DISRESPECTFUL AND DEROGATORY REMARKS REVISITED

[TDRComm]

DISRESPECTFUL AND DEROGATORY REMARKS REVISITED
​

Yep, in the preceding $1.675-billion articles and discussion, I may have been a bit too disrespectful and derogatory towards Cummins.

As I look back at Issue 121 and 120 and the book reviews of the Volkswagen emissions scandal, “Faster, Higher, Farther,” it is clear to me that there was intent on the part of VW to cheat the emissions rules.

Do I think it was Cummins’ intent to bypass the rules? Nope, I really don’t.

Official Statement from California Air Resources Board (CARB)​

On January 10, 2024the CARB folks released their version of the EPA’s “16 Frequently Asked Questions” with their own list of 20 FAQs.

Here are some interesting-to-note items from their document.

• The population of trucks involved from the 2013-2023 model year Ram 2500-3500 trucks is close to 1 million (960,000) with approximately 97,000 (almost 10%) registered in California.

• What did Cummins do? The CARB response: “The emission control software contained an alleged defeat device that was designed to control emissions during certification but illegally reduced the effectiveness of the emission control during real world on-road driving."

• ”How did the EPA and CARB discover the violations? When? “The EPA discovered inconsistent emissions behavior in these vehicles through testing at the National Vehicle and Fuel Emissions Laboratory (NVFEL). The testing raised questions about whether emissions were being adequately controlled in normal driving conditions. EPA initially identified alleged defeat devices in the model year 2019 diesel Ram 2500 and 3500 diesel vehicles, and that discovery led to further questions. “The EPA began performing this specific type of testing after the September 2015 Volkswagen diesel emissions scandal and announced that going forward it would perform additional testing ‘using driving cycles and conditions that may reasonably be expected to be encountered in normal operation and use, for the purposes of investigating a potential defeat device.’”

• The repair for the problem? The CARB response: “Cummins has already developed a software repair for this issue for the affected vehicles. CARB and the US EPA have approved the repair. Cummins through Fiat Chrysler have already issued a recall referred to as campaign 67A.” The repair/reflash is done at no charge to the customer.

• Do I have to get the repair to pass a California smog check or to register my vehicle? The CARB response: “No.” I find this difficult to believe. Likewise, I find it difficult to believe that a dealership would not automatically do the 67A recall if, say, you just went in for an oil change.

• Your warranty remains in effect.

• Fuel mileage. The CARB response: “The repairs are not expected to impact fuel economy, vehicle durability, or operation. Fiat Chrysler’s or Cummins’ letter informing owners/lessees of the availability of a repair for effected vehicles will describe any anticipated impacts of the repair, if any.” Again, I find this difficult to believe.

• What does the repair include? “The repair includes only what is approved by the US EPA and CARB, which in this case is a software update to the engine control module. After completing the repair, the vehicle identification number is submitted to US EPA and CARB to report that the vehicle has been repaired.”

• Vehicle buyback? “Vehicle buyback is not part of the settlement in this case.”

More Reflections from “The Big Picture: Issue 120, page 29”
​

Okay, you’ve read the preceding and “Disrespectful and Derogatory Remarks Revisited,” let’s take a minute to look further at the $1.675-billion fine by the EPA.

The preceding “Big Picture; Issue 120, page 29,” text gave you some insight into the 1998 $1-billion diesel emissions fine by the EPA that was imposed on six different heavy-duty diesel manufacturers.

Twenty-five years ago, I was there. Let’s reread the summary: “In retrospect, the $1-billion fine was a mere slap on the hand. (Yep, $1-billion was divided by six entities. There were vague financial rules about this-and-that being dedicated to research and development.) Again, folklore has it that the EPA was understanding of the drive-cycle conditions/adjustments that the truck engine OEMs were making. (NOx controls ‘on’ in city driving cycles, ‘off’ on steady state highway conditions.) Likely we will never know the rest of the story.”

Now, ask yourself, “How is it that six manufacturers misinterpreted the EPA’s rule set?

