Opti said:In reply to STM317 :
Companies outside the US have no problem with it\
If the demand is there its plenty easy to set up a company, do the R&D here and send it overseas to be manufactured and "sold" by a company in a different country
And those parts would be illegal to import.... Pretty easy target.
In reply to Opti :
I would imagine that more and more states are likely to be doing more and more testing too. And if not, then it's pretty easy to spot packages from certain companies in customs and confiscate the illegal products. It happens all the time with other stuff.
That also shifts the responsibility completely onto the consumer. If you have to go outside of your country to buy something that's pretty well know to be illegal, then the consumer is looking at much stiffer penalties for themselves as well. Right now they can say "I didn't know _____ was illegal! They never should've sold it to me/installed it for me". But that deniability disappears when you're illegally importing things either for your own private use or to put on paying customer's stuff.
In reply to STM317 :
Well when you get caught and a shipment is seized, you are outside of the US jurisdiction and simply change the name of your fake company and go on about your business until you get caught again. Its super common.
This also largely relies on the competency of the government to make laws and regulations without loopholes and enforce them thoroughly. Which they are pretty bad at since this stuff is already illegal and still happening everyday.
Which results in little to no change in consumer behavior
In reply to Opti :
Seems like you are over estimating the number of cars that are tampered with..... And the number of people actively trying to tamper with their cars. The reason this all blew up is because the diesel modifiers got to a point that it was clear they are not race cars- so they could be the largest single segment of vehicle owners who are modifying their cars in illegal ways.
BTW, having seen enforcement in action, I would not question the competency as much as you do.
FYI, the crackdown has had a noticeable effect on easily available diesel mods. If you want to delete a cat or EGR, you're not going to get that from a US based company anymore. Even gas engine tunes are more likely to have a CARB EO if you get them from a major vendor like Superchips.
Note that I said easily available. It's still possible, but taking those parts out of the JEGS and Summit and Banks catalogs drops the number of people using them considerably.
In reply to Opti :
If the consumers have to jump through a bunch of hoops, or go through some black market and pay a bunch more for the product because it's being purchased through illegal means and might be seized by customs then I think it certainly can change consumer behavior.
If somebody is willing to do illegal things and isn't swayed by hefty fines then they'll probably find a way. You probably can't stop everybody. But each hurdle put in place makes it more and more likely to be followed. Big fines will stop most of the companies from selling non-compliant items. If you have to illegally import goods, that adds import/export crimes on top of emissions crimes, and it means you deal with US customs and the EPA. The idea is to stop as many people as you can as efficiently as you can. That seemed to be your concern at the start of this.
In reply to STM317 :
No the idea is to reduce emissions. My point is this probably isnt the best way to actually reduce emissions. As Alfa just said its a small number of people actually tampering with emissions, and they are already breaking the law, what makes anyone think they will care if you start going after the people selling parts (which is about all the EPA did) and not them.
About import/export crimes its literally happening right now. People think all the manufacturers stopped making these parts when they started getting cracked down on, many of them just went off shore. Yes some of the larger more reputable ones didnt, but when your whole thing is diesel performance, what are you going to do, shutter the whole business or find a loophole and go offshore, and they arent hard to find.
My whole point is these regulations in their current form will have little impact on consumer behavior, just like they havent in the past, which in turn will result in little to no impact on actual emissions. Where could you cast a broader net and affect more than the small number of tampered vehicles, and actually see an improvement.
The government also wanted to crack down on drugs. They made it illegal to import them, and yet millions of people still got them. They threatened the producers and users will jail time (not even fines), no one cared. Drug use actually got worse.
So yes I have no faith that the enforcement will be effective or have any effect on consumer behavior, which means it will have no effect on emissions.
In reply to Opti :
What would be a better way, then?
BTW, over the time I've been a driver, I would pretty much say that the laws have changed consumer behavior a LOT. Back in the 80s, it was both common and easy to bypass the stuff on the cars. Now it's far, far less so. Especially with the car being able to tell there's been a modification, and many states having car inspections that include that feature.
If there's little to buy, then there's not much of a chance to break the law.
In reply to alfadriver :
Its not very hard to defeat emissions nowadays. Remove components you dont want, tune it. With most flashable and cracked ECUs you can just turn the readiness monitors off so they show NA, and turn off the codes related to the systems you removed. You will pass inspection in like 47 or 48 states because no one actually does a visual inspection. Even people in California, just revert to stock for smog, or if they have a hook up get an illegal inspection.
