US EPA Wants to End Emissions Exemption for Street Cars Turned Racecar

mustang gt350r
In a recent regulatory update, the US EPA has stated that it intends to eliminate emissions exemptions for street cars turned into competition vehicles. We really really really really really hate writing about politics here, but we’re making an exception this once for two reasons: this is really really right up our collective alley and there’s already endless misinformation spreading. Without delay, let’s get to some facts.
Currently, you’re not allowed to modify the emissions equipment on a new vehicle certified to meet emissions standards, except if it’s used “for competition use only”. For example, you could buy a new GT350R Mustang and do whatever you want with it, ECU and exhaust-wise, so long as you never put it back on the street.
EPA is proposing to “fix” that regulation (emphasis ours):

In particular, we generally consider nonroad engines and vehicles to be ‘‘used solely for competition’’ based on usage characteristics. This allows EPA to set up an administrative process to approve competition exemptions, and to create an exemption from the tampering prohibition for products that are modified for competition purposes. There is no comparable allowance for motor vehicles. A motor vehicle qualifies for a competition exclusion based on the physical characteristics of the vehicle, not on its use. Also, if a motor vehicle is covered by a certificate of conformity at any point, there is no exemption from the tampering and defeat-device prohibitions that would allow for converting the engine or vehicle for competition use. There is no prohibition against actual use of certified motor vehicles or motor vehicle engines for competition purposes; however, it is not permissible to remove a motor vehicle or motor vehicle engine from its certified configuration regardless of the purpose for doing so.

This reads to say that from the date the regulation goes into effect a vehicle built to an EPA certification (i.e. all new cars) should never be modified from that certified configuration, even if it never drives another mile on a public road.
A few thoughts and bullet points after the jump…

  • This regulation would not be retroactive, meaning no one’s coming after your LeMons car or any other track car in existence today. It’s more like dedicated track cars made from 2018 model year street cars.
  • It’s unclear there’s any way to enforce this. If a car is a dedicated track car, it’s no longer being registered for street use, which is the current mechanism by which local authorities enforce emissions requirements (e.g. semi-yearly smog checks required for registration renewal).
  • As far as we know, the EPA has no local automotively-focused presence anywhere. To enforce this, they’d have to send inspectors to local track events or something?
  • What’s also unclear is how long a car is required to remain in compliance with its certified configuration. Most states (not California, unfortunately) have rolling emissions exemptions. By the time something’s likely to be turned into a dedicated track car, it’s outside of emissions enforcement anyway. Will EPA black helicopters be circling LeMons Arse-Freeze-apalooza 2032?

To be clear on our stance here: The EPA has been good for cars and humanity in general. Cars today are faster, cleaner and more efficient because of the EPA. It’s good that leaded fuel is banned from mass usage. But this is dumb. Racecars in no way contribute meaningfully to air pollution. Regulatory enforcement would be better directed elsewhere.
As an aside, the SEMA press release on the topic is useless. No citations and no link to the actual proposed regulations. They offer a tiny nugget of info then jump straight to fighting words. We know you’re a lobbying group, but c’mon guys, you can do better than that.
In an effort to be more thorough and let you find things out for yourself, click through on the Proposed Rules and do a search for “competition”, you’ll come across the relevant sections.
 

90 Comments

  1. My guess is that the enforcement would, at least in part, be forced upon the tracks and/or event organizers.

    1. No, the enforcement would happen at the aftermarket industry level, which is why SEMA is concerned. They are like the NRA telling people that Obama is going to take their guns with this.

      1. Don’t understand how that would work. Tracks or race promoters could be forced to test emissions or certify that original equipment was in place. Aftermarket manufacturers would likely never even see the car.

        1. No, they would just not allow “test” pipes and oil catch cans, and breather vents to be sold for new model cars, that’s it.

  2. If they create the rule, they’ll likely look for a way to enforce it. Saying, “Don’t worry. They have no current mechanism to enforce this” is akin to “don’t worry about that Hitler guy because you’re not a Jew.”

    1. Don’t make me break your stupid law. If you’re not going to enforce it, just don’t write it.

    2. They’ll find a way to enforce it? That’s crazy talk. The only thing crazier would be to suggest that they’d find a way to generate revenue while enforcing it.