I suggest to you (based on data I have from back in the day) that the 1998 fiasco involved “moving targets” by the EPA and a series of six misunderstandings. Perhaps a different political “appointee or official” had to make their mark and at the eleventh-hour he/she/group did not agree with the “‘on’ in city, ‘off’ in steady state highway conditions.” Obviously, the six manufacturers interpreted the agreement differently. An interesting concept to think about, yes, no?

CUMMINS - ALL BY MYSELF
The Lyrics
​

Which version of this song "All By Myself" do you like better? The original 1977 version written and sung by Eric Carmen that peaked at Number 2 on the Billboard Adult Contemporary chart. Or, the 1997 version sung by Celine Dion that was Number 1 on the Billboard charts?

I prefer the original Carmen song. If I remember, the lyrics go something like this:

Driving alone
I think of all the trucks I’ve owned
But when I face the EPA
There is no way

All by myself, don’t wanna be
All by myself anymore
All by myself, don’t wanna be
All by myself anymore

12/21/2023 Cummins – All By Myself​

Friday 12/21/2023 was the date of the press articles about the “Record 1.675-billion Dollar Fine.” This go-round Cummins bears the entire financial burden “all by myself.” How will the financials actually play out?

Who knows.

Known Recap.

• 1.675 billion ÷ 960,000 trucks/vehicles = $1745 per engine
• Cummins’ profit for 2022 was 2.2 billion. Let’s assume the same profit level for 2023.
• Cummins’ profit for 2023 was essentially negated by the fine. (Or was it? Who knows how the accounting entries will read?)
• Recalibration of the engine’s ECU will be needed. (You’ll likely use more DEF.)
• Your warranty is still intact.

Items to Ponder

• The $1.675-billion settlement does not have any criminal charges referenced. (Unlike the VW scandal, to me this says “no intent” on the part of Cummins.)
• The “consumer” Ram 2500 and 3500 trucks are a part of this fiasco. The Cab and Chassis trucks (3500/4500/5500) are not mentioned. They fall under a different emissions testing procedure. Could there have been some confusion between Cummins and the government over testing?
• There is no hardware change required to the engine, a reflash of the ECU is needed. The truck will consume more DEF. Was Cummins (and Ram) out ma rketing the “great DEF/miles” advantage over their competitors? No. Heck, if I’m the engineer-dude…I’ll turn up the DEF consumption and I’ll sleep well at night.
• Cummins’ stock price should have taken a beating on this announcement. It hasn’t.
• There is an election coming up in November.
• I’m sure I’ll think of more…

Robert Patton

 

[bcbender]

Yeah it still smells a bit off color to me that it took them a decade of discovery to find some odd transient mode where the emissions are out of SPEC. Cummins and FCA (now Stelantis) would've tested the vehicles and engines to the applicable EPA / CARB drive cycles and engine Tier XX levels to measure and compare the emissions output to that applicable standard. I simply cannot believe they did not meet the standards that were assigned to those very specific drive / duty cycles in the product validation and certifications which then leads me to the next thought.
Did the EPA decide that there is a "new" drive cycle or mode that needs to be tested?
If so did they negotiate with the parties involved or go out on their own and measure / confirm it?
If so, then that's great, they are simply checking up on the actual situation and doing due diligence in the evolving aftertreatment arena to confirm the real world emissions and confirm if additional testing or modes should be imposed. We all know the new trucks use more DEF and likely have lower emissions that may or may not be related to this very issue in some backroom somewhere.
Where is gets murky is the word "defeat device" as if code is a device, and as if they were altering real time to allow for emissions that exceed the very certifications that as a manufacture they guarantee. I for one feel that if they cannot produce the specific method of "cheating" or defeating, then there technically was none. Seems more likely there was an effort on the regulatory body to tighten the NOx restriction and lower the allowable emissions level moving forwards (aka why the new trucks use more DEF). This happens all the time where new tests are created and new standards implemented based on technological improvement and real world testing. The only oddity here is that this seems to be the first time a engine / auto manufacturer is being fined for older vehicles not meeting a new standard that may have been created after the products were made, certified, and ultimately sold to the customers. It is very odd that they would then also go so far as requiring the manufacturer to, on their dime, go back and reprogram the trucks since in their minds the trucks are capable of lowering the level, if re-tuned, and that should be what is done. It sets a terrible precedence for manufacturers moving forwards if this pans out to be the case, since emissions levels could be retroactively applied on a whim of the regulatory body and the customer ultimately ending up holding the bag......

