@bob_442
(In a southern Buford T Sheriff drawl...)
"
What we have heeeeerrre is a case of 'Engine Change' and a change in 'Motive Power', we reckon."
Remember, that California is only interested in smog checking what actually produces smog, which is the engine. So they follow the year of the engine (in heavy duty vehicles) or the year of the original donor vehicle from which the engine was taken (in light duty vehicles).
Once an engine change has taken place, the smog rules that formerly applied to the recipient vehicle no longer matter. California follows the engine and the smog standards of the chassis the engine came from, not the smog standards for the chassis the engine was retrofitted to.
At the time of the engine change, the BAR referee should have affixed a label (oftentimes blue in color) to the vehicle reflecting the approval of the engine change.
One question I have for you is, are the Cummins engines 1998 or newer? I've forgotten a lot about 5.9 engines, but I seem to recall that 1998 was a split year between 12 valve and 24 valve availability, so even if you are running 12 valves, if the Federal Emissions Certification label that has the Engine Family Number and year of manufacturer for the ENGINE is 1998 or newer, that information would be documented by the BAR on blue label the referee may have affixed somewhere in the engine compartment, and that information would also be on electronic record associated with the vins of the 1988 and 1989 Chevys.
Since the engine is what produces the smog, if the diesel engines that were retrofitted are newer than 1998, this could very well been the computer programming "trigger" that caused you to receive those notices in the mail.
"Smog Check Tests- The vehicle must pass ALL of the following Smog Check tests (regardless of model year) using the donor vehicle Smog Check test type requirements." Smog Check Reference Guide, Appendix D: Engine Change Guidelines, Section IV, Paragraph d.
If the engines are older than 1997, then the trigger may be due to some insufficiency in the notations of the original BAR referee who inspected the vehicles following the engine change. Any insufficiency will require another visit to a BAR referee who has the authority to verify and correct the vehicle status record.
If the diesel engines are the same year or newer than the model year of the recipient trucks (all Dodge Cummins engines are, in the case of your '88 and '89 Chevies) and, are of a model year that would not otherwise by subject to smog inspection (1997 or older), then your vehicle should be exempted from smog inspections in the future.
HOWEVER, if your donor vehicle of your engines was say, a Ford F-800 heavy duty truck, then that diesel engine swap would no longer be allowed under current engine change rules. However, the vehicle class limitations may not have been in effect at the time your Chevys were re-powered. Will you be grandfathered, since the BAR already approved your engine swap and accepted your registration fees for X number of years since? That would certainly be the right thing to do, in the interest of justice, but this is new, gray, and not very often treaded upon territory, which is one of the reasons why I am weighing in and subscribing to this thread... to follow the outcome.
If the Cummins engines are both 1998 or newer, then this is another interesting and not very often treaded territory, but it isn't gray. It's black and white. You will be subject to diesel smog check standards that applied to the donor vehicles... unless the donor vehicle were heavy duty trucks. Then it gets gray again. I'll be watching for updates to this thread to see how that plays out in practice. In the meantime...
Remember the phrase "
Motive Power", when communicating with
DMV personnel who have never encountered a case like yours before. Motive Power is the key word for them to be able to look up what they are supposed to do in their procedural manual, and will lead them to
Section 22.040: Changes to Engine or Fuel Type/Motive Power.
https://www.dmv.ca.gov/portal/handb.../changes-to-engine-or-fuel-type-motive-power/
I'll go ahead and post the text for your convenience here, as with the number of pre '75 vehicles smog exempt vehicles that you already have registered, Big Brother is probably tracking your IP address, and is standing by with a fleet of tow trucks to haul them away...
"Chapter 22 Corrections and Adjustments
22.040 Changes to Engine or Fuel Type/Motive Power
A motive power (MP) change must be referred to the Bureau of Automotive Repair (BAR) Referee Center when the new MP is not the same as originally equipped, as indicated by the vehicle identification number (VIN) decoding program.
The BAR Referee Center will inspect the vehicle to verify and/or approve the new MP change. BAR will issue a smog exemption on the vehicle record if the MP exempts the vehicle from smog certification.
Do not refer the vehicle to BAR if:
- The MP change indicated is the same MP as originally equipped as indicated by a VIN decode. Correct the MP to what the VIN decode indicates.
- Keying type transaction code (TTC) A00, and the vehicle was converted to an alternate fuel type prior to the sale. Change the MP to what is recorded on the Report of Sale.
The procedure below must be followed:
Refer inquiries regarding engine changes or fuel type/MP changes to:
BAR 1-800-952-5210
Bar Referee Center 1-800-622-7733
BAR Internet website smogcheck.ca.gov
Refer customers to contact the California Air Resources Board (CARB) at 1-800-242-4450 prior to making any alterations to the emission control system configurations.
For customers who already made an engine change, including those to a different fuel type/MP (Example gas to electric), the vehicle must be referred to the BAR Referee Center. BAR will notify DMV of any permanent smog exemptions after inspecting the vehicle."
NOW, once you start dealing with the
BAR, the keyword to remember is
Engine Change. The BAR doesn't speak "Motive Power". They speak "Engine Change", and "Engine Change" is very distinct from "
Engine Replacement".
"Engine Replacement" means like kind engine as the vehicle was originally equipped with, using the same fuel.
"Engine Change" means a different kind of engine (or what the DMV calls Motive Power), using a different kind of fuel.
There have been changes in the rules between 2010 and 2019 regarding Engine Changes. Here is only a SMALL PART of what applied in 2019:
All model year vehicles (gasoline, diesel, hybrid, CNG, LNG, LPG, etc.) must meet the following:
a. Model Year - The installed engine must be of the same model year or newer than the model year of the recipient vehicle.
b. Engine Classification- Vehicle and engine classifications of the donor and recipient vehicles must be the same based on Gross Vehicle Weight Rating (GVWR). Classification examples include passenger car, light-duty truck (LDT1, LDT2), light-heavy-duty truck (LHD1, LHD2), medium-duty vehicle (MDV), etc. For example, a heavy-duty truck engine may not be installed in a light-duty truck even if they have the same displacement. Non-emissions controlled engines, such as industrial and off-road-use-only engines, and non-certified “crate engines”, MAY NOT be installed in any emission- controlled vehicle.
c. Certification Type - The certification type (California or Federal certification) of the engine and recipient vehicle must be the same or, if not, the engine must adhere to the more stringent standard. For example, a California certified engine may be installed in a Federal vehicle but a Federal engine may not be installed in a California vehicle. Proof of the certification type from the manufacturer or CARB EO of the donor engine must be provided at the time of the engine change inspection at the Referee.
d. Smog Check Tests- The vehicle must pass ALL of the following Smog Check tests (regardless of model year) using the donor vehicle Smog Check test type.
Please keep us posted. What you experience will help a lot of people navigate their way to lawfully approved repowers, and avoid costly errors.
