I found an article that answers a few questions that most everyone has had at one time or another. Now, before I go any further with this, let me make one thing ABSOLUTELY clear. I have not been able to verify the legality of the question that this article brought to mind. I am however checking into a few things that look promising. Expensive, but promising. The full article can be found at. http://www.off-road.com/dodge/...l.htm
Based on my understanding of this article, ANY tampering with the configuration of a certified vehicle is illegal. That DOES include CARB certified parts. This is an EPA (Federal) statute. Now, the article was aimed at emmisions, but quotes the statute from the clean air act, as well as a few interpretations from an EPA official. Towards the end of the article, there is a very encouraging statement; "Specifically, the USEPA has placed the burden of proof on the individual. The only way an individual is absolutely assured of remaining in compliance after making modifications is to spend about $2,000 dollars or more putting the modified vehicle through the full federal test procedure (FTP) that the automakers use." Remember that, there will be a quiz later.
Upon further research, I found a letter from Steve Albrink (USEPA) that stated; "However, while it may be legally possible to insert a newer powertrain and control system from one vehicle manufacturer into and older vehicle or the chassis of another manufacturer, there is a concern that in practice, these types of changes are usually not completed correctly either because of the prohibitive cost or the lack of proper ability or knowledge.... Therefore, EPA presumes this type of engine change to be illegal unles the person who installs the engine can demonstrate that he/she has or will correctly make all the necessary modifications to make the powertrain and control system in the vehicle identical to an appropriate certified configuration."
Now, having said that, (bear with me, almost done) it stands to reason, that although engine swaps (ie. KA to SR) are currently illegal, IF, and only if someone performed the swap, then had the FTP performed and the configuration was then certified, they could then perform the swap in a legal manner with EPA (Federal) approval, having demonstrated that the configuration meets Federal standards.
Before the flaming starts as I'm sure it must, keep in mind that this is currently only a theory that I have developed. I am researching this with the EPA, CARB, and have been in contact with Mr. Albrink to confim whether or not this is indeed possible. I'm sure that should this prove to be the case, the LEGAL method of swapping will remain quite expensive, somewhere in the range of $10,000 including parts, labor, and certification.
Some time ago, I stated that I believed there was indeed a loophole that would allow LEGAL SR swaps. I believe now that I may in fact have found that loophole. Albeit an expensive one, it does appear to at least be an avenue worthy of consideration. I'll keep everyone posted.
By the way, Have any Moderators/Administrators considered a Automotive politics forum? Might be a good idea. Just a thought.
Thanks for your patience, I know this was a long post.
EPA, Swaps, and The Law. (long)
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lessthanjakejohn
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MaineExport
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The high $ of a legal swap was what concerned me. I'm looking into whether or not one car could be used to run the FTP, and then once that configuration is certified, if other cars could be converted by the same shop/mechanic/whatever as long as they are identical in mods to the original config.maineimport wrote:Nice call Ryno..... but it sounds cost prohibitive. It would be nice if it works out though.
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MasterMan
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eh so whats the problem with doing it illeagly? i really dont think any cop would look under your hood.. (well maby in a big city) and even if they do, do u really think they could memorize ever engine out there? (honda swaps, nissan, toyota.. ect) i think ill just stick with being illeagle.. no one has been busted for it yet anyways...
It's stands to reason that most cops won't cause too big of a problem assuming you abide by the regular laws....
However if perhaps you were to encounter a "jerk" then having this legalized may infact pay for itself in one way or another...
But either way, legal, or not, the amount of paperwork not only to do the swap but also to prove to the local 5-0 that your car is legal...
Though your car may legal... you still have to prove it, and more often then not, it takes alot moore then a piece of paper...
However if perhaps you were to encounter a "jerk" then having this legalized may infact pay for itself in one way or another...
But either way, legal, or not, the amount of paperwork not only to do the swap but also to prove to the local 5-0 that your car is legal...
Though your car may legal... you still have to prove it, and more often then not, it takes alot moore then a piece of paper...
