Document dQzgKawjXEQykXeEzzaDx6Mp6

VIA CERTIFIED MAIL RETURN RECEIPT REQUESTED and VIA ELECTRONIC MAIL: partners@spelabautoparts.com ATTENTION TO: Oliver George, Partnership Manager SPELAB 18275 Fullerton Rd., City of Industry, CA 91748 Re: Notice of Violation of the Clean Air Act Dear Oliver George: The United States Environmental Protection Agency (EPA) has investigated and continues to investigate SPELAB Auto Parts ("SPELAB" or "You") for noncompliance with the Clean Air Act ("CAA" or "the Act"), 42 U.S.C. 7401-7671q, and its implementing regulations. As summarized in this Notice of Violation, the EPA has determined that SPELAB has offered for sale, or caused the offer for sale of, parts or components for motor vehicle engines that bypass, defeat, or render inoperative devices or elements of design installed on motor vehicles and motor vehicle engines to meet emission standards promulgated under the CAA, and knew or should have known that these parts or components were offered for sale or installed for such use or put to such use. Therefore, You have violated Section 203(a)(3)(B) of the Act, 42 U.S.C. 7522(a)(3)(B). The EPA continues to investigate these violations and other potential violations under the Act and its implementing regulations. Law Governing Alleged Violations This Notice of Violation arises under Part A of Title II of the Act, 42 U.S.C. 7521-7554, and the regulations promulgated thereunder. These laws were enacted to reduce air pollution from mobile sources of air pollution. In creating the Act, Congress found, in part, that "the increasing use of motor vehicles . . . has resulted in mounting dangers to the public health and welfare."1 Congress's purpose in creating the Act was, in part, "to protect and enhance the quality of the Nation's air resources so as to promote the public health and welfare and the productive capacity of its population," and "to initiate and accelerate a national research and development program to achieve the prevention and control of air pollution."2 The EPA's allegations here concern parts or components for motor vehicles and engines subject to emission standards.3 The Act requires the EPA to prescribe and revise, by regulation, standards applicable to the emission of any air pollutant from new motor vehicles or engines that cause or contribute to air pollution, which may reasonably be anticipated to endanger public health or welfare.4 As required by the Act, the emission standards "reflect the greatest degree of emission reduction achievable through the application of [available] technology."5 Motor vehicles and engines are subject to specific emission standards for each pollutant, based on a vehicle's or engine's class and model year.6 Vehicle and engine manufacturers employ many devices and elements of design to meet emission standards. "Element of design" means "any control system (i.e., computer software, electronic control system, emission control system, computer logic), and/or control system calibrations, and/or the results of systems interaction, and/or hardware items on a motor vehicle or motor vehicle engine."7 For example, manufacturers often employ retarded fuel injection timing systems as a primary emission-related element of design to achieve reduction of emissions of oxides of nitrogen (NOx) and particulate matter (PM). Manufacturers also employ certain hardware devices as emission control systems and elements of design to reduce emissions of regulated pollutants into the ambient air. Examples of such devices include sensors, filtration systems such as diesel particulate filters (DPF) systems, exhaust gas recirculation (EGR) systems, and catalyst devices such as diesel oxidation catalysts ("DOC," also referred to as "CAT"), crankcase ventilators (CCV), NOx adsorption catalysts, and selective catalytic reduction8 (SCR) systems. SCR systems apply an aqueous urea, known as diesel emission fluid (DEF), onto a special catalyst, causing a chemical reaction and thereby reducing NOx emissions. Modern vehicles and engines are equipped with devices known as electronic control modules (ECMs), also commonly referred to as electronic 1 CAA 101(a)(2), 42 U.S.C. 7401(a)(2). 2 CAA 101(b)(1)-(2), 42 U.S.C. 7401(b)(1)-(2). 3 See generally 40 C.F.R. Part 86, Subpart A (setting emission standards for these categories). 4 CAA 202(a)(1) and (3)(B), 42 U.S.C. 7521(a)(1) and (3)(B). 5 CAA 202(a)(3)(A)(i), 42 U.S.C. 7521(a)(3)(A)(i). 6 See, e.g., heavy-duty diesel engine emission standards at 40 C.F.R. 86.004-11, 86.007-11, 86.099-11. 7 40 C.F.R. 86.094-2. 8 SCR systems include catalyst injection and tank storage components. 2 control units (ECUs). ECMs or ECUs continuously monitor engine and other operating parameters and control the emission control devices, such as the fueling strategy. Manufacturers further employ onboard diagnostics, or "OBD," which are comprised of systems designed to: monitor components that can affect the emission performance of a motor vehicle; detect problems with the vehicle's emission-related systems that could cause the vehicle to fail to comply with emission standards; alert drivers to these problems; and store electronically-generated malfunction information.9 If a problem is detected, the OBD system illuminates a warning indicator on the vehicle instrument panel to alert the driver, called a malfunction indicator light ("MIL") or check engine light. The OBD system also records diagnostic trouble codes to aid in the identification of the emission control problem requiring repair. The OBD system may force an engine power reduction (known as "limp mode") to prompt the repair of a missing or malfunctioning emissionrelated device or element of design. Given these functions, the OBD System is a key part of a motor vehicle's emission control system. To ensure that every new motor vehicle or motor vehicle engine sold, offered for sale, imported, delivered for introduction into commerce, or introduced into commerce in the United States (collectively, "introduced into commerce") satisfies applicable emission standards, EPA runs a certification program for manufacturers. Under this program, the EPA issues certificates of conformity (COCs), thereby qualifying motor vehicles and engines for introduction into commerce.10 To obtain a COC, an original equipment manufacturer (OEM) must submit a COC