Here is a truly NEW development in the DEF failures

[Fanukalum]

Originally Posted by buck58

Where can I get one

X 2

[Archer2]

Originally Posted by Bobby F

As someone who has conducted many trials, state and fed court, even a few with the EPA, I would buy this device if it would get my dead RV off of the road and into some safe place.

And then I would unplug it and await the right parts.

I won't go into all of the reasons for saying this here. This isn't the right place. But . . . there is no "damages" phase in a criminal trial.

Hi Bobby. Two things about your post. First, I want to stress again that what we are discussing here is not a “product” that you can buy. It is a description of parts that you have to obtain and assemble. Part of the process is to download some free, no charge, given away, no guarantees software as one of the components. This is no different than saying I’ll tell you how to fix your toilet but first you need to buy some parts at Home Depot.
Second, just for the sake of argument, if the EPA wanted to assert that what’s going on constitutes a “Prohibited Act” under the CAA, an assertion I strenuously disagree with, what part of the CFR allows a criminal action? All actions the EPA has ever taken, even with parties who were CLEARLY and grievously violating the letter of the Regulations, were Civil/Administrative proceedings. Also how is doing effectively the same thing that the EPA is encouraging the manufacturers to do, which is to prevent the ECM from derating the engine due to bad data from a failed sensor, a problem?
I know I said I didn’t want to debate this issue but since you implied that you had some expert knowledge of the courts’ proceedings I would like like to be better informed.

[Bobby F]

Originally Posted by Archer2

Hi Bobby.

Hi, Archer2.

As an initial matter: congrats to all on what appears to be a good bit of reverse engineering and engineering. Sounds like an elegant solution to the problem - if you can get agency approval. Like I said, I would use it to get off the side of the road and get my rig home. I would consider it to be a risk with no benefit to just leave it on and continue use. As to your two questions:

First: When I said "buy this device", read it as "buy the parts and assemble and install this device." I didn't necessarily mean "buy this device from these people who are discussing it." This can be an important distinction for an owner's decision, as there is no one left higher up the chain to point at and claim "he sold it to me and said it was okay!" If an owner follows the instructions and buys the components and programs it and installs it, it's clear why he did so, and "intent" is purely locked up.

Second, EPA has long had criminal prosecution as one of its tools. Its use seems to cycle up and down depending on who is in charge, but currently I'd call that area "almost robust and rising." Its use is predicated upon intent. A conviction of knowing intentional violation of the CAA carries criminal penalties. If someone bypasses the DEF component of the anti-pollution equipment on a large diesel in order to get it going again or keep it going in the face of a difficulty, I'd have to infer intent. My crim-EPA experience was mostly in RIFRA, not CAA, but they're both enforced and prosecuted by the same AUSA's, and they tend to be dour humorless believers in the letter of the law.


(Edited to add an afterthought: In the case of individual owners, the matter would likely be small enough to be handed over to your particular state's version of the EPA. Here in MN, it's the MPCA, backed by state or local prosecutors. A bit easier to deal with, but still not your happy-go-lucky brother-in-law who says "ah, no big deal, just take it off!")


I'm not going to go search for the CFR or statutory support for this - I'm lazy, I'm retired, I'm boondocking and I'm off Westlaw. But just a quick Google search of "EPA CAA criminal" gives me these as numbers one and two:

https://ballotpedia.org/Enforcement_at_the_EPA

"The U.S. Environmental Protection Agency (EPA) can initiate civil and criminal actions against against private individuals, businesses, and organizations through enforcement of federal environmental laws. Civil enforcement involves EPA or state-initiated legal action to compel compliance with federal law and may involve fines or penalties leveled against private parties. Criminal enforcement involves criminal investigation and prosecution of deliberate and/or severe violations of federal environmental law. Some violations can result in jail time."

https://www.jdsupra.com/legalnews/pu...rough-7586547/

" . . . several federal environmental laws contain criminal provisions. For example, the Comprehensive Environmental Response, Compensation and Liability Act (“CERCLA,” sometimes referred to as Superfund), the Clean Air Act (“CAA”), the Clean Water Act (“CWA”), the Resource Conservation and Recovery Act (“RCRA”), the Federal Insecticide, Fungicide and Rodenticide Act (“FIFRA”) and the Toxic Substances Control Act (“TSCA”) each provides the imposition of criminal fines and penalties as well as imprisonment for knowing violations of the applicable requirements."

The DEF feedback loop - the loop that collects data and then shuts down your engine if the data isn't within proper parameters - exists only because of EPA mandate. The EPA wasn't going to allow the system without it. Depending on owner compliance - "my red DEF failure light is on, it might be still working fine or not, I'm going to keep driving until I can find out" - wasn't acceptable to them. So it's there. (Would any RV/diesel maker have put in such a system if it were voluntary?)

This device deletes that mandatory shutdown from the chain of consequences of bad data. At the point where you install and engage it, you have "interfered with or removed mandated anti-pollution equipment or function."

Of course, all of this is only a danger to you if the EPA decides to target RV modifications and individual RV owners. Risk/reward decision. While the EPA may see no huge incentive for going after such modifications, there's also little risk in doing so, because the affected market is not within some politically protected class of people. So, you takes your chances, I guess. For me, it's a chance I'd not take. When the EPA comes after you, your life usually gets worse in many ways.


So let me emphasize: 1. Great piece of work! and 2. If I was stuck on the road, I'd buy it and install it temporarily in a heartbeat, and remove it when I could no longer claim emergency.

