## CFR

**Citation**

General

General

General

General

§ 1066.105 Variable Fan1066.105(c)(3)

SC03 Fan

1066.137

1066.137

1066.410(b)

1066.4101066.430(g)

1066.430(j)

1066.501

1066.650(x)1066.652(b)

1066.710

1066.710

1066.710

1066.7101066.710

1066.710

1066.814

1066.820

1066.8311066.831

1066.832

1066.832

1066.835

1066.8351066.835

1066.695

1065.140

1065.140
1065.6551065.701

1065.710

1065.725

1065.1001

1065.1005

1065.1005

1065.101086.101(a)

86.101(b)(1)

86.101(b)(2)(ii)86.113

86.113

86.117-96 (c)(1)(ix)86.117-96

(c)(1)(ix)

86.167

86.16786.201

86.1811-04

86.181385 & 86

Multiple

## Al **liance / Global Comments**



# General Comments **Further harmonization needed - EPA and ARB test procedures:** ● PHEV/HEV procedures ●EV AP ●Exhaust **General comment:** Tier III rulemaking is complex, driving new test types and measurement technologies. Additionally Part 1066 couples current LD test procedures (Part 86 subparts B & C and Part 600) with the established HD Part 1065. Inadvertent errors will occur. This needs to be an iterative process with a mechanism to make regulation corrections even after the FRM comes out. Industry asks the agency to provide a mechanism for these further changes. With this being said, it is also **very important**for the Tier III phase in that industry have **stability**in general directions as capital investments will be made for the duration of the phase in. **General comment:** EPA's current practice of internally splash blending of fuels, especially w.r.t. ethanol blends **Comment:** Should use industry practice a procure pre mixed fuels to eliminate a source of error **General Comment:** Appendix 2 (HEV / PHEV test procedures) from the Alliance / Global comments appeared not to be addressed **Comment:** These are important issues where harmonization will benefit both industry and government. What is the next step? 

# Part 1066 **§1066.105(c)(2) or (d** ): Using a road-speed modulated fan meeting the requirements of §1066.105(c) (2) or (d) **Comment:** We would like ask EPA to specify official EPA test equipment and make clear whether OEMs need to submit official approval request for using a road-speed modulated fan or not. Secondly w.r.t. vehicle cooling fans, EPA should test the same way OEM's test (fixed speed or road speed). Recommend: 1066.105(c): Add "EPA will use the same fan method or technology as OEM's used for testing"**1066.105(c)(3)(iii);** " Measure the fan axial air flow velocity **60cm** from the nozzle outlet at each point of the

**discharge area grid** ." **Comment:** Should be 61 cm (2 feet), but ok. Issue is this implies within 0.5 cm, which is not an important criteria. Suggest inserting "approximately" before 60 cm. Second issue is discharge grid area is not defined. Current CFR defines this as §86.161-00 (4)(i) Fan axial air flow velocity is measured two feet from nozzle outlet at each point of a **one foot grid** over the entire discharge area. Recommend to add "one foot grid" in 1066.105(c)(3)(iii) **1066.137(b):** (1) "For each range calibrated, if the deviation from a least-squares best-fit straight line is 2 % or less of the value at each data point, concentration values may be calculated by use of a **single calibration factor** for that range. If the deviation exceeds 2 % at any point, use the best-fit nonlinear equation that represents the data to within 2 % of each test point to determine concentration." **Comment:** Not sure what a "single calibration factor" means, intent is linear, Suggest replacing "single calibration factor" with "straight line curve fit". **1066.137(b):** (2) "If you choose this linearity **option** , you must drift check and drift correct your emission data according to 40 CFR 1065.672." **Comment:** Somewhat confusing as to which option is being referenced, for clarity suggest: To clarify language, suggest "If you choose this linearity option **(b)(2) for analyzers except CO2** , you must drift check and drift correct your emission data according to 40 CFR 1065.672." **1066.410(b) & (b)(2); "** For FTP, LA-92, US06, or HFET testing of vehicles at or below 14,000 pounds GVWR, you **may use**a fixed-speed fan meeting the requirements of §1066.105(c)(4) or (c)(5) as specified in the following table, with the engine compartment cover open:" **Comment:** Industry has a concern that EPA test vehicles the way OEM's test vehicles. This clarification should be added to 1066.410 (b) as follows: 1066.410(b): Add "EPA will use the same fan method or technology as OEM's used for testing" **1066.410(c);** "Record the vehicle’s speed trace based on the time and speed data from the dynamometer. Record speed to at least the nearest 0. **01** mph and time to at least the nearest 0. **01** s."
**Comment:** Perhaps this is a typo and should say the equivalent of 10hz like §1066.122 Table 1, "Minimum Recording Frequency for Vehicle speed — 10 Hz. Same is true for time. "Recording" at such a high frequency is not warranted and very burdensome to data bases. This high frequency was meant for certain dyno verifications as being able to "measure" at these higher frequencies**1066.430(g)(3)(i):** Typo, drift check should be per (g)(5) not (6)

