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rslifkin
rslifkin UberDork
6/13/21 9:25 p.m.

In reply to Keith Tanner :

I think the "limited use" exemption would be nice mostly for cars where there isn't a big aftermarket, so not much in the way of emissions compliant performance parts out there. 

Pete. (l33t FS)
Pete. (l33t FS) GRM+ Memberand MegaDork
6/13/21 9:46 p.m.

In reply to Keith Tanner :

Pure competition cars aren't really "exempt" so much as not even considered, are they?  They can't ever be registered on the road because they weren't built to Federal DOT/EPA regs.

 

I'm sure there's going to be one or two outlier cases where someone got license plates on a spec racer by calling it a kit car or homebuilt or something, but if anything that makes the point.

TurboFocus
TurboFocus HalfDork
6/13/21 10:04 p.m.

In reply to alfadriver :

highly doubt its a real number, it was probably pulled out of thin air to show that car guys are really not that detrimental. the city im in feels very car scene/mod friendly but my views may be skewed. i came from germany which is extremely anti-car mod friendly, that is an unarguable fact. there is 1.5 million here and i can tell you for a fact that the # of modified cars is nowhere near 3 in 100. of the much smaller than 3 in 100 'modified' cars there's probably an even tinier number that actually got rid of their emissions equipment judging from my own 'outside/IRL' experiences.

per volume, im sure there is a ton of catless cars; most of which serve no 'real/tangible/whatever' purpose. per rate, even with the 100-300x multiplier? im skeptical to think that catless cars would qualify as a drop in the bucket. if someone has a study on gasoline vehicles, please link it.

the 15% for diesel makes sense, especially with working trucks. emissions equipment hampers performance and reliability quite a bit on them afaik. im sure as soon as that warranty is up, its a delete and tune before another mile is driven. same goes for tractors, construction equipment, industrial generators etc.
its cutting into their pocket books, if i was in their position id strongly consider doing the same. 1 in 7 do it for a reason, its probably a good one.

TurboFocus
TurboFocus HalfDork
6/13/21 10:42 p.m.
Keith Tanner said:
Pete. (l33t FS) said:
TurboFocus said:

In reply to captdownshift (Forum Supporter) :

that's a bunch of BS.
if you race it, its a race car.

Currently, legally, if it was a production vehicle, it is still a production vehicle.

"Race car" does not exist as a legal term.  If it did, it would/will be/may be something that may not be registered on the street.  (thinking here of open wheel cars, dedicated chassis cars, etc)

Actually, cars built from the start as competition cars are already exempt AFAIK. There are no emissions requirements for pure competition cars like open wheelers from what I understand.

It's the street cars that get turned into race cars that don't currently exist as a legal thing. That's what the RPM Act is intended to do.

The suggestion for another hybrid category - ultra low mileage street cars that are allowed to modify emissions - is an interesting one. Open for all sorts of abuse, of course, but I think it's what would make the greatest number of GRM types happy. The question is why we should be allowed to do that from the point of view of those who are outside our hobby. Can we modify our cars without affecting emissions? Yes. So why don't we just do that instead?

The EPA already has the "Show or Display" exemption, but it's for importation and definitely not for people who want to put a Megasquirt on their Miata.

I appreciate the point that the Karen soccer moms would like to strip us all of our hobby entirely. However, we are allowed to disagree with them and I think that most people don't really care all that much. If they did, we'd see more of a conundrum. To reference and earlier poster, we're not causing mass casualties or extremely grave harm to the environment. we are not 'the bad guys' by the public, we're relatively invisible; annoying hondas and coal rollers aside. 

it's an entirely winnable situation for us, we can change our own destiny. it starts with making our voice heard.

alfadriver
alfadriver MegaDork
6/14/21 6:14 a.m.

In reply to TurboFocus :

I am not allowed to show you the data that I take on a daily basis...  But the TP data I am referencing is available on the EPA website- they keep a database of all car certification on their website.

If you can actually come up with real data to show the EPA that car modifications are insignificant, they are legally required to examine it.  But just claiming that you think that there's not a big impact will not have much impact- real data is required.

IMHO, there are enough pre-1968 cars on the road to have an emissions impact on society.  And they can not legally be required to make any specific level.  Many of these cars are also road draft- increasing the HC emissions by 2-3x what they were (making them 400-600x a new car if they are tuned perfectly).

It's fair to remind you that the rule against tamping with emissions is almost 50 years old now.  You are welcome to try to undo that long standing law, but it's become pretty clear to me that the enforcement of the law was pretty much forced by the aftermarket.  And to try to legally pick and choose who to enforce that on- I just don't see a path where it will be equal to all.

rustomatic
rustomatic Reader
6/14/21 6:46 a.m.

