Right but in that case they had clear and straightforward compliance with the regulatory regime for emissions, and they were building a product well within the limits at that time. Now, things are different. Under EPA Tier 3 regs, the more relaxed NMOG+NOX standard for Small Volume Manufacturers (0.125 g/mi) expired after MY2021.
SVMs now have to meet a maximum allowable fleet average of
0.051 g/mile for NMOG+NOX for model years 2022-2027, and as recently as late 2020 the MY2021 Evora GT was only achieving a test result of
0.0729 g/mi according to the public records of their EPA submissions. Lotus themselves actually notated their EPA submissions for the MY2021 Evora GT, saying explicitly "As an SVM, Lotus will meet Tier 3 requirements in MY22". But they didn't sell a MY22 Lotus Evora in the US.
I hope Lotus were able to miraculously get the same "MLTXV03.5JHB (2GR-3.5S)" engine down by the necessary
30% reduction to hit the 0.051 g/mi target for MY22-MY27, because if not they'll have experienced an uphill battle trying to get EPA to grant them any sort of waiver. This is also somewhat complicated by their 51% ownership by Geely, who also own Volvo and therefore there's some math that has to be done on whether they have enough of a relationship to affect EPA SVM status.
Now, in my own mind, all this raises contextual questions. Is this fleet average problem possibly one of the reasons the Emira V6 has been delayed so long for the US? Is the long stack of delays since early 2022 maybe not about all the things they've claimed, but possibly instead a strategic choice, waiting for the Emira I4 AMG and Eletre to simultaneously certify for US compliance under the same Model Year for EPA, so that they're considered as a batch and Lotus get a better fleet average?
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