Cleophas
Jackson
U.
S.
EPA
­
OTAQ
Assessment
and
Standards
Division
2000
Traverwood
Drive
Ann
Arbor,
MI
48105
(
734)
214­
4824
(
734)
214­
4816
FAX
­­­­­
Forwarded
by
Cleophas
Jackson/
AA/
USEPA/
US
on
10/
23/
03
08:
02
AM
­­­­­
"
Larson,
Cameron"
<
clarson@
kubotaengine.
com>
Received
Date:
10/
22/
03
05:
29:
46
PM
Transmission
Date:
10/
22/
03
05:
29:
46
PM
To:
Cleophas
Jackson/
AA/
USEPA/
US@
EPA
cc:
Subject:
Kubota
Additional
TRU
Data
Cle,

I
have
some
additional
TRU
data.
For
this
test
the
load
was
more
directly
measured
from
exhaust
temperature,
compared
to
the
earlier
data
which
was
determined
indirectly
from
compressor
pressures.
This
is
confidential
data,
please
do
not
disclose
it
outside
EPA.

I
think
the
Thermo­
King
comments
concerned
the
definition
of
a
TRU
more
than
the
definition
of
the
data
points.
The
wording
in
the
NPRM
seems
to
say
that
the
engine
must
run
exactly
at
these
4
points
in
order
to
be
called
a
TRU.
Their
fix
was
to
add
a
tolerance
to
the
test
points.
I
don't
think
it
is
necessary
to
change
the
test
points,
perhaps
we
can
modify
the
definition
another
way.

I
have
some
additional
comments
on
the
attachment,
if
you
could
call
when
you
get
it
I
will
explain.
I
am
still
looking
for
data
taken
with
a
smaller
time
period
which
better
illustrates
that
TRU
operation
is
steady
state.

Thanks
and
Best
Regards
Cameron
Larson
Kubota
Engine
America
<<
8450524tru.
xls>>
