Investigation Summary Report

H&S Performance, SCT Performance, and Spartan Diesel

Technologies

July 2, 2014

Submitted to:

U.S. ENVIRONMENTAL PROTECTION AGENCY
Ariel Rios Building, 1200 Pennsylvania Ave., NW,

Washington, DC 20004

Submitted by:

Eastern Research Group, Inc.
14555 Avion Parkway, Suite 200
Chantilly, VA 20151

EPA Contract No. EP-W-12-007
EPA WA-1-1


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EXECUTIVE SUMMARY

In December 2013, a compliance inspection team comprised of staff from EPA and EPA's contractor,
Eastern Research Group, Inc. (ERG) conducted emissions tests of SCT Performance (SCT), Spartan
Diesel Technologies (Spartan), and H&S Performance (H&S) products. This report summarizes the three
devices sold by the aforementioned companies that changed the vehicle manufacturers' stock parameters
within the engine computer module, as well as hardware designed to deactivate the exhaust gas
recirculation system and exhaust aftertreatment device. Further, the manufacturers of these tuners could
not have emission testing results that are in compliance with the regulations as demonstrated by EPA-
purchased tuners on a Ford F-350 test vehicle with a 6.7 Liter Powerstroke turbo diesel engine. The test
results confirm that the tuners and other devices alter the engine's operational design and profoundly
increase regulated exhaust emissions of the vehicles on which they are installed.

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TABLE OF CONTENTS

Page

I.	Introduction	5

II.	Background	5

III.	Purchase of Tuners and Aftertreatment Delete Pipe	6

A.	Spartan 6.7 Liter Phalanx Tuner	6

B.	H&S XRT Pro Tuner	7

C.	SCT 3015R Tuner	7

D.	Flo-Pro Aftertreatment Delete Pipe	8

IV.	Ford Testing Overview	8

A.	Test Vehicle	9

B.	Testing Procedures	10

1.	Tuner Calibration Installation	11

2.	Flo-Pro Aftertreatment Delete Pipe Installation	15

3.	OBD Scan Tool Data Procedure	16

4.	Live Engine Data Logger Procedure	16

5.	Test Cycle Selection and Test Procedure at Ford	17

V.	Ford Testing Results	20

A.	OBD Scan Tool Data Observations	20

1.	Cal ID and CVN	20

2.	DTCs and MIL	20

B.	Analysis of Engine Data Maps by Bosch	23

C.	Live Engine Data	24

1.	Methodology	24

2.	Summary of Live Data Results	25

D.	Measured Emissions Results	28

1.	US06 Test (Emissions Equipment-Present Only)	28

2.	FTP4-74 Test	32

Appendix A Photograph Log	34

Appendix B Chronological Order of Produced Performed by Ford, EPA, and ERG	61

Appendix C Spartan Tuner Purchase Memorandum	64

Appendix D SCT Tuner Purchase Memorandum	65

Appendix E Communication with Spartan for Tuner Activation	66

Appendix F Bosch's Evaluation of Tuner Calibration	67

Appendix G Miscellaneous Email Communication	68

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I. Introduction

A compliance inspection team comprising staff from EPA and EPA's contractor, ERG, investigated SCT,
Spartan, and H&S for manufacturing and selling potential defeat devices for on-highway engines. The
investigation included purchasing engine computer module (ECM) tuning devices from each company,
installing each tuner calibration on a test vehicle, and performing emissions testing. ERG and EPA
traveled to Ford Motor Company (Ford) the week of 2 December 2013 to conduct emission testing on a
test vehicle. The purpose of this testing was to identify which engine controls are altered by each tuner
and how use of these tuners, along with defeat devices to physically bypass the exhaust aftertreatment
systems, affect emissions of regulated pollutants.

EPA Representatives:	Anne Wick, MSEB, EPA Headquarters

Anthony Miller, MSEB, EPA Headquarters

EPA Contractors:	Brent Ruminski, ERG

Michael Sabisch, ERG
Alan Stanard, ERG
Andrew Loll, ERG

Ford Representatives:

Appendix A contains photographs taken during the investigation including at the Ford emissions test
facility. Throughout the report, ERG refers to photographs in Appendix A as Photograph [#]. Section II
provides additional background on the investigation.

II. Background

The companies investigated offer many types of automotive performance products, including the
aforementioned engine computer module (ECM) tuners, cold air intakes, and tuning software for personal
computers.1 EPA focused this investigation on the ECM tuners. The companies investigated manufacture
and sell these ECM tuners for use with on-highway light heavy-duty engines. They advertise these
devices to increase performance and fuel economy. The companies and respective tuner models evaluated
in this investigation are:

•	Spartan Diesel Technologies (Spartan): 6.7 Liter Phalanx

•	H&S Performance's (H&S): XRT Pro

•	SCT Performance (SCT): 3015R

To date, the companies investigated have not submitted any documentation to EPA of completed
emissions testing.

For this investigation, EPA was primarily concerned with investigating the following:

•	Emissions equipment-present calibrations: Determining what engine parameters these types of
calibrations alter and if these alterations adversely affect emissions.

•	Emissions equipment-removed calibrations: Determining if each tuner is able to render
inoperative or bypass emission control devices such as exhaust gas recirculation (EGR), selective
catalytic reduction (SCR), oxidation catalyst (OC), diesel particulate filter (DPF) and devices
involved in engine control. This includes determining what engine parameters these types of

1 This software allows users to view, create, or modify calibrations.

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calibrations alter and if these alterations adversely affect emissions. More specifically, this
includes determining whether the tuners:

o Disable or alter functions of the ECM and OBD to allow the engine to operate after the
user physically removes the emission control devices (applies to OC. SCR. and DPF);
and/or

o Disable or alters functions of the ECM and OBD to defeat (i.e.. electronically turn off)
the EGR system without physically removing the EGR system.2

III. Purchase of Tuners and Aftertreatment Delete Pipe

ERG purchased the three tuners online as typical customer. Once received. ERG handled the tuners as
evidence, completed chain-of-custody forms for each upon receipt, and properly maintained the
documentation and evidence throughout the investigation. Table 1 summarizes some of the key functions
of the three tuners that ERG confirmed during this investigation. The following subsections summarize
how ERG purchased each tuner.

Table 1. Summary of Tuner Capabilities

Parameter

Spartan Phalanx

XRT Pro

SCT 3015R

Number of vehicles tuner can be
installed ou

One. unless a
second license is
purchased

Unlimited as long as
previous ECM was
returned to stock

Up to five as long as
previous ECM was
returned to stock

Capable of defeating EGR when EGR
system is not physically removed?

Yes

Yes (but must unplug
two EGR sensors)

No

Capable of defeating EGR when EGR
system is physically removed?

Yes

Yes

Yes

Capable of defeating aftertreatment
system when physically removed?

Yes

Yes

Yes

A. Spartan 6.7 Liter Phalanx Tuner

On 13 September 2013. ERG purchased the Spartan Phalanx tuner through Rudy's Diesel Performance
website.3 The memorandum in Appendix C describes the purchasing process. Photograph [1] shows the
Spartan timer out of the box as received by ERG on 19 September 2013. Photographs [2] and [3] show
the product description and the serial number as 018914130513Q.

The Spartan Phalanx timer ERG pmchased is only compatible with the Model Years 2011 and 2012 6.7
Liter Powerstroke engine. The 6.7 Liter Powerstroke is typically installed in Model Years 2011 and newer
offered by Ford hi their F-250 models and larger (e.g.. F-350. F-450). A different version of the Phalanx
was available that is compatible with the 6.4 Liter Powerstroke. The 6.4 Liter Powerstroke is typically
installed on Model Years 2008 to 2010 Ford truck models F-250 and larger.4

2	As determined by ERG during this investigation, this may or may not require the user to unplug wiring to the EGR
valve depending oil the tuner.

3	More infomialion on Rudy's Diesel Performance is available online at: www rudysdiesel.com.

4	During the purchase process, there was some confusion on whether the tuner could be used on the 6.7 or 6.4 Liter
Ford Powerstroke. The receipt ERG received indicated the timer was for a 6.4 Liter. ERG called a sales
representative at Spartan who indicated the desired tuner could be used on the 6.7 Liter. Upon receipt, ERG
confirmed the tuner that was received could be used on the 6.7 Liter. The representative also indicated that the
device could allow an EGR DPF delete.

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B. H&S XRT Pro Tuner

On 18 July 2013, ERG purchased the H&S XRT Pro tuner from Monster Performance Exhaust.5
Photograph [4] shows the XRT Pro tuner out of the box as received by ERG on 23 July 2013. Photograph
[5] shows the serial number on the sticker as 0060039934 and also shows the date 21 March 2013 next to
the serial number suggesting that H&S produced this unit on this date.6 Photographs [6] and [7] show the
warranty card ERG received with the XRT Pro which includes the part number and serial number. The
warranty card also indicates that the XRT Pro is capable of installing software modifications necessary to
support "off-road/race modifications".

The XRT Pro instruction manual indicated that the unit is compatible with the following engine model
makes, models, and Model Years:

•	2006 - 2007: Cummins 5.9 Liter;

•	2007.5 - 2009: Cummins 6.7 Liter;

•	2010 - 2012: Cummins 6.7 Liter;

•	2003 - 2007: Ford Powerstroke 6.0 Liter;

•	2008 - 2010: Ford Powerstroke 6.4 Liter;

•	2011 - 2013: Ford Powerstroke 6.7 Liter;

•	2007.5 - 2010: Duramax 6.6 Liter; and

•	2011 - 2013: Duramax 6.6 Liter.

C. SCT 3015R Tuner

On 16 September 2013, ERG purchased the SCT tuner from Rudy's Diesel Performance website.3 The
memorandum in Appendix D describes the purchasing process. ERG received the SCT unit on 23
September 2013. Photographs [8] and [9] show the SCT tuner in its original packaging on the front side
and back side, respectively. The serial number of the unit was XP06281339A62, as shown in Photograph

[10].

During the purchasing process, Rudy's website indicated the SCT tuner was only compatible with the
Ford Powerstroke 6.4 Liter. ERG emailed Rudy's Diesel Performance and asked if the tuner that was
available was compatible with the Ford Powerstroke 6.7 Liter. A representative responded and stated that
the tuner is in fact compatible with the 6.7 Liter. Both the website and the receipt indicated that ERG
purchased the SCT 3025 tuner. However, the tuner ERG received was instead the 3015R model. The
instruction manual that came with the tuner indicated it is only compatible with the engine model makes,
models, and Model Years listed below. During testing, ERG confirmed the tuner is also compatible with
Model Year 2011 Ford Powerstroke 6.7 Liter engine, which the manual did not list.

1996—2008	V-8 Mustangs, Cobras, Mach I and Shelby GT500;
1994—2008 V-6 Mustangs;

1997—2003	F-Series 4.6L / 5.4L / 7.3L Diesel ('99-'03 Only);
2004—2008 F-Series 4.2L / 4.6L / 5.4L / 6.8L / 6.0L Diesel;
2009 - 2010 F-Series 6.4 Liter Powerstroke;

1999—2004 Focus SVT / Zetec;

2003—2004 Mercury Marauder;

1999—2008 Crown Victoria;

2002—2006 Thunderbird 3.9L;

5	Monster's website is available at: http://monsterperformanceexhaust.com.

6	H&S reported to EPA they stopped selling EGR/DPF delete tuners on 11 July 2013 (based on internal
communication from EPA to ERG on 1 August 2013).

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•	2000—2006 Lincoln LS 3. 9L;

•	1996—1999 Taurus SHO;

•	1999—2005 Excursion 6.8L / 6.0L Diesel;

•	1997—2006 Explorer 4.0L / 4.6L;

•	1997—2005 Expedition 4.6L / 5.4L; and

•	2005—2006 Ford GT Supercar.

D. Flo-Pro Aftertreatment Delete Pipe

ERG originally ordered a Flo-Pro aftertreatment delete pipe with the Part Number 857 NB for the 6.7
Liter Powerstroke from USA Performance Exhaust7 located in Butte, Montana. ERG purchased the
system for the purpose of installing the system on the test vehicle and evaluating emission equipment-
removed calibrations (SCR, DPF, OC removed). The aftertreatment delete pipe received the week of
testing was Flo-Pro part number 837 NB, which is the 6.4 Liter Powerstroke model, instead of the 857
NB that ERG ordered for the 6.7 Liter Powerstroke. Photograph [11] shows the box received from USA
Performance. Photograph [12] shows the document received with the aftertreatment delete pipe verifying
that it is the incorrect part number 837 NB. ERG also confirmed it was the incorrect part by measuring the
full length of the aftertreatment delete pipe. It was approximately one foot shorter than the stock bolt-on
aftertreatment system.

ERG researched local performance shops in the Detroit area that Flo-Pro lists as certified dealers and
identified Wolf Diesel Performance located at 396555 Willow Road, New Boston, Michigan. ERG called
Wolf Diesel Performance on 3 December 2013 and ordered an 857NB aftertreatment delete pipe with
overnight shipping. ERG returned the incorrect aftertreatment delete pipe to USA Performance and later
received a full refund from the company.

On 4 December 2013, ERG received a call from a Wolf Diesel Performance8 representative stating that
the system arrived at their location. At that time, the representative requested that ERG pick up the system
at Jimmy John's Gourmet Sandwiches located at 22211 West Road, Woodhaven, Michigan. When the
contact met ERG and EPA in the parking lot, the facility contact was able to swipe a credit card for a
payment of $255 to a PNC business account and immediately emailed a receipt to ERG. The Wolf Diesel
Performance representative noted that he wanted to meet at Jimmy John's because his family owns the
restaurant and he had to begin a work shift. He also stated that he typically ships parts to his customers for
future reference. ERG and EPA arrived back at Ford in the afternoon of 4 December 2013 with the Flo-
Pro 857 NB aftertreatment delete pipe.

Photograph [13] shows the box containing the Flo-Pro aftertreatment delete pipe as received by Wolf
Diesel Performance. Photograph [14] shows the Flo-Pro aftertreatment delete pipe out of the box. This is
a two piece system and contains no bungs.9 The two main pipes have Part Numbers 31112NB and
31114NB. Photograph [15] shows that Wolf Diesel Performance's distributer is called Thunder Diesel
located at 1835 Highway 201 South Spur, Mountain Home, Arkansas. It also shows that Wolf Diesel
Performance had the distributer ship the unit to 18282 Huron River Drive, New Boston, Michigan instead
of the address reported on Flo-Pro's website for Wolf Diesel Performance previously mentioned.

IV. Ford Testing Overview

Ford agreed to provide EPA with a test vehicle and conduct testing to measure emissions and engine
operating data when various calibrations from the three tuners are installed. ERG and EPA traveled to

7	USA Performance Exhaust's website is: http://www.usaperformanceexhaust.com/home.

8	Wolf Diesel Performance does not have a website.

9	The bungs in the OEM exhaust pipe are threaded holes for sensors.

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Ford's testing facility in Allen Park, Michigan the week of 2 December 2013. Ford performed testing and
ERG installed the calibrations. In addition. Ford allowed Bosch, their ECM supplier, to analyze what
modifications the timers make to the ECM data maps after the testing. Hie following subsections
summarize the results and observations.

A. Test Vehicle

Ford provided a Model Year 2011 F-350 with a 6.7 Liter diesel engine. Table 2 provides a detailed
description of the test vehicle. Photographs [16] through [22] show the test vehicle at the time of the
testing. The test vehicle was OBD II compliant and certified to meet model year 2011 emissions standards
for complete10 heavy-duty vehicles (40 CFR 86.1816-05 and 86.1816-08).

Table 2. Ford Test Vehicle Description

Parameter

Value

Make

Ford

Model

F-350

Model year

2011

Engine Configuration

V-8

Engine Size (liters)

6.7

VIN

1FT8W3CT6BEA00289

Engine mileage (Odometer beginning of testing)

33,933 miles'

Afteitreatment mileage

-4,000 miles

EPA engine family

BFMXD06.771C

Emissions Equipment

EGR. SCR. OC. period trap oxidizer (PTOX)b. turbo charger
(TC). direct diesel injection (DDI), charge ah cooler (CAC)

a - This is the odometer reading observed at the beginning of testing on 2 December 2013.
b—This system contains the DPF.

Table 3 shows the emissions standard, certification level, additive deterioration factors (DF), and engine
adjustment factor (EAF) for the test vehicle's engine family (EF), BFMXD06.771C. The table shows the
standards for nitrous oxides (NOx). particulate matter (PM), carbon monoxide (CO), and non-metliane
hydrocarbon (NMHC).

•	DF is a factor that represents the increase in emissions over the life of a vehicle. Specifically, this
is the increase between certification testing, when the afteitreatment has only been used for
approximately 4,000 miles, and the end of the useful life of the afteitreatment system. The
applicable emission standards define the useful life for EF BFMXD06.771C as 11 years or
120,000 miles. Engine manufactures must add the DF to die measured emissions when
determining the official certification level.

•	EAF is an additional factor added to the measured emissions for certification under certain
circumstances. This factor accounts for excess emissions during DPF regeneration. Engine
manufacturers must add the EAF to the measured emissions for certification if regeneration does
not occur during the testing.11

10	A complete vehicle is one that requires no further manufacturing operations to perform its intended function and
is a functioning vehicle that has the primary load carrying device or container (or equivalent equipment) attached or
that is designed to pull a trailer (40 CFR 523.2).

11	More information on engine adjustment factors is available online at: http://www.epa.gov/otaq/highway-
diesel/workshop/420f04022 .pdf.

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•	Certification level is the measured emissions after all DFs and EAFs are added to the measured
emissions for certifications. The certification level must be less than the certified standard.

