Green Diesel Engineering - Compliance Form- California

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smiller

2008 View J (2007 NCV3 3500)
Not to rain on anyone's freak-out fest, but email is hardly a channel for formal legal notification. One could legitimately have changed their email address, or a message may not be received for any of a host of reasons. In this case CARB would have to request that the DMV block your registration renewal absent due process or even any proof that the individual has been notified of a violation or given any opportunity to remedy, and this seems rather unlikely. As an individual California GDE user the best thing to do might be to just sit tight and see if anything ever really happens.

As to other states, impossible to say. Enforcement of this sort of thing varies wildly from relentless in California to just don't care (or at least not enough to devote resources) in others, and everything in between. But bottom line if you are not registered in California I wouldn't exactly be up nights over this.

It certainly didn't seem wise for GDE to market products in California given CARB's well-known penchant for strict enforcement, that much is for sure.

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OrioN

2008 2500 170" EXT
Not to rain on anyone's freak-out fest, but email is hardly a channel for formal legal notification. One could legitimately have changed their email address, or a message may not be received for any of a host of reasons. In this case CARB would have to request that the DMV block your registration renewal absent due process, or even any proof that the individual has been notified of a violation, and this seems rather unlikely. As in individual California GDE user the best thing to do might be to just sit tight and see if anything ever really happens.

As to other states, impossible to say. Enforcement of this sort of thing varies wildly from relentless in California to just don't care (or at least not enough to devote resources) in others, and everything in between. But bottom line if you are not registered in California I wouldn't exactly be up nights over this.

It certainly didn't seem wise for GDE to market products in California given CARB's well-known penchant for strict enforcement, that much is for sure.

.
Tick.... tick.... tick.... tick.....


Don't fool yourself in thinking that they won't go the distance, and with you.
 

220629

Well-known member
...

As to other states, impossible to say. Enforcement of this sort of thing varies wildly from relentless in California to just don't care (or at least not enough to devote resources) in others, and everything in between. But bottom line if you are not registered in California I wouldn't exactly be up nights over this.

It certainly didn't seem wise for GDE to market products in California given CARB's well-known penchant for strict enforcement, that much is for sure.

.
If my recollection is correct.
Being that GDE modifications only applied to NAS aka NAFTA MY 2001 - 2007, the States, and even Feds, that just don't care may be the smart ones. The T1N and first 2 years of NAS Sprinters will age out of service on their own. "Bigger fish to fry" comes to mind unless CARB is trying to send a message and GDE was the low hanging fruit.

Even then, the newer ECM aka ECU all have better protections against illicit emission control modification.

Keep it civil and carry on. :thumbup:

:cheers: vic
 

avanti

2022 Ford Transit 3500
If my recollection is correct.
Being that GDE modifications only applied to NAS aka NAFTA MY 2001 - 2007, the States, and even Feds, that just don't care may be the smart ones. The T1N and first 2 years of NAS Sprinters will age out of service on their own. "Bigger fish to fry" comes to mind unless CARB is trying to send a message and GDE was the low hanging fruit.
It isn't just "low hanging fruit". There is no doubt a long tail of small bottom-feeding businesses doing this kind of crap. They may well add up to serious impact in aggregate. I am sure the regulators do want to send a message that just being small does not make them invulnerable.
 

smiller

2008 View J (2007 NCV3 3500)
If my recollection is correct.
Being that GDE modifications only applied to NAS aka NAFTA MY 2001 - 2007, the States, and even Feds, that just don't care may be the smart ones. The T1N and first 2 years of NAS Sprinters will age out of service on their own. "Bigger fish to fry" comes to mind unless CARB is trying to send a message and GDE was the low hanging fruit.

Even then, the newer ECM aka ECU all have better protections against illicit emission control modification.
It may not be much more than they were simply in violation of CARB regulations and got caught. But 'bigger fish to fry' probably does apply in that while it doesn't cost much to go after the source (GDE) it would be a complex proposition to try to identify every user, formally contact them (in the absence of valid contact info in many cases), and then track whether they have come back into compliance, and then enforce after some time period if they have not. CARB has gone after many such violators on a corporate level but I'm not aware of a case when they have gone after thousands (or perhaps tens of thousands, as in other examples) of private purchasers, often with scant records as to who/what/when/where, to try to enforce removal of equipment on an individual basis. That would be an enormous task and as such unlikely.

So again I would not exactly be holding my breath waiting for my registration to be canceled out of the blue, in California or any other state. As to whether it's a bad idea to sell illegal modifications in California... well, ya.
 

