So... how do track-only cars deal with this? My understanding is that non-road vehicles wouldn't have the same restrictions. Even at the state level, travelling under 5k miles per year exempts you from emmissions standards. I'm not sure if this is built off of the federal law, but it would be very interesting if it actually conflicts with it.
It would seem that these tuners have a lawful purpose if there are in fact exceptions for non-road vehicles, such as true race cars.
Edit: answered my own question. Seems it's just selective enforcement. State level inspection exemption is still a "visual only" inspection, meaning there can't be any obvious deletes (not really enforced it seems).
https://www.thedrive.com/accelerator/2137/epa-clarifies-its-...
Historically the entire engine tuning industry's loophole was some text on their website and product packaging that said "for off road use only". But over the years they've become more brazen about marketing for street use while expecting that disclaimer to protect their liability. IMO the real breaking point was the diesel truck guys. They were both far more active in marketing their defeat devices for road use ("improve towing fuel economy with a DPF delete") as well as the coal rollers just being so hilariously anti-social that there was bound to be pushback. They really pushed the uneasy look-the-other-way truce that the industry had with the EPA and even as a longtime car enthusiast (and engineer who's worked in both emissions engine calibration and electrical vehicles) I can't fault the regulators on this.
So to answer your actual question, while technically actual off road use is still legal a lot of bad actors in the industry used every bit of leeway that the regulators gave them and now this crackdown is the result.
The EPA maintain that converting an on-road vehicle to off-road use is illegal, however, by decree rather than legislation. The EPA's interpretation of the Clean Air Act is that any alteration to an emissions control system is illegal - that it's the act of modification, and not the result, that's breaking the law.
This is a double edged sword for tuning companies as the "CARB approval makes the device EPA legal" loophole is also "just" an EPA enforcement order, rather than legislated.
> however, by decree rather than legislation. The EPA's interpretation of the Clean Air Act is that any alteration to an emissions control system is illegal
imo its pretty clearly part of the plain text of the Clean Air Act:
> The term "motor vehicle" means any self-propelled vehicle designed for transporting persons or property on a street or highway.
> [it is prohibited] for any person to manufacture or sell, or offer to sell, or install, any part or component intended for use with, or as part of, any motor vehicle or motor vehicle engine, [whose purpose is defeating emissions systems]
Clearly this applies to any vehicle sold to operate on roads. The owner's intent to use it only off-road has no bearing on the 'design' of the unmodified vehicle and thus is irrelevant to the legality. There are of course exceptions and legal complexities but to call it a decree rather than legislation is plain wrong.
> Chevron decision probably changes the playing field here a little bit.
This is probably true but if it does come into play it will have much less to do with the text of the law than it will the preferences of the majority.
All that said, the EPA has made it pretty clear that they don't really care if you perform your own emissions delete on your track only car:
> “In the course of selecting cases for enforcement, the EPA has and will continue to consider whether the tampered vehicle is used exclusively for competition. The EPA remains primarily concerned with cases where the tampered vehicle is used on public roads, and more specifically with aftermarket manufacturers who sell devices that defeat emission control systems on vehicles used on public roads.”
"The EPA maintain that converting an on-road vehicle to off-road use is illegal"
Technically you can convert the vehicle, you just can't convert the engine. The emission regulations prevent deletes based on the engine, not the vehicle. So you could drop in a purpose built race engine and be legal.
But even the EPA looks the other way if your vehicle is truly never used on the road. They only seem to enforce it on dual use vehicles.
This is incorrect. Installing an entire new powertrain constitutes a "defeat device". The EPA most definitely does not look the other way for non-road vehicles.
* Some crate engines are emissions legal as "service replacements," if installed into a chassis that originally had a variant of that engine and if all emissions control systems are retained. In this case you're using the emissions controlled accessories from the existing vehicle.
* A few crate engine packages have CARB Executive Orders. Due to a weird enforcement note from the EPA, CARB EOs are essentially a loophole in the emissions certification process. These Executive Orders apply only to crate engines that are retained in the shipped configuration and only apply to packages that come with accessories including intakes and upstream-catalyst exhaust systems (usually header+downpipe).
* Exhaust downstream of catalyst is a murky area. It's "de facto" considered not part of the emissions control system, even though backpressure could affect actual measured emissions.
Custom non-road engines are found in many track only cars. And if you are to read the article I posted early, even the EPA doesn't really care if a street car is converted to a track car so long as it's never used on the street. It might be technically illegal to do, but the enforcing agency doesn't care. Pretty similar to things like federal enforcement of marijuana. Not legal, but not generally not enforced.
