1
In­
Use
Testing
for
Heavy­
Duty
Diesel
Engines
Draft
Final
Rulemaking
OMB
Briefing
May
5,
2005
2
Overview
°
Background
°
Review
of
HDIUT
Proposal
°
Review
of
Test
Procedure
Proposal
°
Our
Goal
and
Approach
°
Summary
of
Public
Interactions
°
Summary
of
Comments/
Key
Changes
°
MOA/
Test
Plan
°
Near
and
Longer
Term
Challenges
°
Next
Steps
°
Appendix
3
HDIUT
Background
°
EMA
Sued
Over
NTE
Provisions
of
2007
HDDE
Standards
°
EPA,
EMA,
and
ARB
Reached
a
Settlement
Agreement
to
Implement
a
Manufacturer­
Run,

HDDE
In­
Use
Testing
(
HDIUT)
Program
°
EPA/
ARB/
EMA
have
worked
diligently
to
develop
programs
and
resolve
issues
°
Court­
Ordered
Rulemaking
Schedule
 
Proposal
to
be
Signed
by
June
3,
2005
 
Needs
to
incorporate
both
program
and
test
procedure
elements
4
Test
Procedure
Background
°
Initially
arose
from
unfinished
business
in
2007
highway
diesel
and
nonroad
Tier
4
rules
°
At
EMA's
initiative
NPRM
was
expanded
to
include
overdue
tech
amds
from
other
sectors
(
e.
g.,
locomotive,
marine,
nonroad
diesel,
highway
diesel,
etc)

°
Most
work
done
EPA/
EMA/
ARB
Calibrations
and
Standards
Task
Force
(
CSRF)

 
Major
focus
on
part
1065
regs
needed
for
HDIUT
5
Our
Goals
and
Approach
°
Work
closely
with
ARB
to
have
a
consistent
program
°
Work
constructively
with
industry
and
others
to
identify
and
resolve
technical
issues
°
Set
up
for
success
at
OMB,
during
pilot
and
fully
enforceable
program
implementation,

and
develop
template
for
nonroad
engines
6
Summary
of
Public
Interactions
°
Public
Hearing
July
2004
 
No
significant
issues
raised
 
No
public
hearing
requested
for
Test
Procedure
rule
 
Comment
period
closed
end
of
Oct
2004
°
Prior
to
close
of
comments
EMA
presented
list
of
HDIUT
issues
for
resolution
 
5
meetings
over
a
4
month
period
to
discuss
and
resolve
 
Significant
action
items
for
EPA
and
EMA
°
Many
issues
related
to
test
procedures
discussed
many
months
prior
to
NPRM
and
monthly
since
then
in
CSTF
°
In
Sept
2004
briefed
ATA/
TAG
on
NPRM
°
Briefed
states/
enviros
prior
to
NPRM
and
in
March
 
No
substantive
comments
or
issues
7
HDIUT
Comment
and
Response
°
Comment:
More
Information
Needed
for
PEMS
Accuracy
Margins
 
Margins
developed
with
input
from
EMA
calibration/
standards
task
force
 
Negotiated
different
interim
margins
for
pilot
program
 
EPA,
ARB,
EMA
cooperative
development
program
for
enforceable
program
(
MOA)

°
Comment:
Portable
PM
Measurement
is
Still
Under
Development
 
Delaying
PM
pilot
program
until
2006
and
enforceable
program
until
2008
(
longer
depending
on
development
outcomes
(
MOA))

 
EPA
in­
house
development
effort
ongoing
°
Comment:
No
Need
to
Measure
PM
 
Catalyzed
Filters
Effective
and
Emissions
only
High
on
Catastrophic
Failure
 
Traps
do
not
guarantee
low
emissions
in
all
other
failure
modes
 
Many
future
unknowns
with
after
treatment
technologies
8
HDIUT
Comment
and
Response
°
Comment:
Portable
Gaseous
Emission
Measurement
not
Available
for
2007
Engine
Development
 
PEMS
available
in
2002
that
measure
at
2007
development
levels
for
NOx
,
THC,
and
CO
 
PEMS
available
in
2003
that
allow
measurement
of
NMHC
 
PEMS
part
of
otherwise
regular
development
practices
using
laboratory
testing
and
statistically
sound
test
plans
 
DDC
publicly
described
using
PEMS
for
field
testing
final
engine
calibrations
in
2003
°
Comment:
Reporting
Requirements
Overly
Burdensome
Need
comprehensive
reports
to
ensure
test
program
properly
conducted,
need
raw
data
to
ensure
reproducibility
of
compliance
manufacturer's
results,
etc.

 
Manufacturer's
will
electronically
record
most
data
anyway
 
Cooperatively
developing
standard
electronic
reporting
format
9
HDIUT
Comment
and
Response
°
Comment:
Reporting
Incomplete,
Invalid,
and
Voluntary
Tests
Burdensome
 
Incomplete,
invalid,
and
voluntary
test
reporting
changed
to
notification
and
recordkeeping
 
Voluntary
testing
subject
to
rule
now
limited
to
tests
on
same
engine
family
while
under
active
testing
in
the
in­
use
program
 
addresses
"
shopping
for
results"

°
Comment:
Required
Testing
with
Activated
MIL
or
OBD
Code
Inconsistent
with
Settlement
Agreement
(
normal
operation)

 
Changed
from
requiring
tests
under
most
cases
to
allowing
repair
before
testing,
or
rejecting
and
replacing
vehicle
prior
to
testing
10
Part
1065
Regs
°
HD
In­
use
Testing
Rule
depends
on
new
PEMS
test
procedures
in
40
CFR
part
1065
 