**1066.430(j)(1)(i)-(iii):** EER, ASCR & IWR determination requirements need to be updated to latest version of SAEJ2951 to include weighted 3 and 4 phase FTP methodologies. (i) Determine the Energy Economy Rating as described in Section 5.4 of SAE J2951. (ii) Determine the Absolute Speed Change Rating as described in Section 6.1.2 of SAE J2951. (iii) Calculate the Inertia Work Rating, IR, using the both the sums of the incremental driven and the target inertia work as described in Eq. 1066.430-1. Equation 1066.430-1 + terminology descriptions **Comment:** Replace 1066.430(j)(1)(i)(ii)&(iii) with: 1066.430(j)(1)(i) Determine the Energy Economy Rating (EER), Absolute Speed Change Rating (ASCR) and Inertia Work Rating (IWR) as described in Section 5.7 of SAEJ2951 **1066.501:** J1711 differing from the standard setting part. Examples, US06 split bag, cold CO heater controls. **Comment:** Suggest inserting some general guidance like "For test elements that are not specific for hybrid vehicles , if J1711 differs from the standard setting part then the standard setting part takes precedence." Similar language appeared in either the GHG preamble or Part 600. **1066.650(b)(x):** "If the equation meets the criteria of SEE <= 0.5% n_dot_refmax ..." **Comment:** This should be updated to reflect the rest of the section, in that flow meters for chassis testing typically report mass or standardized volume flow rates, not molar flow rates.**1066.652(b):** "Calculate SSV volumetric flow rate during an emission test ... as follows:

**Comment:** For calculating flow through an SSV, iteration is required to determine the final combination of Re# and Cd, since they depend on one-another; Re# depends on flow rate, which depends on Cd, which is calculated as a function of Re#. No mention of this is made in the document. CEESI Technical Note TN-014, for instance, addresses this in section 4. Their recommendation is to begin iteration with a Cd of 0.98 and continue until the Cd value changes by less than 0.05% between successive iterations. Alternatively, Re# could instead be DEFINED in terms of the theoretical, ideal flow rate (1D flow, Cd = 1), and Cd defined as a function of this. Then iteration would not be required, since the theoretical flow rate depends only on the measured gas properties and the venturi geometry.

**1066.710 Figure 1:** Preconditioning average start temperature tolerance ±2.8 0 incorrect per 86.230-11(c)(2) and historical figure C94-1 from 86.230-94 **Comment:** Should be ±1.7 0 **1066.710 Figure 1:** Typo in note between boxes 4,5 & 6, the minus sign "-" is separated from the numerical temperature "7.0 0 C" **Comment:** Correct formatting **1066.710(b)(1):** Missing the average test temperature over the test - like figure 1 **Comment:** Add "The average ambient temperature during the test must be ( −7.0 ±2.8) °C." **1066.710(b)(2):** Missing the start test temperature and 3 minute excursion temperatures over the test - like figure 1 **Comment:** Add "The temperature must be ( −7.0 ±1.7) °C at the start of the test. Instantaneous temperature values may be above −4.0 °C or below −9.0 °C, but not for more than 3 minutes at a me during the test."**1066.710(c):** (1)(A) "Temperature. Set manually operated to maximum heat. Automatic systems may optionally

use the provisions of this paragraph (c)(1) and must set the temperature to **72 °F**or higher." (2) "Automatic control systems. Automatic control systems may use either the provisions in paragraph (c)(1) of this section or manufacturers may set the temperature at **72 °F**and the air flow control to the front window defroster mode for the entire duration of the test." **Comment:** Should add Celsius units as well but in parenthesis since in vehicle units are typically in 0F. Add "(22 0C )" **1066.710(e)(1):** "Instantaneous ambient temperatures during the soak period may be above **−1.0**°C or below **−12.0**°C, but not for more than 3 minutes at a time. This is different than Figure 1 and in error, temperature maximumsare "..above −1.0 °C or below −12.0 °C...", not the 3 minute windows. **Comment:** Should be "..above −4.0 °C or below −9.0 °C..." **1066.814e(2):** evap vehicle preconditioning not allowed over 12mo vehicle age. Comment: for very low volume specialty vehicles, cert car will be used many time. Component removal will contaminate vehicle,need some baking to clean up.

**1066.820:** Testing must meet the requirements related to filter face velocity as described in 40 CFR 1065.170(c)(1)(vi), except where flow weighting is allowed. **Comment:** For flow weighted PM testing, suggest FFV be allowed to exceed 100 cm/sec per phase, but on average be less than or equal to 100 cm/sec per Part 1065
**1066.831(b)(3)(ii)(D); PREP Cycle:**  "US06 driving schedule or, for heavy-duty vehicles above **10,000 pounds GVWR**, just the **highway portion of the US06 driving schedule**  ." **Comment:** Incorrect, and needs to be aligned with LEV III rule. Should be: Class 3's run the LA92, Class 2b's run the US06 unless they are underpowered and they then run only the highway portion of the US06 as specified in 86.1816-18 (b)(1)(ii)(B). Also per 86.1816-18 (a)(1), all testing is done at ALVW. 1066.831 is missing reference to "normal" (not underpowered) class 2b vehicles - they run the full US06.**1066.831(f)(2); Drive Cycle:**

