FSAE and EPA Regulation

[Will M]

Update: This thread has gone wildly off topic. Proceed at your own discretion.

There have been several articles* in the past week about a clarification from the EPA regarding modifying motor vehicles for off road use.
My understanding is that starting in 2018 a tampering with or defeating the emission controls of a motor vehicle even if it is only used off road will not be permitted.
This of course applies only to the USA.

There is confusion about what that will mean in practice.
But it sounds like removing the engine from a motorcycle and configuring it for FSAE would constitute tampering.
Any individual can submit comments on the clarification** but an inquiry from FSAE or SAE would carry more weight.

So the question for now is who should be contacted to have FSAE/SAE make that inquiry?
Otherwise teams (and by extension universities and FSAE) may have a significant liability.

-William

*http://arstechnica.com/cars/2016/02/...to-a-race-car/
*http://www.roadandtrack.com/motorspo...ctually-means/

** http://jalopnik.com/how-and-why-you-...ace-1758288770

[BillCobb]

Have someone from UofM (Ann Arbor) do a walk in at the EPA testing lab on Plymouth road to feel out the policy and whether an exception can be issued by petition.

I know a faculty advisor there that could do the job.

The EPA regulation reads,

“Certified motor vehicles and motor vehicle engines and their emission control devices must remain in their certified configuration even if they are used solely for competition or if they become nonroad vehicles or engines”. 80 Fed. Reg. 40138, 40565 (July 13, 2015). “

[Claude Rouelle]

Switch to FS Electrical car and you won't have the issue. Electrical car is the future anyway

[smokebreak]

With 260 million ICE-powered vehicles on the road and 16 million new ICE-powered vehicles sold last year in the US alone, said electric future, while inevitable, is very distant and most likely outside of our lifetime, especially in motorsports. However, as a FSAE participant I aim to work within the motorsports industry and I'm pretty certain I am not the only person with this goal. Therefore the career/education we are working and paying for may become obsolete (in US) due to overreaching federal regulation which equates to nothing more than a tax on small business, which ultimately creates yet another handicap to the US economy versus the rest of the world. Unfortunately there is no reason for politicians to oppose this mandate because the largest producers want this regulation to eliminate competition and they have the lobbyist to make it happen. Typical US politics, 'if you can't beat them regulate them either out of business or out of competition.' Given the history of the US government I suggest students plan accordingly. The sacrifices being made as part of an FSAE team may no longer be beneficial to the engineering student and FSAE will become a thing of the past much like the rest of the US motorsports industry. Buckle up because at this point we are just along for the ride.

John

[MCoach]

Yes, Claude, you do seem to be right! The generator engines used on-site at competitions do not appear to be regulated by these proposed emissions. Keen eye!

Electric cars will be the future when I can routinely make my commute to work across the urban sprawl that is the United States without having the mindset of the character of the recent movie, The Martian. "Well, I have extended the range of my vehicle by double by not running the heat. However, I still am not able to make it to [GM Headquarters]. But, if I don't run the heat, I will eventually succumb to the laws of thermodynamics and freeze [in the harsh Michigan winters]."

With that, I do hope to see the best of curbing the coal rolling bro-dozers emissions while leaving our good intentions of alcohol and petrol powered racing culture intact.

[Will M]

I would not expect the EPA to come knocking at MIS; as they have said that is not their focus.
But I also would not expect Universities to allow their students to continue using motorcycle engines for FSAE.
FSAE also might not accept entries which use said engines.

If that were the case teams could use dirt bike / atv / snowmobile engines.
So it is not the end of the world but it would restrict designs.

-William

[smokebreak]

"The existing prohibitions and exemptions in 40 CFR part 1068 related to competition engines and vehicles need to be amended to account for differing policies for nonroad and motor vehicle applications. In particular, we generally consider nonroad engines and vehicles to be “used solely for competition” based on usage characteristics. This allows EPA to set up an administrative process to approve competition exemptions, and to create an exemption from the tampering prohibition for products that are modified for competition purposes. There is no comparable allowance for motor vehicles. A motor vehicle qualifies for a competition exclusion based on the physical characteristics of the vehicle, not on its use. Also, if a motor vehicle is covered by a certificate of conformity at any point, there is no exemption from the tampering and defeat-device prohibitions that would allow for converting the engine or vehicle for competition use. There is no prohibition against actual use of certified motor vehicles or motor vehicle engines for competition purposes; however, it is not permissible to remove a motor vehicle or motor vehicle engine from its certified configuration regardless of the purpose for doing so."

P1310470.jpg


The quote above is taken directly from the document. (Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium and Heavy-Duty Engines and Vehicles; Phase 2) There seems to be a significant amount of ambiguity in the definition of "nonroad" though; "A motor vehicle qualifies for a competition exclusion based on the physical characteristics of the vehicle, not on its use.". One could interpret this many ways. I would say that the physical characteristics of any modified car (like above) could classify it as a "nonroad" vehicle. Just because one may use it on the street doesn't disqualify it from the competition exemption. Then you get to "certified configuration" and the statement seems to contradict itself, I guess you would have to purchase the vehicle or engine in an un-certified configuration to use it in competition, but one would think it would not legal (or cost effective) for a manufacturer to offer such a product.

