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Thread: Registration nightmare New York

  1. #1
    Senior Member Joel Hauser's Avatar
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    Registration nightmare New York

    Help.
    My Roadster is practically complete. I have started the registration and inspection process, and have run into an obstacle. New York State has a multi step registration process. After the car is weighed, you submit pictures of your cobra, receipts for parts, and an affidavit form in which you identify the year of your donor car, and declare if the car has equipment that is required by DMV. I submitted my affidavit and pictures a couple weeks ago. Yesterday I received a letter from DMV's Technical Services Bureau stating that "there are a number of issues that will need to be addressed". I called the DMV rep who sent the letter; he was very sympathetic, helpful, and told me not to be too pessimistic.

    1) I need to install approved back up lights. this shouldn't be a problem. I wired the back up lights to one of the red tail lights. I can buy some clear lights and wire them in. I think I can bolt them to the bumpers; I used after market VW beetle overriders made by Empi; I think they look great, and only cost $50 for all four.
    2) I need a windshield defroster. The DMV rep said that a 12 volt defroster sitting on the dash is fine.
    3) I need to install 4 way hazard flashers. That will be tricky, but I think I can figure it out
    4) padded dash and padded visors. I have the hard plastic visors from factory five. The rep said I can just cover them with padding. He also told me that the wind wings must be removed for inspection. Go figure.
    5) "a statement indicating the emissions control devices present on the vehicle (the vehicle must be equipped with all emission control devices required for the application year of the engine."

    The problem is I used a 1996 donor car with the modular motor. I also used the factory five hooker headers. I don't have catalytic converters or an EGR valve.

    I could buy OEM stock exhaust manifolds and factory five catalytic converters, but that's a lot of money. I think I would also have to remove the body to do the conversion; that would feel like a terrible set back.

    Does anyone have experience getting around the catalytic converter requirement? The DMV rep hinted that some guys just check the boxes affirming that the car has cats and an EGR; some guys say they are using a motor from 1965, since it is 1965 replica...but added that he couldn't tell me to do that and still keep his job. He said that DMV does not visually inspect the car for compliance. Rather, it relies on the builder to self certify. I didn't ask him if the repair shop inspection stations will also take your word for it that the engine is from 1965, or that it has all the required equipment. Or maybe I could buy some catalytic converters and an EGR valve, put them in a box and put the box in the trunk. The car will have the required equipment; it just won't be hooked up.

    Sorry for the long post; but this is very frustrating, and giving me an ulcer. I'm so close, and just want to drive my car. Any advice or experience will be appreciated, especially if it involves the modular fuel injected motors from 1996 to 2004.

    Thanks
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  2. #2

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    Go here: http://www.bipac.net/page.asp?conten...olbox&g=SEMAGA, scroll down and print the New York information. SEMA has down a really great job gathering this to help with just this type of problem.

    Good luck,

    Ray
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  3. #3
    EFI Rules and Carbs Drool Arrowhead's Avatar
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    Quote Originally Posted by Ray View Post
    Go here: http://www.bipac.net/page.asp?conten...olbox&g=SEMAGA, scroll down and print the New York information. SEMA has down a really great job gathering this to help with just this type of problem.

    Good luck,

    Ray
    Not to be a jerk Ray, but following any information from any source other than NYS DMV in this case would not be productive. Lots of FFR cars have been registered in NY and as usual with state governments, it's like reinventing the wheel. Everyone seems to have a different experience.

    Joel,

    First off, since you are upstate, homemade vehicles are exempt from catalytic converters (unless something has changed). I'm surprised he didn't mention that. I can't put my finger on on it, but I have seen this in writing on an official NYS form or instruction sheet. You have to remember your car will be looked at for stolen parts by the DMV field office and a safety inspection at a shop of your choosing AFTER you get the vin number from NYS. So, the theft inspection isn't looking for compliance to emissions requirements (I don't think they even see that form you are filling out - only the technical services guy you are dealing with does). It's two separate processes and two separate forms that go to two separate departments.

