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California Assembly Bill 2683
As some of you may know, AB 2683, if passed, will terminate the current 30-year rolling emission test exemption and freeze it at the current 1975 model year. If you live in CA please forward the text of this letter to your state senator. The bill was passed by the Assembly and is now in the Senate assigned to The Transportation Committee.
You can copy and paste the text of my e-mail as follows or e-mail me, and I will forward the e-mail to you so you can forward it to your state senator and any other interested party. The draft April 2004 report to the IMRC also lays the groundwork to further roll back emission testing to cars currently exempt, so AB 2683 is not the end by any means! Ultimately, this legislation, if passed, will affect you directly. Help yourself and your fellow vintage car enthusiasts by joining the fight against AB 2683. To: Members of the Senate Transportation Committee References (first three at www.assembly.ca.gov ; remainder at www.smogcheck.ca.gov ) : 1. AB 2683 Assembly Bill - Bill Analysis (As amended April 12, 2004) 2. AB 2683 Assembly Bill - Bill Analysis (As amended April 21, 2005) 3. AB 2683 Assembly Bill - Bill Analysis (As amended May 20, 2004) 4. California Inspection Maintenance Review Committee Report, June 19, 2000 5. Evaluation of the California Enhanced Vehicle Inspection and Maintenance (Smog Check) Program, Draft Report to the IMRC, April 2004, Submitted by Air Resources Board and Department of Consumer Affairs/Bureau of Automotive Repair 6. Average Emission Concentration Values for Passing Vehicles - ASM 7. ASM Table - Phase 4.3 Acceleration Simulation Mode Standards and Gross Polluter Standards References 1 and 3 state in part: "...that 1976 model-year cars, on average, emit 155 times more hydrocarbons per mile than new vehicles..." This statement is ludicrous and totally unsubstantiated. Average passing hydrocarbon emissions for 1975-1980 model passenger cars are (Ref. 6) 47/37 PPM on the 5015/2525 ASM tests versus 4/4 for brand new cars, which have near zero emissions as built and no degradation from wear and tear. As late as the 1995 model year, comparable average passing HC emissions are 21/13 (Ref. 6). Model-year 1975 marked the near universal adoption of catalytic converters and dramatic reductions in emissions from prior emission controlled vehicles; 1975 certification standards reduced HC and CO emissions by approximately 90 percent relative to uncontrolled engines (prior to the 1966 model-year in California) with a nearly 50 percent reduction in NOx. Current new car certification tests show HC and CO emissions are reduced by approximately 99 percent relative to non-emission controlled engines. This is due to dramatic improvements in engine design and emission control technology that have occurred in the past 30 years. References 1 and 2 also state: "By 2010, pre-1982 cars (those that would be exempt from smog check at that time under current law) will account for 22% of the hydrocarbons and 11% of the NOx emissions representing only 2.6% of the vehicle population and 1.3% of the vehicle miles traveled." This statement is totally unsubstantiated and refuted by the data contained in Ref. 5, the April 2004 draft report to the IMRC. Table 4.1, page 30 lists estimated reductions in emissions proposed by the provisions of AB 2683 at 2.7 tons per day (tpd) for HC and 3.0 tpd for NOx. Total emission production by gasoline power vehicles is estimated in 2010 at 670 tpd HC and 650 tpd NOx (page 3, same reference). Placed in context, the estimated reduction by implementing AB 2683 is on the order of one-half of one-percent of the gasoline powered fleet, and even less as a percent of emissions from all vehicles! Even if the estimated emissions contribution from '66 to '73 models is added from Table 4.2 , the sum is less than two percent. Emission estimates for models built prior to the implementation of California tailpipe standards are not listed, and any estimate would be highly speculative at best due to lack of data. The statement from references 1 and 2 has no statistically valid basis in fact! Meanwhile, in the South Coast Air Basin alone, which accounts for about half of state emissions, off-road vehicle emissions are quoted as 135 tpd HC and 298 tpd NOx (Ref. 4, Table 8, page I-36) for the year 2000! This class of vehicles and other sources such as aircraft, watercraft, and even lawn and garden equipment collectively emit multiple orders of magnitude more emissions than collector cars. SB 42 (Kopp) that became law in 1998 won collector car enthusiasts a long-fought-for 30 year rolling exemption from the burden of emission testing and available data shows the provisions of AB 2683 yield insignificant reductions in emissions while placing an onerous burden on those affected by this legislation. Certain interests in the state appear to be using collector car enthusiasts as a whipping post for reasons unknown to me and are manipulating data or making outright false claims about the contribution to aggregate emissions by vintage car owners. Keep your promise to your constituents. Defeat AB 2683. Evaluate available data in an unbiased context. Demand that the proponents justify their specious claims rather than manipulating data by using different baselines for comparison and other forms of obfuscation to justify their own agendas and think about the spirit of California Vehicle Code Article 8.3 Section 5050: "The Legislature finds and declares that constructive leisure pursuits by California citizens is most important. This article is intended to encourage responsible participation in the hobby of collecting, preserving, restoring, and maintaining motor vehicles of historic and special interest, which hobby contributes to the enjoyment of the citizen and the preservation of California's automotive memorabilia." Very truly yours, G. R. Williams, MSME, University of Wisconsin Engine Research Center, 1971 |
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Update: The California Senate Transportation Committee hearing on AB 2683 is now scheduled for next Tuesday, June 29 in Sacramento.
Duke |
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