UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

MAR 27 2007 

CISD -07- 07(LDV/LDT/MDPV/HDV/HDE) 

OFFICE OF 

AIR AND RADIATION 

Dear Manufacturer: 

SUBJECT: Certification Procedure for Light-Duty and Heavy-Duty Diesel Vehicles 

and Heavy-Duty Diesel Engines Using Selective Catalyst Reduction 

(SCR) Technologies 

I. Background 

On February 10,2000, EPA published the Tier 2 emission standards for light-duty 

vehicles and trucks. These standards established common, “fuel neutral” emission 

requirements for gasoline and diesel vehicles. They also set common standards for all 

passenger cars, light trucks, and medium-duty passenger vehicles. The Tier 2 standards 

allow emission averaging and require new vehicles to meet an average NOx emission 

level of 0.07 grams per mile (glmi). On January 18,2001, EPA published a rule setting 

stringent new requirements for heavy-duty highway engines and vehicles starting in 

2007. Manufacturers plan to meet these requirements by optimizing engine designs for 

low emissions and adding high-efficienc y aftertreatment. The diesel engine NOx 

standard, which is phased-in between model years 2007 and 2010, is 0.20 grams per 

brake horsepower-hour (g/bhp-hr). 

Diesel engine and vehicle manufacturers have examined the use of several different types 

of NOx reduction technologies in order to meet these requirements. One type of NOx 

reducing technology, selective catalyst reduction (SCR), is of particular interest to diesel 

manufacturers because it can achieve as high as 90% NOx conversion efficiencies. An 

SCR system uses a nitrogen containing reducing agent (usually ammonia or urea) 

injected into the exhaust gas upstream of the catalyst. The reducing agent needs to be 

periodically replenished. Without the reducing agent, the efficiency of the SCR catalyst 

drops to zero and NOx emissions can increase substantially. 

The purpose of this letter is to discuss our intended approach for the certification of lightduty and heavy-duty diesel vehicles and heavy-duty diesel engines using SCR systems. 

The information in this letter reflects our current thinking. We recognize that SCR 

technology is still evolving and reserve the right to make any necessary changes to our 

approach for certification of light-duty and heavy-duty diesel vehicles and heavy-duty 

diesel engines using SCR systems that we deem appropriate. We also recognize that 

efforts currently underway by manufacturers, including infrastructure development, could 

help address some of the issues raised in this guidance prior to EPA’s review of 

individual certifications. 

Internet Address (URL) http://www.epa.gov 

RecycledlRecyclable Printed with Vegetable Oil Based Inks on 100% Postconsumer, Process Chlorine Free Recycled Paper 
II. Regulatory Requirements 

There are several regulatory requirements that can impact the certification and 

implementation of SCR for light-duty and heavy-duty diesel vehicles and heavy-duty 

diesel engines. Two requirements of particular importance are: 

40 CFR §86.004-25, §86.094-25 & §86.1834-01 Allowable Maintenance; and 

40 CFR §86.094-22 & §86.1833-01 Adjustable Parameters 

A. Allowable Maintenance 

Maintenance performed on vehicles, engines, subsystems, or components used to 

determine exhaust, evaporative, or refueling emission deterioration factors is classified as 

either emission-related or non-emission-related, and as either scheduled or un-scheduled. 

EPA considers service operations performed on SCR systems and which meet the 

definitions of “emission-related maintenance” at §86.088-02 and §86.1803-01 and 

“scheduled maintenance” at §86.082-2 and §86.1803-01 to be emission-related scheduled 

maintenance. Emission-related scheduled maintenance is considered technologically 

necessary to ensure in-use compliance with the emission standards. Manufacturers must 

determine the technological need for maintenance using good engineering judgment. 40 

CFR §86.094-25(b)(3) and (4) and §86.1834-01(b)(3) and (4) establish minimum 

allowable maintenance intervals for various emission-related technologies. EPA 

determined that emission-related maintenance at intervals shorter than those listed in 

paragraphs (b)(3) and (4) are not technologically necessary. However, there is a 

provision in paragraph (b)(7) that allows a manufacturer to request a change to the 

scheduled maintenance interval, including an interval shorter than prescribed in (b)(3) 

and (4). 

