Re: End of an Era?
You are correct on about every count.
one minor thing is that there is no classification for a bicycle engine..and it will be certified under the non-road spark-ingnited classification as a class one. (less than 225cc's). I will attempt to clarify the overburden of regs the EPA has been pouring out, since you mentioned this discussion if for clarity..and I agree. I have been dealing daily with the regs for about 15 months now on larger than 225cc engines..and its a nitemare.
Begining in 2012, for engines produced in 2012, and equipment produced in 2012 with 2012 production engines, ALL engines regardless of size will require 2 labels..and 2 certificates of compliance from the EPA. (as class 2 engines do now for 2011.)
ONE is the exhaust emissions label. It identifies that the engine has been proven comliant with the appropriate exhaust emission regs for its class.
TWO is the evaporative emmissions label. This identifies the fuel system is compliant with the evaporitive emission regs for its class.
Engine supplied with fuel tanks will have 2 labels already on them and mfgs can use them without doing anything.
Engine supplied by an engine manufacturer without a fuel system..(tank lines and cap and such) will not have an evap label on them. The manufacturer of the equipment using a gasoline engine is required by the EPA to apply for a mfg 's code, and then submit data to the EPA , maintain a database on the EPA's computers via the "E-verify" system, and a whole myriad of things.
For defination of a Equipment manufacturer, the EPA has a definitions glossary..and it says" Any individual or group of individuals, or company that purchases a gasoline Engine and installs it on a newly manufacturered machine shall be deemed the mfg and considered such for the purpose of this part."
I point this out because it is a NEWLY modified defination..previously was included "for sale or rent, or any commercially based enterprise". That sentence has been removed. I cannot speculate why, but it follows with the newly promoted philosophy that any "individual" can now be in violation of the clean air act emmission regs, by modifying or tampering with a certified engine or fuel system, and subject to fine. previously it should be noted, it was not against the regs for the "end user" to change a component on a certified engine to a non-certified part. NOW it is.
Now back to fuel systems, which is the subject at hand.
EPA definations also differentiate between engine mfg;'s and equipment mfg's, and an engine supplied without an evap lable to an equipment mfg (which would be an engine without a fuel tank, for instance) are a large part of the market, and it is now up to the equipment mfg to obtain a certificate of compliance, and print a label with the corresponding identification numbers on it. machines, regardless of purpose shall be labeled, or they are not permitted to be sold in the USA. The inspectors are already on the job, and they only look for labels...right now, they are only concerned with equipment powered by 225cc and larger engines, but jan 1st 2012...they will be concerned with all gas powered equipment. Even your 16cc stringtrimmer will have to have a carbon canister, and a evap recovery system.
Fuel tanks for instance, are also required to be labled as the design of them is now regulated. So get your little whizzer looking tanks now..cause after the end of this year????? GAs caps also must be numbered and labled..and on and on..
Since they wrote vergage into the law that say.." Any engine manufacturer that supplies an engine to an equipment mfg for a non-compliant application shall share in the responsibility of the violation', if an engine mfg sells an engine to ANYONE who installs it on machine with a non-compliant fuel system , the engine mfg will be included in the finies. I have absoultely no doubt they did this simply to include the deep pockets of the engine mfgs into a position of liability. This is the part that really frosts me the most.
They have succeeded in making us..the engine mfg's actually enforce their rules for them,.by shutting off engine supplies to our customers..or fear the fines if they are not compliant.
I can tell you with the utmost certainty, that all USA based engine mfg's and all offshore engine mfg's with assets in the USA, are scrambleing to help their thousands of customers get EVAP compiant...simply so we can continue to sell them engines. The ones that are not helping are ones that have no assets here and cannot be attached by a US court.
ONe caveat to this all..and I want to mention it. The EPA has issued a one year "grace period" for using up old stock..and they have proclaimed that an equipment mfg can use a 2010 engine for production on a 2011 machine, and be compliant to the regs in force on the date of the engines mfg..but only for 1 year. So in 2012 a equipment mfg can install engines with a 2011 date code, and be subjected to the 2011 regs untill those engines are gone...and so on.
This is why in paragraph number 2, I specifically said, "equipment produced in 2012 with 2012 production engines,, Because equipment produced in 2012 with a 2011 production engine is immune.
ONE last thing..just a thought..IF i were a Motorized mike builder and built them to sell..I might consider building all my machines with a 2011 date code on the machine...regardless of what the calander was.
This is not a new idea..it happened when production of 10 round magazines was banned in the USA. Offshore mfgs simply produced docs that stated all there production was built before the ban..regardless of the true date of mfg. I am not saying any american mfgs did this...because I dont know. American mfgs risk being caught by inspectors..offshore mfgs do not.