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Proposed Amendments to Verification Procedure Public Workshop

This workshop outlines proposed amendments to the 2002 verification procedure ensuring real and durable emissions reductions. The amendments address various aspects such as conditional extensions, fuel-based strategies, in-use compliance, verification transfers, and more. Changes in sales requirements, NOx reduction classifications, testing for NOx systems, and in-use compliance modifications are proposed. The procedure also covers testing proposal deadlines, verification transfers, record-keeping requirements, and testing and installation specifications. Proposed NOx reduction thresholds, aftertreatment test requirements, and NO2 pre-conditioning specifics are detailed. Language adjustments for sales and monitoring systems, as well as fuel testing modifications, are included to enhance compliance.

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Proposed Amendments to Verification Procedure Public Workshop

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  1. Proposed Amendments to Verification Procedure Public Workshop July 31, 2007 California Environmental Protection Agency Air Resources Board

  2. Verification ProcedureBackground • Approved May 2002 • Ensures that technology achieves emissions reductions of diesel PM and NOx that are real and durable • Requires warranty coverage and in-use compliance testing • Amendments adopted February 2004 and March 2006

  3. Outline of Proposed Amendments • Conditional Extensions • Fuel Based Strategies • In-Use Compliance • Verification Transfers • Acceptance Of Existing Data • Record Keeping • Consideration Of Non-CCR Title 13 Compliant Test Fuels

  4. Outline of Proposed Amendments • Sales and installations requirement • Verified NOx reduction classifications • NO2 pre-conditioning • Require functional testing and additional requirements of monitoring and notification systems • Additional requirements for SCR systems • Require parts list and installation manual

  5. Outline of Proposed Amendments • Testing requirements for NOx systems • Required test cycles for off-road applications • Demonstration of sales or pursuit of sales in California • End user installations

  6. Conditional Extension • Conditional extensions may be requested for on-road applications of currently verified systems • Expedites the verification process for reliable systems that can be applied to a broader range of applications • Provides the opportunity to sell systems while obtaining data and information required for a full verification • Will satisfy fleet rules

  7. Fuel Based Strategies Testing Modifications • All fuel based strategies (including fuel additive based systems) must comply with testing per Section 2710 • FTP cycle for on-road applications only • Off-road and stationary applications must adhere to the appropriate test cycles per Section 2703(e)(2) and 2703(e)(3)

  8. In-Use Compliance ModificationsTesting Proposal Deadlines • Testing proposals for phase 1 and phase 2 • Must be submitted no later than 90 days after 50th unit is sold (phase 1) • Must be submitted no later than 3 years after 50th unit is sold (phase 2) • Proposals must include: • Information required in the in-use test report • A test plan • A test engine/vehicle description • A list of candidate test systems

  9. In-Use Compliance ModificationsPhase 1 and Phase 2 Reports • Phase 1 Report • Must be submitted no later than 18 months after the 50th unit is sold • Phase 2 Report • Must be submitted no later than 4 years after the 50th unit is sold

  10. Verification Transfers • Applicants who wish to market another manufacturer’s previously verified system would have to: • Submit an Application • Provide documented approval • Demonstrate understanding of technology • Submit any required additional information

  11. Pre-existing Data • Pre-existing data and/or verifications from other programs (e.g. EPA, VERT, etc.) can be submitted for review • Pre-existing data may support conditional or full verifications • Applicants with pre-existing data are encouraged to apply

  12. Record Keeping • Applicants would be required to keep updated end user contact information and vehicle/engine information for each installed system • Records must be kept until the in-use compliance requirements are completed • Applicants receiving conditional extensions and conditional verifications must submit records one year after receiving their conditional status • Other applicants would submit records upon request by the Executive Officer

  13. Test Fuels • Test fuels for emissions and durability tests must meet California Code of Regulations, Title 13, Sections 2280 – 2283 • Some applications (e.g. marine vessels, locomotives, etc.) use fuels that do not necessarily meet these specifications • Staff proposes the addition of language allowing test fuels that are representative of in-use fuels for the above mentioned applications

  14. Sales and Installation • Include language that applicants, distributors, and installers must adhere to terms of the Executive Order • Violations may result in remedial action

  15. NOx Reductions • Propose that verified NOx reduction systems reduce NOx by at least 25 percent • NOx Reduction Classifications • Mark 1 > 25% • Mark 2 > 40% • Mark 3 > 55% • Mark 4 > 70% • Mark 5 > 85%

  16. NOx ReductionTest Requirements • Propose removal of additional testing with a test cycle that triggers elevated NOx emissions • Chemical reductant consumed during emissions testing would be measured and recorded

  17. NOx Aftertreatment Test Requirements • Durability Demonstration • Measure and record NOx upstream and downstream of the device for at least the first and last 100 hours • Field Demonstration • Measure and record upstream and downstream NOx for entire field demonstration period

  18. NO2 Pre-Conditioning • There must be at least three test cycle repetitions before and after the alternative 10 hour pre-conditioning period • Backpressure check before final emissions test and in-use compliance testing • Avg. backpressure within 30 percent of initial emissions test, or • For transient test cycles, backpressure does not exceed 60 inches of water for more than two percent of time over any test repetition, or • For steady state test cycles, backpressure never exceeds 60 inches of water

  19. Off-Road Test Cycles • Require control strategies for off-road engines/equipment to follow transient test procedures in the ARB off-road regulations • Variable speed engines must be tested on the Nonroad Composite Transient Cycle

  20. Off Road Test Cycles • Alternatively, applicants could test using the FTP cycle under the following conditions: • They receive authorization in a test plan approval letter dated prior to January 1, 2009 • They complete testing in a year

  21. Off Road Test Cycles • Prior to testing, baseline emissions of certified engines must be measured using test cycles with which they were certified • Executive Officer would require other test cycles more representative of intended applications

  22. Monitoring and Notification Systems • Applicants must demonstrate durability of all monitoring and notification system components of the control strategy • Test proposal of demonstration added to pre-application • Notification must occur while vehicle/equipment in operation and clearly visible to operator

  23. SCR Systems • Require monitors that measure available reductant and notifies operator when reductant supply is low • Require strong inducement method for operator to maintain reductant supply • Must be resistant to tampering • Ensure the quality of reductant is sufficient for proper SCR functioning

  24. Installation Practices • Verified device manufacturer must specify if end user may remove control system from original installed configuration and re-install it on other vehicles/equipment • Verified device manufacturer must specify proper methods of removing and reinstalling the control system

  25. Other Amendments • Require parts list and installation manual • May suspend application review if applicant fails to submit warranty reports, in-use compliance reports, and other required submittals

  26. Other Amendments • Executive Officer may require the applicant to submit records pertaining to their diesel emission control strategy at any time • Applicants that receive verifications, conditional verifications, or conditional extensions must demonstrate they have sales or are actively pursuing sales in California • Executive Officer may require additional emissions testing if it is necessary for a complete evaluation of the technology

  27. Other Amendments • For single unit testing, must conduct baseline testing before and after durability period • If baseline test after durability period is not technically feasible, applicant may request Executive Officer to waive requirement • Applicant and installer must ensure that system label is resistant to tampering and degradation from conditions of the environment

  28. Next Steps • Provide comments on proposed amendments by August 7, 2007 • Board Hearing on November 15, 2007 • Contact Information: Danielle Robinson Shawn Daley, Manager (626) 450-6109 (626) 575-6972 drobinso@arb.ca.govsdaley@arb.ca.gov • Please visit our website at: http://www.arb.ca.gov/diesel/verdev/verdev.htm

  29. Questions/Comments

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