    3. Butt sex and sodomy laws would be the more appropriate analogy here. But clearly it’s the gas oven dealers group that is worried as a point of enforcement since the illegal goods originate with them.

    1. Jay Lamm’s “less pollution than caused by middle aged dudes in flip-flops with their lawn mowers every Sunday” is probably correct, possibly by a couple orders of magnitude (haven’t actually done the Fermi estimation yet, too tired for even that level of math right now, but the order-of-magnitude difference in number of folks with lawn mowers vs people with dedicated track cars at least cancels out the difference in fuel consumption per hour between a track car and a lawn mower, and the race car probably still burns its fuel cleaner).

    1. Well that’s a terrifying thought. As far as taxes go, I actually like the idea of an infrastructure-supporting tax on mileage traveled on state roads (I’d much rather pay my fair share for services rendered than pay an arbitrary share towards something that has nothing to do with me), but unfortunately I can’t figure out a way to do that without being extremely invasive. That, and realistically once the tax money is collected I have no confidence that it would actually be used to pay for what it was supposed to. That doesn’t seem to be holding this proposal back, though.

        1. One of those songs I never need to hear again, along with Sweet Home Alabama, Stairway to Heaven, Life in the Fast Lane, Hotel California, Slow Ride, and Old Time Rock ‘n’ Roll.

  3. The link to the full text of the proposed change is this one:
    https://www.gpo.gov/fdsys/pkg/FR-2015-07-13/pdf/2015-15500.pdf
    The proposed change is described repeatedly as a “clarification” of existing rules, which sounds to me like it would indeed apply to any vehicle and any engine that has EPA certification, not just those manufactured after the date this change would go into effect. I see nothing in the proposal to suggest otherwise. Every certified vehicle and every certified engine would have to remain in certification for all time, no matter how they were being used.
    According to p. 584 of the text, the EPA “may assess a civil penalty up to $37,500 for each engine or piece of equipment in violation.” That sounds like sufficient motivation to develop methods of enforcement.

    1. Is there a good definition of “certified vehicle” in the document or anywhere else in any EPA documentation?

      1. Yes. If something was originally issued an EPA certificate of conformity as a “motor vehicle” or as a “motor vehicle engine” then that is what it shall always be. Nonroad vehicles and nonroad engines (such as race vehicles and race engines) are separate categories and the EPA now wishes to clarify its position that a person cannot change the former into the latter just by using it as the latter. Using it for racing is okay but it would still have to meet its original standards.
        This is discussed on p. 391 of the document I cited above as well as elsewhere in the document. A lot of it is contained within the various sections of 40 CFR part 1068 which are discussed throughout the document.

        1. I just want to point out that their choice of terminology is really poor. How, exactly, is a non-road vehicle powered by a motor of some kind not considered a “motor vehicle”? I re-read that paragraph from the EPA several times trying to parse it. I’m still not sure I’ve interpreted it correctly, but I eventually settled on “OH, they’re using ‘nonroad vehicles’ and ‘motor vehicles’ as mutually exclusive categories, with ‘motor vehicles’ referring specifically to vehicles meant for use on public roads. …well that’s stupid.”

          1. It isn’t the best choice of terminology, no. It doesn’t help that this is just a proposal to modify and/or clarify the existing rules and therefore a lot of the terms are defined elsewhere. “Motor vehicle” is in fact narrowly defined as you inferred from context.

    2. That’s how I’m reading it as well. This is not a new requirement to prohibit tampering with the emissions control systems of a vehicle that was originally built and certified for highway use; it was already prohibited a long time ago, even if the tampered vehicle was only going to be used for racing.
      But I don’t expect to see EPA showing up at the local dirt track some race night and doing a sniffer test on all the GM G-body street-stockers anytime soon.

  4. screw the EPA & cut all funding AND personnel tomorrow, none will be missed. Tomorrow, none will be missed. 3-4 months from now, we shall do this again.

  5. OK that wash a bit harsh cut 1/2 the funding AND the personnel at the DOT first, let us see how this works

    1. These agencies have become so bloated and out of control it would make sense to close entire agencies and replace them with new ones with new simpler regs, paper, compliance, etc. How else do you reign in these self perpetuating albatrosses?