Y'all are approaching an emotional argument with hotrodder logic.  That's exactly what they want you to do, which is why the argument(s) will lose.

Consider how badly "normal" people misinterpret what it means to race:  The local Atlanta news (multi-million person broadcast coverage) frequently references idiots doing donuts on downtown/city streets, swerving around parked cars and standing people as "racing" or "illegal street racing."  They do not care to establish the difference between morons doing pointlessly dangerous things in fast (or not fast) cars and actual competition between point A and point B (not that it matters that much when it's on a city street).  The hotrodder's logic does not matter, because to the general public, what he/she is doing just needs to stop.

So your brodozer pisses people off because you think a huge cloud of soot means you're fast or powerful (more so than the non-idiot whose deezel just stinks instead of showering people with "coal").  Unfortunately, your bitchin' brodozer pissed off some powerful people on the way to work.  Enter multi-million dollar lawsuits and influence that will steamroll the people who support such hobbyist proclivities (and never go away).

As someone who grew up in CA in the 80s, 90s, and the oughts (?), I actually saw the smog police do something that worked, however much my hotrodder's needs wanted the opposite.  I remember how you used to actually be able to feel, taste, and see the air in L.A. and Las Vegas (especially in the summer); it was hideous, dangerous, and disgusting (however quite attractive for an odd sunset, in a nuclear kind of way), and smog laws have actually worked, however annoying they've been.  With this kind of evidence available, the EPA has sound conviction . . .

captdownshift (Forum Supporter)
captdownshift (Forum Supporter) GRM+ Memberand UltimaDork
6/14/21 8:29 a.m.

In reply to TurboFocus :

You have it backwards. If it's driven on the street ever it's a street car. Being taken to a Friday night test in tune does not make it a race car. Sorry but not sorry. If it is tagged it is a street car, period end of story. If that offends you to know that you're not a race car driver or your friends are not race car drivers welcome back to reality. Now put on a legal exhaust. 

docwyte
docwyte PowerDork
6/14/21 8:40 a.m.

Yep, if you have a license plate on it and drive it on city streets it's a street car NOT a race car.  As such, it absolutely, positively HAS to have a catalytic convertor and all the other working smog devices on it.  Since removing them nets you zero HP, I don't see the point in taking them off...

Keith Tanner
Keith Tanner GRM+ Memberand MegaDork
6/14/21 8:54 a.m.
Pete. (l33t FS) said:

In reply to Keith Tanner :

Pure competition cars aren't really "exempt" so much as not even considered, are they?  They can't ever be registered on the road because they weren't built to Federal DOT/EPA regs.

 

I'm sure there's going to be one or two outlier cases where someone got license plates on a spec racer by calling it a kit car or homebuilt or something, but if anything that makes the point.

Right, not exempt. Unregulated is a better term.

Keith Tanner
Keith Tanner GRM+ Memberand MegaDork
6/14/21 9:01 a.m.
TurboFocus said:
Keith Tanner said:
Pete. (l33t FS) said:
TurboFocus said:

In reply to captdownshift (Forum Supporter) :

that's a bunch of BS.
if you race it, its a race car.

Currently, legally, if it was a production vehicle, it is still a production vehicle.

"Race car" does not exist as a legal term.  If it did, it would/will be/may be something that may not be registered on the street.  (thinking here of open wheel cars, dedicated chassis cars, etc)

Actually, cars built from the start as competition cars are already exempt AFAIK. There are no emissions requirements for pure competition cars like open wheelers from what I understand.

It's the street cars that get turned into race cars that don't currently exist as a legal thing. That's what the RPM Act is intended to do.

The suggestion for another hybrid category - ultra low mileage street cars that are allowed to modify emissions - is an interesting one. Open for all sorts of abuse, of course, but I think it's what would make the greatest number of GRM types happy. The question is why we should be allowed to do that from the point of view of those who are outside our hobby. Can we modify our cars without affecting emissions? Yes. So why don't we just do that instead?

The EPA already has the "Show or Display" exemption, but it's for importation and definitely not for people who want to put a Megasquirt on their Miata.

I appreciate the point that the Karen soccer moms would like to strip us all of our hobby entirely. However, we are allowed to disagree with them and I think that most people don't really care all that much. If they did, we'd see more of a conundrum. To reference and earlier poster, we're not causing mass casualties or extremely grave harm to the environment. we are not 'the bad guys' by the public, we're relatively invisible; annoying hondas and coal rollers aside. 

it's an entirely winnable situation for us, we can change our own destiny. it starts with making our voice heard.