OrioN

2008 2500 170" EXT
It may not be much more than they were simply in violation of CARB regulations and got caught. But 'bigger fish to fry' probably does apply in that while it doesn't cost much to go after the source (GDE) it would be a complex proposition to try to identify every user, formally contact them (in the absence of valid contact info in many cases), and then track whether they have come back into compliance, and then enforce after some time period if they have not. CARB has gone after many such violators on a corporate level but I'm not aware of a case when they have gone after thousands (or perhaps tens of thousands, as in other examples) of private purchasers, often with scant records as to who/what/when/where, to try to enforce removal of equipment on an individual basis. That would be an enormous task and as such unlikely.

So again I would not exactly be holding my breath waiting for my registration to be canceled out of the blue, in California or any other state. As to whether it's a bad idea to sell illegal modifications in California... well, ya.
"It may not be much more than they were simply in violation of CARB regulations and got caught."

In order for GDE to be noncompliance, CARB would have to have the proof that sales occurred. By GDE's own words they have complied and submitted the evidence which most likely is to the tune of all their CA sales. Regardless of whether or not GDE can or cannot contact you, CARB will and by or when you go to re-register your vehicle. If GDE cannot prove your vehicle was remedied, eventually you will have too. :thumbup:
 

avanti

2022 Ford Transit 3500
It may not be much more than they were simply in violation of CARB regulations and got caught. But 'bigger fish to fry' probably does apply in that while it doesn't cost much to go after the source (GDE) it would be a complex proposition to try to identify every user, formally contact them (in the absence of valid contact info in many cases), and then track whether they have come back into compliance, and then enforce after some time period if they have not. CARB has gone after many such violators on a corporate level but I'm not aware of a case when they have gone after thousands (or perhaps tens of thousands, as in other examples) of private purchasers, often with scant records as to who/what/when/where, to try to enforce removal of equipment on an individual basis. That would be an enormous task and as such unlikely.

So again I would not exactly be holding my breath waiting for my registration to be canceled out of the blue, in California or any other state. As to whether it's a bad idea to sell illegal modifications in California... well, ya.
Yeah, I daresay you would prefer this to be true.

You're the one who shouldn't hold his breath. Your description of the complexity is correct, but if you read the letter, you will see that all the hard parts have been off-loaded to GDE as part of the consent decree. THEY have to deliver VINs of their customers to CARB, which I agree won't be easy. This won't cost the government anything. Once they have a spreadsheet of VINs that haven't had their "tunes" undone, it is just pushing buttons to pull their registration.

The "cost effectiveness" argument is also specious. As long as there is a demand for some criminal product or service, there will always be suppliers. That is why drug users are pursued, and not just dealers. It is probably true that you will only get a slap on the wrist. That is exactly what losing the ability to register your polluting van is.

This is all very gratifying.
 

avanti

2022 Ford Transit 3500
The EPA already has already paid them an unannounced visit:

https://ofmpub.epa.gov/apex/tocar/f?p=174:30:7442659930255:::::

Search for "green diesel"

Shoe is on it's way down.
What a crack up. I especially liked this part:

According to Mr. Cavallini, GDE only conducts the research and development (R&D) of these tunes. A separate, confidential company, which Mr. Cavallini referred to as "Company X," conducts the engineering and mechanical work. Mr. Cavallini further explained that this work is contracted out by GDE to Company X.
What a slimeball.
 

OrioN

2008 2500 170" EXT
Yeah, I daresay you would prefer this to be true.

You're the one who shouldn't hold his breath. Your description of the complexity is correct, but if you read the letter, you will see that all the hard parts have been off-loaded to GDE as part of the consent decree. THEY have to deliver VINs of their customers to CARB, which I agree won't be easy. This won't cost the government anything. Once they have a spreadsheet of VINs that haven't had their "tunes" undone, it is just pushing buttons to pull their registration.

The "cost effectiveness" argument is also specious. As long as there is a demand for some criminal product or service, there will always be suppliers. That is why drug users are pursued, and not just dealers. It is probably true that you will only get a slap on the wrist. That is exactly what losing the ability to register your polluting van is.

This is all very gratifying.
No slap on the wrist, he will be sentenced to FEAR!

Once he is forced to have his vehicle compliant he will be forced to live in crippling fear of the pending failed egr and swirlwalve and their financial consequences!!
 

smiller

2008 View J (2007 NCV3 3500)
Yeah, I daresay you would prefer this to be true.
Not a matter of preference, just likelihood. Your gratification aside, has CARB ever in the past attempted to go after large numbers of individual retail purchasers, carrying it through to individual enforcement? If this has been their typical MO in the past then it is logical to assume that they may do so in this case, and if they have not it is logical to assume that they won't.

.
 
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Old Crows

Calypso 2014 View Profile
Thanks for posting that link Mark. It is a good read.