Yes. This was already implemented quite a long time ago by Cobb (2022 - they called it Project Green Speed), the settlement is just now becoming public. Many tuners air-gapped their tuning computers and hoarded old AccessPorts. However, in exchange they don't get new features, and since Cobb is an end-to-end locked platform (flashing, editing, and logging must all be done using the Cobb tools), this is a fairly significant price to pay.
I'm curious what kind of sanction a civil fine from a federal agency gives them in this case. For example, if they used a 0 day to compromise my laptop and remove these features would they be within federal law?
> A "full delete" of the emission controls on a modern heavy-duty diesel pickup truck can cause it to emit as much harmful pollution as 300 trucks with fully functioning emissions controls! Tampering with only some components also leads to significantly elevated emissions of NOx, PM, carbon monoxide, and hydrocarbons. These pollutants contribute to a variety of public health problems, such as premature death in people with heart or lung disease, heart attacks, irregular heartbeat, aggravated asthma, decreased lung function, and respiratory symptoms such as irritation of the airways, coughing, or difficulty breathing. NOx reacts with sunlight to cause ground-level ozone pollution (smog), so visibility, discomfort and illness may increase in the summer, when people enjoy being outside and traffic increases with travel to vacation and recreation areas.
> Violations are widespread and financial penalties are significant. Those who sell or install devices to defeat emission controls can be fined over $5,000 per defeat device, and dealers can be fined over $5,000 per tampered vehicle. Nationally, EPA has settled over 100 civil tampering cases to date, and the Department of Justice has won jail terms and high fines in criminal cases.
I'm all for lower emissions, I own an EV. But its silly to go after Cobb which only has 81k sales over 20 years while Ford sells 750k F-150s a year. Yes I know what Cobb is doing is illegal and F-150s are legal, but in the grand scheme of things...
edit: see reply, cobb got hit for gas tuners, not diesel, and cobb tuners are 1:1 per car
81k tuners which can each flash any number of trucks, and a full emissions delete on a diesel pickup emits ~300x the pollution of an unmodified vehicle. Further, those 750k trucks are providing astronomically more utility relative to their pollution than diesel drivers are getting out of their +XX HP or +X MPG.
> 81k tuners which can each flash any number of trucks
Cobb hardware has a 1:1 "marriage" system with a given vehicle.
> a full emissions delete on a diesel pickup emits ~300x the pollution of an unmodified vehicle
This is gasoline tuning.
I agree that diesel defeat tuning is awful and should be aggressively destroyed. This isn't that. The calculus for gas tuning is dramatically different from diesel; the fundamental reason is basically that the operating range for a gas engine is tighter and they simply can't be made as dirty as a diesel (plus, the engines are generally physically smaller and just can't pump as much pollutant out no matter how hard you try).
Ahh thanks for the correction, I mixed this up/assumed it was part of the EPA diesel tuning case from last week. You're totally right, gas tuning is definitely not a big deal by comparison although they definitely shouldn't have been facilitating the sale of cat deletes. A cat delete alone causes a 10x-100x increase in pollutants before tuning.
Cobb doesn't sell full emissions delete. They sell performance maps which, yes, increases emissions slightly, not 300x. These aren't the devices you buy to roll coal. And its mostly 1-1 sales.
750k F-150s getting sub 20MPG is the bigger problem than the niche tuner market.
This may be a surprise to you, but if they can't pay the larger fine... it just goes unpaid. Funny that. Nor does escalation likely work... if you go seize all the office chairs and other assets, then they can no longer conduct the business which would eventually make it possible for them to pay the fine.
Attempting to be more harsh often results in less harsh results.
Wiping out all the equityholders and wiping out everything they've worked to build is a much harsher penalty than some money. The point isn't to actually get money from them.
> The point isn't to actually get money from them.
No, I suppose it isn't. The point, I think, is that you're irrationally jealous of other people doing things, and like to see them spitefully stomped into the ground. But it's good to hear you be honest about it.
Don't know where you got that, until seeing this, I didn't know or care about Cobb, I'm certainly not jealous of them. I was just saying that the EPA is not trying to optimize the amount of money they get, they're just trying to punish without killing the company, that would be much harsher than what they're going for.
It looks like they want the company to stick around long enough to brick/cripple the existing devices. If they force them into bankruptcy with an enormous fine, presumably nobody will clean up the mess.
Or...just go through their customer list and revoke the registration of any vehicles that were modified. Customers can then pay for having vehicle inspected at the DMV.
The throttle mapping is nonlinear so that something like 10% pedal gives you 50% gas, so it's really hard to control smoothly.
The 1st gear to 2nd gear shift also has really bad rev hang where you have to wait for a very long time in between 1st and 2nd gear before you can engage the next gear. This makes controlling the car at slow speeds to be really jumpy and uncomfortable. Lots of manual transmission cars made after 2010 have rev hang supposedly for emissions purposes.
