Discussions with CARB and the EPA on the future of performance parts

Rodan said:

Keith Tanner said:

 

Furious_E said:

So what does this mean for products like Megasquirt and HPTuners? 

Nothing good at all. HP Tuners can be a tool for installing legal, approved tunes like Hondata can. They're really just the interface. That's where one of the questions about "how can we tell if the legal tune has been replaced?" comes from.

 

This is a very interesting point.  I had some issues with our '18 ZL1 at our last track event, and of course the dealer couldn't duplicate the problem on the street (unsafe, illegal, etc.), which is completely understandable.  No codes were set.  The tech recommended I buy HP Tuners' MPVI2 to datalog the car at the track so we could see what was going on.  

In this case, the MPVI2 would have been a tool to diagnose, not modify, and a pretty useful one at that.  Hell, I bought a ZL1 so I wouldn' t have to modify it for track use.  I would hate to see something like the MPVI2 to go away, when it could be a very useful tool.

The HPT tuning software (VCM Editor) is a different package from the scantool software (VCM Scanner).  You log in one and you edit with the other, and the two don't play well with each other running at the same time, sometimes...

VCM Scanner is pretty useful as a scantool rather than just datalogging, it has most/all of the bidirectional controls that a "real" scan tool has, and in a format that is frankly a lot more user-friendly.  (The datalogging can be mind-cramping to get it to record what you want in the form that you want, though!)  If I had something HPT supported, I'd buy it just for that functionality alone.

There is precedence for HPT removing functionality with updates - they USED to give you access for the things that would delete emissions stuff on Diesels, and that was removed a few years back.

TheRX7Project said:

I don't get the interest the government has for modified vehicles. For every modified vehicle on the road there are hundreds if not thousands of factory stock vehicles putting out minimal emissions, compound that with the amount of modified vehicles that still run emissions equipment and you're essentially looking for ghosts. Tom from the mailroom isn't gutting the cats on his '13 Camry to try and get to work faster.

If they want to go after someone, go after the guys who are knowingly modifying their vehicles illegally. Pretty easy to prove with a quick inspection, if someone doesn't have a catalytic converter or is spotted "rolling coal". Make a portable emissions testing kit- like a breathalyzer for cars- that can be utilized on site when a violation is suspected. Set a measurable limit on emissions, and if the vehicle does not pass, issue a 30-day repair order.

Or better yet, just leave us alone. I believe if the government could regulate sex into being unenjoyable, they would.

The thing is that modified vehicles can have massively increased emissions compared to compliant ones. It's not 5-10%, it's 4000%. And 13% (the number of pickups with full deletes according to their investigations) means more than 1 in 8. So it makes perfect sense to go after the source of the parts. 

They're not going after Tom from the mailroom. They're looking for the guys who give Tom the tools to remove the cat from his Camry because he doesn't want to replace a failed one. Yes, this means Tom can't put on a cheap test pipe, but it also means that Tom's Camry will stay clean.

Mobile and roadside emissions checks already exist. Fix-it tickets exist. That's at the state enforcement end, and we did talk with BAR about some of that - what to do when a cerfified tune ID gets applied on top of a manufacturer update and the check sums change. But the EPA and CARB are going after the source.

alfadriver said:

In reply to Keith Tanner :

So for all of the companies that want to comply with the proper EO rules, they will all need experienced emissions calibrators, right?  

Good jobs there.

Definitely. If you're a tuner, stop playing around with WOT dyno hero runs and start looking at cold start and transient conditions :)

There is the potential for a real logjam at CARB for EOs. Basically, California has the only procedure for proving emissions compliance. You can do the same tests, not get an EO and it'll work to prove that your parts are compliant - but that's a longer conversation with the EPA than simply providing an EO number. That's why CARB is working to streamline the process and why they're bringing on more staff. But they only signed 30 EOs in August 2019. That's more than triple what they did in August 2018 and they're proud of that, but it's nowhere near enough for the size of the aftermarket.

As for rolling exemptions - the 1975 date comes from the infamous "Memo 1A". It's only 5 pages and definitely worth a read if you want to know what the EPA's stand is. Aftermarket parts are not a problem unless they affect emissions. That's basically it.

