Combined Fwd from Biofuel - very interesting! >To: biofuel@yahoogroups.com >From: "detrickm79" <[EMAIL PROTECTED]> >Date: Tue, 20 May 2003 13:11:35 -0000 >Subject: [biofuel] A question about using SVO/WVO in the U.S. > >I've searched the archive trying to find information on this, and >haven't found any yet (although I must say, this list has a HUGE >archive!). > >Does anyone know about any legal hitches with using SVO/WVO in the >U.S.? I seem to be able to find companies selling kits to allow >SVO/WVO to be used in a diesel engine. None of them, so far, have >been able to give me any support or ideas on whether or not it's >legal! They all either don't care, or tell me it's not their >responsibility to research these things. > >thanks for any insight, > >detrick
>To: biofuel@yahoogroups.com >From: Hakan <[EMAIL PROTECTED]> >Date: Tue, 20 May 2003 16:47:38 +0200 >Subject: Re: [biofuel] A question about using SVO/WVO in the U.S. > >Detrick, > >It has been discussed and as far as I understood it, >it is legal to produce and use up to a specified amount >during the year. I do not remember the amount, but it >was enough for extensive driving of a large SUV, or >driving two smaller family cars. Something around >1,500 gallon a year. The conclusion is that it is legal, >but for commercial the taxes have to be paid. > >Hakan >From: Detrick Merz <[EMAIL PROTECTED]> >Date: Tue, 20 May 2003 11:43:07 -0400 >Subject: Re: [biofuel] A question about using SVO/WVO in the U.S. > >Does anyone have the evidence to support this? In speaking with an >engineer at the EPA (one I've seen quoted in several news articles >describing crack downs on this type of operation), the EPA won't give >approval for it until extensive testing has been completed. I'd feel >more comfortable if I could carry around the supporting evidence with >me, in case I run into trouble. > >thanks!! > >-detrick >From: Keith Addison <[EMAIL PROTECTED]> >Date: Wed, 21 May 2003 02:26:27 +0900 >Subject: Re: [biofuel] A question about using SVO/WVO in the U.S. > >Hello Detrick > >Aren't you confusing SVO/WVO with biodiesel? With biodiesel, the >situation with the EPA etc is summed up here: >http://archive.nnytech.net/index.php?view=24742&list=BIOFUEL > >Please, everybody, this needs a test case - has there been a test >case? Does anybody know, or have anything to add to this? > > >Does anyone have the evidence to support this? In speaking with an > >engineer at the EPA (one I've seen quoted in several news articles > >describing crack downs on this type of operation), > >Which one? He was talking about SVO/WVO? > > >the EPA won't give > >approval for it until extensive testing has been completed. I'd feel > >more comfortable if I could carry around the supporting evidence with > >me, in case I run into trouble. > >Re SVO/WVO, Hakan's right, it has been discussed, and will thus be in >the archives, but I don't remember the details. There are plenty of >US SVO'ers here who should know, however. > >By the way, which archives did you use - not Yahoo's, I hope? >Nightmare! Use Martin's archives at NNYtech, if you haven't already >been doing so, much better - Biofuel, and Biofuels-biz: >http://archive.nnytech.net/index.php > >Best > >Keith >From: Detrick Merz <[EMAIL PROTECTED]> >Date: Wed, 21 May 2003 08:47:52 -0400 >Subject: Re: [biofuel] A question about using SVO/WVO in the U.S. > >Thanks for the input Keith!! It's been nice finding a more living >resource that responds positively :) I've put some more >comments/ideas/questions inline below... > >Keith Addison wrote: > > Hello Detrick > > > > Aren't you confusing SVO/WVO with biodiesel? With biodiesel, the > > situation with the EPA etc is summed up here: > > http://archive.nnytech.net/index.php?view=24742&list=BIOFUEL > >nope... I'm talking about SVO/WVO, not biodiesel. Everything I've seen >and heard from talking with Jim Caldwell of the EPA, states that the use >of SVO and/or WVO in an on-road diesel is against current regulations. > > > Please, everybody, this needs a test case - has there been a test > > case? Does anybody know, or have anything to add to this? > > > > > >>Does anyone have the evidence to support this? In speaking with an > >>engineer at the EPA (one I've seen quoted in several news articles > >>describing crack downs on this type of operation), > > > > > > Which one? He