Comment by itsdrewmiller
15 hours ago
> As one example, one state agency has asked Revoy to do certified engine testing to prove that the Revoy doesn’t increase emissions of semi trucks. And that Revoy must do this certification across every single truck engine family. It costs $100,000 per certification and there are more than 270 engine families for the 9 engines that our initial partners use. That’s $27,000,000 for this one regulatory item. And keep in mind that this is to certify that a device—whose sole reason for existence is to cut pollution by >90%, and which has demonstrably done so across nearly 100,000 miles of testing and operations—is not increasing the emissions of the truck. It’s a complete waste of money for everyone.
Wild - whoever did this should lose their job.
The problem isn’t that regulations exist. The problem is that they are defined in a way that reasonable work arounds or alternative pathways do not exist for situations like this. 270 engine families for 9 engine suggests that the designs may be small variations that would not significantly change the emissions between them. The bureaucrats should waive off some requirements here.
The other alternative that I can think of is that experimental engines get an exception to be not certified for X miles of operation. Once the candidates are chosen for mass production, mandatory certifications can be introduced. Even if your new design doubles the emissions for some reason, over 100000 miles, that’s barely a drop in the bucket. For reference, double the emissions for 100000 miles is roughly equivalent to having an extra semi on the road for a year, which is nothing.
> The problem isn’t that regulations exist. The problem is that they are defined in a way that reasonable work arounds or alternative pathways do not exist for situations like this. 270 engine families for 9 engine suggests that the designs may be small variations that would not significantly change the emissions between them. The bureaucrats should waive off some requirements here.
Any form of regulation is attacked by those who seek to profit by freely causing the harm that regulation prevents. These attacks aim at completely eliminating any and all regulation, but also aim at eroding it so that complying with the letter of the law is ineffective at actually complying with the spirit of the law.
Trying to make mountains out of molehills is one way to attack regulation.
Look at OP's example. In no way did OP offer any support for the $100k price tag for certification, or even mentioned what this hypothetical amount represents in the total investment in a product such as an engine. We're talking about investments that range well in the tens of million of dollars. It's an insignificant drop in the bucket. The design team's salaries alone eclipse that value. On top of that, a single engine alone sells for thousands. Is this hypothetical regulatory cost that high if it can be covered by selling a few dozen units?
The combinatorial explosion is also a far-fetched example of this desire to make mountains out of molehills. You do not need to recertify a whole engine if you do a minor change out of a whim such as changing the color of a knob.
Ultimately, the goal is to ensure that whoever wants to sell an engine isn't putting out subpar products that underperform and outpollute at clearly unacceptable levels. If proving that your product is not poorly designed and irredeemably broken is too much to ask, is regulation really the problem?
> We're talking about investments that range well in the tens of million of dollars. It's an insignificant drop in the bucket. The design team's salaries alone eclipse that value. On top of that, a single engine alone sells for thousands. Is this hypothetical regulatory cost that high if it can be covered by selling a few dozen units?
I think you missed the context here. Revey, the company being asked to do these certifications, doesn't make diesel engines for semi-trucks. The company makes an electric "powered converter dolly" which puts a mini trailer between the semi truck and trailer that uses batteries and electric motors to reduce the amount of diesel burnt per mile.
It's clever solution, there are externalities to consider (increased truck weight and length, changes to turning behavior, etc) but expensive certification per motor to prove that giving a truck an extra electric push doesn't increase the emissions doesn't strike me as making sense.
We need more information. How does this work for internal combustion truck engines?
Is the regulation well intentioned poorly designed? Is it anti-competitive gatekeeping drafted by lobbyists? Is the author misrepresenting something? All of the above? Hard to say.
I imagine that the variation is in the internal combustion engines the system is being paired with. In that scenario, it can be that the regulator is treating the combined units as a new drivetrain and requiring certification of each combination as if it were a new engine.
It would be interesting to see a breakdown of what larger operators have in their fleets. It could be that a few certifications go a long ways. They are going to be at least somewhat inclined to avoid variation.
You cannot separate the idea of regulation from their harm because they are inherent to the concept. A system so complex and dynamical as human civilization is beyond our ability to correctly ascertain the outcome of interventions, especially those imposed from the top down. In other words, we're likely to do more harm than good by imposing interventions because we cannot accurately predict their outcomes. Which is why they often have paradoxical effects. Rent control is a fantastic if trivial example of such.
