Anne Wick
U.S. Environmental Protection Agency (Mail Code 2242A)
Diesel Engine Consent Decree Coordinator
1200 Pennsylvania Avenue, NW
Washington, DC 20460-0001
wick.anne@epa.gov
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
here is a letter from ATS to the EPA............. what u think? :banned:
U.S. Environmental Protection Agency (Mail Code 2242A)
Diesel Engine Consent Decree Coordinator
1200 Pennsylvania Avenue, NW
Washington, DC 20460-0001
wick.anne@epa.gov
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
here is a letter from ATS to the EPA............. what u think? :banned:
