EPA Proposed Phase II GHG Regulations and Standards: Questions and Comments from American Power Group Inc. (APG) APG Address : 2503 E Poplar St, Algona, Iowa, 50511, www.americanpowergroupinc.com, APG/EPA interface: Bob Natkin, Chief Engineer, rnatkin1@att.net, (734) 657-5651 {mobile#), {734) 454- 1068 (fax#) 1) Question: For a Small Vo lu me Manufacturer {SVM) of Clean Alt Fuel and/or M ixed - Fuel After-market Upfit Conversion Systems, how are the proposed Phased II GHG regulations to be applied to:
• OUL approval criteria: " same -as" or lower exhaust emission relative to OE "diesel -fuel-only" {baseline) at the OUL vehicle mileage tested o C02: expected to be reduced for the Alt Fuel conversion o N20: expected to be same as or reduced for the Alt Fuel conversion o CH4: expected to increase for all Aft-Fuel conversions (please see #5 commentary) • IUL approval criteria: Must meet all relevant exhaust emission standards w/ OF's or ADF's applied. 2) Question: Can a Small Vo l ume Manufacturer (SVM) of Clean Alt Fuel and/or Mixed - Fuel After- market UpFit Conversion Systems accrue emission credits? 3) Question: As the proposed C02 standards reduction for Heavy-Heavy Duty-Tractor/Vocational, (and therefore FE increases) for M.Y.'s groupings of [2017- 2020], [2021-2023], [2024-2026], [2027 and later] are reducing by 3.15%, 1.52%, 2.2 %, 0.45% respectively for HHD-Tractor and by 2.12%, 1.98%, 1.47%, 0.56% respectively for HHD-Vocational (or FE is increasing by the same percentages listed) and C02 reduction/FE increases will be manifested through both eng in e efficiency improvements and vehicle efficiency improvements (tires, aero, etc), and as the C02 exhaust emission values are determined by engine dynamometer tests {RMC13: HHD-Tractor or FTP- HDT: HHD-Vocational) , 

### how is the EPA proposing to reflect the vehicle efficiency improvements within the respective M. Y . engine dyna testprocedures? Will 

### there be a modification to the testparameters and/or a correctionfactor applied? 4} With respect to§ 86.1819-14 Greenhouse gas emission standards for heavy-duty vehicles: Vehicles produced by small businesses may be excluded from the standards of this section as described in paragraph (k)(5}; Provisions for small manufacturers. Standards app ly on a delayed schedule for manufacturers meeting the sma ll business criteria specified in 13 CFR 121.201. Apply the small business criteria for NAICS code 336111 for vehicle manufacturers and 

### 811198 for companiesperforming fuel conversions with v ehi cles manufactured by a different company. for "Heavy Duty Truck Manufacturing" Qualifying rna nufacturers 

### are notsubject to the greenhouse gas standards of this sectionfor vehicles built before January 1, 2019 §§1037.104 through 1037.106, as specified in 40 CFR 1037.150(c)this paragraph (c). The employee and revenue limits apply to the total number employees and total revenue together for affiliated companies. In addition, manufacturers producing vehicles that run on any fuel other than gasoline, E85 , or diesel fuel may 

### delay complying with every new standard under this port by one model year. (Jan 12020}. And, with respect to§ 1036.150 Interim provisions: (d) Small manufacturers. Standards apply on a delayed schedule for manufacturers meeting the small business criteria specified for "Gasoline Engine and Engine Parts Manufacturing" or "Other Engine Equipment Manufacturers" in 13 CFR 121.201. Apply the small business criteria for NAICS code 336310 for engine manufacturers with respect to gasol in e-fue led engines, 333618 fo r engine manufacturers with respect to other engines, and 

### 811198 with respect to fuel conversions with engines manufactured by a different company. 

### Qualifying manufacturers are notsubject to the greenhouse gas emission standards in § 

### 1036 . 108 for engines builtbeforeJanuary 1, 2022. In addition, qualifying manufacturersproducing engines that run on any fuel other than gasoline, E85, or diesel fuel may delay complying with every newstandard under this part by one modelyear. (Jan 1 2023}

### It would appear the SVM converting gasoline {SI) engines to Alt-Fuel are exempt from GHG standards until 2023, whereas the SVM converting HDDE (CI) engines to Alt-Fuel are exempt from GHG standards until 2020, is this true, if so why the discrepancy betw een HDDE C/ converters and51 converters? 

