Connecticut: Registration, Inspection & Emissions

[ZOERA-SC7XX]

Do they still make you trailer the Cobra (CT.) or can you use a dealer plate?

[Joy]

Composite vehicles now exempt from emissions (7/1/2007) http://www.ctemissions.com/exempt.html

[Cashburn]

Originally Posted by ZOERA-SC7XX

Do they still make you trailer the Cobra (CT.) or can you use a dealer plate?

I would trailer to be safe still. They wanted to know where my trailer was.

[convincor]

Originally Posted by ZOERA-SC7XX

Do they still make you trailer the Cobra (CT.) or can you use a dealer plate?

Yes, composites must be trailered, doesn't matter who you are.

[Don]

The last known update to R-157 Composite Motor Vehicles dated 12/04 states the requirement to trailer the vehicle:

http://www.ct.gov/dmv/LIB/dmv/20/29/R-157.pdf

While a number of years ago, I was also asked where I had parked the trailer

[Don]

Summary web site for the individual states DMV:

http://www.dynacornclassicbodies.com/stateseal.html

[SJK2]

What is CT. up to now read post from Factory 5 site:

http://www.ffcobra.com/forums/showthread.php?t=191391

http://www.ct.gov/dmv/cwp/view.asp?a...DLTEST=|30150|


?????????????????

[philminotti]

So I'm building a shiny aluminum boat anchor? Is that what this is saying???

I sincerely thought we were done with this crap.

[Don]

Steve:

Until you mentioned in your reply, I had not seen any reference to the new regulations effective as of August 1.

I will be in contact with Dave at the 4C's ( CT Council of Car Clubs ) , he actively participated in the initial emissions exemption obtained in 2007 for Composites. The 4C's have a paid lobbyist that monitors DMV laws and regulations. Also, their recent newsletter did not mention any changes.

Similar to 2007, there was a DMV Bill passed in 2008 which encompasses all the updates etc.

I did not research the active Composite registrations at 2007 year end, but with approx 300 to 330 at 2006 year end, out of over 3,000,000 + passenger car registrations, good question as what prompted the new regulations.



Don

[Don]

Update:

** Neither the 4C's ( Dave ) or their legislative monitor are aware of any legislative action. It appears, to be verified, the emission hardware requirement was an Administrative action step and the 4C's along with the legislative monitor will be contacting the DMV to obtain additional information etc., etc., Their DMV contacts are not available this week. Goal will be to have the new regulation rescinded.

** Jay from Vintage Motorsports will be in contact with the Lt that heads up the DMV Inspection Unit

** Peter and Bob at ERA have been advised of the new requirements.

With the 4C's & Jay making inquiries, it has been suggested there is no other communication with the initial sponsor of the emissions exemption , Rep Janowski , or the General Assembly Transportation Committee

Steve......could you update the Factory Five forum with the above....thanks

[Don]

I wanted to advise everyone regarding the initial inquiry even though additional reviews are still underway. The CT DMV indicates that Federal EPA regulations state the emission hardware needs to be in place even though the vehicle is exempted from emission testing. In essence, the provision in the CT General Assembly DMV Bill passed in 2007 only exempted the testing, not the installation of the required hardware, which is stated as mandatory by the Fed EPA.

Does anyone have any factual info on the Federal EPA regulations for the above and/or are aware of any other states that exempt emission testing without requiring the installation of the emission systems/hardware ?

I contacted Dan Jalbert in the DMV Emissions Division and asked the following:

I just became aware of the new Composite Emission requirements, excerpt
below. Would appreciate being advised on the background and intent
behind the new regulations, since it appears the Composite Emission
Exemption passed by the General Assembly in 2007 is still
valid.

Dan's reply


From: "Jalbert, Dan" <Dan.Jalbert@ct.gov>
Date: August 7, 2008 1:04:10 PM EDT
Subject: RE: Composite Emissions Requirements: August 1

Hi Don

I Tried to contact our Chief Engineer Harry Gough regarding your
questions but he is out of the office, I can tell you EPA sets
guidelines for states to follow with regards to exempting vehicles
from emissions testing,and states have to follow up with
certain requirements for exempting those vehicles from emissions
testing.
As you are aware composite vehicles are still exempt from emissions
testing,just the inspection requirements have been updated.

I hope this will help.

Sincerely

Dan Jalbert
DMV Emissions Division

[Cashburn]

Based on the wording (and the fact that it does not state functioning and only that the equipment must be present) you could argue that having this in the car is meeting the requirements for pre-1988 engines:

[ZOERA-SC7XX]

Install either the 'dummy' smog pump & hardware, or just use a pre '66 small block or big block. We still are emmissions-exempt, so all is not lost. They could have recinded the exemption entirely!
PS: I just went through DMV inspection last month with my ERA and the car passed without incident, although the lead inspector spent about an hour with both the car and the paperwork. He did tell me more than once that the car was too loud. My engine and trans were from a '66 Galaxie and I had both the title and a bill of sale. There was NO indication that anything was about to change. Just be sure to have paperwork for an old engine. He did NOT check the engine serial number or casting number, just the paperwork.