application to the EPA for each engine family (also referred to as test group) and each model year in which it intends to manufacture or import motor vehicles or engines for introduction into commerce. The COC application must include, among other things, identification of the covered engine family, a description of the motor vehicle or engine and its emission control systems, all auxiliary emission control devices (AECDs)11 and the engine parameters they sense, as well as test results showing that a test vehicle or engine satisfies the applicable emission standards.12 The motor vehicles or motor vehicle engines must then be manufactured exactly as described in the approved COC application, in part to ensure that the emission control systems function as described. In addition, the Act makes it a violation "for any person to manufacture or sell, or offer to sell, or install, any part or component intended for use with, or as part of, any motor vehicle or motor vehicle engine, where a principal effect of the part or component is to bypass, defeat, or render inoperative any device or element of design installed on or in a motor vehicle or motor vehicle engine in compliance with regulations under this subchapter, and where the person knows or 9 See CAA 202(m), 42 U.S.C. 7521(m), requiring EPA to promulgate regulations requiring OBD systems for motor vehicles after 2007; see also 40 C.F.R. 86.005-17, 86.007-17, 86.1806-05, and 86.1806-17. 10 40 C.F.R. 86.007-30. 11 An AECD is "any element of design which senses temperature, vehicle speed, engine revolutions per minute, transmission gear, manifold vacuum, or any other parameter for the purpose of activating, modulating, delaying, or deactivating the operation of any part of the emission control system." 40 C.F.R. 86.082-2. 12 40 C.F.R. 86.004-21, 86.007-21, 86.094-21, 86.096-21; see also EPA, Advisory Circular Number 24-3: Implementation of Requirements Prohibiting Defeat Devices for On-Highway Heavy-Duty Engines (Jan. 19, 2001). 3 should know that such part or component is being offered for sale or installed for such use or put to such use."13 It is also a violation to cause any of the foregoing acts.14 The Alleged Violations The EPA has determined that SPELAB has sold, offered for sale, or caused the offer for sale, multiple products that have a principal effect of bypassing, defeating, or rendering inoperative emission control devices or elements of design certified to control emissions on motor vehicles or motor vehicle engines. These products are commonly referred to as "Defeat Devices." SPELAB operates the website https://spelabautoparts.com (hereinafter, the "SPELAB Website") as a platform from which to sell or offer to sell Defeat Devices. On this website, SPELAB advertises for sale Defeat Devices which are intended for use with a variety of motor vehicles and motor vehicle engines including, but not limited to, vehicles and engines manufactured by Ford, Dodge Ram, Chevrolet, General Motors, and Cummins. In addition to the SPELAB Website, SPELAB promotes its products on the following platforms: Youtube.com (https://www.youtube.com/@spelabofficial/featured), Facebook.com (https://www.facebook.com/SpelabAutoparts), Instagram.com (https://www.instagram.com/spelabautoparts/), and Tikok.com (https://www.tiktok.com/@spelabofficial). Through these social media accounts, SPELAB publishes text posts, photographs, and videos advertising SPELAB Defeat Device products and providing instructions for installation. SPELAB provides links to these social media accounts on the Blog & Videos page of the SPELAB Website: https://www.spelabautoparts.com/blogs/news/. In 2024, EPA conducted several reviews of the SPELAB Website and social media accounts for advertisements of Defeat Devices. Since January 1, 2021, SPELAB advertised for sale at least four categories of Defeat Devices: (1) Aftermarket Software ECM Programs; (2) Exhaust Aftertreatment Delete Hardware; (3) EGR Delete Parts; and (4) CCV Delete Parts. We describe the products in further detail below: 1. Aftermarket Software ECM Programs The first category of Defeat Devices sold or offered for sale by SPELAB is aftermarket software ECM programs, commonly referred to as "tunes" or "calibrations." These programs are either distributed in a console (commonly referred to as a "tuner" or "programmer") or transmitted electronically via weblink or email and are designed to modify the vehicle's original ECM programming or calibrations 13 CAA 203(a)(3)(B), 42 U.S.C. 7522(a)(3)(B). 14 CAA 203(a), 42 U.S.C. 7522(a). 4 and/or the OBD System operation, where a principal effect of the program is to bypass, defeat, or render inoperative devices or elements of design, including EGR, DOC, DPF, SCR, CCV, or OBD systems, or fuel injection timing calibrations, installed on or in motor vehicle engines ("Defeat Tuning Products"). On the SPELAB Website, SPELAB offers several tuners and tunes designed to modify the original ECM programming or calibrations of a variety of motor vehicles. On a page titled "Tuner Delete | SPELAB,"15 SPELAB explains what a truck tuner is, how it works, the purported performance benefits of tuners generally as well as the "Unique Advantages of SPELAB's Self-Developed Products," and steps for installing the tuners. . . . 2. What is a Truck Tuner and How Does It Work? The Basic Functions of a Truck Tuner Truck tuners are powerful tools designed to optimize your truck's engine performance by adjusting the Engine Control Unit (ECU). These devices recalibrate essential engine parameters, such as air/fuel ratio and ignition timing, which can lead to increased horsepower, improved torque, and enhanced fuel efficiency. With SPELAB tuners, you can expect significant performance gains that are tailored to the specific needs of your truck. How Tuners Improve Truck Performance SPELAB tuners are designed to cater to heavy-duty diesel trucks, ensuring peak performance under various driving conditions. By modifying the ECU, these tuners unlock additional power and optimize fuel consumption. Whether your goal is to achieve better towing capacity, faster acceleration, or superior fuel economy, SPELAB tuners provide the necessary adjustments to meet these demands. Ready to enhance your truck's performance? Discover the SPELAB tuner that fits your vehicle and driving needs. . . . 