FOIA Request on Stella 4T Rec'd Today from EPA

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FOIA Request on Stella 4T Rec'd Today from EPA

Post by rtaite »

All,

The EPA responded to my FOIA request concerning the delay in certification of the Genuine Scooter. Two letters are attached to this post.

It appears the EPA had already fully approved the Stella 4T, but Customs found additional deficiencies.

The certification consultant for Genuine describes them as follows:

1) The VECI (Vehicle Emissions Control Information) stickers could be "cleanly removed"
2) The carburettor did not have have a hard epoxy covering the idle mixture screw (to prevent tampering I guess)

The letters are attached.

I have an email in to John LaCroix to find out why these deficiencies were not picked up in October of last year when the EPA approved the engine.

Ralph
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Certification Rep.pdf
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Continued...

Post by rtaite »

For some reason, the second attachment didn't come through... here it is...
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Post by charlie55 »

Your tax dollars hard at work, protecting you from loose stickers and insuring that you can't adjust an adjustable mechanism.

As if you couldn't drill out an epoxy coating in a couple of seconds and do what you had to do. Oh crap, what if the idle mixture adjustment screw police are monitoring this forum? Guess I'll be getting a free trip to Gitmo.

Just proves my theory that there are more people than there are meaningful jobs for them to do.
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Continued...

Post by rtaite »

And a third attachment containing the original certification work done in 2009....
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Post by JoshWED »

Thanks for digging these up. Fascinating.
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Post by illnoise »

Well there you go, conspiracy theorists. You were right. Genuine, you slimeballs, HOW COULD YOU!?

Bb.
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Post by Rippinyarn »

What a giant cluster%*$. I now feel even worse for all parties involved. I'm highly disappointed that the inspectors and agencies couldn't come up with a better solution, one that did not involve the shipping of these scooters back across the ocean, and forced the order to be built anew only to be shipped across the ocean. Very frustrated and disappointed! A colossal waste of time and effort for NOTHING!
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Post by jmkjr72 »

yes but it may be a big pia but if they were to let them in to be "fixed" prior to deliver to the public

then when the tried to send the next container full of pos chineese scoots back that dont meet standerds the slime balls importing them would have prcidence that they could be "fixed" prior to delivery and never fix them
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Post by jmer1234 »

illnoise wrote:Well there you go, conspiracy theorists. You were right. Genuine, you slimeballs, HOW COULD YOU!?

Bb.
Ok, first, how does this series of communications show Genuine acting an an un-ethical manner? What I see is them submitting a product, and it being rejected for a particular reason. There was no subterfuge that I can see.

Second, is this not all paperwork from submissions in 9/09 - 10/09? What does this have to do with the inspections in 07/10 -08/10?
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Post by BGK »

jmer1234 wrote:
illnoise wrote:Well there you go, conspiracy theorists. You were right. Genuine, you slimeballs, HOW COULD YOU!?

Bb.
Ok, first, how does this series of communications show Genuine acting an an un-ethical manner? What I see is them submitting a product, and it being rejected for a particular reason. There was no subterfuge that I can see.

Second, is this not all paperwork from submissions in 9/09 - 10/09? What does this have to do with the inspections in 07/10 -08/10?
Really?
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Post by jmer1234 »

What everyone has to understand is that regulations are subject to interpretation. When you are bringing a new product to market, you make your best stab at adhering to the regs, and then submit it to the regulatory agency for approval. They then either approve it, or reject it and state why so that changes can be made for re-submission. This is all that has occurred here. It sucks that some people have money on the table already, and are having to watch this play out. But I have yet to see anything that makes me want to cry "foul".
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Post by jmer1234 »

BGK wrote:
jmer1234 wrote:
illnoise wrote:Well there you go, conspiracy theorists. You were right. Genuine, you slimeballs, HOW COULD YOU!?

Bb.
Ok, first, how does this series of communications show Genuine acting an an un-ethical manner? What I see is them submitting a product, and it being rejected for a particular reason. There was no subterfuge that I can see.