For diesel-cycle light-duty vehicles and light-duty trucks, emission-related maintenance, 

such as the adjustment, cleaning, repair or replacement of the catalytic converter can not 

occur before 100,000 miles of use or before 100,000 mile intervals thereafter. For dieselcycle heavy-duty engines, emission-related maintenance can not occur before 100,000 

miles of use or before 100,000 mile intervals thereafter for light heavy-duty engines, or 

before 150,000 mile intervals thereafter for medium and heavy heavy-duty engines. 

Since the SCR catalyst does not function without the use of a reducing agent, we believe 

40 CFR §86.1834-01(b)(4)(ii)(F) and §86.004-25(b)(4)(iii)(F) would apply to the SCR 

catalyst and all of the associated hardware, including but not limited to, the reducing 

agent, the reducing agent storage tank, the dosing valve, and all lines and hoses. Because 

of packaging constraints, many manufacturers have indicated that they would not be able 

to equip their vehicles with reducing agent storage tanks of sufficient size to allow for 

minimum reducing agent refill intervals that meet the required intervals of 100,000 or 

150,000 miles. 

In order for EPA to consider a change to the scheduled maintenance interval per 

paragraph (b)(7), the Administrator must approve a request for approval indicating that 

the requested change in maintenance schedule is “new,” meaning the maintenance did not 

exist prior to the 1980 model year, and that the new maintenance interval is 

technologically necessary. If EPA approves a request for new scheduled maintenance, 

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the Agency must announce in the Federal Register the designation of emission-related 

maintenance items, along with their identification as critical or non-critical, and the 

establishment of the technologically necessary maintenance intervals. Unless 

manufacturers can develop an SCR system that only requires the replenishment of the 

reducing agent every 100,000 miles for light-duty and 150,000 miles for heavy-duty, it 

appears that manufacturers wanting to use SCR technology will have to request a change 

to scheduled maintenance per 40 CFR §86.1834-01(b)(7) or §86.094-25(b)(7). It may be 

appropriate for EPA to approve an industry-wide scheduled maintenance change, as we 

have done previously in similar situations. 

B. Adjustable Parameters 

40 CFR §86.094-22 and §86.1833-01 authorize EPA to determine those vehicle or engine 

parameters that will be subject to adjustment for emissions testing purposes. Paragraphs 

§86.094-22(e)(1) and §86.1833-01(a)(1) discuss how the Agency determines which 

parameters are subject to adjustment. Specifically, the paragraphs state “The following 

parameters may be subject to adjustment: the idle fuel-air mixture parameter on Ottocycle vehicles; the choke valve action parameter(s) on carbureted, Otto-cycle vehicles (or 

engines); or any parameter on any vehicle (Otto-cycle or diesel) which is physically 

capable of being adjusted, may significantly affect emissions, and was not present on the 

manufacturer’s vehicles (or engines) in the previous model year in the same form and 

function.” The Administrator can also determine other parameters to be subject to 

adjustment under §86.094-22(e)(1)(ii) and §86.1833-01(a)(1)(ii) but must provide notice 

and lead time 

It is important to test a vehicle for emissions over the full range of an adjustable 

parameter because EPA needs to ensure that the emission performance in-use is as good 

as at certification. Since some emission components and/or systems can be adjusted, 

there is a concern that the vehicle could be operated at settings other than the 

manufacturer’s recommended setting possibly resulting in emissions levels that could 

exceed the emission standards. Paragraphs §86.094-22(e)(2) and §86.1833-01(a)(2) state 

that a parameter may be determined to be adequately inaccessible or sealed. If a 

parameter is determined to be adequately inaccessible or sealed, the vehicle will only be 

emission tested at the actual settings to which the parameter is adjusted during 

production. Paragraphs §86.094-22(e)(2)(iv) and §86.1833-01(a)(2)(iv) state that in 

determining the adequacy of a physical limit, stop, seal, or other means used to inhibit 

adjustment of a parameter not covered by paragraph (a)(2)(i) or (ii) of this section, the 

following shall be considered: the likelihood that it will be circumvented, removed, or 

exceeded on in-use vehicles. 