16 15 https://www.spelabautoparts.com/collections/tuner-delete-spelab 16 SPELAB Auto Parts, "Tuner Delete|SPELAB" (last visited Sept. 24, 2024), https://www.spelabautoparts.com/collections/tuner-delete-spelab. 5 On the same page, under the "FAQs" section, SPELAB includes the following questions and answers: Q1: What is the primary purpose of a SPELAB truck tuner? A1: A SPELAB truck tuner optimizes your truck's engine performance by adjusting parameters like air/fuel ratio, ignition timing, and speed limiters, leading to improved power, fuel efficiency, and overall vehicle responsiveness. Q2: Can I install the SPELAB tuner myself, or do I need professional help? A2: SPELAB tuners are designed for easy installation and can typically be installed by the truck owner with basic tools. Detailed instructions are provided, but if you're unsure, professional installation is always an option. Q3: Will using a SPELAB tuner void my truck's warranty? A3: Modifying your truck with a tuner can affect the warranty, depending on the manufacturer's policy. It's recommended to check with your vehicle manufacturer or dealership before installing any aftermarket tuner.17 On this same page, under the FAQs, SPELAB advertises nine different tuning products (or kits that include tuning products)18: The "Mini Maxx V2 Tuner and EGR/DPF/DEF Full Delete Kit" The "H&S PERFORMANCE Mini Maxx V1 DPF Delete Tuner |SPELAB" The "DPF/DEF/EGR/CCV Delete 2011-2019 6.7L Powerstroke All-in-one Kit |SPELAB" The "Diesel Tuner EGR/DPF/DEF/CCV Delete 2011-2015 LML 6.6L Duramax All-in-One Kit |SPELAB" The "SPELAB DPF/DEF/EGR/CCV Delete 2011-2019 6.7L Powerstroke All-in-One Kit" The "GM 2017-2023 6.6L Duramax L5P - OBDii Flash Delete Tuning Interface |SPELAB" The "Commander Tuner for 2020-2022 Powerstroke 6.7L Ford F250, F350 |SPELAB" The "Delete Tuner For Ford 2011-2019 6.7 Powerstroke |SPELAB" The "EFILive AutoCal V3 DPF Delete Tuner For 2006-2021 Dodge RAM Cummins and 2001- 2016 Duramax" 17 Id. 18 Id. 6 Of these nine products, eight include the word or phrase "Delete," "Delete Tuner," and/or "Delete Tuning" in the title, indicating that the products disable certified emission controls on vehicles. These title descriptions identify these products as Defeat Tuning Products. In some of these products' descriptions, SPELAB also explicitly promotes features of its products that delete emission controls. For example, in the description of the "Mini Maxx V2 Tuner And EGR/DPF/DEF Full Delete Kit," SPELAB writes: Spelab recommends the Mini Maxx V2 Tuner - the next generation of diesel downloaders that offers everything a diesel owner could want, all in one high-tech unit. This tuner is ideal for those looking for the most cost-effective delete tuner that will run clean & smoke-free tunes and provide extra performance. If you're looking for a tuner that will allow you to delete all of your emission components while ensuring you don't have any check engine lights or DTCs (diagnostic trouble codes), the Mini Maxx is the tuner for you. The Mini Maxx V2 DPF/EGR/SCR delete race tuner comes pre-loaded with tunes for a variety of different trucks, making it a great choice for those looking to do a DPF, DEF, and EGR delete. . . . Is it legal to have a Mini Maxx Tuner installed in your truck? What about the emissions? Please note that the Mini Maxx race tunes are designed for off-road use only. If you live in a country without such requirements, the Mini Maxx is a great option for tuning your truck cheaply. What does a Mini Maxx Tuner do? The Mini Maxx tuner is a device used to improve diesel engine performance. It does this by increasing the power and torque of the engine, as well as improving the fuel economy. The Mini Maxx tuner is available for Ford, Dodge, and GM trucks. It can be installed in just a few minutes and is easy to use. By installing this state-of-the-art DPF delete race tuner you will be able to delete the following emission systems: 7 DPF: Diesel Particulate Filter Easily delete the components of your DPF system. The Mini Maxx allows you to remove all the components of your truck's DPF system while turning off all the codes for the related sensors, eliminating any check engine lights. EGR: Exhaust Gas Re-circulation Mini Maxx v2 disables the EGR function and any related check engine lights and DTCs. It will work if you leave the EGR system installed (run with the EGR system) and it will also work if you install an EGR block kit. Works in conjunction with an EGR block. No more leaks from the EGR system! Yes say goodbye to coolant leaks from the EGR! DEF: Diesel Exhaust Fluid This tuner will allow you to turn your urea injection system off completely, which will allow you to remove the tank and all related sensors. This is a great option for those that want to remove the extra weight from their vehicle or those that are having problems with the system. Note: ULSD (Ultra-Low Sulfur Diesel) is not required if you have the Mini Maxx installed on your truck. You can now feel safe using high-sulfur diesel, which will make you happy if you live in an area where it is hard to find ultra-low diesel fuel. Mini Maxx offers the flexibility of turning your truck into a more capable and economical vehicle. . . .19 Similarly, in the description of the "H&S PERFORMANCE Mini Maxx V1 DPF Delete Tuner |SPELAB," SPELAB includes the following as "Standout Features" of the product: DPF system & ALL sensor removal capability (for an uninterrupted race exhaust system) 19 SPELAB Auto Parts, "Mini Maxx V2 Tuner And EGR/DPF/DEF Full Delete Kit" (last visited Sept. 24, 2024), https://www.spelabautoparts.com/products/mini-maxx-v2-delete-tuner-egr-dpf-def. 8  Automatic safety backdown governed by EGT, Boost, Trans Temperature, and Coolant Temperature Tailored engine tuning with HP boosts ranging from 0-250HP Adjustment and removal options for top speed limiter Speedometer recalibration for custom-sized tires or gear modifications Complete EGR system removal option without triggering any trouble codes Enable or disable built-in "special features" like high idle, fog lights, chimes, and, more specific for 6.7L Cummins Effortless EGR disabling without removing ANY components Efficient DTC reader/clearer Internet updates facilitated with the included SD Memory Card and USB Cable Monitor engine parameters with 20+ digital gauges20 Additionally, in