  6. I think this is to go after chip tuners, and other makers of performance mods.
    Up till now they’ve been able to claim that they sell their product for “off road” use only. If off road use is also illegal, E.P.A. can claim the aftermarket tune has NO legal use.

    1. This is an important distinction. Would definitely increase the gyrations required to claim a part has a legal application, e.g. “for use on non-certified motor vehicles only”, assuming someone could claim there’s a non-certified Ford 4.6 2V out there that was never subject to EPA compliance.

      1. “I don’t sell auto parts. I, um, I sell paperweights and objets d’art. I sell them in boxes labeled with specific vehicles and engines for people who wish to make a harmonized fashion statement among their otherwise unrelated possessions, sort of like the tags on Garanimals. Yes, that’s it. Why do you ask?”

        1. Ah. The “Glass Sculpture Ruse”. Usually works, but Tommy Chong still got arrested for selling paraphernalia.

        2. Ooh, now your talking like 80% receivers for guns. This is just a unregulated chunk of aluminum, but here are all the fixtures and jigs you need to make an AR-15 receiver (legally). Or maybe more like the idiots that buy and sell steel tube with all the cuts you need to make your own homemade illegal submachine gun. “Here is a chip, just a technical curiosity. Whatever you do don’t program this additional line of code into it. Here is a USB adapter for said chip too by the way. “

          1. Have this nice shiny new GT-R. Now, not that you’d ever do it, and we don’t suggest that you should, but if you were to remove this little restriction plug in you boost control line then you’d have an “illegally” fast car.
            Why can’t we just do this? It doesn’t impact emissions equipment, it leaves emissions stock if replaced before testing, satisfies owners and is fairly legal.
            I also wonder if any car with a track/power key passes emissions with the key engaged.

          2. Pulling out the plug could be construed as tampering… sorry.
            IIRC*, a system with multiple power modes has to be emissions-compliant in all the modes.
            *(My day job is engineering of various engine-related parts & systems on a series of off-highway construction equipment [wheel loaders] that happens to have multiple power modes. I could be completely wrong about on-highway stuff.)

          3. During Prohibition, some of the big brewers with diverse holdings sold malt extract “baking kits” that came with explicit instructions about how not to dilute said extract, boil & cool it, nor add yeast to the finished mix.
            That’s how “not” to make beer.

          4. Many of the big brewers are still demonstrating how not to make beer to this very day.

  7. I remember the first USGP at COTA they had EPA planes crisscrossing over the track to take air samples. If the EU hasn’t taken this action already, I doubt the rest of the world will follow us.

    1. That happened?
      I’d guess the once a year F1 event produced less emissions that the methane-expelling longhorns the track displaced.

      1. The last GP of India had a brown haze thick enough to see a rooster tail and obscured the shots down the straight. Not specifically race car-caused but you can bet the air quality around the track was more toxic that weekend than ever.

  8. I don’t want this to become a “First they came for the…” situation, but this isn’t us… yet. This doesn’t affect LeMons, or future LeMons, or dedicated track toys.
    It’s about semi trucks. And construction equipment. And stationary generators.
    Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium and
    Heavy-Duty Engines and Vehicles

    1. That is indeed the title of the proposal, but from p. 2 of its summary:
      “EPA is also proposing technical amendments to EPA rules that apply to emissions of non-GHG pollutants from light-duty motor vehicles, marine diesel engines, and….”
      There’s more, but the part about “light-duty motor vehicles” means cars, pickup trucks, and the like. The actual text of the proposal makes it quite clear that they’re including light-duty vehicles (e.g. cars) when it comes to racing.

  9. This is what happens when our legislators pass insufficiently specific laws. This is a rule change under the existing law, there is no accountability for it. This happens in every corner of American commerce. The administrators at the EPA are emissions absolutists. They do not care about what specific benefit is gained when they have a computer model that proves their every action is forestalling the apocalypse. Never mind the costs, or that the model has been proven wrong.

