[Morgester]

Remember I am not DMV and it is DMV who decides how to implement the laws as they currently exist in California. The only reason I am involved in this process is to deal with the resulting registration fallout that follows our office’s prosecutions of illegal registration services. Our goal is to place the registered owner in a position they would have been had they registered the vehicle legally.

Here we have two rules at issue "full faith and credit" and the SPCN rule. In the past we have seen DMV Field Offices use the “full faith and credit” to issue a year on a SPCN that allowed it to be smog exempt. DMV’s main office is now looking at the issue and it appears that they will register the vehicles but the vehicles still have to comply with SPCN emission standards – SB100 or pass an emission test for the year of the build.
To be candid these vehicles should meet SPCN emission rules. The use of “full faith and credit” to avoid emissions is at best an unfortunate unintended consequence or simply does not apply to emission testing. DMV is now looking like they will take the position that “full faith and credit” doesn’t apply to emission testing.

So my free advice (worth what you paid for it) – don’t do it. If you choose to do it make sure you disclose everything and then DMV will do whatever DMV will do. Of course if you don’t like what DMV does on this issue there are administrative remedies available to you that you will have to win prior to your vehicle being registered.

Final note, if the amnesty bill makes it through and SEMA’s “greenrod” after market kit allows SPCN to meet current emission testing standards I plan on offering legislation to put to rest the “full faith and credit” issue so that it is clear it does not apply to emission testing. I like things simply, one set of rules that apply to everyone and that are enforced equally and fairly.

The plan is simply – consistent rules that allow hot rods and SPCN to be legally registered in California. Once in place our targeted registration services lose around 90% of their revenue and it will no longer be cost effective for them to remain in business. Without the funding from you folks these services will not be around to register those other vehicles (stolen / lemon / Katrina . . .)

The best way to get a bad law repealed is to enforce it strictly.
-- Abraham Lincoln