•	Certified standard is the applicable standard under 40 CFR Part 86 that the certification level
must meet.

Table 3. Certification Emission Levels and Standards for Engine Family BFMXD06.771C

Constituent

Additive DF
(g/ini)

EAF (g/rni)

Certification
Level (g/mi)a

Certified
Standard (g/ini)b

NOx

0.0000

0.0200

0.3000

0.4

PM

0.0070

0.0000

0.0100

0.02

CO

0.2300

0.0100

0.6000

8.1

NMHC

0.0334

0.0001

0.0510

0.23

a — Certified emissions levels for this engine family at the end of the useful life after applying appropriate DF and
EAFs to the raw emission test results using an FTP75 test cycle.

b — Emissions standards this engine family is required to meet at the end of the useful life after applying appropriate

DF and EAFs to the raw emission test results using an FTP75 test cycle.

Source: All data is available on EPA's website at: http://WwW.epa.gov/otaq/crttst.htm.

B. Testing Procedures

The following subsections describe the test procedures Ford. EPA, and ERG followed the week of testing
including:

•	Tuner calibration installation;

•	Aftertreatment delete pipe installation;

•	Obtaining OBD data;

•	Obtaining live engine data: and

•	Test cycle selection and test descriptions.

After consulting with Ford. EPA decided to test each calibration/tuner with the F-350 using a consecutive
series of FTP4-74 and US06 test cycles. These tests are described in more detail in Section IV.B.5. Table
4 summarizes the matrix of test cycles and calibrations EPA completed for each tuner at Ford's testing
facility. Ford completed a baseline FTP4-74 test on the F-350 prior to the week of 2 December 2013 on
26 November 2013 prior to ERG's and EPA's arrival at the testing facility, hi addition. Ford completed a
baseline US06 test cycle after the week of 2 December 2013. Ford stated that DPF regeneration occurred
on the test vehicle prior to the baseline test on 26 November 2013 such that regeneration would not occur
during the actual emission tests. ERG and EPA confirmed that no regeneration occurred during any of the
emission tests.

Table 4. Chassis Dynamometer Test Matrix for Testing at Ford

Tuner

Test

Baseline

Emissions Equipment-
present

Emissions Equipment-
Removed

Spartan

FTP4-74

11/26/2013

12/2/2013

12/5/2013

US 06

1/3/2014

12/4/2013

	a

XRT

FTP4-74

11/26/2013

12/2/2013

12/6/2013

US06

1/3/2014

~a

	a

SCT

FTP4-74

11/26/2013

12/3/2013

12/5/2013

US06

1/3/2014

12/3/2013

	a

a - Due to limited access to the test cell, these tests were not performed.

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Table 18 in Appendix B provides a more detailed order of procedures than what is shown in Table 4 that
Ford, EPA, and ERG completed during the testing at the Ford laboratory the week of 2 December
2013.The following describes how Ford, EPA, and ERG tested each calibration for each tuner.

1.	ERG and EPA removed the original ECM in the truck and installed the original
equipment manufacturer (OEM) stock-calibrated ECM assigned to the tuner being tested.
Ford supplied a new stock ECM dedicated to each tuner being tested.

2.	Ford reset the anti-theft system on the vehicle which is required when a new ECM is
installed. Without this process, the engine would not run. This process involves
connecting a Ford laptop to the ECM and running a program for approximately 10
minutes.

3.	ERG obtained the calibration identifications (Cal ID), calibration verification numbers
(CVNs), the status of the malfunction indicator light (MIL), and any diagnostic trouble
codes (DTC) from the ECM with the existing calibration installed. See Section IV.B.3 for
more information on what these parameters are and how ERG obtained them. ERG
started the engine momentarily at the beginning of this step to allow the ECM to detect
DTCs and to recalculate the CVN.

4.	ERG installed one of the calibrations using the tuner. See Section IV.B. 1 for detailed
procedures ERG followed for each tuner and calibration installation.

5.	ERG obtained the Cal ID, CVN, MIL status, and any DTCs from the ECM with the
calibration installed. See Section IV.B.3 for more information on what these parameters
are and how ERG obtained them. ERG started the engine momentarily at the beginning
of this step to allow the ECM to detect DTCs and to recalculate the CVN.

6.	Ford connected an ECM data logger to the vehicle to obtain live engine data parameters
over time during the testing. See Section IV.B.4 for detailed procedures related to the
ECM data logger.

7.	Ford performed one of the two test cycles selected for testing. See Section IV.B.5 for
more details on these test cycles and procedures.

Testing of emissions equipment-removed calibrations required installation of an aftertreatment delete
pipe. The installation process for this delete pipe is described in Section IV.B.2.

1. Tuner Calibration Installation

Each purchased tuner came preloaded with multiple calibrations. For the purpose of this investigation,
ERG categorized calibrations into one of two categories:

•	Emissions equipment-present - These calibrations modify engine data maps to alter engine
operating parameters (e.g., injection timing, fuel injection quantities). These calibrations do not
disable emission control devices.

•	Emissions equipment-removed - These calibrations defeat emission control devices in addition to
the functions performed by emissions equipment-present calibrations.12

Ford provided three identical OEM ECMs for testing each with a stock calibration. ERG installed a new
ECM onto the test vehicle for each tuner so that each tuner had a designated ECM which allowed Bosch
to analyze calibrations from all three tuners after testing without the potential for interference from
flashing the ECM using multiple tuners. Table 5 shows the ECM serial number designated to each tuner.

12 This includes calibrations that disable functions of the OBD that would otherwise prevent the engine from running
if a vehicle owner was to tamper with an emission control device. This also includes calibrations that electronically
disable the function of entire emission control system without physically removing the system.

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Table 5. Designated ECM Serial Numbers for
Each Tuner

Tuner Make and Model

ECM Serial Number

Spartan 6.7 Liter Phalanx

260310-2593

XRT Pro

260210-0143

SCT 3015R

160210-1855

The following subsections provide a more detailed description of the tuners including the installation
process ERG followed for emission equipment-present and equipment-removed calibration installation

a. Spartan 6.7 Liter Phalanx Tuner

After powering on the Spartan tuner, shown in Photograph [23]. the user is immediately prompted to
agree to the "off-road" disclaimer shown in Photograph [24], The main menu has several icons including
"load tune" and "load stock" which were the two menu options used to install preloaded calibrations to
the ECM and return in to stock, respectively. As received, the Spartan tuner showed no preloaded tunes
available for install. As directed in the installation manual. ERG completed the following steps to activate
the Spartan 6.7 Liter Phalanx tuner:

1.	Set up an account on Spartan's website and entered detailed information about the vehicle13

2.	Sent an email to Spartan with a signed license agreement

3.	Copied an index file received from Spartan via email after completing Steps 1 and 2 to the timer's
memory card

Appendix E provides emails and screenshots documenting each step described above. ERG placed the
memory card back into the timer. Once the memory card was inserted into the timer containing the mdex
file, the following preloaded times for the 6.7 Liter Powerstroke were available in the tuner's "load mne"
menu:

•	25HP DPF On Cab & Chassis Only;

•	90 HP DPF On Cab & Chassis Only:

•	50 HP DPF On;

•	125HP DPF On;

•	40 HP DPF Off;

•	80 HP DPF Off:

•	120HP DPF Off;

•	165HP DPF Off; and

•	200HP DPF Off War Hammer Race.

For emissions equipment-present testing, ERG installed the "125 DPF On" calibration as shown in
Photograph [26], The timer does not allow the user to input any other options after selecting the
calibration to install.

For emissions equipment-removed testing, ERG selected the performance calibration as shown in
Photograph [27]. The ftmer does not allow the user to input any other options after selecting the
calibration to install. Spartan's instructions for disabling the EGR and aftertreatment system were vague.

13 The detailed information included tuner serial number, vehicle model year, vehicle model, transmission type
(automatic), gear ratio, tire size, manufacturer date, engine strategy code, and transmission strategy code.

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On 3 December 2013, ERG called Spartan technical support and asked if it was necessary to unplug
sensors for the EGR and aftertreatment system. The Spartan representative instructed ERG to leave all
electronic EGR sensors plugged in and stated that when a L'DPF off' tune is selected, the calibration
automatically turns off the EGR valve. The Spartan representative also stated that the sensors in the
aftertreatment should be left plugged in and seemed in another fashion assuming the aftertreatment delete
kit (i.e., straight pipe) has no bungs.

b. H&S XRT Pro Tuner

When powered on for the fnst time and connected to a vehicle, the H&S XRT Pro immediately prompts
the user to enter the vehicle model and model year. On the first day of testing, ERG selected "11-12 Ford
6.7L Powerstroke" (see Photograph [28]).

To install a new calibration. ERG selected the "download" menu option. Within this menu. ERG used the
"Download H&S ftming" and "Return to stock (OEM tune)" options to install new calibrations and reUun
to stock, respectively (See Photograph [29]). After selecting to download a new calibration, the tuner
prompted ERG to answer a series of prompts. Table 6 shows the H&S XRT Pro installation prompts in
sequential order and indicates the options ERG selected for testing by calibration type. Photographs [30]
through [34] show screenshots for each prompt during the Ford testing installation. Prompts 4 and 5 only
become available after the user enters the "upgrade code" to unlock the "high sulfur" calibrations. For this
timer, "high sulfur" indicates that the user has removed the aftertreatment system and either removed or
unplugged the EGR.14 ERG entered the "upgrade code" provided on the warranty card, shown in
Photograph [6], into the emissions selection menu (see Photograph [35]). Entering this code unlocked the
emission equipment-removed calibrations as indicated in Photograph [36],

Table 6. Installation Prompts for the H&S XRT Pro Tuner

Step #

Prompt

Input Options

Option Selected for Testing

Photograph #

Emission
Equipment-

Present
Calibration

Emission
Equipment-

Remove
Calibration

1

Please Select Power Level

•	Stock

•	Street

•	Tow

•	Performance

Performance

Performance

30

2

Do you want to adjust the speed
limiter?

• Yes
•No

No

No

31

3

Do you wrant to tune the
transmission?

•	Yes

•	No

No

No

32

4

Is the emissions system still
PRESENT on this vehicle, or has
it been REMOVED or modified
for high sulfur fuel use?

•	Present

•	Removed

Present1

Removed

33

5

Do you want to adjust low boost
fueling?

1. Stock fueling (less

smoke)0
5.No limit (more
smoke) c

N/Ab

5

34

a—This prompt only appeals after entering the "updated code" into the emissions selection menu,
b—Tins prompt does not appear for when the answer to prompt 4 is "present".

c—The user may enter any value form 1 and 5 but descriptions are only provided for 1 and 5 in the table above.

14 The use of "high sulfur" by H&S is irrelevant to the type of fuel used.

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The H&S XRT timer requires the user to unplug several electrical connections to emission control
systems for emissions equipment-removed calibrations. The instruction manual clearly indicates that two
EGR harnesses must be unplugged in order for the emissions equipment-removed calibrations to work
without physically removing the EGR system. Photographs [38] and [39] show these two harnesses. ERG
and EPA. with the assistance of Ford, disabled the EGR by unplugging both two harnesses. The rest of
the EGR system remained fully installed. The instruction manual also clearly indicated that the sensors on
the aftertreatment system must be unplugged. Section IV.B.2 provides more information on these sensors.

c. SCT 3015R Tuner

After the SCT tuner turns on. a simple menu option appears. To install a new calibration. ERG selected
the "strategy tune" menu option (see Photograph [39]). When ERG attempted to install the fust
calibration onto the test vehicle on 2 December 2013, the SCT timer recognized the 6.7 Liter Powerstroke
engme as shown hi Photograph [40]). However, the next screen stated "ECU unsupported additional
update needed, please run auto-update" (see Photograph [41]). ERG immediately hooked the SCT tuner to
a laptop computer and ran the auto-update software that came with the timer on a CD. After this update,
the SCT no longer reported this error dining the installation process.

Table 7 shows the SCT 3015R installation prompts in sequential order and indicates what ERG selected
for testing by calibration type. Photographs [42] through [48] show screenshots for each prompt during
the Ford testing installation.

Table 7. Installation Prompts for the SCT 3015R Timer

Step #

Prompt

Input Options

Option Selected for Testing

Photo.

#

Emission-
Equipment-Present
Calibration

Emission
Equipment-Remove
Calibration

1

Do you have a race exhaust
installed?

•	Yes

•	No

No

Yes

42

2

Recalibrate speedometer for non-
stock tire sizes?

•	Yes

•	No

No

No

43

3

Change axle gear ratio setting for
non-stock gears?

•	Yes

•	No

No

No

44

4

Change tire pressure monitor
system cold PSI setting?

•	Yes

•	No

No

No

45

5

Please select your engine power
level

•	Stock

•	Street

•	Tow

•	Performance

Performance

Performance

46

6

Please disable or select your
speed limit

•	Stock

•	Disable

•	60MPH

Stock

Disable

47

7

Please select your trans power
level

•	Stock

•	Performance

Stock

Stock

48

For emissions equipment-removed testing, SCT's instructions do not clearly indicate what to do with
sensors when installing emissions equipment-removed calibrations. On 2 December 2013, ERG called
SCT technical support to ask whether or not to unplug the EGR harness. The SCT representative
mdicated that the timer is only able to install calibrations that disable the EGR when installing a full EGR
delete kit. Simply unplugging the EGR is not an option for this timer and will cause the OBD to

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illuminate the MIL and derate the engine.15 The representative also confirmed that all sensors related to
the aftertreatment system must remain plugged in but do not need to be installed in the aftertreatment
system. Consequently, ERG left the EGR fully intact and functional for emission equipment-removed
testing. ERG left all aftertreatment sensors plugged in (i.e., connected to the ECM) but did not reinstall
them because the Flo-Pro aftertreatment delete pipe did not contain bungs (see Sections III.D and IV.B.2).

2. Flo-Pro Aftertreatment Delete Pipe Installation

Prior to emission equipment-removed testing, Ford installed the Flo-Pro DPF delete kit onto the test
vehicle in the garage located in the testing facility. Photographs [14] and [49] show the Flo-Pro
aftertreatment delete pipe out of the box and installed on the vehicle respectively. Ford removed the bolt-
on exhaust section that included the oxidation catalyst, SCR, and DPF (in order from upstream to
downstream). Photograph [20] shows the stock aftertreatment system that Ford removed and replaced for
this portion of the testing. Prior to installing the delete kit, ERG installed a Spartan DPF-off tune onto the
vehicle to prevent the OBD from derating the engine because Ford had to start the engine to move the
vehicle from the garage to the testing area.

The Flo-Pro aftertreatment delete pipe did not contain any bungs for sensors but the stock aftertreatment
system removed from the test vehicle contained bungs for the following sensors:

•	Three EGT sensors;

•	One pressure sensor;

•	One NOx sensor; and

•	One urea injector.

The instructions for each tuner require the user to do handle these sensors differently:

•	Spartan 6.7 Phalanx: Remove from pipe but remain plugged in

•	SCT 3015R: Remove from pipe but remain plugged in

•	XRT Pro: Removed from pipe and unplugged.

During the Flo-Pro aftertreatment delete pipe installation, Ford left all sensors plugged into the harnesses
as directed by the Spartan installation instructions. The sensors remained plugged in and tucked away for
the SCT emissions equipment-removed testing. Prior to testing the XRT emissions equipment-removed
calibration, Ford unplugged all sensors.

After successfully installing the aftertreatment delete kit and the Spartan emission equipment-removed
calibration, Ford performed a transmission relearn on a nearby highway.16 Due to logistics, this was the
only opportunity to perform a transmission relearn during the entire testing week. However, Ford
suggested that not performing a transmission relearn would not affect emissions performance but may
cause some "harsh" shifting in the early phase testing after the transmission is recalibrated. In addition,
the Spartan 6.7 Phalanx was the only tuner investigated by EPA that automatically calibrates the
transmission and does not provide the user the option to calibrate the transmission during the installation
process. Although the other tuners were capable, ERG and EPA decided to not calibrate the transmission
for the other tuners.

15	The SCT representative indicated that the user must indicate if they removed the EGR in the "adjustable options"
tab on the main menu. However, ERG was unable to find this indicator in the adjustable options tab.

16	Manufacturers recommend a transmission relearn whenever a transmission is recalibrated. A transmission relearn
consists of a series of aggressive and non-aggressive accelerations.

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EPA used this transmission relearn as an opportunity to demonstrate the Spartan tuner is capable of
altering the OBD in a way that allows the vehicle to operate without any aftertreatment system.
Photograph [50] and [51] show black smoke the vehicle generated from a hard acceleration during the
transmission relearn.

3.	OBD Scan Tool Data Procedure

After installation of each calibration and testing scenario, ERG immediately removed the tuner, connected
an OBD II scan tool to the OBD II data link connector (DLC) on the test vehicle, and obtained vehicle
data including DTCs, status of the MIL, Cal ID, and CVN. ERG used an AutoXray ® 4000 OBD II scan
tool. ERG obtained this information for each tuner and calibration during the testing process:

•	Before removing the ECM that was already installed on the vehicle from the previous test;

•	After installing the new ECM that is assigned the tuner being tested;

•	After installing the new calibration using the tuner being tested; and

•	After returning the calibration to stock after the test cycle (if applicable).

The following describes each one of the parameters ERG recorded during testing. Section V.A
summarizes the observations.

•	Cal ID - The Cal ID represents the software version, which includes the engine data maps. A new
calibration installation may or may not result in a new Cal ID depending on the tuner.