was talking about SVO/WVO? > >Jim Caldwell was the EPA engineer I've been speaking with. We were >specifically discussing SVO/WVO. He mentioned that biodiesel is well >known to the EPA, but that SVO/WVO would need extensive testing before >being allowed for use as a motor fuel by the EPA. > > >>the EPA won't give > >>approval for it until extensive testing has been completed. I'd feel > >>more comfortable if I could carry around the supporting evidence with > >>me, in case I run into trouble. > > > > > > Re SVO/WVO, Hakan's right, it has been discussed, and will thus be in > > the archives, but I don't remember the details. There are plenty of > > US SVO'ers here who should know, however. > > > > By the way, which archives did you use - not Yahoo's, I hope? > > Nightmare! Use Martin's archives at NNYtech, if you haven't already > > been doing so, much better - Biofuel, and Biofuels-biz: > > http://archive.nnytech.net/index.php > >I'll go looking through the archives again (yes, I used Yahoo!'s the >first time... I'll check out Martin's). Hopefully some people will pipe >up again, too. If not, I'll just keep digging :) > >From: Keith Addison <[EMAIL PROTECTED]> >Date: Thu, 22 May 2003 06:58:43 +0900 >Subject: Re: [biofuel] A question about using SVO/WVO in the U.S. > >Hello again Detrick > > >Thanks for the input Keith!! > >You're welcome. :-) > > >It's been nice finding a more living > >resource that responds positively :) I've put some more > >comments/ideas/questions inline below... > > > >Keith Addison wrote: > > > Hello Detrick > > > > > > Aren't you confusing SVO/WVO with biodiesel? With biodiesel, the > > > situation with the EPA etc is summed up here: > > > http://archive.nnytech.net/index.php?view=24742&list=BIOFUEL > > > >nope... I'm talking about SVO/WVO, not biodiesel. Everything I've seen > >and heard from talking with Jim Caldwell of the EPA, states that the use > >of SVO and/or WVO in an on-road diesel is against current regulations. > >Jim Caldwell, yes, I know of him. Some of us have had contact with >him in the past I believe. > >But I still think there's some confusion here. AFAIK they're only >interested if you SELL the stuff, not if you simply use it. All the >fuss with biodiesel has been over selling it, for on-road use (no >problem for off-road use). > >If you're just a user, with no sales transaction anywhere along the >line, as is the case with SVO/WVO fuel (I think), then all you have >to do is pay whatever on-road taxes apply. I think... As Hakan said. > >You're just aiming to be a user, aren't you? Can't see much of a >future in selling SVO/WVO fuel (though there are Europeans who're >doing just that with their "PPO"). > > > > Please, everybody, this needs a test case - has there been a test > > > case? Does anybody know, or have anything to add to this? > > > > > > > > >>Does anyone have the evidence to support this? In speaking with an > > >>engineer at the EPA (one I've seen quoted in several news articles > > >>describing crack downs on this type of operation), > > > > > > > > > Which one? He was talking about SVO/WVO? > > > >Jim Caldwell was the EPA engineer I've been speaking with. We were > >specifically discussing SVO/WVO. He mentioned that biodiesel is well > >known to the EPA, but that SVO/WVO would need extensive testing before > >being allowed for use as a motor fuel by the EPA. > >Again, I'd think that should be "allowed *for sale*". But, could be >wrong, very interested to know. > >I think you're right to try to find out just what the situation is, >please keep going, if your archives search is fruitful please post >the results here, no harm in airing it once again, and/or let us know >what you find out elsewhere. > >But, once you've nailed it down, I don't think you need to go as far as this: > >"I'd feel more comfortable if I could carry around the supporting >evidence with >me, in case I run into trouble." > >Up to them to prove you guilty, after all, not you to prove your innocence. > >Please keep us advised. > >Best wishes > >Keith >From: Detrick Merz <[EMAIL PROTECTED]> >Date: Thu, 22 May 2003 08:40:44 -0400 >Subject: Re: [biofuel] A question about using SVO/WVO in the U.S. > >more comments inline... > >Keith Addison wrote: > >>nope... I'm talking about SVO/WVO, not biodiesel. Everything I've seen > >>and heard from talking with Jim