Second, is this not all paperwork from submissions in 9/09 - 10/09? What does this have to do with the inspections in 07/10 -08/10?
Really?
Really, what?
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Post by JoshWED »

illnoise wrote:Well there you go, conspiracy theorists. You were right. Genuine, you slimeballs, HOW COULD YOU!?

Bb.
The conspiracy never was that they are slimeballs. Just that they suck at certain business processes and communications. I see no reason to think otherwise, even in this most shitty of situations. I mean, someone had to FOIA this? The administration I work for has been called arrogant and opaque...but this takes the cake!
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Post by BGK »

jmer1234 wrote: Really, what?
I don't think his post was in the spirit of sincerity.
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Post by illnoise »

jmer1234 wrote:What everyone has to understand is that regulations are subject to interpretation…I have yet to see anything that makes me want to cry "foul".
Thank you, exactly.

And yes, I was being sarcastic in the earlier post.
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Post by rtaite »

JoshWED wrote:
illnoise wrote:Well there you go, conspiracy theorists. You were right. Genuine, you slimeballs, HOW COULD YOU!?

Bb.
The conspiracy never was that they are slimeballs. Just that they suck at certain business processes and communications. I see no reason to think otherwise, even in this most shitty of situations. I mean, someone had to FOIA this? The administration I work for has been called arrogant and opaque...but this takes the cake!
I am really surprised the EPA would miss such basic deficiencies.

Could it be that the EPA depends on the certification consultant to do all the relevant inspections and that Genuine's consultant messed up?

I was reading recently that the EPA does not test the fuel economy of cars itself. It takes the results from certified labs hired by the auto manufacturers.

Still waiting to hear from John LaCroix.

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Post by mattgordon »

It sounds from the letter, that the label issue was that the EPA labels COULD be removed easily, and intact, opening the possibility of them being fraudulently transferred to another vehicle. Apparently the labels are supposed to self destruct when attempting to remove them.

Seems so simple (from the outside, looking in) to fix, but then thats Government. If indeed it IS just those two issues, label and idle screw epoxy....makes it even more heartbreaking for Genuine and its waiting 4t customers.
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Post by jmer1234 »

illnoise wrote:Thank you, exactly.

And yes, I was being sarcastic in the earlier post.
I respectfully withdraw any misunderstood criticism, while standing by my statement to the "conspiracy theorists".
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Post by ericalm »

There's been a lot of discussion of this outside the Stella forum and I want others to see it so I'm moving it to General Discussions (before I even read it!).
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Post by ericalm »

Read… and… Yeah, exactly.

All the conjecture and argument and accusation and laying of blame and what it all comes down to is sticker glue and a screw.

Ralph, thanks for digging this up. I'm going to poke through the documents.
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Post by illnoise »

jmkjr72 wrote:yes but it may be a big pia but if they were to let them in to be "fixed" prior to deliver to the public then when the tried to send the next container full of pos chineese scoots back that dont meet standerds the slime balls importing them would have prcidence that they could be "fixed" prior to delivery and never fix them
That's the bottom line, yeah, If they're gonna take a stand, they need to be consistent.

But it's just so painfully ironic that they let in a decade's worth of garbage and now that all the crap merchants have finally run themselves into the ground, they're cracking down on legitimate companies with a track record of quality and compliance and good reputations.

It's sad that this is all bureaucracy-driven rather than considered on a case-by-case practical basis, especially because the environmental costs of shipping them back and forth again has got to outweigh a quarter-turn on a thousand Stella screws, and a problem that would take 30 seconds to repair will take months. But as jmkjr72 said, it's how it has to be done. It's just logistically impossible to unload however many containers and uncrate 1000 scooters in a secure government warehouse in the dockyards and replace a sticker and glue down a screw, and even if there were, there's probably no protocol for the government to supervise it.
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Post by bigbropgo »

When the dealer does the set up, how can they adjust based on altitude? Or just that carbs need minor adjustment as things break in. (Just a quick thought )[/u]
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Post by ericalm »

There are a lot of painful ironies here. The numbers from CARB on the emissions were way under the limits. Cranking that idle screw open may lower the gas mileage, but I'd betcha the emissions would be within legal limits.