**"** (2) Operate the vehicle over the full US06 driving schedule, except as follows: (i) For heavy-duty vehicles above 10,000 pounds **GVWR** , operate the vehicle over the LA-92 driving schedule. (ii) Heavy-duty vehicles at or below 10,000 pounds **GVWR**may be certified using only the highway portion of the US06 driving schedule. See 40 CFR 86.1816." **Comment;** Incorrect, and needs to be aligned with LEV III rule. Should be: Class 3's run the LA92, Class 2b's run the US06 unless they are underpowered and they then run only the highway portion of the US06 as specified in 86.1816-18 (b)(1)(ii)(B). Also per 86.1816-18 (a)(1), all testing is done at ALVW. 1066.831 is missing reference to "normal" (not underpowered) class 2b vehicles - they run the full US06. **1066.832 (a):** Typo - "most" **Comment:** Should be Last **1066.832 (b)(3):** Typo's - "(d)" & "(e)" **Comment:** Should be "(e)" & "(f)" **1066.835(e):** (1) "For automatic systems, set the temperature control to **72 °F** ." (2) "... and adjust the temperature setting to target a temperature of **55° F**at the dashboard air outlet. Maintain these settings for the remainder of the test. You may rely on prior temperature measurements to determine the temperature adjustment setting, however, if the **55 °F**dashboard air temperature cannot be met, setting the control to 50% of maximum blower, airflow to “fresh air” and temperature to full cold is sufficient. If the vehicle is equipped with technology that defaults to recirculated air at ambient temperatures above **75 °F** , that technology" **Comment:** Should add Celsius units as well but in parenthesis since in vehicle units are typically in 0F. Add "(13 0C ) & " (22 0C) as appropriate **1066.835(f)(1);** "Prepare the vehicle for testing according to 40 CFR 86.132-00 (a) through (g)." **Comment:** This procedure (86.132-00) contains many elements [Fuel change => 6hrs soak => UDDS driving => Fuel change =>12 ~ 36hrs soak => pre-con driving for AC test] which may not be needed for the A/C test sequence. Could be simplified like SFTP testing if the A/C testing is following other emissions test sequences. Suggest adding wording that if following another emissions test sequence as follows: "The preparation procedure defined in 86.132-00 (a) through (g) is not required if the vehicle has been tested within the last 36 hours concluding with a 12 to 36 hour soak . As an alternative to the 12 to 36 hour soak the AC17 test may use a forced cool down system to bring critical vehicle temperatures within soak temperature limits. Critical temperatures include: transmission oil, engine oil, engine coolant and cabin air temperatures." (Note typo in original comment in red font - per §86.167-17(g))**1066.835(h):** AC17 recordkeeping. "In addition to the information specified in §1066.695, you must record the

following information for each vehicle tested: interior volume, climate control system type and characteristics, refrigerant used, compressor type, and evaporator/condenser characteristics." **Comment:** Recommend consolidating this into 1066.695, with the qualifier that this applies to 1066.835 AC17 testing **1066.695:** (o) Flow meter inlet temps, (q) Heated FID temperatures, (r) Flow meter readings at start and end of test interval, (t) PM media stabilization temperatures and humidity's **Comment:** Recommend adding to each of these "These can be stored as minimum, maximum and averaged readings over the test interval" Also suggest for (r) to be changed to over each test interval versus "start and end" 

# Part 1065 **1065.140(a):** Replacing "synthetic" with "purified" for dilution air. **Comment:** Missed in NPRM, should retain synthetic along with purified, some labs may make their own "air". Multiple references in Part 1065

**1065.140(e):** Font typo "...other than the heat you may need to add to prevent aqueous condensation." **1065.655(d)(2)(ii)(A):** Font typo "When using ASTM D5291 to determine carbon and hydrogen mass fractions from gasoline (with or without blended ethanol), use good engineering judgment to adapt the method as appropriate. ."**1065.701(f) Table 1:** ASTM D6985 specification has been withdrawn.

**Comment:** Withdrawn Rationale: Formerly under the jurisdiction of Committee D02 on Petroleum Products and Lubricants, this specification was withdrawn in July 2010 due to the fact that SC E has been unable to find anyone using this specification or in support of maintaining this specification. Should be updated or replaced **1065.710(b) Table 1:** Lists only E15 fuel **Comment:** Will this be the Tier III certification fuel? Concern over harmonization with ARB's E10

**1065.725(a):** Retains unrepresentative Ethanol 80-83% fuel specifications **Comment:** Alliance / Global recommended alternative based on field fuels **1065.1001:** No definition for "purified air" for dilution air. Should allow synthetic blends as well, like that defined for span and zero gas. **Comment:** Add definition **1065.1005(a):** Typo In table "DR...dilution ratio...mole per **mol** ...mol/mol...1" **Comment:** Should be "mole" **1065.1005(g):** Doesn't list "IBR" acronym. This is a common acronym used throughout Part 1065, but may not be obvious to the reader **Comment:** Should list "IBR" as "incorporated by reference" **1065.1010(a)(44):** ASTM D6985 specification has been withdrawn. **Comment:** Withdrawn Rationale: Formerly under the jurisdiction of Committee D02 on Petroleum Products and Lubricants, this specification was withdrawn in July 2010 due to the fact that SC E has been unable to find anyone using this specification or in support of maintaining this specification. Should be updated or replaced 