JM2C... but I agree with you Robert, I believe Cummins is a victim here, and this is likely the least cost option for them to move on....

 

[Diesel85]

Thanks for posting the CARB info.

The way I look at it, the damage is done.

Now it's time to pick up the pieces and move on.

Will I still buy a Cummins? A diesel? Absolutely.

I'm itching for a real refresh to happen (Gen 5), and I'll pull the trigger to have a heavy duty again.

For now, my work 3500 Cummins and my EcoD is filling my diesel needs. I want more diesel. That's the problem.

 

[Tuesdak]

Now it's time to pick up the pieces and move on.

No, it’s not. Divided we fall, united we stand. It’s divided to ask why are gasoline engines allowed to be higher. We need to be united in saying “No! The standards are too strict for the minor reduction in emissions gained.” Do not encourage another “Glowing Government Report” that puts the target on gasoline engines.

Last I checked our diesel emissions were stricter than the EU.

Uses more DEF… that is in short supply. You should care as it’s also an ingredient to make the food that goes on your table. Inflation as farmers have to bid against diesel engine use of a scarce commodity.

The EPA’s retro law or cost prohibitive strict standards have reached a point where there is no return on investment. Rather it costs everyone more. DEF wasn’t on my bottom line when I shipped RV’s and auto parts. However the DPF of the 2008 era costing me 10% of my MPG I had to eat it as the broker didn’t pay more for DPF rigs.

I am glad The TDR was able to induce vomiting for the Kool-Aid initially swallowed.

I say again Retro-Laws were already proven by CA banning pre-DPF diesels.

 

[Diesel85]

No, it’s not. Divided we fall, united we stand. It’s divided to ask why are gasoline engines allowed to be higher. We need to be united in saying “No! The standards are too strict for the minor reduction in emissions gained.” Do not encourage another “Glowing Government Report” that puts the target on gasoline engines.

Last I checked our diesel emissions were stricter than the EU.

Uses more DEF… that is in short supply. You should care as it’s also an ingredient to make the food that goes on your table. Inflation as farmers have to bid against diesel engine use of a scarce commodity.

The EPA’s retro law or cost prohibitive strict standards have reached a point where there is no return on investment. Rather it costs everyone more. DEF wasn’t on my bottom line when I shipped RV’s and auto parts. However the DPF of the 2008 era costing me 10% of my MPG I had to eat it as the broker didn’t pay more for DPF rigs.

I am glad The TDR was able to induce vomiting for the Kool-Aid initially swallowed.

I say again Retro-Laws were already proven by CA banning pre-DPF diesels.

@Tuesdak I understand where you are coming from.

Don't even get me started with how lenient the EPA is with gas vehicles. Go look at any modern gas car, and you see a black, sooty tail pipe. I hate the smell of gas vehicles, especially when they are floored or when going up a hill/mountain. That nasty sulfur or rotten egg smell is disgusting. If one does research, it is actually the converter system not doing it's job. But yet, that's allowed to pass emissions?! On top of all of the stupid EVAP nonsense that usually starts giving the user issues well before 100k miles?

If emissions was THAT important, why isn't the EPA and CARB going after these gasoline engines? How about all of these cheapscape dinky little cars that start eating a quart of oil after 50k miles, but yet still seemingly are able to "pass" emissions? But yet our high end, highly advanced diesel trucks are always under scrutiny? That's what ticks me off! Why aren't gas engines having diesel-gates??

It all boils down that "they" don't like us diesel owners. It goes beyond that... "they" don't like the fact that the diesel engine is clean, reliable, safe, and when engineered to do so, be ran on fuels that the "normal" person can be able to get or make. It's easier for "them" to control gas, electric, and hydrogen. Also, after reading about all of the hybrid and EV fires lately, no way, no how is one of those getting parked near any of my buildings, especially not one I sleep in. "They" are targeting us because diesel is the means of cultivating, harvesting, and transporting food to everyone's dinner table in a reasonable time frame and for a reasonable cost.

