The Non-Financial Ledger: What $872 Per Truck Buys

Jackson, Minnesota has about 3,300 people. It sits in the flat southwestern corner of the state, far from any major metro, surrounded by farmland. Full Tilt Performance, LLC operated out of a building on Highway 71. On paper, they sold auto parts. In practice, they ran a business stripping out the pollution controls on diesel trucks and selling the tools to help anyone do the same.

The people who breathe the air near those trucks did not sign up for that transaction. They were not party to any agreement. They were not compensated. They were not consulted. The nitrogen oxides and particulate matter that pour out of a diesel engine whose emissions system has been deliberately disabled do not stay in Jackson. They travel. They settle into lungs. They trigger asthma attacks in kids, cardiac events in elderly people, and long-term respiratory disease in communities that already have limited access to medical care. This is not a hypothetical. This is the documented, peer-reviewed, repeatedly litigated reason the Clean Air Act’s vehicle emission standards exist in the first place.

Full Tilt knew this. The legal language of the consent order is careful to state that the company “knew or should have known” that the parts it manufactured and sold were being used to defeat emissions controls. That phrase is legal cover, but it also carries a simple meaning: you do not sell EGR block plates and ECM tunes to diesel truck owners because you think they will be used for something other than gutting the truck’s pollution systems. That is precisely and exclusively what those parts do.

The EPA’s investigation dragged on for more than five years from the date of the initial information request in July 2018 to the signing of the final order in February 2024. During most of that time, Full Tilt was still selling the illegal parts. The company stopped in September 2021, not because it was ordered to, not because a judge compelled it, but because, as confirmed in a meeting with the EPA in June 2022, it had simply chosen to. The law had been violated across at least 516 transactions before anyone made them stop.

There is no victim fund attached to this settlement. There is no community remediation. There is no medical monitoring for people who lived near roads where those tuned trucks were running. The $450,000 goes directly to the federal government. The air stays as it was left.

Five years of federal investigation. 516 illegal devices sold. The penalty comes out to roughly $872 per truck. No one who breathed that air gets a dollar.

Legal Receipts: What the Documents Actually Say

Every quote below is pulled verbatim from the EPA Consent Agreement and Final Order, Docket No. CAA-05-2024-0014. These are the agency’s own words, the company’s own admissions, and the law itself.

“Respondent manufactured, sold, offered for sale, and/or installed at least 516 aftermarket automotive parts that had a principal effect to bypass, defeat, render inoperative, or allow for the removal of one or more emission control devices or elements of design installed on or in a motor vehicle or motor vehicle engine. Respondent knew or should have known that such parts or components were being offered for sale or installed for such use or put to such use.” — CAFO, Paragraph 33, Factual Allegations

• The phrase “knew or should have known” is the legal threshold for willfulness. Selling EGR block plates and ECM tunes to diesel truck operators carries no commercially plausible purpose other than defeating emissions controls. The EPA’s standard confirms the company cannot claim ignorance.
• 516 is a minimum, established by Full Tilt’s own spreadsheet and QuickBooks data. The actual number of polluting transactions could be higher; this figure reflects only what the company disclosed covering January 2016 through June 2018.
• The parts named, ECM tunes and EGR/CGI block plates, are specifically engineered to override the onboard diagnostic systems and exhaust gas recirculation systems that federal law requires on diesel engines manufactured after 2007.

“It is unlawful for any person to manufacture or sell, or offer to sell, or install, any part or component intended for use with, or as part of, any motor vehicle or motor vehicle engine, where a principal effect of the part or component is to bypass, defeat, or render inoperative any device or element of design installed on or in a motor vehicle or motor vehicle engine in compliance with regulations under [Title II of the CAA], and where the person knows or should know that such part or component is being offered for sale or installed for such use or put to such use.” — Section 203(a)(3)(B) of the Clean Air Act, as cited in the CAFO, Paragraph 21

• This is the precise law Full Tilt violated. It was written to close exactly this loophole: selling hardware to do what manufacturers cannot legally do themselves.
• The law does not require proof that anyone actually breathed the resulting pollution. The sale itself is the crime. Full Tilt committed it at least 516 times across a documented 30-month window.

