1 ( Dr. Julius Rim to testify i n the Proposed joint (EPA & NHTSA) Rule Making H earing for the “ Gr eenhouse Gas
Emissions and Fuel Efficiency Standards ” for Medium

- and Heavy

- Duty Engines Vehicles , O n N o v 15 2010, in Chicago )



### Speaker: Julius J. Rim, Ph.D.

President, International Metals & Energy Technology, Ltd

45429 Tournament Dr., Northville, MI 48168, (T) 734

- 414

- 1414; (M) 248

- 765

- 7747

juliusrim@autogreenpower.com ; dieseltrap@gmail.com

Subject: Support for the EPA ’ s Fuel Efficiency Increase

. T h e E P A Reduce s t h e NOx standard for Economy.

A m e r i c a n t r u c k i n g i n d u s t r y c a n Save $ 10 Billions of Fuel cost by employing a new GreenPower TM DPF

- Hydrated EGR process that does not need ULSD & Urea to reduce PM &
NOx emissions.

F uel efficiency is related to global warming gas emission as well

- known. Not well

- known to the public is
, however, a thermodynamic theory that fuel efficiency is also related to the NOx emission level for heavy

- duty diesel engine combustion system . T herefore, any discussion of fue l efficiency can not be
defined until a new NOx level regulation is optimized for fuel

- efficiency, environmental benefits, and economy.

I would support the Administration ’ s fuel efficiency increase target of 15% for diesel engine and 10% for gasoline
vehicle . This can be achieved perhaps by employing a new process of GreenPower TM system patented in 2009 in the USA, an Award Winning T echn ology for marine diesel engines. The fuel saving by more than 10% is possible because the patented process utilizes a waste heat from the muff ler

.2

The 2007 PM

- NOx Emission Standard (not 2010 NOx standard) as our national target :

American trucking/automotive/oil industries have achieved a remarkable progress toward clean emis sion
as shown in the chart . Today ’ s (2007) trucks are much cleaner : in PM reduction by 98% and NOx reduction by 7 0% compared to old trucks ( per the 2007 NOx

- PM emissions standard). Up to 98% PM reduction was necessary to eliminate the toxic health threat by cancer

- causing PM nano

- particles, for which a Diesel Particulate Filter technology is employed. The DPF technology is now mandated for all heavy duty vehicles in the USA and throughout the world. A marine DPF system is also to be employed for Ocean Going Vess els, to reduce both PM and NOx emission from ships, for which demonstration p rogram the GreenPower TM DPF

- Hydrated EGR was
selected as a Grant Award Winner for marine diesel engines from the Port of Los Angeles (POLA)

. What level of NOx emission is good for both environment and economy? I propose the EPA adopts a new lower NOx red uction regulation to 40% for retrofits and 60% for the OEM ’ s, while keeping the PM reduction level by 90%. In the region of ports of Los Angeles and Long Beach , California

, where diesel pollution was considered as a serious public

- health threat, they h ave selected the 2007
PM

- NOx emission target as their environmental target.

E conomic Benefit to be realized by the new technology of GreenPower TM

1) $10 billions Fuel Cost Saving:
America n truckers can save fuel cost by $ 10 billions per year today by using a lower

- cost non

ULSD fuel, when the GreenPower TM technology is commercialized to be retrofitted on all diesel engine vehicles. It is because GreenPower TM system does not require “ ultra ” low

- S fuel. It can

use a 50

- ppm

- S fuel , for example, which is much cheaper than ULSD by about 8

- 10% of fuel

cost. In 2006, in retrospect, a ULSD was mandated as “ en

- abler ” for catalysts to function to
reduce PM emissions.

The current practice of ULSD

- DPF system was a very expensive national technology demonstration program to mandate the DPF system to work to reduce PM emission. Now it is
the time to re evaluate the techno logy option and fuel requirement again to reduce the costs.

It is because the c atalysts are not the pan acea for Ame rican truck in dustry any more. The fuel borne catalyst

- DPF system is commercialized in Eur ope, and is an alternative process to the conventional catalyst

- DPF system and the GreenPower DPF

- Hydrated EGR system can reduce the system cost further, while using a non

- ULSD fuel.

2) Increase Fuel Efficiency by 1 0 + % by utilizing waste heat to boil water to steam (rather than Urea chemical) as well as reducing NOx emission.3

Concluding Remarks :

1. The Energy, Environment, and Economy can be benefi tted by choosing the optimum level of
NOx emission

.

2. I p ropose t h e E P

A a d o p t s t h e 40% NOx level for retrofit and 60% for OEM.

3. T h e E P A a b a n d o n s the 2010 NOx regulation

.

4. American truckers c a n Save fuel cost by $10 billions per year by using GreenPower TM technology which requires a non

- ULSD, or che aper fuel without affecting our environment.

5. H e l p t o Commercialize the GreenPower TM technology, invented in the USA for America ’ s f u t u r e

.

Julius J. Rim, Ph.D., Inventor/Developer of GreenPower TM system

.

Nov 15, 2010, Chicago

www.autogreenpower.com :