My EcoD is the first vehicle I've personally owned that requires DEF, and it add to the cost of operation, especially adding in on a ROI. Granted I use the more expensive bottled DEF, either way, it still adds into the cost of ownership and running tab. Something that my pre-DEF 2002 Cummins 2500 didn't need.

As far as strict emissions... EPA2027 is interesting......

https://www.4cleanair.org/wp-content/uploads/2023-03-03_EPA_HD2027_FRM_NACAA.pdf

https://www.epa.gov/system/files/documents/2023-04/420f23009.pdf

 

[bcbender]

My EcoD is the first vehicle I've personally owned that requires DEF, and it add to the cost of operation, especially adding in on a ROI. Granted I use the more expensive bottled DEF, either way, it still adds into the cost of ownership and running tab. Something that my pre-DEF 2002 Cummins 2500 didn't need.

Me too, but if you buy in bulk at a truck stop... its really not a huge deal over all... just another step we didnt have to think about 2 decades ago, personally Im ok with is , I can stand on the white glove in my tailpipe as evidence, but I also live near big truck stops so it isnt a cost issue for me.

 

[Tuesdak]

Don't even get me started with how lenient the EPA is with gas vehicles. Go look at any modern gas car, and you see a black, sooty tail pipe. I hate the smell of gas vehicles, especially when they are floored or when going up a hill/mountain

They smelled a lot worse around 1990. I still recall being slightly behind a 350 Gas V8 powered Suburban "sulfur smell" while our disposable engine NA 6.2L Diesel Suburban was smoking a light haze. The EPA has forced sulfur removal from fuels since. Putting a turbo on a automotive diesel apparently would have put GM into insolvency as well as timing gears or even a 3 bolt starter.

We need more members like you to "stir the pot" on alternative fuels. Mr. Diesel's original design has been adapted to #1 and #2 ULSD with older, antique and vintage, designs suffering wear from ULSD being so dry as far as lube quality. (It's the sulfur removal process that reduces lube quality not the actual sulfur itself that most think provides lube in diesel. It doesn't.) Oddly we debate engine oil passionately yet most ignore the changes to the oil in the fuel tank. The most thought to fuel appears to be cost and where is the cheapest fuel. Followed by "what can I wreck the injection system and engine with?" say waste cooking oil, engine oil, etc. I do not understand why B99 is even allowed for sale as it raises the unholy NOx emissions levels of a diesel engine. You know the ones that don't have sensors in the exhaust? It also LOVES water that contributes to bug growth in the fuel. Further it doesn't evaporate as well as #2 diesel fuel. This means during DPF regeneration with a exhaust stroke injection event some of the B99 hits the cylinder walls. Oh yeah, it also doesn't evaporate out of the engine oil like #2 ULSD will. You need better water separator fuel filters to run even B20 and need to change the engine oil more often. As the bugs in B99 ate up a couple of my injection systems and a pallet of fuel filters I suggest it's an experimental fuel and YOUR injection system with the question of "What's in your wallet?" is the R&D.

(B99 is referenced as there was/is a blender tax credit so 1% ULSD was added for a $1.00 gal tax credit to subsidize the Biodiesel industry. Otherwise I may as well say B100 as 1% is a rounding error.)

Do you know of ANY OEM that has emissions certified a diesel engine for B100? I haven't looked in awhile and the answer would be interesting IF there is one. B20 is the highest I have seen so far. The RAM Cummins does not use an expensive dedicated exhaust injector for cleaning the DPF like some of the V8 do: The dedicated injector eliminates the post DPF injection cycle and it's engine oil fuel contamination problem. Without the dedicated exhaust injector DPF regen is also affected from less fuel evaporating to heat it up during the regen process. If Diesel fuel is mandated by law to contain more than 5% Biodiesel, like it is at 5% by law now in Arizona, my 2018 RAM Cummins will be OBSOLETE.