# Parts 86 &600**86.101(a):** Need additional guidance for exhaust emissions testing with ethanol-gasoline blends less than 25%

ethanol by volume, if using the NMHC to NMOG conversion factors listed in 1066.665(c) **Comment;** This comment is mirrored with the Shed ethanol comment below in 86.117-96 (c)(1)(ix) for E1x fuels. The Alliance / Global believes that if an NMHC to NMOG adjustment factor is used for exhaust emissions testing, with ethanol-gasoline blends less than 25% ethanol by volume, that neither FID alcohol response factor determinations, ethanol measurements, or alcohol recovery checks are necessary. Since this issue is in several Part 86 sections, suggest adding an new (a)(7) paragraph as follows: (a)(7) "For exhaust emissions testing which with ethanol-gasoline blends less than 25% ethanol by volume, if using the NMHC to NMOG conversion factors listed in 1066.665(c) instead of measuring ethanol, you do not have to follow any of the alcohol specific test procedure or diagnostic requirements in Part 86 like ethanol injections, etc." **86.101(b)(1)** ; "Through model year 2021, manufacturers may use the test procedures specified in paragraph (c) or (d) of this section. For any EPA testing before the 2022 model year, EPA will use the manufacturer's selected procedures for determining road load parameters and applying cycle-validation criteria. For any other parameters, EPA may conduct testing using either of the specified procedures." **Comment;** Two issues, (1) Everybody will need the ability to pull ahead "elements" of Parts 1065 and 1066 - which likely will involve hardware, software and procedures at differing times. The Alliance / Global wants to work with the agency on the definition of "elements", and bring into this migration "good engineering judgment". (Alliance / Global / EPA Action Item) (2) The agency should use the long standing practice of testing the way OEM's certify. (Alliance / Global / EPA Action Item) **86.101(b)(1);** "Through model year 2021, manufacturers may use the test procedures specified in paragraph (c) or (d) of this section. For any EPA testing before the 2022 model year, EPA will use the manufacturer's selected procedures for determining road load parameters and **applying cycle-validation criteria** . For any other parameters, EPA may conduct testing using either of the specified procedures." **Comment (Apr 2013);** It is not clear what "cycle-validation criteria" is this referring to. Is this the normal trace validation (+/- 2 mph) or is this (also) referring to the new Part 1066.430(j) Energy Economy Rating. If EER is included, there is no cycle validation criteria established for this, and this is just a reporting requirement. Language is this section should be corrected to reflect this.**86.113-04 Fuel specifications :**  (a)(2)(ii)(D) For non-tier III testing but with Calif E10, "The vehicle must meetthe

applicable **cold-temperature**standards using the fuel specified in paragraph (a)(1) of this section." But (a)(1) specifies **non-cold** E0 fuel. **Comment:** Should point to 86.213 or 1065 cold E0 & cold E1x. Also language should be added to provide guidance on interim E0 FE provisions. One additional area of concern is what test procedures are to be used for Tier III, E0 testing? One example of an issue is with the NMHC to NMOG factor, where §86.1810-01 (p) uses 1.04 multiplier, but 1066.665 uses a combination of factors and equations for "...vehicles subject to an NMOG standard..." It is likely that there is other language in Parts 86 or 600 requiring other specific test procedures for E0.

**86.113-07 Fuel specifications** : (a) "Manufacturers must certify using service accumulation fuel and E15 test fuel as specified in 40 CFR 1065, subpart H..." (1) "Use the E15 test fuel to demonstrate compliance with the Tier 3 exhaust emission standards as specified in §86.1811 and 86.1816. Where testing with E15 test fuel is required, this applies for **all testing**for demonstrating compliance with exhaust emission standards and fuel economy requirements." What about E0 interim provisions? **Comment:** Language should be added to provide guidance on interim E0 FE provisions One additional area of concern is what test procedures are to be used for Tier III, E0 testing? One example of an issue is with the NMHC to NMOG factor, where §86.1810-01 (p) uses 1.04 multiplier, but 1066.665 uses a combination of factors and equations for "...vehicles subject to an NMOG standard..." It is likely that there is other language in Parts 86 or 600 requiring other specific test procedures for E0. **86.117-96 (c)(1)(ix);** "To verify the enclosure calibration, calculate the mass of propane and the mass of methanol using the measurements taken in paragraphs (c)(1)(vi) and (viii) of this section. See paragraph (d) of this section. This quantity must be within ±5 percent of that measured in paragraph (c)(1)(vii) of this section." **Comment;** ±5 percent is a large error compared to traditional propane tolerances of ±2%, and this increased error will directly lead to higher shed vehicle emissions variability. The traditional ±2% propane tolerance needs to be retained for both recovery and retention diagnostics. However the Alliance / Global does see the value to modifying ethanol injection tolerances and test sequence as well to reflect the difficulties of the measurement itself plus minimizing burden. To this end the Alliance / Global recommends expanding the ethanol recovery tolerance to ±5%, and only do an ethanol retention upon major shed modifications or annually. Doing this would allow the propane to be run first to verify shed integrity, then a short ethanol recovery would verify ethanol measurement accuracy (Note typo in original comment in red font)**86.117-96 (c)(1)(ix);** "To verify the enclosure calibration, calculate the mass of propane and the mass of