Here's the problem with all those what if, cop checks under hood things. According to the EPA ANY modification, CARB approved or otherwise, is illegal. That includes even changing your intake. It is also a federal mandate, that altering a vehicle from the approved configuration is unlawful. There is no such thing as off road use only. As I said, changing a car from the original configuration without EPA approval is illegal. The EPA has stated that they are not going to heavily enforce this "gray area", but if it is politically expedient, then they will do so. What this means is that any cop, IF he knew the statute, could cite you for a FEDERAL crime. FOR SWAPPING AN INTAKE. Yes, I know how nutty this all sounds, and that's why I'm doing the research. As for proving that the swap is legal, all it will take IS a piece of paper, in a sense anyway. What I'm working on is a way for individuals like Daunttless to cover his arse. See, if you and your buddies swap out a motor, get caught, and someone decides to make an example out of you, it's going to cost you around $2500. However, if you get caught, and Dauntless did your swap, or even sold you the engine, he can get slapped with up to $25,000 in fines. What I'm looking at is how a "dealer" (such as Daunt) can certify through the EPA that he/she has the ability and will to perform the swap so that the vehicle conforms to an EPA approved configuration. The first obstacle is to build an SR20DET powered 240sx that will meet or exceed FEDERAL emmisions requirements. then have it tested by the EPA. once it's certified, that configuration WILL pass ANY state req. as federal mandates overshadow the less restrictive state boards.
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MaineExport
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RYNO_s13 wrote:The first obstacle is to build an SR20DET powered 240sx that will meet or exceed FEDERAL emmisions requirements. then have it tested by the EPA. once it's certified, that configuration WILL pass ANY state req. as federal mandates overshadow the less restrictive state boards.
Well... I'm sure emissions are like any other mandate... in that the states can be more strict than the federal level... but NEVER less strict.
For example.... California has much more rigorous emissions standards than the fed. The states have the right to make laws beyond the nature of the federal level... but not less... to the best of my knowledge.
According to the EPA, the FTP to certify a particular chassis/drivetrain configuration is MUCH more strenuous than emissions testing at state level. As I said, this is a very young idea, so I'm sure that there are a number of obstacles before a legal SR swap will be a reality. But, I do have a starting point at least.
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BB Turbo
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Wow, this is very interesting, hey Ryno! Are you with SEMA? Or like http://www.enjoythedrive.com besause thats all they do is fight for people and make a stand against thses laws. You should join.
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EZcheese15
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Ryno...
Without looking any of this up right now, here's what I can recall off the top of my head. And by the way, I have studied this topic intensively, as part of my senior design project for school...so here's some things I think are facts. Research them and tell us what you find...
An engine swap is legal if the engine comes from the same model car with the same model engine, the same year or newer. Only if all connections and emissions compenents work and function correctly.
An SR swap could never be legal because it is not the same engine model as any U.S. 240sx. However, it *could* be legal in a Sentra, since they are both SR20's.
Also, there are two certifications a product must undergo to become street legal. There is the EPA FTP certification that you spoke of, and the CARB certification. Either can be done on one model, and the paperwork is good for all identical modifications to future cars. You can choose to do either test, the EPA or CARB. The EPA FTP test will make the product 49 state legal, while the CARB test will make it 50 state legal. Due to the fact both tests cost nearly the same, most companies opt for the CARB test to make it 50 state legal.
The FTP (Federal Test Procedure) is a test that is given to a car while on an emissions chassis dyno. It's very much like the IM240 test that many are familiar with, but it's approx. an hour long (vs. 240 seconds), and includes a cold start, a hot soak, and a hot start. Just like the IM240, the person conducting the test can fall +/- 2 seconds off the trace, but any more than that will cause a fail. Then the test must be repeated. Also, the car must sit atleast 12 hours on the dyno in a temperature controlled room to create a regulated cold start. The FTP also has some faster increases in speed than the IM240, and may hit boost on a turbo car.
Anyway, I know more about the FTP test if anyone is interested. I have actually driven the trace a good number of times (probably more than nearly anyone in the world who is not a certified tester). I've also driven the IM240 test a number of times as well.
As for modifying your car, if you have a CARB or EPA certification, it *is* legal. The problem is, hardly any companies pay for CARB certication, and even less pay for EPA certication, because the cost of the tests are very high ($10k sounds accurate).
One thing is the car must be tested stock, then modified with 4000 miles more than when it was stock (4000 miles of modification miles on it). To pass, it must create equal or less amount of pollutants than it did when stock. This is why few turbo kits are CARB legal, but there are some low boost supercharger kits for certain cars that are CARB legal. An example is the Downing/Atlanta Supercharger kit for the BMW M42 and M44 engines.
So Ryno...add this to what you are researching, and correct anything you see an argument against.
