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Dear Board Members, I believe the entire waiver and Executive Order
(EO) process should be exempt for any products fitted to 1996+
OBD-II equipped vehicles. I think the EO process is redundant to
already established federal and state laws regulating emissions and
emissions oversight. The purpose of these OBD-II systems is to
monitor engine and evaporative emissions and flag excessive
emissions with fault codes, check engine lights, and even reduced
engine performance. The inspection station has the authority to
flag and deny emissions certification for any vehicle exceeding
emissions. Aftermarket parts installed on OBD-II vehicles already
go through this mandated self-inspection monitoring system.
Therefore the EO process is redundant red tape and bureaucracy that
does nothing that is already in place on every new vehicle sold in
California since 1996. However, in order for this OBD-II system to
function the software code of the vehicle should not be altered or
tampered with as to render the emissions oversight inoperable
(other code changes should be permissible). Aftermarket software
products that are proven to not alter this oversight code should be
allowed and legal with a EO or waiver. Applying this waiver/EO
process to "bolt-on" aftermarket parts that are already subject to
constant and persistent OBD-II monitoring should no longer be a
requirement. Thank you.