Or you can go old school. You pulled your cats off, then just put a defouler on the rear o2.
Most of TX doesnt even have emissions inspections.
Just because something is a bad idea doesnt mean I have to have a fully formed alternative. If my wife asks me if we can buy an elephant and I tell her its a bad idea, I dont have to have an alternative thats an equally large mammal, the alternative is just dont do it because its stupid.
The most recent thing we did that actually reduced emissions were the lockdowns (no im not saying that was a good or bad idea), and there is something to be learned there. Want less emissions, have less cars on the road. Do I think thats the governments place, probably not, but can you incentivize car pooling (TX does), can you incentivize remote work?
I think we are at the point of diminishing returns on ICE emissions. Probably why we are seeing cars become less reliable overall (chasing CAFE), and emissions cheating by OEMs. Not that it wont get better, it will get marginally better, but seeking a major reduction in emissions isnt going to happen by chasing less than a percent of the cars on the road. You want to reduce automotive emissions by an actual material amount, it will require a massive leap in technology or a huge adoption of electric cars (and even then what produces the electricity for the cars?0
About the "small number of people" tampering with emissions: the Bully Dog penalty a couple of years ago was for 330,000 devices. That's one manufacturer.
I agree that the new car emissions standards are definitely chasing diminishing returns. They're getting crazy tight, to the point that cars are cleaning the air in some areas and causing all sorts of expensive complication. But I do think that preventing people from removing those emissions control systems is a good idea as they have an outsize effect. They're the gross polluters, so they're the ones you knock down first. Doesn't mean we don't go after mines and power plants and ships, the EPA is not just one person or branch.
In reply to Keith Tanner :
Im just using the EPA estimates of 500,000 deleted diesels. Yes one manufacturer had 330,000 devices (not all will be deleted, which is what the EPA was talking about), it is also one of the main manufacturers of only a few that do it. Look they went after Bully Dog one of the big guys in the industry, yet here we are a few years later and we still have the problem. To the consumer it just meant you got a tuner from someone else, or used EFILive or HPTuners. No material effect on consumer behavior.
When there are 285,000,000 registered cars, half a million is not a lot.here
In reply to Keith Tanner :
I agree you go after the gross polluters first, but im not talking about people, im talking about on a macro level. What industry/process can you actually affect to give you largest reduction in emissions. I doubt that its less than 2 tenths of a percent of the cars on the road. They already made doing these things illegal, and the people that dont want to break the law dont do them, and everyone else doesnt care. Chasing that tiny percentage doesnt have good ROI. Its the same reason six sigma was mostly abandoned in manufacturing, it becomes so costly chasing every problem, that productivity goes down.
We should seek to reduce emissions as a whole and realyze that like in everything there is an acceptable amount of "slip" that you cant reasonable catch, be it because of enforcement or loopholes or people just not caring.
If 99% of the population doesnt tamper with their car, then make their car better or if you cant ,incentivize less cars, if you cant then look to other industries.
In reply to Opti :
You see it as easy, but I don't think most people would be doing it. You keep saying that it's a small population that we are worried about, but seem to also think that it's rampant. Which is it?
Virtially all shops out there will not be violating the law to fix your car, and DIY'ers are prety rare- so for a vast majority of people, their cars still meet the law.
None the less, I still don't see an alternative. If we are getting into marginal improvements, then going after 500,000 trucks that are gross polluters is a very big deal. And I am fully aware of the new laws, next year is the real first year for LEVIII set of rules, and by 2025, the corporate fleet average will be SULEV30, which is really small- making the impact of those trucks really big on a relative basis.
Can we go cleaner? I think SULEV30 is good enough, and the next step would be to make sure OEM's are more robust to reality- I'm more confident in that than getting tighter for new cars. Hearing what CARB is actually saying, they are far more interested in robustness than anything else. But California STILL has a HC and NOx problem- not CO. They are saying that directly to us.
But lets get back to those companies who take what we (the auto industry) are legally required to put on, test, and prove that they work. I honeslty don't care that they do it on a "small" basis- they are taking our requirements- so they should be held responsible.
BTW, OEM's don't cheat on emissions testing. Just because VW did does not mean it's common. We test competitor cars all the time, and find that they are all complying very well.
Still, provide an alternative to actually prosecuting the law so that air quality can get better. Which it very much does in parts of your state.
But if you HONESTLY think OEM's cheat, and everyone with a car is breaking the law- I don't know what to tell you. I see this stuff first hand, and that's just not the case.
