Page
1
Proposal
for
Updated
Test
Procedures
and
Technical
Amendments
Briefing
for
Margo
Oge
June
2004
Page
2
Test
procedures
 
Part
1065
has
test
procedures
for
multiple
engine
categories
 
Originally
adopted
for
nonroad
spark­
ignition
engines
 
Nonroad
diesel
Tier
4
 
Part
1065
is
adequate
for
these
final
rules
 
Proposal
includes
three
types
of
change
 
Improved
precision
and
new
measurement
techniques,
consistent
with
HD2007
final
rule
 
Updated
measurement
procedures
for
in­
use
testing
 
Updated
language
to
make
testing
general
and
understandable
for
all
engine
categories;
Part
1065
will
be
become
the
global
technical
standard
 
Proposed
language
has
been
closely
coordinated
with
industry
Page
3
Rulemaking
Background
 
Most
of
the
changes
to
the
test
procedures
in
part
1065
were
drafted
for
the
Tier
4
final
rule
 
The
final
draft
included
many
changes
from
the
proposal
 
OGC
recommended
adopting
only
those
changes
needed
for
the
Tier
4
final
rule
 
The
heavy­
duty
in­
use
testing
rule
depends
on
updating
the
test
procedures
in
part
1065
 
Need
signature
by
early
July
to
support
in­
use
testing
rule
 
Initiating
a
separate
rule
for
changing
test
procedures
gave
us
the
opportunity
to
add
technical
amendments
Page
4
Technical
Amendments
 
OTAQ
has
had
no
technical
amendments
for
3+
years
 
Industry
and
EPA
review
of
regs
has
produced
several
amendments,
which
can
be
grouped
into
three
types:

 
Correct
errors
(
equations,
cross­
references,
typos,
etc.)

 
Clarify
various
provisions,
none
of
which
are
expected
to
raise
big
issues
(
see
Appendix)

»
many
of
these
align
other
programs
with
the
nonroad
diesel
Tier
4
final
rule
 
Make
minor
program
adjustments
 
No
changes
related
to
fuels
program
Page
5
HD2007
Amendments
 
Migrate
test
procedures
from
Part
86,
subpart
N
to
Part
1065
 
Test
requirements
are
consistent,
but
clarify
several
provisions
and
incorporate
recent
testing
upgrades
 
Adjust
the
testing
method
for
the
Supplemental
Emission
Test
 
Conventional
approach
requires
13
separate
measurements,
which
can
reduce
repeatability,
especially
with
infrequent
regeneration
events
 
New
"
ramped­
modal"
approach
covers
the
same
engine­
operating
modes,

but
connects
them
with
gradual
transition
"
ramps"
that
allow
for
a
single
measurement
 
Accuracy
and
repeatability
are
substantially
improved
 
We
and
manufacturers
strongly
support
this
change
Page
6
Aftertreatment
Shipment
 
We
are
considering
a
provision
to
allow
manufacturers
to
ship
aftertreatment
separately
to
truck
builders
 
We
adopted
this
for
nonroad
diesel
engines
for
Tier
4
 
Manufacturers
are
eager
do
this
also
for
highway
engines,
but
are
concerned
with
a
restriction
we
adopted
for
nonroad
engines
 
Engine
manufacturer
must
include
the
cost
of
aftertreatment
in
the
price
of
the
engine
 
This
removes
the
incentive
for
equipment
manufacturers
to
ignore
aftertreatment
or
skimp
on
quality
 
We
recommend
taking
comment
on
the
concept
of
separate
shipment
for
highway
engines
to
give
ourselves
flexibility
to
address
it
in
the
final
rule
if
appropriate
Page
7
Recreational
Vehicles
 
To
resolve
a
pending
lawsuit
from
the
Motorcycle
Industry
Council,
we
agreed
to
make
several
changes
to
the
regulations:

 
Clarify
approach
to
defining
exhaust
and
evaporative
engine
families
 
Clarify
gas­
cap
specifications
for
permeation
testing
 
Clarify
the
sequence
of
permeation
testing
 
Define
"
fuel
line"
to
clear
up
ambiguous
testing
specification
 
Correct
the
equations
defining
advertised
emission
levels
for
consumer
labels
 
Allow
exhaust
testing
using
raw­
gas
sampling
methods
 
Allow
manufacturers
to
select
a
different
maximum
engine
speed
for
testing
Page
8
Other
Program
Adjustments
 
Independent
Commercial
Importers
 
Allow
limited
import
of
products
subject
to
year­
of­
production
standards
 
HD2007:
allow
flexible
phase­
in
for
HD2007
rule
 
Manufacturers
may
base
compliance
on
model
year
or
calendar
year
 
This
addresses
Cummins'
concerns
 
Nonroad
Diesel
Tier
3:
allow
the
same
technical
hardship
provisions
we
adopted
in
Tier
4
final
rule
 
This
addresses
Ingersoll
Rand
concerns
 
Nonroad
Diesel
Tier
4
and
Recreational
vehicles:
require
separate
ABT
accounting
if
states
adopt
separate
standards
 
Consistent
with
previous
programs
 
This
will
have
no
effect
until
California
adopts
standards
 
Adjusting
maximum
penalties
to
$
32,500
 
Consistent
with
February
2004
OECA
final
rule
