EPA exemptions for new and/or transitional engines

[jimmason]

i'm impressed with bob's seriousness with trying to find a route to affirm experimental and repurposed old design import engines for new interesting work.  this is a hard problem, and one i usually want to run away from given war scars from previous battles with govt regulatory entities.  it is a deadening, thankless and usually sum negative task.  so thank you bob for trying to make some progress on the near impossible.

unfortunately (or fortunately) i've found myself trying to use engines in a related non-conforming manner for woodgas based gensets.  woodgas is well outside current regulatory standards, but we're now trying to distribute engines and gasifiers that run on it.  what do we do, after just doing it diy?

with some trepidation, i've wandered into the actual regulatory text on these matters.  for spark ignition engines, there seems to be some relief for low volume or transitory engine designs.  i'm not sure if it understand the particulars yet, but the text engaging it is here:
http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr;sid=368553d7c4d90b62423a24a74e2b5086;rgn=div5;view=text;node=40%3A32.0.1.1.9;idno=40;cc=ecfr#40:32.0.1.1.9.7.1.7

the general section on all issues for small stationary spark fired engines is here:
http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr;sid=368553d7c4d90b62423a24a74e2b5086;rgn=div5;view=text;node=40%3A32.0.1.1.9;idno=40;cc=ecfr#PartTop

there seems some possibilites here, but then again the emissions issues on otto engines are always less than late fuel/air mixing compression fire engines.  it might be that spark engines have some latitude and exceptions not similarly allowed in compression fired engines.

looking around the site a bit more, here's the related info on compression fired engines.

the general section on all issues for small stationary compression fired engines is here:
http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=41ce2d3e804c63067eee0e52fe4f7d37&tpl=/ecfrbrowse/Title40/40cfr1039_main_02.tpl

some interesting potential exemptions:

exemptions for engines using non-commerical fuels
http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=41ce2d3e804c63067eee0e52fe4f7d37&rgn=div8&view=text&node=40:32.0.1.1.3.7.1.4&idno=40

importer eq manufacturing flexibility
http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=41ce2d3e804c63067eee0e52fe4f7d37&rgn=div8&view=text&node=40:32.0.1.1.3.7.1.7&idno=40

reading the importer eq manufacturing flexibility, there seems to be a provision to import non-conforming engines with a bond posted per engine.  150 dollars per engine under 19kw.  that seems a small gate fee to continue to be able to play with our engine bases of interest.  has this route been explored previously?


for the full regulatory monty, see here for the top level link for all categories of stationary engines and related non-vehicle engine uses:
http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?sid=41ce2d3e804c63067eee0e52fe4f7d37&c=ecfr&tpl=/ecfrbrowse/Title40/40cfrv32_02.tpl

has anyone explored these texts in detail?  maybe this has passed here before and i'm not aware of the details.  i know we always reference the coming and going of epa problems, but i've yet to see a good parsing of the regulatory particulars. 

anyone see any new ideas or possibilities in these links?

jim

[billswan]

i'm impressed with bob's seriousness with trying to find a route to affirm experimental and repurposed old design import engines for new interesting work.  this is a hard problem, and one i usually want to run away from given war scars from previous battles with govt regulatory entities.  it is a deadening, thankless and usually sum negative task.  so thank you bob for trying to make some progress on the near impossible.

Yes 3 cheers for bob and I can sure agree with the rest of the paragraph too. As a farmer I have had ISSUES with government that can be resolved with a mitigation type action (read that as) well if you pay enough money for this we will look the other way and let you do that.

Jimmasom

good work on your research but when I try to read such government gobblety gook I just throw up my hands and cuss (#%&**#@!!) and give up. My guess is that is the effect the government man wants.

When I follow this link you posted I scanned the text and it looks like the 150$ is just a bond and you have to then report in yearly, not a comfortable thing to me.mporter eq manufacturing flexibility
http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=41ce2d3e804c63067eee0e52fe4f7d37&rgn=div8&view=text&node=40:32.0.1.1.3.7.1.7&idno=40

reading the importer eq manufacturing flexibility, there seems to be a provision to import non-conforming engines with a bond posted per engine.  150 dollars per engine under 19kw.  that seems a small gate fee to continue to be able to play with our engine bases of interest.  has this route been explored previously?
I hope some one with more patience can read that (@#$%^&*() stuff and tell the forum if it is something positive. You know the old saying Ignorance of the law is no excuse, there may be an import loophole that will work if you know how to jump through it. Of course the government man won't tell you how, that is for you to figure out and then tell him.

Billswan

[Fat Charlie]

Of course the government man won't tell you how, that is for you to figure out and then tell him.

Billswan

What we need to do is get some of those Minerals Management Service regulators assigned to the EPA.  The parties will be pretty wild and those folks will be so helpful with importing engines that they'll give us a hand with the casting sand.