Opti said:In reply to Keith Tanner :
Im just using the EPA estimates of 500,000 deleted diesels. Yes one manufacturer had 330,000 devices (not all will be deleted, which is what the EPA was talking about), it is also one of the main manufacturers of only a few that do it. Look they went after Bully Dog one of the big guys in the industry, yet here we are a few years later and we still have the problem. To the consumer it just meant you got a tuner from someone else, or used EFILive or HPTuners. No material effect on consumer behavior.
When there are 285,000,000 registered cars, half a million is not a lot.here
Just to be clear, any software that changes how an engine performs would fall under the heading of an emissions defeat device without an EO that proves its legit. So There may be half a million fully deleted diesel trucks running around on public roads, but there are many times that number of vehicles with illegal tunes, down pipes, camshafts, headers, etc. That's how you bust a company for selling 300k tuners in a world with 500k deleted diesels.
If you believe that EFI Live and HP Tuners are going to go much longer without some penalty as well, or that they're not scrambling to prepare for that possibility then I think you're crazy. In the first year that they actually bothered enforcing the rules they busted 31 companies and numerous others quit selling illegal products in order to proactively avoid large fines. If other companies didn't get the message, then they're eventually going to be penalized as well. You're judging the impacts of the process very early in that process.
Opti said:In reply to Keith Tanner :
I agree you go after the gross polluters first, but im not talking about people, im talking about on a macro level. What industry/process can you actually affect to give you largest reduction in emissions. I doubt that its less than 2 tenths of a percent of the cars on the road. They already made doing these things illegal, and the people that dont want to break the law dont do them, and everyone else doesnt care. Chasing that tiny percentage doesnt have good ROI. Its the same reason six sigma was mostly abandoned in manufacturing, it becomes so costly chasing every problem, that productivity goes down.
We should seek to reduce emissions as a whole and realyze that like in everything there is an acceptable amount of "slip" that you cant reasonable catch, be it because of enforcement or loopholes or people just not caring.
If 99% of the population doesnt tamper with their car, then make their car better or if you cant ,incentivize less cars, if you cant then look to other industries.
I will say one thing- if people weren't cheating, the rules would not be getting tighter.
But, once again, every emissions source in this country has rules they have to meet. Some have better lobbying than others, I will say that. What degree of "slip" is ok? Letting things just slide is an incredibly slippery slope that is impossible to apply evenly to everyone.
As for your last line, I'm not sure what you are getting at. What do you meanby "make their car better"?
In reply to alfadriver :
No I don't think it common, in fact I keep saying that it's a tiny portion of the population so spending a bunch of money going after them is dumb.
It is easy though.
OEMs do cheat, I didn't say it was common, but the fact that it happened at one of the largest automakers in the world should tell you something. VW obviously cheated, Mercedes and Opel had a little different interpretation of the law and were "technically legal" because of a loophole.
No law has a 100 percent compliance, none. We are probably currently at 99 percent compliance with emissions laws. That's pretty good. I'm not saying we all the sudden let everyone do whatever they want but spending a bunch of time a resources trying to get all these off the road is a loosing battle, because it won't happen and we won't see a reduction in actual emissions which should be the point.
The government cracked down on alcohol, people still drank. The cracked down on drugs, didn't stop people. Literally you can't get 100 percent compliance, but we are pretty damn close
VW cheated on one line of their cars, not all of them. So to extrapolate that to all of us, well... Like I've said, I've seen plenty of data on competitor vehicles, and they are not cheating. Unless you can come up with real data outside of the single VW powertrain, then I'll stick with my position.
Are there creative interpretations? Or are makers pushing the limits? Sure. But it still results in clean air.
BTW, the repercussions of VW's actions has been some massive changes in the laws in the EU. Thanks to VW cheating, all of us suffer.
None the less- the laws have to be prosecuted the best way we can, and these diesel modifiers are breaking the law. You may think that it's not helping, but again, provide data. Not "well, it's 10x"- 5,000,000 cars represents 1/4 of the new car market every year, so even that it a lot. My data of emissions has it considerably more than that.
So provide an alternative to make sure we have clean air. If this isn't the most effective way, what is?
In reply to alfadriver :
Part smartass remark, part serious question: are EPA regs finally being enforced on military vehicles or are they still exempt?
Edit to expand a little bit. You mentioned finally cracking down on shipping, which was a big outlier exemption. The military had been exempt for a really long time from any sort of regulation but it wasn't mentioned beyond foot notes because you don't question the military.
