Item — HN Reader

> The article is about a company trying to make an electric "converter dolly" that improves the fuel efficiency of diesel trucks by essentially turning them into hybrids.

No. The article is about someone who is whining about having to comply with regulation. But not all regulation, only the one they feel they are having trouble complying with.

There is a difference. And a nuance.

You'd be naive if you were hoping to get objective statements from what reads clearly as a promotion piece.

> Suppose that there exist regulations that are ill considered or poorly drafted and require things that are not aligned with their ostensible purpose.

You can imagine all hypotheticals you wish. We need to discuss objectively verifiable facts if you want to attack specific regulations, though. I don't see fact-based arguments being made, and that reads like a desperate straw man.

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> No. The article is about someone who is whining about having to comply with regulation. But not all regulation, only the one they feel they are having trouble complying with.

Which brings us to the question of whether the regulation they're complaining about is actually objectionable. And it appears that they rather have a point. Why should they have to spend millions of dollars testing for something that makes no sense in this context? Why is the government even testing for this at all, when fuel is a semi truck's primary operating cost and buyers are going to be highly sensitive to fuel efficiency independent of any government regulations?

> You can imagine all hypotheticals you wish.

This is not a hypothetical unless your contention is that all existing regulations are entirely without flaws or inefficiencies.

> We need to discuss objectively verifiable facts if you want to attack specific regulations, though.

Do you want to try to defend the rule requiring them to spend millions of dollars on certifications for no apparent benefit to anyone?

> Why should they have to spend millions of dollars testing for something that makes no sense in this context?

To have data to back the claims being made.

The requirement doesn't depend on the company having made any particular claims.

False. The claim, even if implicit, is "does not increase emissions beyond particular threshold within particular operational domain".

Further, the article makes a claim that there are more emissions testing groups to test on than there are individual members, which cannot be true.

> The claim, even if implicit, is "does not increase emissions beyond particular threshold within particular operational domain".

So the government wants data to validate a claim the company never explicitly made, but the government doesn't want to pay for the data, and the nature of the product is such that data showing higher emissions would be baffling and implausible. We're back to, how does this make any sense?

> Further, the article makes a claim that there are more emissions testing groups to test on than there are individual members, which cannot be true.

Consider the possibility that an "engine family" could be an engine configured in a given way rather than a set of distinct engines.

> So the government wants data to validate a claim

The claim is "our contraption is roadworthy", which implicitly includes claims regarding roadworthiness requirements, including emissions. This is literally how market availability works.

> Consider the possibility that an "engine family" could be an engine configured in a given way rather than a set of distinct engines.

"Engine family" is a set of particular engine configurations/codes, specifically to reduce re-test burden. Group validation automatically validates all group members, therefore there are at most number of engines groups to test. I suspect the testing requirements are not for the engines, though, but why would an article by a startup struggling to follow regulations misrepresent the regulations?

> The claim is "our contraption is roadworthy", which implicitly includes claims regarding roadworthiness requirements, including emissions. This is literally how market availability works.

You can't get around the government demanding that someone else pay an unreasonable amount of money for data that only the government wants. If they think the value to the public of the testing is worth the cost then why aren't they paying for it? If it isn't worth the cost then why are they forcing someone else to pay for it?

> Group validation automatically validates all group members, therefore there are at most number of engines groups to test.

Unless the state requires you to test all 270 engine groups regardless of how many you're actually using.

It's an electric motor with no emissions and therefore can't possibly increase emissions. There's your data. No regulations needed.