quote:

selling directly from a fueling pump style device that can be dispensed and in fact encourages it to be dispensed directly into an automobile implies you are selling a "motor fuel". And that is where the problem begins.

You might notice that in this entire discussion I have never suggested that.

quote:

I think in the short term, we are limited to selling WVO by the jug, as simply oil, to avoid being accused of selling a “motor fuel”.

As do I.

This seems like the easiest, cheapest, and most fool proof way to begin this process.

Combined with a "cubee cage" with a changable combination lock the use of cubees also allows for an unattended depot where cutomers that have pre paid for wvo can serve themselves.

quote:

Originally posted by danalinscott:

It appear there are two types of individuals who are seriously interested.

Those that already have some type of WVO collecting/processing that currently sell VO as fuel or biodiesel feedstock.
and
Those that are looking for extra income, have the processing equipment already, and have access to more wvo than they can possibly use.

To either of these groups of people, Legal or not, I doubt anyone wants to deal with the inevitable hassles that will come with selling WVO from a variety of sources besides Tax concerns.

As mentioned, EPA, local councils, fire Departments and and no doubt a bunch of other people are going to be interested in these ventures. One can try to " fly under the radar" but if discovered, you can bet that everyone will be going through you with a fine tooth Comb trying to find out what and why you were hiding.

People should make no mistake, in order to do this without attracting unwanted attention and risking heavy fines, this is a major undertaking that is going to require a huge investment of time and no doubt a significant one monetarily just complying with all the regs various authorities will require. If people are coming onto a property to buy something, there is also the public liability insurance aspect. If the property is already covered the oil sales would have to be included and if someone is doing this as a side line, they would want to get insurance lest someone gets out of a vehicle, gets their foot caught in the seat belt and falls and hurts themselves. The fact they were on your property ( Or someone's ) means you are liable and without insurance, your puting every thing you own ( and may own in the future) at risk.

I am sure those that start out of this endeavor whom want to do it fully legally will realize all this and come to see what an undertaking it is.

Out of interest, where do you have in mind to set up your facility Dana and how are you going to actually go about the sales and delivery/ dispensing of the oil?

quote:

Originally posted by Sunrise Club:
Now if we consider selling WVO in the same fashion that water is sold, we might be stepping in the right direction.

Consider for a moment two types of selling...
1) Water from a grocery store - Is sold in plastic containers ranging from a pint to 2.5 gallons. There are also varieties of water intended for different purposes (filtered, distilled, spring, RO). Yet in each case, the water can be consumed (drank) by the consumer.

2) Water from a water store or parking lot dispenser - Is sold by volume and dispensed into the customer supplied container. In some cases, container size is not limited.

Oh...
We're not back to the HHO stuff are we?

As far as the VO.

I'd encourage trying to work out paying the road taxes.

Dana's original map shows a mark in most of the western states, and many of the eastern states...

It would be easy enough to adjust the map to skip any state that was overly uncooperative.

I suppose at first the majority of the "vendors" would be looking at pretty small sales volumes... so say if they get hit with a 50 cent tax on 10,000 gallons of previously sold fuel, it won't break anybody's bank, although it would bite quite a bit.

Or,
As I've suggested earlier, there should be a 50 cent or so Federal Tax credit on renewable fuels. I'd argue for a tax exemption (in writing / legislation) for choosing to neither pay road taxes, nor request a tax credit.

Other than road taxes. There are also income taxes and sales taxes... All states have their limits, but I wouldn't encourage trying to fly so low under the radar to avoid applicable state and federal income and sales taxes.

Far too often one hears of people who have tax liabilities in excess of $100K... and are loosing their house, and other assets... generally from small business cutting corners with taxes.

"Road Taxes" are largely a myth. There are motor fuel taxes imposed by most jurisdictions in N.America. Most jurisdictions only tax motor fuel used on public roads, but that doesn't make them 'road taxes' per se. The tax money usually goes into general revenue. In some jurisdictions only petro fuels are taxed. It's up to the user to decide what taxes are applicable.

quote:

I am sure those that start out of this endeavor whom want to do it fully legally will realize all this and come to see what an undertaking it is.

I think that many might do exactly that. But some will likely come to believe that one or more of the options which are developed from this discussion are not as huge an undertaking as you imply.

quote:

Other than road taxes. There are also income taxes and sales taxes... All states have their limits, but I wouldn't encourage trying to fly so low under the radar to avoid applicable state and federal income and sales taxes.

I don't think that tax avoidance is even being discussed/considered here.
Finding legal ways to comply with the existing laws are.

quote:

It would be easy enough to adjust the map to skip any state that was overly uncooperative.