The unannounced “inspection” report was well done. Thorough. Reminded me of my previous life. Inspections like this are for the most part routine and conform to a schedule....say every 5 years. Exact dates are never announced unless special circumstances trigger it. An example would be an allegation, incident or an enforcement action by another agency. Not exactly a “Roger Stone” moment but close. “Good Moring Sir, We’re from the Gummint and we are here to inspect your facility and operation. Say, nice looking black truck out front. Is that yours?”

IME, this is the beginning of a long journey and the destination is not the Sandals Resort. Inspectors do their home work and I’d bet they already knew many answers before they asked a question. I sure knew a lot more about a licensee’s OPS and business than the contact thought I did. The licensee’s reluctance to fully and truthfully answer questions or to answer with a lot of hand waving and BS is always a big clue that something is hinky. “Company X” “Can’t tell you about the stealth owner of Company X” “Protecting privacy of a customer” “Don’t know who owns the red truck” “Owned by company X” Really? Agreement forms that can’t be printed? Really? Product boxes on a shelf and one of Santa’s Elves bumbling about? Well, My,My,My! How interesting. My retired BS antennas were tingling just reading that report.

So, photos, visual observations, confirmatory data collection......the dreaded “If we have questions and need to confirm with you our findings today, you won’t mind if we telephone you....would you? We just want to get the report straight...”. We’ll have a final report in 45 days, or less. And by the way, there is a real possibility that we’ll have an Enforcement Conference as the result of this Inspection. Thanks for helping us and have a nice day, Sir.....

I’d not be surprised if they pulled a follow up visit to “collect” more information and some product for confirmatory lab analysis. Might depend on whether or not the EPA Region 5 senses that they are being flimflammed or there are material false statements by the company representatives. Or, they could be moving to an enforcement action.
 

NBB

Well-known member
CARB isn’t going after anyone except the complete morons who log into that Google Sheet and completely identify themselves and their vehicle.
 

HighPockets

Active member
Avanti, this is just a psychological curiosity to me but you mentioned "This is all very gratifying." in a recent post about GDE being called to task and you have often called people who used the tunes criminals. I have just wondered "what got a bee in your bonnet" so to speak that you get such pleasure from seeing "wrongdoers" getting their "just deserts"? I don't get pleasure from seeing someone pulled over for speeding. Many of us have gone through speed traps and gotten an unwarranted ticket, not to say that everyone getting a ticket for speeding doesn't deserve it, just that it gives me no pleasure as a passerby to see it. Now if someone tailgates me in heavy traffic where I cannot move over and then passes me narrowly missing me and the other car at a high rate of speed, then yes, I get satisfaction from seeing him stopped. So what in your past causes you to get this "satisfaction" from seeing this "justice" persecuted. Are you so perfect that anything anybody else does that infringes on your perception of "obeying the law" is worth your disdain? I have worked for 68 of my 78 years, paid my taxes, been a member of a civic club and have tried to be a good citizen but I do bend laws if I think the situation is not one that the law was written for and I am willing to accept the consequences, e.g. pay a traffic violation. Just wondering!

Gene
 

HighPockets

Active member
I have 8 grandchildren coming for Thanksgiving this weekend. They love to come visit their grandparents on the farm in the piney hills of north Louisiana where there is plenty of fresh air and you can see the milky way on a clear night. Point is this is not smog-ridden LA. What needs to be done in southern CA doesn't necessarily need to be done in Louisiana. To go back to a vehicle analogy, Speed limits have to be set for average vehicles. This includes '80s American station wagon with 250K miles with original shocks and worn-out tires as well as a late model sports sedan with quality shocks and "S" rated tires. The former is unsafe at 50mph and the latter safe at 80mph or even 100mph on isolated modern highways. I get your point about wanting the best for your kids but I still don't understand your "gratified feeling" (maybe for GDE) but is anyone who has used them as the only reasonable way to get an efficient fuel-burning engine a criminal and subject to your incrimination and joy to you if they get caught? I think that is a little harsh.

Gene
 

Sinatorj

Active member
I have 8 grandchildren coming for Thanksgiving this weekend. They love to come visit their grandparents on the farm in the piney hills of north Louisiana where there is plenty of fresh air and you can see the milky way on a clear night. Point is this is not smog-ridden LA. What needs to be done in southern CA doesn't necessarily need to be done in Louisiana. To go back to a vehicle analogy, Speed limits have to be set for average vehicles. This includes '80s American station wagon with 250K miles with original shocks and worn-out tires as well as a late model sports sedan with quality shocks and "S" rated tires. The former is unsafe at 50mph and the latter safe at 80mph or even 100mph on isolated modern highways. I get your point about wanting the best for your kids but I still don't understand your "gratified feeling" (maybe for GDE) but is anyone who has used them as the only reasonable way to get an efficient fuel-burning engine a criminal and subject to your incrimination and joy to you if they get caught? I think that is a little harsh.

Gene
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.
 

Midwestdrifter

Engineer In Residence
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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