2007 Diesel Regulations – Environmental Irresponsibility?

2007 Diesel-engine vehicles are all about an expensive attempt to meet the new EPA regulations by using high EGR percentages, Diesel Particulate Filters, CJ-4 motor oil specifications, and Ultra Low Sulfur diesel fuel.  Now, all this has increased the cost of fuel, reduced fuel economy by 10% (burning MORE non-renewable resources!), increased engine wear rates, and – one can argue – may well increase the amount of used motor oil dumped in the environment, which has a highly negative environmental impact.  So the questions need to be asked: Does the EPA’s strict new diesel emissions regulations really benefit the environment, or does it create a heavier environmental impact?   How important is it to feel good about ridiculously low NOx emission levels which have no demonstrable benefit? 

This could get quite technical, but I’ll keep it simple.  For low engine wear rates (prolonging vehicle life, and reducing both oil consumption and maintenance costs), you must control soot and acid content in the diesel motor oil.  Good levels of ZDDP (a Zinc compound) and sulfated ash are clearly the best and most effective ways to achieve those goals, producing low wear rates and high TBN’s (total base number) for neutralizing acids.  Having plenty of ZDDP and high TBN in a high-quality synthetic oil base-stock means that oil change intervals can be dramatically extended to 25,000 miles in typical diesel pickups, or – by adding bypass filtration systems – oil changes can be completely eliminated.  Amsoil turned this technology into a proven science decades ago, which has been proven in extensive oil analysis sampling and fleet engine rebuild results, and has been repeatedly noted for the strong environmental benefits: 25,000 mile oil change intervals produce more than an 87% reduction in motor oil useage.  The environmental benefits of “extended drain” oil and filter technologies include increased fuel economy, dramatic reductions in the amount of “dumped” used oil and of filters disposed, and improved vehicle emissions.

Unfortunately, the new CJ-4 spec places strict limits on what you can use to get good TBN, keep the engine clean (minimizing emissions increases), increase fuel economy, and reduce wear  - essentially it cripples the oil formulation so that we can’t get what we need for best use of resources.   Amsoil played a vital role in writing this spec, which is what made it possible for the vehicle OEM’s to meet the new EPA emissions reg’s and not destroy their engines or emissions equipment before the warranty is up (they hope).

The issue all goes back to NOx emissions: that’s the first “domino” in the chain, and I’ll walk you down the chain from link to link.  Both Oxygen and Nitrogen are abundantly present in the air anyway.  So the environmental importance of extremely low NOx emissions is highly questionable in my opinion (and I’m not alone in this).  Apart from this, the newer 2002+ diesels are VERY clean and environmentally friendly.  However, based on an assumed importance for extremely low NOx, the EGR (exhaust gas recirculation) rates had to be dramatically increased – from a typical 10-15% for the earlier EPA standards, to an amazing 25-35%.  The proof of the technical ridiculousness of this is not that it creates hotter-running engines, but that it results in about a 10% reduction in diesel fuel economy - much of that due to a lot of unburned fuel that exits the exhaust (“soot” as black smoke).  That’s where the diesel particulate filters (DPF’s) come in: these are required in order to trap the soot (unburned fuel), then periodically burn off that unburned fuel - by consuming more fuel.  Once you do all that, you now have exhaust that is both clean AND extremely low in NOx emissions.

Now, you might say “wait a minute.  Do I understand correctly that in order to reduce NOx emissions, they are increasing fuel consumption by 10% – trading a small and very questionable environmental improvement for a 10% increase in the amount of fuel used?”  Yes.  You’ve got the environmental picture so far, except that the story gets worse. 

The DPF’s typically contain SCR technology (Selective Catalyst Reduction), which is a catalytic converter for diesels.  These “cat bricks” will slowly plug up from deposited solids that can’t be burned off, while the fuel economy will get worse and worse as the exhaust backpressure continues to increase.  OEM’s are hoping that they’ll “last” 150,000 miles before the fuel economy gets absurdly bad, but no-one really knows.  Many are concerned about the public backlash when people find out how ridiculously expensive it’s going to be to service or replace these units.  The main factors determining the effective life of an SCR/DPF are fuel quality, engine oil content, and the amount of engine oil that is burned.  (In other words, if you want to keep good fuel economy and avoid expensive repairs on a 2007 diesel for as long as possible, pay close attention!) 

