Proposed Amendments to Verification Procedure Public Workshop

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