New
procedures
say
how
to
install
PEMS
on
trucks
for
conducting
valid
tests
°
EMA
has
been
pushing
hard
for
additional
changes
to
part
1065
 
Part
1065
has
become
the
centralized
reference
for
testing
all
types
of
engines
 
Proposed
changes
include
complete
PEMS
procedures
and
incorporate
a
wide
range
of
improvements
°
New
types
of
analyzers,
better
correction
factors,
more
accurate
engine
mapping,

calibrations
reflecting
the
full
range
of
applicable
standards,
units
and
calculations
following
international
protocol
 
We
have
held
many
all­
day
meetings
with
EMA
staff
to
work
out
hundreds
of
technical
details
°
The
international
community
is
also
very
interested
in
getting
part
1065
procedures
right
for
global
application
 
Part
1065
will
effectively
replace
ISO
8178
for
all
testing
°
Capturing
all
the
testing
improvements
requires
migration
of
test
procedures
from
part
86
to
part
1065
 
The
regulations
for
different
kinds
of
nonroad
engines
all
rely
on
part
86
procedures,
so
changing
this
for
highway
engines
requires
tech
amendments
for
other
engine
categories
11
Tech
Amendments
°
Technical
amendments
are
needed
to
stay
current
with
changes
to
parts
86
and
1065
°
We
have
adopted
several
new
rules
recently
without
a
chance
to
make
technical
amendments
based
on
implementation
experience
°
Proposed
amendments
included
a
wide
range
of
minor
corrections
and
program
adjustments
across
all
mobile­
source
programs
 
Adding
certification
flexibility,
clarifying
exemptions,
adjusting
labeling
requirements,
making
requirements
uniform
across
categories,
etc.

 
Manufacturers
suggested
many
additional
amendments
in
their
comments
 
Final
rule
reflects
hundreds
of
individual
changes
 
All
issues
worked
out
with
affected
industries
°
The
most
noteworthy
issues:

 
Adding
ramped­
modal
testing
to
allow
more
accurate
measurements
 
Adjusting
HD
highway
procedure
to
address
engine­
overspeed
 
Allowing
highway
engine
manufacturers
to
ship
engines
and
aftertreatment
separately
to
vehicle
manufacturer
12
MOA/
Test
Plan
°
Two
key
issues
emerged
from
discussions
with
industry
 
Accuracy
margins
for
PEMS
units
 
Availability
of
PM
PEMS
units
°
To
address
accuracy
margin
we
worked
with
EMA
and
ARB
to
develop
MOA
and
test
plan
to
determine
needed
values
°
MOA
covers
implementation
of
test
plan
 
Scope
of
program
 
Schedule
and
where
testing
will
be
done
 
Who
pays
and
how
much
 
Consequences
of
failure
 
Impacts
on
the
regulation
°
Test
plan
addresses
factors
and
operations
to
be
assessed
in
developing
accuracy
margins
and
how
they
will
be
determined.
Key
factors
include
variability,
environmental
effects
on
the
instrument,
chassis
vs
on
engine
comparison,
other
miscellaneous
engine
parameter
issue
°
MOA
and
Test
Plan
in
final
review
and
coordination
°
MOA
(
with
test
plan
as
an
attachment)
must
be
signed
by
June
2,
2005
 
EPA,
ARB,
EMA.
13
PM
PEMS
°
At
present,
PM
PEMS
capability
is
not
commercially
available
°
Technical
issues
 
PM
reference
method
 
Development
of
on­
vehicle
capability
 
In­
use
proveout
 
Accuracy
margins
°
Under
settlement
agreement
industry
is
not
required
to
test
if
equipment
is
not
commercially
available
°
Work
continues
in
private
sector
and
at
EPA
°
Laboratory­
proven
already,
road
ready
prototype
needs
to
be
available
by
June
2006
to
meet
schedule
in
test
plan
for
accuracy
margin
determination
14
Next
Steps
and
Schedule
°
Consent
Decree
date
June
3,
2005
°
Final
touches
on
rulemaking
documents
for
both
HDIUT
and
Test
Procedures
°
Closure
and
signature
on
MOA/
Test
Plan
°
Rule
submittal
for
final
review
and
signature
15
APPENDIX
16
HDDE
In­
Use
Testing
Objectives
°
Monitors
NTE
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
based
on
NTE
17
HDDE
In­
Use
Testing
Salient
Program
Features
°
Onboard
Emission
Measurement
Devices
°
Pilot
Program
2005/
06­
gaseous;
2006/
2007
PM
°
Enforceable
Starting
2007
gaseous
and
2008
PM
°
Up
to
25%/
Year
of
Engine
Families
Tested
or
1/
Year
for
Small
Engine
Manufacturers
°
Truck/
Bus
Procurement,
Mileage,
and
Screening
 
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
18
HDDE
In­
Use
Testing
Salient
Program
Features
(
Cont'd)

°
Emissions
Measured:
THC,
CO,
NOx,
PM*,
CO2,

and
O2
°
EPA/
ARB
Reserve
Right
to
Conduct
Own
Testing
°
Limit
SEA
Program
Solely
to
Instances
Where
Other
Credible
Evidence
Indicates
Potential
Nonconformity
_______________

*
Requires
significant
development
by
EPA
19
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
accuracy
margins
set
for
pilot
program
 
Instrument
margin
to
be
adjusted
after
test
plan
completed
20
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
21
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
22
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