In reply to Keith Tanner :

That sounds mostly positive to me. I've always suspected 1% of people were responsible for most vehicle emissions, while the other 99% of us are on the hook for expensive and time-consuming crap (like evaporation canister system repairs) that don't do much at all.

When I picture that 1%, it's mostly tightwads who hop from non-compliant Corolla to non-compliant Corolla around emissions-testing time, and unload the castoffs in non-tested states like Alabama. There's a whole network of people doing that where I live. Many of them also own Circle Ks I avoid.

As for "Coal rollers," they are a special type of stupid altogether. If you break emissions law in that egregious a manner, you should go to prison, in my opinion.

b13990 said:

In reply to Keith Tanner :

That sounds mostly positive to me. I've always suspected 1% of people were responsible for most vehicle emissions, while the other 99% of us are on the hook for expensive and time-consuming crap (like evaporation canister system repairs) that don't do much at all.

An evaporative emissions failure can DRAMATICALLY increase your car's HC emissions.

In the 1990s, the rule of thumb was that a new car polluted less when driving down the Interstate than a 1965 car polluted while shut off in your garage.  If you take the allowable grams/mile of HC emissions today and do a little math, the amount of pollution that a car is allowed to emit (both evaporative and exhaust) over its expected lifespan will come to a mild fuel spill when gassing up your lawnmower.

Cars are incredibly clean nowadays, and the flip side of that coin is that yes, a .010" evap leak is actually a pretty significant increase in emissions.  Consider that some manufacturers went to completely sealed fuel tanks because the permeability of the O-rings represented a significant enough amount of emissions that it was worth the expense to eliminate them...

How much longer do we think the "coal rolling" trend will last? And, how long will it take to put effective enforceable combative measures into effect? And then the big question, at what cost?

NOT A TA said:

How much longer do we think the "coal rolling" trend will last? And, how long will it take to put effective enforceable combative measures into effect? And then the big question, at what cost?

For a long time.  There's a person at work who has a modified F150 that has a big sticker on the rear cap that says "I identify as a Prius"

Tells me a lot about people who do that.  It's not by accident.

In reply to alfadriver :

I saw some big truck that had "Prius repellent" written on the bumper near the exhaust pipe.

It must be hard, living a life where your major financial decisions are determined by what you think are other peoples' opinions.  At least we know that they are extremely easy to manipulate to do what you want them to do.

NOT A TA said:

How much longer do we think the "coal rolling" trend will last? And, how long will it take to put effective enforceable combative measures into effect? And then the big question, at what cost?

The problem is that the enforcement of individuals is up to the states, and some states are pretty relaxed in that regard. I suspect those states also have a high proportion of brodozers. 

My 2010 diesel has an exhaust that’s totally inoffensive at idle and it doesn’t blow any smoke when towing. I kinda like that. 

Knurled. said: An evaporative emissions failure can DRAMATICALLY increase your car's HC emissions.
Cars are incredibly clean nowadays, and the flip side of that coin is that yes, a .010" evap leak is actually a pretty significant increase in emissions.

Oh, I don't doubt any of that. But one guy rolling coal is emitting orders of magnitude more hydrocarbons still, and is also emitting a whole lot of other, even nastier stuff (e.g. sooty particulates). A car burning oil probably is, too.

That was my basic point: all of the hard work done by car companies to keep well-intentioned people operating well-running vehicles clean is good, but it's getting washed away by a metaphorical tide of knuckleheads and scofflaws.

Many states have laws against visible smoke that have been on the books for decades. I have never heard of any enforcement except maybe in California. I know we have such a law here in PA, and I see coal rollers frequently.

b13990 said:

Knurled. said: An evaporative emissions failure can DRAMATICALLY increase your car's HC emissions.
Cars are incredibly clean nowadays, and the flip side of that coin is that yes, a .010" evap leak is actually a pretty significant increase in emissions.

Oh, I don't doubt any of that. But one guy rolling coal is emitting orders of magnitude more hydrocarbons still, and is also emitting a whole lot of other, even nastier stuff (e.g. sooty particulates). A car burning oil probably is, too.

That was my basic point: all of the hard work done by car companies to keep well-intentioned people operating well-running vehicles clean is good, but it's getting washed away by a metaphorical tide of knuckleheads and scofflaws.

