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under Title 42, section 203b of the Clean Air Act it is illegal
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Anadigelec Offline
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Post: #1
under Title 42, section 203b of the Clean Air Act it is illegal
Dear friends,
I am a seller on eBay and my name on eBay Anadigelec. I think a lot of people know me (Universal EFIE). I have received email from another ebay user:

"Did you know that under Title 42, section 203b of the Clean Air Act it is illegal:

for any person to manufacture or sell, or offer to sell, or install, any part or component intended for use with, or as part of, any motor vehicle or motor vehicle engine, where a principal effect of the part or component is to bypass, defeat, or render inoperative any device or element of design installed on or in a motor vehicle or motor vehicle engine in compliance with regulations under this subchapter, and where the person knows or should know that such part or component is being offered for sale or installed for such use or put to such use

40 CFR Part 85 Sub part F requires certification of aftermarket fuel conversions to avoid violating the anti-tampering provisions in Section 203(a) of the Clean Air Act. EPA considers supplemental fuel systems such as an on-demand supply of hydrogen to be a type of fuel switching. You will be reported as a violator. Ignorance of the law is no excuse
"

And another:
"If you would have taken the time to read what I sent, it says you are in violation of Federal law by selling a device that tampers with the emission system. This device qualifies as such a device. Stop selling or be reported to the EPA as a violator. Prison time and up to a $25,000 fine is possible. These devices are NOT approved by the EPA and therefore illegal to sell. Your ebay items will be used against you as evidence of non compliance"

WHAT TO DO? ALL WILL CLOSE? NO MORE HHO?

Sincerely, Anadigelec. Sad
03-07-2009 09:00 AM
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Anadigelec Offline
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Post: #2
RE: under Title 42, section 203b of the Clean Air Act it is illegal
I found the answer from Mike:
Quote: Theoretically, EFIEs and MAP enhancers don't violate the law, as they don't defeat the system. When I read the law, the word "tamper" doesn't appear. Only "defeat". And we definitely don't defeat the system when adding an EFIE. The purpose of the EFIE is actually to bring the system back to spec after adding hydrogen, and if done properly will make the system less "defeated" if anything. The whole thrust of the law is so that people won't make their cars more polluting, and an HHO system user will be pretty hard to accuse of violating that law.

Also, the H2 systems do not negate the need for an EFIE. The amount of oxygen being added by HHO systems is trivial. I personally don't see the need for separating and venting the oxygen, since it is such a small amount of gas compared to what is coming in through the intake. But any system that improves combustion efficiency, will have added oxygen in the exhaust and will need an EFIE to get the full benefit of the device.

And I found the link of this law:
http://www.epa.gov/compliance/resources/...defeat.pdf
Sincerely, Anadigelec.
(This post was last modified: 03-07-2009 12:20 PM by mike.)
03-07-2009 12:13 PM
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mike Offline
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Post: #3
RE: under Title 42, section 203b of the Clean Air Act it is illegal
Quote:Edit: Haha, Anadigelec. I think I wrote this at the same time as you wrote the post above. I forgot about that post. But I think I explained it in a little more detail below:

The whole point of an EFIE is not to do any of the points prohibited by this reference. It does not "bypass, defeat, or render inoperative" the oxygen sensor. It assists it to do it's job in the presence of a hydrogen on demand system.

The hydrogen increases fuel combustion efficiency. This increase in efficiency has, as one of the effects, higher levels of oxygen in the exhaust. This causes the computer to incorrectly add higher levels of fuel than is needed. This then reduces both the fuel mileage, and reduces the improvement to exhaust gas emissions.

People most often think we use an EFIE to lean the air/fuel mix. This is really a misnomer. We use the EFIE to compensate for the higher oxygen content of the exhaust. The EFIE allows the oxygen sensor to do it's job correctly under these conditions of improved combustion efficiency.

The overall result of a good HHO generator and an EFIE is a dramatic decrease in all types of emissions. I believe that even the most prejudiced enforcer of the Clean Air Act would have a hard time prosecuting someone when the results of the mods dropped the emissions by 30% or more.

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(This post was last modified: 03-07-2009 12:22 PM by mike.)
03-07-2009 12:15 PM
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Anadigelec Offline
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Post: #4
RE: under Title 42, section 203b of the Clean Air Act it is illegal
(03-07-2009 12:15 PM)mike Wrote:  
Quote:Edit: Haha, Anadigelec. I think I wrote this at the same time as you wrote the post above. I forgot about that post. But I think I explained it in a little more detail below:

The whole point of an EFIE is not to do any of the points prohibited by this reference. It does not "bypass, defeat, or render inoperative" the oxygen sensor. It assists it to do it's job in the presence of a hydrogen on demand system.

The hydrogen increases fuel combustion efficiency. This increase in efficiency has, as one of the effects, higher levels of oxygen in the exhaust. This causes the computer to incorrectly add higher levels of fuel than is needed. This then reduces both the fuel mileage, and reduces the improvement to exhaust gas emissions.

People most often think we use an EFIE to lean the air/fuel mix. This is really a misnomer. We use the EFIE to compensate for the higher oxygen content of the exhaust. The EFIE allows the oxygen sensor to do it's job correctly under these conditions of improved combustion efficiency.

The overall result of a good HHO generator and an EFIE is a dramatic decrease in all types of emissions. I believe that even the most prejudiced enforcer of the Clean Air Act would have a hard time prosecuting someone when the results of the mods dropped the emissions by 30% or more.