The map is a representation of a prospective initial network. No state is going to "cooperate" in this venture. Rather the participants need to set up the ventures to comply with state law as best they can. This is an intial step in the creation of any business.

quote:

As I've suggested earlier, there should be a 50 cent or so Federal Tax credit on renewable fuels. I'd argue for a tax exemption (in writing / legislation) for choosing to neither pay road taxes, nor request a tax credit.

That would be a good discussion to have separately.
It is not centrally germain to this discussion.

quote:

I'd encourage trying to work out paying the road taxes.

Why?
It would appear to be much more advantagous to not refer to WVO as fuel at all.
As another poster pointed out earlier in this discussion if WVO is not considered a fuel it need not be sold as one. The use is up to the end user. If one buys svo at the supermarket one does not even pay sales tax on it in some states. WVO should be no different..except that it cannot be sold as food..and so sales tax will likely be due on its retail sale in nearly every case.

This is a relatively easy regulation to comply with and clerly indicates that "WVO Depot" operators are not attempting to avoid paying state taxes due.

Building on this concept I believe that while the quality of the wvo (filtered to 10 microns, <500ppm water content,etc) should be available in "advertising" these depots the word "fuel" should only be used in the context of "can be used as feedstock for making biodiesel fuel".

quote:

As mentioned, EPA, local councils, fire Departments and and no doubt a bunch of other people are going to be interested in these ventures.

I think not.
As long as these ventures comply with the applicable laws and regulations I doubt that anyone will be "interested" except those who wish to buy prefiltered/dewatered wvo.

quote:

People should make no mistake, in order to do this without attracting unwanted attention and risking heavy fines, this is a major undertaking that is going to require a huge investment of time and no doubt a significant one monetarily just complying with all the regs various authorities will require.

Pure FUD.
This may be true in OZ but it is not in NA.

Part of the discussion we are attmpting to have here is how we can set up these (initially very) small businesses with a very small investment in time and capital while complying with all applicable laws and regulations. Your speculation may apply to OZ...but I think that you have nothing but speculation to suppport your above statement.

quote:

there is also the public liability insurance aspect.

Yes..something that will have to discussed in detail at some time.
If anyone considering joining this project wants to discuss it NOW..please speak up..otherwise I think it might not be as key as a few other subjects that may have a higher priority currently.


I think that the TAX issue has pretty much been resolved.
Sales taxes are due in states that have sales taxes which apply to sale of WVO.
State and Federal income taxes is due on any net profit from ANY business.

I suggest that we discuss how to initially set up the depots themselves.
It has been suggested by myself and others that they not resemble "fuel stations".
No tanks, pumps, nozzles, hoses, signs, or attendants.
Self serve..pre-pay.

I would like to apply the KISS principal which referrs to "Keep It Simple Stupid"..but is more accurately expressed by engineers like this.

quote:

Every aspect should be as simple as possible..but no simpler

So how simple can this be made?

The depot itself can be portable but well secured.
This allows for a very low inital investment in infrastructure.
A simple to fabricate depot unit needs to be developed.

Product can be purchased/dispensed by the "cubee".
This allows for a low cost method of determining volume at a very low cost.
A deposit can be required on cubees to allow that ongoing cost to approach zero.
A minimum purchase volume or bulk discount should be established.

The purchase/sale transaction can be accomplished online.
This transaction can use a central "escrow" agent to protect the interests of both parties.
Once payment is in "escrow" the vendor can provide the "VO Depot" location to the customer and a simple number to open the combination lock on the depo kiosk doord which will provide access to the number of cubees of wvo requested. A deposit on clean cubees will also be required. After the the depot owner has verified the number of clean cubees deposited equals those removed the deposit porting can be refunded to the customer automatically.

A mechanism should be developed that will ensure that WVO being sold through this network meets a minimum standard. That standard needs to be established.

A ROI on initial investment needs to be determined.
For those who have collection and processing (prefiltering/dewatering) eqipment already the main cost will be the "kiosk" itself. I beleve a simple to fabricate design for that should be relativly easy to create.

This would appear to be a reltivly simple and low cost to establish and operate small busniess.
But there are still many details to discuss.

This message has been edited. Last edited by: danalinscott,

quote:

A minimum purchase volume or bulk discount should be established.

Would 4 cubees be a reasonable minimum purchase?

If so this might be a good starting point for the"kiosk" design.
I have a BMP image if anyone wants to import it into "MS paint" to improve it.



I assume that most would want a design that can be fabricated without welding equipment/skills.
It would need to be fire, theft, and weather resistant of course.