That's rather why the EPA is (rightly) going after the people, or at least the people who cater to the people, who apparently think E36 M3ting in everyone's Cheerios is groovy, and the unfortunate side effect is that everyone else who isn't as shiny or happy will get caught in the crossfire.

So what you're saying is only the real DIY hot rodders will survive? Maybe i wasn't born in the wrong era after all.  

Anyway, this is a pretty clear side effect of something i've mentioned before with regard to the likelihood of 100 million tiny stakeholders organizing politically vs a 3 digit number that are in it for hundreds of millions each.  Oh well, that's the way the world is. The kind of people that will want to change the performance of cars they don't actually get to drive will not have much overlap with the enthusiast scene as we know it today. In other words, there is a bigger clock that started ticking before this one did, and stopping this one still won't stop that one. We'll all be modifying race-only vehicles in a short time frame (well, some people in this thread might conceivably be dead) if what used to be a street vehicle isn't legal to operate on the streets any more.

I'm sure there are a fairly small number of highly invested stakeholders working out the kinks of that process right now too. I'm sort of glad they're not posting here about how the sausage is being made. It wouldn't change the story arc. We're going there. 

TurnerX19 said:

Many states have laws against visible smoke that have been on the books for decades. I have never heard of any enforcement except maybe in California. I know we have such a law here in PA, and I see coal rollers frequently.

My totally stock 2000 F-350 7.3 TD will put out a cloud of smoke if I mash the throttle. Very rarely is it necessary so I never think about it. I keep the truck in good operating condition and with my use it'll probably last till I'm dead. While it's not the most efficient eco friendly truck, I'd bet making a new truck to replace it would be worse for the environment. If people took better care of their cars the world would need less replacement cars thereby reducing environmental impact.

The point of my previous post was that trends come & go (usually young drivers in teens and early 20's) and the trend will probably be on the way out by the time measures to curb coal rolling are put in place. There was a time when cars had air shocks and big & little tires. Other people didn't like them but they got older and stopped doing it. Vans with wild paint jobs, custom interiors, etc. became a thing. Other people didn't like them. They got older and the vans became repainted work trucks. . Huge stereos became a thing with giant sub woofers vibrating license plates and what not. Other people didn't like them and "quiet zone" signs were put up in neighborhoods. They got older and stopped putting huge stereos in the cars rotted away. Imports scraping the pavement shod with tacked on fiberglass body parts and fart cans became a thing. Other people didn't like them. Then they grew older and are rare now. Same type of thing happened with Mini trucks, Pro Street,  etc. So history repeating itself the coal rolling trend will probably go away on it's own.

Here in FL there's no emissions testing. I do occasionally see someone rolling coal. Seems to me it's primarily unburnt fuel which evaporates. I see a lot of older diesel trucks that leak fuel but there's no laws against that. Leaks out on the pavement and evaporates just like the "coal".  Since diesel isn't explosive like gas many owners let them leak for long periods because it's cheaper than fixing them. You can spot the leaker's where they park regularly because the pavement, concrete, or dirt is soaked with a big patch of diesel. Does the EPA, CARB, or any other gov agency worry about leaking diesel contaminating the ground water supply or evaporating? Just seems to me like spending time/money to stop the coal rolling is just more government spending that will have little benefit per dollar spent and the trend is likely to go away anyway.

I'm getting the feeling you're not understanding what I'm saying.

Stopping the coal rollers at the source should have a very large effect, and that's what the EPA is working towards. Shut down a company selling thousands of delete tuners, and you've made an enormous difference. Shut down a shop doing hundreds or dozens of deletes and you've made a decent dent.

Trying to hunt down each one individually, yes, that's low return. But it's still more effective to shut down one gross polluter than to make hundreds of others slightly cleaner, so it's also a good return on investment.

Particulate emissions don't "evaporate", they disperse. Leaking diesel is also not really permitted but if you live in a state with really lax enforcement you might think otherwise. It also does not evaporate very well, but it sure does damage asphalt visibly.

Coal rollers are very visible and create political pressure for the EPA and other agencies to do something. But gas cars with the cats removed and with a "power tune" is also a big outlier, so the agencies are also targeting them. It's not a war against performance, it's a war against emissions. It's just that some people think you can't have power without taking off emissions components. That's pretty obviously false.

