FYI......reply regarding the August 1 Composite regulations received from Harry Gough, CT DMV Principal Engineer: The first item is the question/statement and then Harry's response
* The Federal EPA mandate for installation of the emission hardware did not exist when the CT General Assembly passed the Composite Emission Exemption in 2007.
It is this EPA hardware mandate which requires with no options or alternatives CT to issue the new Composite emission regulations. The EPA requirement has been in effect at least since 1994. If you care to review their information it is available at
http://www.epa.gov/otaq/imports/kitcar.htm
* CT is not allowed by the EPA to have an emission hardware exemption such as the SB-100 program in CA?
The CT Department of Environmental Protection (DEP) sets the emissions criteria with the approval of the EPA. The DMV implements what DEP gets approved. Initially it was intended that composites simply be exempt, however, the EPA took exception with that plan and the current alternative which you are questioning was approved in lieu of a blanket exemption.
* A grandfather clause for those hobbyist and businesses ( with customer paid turn key orders ) that had already purchased the replica and/or engine was either not considered or not allowed.
I will forward your request for a grandfather clause for hobbyists to the appropriate personnel for consideration, but I cannot promise what the result will be. As far as businesses are concerned, the EPA source listed above states in part: "an individual or firm that assembles kits for hire or resale, that produces assembled kit cars for resale or that produces complete kit car packages for resale will be considered to be a manufacturer of new motor vehicles under the Clean Air Act. Such manufacturers and their vehicles are subject to all applicable regulations under the Act including civil penalties of up to $25,000 per vehicle for each new motor vehicle distributed in commerce, sold, offered for sale, or introduced, or delivered for introduction, into commerce, unless such vehicle is covered by a certificate of conformity issued by EPA."
* Date the new emission regulations were added to the CT DMV web site and any public announcement and press release intended for the CT hobbyist and businesses.
To the best of my knowledge the newly published requirements were put up on the Internet on July 28, 2008. I am not aware of any press release, however, you may want to check with the DMV Public Information Office for verification.
* With the very limited availability of pre 1966 engine blocks, there are no provisions for a newly manufactured block that is a 100% replica of the pre-1966 engine block.
Quoting from the EPA link listed above: "The components of the drivetrain (engine, transmission, differential) must be exclusively or substantially used and/or rebuilt. Regardless of the combination of new and used components, the engine must be used or used and rebuilt. The engine block and cylinder head(s) must be used, other components of the engine may be new. "Used" means the component has been in a vehicle that has been titled to an ultimate purchaser. A rebuilt component is defined as a used component which has been refurbished with new or other used parts."
* Can " Documented Proof " as mentioned in the new emission regulation be defined as to exactly what is the minimum required.
The requirement for "Documented proof" is listed in the DMV Composite Vehicles informational web page as "Bring the Certificate of Titles of all vehicles used for major component parts or one Title, plus receipts, for the parts of the other vehicles used. If the parts are from used vehicles, make sure the receipts specify the vehicle identification number (VIN). No Title is needed for non-major component parts (examples of major parts are: engine, cowls, transmission, frame, doors, trunk lid, front and rear fenders and quarter panels)." This requirement was not changed as part of the update in question and is available at http://www.ct.gov/dmv/cwp/view.asp?a=804&Q=244898&dmvPNavCtr=|#30236.
I hope that the information provided above addresses all of your questions.
Harry Gough, PE
Principal Engineer
State of CT DMV
203-271-5413