This message has been edited. Last edited by: danalinscott,

The FDA will get down on you very heavily if you imply in any manner that the WVO is intended for human consumption.

If this is being SOLD (exchange of money for product)
And it is intended to be used as a fuel.
Going to the end consumer...

Then it should have road taxes.

Too many stories about people getting fined for running fuel in their vehicles without the proper taxes.

http://www.newsobserver.com/news/story/599471.html
http://www.groovygreen.com/groove/?p=1480

EPA not quite recognizing vegetable oil as a fuel, but more or less ignoring it is another issue.

Cubies would be ok...
(with recycling & etc).

But, it would be so much easier to pull up to a pump. Put a hose nozzle into the vehicle, and let it go chug until the tank is full. Then either get a dollar amount, or a volume, and pay for it.

I guess I would tend towards a "filling station" network like is done with every other fuel. Cardlock, manned, or a combination of the two.

Although I like the ease of refueling from a regular "fuel" despensing pump, they're expensive to purchase, require maintenance, require periodic certification by Weights and Measures if used for retail sales, and are prone to vandalism and abuse unless somehow protected (in a locked enclosure? Hmmm).
How much does it cost to buy new, empty cubies of the kind used by fryer-grease companies? They would need an appropriate product label, and would need to be very clearly identified as "NOT FOR HUMAN CONSUMPTION". Around here (eastern Washington), used cooking oil is presently more valuable as a hog feed suppliment than as a biofuel feedstock.
The same recycle system being used for restauraunt cubies would work for these ones, too.
A long time ago I asked the rendering company if I could buy used cooking oil from them. They told me that it had to be processed before it could be resold, in order to eliminate pathogens that could re-enter the foodchain through misuse. The processing involved steam cooking, filtering and gravity separation into different weights, plus a limited amount of "winterization" to strip out high melting point fats. It's not a cheap process to construct, but isn't complicated technology. Oh, yes, they also have to submit samples to the Department of Health to keep their certification. That's likely to be way beyond what we would need to do as a "filling" (not "fueling") station, but some jurisdictions might not agree.

Our local Farm Coop cardlock station has unattended gas, diesel, untaxed diesel, lube oil and Kerosene despensers. The oil and kerosene despensers have skinny hoses and appear to be 1950's despensing pumps. They don't have "fuel nozzles", but rather a sort of cast metal nozzle that obviously fits easily into a barrel bung. They would be perfect for despensing "animal grease suppliment".

Cheers,
JohnO

quote:

The FDA will get down on you very heavily if you imply in any manner that the WVO is intended for human consumption.

I don't think that nayone has implied that...or is likely to.

quote:

Too many stories about people getting fined for running fuel in their vehicles without the proper taxes.

It is clearly the responsibility of any end user to pay the "road" tax on wvo they use for on the road fuel.

quote:

Cubies would be ok...
(with recycling & etc).

But, it would be so much easier to pull up to a pump. Put a hose nozzle into the vehicle, and let it go chug until the tank is full. Then either get a dollar amount, or a volume, and pay for it.

I guess I would tend towards a "filling station" network like is done with every other fuel. Cardlock, manned, or a combination of the two.

I agree. THAT would be so much nicer..but it seems impractical to BEGIN that way. The investment is too high and the volume too low to justify such an infrastructure currently. Perhaps as the initial "depots" prove they can generate income without generating fines the owners will upgrade them little by little.

quote:

A long time ago I asked the rendering company if I could buy used cooking oil from them. They told me that it had to be processed before it could be resold,

Many years ago I too contacted local wvo collectors and rendering plants. The collectors could sell wvo to me..but the rendering plants (who included carcasses of diseased animals in their collections) could not without processing it.

I have found it is very easy to get as many "clean" cubeees as I want for $1 each. "Clean" in that they only have a little unused svo in them.

I think that labels are also be a very good idea. Is there any other information that might be wise to include on lables besides the "not for human consumption" advisory?

A simple label that states "USED VEGETABLE OIL" "NOT FOR HUMAN CONSUMPTION" is all that's needed. Any more information and it starts to get complicated re: taxes, liability, etc.
Words like "fuel" "SVO" "WVO" "biodiesel", should be specifically avoided so as not to imply any end use. What the buyer chooses to do with it is their business.
I agree that empty cubies [in their cardboard box] should be easy to obtain, then stick the label over the existing label. If enough cubies were difficult to find then a reduced price might be offered if someone returned a clean cubie.

quote:

Originally posted by danalinscott:

[QUOTE] People should make no mistake, in order to do this without attracting unwanted attention and risking heavy fines, this is a major undertaking that is going to require a huge investment of time and no doubt a significant one monetarily just complying with all the regs various authorities will require.

quote:

Pure FUD.
This may be true in OZ but it is not in NA.