One way of solving this is to buy a $700 Cobb Accessport and flash your car's ECU with a "stage 1" off-the-shelf Cobb tune. This makes the throttle mapping linear and removes most of the rev hang. These off-the-shelf maps are supposedly CARB compliant.
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Cobb also has a stage 2 tune that requires replacing the turbo-back exhaust of the car (a.k.a. a downpipe/j-pipe), which is less restrictive for emissions and adds a good amount of horsepower. Supposedly these stage 2 tunes and turbo-back hardware are CARB compliant nowadays, but the laws are fairly new so Cobb sold non-compliant versions up to a few years ago iirc. Tuner shops can also create their own non-compliant custom tunes using the Accessport.
It's a similar world with fuel injected dirt bikes. Although the throttle is mechanical, some specific fuel and ignition mapping choices the manufacturers provide results in huge amounts of acceleration with small amounts of throttle input. The exact reasons why aren't published, but the general consensus is it relates to emissions.
Remapping the factory ECU completely resolves the issue, albeit obviously a "defeat device" per the EPA
"Lots of manual transmission cars made after 2010 have rev hang"
I think this is similar to "skip shift". The idea is to force you to shift from 1st to 4th so you use the more efficient ratio. Stupid idea in my experience since it forced higher RPMs in an inefficient gear and can have some drivability issues in traffic and on hills. You technically don't need a tune to eliminate this. They make jumpers that sit between your computer cable and the transmission that eliminate the gear lockouts. You could also pullout in second and it would bypass the skipshift logic since you aren't in first.
The rev hang or skip shift isn't about unburnt hydrocarbons, it's about efficiency standards. It's a different problem - emissions efficiency is one thing and emission compound/type restrictions are another.
Incorrect. The engine speed hold is there to optimize mixture while the engine decelerates, instead of just slamming the throttle shut. Depending on where the fuel is injected, cutting off fuel and air instantly leads to either too much fuel or too much air in the cylinders. The electronic rev hang corrects this to reduce NOx and unburnt fuel. It does not improve fuel efficiency.
The difference between DI and port injection is only which thing is escaping the catalytic converter. With port injection the engine is rich after lifting off the throttle, and hydrocarbons escape. With direct injection the engine leans out, and NOx escapes. In both cases the rev hang exists to keep the emissions system in its effective air/fuel ratio range. Every hanging MT car I ever owned was DI.
That's very odd. DI should only be firing a full shot injector as the air is coming in, or already came in. It really shouldn't lean out. If your DI car had rev hang, it's for other reasons.
We were discussing the 2015 WRX after all, it is port injected. The guy who wants to delete the rev hang from his VA WRX is advocating to blowing unburnt gas right out of the tailpipe, like a psycho.
> Why do people install these parts? Do they improve performance somehow?
Yes. Most turbocharged cars come from the manufacturer with an enormous amount of left-over power. Many "Stage 1" (no hardware, only software) calibrations for a modern turbocharged car like a VW GTI will produce a 30-40% gain in peak torque. This is for several reasons:
* Emissions. A catalytic converter in some ways works as an oxygen capacitor - it "fills" with oxygen while excess O2 is present (for example, when fuel is cut on deceleration or when the car chooses to run lean-of-stoich) and "discharges" while converting excess hydrocarbons to water. There are other extremely complicated principles at play like catalyst light-off and heating, but this is the basic concept.
* This means that an OEM calibration is a careful balance wobbling between lean and rich of stoichiometric operation (called "catalyst stimulation"). However, this is not the ideal condition for producing power. Due to the flame propagation properties of gasoline-air mixtures, gasoline engines produce optimal torque at a mixture condition rich-of-stoichiometric (this is called, counterintuitively, Lean Best Torque or LBT). And turbocharged and high-compression gasoline engines are extremely vulnerable to unstable combustion conditions (detonations and preignition) which are also alleviated by running a richer mixture. The most common way to increase power on a turbocharged car is to change the air-fuel lambda target from 1.0 (stoichiometric) to around 0.84 under full load, then to increase boost to the safe maximum from the turbocharger (or beyond) and timing to the knock threshold.
* There are also obvious warranty and longevity concerns. Running a turbocharger at 70% of its shaft speed maximum will make it last longer than running it at 120% of its shaft speed maximum. Putting 450 ft-lb through a transmission designed to handle 300 ft-lb will break it.
None of the comments at the time of writing this comment actually answer your question in regards to cobb tuning devices I’ll try.
It depends.
It’s not that these devices really significantly increase power, it’s that all the mods that do make power are near useless without a tune, and this device allows that tune.