•	CVN - The CVN is the result of a 'check-sum' calculation performed by the OBD system using
the engine data maps as inputs. If the data values have not been changed or corrupted, the CVN
will always provide the same sum for a given Cal ID. If the ECM has been modified or corrupted
any of the calibration values, the CVN calculation will generate an incorrect 'sum'. ERG used this
as the ultimate indicator that the tuner installed a new calibration between each test.

•	DTCs - DTCs are codes that indicate a fault has been detected in one of the engine or emission
systems. DTCs specifically indicate what system the fault was identified.

•	MIL - The MIL, also known as the check engine light, is a symbol located near the odometer.
The MIL indicator is amber (yellow) in color and should be illuminated for the first five seconds
after the ignition key is turned on to show that the MIL light is working properly. After startup,
the light is only illuminated when a malfunction is detected following the detection of DTCs. The
MIL activates when monitored operating parameters indicate an engine component is
malfunctioning to the point that the vehicle may be exceeding its applicable emission standards
by certain thresholds.

4.	Live Engine Data Logger Procedure

After ERG completed the calibration installation process, Ford installed an engine data logger into the
OBD II DLC after ERG installed the new calibration and removed the tuner from the vehicle. To activate
the device, Ford plugged the logger into the OBD II DLC. The logger begins recording the data when the
vehicle engine speed (i.e., RPM) increases from zero after the engine is turned on. Ford set the data logger
to record data at a rate of 60 hertz or one data point per second. Ford selected the parameters to record
prior to ERG and EPA's arrival for testing the week of 2 December 2013. The list of parameters recorded
are below (units are noted parenthetically).

Ford provided all logged data to ERG after the testing. ERG used the data to compare operating
parameters that may affect emissions such as EGR, fueling rates, and fresh air flow. Section V.C
summarizes ERG's analysis of the live engine data.

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Parameter List

•	Time (ms)

•	RPM (RPM)

•	Rel Pedal Angle (%)

•	Vehicle Speed (MPH)

•	Fresh Air Flow Mass (mg/hub)

•	ASMODEGRrate (%)

•	Engine Coolant Temp (deg F)

•	Inlet Air/Air Charge Temp (deg F)

•	Engine Oil Temp (defF)

•	EGR Valve Position (%)

•	Engine Torque (Nm)

•	Temp Downstream of DPF (deg C)

•	Filter Restriction (hPa/(mA3/s))

•	Percent Soot Load Regenerated (%)

•	Condition of DPF (1 to 7)

•	Regen Enable State (value)

•	Engine Coordinator State (value)

•	Exhaust Back Pressure (hPa)

•	Post 1 Fuel Quantity (mg/hub)

•	Post 2 Fuel Quantity (mg/hub)

Parameter List (Continued)

•	Tailpipe NOx Sensor (ppm)

•	UREA Command (mg/sec)

•	Mass Fuel Desired (mg/hub)

•	Engine Operating Mode (value)

•	Throttle Angle (%)

•	Low Temp Coolant Temp (deg C)

•	Desired EGR Rate (%)

•	UREA Tank Level (L)

•	Rail stCtlLoop* (RAM)

•	Rail stCPC* (RAM)

•	Regen Request (value)

•	Temp Upstream of DPF (deg C)

•	Temp Upstream of DOC (deg C)

•	IMAP (hPa)

•	Temp Downstream of DOC (deg C)

•	NH3 Stored in SCR (gm)

•	Trans Gear Commanded (value)

•	Exh Pressure Upstream of DPF (hPa)

•	Distance Between Regens (miles)

5. Test Cycle Selection and Test Procedure at Ford

EPA's goal for this testing was to evaluate the relative change in emissions between the stock calibration
(i.e., baseline) and calibrations from each tuner and, therefore, EPA did not use the FTP75 certification
test cycle. Instead, Ford recommended running consecutive (FTP4-74 or US06) test cycles to complete a
single test for each tuner calibration. Running consecutive test cycles ensured that at the beginning of the
last test cycle in each test, the vehicle operating conditions (e.g., aftertreatment system temperature,
engine oil temperature, coolant temperature) were consistent between tests thus providing comparable
results. Consequently, EPA only compared results for the last phase of the test. Additionally, this allowed
the testing to be completed in the limited time available17.

The following subsections describe the two tests performed at Ford for the purpose of analyzing the effect
of each calibration/tuner.18 Section V.D summarizes the corresponding results for these tests.

a. FTP4-74

The FTP4-74 test cycle, also known as the Federal Test Procedure 74 or the Urban Dynamometer Driving
Schedule, is designed to mirror city driving conditions simulating frequent starts and stops. The FTP4-74
test cycle has the same speed trace as the FTP7219 cycle described in 40 CFR Part 86 Appendix I (a). Ford

17	The FTP75 certification test cycle requires a 12-hour cold soak in a 75°F room prior to running the test which
would have limited the number of tests Ford and EPA could run the week of testing.

18	All information provided in this section is available on EPA's website at:
http://www.epa.gov/nvfel/testing/dynamometer htm.

19	The FTP75 and the FTP72 are two variations of the EPA Urban Dynamometer Driving Schedule. The FTP75 is
the successor of the FTP72 and is derived from the FTP72 by adding a third 505 second phase to the test cycle that
is identical to the first phase of FTP72. The FTP75 is also described in 40 CFR Part 86 Appendix I (a).

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stated that the difference between the FTP4-74 test cycle and the FTP72 test cycle is that the FTP72 test
cycle requires a 12 hour "cold soak" at 75 degrees Fahrenheit prior to testing. Table 8 describes the FTP4-
74 test cycle in more detail. Figure 1 shows the speed trace of a single FTP4-74 test cycle. As shown in
Figure 1 and Table 8. each FTP4-74 test cycle has two phases.

For each calibration and timer FTP4-74 test. Ford completed the following procedure:

1.	Performed one FTP4-74 test cycle when the engine was cold

2.	Allowed a 10 minute engine off period

3.	Performed a second FTP4-74 test cycle

4.	Performed a third FTP4-74 test cycle (ERG only used the result from this cycle for evaluating
how each calibration affected emissions in Section V.D). A short engine-on idle period occurred
between Steps 3 and 4 above, as specified in the FTP speed trace, at the end and beginning of
each FTP4-74 test cycle.

Ford recommended only using the third FT4-74 test cycle result as the valid result. This ensures that the
vehicle's engine and emission control devices were at "steady state" operating temperature at the
beginning of thud and valid test.

Table 8. FTP4-74 Test Cycle Description

Parameter

Description

Description

Normal city driving



Phase 1
("cold start")8

~3.6 miles
505 seconds

One FTP4-74 test cycle

Phase 2
("stabilization phase")

~3.9 miles
867 seconds



Total test cycle

~ 7.5 miles
1372 seconds

a — Although this is typically described as a "cold start", it was actually a hot start by the third consecutive test cycle
during each FTP4-74 test Ford conducted the week of 2 December 2013.

ocMTrtfoooNtftfcootNtrvooooN
lf)l/)\Ovfif^r-c6cO^(7*GO*- — N I? H)

Test Time, sees

Phase 2

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Source: EPA (OTAQ)20

Figure 1. One FTP4-74 Test Cycle Speed Trace

b. US06

The US06 test cycle is also known as the Supplemental Federal Test Procedure (SFTP) which was to
address the shortcomings with the Urban Dynamometer Driving Schedule. It captures aggressive, high
speed and/or high acceleration driving behavior, rapid speed fluctuations, and driving behavior following
startup. Table 9 describes the US06 test cycle in more detail. Figure 2 shows the speed trace of a single
US06 test cycle which is available in 40 CFR Pail 86 Appendix I (g).

For each calibration and tuner US06 test. Ford completed the following procedure:

1.	Performed one US06 test cycle when the engine was cold

2.	Performed a second US06 test cycle (ERG only used the result from this cycle for evaluating how
each calibration affected emissions in Section V.D). A short engine-on idle period occurred
between steps 1 and 2, as specified hi the FTP speed trace, at the end and beginning of each US06
test cycle.

Ford recommended only using the second US06 test cycle result as the valid result to ensure that the
vehicle's engine and emission control devices were at "steady state" operating temperature at the
beginning of the second and valid test.

Table 9. US06 Test Cycle Description

Test Scenario

US06

Description

Hard city driving

Breakdown of test cycle

Only 1 phase

~8 miles
-600 seconds

90

80

a. 70
E

-60

« 50

w 40
£

£ 30

I 20

10
0

OKi'-tfc^cNinco — -
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V. Ford Testing Results

The following subsections summarize the results and observations from the emissions testing at Ford.
Section A describes observations of general diagnostic information reported through the OBD. Section B
presents Bosch's analysis of the ECMs after testing. Section C presents ERG's analysis of live engine
data obtained during the testing. Section D Presents the measured emissions results from the Ford testing.

A. OBD Scan Tool Data Observations

After installation of each calibration and testing scenario, ERG immediately removed the tuner, connected
an OBD II scan tool22 to the OBD II DLC on the test vehicle, and obtained vehicle data. ERG observed
DTCs, the status of the MIL, Cal ID23, and CVN.24 After each emission testing each calibration, ERG
returned the ECM to stock and observed the same data. Table 10 shows the data obtained through the
OBD DLC after each set of tests. It is important to note that when a tuner is unplugged, the most recent
calibration remains installed on the ECM along with any software modifications.

1.	Cal ID and CVN

EPA's OBD scan tool reported "33EC57FE" for the stock calibration on all three ECMs that Ford
provided.25 Observations shown in Table 10 show that:

•	The Spartan and H&S tuners altered the Cal IDs for each calibration modification.

•	The SCT tuner did not alter the Cal ID.

For all tuner calibrations, the observed CVNs changed from the stock CVN confirming that the tuners
modified engine data maps in some way. Also for all tuner calibrations, the ECM Cal ID and CVN
matched the certified values after returning the ECM to stock, verifying that the each tuner successfully
returns the ECM to its stock calibration with no obvious trace of modification.

2.	DTCs and MIL

For all tuners, after installing each emissions equipment-present calibration and starting the engine, the
OBD II scan tool reported the MIL as "off' and no DTCs were present. Ford verified that none of the
emissions equipment-present calibrations should have triggered a DTC or the MIL. However, Ford
confirmed that with the aftertreatment system removed, the OBD would immediately trigger DTCs,
illuminate the MIL, and shut off the engine if started with a stock calibration. After each of the emissions
equipment-removed calibrations were installed, no DTCs were triggered and the MIL status was always
"off' indicating that all tuners deliberately disable functions of the OBD.

Between installations of emissions-removed calibrations from different tuners, ERG observed DTCs and
the MIL status as "on" while the ECM was temporarily in its stock configuration and the aftertreatment
system as removed verifying what Ford reported. These observations varied by tuner. For example, ERG

22	The OBD scan tool was an AutoXray ® 4000.

23	The Cal ID represents the software version, which includes the engine data maps.

24	The CVN is the result of a 'check-sum' calculation performed by the OBD system using the engine data maps as
inputs. If the data values have not been changed or corrupted, the CVN will always provide the same sum for a
given Cal fD. ff the ECM has been modified or corrupted any of the calibration values, the CVN calculation will
generate an incorrect 'sum'.

25	Ford provided all ECMs with exactly the same calibrations: Cal ID 1: BC3A - 14C204-FAA and Cal ID 2:
DDBN3C3.H32. However, EPA's scan tool read the first calibration slightly different as BC3A-14D609-AD. For
the purpose of this testing, ERG assumed BC3 A-14D609-AD is equivalent to the stock calibration reported by Ford.
The second observed calibration matched the second calibration reported by Ford: DDBN3C3.H32.

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observed no DTCs related to the EGR after returning the ECM to stock from the Spartan emission
equipment-removed calibration because the Spartan tuner does not require the user to unplug or remove
the EGR to disable it. However, ERG did observe emission control related DTCs after returning the H&S
XRT Pro to stock because ERG unplugged all EGR and aftertreatment sensors.

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Table 10. OBD Scan Tool Observations

Tuner

Calibration

MIL

Status

DTC Count

Cairo 1
(Calibration Name)

Cal ED 2 (Cal ID)

CVN 1



Stock3

Off

0

DDBN3C3.H32

BC 3 A-14D609-AD

33EC57FE



Emissions Equipment-Preseutb

Off

0

SPRTENG.H32

BC3A-12B533-AD

1B828E73

Spartan

Returned to Stock0

Off

0

DDBN3C3.H32

BC3A-14D609-AD

33EC57FE



Emis sions E quipment-Reniovedd

Off

0

SPRTENG.H32

BC3A-12B533-AD

C50A6DD6



Returned to Stock0

Off®

0

DDBN3C3.H32

BC 3 A-14D609-AD

33EC57FE



Stock"

Off

0

DDBN3C3.H32

BC3A-14D609-AD

33EC57FE



Emissions Equipment-Presentb

Off

0

DDBM3CZ.H32

BC3 A-12B5 3 3-AD

BE884C2F

XRT Pro

Returned to Stock0

Off

0

DDBN3C3.H32

BC3A-14D609-AD

33EC57FE



Emis sions E quipment-Removedd

Off

0

DDBM3CZ.H32

BC3A-12B533-AD

DF0E651S



Returned to Stock0

Off?

11

DDBN3C3.H32

BC 3 A-14D609-AD

33EC57FE



Stock3

Off

0

DDBN3C3.H32

BC 3 A-14D609-AD

33EC57FE



Emissions Equipment-Present11

Off

0

"Not Supported',f

"Not Supported"

A03A2541

SCT

Returned to Stock0

Off

0

DDBN3C3.H32

BC3A-14D609-AD

33EC57FE



Emissions Equipment-Removed*1

Onh

1

DDBN3C3.H32

BC 3 A-14D609-AD

86E782D7



Returned to Stock0

Off?

0

DDBN3C3.H32

BC3A-14D609-AD

33EC57FE

a - Tliis OBD data was observed piior to any testing.

b - This OBD data was observed after each ECM was calibrated to the emissions equipment-present calibration.

c - This OBD data was observed after each ECM was returned to its stock calibration immediately after emissions equipment-present testing,
d — This OBD data was observed after each ECM was calibrated to the emissions equipment-removed calibration.

e - This OBD data was observed after each ECM was returned to its stock calibration immediately after emissions equipment-removed testing,
f — The SCT tuner reported the strategy as "DDBN3C3" after the emissions equipment-present calibration was installed but the scan tool reported "'not supported'',
g — ERG was did not start the engine after each ECM was returned to stock from emission equipment-removed calibrations because the afteitreatment system was
still removed. According to Ford, starting the engine with the stock ECM would result in engine derating.

h - The MIL turned oil during this test. The triggered DTC was P167F: "Non-OEM Calibration Detected". However, vehicle continued to operate normally.

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B. Analysis of Engine Data Maps bv Bosch

As described in Section IV.B.l, Ford supplied three different ECMs for testing such that ERG installed
the calibrations from each Uiner onto a designated ECM. On 6 December 2013, ERG left each ECM in a
specific calibration determined by EPA so that Bosch, Ford's ECM supplier, could compare the stock
calibration file against the tuner calibration file. Appendix F provides the engine data map results as
reported to ERG by Ford after the testing.

Table 11 lists the engine data map parameters that the timer calibration altered as reported by Ford/Bosch
after the testing. Asterisks indicate parameters that are of concern in respect to emissions. In addition to
observing the alterations to data maps described in Table 11. Bosch/Ford also observed changes to data
stream label names. Appendix F also provides a complete list of the data streams that involved a label
change.

Table 11. Summary of Calibration File Compare by Bosch

Tuner

Calibration
Type

Parameter

Observed Changes in Calibration

Spartan 6.7 Liter
Phalanx
(ECM Serial

Number:
260310-2593)

Emissions
equipment-
present

Fuel quantity*

Increases

Rail pressure*

Increases

Smoke limit*

Allows lower air-to-fuel-ratio (fuel rich)

Fuel injection timing*

Advanced timing by 5 degrees at higher torque
demands

Compoent protection3

Increased T3 limit from 800 to 900 DegC

Driver demand

Moved to upper bounds

Disable codes

\TD Block

Max engine speed

Moved from 3,800 to 4,000

Engine protect

Moved torque and fuel to max allowed

Max vehicle speed

Moved to max allowed

H&S XRT Pro
(ECM Serial

Number:
260210-0143)

Emissions
equipment-
present

Fuel quantity *

Increased during the fuel injector energizing time

Fuel Injection timing*

Advanced timing by 2 degrees at higher torque
demands

Smoke limit*

Allows lower air-to-fuel-ratio (fuel rich)

Compoent protection3

Moved T3 way out

Lug curve

Moved out of the way

Driver demand

Increased torque early on in pedal

Disabled codes

—

Max engine speed

Increased from 3,800 to 4,500 rpm

Engine protect

Eliminated overheat threshold for coolant and oil

Max vehicle speed

Moved to max allowed

SCT 3015R
(ECM Serial

Number8:
160210-1855)

Calibration
returned to
stock

No changes observed

" no description provided.

a—The summary ERG received from Ford reported "Compoent" but it was likely meant to be "component".

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C. Live Engine Data

During the testing, Ford logged live engine operating data by connecting a Ford data logger directly to the
OBD II data link connector. Ford provided ERG all of the recorded data after testing. ERG analyzed
engine parameters that can potentially affect emissions performance if altered from the designed
operating range including:

•	EGR (%);

•	Total urea consumption;

•	Total fuel consumption; and

•	Cumulative air-to-fuel ratio (AFR).

