1 

### Stout, Alan

From: steven.j.horetski@gm.com
Sent: Wednesday, June 19, 2013 10:47 AM
To: Stout, Alan
Cc: Glodich, Jeffrey (J.M.); Middleton, Kenneth (K.C.); Steve Douglas; Bill Blomquist Subject: RE: HD evap testing

Alan,

I checked with all the HD OEMs we sell gasoline eng ines to and most support the move to point at the L D evap test procedures and LD-UDDS for HD evap testing. The ex ception to this is Freightliner. Apparently when t hey conducted their evap testing they utilized the HD-UDDS. Sinc e HD product designs remain unchanged for long time periods they unfortunately will require some type of protracted carryover or grandfather provisions. I don't know if you can just include some type of statement to indicate that EPA views t he optional use of the HD-UDDS for HD evap testing as functiona lly equivalent to the LD-UDDS.

Best regards,

Steve Horetski Total Compliance Engineer - Evaporative Emissions GM Powertrain - Compliance & Certification

248.444.7286 steven.j.horetski@gm.com

From: "Stout, Alan" <stout.alan@epa.gov>
To: "Middleton, Kenneth (K.C.)" <kmiddle1@ford.com>
Cc: "Glodich, Jeffrey (J.M.)" <jglodich@ford.com>, Stev e Douglas <sdouglas@autoallianceissues.com>, Bill B lomquist <William.Blomquist@chrysler.com>, "steven.j.horetski@gm.com" <steven.j.horetski@gm.co m>, "Whitbeck, Neil (N.G.)" <nwhitbec@ford.com>, "O kafor, Chijioke (A.)" <cokafor@ford.com>, "Walkowicz, Erin (E.A.)" <ewalkow2@ford.com>, "Moul is, Charles" <moulis.charles@epa.gov>
Date: 06/17/2013 01:43 PM Subject: RE: HD evap testing

Ken, That is helpful. We won’t be changing the high-alt itude provisions in §86.1829-01; the text you noted (and the associated implementation practice) will continue to apply. W e are re-writing all the high-altitude test waiver in §86.1829- 17 for Tier 3 to apply
generically for all vehicles meeting standards unde r subpart S (copied below from the NPRM, for refere nce).

I confirmed that the allowance for the light-duty d riving schedule for HD vehicles was a change from t he original enhanced evap procedures. Someone added §86.1215-85(a)(2) in 200 0 to add in the alternate driving schedule. I didn ’t find that since it should
have been written to apply more broadly to cover th e whole procedure. This isn’t necessarily a proble m, but any little differences
that would have accumulated between subparts B and M would be preserved under the alternate testing s that is currently written.
What I would have done then, and what we will do n ow, is to move away from subpart M entirely and pro vide the simple
instruction to use the subpart B procedures to test just like LDV (except for omitting the exhaust meas urement).

I think we’re clear on these issues. That just lea ves us to figure out whether we need any lead time or carryover provisions.

Alan

_______________2 

### §86.1829-17 (c) The manufacturer must demonstrate compliance wi th emission standards at low-altitude conditions as described in paragraph (b) of this section. For st andards that apply at high- altitude conditions, the manufacturer may either perform the same tests or provide a stat ement in the application for certification that, ba sed on an engineering evaluation of appropriate testing to me asure or simulate high-altitude emissions, all vehi cles comply with applicable emission standards at high a ltitude.

From: Middleton, Kenneth (K.C.) [ mailto:kmiddle1@ford.com ]

Sent: Monday, June 17, 2013 11:27 AM

To: Stout, Alan

Cc: Glodich, Jeffrey (J.M.); Steve Douglas; Bill Blomq uist; steven.j.horetski@gm.com; Whitbeck, Neil (N.G .); Okafor, Chijioke (A.); Walkowicz, Erin (E.A.) Subject: RE: HD evap testing

Alan,

I am not aware of any guidance documents related to evaporative emissions testing on heavy duty engine dynamometer certified

programs.

It is my understanding that HD engine dynamometer c ertified programs are exempt from high altitude tes ting because there is no
requirement shown in CFR Part 86 Subpart A to requi re high altitude compliance. The high altitude req uirements are shown in
Subpart S and are applicable to chassis dynamometer certified programs (shown below is the high altitu de requirement from Subpart S):

§ 86.1829-01 Durability and emission testing requir ements; waivers. (ii) Testing at high altitude . For high-altitude evaporative and/or refueling em ission compliance for each evaporative/refueling family, the manufacturer shal l follow one of the following two procedures: (A) One EDV in each evaporative/refueling family an d evaporative/refueling emission control system com bination shall be tested in accordance with the evaporative/refueling test procedure requirement of subpart B of this pa rt. The configuration of the EDV will be determined under the provisions of § 86.1824-01. The EDV must also be tested for ex haust emissions using the FTP procedures of subpart B of this part while operated at high altitude; or (B) In lieu of testing vehicles according to the pr ovisions of paragraph (b)(2)(ii)(A) of this section , a manufacturer may provide a statement in its application for certific ation that, based on the manufacturer's engineering evaluation of such high-altitude emission testing as the manufacturer deems appropriate, all light-duty vehicles, light-d uty trucks and complete heavy-duty vehicles comply with the emissi on standards at high altitude.

