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

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 cost of how this is being enforced is actually pretty reasonable.  Instead of having a ton of people out there monitoring each car, it's just a handful of people working with the industry.  And the ones who are following the letter of the law actually have vested interest in making sure their competitors are also following the laws.  Finally, if a law breaker is found, their fines help pay for this program.

As I noted in my first post - those that try to fight this and get all het up are going to lose. There’s a tuning shop in CA whose rep was sitting in front of me and got all frothy at the mouth at his rights being violated. That guy will be out of business in a couple of years.  The winners will be those that work with the agencies to make it happen. SEMA has been at the forefront of that for decades. They’re a lot more than just the guys who put on an annual show of modified cars. 

NOT A TA said:

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.

At this point on the technology curve, that's always my question with this.   Cars are so clean now, and modified cars such a small number to begin with, gov't intrusion is costing a lot of money for everyone, with little overall benefit at this point.

I've not much to add, but would just like to thank you all for this pleasant and reasonable conversation that's relevant to my interests that I get to enjoy reading this Sunday morning.

I think I agree with the general approach Keith is communicating to us, prioritizing the manufacters etc vs the individuals. 80/20 rule, 20% effort to get 80% of the job done. I know some will say any govt regulation whatsoever is money wasted here, but this seems like a pretty reasonable compromise. If anything, it uses the basic concept of capatilism to multiply a relatively small effort of regulation. Going after the drug suppliers vs the end users is a good analogy, I think.

OldGray320i said:

NOT A TA said:

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.

At this point on the technology curve, that's always my question with this.   Cars are so clean now, and modified cars such a small number to begin with, gov't intrusion is costing a lot of money for everyone, with little overall benefit at this point.

 

The actual amount of "government intrusion" isn't nearly what you think it is- it's not an armed bunch of DEA people raiding various smuggling ports, or anything like that.  It's a handful of people making sure that the groups of people selling parts are doing it legally- and there are a lot fewer actual companies making parts than you think (if you really think this cost a lot).   Given what they are legally able to enforce, the amount of people and work required isn't all that much.

Mind you, as Kieth started, the air quality isn't getting better when it should be- given the current state of the rules.  So the violators are really doing a number.

Besides, there's a lot of legal companies out there who suffer when other companies are doing it illegally- so the enforcment of these laws are not just about clean air.  It's also so that Sinking Miata isn't making money skirting the law at Flyin Miata's expense.

MrJoshua said:

The EPA is specifically going after emissions defeat devices, and no surprise it's being driven by coal rollers. But according to their numbers, 13% of diesel trucks sold in the last 10 years are running full defeat devices.

Sounds like a preposterously high number. 

indeed

NOT A TA said:.

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

nothing

It will be illegal, so that should keep them from doing it

This all can be expected to increase performance parts prices significantly.  It can be expected to reduce the number of vendors, in addition to the expense that will be added to each individual part.  Basic economic principles indicate what the result of this will be.

Toebra said:

NOT A TA said:.

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

nothing

Uh, unless the parts are being smuggled into the country, there are import restrictions.  It's why Customs exist.  And I don't see the profit enought to smuggle them into the country.  Works the same way for cars.

alfadriver said:

OldGray320i said:

NOT A TA said:

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.

At this point on the technology curve, that's always my question with this.   Cars are so clean now, and modified cars such a small number to begin with, gov't intrusion is costing a lot of money for everyone, with little overall benefit at this point.

 

The actual amount of "government intrusion" isn't nearly what you think it is- it's not an armed bunch of DEA people raiding various smuggling ports, or anything like that.  It's a handful of people making sure that the groups of people selling parts are doing it legally- and there are a lot fewer actual companies making parts than you think (if you really think this cost a lot).   Given what they are legally able to enforce, the amount of people and work required isn't all that much.

Mind you, as Kieth started, the air quality isn't getting better when it should be- given the current state of the rules.  So the violators are really doing a number.

Besides, there's a lot of legal companies out there who suffer when other companies are doing it illegally- so the enforcment of these laws are not just about clean air.  It's also so that Sinking Miata isn't making money skirting the law at Flyin Miata's expense.

 

 I see those points, good ones, especially Sinking Miata (cuts in to FM sales, and if they can't make money we all suffer), but the additional cost isn't just the direct cost of government, it's the added administrative cost of compliance for everyone who touches part.  My experiece with federal contracting says that compliance is a large cost.  Define large in this context, I guess. 

If the air isn't getting better, is it really going to be the offending brodozers (or parts marketplace) that moves the needle?   The mfgrs, well, that's the entirety of the vehicle population,  so the new cars that shut off at idle, well, that's going to be a much larger impact. 

The fines that some places have had to pay for breaking the current rules have been significant, I'm sure they've been effective - and there will always be scoflaws.

We could argue that what we all enjoy so much isn't necessary at all, shut them all down.  So the government intrusion aspect isn't without merit.  Throw around the big numbers like 4000% or whatever it was, and whoa Nellie, we gotta fix that!  But 4000% on .00001 of the population isn't much. 