    I wouldn't sweat the wiring for the backup light and four way flashers (even though they are a good idea anyway). He is just looking at pictures and going by the form you are filling out - that is all. As long as the boxes are checked and you can see all the equipment in the pictures you'll be fine.

    Now when you do the field inspection that's when they check vin numbers and receipts. They are not doing a safety inspection or looking for proper emissions equipment (as last I knew).

    And BTW, yours is not a horror story by any means, this is just normal process for NYS. If you get your car to Guptils this summer, pull up a chair and I'll tell you a real horror story about the DMV
    Last edited by Arrowhead; 06-30-2017 at 07:11 PM.

  4. #4
    Senior Member Paparazzi's Avatar
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    I'm downstate from you, but still out of the NY Metro area that requires the full emissions testing. Do check your engine requirements - typically they are as per 'the application year of the block'. If you put 1996 you will need to have the original equipment fitted. I have a 351W and required only a PCV.

    EDIT: The NY Upstate differentiation is only that we don't have to have emissions tests. So, had I still lived on Long Island I would need to have passed the testing which would be really tricky with my 351W. Upstate there's no need to have an emissions test but you will still have to have all the original engine parts installed. It doesn't mean that you can strip down a modern block and remove all the restrictive parts.

    You will need backup lights. I bought a 1960s VW Kharman Ghia light attached via the quickjack - I really like what I consider the period look.

    You'll need wipers, padded dash, padded visors, side mirror, and a defroster. This was my prep (may even have been one of my photo submissions!)



    Clip on wipers, some felt over the visors, a 12v plug in Harbor Freight heater, a temporary clamp on side mirror. I've since made a side mirror mount that uses the wind wings mounting. The wiper went on once during a downpour (useless) and the heater went back in the box.

    Four way flashers are easy enough - a switch into the two turn signal circuits with some diodes - although with body on that might be a little tricky.

    Arrowhead is spot on - the State Police inspection couldn't give a damn about safety - they're looking only for stolen parts. I had removed my 'DMV setup' before going there and they didn't say anything. The serial on my engine isn't visible - they just went through my receipts and gave me my VIN.

    Your motor is going to be your problem. Up to you whether you just put an earlier application year - it is an attestation from you, no one will see this paperwork again.

    Good luck - and keep us posted.
    Last edited by Paparazzi; 06-30-2017 at 08:15 AM.
    FFR6243RD, MkIII, 3.55, IRS, pin-drive width, carb'd 351W, T5, 1/2 dropped butt, Fortes hydraulic clutch, deep dish AC-III wheels by Team III. 9 year build; NY registered 7/18/2016 - "Sweet 16" winner at 2016 Taconic State Nationals 5 days later ... in 'rough as hell' gel coat for the foreseeable future! Build Blog - Leave me a comment!

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  5. #5
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    I'm early in my build, but I called the dmv last month and was told the emissions goes by "application year" not the year of the donor. Fill in the top line of the forms as 1965 ac cobra replica and the requirements will be for 1965, pcv valve only. If you put 2017 factory five, you will need emissions for a 2017. I hope this helps.

  6. #6
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    When I went thru it 2 yrs ago, tech services told me the emissions installed on the car (not a testing requirement) needed to match the year that the motor was first available. So if its a mod motor only available in the 2000's then the emissions should match. Mine was a new (remanuf.) 302 variant, so I was able to call it a 1965 replica motor since the 302 was available then, and only needed PCV. Like the inspector alluded to and Arrowhead said, he is only checking compliance on the form and will not compare the form to the actual car in person. The DMV inspection (State Police) will only look for stolen parts and to make sure serial numbers match your paperwork and receipts and don't come up as stolen. When it comes time for the safety inspection, you will need to fool the computer system at the local shop anyway since the car will not be recognized in their system, so there should be no worries there. Being that you already filled the paperwork out once indicating year of motor, I think it would be best to take his advice and check the boxes stating what equipment is necessary to match (cats & egr). It should be the last time it comes up.