Caldwell of the EPA, states that the use > >>of SVO and/or WVO in an on-road diesel is against current regulations. > > > > Jim Caldwell, yes, I know of him. Some of us have had contact with > > him in the past I believe. > > > > But I still think there's some confusion here. AFAIK they're only > > interested if you SELL the stuff, not if you simply use it. All the > > fuss with biodiesel has been over selling it, for on-road use (no > > problem for off-road use). > > > > If you're just a user, with no sales transaction anywhere along the > > line, as is the case with SVO/WVO fuel (I think), then all you have > > to do is pay whatever on-road taxes apply. I think... As Hakan said. > > > > You're just aiming to be a user, aren't you? Can't see much of a > > future in selling SVO/WVO fuel (though there are Europeans who're > > doing just that with their "PPO"). > > > >Yes, I'm aiming just to be a user. According to what I've heard from >Jim so far, SVO/WVO can't be used as a motor fuel in an on-road diesel >automobile unless the EPA knows more about it's emissions performance. >Here's an email I received from Jim: > >========================================== >Detrick, > >With respect to a fuel acquired for free and intended solely for >personal use, please see the attached letter where we recently >established a policy that, for a similar situation for biodiesel, >registration is not required. Once we know more about the emissions >performance of the kit for vegetable oil we could consider a similar >policy. However, a lot of testing has been done on biodiesel, so we >have a good handle on its performance. Please see >http://www.epa.gov/otaq/models/analysis/biodsl/p02001.pdf > >Jim Caldwell >(202) 564-9303 > >(See attached file: MaineBiodiesel4.wpd) >========================================== >And, the contents of the attached letter, "MaineBiodiesel4.wpd": >========================================== >Ms. Lynne A. Cayting, Chief > April 22, 2003 >Mobile Sources Section >Bureau of Air Quality >Department of Environmental Protection >State of Maine >17 State House Station >Augusta, Maine 04333-0017 > >Dear Ms. Cayting: > >Thank you for your December 30, 2002 letter to Robert Judge of our >Boston office concerning the production of biodiesel by individuals and >organizations. You asked if those parties were subject to the fuel >registration regulations at 40 CFR 79 if the biodiesel were solely for >their own use. These regulations apply only to fuels used in motor >vehicles. > >As a matter of policy, we will not require the registration of >biodiesel, as defined in our regulations at 40 CFR ¤ >79.56(e)(4)(ii)(B)(2), produced by an individual solely for use by that >individual. With respect to an organization producing biodiesel for its >own use, we will consider this policy on a case-by-case basis. We would >also point out that there are exemptions to the registration >requirements based upon the use of biodiesel in a research program such >as a program that might be conducted by a school. > >Any person producing biodiesel should follow routine quality-control >measures. A fuel of poor quality that, for example, does not meet >industry based standards such as those published by the American Society >for Testing and Materials (ASTM), could damage the engine and jeopardize >the warranty. > >I hope that this is helpful. Please contact us if we can be of further >assistance. > >Sincerely, > >/s/ >Suzanne Rudzinski >Director >Transportation and Regional Programs Division >========================================== > > > > >>>Which one? He was talking about SVO/WVO? > >> > >>Jim Caldwell was the EPA engineer I've been speaking with. We were > >>specifically discussing SVO/WVO. He mentioned that biodiesel is well > >>known to the EPA, but that SVO/WVO would need extensive testing before > >>being allowed for use as a motor fuel by the EPA. > > > > Again, I'd think that should be "allowed *for sale*". But, could be > > wrong, very interested to know. > > > > Up to them to prove you guilty, after all, not you to prove your innocence. > >In a state where they set up road blocks and pull over diesel powered >vehicles to test their fuel to make sure road taxes are paid, I'd rather >carry some backing that explains my legal use of this fuel they don't >recognize. > >-detrick >From: Keith Addison <[EMAIL