Green Diesel Engineering - Compliance Form- California

Midwestdrifter said:

Only 20% of Americans live in rural areas. The remainder are in urban or suburban locations.

Regardless of how rural you are, the pollution ends up somewhere. Visit the high country of The Great Smoky Mountains NP. It has a perpetual haze from the pollution produced hundreds of miles away. The acid and sulfur are killing many of the trees.

Given that vehicles are mobile, and that pollution crosses borders, do you think its reasonable for the government to ignore pollution sources due to their current location?

If diesel (or MB) emissions gear is truly so onerous to maintain, we should let the true costs be borne by those who want to operate them. If those costs are too high, then the almighty dollar will drive a switch to other designs or fuel types.

Like many things, the effects of this behavior are dependent on the number of people who participate. I have spent time in areas (and countries) where 90% of the vehicles have no emissions controls, and most people use wood or charcoal for cooking and heating. The average person can expect to have 1-4 years removed from their life span.

I hear an endless stream of comments about young people and "millennials". Most to the effect that "they don't want to be responsible for their actions", or "they don't respect authority". I find this really ironic, as millennials are much more environmentally aware as a whole. On the other side of this coin we have members of other generational groups implying that emissions controls, which are required by the government (authority)for the public good, are evil. When the hammer comes down on a company who was operating in the grey area, the tales of woe, and the rationalizing start. Who doesn't want to be responsible for their actions? An interesting observation for sure.

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Extremely well put. I was going to highlight the important parts, but every word of the above is important.

When we all chose to purchase vehicles that cannot be economically operated without polluting, WE MADE A MISTAKE. We should correct that mistake as soon as we can manage it (that is certainly what I am going to do). In the mean time, we need to accept the consequences of our error, not foist them onto everybody else.

The thing that really bugs me about the "rip it out" arguments is that they all implicitly assume that if you think a given law is misguided, too expensive, or otherwise inconvenient, then the correct response is to ignore that law. The flaw in this logic is so obvious that I will not waste pixels articulating it. There ARE situations where ignoring a law is the ethical choice--this are called "civil disobedience". But that involves going to jail. Welcome to Civilization.

Sinatorj said:

And here is the main point of such arguments. I live in a small mountain town in Northern Arizona. I don't deal with crippling traffic, smog or really any of the other issues that plague a major metropolitan area. We are free of Smog regulations and what am I going to do as soon as I am out of warranty and all my emissions gear goes to crap? Prob gonna get rid of it and I will sleep like a baby afterwards knowing that I get better mileage and use fewer finite resources.

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Assuming your believe that your vehicle's emission has little or no effect on the immediate or further distance environment, what do you propose as or how would an effective solution work or be enforced where regulating pollution controls is based on geography?




PS.... I spent a few summers in the 70's helping restore the acid rain (nox) damaged forests emanating from neighbouring states....

Since apparently nobody anywhere has measured the resulting emissions of a GDE tune, this is actually a rather heady and baseless discussion. One thing - I've never seen a Sprinter "Rolling Coal".

NBB said:

Since apparently nobody anywhere has measured the resulting emissions of a GDE tune, this is actually a rather heady and baseless discussion. One thing - I've never seen a Sprinter "Rolling Coal".

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That is the point. When manufacturers design a vehicle to meet emissions standards, they do extensive testing, including life testing. They describe the emissions system, and what the critical parts are and warranty it for longer than the rest of the vehicle.

They, in effect, promise that the vehicle will meet emissions standards for some long period of time. If anything is changed, parts deleted, software changed, whatever, it by definition no longer meets emissions standards until it is fully retested.

Since Green Diesel did not do that, and it would be very expensive to do so, it is not compliant. It does not matter to the government if it is better or worse, it does not comply until it is tested to comply.

It is the same in the aviation industry I work in. If a change is made to an aircraft from the certified configuration, it is assumed to be not flightworthy until you prove that it is. There are plenty of companies that make changes and then test and certify them. It could be done in this industry too. Someone posted a link to the guide from California for doing so. I remember looking at it and it is a lot of work.

