In reply to Keith Tanner :
Got it, for free. Not a member. Cool.
In reply to Keith Tanner :
Got it, for free. Not a member. Cool.
Thank you - the download works for me too. We definitely want to make sure we're playing by the rules here - the main concern I have is that it sounds as if there may be some new, and unwritten, rules.
So just finished reading it.
It's interesting, but you need to feedback to SEMA that it's not fully complete.
The big question that I didn't see answered is "how good is good enough?"
On page 4, it goes over teh various recent levels of emission rules- Tier1 and LEVI up to present. What's missing is that there are a ton of different levels within each of those standards (except for the last ones, where the name has the value in it, like ULEV125). So as a user of this document, one is not sure of what level you need to work toward meeting.
There is this page, which is nicely public by the EPA- https://www.epa.gov/compliance-and-fuel-economy-data/annual-certification-data-vehicles-engines-and-equipment
As an example, lets say a 1994 Miata with a manual. It takes a little bit of digging, but for the certification of that car, it just ran an FTP and a Highway, and for cert, it's numbers were
FTP:
HC: 0.137 g/mi
CO: 0.83 g/mi
CO2: 364 g/i
NOx: 0.05 g/mi
And I can list the highway numbers, but it's not important.
So if I have a kit for a 1994 Miata, do I just have to meet those numbers, or do you just have to meet the standard?
For later cars, aging matters, and since cert tests are done at 4,000 miles, then there's a deterioration factor (DF) that is also part of the requirement.
The document really does not go into the data of what the targets are if you were going to do some development, to be sure that you would pass the test requirements (which are also not listed).
The document is good that it explains what the manufacturer needs to test so that they demonstrate that an EO is properly given. So that's good. But if it just explained to the groups how to figure out what the testing targets should be, that would be really useful. That includes people who want to replace a carb with some kind of EFI legally- if I had a 1973 Alfa Romeo (which I do), and I put and EFI on it to replace the SPICA, what would I need to demonstrate that it's a compliant change (and I could sell it)?
There are some proposed changes in the works in the EO process, but they're not rules yet. Most of them just follow the SEMA best practices on how to put in an application that are in that document. Feel free to hit me up for clarification.
alfadriver said:That includes people who want to replace a carb with some kind of EFI legally- if I had a 1973 Alfa Romeo (which I do), and I put and EFI on it to replace the SPICA, what would I need to demonstrate that it's a compliant change (and I could sell it)?
First off, that's the sort of thing that would be viewed favorably because it's obviously going to improve emissions. The test procedures are mostly about new vehicles, so the discussion of old stuff (anything more than a couple of years old, really) is only mentioned briefly on page 14. Basically, you do baseline testing on a test vehicle. If the modified vehicle is within 10% of the baseline, you're usually okay. It's understood that you simply can't find a 4000 mile 1994 Miata - or if you do, it's still probably not meeting original specifications because all the components are 25 years old.
Testing is done on a worst-case scenario, so if your product fits 1999-05 Miatas, you'd test on the 2005. That's not a randomly chosen example because the US06 (I think) was introduced in 2004 models, so it's harder to get a boosted application to pass on a 2004 Miata than it is a 2003. There's a supercharger with an EO for 1999-03 Miatas, you can figure out why :)
There can be some arrangements made if the worst case is some sort of unicorn and a representative test car cannot be located. SEMA can help with locating one. There is some back and forth here, it's basically a matter of negotiation to find a solution that suits all parties in some cases.
In reply to Keith Tanner :
Ok, so my examples were not perfect. but I do feel that the "how good is good enough" target isn't really listed all that well. Going against a "baseline" is very misleading, as there are so many reasons that in-use test vehicles are allowed to be excluded from a sample, it's not even funny. And there's no solid way of choosing a good baseline vehicle in the first place. While some of the cert vehicles could be special, it's very rare, so it seems like a much better choice is to use either the legal cert limit. Still- it doesn't even say that within 10% of baseline is good enough.
When I get home tonight, I'll send a letter to SEMA about that. That needs to be cleared up. If you are going to go through the trouble of doing your own testing, you should have enough confidence that you are making a fully compliant target.
It does say that 10% of baseline is normally viewed as good enough - that's on page 14. I know that the "10% rule" is one of the things that's undergoing a review right now as there is some dissatisfaction about it.
