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TDI (Diesel) Emissions This is a discussion about emissions from TDI's. Pro's cons of Diesels (including biodiesel) effects on the environment and how they compare to Gasoline and other fuel sources for Internal combustion engines.

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Old November 9th, 2019, 11:04   #1
KERMA
 
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Default from the horse's mouth (EPA/CARB at SEMA)

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.
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Last edited by KERMA; November 10th, 2019 at 17:52. Reason: made a little clearer
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Old November 9th, 2019, 17:39   #2
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Interesting, thank you!
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Old November 9th, 2019, 18:43   #3
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Quote:
DELETED VEHICLES ARE NOW THE #1 AIR POLLUTION SOURCE in the country.
I call bull s#!t. Its #1 from the EPA numbers which "pollution" is defined as anything diesel related. Oh gee your F150 raptor is pumping out CO, VOCs and and PM like crazy but we won't look at that.
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Old November 10th, 2019, 08:24   #4
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Quote:
Originally Posted by KERMA View Post
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:
Extremely valuable info. Thanks, Kerma, for taking the time to summarize it.
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Last edited by RIP TDI; November 10th, 2019 at 08:35.
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Old November 10th, 2019, 08:29   #5
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That F150 Raptor is Tier II EPA certified. An emissions-deleted diesel engines is not. The aftertreatment that came with that diesel engine is 95 ~ 99% efficient at controlling the regulated emissions, and the engine itself is designed and calibrated to have low engine-out emissions. So, remove that 95 ~ 99% efficient aftertreatment AND recalibrate the engine with no consideration whatsoever to engine-out emissions and it's entirely possible that the regulated emissions (CO, HC, NOx, PM) could be 300 times higher.

High-emitters are waaaay disproportionate emission sources. I have my doubts about emissions-deleted vehicles being the #1 emission source in the country, but they certainly would represent a disproportionate amount.

Just because an engine is small doesn't mean it emits less. You may have heard that gasoline-fueled small engines (for outdoor power equipment) emit more than automotive engine. Test - F150 Raptor vs leaf blower: https://www.edmunds.com/car-reviews/...af-blower.html
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Old November 10th, 2019, 08:32   #6
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Old November 11th, 2019, 10:38   #7
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NOx aside (since that seems to be a red herring anyway), wouldn't CO, HC, and PM be directly proportional to the amount of fuel used? I get a reduction in PM from aftertreatment, but exactly how does an engine that went from 14 MPG to 20 MPG be pushing out more HC and CO? It isn't coming from thin air. The only things going into the engine are hydrocarbons (HC), oxygen, nitrogen (which is not "combusted") and trace amounts of CO2. Or are they talking about the black stacking brodozers and lumping all of them into the same category?

Or is it just that even with so much less fuel used, there is still a bad combustion event happening no matter what?

And I would also ask what specifically are they talking about, since many diesels never had anything beyond a simple one way catalyst for a long time. You cannot "delete" something that was never there in the first place (DPF, SCR, etc.).

Thanks for sharing, Kerma. It does look like it will be more expensive going forward to own some of these vehicles.
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Old November 11th, 2019, 12:52   #8
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It sounds like they are focusing on the coal-roaling, bro-dozer crowd for now. Those are the really gross polluters, and there are quite a lot of them. There are too few deleted diesel cars here to be worth targeting.
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Old November 11th, 2019, 14:10   #9
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Just my personal input here... One thing I've learned, is that emissions are not simply a linear relationship to fuel burned. Combustion phasing has everything to do with it. And our CR cars actually control this in closed loop. Pretty special stuff. Even if it's not widely understood or even on the radar of "the internet" lol. Lots of literature out there for those who care to investigate.

And... There are several enforcement action summaries on the EPA web page where they fined a company for ONE vehicle being "deleted".

regarding the "can't delete what wasn't there in the first place" comment:

The discussion included a slide showing the various "tiers" of diesel emissions controls going back to 1988. Tier 0 being no specific controls, 10g/mile, all the way to tier 3 with almost zero PM/nox. They had a real problem with all the "progress" being undone "back to tier zero" by deletes. (and they emphasized that factory power output has doubled during that time as well... so cleaner emissions does not necessarily mean less power, in fact quite the opposite)

"Straight pipe and full delete tune" are easy to prove as violating, because it is such a gross change "back to tier zero" as they stated.

There was also a pie chart showing all the main contributors to air polution that the EPA regulates.... and "deleted diesel trucks" had the largest slice, by far. Whether it's "true" or not, it is definitely true in the eyes of the EPA, and that's what matters in this context.

