RE: {Chrysler 300} California Air Resources Board (CARB) --- Danger, Dan

I was very surprised that you still have a Smog Check program! I would have thought your air pollution would be under control by now.

My background includes being the Queensland member for the Australian Council for Vehicle Emissions and Noise which was a sub group that made changes to the Australian Design Rules (ADRs are equal to your FMVSS) and for state in-service programs.

Brisbane has a similar topography to Los Angeles with ocean on one side and a line of hills on the other. In still weather, air pollution recirculates and accumulates for days rather than disperses. Back in the 90’s this was becoming a problem. We trialled a local Air Care program in south east Queensland to randomly check vehicle emissions at idle by the roadside and gave a report to the driver. If the emissions were poor we recommended (not mandated) the driver get their car fixed. This was surprisingly well received along with a comprehensive public education campaign. However, after a few years, Inspectors were complaining about not getting enough bad vehicles and wanted to go back to their “real job” of finding safety defects (and issuing defect notices that were mandatory). See attached for a copy of the cover of my report. The handsome guy on the left in the photo attached is me. Mandatory testing could not be justified and random testing also ceased.

Basically, new vehicles were getting so much cleaner and far more reliable under more stringent ADRs that pollution levels dropped significantly without the need for testing. We now have very clean air despite a huge increase in traffic, that is only spoiled when we do vegetation burn offs to reduce the risk of bush fires.

As a government we were obliged to only bring in regulations after doing a thorough cost benefit analysis (CBA) that showed the benefits outweighed the cost to the public. I suggest you ask your friends in CARB for a copy of their CBA that still justifies why you still have Smog Check. Maybe that is what they are updating in light of current air quality? If so, good. That is what they are supposed to do

My comments were directed towards the more recent unjustified fervour towards eliminating greenhouse gases. Some places want to mandate electric vehicles (California maybe?). How can you justify that in the mind of a greenie while still allowing old gas guzzlers (like 300s) free reign? Are you sure restrictions on old cars aren’t on the government’s agenda? Worth asking the question. I don’t think they would get away with that here. But... if you want to see the extremes of some of our politicians, check out this guy who got elected by the vocal few amongst us. https://www.youtube.com/watch?v=vqvIVwERTbg

Henry

From: James Douglas [mailto:jdd@xxxxxxxxxx]
Sent: Saturday, 5 August 2023 9:43 AM
To: Steve; rdr_inc
Cc: Henry Schleimer; Chrysler 300 List Server (chrysler-300-club-international@xxxxxxxxxxxxxxxx)
Subject: RE: {Chrysler 300} California Air Resources Board (CARB) --- Danger, Danger Will Robinson

Steve,

Interesting in that I have been corresponding with the staff doing the project and got a different take on it. They told me in writing that:

“We're CARB's on-road emission inventory modeling group. The purpose of the survey is to help us update information about vehicles older than 45 years old (MY 1978 and older as of today) in our on-road emissions inventory model, EMFAC. “

And

“We are exploring reincorporating vehicles older than 45 years old in a future release of EMFAC, but just want to make sure the number of miles driven per year is dialed in the best we can. The key question in the survey is the annual mileage driven by these vehicles. In addition, we are trying to assess whether evaporative emissions should be discounted in any way if fuel tanks are drained, or additives are used in the tanks when vehicles are not in use. That’s why there are questions regarding vehicle driven frequency, storage conditions and fuel tank.”

This description does not quite jive with your take on it.

It could be that want to use it to determine of they need to cut cars from the smog program or not. BUT THEY SHOULD BE CLEAR AS TO THE REASON UP FRONT.

The fact is that the Model year 1978 and older are almost all smog exempt as the cut off ids 1972 or 1973 and back if memory serves.

Therefore, your comment about removing classic cars from the smog check program is suspect as most already are exempt. I suspect that you are being sold a bill of goods because they are worried about skewing their response rates.

With respect Steve, something does not ring right in what you were told.