HAHA! Really??
You have laws and regulations there I have never heard of here.
If it's going to be so easy, I take it you would recommend those interested in this sort of facility contact all the relevant authorities that may have a say in this and tell them exactly what is being done and obtain any and all necessary permits, Licenses and be totally up front and above board. That is what you would reccomend people do isn't it Dana?

IF people did this before they did anything else then they could sleep easy knowing they have nothing to worry about if any inspector or authority turn up on their door step.

quote:

there is also the public liability insurance aspect.

I suggest that we discuss how to initially set up the depots themselves.

I suggest you tackle the insurance issue first because there is little point in getting something up only to later find something has to be re-done because of some insurance technicality.
People also would be well advised to find out what insurance will cost as well as getting estimates on everything else so they get and accurate idea on how cheap, easy and simple doing this legally and in full compliance of all relevant regulations will be.

quote:

Out of interest, where do you have in mind to set up your facility Dana and how are you going to actually go about the sales and delivery/ dispensing of the oil?

You missed my question here Dana. Id be interested to hear how and where you are going to do your setup amd I'm sure others would be as well so they could follow your lead.

quote:

You missed my question here Dana.

I saw it.And ignored it.
I don't feel any obligation to answer the questions of someone who is pretty obviously trolling.

quote:

IF people did this before they did anything else then they could sleep easy knowing they have nothing to worry about if any inspector or authority turn up on their door step.

That is impractical.
Until a business plan is fairly well formed it is unproductive to request information on regulations which may be relavent to the activities of that business. Once the basic business plan is fleshed out a bit it becomes possible to understand better which authorities might have regulations governing this business activity. But since there are 50 states in the US..and there are some in Canada that might ALSO wish to participate a general plan is all that can be accomplished here. Each individual will have to approach their own state or province to determine the exact regulations that might apply. However that general plan should be designed to minimise the amount of regulation which might apply to it wherever in NA it is used.

quote:

be totally up front and above board. That is what you would reccomend people do isn't it Dana?

Yes..I reccomend complying with all laws and paying all taxes that applly to the business.
But in order to do that one has to have a pretty good idea of exactly how that bussiness will be operated. We have not developed that at this point. Eventually we will.

For example:
If I contacted my state commerce dept and told them I am planning on selling fruit and vegetables they would provide me with a set of regulations which need to be complied with that is several inches thick. However if I told them I was planning on selling fruit and vegetables I raised myself they would hand me a pamphlet. Until one can provide specific questions to a regulatory agency they cannot provide useful or accurate responses.

Similarly I think we have just determined that it is probably best to not sell wvo as "fuel". I don't think anyone considering providing prefiltered/dewatered wvo cares if it is used for animal feed supplement, biodiesel feedstock, or fuel. If we are not selling it specifically to be used for fuel the regulations governing this activity appear to be significantly simpler than if we are. Clearly sales tax will be due in states that tax the retail sale of recycled commodities but paying the taxes on any used as fuel in road vehicles is clearly the responsibility of the consumer. But the regulations which apply to THAT are MUCH easier and less expensive to comply with than selling fuel.

Incorporating this concept into the business plan significantly reduced the amount of regulations which apply to the business activity. Simlarly adding a label to the cubees of wvo lowers the liability exposure. I imagine that agreements that the customer must "sign" in order to complete the pre-pay transaction can further lower the risk exposure. For example a liability waiver can be incorporated in the online pre-payment agreement. Or a arbitration clause.

quote:

I suggest you tackle the insurance issue first

Again..there is little point in discussion of what insurance might be required until the business plan is developed a bit better. No insurance company can provide an accurrate idea of the type of insurance needed let alone a quote of the cost until that is more well developed.

You have never started a small business have you?
There are a lot of preliminary steps in creating one.
We are currently engaged in the preliminary steps of creating a business "template" which can then be applied to the individual business plans which may then still require slight modification to comply with the regulations for each specific state/province.

quote:

Originally posted by danalinscott:
Similarly I think we have just determined that it is probably best to not sell wvo as "fuel". I don't think anyone considering providing prefiltered/dewatered wvo cares if it is used for animal feed supplement, biodiesel feedstock, or fuel.

Unfortunately, that is the whole point of this endeavor...

You aren't designing this national web so that hog farmers everywhere can pay extraordinary prices for the oil.

