Comment by GuB-42
3 months ago
I get the idea but it is a very one-sided argument. It sounds like "but can't they just trust us?". And no, they can't, that's the reason why regulation exists. They said they have done all sorts of research to make sure their tech is safe, but would they have done it if there wasn't any regulation? Many companies wouldn't have, because it is not profitable, even accounting for the risk and especially for startups that don't have a lot to lose.
They also claim that by not letting they do their things, regulation caused the emission of plenty of CO2, NO, etc... Yeah, right, we can say the same for drug testing too, drug testing may have killed millions by delaying the adoption of life saving drugs, so should we stop testing drugs? It is debatable really, but I am sure that experts studied to question seriously and that the answer is no.
Regulation is costly and inefficient, obviously, that's the point, if it wasn't you wouldn't need regulation because that's what companies would do naturally. It is also not perfect and you can always find bad regulation. But overall, they are important.
Do you think your points are applicable to the specific examples he gives? e.g.:
>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.
And that $27M dollar cost doesn’t include the cost to society. This over-regulation will delay deployment of EV trucks by years, increasing NOₓ and PM 2.5 air pollution exposure for many of society’s least well-off who live near freeways
It’s quite possible that the pollution controls on some of those engines wig out and turn the truck into a coal roller. Even with 10-100x fuel efficiency improvements, it could increase particulates, etc due to a bad fuel mix.
The real question is why they’re paying $100K per truck for a mobile smog test rig.
The test equipment can’t possibly cost more than $100K. That leaves $26.9M of “you’re doing something obviously wrong”.
My guess is that the regulations aren’t actually forcing the idiocy, or they are designed to subsidize emissions testers in some way. I’d guess it is the latter, which is just bad regulation.
Smog checks in California have been pretty poorly administered for years. For one of my cars, the lowered the nox standard until it would have failed fresh from the factory, then made me spend more than the car was worth on a special cat that reduced emissions by < 10%.
These days, cars continuously smog check themselves, so there could be a mandatory “send smog check report to the state” button on the dash, but that’d stop the gravy train for the smog test operators. At least they don’t make you smog test EVs, I guess.
With all the money that’s wasted on having stations that check dashboard error lights, they could install air and noise pollution monitoring sensors, and seize cars that have been modified to be non-street-legal. This would be stronger and better regulation than we currently have (less disruption to people obeying it, more bad cars taken off the road, minimal privacy implications for anyone in compliance with the law, and lower cost to enforce).
Also, it’d eliminate the need for the startup to test their truck retrofit, since the trucks would just light the stations up like a Christmas tree if there was an actual problem.
> The real question is why they’re paying $100K per truck
> The test equipment can’t possibly cost more than $100K. That leaves $26.9M of “you’re doing something obviously wrong”.
It seems clear from the original text ("It costs $100,000 per certification") that it's the certification FEE that is $100k. For example, https://ww2.arb.ca.gov/sites/default/files/2024-08/mac202403... includes an individual base fee of $126,358.
>This over-regulation will delay deployment of EV trucks by years
And we only need to look at Tesla to see what under-regulation could bring.
I don't know if 27 million is a lot for a business at this scale. It sounds like a lot, but I see 62 "contacts" at the company. 62 workers making 100k a year means a year of compensation is already pushing on half this amount after other benefits (and that's just this companies employees, who are mostly management. So I'm probably underselling compensation and other companies they work with).
> They said they have done all sorts of research to make sure their tech is safe...
We've heard this one before. This really is a regulation bad because "trust me bro our product/service is so good for you/the environment/the world/etc and it's just regulations that are holding us back."
This isn't to say that it's not a fine product/service, but we are talking about a service that alters how companies may comply with current/future emissions regulations. By apparently pumping it back into the ground. We might want the regulators to really make sure that is a good idea and not just take their word for it.
It is a quagmire created out of the environmental regulatory regime. Until that is removed and replaced, innovations will be hampered, and the countries part of that regime will suffer or even stagnate.
Did you read the article? The very first example is about taking 4 years to decide which regulatory framework applied to their carbon sequestration process. Does that seem acceptable to you? Again, that wasn't to actually complete the regulatory review to determine that it was safe, that only took 14 months, that 4 years was just arguing over which of three permits applied to them.
It's not "just trust me bro", the entire point of the article is that there are costs to doing nothing that regulators refuse to accept. It's the same thing with drug trials actually, we need testing for very obvious reasons but every day that lifesaving drugs are stuck in testing and review is another day that they aren't saving or improving the lives of patients. There is a tradeoff.
> that 4 years was just arguing over which of three permits applied to them.
sounds like an average legal case for a business at this level, yes.
I'm all for overhauling the legal system and the meaning of "speedy trials", but the enforcement of regulations that seems tangential to if regulations are good/bad/over/under.
The entire point of the article is that this timeline is utterly unacceptable, and honestly if you disagree then I don't really care about any of your other opinions.