Egr delete

[Bmyers]

I don’t need a bunch of links to a myriad of laws that don’t address the question “What constitutes a motor vehicle”... I only want to know if that law previously quoted defined the term.

Also, I notice that the law states “...prior to its sale and delivery to the ultimate purchaser, or for any person knowingly to remove or render inoperative any such device or element of design after such sale and distribution to the ultimate purchaser;”

I am the Owner. I am the “ultimate purchaser”. It is mine and I am not selling it for anyone else, and I am not working on anyone elses. I use it only on my own property. I will do whatever it takes to make MY equipment do it’s job for ME.

You choice, ignorance of the law is no excuse.

As you pointed out, not my job to explain to you what a motor is and if you aren't willing to take the time to read the law, do whatever you would like, but you also face the consequences of your actions, just as we all do.

Realize you are shooting the messenger here. You asked where the law was and what it covered, I provided the info. I don't care what you do with your tractor. I'm not a lawyer nor do I work for the EPA, so what you do is your own business.

 

[GeoHorn]

You choice, ignorance of the law is no excuse.

As you pointed out, not my job to explain to you what a motor is and if you aren't willing to take the time to read the law, do whatever you would like, but you also face the consequences of your actions, just as we all do.

Realize you are shooting the messenger here. You asked where the law was and what it covered, I provided the info. I don't care what you do with your tractor. I'm not a lawyer nor do I work for the EPA, so what you do is your own business.

We were writing/posting at the same time. I HAVE read the rule. I posted an excerpt from it above.
The rule is directed at anyone who imports, sells or services engines and/or adapts them for alternative fuels. That ain’t Me.
There are rules regarding airbags, roll-over protections, seat belts, etc. Does that mean an owner cannot defeat those at his own risk? (I understand that once the ROPs are welded upon that a Kubota dealer may not want to work on that tractor. That’s a different issue than stating an end-user cannot modify equipment. )
The trigger on my Marlin has been changed and the cross-bolt-safety on my lever-action has also been removed.

Reposting the EPA answer to the question:
“Does This Action Apply To Me?
This action may affect you if you produce or import new diesel engines which are intended for use in nonroad vehicles or equipment, such as agricultural and construction equipment, or if you produce or import such nonroad vehicles or equipment. It may also affect you if you convert nonroad vehicles or equipment, or the engines used in them, to use alternative fuels. It may also affect you if you produce, import, distribute, or sell nonroad diesel fuel....”

 

[SDT]

You choice, ignorance of the law is no excuse.

As you pointed out, not my job to explain to you what a motor is and if you aren't willing to take the time to read the law, do whatever you would like, but you also face the consequences of your actions, just as we all do.

Realize you are shooting the messenger here. You asked where the law was and what it covered, I provided the info. I don't care what you do with your tractor. I'm not a lawyer nor do I work for the EPA, so what you do is your own business.

Well said, and I fully agree.

SDT

 

[GeoHorn]

If you guys don’t “take the time to read”.... what the EPA answers to the question “does it apply to me”.... then that’s also your choice.

 

[Bmyers]

If you guys don’t “take the time to read”.... what the EPA answers to the question “does it apply to me”.... then that’s also your choice.

I did and it does apply. You have to read ALL the regulations and not just parts of it.

What requirements apply to owners and operators of certified products?