From a purely practical level: Doesn't the idle mixture screw need to be adjustable?
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Post by illnoise »

Also, to defend Genuine's decision to not share the specific issues with the public, I once again argue that there is probably litigation or at least negotiation with LML and/or their compliance consultants to cover the costs of re-shipping, re-crating, and making the changes, and they're not at liberty to talk about it publicly until that's all settled, for fear of souring their relationships or hurting their chances of recouping the extra costs.

And in any case, it would have been unprofessional of them to play a public blame game. I still wonder if there is even blame to be assigned, or if it just comes down to varying interpretations of the specifications, I'd bet it's a little bit of both.

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Post by illnoise »

Yes the idle screw should be pretty well dialed-in at the factory, but if it never needed to be adjusted, it wouldn't be a screw, it'd be cast into the carb body.

I obviously don't know the 4T setup that well, but on a P-series, tiny adjustments even out the idle, but don't seem to make a big change on RPMs. You adjust the throttle to a low idle, then adjust the air screw to get an even chugchugchugchugchug. I can't imagine they'd affect emissions much, or at least not compared to the throttle screw or jetting.

All I can think is that maybe US specs decree that the screw should be coated with a Loctite-like substance to prevent it from vibrating out, and it wasn't. That's a valid concern, I guess. I haven't messed around with modern scooters enough to notice, has anyone on the list ever encountered a glued-down air mixture screw, or noticed if it was coated in anything?
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Post by ericalm »

When I next pull off the cowls I'll see if I can get a pic of mine.
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Post by Skootz Kabootz »

illnoise wrote:Also, to defend Genuine's decision to not share the specific issues with the public, I once again argue that there is probably litigation or at least negotiation with LML and/or their compliance consultants to cover the costs of re-shipping, re-crating, and making the changes, and they're not at liberty to talk about it publicly until that's all settled, for fear of souring their relationships or hurting their chances of recouping the extra costs.

And in any case, it would have been unprofessional of them to play a public blame game. I still wonder if there is even blame to be assigned, or if it just comes down to varying interpretations of the specifications, I'd bet it's a little bit of both.

Bb.
Precisely.

Seriously, anyone who thinks Genuine are somehow playing games, well, they just don't know business or Genuine. What sane company would do that? None. I'm sure Phil and the entire Genuine crew would love nothing more than to loudly and publicly raise holly hell about this debacle – such a totally benign problem causing such an expensive mess. Really, after all the work Genuine have done to make the 4T Stella a reality (and a damn fine scooter too based what I've observed of Eric's 4T), only to have it stymied by a friggin' sticker and a screw??? Pleeease! I mean really, can you imagine??? I would be purple with rage.

How about the MB community give a little support back to Genuine after all the support they have shown us? Seriously.

Phil, I'll be the first to buy you a beer. You certainly deserve one, and after all this stickergate mess, I'm sure you could use one. Cheers. And thank you for doing what you do.
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Post by ericalm »

Oh, crap, you did not just coin "stickergate." Well, that's going to catch on. :P

Thing is, there are plenty of companies that don't act sane or in the best interest of either their business or their customers. It's made people very cynical and negative about everything. And—let's face it—the Internet just fosters negativity and criticism.

But I suppose it's time to move on. Cat's out of the bag. All the speculation and so on can be laid to rest.
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Post by Skootz Kabootz »

ericalm wrote:Oh, crap, you did not just coin "stickergate." Well, that's going to catch on. :P

Thing is, there are plenty of companies that don't act sane or in the best interest of either their business or their customers. It's made people very cynical and negative about everything. And—let's face it—the Internet just fosters negativity and criticism.