Regards,

Mark

Given the dramatic changes in noise, and the elimination of EGR flow, I can be fairly certain the increase in NOX is at least 10x. The difference in tailpipe odor is significant as well.

exactly. They eliminated the EGR function. If it were possible to meet emission requirements without an EGR no one would be using one

On my T1N the advanced injection timing also results in an increase in HC when cold, especially at high altitudes and low loads.

The primary purpose of CARB is to have high paying jobs and fancy offices for the dept. Their effect on pollution in CA vs if they didn't exist is questionable.

The only thing they do is enforce the concept that it is ok for cargo ships to pollute by forcing expensive reductions on land based entities.

In emissions reduction, you have to decide if the goal is to:
- reduce particulate and CO2 emissions - OR
- reduce NOx

The best way to increase fuel efficiency / CO2 reduction and burn up particles is to increase the burn temperature and burn time.

The best way to reduce NOx is to run at lower temperatures and add DEF.

We live in the suburbs east / downwind of Oakland and SF. For us, we would prefer that they focused on improved fuel efficiency and low particulate. All of the kids that live downwind from the ports with asthma would similarly benefit.

NOx is a significant contributor to lung related diseases and Ozone production.


https://www.lung.org/our-initiatives/healthy-air/outdoor/air-pollution/nitrogen-dioxide.html

So you would argue that California should not enforce emissions? That appears to be the end goal of your attack on CARB. If you have legitimate questions of the agencies efficacy, or enforcement practices, there are ways to discuss them. The reality is that most humans dislike any regulation that causes them inconvenience. Low speed limits around schools? STUPID! Air bags in cars? Only fools get into accidents! Mandatory vaccinations? Poison!

Regardless of your views on CARB, you cannot question the effectiveness of emissions controls on vehicles. In LA the current pollution levels are 40% of the 1940-1950s, and that's with several times the cars.


Cargo ships are a different matter completely. To my knowledge California has no control over what happens in international waters? By the logic you use, its futile to do anything to remedy the issue?

OrioN said:

Assuming your believe that your vehicle's emission has little or no effect on the immediate or further distance environment, what do you propose as or how would an effective solution work or be enforced where regulating pollution controls is based on geography?




PS.... I spent a few summers in the 70's helping restore the acid rain (nox) damaged forests emanating from neighbouring states....

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If you compare any car / van engine built in the 60s / 70s to something built in the past 25 years, the difference is night and day emissions and fuel efficiency wise.

Most people who are complaining about emissions now don't even know what real air pollution is compared to that era.

IMHO, people are spending way too much time thinking about air emissions from consumer products and not enough time thinking about how to reduce the effects of mining waste.

HarryN said:

The primary purpose of CARB is to have high paying jobs and fancy offices for the dept. Their effect on pollution in CA vs if they didn't exist is questionable

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Actually, the purpose was to reduce smog as was apparent in the 70's in LA, in particular, and their success is rather unquestionable, especially in contrast to 3rd world countries that are still at the same standard as LA 40 years ago.

However - my point - there is a lack of data for whatever it is GDE is doing. Always get the data. I'm sure it's "worse", but that is always relative. Consider these auto makers comply by the overall fleet, not just one vehicle. Some vehicles are better so others can be worse. I also question the vast economic waste these diesel emissions systems have cost by way of necessarily replaced parts and vehicles. Every dollar you spend - on anything - degrades our environment in some way, somewhere.

Midwestdrifter said:

NOx is a significant contributor to lung related diseases and Ozone production.


https://www.lung.org/our-initiatives/healthy-air/outdoor/air-pollution/nitrogen-dioxide.html

So you would argue that California should not enforce emissions? That appears to be the end goal of your attack on CARB. If you have legitimate questions of the agencies efficacy, or enforcement practices, there are ways to discuss them. The reality is that most humans dislike any regulation that causes them inconvenience. Low speed limits around schools? STUPID! Air bags in cars? Only fools get into accidents! Mandatory vaccinations? Poison!

Regardless of your views on CARB, you cannot question the effectiveness of emissions controls on vehicles. In LA the current pollution levels are 40% of the 1940-1950s, and that's with several times the cars.


Cargo ships are a different matter completely. To my knowledge California has no control over what happens in international waters? By the logic you use, its futile to do anything to remedy the issue?

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I don't disagree with emissions management, I disagree with the approach.