[Don]

The new August 1 regulations state:

Documented proof of engine year must be provided by the applicant. This information will be verified for accuracy and the presence of all required components will be verified during the inspection.

However, " Documented proof " is not defined and needs to be clarified as to the proof the DMV will accept for the August 1 regulations. The Title and Bill of Sale as stated by ZOERA would be a basic requirement, but will a junk yard still have the Title ?

Jay from Vintage Motorsports mentioned the possible challenges when buying a pre-owned or new out of state Cobra and providing the " documented proof " , when the seller does not possess the required paperwork etc

[Don]

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

[ZOERA-SC7XX]

I won't say it's good news, but add the cost of an old title to reasonably match the engine used and you should be okay. This will put a demand for CT. Ford titles from 1961-1970. Titles don't include engine serial numbers, so I think if you're close, you're gonna be okay.

If you're gonna use a new aluminum block, put it in after you register and inspect it.

[Don]

Since August 1 when the new Composite Emissions regulations were implemented, has anyone had a Composite Inspection @ Wethersfield ?

If so, how was the emissions hardware portion handled and what did the DMV accept as " Documented Proof " on the year of the engine block ?

[Don]

Just a reminder if anyone desires to support the CT Council of Car Clubs ( 4C's ) with an Individual Membership. The 4C's actively supported and participated in the successful group effort in 2007 exempting CT Composites from emission testing. The link for accessing the 4C's newsletter, The Voice. is not active at this time


From the Nov/Dec newsletter Editor:

" At this point I believe that the best thing to do is to solicit professional help to successfully get legislation enacted. Retaining the strategic and lobbying services of Carroll Hughes, our current Legislative monitor, to make this happen may be our best success path "

An abbreviated version, 4C's newsletter has 7 pages with detail explanation, of the current issues in PA 08-150, Senate Bill 298:

*** Property Tax Assessment: Unintended consequence that the maximum $500 assessment ( all antique , rare and special interest motor vehicles 20 years or older regardless of whether they have early American plates ) decision was transfered to the individual municipalities rather than the DMV. Middletown assessor has sent a letter containing a questionnaire to all auto hobbyists in that town. Questions include: " whether it is altered from original, and if so, how was it altered, whether the vehicle was restored and to what extent and to identify the historic interest of the vehicle " With the DMV, issuing Early American Plates for antique, rare or special interest for vehicles 20 years or older was the determining factor

*** Extending to Composite Vehicles Section 14-16a.(b): The model year designation for the purpose of registration of a modified antique motor vehicle shall be the model year that the body of such vehicle most closely resembles " We would then have a 1965 or 1966 Composite rather than the model year being the first year registered in CT. Not sure, but I think the Model name, at this time, would still be Composite.

Two 4Cs Board Of Directors members and Carroll Hughes have had discussions with the DMV and no other action is required at this time.

" Over thirty five years ago the Connecticut Council of Car Clubs (4Cs) was established. Since 1973, the 4Cs hs effectively monitored legislative proposals, informed member clubs, and acted in the best interest of antique, classic and special interest car hobbyists. This year brings new challenges and opportunities."

" The 4Cs continually monitors committee assignments, proposed bills and the legislative agenda. We will meet with legislators, governmental agencies and speak at public hearings on behalf of hobbyists ".


http://www.ctccc.net/index.php

Membership Form

http://www.ctccc.net/files/membershipapp.pdf

[Cashburn]

Anymore info on...

Originally Posted by Don

*** Extending to Composite Vehicles Section 14-16a.(b): The model year designation for the purpose of registration of a modified antique motor vehicle shall be the model year that the body of such vehicle most closely resembles " We would then have a 1965 or 1966 Composite rather than the model year being the first year registered in CT. Not sure, but I think the Model name, at this time, would still be Composite.

I mentioned to the DMV a few months ago how that would help the hobby AND the DMV on identifying/tracking these vehicles.

We have been through inspection as early as last Thursday and it is a breeze.

[Don]

From the newsletter:

" Our ( 4Cs ) goal is to introduce legislation in the 2009 session that gets the model year designation for the purpose of registration of a Composite motor vehicle to be the model year that the body of such motor vehicle most closely resembles. Initial discussions with DMV appear that this is a feasible success path. It is noted that the current state statues do not define a Composite or replica motor vehicle. Further discussions will be necessary to work out language that DMV finds acceptable prior to introducing legislation in 2009. The 4C's is in the process of having those discussions with DMV."

........a reason to support the 4Cs with Individual Membership