from the horse's mouth (EPA/CARB at SEMA)

KERMA

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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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turbocharged798

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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.
 

RIP TDI

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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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GoFaster

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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/features/emissions-test-car-vs-truck-vs-leaf-blower.html
 

oilhammer

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There are just too many to list....
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.
 

turbobrick240

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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.
 

KERMA

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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.

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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oilhammer

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There are just too many to list....
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. :rolleyes:
 

Jetta SS

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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?
 

Lightflyer1

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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.
 

crazyrunner33

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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.
 

tikal

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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.
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).
 

forrest resto`s

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So.. what are all the cars etc.. tdi's that had the fix and have constant dpf/egr coolant etc. failures supposed to do when the "warranty" expires?..(or denied because of this or that)..just toss the cars over the cliff??... Most people do a delete for one of 2 reasons: more hp/torque gains and dependability..or just can't keep paying for the repair..or both...we bought these cars without knowing these problems would arise..and they are SERIOUS problems to deal with later on..and to resolve it, a "delete" is for some people the ONLY option..besides dumping the car..alot of people cannot afford to dump the car..(years of financing etc..investing 25,000 new, more or less used) and now own it free and clear..wow
 
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Lightflyer1

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Fix it like everyone else has to do when their car breaks. Or you can always sell it. The majority of the people who now own these cars should be fully aware of the circumstances of the car they own. There will be used and new parts available. If you haven't paid the car off after "years of financing" then you made a bad choice in buying a car you couldn't afford.
 

GoFaster

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What are the owners "supposed" to do when the warranty is up and the car breaks? Same as any other major breakdown. An economic decision needs to be made. Either pay to fix it, or junk it and get a different vehicle (or trade it in, probably for peanuts, at which point the dealer that they traded it in to, gets to make that decision. Who's going to want to buy a car with a current, known, major problem? Off to the scrap heap it goes).

Most owners aren't technically savvy and won't go the modification/delete route. Many others live in areas subject to periodic emissions inspections and won't be able to go that route. If the EPA keeps rattling cages, finding companies that sell that sort of stuff and finding mechanics willing to install it may become difficult. Sure, there will be a few savvy enough to do it, but they will be few in number. And that's what the EPA wants.

I have always been of the opinion that VW is going to be very hard-nosed about the extended warranty time and mileage limits. If it breaks a week out of warranty, it'll be on you.

P.S. This sort of thing is FAR from isolated to VW. A friend of mine has a Ford Fiesta automatic with about 170,000 km on it. Now there's a time-bomb, and he knows it. YES, there's an extended warranty on those cars. He's already past it. Drive it 'til it drops, leave it where it stops.
 

MPLSTDI

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I was considering a another diesel and always planned if something goes wrong after the emissions warranty ran out deleting it.
This makes me rethink that plan, The E-Golfs are looking a little more appealing now.

It also makes me rethink ever selling my PD.
 

oilhammer

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There are just too many to list....
Well I can tell you that part unavailability is not something limited to late model diesels, or any diesel, or Volkswagens. I have dealt with all kinds of that over the years. ANYTHING Chrysler is a royal pain, because they were gobbled up by Mercedes-Benz, then spit out, then cobbled together by Cerebus, then a sort of bankruptcy/rescue by Fiat. So pretty much anything that is not in current production is a complete fiasco to get parts for. The latest is all the Ram pickups that need fuel tanks. The company that made them no longer exists. PT Cruiser? Forget it.

We are dealing with a heater core on a Pontiac Vibe. Which nobody has. GM cannot get it. NUMMI (the people that built it, along with Toyota Matrix and some Corollas at the time) no longer exists. GM during that tenure no longer exists. Pontiac no longer exists. GM can get virtually nothing for it. Toyota only sells the entire HVAC case, which we are not even 100% sure is even the same. This Vibe has a Delphi HVAC system in the dash, not sure if a Matrix does or not, despite rolling down the exact same assembly line at the exact same time, they may have gotten Denso HVAC... in which case NOTHING is the same. We've had this poor car here in the shop with its dash out for over a week. :rolleyes:

The latest is using a new core that does not quite fit and modifying the case. I am glad I am not working on it.

Ford has discontinued everything for my unique one-year-only 1996 F150, and they actually did so a decade ago. My only fix for the MIL? Taking the cluster out and removing the bulb. The parts to properly fix it do not exist.
 

MPLSTDI

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It would appear green diesel engineering has quit selling Tunes. Not sure how long ago that happened. Very sad to see.
 

crazyrunner33

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Or to keep it open pending decision of the EPA. Easy to reopen this way.
I've got a bad feeling about that. The one shop I was referring to was initially put on the radar for their Ecodiesel tuning posts and caught red handed in person deleting a customer's truck.
 

nicklockard

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Charlie, excellent reporting and good analysis overall here guys. I want to mention that the COST of staying compliant is ridiculous, at least in BMW diesel sedans. When a DPF costs $2600 ($785USD in Germany, shipped to USA), it is a shameful thing. How in HELL do they expect us to maintain our rides? The Euro-version DPF only has minor differences in sensor bungs and I think one mount tab is located a little different, and they're missing the integrated OX-cat.