A key part of the regulations that applies to you is the tampering prohibition—you may not disable any emission controls installed on certified engines, vehicles, or equipment. This would apply for removing emission control devices, adding or modifying hardware or software that increases emissions (of any pollutant), reprogramming onboard computers, or operating engines without any needed supplies such as Diesel Exhaust Fluid. Manufacturers explain in their owner’s manual what type of emission controls exist for each model; they may also specify some minor maintenance that must be done to keep emission controls working properly. For restrictions and recordkeeping requirements that apply for rebuilding engines and performing maintenance on certified products, see “How to Maintain or Rebuild Engines Certified to EPA Standards,” (EPA-420-F-18-003, February 2018) which is available at www.epa.gov/regulations-emissions vehicles-and-engines/regulations-emissions-nonroad-vehicles-and-engines. Similarly, EPA regulations prohibit defeat devices—you may not make, sell, or install any part that bypasses, impairs, defeats, or disables the control of emissions of any regulated pollutant. Since manufacturers have the primary responsibility to meet emission standards for their products, you generally have no requirements to achieve a certain level of emission control or to re-certify. However, you must meet additional requirements in two special circumstances: • You may need to use certified kits or systems when remanufacturing locomotive engines or marine diesel engines. • In the case of Marine SI engines (40 CFR part 1045), Recreational vehicles (40 CFR part 1051), and Small SI engines (40 CFR part 1054), you must re-certify if you upgrade your engine to operate on a different fuel. For fuel conversions with other types of nonroad engines, vehicles, or equipment, you may need to do testing to show that the conversion is not considered tampering, but you do not need to re-certify.

Frequently Asked Questions from Owners and Operators of Nonroad Engines, Vehicles, and Equipment Certified to EPA Standards - Questions and Answers (EPA-420-F-18-004, February 2018)

 

[Bmyers]

Before you ask for another definition:

This page provides regulations for nonroad compression-ignition (diesel) engines that are used in machines that perform a wide range of important jobs. These include excavators and other construction equipment, farm tractors and other agricultural equipment, forklifts, airport ground service equipment, and utility equipment such as generators, pumps, and compressors.

 

[GeoHorn]

It’s a shame EPA in their Federal Register publication does not iterate that (Especially since their comments specifically seem to relieve end-users.)

Here is a forthright article which says it in plain language:

What You Need to Know Before Deleting or Tuning Your Heavy Equipment's Emissions System

We constantly receive calls from customers asking about deleting their emissions systems on machines ranging from tractors to heavy equipment. Some of these people want to delete before they send the piece of equipment out of the country, but the large majority are just tired of spending...

www.diesellaptops.com

 

[tradosaurus]

Just because there is a law doesn't make it morally right.

 

[Bmyers]

It’s a shame EPA in their Federal Register publication does not iterate that (Especially since their comments specifically seem to relieve end-users.)

Here is a forthright article which says it in plain language:

What You Need to Know Before Deleting or Tuning Your Heavy Equipment's Emissions System

We constantly receive calls from customers asking about deleting their emissions systems on machines ranging from tractors to heavy equipment. Some of these people want to delete before they send the piece of equipment out of the country, but the large majority are just tired of spending...

www.diesellaptops.com

You have to love the Government 'speak'. The laws can be challenging to understand and then you have to look into the court decisions that have been made concerning the laws and if those courts have jurisdiction in your area. Toss in State and Local laws, it is amazing we aren't all sitting in jail.

I will agree that our Government makes it very challenging to figure out what you can legally do and not do, which this doesn't even bring into consideration the local prosecutors prerogative if a person will be charged or not.

 

[JimmyJazz]

Agree; specifically with the supply and demand statement. B3350 has problems so there would be some demand from B3350 owners but that’s a small subset of tractor owners. Most models, the DPF regen is an occasional annoyance if timing of regen is inconvenient which is a lot less problematic than breaking Federal law and having a tractor that no dealer will touch, potentially decreasing value by narrowing resale market by reducing potential buyer pool to like minded individuals who don’t mind ignoring the law and never having the option to involve a dealer in maintenance or repair. Cost/benefit and risk/reward analysis just doesn’t make sense for the vast majority of Tier 4 owners so the demand for delete isn’t there and neither is supply.

If I owned a 3350 that gave continual problems, I’d be pretty ill about the situation. Thankfully, I’m not in that group.

Some might pay more for a 3350 that had the DPF regen removed. Or at least consider it as a candidate for purchase. There is one on ebay right now 15 miles from me. I am in the market so to speak but would not think of it. Something to consider.