PROTECTED]> >Date: Fri, 23 May 2003 05:27:31 +0900 >Subject: Re: [biofuel] A question about using SVO/WVO in the U.S. > >Hi Detrick > >Hm - very interesting! Seems you've uncovered something. Please >pardon my earlier doubts. > >Now why don't the SVO missionaries and sellers of kits know about >this? - as it seems they don't - and done something about it? As it >seems they haven't. Is it up to Jim Caldwell/the EPA to go to them? > >This seems quite a clearcut issue, much more so than the so-called >"EPA hassle" was with biodiesel - there's no question of a conspiracy >of Big Guys ganging up on the little guys, as was alleged with >biodiesel. > >There is information available on SVO emissions, quite a lot more >than there was a year or two ago, and a growing body of... something >or other, not sure that it's evidence exactly, recorded user >experience anyway, on a couple of databases on the web. This could be >forwarded to Jim Caldwell - I doubt he's "anti" SVO in any way, >probably be quite willing to cooperate. > >Some interested party/parties should make a start, engage Jim >Caldwell - you've already done that Detrick, now you need some >support from the SVO fraternity. With these legal issues, there's one >BIG difference (well, another one) between SVO and biodiesel: there's >no industry lobby for SVO. Two sides to that, sure enough, but it >leaves a vacuum. > >Best wishes > >Keith >From: Detrick Merz <[EMAIL PROTECTED]> >Date: Thu, 22 May 2003 17:17:00 -0400 >Subject: Re: [biofuel] A question about using SVO/WVO in the U.S. > >this may offend/irritate some of the kit resellers, espicially the ones >that visit this list... regardless, that is not my intention, I only >wish to find resolution to my initial questions. > >see inline, as has become usual :) > >Keith Addison wrote: > > Hi Detrick > >hello, again! > > > Hm - very interesting! Seems you've uncovered something. Please > > pardon my earlier doubts. > >done :) > > > Now why don't the SVO missionaries and sellers of kits know about > > this? - as it seems they don't - and done something about it? As it > > seems they haven't. Is it up to Jim Caldwell/the EPA to go to them? > >I can't speak for the missionaries, but I can speculate with some well >educated guesses on why the kit sellers don't. They simply don't want >to be bothered... yet :) I've spoken with two kit sellers, Greasel.com >and Neoteric Biofuels Inc., asking them the very question I first posted >in this thread. I found some others who seem to deal regularly/mostly >with the U.S., but they all were Greasel.com resellers. > >I can't find the email the Neoteric sent back to me, but they said they >leave it up to their customers to explore the legal aspects of using >their products. A quote from their website summarizes this as well: > >"The user is to determine suitability for the intended application, and >is responsible for determining the legal and warranty implications of >installation and use." > >Charles, from Greasel.com, sent me the following response: >======================================= >Detrick, >Sounds like you are going to get there faster than me. >Right now since I, and my customers are not buying and selling fuel >there has not been a problem with the tax man and the petty bureaucrats. >If this is something that you are concerned with, I encourage you to >look into it as you already have. >I am careful not to get into a situation where I am giving my customers >legal advice. >We sell our kits to a verity of people in a verity of countries with on >road and off road use. I can't even try to anticipate and advise. >Although right now we are at a "if it ain't broke don't fix it" stand point. >We do stay on top of it and try to keep ourselves aware of the issues. >At some point if we feel it necessary to take a stand or advise people >we will do so, carefully. >I can tell you that the emissions with WVO are much better than diesel >and in some areas even better than the Toyota Prius, a gas electric Hybrid. >We are working on getting that info published. >Thank you. >Charles >======================================= > >So, it seems that these kit sellers are in the business of selling kits, >but not checking to see if they are legal. So far (I've only learned >about this whole "WVO powering your diesel" on April 22 (shameless >slashdot.org plug), I've