A 2000-era truck is in a different ballpark of emissions than a modern one. The agencies know that vehicles are lasting longer now, so the emissions parts also have to last longer. I know that when we got the EO for our turbo kits, they extrapolated what the emissions would be at some high mileage, it had to remain within certain limits. I forget the mileage, something like 150k.

Kind of like they're not busting pot smokers, they're busting the growers and sellers.

NOT A TA said:

Here in FL there's no emissions testing. I do occasionally see someone rolling coal. Seems to me it's primarily unburnt fuel which evaporates. I see a lot of older diesel trucks that leak fuel but there's no laws against that. Leaks out on the pavement and evaporates just like the "coal".  Since diesel isn't explosive like gas many owners let them leak for long periods because it's cheaper than fixing them. You can spot the leaker's where they park regularly because the pavement, concrete, or dirt is soaked with a big patch of diesel. Does the EPA, CARB, or any other gov agency worry about leaking diesel contaminating the ground water supply or evaporating? Just seems to me like spending time/money to stop the coal rolling is just more government spending that will have little benefit per dollar spent and the trend is likely to go away anyway.

People seem to be focusing on coal rolling, but there are tons of people with deleted diesel trucks or tuned gas vehicles that aren't obviously rolling coal, and they're arguably doing more harm to people and the environment. Not all tailpipe emissions are equal in their visibility, their impact on people, or their impact on the environment.

Tailpipe emissions are the result of decisions/compromises in the combustion process. And reducing one bad chemical compound often results in increasing another. Direct injection makes this easier to get right, and also easier to screw up as you can inject fuel multiple times in each stroke, and the timing/amount of these fuel injections controls what you get out of the combustion process. If you want to prioritize fuel efficiency, and run lean, you get high temps and lots of invisible NOx. If you want to prioritize making more HP, or rolling coal, you add more fuel which reduces combustion temps and NOx, but increases hydrocarbon and particulate production.

Each of those compounds does different things once it's out in the world. NOx and particulates are both pretty harmful for humans, so the regulators have chosen to reduce those things first with the trade off being that they increased some less harmful emissions like HC and CO2. Essentially they prioritized human health over the environment in the beginning. Now that the stuff that harms people is mostly controlled, those environmentally harmful compounds are also being targeted for reduction.

Modern diesels have gotten so good at cleaning up the stuff after combustion, that they actually run dirtier combustion than older diesels like your Powerstroke. If you measure immediately after the turbo, they make far more NOx than a pre-emissions diesel and then they rely on emissions hardware to clean it up. That's how you get 1000ft-lbs with a warranty and cleaner tailpipe emissions and basically the same fuel economy as 20 years ago. But, if you delete that emissions hardware that's doing all of that cleanup, you've just got that dirtier combustion process creating more tailpipe emissions. And that's before you start trying to make more power, or roll coal, or increase fuel economy. And as Kieth has said, it could mean increasing emissions several orders of magnitude higher than allowed by law.

So the point is that coal rollers are highly visible for enthusiasts and non enthusiasts alike. But for every brodozer rolling coal and making it obvious that they're breaking the law, you've got several others creating just as much harm without making it obvious. Thats why regulators are going after those who enable and profit from emissions modification. It eliminates all of the offenders at the source.

NOT A TA said:

Here in FL there's no emissions testing. I do occasionally see someone rolling coal. Seems to me it's primarily unburnt fuel which evaporates. I see a lot of older diesel trucks that leak fuel but there's no laws against that. Leaks out on the pavement and evaporates just like the "coal".  Since diesel isn't explosive like gas many owners let them leak for long periods because it's cheaper than fixing them. You can spot the leaker's where they park regularly because the pavement, concrete, or dirt is soaked with a big patch of diesel. Does the EPA, CARB, or any other gov agency worry about leaking diesel contaminating the ground water supply or evaporating? Just seems to me like spending time/money to stop the coal rolling is just more government spending that will have little benefit per dollar spent and the trend is likely to go away anyway.

Just wanted to add one thing- CARB and EPA laws are very strict WRT leaks- both for vapor and liquid leaks.  When those leaks happen, the MIL light should light up.  That's a clear requirement of the OBD laws.

As mentioned, it's up to the states to actually enforce individual leaking vehicles.

And OBD is something that is supposed to help keep states that don't have testing requirements clean- it doesn't work perfectly, though.