But I suppose it's time to move on. Cat's out of the bag. All the speculation and so on can be laid to rest.
Well I did say what "sane" company. That does limit the field :) And it was either "stickergate" or calling it a "screw job". Both winners :lol:
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Post by jmkjr72 »

illnoise wrote: All I can think is that maybe US specs decree that the screw should be coated with a Loctite-like substance to prevent it from vibrating out, and it wasn't. That's a valid concern, I guess. I haven't messed around with modern scooters enough to notice, has anyone on the list ever encountered a glued-down air mixture screw, or noticed if it was coated in anything?
yes the us lawed changed in the 70s and all motor vehicles cant have adjustable af screws motorcycles and scooters were able to get away without caping it off for many years apst cars as they were just overlooked by the epa

yamaha and the big 3 use a lead or soft metal plug that is pressed over the screw :twisted:
meets the requrements as you cant even find the darn thing but but is easily fixed with a drill and dental pic :D
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Post by PeterC »

I wonder how many henhouses it would take to produce this level of chickensh#t. "We're from the gummint, and we're here to help." NOT.
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Post by rtaite »

I did an FOIA request because I think the truth is important regardless of whether it supports the Genuine fans or cynics. The processes of our government should be transparent and we should expect high standards from the companies from which we do business. I don't care if the company is small or large.

I don't think Genuine was completely forthright. Let me quote from Genuine's Facebook update on the 4T delay:

"These [regulatory agency] concerns are non-mechanical and have no effect on the emissions standards, the safety, or the operation of the Stella 4 stroke scooter."

They aren't concerns -- they're deficiencies -- because they are binding and prevent the product from entering our country. The suggestion that these "concerns" have no effect on emissions standards is disingenuous as well. The EPA enforces the rules and has decided this is part of maintaining the emissions standards.

Yes, I know. Picky, picky. But the failure to cross Ts and dot Is has meant people are without bikes. So, regardless of whether the EPA dropped the ball or Genuine did, a good business should be honest about what has happened and explain what they are doing to prevent this from happening again. I think Phil got a pass as long as no one knew what the problem was.

Now that we know what the problems were, we can remind Phil about those labels and those screws. Because it makes him a more effective businessman and it helps us get the newest, coolest products which are available in the marketplace.

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Post by bigbropgo »

The stickers ability to be pealed of easily is a fluke. Who determined to level of adhesive power? That's lame. Also, do the buddys have a plug on the Carb? Is the new standard for all 4t scooters to achieve more that 100 mpg. Adjusting to screw can't affect the mpg that much. Genuine is bent over and taking it. They are not trying to get away with something.
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Post by Skootz Kabootz »

rtaite wrote:"These [regulatory agency] concerns are non-mechanical and have no effect on the emissions standards, the safety, or the operation of the Stella 4 stroke scooter."
Dude, how on earth do you manage read all that from this statement? Seriously. All they are saying is it is not a mechanical problem. Which it is not. It is way cool that you got hold of the true info so we can all put rumor to rest and learn just how benign the 4TStella's issues were - a sticker and a screw. (Seriously, I love that you took the initiative). But to say Genuine is not being forthright or are somehow disingenuous is rubbish. As Illnoise said, there could be very sound and ongoing legal reasons for not discussing all the juicy details in public. You do not know. But it is more than likely as letting the general public know it was nothing more than a sticker and a screw could only help Genuine. So I am sure they would love to do it. But even if there is nothing to stop Genuine shouting all the juicy details from the highest mountain, so what if they don't? What is the big deal? I'm sure they have had the delayed shipments before, as does every company from time to time. This one just happens to be the delay of a very awesome and highly anticipated new scooter.