The following subsections describe the calculations ERG made and the summary of results.
1. Methodology

The raw data from Ford included a value for each engine parameter over time at the rate of 1 hertz, or 1
data point per second. ERG calculated ranges, medians, and cumulative totals for the aforementioned data
streams using Microsoft Excel. For this analysis, ERG excluded all data points logged before the vehicle
speed increased from zero at the beginning of testing and all data points after the vehicle speed reached
zero at the end of the testing. This was done because the data logger often started logging data
immediately after engine start up and not when the actual test cycle commenced (i.e., the vehicle was put
into drive). By eliminating the excess data before the vehicle moved and after the vehicle stopped, ERG
was able to compare data sets on an equivalent basis (e.g., same length of time).

EGR

ERG evaluated the data stream called "ASMOD EGR rate" in order to investigate if the tuners disable the
EGR system function. The "ASMOD EGR rate" data stream represents the recirculated exhaust gas flow
as a percentage of total intake volume. The ECM calculates this data stream by converting the measured
delta pressure to mass flow rate downstream of the EGR cooler just prior to the engine intake. The ECM
uses the fresh air and/or total intake mass flow rate to convert this mass flow rate to a percentage of total
intake volume.

Ideally, ERG would use the actual EGR valve position data stream, but the Spartan emissions equipment-
present calibration defaulted this data stream to zero. Ford confirmed that the ASMD EGR rate provides a
valid measurement for approximate EGR flow.

Urea consumption

ERG evaluated the data stream called "Urea Command" in order to investigate if the tuners disable the
SCR system function. The "urea command" data streams represent instantaneous urea consumption in mg
per second. ERG used Equation 1 to convert the instantaneous rate to cumulative urea consumption for
each test.

Equation 1

V	f m9 \

Cumulative Urea (mg) = ^ UreaInst (seconc/) x ATime

Note: Bold values in the equations are data streams as reported in the raw engine data.

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Cumulative Average AFR (and Fuel Consumption)

ERG used several individual data streams to calculate the cumulative AFR. ERG analyzed AFR because
any increase or decrease in AFR from stock will potentially affect emissions. As described below, this
included the calculation of cumulative fuel consumption and fresh air flow. ERG specifically evaluated
fuel consumption in this report because we expected the tuning devices to alter the fueling rates as
opposed to fresh air rates. In addition, a significant increase in AFR is an indicator that the EGR has been
turned off because the volume within the cylinder that is typically displaced by recirculated exhaust gas is
replaced with fresh air.

Although the raw data did include instantaneous air and fuel flow rates necessary to calculate
instantaneous AFR, ERG did not analyze instantaneous AFRs due to potential time lag differences
between air and fuel rates.26 Instead, ERG integrated the instantaneous fuel mass rate (Fuelmst) and
instantaneous intake air mass flow (Fresh Airmst) across each time increment (ATime) to calculate the
cumulative air and fuel flow for the entire test cycle and then subsequently calculated the cumulative
average AFR. Furthermore, the raw data reported fuel flow rate in units of mass per stroke which required
conversion to mass per unit time using other data reported. ERG used Equation 2 and Equation 3 to
convert the reported fuel and fresh air mass per stroke to cumulative values respectively. These equations
convert the reported mass per stroke to mass per unit time and then integrate the instantaneous mass flow
rate to calculate the cumulative values for each test cycle. Equation 4 calculates the cumulative AFR
using the results from Equation 2 and Equation 3.

Equation 2

Cumulative Fuel (mg)



/revoltions\ , ma \ / 2n \ /180 dearees\
	) x Fuelinst (	V) x 	) x 			

\ ms J	VstrokeJ \revolutionJ \ n J

(720 degrees / cylinder J
Equation 3

= ^ RPMlnst

1 stroke \

x 8 (cylinders) x ATime

Cumulative Air (mg)

ST1	lrevoltions\	/ ma \ / 2n \ /180 deqrees\

) x Fresh Air inst(	;—) x (	-—;—]x(	]

J	\stroke> \revolutionJ \ u J

= > RPM:

L-i inst \ ms

c

Equation 4

1 stroke \

		—	:—-—;— x 8 (cylinders) x

720 degrees/cylinder)

Cumulative Air (kg)

Cumulative AFR (kg-, kg) = ¦

Cumulative Fuel (kg)

Note: Bold values in the equations are data streams as reported in the raw engine data.

2. Summary of Live Data Results

Table 12 presents the values ERG calculated for the live engine data logged by Ford by tuner, calibration
type, and parameter. Table 13 summarizes these statistics in comparison to the baseline FTP4-74 test by
tuner and calibration type. Due to logistics, Ford was unable to log data for the US06 baseline test. Due to
the lack of duplicate tests, ERG was unable to determine typical repeatability for these data streams.
Despite having no duplicate data logger results, it reasonable that the some of the changes summarized in
Table 13 are statistically measureable. Statistically measurable results are highlighted red. It is possible

26 A very small time lag (less than a second) can cause an inaccurate instantaneous AFR.

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that the other measured increases are also statistically measureable, but there are 110 duplicate results to
confirm. These results are highlighted yellow.

Table 12. Live Engine Data Observations







FTP4-74 Test

US06 Test

Tuner

Parameter

Value Type

Baseliue

Emissions
Equipment-
Present

Emissions
Equipment-
Removed

Baseline

Emissions
Equipment-
Present



EGR Air System

Range

0-54

2-55

0



0-54

Spartan
6.7 Liter

Model (%)

Median

37

38

0



27

Urea (g)

Total

17

22

0



>2T

Phalanx

Fuel (kg)

Total

1.72

1.72

1.52



>1.62



AFR (kg/kg)

Cum. Average

30

31

55



~2Sa



EGR Air System

Range

0-54

No datab

0



Not tested0

H&S

Model (%)

Median

37

No datab

0



Not tested0

XRT

Urea (g)

Total

17

No datab

0

No Datad

Not tested0

Pro

Fuel (kg)

Total

1.72

No datab

1,64



Not tested0



AFR (kg/kg)

Cum. Average

30

No datab

52



Not tested0



EGR Air System

Range

0-54

0-54

0-53



0-55

SCT
3015R

Model (%)

Median

37

39

40



26

Urea (g)

Total

17

12

0



29

Fuel (kg)

Total

1.72

1.53

1.44



1.82



AFR (kg/kg)

Cum. Average

30

33

34



30

a — The first 30 seconds of the test was not recorded by the data logger,
b — Ford did not use a data logger for this test,
c — The XRT was not tested on the US06 test.

d — Ford was unable to obtain data from the data logger for the baseline US06 test.

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Table 13. Summary of Live Engine Data Observations on tlie FTP4-74 Test

Tuner

Calibration Type

Observed Changes in Measured Operating Parameters

Spartan 6.7

Liter

Phalanx

Emissions equipment-
present

• Urea consumption increased

Emissions equipment-
removed

•	EGR eliminated

•	Urea consumption eliminated

•	Cumulative AFR increased significantly because of elimination of EGR

• Fuel consumption decreased

H&SXRT
Pro

Emissions equipment-
present

	a

Emissions equipment-
removed

•	EGR eliminated

•	Urea consumption eliminated

•	Cumulative AFR increased significantly because of elimination of EGR

• Fuel consumption decreased

SCT 3015R

Emissions equipment-
present

•	Urea consumption decreased

•	Fuel consumption decreased

•	Cumulative AFR increased

Emissions equipment-
removed

• Urea consumption eliminated

•	Fuel consumption decreased

•	Cumulative AFR increased

a — The data logger was not used for this test.

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D. Measured Emissions Results

The following sections summarize the results from emissions testing at Ford's testing facility using an
engine dynamometer the week of 2 December 2013. Ford measured NOx, PM, CO, NMHC, and fuel
economy for each tuner model and calibration type on the US06 and FTP4-74 tests. For CO and NOx,

Ford provided both system out (SO) values, which represents tailpipe emissions, and engine out (EO)
values, which represents emissions prior to aftertreatment. Ford was able to estimate the EO emissions by
inserting a probe immediately downstream of the turbo charger, prior to aftertreatment. EO results
represent modal measurements and SO results represent bag measurements.27 EO values were not
measured for PM and NMHC or when emission equipment was removed. Ford did not measure EO
values when emission equipment was removed because the section of the exhaust system that contained
the probe was removed in order to install the aftertreatment delete pipe.

1. US06 Test (Emissions Equipment-Present Only)

Ford conducted US06 tests on the Spartan and SCT tuners in addition to duplicate baseline US06 tests
with a stock calibration. This section is divided into two parts: US06 test results (Section V.D.I.a) and
US06 baseline test results (Section V.D.l.b). Section V.D.I.a summarizes the test results with the tuners
installed and V.D. 1 .b summarizes the duplicate baseline test results and how ERG used them.

a. US06 Test Results (Emissions Equipment-Present Only)

Table 14 present test results for NOx, PM, CO, NMHC, and fuel economy for the US06 test. Results are
categorized by tuner model and calibration type.

Red highlighted results - The red highlighted results shown in Table 14 are statistically significant
increases over the mean baseline result. These results include the EO and SO CO measured with the
Spartan and SCT tuners. For the purpose of US06 test results only, ERG classified these results as
significant using the statistical analysis described in Section V.D.l.b with the assumption that the
emissions measurement variability is relative to the magnitude of the emissions values.28

Yellow highlighted result - The yellow highlighted PM result for the Spartan tuner shown in Table 14 is a
potential increase over the mean baseline PM result. ERG classified this result as such using the statistical
analysis described in Section V.D.l.b on a regular (i.e., non-log) scale.29

27	For each test, Ford used the same dynamometer calibration settings including an inertia of 11,000 pounds, "Road
Load A" of 53.79 pounds, "Road Load B" of -0.6331 pounds, and "Road Load C" of 0.05883. Each test Ford
performed used the same exact fuel identified "DIES 720-A" in the raw result files.

28	The assumption of relative errors in measured emissions was made by conducting this statistical analysis on the
natural logs of the measured emissions values. This approach conservatively assumes that variability of
measurements increases relative to the measured result.

29	Conducting this statistical analysis on a regular (i.e., non-log) scale is less conservative and assumes that
variability of measurements does not increase relative to the measured result.

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Table 14. US06 Test Results for Model Year 2011 6.7 Liter Powerstroke Vehicle at Ford with the Spartan 6.7L Phalanx and SCT 3015R

Tuners

Tuner

Test Scenario

EO NOx

SO NOx

SO NMHC

EO CO

SO CO

PM

Fuel Economy

Result
(g/mi)

%
DifP

Result

(g/mi)

%
DifP

Result
(g/mi)

%
Difr

Result
(g/mi)

% Difr

Result
(g/mi)

% Diff

Result
(g/mi)

% Difr

Result
(mpg)

%
DitT

Spartan

Mean baseline

3.621

—

1.6053

—

0.0060

—

2.823

—

0.0096

~

0.0012

—

12.06

—

Equip-Presentb

3.118

-14

1.2191

-24

0.0012

-80

4.205

49 (8.6)f

0.4550

4.664 (11 l)f

0.0072e

526 (5.0)f

12.14

1

SCT

Mean baseline

3.621

—

1.6053

—

0.0060

-

2.823

—

0.0096

--

0.0012

-

12.06

—

Equip-Presentb

3.162

-13

0.5287

-67

0.0042

-29

5.059

79 (14)f

0.7152

7,389 (175/

0.0014

22 (0.2)f

12.23

1

EO — Engine Out

SO — System Out (tailpipe)

Red — Statistically significant increase from baseline
Yellow - Potential increase fioni baseline

a — Percent difference of the result compared to baseline (or stock OEM), Negative values represent decreases. Positive values represent increases,
b —Emissions equipment-present calibration
c —Emissions equipment-removed calibration

d — No EO data was available when emission equipment was removed.

e —As described in Section IV.B, Ford stated the results from second consecutive US06 test cycle during each US06 test should be considered the valid result. Due to a
procedural reporting error, this test result was inadvertently reported as the Phase 1 result rather than the Phase 2 result. However, Ford confirmed after the testing that
this test result was, in fact, for Phase 2.

f — Values in parenthesis represent the increase in terms of number of standard deviations over the mean baseline result. Additional statistical data for duplicate
baseline tests are shown in V.D.I.b.

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b. Duplicate US06 Baseline Test Results

Replicate measurements can be used to estimate the statistical significance of differences in the emissions
measurements as a consequence of modifying the stock calibration through the use of the tuners. Ideally,
replicate measurements would be made for both the baseline and the modified configurations. However,
due to logistics, replicate test results were only obtained for the US06 baseline test with the stock
calibration and not when the ECMs were modified using the tuners. Therefore, variability is unknown
when the ECMs were in a "tuned" state.

An alternative approach to collecting actual replicate measurements for the modified calibrations is to
make an assumption about how the variability is related to the observed measurement. Two options that
may be used include: 1) assume the magnitude of the measurement variability is the same for all
configurations regardless of the measured value (absolute variability), and 2) assume the magnitude of the
measurement variability increases as the magnitude of emissions increases (relative variability). ERG
analyzed the significance of US06 test results using both options:

•	Option 1: ERG classified a measured result in Table 14 as a potential increase from baseline
(yellow highlight in Table 14) if it passes the statistical test described below without using a
natural log scale. This is less conservative than option 2 and assumes that variability of
measurements does not increase relative to the measured result. For example, this assumes that
the 0.004 grams per mile standard deviation for CO calculated for the baseline US06 test would
be exactly the same on the US06 test when the ECM is calibrated with one of the tuners despite
the fact that the measured CO increased by up to 7,000 percent over baseline

•	Option 2: As explained in Section V.D.I .a, ERG only classified a measured US06 test result as a
significant increase from baseline (red highlight in Table 14) if it passes the statistical test
described below on a natural log scale. On a natural log scale, the criterion for determining if an
increase is statistically significant becomes more stringent. Conducting this statistical analysis on
a log scale conservatively assumes that the variability of measurements increases relative to the
measured result.

ERG used the statistical test called the "one-sided t-test"30 to determine if the measured increase is
statistically greater than the mean baseline. For each measured parameter, ERG followed the following
procedure:

1.	ERG used Equation 5 to calculate the relative percent difference of the base results. Note
that this value is not used in any subsequent calculations and is shown for context.

2.	ERG used Equation 6 to calculate the standard deviation of the baseline results.

3.	ERG used Equation 7 to calculate a criterion, defined as |_i. based on the number of
baseline samples and the standard deviation of the mean baseline results.

4.	ERG determined if Equation 8 is true. If the result of Equation 8 is true, ERG determined
that this test result is statistically greater than the mean baseline test result.

Equation 5

Equation 6

Relative Percent Difference =

|Xi -x2\

SD =

\

S (Xj - x)2

(n- 1)

1 Test procedure from National Bureau of Standard's Experimental Statistics (August 1, 1963).

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Equation 7

SDt

I1 = f0.95 X ~r=

Vn

Equation 8

mj — x > [i

Where:

|i = criterion for significance ~ 4.5

to 95 = t value for 95 percent confidence = 6.31431

n = number of duplicate baseline results = 2

SDi = Standard deviation of the duplicate baseline results for each parameter

xi = l5' baseline result

X2 = 2nd baseline result

Xi = individual baseline result

x = the mean baseline result

in. = measured parameter result of sample "i"

Table 15 provides the results for the two US06 baseline tests in grains per mile along with the calculated
mean, the standard deviation of the two US06 baseline test results, and the standard deviation of the
baseline results. To allow ail examination of significant differences under the assumption that variability
increases relative to the measured result. Table 16 provides the same statistics as Table 15 on a natural log
scale.

Table 15 Results for Duplicate US06 Baseline Tests (Absolute Scale)

Parameter

1st US06
Baseline Test
Result
(g/milea)

2nd US06
Baseline Test
Result
(g/milea)

Relative
Percent
Difference

(%)

Mean US06
Baseline Test
Result
(g/milea)

Standard
Deviation
(g/milea)

(g/milea)

EO NOx

3.461

3.781

9%

3.621

0.2263

1.010

SONOx

1.556

1.655

6%

1.605

0.0701

0.3129

SO NMHC

0.0068

0.0051

29%

0.0060

0.0012

0.0054

EO CO

2.937

2.709

8%

2.823

0.1612

0.7198

SO CO

0.0067

0.0124

60%

0.0096

0.0040

0.0180

SO PM

0.0003

0.0020

148%

0.0012

0.0012

0.0054

Fuel Economy
(mpg)

12.17

11.94

2%

12.06

0.1650

0.7368

a - Unless otherwise noted.

31 It is important to note that as the number of samples increases to 95 becomes less stringent. For example, if the
number of duplicate test results increases from two to three, to 95 decreases from 6.314 to 2.920.

31

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Table 16. Results for Duplicate US06 Baseline Tests (Log Scale)

Parameter

log of 1st US06
Baseline Test
Result
(g/inilea)

log of 2nd
US06 Baseline
Test Result
{g/inilea)

Relative
Percent
Difference

(%)

Mean of log

of US06
Baseline Test
Result
(g/milea)

Standard
Deviation
(g/inilea)

(g/inilea)

EO NOx

1.242

1.330

7%

1.286

0.0625

0.2792

SO NOx

0.4419

0.5037

13%

0.4728

0.0437

0.1950

SO NMHC

-4.991

-5.279

6%

-5.135

0.2034

0.9082

EO CO

1.077

0.9966

8%

1.037

0.0571

0.2551

SO CO

-5.006

-4.390

13%

-4.698

0.4353

1.943

SO PM

-8.112

-6.215

26%

-7.163

1.342

5.989

Fuel Economy
(mpg)

2.500

2.4S0

1%

2.490

0.0137

0.0611

a — Unless otherwise noted.