Although the high altitude evap. requirement refere nces “complete heavy-duty vehicles”, it is my under standing that incomplete
vehicles 8500 -14K GVWR which optionally certify to Subpart S under the following regulation would be r equired to meet high
altitude evap. because they are optionally certifyi ng to all of the complete heavy-duty vehicle requir ements in Subpart S:

§ 86.1801-01 Applicability. (2) Beginning with the 2001 model year, a manufactu rer may request to certify any incomplete Otto-cycl e heavy-duty vehicle of 14,000 pounds Gross Vehicle Weight Ratin g or less in accordance with the provisions for com plete heavy-duty
vehicles . Heavy-duty engine or heavy-duty vehicle provision s of subpart A of this part do not apply to such a vehicle.

Also, the following Subpart M provision gives a man ufacturer the option to use the light duty drive cy cle in place of the heavy duty
drive cycle for evap. testing:

§ 86.1215-85 EPA heavy-duty vehicle (HDV) urban dyn amometer driving schedule. (a)(1) The EPA dynamometer driving schedule for hea vy-duty vehicles is a 1060 second transient speed v ersus time cycle which is designed to simulate gasoline-fueled HDV operation in urban areas. A second by second l isting of this schedule is given in Appendix I(d) of this part. Th irty-three percent of the cycle is idle operation, and the average vehicle speed is 18.9 mph (30.4 km/hr). The Administrator w ill use this driving schedule when conducting evapo rative emission tests, as described in § 86.1230-96. (2) For evaporative emission testing of heavy-duty vehicles a manufacturer may optionally use the dyna mometer driving schedule for light-duty vehicles and light-duty tru cks specified in appendix I(a) of this part. This driving schedule may not be used for exhaust emissions testing of heavy-duty vehicles.3 If the manufacturer chooses to use this option, the Administrator will use this driving schedule when conducting evaporative emission tests, as described in § 86.12 30-96.

Please let me know if you have any follow-up questi ons on this topic. Thank you.

Regards,

Ken Middleton Supervisor, Evaporative and Advanced Certification Phone: (313) 805-8233

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

Sent: Friday, June 14, 2013 2:54 PM

To: steven.j.horetski@gm.com

Cc: Glodich, Jeffrey (J.M.); Middleton, Kenneth (K.C.) ; Steve Douglas; Bill Blomquist Subject: RE: HD evap testing

Steve, I sneaked out for vacation just before your last me ssage. I haven’t been away this whole time -- I’m finally catching up.

I’m glad to hear that Ford and GM have already been on the LD track for HD evap testing. It wouldn’t be a problem to build in lead time and/or carryover provisions for the others, bu t it would be nice to avoid that if it’s not necess ary. I’ll take you up on your offer
to touch base with colleagues at Freightliner.

By the way, I suspect that both the HD-evap altitud e provisions and the allowance to use LD evap proce dures are in guidance

documents rather than the CFR. I’m not aware of ei ther of those things being written down. I will ta ke every available opportunity to move things from guidance to regulations. If yo u can help track down any relevant documentation on these issues, that will help
a lot to make sure we get everything right. It sho uldn’t be hard to isolate the HD testing provisions to evaporative measurements, but I’m confident you’ll have a chance to help us m ake sure we do just that.

Alan

From: steven.j.horetski@gm.com [ mailto:steven.j.horetski@gm.com ]

Sent: Wednesday, May 22, 2013 4:20 PM

To: Stout, Alan

Cc: Glodich, Jeffrey (J.M.); Middleton, Kenneth (K.C.) ; Steve Douglas; Bill Blomquist Subject: RE: HD evap testing

Alan,

There is a provision in the CFR that allows OEMs th e ability to optionally use the LD evap test proced ures for HD evap testing. Both Ford and GM have been using this opt ion, so no lead time or carryover provisions are re quired for us.

But, I'm not sure about companies such as Navistar or Freightliner. If you don't want a bunch of back and forth with these companies you could either allow some type of data carryover period (or maybe indefinitely) or tie the carryover to the end of the Tier 3 evap phase-in period. I will be a va cation for a few days, but when I get back I can tr y to contact Freightliner if it helps.

This alignment of the test procedures is just for e vap emission and any changes should be structured s uch that no new exhaust (or other) requirements are somehow picked up. Also, any exclusions or special existing provi sions need to be maintained. I believe there is some type of specia l high altitude evap provisions for HD engine certi fied programs that should remain in place.

. Best regards,

Steve Horetski Total Compliance Engineer - Evaporative Emissions GM Powertrain - Compliance & Certification

248.444.72864 steven.j.horetski@gm.com

From: "Stout, Alan" < stout.alan@epa.gov > To: " steven.j.horetski@gm.com " < steven.j.horetski@gm.com > Cc: Bill Blomquist < William.Blomquist@chrysler.com >, "Glodich, Jeffrey (J.M.)" < jglodich@ford.com >, "Middleton, Kenneth (K.C.)" < kmiddle1@ford.com >, Steve Douglas < sdouglas@autoallianceissues.com > Date: 05/22/2013 03:38 PM Subject: RE: HD evap testing

Steve, Thanks for the input. I’ll carry that forward.