Big picture, the Stella is perfect mechanically and the screw and the sticker are nothing but a big pain in the butt and a very expensive detour for the 4TStella. That's it. So really, let's not make this into more than it is. Be glad there was nothing more serious afoot with the scooter! After all, don't we all just want this great scooter to be here as soon as possible? I know I do. For goodness sakes...
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Post by ericalm »

rtaite wrote:Now that we know what the problems were, we can remind Phil about those labels and those screws. Because it makes him a more effective businessman and it helps us get the newest, coolest products which are available in the marketplace.
I can guarantee you: he does not nor ever will need a reminder.
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Post by rtaite »

Skootz Kabootz wrote: [...]
Big picture, the Stella is perfect mechanically
[...]
O really?

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Post by cheez37 »

rtaite wrote:...I don't think Genuine was completely forthright. Let me quote from Genuine's Facebook update on the 4T delay:

"These [regulatory agency] concerns are non-mechanical and have no effect on the emissions standards, the safety, or the operation of the Stella 4 stroke scooter."

They aren't concerns -- they're deficiencies -- because they are binding and prevent the product from entering our country...
Ralph
I disagree with your assessment of Genuine's statement. It is completely accurate that the concerns are regulatory in nature, and not of a mechanical, emissions, or safety nature. Although you may disagree with the use of word 'concern,' this can be standard language in various industries or governmental regulatory agencies. I work in the space biz, and the terms 'risk', 'issue', and 'concern' carry varying levels of attention with them. Also, they have no requirement to let customers know the specifics of a product delay, for a myriad of reasons that I don't feel I need to go over.

One other thing that we don't know is if Genuine knew about these issues before those scooters left LML. The prints may have directed LML to use the proper stickers and screw covers. LML (or one of their vendors) may have had an issue procuring those those exact parts, or looked to cut corners, and used what they thought was acceptable substitution. These substitutions may not be detectable by visual inspection.

And before any of you say "How could Genuine allow that to happen?!" just know these issues happen in all industries. The acceptable substitution thing even happens infrequently with parts that are destined to fly on the Space Shuttle and Space Station. There are extremely high (and massively expensive) quality and process standards in place for space hardware vendors. If it can happen to us, then it can most certainly happen to Genuine when you have foreign vendors with a thousand times less quality control.

I'm not saying that anyone should be happy with the delay, but let's not go bad mouthing Genuine, and make accusations that border on negligence.
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Post by Wheelz »

Well here we go again....

I believe it was Stella, herself, which fired the magic bullet from the grassy knoll.
The ensuing chaos, jostled a sticker delivery guy while he was making deliveries. Thus, causing him to mix up a batch of emissions stickers meant for another company and, in turn, he ended up delivering the wrong ones to LML.
LML, not knowing they received the wrong sticker, put them on said scooters.
Not so coincidentally, the worker applying these stickers was also responsible for the covering of the air mixture screw. He not so coincidentally is a distant 15th cousin, twice removed, of our own "Ericalm"
hmmmmmmmm?
Now from careful investigation, I know that Eric is part of a conspiracy to bring Vespa and Piaggio down, from within and without.
Now could it be, that our own Eric is in actuality trying to bring the whole scooter sub culture to it's kness from way way inside?
All the while, young Stella sits at a coffee shop on the Docks of an Indian port city, giggling to herself about what's really goin on....


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Post by cheez37 »

Wheelz wrote:Well here we go again....
Sorry if my post gets a few people fired-up and cranks up the anxiety level in this thread, but I was trying to bring perspective as an unaffected bystander.
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Post by charlie55 »

PeterC wrote:I wonder how many henhouses it would take to produce this level of chickensh#t. "We're from the gummint, and we're here to help." NOT.
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Post by JoshWED »

illnoise wrote:Also, to defend Genuine's decision to not share the specific issues with the public, I once again argue that there is probably litigation or at least negotiation with LML and/or their compliance consultants to cover the costs of re-shipping, re-crating, and making the changes, and they're not at liberty to talk about it publicly until that's all settled,

Bb.
This rings true and makes a lot of sense. A good choice by Genuine--If I were on their side, I'd do the same thing.

