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 engines to and most support the move to point at the LD evap test 

procedures and LD-UDDS for HD evap testing. The exception to this is Freightliner. Apparently when they conducted 

their evap testing they utilized the HD-UDDS. Since 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 the optionaluse of the HD-UDDS for HD evap testing as functionally 

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>, Steve Douglas <sdouglas@autoallianceissues.com>, Bill Blomquist <William.Blomquist@chrysler.com>, 

"steven.j.horetski@gm.com" <steven.j.horetski@gm.com>, "Whitbeck, Neil (N.G.)" <nwhitbec@ford.com>, "Okafor, Chijioke (A.)" <cokafor@ford.com>, 

"Walkowicz, Erin (E.A.)" <ewalkow2@ford.com>, "Moulis, 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-altitude provisions in §86.1829-01; the text you noted (and the associated 

implementation practice) will continue to apply. We are re-writing all the high-altitude test waiver in §86.1829-17 for Tier 3 to apply 

generically for all vehicles meeting standards under subpart S (copied below from the NPRM, for reference). 

I confirmed that the allowance for the light-duty driving schedule for HD vehicles was a change from the original enhanced evap 

procedures. Someone added §86.1215-85(a)(2) in 2000 to add in the alternate driving schedule. I didn’t find that since it should 

have been written to apply more broadly to cover the whole procedure. This isn’t necessarily a problem, 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 now, is to move away from subpart M entirely and provide the simple 

instruction to use the subpart B procedures to test just like LDV (except for omitting the exhaust measurement).

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

Alan

_______________
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§86.1829-17 

(c) The manufacturer must demonstrate compliance with emission standards at low-altitude conditions as

described in paragraph (b) of this section. For standards that apply at high-altitude conditions, the manufacturer 

may either perform the same tests or provide a statement in the application for certification that, based on an 

engineering evaluation of appropriate testing to measure or simulate high-altitude emissions, all vehicles 

comply with applicable emission standards at high altitude. 

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 Blomquist; 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 certified programs are exempt from high altitude testing because there is no 

requirement shown in CFR Part 86 Subpart A to require high altitude compliance. The high altitude requirements are shown in 

Subpart S and are applicable to chassis dynamometer certified programs (shown below is the high altitude requirement from 

Subpart S):

§ 86.1829-01 Durability and emission testing requirements; waivers.

(ii) Testing at high altitude. For high-altitude evaporative and/or refueling emission compliance for each 

evaporative/refueling family, the manufacturer shall follow one of the following two procedures:

(A) One EDV in each evaporative/refueling family and evaporative/refueling emission control system combination shall be 

tested in accordance with the evaporative/refueling test procedure requirement of subpart B of this part. The configuration 

of the EDV will be determined under the provisions of § 86.1824-01. The EDV must also be tested for exhaust 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 provisions of paragraph (b)(2)(ii)(A) of this section, a manufacturer may 

provide a statement in its application for certification that, based on the manufacturer's engineering evaluation of such 

high-altitude emission testing as the manufacturer deems appropriate, all light-duty vehicles, light-duty trucks and 

complete heavy-duty vehicles comply with the emission standards at high altitude.

Although the high altitude evap. requirement references “complete heavy-duty vehicles”, it is my understanding that incomplete 

vehicles 8500 -14K GVWR which optionally certify to Subpart S under the following regulation would be required to meet high 

altitude evap. because they are optionally certifying to all of the complete heavy-duty vehicle requirements in Subpart S:

§ 86.1801-01 Applicability.

(2) Beginning with the 2001 model year, a manufacturer may request to certify any incomplete Otto-cycle heavy-duty 

vehicle of 14,000 pounds Gross Vehicle Weight Rating or less in accordance with the provisions for complete heavy-duty 

vehicles. Heavy-duty engine or heavy-duty vehicle provisions of subpart A of this part do not apply to such a vehicle.

Also, the following Subpart M provision gives a manufacturer the option to use the light duty drive cycle in place of the heavy duty 

drive cycle for evap. testing:

§ 86.1215-85 EPA heavy-duty vehicle (HDV) urban dynamometer driving schedule.

(a)(1) The EPA dynamometer driving schedule for heavy-duty vehicles is a 1060 second transient speed versus time 

cycle which is designed to simulate gasoline-fueled HDV operation in urban areas. A second by second listing of this 

schedule is given in Appendix I(d) of this part. Thirty-three percent of the cycle is idle operation, and the average vehicle 

speed is 18.9 mph (30.4 km/hr). The Administrator will use this driving schedule when conducting evaporative emission 

tests, as described in § 86.1230-96.