methanol using the measurements taken in paragraphs (c)(1)(vi) and (viii) of this section. See paragraph (d) of this section. This quantity must be within ±5 percent of that measured in paragraph (c)(1)(vii) of this section." **Comment;** The Alliance / Global believes that if total hydrocarbon equivalent factor(s) are used for ethanolgasoline blends less than 25% ethanol by volume, that neither FID alcohol response factor determinations, ethanol measurements, shed alcohol recovery (calibration) or alcohol retention checks are necessary. Since this issue is in several sections of 86.117-96, suggest adding in the opening paragraph (a) the following clarifier: 86.117-96(a); Add "For evaporative and refueling emissions testing with ethanol-gasoline blends less than 25% ethanol by volume, if using the total hydrocarbon equivalent factor(s) as listed in 86.1813-17(a)(1)(iv) instead of measuring ethanol, you do not have to follow any of the alcohol specific test procedure or diagnostic requirements in Part 86 like ethanol injections, etc." This comment could also be inserted in 86.101(a)(6) as a global comment. **86.167(k)(10):** " **Eighteen** seconds after the engine starts, begin the initial vehicle acceleration of the SC03 driving schedule. (9) specifies "Fifteen seconds after the engine starts, place vehicle in gear." **Comment:** This test start timing is slightly different than the SC03, and should be consistent. Should be 20 seconds. **86.167(g);** "The vehicle shall be prepared for testing according to § 86.132(a) through (g), concluding with a 12- 36 hour soak." **Comment:** This procedure (86.132-00) contains many elements [Fuel change => 6hrs soak => UDDS driving => Fuel change =>12 ~ 36hrs soak => pre-con driving for AC test] which may not be needed for the A/C test sequence. Could be simplified like SFTP testing if the A/C testing is following other emissions test sequences. Suggest adding wording that if following another emissions test sequence as follows: "The preparation procedure defined in 86.132-00 (a) through (g) is not required if the vehicle has been tested within the last 36 hours concluding with a 12 to 36 hour soak . As an alternative to the 12 to 36 hour soak the AC17 test may use a forced cool down system to bring critical vehicle temperatures within soak temperature limits. Critical temperatures include: transmission oil, engine oil, engine coolant and cabin air temperatures." (Note typo in original comment in red font - per §86.167-17(g))**86.201;** General applicability. (a) Vehicles are subject to cold-testing requirements as described in subpart S of

this part and 40 CFR part 600. **Perform testing**to measure CO and NMHC emissions and determine fuel economy **as described in 40 CFR part 1066;** see especially 40 CFR 1066.710. **Comment;** Requires all cold testing, for **Tier II** and Tier III to follow 1066 w/o any lead time nor guidance like that in 86.101. Would have to be 1066 compliant when promulgated including using E15 fuel for Tier II emissions and FE testing. Also this section **does not allow any** subsequent sections in subpart C like that in the revised **86.213**fuels guidance.

**86.1811-04(n);** "Manufacturers must measure emissions from hybrid electric vehicles , including plug-in hybrid electric vehicles during charge sustaining operation, according to the procedures specified in SAE J1711 (incorporated by reference in §86.1); however, these procedures do not apply for plug-in hybrid electric vehicles during charge-depleting operation." **Comment:** Should this section reference Part 1066, subpart F? **86.1813-17;** Evaporative and refueling emission standards. (a)(1)(iv) Emissions are measured as total hydrocarbon; however, in the case of E15 test fuel, multiply measured values by 1.1 to convert values to total hydrocarbon equivalent. **Comment;** Ethanol shall be accounted for via measurement or the use of an optional mass adjustment factor. Additionally the ethanol adjustment factors should be further evaluated for equivalency based on any new studies or data.**§85.1515 (Import-Nonconforming), §86.201 (20 0F Cold)**  **, §86.1810-17 (General Stds), §86.1811-17 (Exh Emiss**

**Stds), §86.1813-17 (Evap/Refuel Stds), §86.1816-18 (Emis Stds HD Veh), §86.1829-17 (Waivers), §86.1844-01 (Info reqm'ts), §86.1845-04 (In-Use), §86.1868-12 (CO2 Credits);**  All reference 1066 but with no Tier III roll out provisions as in 86.101 **Comment;** Should add language like that in 600.111-08 "References in this section to 40 CFR part 86 generally apply to Tier 2 and older vehicles, **while references to 40 CFR part 1066 generally apply to Tier 3 and newer vehicles; see 40 CFR 86.101 for detailed provisions related to this transition**  ." Also should retain 86.167 (&165?) for this roll-out as the part 86 procedure

## New or (Revised) Fall 2013 Comments

Same comment

Comment still a priority. LEV III & Tier III is upon us and industry needs to start modifying facilities. Stability is important unless errors need to be corrected

New comment - Fall 2013

New comment - Fall 2013

New comment - Fall 2013Did change distance to approximately

But did not define grid spacing to be like current SC03 fan spec's

New comment - Fall 2013

New comment - Fall 2013

Not specifically addressed, added recommendation (in blue font)

Big Issue - especially the recording frequency requirement of 0.01s, which has a dramatic and adverse affect to data bases (x10 more storage). This very fast recording frequency and ultra high dyno speed resolution was really intended for dyno verification of speed / time, not for routine data collection which is where its listed. A 10 hz & 0.1 mph is all that's needed for accurate measurements, anything greater has no value but comes at very high costNew comment - Fall 2013

New comment - Fall 2013

Not adopted, appears comment was not clear in intent. Modified recommendation ( blue font).

