EPA’s Anti-Racecar Proposal and the RPM Act – Whale Watching
But We Have a Bureaucracy to Feed!
You are aware, no doubt, of an EPA proposal from earlier this year that clarifies that any vehicle originally certified and destined for road use may not have its emissions equipment modified, even if that vehicle is used exclusively for competition or off public roads. That proposal was hidden deep within a 600-plus-page heavy-duty vehicle manifesto, so it almost went by unnoticed.
The EPA said their interpretation of the law Congress approved was merely clarifying an existing rule, while the Specialty Equipment Market Association (SEMA) that represents many in the multi-billion-dollar aftermarket industry said the EPA was making new rules that clearly weren’t within Congress’ intent. People worried about engine performance parts and their SCCA/NASA/SCORE weekend racers. However, it goes beyond engines and exhausts because many sanctioning organizations require fuel cells and a fuel tank is part of the emissions certification, so even if your old Taco-turned-dirt-truck or Camaro-turned-racer had a completely stock engine and catalysts intact that somehow don’t overheat, you may still be turned away.
The whole thing had me thinking I should enter a LeMons car running Fourth Amendment sponsorship decals on privately owned race tracks.
By the EPA’s own charts it can’t be air quality that’s causing the hullabaloo. Of the six air pollutants they’ve historically tracked—CO, ground-level ozone, lead, NO2, SO2 and PM10 (particulates)—all are better than EPA’s healthy air standards, often by considerable margins, and most are trending better, none worse. EPA’s January 2011 GHG regulations showed power generation responsible for more emissions than transportation (motor vehicle, train, ship, air), and their 22-page “Plain English Guide to the Clean Air Act” shows transportation has made the greatest strides in pollution reduction. So does California’s Air Resources Board.
VW’s screw-up didn’t help but even those cars aren’t as “dirty” as an early HD diesel pickup and for perspective, the particulate matter that comes off a passing coal train (more than the locomotive pulling it emits) has a far greater public health impact. And anyone remember when Edmunds.com tested a 6.2L Raptor, one of the least efficient vehicles of its time, against a leaf-blower for emissions and the leaf blower was 300 times dirtier? Do the math for a couple of hours’ run time on each, per day, and it looks again like EPA is going for the low-hanging fruit, not big industry nor any potential political damage.
But EPA does have a bureaucracy and a financial-year 2016 budget request of $8.6 billion to feed. Just for giggles, that’s $27 per person in the U.S. or, if all they covered was automotive, more than $5,000 per new vehicle sold this year. EPA employs more than 15,000 people and contracts with thousands more. The numbers would be higher if a thousand or two hadn’t taken advantage of early retirement incentives in the last couple of years. What began in 1970 with 4,000 employees more than tripled in a decade and was 17,000-18,000 until a few years ago while the rest of the Federal bureaucracy employment dropped by 2 percent.
And EPA lets individual states take care of their own Clean Air Act compliance, though any state wishing to do so must file a plan with EPA about how they’ll do it, and state rules must be at least as strong as EPA standards. California’s clean air act preceded the EPA’s by two years and for better or worse many other states tend to follow the Golden State’s lead, but given population and area, its environmental agency seems even more inefficient than the Federal version.
So despite a much better environment than when the EPA was created and some states doing the job for them, the EPA needs a reason to justify their budget, and this time grassroots motorsports was the easy target.
The RPM (Recognizing the Protection of Motorsports) Act should have collected your signature on its way to DC, maintaining the potential livelihood of some of SEMA’s 6,300 member companies that support such endeavors. At this writing, the EPA appears to be bowing to Congressional pressure thanks to that act.
However, it’s election season, so your next act should be to vote—EPA administrators are nominated by the president and confirmed by the Senate.