Recent engines may suffer in performance due to the ever stricter emissions standards. Earlier engines from like 10 years ago probably benefited from emissions standards because things like direct injection, higher compression ratio and so on all both increase performance and reduce emissions(this is oversimplified)
So in a very recent car a device like this might actually be able to be used to give a “better” tune to the car that sacrifices emissions for performance. It’s like the government and the manufacturer of the car make choices on the trade off between engine performance and good emissions, this device allows you to make a difference choice.
However, that’s not really how I’ve seen these used because that would be a very expensive way to gain a small amount of power. The thing is that with any car from like the last 20 years or more, if you do modifications like high flow exhaust, bigger cams, adding a turbo where there was none or adding a bigger turbo, and so on, will all, almost certainly, decrease the performance of your car if those mods start to add so much air flow that the default tune can’t keep up. It should also be mentioned that running an engine like that will ruin it quickly. If then, you use a device like this to tune the car to suit the mods, you can double or more the performance of the engine.
I’m glossing over a lot of details here, like for instance ecus are sometimes closed loop systems that can to some extent adjust the fuel flow with increased air flow, but it’s likely that the engine will give you an error code and display the check engine symbol. It should also be noted that some ecus will go into open loop when you floor the car, which is when you want the most power. This can be really bad if you have mods that increase the airflow and volumetric efficiency of the engine. Point is, your mods are useless without a tune.
I have a few device(s) installed on my 2017 Turbo Lexus. Yes they improve performance. Newer drive by wire throttle controls are laggy as crap. 30 year old cars with cable driven throttles perform better than new electronics in some cases.
I've got an aftermarket OEM Toyota (Tom's) device sitting between my boost sensor and cam sensor to advance the timing and boost and I've got a throttle advance controller to get rid of the throttle delay in the drive by wire throttle.
And the car isn't fun to drive without those two things. I would just drive something older without all the throttle delay between pushing the accelerator and the car "going"
Yes we have a salvage model 3 Tesla - I'm saving the planet or something. I also have 5 other cars I like to tinker with on the weekends. This will keep happening most likely due to the RPM Act.
If you're not an OEM certifying the car, the EPA is going to keep going after aftermarket tuners; too much evidence to ignore.
>the EPA is going to keep going after aftermarket tuners; too much evidence to ignore.
Which will probably drive them off shore where the regulators don't matter and then people will be buying tuners from China or buying off the shelf commercial scan tools and loading new firmware onto them that lets them use them as tuners and do whatever.
The only reason this hasn't happened yet is because domestic tuners have generally satiated that demand at the right price.
Many of these tuners deal with all sorts of pesky chimes and idiot-proofing of which at least a couple specific features are a nuisance to any given person, default settings you can't change, etc, etc so the demand that's there is more than just enthusiasts and the people who'd rather turn off the CEL in software than replace a cat.
Any cats and whatever impede the flow of exhaust gases - by removing them you may get quicker turbo spool up
It used be that tuning turbos to run 'rich' (more fuel) was the safer move, because lean can cause engine knock; although I don't really know how things are nowadays
Your information is out of date like you suspected. The causation is now backwards from what you said.
Some people are removing the cats because they're running super rich tuns that trash the cat fast enough to be a problem. No cat on a vehicle this century restricts anything enough to matter when compared to the the rest of the exhaust system.
Some other people who intend to make so much power that they upsize the whole exhaust system they frequently just don't run a cat because the cat is a restriction compared to the now larger system and tuning it out in the software you already paid for is free and a new cat is expensive.
Interesting. The old belief was 'catback for noise, turboback for power'
I remember reading that some big power Lightnings blew motors when the seasons changed (guessing they tuned in the summer so in the winter it ran lean, but I can't recall).
All of this probably depends on how smart your ECU is...or isn't
If you did not change anything about the intake, installing a wider exhaust could be either neutral or detrimental. Many people have bought magic exhaust mods for their naturally-aspirated cars only to discover that the engine now guzzles fuel without being noticeably more powerful.
Quite ironically, turbochargers remove a big deal of sound from exhaust, because the energy is extracted back to do useful work. Otherwise it would be emitted as noise pollution, which some sociopaths cherish for some reason. I believe exhaust systems can (and most likely are) acoustically tuned to do similar thing by fluid dynamics too.
It would seem that these tuners have a lawful purpose if there are in fact exceptions for non-road vehicles, such as true race cars.
Edit: answered my own question. Seems it's just selective enforcement. State level inspection exemption is still a "visual only" inspection, meaning there can't be any obvious deletes (not really enforced it seems). https://www.thedrive.com/accelerator/2137/epa-clarifies-its-...