James

From: Steve <saforwardlook@xxxxxxxxx>
Sent: Friday, August 4, 2023 15:27
To: rdr_inc <rdr_inc@xxxxxxxxxx>
Cc: James Douglas <jdd@xxxxxxxxxx>; Henry Schleimer <henry.schleimer@xxxxxxxxxxxxxxx>; Chrysler 300 List Server (chrysler-300-club-international@xxxxxxxxxxxxxxxx) <chrysler-300-club-international@xxxxxxxxxxxxxxxx>
Subject: Re: {Chrysler 300} California Air Resources Board (CARB) --- Danger, Danger Will Robinson

I checked into this with CARB staff that I know personally and the purpose is to determine whether to exempt all classic cars from the biennial smog check inspection program - currently the cut off is 1975 and earlier cars are exempt. Carb would like MORE of them to be exempt and determine whether a higher exempt model year would hurt emissions such that any measurable increase in smog emissions or CO2 emissions would result. Smog check here in California is largely based on a check of the OBDII system to see if any fault codes are present - if not the car sails through with no dynamometer based exhaust measurement test.

The reality is that most Smog Check stations don't even keep their emission measurement systems or dynamometers operating much at all anymore and only turn them on when they get a car without OBD II.from model year 2000 and later. (OBD II systems were first used in most 1996 and later vehicles and since such vehicles were early efforts to implement OBD II, cars built before 2000 are not relied on only for an OBD II check and must also pass a dynamometer based emission check as well as the OBD II system results in the first few years).

Their current thinking is that if older collector cars are not driven much anymore and even when driven are not very extensive trips in terms of mileage accumulated, then it is appropriate to exempt them from the program and eliminate the hassle for both smog shops and owners of collector cars.

They are well aware of the foibles of the survey methodology but were unable to come up with a better approach since such data are just not available anywhere.

The reality is that there are many car collectors and enthusiasts even at CARB and emissions continue to come down in the state relative to gasoline vehicles in terms of smog and CO2 emissions and they believe from the collector car fleet as they age and are likely driven less and less as they age and not significant at present and given that the increasing use of renewable energy and electric vehicles will only improve matters in terms of smog emissions and the CO2 emissions that contribute to climate changes.

In determining a cut off age of about 1975 to eliminate such cars from the Smog Check program, the reasoning then was that the improving catalyst and electronic fuel control systems on new vehicles would lower emissions so much better, in fact down to near zero smog emissions after the first minute of vehicle operation that such dramatic improvements in vehicles were forecast and actually were achieved such that eliminating the 1975 and earlier vehicles was warranted - and it came to pass. So the precedent was set and the intention is the same here....................

My recommendation would be to answer the survey honestly so that they will have the data they need to justify eliminating most collector cars from the Smog Check program.

The Specialty Equipment Market Association (SEMA) has a tremendous interest in selling their modification parts and also have intense clout with California Regulators in the California Legislature whose reelection campaigns they support and they would be the first to complain of any attempt to get collector cars off the road or convert to electric so while some may conjecture that this is to get collector vehicles off the road, there are still large numbers of them still around and the pushback would be impossible to control.

CARB's only attempt to get gasoline vehicles off the road would be to put a cutoff date into place in which all NEW vehicles would need to operate on electric or hydrogen based fuel supplies. Anything else would bring down massive pushback from all owners of gasoline cars and SEMA would lobby against such a measure and would surely win.

Since all vehicles starting with the 2000 model year OBD II systems are exempt from dynamometer emission tests there is a real possibility the only cars with OBD II built in or after the 2000 model year would be required to be Smog Checked. That would mean that vehicles that are 23 years of age or older could be exempt.

So if they can accumulate enough data to support this effort, they could go ahead and implement it just as they did circa the 1975 timeframe with possibly a 2000 model year cutoff date this next go around.

Steve

On Fri, Aug 4, 2023 at 9:26 AM rdr_inc <rdr_inc@xxxxxxxxxx> wrote:

Unfortunately, garbage often turns into law / legislation, etc.