The problem with this kind of business is that someone will get pissed off... Perhaps it will be a competitor (several may feel you are taking away THEIR product or business). Perhaps it will be someone concerned about smoke being generated by a vehicle.

Someone will sit outside of the kiosk, and get a photo of a person showing up at the kiosk, getting some cubies out, and pouring them into their fuel tank, then driving off.

Then you can bet, every tax man in the country will show up, the EPA, OSHA, DOT, FDA, Business Licensing, etc.

And, suddenly the game of trying to avoid notice will fall flat.

quote:

Someone will sit outside of the kiosk, and get a photo of a person showing up at the kiosk, getting some cubies out, and pouring them into their fuel tank, then driving off.

That is highly unlikely...

quote:

Then you can bet, every tax man in the country will show up, the EPA, OSHA, DOT, FDA, Business Licensing, etc.

And that is even more unlikely.

quote:

The problem with this kind of business is that someone will get pissed off... Perhaps it will be a competitor (several may feel you are taking away THEIR product or business). Perhaps it will be someone concerned about smoke being generated by a vehicle.

Might I ask...WHO exactly is a "competitor" likely to do that?
There IS no competition currently.

And who is likley to generate more smoke with a VO fuelled diesel?
Normally they produce less visible smoke than diesel fuel does.

I encourage you to bring up legitimate problems..but theses are pretty far fetched.

quote:

Similarly I think we have just determined that it is probably best to not sell wvo as "fuel". I don't think anyone considering providing prefiltered/dewatered wvo cares if it is used for animal feed supplement, biodiesel feedstock, or fuel.

Unfortunately, that is the whole point of this endeavor...

Not really.
That may be why I began this dicsussion..but that is a point that any businesss that sells wvo should probably be careful to avoid making.


Currently it is possible to purchase VO in nearly any supermarket.
The final use of the VO purchased from them is up to the customer.
It can be used for frying or baking or for massaging or to add to pet food or the making of biodiesel..or as fuel. How it is used is ultimately up to the customer.

Costco does not advertise that they sell VO which might be used as fuel...and neither should these "VO Depots". They sell VO ..and these businesses will sell WVO. That is the only significant difference. Possibly there is one other signficant difference. In states that do not collect taxes on food items Costco would not have to remit sales tax..and these businesses will.

quote:

You have no problem answering my other questions including the ones below and quoting them to do so. What's is wrong with this question?

Nothing is "wrong" with it..but as I said before...

quote:

I don't feel any obligation to answer the questions of someone who is pretty obviously trolling.

When you post questions that may produce productive discussion IMO I reply to them. When you don't I don't.

I think that most readers will see that your intention is not to contribute to a constructive discussion..but to troll for responses as entertainment.

Perhaps both of our puposes will be served by the following responses.

quote:

I would think that someone with all the experience and knowledge you so often remind us of would only be too willing to take the lead and kick this off

Which is exactly what I am doing by encouraging this discussion.

quote:

It seems to me that you are trying to convince others to put their time, effort and money on the line

Nope..just trying to encourage a discussion on this subject.

quote:

For example:
If I contacted my state commerce dept and told them I am planning on selling fruit and vegetables they would provide me with a set of regulations which need to be complied with that is several inches thick. However if I told them I was planning on selling fruit and vegetables I raised myself they would hand me a pamphlet.


I find this VERY hard to believe. The point is not how they were grown or by whom, the point would be that you are selling them commercially to the public and you would need to comply with the same regulations.

You may find it hard to believe..but it is a fact.

quote:

Perhaps in one odd corner of the world your example may be accurate but I find it highly unlikely it would apply many other places, especially in a regulated country like the US.

And yet it does.

quote:

You are clearly going out of your way to be deceptive, hide what you are really doing and circumvent laws, taxes and other regulations.

No..actually we are researching how we can accomplish something without breaking any laws, avoiding any taxes, or violating any regulations.

quote:

You are purposefully being deceptive and dishonest by fully intending the oil to be sold as fuel but then trying to pass it off as if you intended it to be used for other purposes.

Not at all..no one involved cares what the product will be used for.
That is up to the end user.

quote:

When the officials whom you reckon will never investigate

Whe exactly would those "officials" be?

quote:

you are clearly adviseing people how to circumvent them.

That may be your POV...but it is not reality.

I am not advising anybody to do anything.
We are discussing how to legally sell prefiltered and dewatered wvo legally.

quote:

you are trying to play down a lot of the risks, costs and trouble

Nope. Just trying to have a discussion on what those might realistically be..and how to minimise them.

quote:

People should believe neither you nor I.
They should go out and make their own through investigations

We agree on that.
And while the information developed in discussions such as this one is a good start it is not the "end" by any means.

quote:

You don't need a completed business plan to go to the EPA, your local council or an insurance company and say " This is what I am thinking of doing, what laws and regulations do I need to be aware of and comply with?"