“During the meeting, the Respondent confirmed that it stopped the manufacture, sale, and offer for sale of aftermarket defeat devices in September 2021, before receipt of the FOV.” — CAFO, Paragraph 31, describing a June 2022 meeting between EPA and Full Tilt

• The EPA issued its formal Finding of Violation in April 2022. Full Tilt had already stopped selling the parts in September 2021, roughly seven months earlier. The company did not disclose this stoppage proactively. The EPA learned of it during a meeting after the FOV was already issued.
• Stopping before the formal complaint arrived reduced the company’s penalty. The CAFO explicitly cites “compliance steps that Respondent has taken” as a factor in the $450,000 figure, which is below the statutory maximum of $5,580 per violation (which would have totaled up to approximately $2.88 million for 516 violations).

“Within 15 calendar days of the Effective Date of this CAFO, Respondent shall permanently destroy all defeat devices remaining in Respondent’s inventory and/or possession, by compacting or crushing the defeat devices and all associated parts and components, and/or drilling holes in them, to render them useless.” — CAFO, Paragraph 43, Other Conditions

• The specificity of this instruction, compacting, crushing, drilling holes, signals that the EPA had reason to believe physical inventory still existed and needed a definitive destruction order to prevent resale or redistribution.
• The 15-day deadline is tight. Full Tilt also had to certify the destruction in writing to the EPA within 30 days. False certification carries criminal liability under federal law.

“On [Date], Full Tilt Performance, LLC (‘Full Tilt’) cooperatively entered into a settlement with the United States Environmental Protection Agency (EPA) to resolve alleged violations of Section 203(a)(3)(B) of the Clean Air Act, related to the removal and/or rendering inoperative of emission control devices and elements of design and the manufacturing selling, offering to sell, and/or installing defeat devices for use on heavy-duty diesel engines.” — Appendix A: Announcement, the text Full Tilt was ordered to post on its own website and social media for at least 60 days

• This is the public confession the EPA required Full Tilt to publish in at least 12-point font on its homepage and on every social media account, including Facebook, Twitter, Pinterest, and Instagram. The company could not bury it, reword it, or make it disappear after 59 days.
• The word “cooperatively” in the required announcement text is the company’s reward for settling before trial. It is the single piece of face-saving language the EPA permitted.

Societal Impact Mapping: Who Pays the Real Price

Public Health

Diesel emissions are among the most studied and documented sources of preventable disease in communities near freight corridors, farms, and rural highways. Defeating the systems that control those emissions is not a victimless transaction.

• Diesel particulate matter, the microscopic soot that DPFs are designed to capture, is classified as a Group 1 carcinogen by the International Agency for Research on Cancer. Heavy-duty diesel trucks with defeated DPFs release this material directly into the air. There is no safe threshold for long-term exposure.
• Nitrogen oxides, which EGR systems are designed to reduce, react with sunlight to form ground-level ozone and contribute to the formation of smog. Ozone exposure triggers asthma attacks, reduces lung function, and is associated with premature death from respiratory and cardiovascular causes.
• Rural and agricultural communities in Minnesota and neighboring states, where heavy diesel equipment is common, already experience elevated rates of respiratory disease and have fewer hospital resources per capita than urban areas. Adding uncontrolled diesel emissions to that environment compounds existing health disparities.
• Children are disproportionately vulnerable to particulate matter exposure, because their lungs are still developing. Asthma is the leading chronic disease among children in the United States, and diesel exhaust is a primary trigger. No child affected by the trucks running Full Tilt’s modified parts will ever be identified in this settlement.
• Defeated OBD systems, which are required to alert drivers when emissions components malfunction, mean that even accidental failures in the emissions system go undetected and unreported. The diagnostic safety net has been pulled out.

Economic Inequality

The defeat device market does not distribute its costs equally. The people who profit from selling these parts are not the same people who absorb the health consequences of the extra pollution they generate.