This is where being a SEMA member is useful. We talk to the emissions team at the SEMA garage and they give us guidance on how to structure the testing and make sure the baseline car is good. Sometimes they'll check with the ARB to make sure they're good with it. There really are humans in the process, it's not just a rigid checklist. Everyone involved wants to get clean products to market, so we work out a way to reasonably satisfy all parties involved. It's quite possible life is different at the OE level.
We've used baseline tests on at least two EO applications because some Miatas were awwwfully close to the line when new. Like, our testing made it look like our new stock car wouldn't pass. So we matched the cold start numbers to stock and figured that would be good enough with a baseline. We were right.
BTW, there are only a small number of test cells available to the aftermarket. I'm not 100%, but I think it's 2-4 in California. Mazda has something like 14, and most of their R&D isn't even done in the US.
In reply to Keith Tanner :
There are a couple other things that need looked into, too- so I'll still drop them a line.
As for your testing, are you doing it in-house or in California? Or better phrasing- SW CO, or near sea level? There's a really big difference.
The new PEMS devices with chassis dynos make it really easy for companies to do their own unofficial development, so that when you actually go and run the real test- you are more prepared for it to be right than having to re-do work when dyno time is so expensive.
That's how we do it - test on our own dyno with our own PEMS, then make the trek to CA for the test. A proper test cell has at least a million bucks worth of equipment in it, that's a bit rich for our blood :)
In reply to Keith Tanner :
So you know, for almost all cars out there, there's a separate standard for 5280 than there is for sea level.... You'll be higher emissions at that altitude, and it's expected to be that way.
(I'm asking about where the altitude data is...)
We work around that by doing our own baseline. Since we don't have the ability to fully replicate an FTP, we just do various tests on the stock car and then aim to match.
In reply to Keith Tanner :
So the answer is about 33% more- testing at your site, the baseline will probably be just over 30% of the certified version.
But I still don't like the "baseline" thing, and being close to the baseline. It's one thing if you are doing just a part add, but it's another if it's an entire system change- where you can't just add the one part. Like if you do a catalyst change.
And with a PEMS and a dyno, you can come close enough to a full FTP to be confident in the process....
Keith, thanks for the link, hope it's a good read.
From my perspective (tuner, DIY distributor, maker of things for race cars) the burden of required proof that myself and others like me are selling to only "race use" will be interesting. I saw it mentioned above that Mazda needs documentation of previous races, which could make sense. However, if you're a weekend bracket racer coming up with a new setup? Weekend time attack driver building a new car? Is a checkbox or dropdown on a website (example dropdown: NHRA Lucas Oil Series) enough to ensure compliance? How can I tell a customer is or is not putting insurance and a plate on something?
In reply to Paul_VR6 :
In Mazdaspeed's case, if you are currently building a car, that you pinky-swear you are going to run, you can buy parts, but I am uncertain on time limits. Unless they have changed the rules again, engine or chassis builders may not buy parts on your behalf, but you as the racer have to buy the parts and have the option to have them shipped directly to them.
If you buy parts, and win contingency money that year, they deduct the parts from your winnings on the tax form.
I love how educational and productive this thread has been.
First, you need to lose the quotes around "race parts" and "race cars". Because "race parts" are what will get you in trouble. You sell race parts. Seriously, this is a mindset thing.
If the car is used on the street, in the minds of the EPA, it needs to maintain emissions compliance. Only cars that have made a one-way irrevocable and complete transformation into a dedicated race car can legitimately run non-compliant parts. "Race cars" that have license plates are not race cars.
There is no published set of guidelines for how to ensure your parts are not being used on street cars. The website checkbox/dropdown/warning was specifically called out as not being sufficient. If you're going to sell non-compliant parts, you have to make a legitimate effort to make sure they don't end up on street cars. Available for sale to the general public is not a legitimate effort, some screening would be necessary.
Mazdaspeed does indeed have a "I am building a car" program. They're probably a pretty good example to model yourself after. Details. You have to apply, provide documentation and get approved, then you get a login for the site that lets you purchase things. Car owners do get different access than shop owners - shops can buy OEM parts, but not competition parts.
There will be some guys who manage to get race parts on their street cars. You can't stop it all. But selling a few hundred thousand emissions delete kits for diesel pickups is pretty clear that you're not selling race-only parts. Advertising that your parts will improve towing capacity and fuel economy (yes, I know that for an endurance racer this is a legit concern but it's an example from the EPA) is a problem because those are street car attributes. It has to pass the sniff test. If you're selling a camshaft that idles at 2000 rpm and a head that requires race gas to run, the burden of proof will likely be much lower than if you were selling O2 signal simulators simply because it's unlikely anyone would buy the former for a street car.
