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Comment 2 for Procedures for the Exemption of Add-On and Modified Part(s) for On Road Vehicles/Engines (ampts2020) - 45 Day.

First NameJohn
Last NameLambert
Email Addressjlambert@hypertech.com
AffiliationHYPERTECH
Subjectprocedures for exemption - aftermarket parts - categories
Comment
Hello,
  First, I want to say thank you for working so diligently to
revamp the E.O. process to better serve everyone involved with the
exemption process for aftermarket parts. This has been a long time
coming, and is a massive undertaking. Your hard work and
perseverance is appreciated.
  I have seen the latest version of the proposed procedures for
exemption outline and would like to recommend a couple of parts for
consideration to be added to the named categories.
  One is the electronic pedal adjusters. I believe these would fit
into Category 8 along with throttle bodies. I believe OBD testing
would be sufficient for these devices. When installed these devices
would not affect a drive trace emissions because the operator has
to adjust his foot position accordingly to follow the trace which
negates any change the pedal adjuster has made.
  The second I made note of is a recirculating blow-off-valve. I do
believe these products should be listed in Category V with other
turbocharger intake tract parts that also require no modifications
for proper installation. This would not include units that do not
recirculate which would require modifications to the vehicle to
install.
  I hope my recommendations are sensible and helpful. Good luck
with this process and please feel free to reach out to me if there
is anything I can do to help.

Thank you, John.

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Date and Time Comment Was Submitted 2020-06-16 14:36:25

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