Modification in 1066.650(b)(2)(ix) looks correct. The molar-versus-volume issue has prompted an explicit calibration section for dilute exhaust flow in 1066 (1066.140), which 1066.130(e) refers to. Question whether something similar should be done for linearity requirements since 1066.137 currently references 1065.307, where the table is in molar flow. Also, 1065.330(c) refers to 1065.340 for the raw exhaust flow calibration procedure, and 1066.130(e) refers to 1066.140 for all flows. So can 1065.340 and 1066.140 be renamed from “Diluted exhaust flow calibration” to “Raw and diluted exhaust flow calibration?” Also, there appears to be a numbering discrepancy: 1066.650(b)(2)(vii) appears twice.**EPA Response** : Direction on the use of iteration to determine the

final combination of Re# vs. Cd is given in 1066.140(g)(9). There seems to be some confusion regarding CALIBRATION of the SSV with USE of the SSV during emissions testing. 1066.650 contains a calculation for determining C_d during CALIBRATION of the SSV. Here, both C_d and Re for the SSV are calculated using the value of Q_dot PROVIDED BY THE REFERENCE METER (Q_dot_ref), and iteration is not required. 1066.652(b) deals with USE of the SSV to measure flow DURING A TEST, when there is no reference meter to provide a value of Q_dot. Since C_d and Re both depend on Q_dot, it is necessary to choose an initial “guess” value for C_d, determine a “guess” Q_dot from that, determine a “guess” Re from that, then determine a more correct value for C_d from that based on the calibration curve. This process should be repeated until the value for C_d converges to within some limit. Alternatively, as stated in the original comment, Re could be defined in terms of the ideal (1-D, inviscid) flow rate through the SSV, and C_d would be expressed as a function of this. 1066.140(g)(9) points to 1066.650 for purposes of applying statistical criteria to validate the C_d vs Re equation. It mentions nothing about iteration. New comment - Fall 2013

New comment - Fall 2013

New comment - Fall 2013

New comment - Fall 2013New comment - Fall 2013

New comment - Fall 2013

New comment

Should be allowed - results in nominal excursions over 100, most of the mass collected will be at < 100 cm/s

Partially changed - Didn't change Class 3's and 2b's or ALVW, also specified underpowered as <0.024 hp/lbmIs now "(e)(2)" Partially changed - Didn't change Class 3's and 2b's,

also specified underpowered as <0.024 hp/lbm. Did address ALVW

New comment - Fall 2013

New comment - Fall 2013

New comment - Fall 2013

In the revised language, a UDDS was inserted but no mention of the required 12-36 hour cold soak per §86.167-17(g). Recommend revising the newlanguage in 1066.835(f)(1) as follows ( blue font): 1066.835(f)(1) 1st 2 sentences: "Prepare each test vehicle for a series of tests according to 40 CFR 86.132-00 (a) through (g). If the vehicle has been tested within the last 36 hours concluding with a 12 to 36 hour soak, continue on to paragraph (f)(2) of this section, otherwise perform an additional UDDS preconditioning cycle concluding with a 12 to 36 hour soak. As an alternative to the 12 to 36 hour soak..."New comment - Fall 2013

New comment - Fall 2013

New comment - Fall 2013

New comment - Fall 2013 New comment - Fall 2013New comment - Fall 2013

New comment - Fall 2013

New comment - Fall 2013

New comment - Fall 2013

New comment - Fall 2013

New comment - Fall 2013

New comment - Fall 2013New comment - Fall 2013

**Comment #1:** "Through model year 2021, manufacturers may use the test procedures specified in paragraph (c) **or**(d) of this section." This could imply one or the other, but not elements of both which is a migration path both OEM's and agencies will need for implementation. Suggest minor wording change which reflects what we believe the intent was as follows: "Through model year 2021, manufacturers may use the test procedures specified in paragraph (c) or (d) of this section, or using good engineering judgment elements of both."
Phrase remains confusing as it could mean 1066.430(j) cycle energy equations, which was not the agencies intent. Suggest keeping the language consistent with 1066.430 (b)&(c) as follows ( blue font) or delete: "...determining road load parameters and applying acceptable speed tolerance criteria."New comment - Fall 2013

New comment - Fall 2013

86.117-96(c)(1)( ix ): Adopted ethanol recovery of +/- 5% but increased propane from +/-2 to +/-3%. Should retain 2% because this fundamentally affects shed mass determination (volume) and +/-2% is consistent with ARB regulations and chassis site diagnostics. 86.117-96(c): Alliance / Global recommends changing the ethanol retention test to " ...on installation, or upon major shed modifications". Current CFR requires ethanol retention twice a year but this is burdensome and serves little purpose beyond the more frequent propane retentionNew comment - Fall 2013

Proposed for deletion - but inconsistent with 1066. Also see Tier II comment below

Proposed for deletion - but what do we use for Tier II vehicles?Important - cold testing has no part 1066 phase in like 86.101, should

add something after part 1066 like "...as described in 40 CFR part 1066 per the part 86.101 phase in allowances;" Expanded comment identifying other CFR sections - below

Same comment plus concern over not referencing 86.101 for phase in allowances (see "85 & 86 Multiple" comment below)

No changes made. EPA is evaluating factor, but didn't address the measurement proposal. Again the Alliance / Global recommends emissions be a measurement with the ethanol adjustment factor being optional. Additionally industry believes a 10% value is too high.New comment - Fall 2013

## EPA Response

Noted.

