UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
National
Vehicle
and
Fuel
Emissions
Laboratory
2565
Plymouth
Road
Ann
Arbor,
Michigan
48105­
2498
October
25,
2004
MEMORANDUM
SUBJECT:
Meeting
with
EMA/
ARB
regarding
HDDE
In­
Use
Testing
Program
FROM:
Glenn
W.
Passavant,
Director
Nonroad
Center
TO:
Public
Docket
OAR­
2004­
0072
On
August
26,
2004
,
September
20,
2004,
and
October
14,
2004
representatives
from
EPA,
EMA,
and
ARB
met
in
Chicago
and
Detroit
to
discuss
EMA's
concerns
about
the
proposed
in­
use
testing
program
for
heavy­
duty
diesel
vehicles
and
engines.
The
positions
and
concerns
presented
by
EMA
largely
reflected
those
presented
in
their
written
comments
dated
August
16,

2004.

Summary
of
Points
Made
In
Discussions
1.
Measurement
Equipment
Availability
and
Program
Implementation
­
Conduct
PM
measurement
technology
demonstration
on
vehicles
during
pilot
program
­
Discussion
about
whether
PM
measurement
technology
used
during
pilot
program
should
be
purchased
by
industry
or
provided
on
loan
from
EPA/
ARB
­
Discussed
the
idea
of
a
2006/
2007
technology
review
for
the
PM
in
final
regulations
­
EMA
wants
across
the
board
review
for
all
pollutants
­
EMA
wants
the
possibility
of
technology/
application
specific
testing
exemptions
­
Need
sense
of
what
parameters
and
information
would
be
reviewed
in
making
PM
implementation
determinations
2
­
Do
not
make
change
process
too
easy;
options
include
­
temporary
waiver
­
program
modification
­
off
ramp
(
if
necessary)
would
need
strong
record
for
change
­
Discussed
extending
PM
pilot
one
year
to
give
time
for
technology
proveout;
no
change
to
gaseous
pollutant
pilot
program.

2.
New
Instrumentation
Accuracy
Allowance
­
For
pilot
program
options
discussed
included
10%
across
the
board
covering
all
variables
or
larger
of
10%
or
nominal
ASTM
round­
off
by
pollutant
­
EPA
wants
full
pilot
program
in
2005­
2006,
EMA
concerned
too
much
follow­
on
testing
(
Phase
1
and
2)
would
occur
if
accuracy
allowance
too
small
­
Discussion
of
how
to
have
pilot
program
accomplish
its
goal
without
too
much
or
too
little
testing
­
EMA­
every
mfr
must
do
at
least
one
phase
2
­
Cummins:
limit
of
1/
3
of
families
go
to
10
tested
or
include
a
double
cap
if
exceed
by
25%
then
go
to
10
or
if
exceed
by
40%
then
all
must
go
­
Develop
trigger
based
approach
based
on
avg
emission
level
­
Limit
total
number
tested
per
year
by
any
manufacturer
(
say
25)

­
It
appears
more
data
and
experience
are
needed
to
resolve
the
accuracy
margin
issue
3.
Waiver
of
Measurement
Requirement
­
EMA
wants
a
measurement
waiver
process
based
on
good
experience
and
data.
EPA
says
a
temporary
waiver
possible,
but
any
long
term
changes
need
to
go
through
rulemaking.
ARB
would
consider
but
hurdle
would
be
high
4.
Instrument
Verification/
Certification
­
EPA
expects
that
commercial
vendors
would
go
to
expense
of
validating
performance
for
purposes
of
marketing
and
customers.
Instrument
manufacturer
not
responsible
for
3
torque
reconciliation.
Vendor
may
need
to
demonstrate
accuracy
to
OEMs
using
EPA
criteria.

­
Working
with
CSTF,
EPA
has
proposed
guidance
criteria
for
measurements
within
the
NTE
Zone.
Expect
to
map
"
X"
points
(
say
25
point
matrix.).
Release
guidance
with
final
rule.