 

[NCL4701]

I’m aware the DPF/DEF stuff is 1) expensive in adding cost to purchase and maintain, 2) creates one more thing to break, 3) does not do one solitary thing to make the machine pull harder, lift more, etc. so embracing it is kind of a cactus hugging operation. If I had a choice of be responsible and do your part to save the planet by buying a Tier 4 DPF or be a selfish lout and get the same machine without exhaust treatment, honestly I would have taken the the smoker and proudly worn my selfish lout hat home.

However, I can’t help but be reminded of the consternation of the hot rodder and mud bogger gear heads I seemed to be running with back when catalytic converters came out. The craziness of taking one of the simplest things on the vehicle, nothing but an empty pipe, (often without even a muffler as all the cool guys were running straight pipe dual exhaust) and put an expensive box with platinum coated balls in it in the middle of that simple pipe. Insanity. NC put in an annual emissions inspection for passenger vehicles manufactured after some certain year so taking it off was verboten and you couldn’t renew the license plate without the inspection. I knew guys that would take it off and run 364 days a year without it, just putting it on for the one day it was inspected. Everybody knew somebody that had one collapse, plug the exhaust, and left them stranded in some perilous place. My brother actually had that happen to the 350 in his Monte Carlo but it was in our driveway, which wasn’t very perilous.

To my amazement the value of the 1973 Dodge pickup I was driving at the time actually started going up because it was pre-emission and there was demand for pre-emission light trucks. Guys buying them didn’t much care about the drive train. They just wanted a relatively straight body without rust that they could polish up, lift, and drop a modded engine in without having to deal with that catalytic converter.

I’m having a hard time recalling the last time I heard anyone complain about a catalytic converter or last time I’ve heard of one collapsing and plugging the exhaust. There just weren’t many problems so it faded to a non-issue.

People here seem to post about every mechanical and electrical problem, from total restorations to some pretty minor stuff, and yet I don’t see people having problems with DPF or regen unless user error deferring regen too much limped it.

I can easily see this going the way of the catalytic converter.

BTW, I wasn’t cool and neither was my truck but I did have straight pipe dual exhaust on a 318 because I was far too cheap to actually buy mufflers. Cool or not it annoyed the crap out of anyone nearby. So I did have that going for me.

 

[SDT]

I’m aware the DPF/DEF stuff is 1) expensive in adding cost to purchase and maintain, 2) creates one more thing to break, 3) does not do one solitary thing to make the machine pull harder, lift more, etc. so embracing it is kind of a cactus hugging operation. If I had a choice of be responsible and do your part to save the planet by buying a Tier 4 DPF or be a selfish lout and get the same machine without exhaust treatment, honestly I would have taken the the smoker and proudly worn my selfish lout hat home.

However, I can’t help but be reminded of the consternation of the hot rodder and mud bogger gear heads I seemed to be running with back when catalytic converters came out. The craziness of taking one of the simplest things on the vehicle, nothing but an empty pipe, (often without even a muffler as all the cool guys were running straight pipe dual exhaust) and put an expensive box with platinum coated balls in it in the middle of that simple pipe. Insanity. NC put in an annual emissions inspection for passenger vehicles manufactured after some certain year so taking it off was verboten and you couldn’t renew the license plate without the inspection. I knew guys that would take it off and run 364 days a year without it, just putting it on for the one day it was inspected. Everybody knew somebody that had one collapse, plug the exhaust, and left them stranded in some perilous place. My brother actually had that happen to the 350 in his Monte Carlo but it was in our driveway, which wasn’t very perilous.

To my amazement the value of the 1973 Dodge pickup I was driving at the time actually started going up because it was pre-emission and there was demand for pre-emission light trucks. Guys buying them didn’t much care about the drive train. They just wanted a relatively straight body without rust that they could polish up, lift, and drop a modded engine in without having to deal with that catalytic converter.

I’m having a hard time recalling the last time I heard anyone complain about a catalytic converter or last time I’ve heard of one collapsing and plugging the exhaust. There just weren’t many problems so it faded to a non-issue.