The rest of the regulation is aimed at emissions reduction in heavy-duty application like the trucking industry, which coincidentally is one of the largest industries in the US. Personally I would rather see standard recommendations and compliance based upon good business practices rather than regulatory compliance, which is the reason that business' continue to scam the system ie. VW. It is less expensive to pay the fines than to meet the standards, and the government knows that and uses its power to increase its size and revenue in the name of environmental protection. Ultimately this is a tax on the Americans who will realized the additional costs in the form of cost of goods increase across the board (all industries rely on trucking in some form). Lowest income hit the hardest, by design. Sorry to get political but this is clearly a politically motivated regulation. Get government out of the way and let the market self-correct, I think we would be much better off.

[DougMilliken]

Get government out of the way and let the market self-correct, I think we would be much better off.

Since you have added in your politics...

My guess is that you are not old enough to have been in LA before emissions were regulated? It was not pleasant, and was approaching "deadly" at some times. There is no way that "the market" would have ever fixed it. From what I understand, Beijing is now in a similar unhealthy state (for just one example).

It's entirely possible that current light vehicle emission regulations have gone overboard (while giving a free ride to other mobile and stationary sources), often the "social pendulum" is undamped and swings past center -- but there is a real need for government regulation in a number of areas (like quality of life) where profit isn't the best means of feedback.

[Swiftus]

It would be nice if the battery voltage limit in the US competitions was raised to more of the 'industry standard' for electric cars. I think Teslas, the Leaf, the Audi e-tron, run on ~400V systems, the BMW i3/i8, Chevy Volt/Spark EV, Fiat 500e, Cadillac ELR, Kia Soul EV, latest generation Prius, on ~360V systems, and Fords, the Mitsubishi i-Miev have ~330V systems.

If we start looking at 'performance' vehicles, the Porsche 918 has a 385V battery, the Mclaren P1 has a 535V battery, F1 KERS is ~610V and Formula E is 1000V.

(All of these numbers are from ~10 minutes of google searching, so they may all be wrong!)

If these battery voltages are true, then why the 300V limit on eCars in the US and when 600V is allowed in other competitions? It seems to me that if we are to be using 'the latest and greatest' industry technology in the development of our designs, that technology should be made available for us to use. The turbo regulations were changed because it placed turbos in an 'industry standard' layout. Can the same argument be made for cell layout in batteries?


Al side note which is nice to think about but it only using promotional marketing materials from Chevy. Chevy says their Bolt EV battery gets the price of a kWh down to 150$/kWh. eCars typically have batteries between 5kWh and 10kWh in the current FS competitions. If Chevy were to donate cells to team that wanted to use them, it would cost them between $750 and $1500 a team. That is about the sponsorship level of Briggs and Straton for the Baja competition. For ~175 US teams that sponsorship value is in the $250,000 per year range. Definitely expensive, but a huge enabler in the development of EVs at a university level.

*The above is my own opinion and does not reflect the opinion of my school or team*

[JulianH]

If these battery voltages are true, then why the 300V limit on eCars in the US and when 600V is allowed in other competitions? It seems to me that if we are to be using 'the latest and greatest' industry technology in the development of our designs, that technology should be made available for us to use. The turbo regulations were changed because it placed turbos in an 'industry standard' layout. Can the same argument be made for cell layout in batteries?

Jay,

I had a lengthy discussion with FSAE (US) about this topic when they basically prevented all European cars from competing in the US. (All FSE cars that are running in the Top10-20 are rated >400V. The last competitive car that would have been legal in Lincoln was our 2012 car with <200V (and some issues related to that..)).

The argument was: "Just because Europe is doing it like that, does not mean the US has to do it as well. We will start like this, because it is industry standard and consider a change later". (E.g. "We just don't want you here").

Looking how fast the machines from Delft, Stuttgart, Karlsruhe and Zurich became in the last years (they even dominate combustion cars with only 60kW in the UK!), it was clear that they wanted to protect the US teams from getting whipped by the Europeans as they have more experience and more funding.
The problem with FSE cars still is, that you need a decent budget (or sponsorship) to get "good" parts. Batteries are expensive. AMK charges you 10k € for their motors... those little connectors for the battery cost as much as a motorcycle engine...
I understand that they want to protect the US teams from getting destroyed but it also would be a great learning opportunity just to get ahead.

In Europe we have FSE since 2010. A lot has happened in 7 seasons... Of course you cannot directly compete at the front (but examples like Trondheim show that it is possible to have a super decent and quick electric car in the first year).

Time to change that. And don't go for slow FS Hybrid Electric Class cars (which is a challenge for it self, but prevents teams from using one car for both competitions without making compromises).