The only remaining question I can think of regards lead time. Would we need to allow time to transiti on to the new procedure? If
so, we would be interested in a recommendation for managing the transition. I suppose that would at l east presume carryover of
existing families for a while.

Alan

From: steven.j.horetski@gm.com [ mailto:steven.j.horetski@gm.com ]

Sent: Wednesday, May 22, 2013 3:24 PM

To: Stout, Alan

Cc: Bill Blomquist; Glodich, Jeffrey (J.M.); Middleton , Kenneth (K.C.); Steve Douglas Subject: Re: HD evap testing

Alan,

The preferred approach would be to just use the LD evap test procedures for all chassis evap testing. This would include the UDDS for the evap prep, FTP, run loss and FTTP drives.

Ford and Chrysler agree with this approach. To the best of my knowledge Ford and GM are the only OEMs that offer gasoline products in this segment.

I also outlined the proposal to align the HD evap t est procedures with the LD evap test procedures dur ing a recent AAM conference call and did not receive any objections or commentary from other OEMs. So this input can b e viewed as supported by industry.

Best regards,

Steve Horetski Total Compliance Engineer - Evaporative Emissions GM Powertrain - Compliance & Certification

248.444.7286 steven.j.horetski@gm.com

From: "Stout, Alan" < stout.alan@epa.gov > To: " steven.j.horetski@gm.com " < steven.j.horetski@gm.com > Date: 05/16/2013 05:01 PM Subject: HD evap testing5 Steve, This follows up on our discussion from this afterno on about evap testing for heavy-duty vehicles over 14,000 pounds GVWR. The
proposed rule eliminates part 86, subpart M, and re places it with §1037.530, as noted below. The idea was to preserve the small
amount of HD-specific content from subpart M, but p oint to the light-duty test procedure where there w as already commonality. There are a handful of very minor differences betw een the light-duty and heavy-duty procedures that w e ignored, so the list
captured in §1037.530 is short, but meaningful.

You suggested taking this a step further and reduci ng it down to a single statement that all heavy-dut y vehicles should follow the
light-duty procedures without change. This is really only about the drive cycle, since th e timing issue identified in §1037.530(b) looks
pretty minor, and the part about measuring exhaust emissions is easy to preserve even if we conclude t hat there should be only a
single procedure.

That leaves us to figure out the drive cycle. I’m confident we’ll be ready to go with any consensus p osition from the manufacturers on this point. There are really three options: (1 ) Stick with the heavy-duty UDDS as it’s always bee n. (2) Change the regulation to
apply all of the light-duty procedures for all size s of vehicles. In this case, we would eliminate th e HD UDDS from the CFR, since it is not used for any other purpose. (3) Switch from the current HD UDDS to the transient chassis test spec ified in 40 CFR part 1037. I
know very little about that cycle. We would have t o figure out how the cycles compare and perhaps adj ust for a consistent degree
of purge, but there would be some elegance to takin g that step to unify the program requirements for t hose vehicles. In this case

we would also eliminate the HD UDDS from the CFR.

You will need to keep in mind too that the drive cy cle matters for the coming up with the fuel tank te mp erature profile in addition to
the various evaporative measurements.

So, there you have it. Feel free to pass this arou nd as necessary. I’ll be eager to see how you come out on all that.

Alan

________________



### § 1037.530 Evaporative emission test procedures. Apply the provisions of 40 CFR part 86, subpart B, to demonstrate compliance with the diurnal, running loss, and hot soak emission standards as specified in §10 37.103, with the following exceptions: (a) Use drive cycles for heavy-duty vehicles as fol lows: (1) The Heavy-Duty Urban Dynamometer Driving Schedu le (HD-UDDS) is specified in 40 CFR part 86, Appendix I, paragraph (d). It represents about 5. 6 miles of driving for a heavy-duty vehicle in an u rban area. (2) For the preconditioning drive, operate the vehi cle over one HD-UDDS instead of the drive specified in 40

CFR 86.132. (3) For the dynamometer run preceding the diurnal e mission test, operate the vehicle over one HD-UDDS instead of the FTP driving schedule. (4) For performing the running loss test and develo ping fuel tank temperature profiles, operate the ve hicle over three consecutive HD-UDDS cycles, each separated by two minutes if idle operation, instead of the driv ing specified in 40 CFR 86.134. (b) The vehicle may be driven onto the dynamometer, as long as the vehicle is driven at minimum thrott le and the total time of engine operation in the soak peri od before the diurnal emission test does not exceed 3 minutes. (c) Testing under this subpart does not require mea surement of exhaust emissions. Disregard reference s in 40 CFR part 86, subpart B, to procedures, equipment sp ecifications, and recordkeeping related to measurin g exhaust emissions. All references to the exhaust t est under 40 CFR part 86, subpart B, are considered the “dynamometer run” as part of the evaporative testin g sequence under this subpart.6 

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