2. FTP4 74 Test

Ford conducted FTP4-74 tests on all tuners in addition to one baseline FTP4-74 test. Table 17 present the
test results for NOx, PM, CO. NMHC, and fuel economy for the FTP4-74 test. Results are categorized by
mner model and calibration type. Because testing included FTP4-74 test for both emissions equipment-
present and -removed, this section is divided mto two parts.

a. Emissions Equipment-Removed

The red highlighted results shown in Table 17 are large increases32 over the baseline results. This includes
all measured emissions for all timers when emissions equipment was removed. It is important to note that
smallest relative increase of emissions was approximately 4.000 percent and increases as high as 114.000
percent were obseived. In addition, the measured increases for all three tuners for each measured
parameter were similar. For example, measured NMHC increased by approximately 100,000 percent for
all three tuners. Hie only parameter that did not increase the same was NOswith the SCT tuner. This can
be explained by the fact that the SCT tuner does not electronically disable the EGR system like the other
two tuners. However, the SCT tuner still resulted in a 4.000 percent increase hi SO NOx due to the
absence of the SCR system.

a. Emissions Equipment-Present

The yellow highlighted results shown in Table 17 are all potential increases measured over the baseline
result. ERG was unable to specifically classify any emissions equipment-present results as increases due
to the following reasons:

•	No historical variability data for the FTP4-74 test cycle with this engine family are available;

•	No duplicate test results are available; and

•	Some SO and EO increases were inconsistent (e.g.. EO and SO CO measurements for SCT).

32 The statistical significance of these increases were not determined since replicate emissions measurements during
FTP4-74 testing were not available.

32

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Table 17. FTP4-74 Test Results for Model Year 2011 6.7 Liter Powerstroke Vehicle at Ford at Ford with All Tuners

Tuner

Test Scenario

EONOx

SO NOx

SO NMHC

EO CO

SO CO

PM

Fuel Economy

Result
(g/rni)

%
DifP

Result
(g/mi)

% DifP

Result
(g/mi)

% DifP

Result
(g/mi)

%
DifP

Result
(g/mi)

%
DifP

Result
(g/mi)

% DifP

Result
(mpg)

% DifP

Spartan

Baseline

1.036

--

0.0303

--

0.0005

-

5.384

--

0.0255

--

0.0017

-

13.16

--

Equip-Presentb

1.087

5

0.0579

91

0.0005

0

5.035

-6

0.0269

5

0.0025

47

13.54

3

Eqmp-Removedc

	d

	d

10.5344

34,667

0.5678

113.460

	d

	d

3.3177

12.911

0.0649

3.718

14.58

11

XRT

Baseline

1.036

—

0.0303

--

0.0005

-

5.384

—

0.0255

-

0.0017

-

13.16

-

Equip-Presentb

0.986

-5

0.0107

-65

0.0005

0

5.107

-5

0.0156

-39

0.0002

-88

13.56

3

Equip-Removedc

	d

	d

8.3975

27.614

0.5731

114.520

	d

	d

3.0056

11.687

0.0685

3.929

14.60

11

SCT

Baseline

1.036

—

0.0303

-

0.0005

-

5.384

—

0.0255

-

0.0017

-

13.16

-

Equip-Presentb

0.911

-12

0.0146

-52

0.0005

0

6.111

14

0.0146

-43

0.0013

-24

13.58

3

Equip-Removedc

	d

	d

1.3222

4,264

0.4524

90.380

	d

	d

4.8951

19.096

0.2103

12.271

14.04

7

SO — System Out (tailpipe)

Red — Large increase from baseline

Yellow - Potential increase from baseline

a - Percent difference of the result compared to baseline (or stock OEM). Negative values represent decreases. Positive values represent increases,
b —Emissions equipment-present calibration
c —Emissions equipment-removed calibration

d — No EO data was available when emission equipment was removed.

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Appendix A
Photograph Log

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H&S Performance, SCT Performance, and Spartan Diesel Technologies

PHOTOGRAPH #: 1

TAKEN BY: A. Stanard

DATE TAKEN: 9/19/2013

COMMENTS: Spartan Phalanx
tuner box as received from Rudy's
Diesel.

SITE LOCATION: ERG Austin, Texas Office

PHOTOGRAPH #: 2

TAKEN BY: B. Ruminski

SITE LOCATION: Ford Testing Facility

DATE TAKEN: 12/2/2013

COMMENTS: Front of the Spartan
Phalanx box showing several
disclaimers.

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H&S Performance, SCT Performance, and Spartan Diesel Technologies

DashDAQ-XL





DasHOAO-J
1 in 0IS914130

1		 —twamm il«il

i ii wpi >441

mti tro##oi cmufs



PHOTOGRAPH #: 3

TAKEN BY: B. Ruminski

DATE TAKEN: 12/2/2013

COMMENTS: Label observed on
the Spartan Phalanx box exterior
showing the unit serial number.

SITE LOCATION: ERG Office, Chantilly Office

PHOTOGRAPH #: 4

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July 2014

TAKEN BY: A. Stanard
DATE TAKEN: 7/31/2013
COMMENTS: H&S XRT Pro
tuner box.

SITE LOCATION: ERG Austin, Texas Office


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H&S Performance, SCT Performance, and Spartan Diesel Technologies

PHOTOGRAPH #: 5

TAKEN BY: A. Stanard

SITE LOCATION: ERG Austin, Texas Office

DATE TAKEN: 7/31/2013

COMMENTS: Label observed on
the H&S XRT Pro box exterior
showing the unit serial number.

XRT Pro

Street

08-13 DURAMAX t 06-12 CUMMINS
03-13 POWERSTROKE

109006

8 87753 00055

SN: 0060039934

flQ Anr .1

PHOTOGRAPH #:

TAKEN BY: A. Stanard

DATE TAKEN: 7/31/2013

SITE LOCATION: ERG Austin. Texas Office

COMMENTS: Top half of the
warranty card found inside the
H&S XRT Pro box containing the
part number and serial number for
the unit.

OFF-ROAD / RACE UPGRADE INSTRUCTIONS

Part Number

Serial Number

Upgrade NUMBER

6009

0060039934

3S089

POWER UP THE DOWNLOAD* * BY PLUOOlMO It INTO THE TRUCK* OOOl PORT
IELECT ANY Vt HICLE APPLICATION
THE OOWNLOAOCR WILL OPEN UP THE MAIN MENU
THEN 00 to um* ornows*«»$siOKS SELECTION
(TXN (MT1R THE UPORAOC NUMBER)

OUCf TMf DOWNLOAD** I* JPOHADCO FT WILL ALWAYS BE UPGRADED
rr CAM M LOCKED * UNLOCKED TO AMY APPUCA8LE YCCmCLES
T>€$ UTORAOC INCLUOCS ALL TME CURRENT UNLOCK COOES

oooot mm jwij ¦ pqrd »«- gm ims »i i

IVIVIR TUl HAS THE Off-SOAP / RACE ttPGRAQt INSTALLED

DOING SO WAV TOlO T^E WARRANTr
NEVf ft CONTACT H4S WITH ANY Of f ROAD / RACt UPGRADE
RtLATl 0 QUESTIONS OR ISSUES - CONTACT TOUR OtALI*
fOB ADDITIONAL H&S DOWNLOADS IT IS RECOMMENDED
	TO CONTACT YOUR DIAlfB	

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PHOTOGRAPH #: 7

TAKEN BY: A. Stanard

SITE LOCATION: ERG Austin, Texas Office

DATE TAKEN: 7/31/2013

COMMENTS: Bottom half of the

IMPORTANT WARRANTY INFORMATION

warranty card found inside the H&S

NEVER TELL H&S THE Off ROM 
-------
H&S Performance, SCT Performance, and Spartan Diesel Technologies

PHOTOGRAPH #: 9

TAKEN BY: A. Stanard
DATE TAKEN: 9/23/2013
COMMENTS: SCT 3015R tuner
package as received from Rudy's
Diesel.

SITE LOCATION: ERG Austin, Texas Office

PHOTOGRAPH #: 10
TAKEN BY: B. Rununski

DATE TAKEN: 2/6/2014

COMMENTS: SCT 3015R Tuner
serial number observed on back of
tuner.

SITE LOCATION: ERG Chantilly, Virginia Office

Enforcement Confidential

39

July 2014


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H&S Performance, SCT Performance, and Spartan Diesel Technologies

PHOTOGRAPH #: 11

TAKEN BY: B. Ruminski

DATE TAKEN: 12/4/2013

SITE LOCATION: Ford Testing Facility

COMMENTS: Flo-Pro

aftertreatment delete kit as received
from USA Performance.

PHOTOGRAPH #: 12

TAKEN BY: B. Ruminski

DATE TAKEN: 12/4/2013

SITE LOCATION: Ford Testing Facility

COMMENTS: Label on the Flo-

Pro aftertreatment delete kit
received from USA Performance
indicating that the aftertreatment
delete pipe received is for the 6.4
Liter Powerstroke, not the 6.7 Liter.

Enforcement Confidential

40

July 2014


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H&S Performance, SCT Performance, and Spartan Diesel Technologies

PHOTOGRAPH #: 13

TAKEN BY: B. Ruminski

DATE TAKEN: 12/4/2013

SITE LOCATION: Ford Testing Facility

COMMENTS: Flo-Pro

aftertreatment delete kit as received
from Wolf Diesel Performance.

PHOTOGRAPH #: 14

TAKEN BY: B. Ruminski

DATE TAKEN: 12/4/2013

SITE LOCATION: Ford Testing Facility

COMMENTS: Flo-Pro
aftertreatment delete kit out of the
box.

Enforcement Confidential

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July 2014


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H&S Performance, SCT Performance, and Spartan Diesel Technologies

PHOTOGRAPH #: 15

TAKEN BY: B. Ruminski

DATE TAKEN: 12/4/2013

SITE LOCATION: Ford Testing Facility

COMMENTS: Label observed on
the Flo-Pro box exterior showing
Wolf Diesel Performance and the
original supplier, Thunder Diesel,
located in Mountain Home,
Arkansas.

T 5783 8165 m

XH NFBA

'WOLF DIESEL PERFORMANCE
18282 HURON RIVER OR
NEW BOSTON Ml 43164

FedEx

Kill

PHOTOGRAPH #: 16

TAKEN BY: B. Ruminski
DATE TAKEN: 12/4/2013

SITE LOCATION: Ford Testing Facility

COMMENTS: Overview of the
test vehicle on the dynamometer.

Enforcement Confidential

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July 2014


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H&S Performance, SCT Performance, and Spartan Diesel Technologies

PHOTOGRAPH #: 17

TAKEN BY: B. Ruminski

SITE LOCATION: Ford Testing Facility

DATE TAKEN: 12/2/2013

COMMENTS: Close up of the
vehicle chassis model (i.e., Ford-



350).

Enforcement Confidential	43	July 2014


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H&S Performance, SCT Performance, and Spartan Diesel Technologies

PHOTOGRAPH #: 19

TAKEN BY: B. Ruminski

DATE TAKEN: 12/2/2013

COMMENTS: Odometer reading
prior to any testing. 33,932.6 miles.
Note: Ford stated that the actually
vehicle had approximately 34,000
miles but the aftertreatment system
had only been used for 4,000 miles
prior to testing. Ford installed a
new aftertreatment system prior to
testing.

SITE LOCATION: Ford Testing Facility

PHOTOGRAPH #: 20

TAKEN BY: B. Ruminski

DATE TAKEN: 12/2/2013

SITE LOCATION: Ford Testing Facility

COMMENTS: OEM after
treatment system. The system
includes three catalysts: OC (left),
SCR (middle), and DPF (right).

Enforcement Confidential

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July 2014


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H&S Performance, SCT Performance, and Spartan Diesel Technologies

PHOTOGRAPH#: 21

TAKEN BY: B. Ruminski

DATE TAKEN: 12/2/2013

COMMENTS: Label 011 the

vehicle chassis.

SITE LOCATION: Ford Testing Facility

PHOTOGRAPH #: 22

TAKEN BY: B. Ruminski

SITE LOCATION: Ford Testing Facility

DATE TAKEN: 12/2/2013

COMMENTS: VIN of test vehicle
visible through the bottom of the
front windshield.



m 01/10 mm a

FRONT 6AWR

?Tsnur imb	mt

WITH 1 WW,

U24S/75R17t iifes mnm
17x6 SJ	Illtt IfiiH M

1 450 kPo/ 65 nm\u wrs^

Js..

TrtKk

Enforcement Confidential

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July 2014


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H&S Performance, SCT Performance, and Spartan Diesel Technologies

PHOTOGRAPH #: 23

TAKEN BY: B. Ruminski
DATE TAKEN: 12/3/2013
COMMENTS: Screen shot of the
Spartan 6.7 Liter Phalanx turning
on.

SITE LOCATION: Ford Testing Facility

PHOTOGRAPH #: 24

TAKEN BY: B. Ruminski

SITE LOCATION: Ford Testing Facility

DATE TAKEN: 12/4/2013



COMMENTS: Screen shot of
Spartan 6.7 Liter Phalanx showing
¦'off-road" disclaimer that appears
immediately after turning on the
device.

m.-

OFF ROAD USE ONLY

Th* Product Manutoctuw, vMr 1r

to theenvlronmwTt

.J—

L Accepl



¦ 04.2013 I51

Enforcement Confidential

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July 2014


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H&S Performance, SCT Performance, and Spartan Diesel Technologies

PHOTOGRAPH #: 25

TAKEN BY: B. Ruminski

SITE LOCATION: Ford Testing Facility

DATE TAKEN: 12/2/2013

COMMENTS: Main menu options
on the Spartan 6.7 Liter Phalanx.

V 0 ^

U*4 T!m Status Load stock

A Cb

f® — - J



PHOTOGRAPH #: 26

TAKEN BY: B. Ruminski

SITE LOCATION: Ford Testing Facility

DATE TAKEN: 12/2/2013



COMMENTS: Screen shot of the
Spartan 6.7 Liter Phalanx showing
the calibration selected for emission



equipment-present testing.

I- Select Tune to Load







•un-urr-uw





Enforcement Confidential

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July 2014


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H&S Performance, SCT Performance, and Spartan Diesel Technologies

PHOTOGRAPH #: 27

TAKEN BY: B. Ruminski

DATE TAKEN: 12/4/2013

SITE LOCATION: Ford Testing Facility

COMMENTS: Screen shot of the
Spartan 6.7 Liter Phalanx showing
the calibration selected for emission
equipment-removed testing.

ERG installed this calibration on 4
December 2013, the day prior to
testing. It was installed
immediately before Ford installed
the Flo-Pro aftertreatment delete kit
on 4 December 2013.

Select Tune to Load

200HP OPF OFF WafHamimr Rati
DATE: Ttiu Jul 0517:13:04 2012
HJNE LEVEL 1

lunt lliu:

I

PHOTOGRAPH #: 28

TAKEN BY: B. Ruminski

DATE TAKEN: 12/2/2013
COMMENTS: Screen shot of
available vehicle options (partial
list) that the H&S XRT Pro can be
used for. The tuner contains
preloaded tunes for each of these
vehicles.

SITE LOCATION: Ford Testing Facility

< Go Back VEHICLES

	

~	¦03-"07 Ford W)L PowarStroke
» 08-10 Ford PowwStroke

~	Ford 6.7L Power Stroke
>'13 Ford 6.7L PowerStroke

. fi>2^62r5013 1

Enforcement Confidential

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July 2014


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H&S Performance, SCT Performance, and Spartan Diesel Technologies

PHOTOGRAPH #: 29

TAKEN BY: B. Ruminski

SITE LOCATION: Ford Testing Facility

DATE TAKEN: 12/2/2013



COMMENTS: Download menu
shown on the H&S XRT Pro. This
menu option is used to install a new
H&S calibration or return the ECM
to the stock calibration.

4 *«JSck vmaamm

4 Do-nload WkST"** }

4 ^



PHOTOGRAPH #: 30

TAKEN BY: B. Rummski

SITE LOCATION: Ford Testing Facility

DATE TAKEN: 12/2/2013



COMMENTS: Screen shot of the
H&S XRT Pro showing the
calibration selected for emission
equipment-present testing
(Performance).

¦ » ENTER po«« I*"1



rpgRFOR^NCE *

L"*'







12.02.2013^

Enforcement Confidential

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July 2014


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H&S Performance, SCT Performance, and Spartan Diesel Technologies

PHOTOGRAPH#: 31

TAKEN BY: B. Ruminski

SITE LOCATION: Ford Testing Facility

DATE TAKEN: 12/2/2013



COMMENTS: Screen shot of the
H&S XRT Pro showing the
installation option to adjust the
vehicle speed limiter. ERG always
selected "no" for this option.





~

KES

Do You **ILUStvyiJ
the Speed LMter? Y/N



m
| ~



12 02-2013 14 23

PHOTOGRAPH §: 32

TAKEN BY: B. Ruminski

SITE LOCATION: Ford Testing Facility

DATE TAKEN: 12/2/2013

COMMENTS: Screen shot of the
H&S XRT Pro showing the
installation option to tune the
transmission. ERG always selected
"no" for this option.

TRANSMISSION TUNING



1 *

Do you want to tune the

transmission?

1 ~

12 02 2013 14 23

Enforcement Confidential

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July 2014


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H&S Performance, SCT Performance, and Spartan Diesel Technologies

PHOTOGRAPH #: 33

TAKEN BY: B. Ruminski

SITE LOCATION: Ford Testing Facility

DATE TAKEN: 12/5/2013

COMMENTS: Screen shot of the
H&S XRT Pro showing the prompt
for indicating whether the emission
equipment has been removed from
the vehicle. This option only
appeared after the "upgrade code"
for "high sulfur" fuel use was
entered as shown in Photograph
[35], ERG selected "removed" for
emissions equipment-removed
testing.