only been able to locate these two major kit >suppliers in the U.S. I've found some in europe, but I doubt they have >much reason to be concerned about the U.S. EPA. I have not verified >whether or not they export their kits to the U.S., but I fear that might >open a larger can of worms, once the import/export laws get involved. >Easier for me to keep them out, for now anyway. > >Now, here's another interesting thing that Jim Caldwell sent me. Keep >in mind, too, that this next quote was sent to Greasel.com, and received >the reply above: > >======================================= >Detrick, > >I spoke with our attorney who handles this area. A manufacturer of a >kit to convert a vehicle from gasoline or diesel to compressed natural >gas is required to demonstrate that the vehicle(s) for which the kit is >designed will still meet emission standards. Thus, the manufacturer of >a kit to convert a vehicle to run on vegetable oil should be conducting >emissions testing and demonstrating that the standards will still be >met. > >Sincerely, > >Jim Caldwell >(202) 564-9303 >======================================= > >So, now we have evidence from the EPA lawyers that the kit sellers are >required to demonstrate that the kits are legal, at least from the EPA's >realm of laws/regulations. I realize that fuel taxes may still be an >issue, but they seem resolved, at least by what I've read so far. > > > This seems quite a clearcut issue, much more so than the so-called > > "EPA hassle" was with biodiesel - there's no question of a conspiracy > > of Big Guys ganging up on the little guys, as was alleged with > > biodiesel. > >It seems pretty clearcut to me too, it's just a matter of appeasing the >EPA with the testing results they want. Clearcut, but full of labor. > > > There is information available on SVO emissions, quite a lot more > > than there was a year or two ago, and a growing body of... something > > or other, not sure that it's evidence exactly, recorded user > > experience anyway, on a couple of databases on the web. This could be > > forwarded to Jim Caldwell - I doubt he's "anti" SVO in any way, > > probably be quite willing to cooperate. > >I'd love to be able to send this information to Jim Caldwell, but I fear >it may not be in the format they're looking for. If you view >http://www.epa.gov/otaq/models/analysis/biodsl/p02001.pdf you will >notice it's the test results that the EPA based their biodiesel approval >on. I believe this is the kind of test results that the EPA would be >looking for before they approve SVO/WVO as a motor fuel. It's a >delightful read (well, not particularly, but there is some good info in >it... yes, I have read it.) Now, the other good thing about that PDF >file is that they actually have test results from 'Virgin Vegetable Oil' >sources. But, since they had limited sources for the fuel, they were >not able to get sufficient data to include SVO/WVO in the results. But >hey, I look at it as a good start! I also found I have access to the >test data (in Excel format) that goes along with that PDF file. Perhaps >both would be good to post in the yahoogroups file section? > > > Some interested party/parties should make a start, engage Jim > > Caldwell - you've already done that Detrick, now you need some > > support from the SVO fraternity. With these legal issues, there's one > > BIG difference (well, another one) between SVO and biodiesel: there's > > no industry lobby for SVO. Two sides to that, sure enough, but it > > leaves a vacuum. > >I'd love to help anyone else who wants to fight this battle with me. >I'm not saying I will lead it, I don't even believe I can. I'm still >quite naieve about the SVO/WVO world. From the EPA's prospective, it >seems largely up to the conversion kit sellers to produce this data. >Since I believe the kit sellers are not large corporations, but rather >people like you and I, I can understand the daunting task at hand. But, >I've also learned something else in my life... when you have a group of >people such as the ones interested in using SVO/WVO as a motor fuel, you >often get an outpouring of small efferts from a LARGE group. This >combination of small efforts will (I hope anyway) make a strong enough >cumulative effort to make the necessary progress. > > > Best wishes > >perhaps you should say, "Good luck?" :) > > > Keith > > ><SNIP> - save bandwith, check the archives if you want to see what was >snipped out! >From: Neoteric Biofuels Inc <[EMAIL PROTECTED]> >Date: Thu, 22 May 2003 20:51:49 -0700 >Subject: Re: [biofuel] A question about using SVO/WVO in the U.S. > >I'm not offended at all Detrick - my response was simple "no idea" - >because I really don't pretend to know the latest regulations for >on-road and off-road, in may countries that we export to, and because >it is all changing rapidly. > >Perhaps this helps: emissions testing was done as part of my thesis >work. For EPA regulated emissions basically we saw the same as >biodiesel. For particulates, same story. About the same as biodiesel. > >Life cycle basis, probably some advantages for SVO and WVO over >biodiesel (no methanol or lye component, less transport, less energy >for processing, etc.) > > >See my thesis, online, for details, at links section: > >http://www.biofuels.ca > > >Edward Beggs >Neoteric Biofuels Inc. >http://www.biofuels.ca >From: Detrick Merz <[EMAIL PROTECTED]> >Date: Fri, 23 May 2003 09:18:59 -0400 >Subject: Re: [biofuel] A question about using SVO/WVO in the U.S. > >Edward, > >I'd love to forward this thesis to the EPA, with your permission. I >believe it may provide us another step towards EPA acceptance. I did >notice, however, that 'Appendix B' and 'Appendix C' seemed to have no >content beyond their headings. If you are okay with me forwarding this >on to the EPA, could you send me a copy which contains the contents of >these appendices? > >thanks, > >detrick >From: Keith Addison <[EMAIL PROTECTED]> >Date: Sat, 24 May 2003 01:21:53 +0900 >Subject: Re: [biofuel] A question about using SVO/WVO in the U.S. > >Hello Detrick > >You'll find a linked pull-together of the available research here, >quite extensive, if not exhaustive: > >References >http://journeytoforever.org/biodiesel_svo.html#refs > >I don't know of a more complete list, though there may be one. You're >welcome to steer these resources at Jim Caldwell, or steer him at >them. > > > > On Thursday, May 22, 2003, at 02:17 PM, Detrick Merz wrote: > > > > > > > > >>this may offend/irritate some of the kit resellers, espicially the ones > > >>that visit this list... regardless, that is not my intention, I only > > >>wish to find resolution to my initial questions. > > >> > > >>see inline, as has become usual :) > > >> > > >>Keith Addison wrote: > > >> > > >>>Hi Detrick > > >> > > >>hello, again! > > >> > > >> > > >>>Hm - very interesting! Seems you've uncovered something. Please > > >>>pardon my earlier doubts. > > >> > > >>done :) > >Thankyou. :-) > >I think it was me who persuaded Craig Reece, a regular contributor >here (see archives), to have a closer look at the German Elsbett >system - see archives, and here: >http://journeytoforever.org/biodiesel_svo.html#systems > >Briefly, Craig has imported Elsbett kits to the US and has been >instrumental in Elsbett's taking an active interest in the US market >(which I'd also encouraged them to do). > >So you might include Elsbett in your efforts. Another reason for >doing this is that I think Klaus Elsbett should have access to German >research on SVO which we probably don't know about, or which may not >be in the public domain. Putting Jim Caldwell and Klaus Elsbett in >touch with each other could be a positive thing to do. > > > >>>Now why don't the SVO missionaries and sellers of kits know about > > >>>this? - as it seems they don't - and done something about it? As it > > >>>seems they haven't. Is it up to Jim Caldwell/the EPA to go to them? > > >> > > >>I can't speak for the missionaries, but I can speculate with some well > > >>educated guesses on why the kit sellers don't. They simply don't want > > >>to be bothered... yet :) I've spoken with two kit sellers, Greasel.com > > >>and Neoteric Biofuels Inc., asking them the very question I first > > >>posted > > >>in this thread. I found some others who seem to deal regularly/mostly > > >>with the U.S., but they all were Greasel.com resellers. > > >> > > >>I can't find the email the Neoteric sent back to me, but they said they > > >>leave it up to their customers to explore the legal aspects of using > > >>their products. A quote from their website summarizes this as well: > > >> > > >>"The user is to determine suitability for the intended application, and > > >>is responsible for determining the legal and warranty implications of > > >>installation and use." > > >> > > >>Charles, from Greasel.com, sent me the following response: > > >>======================================= > > >>Detrick, > > >>Sounds like you are going to get there faster than me. > > >>Right now since I, and my customers are not buying and selling fuel > > >>there has not been a problem with the tax man and the petty > > >>bureaucrats. > > >>If this is something that you are concerned with, I encourage you to > > >>look into it as you already have. > > >>I am careful not to get into a situation where I am giving my customers > > >>legal advice. > > >>We sell our kits to a verity of people in a verity of countries with on > > >>road and off road use. I can't even try to anticipate and advise. > > >>Although right now we are at a "if it ain't broke don't fix it" stand > > >>point. > > >>We do stay on top of it and try to keep ourselves aware of the issues. > > >>At some point if we feel it necessary to take a stand or advise people > > >>we will do so, carefully. > > >>I can tell you that the emissions with WVO are much better than diesel > > >>and in some areas even better than the Toyota Prius, a gas electric > > >>Hybrid. > > >>We are working on getting that info published. > > >>Thank you. > > >>Charles > > >>======================================= > > >> > > >>So, it seems that these kit sellers are in the business of selling > > >>kits, > > >>but not checking to see if they are legal. > >Sounds like. > > >So far (I've only learned > > >>about this whole "WVO powering your diesel" on April 22 (shameless > > >>slashdot.org plug), I've only been able to locate these two major kit > > >>suppliers in the U.S. > >There are some others (see same link as to Elsbett, above), but these >are the main ones. > > >I've found some in europe, but I doubt they have > > >>much reason to be concerned about the U.S. EPA. I have not verified > > >>whether or not they export their kits to the U.S., but I fear that > > >>might > > >>open a larger can of worms, once the import/export laws get involved. > > >>Easier for me to keep them out, for now anyway. > >Maye not, see above. Suggest you discuss it with Craig Reece. > > > >>Now, here's another interesting thing that Jim Caldwell sent me. Keep > > >>in mind, too, that this next quote was sent to Greasel.com, and > > >>received > > >>the reply above: > > >> > > >>======================================= > > >>Detrick, > > >> > > >>I spoke with our attorney who handles this area. A manufacturer of a > > >>kit to convert a vehicle from gasoline or diesel to compressed natural > > >>gas is required to demonstrate that the vehicle(s) for which the kit is > > >>designed will still meet emission standards. Thus, the manufacturer of > > >>a kit to convert a vehicle to run on vegetable oil should be conducting > > >>emissions testing and demonstrating that the standards will still be > > >>met. > > >> > > >>Sincerely, > > >> > > >>Jim Caldwell > > >>(202) 564-9303 > > >>======================================= > > >> > > >>So, now we have evidence from the EPA lawyers that the kit sellers are > > >>required to demonstrate that the kits are legal, at least from the > > >>EPA's > > >>realm of laws/regulations. I realize that fuel taxes may still be an > > >>issue, but they seem resolved, at least by what I've read so far. > >I think so, but this issue above isn't resolved. So greasel knows >they're selling kits in contravention of the EPA. Hm. We take issue >with the greasel folks somewhat for their claims that their two-tank >pre-heating kit will allow "any diesel" to run on WVO. Maybe so, but >that's quite a long way from being established, and there are some >well-founded doubts. Neoteric has a more responsible attitude to this >issue IMO. Be interesting to see greasel et al having to prove it >emissions-wise, which might settle something that needs settling, but >also it could potentially prove a setback for SVO. I really hope this >new initiative can be made to take the issue forward, not backward. >Whatever, it's clear it must be dealt with. > > > >>>This seems quite a clearcut issue, much more so than the so-called > > >>>"EPA hassle" was with biodiesel - there's no question of a conspiracy > > >>>of Big Guys ganging up on the little guys, as