CFR 

Citation

General

General

General

General

§ 1066.105

Variable Fan
1066.105(c)(3)

SC03 Fan

1066.137

1066.137

1066.410(b)

1066.410
1066.430(g)

1066.430(j)

1066.501

1066.650(x)
1066.652(b)

1066.710

1066.710

1066.710

1066.710
1066.710

1066.710

1066.814

1066.820

1066.831
1066.831

1066.832

1066.832

1066.835

1066.835
1066.835

1066.695

1065.140

1065.140

1065.655
1065.701

1065.710

1065.725

1065.1001

1065.1005

1065.1005

1065.1010
86.101(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

86.167
86.201

86.1811-04

86.1813
85 & 86 

Multiple
Alliance / Global Comments

General Comments

Further harmonization needed - EPA and ARB test procedures: 

●PHEV/HEV procedures

●EVAP

●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 ±2.80 incorrect per 86.230-11(c)(2) and 

historical figure C94-1 from 86.230-94

Comment: Should be ±1.70

1066.710 Figure 1: Typo in note between boxes 4,5 & 6, the minus sign "-" is separated from the numerical 

temperature "7.00 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 

"(220C)"

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 

maximums are "..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 

"(130C) & " (220C) 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 meet the 

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 (200F 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 2013
Did 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 cost
New 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 2013
New 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/lbm
Is 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 new language 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 2013
New 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 2013
New 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 retention
New 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 change
EPA 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 measuring 

ethanol, 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.