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



>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


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