See? You figured out your own response in one post, two paragraphs. +1 Internets for The Bettencourt.
On edit: Andy et al, you can believe whatever you want, whatever lets you sleep at night. But that fact is, exhaust heat shields are part of the exhaust system; after all, what other system would they be a part of? It is my opinion as a competitor, National scrutineer, and member of a CRB sub-committee that such an "interpretation" (as much as it is not) would survive any and all appeal/protest/tech shed scrutiny.
If you really think that exhaust heat shields are not part of the exhaust system, then I strongly encourage you to write a letter to the CRB and ask them to "clarify" the regs accordingly. After all, the very fate of the future of Improved Touring may depend on it...
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