CWright@
arcticcatinc.
c
om
Received
Date:
10/
15/
2004
10:
26:
32
AM
Transmission
Date:
10/
15/
2004
10:
26:
32
AM
To:
Linc
Wehrly/
AA/
USEPA/
US@
EPA
cc:
Subject:
Tech
Amendments
Hi
Linc,

I
have
two
concerns
with
the
tech
amendments.

1.
1051.225(
f)(
1)
See
below
(
the
following
cite
should
include
strikeout
and
underlined
text).
There
is
a
fundamental
change
in
meaning
here
from
a
"
must"
to
a
"
may
not".
If
we
are
raising
an
FEL
it
is
because
PLT
units
are
not
passing.
The
problem
is
how
do
units
already
produced
comply
to
the
FEL
if
PLT
results
are
not
making
it
and
we
can't
change
the
FEL
for
these
units?
If
you
recall,
we
asked
EPA
to
include
this
section
for
this
very
reason
and
we
discussed
this
at
length.
I
don't
believe
your
intent
to
make
us
recall
the
engines
that
we
produced
before
raising
the
FEL.
If
so
that
is
that
is
a
monumental
change,
not
a
technical
amendment.
I
also
do
not
believe
that
you
intend
to
let
us
take
credit
for
engines
already
produced
that
are
failing
PLT
without
a
recall.
If
so
please
add
language
to
clarify
this.

Honestly,
I
find
it
really
disturbing
to
discover
this
change
in
the
language.
I
sincerely
hope
that
it
was
just
a
simple
error
because
this
was
an
important
issue
for
us
and
we
had
an
understanding
with
EPA
as
to
how
this
section
solved
the
problem
in
a
way
that
was
acceptable
for
all
of
us.

(
f)
You
may
ask
to
change
your
FEL
in
the
following
cases:
(
1)
You
may
ask
to
raise
your
FEL
for
your
engine
family
after
the
start
of
production.
You
must
use
may
not
apply
the
higher
FEL
for
the
entire
family
to
engines
you
have
already
introduced
into
commerce.
Use
the
appropriate
FELs
with
corresponding
sales
volumes
to
calculate
your
average
emission
level
under,
as
described
in
subpart
H
of
this
part.
In
your
request,
you
must
demonstrate
that
you
will
still
be
able
to
comply
with
the
applicable
average
emission
standards
as
specified
in
subparts
B
and
H
of
this
part.

2.
We
would
like
to
see
some
language
in
the
technical
amendments
that
clarifies
what
you
said
below
about
tamper
proof
screws
on
carburetors
that
use
jet
charts.
I
recommend
adding
the
following
paragraph:

1051.115(
d)(
3)(
vi)
The
adjustable
range
of
carburetor
screws,
such
as
air
screw,
fuel
screw,
and
idle
speed
screw
must
be
defined
by
stops,
limits,
or
specification
on
the
jetting
chart
in
a
manner
consistent
with
requirements
for
specifying
jet
sizes
and
needle
configuration
in
this
section.

Thanks,
Chris
Wehrly.
Linc@
epamail.
epa.
gov
on
09/
24/
2004
03:
03:
07
PM
To:
CWright@
arcticcatinc.
com
cc:
Subject:
Re:
Oil
cap
Chris,
It
would
be
ok
to
use
a
pressure
relief
oil
cap
as
long
as
it
is
only
a
fix
for
models
that
you've
already
sold
and
not
to
be
used
on
any
current
or
future
models.
As
for
your
question
the
other
day,
idle
screws
would
be
considered
the
same
as
jets
and
needles.
You
do
not
need
to
sell
tamper­
proof
screws
on
your
carburetors.
Let
me
know
if
you
have
any
other
questions.

Linc
Linc
Wehrly
USEPA
Certification
and
Compliance
Division
(
734)
214­
4286
wehrly.
linc@
epa.
gov
CWright@
arcticcatinc.
com
To:
Linc
Wehrly/
AA/
USEPA/
US@
EPA
cc:
Subject:
Oil
cap
Transmission
Date:
09/
24/
2004
02:
47:
45
PM
Hi
Linc,

I
forgot
to
bring
up
another
issue
when
I
talked
to
you
today
about
adjustable
parameters
on
snowmobiles.
We
have
had
a
few
customers
that
have
been
able
to
find
conditions
of
extreme
cold
and
riding
styles
that
result
in
moister
traveling
through
the
breather
tube
to
freeze
and
plug
the
tube
on
our
4­
stroke
turbo
models.
We
have
not
been
able
to
repeat
the
problem
here
but
have
had
more
than
one
report.
We
have
changed
the
design
of
current
and
future
models
to
supply
engine
coolant
to
the
breather
area
to
prevent
freezing,
however,
this
is
difficult
to
retrofit
on
to
prior
model
years.

For
prior
models
we
would
like
to
supply
an
oil
cap
directly
to
the
customer
with
a
pressure
relief
valve.
This
valve
would
relieve
crankcase
gasses
into
the
engine
compartment
in
very
rare
conditions
where
the
breather
tube
temporarily
freezes
closed.
If
venting
does
not
occur
when
the
breather
freezes
up
then
the
PTO
seal
blows
out
or
the
dipstick
pops
out
and
oil
goes
everywhere
resulting
in
a
series
of
potential
problems
(
mess,
stranding,
serious
engine
damage).

Is
our
solution
to
use
a
pressure
relief
cap
OK?

Thanks,

Chris
