Anne Wick
U.S. Environmental Protection Agency (Mail Code 2242A)
Diesel Engine Consent Decree Coordinator
1200 Pennsylvania Avenue, NW
Washington, DC 20460-0001
Dear Anne:
I would like to start by thanking you for speaking with Stewart Cables and myself at SEMA. You and your team did a very good job of preventing the meeting attendees from rioting!
As you may or may not be aware, ATS Diesel has been working on certain emission technologies to better our niche in the diesel community. Currently, we’re funding and developing a very expensive Diesel Particulate Filter (DPF) technology; this product will allow more efficient flow, resulting in better fuel mileage and lower emissions than today’s technology. ATS’ profits are funding the majority of this project’s development budget.
A serious concern that we have — and dramatically affects the development of our new high flow DPF -- is the presence of so-called “DPF Delete Kits” on the market. Right now consumers are looking for a solution to the problematic factory DPF exhaust systems, and a few companies out there are manufacturing and/or selling these DPF delete kits for a very low margin.
As you’re aware, the main problem with DPF delete kits is this: for every illegal kit sold, research money is not invested into a real “fix” for the consumer’s problem. EPA has made it clear to the diesel manufacturing industry, in no uncertain terms, that DPF removal is illegal. However, at this time, EPA has been unable to enforce its regulations to get these illegal DPF delete kits off the street. When we spoke a few weeks ago, you mentioned that the EPA can only enforce so many of its regulations right now, and it’s becoming increasingly difficult to track offenders (whether they be manufacturers, resellers, or end users).
ATS has prepared a list of the larger DPF Delete kit manufacturers and resellers, gleaned from our knowledge of the industry, for you. We’ve also included support documentation for your convenience. A few of these act as resellers (in place of manufacturers) in an attempt to hide behind a “shell corporation.” Performance Diesel, Inc. (“PDI”) in St. George, Utah is one of these companies. Jared Wittwer, the owner of PDI, is also the creator of H&S Performance, (H & S Performance). All of these kits are assembled at PDI in Utah and sold through PDI as though H&S Performance manufactures them. Attached is a copy of one of the receipts PDI invoices on; the part number should easily be used to help track down additional units that PDI or H&S have sold over the last year. We have been told by PDI’s manager that they sell over 100 units per month.
ATS is relying on the EPA to enforce its rules on this matter so we can generate enough revenue to properly manufacture a “fix” to the DPF problem. The word in our industry is that 1) if you don’t manufacture, you are allowed to resell, install, and use, and 2) manufacturers or resellers can hide behind the “Race Only’ labeling that the products are sold under. The fact is, and as I’m sure you know, nearly all of these kits are being used for on road trucks. Thank you for taking the time to listen.
Clint Cannon and Stewart Cables
for ATS Diesel Performance
ATS... Come on, I know you have something wity to say???
The DFP does not work here in Alaska. Because my exhaust does not get hot enough to burn what is inside when its -40'F. DPFs clog up here and our local Ford diesel techs spend about half of thier time cleaning turbos, EGRs and DPFs when its cold out. Nothing ATS or anyone else can do will "fix" the problems connected with cold weather operations.
As a side effect my fuel mileage is better without the CAT. That means I am burning less of our prescious oil. I can't help but think that means I am making less emmisions.
ATS should mind thier own business. They certainly don't have to worry about building anything I will spend MY money on.
__________________ 06 F-350, North Pole, Alaska
Brush Guard w/4 moose lites
Mobil-1 Turbo diesel truck oil
fuel filters every 10,000 miles
AstroStart auto start
98 gal Transfer flow tank
Rhino liner on the rockers
Wabasto-Blue heat
MBRP turbo back duels w/ no CAT
I have been waiting to see what the fallout from this has been. Haven't heard anything since a few days after it was posted. Any new developments on the ATS blunder? Just curious...
__________________
'04 F250 KingRanch CC FX4 6.0 swb "BIG D" Tim
GO FLYERS! GO PHILLIES!
Originally Posted by hubler13f When congress refuses to provide soldiers with the equipment to complete the mission. S.T.E.A.L. Sudden Transfer Of Equipment to an Alternate Location
can't believe this thread didn't take off like mad.
__________________ 06 F-350, North Pole, Alaska
Brush Guard w/4 moose lites
Mobil-1 Turbo diesel truck oil
fuel filters every 10,000 miles
AstroStart auto start
98 gal Transfer flow tank
Rhino liner on the rockers
Wabasto-Blue heat
MBRP turbo back duels w/ no CAT
Yeah, really. What gives? I mean there's been absolutely nothing?
__________________
'04 F250 KingRanch CC FX4 6.0 swb "BIG D" Tim
GO FLYERS! GO PHILLIES!
Originally Posted by hubler13f When congress refuses to provide soldiers with the equipment to complete the mission. S.T.E.A.L. Sudden Transfer Of Equipment to an Alternate Location
The heat went elsewhere. Mainly because this particular section isn't as highly viewed as others. This was also posted in a few other sections of this forum, some were deleted, some didn't go too far. Other forums such as CompD has hundreds of pages dedicated to this.
In short, the letter was real, but it was never sent to anyone. It was a draft letter created by ATS's lawyer and emailed to Clint. There it sat in his inbox until an employee (or former employee) hacked into his account and retrieved it.
Several issues surrounded this, particularly why this letter was drafted in the first place. Apparently it was a follow up letter from events, seminars, and discussions between ATS and the EPA during SEMA. ATS has not denied that some or all of what is in the letter was already discussed in person at SEMA with the EPA. Also, they are not apologizing for the letter. The entire situation is just plain ugly.
