NJ TAMPERING INITIATIVE - DIVISION OF AIR QUALITY AIR QUALITY, ENERGY, AND SUSTAINABILITY

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NJ TAMPERING INITIATIVE - DIVISION OF AIR QUALITY AIR QUALITY, ENERGY, AND SUSTAINABILITY
DIVISION OF AIR QUALITY
     AIR QUALITY, ENERGY, AND SUSTAINABILITY

                                                  Air Quality

NJ TAMPERING INITIATIVE                        Energy

                                                 Sustainability
           MARCH 2019
NJ TAMPERING INITIATIVE - DIVISION OF AIR QUALITY AIR QUALITY, ENERGY, AND SUSTAINABILITY
Why pay attention to tampering?

                                  Slide 2
NJ TAMPERING INITIATIVE - DIVISION OF AIR QUALITY AIR QUALITY, ENERGY, AND SUSTAINABILITY
PM2.5 emissions

                  Slide 3
NJ TAMPERING INITIATIVE - DIVISION OF AIR QUALITY AIR QUALITY, ENERGY, AND SUSTAINABILITY
WHY FOCUS ON TAMPERING?

• Gap in NJ’s Inspection & Maintenance Program

• No diesel inspections for vehicles having a
  GVWR between 8,501-17,999 lbs

• This weight class is ripe for tampering

                                                 Slide 4
NJ TAMPERING INITIATIVE - DIVISION OF AIR QUALITY AIR QUALITY, ENERGY, AND SUSTAINABILITY
CRAIGSLIST SEARCH

                                                            2008 Ford F250

                      EGR & DPF deleted.
                  Trucks is perfect, and crazy
                 clean, come look for yourself
                      and yes it rolls coal!
2011 dodge ram 2500 Cummins SLT
                                                        Truck has 191k miles on it. EGR/DPF delete
                                                        done at 140k miles. 4" exhaust to a 7" stack.
                                                        H&S tuner with custom tunes.

                                  2008 F250

               Truck is fully deleted- EGR delete DPF
               delete with SCT x 4 tuner with Rudy's
               diesel tunes
                                                                                                        Slide 5
NJ TAMPERING INITIATIVE - DIVISION OF AIR QUALITY AIR QUALITY, ENERGY, AND SUSTAINABILITY
Coal Rolling Law – signed May 5, 2015

• Coal Rolling Law -No person shall retrofit any diesel-powered vehicle
  with any device, smoke stack, or other equipment which enhances the
  vehicle’s capacity to emit soot, smoke, or other particulate emissions, or
  shall purposely release significant quantities of soot, smoke, or other
  particulate emissions into the air and onto roadways and other vehicles
  while operating the vehicle, colloquially referred to as “coal rolling.”
                    rolling coal video

                                                                           Slide 6
NJ TAMPERING INITIATIVE - DIVISION OF AIR QUALITY AIR QUALITY, ENERGY, AND SUSTAINABILITY
NJ DEP’S RULES FORBID:

• Tampering with vehicle emissions controls by
  disconnecting, detaching, deactivating or otherwise
  altering or modifying emissions control devices, N.J.A.C.
  7:27-14.3(e)(1);
• Operating a tampered vehicle on the road without
  properly-functioning emissions controls, N.J.A.C. 7:27-
  14.4(a)(4);
• Selling or offering for sale or lease any tampered vehicle,
  N.J.A.C. 7:27-14.3(e)(2); and
• Selling or offering for sale any defeat device or
  emissions-related component designed to be installed or
  used with a vehicle except those that faithfully duplicate
  OEM parts. N.J.A.C. 7:27-14.3(e)(3).

                                                          Slide 7
NJ TAMPERING INITIATIVE - DIVISION OF AIR QUALITY AIR QUALITY, ENERGY, AND SUSTAINABILITY
INVESTIGATIONS
• Focus on medium duty pickup trucks – low hanging fruit
• Focus on used car dealerships – advertise tampered
  vehicles
• 3 investigations at used car dealerships = 30%
  • Phoenix Truxx – South Amboy
    • 35 trucks inspected and 11 tampered
    • Tampered trucks MY 2006-2016
  • TSJ Auto Brokers – Lakewood
    • 15 trucks inspected and 4 tampered
    • Tampered trucks MY 2008-2016
  • Wholesale Outlet – Waterford
    • 16 trucks inspected and 5 tampered
    • Tampered trucks MY 2007-2013
• Enforcement action 1st offense
  • $2,000 penalty per vehicle and vehicle must be made whole
                                                            Slide 8
NJ TAMPERING INITIATIVE - DIVISION OF AIR QUALITY AIR QUALITY, ENERGY, AND SUSTAINABILITY
Exhaust gas recirculation – Nox
Tampered
Blocked EGR

                                              Repaired
                                              EGR valve reinstalled

              Missing                                       Repaired

Tampered
                                               Repaired
Missing components

                                                                       Slide 9
NJ TAMPERING INITIATIVE - DIVISION OF AIR QUALITY AIR QUALITY, ENERGY, AND SUSTAINABILITY
Diesel Particulate Filter      Straight pipe
                                   indicating DPF has
                                     been removed
   TAMPERED

                     REPAIRED

 Straight pipe has
  been removed
and DPF has been
      installed

                                                   Slide 10
EMISSION INCREASES FROM EMISSION DELETE
                                                              Fully Deleted Results from EPA’sTesting
                                                               Makes this….      …run like this..