Without looking any of this up right now, here's what I can recall off the top of my head. And by the way, I have studied this topic intensively, as part of my senior design project for school...so here's some things I think are facts. Research them and tell us what you find...
An engine swap is legal if the engine comes from the same model car with the same model engine, the same year or newer. Only if all connections and emissions compenents work and function correctly.
An SR swap could never be legal because it is not the same engine model as any U.S. 240sx. However, it *could* be legal in a Sentra, since they are both SR20's.
Also, there are two certifications a product must undergo to become street legal. There is the EPA FTP certification that you spoke of, and the CARB certification. Either can be done on one model, and the paperwork is good for all identical modifications to future cars. You can choose to do either test, the EPA or CARB. The EPA FTP test will make the product 49 state legal, while the CARB test will make it 50 state legal. Due to the fact both tests cost nearly the same, most companies opt for the CARB test to make it 50 state legal.
The FTP (Federal Test Procedure) is a test that is given to a car while on an emissions chassis dyno. It's very much like the IM240 test that many are familiar with, but it's approx. an hour long (vs. 240 seconds), and includes a cold start, a hot soak, and a hot start. Just like the IM240, the person conducting the test can fall +/- 2 seconds off the trace, but any more than that will cause a fail. Then the test must be repeated. Also, the car must sit atleast 12 hours on the dyno in a temperature controlled room to create a regulated cold start. The FTP also has some faster increases in speed than the IM240, and may hit boost on a turbo car.
Anyway, I know more about the FTP test if anyone is interested. I have actually driven the trace a good number of times (probably more than nearly anyone in the world who is not a certified tester). I've also driven the IM240 test a number of times as well.
As for modifying your car, if you have a CARB or EPA certification, it *is* legal. The problem is, hardly any companies pay for CARB certication, and even less pay for EPA certication, because the cost of the tests are very high ($10k sounds accurate).
One thing is the car must be tested stock, then modified with 4000 miles more than when it was stock (4000 miles of modification miles on it). To pass, it must create equal or less amount of pollutants than it did when stock. This is why few turbo kits are CARB legal, but there are some low boost supercharger kits for certain cars that are CARB legal. An example is the Downing/Atlanta Supercharger kit for the BMW M42 and M44 engines.
So Ryno...add this to what you are researching, and correct anything you see an argument against.
Originally posted by EZcheese15 "]Ryno...
An engine swap is legal if the engine comes from the same model car with the same model engine, the same year or newer. Only if all connections and emissions compenents work and function correctly. True. The key here is that the car is not modified from its OC ("original configuration" ie. S13 chassis/KA24DE)
An SR swap could never be legal because it is not the same engine model as any U.S. 240sx. However, it *could* be legal in a Sentra, since they are both SR20's. Motorex has created a precedent with the skyline import. This area is going to need a GREAT deal of work. Having an ENTIRE car imported and legalized (lots of crying I'm sure) has opened the door.
Also, there are two certifications a product must undergo to become street legal. There is the EPA FTP certification that you spoke of, and the CARB certification. Either can be done on one model, and the paperwork is good for all identical modifications to future cars. You can choose to do either test, the EPA or CARB. The EPA FTP test will make the product 49 state legal, while the CARB test will make it 50 state legal. Due to the fact both tests cost nearly the same, most companies opt for the CARB test to make it 50 state legal. Once the configuration is given EPA approval, passing even CA emmissions is only a matter of passing sniffer. While they will still do a visual inspection, everything that they see under the hood is EPA legal. Believe me, if I go through the effort to pass the EPA test, you can be DAMN sure it'll pass smog.
As for modifying your car, if you have a CARB or EPA certification, it *is* legal. The problem is, hardly any companies pay for CARB certication, and even less pay for EPA certication, because the cost of the tests are very high ($10k sounds accurate). According to the EPA, modifying a vehicle from OC in order to de- certify it for use on public roads is still illegal. However the EPA is not actively enforcing this mandate unless it becomes pollitically expedient. In terms that you and I can relate to, NASCAR is illegal "technically". However, the only way that the EPA will enforce the above mandate is to replace the revenue that they recieve from NASCAR monsters such as GM and Fraud, I mean Ford.
So Ryno...add this to what you are researching, and correct anything you see an argument against. I appreciate all the suggestions and comments. Thanks. And if any of you guys have information or relevant questions, let me know, and I will pass them on to USEPA.
