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Comment for Proposed Low Carbon Fuel Standard Amendments (lcfs2024) - 15-3.

First NameAl
Last NamePimentel
Email Addressthe4pimentels@comcast.net
Affiliation
SubjectRequest for an EO for aftermarket exhaust on 20+ year old car
Comment
**Subject:** Request for Assistance in Obtaining CARB Executive
Order for Aftermarket Part for 
2004-2005 Mazdaspeed MX-5 Miata

I am writing as a constituent and as someone seeking your
assistance in 
obtaining a California Air Resources Board (CARB) Executive Order
(EO) for an aftermarket part 
designed specifically for the 2004-2005 Mazdaspeed MX-5 Miata. As
you may know, CARB 
requires an EO to certify that add-on or modified parts do not
increase vehicle emissions. 
However, the process to obtain this exemption presents unique
challenges for vehicles with low 
production numbers--fewer than 6,000 units of this model were sold
in North America and they 
are all 20+ years old now.
The part in question is a downpipe and catalytic converter, SKU#
06-58300, produced by Flyin' 
Miata, a highly respected manufacturer and retailer of quality
aftermarket components. The 
catalytic converter meets California emissions standards and will
pass the sniffer test. Flyin' Miata 
is well known for their commitment to engineering excellence and
emissions compliance, yet the 
complexity, cost, and delays of the CARB approval process make it
extremely difficult for them to 
justify pursuing certification for niche vehicles like the
Mazdaspeed MX-5.
While I fully support California's efforts to reduce vehicle
emissions, the current EO process is 
unnecessarily burdensome for small manufacturers and enthusiasts
trying to bring compliant parts
to market. The extensive testing requirements, high costs, and
bureaucratic roadblocks 
discourage compliance and push people toward off-the-books
modifications or simply abandoning 
efforts altogether. This kind of government inefficiency is exactly
why voters become frustrated 
with the system, leading to electoral outcomes like Donald Trump's
victories. People want 
practical governance, not red tape that makes life harder for those
who are trying to follow the 
rules.
I respectfully request your help in addressing these issues:
1. **Advocacy for Streamlined Processes:** Encourage CARB to
develop alternative approval 
pathways for low-production vehicles, such as reduced testing
requirements or lower fees.
2. **Support for Small Manufacturers:** Promote initiatives that
provide financial or technical 
assistance for small businesses seeking EO certification.
3. **Policy Development:** Support legislative or regulatory
reforms that account for the 
challenges of certifying parts for low-production vehicles without
compromising environmental 
goals.
I appreciate your time and your service to our community. Your
leadership is crucial in ensuring 
that California's regulatory framework remains fair, practical, and
accessible to businesses and 
consumers alike. Please let me know how I can assist in advancing
this discussion.
Sincerely,
Alex Pimentel
2005 Mazdaspeed Miata Owner
3739 Painted Pony Road
Richmond CA 94803
the4pimentels@comcast.net
510-813-0479

Attachment
Original File Name
Date and Time Comment Was Submitted 2025-04-08 21:12:01

If you have any questions or comments please contact Clerk of the Board at (916) 322-5594.


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