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Comment 2 for Open Comment for the September 23, 2021 Board Meeting (sept232021opencomm) - Non-Reg.

First NameJoseph
Last NameBuccino
Email Addressjoe.buccino.53@gmail.com
Affiliation
SubjectCARB D-707 Exemption and Smog test failures due to "Modified Software"
Comment
I am the owner of  a 2008 Corvette which is equipped with an A&A
Supercharger that was installed in compliance with the requirements
established by the CARB Executive Order D-707. As a key component
of this installation the factory ECU software was required to be
modified so that the engine's fuel management and pollution control
systems continue to be effective. A&A Corvette Performance Ltd is a
small business enterprise located in Oxnard, CA. They have
manufactured and installed over 1000 of these CARB compliant units
without incident related to a failed Smog test. However, newly
adopted test procedures in effect as of July 19, 2021 have caused
previously approved vehicle tests to fail due to "modified
software". These new test procedures check the factory installed
ECU program against a checksum of the vehicle's ECU. A mismatch
indicates a failure. I understand the reasoning behind this
approach and its effectiveness in determining modified tuning
parameters on the vehicle being tested.
However, a vehicle such as mine, having the installation done in
accordance with the D-707 exemption, will by its certification
parameters have a different checksum recorded on its ECU. Even
thought it has an otherwise compliant installation it is this
mismatch of the checksum against the factory specs that is causing
a failure.  I suggest that the CARB testing stations have within
their database a modified ECU checksum that matches those ECU's for
the equipment installed under the D-707 exemption requirements. The
current status for vehicles such as mine is that I cannot sell or
transfer my vehicle to another owner because of its inability to
pass the required smog test. Also, California based A&A Corvette,
despite going through the compliance process in developing their
componentry, is effectively being shut down due to this recent
testing procedure. I urge the California Air Resource Board to act
expeditiously in correcting the test process so that these
otherwise compliant vehicles continue to be properly vetted and
registered, and that a company like A&A can continue to do business
within the State of California.
Sincerely,
Joseph Buccino

Attachment
Original File Name
Date and Time Comment Was Submitted 2021-09-23 10:28:55

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