipment (as applicable), or whom to contact for further information.
(iv) One of these statements (as applicable):
(A) “THIS ENGINE IS EXEMPT UNDER 40 CFR 1068.210 OR 1068.215 FROM EMISSION STANDARDS AND RELATED REQUIREMENTS.”
(B) “THIS EQUIPMENT IS EXEMPT UNDER 40 CFR 1068.210 OR 1068.215 FROM EMISSION STANDARDS AND RELATED REQUIREMENTS.”
(4) Tell us when the test program is finished.
(5) Tell us the final disposition of the engines/equipment.
(6) Send us a written confirmation that you meet the terms and conditions of this exemption.
 
 
 
 
David C. Hurlin
EPA Imports Line, Exemptions
Managed by Jacobs, Contractor to the U.S. EPA
Phone: (734) 214-4098 or 4100
Fax: (734) 214-4676
Yanmar L100-5KW set
Chinese 1115-8KW stamford
96 Suburban 6.5 turbo

veggie

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Re: Testing import exception
« Reply #11 on: January 31, 2019, 08:38:08 PM »

That's a lot of work just to get an engine.
They have to approve your test objectives.
Unlikely you will ever get an approval.

Veggie
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ajaffa1

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Re: Testing import exception
« Reply #12 on: January 31, 2019, 11:41:10 PM »
You could throw a spanner in their works by applying for an exemption on the grounds that you want to test out the procedures and effectiveness of the EPA!  :laugh:

Bob