The EPA/CARB do not have unlimited resources, so they have to create standards that do the greatest good while still being manageable. As soon as they start looking at things on a case-by-case basis as you suggest, the resources they require to do their job will skyrocket. Perhaps you should write your congressmen and ask them to bump up the funding for EPA and CARB so that they can do independent emissions testing and studies for every configuration that someone thinks will run clean and meet their emissions goals.
CARB does do case by case evaluation. Each instance costs the manufacturer a lot of money. And each instance is based on model and year only. So if you have a 1/2 ton pickup truck with a 6L V8 you have to pay for the CARB approval. If you have a 1/2 ton SUV with a 6L V8 that is a different model and year and you have to pay for a different CARB approval, regardless if the engine and transmission are EXACTLY the same.
I have had talks with people in the industry. I got to talk to an engineer at a company that makes Natural Gas and Propane retrofit kits in Southern California. They sell pretty much ALL of their products in South America. He told me it would cost them $50,000 per model/year combination to get CARB certification.
When the head of CARB was asked why it cost so much and took a long time the answer was "We have to ensure it won't violate the vehicle manufacturers warranty".:Wow1:
Think about it this way. If the emissions testing was based on real world performance everything would be simpler and more effective. Instead of making test facilities go through lots of training and buy updates to the books(which contradict the real world) establish a real world performance test. If you vehicle is supposed to produce between less than X emissions and it does you pass, no equipment requirements. Go a bit further, if you vehicle produces less than 1/2 X emissions you get to pay less in registration or get to drive in the carpool lane alone.
Performance based testing, less complicated more effective than compliance inspections and testing. With the incentive to produce less you would also see a big boom in the aftermarket industry to make kits and parts to produce less. AND it would make it legal for people to swap in better engines and transmissions to get better mileage, performance, and lower emissions.
I would love to have a mid sized SUV with a diesel and a 6-speed manual like the Jeeps this thread is about. I've looked, there are no diesel engines that are legal to put in mid sized SUVs in California, even though it would result in better mileage and with Bio Diesel lower emissions.
I had to smog my 2001 F350 this year. The sticker on the engine says it needs a Catalytic Converter. It did not have one. I spent a lot of time and money trying to get answers to what it needed(CARB was USELESS). I finally got one, put it on and went to the check station. Turns out even though the sticker on the engine(mandated by the state of California) says the truck needs a Cat, the CARB official emission book says the truck DOES NOT. How is that making ANYTHING better?
The EPA/CARB do not have unlimited resources, so they have to create standards that do the greatest good while still being manageable. As soon as they start looking at things on a case-by-case basis as you suggest, the resources they require to do their job will skyrocket. Perhaps you should write your congressmen and ask them to bump up the funding for EPA and CARB so that they can do independent emissions testing and studies for every configuration that someone thinks will run clean and meet their emissions goals.
Its no different than what I deal with at work. I manage a computer network of a couple thousand PC's. There is no way possible to test every piece-of-crap software package that users think they have to have installed on their computers, so we have a published list of approved software that has been thoroughly tested and we know works well without causing damage.
Think of it this way. A new policy. Let them install anything they want. If they do this and the computer acts up you wipe the drive and install the standardized image for their system you have. If they let only you install SW you will support that configuration.
Performance based policy. Instead of getting deep into every single thing every one does, make them pay for their decisions and start them over from scratch if their performance(SW choices) create failures.
This is what I did when I administered a high volume UNIX and Windows production environment.