Quote:
Originally Posted by oilhammer View Post
NOx aside (since that seems to be a red herring anyway), wouldn't CO, HC, and PM be directly proportional to the amount of fuel used? I get a reduction in PM from aftertreatment, but exactly how does an engine that went from 14 MPG to 20 MPG be pushing out more HC and CO? It isn't coming from thin air. The only things going into the engine are hydrocarbons (HC), oxygen, nitrogen (which is not "combusted") and trace amounts of CO2. Or are they talking about the black stacking brodozers and lumping all of them into the same category?
Or is it just that even with so much less fuel used, there is still a bad combustion event happening no matter what?
And I would also ask what specifically are they talking about, since many diesels never had anything beyond a simple one way catalyst for a long time. You cannot "delete" something that was never there in the first place (DPF, SCR, etc.).
Thanks for sharing, Kerma. It does look like it will be more expensive going forward to own some of these vehicles.
(as an aside... Curiously enough ALH/PD seem to be certified under Tier 1 Bin 10, which is the worst possible rating for Tier 1, and technically a "transition" Bin that was disallowed by California in 2004... which is why you couldn't buy a new PD in Cali back in the day. So it could be argued that the non-CR cars are no better, or only marginally better, than tier 0 non-emissions trucks/cars, even stock... FWIW, my opinion)
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Last edited by KERMA; November 11th, 2019 at 15:39. Reason: phasing not phrasing lol
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Old November 12th, 2019, 05:39   #10
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I agree, power output has gone through the roof during this time, but fuel economy has not, and in some cases got worse, despite having a couple more gears in the transmission. Which is why I have always felt a choice of heavy duty diesel engines would have possibly been a good idea. Not everyone needs a 600+hp truck. My 1990 F350 did surprisingly well with less than 200hp, and even with only having 4 gears in its transmission, was able to use no more fuel than my half ton gas truck with a 6 cylinder and a 5sp manual. Oh, the dually also had a 4.10 rear end to boot. The F150 has a 3.55.

I did know that the ALH was "barely" inside the regulations at the time. As was the 1Z and AHU before it. However, I learned from VW training that they were specifically tuned for the US regulations, and that they too used more fuel to be "cleaner". All because of NOx. Which, again, seems to be something that the EPA has a hard on over despite it not being an issue for us. It never was, aside from the LA basin, which has not had the problem for over 2 decades now... and the overall air quality has improved everywhere... which is why there are strong talks in the STL area to ditch our OBD testing for good. It is interesting listening to both "sides" of the discussion here, as there clearly is no easy answer. One side says "the air is cleaner, we do not need this", and the other side says "the air is cleaner BECAUSE we have this". We (people in my field in this area) have an interest in it because we do the OBD testing, as well as the safety testing, which is also under constant scrutiny.

Which has always made me call into question the abundance of [clearly] deleted/tuned diesel trucks around here. Someone is passing them on inspection. It would appear to be a pretty easy thing to track down, but nobody does. Like all the stupid HD motorcycles with illegal loud pipes on them.
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Old November 13th, 2019, 17:33   #11
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Believe it when I see it. Federal gov can't force states to obey immigration or drug laws, how they going to enforce this?
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Old November 13th, 2019, 19:24   #12
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Selective enforcement. They can pick out their targets and go after them. They may not get everyone but they can get whomever they actually target. Just like VW, if the punishment hurts and is unbelievable then going after everyone isn't required. You just have to target some bad offenders and everyone else for the most part will fall in line, so they aren't targeted next. Make huge glaring examples of some tuners, some garages and some owners and leak it to the news and I would bet you would be surprised how many revert.
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Old November 13th, 2019, 19:52   #13
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Believe it when I see it. Federal gov can't force states to obey immigration or drug laws, how they going to enforce this?
I already know of a smaller shop that was busted a little over a year ago. This occured in a red state that did not check the emissions. It may or may not happen to the customers, but any shop that's selling or installing deletes is at risk.
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Old November 14th, 2019, 07:35   #14
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I can see that. Just like they did when shops were removing catalytic converters years ago.
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Old November 14th, 2019, 09:56   #15
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Originally Posted by turbobrick240 View Post
It sounds like they are focusing on the coal-roaling, bro-dozer crowd for now. Those are the really gross polluters, and there are quite a lot of them. There are too few deleted diesel cars here to be worth targeting.
Good prioritization from EPA indeed! These emission-modified diesel pick up trucks (and larger diesel trucks) are giving a bad name to the very small percentage of compliant light duty diesel vehicles in the US that are averaging around 40 MPG (or more) and are much better efficiency-wise and performance-wise than the rest of the ~250+ million ICE passenger vehicles in the country (probably averaging something like lower 20's MPG).
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