You do if you want to get useful and accurate responses from them.

quote:

You don't want to go building something to then find out 75% of what you have done and spent money on is illegal and you have to do it again.

Which is why it is best to begin with a discussion such as this one.

quote:

There are TAXES involved here QUOTE]

Which we are discussing how to remain in compliance with.

Do you think any state revenue deptartment casre if you pay $1 in "fuel tax" or $1 in sales tax?

[QUOTE] not to mention EPA issues.

Nope..no EPA issues.

quote:

Tax departments have virtually unlimited budgets and resources in getting convictions for breaches of the law concerning them and there is little they won't do to stop and violations even small ones before they spread.[/

You need to check your information source on that.

quote:

No, the difference is that Costco do not INTEND their VO to be used as fuel, nor do anything to facilitate that. You will.

Nope. We will be very careful to not facilitate the products use as fuel.
That will be entirely and utterly up to the end user. Exactly like Costco.

quote:

Intent is a big part of the law here,

And proving "criminal intent" is a big part of any criminal prosecution.
No intent to break the law here. Rather a discussion on how to comply with it.

quote:

It would take a hack laywer about 2 minutes to tear your deception to shreds.

No..in fact it would be nearly impossible to do so. And some "lawyer" would have to want to prosecute first. That is highly unlikely if the business is properly structured. And knowing quite a few lawyers..a few of them judges...they tend not to want to waste their time prosecuting a case the have a very small chance of winning.

quote:

" Why do you have a standard for those involved in selling WVO for it to be dried and filtered to 5Um when our Animal feed exert here says that 100 UM would be fine and the feedlot standard only requires 1% water and 100UM filtering?"

To minimise long term storage degradation.

quote:

Originally posted by danalinscott:

quote:

The problem with this kind of business is that someone will get pissed off... Perhaps it will be a competitor (several may feel you are taking away THEIR product or business). Perhaps it will be someone concerned about smoke being generated by a vehicle.

Might I ask...WHO exactly is a "competitor" likely to do that?
There IS no competition currently.

Right,
Now, there is nobody selling VO in a kiosk like you are envisioning.

However, that doesn't mean there isn't any competition.

There are gas stations (who are often hit heavily by the EPA, in fact several were run out of business by the EPA with new tank requirements). And, I'm sure many have struggled with fluctuating fuel prices and the recession.

There is competition for oil, and WVO accounts. People stealing oil, cutting locks, cutting barrels, etc... pretty amazing to read the lengths that some people go to.

Read this recent posting, and unfortunately too many similar postings:

http://biodiesel.infopop.cc/ev...5551/m/711104361/p/1
http://www.biodieselsmarter.co...sit-from-the-epa.php

quote:

After we took over a couple of accounts from our competitor last year, we got a visit from the city's zoning board, the air quality, water quality, stormwater runoff, state environmental board, fire marshall, and city planner - literally within a week of each other. Each one said it was complaint driven and they came in about two weeks after we took over those accounts.

quote:

Originally posted by danalinscott:
And who is likley to generate more smoke with a VO fuelled diesel?
Normally they produce less visible smoke than diesel fuel does.

I encourage you to bring up legitimate problems..but theses are pretty far fetched.

Smoke and Diesel Engines has been a long time issue...
Better now, especially in newer vehicles, and more strict standards

However, many vehicles gravitating towards vegetable oil conversions aren't new.

Are you saying that you've never seen a 30 year old Diesel Engine with 300,000 miles on it emit visible smoke? Even on startup? Or during heavy acceleration?

It doesn't have to be worse than it would otherwise be using regular Diesel. It just has to be something that attracts attention, and is noticed by someone.

And, it may not be your car that is smoking... but, if it is running your fuel (which you claim is not fuel), it will still bring attention back to you, and everyone working with you.

quote:

Originally posted by danalinscott:
Nope..no EPA issues.

The EPA (and DOT) regulates the air, water, soil.
They regulate the fuel we can legally burn in our vehicles (which Vegetable Oil isn't considered one of them)
They regulate the vehicles we can burn the fuel in.
They regulate, and test vehicle emissions.
They regulate containers for transportation of fuel.
And, they regulate storage tanks and facilities at fuel filling and fuel distribution centers.

Certainly you will want to convince regulators that there aren't any EPA issues "of concern to them". And, preparing vegetable oil for fuel consumption should be less of an EPA issue than making biodiesel. However, don't ignore the power of the EPA, or the chance of a business being audited on a local level... or following the distribution web on a national level.

