1

Stout, Alan

From: Donald Nagy <donald.nagy@gm.com>

Sent: Monday, November 24, 2014 3:24 PM

To: Stout, Alan; Giedrius Ambrozaitis

Cc: Chris Nevers; Laroo, Chris; James S. Ehlmann; Andrew S. Barren

Subject: RE: Tier 3 Tech Amend DFR - one more item

Alan

Thanks for the explanation, I did not realize this E0 fuel was for non-road only, although this explains some confusion we

had wrt 86.113 vs 1065.710. Thanks

Donald B. Nagy

Professional Technical Fellow 

General Motors 

GM Proving Grounds

Building 31 West

3300 GM Road

Milford, Michigan 48380

Tel: 248-431-9540

Email: donald.nagy@gm.com

From: Stout, Alan [mailto:stout.alan@epa.gov] 

Sent: Monday, November 24, 2014 2:30 PM 

To: Giedrius Ambrozaitis 

Cc: Donald Nagy; Chris Nevers; Laroo, Chris 

Subject: RE: Tier 3 Tech Amend DFR - one more item

 

Giedrius,

The E0 fuel specified in Table 2 applies for nonroad engines/equipment. Manufacturers subject to nonroad standards 

have been certifying based on the specified E0 test fuel, which is a slight mismatch to the E0 test fuel in part 86. That 

was probably not intentional, but there it is. Making the change you suggest would harmonize our programs, but it 

would also have the effect of potentially invalidating existing nonroad certifications because we would be declaring 

some test fuel to be invalid by narrowing the allowable volatility range. We would also be (slightly) affecting the 

stringency of those emission standards, neither of which we can or should do in a direct final rule. We may consider 

revising this in a future proposed rule, which would give everyone opportunity to weigh in on the merits of making the 

change. We would more likely invest our efforts in migrating the nonroad testing to use the E10 test fuel specified in 

Table 1, but we will need to leave all that for another day.

Highway vehicle manufacturers are not in any way subject to testing using the E0 test fuel in Table 2, so I expect this will 

not pose any substantial trouble to Alliance members. 

Let me know if this raises any new questions or concerns.

Alan

From: Giedrius Ambrozaitis [mailto:gambrozaitis@autoalliance.org] 

Sent: Monday, November 24, 2014 1:30 PM 
2

To: Stout, Alan; Laroo, Chris 

Cc: Don Nagy; Chris Nevers 

Subject: Tier 3 Tech Amend DFR - one more item

 

Alan, Chris Laroo - 

One more item needing correction: 

 

1065.710(c) Table 2, Note 2, 

“For testing at altitudes above 1219 m, the specified initial boiling point range is (23.9 to 40.6) °C and 

the specified volatility range is (52.0 to 55.2) kPa ((7.5 to 8.0) psi).” 

 

52.0 kPa should be 52.4 kPa and 7.5 psi should be 7.6 psi. This would then be consistent with 86.113-

04(a) Table 1 note 5. 

Regards,

Giedrius

Alliance of Automobile Manufacturers

(248) 915-8836

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