Because the NOx efficiency and thus the NOx emissions performance of an SCR system 

is so dependent on a nitrogen-containing reducing agent, it is critical that a vehicle using 

SCR never operate without the reducing agent. Most SCR system designs rely on storing 

reducing agent in a tank located on the vehicle and on the vehicle operator taking 

responsibility for refilling the tank with reducing agent. This means that the vehicle 

operator has to be made aware that reducing agent needs to replaced and that reducing 

agent is available. Without a mechanism to inform the vehicle operator that the reducing 

agent needs to be replaced, and without a readily available source of replacement 

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reducing agent, there is a high likelihood that the adjustable parameter will be 

circumvented or exceeded on in-use vehicles. Therefore, we do not believe that an SCR 

system that requires the vehicle operator to replace the reducing agent can be considered 

to be adequately inaccessible or sealed. 

As a result, it appears to EPA that an SCR system utilizing a reducing agent that needs to 

be periodically replenished would meet the definition set forth in paragraphs §86.094­

22(e)(1) and §86.1833-01(a)(1) and could be considered an adjustable parameter by the 

Agency. This means that we have the authority to test an SCR-equipped vehicle with 

varying levels of reducing agent in the storage tank, or, theoretically, without any 

reducing agent at all. If the vehicle is capable of meeting the NOx standard without any 

reducing agent, we would not consider the SCR system to be in violation of the standard. 

However, if the vehicle exceeds emissions standards without reducing agent in the tank, 

we expect that we would deny the certification because the design will be considered 

unacceptable. If the manufacturer can prove to EPA that their SCR system design will 

not run out of reducing agent in-use and thus not exceed the emission standards, we may 

determine that the design is acceptable and approve certification of the vehicle design. 

The remainder of this guidance document discusses the acceptance criteria EPA will 

apply to assure that diesel vehicles or engines using SCR technology achieve the Agency 

goal of always meeting emission standards in-use. 

III. Adjustable Parameter Acceptance Criteria 

We have based our SCR adjustable parameter acceptance criteria on the Agency’s goals 

of ensuring that SCR-equipped vehicles control emissions in use and, more specifically, 

that the reducing agent is readily available for and used in these vehicles wherever and 

whenever they need it. We have divided the acceptance criteria into two categories: 

• Vehicle compliance – 

o Ensure that vehicles are designed to meet the emission standards in-use 

and that drivers will not operate the vehicle with empty reducing agent 

tanks. 

• Reducing agent availability and accessibility – 

o Ensure that drivers will find SCR-quality reducing agent when they need 

it. 

In addition, while not a specific acceptance criterion, we believe it will be important for 

manufacturers to educate potential users, service industry representatives, and other 

stakeholders about SCR systems and their special needs. These efforts would be in 

addition to the required vehicle labeling and owner’s manual information that is already 

provided. 

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A. Vehicle Compliance 

The vehicle compliance criteria are divided into five different categories. Manufacturers 

must satisfy all five categories. The categories are as follows: 

1. Driver warning system 

2. Driver inducement 

3. Identification of incorrect reducing agent 

4. Tamper resistant design 

5. Durable design 

1) Driver Warning System. The emissions performance of SCR-equipped vehicles is 

expressly reliant on having reducing agent in the system. Unlike all other major emission 

control devices, SCR systems require regular user interaction to ensure the system is 

operating properly. It is thus critical that the operator both know when reducing agent is 

needed and have enough time to replace it before it runs out. A properly designed driver 

warning system should help address these concerns. Manufacturers would need to use a 

warning system consisting of visual and possibly audible alarms informing the vehicle 

operator that reducing agent level is low and must soon be replenished. The warning 

system would need to escalate in intensity as the reducing agent level approaches empty, 

culminating in driver notification that cannot be defeated or ignored, and cannot be 

turned off without replenishment of the reducing agent. To provide appropriate notice, 

the visual portion of the warning system would, at a minimum, need to consist of a 

unique light or message indicating low reducing agent level. The light or message should 

be located on the dashboard or in a vehicle message center. The warning light or 

message would need to be different from the “check engine” or “service engine soon” 

lights used for OBD or other maintenance. The symbol or message used as the warning 

indicator would need to unmistakably communicate to the vehicle operator that the 

reducing agent level is low. The warning light or message does not initially have to be 

continuously activated, but we would anticipate that as the reducing agent level 

approaches empty the illumination of the light or message would escalate, culminating 

with the light being continuously illuminated or the message continuously broadcast in 

the message center. All unique SCR system warning lights or messages would need to be 

approved by EPA. The location of the warning light or message also would need to be 

approved by EPA. 