Rick Dutkiewicz Haynes

Sent from my Galaxy

-------- Original message --------
From: 'James Douglas' via Chrysler 300 Club International <chrysler-300-club-international@xxxxxxxxxxxxxxxx>
Date: 2023-08-04 12:02 p.m. (GMT-05:00)
To: Henry Schleimer <henry.schleimer@xxxxxxxxxxxxxxx>
Cc: "Chrysler 300 List Server (chrysler-300-club-international@xxxxxxxxxxxxxxxx)" <chrysler-300-club-international@xxxxxxxxxxxxxxxx>
Subject: RE: {Chrysler 300} California Air Resources Board (CARB) --- Danger, Danger Will Robinson

Henry,
The survey is anonymous in theory. My problem is the GIGO nature of it. Take for example the odometer. It is meaningless in the classic car world. They roll over as they only have 5 digits. They get reset when rebuilt and on and on.
What will happen is that the survey numbers will get crunched and they will come to conclusions based on it. Those conclusions will use miles driven and odometer numbers but that data has no relation to reality. Yet, then will make decision on it.
The folks doing this survey are clueless as to the population they are surveying. Garbage in and Garbage out.
James

From: Henry Schleimer <henry.schleimer@xxxxxxxxxxxxxxx>
Sent: Friday, August 4, 2023 08:54
To: James Douglas <jdd@xxxxxxxxxx>
Subject: RE: {Chrysler 300} California Air Resources Board (CARB) --- Danger, Danger Will Robinson

Hi James
Seems like your greenies are desperate to account for every last drop of evil CO2 producing oil. Our lefty government in Australia is heading that way too. Net zero to save the world from oblivion! Hopefully the rest of us will wake up and kick them out at the next election.
I do however question why you refer to “concourse car that is never driven”. Why would you register such a car? If it isn’t registered, it couldn’t get flagged for the survey.
Is there a penalty for not answering, or even falsely answering, the survey? I would have thought that sort of information would be private and not the business of the state. Land of the free and all that. I agree you should complain to your representative about your rights (while you still have some). You could also just throw the survey in the bin, or reply that the car has been converted to battery power... that will confuse them.
Sorry for my rant.
Cheers
Henry
From: 'James Douglas' via Chrysler 300 Club International [mailto:chrysler-300-club-international@xxxxxxxxxxxxxxxx]
Sent: Saturday, 5 August 2023 12:50 AM
To: Chrysler 300 List Server (chrysler-300-club-international@xxxxxxxxxxxxxxxx)
Subject: {Chrysler 300} California Air Resources Board (CARB) --- Danger, Danger Will Robinson

To all Classic Car Hobbyists, particularly in California. I have had reports that the CARB has sent surveys to randomly selected people that were pulled from the Department of Motor Vehicles Data base. People who have classic cars.
The survey reads to the trained eye as a foundational study to regulate classic cars and their use.
The problem is that the survey methodology is so flawed as to make the results worthless in the real world. It can however be used by unscrupulous policy makers to back up ideas that they want to implement.
The questions, abbreviated are as follows:
In which county is your MY 1978 or older vehicle primarily operated?
What is the current odometer reading (total mileage since the car was new) on your MY 1978 or older vehicle? Please specify, and use your best estimate if you are not sure:
Approximately how many miles does your MY 1978 or older vehicle get driven in a year? Please specify:
How often is your MY 1978 or older vehicle driven?
How is your MY 1978 or older vehicle stored when not in use?
When you store your MY 1978 or older vehicle for an extended period of time when it is not being used, what do you typically do with the fuel tank?
Each question has a list of answers to choose from.
The problem with this so-called survey is the methodology which is so bad is to be an insult to professional Transportation Survey Researchers. The survey is a random sample from the DMV database. Their assumption is that the survey respondents are a representative sample of all the classic car owners in the DMV database. In techno speak the small “n” represents the large “N”. In this case it does not.
As classic car hobbyists all know, there are people who have collections of 5 cars, 10 cars, 100 cars. If someone with a collection responds to the survey on one car in a collection it is possible that the particular car, which was pulled at random for the survey, is this hobbyist’s daily driver classic car or it could be a concourse car that is never driven.
Even if they pulled enough data to have a legitimate 95% - 90% confidence level, the lack of homogeneity of the hobby means that their conclusions will be junk.
I suggest that every classic car hobbyist in California contact their elected representatives and ask why with a budget deficit looming in California that the CARB is being allowed to spend taxpayer money on junk science. Ask they investigate shutting this kind of junk science down.
As an aside, in the 1990’s there was a push by CARB and some legislators to place restrictions on classic cars. They made, what at the time, were clearly false representations as to data they had backing up their wish list. When confronted with their nonexistent data they backed down. We should not allow them to create bad science data to do the same things now. Act!
James Douglas
San Francisco.

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