What we need is HARMONIZED standards for all major automakers in the western and eastern hemispheres. I know it's hard work, but ISO standards organization does it for nearly every other manufacturer type, from pharma to medical devices to packaging to quality control to electronics and much much more. Why can't we have an ISO standard for 'on road vehicle emissions'? There is no logical reason except country governments use emissions policy as back-door tariffs and trade impediments.

STOP the BS.

The #1 emitters are international shipping companies. I would argue a close second is the fast food restaurant industry--watch what comes out the smoke stack of a Burger King on an average Saturday! About 10x-30x the pollutant mass that comes out of all the vehicles passing it in that same day, is what. Yet somehow they get a pass. Use your freaking eyes, EPA, or go grab a particle counter and stand next to a Burger King during their business hours. Then compare that emissions to the car's emissions alone when the Burger King is closed (have to increase sample time such that the number of car transits is same for both A and B data sets). Then subtract and figure out the restaurant's emissions. I bet it will ridiculously dwarf the car's.
 

turbobrick240

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GDE got a surprise inspection from the EPA, and is working on developing some compliant tunes. They are done with the delete stuff.
 

IndigoBlueWagon

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So.. what are all the cars etc.. tdi's that had the fix and have constant dpf/egr coolant etc. failures supposed to do when the "warranty" expires?..(or denied because of this or that)..just toss the cars over the cliff??... Most people do a delete for one of 2 reasons: more hp/torque gains and dependability..or just can't keep paying for the repair..or both...we bought these cars without knowing these problems would arise..and they are SERIOUS problems to deal with later on..and to resolve it, a "delete" is for some people the ONLY option..besides dumping the car..alot of people cannot afford to dump the car..(years of financing etc..investing 25,000 new, more or less used) and now own it free and clear..wow
These concerns are true for all cars, and not just the engines. There are many, many items in modern cars that, if in need of replacement, will quickly exceed the value of the car. That's why luxury cars depreciate so quickly. Once they're out of warranty people are, justifiably, terrified of repair costs.

I recently read about how bumper requirements on cars were supposed to lower repair costs. But now, with crumple zone standards, pedestrian safety standards, and cameras and sensors in bumpers, repair costs have skyrocketed.

Keeping a modern diesel running with emissions intact probably isn't a lot more expensive than any car with a turbocharged gasoline engine. And a lot of light duty diesels will run fine for well over 100K miles without a major emissions-related repair. Let's hope the car's paid for by then. :D
 

oilhammer

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There are just too many to list....
The body shop we deal with recently changed owners, the original owner sold the business. He said in the last 10 years, minor crashes are turning into crazy stupid high jobs that will total the car LONG before it is "used up". He got out while he still could.

Case in point: the previous generation Silverado. Those ignorantly blinding LED headlamps? $1300 each. He had a truck that was only three years old have a $6500 repair for a glancing deer hit. A headlight, bumper cover, grill, hood, and fender, with some various plastic bits. That's it. $6500. That truck will be a total if that happens by the time it is only seven years old. And he showed me the picture, it was barely anything. But once you add in the price of the parts.... and then the labor to just reset all the various modules and stuff. It is nuts.
 

GoFaster

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What we need is HARMONIZED standards for all major automakers in the western and eastern hemispheres. I know it's hard work, but ISO standards organization does it for nearly every other manufacturer type, from pharma to medical devices to packaging to quality control to electronics and much much more. Why can't we have an ISO standard for 'on road vehicle emissions'? There is no logical reason except country governments use emissions policy as back-door tariffs and trade impediments.
The UN-ECE standards are used worldwide ... except the USA (due to "not invented here" syndrome) and Canada (copies USA standards for the most part). Some countries have their own standards that more or less duplicate the UN-ECE standards. But the American standards are just different enough that you can't state that complying with one body of standards achieves compliance with the other, even though the engineering solutions that are actually implemented in the vehicle are broadly similar.

Not that those standards, or the means of implementing them, are without their own flaws, as we have seen over the last few years (and you can say the exact same thing about both bodies of standards).
 

oilhammer

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There are just too many to list....
The difference in standards for automobiles here is also what drives prices up. When a company has to make a car a certain way JUST for the USA (and perhaps Canada ;) ), it used to not make *that* much of a difference, since the US used to be a substantial market. But now, with so many other markets jumping on the car culture, especially China and India, our standards are no longer the sizable percentage they once were. China took over the US a few years ago for Audi sales outside Germany, and that trend continued although recent developments may have slowed that.

Still, when a company can sell literally the exact same model of vehicle in every other part of the world with just minor tweaks (even allowing for LHD/RHD), they cannot sell them here. So we have to get stuck with something specific for us OR something drastically changed (often the powertrain) that otherwise ruins the whole vehicle.
 
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