Cummins
Marine
Suite
301
4500
Leeds
Avenue
Charleston,
SC
29405­
8521
Phone:
843
745
1620
Fax:
843
745
1549
A
Division
of
Cummins
Inc.
February
28,
2005
Purpose
To
provide
evidence
that
the
EPA
should
consider
the
E3
cycle
(
94.105
Table
B­
1)
appropriate
for
propeller­
law
operated
variable
speed
auxiliary
engines
instead
of
or
in
conjunction
with
the
C1
cycle
(
94.105
Table
B­
3)
as
defined
in
the
regulation.

Background
/
References
1.
Per
94.105(
a)
of
40
CFR
94,
"
engines
shall
be
tested
using
the
appropriate
duty
cycles
described
in
this
section.

2.
Per
94.105(
b)
of
40
CFR
94,
"
Propulsion
engines
that
are
used
with
(
or
intended
to
be
used
with)
fixed­
pitch
propellers,
and
any
other
engines
for
which
the
other
duty
cycles
of
this
section
do
not
apply,
shall
be
tested
using
the
duty
cycle
described
in
the
following
Table
B
 
1"(
ref.
ISO
8178
E3
cycle)

3.
Per
94.105
(
d)(
2)
of
40
CFR
94,
"(
2)
Variable
speed
auxiliary
engines
shall
be
tested
using
the
duty
cycle
described
in
Table
B
 
3
in
paragraph
(
c)(
2)
of
this
section."(
ref.
ISO
8178
C1
cycle)

4.
Per
Annex
VI
of
MARPOL
73/
78:
Appendix
II
section
.3,
"
For
propeller­
lawoperated
main
and
propeller­
law­
operated
auxiliary
engines
the
test
cycle
E3
should
be
applied.

Discussion
As
identified
in
reference
3
above,
EPA
requires
engine
manufacturers
to
certify
all
variable
speed
auxiliary
engines
to
the
cycle
described
in
Table
B­
3
(
ISO
8178
C1)
of
the
regulation.
In
contrast,
reference
4
illustrates
that
IMO
requires
propeller­
law­
operated
auxiliary
engines
[
variable
speed]
to
certify
using
the
E3
cycle
(
40
CFR
94,
Table
B­
1).

We
believe
that
the
emissions
test
cycle
referred
to
by
IMO
is
more
appropriate
for
variable
speed
auxiliary
engines
that
are
used
in
propeller­
law
operated
applications
i.
e.
pumps,
thrusters,
or
compressors.
These
applications
are
characterized
by
power
demand
(
load
curve)
that
is
exponential
as
a
function
of
RPM,
identical
to
that
specified
by
the
ISO
8178
E3
cycle.
The
C1
test
cycle
includes
points
of
operation
at
part
&
full
throttle
that
are
not
part
of
a
typical
load
profile
for
engines
used
in
these
applications.
Also,
in
order
to
comply
with
Cummins
Marine
installation
requirements,
a
variable
speed
auxiliary
engine
(
propeller
law
operated)
must
achieve
rated
speed
at
full
throttle.
This
clearly
indicates
that
the
E3
cycle
is
the
most
appropriate
cycle
for
engines
used
in
these
applications.
Cummins
Marine
Suite
301
4500
Leeds
Avenue
Charleston,
SC
29405­
8521
Phone:
843
745
1620
Fax:
843
745
1549
A
Division
of
Cummins
Inc.
In
addition
to
the
items
above,
harmonization
is
an
important
issue.
As
we
supply
engines
that
are
IMO
and
EPA
certified,
a
common
approach
would
simplify
the
engine
selection
process
for
our
customers.
Instead
of
running
additional
emissions
tests
on
product
to
validate
C1
results,
we
could
continue
to
offer
existing
engines
certified
to
the
E3
cycle
as
permitted
by
the
IMO
regulation.

Proposal
As
the
definition
of
General
Marine
Test
cycle,
specified
in
by
reference
1
above,
includes
the
statement
"
other
engines
for
which
the
other
duty
cycles
of
this
section
do
not
apply"
we
feel
that
there
is
room
to
interpret
that
the
applications
which
we
have
described
above
are
in
fact
covered
under
this
cycle
[
ISO
8178
E3];
the
C1
cycle
is
inappropriate
in
these
cases.
We
propose
that
this
interpretation
be
considered
and
accepted
based
on
the
facts
included
in
this
letter.
