from the horse's mouth(s)
SEMA had a seminar about this. CARB and EPA officials held a Q&A panel after a slide presentation. There was a lot of really good info, but here are some key takeaways:
1) The words "enforcement discretion" were spoken many times.
2) Their testing on "full delete, straight pipe and tuner diesel trucks", shows emissions of PM and Nox that are 300x stock. Not 300%, 30,000%.
3) estimated hundreds of thousands of deleted diesel trucks are having a polluting effect of an additional 5 million trucks being on the road. When considered together, DELETED VEHICLES ARE NOW THE #1 AIR POLLUTION SOURCE in the country. Deletes are therefore the #1 air pollution compliance objective of the EPA at this time, above all others combined.
4) the words, "full delete straight pipe and tuner" were spoken many times, as THE focus of their initiative.
5) when specifically asked whether "emissions intact" tunes are included in their initiative, the response always was pretty much 1) through 4) above. Enforcement discretion, straight pipes and tuners, 300 fold increase. They consider emissions intact tunes in the same category as different size tires, changed bumpers, turbos, intercoolers, etc as things that may effect emissions and COULD be enforced, but they are using enforcement discretion to go after what has the largest impact. (and obviously, easy to find and enforce.)
6) 300 fold increase in emissions from full deletes cancels any supposed benefit from less co2/co that goes along with any alleged fuel economy gains (many times over)
7) Let racers race, they don't care about race cars and true dedicated competition vehicles. but... If you drive your "race car" to work or to get groceries or talk about fuel economy, that is not a race car. They are not "taking away your race car". There is no exemption for "dual use cars"
8) They are NOT fooled by "off road disclaimers". In fact they are viewed as a confession of wrongdoing. Parts for race cars are low volume and not indiscrimnately sold to anyone who can click a check box "disclaimer" in large numbers. (they also categorized disclaimers check boxes as "a good start" or "step in the right direction" but not even close to "the solution"). There are only 2 categories, on-road and non-road vehicles, both categories are regulated by the EPA. There is no such thing as an "off road" vehicle as far as they are concerned, so "off road use only" disclaimers are basically considered utter nonsense and do absolutely nothing to deflect liability from the seller.
9) PM and NOx were both of concern and bother were included together in the charts, etc, in the discussion of why they are going after full deletes.
10) EPA has the burden of proof in enforcement cases, and "full deletes with straight pipe and tuner" are their focus. (my take on this was because low hanging fruit and very easy to prove as a violation.)
11) they are well aware of "offshore" products and have several avenues to stop them including going after dealers and installers in the USA, and Customs. They have successfully "put out of business" chinese companies that made violating engines, as one example that was offered regarding this capability.
12) They aim to negate and reverse any potential competitive marketplace advantage that may be afforded to those who make, sell, and install "full deletes and straight pipe with a tuner" over those who do not.
13) The talk was all of "diesel trucks" and no specific mention was made of cars. VW was mentioned exactly once and only in the context of a comment regarding what the epa has done before with manufacturers. (but this does not mean they "don't know about" VW deletes, only that it was not brought up or asked about specifically)
14) they are on the forums and facebook.
Just let me say, I'm just the messenger here. Just repeating what I heard. Hopefully it helps clear up some of the speculation going around.
SEMA had a seminar about this. CARB and EPA officials held a Q&A panel after a slide presentation. There was a lot of really good info, but here are some key takeaways:
1) The words "enforcement discretion" were spoken many times.
2) Their testing on "full delete, straight pipe and tuner diesel trucks", shows emissions of PM and Nox that are 300x stock. Not 300%, 30,000%.
3) estimated hundreds of thousands of deleted diesel trucks are having a polluting effect of an additional 5 million trucks being on the road. When considered together, DELETED VEHICLES ARE NOW THE #1 AIR POLLUTION SOURCE in the country. Deletes are therefore the #1 air pollution compliance objective of the EPA at this time, above all others combined.
4) the words, "full delete straight pipe and tuner" were spoken many times, as THE focus of their initiative.
5) when specifically asked whether "emissions intact" tunes are included in their initiative, the response always was pretty much 1) through 4) above. Enforcement discretion, straight pipes and tuners, 300 fold increase. They consider emissions intact tunes in the same category as different size tires, changed bumpers, turbos, intercoolers, etc as things that may effect emissions and COULD be enforced, but they are using enforcement discretion to go after what has the largest impact. (and obviously, easy to find and enforce.)
6) 300 fold increase in emissions from full deletes cancels any supposed benefit from less co2/co that goes along with any alleged fuel economy gains (many times over)
7) Let racers race, they don't care about race cars and true dedicated competition vehicles. but... If you drive your "race car" to work or to get groceries or talk about fuel economy, that is not a race car. They are not "taking away your race car". There is no exemption for "dual use cars"
8) They are NOT fooled by "off road disclaimers". In fact they are viewed as a confession of wrongdoing. Parts for race cars are low volume and not indiscrimnately sold to anyone who can click a check box "disclaimer" in large numbers. (they also categorized disclaimers check boxes as "a good start" or "step in the right direction" but not even close to "the solution"). There are only 2 categories, on-road and non-road vehicles, both categories are regulated by the EPA. There is no such thing as an "off road" vehicle as far as they are concerned, so "off road use only" disclaimers are basically considered utter nonsense and do absolutely nothing to deflect liability from the seller.
9) PM and NOx were both of concern and bother were included together in the charts, etc, in the discussion of why they are going after full deletes.
10) EPA has the burden of proof in enforcement cases, and "full deletes with straight pipe and tuner" are their focus. (my take on this was because low hanging fruit and very easy to prove as a violation.)
11) they are well aware of "offshore" products and have several avenues to stop them including going after dealers and installers in the USA, and Customs. They have successfully "put out of business" chinese companies that made violating engines, as one example that was offered regarding this capability.
12) They aim to negate and reverse any potential competitive marketplace advantage that may be afforded to those who make, sell, and install "full deletes and straight pipe with a tuner" over those who do not.
13) The talk was all of "diesel trucks" and no specific mention was made of cars. VW was mentioned exactly once and only in the context of a comment regarding what the epa has done before with manufacturers. (but this does not mean they "don't know about" VW deletes, only that it was not brought up or asked about specifically)
14) they are on the forums and facebook.
Just let me say, I'm just the messenger here. Just repeating what I heard. Hopefully it helps clear up some of the speculation going around.
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