  10. I could see this playing out very similar to guns, machine gun in particular. It has been the law for some time that if a gun has ever been in a fully automatic configuration, then it is always considered a machine gun. With guns there is one serial numbered part for each type of gun that is considered “the gun” for purposes of the law. I could see the VIN stamped chassis becoming “the car”, or maybe some combination of the chassis and engine block. Back to the gun analogy, since the fall of communism, the US gun market has gotten a bunch of surplus Soviet Block rifles and machine guns. Now the machine guns could not be imported (manufacture or import of civilian legal machine guns has been banned since 1986, there is a set supply that can be legally traded). What was done was the machine guns were stripped down and the receivers (the gun) were destroyed, these were then imported as “parts kits”. The parts kits were then assembled onto new US made semiautomatic only receivers by companies and individuals (legally). I could see Ford and Chevy selling “parts kits”, for race cars or new virgin non-certified chassis or engines for racing. If this comes to pass at some point the government will determine the “certified part or parts” that constitute the car. Then individuals will get creative and work around those rules. I could even see a future of “registered race cars”. I really pray that the racing community doesn’t have to deal with the same level of government control and bureaucracy that the gun community has had to deal with since 1934.

    1. There’s a lot of wording about what constitutes the certified engine and certified vehicle. Which, of course, only tells us that we’ll be playing cat and mouse over technicalities exactly as you’ve described.

  11. My read of the whole thing is that this is aimed mostly at dual use cars currently registered in places without a yearly/bi-annual smog test. If they had authority over closed course competition vehicles now the motorsports landscape would look a lot different. As stated, the EPA sets federal rules which the OEMs have to meet in order to sell a car, the EPA is not the one who keeps you from driving your Ford Escort with a blown head gasket bellowing smoke until it won’t more any more. That would be your state smog/DMV folks.
    Also, isn’t it time for a SEMA backed ballot initiative in California to start rolling the exemptions forward again? Currently stuck at 1975, this would be a perfect year to roll them forward to 1981 (when the maximum allowable limits started ratcheting down), then keep rolling at a 35 year old exemption at least until we hit 1995 and OBDII

      1. You are correct, because driving a bone-stock 500 cubic-inch ’76 Fleetwood Brougham that passes the test is perfectly fine but putting a junkyard 5.3L LS truck long block with plug-and-play EFI, headers and a set of aftermarket cats in that Caddy will turn the air into toxic sludge. Ditto registering a JDM kei car that’s legal under the federal 25 year rule and produces tiny fractions of the stock Caddy’s CO2, CO, particulates, etc.
        That’s CARB logic in a nutshell.

        1. All the CARB certification regulations have been a pet peeve of mine for a while. If you really want cleaner air, does it not make more sense to simply perform a sniffer test once every however long? Who at CARB really cares about the exact details of what’s under the hood so long as the actual levels of pollution emitted (which is the point of concern, no?) are within allowable limits? If we’re worried about the quantities of certain pollutants that may be produced by a car, and we can measure those quantities, why should those measurements not be the final arbiter of whether a car’s powertrain configuration is legal or not? Maybe the newer-technology, aftermarket high-flow cat that gives me a couple of extra horsepower actually works just as well as the old stocker, who knows? It could even be made part of the periodic maintenance schedule for a car (come to think of it, wouldn’t that be a potentially useful diagnostic to have done on a regular, ongoing basis, to see how the car’s powertrain changes its behavior over time?) Sure, it’s possible for people to spoof the sniffer test, find a shop that’ll look the other way, etc. — but given that that’s already going on in spite of all the additional CARB certifications that are supposedly required, I wouldn’t think that rate would change that much. (Sorry — OK, rant over.)

          1. ” If you really want cleaner air, does it not make more sense to simply
            perform a sniffer test once every however long? Who at CARB really
            cares about the exact details of what’s under the hood so long as the
            actual levels of pollution emitted (which is the point of concern, no?)
            are within allowable limits?”

            Ask your local Volkswagen dealer.
            It’s much easier to say “Yes, this is exactly the OEM equipment” than to find that hidden computer chip and “power valve” in all those millions of aftermarket parts.

  12. “The Law of Chaos: Any activity or event that seems to lie beyond the boundaries of possibility will usually be the first thing to occur.” ― Ian Strang, The Grand Scheme of Things

  13. Have to disagree that cars are faster or more efficient because of the EPA. Cars were becoming faster and more efficient continually before the EPA’s regulations, which when initially implemented made cars slower and less efficient until innovation in the industry adapted and overcame the limitations. Cleaner, sure, but cars are faster and more efficient due to innovation in electronic engine controls, materials, and mechanical systems that would have a tremendous advantage in the marketplace absent any legal requirement to make a car more efficient or pollute less.