Noted.

Noted. EPA is working with the Alliance/GA and ARB to try to come to an agreed upon way forward within the limitations of changes that can be made in this rulemaking.

A road-speed fan is required for (d), there are no other fan options. EPA is procuring a portable road-speed fan. For EPA, constant speed fan testing will be the norm. EPA will test with a road-speed fan at the manufacturer's request. Manufacturers always have the option of making representative testing claim (either for or against the use of a road-speed fan) under 40 CFR 1065.10(c)&(d).EPA has added "one foot grid" to 1066.105(c)(3)(iii).

EPA has made this change.

EPA has made this change.

EPA will not add the suggested language. See EPA response to 1066.105(c)(2) above.

EPA will change the time requirement to report out to the tenths decimal place. We will also add language in the first sentence that directs you to follow 1066.122 Table 1 for recording frequency.EPA has corrected this typo.

EPA has revised this section, but would like to retain the individual desciptions and calculations by phase for each drive metric. We have added a new paragraph (iv) to denote energy based drive metric composite determinations.

EPA has made this change.

EPA has added reference flow meter information and linearity requirements for volumetric flow as a new 1066.137(c) to address molar/volumetric flow concerns. EPA will not revise 1065.340 to add "raw exhaust" flow to the title because we prefer to keep raw exhaust flow meter calibration separate in 1065.330, even though we acknowledge that 1065.330 references the dilute flow meter calibration in 1065.340 for SSV and ultrasonic based raw exhaust flow meters. The flow meter calibration procedures in 1066.140 and equations in 1066.650 are only applicable for SSV and ultrasonic (note that there is no ultrasonic procedure as the section is [Reserved] raw exhaust flow meters, thus the guidance to rely on the manufacturers calibration procedure as given in 1065.330 takes precendent. As such, since 1066.140 will primarily be used for dilute exhaust flow meter calibration, we would prefer not to change the section title. EPA has corrected the numbering issue.EPA has added that you should assume an initial value of Cd

of 0.98 to 1065.640(d)(1) and 1066.650(b)(2)(vi).

EPA has made this change.

EPA has made this change.
EPA has made this change.

EPA has made this change.EPA has made this change.

EPA has made this change.
EPA will not make a change to 1066.814(e)(2), however we will put language into the preamble that will provide a pathway forward for manufacturers that find themeselves in this situation. EPA will consider the allowance to use higher average FFVs, within the constraints of conventional PM sampling systems,based on the outcome of CRC E-99. We realized that the E99 test program may not be done before finalization of this rulemaking. We commit to review the E-99 results and if changes to allowed FFVs are warranted, we will make a change to 1066 or issue guidance until the time where 1066 can be revised.
EPA has previously made changes to this paragraph and the agency believes that the underpowered vehicle requirements and the use of ALVW are clear, especially give the fact that this is stated in the standard setting part in 40 CFR 86.1816-18.EPA has previously made changes to this paragraph and the

agency believes that the underpowered vehicle requirements and the use of ALVW are clear, especially give the fact that this is stated in 86.1816-18 as well as 40 CFR 1066.831(f)(2).

EPA has made this change.
EPA has made this change.

EPA has made this change.

EPA has made this change.EPA has made this change and added the AC17 criterion to

1066.695 (Recordkeeping) as a new 1066.695(w).

EPA has made the suggested changes, and added in a requirement to report the percentage of time outside of the tolerance for temperatures and humidity in (o), (q), and (t).

Part 1065 has been inconsistent in its description of air used in PFDs and calibration gases. 1065.140(a) originally used the term "synthetic" to describe air, while 1065.750 used the term "purified synthetic". In the LD Tier 3 NPRM, EPA made the decision to commonize the description and go with the term "purified" to describe air. This purified air can either be ambient air scrubbed of contaminents or an air mixture generated from combinding pure oxygen and nitrogen gases. In both of the cases described here, the resulting air product is purified air. EPA prefers to use the term purified air thoughout 1065 and has added a new definition for purified air to 1065.1001. EPA has made this change EPA has made this changeEPA has noted in 1065.1010(f)(44) that this specification has

been withdrawn. Even though it has been withdrawn, the specification is still available from ASTM. At this time we plan to leave the specification in place, but may replace it in the future if another specification becomes available. EPA is working on revising the 1065.710(b) Table 1 fuel specification and the revised specifications are not available for review at this time. We note that the Alliance/GA is concered about what the blended and confirmatory tolerances will be for Ethanol and any additional fuel property changes.
Noted.
EPA has added a definition for purified air to 1065.1001.
EPA has made this change.
EPA has made this change.