CARB is already tinkering with the B99 NOx problem in fuel. This wasn't in the fuel when your 10-30+ year old diesel was built. Who knows it's affect on fuel system: metals, hoses, and seals used in the day.

https://ww2.arb.ca.gov/sites/default/files/2018-08/ADF_FAQ_11-27-17.pdf

I am not convinced that B100 is better with what it takes to grow and refine it. Carbon Neutral is a PC term that avoids the question of: it this cost effective or even practical?

I will make an informed guess as to why gasoline engines smell bad under load AND the MPG goes in the toilet single digits when towing or loaded: The catalytic converters for the "EPA foaming at the mouth in their Glowing Government Reports" wants the converters to warm up as fast as possible so they are too close to the engine. I would suggest they believe grocery getter use is more frequent than towing or grades. So to keep the cats that quickly warm up from "melting down" during high/full engine power they have to "put the fire out" in them. To only way to do this is remove the oxygen via going rich. So long grades or towing becomes an overheat converter situation and the ECM is forever dumping fuel to keep the fire out: otherwise melting and ruining the expensive cats the EPA has deemed more important for warm up cold emissions.

This may be why the turbo Fords puff black smoke to keep the converters from melting. I recall a ~1995 Ford Minivan at work that had a spotless tailpipe.

Cold performance be EPA concern #1 say from one of the videos noting cold performance being worse for Cummins vs, the big three and perhaps the basis for the recall and fine: it's a guess on scarce info.

 

[Diesel85]

Yes, I remember back in the 90's with the more awful sulfur smell from gas engines. That was when I more turned off by the whole EPA nonsense.

Eh, "stirring the pot" is a double-edged sword... Especially with the CARB/EPA, as they see unicorns pixie dust eventually powering our rigs. The corruption is going to go in the direction they want it to go in. So someone like me could cause negative waves for the folks that don't want to hear it or don't understand how diesel tech works. However, on the positive side, folks should be informed and aware of what is happening and the terrible direction we are making.

However, I'm a bit outspoken for Mr. Diesel's invention, as for all intensive purposes, we have the technology now to improve on his technology even more. Been a diesel fan since I was a little kid. We used to have a Ford F250 IDI and a Ford Escort diesel. Gosh, I remember those days of 75 cent #2 diesel... lol

I agree on the PC term of is this cost effective or even practical. Batteries are not cost effective nor practical to replace everything, let alone hydrogen. Look at what happened during the past cold snap with all those EVs in Chicago and elsewhere. That was a huge negative publicity stunt for EVs.

I keep seeing more interesting topics on the hydrogen engines, but they all use spark plugs and not natural compression ignition tech. They all state that the NOx from hydrogen is more than twice that of our diesels, which from what I've read something like AdBlue is the only cure to it, but the dosing percentages are high. Meaning more AdBlue is being used per mile. Again is it practical? How about all of the nitrogen used to make AdBlue? At least with the current diesels, they consume the DEF at a lower rate than they would if they were say hydrogen engines. How about the cost to make hydrogen? As far as I'm aware, the only way to get hydrogen on Earth is to synthetically make it using electricity or chemicals.

Maybe bio diesel isn't the right path, but one thing I can say for certain, is that compression ignition engines are the way moving forward. It's just the right fuel that needs to be injected into them that makes sense.

As far as the 5% biodiesel, look at what they did to the EcoD owners like myself. When I go into get the HPFP recall done, the owner is given a card that tells them that only 5% bio diesel is allowed. Versus before it was B20. I'm surprised there isn't lawsuits heating up from that.

It is interesting on the thoughts on the catalytic converters. It does make sense.

The cold performance is an interesting note. I do know that our work F350 diesels have a much heavier DEF smell when we first start them up. More so if they get idled for like 5-10 minutes right after a cold start up. However, the work truck I routinely drive, being a 2020 Cummins, smells about the same... but that's just my nose. It's so hard to tell, more so when you got like 4-5 of them sitting there idling.

I'm hoping my kids will be able to get a diesel or a compression ignition engine when they are my age to drive around in.

 

[Diesel85]