the description of the "EFILive AutoCal V3 DPF Delete Tuner For 2006-2021 Dodge RAM Cummins and 2001-2016 Duramax," SPELAB includes the following as "Key Features" of the product: Precision Tuning: Customize your engine's performance with precision. The EFI Live AutoCal V3 allows you to fine-tune parameters to maximize horsepower, torque, and fuel efficiency, giving you the ultimate driving experience. DPF Delete Capability: Designed for off-road and competition use, this tuner enables the removal of the Diesel Particulate Filter (DPF), enhancing exhaust flow and delivering improved throttle response and power. Advanced User Interface: The AutoCal V3 comes with a larger, more responsive screen and an upgraded interface, making it easier than ever to navigate and adjust your settings. Custom Tune Support: Store and switch between multiple custom tuning maps tailored to your specific driving needs--whether it's for daily driving, towing, or high-performance use. Portable Design: Compact and easy to carry, the AutoCal V3 allows for on-the-go tuning. With the ability to store multiple tunes, you can effortlessly switch configurations to match any driving condition.21 20 SPELAB Auto Parts, "H&S Performance Mini Maxx V1 DPF Delete Tuner |SPELAB" (last visited Sept. 24, 2024), https://www.spelabautoparts.com/products/h-s-performance-mini-maxx-v1-dpf-delete-tuner-spelab. 21 SPELAB Auto Parts, "EFILive AutoCal V3 DPF Delete Tuner For 2006-2021 Dodge RAM Cummins and 2001-2016 Duramax" (last visited Sept. 24, 2024), https://www.spelabautoparts.com/products/efilive-autocal-v3-dpf-delete-tuner-for-20062021-dodge-ram-cummins-and-2001-2016-duramax. 9 These examples from SPELAB's own product descriptions indicate that the products are intended to allow the bypass or removal of the emission control systems including the DPF, SCR, and/or EGR Systems. Accordingly, SPELAB knew or should have known that these products were offered for sale or installed to bypass, defeat, or render inoperative devices or elements of design that control emissions of regulated air pollutants. 2. Exhaust Aftertreatment Delete Hardware The second category of Defeat Devices sold or offered for sale by SPELAB is exhaust aftertreatment delete hardware (often referred to as "Straight Pipes"). This category includes parts or components that physically remove certified exhaust aftertreatment emission control devices or elements of design, such as the DPF, DOC, and/or SCR, from the exhaust system installed on or in a motor vehicle. SPELAB advertises for sale more than 45 products that fall within this category on its website. On a page tiled "DPF Delete Kits," SPELAB writes: Looking to boost your diesel engine's performance? SPELAB, as a leading DPF delete shop, offers a comprehensive selection of DPF Delete Kits tailored for Ford Powerstroke (7.3L, 6.7L, 6.4L, 3.0L), Dodge Ram Cummins (6.7L, 5.9L), GMC Sierra/Chevrolet Silverado Duramax (6.6L), and Jeep/Ram 1500 EcoDiesel (3.0L). Our collection features 46 different products, ranging from DPF delete components to related tools like diesel tuners (DEF delete kits) that help manage error codes through advanced software. Explore options such as: DPF Delete Race Pipe Downpipe-Back DPF Delete Exhaust Tip Downpipe Back Dual Turbo-Back DPF Delete w/Muffler Some kits are available as combinations, offering flexibility to suit your specific needs. For those looking for a complete performance upgrade, our "DELETE KITS" provide a streamlined and cost-effective solution. If you're new to DPF deletes or want to learn more about how these products can benefit your vehicle, check out our detailed guides and resources: 10 How To Clean Dpf Filter How Much Does A DPF Delete Cost? DPF FAQs From Automotive Enthusiasts Navigating the World of DPF Delete Shops and Kits Most post-2007 diesel vehicles are equipped with a Diesel Particulate Filter (DPF) to meet emissions standards. However, the DPF can have several disadvantages, including constant maintenance and repairs. Over time, the DPF clogs up, increasing backpressure. This backpressure disturbs fuel flow, slowing it down significantly. By removing the DPF filter, fuel flows more freely and efficiently, ultimately improving overall fuel mileage and engine performance.22 Of the more than 45 products advertised on this page, many include the phrase "DPF Delete" in the product names and use "DPF & Cat Delete Pipe" as the Product Type.23 Examples include, but are not limited to: 4"/5" 2011-2018 6.7 Cummins Cab & Chassis DPF Delete Exhaust | SPELAB 4"/5" 2013-2018 6.7 Cummins DPF Delete Race Pipe Dodge Ram 2500/3500 | SPELAB 4"/5" Turbo-Back 2013-2018 Dodge Ram 6.7 Cummins DPF Delete Race Pipe | SPELAB 4"/5" 2017-2024 L5P 6.6 Duramax DPF Delete Race Pipe Chevy GMC | SPELAB Clearance Sale 5" Downpipe Back Dual 2017-2023 L5P 6.6L Duramax DPF Delete Race Pipe GM 2500/3500 | SPELAB SPELAB 3" 2014-2018 3.0L Ecodiesel DPF Delete Race Pipe Exhaust| Jeep Grand Cherokee 4" 2011-2015 LML 6.6 Duramax Cat & DPF Delete Race Pipe w/ Muffler | SPELAB Under the description of many of the DPF delete pipes (including, but not limited to, those listed above), SPELAB explains what the DPF is, the effects of a DPF delete, and how to install the DPF delete pipe: What is the DPF and is it worth doing a DPF Delete? Most post-2007 diesel vehicles are fitted with a Diesel Particulate Filter (DPF) for emissions reasons, however there are a few disadvantages to this device; including constant maintenance and repairs. Because the DPF clogs up, it increases backpressure. Due to this pressure, the fuel flow is hugely disturbed and slowed down. Therefore, when you remove this filter, the fuel flows much easily and faster, increasing the 22 SPELAB Auto Parts, "DPF Delete Kits" (last visited Sept. 24, 2024), https://www.spelabautoparts.com/collections/dpf-catdelete-pipe. 23 Id. 11 overall fuel mileage. Installation: Install takes about 1hr with basic hand tools done on the ground of your driveway or garage. Quicker if you have automotive style lift. Cutting may be be required to fit shorter wheelbase bed/cab configurations. Clamps, hangers and hardware are included. You may have to re-use some factory hardware. Tuner Required: Removal of the DPF, CAT, SCR, and/or DOC involves removing and eliminating emission related sensors. A DPF delete capable tuner is