Mr. Rijnders provided an update and background to the dual-fuel work of the Heavy Duty Dual-Fuel Task Force (HDDF TF) within the GFV.
5. Mr. Martinez (European Commission) indicated that Regulation 582/2011 (Euro VI) concerning dual-fuel that the 3rd round of Comitology adopted in July 2013 still is in progress. Publication is expected soon, by the end of January 2014.
6. Decision by the 66th GRPE endorsed the GFV proposal to develop a new UN regulation for HDDF retrofit systems. The initial basic principles have been discussed in the first instance and ACEA/OICA have made suggestions about the framework for a new regulation. AEGPL also has begun developing an initial document that can be a starting point as the basis for the new regulation.
7. Timing of the Retrofit Amendments is now targeted to be completed by the June 2015 WP29 meeting based on the following schedule: 1) an informal document is anticipated for the June 2014 GRPE-69 meeting; 2) a formal document is anticipated in January 2015 for the GRPE-70 meeting and for adoption; 3) If this occurs then the amendments could be approved by WP29 in June 2015.
8. Mr. Stoehr (AEGPL) prefers a robust and usable framework and draft based on experience gained in the field. He cautions about rushing the development process to ensure that the amendments that are developed will be functional.
9. Organization of the activities of fundamentals, principles and process. 1) A chair needs to be selected; 2) NGV Global (Jeff Seisler) will provide secretariat services to the group (which has been done previously on an ad-hoc basis, as needed by the previous co-chairmen – Mr. Renaudin and Mr. Dekker). 3) Mr. Renaudin will not chair this new retrofit activity, however, Mr. Dekker (TNO) as a ‘neutral’ stakeholder could chair the new retrofit work subject to the group’s approval.
10. When asked, the group strongly supported Mr. Dekker as the Chairman overseeing the new retrofit work of the HDDF TF.
11. Jaime D’Alamo (NGVAE) (not present at this meeting) informed Mr. Rijnders prior to this meeting that he is leaving the association so, in the first instance, NGVAE will not have a representative to the GFV until a replacement for Mr. D’Alamo is found. This might be provided through an NGVAE member company on an interim basis.
12. Fundamentals and principles of HDDF retrofit have been discussed and agreed: first Euro IV and Euro V will be completed, with Euro VI to be discussed by the European Commission. Only type B dual-fuel engines will be addressed. Mr. Martinez said that a precedent has been set in the Retrofit Emissions Control (REC). Care must be taken to make the regulations robust but not overly restrictive.
13. Mr. Whelan indicated that the US regulations for dual-fuel retrofits were made somewhat less rigorous in deference to motivating the technology to develop and move forward in the marketplace. Clearly, however, there will be different views between the original equipment manufacturers (OEMs) and the retrofit industry.
14. There is a general discussion of the retrofit vs OEM approach to developing the regulation. The retrofit industry does not have the same, large development budget as the OEMs, therefore, it is better and easier to begin with Euro IV and V.
15. The Chairman indicates that it should be possible to develop a robust retrofit regulation for the earlier Euro stages. The final regulation must be accepted in its entirety (under the 1958 agreement). Contracting Parties (CP) might still have or will use conditions for retrofit that are less rigorous than the new activity to develop a UNECE Regulation. This should not create a problem to agree with the new ECE Regulation. But if a CP has already more stringent National Regulations for retrofit than this could create problems because the CP has to accept UNECE certificates without creating additional, more stringent national requirements.
16. Mr. Stoehr indicated that care also must be taken to focus on the emissions results of these heavy-duty dual-fuel retrofits. He will provide some documents from Germany TUV (in English) as a possible guideline. Emission limits: even if the parent engine (the diesel) is not compliant with the emission limits, the parent engine equipped with the dual-fuel retrofit system shall meet the original emission values. As with other working groups the HDDF TF should prepare an ‘open issue list’ particularly when implementation ultimately will be at the GRPE level.
17. The Chairman proposed an example of an Excel-format ‘open issue list’ for organizing our pending issues and decisions in the task force, GFV and GRPE. The GFV agrees to use this format.
18. Prelude to the OICA documents: two definitions are proposed for retrofits and conversions:
In light of these definitions, OICA assumes that the retrofitting of any dual-fuel system (on either a running vehicle or a running engine) has to be considered as a “conversion” and, therefore, the converter becomes the new engine manufacturer and takes the full responsibility for the engine in-service conformity, while the original engine manufacturer shall not be considered responsible in any manner of the non-compliance of a converted engine system
19. Discussion: it is noted that not all the dual-fuel systems can be considered “conversions”, as defined by OICA. Furthermore it was recognized that the term ‘conversions’ is a new working and definition that could effect more kinds of modifications, like chip tuning. It is a fundamental discussion that will affect other regulations.
20. The GFV participants agreed to keep the historical wording “retrofit” system for our assembly of gas components fitted in after-market equipment in order to avoid any confusion. A sub-classification among HDDF retrofit systems can be taken into account in order to distinguish those systems which “substantially” modify emission and operating strategies from those that do not. In this case, a clarification about “substantially” is also needed. Ideas like intrusive and non-intrusive systems also need clarification.
21. AEGPL asked for further clarifications about which “responsibilities” the retrofit system manufacturers should take in the case its system was considered to be “substantially” modified (original) emission or operating strategies. In other words, excluding commercial responsibilities that are out of R. 49 scope, as well as conformity of the engine production (being the engine is “used” and not produced by the retrofit system manufacturer) which responsibilities related to provisions in R. 49 should be regulated? AEGPL asked to clarify the in-use conformity responsibilities.
22. AECC commented (GFV 29-05rev1): regarding the OICA definitions of “conversions” and “retrofits”, AECC highlighted that installation of an SCR system (to meet Retrofit Class III of the recently-agreed retrofit Reg.) or a combined DPF & de-NOx system (to meet Retrofit Class IV) would fall in the definition of “conversions” with all the legal consequences, i.e. responsibilities related to R 49 and to the Retrofit of Emissions Control (REC) (as proposed by OICA).
23. The Chairman concluded that this is a fundamental discussion and should be discussed again; also with OICA and AECC present.