1 WESTAR Mobile Sources Committee Consumer Modifications to Light Duty Diesels

2 The Issue: Many light duty diesel truck owners are modifying their engines, leading to increased emissions from these vehicles “Tampering” is removing, bypassing, defeating or making inoperable any device or element of design used to control emissions from a motor vehicle engine. Section 203 (a) (3) A & B of the CAA of 1990

3 Some modifications can increase performance with little or no increase in emissions These modifications may or may not constitute tampering under the CAA of 1990

4 “Tuners” and “Downloaders” are used to reprogram factory engine and transmission settings, which can have an immediate effect on tailpipe emissions

5 Adjustable Tuner Modules allow the driver to select a power setting while behind the wheel

6 Manufacturer's claim: Using factory-style connections in just ten minutes you can add five levels of adjustable power ranging from 40 to 100 horsepower and increase torque up to 250 ft. lbs.

7 Auto Manufacturers Must Find Balance Among Many Factors Fuel Economy Performance Cost Federal Emissions Standards Reliability Hot/Cold Weather Drivability Consumer Preferences Changing Factory Settings Upsets This Balance!

8 A Dynamometer Rally held by a Diesel Enthusiast’s Club

9 Maybe we need to be issuing stationary source permits

10 Got PM?

11 All Banks truck and RV Power and Braking Systems product is emissions tested, and complies with California and federal emissions standards. Depending on the Banks system that is installed, your vehicle may be covered under a California Air Resources Board Executive Orders (CARB E.O.).These are issued after meeting the test criteria set forth by CARB for aftermarket product on over- the-road vehicles. Although there are a few companies that follow this procedure for gasoline applications, there are far fewer companies compliant in the diesel aftermarket. Banks Racing products may or may not be emissions compliant on all vehicles in all states. Industry Statement on Emissions

12 Sales of Diesel Pickups n n From model year 1989 to 2000, Dodge diesel sales have steadily increased from 16,750 units to 116,000 units n n Diesels comprise about 1/3 of fullsize pickup sales n n Diesel sales for Ford and GM have also shown consistent increases

13 Statistics In Nevada n n 61,281 Light Duty Diesels (0 to 10,000 lbs GVWR) registered in the state n n This is about 25% of all full-size pickups registered n n Or about 3% of all 1.7 million registered vehicles n n Using an estimate of 10% of LDD having been tampered with amounts to less than 1% of all registered vehicles

14 Estimates of Diesel Modifications in Colorado n n Licensed Diesel I/M shops that also perform aftermarket upgrades were queried n n Shop owners estimated that 30% to 60% of diesel pickups had some performance modification – mostly on newer model trucks n n 3 of 5 shop owners refused to comment

15 Impacts on Mobile Source Emissions n n PM and NOx emissions most likely are increased on these vehicles, but no hard data are available n n Several states have I/M programs that test LDD; these vehicles may fail the smog tests, depending on the testing protocol used in that locality n n In-Use Vehicle emissions testing data are needed – but are difficult to get

16 EPA’s Position When asked about the extent of tampering going on in gasoline-powered vehicles, an EPA official stated: “We have not determined how big an issue this is … we have it on our list of things to investigate further” EPA went on to say that they have an enforcement group that looks into cases of equipment suppliers offering products that affect emissions systems From a policy standpoint, almost no one will acknowledge there is a problem or is willing to address the issue.

17 Where do we go from here Have EPA assess the scope and impact of all vehicle tampering; on both diesel and gasoline engines We should be concerned over the consumer’s relative lack of concern over compromising vehicle emission control systems We need to do a better job of conveying the value of emissions systems to the consumer As well as do a better job of enforcement of tampering regulations at both the national (retailer) and local (emission tester) levels