### 5) Commentary: The CH4 proposed standard of 0.1 g/hp-hr should not be a challenge for OE diesel fueled, lean burn, stratified ch arge HHDD engine manufacturers as there is no NG or CH4 within their combustion fuel. Furthermore with their stratified charge combustion strategy, there should be little to no HC within the combustion chamber crevice and quench volumes during the combustion stroke
.

Altern atively, for a converted Alt-Fuel engine, both Sl and Cl, dedicated NG, Bi-Fuel and Mixed -Fuel, the Air/NG mixture is pre-mixed and therefore more homogenous so there will be Air/NG mixture within th e com bu stion chamber crevice and quench volumes, which will result in CH4 exhaust emissions
. Current HDDE converted engines listed in the EPA dat a-base are showing CH4 exhaust emissions of- 1-2 g/h p-hr and the most s tratified Mixed- Fuel system, the Westport HPDI s ystem, has reported CH4 exhaust em issions (CEC-500-20 13-128, April 2011) , of - 1 .0g/hp-hr
.

For a converted Mixed-Fuel HDDE engine, the exh aus t gas temps duri ng the FTP-HDT and RMC 1 3 tests reach a maxi mum of 

## -40oc and only during the max load portions of the test cycle. It i s well understood that a hig hly load ed oxidation catalyst need s operating temperatures of 585C to attain max oxidation rates of .. 85% . As 

### the Alt-Fuel conversion manufacturers typically do not change the base engine design/configuration (to reduce combustion chamber crevice volum e) and the after-treatment systems do not reach appropri ate temps during the EPA test cycles, {please see EGT data figures below) to achieve 85% oxidation in an HDDE application, it is expected that without some consideration or regulatory relief for the Alt- Fuel conversion companies, the use of NG for a transportation fuel will be se riously curtailed. Even using the proposed GHG equivalence provision (1 CH4 

### = 25 C02), there may not be enough C02 reduction to show compliance with th e proposed GHG equivalence provision . Lxhau:.t Temperature
- Ilca\'y-dut: Transicnt
- Cold Start

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### Figure 1 Exhaust Gas Temps (EGT): FTP- Heavy Duty Transient Cycle- Cold Startwo**3~0**
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### ,,,**[xhau~t** Temperature - !Teavy-duty Transient
- llot Start

.:JI) ('.)0 Figure 2 Exhaust Gas Temps (EGT) : FTP-Heavy Duty Transient Cycle-Hot Start l:xhaust l.:mp.:101tur.:
- I:>-motk RMC Cyck

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l'Ut lm1.: ,, _'OUI Figure 3 Exhaust Gas Temp (EGT): RMC 13 •IllNote :All EGT test data (Figurel -3) from APG IUL Approval Submission Data for Mixed-Fuel system EAPG H 12.8VPA fo r EFN AVPTH012.8S01 appl ication. 6) Question: APG is currently engaged in capturing, filtering and conditioning well head gas to harvest the methane, propane and butane contai ned in what has been considered a waste gas by the exploration and product i on (E 

### & P) companies. Over 70 pe rcent of APG's dual-fuel stationary oi l rig conversions are operating on conditioned well head gas, and an APG custo m er has six drilling rigs operat i ng successfully on high - BTU conditioned wellhead/flared gas in the Bakken. 

### Can APG receive any GHG "cr edit s"for the reduct ion in esc aped andflared methane that is being harvestedfor useful work appli c

ations?