was alleged with > > >>>biodiesel. > > >> > > >>It seems pretty clearcut to me too, it's just a matter of appeasing the > > >>EPA with the testing results they want. Clearcut, but full of labor. > >Indeed. Probably the information they require doesn't yet exist, but >enough exists (above) to engage them in a constructive process in the >meantime, possibly with some kind of interim waivers a possible goal. > > > >>>There is information available on SVO emissions, quite a lot more > > >>>than there was a year or two ago, and a growing body of... something > > >>>or other, not sure that it's evidence exactly, recorded user > > >>>experience anyway, on a couple of databases on the web. This could be > > >>>forwarded to Jim Caldwell - I doubt he's "anti" SVO in any way, > > >>>probably be quite willing to cooperate. > > >> > > >>I'd love to be able to send this information to Jim Caldwell, but I > > >>fear > > >>it may not be in the format they're looking for. If you view > > >>http://www.epa.gov/otaq/models/analysis/biodsl/p02001.pdf you will > > >>notice it's the test results that the EPA based their biodiesel > > >>approval > > >>on. I believe this is the kind of test results that the EPA would be > > >>looking for before they approve SVO/WVO as a motor fuel. It's a > > >>delightful read (well, not particularly, but there is some good info in > > >>it... yes, I have read it.) Now, the other good thing about that PDF > > >>file is that they actually have test results from 'Virgin Vegetable > > >>Oil' > > >>sources. But, since they had limited sources for the fuel, they were > > >>not able to get sufficient data to include SVO/WVO in the results. But > > >>hey, I look at it as a good start! > >Certainly it is, and something that can be built on. > > >I also found I have access to the > > >>test data (in Excel format) that goes along with that PDF file. > > >>Perhaps > > >>both would be good to post in the yahoogroups file section? > >At JtF would be a lot better. Let's discuss this off-list, shall we? >I could run both the pdf and the Excel file at JtF. > > > >>>Some interested party/parties should make a start, engage Jim > > >>>Caldwell - you've already done that Detrick, now you need some > > >>>support from the SVO fraternity. With these legal issues, there's one > > >>>BIG difference (well, another one) between SVO and biodiesel: there's > > >>>no industry lobby for SVO. Two sides to that, sure enough, but it > > >>>leaves a vacuum. > > >> > > >>I'd love to help anyone else who wants to fight this battle with me. > > >>I'm not saying I will lead it, I don't even believe I can. I'm still > > >>quite naieve about the SVO/WVO world. From the EPA's prospective, it > > >>seems largely up to the conversion kit sellers to produce this data. > > >>Since I believe the kit sellers are not large corporations, but rather > > >>people like you and I, I can understand the daunting task at hand. > > >>But, > > >>I've also learned something else in my life... when you have a group of > > >>people such as the ones interested in using SVO/WVO as a motor fuel, > > >>you > > >>often get an outpouring of small efferts from a LARGE group. > >That's exactly what this group and others is all about, and it's been >most successful so far. > > >This > > >>combination of small efforts will (I hope anyway) make a strong enough > > >>cumulative effort to make the necessary progress. > >Entirely possible. So let's try. I can't take an active role, but >with our resources I'm in a good position to take a supportive role, >and willing to do so. > > > >> > > >>>Best wishes > > >> > > >>perhaps you should say, "Good luck?" :) > >Okay - Good luck! :-) > >Regards > >Keith ------------------------ Yahoo! Groups Sponsor ---------------------~--> Get A Free Psychic Reading! Your Online Answer To Life's Important Questions. http://us.click.yahoo.com/Lj3uPC/Me7FAA/CNxFAA/9bTolB/TM ---------------------------------------------------------------------~-> Biofuels at Journey to Forever http://journeytoforever.org/biofuel.html Biofuel at WebConX http://webconx.green-trust.org/2000/biofuel/biofuel.htm List messages are archived at the Info-Archive at NNYTech: http://archive.nnytech.net/ To unsubscribe from this group, send an email to: [EMAIL PROTECTED] Your use of Yahoo! Groups is subject to http://docs.yahoo.com/info/terms/