Hi Mike,
Thank you very much for your answers.
This time I wait from him answers about this law.
He want that I will close all my selling today and immediately.
After your good explanations and reading of this law I will not close my listings.
Again, thank YOU Very Much!
Sincerely, Aleksey. Smile

I have received additional email:
"You can argue that point in court. The factory settings have been altered so that is tampering. I will not warn again. You can let the judge decide. I have already talked to EPA officials about this so this is the last warning you get. Good day."
What to do?
Sincerely, Aleksey.
(This post was last modified: 03-07-2009 01:24 PM by Anadigelec.)
03-07-2009 12:42 PM
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Anadigelec Offline
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Post: #5
RE: under Title 42, section 203b of the Clean Air Act it is illegal
And additional email from him:
"I have written all who sell these devices. You must read the law. Your devices take the signal from the sensor, change the signal and then send it to the computer, modified (tampered with) to cause the computer to lean out the air/fuel ratio. Do not think that I do not know what they do. That signal is part of the emission system. Your devices fool the computer. Therefore they are illegal and you will be reported to the EPA in your state and to EBAY for selling illegal devices. EBay doesnt know the law, but they will by Monday. Good day."

So, I think he want to close all sellers on eBay.
03-07-2009 01:43 PM
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ptours99 Offline
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Post: #6
RE: under Title 42, section 203b of the Clean Air Act it is illegal
(03-07-2009 01:43 PM)Anadigelec Wrote:  And additional email from him:
"I have written all who sell these devices. You must read the law. Your devices take the signal from the sensor, change the signal and then send it to the computer, modified (tampered with) to cause the computer to lean out the air/fuel ratio. Do not think that I do not know what they do. That signal is part of the emission system. Your devices fool the computer. Therefore they are illegal and you will be reported to the EPA in your state and to EBAY for selling illegal devices. EBay doesnt know the law, but they will by Monday. Good day."

So, I think he want to close all sellers on eBay.
if that was real why would'nt they raid your place of business,got all your info from ebay right. i think it's one of your competitors.the M.I.B are'nt that cordial. oh sorry M.I.B[MEN IN BLACK]

selling an enclosure for the rear of cab semi truck 28''X20''X6'' CUSTOM MADE ALUMINUM TO HOUSE HHO GENERATORS AND INCLUDING A RESERVOIR BUBBLER AND REGULAR BUBBLR ptoures@sbcglobal.net usa only
03-07-2009 02:38 PM
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Anadigelec Offline
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Post: #7
RE: under Title 42, section 203b of the Clean Air Act it is illegal
Smile Smile Smile
20 minutes ago I have speak with eBay and my listing not violate any law.
In Monday I will speak wit EPA because I found this very interesting link:
http://www.epa.gov/fuelcell/index.htm
In May 2003, EPA formed a technical partnership with Daimler Chrysler and UPS to conduct a unique fuel cell vehicle testing program.

So, I want ask them about the HHO systems and EFIEs.
Sincerely, Aleksey.
03-07-2009 02:53 PM
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klondikedarol1 Offline
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Post: #8
RE: under Title 42, section 203b of the Clean Air Act it is illegal
I can find no Title 42 In the clean air act. Please inform all of us exactly where it can be found on the net.
03-07-2009 03:34 PM
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Anadigelec Offline
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Post: #9
RE: under Title 42, section 203b of the Clean Air Act it is illegal
http://www.epa.gov/compliance/resources/...defeat.pdf

or

Remove the * from http:
h*t*tp://www.epa.gov/compliance/resources/newsletters/civil/enfalert/defeat.pdf
I found it: Smile
Emission control systems of internal combustion engines are subject to compliance with EPA regulations. Federal regulations prohibit “tampering” with or removing any component of an certified original manufacturer’s emission control system, with exceptions for limited after market conversions to alternative fuels such as propane as provided in EPA Memorandum 1A, and its revised addendum.

The Original text:
http://www.propanesafety.com/Resource%20...1-2007.pdf
(This post was last modified: 03-07-2009 04:24 PM by Anadigelec.)
03-07-2009 03:43 PM
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mike Offline
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Post: #10
RE: under Title 42, section 203b of the Clean Air Act it is illegal
Anadigelec sent me an email with the applicable text from the Clean Air Act, plus a later memorandum regarding the enforcement of it. The following text is from the EPA memorandum.

Quote:B. Interim Policy
1. Unless and until otherwise stated, the Environmental Protection
Agency will not regard the following acts, when performed by a dealer,
to constitute violations of Section 203(a)(3) of the Act:
(a) Use of a nonoriginal equipment aftermarket part (including a
rebuilt part) as a replacement part solely for purposes of maintenance
according to the vehicle or engine manufacturer's instructions, or for
repair or replacement of a defective or worn out part, if the dealer
has a reasonable basis for knowing that such use will not adversely
affect emissions performance; and 􀀀 3
(b) Use of a nonoriginal equipment aftermarket part or system as an
addon,
auxiliary, augmenting, or secondary part or system, if the
dealer has a reasonable basis for knowing that such use will not
adversely affect emissions performance; and
c) Adjustments or alterations of a particular part or system
parameter, if done for purposes of maintenance or repair according to
the vehicle or engine manufacturer's instructions, or if the dealer
has a reasonable basis for knowing that such adjustment or alteration
will not adversely affect emissions performance.

There is quite a bit more text to this memorandum, but it is clear that they are trying to make it clear that if the emissions are not adversely affected, then the device is compliant with the Clean Air Act. You can see the full text of the link here:

http://www.epa.gov/OMS/regs/fuels/cff/memo-1a.txt

Thanks to Anadigelec for his research on this.

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03-09-2009 07:30 AM
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