• The $450,000 penalty, while significant for a small LLC, represents a fraction of the potential maximum penalty of approximately $2.88 million for 516 violations at the $5,580 statutory cap. The gap between what the law allows and what Full Tilt actually paid reflects the discount available to companies that cooperate and settle early.
• Independent truck owners and small fleet operators who purchased these parts often do so because diesel emissions equipment is expensive to repair and maintain. The defeat device market exploits that cost pressure, letting companies like Full Tilt profit twice: once from the sale of illegal parts, and once from the regulatory discount available in settlements.
• Communities along rural freight corridors tend to be lower-income and have less political leverage to demand air quality enforcement. The burden of degraded air quality lands on people who lack the resources to relocate, sue, or lobby for stricter oversight.
• The $450,000 penalty is not tax-deductible, as stated explicitly in the CAFO. This is meaningful but modest. There is no provision requiring Full Tilt to fund any health monitoring, community remediation, or compensation for people harmed by the emissions of trucks running their modified parts.
• The defeat device aftermarket is a national industry, and Full Tilt is one of many regional operators. Companies that never get investigated face zero consequences. The enforcement system is selective by resource constraints, and that selectivity benefits wealthier, better-connected businesses more than small local competitors.

The “Cost of a Life” Metric

What Now: Who to Watch and What to Do

Full Tilt Performance is bound by this consent order, but the defeat device aftermarket is a national industry with many operators who have never faced an EPA investigation. Enforcement is resource-constrained, and the gap between the statutory maximum and the actual penalties collected tells you exactly how much companies can expect to save by cooperating rather than complying.

Leadership on Record

• Jonathan Hellrung, President of Full Tilt Performance, LLC — signed the Consent Agreement on January 27, 2024. His digital signature is on record with the EPA. He certified full compliance and the accuracy of all submitted information, knowing that false certification carries criminal penalties.

Watchlist: Regulatory Bodies With Jurisdiction

• EPA Region 5 Air Enforcement and Compliance Assurance Branch — the office that brought this case. Region 5 covers Illinois, Indiana, Michigan, Minnesota, Ohio, and Wisconsin. Contact: R5airenforcement@epa.gov. If you know of defeat device sales in the Midwest, this is the office to contact.
• EPA Office of Enforcement and Compliance Assurance (OECA) — the national body that sets enforcement policy for the Clean Air Act. Their 2020 Tampering Policy document is the standard Full Tilt certified it had read and would follow.
• U.S. Department of Justice, Environment and Natural Resources Division — empowered to pursue criminal charges for willful violations of the CAA. Civil settlements like this one explicitly do not preclude DOJ criminal action.
• State of Minnesota Pollution Control Agency (MPCA) — has independent authority to enforce state air quality laws. The federal CAFO does not immunize Full Tilt from state-level enforcement actions.

What You Can Do

• Report defeat device sales directly to the EPA. The agency’s tip process for CAA violations is accessible through its enforcement office contacts. Specific company names, product names, and screenshots of advertisements are the most useful evidence. The EPA’s information request process can compel production of sales records, as it did here.
• Pressure your state legislature and congressional delegation to fund EPA enforcement. This case took five years and a modest penalty because enforcement is chronically underfunded. The statutory maximum exists; the gap between that and what companies actually pay is a policy choice, not a legal necessity.
• Support organizations working on rural air quality. Clean Air Task Force, Earthjustice, and regional environmental justice groups are litigating diesel pollution enforcement in communities that lack the resources to fight back alone. Direct financial support or volunteer time to legal defense funds and community air monitoring projects.
• Organize locally around air quality monitoring. Community-owned low-cost air sensors (like PurpleAir monitors) can document elevated particulate matter in areas near freight corridors and provide the kind of localized data that supports enforcement referrals and public health advocacy.
• Share this story. The defeat device aftermarket thrives on low public awareness. Every truck owner who understands that “delete kits” are federal crimes is one fewer potential customer for the next Full Tilt.