This isn't soccer moms trying to strip you of your hobby. Your hobby is doing just fine. This is not some sort of persecution trying to shut you down.

Try to come up with a justification for a non-car person as to why you should be allowed to remove mandated emissions equipment other than "I want to". You can still take part in your hobby without it, so it's not that your hobby cannot exist without this special status.

And pollution does indeed cause mass casualties, it's just not as immediate as blood on the highway. Which, unfortunately for our hobby, also does occasionally happen and doesn't help our public relations overall.

OldGray320i
OldGray320i Dork
6/14/21 9:19 a.m.
Keith Tanner said: Part of the disconnect is that you're not willing to believe information that comes from the government because you fundamentally don't trust it.

If you don't believe that 15% of diesel trucks are modified, you don't know many diesel truck owners. I'm not talking about brodozers, but working trucks. 

In the last few years we have the NIH and the FBI lying, and the IRS pleading the 5th.  I'm not wrong to be skeptical. 

Didn't say 15% was bogus, accepting that and what you represent as fact, and pointing out that it's not representative of the car hobby as a whole, nor is "our" impact the same.  

Keith Tanner
Keith Tanner GRM+ Memberand MegaDork
6/14/21 9:35 a.m.

Fair point on the last few years.

There is no "us and them". We're all in the same hobby. You can't crack down on EGR deletes on pickups and not crack down on EGR deletes on imports. The trucks are the most visible and probably most damaging segment which is why they get used for examples. But they're not really any different than "us". Heck, we talk about trucks all the time on this forum.

Apis Mellifera
Apis Mellifera Dork
6/14/21 9:40 a.m.
OldGray320i said:

How much of an impact do we make, the tiny slice that modify,  on the entirety of air pollutants?

TL:DR - last paragraph(s)

If you want to peek under the government skirts and see "how a hammer can cost $1000" read on.

As others have said, we've been over this topic many times and I've given my observations from the regulatory side.  Keith and Alfadriver are consistantly spot on and it's clear who has firsthand knowledge of this very complex issue.  I will try to give some insight on things that are within my purview.

How much of an impact do modded cars make?  More than you might think or be willing to accept.  Rain drops make an ocean.

First, EPA does not create regulation.  It enforces it.  Your elected officials create law.  One of these officials also installs individuals to run the various agencies and they generally select people that think and act in such a way so as to further the agenda.  The agency heads then install people as heads of the various divisions within the agency that also think and act in accordance to the agenda.  With law, a judge or agency may interpret the meaning or "spirit" of the law and enforce it accordingly.  An example of this is when a former President attempted to make an interpretive argument on what the word "is" means.  There is generally a delay of a year or years while the new boss undoes what the old boss did, or goes further, or leaves the old work alone. It takes a while for a cruise ship to change course.  Without a doubt though, the interpretation of law can make an immediate about face.  This interpretive wiggle room is why EPA gets sued constantly and generally challenged at every step and why it takes a while to turn the ship.  This bit of legislation at hand is a legacy action from a few administrations and is a response to a few things.  One is public outcry - people don't like coal rolling and thus, the legislative broad net that was cast many decades ago, is now being pulled in.  The net has no mechanism to sort the fish.

So back on track.  The CAA places limits on pollutant concentrations allowed in ambient air (NAAQS).  On issues under the jurisdiction of states, EPA allows each entity to decide how they will meet the NAAQS.  Issues that have federal impact or are outside state purview are generally acted upon by EPA.  Each state conducts an emission inventory to determine ambient air quality.  This includes data collection from polluters (point source) and calculations from models and estimators for areas like mobile sources, woodburning, agriculture, etc. etc. (nonpoint source).  Point source is easy to measure because it's one big tailpipe generally with it's own reporting system.  Nonpoint is difficult because it's millions and millions of smaller tailpipes, (literally for part of it - vehicles are a part of nonpoint emissions) each with it's own operator, operating in an unknown manner, and almost all are not measered or reported.  Thus, we have models and estimators to attempt to quantify the pollutant volumes. 

The sum of the point and nonpoint produce your total.  The NAAQS dictate the maximum allowed.  The difference is your annual budget or the "room to grow".  This growth potential could translate into a new road to relieve congestion or a new factory to create jobs - it's the prosperity that every state governor like to boast about.  If there is no room in your budget for growth, someone will have to tell the governor "we can't build the new road" or "Amazon can't build the new distribution center here in Virginia.  It's going to North Carolina instead".  Governors don't like that.  So states have an air monitoring program to measure the effectiveness of their control system (SIP) to make sure the reality matches the calculations and to make sure there is a budget for growth.  On a side note, when a state exceeds the NAAQS, that's when scrubbers get put on power plant stacks, or industry shuts down or you can have a passive control like carpool lanes added,.

