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### 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; Andre w 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 nonroa d engines/equipment. Manufacturers subject to nonr oad standards have been certifying based on the specified E0 test fuel, which is a slight mismatch to the E0 test fu el in part 86. That was probably not intentional, but there it is. Mak ing the change you suggest would harmonize our prog rams, but it would also have the effect of potentially invalidat ing existing nonroad certifications because we woul d be declaring some test fuel to be invalid by narrowing the allow able 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 woul d give everyone opportunity to weigh in on the meri ts 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 ano ther day.

Highway vehicle manufacturers are not in any way su bject to testing using the E0 test fuel in Table 2, so I expect this will not pose any substantial trouble to Alliance member s.

Let me know if this raises any new questions or con cerns.

Alan

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

Sent: Monday, November 24, 2014 1:30 PM2 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 specifi ed 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

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