(2) For evaporative emission testing of heavy-duty vehicles a manufacturer may optionally use the dynamometer driving 

schedule for light-duty vehicles and light-duty trucks specified in appendix I(a) of this part. This driving schedule may not 

be used for exhaust emissions testing of heavy-duty vehicles.
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If the manufacturer chooses to use this option, the Administrator will use this driving schedule when conducting 

evaporative emission tests, as described in § 86.1230-96.

Please let me know if you have any follow-up questions 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 message. 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, but it would be nice to avoid that if it’s not necessary. 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 altitude provisions and the allowance to use LD evap procedures are in guidance 

documents rather than the CFR. I’m not aware of either of those things being written down. I will take every available opportunity 

to move things from guidance to regulations. If you can help track down any relevant documentation on these issues, that will help 

a lot to make sure we get everything right. It shouldn’t be hard to isolate the HD testing provisions to evaporative measurements, 

but I’m confident you’ll have a chance to help us make 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 the ability to optionally use the LD evap test procedures for HD evap 

testing. Both Ford and GM have been using this option, so no lead time or carryover provisions are required 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 vacation for a few days, but when I get back I can try to contact Freightliner 

if it helps.

This alignment of the test procedures is just for evap emission and any changes should be structured such that no new 

exhaust (or other) requirements are somehow picked up. Also, any exclusions or special existing provisions need to be 

maintained. I believe there is some type of special high altitude evap provisions for HD engine certified programs that 

should remain in place. 

. 

Best regards, 

 

Steve Horetski 

Total Compliance Engineer - Evaporative Emissions 

GM Powertrain - Compliance & Certification 

248.444.7286
4

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 transition to the new procedure? If 

so, we would be interested in a recommendation for managing the transition. I suppose that would at least 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 test procedures with the LD evap test procedures during a recent AAM 

conference call and did not receive any objections or commentary from other OEMs. So this input can be 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 testing

 
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Steve, 

This follows up on our discussion from this afternoon about evap testing for heavy-duty vehicles over 14,000 pounds GVWR. The 

proposed rule eliminates part 86, subpart M, and replaces it with §1037.530, as noted below. The idea was to preserve the small 

amount of HD-specific content from subpart M, but point to the light-duty test procedure where there was already commonality. 

 There are a handful of very minor differences between the light-duty and heavy-duty procedures that we ignored, so the list 

captured in §1037.530 is short, but meaningful. 

You suggested taking this a step further and reducing it down to a single statement that all heavy-duty vehicles should follow the 

light-duty procedures without change. This is really only about the drive cycle, since the 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 that 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 position from the manufacturers 

on this point. There are really three options: (1) Stick with the heavy-duty UDDS as it’s always been. (2) Change the regulation to 

apply all of the light-duty procedures for all sizes of vehicles. In this case, we would eliminate the 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 specified in 40 CFR part 1037. I 

know very little about that cycle. We would have to figure out how the cycles compare and perhaps adjust for a consistent degree 

of purge, but there would be some elegance to taking that step to unify the program requirements for those 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 cycle matters for the coming up with the fuel tank temperature profile in addition to 

the various evaporative measurements. 

So, there you have it. Feel free to pass this around 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 §1037.103, with the following exceptions: 

(a) Use drive cycles for heavy-duty vehicles as follows: 

(1) The Heavy-Duty Urban Dynamometer Driving Schedule (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 urban area. 

(2) For the preconditioning drive, operate the vehicle over one HD-UDDS instead of the drive specified in 40 

CFR 86.132. 

(3) For the dynamometer run preceding the diurnal emission test, operate the vehicle over one HD-UDDS 

instead of the FTP driving schedule. 

(4) For performing the running loss test and developing fuel tank temperature profiles, operate the vehicle over 

three consecutive HD-UDDS cycles, each separated by two minutes if idle operation, instead of the driving 

specified in 40 CFR 86.134. 

(b) The vehicle may be driven onto the dynamometer, as long as the vehicle is driven at minimum throttle and 

the total time of engine operation in the soak period before the diurnal emission test does not exceed 3 minutes.

(c) Testing under this subpart does not require measurement of exhaust emissions. Disregard references in 40 

CFR part 86, subpart B, to procedures, equipment specifications, and recordkeeping related to measuring 

exhaust emissions. All references to the exhaust test under 40 CFR part 86, subpart B, are considered the 

“dynamometer run” as part of the evaporative testing sequence under this subpart. 
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