When controls are necessary, EPA and states always go for the low-hanging fruit.  Look for the greatest potential pollution reduction and control it.  Ok that's fixed.  Now what's the biggest?  Ok, controlled. Next?  Since more and more pollution sources are added to the system (more cars, more electronics consuming power, more people, more food production...), you have to keep tightening the belt because the budget doesn't grow with the demand.  Politicians don't mind controlling industry because the public is mad at the power company when the electric bill increases.  Politicians don't like to place such controls directly on people because they'll notice and people vote.  So, what is easiest and/or cheapest to control to ensure NAAQS are met so the governor can get his building project done and people will love him?  What could be easier than enforcing an existing law?  No legislative action is necessary, no added controls on industry (they're already there -just not enforced), no lengthy process of SIP development for states.  Just enforce the law.

So how does all this factor into this discussion?  Mobile emissions from motor vehicles are the largest source of nonpoint emissions generally.  As I said and I think Keith mentioned too, it's bigger than you're apparently willing to accept.  The emissions from this sector are modeled.  The models are only as good as the calculations within.  The calculations are only as good as the variables within.  And, based on design specs of vehicle engines (which are extensively tested and developed for performance, efficiency, and consistency, and therefore predictability), these variables ultimately produce a fairly accurate, albeit conservative, estimate which can then feed into the above process.  When engines are modified in anyway to operate outside of the designed parameters, all bets are off.  When a sector of the population makes a spectacle of the lax enforcement of existing laws in an system running a tight budget anyway and in the current political climate, it should be no surprise of the outcome.  It was stated earlier that some modified vehicles pollute 100s of times greater than average and there's an existing law to fix it, that's low hanging fruit.  Do these modifications reduce emissions?  Maybe, but that's not within the scope of existing laws nor is the burden of proof on the law.  Each one of those drops in the ocean is actually a bucket full.  Clearly operating outside of the existing law.  It's not a perfect one-size-fits-all law, few are, and it couldn't possibly accommodate or predict all the variables that play into it (all Miatas are the same and all Miatas are a Camry and Crown Vic according to the MOVES model).  Think of it this way:  You make $100 a day building and selling a box using one 2x4 and a sheet of 3/4" plywood.  Everyday you buy 5 gallons of gas, eat a Big Mac, and purchase the materials for tomorrow's box.  How much money will you have saved for your mortgage payment at the end of the month and can you afford to take a vacation in 6 months.  Too many unknowns to predict and no way to plan for the future.  So that's how this massive thing works.  It's not a simple as saying "My track car doesn't make a difference."  It doesn't, but they all do and the iceberg is not made up of just cars and trucks.

Finally to the... person... that advocated drunk driving as some sort of freedom of choice/personal responsibility nonsense:  as someone who was nearly killed by a drunk driver and as someone who has cousins orphaned by a drunk driver, you and those that think like you are the reason our society needs laws like these and I'm glad they exist.

OldGray320i
OldGray320i Dork
6/14/21 9:41 a.m.
alfadriver said:

In reply to TurboFocus :

I am not allowed to show you the data that I take on a daily basis...  But the TP data I am referencing is available on the EPA website- they keep a database of all car certification on their website.

If you can actually come up with real data to show the EPA that car modifications are insignificant, they are legally required to examine it.  But just claiming that you think that there's not a big impact will not have much impact- real data is required.

IMHO, there are enough pre-1968 cars on the road to have an emissions impact on society.  And they can not legally be required to make any specific level.  Many of these cars are also road draft- increasing the HC emissions by 2-3x what they were (making them 400-600x a new car if they are tuned perfectly).

It's fair to remind you that the rule against tamping with emissions is almost 50 years old now.  You are welcome to try to undo that long standing law, but it's become pretty clear to me that the enforcement of the law was pretty much forced by the aftermarket.  And to try to legally pick and choose who to enforce that on- I just don't see a path where it will be equal to all.

My legitimate question has always been, in the scheme of all air pollutants, what is the impact of the car hobby?   You intimated earlier it was overlooked becuase it wasn't seen as a problem until the diesel issue popped.

Given that cars emit 30% less NOx, and that modified cars are way less than 15% of the population, what does that figure turn in to? I'm going to make an an assumption that even performance cars with cats intact have higher emmisions, so straight math based on the diesel figure doesn't work, but it sure as hell isn't equal to 8m extra vehicles. 