The best way to prevent issues would be to figure out what would be considered issues, however minor, and fix them before they occur. For example, a spill containment kit probably isn't necessary... but put one in every single kiosk, and it will look very good on an audit.

-------------

I think this is a great idea.

And, if it happens, it will be through an extraordinary investment of time, energy, and money by at least 100 individuals.

But, it will also have to be squeaky clean, otherwise it will crumble very fast.

Also, if you build it as a tree structure with roots leading right back to you, it puts yourself in a very precarious situation. Consider facilitating a consortium of independent producers, each with no more weight than any other.

As an individual, I will not buy into an organization that puts myself at risk. And, that means being upfront with what one is doing. Talking to regulators. And identifying potential problems before they become problems. And paying 100% of the taxes due, no matter how just or unjust they seem.

In CA filtering WVO is considered rendering. Rendering requires a license that cost approx $2500. Plus it requires insurance $2000 plus. Not to mention city zoning requirements.

Selling oil in cubies is going to cause problems from everyone pouring the oil into their vehicles and spilling. Spilling is a major issue I have seen first hand by a biodiesel place that was selling in cubies

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There are gas stations

Clearly not "competition" in that they do not serve the same customer base.
Gas stations customers buy diesel fuel and gasoline.
Our would not be in the market for that.

And realistically, do you really think that any gas station in a major metropolitan area is going to ever notice a "competitor" that has such a low monthly volume?
I seriously doubt that a VO Depot would be considered a competitor by any gas station with hunderds of other gas stations that constitute REAL competition.

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There is competition for oil, and WVO accounts. People stealing oil, cutting locks, cutting barrels, etc... pretty amazing to read the lengths that some people go to.

Yes..there is "competition FOR wvo.
But there would be no competition selling wvo.
AS far as cutting locks, stealing wvo..that will have to be covered when kiosk security is discussed.

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Are you saying that you've never seen a 30 year old Diesel Engine with 300,000 miles on it emit visible smoke? Even on startup? Or during heavy acceleration?

Sure..who hasn't? But how would anyoe tie that into a VO Depot kiosk?
These were real stretches when fisrt suggested. I don;t see how they ahve been strengthened.

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And, it may not be your car that is smoking... but, if it is running your fuel (which you claim is not fuel), it will still bring attention back to you, and everyone working with you.

No more than it currently does for everyone using VO as fuel.

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The EPA (and DOT) regulates the air, water, soil.

This is clerly not correct.
I suggest checking the mandates of the EPA and DOT.

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They regulate the fuel we can legally burn in our vehicles (which Vegetable Oil isn't considered one of them)
They regulate the vehicles we can burn the fuel in.
They regulate, and test vehicle emissions.
They regulate containers for transportation of fuel.
And, they regulate storage tanks and facilities at fuel filling and fuel distribution centers.

Which is why it would be smart to make sure that we comply with any regulations that may apply to this. And be very careful to structure the businesses so as few regulations apply as possible.

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Certainly you will want to convince regulators that there aren't any EPA issues

Why would I want to do that?
Much better to check what EPA regulations cover the sale of prefiltered/dewatered wvo.
Are you aware of any?

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The best way to prevent issues would be to figure out what would be considered issues, however minor, and fix them before they occur.

I agree.
That is what we are trying to do in this discussion.

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For example, a spill containment kit probably isn't necessary

It might be.
Are they required for owners of WVO dumpsters?
Costco?

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I think this is a great idea.

I do to..and as hard a time as I may be appearing to give you I appreciate your particiaption.

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it will be through an extraordinary investment of time, energy, and money by at least 100 individuals.

I don't think so.
I think that initially it will be easier and less expensive than opening a hot dog stand.
And it can start with under 20 people the way it is currently structured.

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Also, if you build it as a tree structure with roots leading right back to you, it puts yourself in a very precarious situation.

I don't think I have suggested that.
My current business puts me at much more risk I think though.

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Consider facilitating a consortium of independent producers, each with no more weight than any other.

Great suggestion.

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As an individual, I will not buy into an organization that puts myself at risk.

Every business entails risk.
The trick is minimizing/managing it.

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that means being upfront with what one is doing. Talking to regulators. And identifying potential problems before they become problems. And paying 100% of the taxes due, no matter how just or unjust they seem.

No one is suggesting anything BUT Paying taxes THAT ARE DUE, or not requesting information from regulatory agencies that clearly have jurisdiction over the activity of WVO sale, or identifying potential problems.