                              11                                                                                                                     11

                              10                                                                                                                     10
NOx or NOX+NMHC Standard s

                              9                                                                                                    DOC,              9
  Heavy-Duty Diesel Engines

                                                                                                                         DOC,

                                                                                                                                                          Heavy-Duty Vehicles
                              8                                                                              DOC, EGR,   EGR,    EGR, DPF,           8
                                      Engine Out Emission Control (calibration and hardware improvements)

                                                                                                                                                            NOx Standard
                                                                                                               OBD       DPF
                                                                                                                         OBDII
                                                                                                                                   SCR
                               7                                                                                                                     7

                                                                                                                                                               (g/mile)
                                                                                                                                  OBDII
         (g/bhp-hr)

                              6                                                                                                                      6

                              5
                                                                                                                                  Stock Results      5
                                                                                                                                  for EPA’sTest
                              4                                                                                                                      4
                                                                                                                                  Vehicle (2011
                               3                                                                                                                     3
                                                                                                                                      HDV)
                                             NOx -HDDE
                              2                                                                                                                      2

                               1             NOx - HDV (8.5-10K GVWR)                                                                                1

                              0                                                                                                                      0
                                   1985        1988         1991                     1998                   2004          2008   2010        Today

                Source: https://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=P100OA01.pdf
EMISSIONS INCREASE DUE TO
          FULL DELETE

      =

These test results show the increase in NOx, NMHC, CO, and PM
when a tuner enables a full delete of the vehicle. These tests
were conducted without the SCR, DPF, DOC, and EGR emission
controls.
• Tailpipe NOx increased ~310x
• Tailpipe NMHC increased ~1,140x
• Tailpipe CO increased ~120x
• Tailpipe PM increased ~40x
BIG NEWS TO COME……

• Large tampering case
• Stay tuned for a future press release

Bottomline
• The word is out and these trucks are slowly
  disappearing from NJ.
• All I can say is….. NY, PA, DE, CT, VA these trucks are
  coming to you.
• Don’t believe me?
  “We stay out of those states that have emission rules so now we
 know NJ does. So we will take the vehicles somewhere else……if
                     you know what I mean”
                                                              Slide 13
N.J.A.C. 7:27-14.3(e)
(e) No person shall cause, suffer, allow, or permit any of the following, unless it is
performed in accordance with EPA Memorandum 1A or it is exempt from prohibition by
CARB Executive Order (information on devices or modifications approved by CARB
Executive Order may be obtained from the California Air Resources Board, 1001 "I"
Street, PO Box 2815, Sacramento, CA 95812 or at www.arb.ca.gov):

   • 1. The disconnection, detachment, deactivation, or any other alteration or
     modification from the design of the original vehicle manufacturer or an element
     of design installed on any motor vehicle with a certified configuration or motor
     vehicle engine with a certified configuration, except temporarily for the purpose
     of diagnosis, maintenance, repair, or replacement;

   • 2. The sale, lease, or offer for sale or lease, of any motor vehicle with a certified
     configuration or motor vehicle engine with a certified configuration in which any
     element of design installed on such vehicle has been disconnected, detached,
     deactivated, or in any other way altered or modified from the design of the
     original vehicle manufacturer; or

   • 3. The sale, or offer for sale, of any device or component as an element of design
     intended for use with, or as part of, any motor vehicle with a certified
     configuration or motor vehicle engine with a certified configuration that is not
     designed to duplicate the function and performance of any element of design
     installed by the original vehicle manufacturer.

                                                                                       Slide 14
Penalty Category                          Class                     First    Maximum
                                                                   Offense    Offense
Idling                                    All vehicles               $0        $1500
                                          Owner of 4 or less        $400       $6000
Tampering of vehicles                     vehicles
                                          Owner of 5 or more        $1000     $15,000
                                          vehicles
                                          Owner of 4 or less        $1000     $15,000
Sale, lease, or offer for sale or lease
tampered vehicle
                                          Owner of 5 or more        $2000     $30,000
                                          vehicles

Sale, or offer for sale any device or     All vehicles              $2000     $30,000
component

Does not have a properly                  Offer for Sale/Sale of    $2000     $30,000
functioning and properly                  Device Component
maintained emission ctrl apparatus
                                          Passenger vehicles        $500       $7500

Installing disconnected, detached,        Commercial vehicle        $1000     $15,000
deactivate or modified emission
control apparatus
                                                                                  Slide 15
RECAP – 3 THINGS TO REMEMBER

1. Enforcement of tampered vehicles is an easy to
   achieve real emission benefits strategy.

2. Do a craigslist search for your state/area.

3. Having regulations for offer for sale or sale of a
   vehicle.

                                                        Slide 16
QUESTIONS

     Melissa Evanego, Bureau Chief
NJ Department of Environmental Protection
        Bureau of Mobile Sources
      melissa.evanego@dep.nj.gov
               609-292-1637

                                            Slide 17
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