Let's take an example:

a) VOC emissions from business / commercial operations
- For many years, LA had a "5 lb rule". A business could emit up to 5 lbs of VOC (solvents) per day without having to add any kind of abatement.
- If their emissions crossed into "5.1 lbs", they now had to reduce this by 99% and "certify" compliance.
- The cost of this was about $200K in equipment and another $100K a year in natural gas costs
- The emissions in some cases were so low that they were nearly below detection limits, but CARB would keep fining them daily until they could prove certification.

If they had instead focused on "get under 5 lbs per day, the cost would have been very small.

Of course they only went after the businesses with a deeper pocket that they could extract daily fines. A dry cleaner across the street could be emitting 200 lbs per day and they were given exemptions.

__

As far as ships, yes the cargo ships like to hide behind the International maritime law, but LA could easily have simply denied allowing high pollution ships to enter port or applied a high tax on them. They had other options.

NBB said:

Actually, the purpose was to reduce smog as was apparent in the 70's in LA, in particular, and their success is rather unquestionable, especially in contrast to 3rd world countries that are still at the same standard as LA 40 years ago.

However - my point - there is a lack of data for whatever it is GDE is doing. Always get the data. I'm sure it's "worse", but that is always relative. Consider these auto makers comply by the overall fleet, not just one vehicle. Some vehicles are better so others can be worse. I also question the vast economic waste these diesel emissions systems have cost by way of necessarily replaced parts and vehicles. Every dollar you spend - on anything - degrades our environment in some way, somewhere.

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Emissions laws and enforcement did in fact reduce pollution substantially.

What I don't agree with is the need for a completely independent set of laws for CA vs at the federal level. CA and the local cities used this as a way to black mail companies into paying fees that have nothing at all to do with emissions reductions.

Enforcement is different than the need for a separate set of laws at the state vs federal level on exactly the same thing.

Just keep in mind that in CA, every fall we have fairly large forest fires that dump massive amounts of particulate and other stuff into the air. That is a natural phenomenon.

Yet, you can be almost certain that the weeks of Thanksgiving and Christmas, they will call for a "spare the air day" and ban having a fire in the fireplace. They do this every year no matter what, so we all know it is contrived.

Midwestdrifter said:

NOx is a significant contributor to lung related diseases and Ozone production.


https://www.lung.org/our-initiatives/healthy-air/outdoor/air-pollution/nitrogen-dioxide.html

So you would argue that California should not enforce emissions? That appears to be the end goal of your attack on CARB. If you have legitimate questions of the agencies efficacy, or enforcement practices, there are ways to discuss them. The reality is that most humans dislike any regulation that causes them inconvenience. Low speed limits around schools? STUPID! Air bags in cars? Only fools get into accidents! Mandatory vaccinations? Poison!

Regardless of your views on CARB, you cannot question the effectiveness of emissions controls on vehicles. In LA the current pollution levels are 40% of the 1940-1950s, and that's with several times the cars.


Cargo ships are a different matter completely. To my knowledge California has no control over what happens in international waters? By the logic you use, its futile to do anything to remedy the issue?

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Last time I checked, you have a T1N. I have no issues with that, but let's be realistic. Even on the worst day of the VW non compliance, it wasn't any worse than what you are driving every day.

It is a real stretch to drive a T1N, drive many thousands of miles around the world, and then complain about emissions from others.

Again, I don't have any issues at all about your approach to life and how you use your van, but let's put some reality into the discussions.

HarryN said:

It is a real stretch to drive a T1N, drive many thousands of miles around the world, and then complain about emissions from others.

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I have not seen anyone complaining about emissions from others (except your "whataboutisms"). Rather, people are complaining about others breaking our laws. We all agree that it is your right to not like a law. You seem to believe that you have the right to unilaterally choose to ignore whichever laws you don't like.

Do I understand your position correctly?

NBB said:

However - my point - there is a lack of data for whatever it is GDE is doing. Always get the data. I'm sure it's "worse", but that is always relative. Consider these auto makers comply by the overall fleet, not just one vehicle. Some vehicles are better so others can be worse. I also question the vast economic waste these diesel emissions systems have cost by way of necessarily replaced parts and vehicles. Every dollar you spend - on anything - degrades our environment in some way, somewhere.