    PM me if you want to talk about the process

  7. #7
    Senior Member Joel Hauser's Avatar
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    Thanks everyone for input. Needless to say there is a lot of confusion and misinformation about the emission rules for our cars, much of it generated by DMV literature.

    In the interest of full disclosure, and at the risk of losing all respect in the cobra community, I must reveal that I am a lawyer. My review of the relevant NYS regulation leads me to believe that the only emissions inspection that homebuilt cars undergo is a look at the gas cap! The operative reg is 15 NYCRR 79.24. After you filter out all the crap that doesn't apply to us homemade car owners, this is what the reg says: "(I) OBD II emissions inspection. (i) All non-exempt vehicles, model-year 1996 and newer, non-diesel and non-electric,registered in any county in the State, except for vehicles with a make of "Custom" or "Homemade", are subject to the OBD II emissions inspection, in addition to the applicable safety inspection. .... Vehicles classified as Custom" or "Homemade" are only subject to the requirements of section 79.24(i), item 8b.... Vehicles classified as "Homemade" or "Custom" on the certificate of registration are only subject to the gas cap inspection/test described in item number 8b:" 15 NYCRR 79.24

    The reg doesn't define what a homemade car is, but I'm guessing it is a car made at home. I conclude that since I made my roadster in my home, in my garage, from the ground up, it is a homemade car. While it is true I didn't mine the ore, make the steel, weld the frame, and bore the cylinders, I did everything else. That makes my car homemade. The only emission control device DMV will look for is a gas cap. I don't know why they even bother asking if we have the other devices.

    Tomorrow I'm going to Harbor Freight to buy a defroster and back up light. I'll put some foam around the visors. My manual wiper and mirrors are in place It turns out I had four way flashers and didn't even know it; I used the original turn signal stem from my donor car, which has the flasher button built in, as well at the dimmer switch. How did I miss that?

    I'm getting excited! Hope it doesn't rain.

    Thanks again
    Joel

  8. #8

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    Are the visors required? Can't you just remove them and the wind wings for the inspection?
    Anyone know what the process if for an titled car - 1997 - being registered in NYS? In central NY?
    Looks like I'm going to be on the move again heading for the southern tier of NY for a while.
    Will need to transfer the car from Texas to NYS soon.
    Ralph Button
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  9. #9
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    Joel, its the paperwork end with Tech inspection that you need to get thru. That is where you are being rejected. So you will need to fill out the paperwork based on what they require as indicated previously. When it comes to an actual inspection, you are right, emissions will not be checked.

  10. #10
    Junior Member Scarlett's Avatar
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    Joel- Not to add to the confusion, but when I went through this 8 years ago, I received a bit of advice about emissions equipment from the polite friendly and helpful guy at the DMV in Albany. I questioned him at length about needing cats and such. He was reluctant to give an outright or straight answer as is typical. He finally got tired of me asking this and that about needing cats because that is what was on the donor and stated, "Ford is not the manufacturer of this car. You are. Whatever you put on the car when you manufacture it needs to stay on it." He then repeated exactly the same words. I thought about that, thanked him for sharing that thought and hung up the phone. Then I checked the box on the form that attested to it having a PCV valve and a gas cap, then sent it in. No issues, ever. Being a lawyer, I'm sure you can appreciate the simplicity of that guy's statement.

    If you want to do a sleek installation of a reverse light, a number of guys, including me, went with one from the first gen new Mini. There should be a thread around somewhere that gives the part number and pics. It was about $25 for the whole unit. It is a real easy install, looks great, and not out of place at all.

    All the wiper, heater, padded visor stuff is simple as you are discovering. No sweat there.

    And as far as the classification of your car as a custom or homebuilt, it should be considered a custom by NYS.

    HTH,

    Steve

  11. #11
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    Just do a transfer of registration from Texas to NY.