Due to the sensitive nature of the DPF’s, automakers had to reduce every possible source of deposits that could kill DPF performance over time – primarily these two sources:

1) Sulfur in the fuel.  This was dropped from 5,000 ppm (parts per million) to 500 ppm in 1994 with the Low Sulfur Diesel (LSD), and now again in 2006 and 2007 – down to an unbelievable 15 ppm with Ultra Low Sulfer Diesel (ULSD).  Why is this bad?  Not because it’s a pollutant, but because it slowly plugs your DPF.  That’s why you DO NOT want to use LSD in a 2007 or later diesel: it kills your DPF 33 times faster. 

Problem is, the Sulfur is an important lubricant for the fuel injector pump and the fuel injectors, and Europe’s experience proved the ULSD puts these expensive components in a junkyard in far less than half their normal life.  U.S. experts don’t think the federal regulations will do much to ensure that fuel-station owners and attendants will remember to dose the diesel with the correct level of lubrication additives.  So a word to the wise: put your own additive into your fuel tank during every fillup!

2) Sulfated ash, Phosphorus, Sulfur, and Zinc in engine oils.  Those contents all play key roles in oil performance, but now they must be restricted.  Because after all, a very slight amount of oil does get consumed in the engine and exits through the exhaust.  And with higher EGR rates, even more oil is likely to be burned.  Again, the problem with each of these four is that they accumulate in the DPF catalyst “brick” and plug it up.

By severely limiting these elements and compounds in the motor oil, the performance capability of the oil has been limited.  And to a great extent, the use of synthetic oils becomes almost essential.  But whether synthetics or fossil-oil, this logically means that the diesel engine oil must be changed more frequently than would otherwise be needed, again consuming more natural resources that are non-renewable, and probably increasing the amount of used oil dumped in the environment.

Specifically, the CJ-4 oils are limited in their capability to reduce wear, to control/disperse soot, and to neutralize acids.  The soot and acid issue means that premium synthetics are limited to lower maximum extended drain intervals. At the same time, the higher EGR rates are producing more soot and more acid in the oil, both of which are proven to reduce engine life.  So oil performance and engine life have both been compromised by these CJ-4 requirements.  To better see what I mean, compare the specs for AMSOIL’s new CJ-4 diesel oil, with the flagship CI-4 Plus Diesel Oil: the new CJ-4 doesn’t perform near as well in the NOACK volatility or the 4-Ball Wear Test, and check out the huge difference in TBN’s.

Kudos to Amsoil, not only because their CJ-4 oil performance is still better than most CI-4+ oils, but because it’s available and has already logged over 12 million fleet miles: most oil companies still don’t have a CJ-4 diesel engine oil formulation, much less have it available in the U.S. market as of October 2006. 

So here are the cards we’ve turned over: the risk of increased motor-oil dumping, an additional 10% fuel consumption penalty (that just gets worse as the DPF back-pressure increases), an additional $700-7,000 per vehicle for the technology, and reduced engine life (at least compared to what it would otherwise be, not accounting for tribology advances that may offset the difference now or in the future).  Now that all those cards are on the table, who wins?   Does this make any environmental sense?  Are those penalties really justified merely in order to take very low NOx emissions to an extremely low level? 

Why did sales of 2006 diesels skyrocket as large fleets pushed to replace all older equipment with 2006 models?  Because the people who know the situation are deeply concerned about the large negative impact of these new regulations on our businesses and economy.  And don’t let the media fool you – the people who pay the bill for ALL of this are us – the consumers, and the taxpayers.

Knock, knock, EPA – is anyone with a brain at home?  Why would responsible environmental groups push for such results or support them?  Sounds like lunacy to me.  Has the EPA abandoned being an Environmental Protection Agency?  Since when did Congress vote to make them a Politically Correct Regulation Agency?  I vote for rolling back the 2007 NOx diesel emissions requirements, in order to reduce diesel fuel consumption by 10%, reduce the cost of the vehicles, reduce vehicle maintenance, extend vehicle life, and not force everyone to waste money to harm the environment while pretending to help it.  Anyone else on the side of sanity and holding government agencies responsible for their assigned roles?

Update on environmental FRAUD: http://autoengineer.wordpress.com/tag/fraud-alert/ 

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