Manufacturers should also consider an audible component of the warning system. We 

would expect that as the reducing agent level approaches empty the audible warning 

system would escalate. 

We also anticipate that manufacturers would design the warning system to activate well 

in advance of the reducing agent running out. Depending on the range between reducing 

agent refills ( a function of reducing agent storage tank size, reducing agent dosing rate, 

fuel consumption, and NOx generation), the warning system for light-duty vehicles 

should begin to activate, at approximately 1,000 miles prior to the reducing agent tank 

becoming empty. For heavy duty diesel vehicles we understand that factors in addition to 

those mentioned above affect the time between reducing agent refills. Vehicle weight 

class and the current load being carried also affect the reducing agent refill intervals, but 

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even given this variability, we believe that the warning system should begin soon enough 

for the operator to have adequate opportunity (e.g., two refuelings) to also refill the 

reducing agent. The Agency may approve initiation of the warning system at shorter or 

longer periods if the manufacturer can demonstrate that shorter or longer periods are 

reasonable. 

2) Driver Inducement. The warning systems discussed above are a critical part of the 

vehicle compliance acceptance criteria. As noted a well designed warning system should 

prevent people from operating SCR-equipped vehicles without reducing agent. However, 

we believe an additional, even stronger deterrent will be. Therefore, some last-resort, 

persuasive measures to induce users to replenish the reducing agent will be essential 

A number of methods could be employed by manufacturers to induce users to replenish 

the reducing agent before the tank becomes empty. The design or mechanism used will 

ultimately be up to each manufacturer. While EPA will not prescribe a specific driver 

inducement design necessary to meet our acceptance criteria, we believe the examples 

below could satisfy our objective for driver inducement designs. Our objective is 

straightforward. The driver inducement design must be robust and onerous enough to 

ensure that users will not operate the vehicle without reducing agent in the vehicle if they 

ignore or deactivate the warning system. The driver inducement mechanism should not 

create undue safety concerns. 

The following are some examples of driver inducement methodologies that we 

understand manufacturers are analyzing as part of their overall system designs. We 

believe other options that can meet our overall objectives could be feasible, and we will 

work with manufacturers as they develop their designs to help address any appropriate 

certification issues. Certification approval will be based on the overall effectiveness of 

the deterrents. EPA will not mandate systems that compromise vehicle performance. 

One group of options focuses on prohibiting vehicle operation if reducing agent is not 

present. A “No-Engine Restart after Restart Countdown” approach allows a limited 

number of restarts once the reducing agent range reaches a certain minimal level of miles 

before the vehicle is unable to restart without the reducing agent tank being replenished. 

A “No-Start after Refueling” system has the vehicle unable to start after a refueling that 

has occurred and the reducing agent range is below a certain level (e.g. the typical range 

of a single tank of fuel). Lastly, a “Fuel-Lockout” approach has the fuel filler system 

lock out, preventing the user from being able to refuel the vehicle after the reducing agent 

range drops below a certain level (e.g. the typical range of a single tank of fuel). The 

lockout mechanism would need to be robust, for example, not just a locked fuel door that 

can be pried open. Systems such as these can all operate while some reducing agent 

remains in the storage tank, thus ensuring emissions controls during all vehicle operation 

times. 

Another way to make sure vehicle operators are adding reducing agent when appropriate 

is to have vehicle performance degraded in a manner that would be safe but would be 

onerous enough to discourage the user from operating the vehicle until the reducing agent 

tank was refilled. The key challenge of this approach is to determine what would 

constitute an acceptable performance degradation strategy. A degradation approach 

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which maintains vehicle or engine compliance with the emissions requirements helps 

address this concern. Additionally, use of this approach in combination with another 

system could be more appropriate. 

3) Identification of Incorrect Reducing Agent. It is also imperative that the SCR 

system design be able to detect incorrect reducing agent. The system must be able to 

identify and appropriately respond to a high NOx emissions performance level associated 

with filling the storage tank with a fluid other than the manufacturer-specified reducing 

agent, or with excessively diluted reducing agent. An example would be filling the tank 

with water rather than the specified reducing agent (e.g., urea). Possible mechanisms to 

address and implement this concern include NOx sensors or urea sensors. 