EMISSIONS selection

Lo«?:5f
-------
H&S Performance, SCT Performance, and Spartan Diesel Technologies

PHOTOGRAPH #: 35

TAKEN BY: B. Ruminski

DATE TAKEN: 12/3/2013

SITE LOCATION: Ford Testing Facility

COMMENTS: Screen shot of the
H&S XRT Pro showing the
"upgrade code" for "high sulfur"
fuel use entered into the
emissions selection menu. After
entering this code, the user is
given the option to enter whether
or not the emissions control
systems (i.e., DPF and EGR) are
present during the installation
process (Photographs [34] and
[35]).

» ekter ewssmhs



> RESET

« left

scr°lL

4 tae«T

gCR0U-

12 03 2013

PHOTOGRAPH #: 36

TAKEN BY: B. Ruminski

SITE LOCATION: Ford Testing Facility



DATE TAKEN: 12/3/2013





COMMENTS: Screen shot of the
H&S XRT Pro immediately after
the "high sulfur" "upgrade code"
was entered shown in Photograph

35.

gftjSgglHS SElECnOH —

— 1



^ 1



IK*** u, a*f*

V

i 2013 16

Enforcement Confidential

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H&S Performance, SCT Performance, and Spartan Diesel Technologies

PHOTOGRAPH #: 37
TAKEN BY: B. Ruminski
DATE TAKEN: 12/5/2013
COMMENTS: First EGR valve
electrical connection
disconnected prior to conducting
emission equipment-removed
testing for the H&S XRT Pro.

PHOTOGRAPH #: 38

TAKEN BY: B. Ruminski
DATE TAKEN: 12/5/2013
COMMENTS: Second EGR valve
electrical connection
disconnected prior to conducting
emission equipment-removed
testing for the H&S XRT Pro.
Note: Photograph was taken
prior to disconnection because
the Ford Technician had to
obtain a long screw driver to
remove this connection due to
the lack of space. This sensor is
directly behind the cooling fan
(shown in left side of photo) in
the front of the engine
compartment.

SITE LOCATION : Ford Testing Facility

SITE LOCATION: Ford Testing Facility

Enforcement Confidential

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H&S Performance, SCT Performance, and Spartan Diesel Technologies

PHOTOGRAPH #: 39

TAKEN BY: B. Ruminski
DATE TAKEN: 12/2/2013
COMMENTS: Screen shot of the
SCT 3015R tuner showing the
"strategy tune" menu option
selected to install new calibrations.

SITE LOCATION: Ford Testing Facility

PHOTOGRAPH #: 40

TAKEN BY: B. Ruminski

DATE TAKEN: 12/2/2013

COMMENTS: Screen shot of the
SCT 3015R tuner during the initial
installation process for the
emissions equipment-present
calibration. The SCT recognized
the 6.7 Liter Powerstroke engine
but, as shown in Photograph [41],
required an update in order to
install calibrations.

SITE LOCATION: Ford Testing Facility

Enforcement Confidential

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H&S Performance, SCT Performance, and Spartan Diesel Technologies



PHOTOGRAPH#: 41

TAKEN BY: B. Ruminski

SITE LOCATION: Ford Testing Facility

DATE TAKEN: 12/2/2013



COMMENTS: Screen shot of the
SCT 3015R tuner during the initial
installation process for the
emissions equipment-present
calibration. The SCT 3015R tuner
was unable to install any
calibrations prior to the software
update, as indicated in this
Photograph.

t . 12 02 2013

PHOTOGRAPH #: 42

TAKEN BY: B. Ruminski

SITE LOCATION: Ford Testing Facility

DATE TAKEN: 12/2/2013

COMMENTS: Screen shot of the
SCT 3015R tuner during the
installation process prompting the
user to indicate if the aftertreatment
system has been removed. ERG
selected "yes" for emission
equipment-removed testing and
"no" for emissions equipment-
present testing.

Enforcement Confidential

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July 2014


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H&S Performance, SCT Performance, and Spartan Diesel Technologies

PHOTOGRAPH #: 43

TAKEN BY: B. Ruminski
DATE TAKEN: 12/2/2013
COMMENTS: Screen shot of the
SCT 3015R tuner during the
installation process prompting the
user to indicate recalibration of the
speedometer for non-stock tires is
desired. ERG always selected "no"
for this option.

SITE LOCATION: Ford Testing Facility

PHOTOGRAPH #: 44

TAKEN BY: B. Ruminski

SITE LOCATION: Ford Testing Facility

DATE TAKEN: 12/2/2013

COMMENTS: Screen shot of the
SCT 3015R tuner during the
installation process prompting the
user to indicate if any non-stock
gears have been installed. ERG
always selected "no" for this
option.

Enforcement Confidential

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July 2014


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H&S Performance, SCT Performance, and Spartan Diesel Technologies

PHOTOGRAPH #: 45

TAKEN BY: B. Ruminski

SITE LOCATION: Ford Testing Facility

DATE TAKEN: 12/2/2013

COMMENTS: Screen shot of the
SCT 3015R tuner during the
installation process prompting the
user to indicate if changing the tire
pressure monitoring system is
desired. ERG always selected "no"
for this option.

12.02.2013 16:58

PHOTOGRAPH #: 46

TAKEN BY: B. Ruminski

SITE LOCATION: Ford Testing Facility

DATE TAKEN: 12/2/2013

COMMENTS: Screen shot of the
SCT 3015R tuner during the
installation process prompting the
user to select a calibration. ERG
selected "performance" both
emission equipment-removed and -
present testing.

¦lee'

-GTltll

12.02.2013 16:58

Enforcement Confidential

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H&S Performance, SCT Performance, and Spartan Diesel Technologies

PHOTOGRAPH #: 47
TAKEN BY: B. Ruminski
DATE TAKEN: 12/2/2013
COMMENTS: Screen shot of the
SCT 3015R tuner during the
installation process prompting the
user to adjust the speed limiter.
ERG always selected "no" for
emission equipment-present testing
and "yes" f°r emission equipment-
removed testing.

SITE LOCATION: Ford Testing Facility

PHOTOGRAPH #: 48

TAKEN BY: B. Ruminski
DATE TAKEN: 12/2/2013
COMMENTS: Screen shot of the
SCT 3015R tuner during the
installation process prompting the
user to if tuning the transmission is
desired. ERG always selected
"stock" for this option.

SITE LOCATION: Ford Testing Facility

WWW.SQTFLABH.COM

Enforcement Confidential

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H&S Performance, SCT Performance, and Spartan Diesel Technologies

PHOTOGRAPH #: 49

TAKEN BY: B. Ruminski

DATE TAKEN: 12/4/2013

SITE LOCATION: Ford Testing Facility

COMMENTS: Flo-Pro
aftertreatment delete pipe installed
onto the test vehicle.

PHOTOGRAPH #: 50

Enforcement Confidential	59	July 2014

TAKEN BY: B. Ruminski
DATE TAKEN: 12/4/2013

SITE LOCATION: Ford Testing Facility

COMMENTS: Black smoke
generated by test vehicle after
installing the Flo-Pro aftertreatment
delete kit and an emission
equipment-removed calibration
using the Spartan 6.7 Liter Phalanx
tuner.


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H&S Performance, SCT Performance, and Spartan Diesel Technologies

PHOTOGRAPH#: 51

TAKEN BY: B. Ruminski

SITE LOCATION: Ford Testing Facility

DATE TAKEN: 12/4/2013

COMMENTS: Black smoke
generated by test vehicle after
installing the Flo-Pro aftertreatment
delete kit and an emission
equipment-removed calibration
using the Spartan 6.7 Liter Phalanx
tuner.

Enforcement Confidential

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H&S Performance, SCT Performance, and Spartan Diesel Technologies

Appendix B

Chronological Order of Produced Performed by Ford, EPA, and ERG

Enforcement Confidential

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H&S Performance, SCT Performance, and Spartan Diesel Technologies

Table 18. Chronological Order of Procedures Performed by Ford, EPA, and ERG The

Week of 2 December 2013

Day

Tuner

Step





Obtained OBD data {e.g., Cal ID, CVN) with the ECM in the stock configuration





Installed emissions equipment-present calibration





Obtained OBD data (e.g., Cal ID, CVN) with equipment-present calibration installed



Spartan

Tested vehicle with the FTP4-74 test (with data logger plugged in)



Obtained OBD data {e.g., Cal ID, CVN) with equipment-present calibration installed





Returned ECM to stock calibration





Obtained OBD data {e.g., Cal ID, CVN) with the ECM in the stock configuration





Uninstalled designated ECM from test vehicle





Installed designated ECM into test vehicle and reset anti-theft system

2 December
2014



Obtained OBD data {e.g., Cal ID, CVN) with the ECM in the stock configuration



Installed emissions equipment-present calibration





Obtained OBD data (e.g., Cal ID, CVN) with equipment-present calibration installed



XRT

Tested vehicle with the FTP4-74 test (with data logger plugged in)





Obtained OBD data (e.g., Cal ID, CVN) with equipment-present calibration installed





Returned ECM to stock calibration





Obtained OBD data (e.g., Cal ID, CVN) from the ECM in the stock configuration





Uninstalled designated ECM from test vehicle





Installed designated ECM into test vehicle and reset anti-theft system



SCT

Obtained OBD data (e.g., Cal ID, CVN) with the ECM in the stock configuration



Installed emissions equipment-present calibration





Obtained OBD data (e.g., Cal ID, CVN) with equipment-present calibration installed

3 December



Tested vehicle with the FTP4-74 test (with data logger plugged in)

2014



Obtained OBD data (e.g., Cal ID, CVN) with equipment-present calibration installed





Tested vehicle with the US06 test (with data logger plugged in)



SCT

Obtained OBD data (e.g., Cal ID, CVN) with equipment-present calibration installed





Returned ECM to stock calibration





Obtained OBD data (e.g., Cal ID, CVN) from the ECM in the stock configuration





Uninstalled designated ECM from test vehicle





Installed designated ECM into test vehicle and reset anti-theft system



Spartan

Obtained OBD data (e.g., Cal ID, CVN) with the ECM in the stock configuration



Installed emissions equipment-present calibration





Obtained OBD data (e.g., Cal ID, CVN) with equipment-present calibration installed

4 December



Tested vehicle with the US06 test (with data logger plugged in)

2014



Obtained OBD data (e.g., Cal ID, CVN) with equipment-present calibration installed





Returned ECM to stock calibration



Spartan

Obtained OBD data (e.g., Cal ID, CVN) from die ECM in die stock configuration



Installed emissions equipment-removed calibration





Obtained OBD data (e.g., Cal ID, CVN) with equipment-removed calibration installed





Removed stock aftertreatment (DOC, DPF) systems and installed aftertreatment delete kit





Performed transmission relearn

Enforcement Confidential

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H&S Performance, SCT Performance, and Spartan Diesel Technologies

Table 18. Chronological Order of Procedures Performed by Ford, EPA, and ERG The

Week of 2 December 2013

Day

Tuner

Step

5 December



Tested vehicle with the FTP4-74 test (with data logger plugged in)

2014

Spartan

Obtained OBD data (e.g., Cal ID, CVN) with equipment-removed calibration installed



Returned ECM to stock calibration





Obtained OBD data (e.g., Cal ID, CVN) from the ECM in the stock configuration





Uninstalled designated ECM from test vehicle





Installed designated ECM into test vehicle and reset anti-theft system





Obtained OBD data (e.g., Cal ID, CVN) with the ECM in die stock configuration





Installed emissions equipment-removed calibration





Obtained OBD data (e.g., Cal ID, CVN) with equipment-removed calibration installed



SCT

Tested vehicle with the FTP4-74 test (widi data logger plugged in)





Obtained OBD data (e.g., Cal ID, CVN) with equipment-removed calibration installed





Returned ECM to stock calibration





Obtained OBD data (e.g., Cal ID, CVN) from die ECM in die stock configuration





Uninstalled designated ECM from test vehicle





Installed designated ECM into test vehicle and reset anti-theft system



XRT

Obtained OBD data (e.g., Cal ID. CVN) with die ECM in die stock configuration



Installed emissions equipment-removed calibration





Obtained OBD data (e.g., Cal ID, CVN) with equipment-removed calibration installed

6 December



Tested vehicle with the FTP4-74 test (with data logger plugged in)

2014



Obtained OBD data (e.g., Cal ID, CVN) with equipment-removed calibration installed





Returned ECM to stock calibration



XRT

Obtained OBD data (e.g., Cal ID, CVN) from die ECM in die stock configuration





Installed emissions equipment-present calibration (calibration analyzed by Bosch)





Obtained OBD data (e.g., Cal ID, CVN) with equipment-present calibration installed





Uninstalled designated ECM from test vehicle





Installed designated ECM into test vehicle and reset anti-theft system



Spartan

Obtained OBD data (e.g., Cal ID, CVN) with the ECM in the stock configuration



Installed emissions equipment-present calibration (calibration analyzed by Bosch)





Obtained OBD data (e.g., Cal ID, CVN) with equipment-present calibration installed

Note: The first test run on each day was a cold start test because the engine did not run since the previous
test the day before. Any 2nd or 3rd tests performed on a particular day were warm or hot starts. However,
because each test includes multiple test cycles and this report only compares the test results of the last test
cycle in each test, it is irrelevant whether the test was a cold, warm, or hot start because the engine was
always hot for the last test cycle. See Section IV.B.5 for more detail.

Enforcement Confidential

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July 2014


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H&S Performance, SCT Performance, and Spartan Diesel Technologies

Appendix C
Spartan Tuner Purchase Memorandum

Enforcement Confidential

64

July 2014


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Enforcement Sensitive - For Internal Use Only

Spartan Phalanx Tuner Purchase

*ERG

MEMORANDUM

TO: Anne Wick, US EPA
FROM: Alan Stanard, ERG

SUBJECT: Summary of purchase of Spartan Phalanx Tuner
DATE: September 30, 2013

Research, Communication and Purchase of Spartan Tuner

Under Contract #EP-W-12-007 Technical Direction 45, EPA directed ERG to research and
purchase a Spartan Phalanx Diesel Tuner that was advertised as having exhaust gas recirculation
EGR /diesel particulate filter DPF delete features. ERG identified three companies that
indicated they sold the Phalanx Tuner on their websites: Rudy's Diesel Performance
www.rudvsdiesel.comI Xtreme Diesel Power http://www.xtremediesel.com). and Performance
Truck Products performancetruckproducts.com). EPA indicated that ERG should choose a
Phalanx Tuner that would work with a MY 2011- MY 2014 Ford F-250 or F-350 with a 6.7 L
engine. The websites of all three retailers offered the Phalanx for the 6.7 L Ford at prices within
two percent of each other.

Communication with Supplier

EPA directed ERG that Rudy's Diesel was the preferred vendor for this unit. ERG called Rudy's
and asked the sales representative a few questions about the tuner and the purchase process. The
representative indicated that the device could allow an EGR/DPF delete. A VEST would not be
needed at the time of purchase, but the tuner would permanently associate with the truck it was
first installed on. In order to install the unit on another truck, the user would need to purchase
another license from Spartan Tuners.

Purchase of Tuner

Figure 1 shows the page for the Phalanx Tuner on the Rudy's Website. Note that there are five
pull-down menus that include optional extras to be purchased with the tuner. The last two
options for EGR Cooler Delete/EGT Probe Mount and Mounting Solution cannot be declined by
the user as a result of the way the menus are designed.

Figure 2 shows the screen capture displayed after selecting to buy the Spartan Tuner and
includes the two forced optional extras (EGR Cooler Delete and EGT Probe Mount). ERG did
not want to incur the extra expense of these devices give that they may not be beneficial to EPA,
and so chose to order the tuner via telephone. Via the telephone, the sales representative did not
require the purchase of the optional extras. ERG ordered the tuner on September 13, 2013.

1 of 4


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Enforcement Sensitive - For Internal Use Only

Spartan Phalanx Tuner Purchase

The total purchase price without the optional extras was $1,499.99. The sales receipt was
received promptly from Rudy's Performance and is presented in Figure 3. Note that there was
some confusion on the part of the sales representative on whether the tuner was for the 6.7 L
Ford or the 6.4 L Ford. ERG clearly indicated that the desired tuner was for the 6.7 L vehicle, but
the sales receipt still indicated that the tuner would be for the 6.4 L vehicle. Upon receipt, ERG
confirmed the tuner that was received was for the 6.7 L vehicle.

Figure 1. Screen Capture of the Spartan Phalanx Offered for Sale on the Rudy's

Website

Figure 2. Screen Capture from the Rudy's Website after Adding the Spartan

Phalanx to Cart

2 of 4


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Enforcement Sensitive - For Internal Use Only

Spartan Phalanx Tuner Purchase

DIESEL PERFORMANCE OFFROAD

1404 CHRISTIAN AVE. DURHAM MC 27705

919.383.9300

Sold To

I Michael Saisch











Check #

Payment Method

Ship Date
Due Date
Other

Date 9/13/3013
Sale# 8D12

Spartan 6.4 Tuner

t.499.99

1,499.99

Subtotal

Sales Tax {7,5%)

Total

$1,499.99
50.D0
$1,499.99

Figure 3. Sales Receipt of Spartan Phalanx from Rudy's Performance after Phone

Order

3 of 4


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Enforcement Sensitive - For Internal Use Only

Spartan Phalanx Tuner Purchase

Receipt of Tuner

ERG received the tuner on September 19, 2013. The hardware for the unit was a Drew
Technologies DashDAQ, and the unit arrived in the original DashDAQ box. The contents of the
box are shown in Figure 4. The serial number of the unit was 018914130513Q. This appears to
be the DashDAQ serial number, not a number given by Spartan. It is unclear what the
relationship between Spartan and Drew Technologies is. It is likely that Spartan purchases
DashDAQ units either 'blank' or with minimal programming from Drew Technologies and then
installs the software and/or programming that performs the diesel tuning function.

