CONCEPTS
FOR
TEST
PROCEDURE
CHANGES
for
Spark
Ignition
Engines
<
19kW
Technical
Amendments
to
Part
90
And
Draft
Part
1054
Proposed
Regulations
for
Phase
3
TECHNICAL
AMENDMENTS
for
Part
90
°
EMA
Comments
 
Many
points
of
common
ground
between
EPA
and
EMA
 
Some
issues
need
further
clarification
 
Some
areas
of
difference
remain
Test
Issues
°
General
agreement
on:

 
90.324
and
90.324(
a)(
3)
­
Analyzer
leakage
check
 
90.405(
d)(
10)
Recording
information
 
90.409
©
(
6)
Engine
dynamometer
test­
run
°
Corrected
reference
 
90.417(
a),
90.419(
d),
90.426(
g)
 
removal
of
reporting
requirement
of
BSFC
 
90.418
Data
evaluation
for
gaseous
emissions
 
Linearization
of
Kh
(
NOx
humidity
correction)
as
per
40
CFR
1065.670
and
1065.645
°
Further
clarification
needed
on
EMA
comments
pertaining
to:

 
90.119(
a)(
1)(
i)
 
Certification
procedure­
testing
°
Test
cycle
selection
with
regards
to
the
A
or
B
cycles
in
40
CFR
90
is
currently
triggered
by
rated
vs.

intermediate
speed
operation,
not
by
variable
speed
vs.
fixed
speed
operation
 
90.326
­
Pre
and
post
test
analyzer
calibration
°
Calibration
of
just
the
analyzer
ranges
used
during
the
test
for
the
post
test
calibration
appears
to
be
already
covered
in
90.326
 
90.408
 
Effects
of
emissions
measurement
on
torque
and
fuel
consumption
°
Remaining
test
procedure
differences:

 
90.127
Gross
Power
Output
°
EPA
prefers
the
definition
from
40
CFR
1039
 
This
would
be
incorporated
into
Part
90
for
purposes
of
applicability
only
(
e.
g.,
<
19
kW
determination)

 
90.312(
c)(
2)
Request
for
optional
use
of
zero
air
or
nitrogen
with
all
gas
analyzers
°
EPA's
approach
in
40
CFR
1065.750
was
to
limit
FID's
to
using
zero
air,
and
all
other
analyzers
to
purified
N2
°
If
EPA
were
to
change
90.312,
we
would
prefer
the
approach
taken
in
40
CFR
1065.750
 
90.426(
a)
Dilute
emission
sampling
calculations
 
request
to
delete
the
requirement
to
report
CO2
°
CO2
emissions
results
are
still
useful
for
QA
purposes
 
90.417(
b)
Fuel
flow
measurement
specifications
 
request
to
allow
2%
of
full
scale
accuracy
at
non­
idle
conditions
°
EPA
does
not
favor
widening
the
accuracy
tolerance
for
fuel
flow
measurement
in
Part
90
°
If
EPA
were
to
change
90.417(
b),
we
would
prefer
the
approach
taken
in
40
CFR
1065.205,
table
1
(
±
2%
of
measured
point
or
±
1.5%
of
the
maximum
measured
value
in
any
test
interval)
40
CFR
1054
Draft
Test
Procedures
°
The
Nonroad
SI
Phase
3
regulations
will
be
moved
to
a
new
section
of
the
CFR:
40
CFR
Part
1054
°
Part
1065
will
be
heavily
referenced
for
test
procedures.
Part
1054
will
contain
details
specific
to
small
engine
testing
that
are
not
included
in
Part
1065.
°
Phase
3
test
procedures
will
include:

 
Use
of
equipment
and
exhaust
emission
test
procedures
for
spark
ignition
engines
as
specified
in
Part
1065
 
Some
changes
to
the
steady­
state
test
cycle
definition
for
exhaust
emission
testing
 
Permeation
emissions
test
procedures
°
Fuel
tank
permeation
°
Fuel
hose
permeation
Steady­
state
Test
Cycle
°
Current
testing
occurs
over
the
A­
cycle
(
intermediate
speed,
typically
3060
rpm)
and
B­
cycle
(
rated
speed,

typically
3600
rpm)

°
For
Phase
2
testing,
all
operation
with
the
exception
of
test
mode
1
was
moved
to
"
governed
operation"
in
place
of
the
fixed
throttle
position
used
for
Phase
1
testing
°
Draft
Phase
3
procedures
would
move
most
engines
to
governed
operation
for
mode
1,
and
would
define
mode
1
using
the
mapping
procedure
contained
in
40
CFR
1065.510d
(
d).
This
would
include:

 
All
Class
II
engines
 
Class
I
engines
with
some
exceptions
 
Some
lower­
power
Class
I
engines
may
not
be
capable
of
sustained
stable
operation
at
the
100%
test
torque
defined
using
the
procedure
defined
in
40
CFR
1065
(
d)

°
Power
for
some
Class
I
engines
drops
off
during
stabilization
in
mode
1
°
EPA
could
optionally
allow
the
use
of
fixed
throttle
operation
in
the
case
of
engines
that
cannot
maintain
sustained
stable
operation
at
the
100%

test
torque
°
EPA
is
also
considering
optional
provisions
within
40
CFR1065.510
that
could
allow
the
use
of
an
operator
demand
controller
to
simulate
governed
operation,
including
governor
droop
°
Testing
during
mode
6
for
Class
I
engines
without
user­
selectable
low­
speed
governor
settings
 
EPA
is
considering
2
options
°
Test
mode
6
at
no­
load
high
idle
(
Current
EPA
method
defined
for
Phase
2)

°
Combine
mode
5
and
mode
6
weighting
factors
for
mode
5
and
skip
mode
6
 
dynamometer
parasitic
losses
at
no­
load
high
idle
often
result
in
little
or
no
difference
in
load
between
modes
5
and
6
for
some
low­
power
Class
I
engines
lacking
lowidle
settings