[Archer2]

Thanks Bobby. I appreciate your time and informed opinions. I was serious about wanting to be better informed and your response helps. As you can probably tell, we are just a group of private citizens who are really wanting to solve a problem for ourselves and a bunch of similarly-situated strangers. We are not interested in selling or manufacturing any commercial product. We would never knowingly break a law. You have given me some things to look at and I thank you for it.

[Bobby F]

Again, Archer2, great work. One question that I have that is sort of central to how EPA might react:

If you get the dreaded DEF head failure, and your rig is shut down even though the DEF system is still working, and you then install this device and keep driving with your antipollution gear intact and working, what happens if your DEF system then truly stops working? Does this device still block the derating and shutdown? That's the problem at the core, to the EPA.

If you could get around this issue, I think you'd be safer. If your rig would still derate in the presence of a true antipollution failure, EPA might be kind. At that point, you've simply replaced a faulty sensor system with a better one. But, your only data on this is what comes through the head, which has been bypassed.

[Archer2]

my understanding is that if you truly, and foolishly, just let the DEF tank run dry the sensors that directly monitor the actual effectiveness or efficiency of the DEF catalytic reaction (i.e. the input and 0utput NOx sensors, among other sensors) in the exhaust system would quickly begin to generate severe faults and warnings. The would, according to Cummins' QSOL service document portal, force the same derate to 5mph but with different codes. Specifically SPN 5246 FMI 0, fault code 3712. That is why I stress often that this is NOT a "delete" device and does not bypass or eliminate any emissions mitigation systems. The operator is still responsible for maintaining the DEF quantity and quality manually by direct inspection.

[Bobby F]

Archer2, if there truly are redundant systems that will shut down a polluting rig even if your DEF head device is installed and working, then I think you're closer to tacit acceptance by the EPA folk. They might still see it as a violation, but with minimal harm. That helps in their enforcement decisions - so long as you're not dealing with a "by the book always" type. Someone there has to decide "is this worth pursuing?" If no pollution is going to result, it might not strike them as the best use of their time.

[flyboy013]

According to Cummins documents, when fault 3031 occurs the “Diesel exhaust fluid injection into the aftertreatment system is disabled.”

So by using the emulator, not only are you avoid the inevitable derate, you’re actually allowing your engine to continue to run in an environmentally friendly way. Perhaps the EPA would like that.

[Archer2]

Hi Flyboy, (not Flyboy013, the one further up) sorry I’m late responding. There is some confusion about the hardware. It is not the case that you need to buy different hardware for different makes/models of coach. What you will have is two or three models of controller boards which will all work. There is no performance or feature difference among them. The idea is to have a few choices depending on what is available at a good price. I can tell you that you can pick from Three models of Arduino boards. They are the UNO, MEGA 2560 And DUE in order of increasing cost. The next thing you need is what Arduino calls a “Shield” but is really just a board that connects on top of the main board and performs interfacing functions. It’s called a “CANBUS” shield. For the UNO and MEGA 2560 you will need a Seeed Studio CANBUS v2. For the DUE you would need a Copperhill Dual CANBUS shield with Extended Power option. You can buy the Arduino and Seeed on Amazon. The Copperhill shield you have to buy from Copperhill Technologies (Google it)
The rest of the parts are just simple wiring, connectors and enclosure/mounting.
This may look a little intimidating but take a look at some pictures and you’ll see that it’s just a little 2x4 inch circuit board with another similar “shield” piggy-back board that mates to already installed headers on the bottom board. Basically they just snap together to form a 2 board assembly.
Again, you can pick whichever hardware that you can buy conveniently, they all work the same for this purpose.
I also should warn you that it’s your responsibility to verify the cabling and connector type for your make and model of Motorhome. You especially need to locate and verify the placement and type of connector (although it should be a standard 4-pin automotive connector) that connects your sensor head to the vehicle wiring harness because that is where you will need to disconnect the failed sensor and substitute the device. The developers have no way of researching every possible variety.
And I will say again, this is <NOT> a “delete” device. You must still make sure that you have proper DEF fluid in the tank at all times. Your vehicle will still consume DEF fluid at the same rate as it always did. If you allow the tank to run dry you will not only get derated anyway and quickly but you may also cause damage to other, really expensive components.

[RealNiceTent]

OK, so I need a little information on this subject. I could swear that my brother said the gauge for his def tank was still working when his sensor failed in the OTR tractor. Now what I would like to know is co the coaches with the DEF system have a level gauge on the dash for the DEF tank? And second when the system codes and puts you in the 5mph de-rate does the gauge still work?

[brobox]

Originally Posted by RealNiceTent

OK, so I need a little information on this subject. I could swear that my brother said the gauge for his def tank was still working when his sensor failed in the OTR tractor. Now what I would like to know is co the coaches with the DEF system have a level gauge on the dash for the DEF tank? And second when the system codes and puts you in the 5mph de-rate does the gauge still work?

On one of my DEF heads, the gauge, 1761 code continued to work, but the other de-rate code were present.

[TXiceman]

I know, no one likes more rules and laws, but if the Federal government would step in and make a law that all emissions systems on all vehicles had to have a manufacturers emissions warranty for a much higher mileage than the current 50,000 miles. Engines are lasting much longer and people are keeping vehicles longer. I think diesels need to be pushed up to 250,000 miles and gasoline engines at 150,000 miles. With this kind of warranty requirement, I can guaranteed that the manufacturers would have better emissions control systems on their product.

Sure it would cost up more to buy the vehicle, are a few multi-thousand dollar repairs and being without use of the vehicle, it would even out for the better.

Ken

[dwaugh10]

This is some of the hardware Archer2 was talking about:

[brobox]

Thank you David! That has been bookmarked!