If you really want it to work, and you're spending public money to achieve a governmental aim, threshold/goal the cost of the test, and watch compliance and market size increase. 

FM is going to do the right thing because that's who they are.   But if EO/CARB testing is free for hitting the spec, FM can now sell the same product for less than the guy who was 5% off on the emissions target? And dont you now incentivize 5% guy with both carrot and stick?

Good intentions, good motives, but is it really going to move the needle on the entirety of air quality,  and the ever creeping scope of regulation making it harder and harder to enjoy the freedom of playing with your car?

God bless Keith and the guys like him, they keep it going at a high level, I'll say that. 

That was 4000% of 13% of the population. They equated it to doubling truck sales (don’t ask me to explain that math). If I get my hands on the presentation (it’s probably on an EPA website already), I’ll share it so you can see their numbers. I think most of the examples were chosen for their sound bite ability, but emissions defeat devices are being viewed as a significant problem that’s not just a few guys. Just look at the size of the SEMA show.

Thinking of the diesel truck owners I know - all of whom use their trucks for truck things, not shopping - 13% is way low. Amongst my circle of acquaintances, I’d put it at about 80%. And that’s not because I hang out with car guys, these are farmers and mechanics. 

The proposed CARB EO procedures are intended to streamline the process. At the moment, an air filter has the same application as a turbo kit. The new setup would give the air filter a shorter application, which makes it easier and less expensive for all involved. 

This push doesn’t make it harder to play with your car. It just makes it harder to buy parts that will make your car dirtier. 

Keith Tanner said:

Thinking of the diesel truck owners I know - all of whom use their trucks for truck things, not shopping - 13% is way low. Amongst my circle of acquaintances, I’d put it at about 80%. And that’s not because I hang out with car guys, these are farmers and mechanics. 

There are about 8 million light duty diesel trucks registered, 13% is about a million.

In reply to OldGray320i :

So, since you are worried so much about the societal cost impact, what is the cost of a preventable death?  Or what is the value to society to keep that person alive?   Based on your post, that seems like the number you question if we are spending too much money on.

BTW, there already is an incentive for OEM's to spend less money making the same standard as the rest of the OEMs.  It's part of an even playing field.  I've been pressing that issue for most of my career.  It's no different in the aftermarket.

Being 100% honest, I just look at this as "The government wants to mess around with something that is a big part of what makes life worth living" and it makes me extremely uncomfortable. Not because I don't believe their intentions are good, but because I don't trust them to not screw it up.

The biggest problem I see is how high it's going to raise the entry bar for anyone wanting to design performance parts. The initial hurtle is going to be so expensive that the guy with a really great idea has zero chance to bring it to market by himself. That's leaves innovation to the big companies that already have the pocket book to buy their way through the EPA process. 

Good news for the existing companies because they won't have to worry about the new upstart company. They can use the EPA as a club to beat them to death and buy or steal their idea.

Bad news for the community as a whole. Less innovation, fewer options, less competition. 

In reply to alfadriver :

That's kind of the "if we save just one life" argument.  That's a bit of a red herring related to the freedoms our nation is supposed to allow (yes, I know my freedom stops at your doorstep).

What is like to see is the entire population of violaters in real numbers compared to the total population of vehicle emissions, and how big is the effect on total pollutants from all sources. 

Sexy political arguments are usually total bulle36m3.  That's what this sounds like to me, hidden in terms of "effective enforcement for reasonable regulations". 

Can't stand the brodozers or the people with the thumping bass stereo blasting out rap (if they're cranking metal I'm down with it!), but in neither case are they in significant numbers that interrupt my daily life, and in the case of brodozers, how much physical harm are they really doing?

If the harm is that real, I'm on your side, but let's see what the real deal is, not just sexy 4000% or a million trucks numbers. 

In reply to OldGray320i :

I'm trying to point out that if you think we are spending too much, then you must have a value to a life.  I, personally, have no real idea how to calculate that.

And the reason I ask for one is that it then applies to the entire population- if we, as a society, want to not have 1000 extra preventable deaths via pollution- how much are we willing to spend to do that?  That's not a political argument, THAT is the core argument.  

On top of that argument, the job gains due to the rules also needs to be factored in- we may need to spend an extra $100 on a FM package that meets the rules, but if that means that someone makes a $100,000 annual salary- which adds a significant amount to the local economy- and then apply that to all the other parts- much of the society cost in meeting the rules just gets cycled back into the economy.  

So the whole value discussion goes quite a bit deeper than the simple- we spend too much vs. how many lives saved that we just started.

I am honestly looking at this as a possible job after I retire soon.  Those economics can't be overlooked.

TheRX7Project said:

Being 100% honest, I just look at this as "The government wants to mess around with something that is a big part of what makes life worth living" and it makes me extremely uncomfortable. Not because I don't believe their intentions are good, but because I don't trust them to not screw it up.

If you assume that the government screws everything up, then that's a natural path to go down.  But when you look at the actual change in air and water quality and health- there's really no reason to assume that.  As I see it.  And I do, realistically, see more room for improvement.

