Comment Log Display

EPA rules and CARB Modified Text differ in the way that permeation
is treated for diesel ATV's and OHRV's.

US EPA excludes diesel ATV's and OHRV's from part 1051 per 40 CFR
1051.5(a) leaving them covered by 40 CFR part 89 where permeation
is not addressed.  This means these diesel engines have no US EPA
fuel tank or fuel line permeation standards.  Due to high
molecular weight and low volatility of diesel fuel there is no
need for corresponding permeation standards.

Since ARB rules DO NOT exclude diesel ATV's and OHRV's fuel tanks
and fuel lines used in these vehicles will fall under new CARB
permeation standards that were recently published in this 15
notice. 

A specific exclusion is needed in the Modified Text to the effect
that CARB permeation standards for fuel tanks and fuel lines do
not apply to ATV's and OHRV's powered by diesel engines.

After raising this issue informally in February we received
correspondence from ARB on 3/6/2007 that ARB will not require
diesel ATVs to meet the permeation standards that begin in 2008. 
It appears that the need for a specific exclusion to execute this
policy may have been overlooked.