And that's just automotive, not all other sources of air pollutants.

You and everybody making the argument give the it's x worse than normal, per car.  And so it is, but in terms of the total impact of all pollutants, as a percentage on the total, it sure seems very small.

Again, the "total impact" on air quality is how the Arizona law was passed.   The air quality in southern Arizona has not taken a turn for the worse due to the car hobby.

DaveEstey
DaveEstey PowerDork
6/14/21 10:20 a.m.

My biggest takeaway from this thread is that some of you equate your opinions to objective facts, which is just plain weird. 

alfadriver
alfadriver MegaDork
6/14/21 11:26 a.m.

In reply to OldGray320i :

I personally don't know the specific impact of modified cars.  What I do know is what simple changes do relative to where we are, as a brand new fleet, is.  I know that an uncatalized car puts out 3-6 g/mi HC+NOx (or worse- it's been a while since anyone cared) when the engine is running at it's best.  And the current fleet average is approaching SULEV 30, or 0.03 g/mi NMOG+NOx.  In reality, real cars are closer to 70% of that, but that's just more confusing.  

So if 200,000 modified cars out there don't have catalysts, that's the equivalent of the entire new car fleet.  All of them.  

Granted, that's an off the cuff calculation, but forgive me for thinking that 200k cars =  the entire new car fleet WRT emissions seems pretty significant.

BUT.... the real key is to come up with real data showing your point.  Not feelings or doubts, but real data.  I'm 100% sure that the EPA has some real data about what modified cars put out- they have testing facilities here in Ann Arbor, and they subcontract out to many originations and universities to gather data.  Oh, and one other source of data- OEMs- pretty much all of us self certify our vehicles, so almost all of the data in the certification database comes from the OEM.

My point was that the lack of enforcement has very certainly gotten a close look at recently- which means data was gathered, models were updated, and information and questions have been put out.  If you really want to change things, you need to gather data, update models, etc.  Doubt only goes so far in this.

 

Apis Mellifera
Apis Mellifera Dork
6/14/21 11:43 a.m.
OldGray320i said:

My legitimate question has always been, in the scheme of all air pollutants, what is the impact of the car hobby?

What car hobby?  Yours or mine or theirs?  With that in mind, please list the number,make, model, year of each vehicle therein along with the grams per mile of CAPs and HAPs for each vehicle.  We will focus on current year for now, but we will also need future modifications and maintenance each one will have by 2023 and 2030 and maybe 2025.  Also please provide the annual VMT and location for each vehicle.  Allowing time for data collection, the calculation will be done on or after 2030 at which time it will no longer be relevant.

Not trying to give you a hard time, but  your question is impossible to answer with the detail necessary to satisfy some people and without being selective regarding what "car hobby" means.  We run our models.  They are continually improved to reflect reality.  The picture they paint is surprising sometimes.  The best we can do is to estimate the impact of this sector collectively and assess whether there will be a beneficial return on enforcing the law.  This is a yes or no question.  This group (something other than stock) within this sector (mobile onroad) contributes a nontrivial amount of pollution, more than is necessary given the controls available but not enforced.  How much?  How heavy is a rock?  That can't be known, but it weighs something.  In this case, it weighs more than it is supposed to.  As other sectors are controlled to the limit of current law and BAT, this sector represents a greater and greater percentage of the whole, more than is necessary, and we already have a law to address the issue that will reduce overall emissions.  Having to accommodate the greater good is one drawback of other people existing.

 

L5wolvesf
L5wolvesf HalfDork
6/14/21 1:54 p.m.
Keith Tanner said:

If you want more studies, feel free to dig around. They're public and the actual numbers are in there. Part of the disconnect is that you're not willing to believe information that comes from the government because you fundamentally don't trust it.

If you don't believe that 15% of diesel trucks are modified, you don't know many diesel truck owners. I'm not talking about brodozers, but working trucks. 

3% of all the cars in the US is a pretty big number. Ever go backpacking? The best way to save a pound is to find 16 places to save an ounce. Same thing applies here. If you can improve the efficiency of the fleet by 3% (I don't know where this came from, but you quoted it), that's a pretty significant improvement. 

Keeping cars clean benefits us all. It's the eternal American problem, the self versus the society. If we can keep the emissions controls - that are placed on cars for very good reasons! - on cars, we have a better society. Im good with that, I like my clean air

Quoted because it is well put.

captainawesome
captainawesome Dork
6/14/21 1:54 p.m.

I have to say I initially want to kick up a fit about the automotive modification noose tightening, BUT there are some well explained arguments/facts from folks in the know here that completely curb that feeling.

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