Note the law's wording about
Note the law's wording about what cannot be removed or rendered inoperative. "..any device or element of design installed on or in a motor vehicle or motor vehicle engine." The individual systems in a vehicle are not the "EPA reg." The vehicle's emissions system is certified as a whole by the EPA. As an entity. By VIN. Stop-start reduces the grams of gases emitted per mile driven. I came to the conclusions I present by researching the subject and then by communicating with the EPA directly.