    1. Faster, yes, but not increasingly efficient before the EPA. For the US at least (and really, if we’re talking EPA, we’re talking US), MPG was at best unchanged if not slightly worsening throughout the middle decades of the twentieth century:
      http://ars.els-cdn.com/content/image/1-s2.0-S0301421509002274-gr1.jpg
      As much as I like my stock ’59 Ford, when it’s running again I expect to get worse mileage from it than I did from my stock ’37 Plymouth. The Ford should be faster, though. I hope.
      http://www.sciencedirect.com/science/article/pii/S0301421509002274

      1. Fair enough, I guess I’m thinking in terms of mechanical/technology advancement. Gas prices made efficiency a valuable thing, prior to the oil embargo gas was so cheap that it would be like spending development dollars making your car use less air in the combustion process. It was addressed once a need to do so became valuable.

  14. While I’m not saying this is a good thing or OK to have happen, I come from a place with supposedly draconian emissions regulations that magically also has the most thriving car culture on the planet.
    We buy cars that are pre-1975 and we buy smog-legal speed parts for those still under certification. There are also loopholes related to “antique/rare vehicle” registrations.
    My default reaction to “XXXXX WILL MEAN THE END OF THE WORLD”, is “probably not”.
    Backing away from the hyperbole increases the likelihood that one’s opposing parties will consider them credible and be willing to reach a compromise through dialog. Characterizing one’s opponents as intractable zealots is about as counterproductive as being an intractable zealot oneself.

  15. Nice to see clear thoughts in the story here. Too many folks were up in arms over an industry lobbying group’s press release this morning.

  16. What a waste of time and energy from the EPA. Are they concerned with race car pollution? Production cars that end up becoming race cars are what, maybe 2% of vehicles? And once becoming race cars they get driven a couple times a month for maybe an hour total. How is this even remotely worth focusing on? It sounds a lot like splitting hairs out of boredom, or perhaps OCD.

    1. Could probably change that to 0.2% at best, and half of those are just keeping the cars out of the landfill /recycling stream for a few years.

  17. As I am Canadian, and have not yet bothered to fully read up on this, I’m not going to comment on the issue.

    I am going to comment on the commenting on the issue, however.

    And I want to say thank you to Hooniverse overlords, for presenting the initial information in a clear, concise, manner, and thank you to fellow Hooniverse underlings for commenting in a calm and informed manner.

    Hooniverse may try to avoid political topics on the whole, and yet when it does, it somehow manages to discuss it better than many sites who deal purely in political topics.

    TL;DR: Thank you, and keep up the good work!

      1. I’m applauding the fact that there are less references to Nazis, Jews, and oven manufacturers than would normally be expected.

          1. My son’s a dual citizen living in Vancouver, British Columbia.
            You have a great day!

  18. We, as voters need to rein in the EPA. I have read a lot on this subject and the EPA is causing real damage to you and me with over regulation.

      1. Judging by the overwhelming GOP victory last night in NH you’ll have to vote a few million times to cancel us out. The desperation shown by the dems is a joy to watch. The party of Youth w nothing but 70 yr olds… Yea you go guy…..

        1. What are you talking about? Both dems got more votes than the top puke in NH. Bernie had 50k more votes than the clown show leader.

  19. This has actually been the law for a very long time:
    Q: “Can I remove a converter from a vehicle that is used only for ‘off-road’ driving?”
    A: “No. The tampering provision … applies to this situation as well. The federal tampering prohibition pertains to “motor vehicles”, which are defined by section 216(2) of the Act as ‘any self-propelled vehicle[s] designed for transporting persons or property on a street or highway.’ A light-duty vehicle manufacturer certifies an engine-chassis configuration as meeting the applicable emissions standards for motor vehicles manufactured in a given model year, and it is not legal for anyone to ‘de-certify’ a motor vehicle for ‘off-road’ use.”
    “Fact Sheet: Exhaust System Repair Guidelines”; US EPA, 13 March 1991
    http://www.epa.gov/sites/production/files/documents/exhsysrepair.pdf

  20. “We really really really really really hate writing about politics here, but we’re making an exception this once…”
    Questionable editorial decision.
    Let’s see. We have an entire set of analogies drawn to the restrictions on automatic weapons. We have references to Hitler, Jews, the Holocaust, and who the government is going to come for first. Oh, and gas oven manufacturers. We have calls to completely eliminate the EPA and (heck, why not?) the rest of the government. We have claims that the EPA had planes crisscrossing over the USGP, as if they would be able to measure air quality that way and as if it weren’t more likely to be fat cat airborne sightseers. Must be a tin foil shortage somewhere.
    To top it all off, we have a Canadian complementing us Americans on the quality and reasonableness of our responses.
    Hey, if you editors wanted to stir things up and generate unreasoned hysteria, you nailed it.

