Comment by BellLabradors
3 months ago
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).