required to prevent any check engine light or diagnostic trouble codes from setting. Benefits: Expect to see a significant increase in fuel mileage. If your DPF is plugged up your probably averaging about 13-14 mpg. More or less depending on the severity of the restriction. After deleting the DPF/CAT expect to get a combined mileage of 18-19 mpg. It removes the need to service the DPF at regular intervals (cleaning, replacement) A DPF delete will remove the possibility of a DPF failure which could cause expensive diesel repairs Due to less exhaust backpressure, the DPF delete increases exhaust flow and therefore increases the performance of your motor! Paired with an ECU remap, the DPF delete is proven to increase power and torque for all vehicles24 These product names and descriptions indicate that the products are intended to allow the removal of the DPF. Accordingly, SPELAB knew or should have known that these products were offered for sale or installed to bypass, defeat, or render inoperative devices or elements of design that control emissions of regulated air pollutants. 3. EGR Delete Parts The third category of Defeat Devices sold or offered for sale by SPELAB is hardware parts or components that physically remove, disable, or bypass one or more components of the EGR system installed on or in a motor vehicle or motor vehicle engine (EGR Delete Parts). EGR Delete Parts 24 See, e.g., SPELAB Auto Parts, "4"/5" 2011-2018 6.7 Cummins Cab & Chassis DPF Delete Exhaust | SPELAB" (last visited Sept. 24, 2024), https://www.spelabautoparts.com/products/4-dpf-cat-delete-pipe-for-2013-2018-dodge-ram-cab-chassis6-7-cummins-diesel-spelab?_pos=1&_sid=3139d02f6&_ss=r. 12 replace and remove the EGR valve and cooler system, and typically include EGR block off plates and/or intake or exhaust manifolds that do not include an EGR port. SPELAB advertised for sale more than 30 products that fall within this category on its website. On a page tiled "EGR Delete Kits," SPELAB writes: Introduction Explore SPELAB's range of diesel delete kits, meticulously designed to improve the performance and efficiency of diesel engines. Our collection features the best diesel delete kits tailored to various vehicle brands and engine types, including Duramax, Powerstroke, and Cummins engines. These kits are engineered to maximize engine performance by removing restrictive components, enhancing airflow, and preventing soot buildup, which can reduce engine efficiency over time. Discover the perfect egr delete kit for your vehicle and experience enhanced performance today. SPELAB's EGR Delete Kit Options for Various Engines SPELAB offers a comprehensive selection of EGR delete kits suitable for a wide range of diesel engines. Whether you drive a Duramax, Powerstroke, or Cummins, we have the right solution for you: Duramax EGR Delete Kits: Designed specifically for GMC and Chevy Duramax engines, these kits are ideal for models like the 6.6L Duramax LML, LMM, LBZ, and LLY. Our Duramax EGR delete kits help improve engine performance by reducing backpressure and preventing exhaust gas recirculation, leading to cleaner intake air and increased horsepower. Powerstroke EGR Delete Kits: Tailored for Ford Powerstroke engines, including the 6.7L, 6.4L, 6.0L, and 3.0L models. These kits are perfect for Ford F250, F350, F450, F550, and F150 trucks. Our Powerstroke EGR delete kits enhance engine efficiency, reduce soot buildup, and improve overall fuel economy, making them an excellent choice for performance enthusiasts. Cummins EGR Delete Kits: Compatible with Dodge Ram and other Cummins-powered vehicles, these kits cater to the 6.7L, 5.0L, and even the robust 15.0L engines. Our Cummins EGR delete kits help optimize engine performance by eliminating the EGR system, which reduces the potential for engine damage due to soot accumulation and improves fuel efficiency. 13 Why Choose SPELAB for Your Diesel Delete Kit Needs? SPELAB is committed to providing high-quality diesel delete kits that cater to various diesel engines. Our kits are designed to offer superior performance, longevity, and reliability. Whether you need an EGR, DEF, DPF, or CCV delete kit, SPELAB ensures you have the best products to enhance your engine's performance. Choose SPELAB and experience the benefits of cleaner intake air, increased horsepower, and improved fuel efficiency. What is a EGR Delete Kit? A EGR delete kit involves removing components like the EGR valve, oil cooler, and associated plumbing from the engine. The EGR system typically recirculates a portion of the exhaust gas back into the intake system to reduce emissions. By deleting the EGR, the intake system is kept cleaner, reducing soot accumulation that can clog the engine and decrease efficiency. This process not only prevents costly repairs but also enhances overall engine performance and longevity. Benefits of an EGR Delete: Why Consider a Diesel Delete Kit? Installing an EGR delete or a diesel delete kit provides numerous benefits: Increased Horsepower: By removing the EGR system, the engine can operate more efficiently, leading to noticeable gains in horsepower. Improved Fuel Efficiency: Eliminating exhaust gas recirculation allows the engine to run more efficiently, which can improve fuel economy. Cleaner Intake Air: Prevents the recirculation of exhaust gases, resulting in cleaner intake air and reduced risk of soot buildup. Reduced Maintenance Costs: Minimizes the chances of engine issues related to soot accumulation, potentially reducing longterm maintenance costs. . . . FAQs Q1: Are diesel delete kits legal? A1: The legality of egr delete kit varies by region and usage. It is essential to check local regulations before purchasing or installing a delete kit. Q2: Will installing a diesel delete kit void my warranty? A2: Yes, installing a diesel delete kit can void the manufacturer's warranty. Always consult with your dealer or vehicle manufacturer 14 before making any modifications. . . . 