The unit that was received was the model that ERG intended to order for the 6.7 L Ford, so the
sales receipt contained a typographical error that was probably related to the confusion of the
sales representative at the time of the order. The memory card installed in the tuner contained a
number of tuning files as well as a brief manual on how to unlock the tuner for a given truck and
how to install the tuning files. The documentation indicated that the unit is not fully functional
when received by the purchaser. According to the manual, the VTN and owner information must
be sent to Spartan for them to allow the user to register/unlock the tuner. This process is not
exactly consistent with the discussions that ERG had with the Rudy's representative over the
phone. The representative had originally said that the tuner would be mated to the first truck that
it was installed in, and made the process of unlocking the tuner and mating to the VIN of the
desired taick sound automatic. The manual also mentions that if the purchaser wants to install
the tuner on a second truck, another license must be purchased from Spartan before this can be
done.

Figure 4. Contents of the Spartan Tuner Box upon Delivery

4 of 4


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H&S Performance, SCT Performance, and Spartan Diesel Technologies

Appendix D
SCT Tuner Purchase Memorandum

Enforcement Confidential

65

July 2014


-------
Enforcement Sensitive - For Internal Use Only

SCT30250R Tuner Purchase

*tERG

MEMORANDUM

TO: Anne Wick, US EPA
FROM: Alan Stanard, ERG

SUBJECT: Summary of purchase of SCT 3015R Tuner
DATE: September 30, 2013

Research, Communication and Purchase of SCT Tuner

Under Contract #EP-W-12-007 Technical Direction 45, EPA directed ERG to research and
purchase an SCT 3025 Tuner that was advertised as having exhaust gas recirculation (EGR)/
diesel particulate filter (DPF) delete features for diesel engines. EPA requested that the
purchased tuner be designed for late-model diesel-powered Ford F-250 or F-350 trucks. SCT
does not manufacture an SCT 3025 tuner that is compatible with the MY 2011 and newer 6.7 L
Ford engine, so ERG pursued the tuner programmed for the MY 2008- MY 2010 6.4 L Ford.
However, ERG later determined that the received tuner is in fact compatible with MY 2011 and
newer 6.7 Liter Ford engine.

Communication with Supplier

ERG identified two websites of companies that indicated that they sold the SCT Tuners to the
U.S. market: Rudy's Diesel (www.rudvsdiesel.com) and Performance Diesel
(www.perfdiesel.com). ERG called Performance Diesel to inquire about the 3025 Tuner, but the
sales representative indicated that they no longer sold the tuner due to the fact that it allowed for
DPF/EGR delete. The sales person did not elaborate further after indicating that that DPF/EGR
delete feature was the reason they no longer sold the item.

Next, ERG emailed Rudy's Diesel and asked whether the 3025OR X3 that was listed on their
website offered the ability to delete DPF, as well as whether a truck VEST would be needed for
purchase. The representative responded that the unit did allow DPF delete and that a specific
truck VIN was not needed. Appendix A provides documentation of this email communication.
ERG did not explicitly ask if the tuner is capable of deleting the EGR via email. ERG later called
Rudy's and asked if the tuner is capable of delete the EGR over the phone. A Rudy's Diesel
representative confirmed that the tuner is also able to delete the EGR.

Purchase of Tuner

ERG ordered the 3025OR X3 Tuner from the website on September 16, 2013. Appendix B
provides screen captures during the ordering process on the Rudy's website. A series of screen
captures from the entire ordering process along with the received sales receipt are included in
Appendix A. The total cost of the tuner was $899.

lof 11


-------
Enforcement Sensitive - For Internal Use Only

SCT30250R Tuner Purchase

ERG received the SCT unit on September 23, 2013. Figure 1 and Figure 2 show the SCT tuner in
its original packaging on the front side and back side, respectively. It is important to note that the
unit ERG received was the SCT 3015R tuner as opposed to the 3025OR X3 that ERG ordered.
The serial number of the unit was XP06281339A62.

Figure 3 shows the contents of the packaging. In addition to the tuner and wiring, the container
also included a quick start guide and a data CD. The data CD contained a program to allow for
firmware updates to the tuner. It also included a variety of instruction documents for various
hardware installations on the different types of vehicles that the tuner's hardware is also
compatible with (i.e., the tuner hardware is available for a variety of vehicles and programmed
differently by SCT for each vehicle). The documentation did not contain any reference to
unlocking the tuner or any "race mode" or "off-road only" modes of operation. The quick start
guide indicates that the tuner does have the capability for DPF delete, but it doesn't mention
EGR. The documentation that comes with the unit appears to be general and intended to apply to
all gasoline and diesel vehicles for which SCT sells tuners. It does not appear to be specific to
the 6.4 L Ford diesel engine. There appear to be no VIN-specific issues indicated in the
documentation, and it appears as though the unit will work with any YIN.

Figure 1. SCT 3015R as Received by ERG (Front)

2 of 11


-------
Enforcement Sensitive - For Internal Use Only

SCT30250R Tuner Purchase

Figure 3. Contents of SCT 3015R Package as Received by ERG

3 of 11


-------
Enforcement Sensitive - For Internal Use Only	SCT30250R Tuner Purchase

Appendix A
Communication with Rudy's Deisel

4 of 11


-------
Enforcement Sensitive - For Internal Use Only

SCT 30250R Tuner Purchase

Gm il

Alan S 

SCT 3025 OR on Website

2 messages

To: aaron@rudysdiesel.com

Hi, I had a question about the SCR 3025OR on your website. Does the OR
version of this offer the DPF delete option? If so, would the VIN of
the truck it would be installed in be required for purchase? (I won't
have access to the VIN for a week or so).

Thu. Sep 12. 2013 at 1:23 PM

Aaron Rudolf 
Reply-To: Aaron Rudolf anceparts@yahoo.com>
To: f

Thu, Sep 12, 2013 at 1:46 PM

Ye= ±c offers the PPF Delete function. No we do nor. need the VIN of the trues. Thanks -Aaron

Aaron @ Rudy's Diesel Performance
Shop: (919) 383 9300
Toll-Free: (SGG) 757-6537
Faxi (919) 351-3902

Rudy's Diesel Performance
1404 Christian Ave.

Durham, HC 27705

From:

To: aaron@rudysdiesel.com

Sent: Thursday, September 12. 2013 2:28 PM

Subject: SCT 3025 OR on Website

[Quoted irxt kidifew]

5 of 11


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Enforcement Sensitive - For Internal Use Only	SCT30250R Tuner Purchase

Appendix B

Screen Captures of Online Purchase from Rudvsperformance.com

6 of 11


-------
Enforcement Sensitive - For Internal Use Only

Appendix A-SCT30250R Tuner Purchase

SCT 30250R 6.4L Off-Road X3 - Opera

F*e £
-------
Enforcement Sensitive - For Internal Use Only

Appendix- SCT30250R Tuner Purchase

r http://www.rudysdiesel.com/ba5ket.aspx - Opera

Vlrw pookmarts TooK Mdp

i4» ~ • a #1	OWwu nj
-------
Enforcement Sensitive - For Internal Use Only

Appendix- SCT30250R Tuner Purchase

https://store.avhost.nct/rudyspcrformanceparts/ordcr_process.aspx - Opera

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-------
Enforcement Sensitive - For Internal Use Only

Appendix- SCT30250R Tuner Purchase

https://store.avhost.net/rudysperformanceparts/order_process.aspx - Opera

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-------
Enforcement Sensitive - For Internal Use Only

Appendix- SCT 30250R Tuner Purchase

Order Confirmation(#1379338057)

1 message

www.RudvsDtesgl.cofn «order@gitf/s<>iesei com*	Mori Sep 16,2013 at 3:27 Pfv

Thank you AJan for shopping at Rud/Diesei com?

Please see your order number and details below Once your order ts snipped, you wit receive an email confirmation wth
the tracKng number

if we may be ct further assistance please can us at 1366-757-6637 or email us at suppon@RuflysOieset com

Sincerely.

Rutf/s Diesel

Your order number is 1379338057
Order Date 09/16/2013

Shipping Address:

3508 Far West Btv<3 Ste 210
Austn. TX 78731

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Snipping & Handing

MOO





Toul

s»ot

SCT-3025OR : SCT 3025OR 6.4L Off-Road X3

Figure B-7, Page 2 of Receipt from Rudy's for Purchase of SCT Tuner

11 of 11


-------
H&S Performance, SCT Performance, and Spartan Diesel Technologies

Appendix E

Communication with Spartan for Tuner Activation

Enforcement Confidential

66

July 2014


-------
Page 1 of 1

Brent Ruminski - Fwd: 6.7L DashDAQ 18914 Level 1 License Mike Sabisch

From:

Subject: Fwd: 6.7L DashDAQ 18914 Level 1 License

>>>  11/27/2013 10:09 AM >>>

Before loading a tune on your truck, be sure to have a battery charger
connected to one of your batteries. Just set it on trickle charge.

Also please make sure you have followed the instructions on page 3 of the
Strategy Flash Manual 67:

DPF DELETE TUNE FILES MUST BE INSTALLED PRIOR TO INSTALLING DPF DELETE
EXHAUST COMPONENTS. FAILURE TO INSTALL NEEDED DPF DELETE TUNING BEFORE
REMOVING THESE COMPONENTS CAN LEAVE YOUR VEHICLE STRANDED

Index File:

Download the attached file (indexfile.idx) to your computer, then copy to
the tuning files folder on the sd card. Do not change the name of the
file. If you do you will NOT be able to load a tune on your truck.

Stock File:

Download the attached file to your computer (ESA_PB_STK_ZIP example name),
uncompress and copy to the stock files folder on the sd card. The actual
stock file will be a .stk file when copied to the stock files folder on
the sd card. Size of the uncompressed file will be 4.25 MB (4,461,388
bytes)

The American service-member wrote a check made payable to the United
States of America for the amount of UP TO AND INCLUDING MY LIFE. Thank a
Soldier, Airmen, Sailor, Marine or Coast Guardsmen for their sacrifices on
your behalf.

Mick @ Spartan

Please reply back to this email if you have additional questions. This way
I will have your original email available to view.

> > >

11/27/2013 12:41 PM >>>

about:blank

2/7/2014


-------


Registration

HendensonviUe, NC <828> 606-3263
www.SpartanDieselTech.com

RACE USE DISCLAIMER AND LIABILITY WAIVER

This product is designed for competition racing use only. Use on State and
Federal Highways is a violation of the EPA Clean Air Act. The Clean Air Act can be
found at http://www.epa.gov/air/caa/. This document contains in detail what are
considered to be violations of the CAA and corresponding penalties for failure to obey
and should be read in full before signing this disclaimer and/or installing this off-road,
race use only product. Ensuring that all emissions, noise/sound, and speed/use related
laws are followed is the responsibility of the Buyer(s). Installation and use of this product
indicates that this disclaimer has been read, acknowledged, and understood fully by both
the Buyer(s) and Installer(s).

The Buyer(s) assume all associated risk of the purchase and/or use of this product.
"Spartan Diesel Technologies" assumes no responsibility of any personal injury, death, or
property damage associated with the use of this competition racing use-only product. The
Buyer(s) assume all responsibility of ensuring that all applicable speed and safety
restrictions are followed during the use of this product. This includes staying within
speed limits of tire rating, engine speed restrictions, and legal competition racing use of the
vehicle and associated product. The above is regardless of capabilities enabled by use of
any "Spartan Diesel Technologies" product. All iocal, state, and federal laws and
ordinances must be adhered during the use of the product. Determining the nature of
these laws and ordinances is the exclusive responsibility of the Buyer(s).

Manufacturer Limited Vehicle Warranties should be referenced before installation and
use of this product. "Spartan Diesel Technologies" shall not be held responsible for
voidance of any Manufacturer Warranties. The vehicle manufacturer is to be referenced
directly by the Buyer(s) to determine what is or is not permissible under the
Manufacturer's Limited Warranty. The Buyer(s) assume all possible damages and
associated costs in the situation of Manufacturer Warranty voidance.

Installation, service, and use are solely the responsibility of the Buyer(s) and Installer(s)
of the given product. "Spartan Diesel Technologies" assumes no liability for personal
injury or property damage due to misuse, mis-installation, or improper service of the
product. The Buyer(s) and Installer(s) assume all responsibility of ensuring that all proper
instructions for installation and use are followed. This product is capable of the
following:

I. Making the vehicle incompliant with Local, State and Federal emissions
regulations.


-------
II Making the vehicle capable of generating vehicle speeds unsafe for driving
conditions.

III. Making the vehicle capable of generating conditions exceeding safe vehicle
speeds based on mechanical condition of the vehicle, such as tire speed ratings.

IV Making the vehicle capable of exceeding mechanical limits of engine speed,
power output, and mechanical stress upon the powertrain. driveline. chassis, and
body of the vehicle.

V. Producing power and torque output requiring superior driving skills and
techniques in order to be safely applied.

It is the sole responsibility of tha Buyer(s) and U3cr(s) of this product to be aware of
these additional capabilities and adjust the installation and use of the product accordingly
All other warranties, express or implied, are not applicable for the purchase and use of
this product. Failure of the product due to misuse or mis-installation is specifically
excluded from the Limited Warranty of this product. "Spartan Diesel Technologies" will
not be held liable for indirect, incidental and/or consequential damages caused by the
purchase, installation, and/or use of the product.

Signature of this disclaimer and waiver is necessary in order to receive
tunes/calibrations from Spartan Diesel Technologies to enable use of our DPF Delete
6.4 Liter, or 6.7 Liter Ford Products.

Signature of this disclaimer and waiver implies that the Buyer(s) and all potential
User(s) have read, understood, and accepted the contents and responsibilities of
both the said disclaimer and Federal EPA Clean Air Act linked and referenced
herein.

PRINT NAME OF BUYER	ADDRESS OF BUYER

CONTACT TELEPHONE

CITY, START, ZIP CODE

EMAIL ADDRESS

TUNER SERIAL NUMBER

018 91413 0 513Q

SIGNATURE OF BUYER


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sabischm

Page 1 of2

Home

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Questions

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Forums
Contact Us

Authorized Spartan
Dealers

Hi, sabischm

Logout

Hits:

Online Status:
Member Since:
Last Online:
Last Updated:
Connections:

0

vONLINE
3 months ago
Now

3 months ago

Contact Info



First Name:



Last Name:



Address:





Crty. State, ZIP:



Phonel:





Phone2:



-

Tuner Serial:

18914

Tuner Level:

1V2

Tuner Purchased From:

Rudy's

Year Model:

2011

VIN:



1FT8W3CT6BEA0G289

Engine Type:

6.7 L

Engine Strategy:

BC3A-14C204-FFA

Trans Strategy:

BC3A-14C337-CH

6.4 L Tunes:

-

Spartan Disclaimer 10-
03-12?:

Yes

6,7 L Tunes:

25HP w/DPF c/c, 40HP, 200HP, 90HP w/DPF c/c, 80HP, 50HP w/DPF, 120HP,
125HP w/DPF, 165HP

Truck Model:

F-350 Pickup

Two or Four Wheel
drive:

2WD

Trans Type:

Automatic

Cab Type:



Crew Cab

Bed Length:

Long Bed (8.0)

Single Rear or Duallte:

Dual Rear Wheel

Traction Control
Equipped:

Yes

Truck Build Date:

-

Gear Ratio:

3:73

Tire Size:



245x75x17

Intake/Filter Type:

Stock Box, Stock Filter

HP Aftermarket Items:

-

Any Additional Details:

-

User Menu
Logout

My Tunes and Files
My Details
Update Tuner
Spartan Default
Configuration Files

Your cart is empty

Show cart

http://www.spai1andieseltecli.com/index.php/my-details

2/7/2014


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sabischm	Page 2 of 2

<© 2014 Spartan Diesel Technologies

http://www.spai1andieseltech.com/index.php/my-details

2/7/2014


-------
H&S Performance, SCT Performance, and Spartan Diesel Technologies

Appendix F
Bosch's Evaluation of Tuner Calibration

Enforcement Confidential

67

July 2014


-------
Calibration File Compare: Spartan 6.7 Liter Phalanx (Emissions-Equipment Present Calibration)

Feature

Driver demand
Compentent Protection
Disable Codes
Max engine speed
Engine Protect
Vehicle speed
Main timing
Fuel (Phymod)

Rail pressure
Smoke limit

Labels that changed

AccPed_trqModeOHRngLSpd_GMAP
AccPed_trqModeOLRng_GMAP
AFS_dmMaxThresMoB1_MAP
AirCtl_mDesBasEO MT rq1_MAP
AirCtl_mDesBasEOMT rq2_MAP
AirCtl_mDesBasEOMT rq4_MAP
atm_t_gas_postturbo_sub_b1
CmpPrt_facT rqCorT3_MAP
CmpPrt_facT rqLim_MAP
CmpPrt_trqCorT3_CUR
CmpPrt_tSetPntT3_MAP
Com_nEngMaxSpd_C
CoVeh_trqLim_CUR