__________________
Curtis
2002 F-250 PSD
Best time: 15.3 @ 86.8 MPH at Bandimere - 9/10/08
The DFP does not work here in Alaska. Because my exhaust does not get hot enough to burn what is inside when its -40'F. DPFs clog up here and our local Ford diesel techs spend about half of thier time cleaning turbos, EGRs and DPFs when its cold out. Nothing ATS or anyone else can do will "fix" the problems connected with cold weather operations.
As a side effect my fuel mileage is better without the CAT. That means I am burning less of our prescious oil. I can't help but think that means I am making less emmisions.
ATS should mind thier own business. They certainly don't have to worry about building anything I will spend MY money on.
About you thinking that since you are burning less fuel you must be making less emissions, its a sticky thing really, my truck(03) gets better mileage then my dads 08 but drive behind both of us and you'll know for sure who is putting out more emissions, even though I can drive a couple hundred km's more per tank then him.
Ok, I'll be the guy to give you the comments you expected.
Quote:
Originally Posted by CSIPSD
ATS’ profits are funding the majority of this project’s development budget.
Let me see if I have this straight, you sell products and then spend profits from those products on R&D for other products. I'm pretty sure that this how business works in today's world. At least, that's how my company understands business to work.
Quote:
Originally Posted by CSIPSD
As you’re aware, the main problem with DPF delete kits is this: for every illegal kit sold, research money is not invested into a real “fix” for the consumer’s problem.
Is the "research money" referred to here the ATS profits that they don't feel they should be spending on their own research? I don't see how they gain anything from people not buying the DPF in the first place.
Of course, this is just my $0.02.
__________________
Brad
2003 F-250 Lariat Supercab 4x4 6.0L PSD, Fumoto, Updated HFCM Plug, DieselSite Bypass Coolant Filter, 22" Wiper Blades, more to come...
2008 Taurus X Limited AWD w/ a Fumoto (The Wife's Family Truckster)
Quote:
You haven't lived life until you've done 110mph in a Yugo
they wont be able to do jack ****, as long as theyre intended for "offroad use".
Except for when they're found on highway trucks. IE every truck in Texas is "safety inspected" at least annually. So in states that do something similar, the truck is obviously intended for on-highway use. Then the state, acting as an agent of the EPA, can seize and impound your truck, then fine the crap out of you for violating federal code.
__________________
Bryan
2007 F-250 6.0L PSD FX4
Growing four inches straight up by Christmas
In California, we are starting a program to retrofit DPF's on existing medium and heavy trucks. The phase-in will take several years, but eventually all medium and heavy diesel trucks operating in the state will have DPF's. A part of the program is also to eventually retrofit DPF's to all off-road equipment as well. How they are going to enforce that part of the program remains to be seen. There is also a question of what they will do to light trucks with diesel engines. No word on that yet. Scary thing is, as California goes, so goes the EPA. If it happens here, it's just a matter of time before the rest of the nation follows. Several states allready use California standards.
In California, we are starting a program to retrofit DPF's on existing medium and heavy trucks. The phase-in will take several years, but eventually all medium and heavy diesel trucks operating in the state will have DPF's. A part of the program is also to eventually retrofit DPF's to all off-road equipment as well. How they are going to enforce that part of the program remains to be seen. There is also a question of what they will do to light trucks with diesel engines. No word on that yet. Scary thing is, as California goes, so goes the EPA. If it happens here, it's just a matter of time before the rest of the nation follows. Several states allready use California standards.
I think that is the wort idea ever. Why waist tons and tons of $$$$$ on stuff that sorta works and gives horible fuel ecnomy?
__________________
Nick PAA#9
08 F-450 K R 6.4 SPARTINIZED, DPF/CAT GONE
04 X 6.0, 08 towing mirrors, 15k hitch, Firestone air bags
01 X 7.3, TN BB turbo, Dp tuner, ITP RR, RR up pipes, 4 Dipricol gauges,MBRP 4inch, 6637,650 dash with 2 auto meeter gauges, RR boots,
95 F-250 7.3, 6637
I think that is the wort idea ever. Why waist tons and tons of $$$$$ on stuff that sorta works and gives horible fuel ecnomy
Nick,
Thats what these bheads do up in Sac ( damn polictians) but did you read the Times today?Arnold is basically putting environmentalists on hold as pushes through some big projects such as $165 million carpool lane expansion on hwy 50 that was delayed because of greenhouse gas it might create. Jobs go a long way right now , some of these laws just don`t make sense to everyday peeps. Yes alot of states play follow the leader in hopes of chasing federal $
Who cares? Bottom line is like every new piece of emissions equipment that has ever come out for the truck and automobile industry since the begining has gone through this same garbage. There will always be ways around it and there will always be kits made available to those wanting it. The company producing the kit is not liable for anyperson who buys an "off-road use only" product and uses it on an "over the road" vehicle. All PDI has to do, as well as everybody else is just label it like they have and be done with it. SEMA nor the EPA can do anything about the company, however they can do something about the vehicle user and they will just not anytime soon.
ATS- well as far as im concerned, Clint needs to grow a sac and deal with competition in the business world, not draft a letter trying to do-away with them. Nobody likes a snitch, especially one that won't stand up and say "Yeah, I wrote it"
FYI- ATS has a 6.7 thats missing a DPF..... must have missed that in their letter
Cowboy Steve
__________________ DI Performance Beans Diesel Stecher Perfomance Hellmann Performance
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06 F-350, North Pole, Alaska