  12. #12
    Senior Member Joel Hauser's Avatar
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    Yesterday was my inspection with New York State DMV Division of Field Investigation, (DFI) which is the office which inspects kit cars, customs and salvage vehicles for stolen parts. It passed. I have been issued a VIN number. My next step is to fax the form that DFI issued back to DMV, which will (hopefully) issue a form VS-103, Notice of Registration Acceptability. Once I get the VS-103, I can bring my car to any NYS approved inspection station.

    I'm getting tired just thinking about it.

  13. #13
    Senior Member Paparazzi's Avatar
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    Congratulations - you're past the worst of it. Now it's just waiting for your form in the mail and then get inspected.
    FFR6243RD, MkIII, 3.55, IRS, pin-drive width, carb'd 351W, T5, 1/2 dropped butt, Fortes hydraulic clutch, deep dish AC-III wheels by Team III. 9 year build; NY registered 7/18/2016 - "Sweet 16" winner at 2016 Taconic State Nationals 5 days later ... in 'rough as hell' gel coat for the foreseeable future! Build Blog - Leave me a comment!

    Register your car with the Factory Five Cars Rule! mobile app available from the app store

  14. #14
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    Quote Originally Posted by Joel Hauser View Post
    Thanks everyone for input. Needless to say there is a lot of confusion and misinformation about the emission rules for our cars, much of it generated by DMV literature.

    In the interest of full disclosure, and at the risk of losing all respect in the cobra community, I must reveal that I am a lawyer. My review of the relevant NYS regulation leads me to believe that the only emissions inspection that homebuilt cars undergo is a look at the gas cap! The operative reg is 15 NYCRR 79.24. After you filter out all the crap that doesn't apply to us homemade car owners, this is what the reg says: "(I) OBD II emissions inspection. (i) All non-exempt vehicles, model-year 1996 and newer, non-diesel and non-electric,registered in any county in the State, except for vehicles with a make of "Custom" or "Homemade", are subject to the OBD II emissions inspection, in addition to the applicable safety inspection. .... Vehicles classified as Custom" or "Homemade" are only subject to the requirements of section 79.24(i), item 8b.... Vehicles classified as "Homemade" or "Custom" on the certificate of registration are only subject to the gas cap inspection/test described in item number 8b:" 15 NYCRR 79.24

    The reg doesn't define what a homemade car is, but I'm guessing it is a car made at home. I conclude that since I made my roadster in my home, in my garage, from the ground up, it is a homemade car. While it is true I didn't mine the ore, make the steel, weld the frame, and bore the cylinders, I did everything else. That makes my car homemade. The only emission control device DMV will look for is a gas cap. I don't know why they even bother asking if we have the other devices.

    Tomorrow I'm going to Harbor Freight to buy a defroster and back up light. I'll put some foam around the visors. My manual wiper and mirrors are in place It turns out I had four way flashers and didn't even know it; I used the original turn signal stem from my donor car, which has the flasher button built in, as well at the dimmer switch. How did I miss that?

    I'm getting excited! Hope it doesn't rain.

    Thanks again
    Joel
    I live on Long Island and I'm about to venture into this build. I was going to use a Coyote setup but do not want to deal with the emissions. Sounds like I might have too due to the newness of this power plant? Does the "Homemade" wording Joel refers too supersede any emissions required? I might as well go with an "older" style setup and call it a '65! Glad I found this thread....................

  15. #15
    Forte's Parts Connection
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    Hi GUYS,
    I sell a stainless steel 4 into one cat header for the roadster with a O2 sensor bung it almost looks to good to mount on a car. Coyote and SB Ford available. Custom applications also available.
    Mike Forte: Forte's Parts Connection / Framingham, Mass. 01702 / 508 875 0016 / [email protected] / fortesparts.com / Facebook Instagram: @fortespartconnection Est: 1981 dealing performance parts to build your dream car. A REAL SPEED SHOP with parts, price & knowledge. Developer of the early Ford & FE Tremec and Mustang firewall adjustable quadrant kits, external slave clutch release conversions & cable release conversions. Tremec Elite, FORD RACING & QUICKTIME DISTRIBUTOR!

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