There's no question at all about CARB and EPA worrying about ground water contamination- they do quite a bit.  But their hands are tied when it comes to enforcement.  Well, the EPA at least.  One huge reason they are not going after individuals is that they do not have the legal ability to do so- but they do have it for companies that sell stuff.    In the long run, when you look at what makes up the gross majority of the Challenge- there's nothing they can do about it- most of that are used parts being put together.  And I'll remind people that there are real car enthusiasts that work at the EPA- one actual challenge entry, two almost starts, and a lot of racers.

Keith Tanner said:

I'm getting the feeling you're not understanding what I'm saying.

Stopping the coal rollers at the source should have a very large effect, and that's what the EPA is working towards. Shut down a company selling thousands of delete tuners, and you've made an enormous difference. Shut down a shop doing hundreds or dozens of deletes and you've made a decent dent.

Trying to hunt down each one individually, yes, that's low return. But it's still more effective to shut down one gross polluter than to make hundreds of others slightly cleaner, so it's also a good return on investment.

Particulate emissions don't "evaporate", they disperse. Leaking diesel is also not really permitted but if you live in a state with really lax enforcement you might think otherwise. It also does not evaporate very well, but it sure does damage asphalt visibly.

I do understand and agree, I just question the ROI.

What would stop people from ordering the offending equipment from Canada, Mexico, or some other country?

Is coal roller shaming a thing on social media? Maybe that'd be a quicker means to an end.

Appleseed said:

Kind of like they're not busting pot smokers, they're busting the growers and sellers.

Ya, the war on drugs was pretty expensive. Now they're making pot legal.Great ROI

This is a very interesting discussion. I think that even as an enthusiast I’m all for it. I would love to be able to tune my cars or add an intake without breaking the law and if they can ramp up the EO process while also shutting down the gross (people) polluters I’m happy. 

I'm not trying to disagree with you guys, just make people think about the big picture and time/money spent.

NOT A TA said:

 

Is coal roller shaming a thing on social media? Maybe that'd be a quicker means to an end.

My take is coal rolling is a very direct response to people wanting someone to be ashamed of their behavior. 

In reply to NOT A TA :

So instead of going after the people producing the hardware and tunes that create massive amounts pollution and pulling them into regulation or shutting them down, we should be diverting resources from bringing junkies back to life to chase individual coal rollers?

I am actually a fan of big Smokey diesels, but I understand the problem they create, especially when thousands upon thousands of people are doing it just for the look or to make some pseudo political statement or to makeup for their micropeen. 

I'm about as anti government and anti oversight as you can get, and even I think this is a good idea. I might not like all of it, and I suspect the transitioning period to everything having an EO number will be long and expensive translating to more expensive parts in the short term, but I feel like it could benefit everybody in the long term in this situation.

Proving race parts are going on race cars is probably the easiest part of it, setup a situation like the Mazda performance parts, where you have to submit time slips from track days to be eligible to buy parts. 

I don't have a dog in this fight, but I've gone from hating threads like this to actually liking them. Hearing from Alfa, Keith, and others actually in the industry about how it affects things from a point of view I'll never have is rather enlightening. Even seeing the differences and similarities of a Big Three producer and an aftermarket shop it's at the very least informative.

NOT A TA said:

I'm not trying to disagree with you guys, just make people think about the big picture and time/money spent.

The point of disagreement is the ROI. If you look at the numbers, cracking down on emissions defeat devices at the source is a very good use of effort. I think you’re vastly underestimating how much more emissions come out of a modified car. The percentage varies depending on what aspect you’re looking at, but it’s major. There were numbers in the EPA presentation, if I can get a copy I’ll pass them along. And the most efficient way to do that is shut down the source. ROI is very good, far better than roadside emissions checks.

 The EPA is also looking at how to control the import of defeat devices. I mean, VW is a fairly significant example. The EPA went after VW Germany. Again, it’s best to go after the source and that is difficult with overseas manufacturers and resellers. They’re not opening USPS boxes to check for non-compliant parts, that is also a low ROI and probably illegal. That’s a very small quantity - but one that was mentioned a few times as problematic.

Coal rollers are just very visible and add pressure to the agencies to do something. But even if every brodozer bro suddenly develops a brain, it’s not going to change the crackdown or the emphasis. “Mobile sources” are a significant source of emissions, almost half.