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 Volume 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 Volume 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 engine 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 test procedures? Will 

there be a modification to the test parameters and/or a correction factor 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 apply on a delayed schedule for manufacturers 

meeting the small business criteria specified in 13 CFR 121.201. Apply the small business criteria for NAICS 

code 336111 for vehicle manufacturers and 811198 for companies performing fuel conversions with 

vehicles manufactured by a different company. for "Heavy Duty Truck Manufacturing" Qualifying 

rna nufacturers are not subject to the greenhouse gas standards of this section for 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 gasoline-fueled engines, 333618 for engine manufacturers 

with respect to other engines, and 811198 with respect to fuel conversions with engines manufactured 

by a different company. Qualifying manufacturers are not subject to the greenhouse gas emission 

standards in § 1036.108 for engines built before January 1, 2022. In addition, qualifying 

manufacturers producing engines that run on any fuel other than gasoline, E85, or diesel fuel may 

delay complying with every new standard under this part by one model year. (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 between HDDE C/ converters and 51 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 charge 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. 

Alternatively, 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 the 

combustion chamber crevice and quench volumes, which will result in CH4 exhaust emissions. Current 

HDDE converted engines listed in the EPA data-base are showing CH4 exhaust emissions of- 1-2 g/hp-hr 

and the most stratified Mixed-Fuel system, the Westport HPDI system, has reported CH4 exhaust 

emissions (CEC-500-2013-128, April 2011), of - 1.0g/hp-hr. 

For a converted Mixed-Fuel HDDE engine, the exhaust gas temps during the FTP-HDT and RMC 13 tests 

reach a maximum of -40oc and only during the max load portions of the test cycle. It is well understood 

that a highly loaded oxidation catalyst needs 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 volume) and the after-treatment systems 

do not reach appropriate 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 

seriously curtailed. Even using the proposed GHG equivalence provision (1 CH4 = 25 C02), there may not 

be enough C02 reduction to show compliance with the proposed GHG equivalence provision. 

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Figure 2 Exhaust Gas Temps (EGT): FTP-Heavy Duty Transient Cycle-Hot Start 

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Figure 3 Exhaust Gas Temp (EGT): RMC 13 

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Note :All EGT test data (Figurel-3) from APG IUL Approval Submission Data for Mixed-Fuel system 

EAPGH12.8VPA for 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 contained in what has been considered a waste gas by the exploration and 

production (E & P) companies. Over 70 percent of APG's dual-fuel stationary oil rig conversions are 

operating on conditioned wellhead gas, and an APG customer has six drilling rigs operating successfully on 

high-BTU conditioned wellhead/flared gas in the Bakken. Can APG receive any GHG "credits" for the 

reduction in escaped and flared methane that is being harvested for useful work applications?