Toyman01 said:

The biggest problem I see is how high it's going to raise the entry bar for anyone wanting to design performance parts. The initial hurtle is going to be so expensive that the guy with a really great idea has zero chance to bring it to market by himself. That's leaves innovation to the big companies that already have the pocket book to buy their way through the EPA process. 

Good news for the existing companies because they won't have to worry about the new upstart company. They can use the EPA as a club to beat them to death and buy or steal their idea.

Bad news for the community as a whole. Less innovation, fewer options, less competition. 

 

there

As Kieth has pointed out SEMA is very much there to help.  And California is looking for a path to simplify the process....

With all of the experience in the OEM sphere, if that manages to pass it's way into the aftermarket (which it does), there will be innovation.  It's not as if solutions don't exist to make a very modified car fully compliant.   Sure, at some point, the cost to modify may be too much.  But then again, the cars OEM's are putting out have light years more performance than I be anyone could have expected- far more than anyone but an actual race driver could deal with at it's maximum.

alfadriver said:With all of the experience in the OEM sphere, if that manages to pass it's way into the aftermarket (which it does), there will be innovation.  It's not as if solutions don't exist to make a very modified car fully compliant.  

HKS had a CARB EO'd single turbo swap setup for FD RX-7s a long time ago.

I did some tune touchup on a 4th-gen F-body that was built by a Very Well Known shop that was making at least one kilohorse at the crank, in a full-cats emissions compliant application.  The scary thing was, looking at the tune, it was running 9psi boost but it was still using a 1 bar MAP sensor.  I didn't touch any of that, I just tweaked some idle air correction factors to make it less likely to stall under certain low speed driving conditions

I would guess that racing spews out far more total emissions than rolling coal. 

In reply to alfadriver :

I agree that innovation will happen. At least by the OEMs and the larger aftermarket companies that can afford it.

My concern is how much innovation will be stifled by the simple fact that the guy dreaming it up won't have the finances to get his idea through the EPA process. A one man garage operation won't have the budget to do it. 

If CARB will simplify the process, that's great. The question is can they also make it less expensive?

For instance, what is the cost to get a innovative intake manifold or turbocharger package CARB approved? I'm betting it's in the 5 figure range at a minimum.

 The scary thing was, looking at the tune, it was running 9psi boost but it was still using a 1 bar MAP sensor.

Eh, that just means it was not optimized in the 1-8 psi range. You can make 0 vac 'tuned' for your peak boost but you'll be rich and retarded (hah) at every boost level between 0 and peak.  Spoken as a man that made a caravan with a 37mm turbo go 97 mph in the 1/4 without a wideband.  I've polished some engine management turds i guess. 

Why would CARB want to make it less expensive? 

alfadriver said:

Uh, unless the parts are being smuggled into the country, there are import restrictions.  It's why Customs exist.  And I don't see the profit enough to smuggle them into the country.  Works the same way for cars.

You never bought anything from a private party seller for your car?  You have more confidence in Customs than I do.

The emissions compliant cars of today are, when taken as a whole, the most powerful group of automobiles that has ever existed. We live in a golden age of power, efficiency and environmental friendliness. My wife's appliance has 273 HP running 87 octane fuel- and it is 8 years old.

I am very interested in putting a more modern 5.3 swap into my 1990 C1500 because it will get me more power, reduced emissions and better gas mileage. It also won't look like a shipping container with wheels. I can currently get a Megasquirt, order a cam and some stuff for that 5.3 and probably still have reduced emissions over the original 1990 engine in there. 

With these changes, the days of buying a cam, porting the heads and doing some tuning might be doomed, but I'm guessing that being able to order CARB OE packages for an engine that give x, y, or z power might be on the horizon.

 am betting they'll have names like 5.3 STAGE ONE and 5.3 STAGE TWO and so on. 




 

I guess my only fear is that this will be a slippery slope, and at some point someone will point out that if wildly uncompliant smoke spitting diesels account for over half of all truck emissions, how much do race cars account for?  Emissions are still emissions whether they are on the track or on the road.  And then Motorsports as we know it will be forever changed. 
 

Diesel trucks are an issue though.  People don't delete diesel emissions equipment for power primarily, they do it for reliability.  Diesel emissions equipment just plain sucks.  Hell, Volkswagen admitted as much with the TDI scandal a couple years ago.  As long as that's true people will find work-arounds.

Number1Gaza said:

Diesel trucks are an issue though.  People don't delete diesel emissions equipment for power primarily, they do it for reliability.  Diesel emissions equipment just plain sucks.  Hell, Volkswagen admitted as much with the TDI scandal a couple years ago.  As long as that's true people will find work-arounds.

I Didn't realize how much of an issue this ^^^ was prior to this thread since I've got an "old" 7.3 without all the modern doodads.  I'd assumed the deletes were primarily for more power and possibly better mileage aside from the few who just want to be coal rollers.  The comments following this article about deletes in Canada were kinda shocking. https://www.trucknews.com/regulations/special-report-truck-news-investigation-finds-widespread-tampering-of-emissions-systems/1002145949/