25 Of the more than 30 products advertised on the SPELAB Website, many include the phrase "EGR Delete" or "EGR Valve & Cooler Delete" (or similar variations), in the product names and use "EGR Delete Kit" as the Product Type.26 Examples include, but are not limited to: EGR Delete Kit for 2015-2016 6.7L Powerstroke Diesel Ford F250 F350 F450 F550 w/ Coolant Bypass | SPELAB EGR Delete Kit For LML 2011-2016 GMC Chevy 6.6L Duramax Diesel | SPELAB EGR Valve & Cooler Delete Kit for 2014 Dodge Ram 1500 Jeep 3.0L EcoDiesel | SPELAB EGR Delete Kit For 2010-2023 Dodge Ram 6.7L Cummins Diesel | SPELAB EGR Delete Kit for 2013-2023 6.7L Cummins CAB & Chassis Dodge Ram 3500 4500 5500 SPELAB EGR Delete Kit for 2013-2018 Ram 6.7L Cummins Diesel Cooler & Throttle Valve | SPELAB SPELAB 2017-2023 6.6L Duramax L5P EGR Valve Cooler Delete Kit In addition, the "FAQs" sections in the "Overview" tab for many of these products indicate that SPELAB was aware its products would bypass, defeat, or render inoperative devices or elements of design of the vehicles and engines. The following are a few examples of questions and answers SPELAB published on the product overviews: In the Overview for the "EGR Delete Kit for 2010-2023 Dodge Ram 6.7L Cummins Diesel | SPELAB," SPELAB writes: Q1: What is an EGR delete kit? A1: An EGR delete kit removes the Exhaust Gas Recirculation (EGR) system, which reduces the amount of exhaust gases recirculated back into the engine. . . . Q3: Will installing an EGR delete kit void my vehicle's warranty? A3: Yes, installing an EGR delete kit can void your vehicle's warranty, it is recommended to check with your manufacturer or dealer before installation. . . . 25 SPELAB Auto Parts, "EGR Delete Kits" (last visited Sept. 24, 2024), https://www.spelabautoparts.com/collections/egrdelete. 26 Id. 15 Q7: Will installing an EGR delete kit affect my vehicle's emissions? Q7: Yes, removing the EGR system can increase emissions, which may make your vehicle non-compliant with local emissions regulations.27 Under "Frequently Asked Questions about L5P Delete Kit" section in the Overview for the "SPELAB 2017-2023 6.6L Duramax L5P EGR Valve Cooler Delete Kit," SPELAB writes: Q5: Will the L5P Delete Kit void my vehicle's warranty? A3: Installing an EGR delete kit may void the manufacturer's warranty. Check your warranty terms or consult a professional mechanic Q6: Is the L5P Delete Kit legal to use? A6: The legality of EGR delete kits varies by region. Check local emissions regulations before installing the kit. ... Q8: Can I still pass emissions tests with the L5P Delete Kit installed? Q7: Removing the EGR system may cause your vehicle to fail emissions tests. Verify local requirements before installation.28 In the Overview for the "SPELAB 2011-2023 Ford 6.7L Powerstroke Diesel EGR Delete Kit w/ Coolant Bypass Black," SPELAB includes the following information about EGR Delete Kits: What is an EGR Delete Kit? EGR Delete Kit Concept An EGR (Exhaust Gas Recirculation) delete kit is designed to remove the EGR system from a vehicle. The EGR system recirculates a portion of the exhaust gases back into the engine to reduce nitrogen oxide emissions. By removing this system, the engine can intake more fresh air, leading to better combustion efficiency and performance. Benefits of Deleting the EGR Removing the EGR system enhances engine efficiency, increases horsepower, and improves fuel economy. It also reduces carbon buildup in the engine, which extends engine life and lowers maintenance costs. 27 SPELAB Auto Parts, "EGR Delete Kit for 2010-2023 Dodge Ram 6.7L Cummins Diesel | SPELAB" (last visited Sept. 24, 2024), https://www.spelabautoparts.com/products/egr-delete-kit-for-2010-2019-dodge-ram-6-7l-cummins-diesel-spelab. 28 SPELAB Auto Parts, "SPELAB 2017-2023 6.6L Duramax L5P EGR Valve Cooler Delete Kit" (last visited Sept. 24, 2024), https://www.spelabautoparts.com/products/spelab-2017-2021-6-6l-duramax-l5p-egr-valve-cooler-delete-kit-pre-sale. 16 Legality of EGR Delete EGR delete is illegal in many regions because it increases nitrogen oxide emissions, which violate environmental regulations. Vehicles with EGR delete may fail emissions tests and be subject to fines or legal penalties. Potential Problems with EGR Delete While an EGR delete can improve performance, it may cause issues such as engine warning lights or increased exhaust temperatures if not properly managed. Ensuring proper tuning and maintenance can mitigate these risks. Black Smoke Concerns EGR delete can lead to black smoke if the fuel system is not properly adjusted. Proper tuning can help prevent this issue, ensuring clean combustion and optimal engine performance. ...29 These descriptions indicate that the products are intended to allow the removal or bypass of the EGR System. Accordingly, SPELAB knew or should have known that these products were offered for sale or installed to bypass, defeat, or render inoperative devices or elements of design that control emissions of regulated air pollutants. 4. CCV Delete Parts The fourth category of Defeat Devices sold or offered for sale by SPELAB is hardware parts or components that physically remove, disable, or bypass one or more components of the CCV installed on or in a motor vehicle or motor vehicle engine (CCV Delete Parts). CCV Delete Parts are designed to replace the crankcase emission control equipment included on newer diesel engines by rerouting crankcase gases either into the atmosphere or into a catch can, instead of back to the intake. SPELAB advertised for sale at least 8 products that fall within this category on its website, listed on a page titled "CCV PCV Reroute Kits."30 Of the eight CCV Reroute products advertised on this page, seven include the word "Delete" and all of them include the word "Reroute": 29 SPELAB Auto Parts, "SPELAB 2011-2023 Ford 6.7L Powerstroke Diesel EGR Delete Kit w/ Coolant Bypass Black" (last visited Sept. 24, 2024), https://www.spelabautoparts.com/products/spelab-2011-2019-ford-6-7l-powerstroke-diesel-egr-deletekit-w-coolant-bypass-black. 