Obviously you're not going to see hybrid emissions from tanks and MRAPS and such, and I'd heard stories at least that it was to keep military fuel consistent for a majority of vehicles, which does make sense, but they've got a buttload of vehicles and vehicle types in 170+ nations around the world. That's a lot of emissions to go unchecked.
Shipping has been regulated since about 2014, so it's been a while.
But I'm not aware of any military regulation for emissions. Which sucks for service members who have to live around that equipment.
In reply to alfadriver :
If Chrysler and Opel are turning off their emissions equipment and then get sued because of it, and then saying we'll because of this loophole it's technically legal, does that actually result in less emissions? I never said all OEMs cheat. I said OEMs cheat (maybe I should have said some, so you don't take personal offense to it) which is true, and illustrates that we are at the bleeding edge of reducing emissions without massively increasing cost, and we are chasing the law of diminishing returns.
You compare 500k cars to the new car market every year, that doesn't work. The EPA said there are 500k on the road, so you compare that to the rest of the cars on the road which is 285 million. They aren't saying there are 500k deleted diesels added every year.
Again im not saying you quit enforcing it, our current enforcement has great compliance as a whole and because of that we have seen less emissions, but you don't add a bunch of time and resources to a problem that already has massive compliance, because you won't actually change behavior. People will still break the law and still delete diesels and the end result is no change in emissions.
People lose track of the actual goal, which is to reduce emissions. Do you think that an additional crackdown on deleted diesels will actually lead to a material reduction in emissions, when these people have already shown they are more than happy to break the law? Also do you believe that it is the most effective way to reduce emissions, because you have to consider opportunity costs, what are we not doing because we are doing this?
In reply to Opti :
If it's not clear, yes, I do think enforcement on deleted diesels makes a difference. The enforcement of the law costs quite little in the scheme of things.
The alternate time would be spend writing new laws and coming up with more expensive ways to measure even lower targets.
The system is quite capable of multi-tasking. While diesels get enforced, FM can certify new parts that meet the letter of the law, OEM's can research more effective ways of lower emission, new models of the climate are worked on, and better solutions to basic scrubbers for large ships are being developed. Etc.
The enforcement will force the suppliers to not be quite as happy to break the law, which will take resources from people so willing to break the law. And the effort to do that is really minor, other than the teeth gnashing that happens on forums.
Again, what alternative is there to reduce the emissions that's not already being done? You can't just say that this isn't the right way forward without providing an alternative, let alone one that is more effective. Remember, you can only enforce laws that exist- so all of the cars you worry about have no laws that are applied or can be applied to them. Whereas these deleted diesels are quite modern, and have very specific laws that can be applied to them. That's why you see that. Heck, even the pre OBD era cars have limited laws applied to them, making monitoring of them quite expensive- it's a WHOLE lot cheaper to enforce laws on deleted diesels vs. rolling road testing on a 1990 car.
Opti said:People lose track of the actual goal, which is to reduce emissions. Do you think that an additional crackdown on deleted diesels will actually lead to a material reduction in emissions, when these people have already shown they are more than happy to break the law? Also do you believe that it is the most effective way to reduce emissions, because you have to consider opportunity costs, what are we not doing because we are doing this?
Isn't that the point of the EPA paper that started this discussion? I've linked it again below, 550,000 deleted trucks=9 million extra cars. I'm not sure that's as insignificant as you claim.
Fueled by Caffeine said:
https://arstechnica.com/cars/2020/12/truck-emissions-mods-pollute-more-than-dieselgate-epa-says/
Basically the epa estimates half a million diesel trucks with tunes or other defeat devicds have the same emissions as an extra 9 million vehicles on the road.
APEowner said:rothwem said:If you think about it, the only reason that the systems are able to be unreliable is because the enforcement of their removal is so lax. Most people I've met with newer diesels aren't scared of the emission system costs because they'll just straight pipe them once they do. If there was actual sniffer testing for diesels, then people would refuse to buy until manufacturers made the systems better. Maybe it would kill diesel, but maybe the parts would just get better.
Mechanically, I don't think a DPF, DOC or SCR system is that complex, the issues come from high temps and high temp materials are getting better and better everyday, though increased nickel prices might drive up costs.
Interesting perspective. That implies the the OEMs aren't doing as much as they can to make the systems reliable. I'm not convinced that's true. I've spent too much time working with OEMs to thing that reliability isn't a concern. Also, despite the impression one might get from the internet it's not like every diesel after treatment system fails spectacularly and expensively. I'm not saying that there's no room for improvement. There clearly is, but there are many trucks that go several hundred thousand miles with the original after treatment systems intact. My Dodge has just shy of 100k miles with zero issues (knocks on wood).