We believe it is appropriate that the vehicle respond in the same manner when incorrect 

reducing agent is detected as when the vehicle runs low on reducing agent. Thus, once 

this condition is recognized, the vehicle’s warning system would engage for a limited 

time before triggering the driver inducement (e.g., no-start, fuel lockout, performance 

degradation, etc.) system. This should allow the operator time to refill the tank with 

proper reducing agent, or, in more serious instances, to obtain vehicle service. 

It is possible that reducing agent quality and resulting SCR performance may vary 

somewhat. However, we believe that industry-wide quality specifications will largely 

address this issue. At this time we do not believe it is necessary to require SCR systems 

to identify slight differences in reducing agent quality. 

4) Tamper Resistant Design. Manufacturers would have to demonstrate to EPA that 

their SCR system design is tamper resistant. There are three aspects of a design that we 

would want to see made tamper resistant: 

• Warning System - The visual and audible components of the warning system 

should be as tamper resistant as reasonably possible. 

• The Driver Inducement Design - Tamper resistant features will be needed to 

ensure that the driver inducement system cannot be easily disabled. The 

specific requirements will depend on the driver inducement design. For 

example, the fuel door cannot be pried open for a fuel lockout system or the 

ability to start the vehicle with no reducing agent for a no-start design. 

• The Reducing Agent Dosing System - Ensure that the dosing system cannot 

be easily deactivated, for example, by disconnecting the electrical connector 

to the dosing valve. 

5) Durable Design. Manufacturers would have to demonstrate to EPA that their SCR 

system design is durable. This can be accomplished through the normal certification 

durability process. For light-duty vehicles, this means a showing of compliance over 

120,000 miles, or 150,000 if manufacturers choose to certify to the higher levels. 

Currently, our light-duty durability requirements require diesel vehicles to undergo 

whole vehicle testing. Whole vehicle testing should ensure that the SCR catalyst, dosing 

system, reducing agent storage tank, and lines and hoses are durable. For heavy-duty 

engines, the useful life is dependent on different classifications. For light heavy-duty 

diesel engines, the useful life is 110,000 miles. For medium heavy-duty diesel engines, 

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the useful life is 185,000 miles, and for heavy heavy-duty diesel engines, the useful life 

is 435,000 miles. At this time for heavy-duty engines we intend to address the durability 

of the SCR system components when deterioration factors are established at 

certification. 

B. Reducing Agent Availability and Accessibility 

The SCR system requires a reducing agent to function properly. Since vehicle operators 

will be responsible for refilling the reducing agent tank, it is imperative that the reducing 

agent be readily available to consumers. Sufficient and convenient availability of the 

reducing agent is essential to meet these objectives. Sufficient availability requires 

widespread distribution across the United States. Convenient availability requires the 

reducing agent to be offered at locations that are easy to find and that would occur 

during the vehicle operator’s normal course of business or operation (e.g., commuting to 

work, going on vacation, transporting and delivering goods, and operation outside the 

scope of normal business hours). We believe that this can be best achieved by relying 

on a combination of reducing agent availability schemes, some of which are discussed 

below. We believe it is also important to ensure that SCR vehicle operators have 

opportunities to go beyond a specific OEM network to obtain reducing agent. We 

understand industry stakeholders are working on such broader availability mechanisms 

and we encourage these efforts. 

Approval criteria for manufacturer’s plan for reducing agent availability and 

accessibility. 

EPA will review a manufacturer’s plan for reducing agent availability and accessibility. 

It is their responsibility to show that reducing agent will be widely available and readily 

accessible. EPA will in particular review whether the following procedures are or will 

be in place: 

1. Reducing Agent Available at Dealerships. The manufacturer supplies its dealers with 

the appropriate reducing agent and uses best efforts to ensure that they will have 

adequate supplies to ensure that any and all of their customers who need the reducing 

agent will have access to reducing agent within a reasonable time through the dealership. 

2. Reducing Agent Available at Truckstops. We understand that heavy duty vehicles 

will routinely refuel and procure reductant at truckstops and similar facilities, rather than 

at the manufacturer’s distributor. Therefore, it will be important for manufacturers to 

demonstrate either individually or as part of a collective effort that it will be reasonable 

for truck operators to obtain reductant at truckstops or other fueling locations when they 

stop to refuel. EPA’s review will look at the overall infrastructure for the particular 

class of vehicles. 