30 SPELAB Auto Parts, "CCV PCV Reroute Kit" (last visited Sept. 24, 2024), https://www.spelabautoparts.com/collections/ccv-pcv-reroute-kit. 17  2011+ Ford 6.7L Powerstroke CCV Reroute/Delete w/ Catch Can Internal&External Kit | SPELAB SPELAB Enhanced CCV/PCV Reroute/Delete Engine Ventilation Kit for 11-23 Ford 6.7L Powerstroke CCV Reroute/Delete Kit 2011-2024 Ford 6.7 Powerstroke F250 F350 F450 w/ Catch Can | SPELAB CCV PCV ReRoute Delete Kit for 2008-2010 6.4L Powerstroke Diesel Ford F250 F350 F450 F550 | SPELAB CCV Reroute/Delete kit For 2017-2024 L5P 6.6L Duramax | SPELAB CCV PCV ReRoute Delete Kit 2011-2016 LML 6.6L Duramax | SPELAB CCV PCV ReRoute Delete Kit 2004-2010 6.6L LLY LBZ LMM Duramax | SPELAB SPELAB 2007.5-2024 6.7L Cummins CCV PCV ReRoute Engine Ventilation Kit Four of the products listed above --the "SPELAB 2007.5-2024 6.7L Cummins CCV PCV ReRoute Engine Ventilation Kit," the "CCV PCV ReRoute Delete Kit 2004-2010 6.6L LLY LBZ LMM Duramax | SPELAB," the "CCV PCV ReRoute Delete Kit 2011-2016 LML 6.6L Duramax | SPELAB," and the "CCV Reroute/Delete Kit 2011-2024 Ford 6.7 Powerstroke F250 F350 F450 w/ Catch Can | SPELAB"-- include the following "benefits" in their descriptions: Vents crankcase blow by - decreasing oil deposits in the engine . . . Eliminates the need for the crankcase box on top of the engine - frees up room for more activities under the hood31 These descriptions indicate that the products are intended to allow the removal or bypass of the CCV. In addition, above the product listings on the page tiled "CCV PCV Reroute Kits," SPELAB provides the following information on deleting CCVs: Why do we need to delete CCV? As engine oil heats up, condensation occurs. The original CCV filter in the crankcase vent system by the OEM allows gases to escape. However, 31 SPELAB Auto Parts, "SPELAB 2007.5-2024 6.7L Cummins CCV PCV ReRoute Engine Ventilation Kit" (last visited Sept. 24, 2024), https://www.spelabautoparts.com/products/spelab-07-19-6-7l-cummins-ccv-pcv-reroute-engine-ventilation-kit; SPELAB Auto Parts, "CCV PCV ReRoute Delete Kit 2004-2010 6.6L LLY LBZ LMM Duramax | SPELAB" (last visited Sept. 24, 2024), https://www.spelabautoparts.com/products/spelab-04-10-6-6l-duramax-ccv-pcv-reroute-engine-ventilation-kit; SPELAB Auto Parts, "CCV PCV ReRoute Delete Kit 2011-2016 LML 6.6L Duramax | SPELAB" (last visited Sept. 24, 2024), https://www.spelabautoparts.com/products/spelab-11-16-6-6l-duramax-ccv-pcv-reroute-engine-ventilation-kit; SPELAB Auto Parts, "CCV Reroute/Delete Kit 2011-2024 Ford 6.7 Powerstroke F250 F350 F450 w/ Catch Can | SPELAB" (last visited Sept. 24, 2024), https://www.spelabautoparts.com/products/ccv-reroute-delete-kit-2011-2024-ford-6-7-powerstroke. 18 stricter emissions standards now require these gases to be recirculated back into the intake system. This process can introduce oil vapor, leading to valve gumming, intake sludge, and reduced engine performance. To learn more, explore the articles below: CCV FAQ Library Pros And Cons Of 6.7 Powerstroke Ccv Delete Should I Opt For CCV Reroute? Guide To CCV Modifications For 6.7 Powerstroke Diesel Engines What Is CCV - All You Need To Know! What Happens If You Don't Change Ccv Filter 6.7 Cummins The Best 6.7 Powerstroke CCV Delete Kit Try Now: SPELAB's New 6.7 Powerstroke CCV Delete Kit - Test Free! . . . 32 The links in the table lead to articles on SPELAB's "Blog & Video" page, which explain the purpose of CCV reroutes and CCV deletes, their purported benefits, and how they work in more detail. For example, in the article titled, "Pros And Cons Of 6.7 Powerstroke ccv delete," SPELAB writes the following: Pros and Cons of 6.7 Powerstroke CCV Delete (2024 Update) If you own a Ford Super Duty with a 6.7-liter Powerstroke engine, you may have heard about the possibility of performing a CCV (Crankcase Ventilation) delete. But what exactly does a CCV delete do for your 6.7 Powerstroke? In short, a CCV delete removes or redirects the blow-by gases from the engine, reducing pressure in the intake system and potentially enhancing performance. This article will dive deep into the advantages and disadvantages of a 6.7 Powerstroke CCV delete, providing you with the essential insights to make an informed decision. Understanding the 6.7 Powerstroke CCV System The CCV system in a 6.7 Powerstroke is designed to collect and recirculate blow-by gases that escape from the engine, filtering out airborne particles, hydrocarbons, and oil vapors. This process helps maintain engine health by reducing oil contamination and ensuring compliance with emission regulations. However, the CCV system can also restrict airflow, negatively impacting engine performance over time. 32 SPELAB Auto Parts, "CCV PCV Reroute Kit" (last visited Sept. 24, 2024), https://www.spelabautoparts.com/collections/ccv-pcv-reroute-kit. 19 CCV Delete vs. CCV Reroute: What's the Difference? There's often confusion between a CCV delete and a CCV reroute. A CCV delete involves removing the CCV system entirely, allowing blow-by gases to vent directly into the atmosphere. In contrast, a CCV reroute uses a kit to redirect these gases to a different exit, often incorporating a catch can to trap oil droplets and contaminants before they can affect the intake system. While both modifications aim to improve performance and reduce intake contamination, a CCV reroute is generally considered more environmentally responsible since it doesn't directly release pollutants into the atmosphere. Benefits of CCV Reroute Kits Using a CCV reroute kit offers several performance and maintenance benefits for your 6.7 Powerstroke engine: Improved Engine Performance: Removing the restrictive CCV system increases airflow to the engine, resulting in enhanced combustion efficiency and overall engine performance. This improvement is especially noticeable in high-performance diesel setups where every bit of airflow counts. Reduced Risk of Oil Contamination: By preventing oil droplets from re-entering the intake system, a CCV delete or reroute reduces oil buildup within the intake manifold and other components. This leads to a cleaner engine and potentially longer engine life with fewer maintenance issues caused by oil contamination. Additional Space in the Engine Bay: Removing or rerouting the CCV system frees up space under the hood, making room for other modifications or easing access for routine maintenance. How Does a CCV Delete Kit Work? A CCV delete kit works by rerouting the crankcase blow-by gases away from the intake system and into the atmosphere (in the case of a complete delete) or a catch can (in the case of a reroute). The goal is to prevent oil vapors and contaminants from entering the intake, thereby maintaining a cleaner air-fuel mixture and optimizing engine performance. This modification is straightforward but requires careful installation to avoid potential engine damage. 