A bit more searching finds:
> In section 203(a)(3) of the Clean Air Act the following acts are
> prohibited:
>
> (3)(A) for any person to remove or render inoperative any device
> or element of design installed on or in a motor vehicle or motor
> vehicle engine in compliance with regulations under this title
> prior to sale and delivery to the ultimate purchaser, or for any
> person knowingly to remove or render inoperative any such device
> or element of design after such sale and delivery to the ultimate
> purchaser; or
>
> (B) for any person to manufacture or sell, or offer to sell, or
> install, any part or component intended for use with, or as part
> of, any motor vehicle or motor vehicle engine, where a principal
> effect of the part or component is to bypass, defeat, or render
> inoperative any device or element of design installed on or in a
> motor vehicle or motor vehicle engine in compliance with
> regulations under this title, and where the person knows or
> should know that such part or component is being offered for sale
> or installed for such use or put to such use; or ........
>
> Section 205 of the CAA
>
> (a) Violations. - Any person who violates sections 203(a)(1),
> 203(a)(4), or 203(a)(5) or any manufacturer or dealer who
> violates section 203(a)(3)(A) shall be subject to a civil penalty
> of not more than $25,000. Any person other than a manufacturer
> or dealer who violates section 203(a)3(A) or any person who
> violates section 203(a)(3)B) shall be subject to a civil penalty
> of not more than $2,500. Any such violation with respect to
> paragraph (1), (3)(A), or (4) of section 203(a) shall constitute
> a separate offense with respect to each motor vehicle or motor
> vehicle engine. Any such violation with respect to section
> 203(a)(3)(B) shall constitute a separate offense with respect to
> each part or component. any person who violates section
> 203(a)(2) shall be subject to a civil penalty of not more than
> $25,000 per day of violation.
>
> Some aftermarket conversion entities are using the guidance EPA
> identifies as "MEMORANDUM 1A" to demonstrate that a tampering
> violation described in section 203 of the CAA has not occurred.
> This guidance is currently being reviewed. It is unlikely the
> existing interpretation of this guidance document will remain in
> effect. Any conversion activity that plans on using the guidance
> in MEMO 1A to show that a tampering act has not occurred should
> contact EPA's Office of Enforcement, Richard Ackerman
> 202-564-1301.
>
Whether or not it is legal in SP it clearly is not actually legal.
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