3. Back-Up Plan. The manufacturer provides a back-up plan, such as a toll-free phone 

number, that customers can call if they need reducing agent but are unable to obtain it 

from a dealership or other convenient source. The back-up plan needs to provide quick 

turn around, such as overnight delivery to the consumer in response to a call to the tollfree number. 

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Manufacturers should also be able to demonstrate that reducing agent will be available 

at other commercial outlets. Such outlets will be considered to be, but not limited to, 

fueling stations, quick oil change facilities, repair and service facilities, and retail outlets 

(e.g., automotive part stores and large retail stores). As the number of SCR-equipped 

diesel vehicles grows, the need for additional outlets will also increase. 

C. Education and Outreach for Potential Owners and Service Industry 

SCR relies on the vehicle operator to periodically replenish the reducing agent to ensure 

the emission control system properly functions. Thus, it is incumbent upon the 

manufacturer to educate potential owners about these requirements. We believe 

manufacturers will need to develop and implement an education plan for prospective 

vehicle owners, dealership staff, including sales and service personnel, aftermarket 

service facilities, fueling station staff, quick oil change facilities staff, retail staff, and any 

other groups or individuals that would be involved in the purchase or sales of SCRequipped vehicles, the service of SCR-equipped vehicles, or the sales of reducing agents 

(such as urea) to the public. The following are examples of the type of information EPA 

anticipates manufacturers would need to provide to demonstrate their public education 

strategies: 

• Explanation as to what an SCR system is, how it works, and why it is important 

that the reducing agent be periodically replenished. 

• What is the reducing agent used? Where does it go in the vehicle? 

• Where can consumers purchase the reducing agent? How much will it cost? Is it 

safe to handle? 

• How often does the reducing agent have to be replenished? 

• How does the vehicle operator refill the reducing agent tank? 

• Explain any potential odors associated with the reducing agent. 

• Explain how the warning systems work. 

• Explain consequences of ignoring warning system and not replenishing reducing 

agent. 

• Other 

The following are examples of where the above information could be provided to the 

public: 

• Owners manual 

• Service manual 

• Vehicle message center 

• Visor 

• Fuel door or cap 

• Reducing agent storage tank door or cap 

• Company web site 

• Dealership brochures 

• Sales agent and service technician training manuals 

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111. Additional Certification Issues 

A. Reducing;Agent Ouality Specifications 

Vehicle manufacturers should establish an industry-widereducing agent quality standard 

and set specifications. In order to ensure proper operation, manufacturers will need to 

design SCR systems for the general range of commercially available reducing agents, 

thus showing the importance of having a defined set of reducing agent specifications. 

As with other parameters, EPA testing will be based on the same. 

It is also important that a common industry-widereducing agent should be clearly and 

unambiguously identified, regardless of any brand name that is trademarked by a 

manufacturer. Similar to motor oils available today, consumers must be easily able to 

identify that the product they are purchasing can be used for their vehicle regardless of a 

brand name. An example of this is the American Petroleum Institute (API) “Staburst” 

logo used for motor oils. 

B. Freeze Protection 

The reducing agent should not be adversely affected by extreme climatic conditions, 

particularly freezing temperatures. Some reducing agents freeze at temperatures that 

occur seasonally in certain parts of the U.S. Urea, for example, freezes at 11°F. 

Manufacturers need to either use a reducing agent that will not freeze at low 

temperatures, or design their SCR system to prevent freezing (e.g., use of heater 

elements in or around the storage tank and heated lines). Manufacturers who use a 

heated SCR system need to ensure that minimal “thaw” time is required to melt enough 

reducing agent to recharge the system, should the reducing agent freeze due to extensive 

exposure to low temperatures. 

C. Reducing Agent Refilling Interval 

The reducing agent refilling interval will ultimately be determined by the manufacturer. 

EPA encourages manufacturers to adopt the longest interval reasonably possible. Since 

the refilling interval falls under allowable maintenance, the process for determining what 

would be an acceptable refilling interval for the reducing agent will be handled under the 

provision of 86.1834-0l(b)(7) for light duty and @36.094-25(b)(7)for heavy duty, as 

discussed above. 

n 

pp- Acting Dir tor 

Compliance and Innovative StrategiesDivision 

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