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The lack of data (for what GDE is doing) is a situation brought about by GDE. The EPA inspection report mentions that GDE chose not to develop data on the changes they effected due to the costs of doing so.

Pollution controls on internal combustion engines were introduced through legislation and regulation after environmental and health issues were analyzed and traced back to those sources. The systems that resulted from the EPA (and other organizations) regulations regarding emissions were an engineering response to the requirement to limit harmful emissions. The economic cost of those systems is a factor in determining whether those emissions can be cost-effectively controlled. If they cannot, and no rebuttal of the claim that they are known to be harmful to the environment and health is successful, then the products causing those emissions will be eliminated from the marketplace. This is a market-oriented approach to regulation and control, rather than a dictatorial approach, and one that I vastly prefer. It is ponderous, but allows the greatest opportunity for innovation and creativity spurred by economic opportunity to solve the problem.

People who choose enrich themselves through a direct/deliberate violation of the rules for the "game" are cheating the system. Although there may be occasions where "civil disobedience" is the only way to cure an injustice (e.g., Rosa Parks not sitting in the back of the bus) I'm hard pressed to accept that the injustice of emissions controls warrants civil disobedience as a cure. The United States has a reputation for supporting large numbers of individualists, and I respect individualism. However, as a society we also need to understand that some of our individual actions, when coordinated with hundreds of thousands or millions of others (e.g., driving vehicles with emissions) can cause significant injury to the environment and to other individuals. The rules limiting vehicle emissions came about because of the harmful effects of vehicle operation at scale. The effective way to enforce those rules is to do so consistently, which means taking legal action against anyone who violates them. This means taking action against corporations like Volkswagen that violate the laws in their products, and it means taking action against individuals operating outside the law to modify the emissions systems post-production. The magnitude of the harm caused is different; the penalties enacted will be as well. But the small violations can't be overlooked, or else large-scale practice of small violations will be encouraged, leading to large violations.

avanti said:

I have not seen anyone complaining about emissions from others (except your "whataboutisms"). Rather, people are complaining about others breaking our laws. We all agree that it is your right to not like a law. You seem to believe that you have the right to unilaterally choose to ignore whichever laws you don't like.

Do I understand your position correctly?

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If someone passes a law that changes the age of drinking a beer from the current 21 to 70 years old, then should I follow this law and stop drinking beer?

I think I am perfectly within my place to say that just because some idiots passed a law, that doesn't mean I agree with it.

We live in a republic / oligarchy, not a democracy. No one gave the general population a chance at a 2/3rd vote on these laws. About the only thing that we can do is complain and call it out - and that is what I am doing.

HarryN said:

If someone passes a law that changes the age of drinking a beer from the current 21 to 70 years old, then should I follow this law and stop drinking beer?

I think I am perfectly within my place to say that just because some idiots passed a law, that doesn't mean I agree with it.

We live in a republic / oligarchy, not a democracy. No one gave the general population a chance at a 2/3rd vote on these laws. About the only thing that we can do is complain and call it out - and that is what I am doing.

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Your example is nonsense. And we live in a democratic republic, where we elect representatives to govern us. A pure democracy where everyone votes on everything is unworkable, beyond the village level.

But back to your example...….Raising the drinking age without it being justified by drunks below a certain age causing harm would be unreasonable.
Vehicles DO cause harm as a result of their exhaust. It is very reasonable to control the levels of harm caused by those vehicles.
Maybe we should just revoke the right to drive for those caught violating those laws.

HarryN said:

If someone passes a law that changes the age of drinking a beer from the current 21 to 70 years old, then should I follow this law and stop drinking beer?

I think I am perfectly within my place to say that just because some idiots passed a law, that doesn't mean I agree with it.

We live in a republic / oligarchy, not a democracy. No one gave the general population a chance at a 2/3rd vote on these laws. About the only thing that we can do is complain and call it out - and that is what I am doing.

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You didn't answer the question:

Is it your position that you have the right to unilaterally choose to ignore whichever laws you don't like?

avanti said:

You didn't answer the question:

Is it your position that you have the right to unilaterally choose to ignore whichever laws you don't like?

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Everyone has the right. It's called or known as freewill.