People here seem to post about every mechanical and electrical problem, from total restorations to some pretty minor stuff, and yet I don’t see people having problems with DPF or regen unless user error deferring regen too much limped it.

I can easily see this going the way of the catalytic converter.

BTW, I wasn’t cool and neither was my truck but I did have straight pipe dual exhaust on a 318 because I was far too cheap to actually buy mufflers. Cool or not it annoyed the crap out of anyone nearby. So I did have that going for me.

People do have problems with the B3350 emissions system whether they follow the instructions in the Operator's Manual to the letter or not.

Nearly all B3350 owners know this and so does Kubota.

SDT

 

[sheepfarmer]

People do have problems with the B3350 emissions system whether they follow the instructions in the Operator's Manual to the letter or not.

Nearly all B3350 owners know this and so does Kubota.

SDT

Agreed. But many of the other dpf models are trouble free absent pilot errors. What will happen when they are 15 years or more old remains to be seen. The biggest criticism for these and many new ag implements is their dependence on a dealer for repair.

 

[MNVikingsGuy]

If you guys don’t “take the time to read”.... what the EPA answers to the question “does it apply to me”.... then that’s also your choice.

You are right that the "motor vehicle" rules don't directly apply to "non-road vehicles" in the statute. But you are wrong in thinking the analysis ends there. Title42:85:ii; Part A section 7547(a) grants the EPA authority to set similar standards for "non-road vehicles" - which it did with the Tier 4 regulations; and 7547(d) authorizes them to be "enforced in the same manner as the "motor vehicle" section. The "motor vehicle" section prohibits, "any person knowingly to remove or render inoperative any such device [referencing pollution control devices] or element of design after such sale and delivery to the ultimate purchaser."

Add to this various state laws that prohibit tampering with pollution control devices (some directed to motor vehicles, some more broadly).

Do what you wish. But it is incorrect to say that these rules do not apply to the activities being discussed on this thread. Operate on the "they won't catch me" principle if that is your approach to being a law-abiding citizen, but don't confuse yourself or others that the law does not apply to you or that you have found a loophole.

 

[802Driver]

Agreed. But many of the other dpf models are trouble free absent pilot errors. What will happen when they are 15 years or more old remains to be seen. The biggest criticism for these and many new ag implements is their dependence on a dealer for repair.

This is the hard reality, farm machinery nowadays are almost completely "dealer dependant". Sensors for everything and everything run by software. Very high-tech until a sensor fails and renders the equipment into limp mode. Watched a documentary on mid-west farmers in the US lobbying against companies like John Deere who hold the software license and are refusing to allow the software into the hands of the farmers so they can access fault codes and such that render their machinery almost useless til fixed.

The point is the days of simple robust "dependable" machinery are disappearing, it's not enough to shell out a premium for a new tractor, when something goes wrong, you have to load it up and cough up more money to the dealer to diagnose and repair it along with the down-time.

I think I'd be a nervous wreck if I was a farmer these days.

 

[NHSleddog]

I’m aware the DPF/DEF stuff is 1) expensive in adding cost to purchase and maintain, 2) creates one more thing to break, 3) does not do one solitary thing to make the machine pull harder, lift more, etc. so embracing it is kind of a cactus hugging operation. If I had a choice of be responsible and do your part to save the planet by buying a Tier 4 DPF or be a selfish lout and get the same machine without exhaust treatment, honestly I would have taken the the smoker and proudly worn my selfish lout hat home.

However, I can’t help but be reminded of the consternation of the hot rodder and mud bogger gear heads I seemed to be running with back when catalytic converters came out. The craziness of taking one of the simplest things on the vehicle, nothing but an empty pipe, (often without even a muffler as all the cool guys were running straight pipe dual exhaust) and put an expensive box with platinum coated balls in it in the middle of that simple pipe. Insanity. NC put in an annual emissions inspection for passenger vehicles manufactured after some certain year so taking it off was verboten and you couldn’t renew the license plate without the inspection. I knew guys that would take it off and run 364 days a year without it, just putting it on for the one day it was inspected. Everybody knew somebody that had one collapse, plug the exhaust, and left them stranded in some perilous place. My brother actually had that happen to the 350 in his Monte Carlo but it was in our driveway, which wasn’t very perilous.

