13. In earlier discussions it was decided that the heavy duty D-F retrofit regulation would be created as an entirely new regulation and not part of an existing one (for example, R.115). Also discussed was the idea to expand the regulation to apply to off-road and agricultural vehicles.

14. Alberto Castagnini (AEB) made a revised PowerPoint presentation on behalf of AEGPL, based on the originally circulated presentation from GFV 26, which was not made due to lack of time (based on GFV 26-07, retrofit heavy duty dual-fuel systems). The revised version now includes agricultural and forestry tractors as well as non-road mobile machinery in the title.

15. Mr. Rijnders commented that we will have to take into consideration at first only the HD road vehicles, with other non-road vehicles in the regulation’s title to be considered at a later time. Other regulations covering these vehicles (or their engines) must be reviewed to see if they are impacted. Also we have to bring forth a suggested change that R.115 applies only to light-duty vehicles.

16. Mr. Renaudin agreed with this approach. He indicated that the new regulation should address the type approval of retrofitted engines rather than of retrofit systems because a gas retrofit system introduces several modifications to the original engine system, for instance , in comparison with Retrofit Emissions Control (REC) systems. Furthermore, there must be details and solid principals that apply to the other non-road vehicles and these may originate from the first round of retrofit regulations that will be created.

17. Mr Piccolo noted that also RECs -other than very simple passive filters- introduce relevant modifications to the engine system. Just for this reason, REC regulation provides proper requirements on that aspect as well as R 115 does in the case of gas retrofits. Retrofit-system-type-approval approach is applied in both regulations, and modifications to the original vehicle/engine are taken into account and properly validated. Mr. Piccolo added that a retrofitted engine would be considered as a new engine, i.e. a “new type”. Hence, at least in EU, the “new engine type” will have to comply with the latest emission stage, even if the base diesel engine conforms to previous stages, which he indicated could impede de facto the retrofitting.

18. As for the inclusion of non-road vehicles, Mr. Cagnoloti proposed to include them in the first instance due to the fact that the engines and operational principles are the same.

19. Mr. Stein suggested that the time table for the HDDF retrofit regulation is not realistic. He noted that the REC regulation took three years to create. He referred to the non-road vehicles and asked if it is desirable for the industry to bring this forward.

20. Mr. Rijnders acknowledged that the retrofit system certification was requested at the very beginning of the work undertaken by the HDDF TF. He said it is important to take some precautions about enlarging the scope to include non-road vehicles at the beginning of the effort to create dual-fuel retrofit regulations.

21. Pierre Laurent (CLEPA) asked why the word ‘retrofit’ is being used. He suggested it would be better from an editorial perspective to use the word ‘replacement.’ In response, Mr. Rijnders suggested that these two principles are different: A ‘replacement’ takes the place of the same type of system that has failed. But ‘retrofit’ indicates a new system is put onto an existing engine/vehicle. Maybe this will be clarified when we work on the document, and provide a good definition of ‘retrofit’. (Mr. Stein agreed with Mr. Rijnders’s interpretation.)

22. Mr. Renaudin asked if we can create a definition of ‘retrofit’ as part of the work at the VPSD, which is working on harmonization of vehicle definitions.

23.There is further general discussion on the principal of defining a ‘retrofit’ versus ‘replacement’ engine as well as including non-road vehicles into the scope of work.

24. Mr. Rijnders summarized what he believes should be presented to the GRPE on this issue. We will ask to work on the new regulation that has modules and we are taking into consideration the retrofit of engines and vehicles as well. We also have to take into consideration the expanded use of LNG as a vehicle fuel. This GFV group facilitates the market introduction through the regulations that are written. But the principals of retrofit engines also can be taken on board for non-road and agricultural vehicles. He summarized that we have a consensus about HDDF engines; to work on retrofit but also work on a ‘module’ basis to include agricultural tractors and non-road vehicles if the industry supports this additional work. The only point we need to ask GRPE is about working on a model regulation and to inform them at what stages we might work to include other engine types.