Date:         Wed, 27 Jan 1999 13:57:00 -0700
Reply-To:     Gary Shea <shea@GTSDESIGN.COM>
Sender:       Vanagon Mailing List <vanagon@gerry.vanagon.com>
From:         Gary Shea <shea@GTSDESIGN.COM>
Subject:      Re: Legal swaps Was: Re: Audi 5 Cyl Swap: Alert! Possible Trouble
In-Reply-To:  <Pine.LNX.3.95.990127131341.320C-100000@gmong.gtsdesign.com>
Content-Type: TEXT/PLAIN; charset=US-ASCII

Well, here's another bit of data.  I just spoke with Jeff Houk
at the Denver EPA Region VIII office, ph # 800 227 8917 x6446.
He had some interesting things to say.

1) The EPA has reg's as far as engine swapping that apply in the
49 states excluding CA.  The EPA reg's are those I described in
an earlier post, namely that the only legal engine
swaps are those which exactly (and I mean _exactly_, it doesn't sound
too flexible...) match a configuration already approved for sale in
the US, are the EPA reg's.  This seems to directly contradict what
Michael Sullivan reported... I can't reconcile the two.  I've heard
it from two sources now, is all I can say.

2) The CA CARB board supersedes the EPA reg's in CA.  Also, the EPA has
no facilities like CA CARB for certifying particular configurations, so
they accept CA CARB cert's anywhere in the 49 states over which they
have jurisdiction.  What that means is that if the results of properly
installing the Eurospec kit or Detlev's installation is ceritified
by the CA CARB board, then it's legal (federally speaking, it says
nothing about local law) everywhere in the country.  Yeay!

3) The EPA laws are enforced by the EPA; the states are not required
to enforce them.  Apparently the EPA does some enforcement on the
work of repair shops and such.  Effectively, the EPA reg's don't
affect those of us who do all our own work, because we'll never
be visited by a representative of the EPA. Keep in mind, however,
that we _are_ technically a bunch of glinty-eyed criminals, renegades,
and generally un-American losers.

To which I'll add:

4) Local government makes its own inspection laws and those are the
point at which things can get sticky.  I don't think that there
are any sure bets at the local level.  You have to talk to your
state, county, and city gov'ts to know what you can do.

I hope this helps make up for my earlier rash statements ;)

        Gary

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Gary Shea                                       shea@xmission.com
Salt Lake City                      http://www.xmission.com/~shea