We know central planning doesn't work, yet we are inclined to do it anyway under the false notion that it's better to do something rather than nothing.
> A system so complex and dynamical as human civilization is beyond our ability to correctly ascertain the outcome of interventions, especially those imposed from the top down. In other words, we're likely to do more harm than good by imposing interventions because we cannot accurately predict their outcomes. Which is why they often have paradoxical effects.
This isn't quite right. There are some regulations that have such obviously enormous benefits that even if our estimates are imperfect, they'd have to be off by a thousand miles to not be the right thing. Examples like banning leaded gasoline or asbestos, or having antitrust laws that kick in if a market gets too consolidated for any reason.
The problem is then people start making a bunch of other rules that on paper would improve things by a couple of percent, but in practice because they're not accounting for overhead or their numbers aren't perfect they're actually making things slightly worse, and then multiply that by thousands of such individual rules and you've got a huge mess.
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>Rent control is a fantastic if trivial example of such.
No it isn't. Rent control is made to provide short term relief. Regulations tend to be long term requriements. Of course making a short term temporary solution long term does not work.
>we're likely to do more harm than good by imposing interventions because we cannot accurately predict their outcomes
For policy, I think it is important to be risk averse. Regulations are extremely risk averse. Slowing down reckless actions so that people don't die should be considered a good thing. Of course, that can be anathema to businesses who rush to be first to market.
I don't see regulations being a problem here, but the cost of the regulations. Instead of focusing on de-regulations we look into what that 100k certification is going to? Hopefully not yet another for-profit middleman with incentives to bog the process down.
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The "we" that knows central planning doesn't work and the "we" inclined toward central planning are the same?
If so, I've not met this group of people, but I'd like to share your first point with them because I tend to agree.
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> In other words, we're likely to do more harm than good by imposing interventions because we cannot accurately predict their outcomes.
This doesn’t follow from your premise.
> We know central planning doesn't work
Europe conquered the world using central planning. Every society on earth with any measure of security, order, and cleanliness to speak of is dominated by a central bureaucracy. It works.
> under the false notion that it's better to do something rather than nothing.
Doing nothing is precisely why anarcho-capitalists failed to change anything. Everyone smart associated with that movement studied power dynamics and moved onto other projects.
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And you cannot separate the idea of lack of regulation from the harm inherent to the concept.
This kind of lazy ideological posturing is thought-terminating and incredibly tiring.
Your position is simply unable to demonstrate to us how a blanket policy of letting whatever corner-cutting garbage slip into your food, medicine, construction materials, safety systems actually leads to globally better outcomes. It would be truly baffling if of all conceivable points on the axis it was a global optimum.
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Central planning is why our cities are no longer choked by smog. It is extremely difficult to predict outcomes in complex human system, but that cuts both ways: it’s hard to know if some intervention is good or bad, and it’s hard to know if leaving things alone is good or bad.
If you leave things alone, you get the light bulb and the airplane, but also leaded gasoline and radioactive tonics. The notion that it’s always better to do nothing rather than something is as fallacious as the opposite.
> We know central planning doesn't work
Most corporations and dictatorships seem to be centrally planned. Communism didn't work out for the Soviets, but they also didn't have smartphones and ChatGPT.
The magic of the system is that we all did it, comrade. There's multiple people, laws define what those people can do, processes, comment periods. It's all spiderman pointing at spiderman. You can't find any one party so clearly culpable that they can in good conscience suffer real consequence.
And it's not just this, every f-ing regulated industry is like this. I work with someone who specs out where the wires and fixtures for the lights are gonna go in commercial buildings. Ceiling lighting is full of crap like this for christ sake. The whole system is rotten.
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Having dealt with regulatory bodies before - they probably did lose their job, maybe multiple times, before becoming an engineer that doesn't have to engineer anything, just come up with rules.
>Wild - whoever did this should lose their job.
Why's that? Because a guy who's apparently friends with the owner of the company that produces these things told you that it saves emissions? Doesn't it seem reasonable to verify these claims?
No that doesn't seem reasonable at all if it's been proven to work _really well_ in several configurations and there's no particular reason to expect that the results would be drastically different in other very similar configurations.
Who proved it works really well in several configurations?
And how do you codify the threshold for what "very similar" configurations don't need to be tested and those that do?
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Of course we should verify such claims.
