1
In­
Use
Testing
for
Heavy­
Duty
Engines
Proposed
Rulemaking
Presentation
for
American
Trucking
Association
September
29,
2004
2
HDDE
In­
Use
Testing
Overview
°
Engine
Manufacturers
Association
(
EMA)
Sued
Over
Not­
To­
Exceed
(
NTE)
Provisions
of
2007
HDDE
Standards
°
EPA,
EMA,
and
California
Air
Resources
Board
(
ARB)
Reached
a
Settlement
Agreement
to
Implement
a
Manufacturer­
Run,
HDDE
In­
Use
Testing
Program
°
Settlement
also
Provided
Manufacturers
with
Detailed
Guidance
on
How
EPA
would
Implement
NTE
Requirements
3
HDDE
In­
Use
Testing
Overview
°
Court­
Ordered
Rulemaking
Schedule
 
Proposal
to
be
Signed
by
June
3,
2004
 
Final
rule
one
year
later
°
Proposal
Published
on
June
16,
2004
°
Comment
Period
Closed
on
August
16,
2004
°
Final
Rule
Expected
Beginning
of
2005
4
HDDE
In­
Use
Testing
Objectives
°
Monitors
NTE
and
Exhaust
Emission
Standards
Compliance
for
MY2007
and
Later
HDDEs
 
Under
real­
world
driving
conditions
 
Over
entire
useful
life
of
the
engine
°
Testing
Conducted
and
Paid
For
By
Manufacturers
with
EPA
Oversight
°
Addresses
Long
Standing
Need
for
Such
In­
Use
Information
and
Retains
NTE
5
HDDE
In­
Use
Testing
Salient
Program
Features
°
Onboard
Emission
Measurement
Devices
Emissions
°
Measured:
THC,
CO,
NOx,
PM*,
CO2,
and
O2
°
Pilot
Program
2005/
06
°
Enforceable
Starting
2007
°
Up
to
25%/
Year
of
Engine
Families
Tested
or
1/
Year
for
Small
Engine
Manufacturers
6
HDDE
In­
Use
Testing
Salient
Program
Features
(
Cont'd)

°
Truck
Procurement,
Mileage,
and
Pre­
Screening
 
Truck
owner/
operator
participation
is
voluntary
 
Test
vehicles
obtained
from
at
least
two
sources
 
Normal
operation
­
routes,
driver,
and
conditions
 
Only
properly
used
and
maintained
vehicles
 
No
screening
out
for
high
mileage
up
to
reg.
useful
life
 
Must
have
indication
of
significant
non­
idle
operation
°
EPA/
ARB
Reserve
Right
to
Conduct
Own
Testing
7
HDDE
In­
Use
Testing
Vehicle
Pass
Criteria
°
Passes
if
90%
of
Valid
NTE
Samples
are
Less
Than
or
Equal
to
NTE
Threshold
°
100%
of
Valid
NTE
Samples
Must
be
Less
than
2X
NTE
Threshold
for
MY2007
through
2009
 
Reevaluate
need
for
this
standard
MY2010
and
later
°
NTE
Threshold
=
Standard
+
Existing
Regulatory
and
New
Instrumentation
Margin
 
Instrument
margin
proposed
at
5%

 
Instrument
margin
adjusted
or
eliminated
in
future
rule
8
HDDE
In­
Use
Testing
Family
Pass
Criteria
°
Two
Phase
Approach
°
Phase
1
 
Vehicle
sample
size:
5
minimum,
10
maximum
 
If
5
out
of
5
or
5
out
of
6
pass,
family
passes
 
If
2
fail,
test
4
more
 
If
all
then
pass
(
8
out
of
10
total),
family
passes
9
HDDE
In­
Use
Testing
Family
Pass
Criteria
(
Cont'd)

 
If
more
than
2
fail,
then
actions
could
include:

 
No
further
action
(
no
significant
issues
indicated
by
data)

 
Mandatory
Phase
2
testing
if
5
or
more
vehicles
fail,

unless
manufacturer
agrees
to
remedial
action
 
Voluntary
Phase
2
testing
if
EPA,
ARB,
and
manufacturer
agree
when
3
or
4
vehicles
fail
 
Pursue
remedial
action
directly
if
warranted
based
on
Phase
1
and
other
relevant
data
or
considerations
10
HDDE
In­
Use
Testing
Family
Pass
Criteria
(
Cont'd)

°
Phase
2
 
Sample
size
up
to
10
vehicles
 
Pursue
remedial
action
directly
if
warranted
based
on
Phase
1
and
2
results,
and
other
relevant
data
or
considerations
11
HDDE
In­
Use
Testing
Next
Steps
°
Working
to
Resolve
Several
Implementation
Issues
with
Manufacturers
°
Final
Rule
by
Beginning
of
2005
°
Continue
Aggressive
Development
of
PEMS
PM
Measurement
Capability