­
ARB
pre­
pilot
program
not
designed
to
address
accuracy/
measurement
allowance.
Need
follow­
on
effort
involving
engine
dyno,
chassis
dyno,
chase
vehicle.

­
EPA
will
not
officially
validate
or
verify
commercially
available
units.

5.
Identification
of
NTE
Zone,
Including
Carve
Outs
and
Approved
Deficiencies
(
ECM
Issues)

­
EPA
would
prefer
needed
information
up
front
on
an
electronic
medium
which
would
allow
the
information
to
be
programmed
into
the
PEMS
unit
before
testing
thus
eliminating
post
processing.
CSTF
has
an
example
of
how
to
address
this
need
and
will
bring
an
example
to
us.
We
need
the
availability
of
all
information
(
preferably
at
certification)
to
conduct
an
accurate
post­
processing
assessment.

­
Industry
concerned
that
up­
front
reporting
is
too
burdensome,
and
reprogramming
of
current
engine
controls
is
too
costly
in
the
near
term.

6.
Engine
Family
Designation
and
Implementation
Date
­
For
pilot
programs
(
2005&
2006)
we
will
designate
families
for
testing
by
June
1.

­
EMA
wants
only
½
of
burden
(
i.
e.,
12
½
%
)
if
first
fully
enforceable
year
­
2007
­
EMA
doesn't
care
when
we
designate
in
2008
­
EMA
concerned
that
fully
enforceable
program
in
2007/
2008
will
look
like
pilot
program
since
they
will
not
be
able
to
accommodate
changes;
may
ask
for
extension
of
pilot
program
in
lieu
of
½
of
fully
enforceable
program
7.
Testing
with
Activated
MILs
or
Trouble
Codes
­
General
discussion
on
excluding
vehicles
from
testing
which
have
an
activated
MIL
light
4
before
testing
starts
and
how
to
handle
if
light
comes
on
during
testing
­
Agreement
to
report
all
MIL,
codes,
etc
to
EPA
regardless
of
when
in
the
entire
selection
or
testing
process
they
are
identified
­
EPA
needs
to
develop
threshold
mileage
on
when
an
MIL
light
could
matter
for
testing.

Will
be
placed
in
guidance
8.
Pre­
approved
Test
Programs
Versus
Guidance
­
EMA
objected
to
EPA's
proposed
language
to
require
manufacturers
to
make
pretesting
submittal
on
basics
of
test
fleet
selection
and
related
information
­
not
required
in
"
program
outline"
and
creates
a
burden
with
minimal
added
value
­
nevertheless,
EPA
expects
most
manufacturers
will
seek
pre­
testing
meeting
with
­
EPA/
ARB
to
discuss
their
"
plans
and
approaches"
and
will
consider
guidance
9.
Minimum
Fuel
Quality
Specification
­
EMA
expressed
concern
about
the
potential
for
non­
spec
fuel
to
adversely
affect
emission
results.
The
use
of
diesel
fuel
meeting
ASTM
D
975
was
discussed
as
was
the
idea
of
allowing
a
drain
and
fill
with
commercially
procured
local
fuel
to
avoid
potential
fuel
issues.
Issues
regarding
biodiesel
were
also
discussed,
including
how
its
use
might
affect
emissions
performance
and
how
its
use
should
be
incorporated
into
the
rule
10.
Confidential
Business
Information
(
CBI)

­
EMA
still
owes
us
input
on
what
information
coming
from
the
engine
and
that
reported
to
EPA
as
a
result
of
the
program
would
be
claimed
as
CBI
In
addition
to
these
matters,
the
parties
discussed
the
need
for
various
guidance
documents
to
help
ensure
a
smooth
rollout
and
implementation
of
the
program
and
to
clearly
lay
out
reporting
and
recordkeeping
requirements.
In
some
cases
these
were
preferred
over
regulatory
provisions.