An engine swap is legal if the engine comes from the same model car with the same model engine, the same year or newer. Only if all connections and emissions compenents work and function correctly. True. The key here is that the car is not modified from its OC ("original configuration" ie. S13 chassis/KA24DE)
An SR swap could never be legal because it is not the same engine model as any U.S. 240sx. However, it *could* be legal in a Sentra, since they are both SR20's. Motorex has created a precedent with the skyline import. This area is going to need a GREAT deal of work. Having an ENTIRE car imported and legalized (lots of crying I'm sure) has opened the door.
Also, there are two certifications a product must undergo to become street legal. There is the EPA FTP certification that you spoke of, and the CARB certification. Either can be done on one model, and the paperwork is good for all identical modifications to future cars. You can choose to do either test, the EPA or CARB. The EPA FTP test will make the product 49 state legal, while the CARB test will make it 50 state legal. Due to the fact both tests cost nearly the same, most companies opt for the CARB test to make it 50 state legal. Once the configuration is given EPA approval, passing even CA emmissions is only a matter of passing sniffer. While they will still do a visual inspection, everything that they see under the hood is EPA legal. Believe me, if I go through the effort to pass the EPA test, you can be DAMN sure it'll pass smog.
As for modifying your car, if you have a CARB or EPA certification, it *is* legal. The problem is, hardly any companies pay for CARB certication, and even less pay for EPA certication, because the cost of the tests are very high ($10k sounds accurate). According to the EPA, modifying a vehicle from OC in order to de- certify it for use on public roads is still illegal. However the EPA is not actively enforcing this mandate unless it becomes pollitically expedient. In terms that you and I can relate to, NASCAR is illegal "technically". However, the only way that the EPA will enforce the above mandate is to replace the revenue that they recieve from NASCAR monsters such as GM and Fraud, I mean Ford.
So Ryno...add this to what you are researching, and correct anything you see an argument against. I appreciate all the suggestions and comments. Thanks. And if any of you guys have information or relevant questions, let me know, and I will pass them on to USEPA.
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lessthanjakejohn
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Quote »However, the only way that the EPA will enforce the above mandate is to replace the revenue that they recieve from NASCAR monsters such as GM and Fraud, I mean Ford.[/quote]
How can NASCAR be illegal though, The engines come from 1960's, I doubt there was much of a CARB or EPA back then. Also, the Chassis, even though "trans am" or whatever, are custom built. The cars weren't even built to go on the road in the first place, so how can they be illegal. Also, even if it was Illegal its not like they are driven on GOverment property(streets) in they first place...
Also, "No offroad" How can that be true. You mod your car on private property, you drive it on private property, What the hell are they going to do to stop you? Can you imagine them, if they took that law seriously, saying, "We are sorry we are going to take your SR20det because you put it in your 240sx and then started it up in your backyard."
I hope what I am saying by private property, Is not like saying "Well since I killed him in my house, You(gov) can't do anything about it..."
What agency does crash testing? I am sure they have a law that you can't modify they safety equipment of your car. That means no aero kits, no big wheels, no lowered(or raised) chassis, and no racing seats. Does that hold true?
How can NASCAR be illegal though, The engines come from 1960's, I doubt there was much of a CARB or EPA back then. Also, the Chassis, even though "trans am" or whatever, are custom built. The cars weren't even built to go on the road in the first place, so how can they be illegal. Also, even if it was Illegal its not like they are driven on GOverment property(streets) in they first place...
Also, "No offroad" How can that be true. You mod your car on private property, you drive it on private property, What the hell are they going to do to stop you? Can you imagine them, if they took that law seriously, saying, "We are sorry we are going to take your SR20det because you put it in your 240sx and then started it up in your backyard."
I hope what I am saying by private property, Is not like saying "Well since I killed him in my house, You(gov) can't do anything about it..."
What agency does crash testing? I am sure they have a law that you can't modify they safety equipment of your car. That means no aero kits, no big wheels, no lowered(or raised) chassis, and no racing seats. Does that hold true?
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EZcheese15
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The DOT does crash testing, and they do have a law that you can't modify the safety equipment in your car. Big wheels and lowering the suspension does not modify the safety equipment in the car (unless it's grotesquely excessive). However, putting a racing seat in your car does, and is technically illegal. Unless ofcourse the manufacturer has paperwork showing tests that the equipment they sell is as safe or safer than original, during street use.