See, we critics are reasonable :shock:
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Post by rtaite »

JoshWED wrote:
illnoise wrote:Also, to defend Genuine's decision to not share the specific issues with the public, I once again argue that there is probably litigation or at least negotiation with LML and/or their compliance consultants to cover the costs of re-shipping, re-crating, and making the changes, and they're not at liberty to talk about it publicly until that's all settled,

Bb.
This rings true and makes a lot of sense. A good choice by Genuine--If I were on their side, I'd do the same thing.

See, we critics are reasonable :shock:
"The reasonable man adapts himself to the world; the unreasonable one persists in trying to adapt the world to himself. Therefore all progress depends on the unreasonable man."
-George Bernard Shaw, Man and Superman (1903)
"Maxims for Revolutionists"

Just sayin'

Ralph
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cheez37
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Post by cheez37 »

rtaite wrote: "The reasonable man adapts himself to the world; the unreasonable one persists in trying to adapt the world to himself. Therefore all progress depends on the unreasonable man."
-George Bernard Shaw, Man and Superman (1903)
"Maxims for Revolutionists"

Just sayin'

Ralph
"Duty then is the sublimest word in the English language. You should do your duty in all things. You can never do more, you should never wish to do less."
-- Robert Edward Lee

I can lay down pretty good quotes too. Not sure what either have to do with the 4T Stella...

Just sayin'
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Skootz Kabootz
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Post by Skootz Kabootz »

rtaite wrote:
Skootz Kabootz wrote: [...]
Big picture, the Stella is perfect mechanically
[...]
O really?

Ralph
Relative to this conversation and Stella's import delay, yup, really. There is one cosmetic issue, the sticker, and one regulatory isssue, the screw.
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rtaite
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Post by rtaite »

Unreasonable men like Abraham Lincoln, whose army defeated the great general you quoted, helped to change the country for the better.

I think you made my point better than I did.

Ralph
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PeterC
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Post by PeterC »

Skootz Kabootz wrote: "Relative to this conversation and Stella's import delay, yup, really. There is one cosmetic issue, the sticker, and one regulatory isssue, the screw."

And it would appear that Genuine, and its customers, got the screw. Thanks, EPA, CARB, Customs, whatever ... mission accomplished!
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ericalm
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Post by ericalm »

It's hilarious that any of us thought that having actual documentation and concrete, pertinent information would in any way impede the colossal bullshitting contest surrounding the whole Stella issue.

Everyone needs to zip up their pants and put their Bartlett's Quotations back on the shelves (or back away from Google).

We enjoy healthy, spirited debate here. But bickering and pissing contests are counterproductive and make us no better than, well, all the other monkeys on the Internet. We (as a community) should strive to be better than that.
Eric // LA Scooter Meetup Group // Stella 4T // Vespa LX // Vespa LXS // Honda Helix // some, uh, projects…
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Roose Hurro
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Post by Roose Hurro »

Look at it this way, people... at least you didn't have to wait two years for your chosen bike to pass CARB, while everyone else got to play. (But I still don't have the money for my Symba... :cry: )

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Lambrettaman
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Post by Lambrettaman »

illnoise wrote:Also, to defend Genuine's decision to not share the specific issues with the public, I once again argue that there is probably litigation or at least negotiation with LML and/or their compliance consultants to cover the costs of re-shipping, re-crating, and making the changes, and they're not at liberty to talk about it publicly until that's all settled, for fear of souring their relationships or hurting their chances of recouping the extra costs.

And in any case, it would have been unprofessional of them to play a public blame game. I still wonder if there is even blame to be assigned, or if it just comes down to varying interpretations of the specifications, I'd bet it's a little bit of both.

Bb.
Exactly. Especially the public blame game.
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charlie55
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Post by charlie55 »

Just for grins, how does everyone think this would have been handled between two private entitites? In all likelihood, a couple of over-nighted packages, a little overtime, and voila, all done in minimal time and for minimal expense. Not even worth getting the lawyers involved.

But, I guess it's easy to waste time and money when you've got all the time in the world and it ain't your money.
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