To my amazement the value of the 1973 Dodge pickup I was driving at the time actually started going up because it was pre-emission and there was demand for pre-emission light trucks. Guys buying them didn’t much care about the drive train. They just wanted a relatively straight body without rust that they could polish up, lift, and drop a modded engine in without having to deal with that catalytic converter.

I’m having a hard time recalling the last time I heard anyone complain about a catalytic converter or last time I’ve heard of one collapsing and plugging the exhaust. There just weren’t many problems so it faded to a non-issue.

People here seem to post about every mechanical and electrical problem, from total restorations to some pretty minor stuff, and yet I don’t see people having problems with DPF or regen unless user error deferring regen too much limped it.

I can easily see this going the way of the catalytic converter.

BTW, I wasn’t cool and neither was my truck but I did have straight pipe dual exhaust on a 318 because I was far too cheap to actually buy mufflers. Cool or not it annoyed the crap out of anyone nearby. So I did have that going for me.

That all sounds good however your catalytic converter isn't a wear item. Every DPF will need future replacement costing thousands.

 

[NHSleddog]

I still can't find a single study, or results showing how burning millions of gallons of a new chemical, and burning millions of additional gallons of diesel are saving ANYTHING! Especially the environment.

I love the current DEP fluid bottles I have, they come in a thick cardboard box and the box is part of the "container" and should not be separated. Must be some super planet saving stuff in the mountains of garbage being created. A pallet of DEF fluid weighs over 1600Lbs and is transported over 900 miles on average. BTW - The creation of the DEF fluid ALSO requires a bunch of energy.

FYI - EPA - With annual DEF demand forecasted to top 1.7 billion gallons by 2026

Sorry for the rant, cheer away!

 

[NCL4701]

This is the hard reality, farm machinery nowadays are almost completely "dealer dependant". Sensors for everything and everything run by software. Very high-tech until a sensor fails and renders the equipment into limp mode. Watched a documentary on mid-west farmers in the US lobbying against companies like John Deere who hold the software license and are refusing to allow the software into the hands of the farmers so they can access fault codes and such that render their machinery almost useless til fixed.

The point is the days of simple robust "dependable" machinery are disappearing, it's not enough to shell out a premium for a new tractor, when something goes wrong, you have to load it up and cough up more money to the dealer to diagnose and repair it along with the down-time.

I think I'd be a nervous wreck if I was a farmer these days.

Agree. And seems to me the dependence on dealer is more of a software issue than a emissions treatment issue.

 

[NCL4701]

That all sounds good however your catalytic converter isn't a wear item. Every DPF will need future replacement costing thousands.

Sort of. The catalytic converter does eventually stop working as it is depleted but it doesn’t collapse or limp the vehicle so exhaust still flows through it and the vehicle runs without any noticeable problem other than if you tested the exhaust it would fail. At least here, they stop testing they exhaust gasses after 10 years. I doubt that was a mistake on the part of lawmakers. More likely they didn’t want masses of their constituents upset about having to replace a no longer functional converter costing almost as much as their old car is worth. The percentage of voters impacted by diesel exhaust regs isn’t enough to get their attention.

No doubt you are correct about the coming cost of replacing the DPF unit. Which is why I would have avoided it if I had a reasonable alternative.

The motives for the regs are more motivated by emotion and politics than by science. The ACTUAL net impact is not material to the regulation.

I’m thinking I should get off this thread now because a lot of this issue is more politically driven than scientifically driven and politics are rightly off limits here.

 

[sempifi99]

Just because there is a law doesn't make it morally right.

Well said!