My only complaint of any significance about my truck is the fuel mileage. It's abysmal but, I'm willing to put up with that for the performance and clean air. If my truck has an after treatment system failure I'm going to fix it rather than delete it.
I work for a big Tier 1 supplier also, and I'm cynical to know that a lot of it comes down to the money--if they'll pay for Inconel, we'll give them Inconel. If all they'll pay for is stainless, then guess what the part is made from. Hell, if the durability test warrants it and the customer will pay, we'll make it from NASA Space Shuttle rocket nozzle material. Also, durability testing varies a lot from OEM to OEM, and even model to model within an OEM. I've seen a "lifetime" durability test before that EVERYTHING passes. That stuff is all based on market research, i.e., does the customer care if the car breaks early. If hotshot carrier drivers suddenly realize that they can't straight-pipe their Duramax after a year, they're not going to be buying Duramax much longer.
And yes, I realize that enforcement is state to state, and that is a large part of the issue. Conceptually, I like the idea of states having a say on things that are local to them, but unfortunately, emissions are a world-wide problem and it doesn't matter if Texans or Arkansans think it's not a big deal.
In reply to alfadriver :
You say they can only enforce laws that exist, which is true but they can always right new laws (not that I think it's a good idea). The government has never had a problem conjuring up a new law for something that hasn't been regulated before.
You won't get 100 percent compliance on any law, it hasn't ever happened. You already have massive compliance with the law, and spending resources going after the sliver of a minority is ridiculous. They don't care. Plus the EPA isn't actually going after them they are going after parts manufacturers, which doesn't and hasn't affected consumer behavior. You have to affect consumer behavior for this to have any result, and they currently aren't doing that.
They also don't have infinite resources so this is a zero sum game. If you spend money and labor going after this tiny subset of the population more than you already are, it takes away resources and time from doing something else, that might actually help.
You know like maybe going after industries that can emit as much as they want as long as they buy emission credits, or the ones that made the water in flint toxic, or the ones that dumped oil into the Amazon River for 20 years.
None or this even matters if we reduce our auto emissions by 2% (by somehow miraculously getting 100 percent compliance on deleted diesels) if China or India doesn't slow down emissions at all.
We are over here freaking out about small potatoes with deleted diesels and ignoring the things that are so big a little movement could actually see some material improvement.
If the government cared so much and this wasn't started by some senator getting coal rolled, how come all of our military diesels don't have emissions equipment? I mean it's all good right, it super reliable and doesn't decrease performance, would be good to reduce emissions, and we have to go after every little thing right?
In reply to Opti :
-Nobody is saying we're going to hit 100% compliance. That shouldn't prevent us from trying.
-The federal government is massive. The EPA rules against coal rollers AND go after other industries that pollute (assuming the laws are on the books)
-You keep using the failure of the drug war as a reason not to write/enforce emissions laws. It's a bad example. I like tuning my car to go faster but it's not a chemical addiction, or something that humans/animals have been doing since the dawn of time.
In reply to CrustyRedXpress :
We you have 285 millions cars on the road , and you are hunting the last 500k, you are absolutely shooting for 100 percent compliance. Which has literally never happened and won't happen. I'm not saying don't try to enforce it, we are already trying to enforce, you can't and won't catch everyone, especially if you aren't actually going after the actual people doing it. Don't just let it go, but also don't throw a ton more resources at it because you won't see results.
I use the war on drugs and prohibition because it's such an obvious one, but give me any law or regulation that has 100 percent compliance, ever. Even if you get 100 percent compliance you've reduced vehicle emissions (and only vehicle emissions) by like 3 percent as a high estimate. Vehicle emissions are supposed to be like one 1/5 of US emissions, so in a fantasy land were you get all the trucks off the road, you actually managed to reduce just US emissions 6 tenths of a single percent. When in reality you'd be lucky to get a fifth of that. That why I think it's dumb to throw a bunch of resources at it ON TOP of what we are already doing.
Yes the EPA and federal government is massive, they are also incredibly inefficient. Doesn't mean they have unlimited resources, putting a bunch of people on this takes them off of something they could be doing that might actually make a difference. It's called opportunity cost.
At a macro level the government should be focusing on results, what reduces emissions the most for resources spent. So if this is a losing battle that isn't going to result in change they should absolutely not even try. That doesn't stop what's there, but don't throw even more resources at a losing battle
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