Even though it has been withdrawn, the specification is still available from ASTM. At this time we plan to leave the specification in place, but may replace it in the future if another specification becomes available.This exemption is reasonable any time factors are used in the

determination of NMOG as allowed in 1066.665. However, these exempted procedures and checks should be specifically called out in this paragraph and not generically stated. EPA recommends using the following language and will add this to 86.101 as a new paragraph (a)(7).(a)(7) For exhaust emissions testing with low level ethanolgasoline blends less than 25% ethanol by volume, if using the NMHC to NMOG conversion factors described in 40 CFR 1066.665(c) instead of measurng oxygenates as described in 40 CFR 1066.665(a), you do not have to follow any of the ethanol-gasoline blend specific test procedure or diagnostic requirements in this Part 86.

EPA has made this change.

EPA has made this change.Noted. EPA will take this into consideraiton when making

changes regarding E0 testing for FE, however we do not have any revised regulatory language available for review at this time. EPA has added revised paragraph 86.113-04(a)(2)(ii)(D) to point to 1065.710 for cold temperature fuel specifications. "(D) The vehicle must meet the applicable cold-temperature standards using E1X test fuel specified for cold testing in 40 CFR 1065.710(a)." EPA has added a requirement as 86.101(b)(2)(iii) that requires the use of the 1066.665 NMOG equations for any vehicles comlying with Tier III. "(iii) Use 1066.665 to determine NMOG for any vehicles certified to the Tier 3 emission standards specified in subpart S of this part." Noted. EPA will take this into consideraiton when making changes regarding E0 testing for FE, however we do not have any revised regulatory language available for review at this time. EPA has added a requirement as 86.101(b)(2)(iii) that requires the use of the 1066.665 NMOG equations for any vehicles comlying with Tier III. "(iii) Use 1066.665 to determine NMOG for any vehicles certified to the Tier 3 emission standards specified in subpart S of this part."

EPA will retain the ± 2% requirement. EPA has changed the requirement for ethanol/methanol retentions in the introductory paragraph (c) to state that "Using good engineering judgment, the methanol retention only needs to be performed upon initial installation and after major maintenance." Note that good engineering judgment may dicated that this retention be performed more frequently in instances wherea vehicle is being tested utilizing E85 fuel (a leak here could affect your ability to comply with the standard).EPA has made the following addition to the introductory

paragraph of 86.117-96: "For evaporative and refueling emissions testing with low level ethanol-gasoline blends less than 25% ethanol by volume, if using the total hydrocarbon equivalent factor(s) described in 86.1813-17(a)(1)(iv) instead of measuringethanol, you do not have to follow any of the ethanolgasoline blend specific test procedure or diagnostic requirements in Part 86."

86.167 has been removed. Please see response to the 86.167 comment below.

In light of the revision to the part 1066 implementation language in 86.101(b)(1), a vehicle manufacturer can implement elements of the AC17 test procedure in 1066.835, without having to fully implement part 1066 before the required MY deadline of 2022. Thus a pathway exists for certification of Tier II vehicles using 1066.835 in conjunction with 86.101(b)(1).Phase in allowance is in 86.201(b), specifically "(b)

Manufacturers may certify vehicles based on data collected according to previously published cold-testing procedures for model years through 2021. In addition, we may approve the use of previously published cold-testing procedures for later model years as an alternative procedure under 40 CFR 1066.10(c)." In discussions with the Alliance/GA, the real concern is that the part 1066 cold testing procedures are comperable to the part 86 procedures. EPA's intent was not to change the procedures when migratingthem to part 1066. The Alliance/GA will review the cold temperature testing procedures to ensure that part 1066 is comperable to part 86. EPA has added a sentence to 86.201(a) referencing 86.101 for requirements on the transition to part 1066. "See §86.101 for guidelines regarding transitioning to 40 CFR part 1066." EPA has changed the reference to 1066 subpart F. EPA will add a reference to 86.101 in 86.1801. See last issue regarding parts 85 & 86.

EPA intends to allow a manufacturer to either measure ethanol to determine THCE or use a factor, however we do not have the revised regulatory text ready for review (including any revision to the factor) at this time.EPA has added the following sentence to paragraph (a) of

86.1801-12: "References in this subpart to 40 CFR part 86 generally apply to Tier 2 and older vehicles, while references to 40 CFR part 1066 generally apply to Tier 3 and newer vehicles; see 40 CFR 86.101 for detailed provisions related to this transition." 85.1515 covers Independent Commercial Importers. The referernce to 1066 in this section is with respect to dynamometers and states that the dynamometer must meet the requirements of 86.108 or part 1066. As such we see no need to provide a transition here, as you have the option to test either way and there is no substantive difference between the dynamomters. Good engineering judgment would dictate that the dynamometer verifications in 1066 subpart C be implemented all together rather than partially. It should be noted that those required upon initial installation and after major maintenance are only required for dynamometers installed for use on model year 2022 and later vehicles (initial installation) and for dynamometers currently meeting the requirements of 1066 subpart C that undergo major maintenance.