DFC_CtlMsk.DFC_CodVarVIDErrP1635_C

DFC_CtlMsk.DFC_MoCComSPI_C

DFC_CtlMsk.DFC_MoFTrqCmp_C

DFC_CtlMsk.DFC_Tprot_Rttp_Err_C

DFC_DisblMsk.DFC_CodVarVIDErrP1635_C

DFC_DisblMsk.DFC_MoCComSPI_C

DFC_DisblMsk.DFC_MoCSOPErrMMRespByte_C

DFC_DisblMsk.DFC_MoCSOPErrNoChk_C

DFC_DisblMsk.DFC_MoFTrqCmp_C

DFC_DisblMsk.DF C_T prot_Rtt p_E rr_C

DFES_Cls.DFC_MoCComSPI_C

DFES_Cls.DFC_MoCROMErrXPg_C

DFES_Cls.DFC_MoCSOPErrMMRespByte_C

DFES_Cls.DFC_MoCSOPErrNoChk_C

DFES_Cls. DFC_T prot_Rttp_Err_C

EGTCond_nEngMaxCSH_C

EngDa_trqEngMax_C

EngDem_trqLimErr1_CUR

EngDem_trqLimErr2_CUR

EngDem_trqLimErr3_MAP

EnglCO_nCtOffCmftlCO_C

EnglCO_nCtOffCmftlCOHard_C

EnglCO_nCtOffStdlCO_C

EngPrt_qLim_CUR

EngPrt_trqNLim_CUR

EngPrt_trqOvhtPrvNRng_MAP

EngPrt_trqPresCor_MAP

H4229Appl_Std_xCalPartNum_ASC

lnjCrv_phiMI1Bas1Cfg1EOMO_MAP

lnjCrv_phiMI1Bas1Cfg1EOM3_MAP

Comments

Moved to upper bounds

Moved T3 limit to 900 degC from 800 degC

Vid block,

Moved from 3800 to 4000

Moving torque and fuel to max allowed

Moved to max allowed

At higher toruqes they advanced timing 5 degrees
Asking for max quanities at full load
Asking for max rail pressure sooner than we are
Allowing for much richer A/F

Labels that changed (continued)

lnjCrv_phiMI1Bas1Cfg2EOMO_MAP

lnjCrv_phiMI1Bas1Cfg2EOM3_MAP

lnjCrv_phiMI1Bas1Cfg3EOMO_MAP

lnjCrv_phiMI1Bas1Cfg3EOM3_MAP

LLim_vMaxFix_C

MoCMem_ctDebHealChkRAM_C

MoCMem_ctDebHealChkRAMCpl_C

MoCMem_ctDebHealChkROM_C

MoCMem_ctDebHealChkROMCpl_C

MoCRam_noRAMChkSD_CW

MoCSOP_stCANErrReac_CW

MoCSOP_stMMErrReac_CW

MoFDrDem_rT rqEng_MAP

MoFICO_nCtOff_C

MoFT rqCmp_ctDeb_C

MoFT rqCmp_ctRst_C

MoFTrqldc_q2trq_MAP

MoFT rqldc_q2trq2_MAP

PhyMod_qCorBas1EOM0_MAP

PhyMod_qCorBas2EOMO_MAP

PhyMod_trq2qBasEOMO_MAP

PhyMod_trq2qBasEOM1_MAP

PhyMod_trq2qBasEOM2_MAP

PhyMod_trq2qBasEOM3_MAP

PhyMod_trq2qBasEOM4_MAP

PPC_CHIPID

Rail_pSetPointBas1EOM0_MAP

Rail_pSetPointBas1EOM3_MAP

Rail_pSetPointBasEOM0_MAP

Rail_pSetPointBasEOM3_MAP

RngMod_trqSpd_CUR

SmkLim_rLamNrmModDyn_MAP

SmkLim_rLamRgn2ModDyn_MAP

SmkLim_rLamSmkNrmMode_MAP

SmkLim_rLamSmkRgnO_MAP

SmkLim_rLamSmkRgn2_MAP

t3m_t3est_bas_b1_a

t3m_t3est_bas_b2_a

Tra_trqMaxGear1_CUR

T ra_t rq M axG ea r2_C U R

VehV vMax C


-------
Calibration File Compare: H&S XRT Pro (Emissions-Equipment Present Calibration)

Feature

Driver demand
Compentent Protection
Disable Codes
Max engine speed
Engine Protect
Vehicle speed
Main timing
Rail prossuro
Smoke limit
Lug curve

Injector energizig (Fuel)

Labels that changed

AccPed_trq Exh BrkDemSet_MAP

AccPed_trqModeOHRngLSpd_GMAP

AFS_trqWinLdAdjThresHiPntO_CUR

AirCtl_trqLimThresHi_CUR

CmpPrt_tSetPntT3_MAP

Com_nEngMaxSpd_C

DFC_CtlMsk.DFC_MoCROMErrXPg_C

DFC_DisblMsk.DFC_AFSMoTrbMinB1_C

DFC_DisblMsk,DFC_AirTMonPlaus_0_C

DFC_DisblMsk.DFC_AirTMonPlaus_1_C

DFC_DisblMsk.DFC_AirTMonPlaus_2_C

DFC_DisblMsk.DFC_AirTMonPlaus_3_C

DFC_DisblMsk.DFC_AirTMonPlaus_4_C

DFC_DisblMsk.DFC_F2DSM_TrbChActCalcB2_C

DFC_DisblMsk.DFC_l14229KOERWGTstFail_C

DFC_DisblMsk.DFC_MoCROMErrXPg_C

DFC_DisblMsk.DFC_MoCSOPErrMMRespByte_C

DFC_DisblMsk.DFC_MoCSOPErrNoChk_C

DFC_DisblMsk.DFC_MoCSOPErrRespTime_C

DFC_DisblMsk.DFC_MoCSOPLoLi_C

DFC_DisblMsk.DFC_MoCSOPMM_C

DFC_DisblMsk.DFC_MoCSOPOSTimeOut_C

DFC_DisblMsk.DFC_MoCSOPPsvTstErr_C

DFC_DisblMsk.DFC_MoCSOPTimeOut_C

DFC_DisblMsk.DFC_MoCSOPUpLi_C

DFC_DisblMsk.DFC_PCRGovDvtMin_C

DFC_DisblMsk.DFC_PlntkVUsPhysRngHi_C

DFC_DisblMsk.DFC_PTrbnUsPlaus_C

DFC_DisblMsk.DFC_RailPSRCMax_C

DFC_DisblMsk. DFC_T prot_Rttp_Err_C

DFC_DisblMsk.DFC_TrbChOLB2_C

EGTCond_nEngMaxCSH_C

EngDa_trqEngMax_C

EngDem_trqLimErr3_MAP

EngPrt_qLim_CUR

EngPrt_trqNLim_CUR

EngPrt_trqNLimSpr_CUR

EngPrt_trqOvhtPrvNRng_MAP

EngPrt_trqOvhtPrvVRng_MAP

Eng Prt_trq PresCor_MAP

EngPrt_trqTempCor1_MAP

EngPrt_trqTempCor2_MAP

EngPrt_trqTempCor3_MAP

EngPrt_trqTempCor4_MAP

FMO_pPCRGovThres_C

Rail_dvolMeUnCtlUpLim_C

Rail_dvolMeUnCtlUpLim_CUR

Rail_pMeUnDvtMax_CUR

Rail_pMeUnDvtMin_CUR

Rail_pMonDvtMax_C

Rail_qRedOfsLimHi_C

Rail_qThresOfsHi_C

RngMod_trqSpd_CUR

SmkLim_qBISmkMinMax_C

SmkLim rLamSmkNrmMode MAP

Comments

Increasing torque very early on in pedal
Moved T3 way out

Tried to move to 4500 (Not sure if it will work)

Moved over heat for coolant and oil out of the way
Moved to max allowed
Moved 2 degrees at full load

Allowing richer A/F
Moved out of the way

Asking for more fuel through injector energizing time

Labels that changed (continued)
l14229Appl_Std_xCalPartNum_ASC
lnjCrv_phiMI1 Bas1Cfg1 EOMOJVIAP
lnjCrv_phiMI1Bas1Cfg1 EOM3_MAP
lnjCrv_phiMI1Bas1Cfg2EOMO_MAP
lnjCrv_phiMI1 Bas1Cfg3EOMO_MAP
lnjCrv_phiMI1 Bas1Cfg3EOM3_MAP
lnjCrv_phiMI1 Bas1Cfg4EOM1_MAP
lnjCrv_phiMI1 Bas1Cfg4EOM2_MAP
lnjCrv_phiMI1Bas1Cfg4EOM3_MAP
lnjCrv_phiMI1Bas1Cfg5EOM1_MAP
lnjCrv_phiMI1Bas1Cfg5EOM4_MAP
lnjCrv_phiMI1Bas1Cfg6EOM1_MAP
lnjCrv_phiMI1Bas1Cfg7EOM2_MAP
lnjCrv_phiMI1Bas1Cfg8EOM2_MAP
lnjCrv_phiMI1Bas2Cfg1EOMO_MAP
lnjCrv_phiMI1Bas2Cfg1 EOM3_MAP
I njCrv_phi M11 Bas2Cfg2 EOMO_MAP
I njCrv_phi M11 Bas2Cfg2 EOM3_MAP
lnjCrv_phiMI1 Bas2Cfg3EOMO_MAP
lnjCrv_phiMI1 Bas2Cfg3EOM3_MAP
lnjCrv_phiMI1 Bas2Cfg4EOMO_MAP
lnjCrv_phiMI1 Bas2Cfg4EOM3_MAP
lnjCrv_phiMI1 Bas3Cfg1 EOM3_MAP
lnjCrv_phiMI1 Bas3Cfg2EOMO_MAP
lnjCrv_phiMI1 Bas3Cfg2EOM3_MAP
lnjCrv_phiMI1 Bas3Cfg3EOMO_MAP
lnjCrv_phiMI1 Bas3Cfg3EOM3_MAP
lnjCrv_phiMI1 Bas3Cfg4EOMO_MAP
lnjCrv_phiMI1 Bas3Cfg4EOM3_MAP
lnjCrv_phiMI1Bas4Cfg1 EOM3_MAP
lnjCrv_phiMI1 Bas4Cfg2EOMO_MAP
lnjCrv_phiMI1 Bas4Cfg2EOM3_MAP
lnjCrv_phiMI1 Bas4Cfg3EOMO_MAP
lnjCrv_phiMI1 Bas4Cfg3EOM3_MAP
lnjCrv_phiMI1 Bas4Cfg4EOMO_MAP
lnjCrv_phiMI1 Bas4Cfg4EOM3_MAP
lnjVlv_tiET_MAP
lnjVlv_tiWup20n_C
LLim_vMaxFix_C
MoCMem_ctDebHealChkRAM_C
MoCMem_ctDebHealChkRAMCpl_C
MoCMem_ctDebHealChkROM_C
MoCMem_ctDebHealChkROMCpl_C
MoCRam_noRAMChkSD_CW
MoCRom_noROMChklni_CW
MoCRom_noROMCodeChkRst_CW
MoCRom_noROMDataChkRst_CW
MoFDrDem_rTrqEng_MAP
Mo FTrq ldc_q2trq_MAP
MoFTrq ldc_q2trq2_MAP
PCV_dvolUpLim_CUR
PPC_CHIPID

urlc_enable_shutdown_end
VehV vMax C


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Calibration File Compare: SCT 3015R (Returned to Stock Calibration)

Comments

Looks to have returned to stock

Labels that changed

DFC_CtlMsk.DFC_MoCROMErrXPg_C

DFC_DisblMsk.DFC_MoCROMErrXPg_C

114229Appl_Std_xCalPartNum_ASC

M o C M e m_ct D e b H e a IC h kR AM_C

MoCMem_ctDebHealChkRAMCpl_C

MoCMem_ctDebHealChkROM_C

MoCMem_ctDebHealChkROMCpl_C

MoCRam_noRAMChkSD_CW

MoCRom_noROMChklni_CW

MoCRom_noROMCodeChkRst_CW

MoCRom_noROMDataChkRst_CW

PPC CHIPID

Feature

Return to stock


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H&S Performance, SCT Performance, and Spartan Diesel Technologies

Appendix G
Miscellaneous Email Communication

Enforcement Confidential

68

July 2014


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> > >

1/10/2014 2:55 PM >>>

Don't worry about the 15th...My management probably won't want to see that level of detail.

Yes, the difference in emissions is because we ran hot 74's and not a 75 procedure that includes a
cold start. A cold start is where most of the emissions are generated. Of course, Ann suggested hot
74's at the start of this...and that was good because we would have never completed the testing by
running 75's. The EPA75 requires a 12 hour soak before each test, so at best we would have been
able to run only one test per day.

From: |	

Sent: Friday, January 10, 2014 2:47 PM

Subject: RE: Baseline US06

Attached is an updated table of results. Usually these types of things would need to go through an internal
review at my company but I don't think I would have enough time to get that step done by 1/15. I will let you
know if I find any errors when I get to that step.

Can you speculate as to why the baseline FTP 74 results are so low compared to certification levels (even
without DF's or EAFs added in)? For example, the cert level for NOx, according to public EPA documents, is
0.3 g/mi but our baseline is around 0.03 (DF 0 and EAF is only 0.02). I guess what I'm trying to confirm is
the big differences between the 74 and 75 from a procedure point of view that would cause an order of
magnitude change in measurements?


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Subject:

Date:

Attachments:

RE: Questions about Testing
Friday, March 07, 2014 3:44:29 PM
imaae002.pna

Sorry for the delayed response...

Hope you're doing well. I put together a list of follow up questions below. No rush on the response
but I couldn't find a complete list in my notes so I figured this would help both of us. Number 3 and 4
don't really require an answer.

1. Confirm that the 0.0072 g/mi PM measurement on the US06 Spartan was actually for the last
bag or if it represents the measurement for the last two bags due to an issue the during
testing. I attached the previous email chain for your reference. Yes the .0072 was for the
final test...It's just the form layout that makes it appear weird, but it is indeed the
total, one-test, final US06 particulate mass.

2. Can you confirm that the following equation is how one would calculate cumulative fuel
consumption for each interval (second).

V"i	/revoltions\	t- mq \ / 2n % /1B0 degrees-.

{ lstrofce

X 		;	;—— x 8 (cylinders') x AT" ime

\720 degrees}cylinder/

This would be a perfectly valid method to calculate fuel consumption

3.Second US06 baseline test in order to gather data on the data logger. I am having a hard time
getting into our busy cert schedule. I am not sure I will ever make it onto the priority list. I
think our day in the sun is over.

4. Calibration file compare . I have preliminary file compare info. ...It has the important stuff
complete. The person performing the file compare felt uncomfortable about letting our Ford strategy
information out in an uncontrolled document, so I have his summarization that I will forward in a just
a few minutes.


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From: |

Sent: Wednesday, March 05, 2014 3:57 PM
Subject: Questions about Testing

Hope you're doing well. I put together a list of follow up questions below. No rush on the response
but I couldn't find a complete list in my notes so I figured this would help both of us. Number 3 and 4
don't really require an answer.

1.	Confirm that the 0.0072 g/mi PM measurement on the US06 Spartan was actually for the last bag
or if it represents the measurement for the last two bags due to an issue the during testing. I attached
the previous email chain for your reference.

2.	Can you confirm that the following equation is how one would calculate cumulative fuel
consumption for each interval (second).

V	/reu£jEttofis\	/ ma \ / 2tt \ f-lBO dearees\

	7~)

f 1 stroke \	,

X 	;		—;—-— 1X 3 (cvlinders') X A Time

\72Q degrees/cylinder/

3.	Second US06 baseline test in order to gather data on the data logger

4.	Calibration file compare


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Brent Ruminski

From:

Sent:

To:

Subject:

"Wick, Anne" 
Thursday, August 01, 2013 9:41 AM
Brent.Ruminski@erg.com
RE: H&S question

H&S said that they would evaluate whether the new unlock code algorithm was "safe" and were willing to eliminate
the race tunes if "hacking" was still occurring. EPA told H&S that we believed there was wide availability of the unlock
codes and asked H&S to make good on their offer to eliminate the race tunes. That is what they claim they did with
production starting around July 11, 2013.

Anne Wick, Mechanical Engineer
Vehicle and Engine Team Leader
202-564-2063

From: Brent Ruminski rmailto:Brent.Ruminski@era.coml
Sent: Friday, July 26, 2013 4:31 PM
To: Wick, Anne
Subject: H&S question

For the final report, I need a short blurb about the events that occurred between EPA and H&S that we may not have
been involved in. It really just needs to be 1-2 sentences that includes the following:

-Did H&S offer to stop selling DPF/EGR delete tuners or did EPA order them to stop, I think EPA ordered them to stop. If
so, wha tis the general name that you would call this order "cease of production order"

-What is the date H&S was supposed to have ceased production of certain tuners
-What specific type of tuners were they supposed to stop selling

Thanks Anne! Have a good weekend,

Brent

Anne,

l


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From:
To:

Subject:
Date:

RE: Diesel Tuner Device Testing: ECM swap notes
Monday, March 10, 2014 1:05:56 PM

ASMOD EGR is "mass flow downstream of the EGR cooler

If it's %, It must be calculated from a delta pressure flow sensor with the raw reading must go
through a bunch of manipulation until a % EGR of intake air is calculated. From the description, I
believe this is the meaning. Regardless of exact definition, it certainly is an indication of EGR flow
after the cooler and into the intake.

From: |

Sent: Monday, March 10, 2014 11:57 AM

Subject: RE: Diesel Tuner Device Testing: ECM swap notes

I came up with one more question, can you provide a definition/description of the data parameter:
"ASMOD EGR rate" in the data logger. The units are %.

I am proposing "ASMOD EGR rate" as the indicator that the EGR was either working or not working
during tests. There is also a EGR valve (%) and desired EGR rate (%) in the data but I can't use them
because the Spartan street tune defaulted those values to 0, even though we know the EGR was in
fact working (based on emission results and the fact that the cumulative AFR did not increase
substantially).


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