20 Pros and Cons of 6.7 Powerstroke CCV Delete Pros: Enhanced Engine Performance: By removing the restrictive CCV system, you can increase airflow to the engine, resulting in better throttle response and improved overall performance. This is a significant advantage for those looking to optimize their engine's power output. Cons: Reduced Risk of Oil Contamination: With the CCV system removed or rerouted, the chance of oil re-entering the intake system and causing deposits is minimized. This benefit can lead to a longer engine life and less maintenance over time. More Room in the Engine Bay: Removing the CCV system opens up space under the hood, allowing easier access for other modifications or routine engine maintenance. Legal and Environmental Concerns: The primary drawback of a CCV delete is the potential legal and environmental implications. The CCV system is designed to reduce emissions, and removing it can lead to increased pollution, which might violate emissions regulations in some areas. It's crucial to consider local laws before proceeding with a CCV delete. Increased Oil Consumption: Without the CCV system, more oil vapors may escape into the atmosphere, potentially increasing overall oil consumption. This can result in higher long-term maintenance costs, as you might need to top off the engine oil more frequently. Risk of Engine Damage: If not installed correctly, a CCV delete can pose risks to your engine, such as improper ventilation leading to excessive crankcase pressure. Always ensure you use high-quality kits and have them installed by a professional to avoid potential issues.33 These articles further indicate that the "CCV PCV Reroute Kits" advertised for sale on SPELAB's website are intended to allow the removal or bypass of the CCV. Accordingly, for all four categories of products described above, based upon SPELAB's status as a custom tune designer and Defeat Device manufacturer, SPELAB's promotion for its services, SPELAB's instructions (on its website and social media pages) on how to remove emission control equipment and install delete hardware, and SPELAB's informational resources about the operation and intended effect of its products on its webpage, SPELAB knew or should have known that these products were 33 Spelab Auto Parts, "Pros And Cons Of 6.7 Powerstroke ccv delete" (last visited Sept. 24, 2024), https://www.spelabautoparts.com/blogs/exhaust-cutout-blog/pros-and-cons-of-6-7-powerstroke-ccv-delete. 21 offered for sale to bypass, defeat, or render inoperative elements of design that control emissions of regulated air pollutants. Furthermore, for all four categories of products, SPELAB knew or should have known that these Defeat Devices were offered for sale or installed on "motor vehicles" or "motor vehicle engines." The Defeat Devices sold or offered for sale, by SPELAB were designed specifically for makes and models of Ford, Dodge Ram, Chevrolet, General Motors, and Cummins vehicles and engines. These OEMs sought and obtained COCs from the EPA for their vehicles or engines, and these certifications unequivocally demonstrates that these motor vehicles and motor vehicle engines are "motor vehicles" and "motor vehicle engines" under the Act. For all of these reasons, SPELAB knew or should have known that it offered for sale, or installed parts or components for motor vehicles or motor vehicle engines with a principal effect of bypassing, defeating, or rendering inoperative devices or elements of design that control emissions of regulated air pollutants. Enforcement The EPA may bring an enforcement action for these violations, and other violations it identifies, under its administrative authority or by referring this matter to the United States Department of Justice with a recommendation that a civil complaint be filed in federal district court.34 Persons violating Section 203(a)(3)(B) of the Act, 42 U.S.C. 7522(a)(3)(B), are subject to an injunction under Section 204 of the Act, 42 U.S.C. 7523, and a civil penalty of up to $5,179 for each violation.35 Each part or component manufactured, sold, offered for sale, or installed in violation of Section 203(a)(3)(B) is a separate violation. 42 U.S.C. 7524(a). Note that the EPA has not completed its investigation to identify and catalogue every Defeat Device sold or offered for sale by SPELAB. The Agency retains the authority to investigate other possible violations and our investigation of SPELAB's compliance with the CAA continues. Simultaneously with this Notice of Violation, the Agency is issuing a request for information to SPELAB pursuant to Sections 114(a)(1) and 208(a) of the CAA, 42 U.S.C. 7414(a)(1) and 7542(a), to obtain sales and other information regarding the Defeat Device products identified in this Notice of Violation as well as information regarding additional products SPELAB has sold or offered for sale. The EPA requests that you immediately cease sale of the Defeat Device products identified above, as well as any other parts, tunes, or components capable of defeating, bypassing, or rendering inoperative any emission control systems or elements of design of motor vehicles. Thereafter, please provide the following statement, signed by an authorized company official: 34 CAA 204 and 205, 42 U.S.C. 7523, 7524. 35 CAA 205(a), 42 U.S.C. 7524(a); 40 C.F.R. 19.4. 22 I hereby certify that, as of [DATE], all employees of SPELAB Auto Parts were instructed not to sell any parts, tunes, or components capable of defeating, bypassing, or rendering inoperative any emission control systems or elements of design on motor vehicles and, to the best of my knowledge and belief, SPELAB Auto Parts has not manufactured or sold, or offered to sell, or installed any such parts since [DATE]. Please provide the requested certification, via courier service or overnight delivery, to: Kayla Steinberg Attorney-Adviser Office of Enforcement and Compliance Assurance United States Environmental Protection Agency 1200 Pennsylvania Avenue, NW William Jefferson Clinton Federal Building, Room 2202F Washington, D.C. 20460 The EPA is available to discuss this matter with you in further detail upon your request. Please contact Kayla Steinberg, an EPA attorney assigned to this matter, within 14 days of receipt of this Notice of Violation. Ms. Steinberg can be reached at (202) 564-7568 or Steinberg.Kayla@epa.gov. Sincerely, MARY GREENE Digitally signed by MARY GREENE Date: 2024.09.29 16:38:50 -04'00' Mary E. Greene Air Enforcement Division 23