  21. EPA clarification:
    “This clarification does not affect EPA’s enforcement authority. It is still illegal to tamper with or defeat the emission control systems of motor vehicles. In the course of selecting cases for enforcement, the EPA has and will continue to consider whether the tampered vehicle is used exclusively for competition. The EPA remains primarily concerned with cases where the tampered vehicle is used on public roads, and more specifically with aftermarket manufacturers who sell devices that defeat emission control systems on vehicles used on public roads.”
    We all knew this was what the law was about. Remove your cats? Illegal. Install a chip that changes what comes out of the tailpipe? Illegal. Not happy with that? That’s sad, but this is nothing new. These aftermarket device sellers always seem to imply that they are smarter than the scientists and engineers at the OEM. If GM, for example, could have simply programmed a chip to produce more power or better efficiency without increasing emissions, they would have done it.

  22. This is a straightforward summary of the issue prepared by an attorney on behalf of LeMons:
    http://www.24hoursoflemons.com/images/EPA-Memo.pdf
    The bottom line seems to be that yes, whether the EPA wishes to admit it or not, this would represent a change in policy and that, either way, the EPA’s current interpretation of policy and their proposed change in policy both appear to be at odds with the underlying letter and spirit of the law from which the policy is derived.
    For anyone who thinks this is just about things like catalytic converters and engine management systems, this policy would also prohibit the installation of safety items such as fuel cells, in that the stock fuel tank is part of the certified emissions system. So, pretty much goodbye to racing anything built for the US market that was made after 1970. Also good luck finding anyone still selling racing parts like fuel cells in the US, even for old cars, once nearly all of the market has been eliminated.

    1. Since we can’t swap VINs because that’s the car’s legal DNA, then I suppose I probably can’t just take a tin snips to the ID plate and then use the reset of the body shell to “make” a custom, dedicated race car chassis, can I?

      1. Generally no. I believe it would be okay to freely repurpose anything except whatever is legally the defining portion of the “motor vehicle” and its “motor vehicle engine” for certification purposes. For body-on-frame I think the “vehicle” is the frame but for unibodies it’s probably what, the main shell? For engines let’s assume it’s the block, which is probably the case (or at least close enough for an informal example).
        So, if you start with a certified frame or unibody shell, even if you’ve modified that frame or shell, then the race car must meet those original standards no matter what other components are used. That would include the engine, fuel system (including tank), and so forth, all of which would have to be either stock for that frame’s or shell’s original factory configuration or of the same types of basically identical replacements that are already currently allowed for a certified street-legal vehicle.
        Also, if you’re using a certified engine block in anything (any race car at all, regardless of age or origin), then everything that makes that block function as an engine (including the fuel system back to and including the fuel tank) would have to be whatever was originally certified for use with that engine block. If you want to drop a modern motor vehicle engine into a ’65 Galaxie and go racing, you’d better be prepared to install EVERYTHING that would have gone with that engine.
        If you build a tube-frame racing chassis, you can probably go ahead and hang a set of repurposed and/or modified street-legal doors, fenders, tail lights, and so forth on it. Those aren’t EPA-certified components. You still wouldn’t be able to run a certified engine block in it unless, again, you install EVERYTHING as above. You also wouldn’t be able to attach whatever is legally “enough” of a main body shell onto a custom-fabricated chassis without, again, the same restrictions.
        Vehicles and engines made before 1971 would be okay to modify and swap around, as long as both the vehicle and the engine are at least that old. The only other exception would be for grey-market imports that are over 25 years old, as those also are exempt from EPA certification. For any other scenario, the most restrictive possible interpretation would be the correct one, assuming this goes into effect as currently written.

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