Educational is what I'm after, Knurled. I want our hobby to continue and for good parts to remain available for our cars. Knowing what's going on is good for everyone, especially if it's actual info and not propaganda of some sort. Alfa has been preaching this for a while, I know he was concerned about FM's exposure with our old non-compliant turbo kits and his viewpoint from inside the OEs is a really valuable one.
Keith thank you for the advice, duly noted. The link is quite helpful as well, the application aspect could be a bit burdensome but I think it may push some different business models. I could see that being a good thing.
Keith Tanner said:TL:DR - expect to see parts without EOs disappear from the market. Expect to see parts with EOs get a little more expensive. Expect to see some sort of check that EO'd parts are not modified post-sale, specifically software. Expect to see a much more concerted effort from vendors to ensure that race-only parts will only get put on actual full time race cars.
So after about nearly a year later, looks like Keith was right and recent news about catless downpipes being discontinued by several big name VW aftermarket vendors (APR, etc) for VWs reminded me of this thread.
EDIT: Forgot to mention, the Stage 2 tune is also discontinued
Yup, APR stopped selling their downpipes and stage 2 tunes for my Golf R. AWE stopped selling their downpipes for my car awhile back. Those guys are huge players in the VW market, if they don't think it's worthwhile to pursue CARB approval on their products that doesn't bode well for the other smaller tuners who also sell downpipes and tunes.
Even though I don't plan on tuning my car for awhile I'm debating picking up a Cobb Accessport and EQT Stage 2 tunes now while I still can.
Hey, I did my research :) I'm surprised to see this popping up as news again, it's like the EPA released a paper at the SEMA 360 show this year or something. The National Compliance Initiative I mentioned in my first post is on a three-year cycle so it's still legit.
CO just passed a law that requires all aftermarket catalytic converters to have an EO number - basically, they have to be proven to meet standards. Turns out ME and NY have similar laws as well. We can no longer ship a number of our cats to our own state. Which is awkward, because every time we offer both a CA legal cat and a non-legal version the latter sells far better beause it's less expensive - fewer precious metals.
So do we only sell CA legal cats and suck up the fact that our sales will tank compared to anyone who doesn't follow the rules? Or do we just get out of the cat business? I suspect it will start as option A and then turn into option B as the cats prove to be economically unfeasible as a product. The transition is going to be painful - profitable for those who ignore the rules and get out without getting nailed by the EPA, expensive for those who move to legal products only before the competition.
Good thing I just replaced my FlyinMiata MSM downpipe then.
I wonder how this will effect generic cats such as the Vibrant part I used on my TR6. At least if those are available, we can replace worn out cats by cutting and welding. But probably not with approval.
For the TR6, it will depend on the state. ME, for example, only requires a 50 state cat for cars that are 2001 or newer AND have California emissions. NY requires it for vehicles that are 1993 or newer, again with the CA emissions. No mention of antique British cars, so they can use "EPA" cats :) The CO law doesn't have a cutoff like that from what I remember seeing, though.
Sooner or later a failed cat will be one of the most common reasons to total a car :(
Not mass market cars because the market will respond. It will very likely become more of a problem for low volume ones or ones that are simply not desirable enough to keep on the road. You can get a CA legal cat for any 1990-15 Miata (not necessarily from us...yet) even though they're pretty low volume. The 2016-2020 Miatas will follow as the cars get older and it becomes clear what the last model year for that platform is.
I'm all for curbing emissions, but I wonder why a sticker matters. Shouldn't legality be determined by what's coming out of the exhaust pipe? If the exhaust meets the standards why does the equipment matter?
That's what the sticker says. It says the part has been tested under the full range of conditions and does not affect vehicle emissions. They measure cold start emissions, evaporative emissions (well, not so much on a cat), emissions under a very specific variety of loads and engine speeds. Forced induction cars may even go into boost on the test.
A tailpipe test on a hot car at idle is the easiest possible test to pass, so it's not really useful. OBD-II (On-Board Diagnostics, in case you forget) helps a lot by monitoring the performance of the emissions controls under all conditions, but it's still a bit of a blunt instrument compared to those test chambers.
You do NOT want to pay for a full test of your car every time it's due for an emissions check to make sure that what's coming out of the tailpipe meets standards. The car would have to sit in the test cell overnight and requires (literally) a million bucks worth of equipment.
You'll need to log in to post.