Just as we should also verify claims that every regulation that has ever been written into law is by definition Good (tm) and can never be questioned.
It's possible for the friend of the company owner to astroturf an online form to get a good regulation eliminated, just because it didn't benefit him.
It's also possible for the such wealthy individuals to astrotruf in favour of bad regulations, just because it would benefit him.
The null hypothesis is that interventions are just as if not more likely to cause harm than do good.
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Verifying is great!
How many types of truck engine do you reasonably need to test with? The number should fit on one hand. And really you should only need to do the full test with one model and limited verifications with others. That'll get it down from $27M to $200k, which would be a far more reasonable requirement.
Some kind of testing should be required but 27mil seems egregious
Yeah why does the certification process cost so much is one question I have. Would this be a conversation if the cost of the test were more reasonable?
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This is China's secret weapon.
Luckily, the internet, software, and the digital world in general; were a bit too out of left field for regulators.
That's why we kept supremacy over them.
If we are lucky, AI may not be regulated to death
This is such a bizarre myth but I guess it matches your priors.
> whose sole reason for existence is to cut pollution by >90%, and which has demonstrably done so across nearly 100,000 miles of testing and operations
Then it should be easy to answer that request? Where does the $27M price tag come from?
Its not usually one person, but many well meaning committees.
It's not like anyone ever added a device to an engine to deliberately defeat these tests.
lol
state and federal bureaucrats do not lose jobs
Seems somewhat reasonable. I don’t know why the company is supporting all 270 engine families.
This company wants to put a bunch of stuff on the road going 70mph that could crash into you and kill you and is complaining about a measly $27 million of regulatory cost.
They are making up a bunch of scary numbers about the cost of the status quo and the tone of the article is basically holding us all hostage. Speed out special snowflake startup company through the regulatory process (written in blood) or else you’ll lose bajillions of dollars in suffering and pain from the “status quo.”
$27 million is basically a rounding error for automotive companies. Maybe do better at raising funds next time, bro.
Why wouldn't they try to support a large number of engines, the testing was about emissions not safety, and they're not a huge automotive company.
Emissions = safety.
I assume that out of 270 entire families that some are more popular than others? Why not pick the 20-30 most popular ones?
The tone of this article is that OP’s company has a savior complex. If they aren’t given expedient special treatment regulatory approval, the status quo is causing a bunch of fake make up dollar values of damage. It’s kind of a gross tone.
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Spoken like someone who has no idea how hard it is to actually get anything done in real life vs your armchair.
Nope. I own a business.
Complying with regulations is a sometimes-difficult but necessary part of my existence.
Small business owners like myself are the ones who comply while the biggest corporations use their armies of lawyers and bean counters to see how many pennies they can save by skirting those regulations. Just like OP.
If you want to argue that adding an electric engine to existing trucks is going to make them go out of control and kill people in some completely common sense defying manner, then the burden of proof is on you and not on the company to prove a negative.
I don't think this is even what they're testing, but come on, it takes very little going wrong for a multiton truck going 80+ to kill someone.
> one state agency has asked Revoy to do certified engine testing to prove that the Revoy doesn’t increase emissions of semi trucks and that Revoy must do this certification across every single truck engine family. It costs $100,000 per certification and there are more than 270 engine families for the 9 engines that our initial partners use. That’s $27,000,000 for this one regulatory item.
Depending where that is one could read it as "fuck you, you haven't bribed us enough". And then "if we come to an understanding, we might be able to look the other way".
Wonder what state that is? Anyone want to guess?
> Depending where that is one could read it as "fuck you, you haven't bribed us enough".
This is often fully formalized, i.e. you're not bribing a specific government official, instead you're paying a huge certification fee hundreds of times because it's a source of revenue generation for the government and whoever passed the bill gave zero fucks that it's a heavily regressive tax on new and small businesses.
Mississippi? I bet it's a flyover state with a tiny sliver of road that sees massive trucking volume.
It's gonna be California (but I'm guessing, not sure). Other states just defer to federal regulation.
That they don't put the state on blast sort of points to the big cost not being entirely real (where they either think they can induce regulatory change or the number of tests that is needed to sell the systems is quite a lot less than the number of tests that would be needed to allow 100% of the market to use their system).
mississippi doesn't make people do certifications lol. unless you drive a hybrid, then you pay the hybrid tax.