Date: Sat, 5 Mar 2011 15:28:22 -0500
Reply-To: Jim Akiba <syncrolist@BOSTIG.COM>
Sender: Vanagon Mailing List <vanagon@gerry.vanagon.com>
From: Jim Akiba <syncrolist@BOSTIG.COM>
Subject: Bostig, CARB EO,
the reasons why not WAS: [WetWesties] Washington state...changes
in vehicle licensing rules..
Content-Type: text/plain; charset=ISO-8859-1
On Wed, Mar 2, 2011 at 7:15 PM, Old Volks Home <oldvolkshome@gmail.com>wrote:
> As Don said, it takes money to get the exceptions - Kennedy was
> willing to pay, but Bostig won't.
>
Ah if it were only so simple. And indeed with the right amount of money we
could get the EO, although the amount would be in the millions of dollars.
Everyone likely just reeled in reading that figure, and now thinks that I'm
either blowing smoke, or have no idea what I'm talking about. But let me
explain why.
It's all too easy for people to speculate on why something happens as it
does. Their perspective warps the speculation, sometimes toward the right
answer, sometimes far far away from it. In the case of california's visual
inspections, and any of their extremely aggressive anti-pollution
legislation you have to remember the goals of the state. They are not those
of individuals, and not even those of a large number of individuals if they
are not also a large part of the state as a group. In trying to understand
the chain of events and their drivers, it's usually a good idea to look to
the same thing that those setting policy do. Previous experiences of
similar entities.
One of California's huge problems is/was/will be pollution control of
"mobile sources" which includes highway and off-highway vehicles. California
has come a long way, and continues to pass the most progressive emissions
control legislation in the world. They are also a massive market for auto
manufacturers. CA has been sued by both the EPA and the manufacturers at
various stages along the way. As contentious as each interested group's
goals might be on the outside, they must collude on the inside to actually
accomplish enough of their individual goals to keep moving forward while
protecting their individual interests as best as they can. The interest of
the industry is to sell vehicles, and spend as little as possible on R&D,
manufacturing etc in compliance in order to access that market. Those
setting compliance policy want to be as stringent as possible to actually
achieve lower pollution levels without triggering backlash from the public
or from those manufacturers, from which they also derive revenue in the form
of various flavors of taxes all along the entire chain of preproduction,
through to sale, ownership, etc. So they arrive at a strategy that can
serve both sets of goals. One that decreases pollution levels effectively,
maintains or increases revenue for both, and will not cause a backlash for
any party that is large or strong enough to cause problems. The problem most
of their legislation is addressing is fleet overturn, just as Germany and
Japan have both taken measures to enforce through legislation. CA has a
massive problem with fleet overturn, or really lack thereof. IIRC the
figures I saw several years ago during my research into what was going on
was something absurd like in 1990 17% of registered CA cars were 100k+, by
1995 it had soared to 40%. In any case, forcing fleet overturn through
legislation achieves the goals they are after. It's actually a very good
plan for meeting all of their goals, BUT we (the little niche interests) get
pinched in the middle. There is also plenty to complain about from the
libertarian POV, but again, to achieve the goals of groups in primary
consideration, and at the correct scale, it really isn't a horrible idea...
even though we (bostig and vanagonland) get screwed in the process.
Be certain it is *not* an issue of Kennedy paying, and Bostig not. Bostig
has invested $1.25 million in development in the last 5 years on something
pretty nuts from most conventional viewpoints. The value to us is in the
capabilities, knowledge, and processes developed and acquired, and the folks
we've returned value to in the form of product, support, and personal
capability. Kennedy spent nothing like this in money, time, or effort.
Kennedy did spend perhaps a couple thousand for the CS95 and shed testing
for the ej22 conversion they/he developed. But the difference is in timing
which some additional absurdity is revealed about the actual effects of the
policy at the small scale (where it matters least if at all). It is still
possible to easily and cheaply get an engine conversion swap an executive
order in CA... as long as it's old enough. So while we could for instance
get a carb EO on an OBDI pre-96 engine conversion, OBDII/ post 96 is
virtually impossible. In fact, when we sent our EO application to the CARB
in 2006, we reached exactly one step into the process before the CARB
deferred and said the EO would not be possible because they would not review
it. They deferred to the BAR, by which a conversion can be stickered on a
case by case basis by ref review. But we weren't the only ones. In fact, the
*only* engine conversion that is OBDII to obtain an EO in CA was announced
in late 09.
The joint project was between GM, SEMA(the largest auto
aftermarket industry association in the US, Bostig is a member), and... the
CARB. The E-rod engine package was born to address a bigger version of
our(vanagonland) complaints. The hot rodder market in CA is 500-1000 times
larger than vanagonland itself. They also (unlike even the import/street
market) have deeper pockets and a voting demographic. They complete more
projects, and build more specialty vehicles. CA realized two problems with
the (relatively) large hot rodder market, one was with titling, the other
with emissions control. The project addressed the issues for the largest
subset of the aftermarket with the most money. The end result with the E-rod
is an engine package that includes the engine(LS3 V8, various displacements,
complete, and includes exhaust ending at the cats) and engine management,
and they even throw in a pedal. The price: $8k-$11k, no mounting, no
carrier, no cooling, incomplete exhaust, etc etc etc... just the engine
ending with the cats, engine management, and you must be able to implement
it in it's full form within your project or not at all.
When you consider that we are able to produce and sell a *much* more
complete system, with much better support and documentation, for less
money... and on top of that at production levels less than 5% of what the
e-rod is doing, it's really not too shabby... but it should also reveal what
it *really* would take to accomplish CARB EO on an OBDII engine swap, as
again.. we look to a previous example. No surprisingly it's the only one to
date, and we see that it is simply not possible given our
conditions/constraints/scale. It is not for lack of trying, either in actual
dev, building, researching, hoop jumping, or cash outlay... at least not in
comparison to KEP and the ej22 EO. Apples to Oranges. If anyone can help us
figure out how to obtain enough growth in vanagonland to achieve even a 4x
increase in scale, I bet we could make enough noise to make it happen. But
as of right now, I don't believe this is possible as of course vanagonland
is shrinking. It would be one thing if cash outlay were the real problem,
but it should be clear that in the reality that I perceive (within which I
always leave plenty of room for me to be wrong and correct my POV) we cannot
justify another attempt at CARB EO in CA for the Bostig conversion, it is
neither realistic nor prudent.
Thanks for your attention,
Jim Akiba
PS (NVC) check out "drunk history" on youtube, hilarious
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