Especially important at this point is identifying potential problems.
Only by identifying potential (realistic) problems can we find the best ways to avoid them.

Is the name of this discussion a realistic potential problem?
How about if I change it to "Establishing a national network of WVO Depots"?

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In CA filtering WVO is considered rendering.

I seriously doubt that but I may not have seen ALL the legislation regarding WVO filtering.
Can you provide a link to the regulations you believe creates that association?

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Selling oil in cubies is going to cause problems from everyone pouring the oil into their vehicles and spilling.

Or there may be a very simple solution to that problem.

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Selling oil in cubies is going to cause problems from everyone pouring the oil into their vehicles and spilling. Spilling is a major issue I have seen first hand by a biodiesel place that was selling in cubies

Simple solution like a sign stating:
"DO NOT POUR USED VEGETABLE OIL OUT OF THE CONTAINERS AT THIS LOCATION"
or something similar. One may need to add "Those who do not respect this will have their VO accounts terminated" The initial information given to clients can make it clear that it is NOT a fuel dispensing station and that filling vehicle tanks at the depot will cause problems with local authorities. I think the clientele you wish to cultivate would respect this if it's made clear with good reasons. A simple 'dummy' camera with a flashing LED will encourage compliance and reduce vandalism.

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Originally posted by danalinscott:

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There are gas stations

Clearly not "competition" in that they do not serve the same customer base.
Gas stations customers buy diesel fuel and gasoline.
Our would not be in the market for that.

Thank you for clearly and unequivocally demonstrating beyond all doubt and spin doctoring the dillusion you are clearly under and trying to completely misinform others with.

That one statement alone shows how naive your thinking in and how potentially dangerous and flawed your statements are. Anyone that is smart enough to be able to undertake this endeavour will see that comment for how misguided and ignorant it is and base treat all else you say with the appropriate credibility it deserves.

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And realistically, do you really think that any gas station in a major metropolitan area is going to ever notice a "competitor" that has such a low monthly volume?
I seriously doubt that a VO Depot would be considered a competitor by any gas station with hunderds of other gas stations that constitute REAL competition.

In these hard times a gas station will notice anything they percieve or fear is going to be competition that will loose them one sale. If you knew anything about the service station business, ( which clearly you have no idea) you would know that fuel isn't the real money spinner, it the sales generated by people coming into the business of things like Drinks, ice creams, accessories, parts, and repairs amongst other things.

Like any business, they would be understandably very protective of their "Patch of Turf" which would normally be regulated as to how many competitors could be in the same area. Should they get wind of someone that they even PERCIEVE is a competitor ( and that would without doubt include someone selling something people were pouring into their fuel tanks) then they would be complaining to everyone they could think of and doing all they could to shut it down.

While you may deny and dismiss this Dana, everyone else will know by their own god given good sense it is undeniably what would surely happen.

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There is competition for oil, and WVO accounts. People stealing oil, cutting locks, cutting barrels, etc... pretty amazing to read the lengths that some people go to.

Yes..there is "competition FOR wvo.
But there would be no competition selling wvo.[/QUOTE]

But there is HUGE competition selling fuel and no matter how you want to spin it, deny it, hide it or play with words and semantics, you and everyone else knows damn well that is exactly what you would be doing.

If you think for one minute that someone with the power and money of a major fuel company is going to stand by and take even one sale from them, ( especially when they aren't in the " Club", You are so far in denial it isn't funny. Would you let a competitor that has skirted all the normal hoops they have had to go through set up a business down ( or worse still, UP) the road from you and stand by and say " Oh well, they are only small and won't be taking much business away from us" Or would you do all you could to have them shut down and moved on?
While you may try to say it wouldn't worry you Dana, other people that are running a real business and have their livelihood or corporate profits in mind are not going to be so charitable and I'm sure everyone else here has experience and a working sense of reality to see that.

It's clear Dana that in your eyes that this idea you have is going to be a piece of cake to set up, cheap as chips, nothing to worry about and you can easily get past all rules and regulations by feeding those in charge a load of Bull and hogwash.

Please keep going with this line of thinking. It is proving more and more just how flawed and inexperienced in business matters you really are. Perhaps in time you will come to see it dosen't matter what you think or how much you want to evade the truth, in the real world it's all about complying with the rules and regulations and while you may be able to dance around them for a while, sooner or later they will catch up and bite you on the ar se hard.

Your endless denials and flippant dismissals of every problem and issue anyone raises is a very telling warning to anyone reading this thread of just how biased, out of touch and completely unrealistic your mindset is and I'm sure that alone will put a lot of intelligent and experienced people off the idea before they even get into it.