Proposed new heavy-duty dual-fuel retrofit regulation
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Reference Number: GFV-25-04
Origin: LG Europe
Date: 24 March 2013
Proposal Status: Superseded
Related Documents:
GFV-27-04 | Working draft of the proposed new regulation on heavy-duty dual-fuel retrofit systems
Informal Group on Gaseous Fueled Vehicles | Session 25 | 14-15 Mar 2013

32. Mr. Castagnini introduced a proposal to create a new UNECE regulation for the provision of HDDF retrofit systems type approval. The task would be to draft a new regulation on uniform provisions concerning the approval of specific LPG (liquefied petroleum gases) or NG (compressed natural gas/bio-methane/liquefied natural gas) dual fuel retrofit systems to be installed in heavy duty vehicles equipped with compression ignition engines. The new regulation might also apply to HDDF retrofit systems for agricultural and forestry tractors and non-road mobile machinery equipped with compression ignition engines.

33. Scope applies to heavy duty dual-fuel retrofit systems for use of natural gas or LPG in compression ignition engines of vehicles of categories M2, M3, and N approved according to R49. Euro III and older engines are excluded. Mr. Castagnini asked the group to agree to extend the scope of the regulation to dual-fuel retrofit systems intended to be fitted on CI engines having a power rating higher than 18 kW but not more than 560 kW installed in non-road mobile machinery (variable, fixed speed or installed on category T vehicles).

34. Definitions are provided for ‘Specific LPG (NG) Heavy Duty Dual-fuel (HDDF) retrofit system of an approved type; ‘dual-fuel retrofit system type; and dual-fuel engine.

35. Main dual-fuel definitions are taken from OEM dual fuel R49 definitions. Other definitions: ‘original engine,’’ ‘the engine family’, parent engine and ‘application range.’ (see document GFV 25-04) refer to specific retrofit system issues. Only D-F retrofit system types 1-B, 2-B and 3-B would be allowed.

36. The HDDF retrofit system shall be tested on the parent engine and the type approval refers to all engines belonging to the engine family. The application range can be extended to other engines using simplified procedures (for example PEMS test).

37. Regarding parent engine exhaust emissions, the test consists in the same cycles as in original R49 type approval, performed in both diesel and dual-fuel mode
38. Durability and OBD requirements are defined.

39. Instruction manuals must include an installation manual and a user/s manual.

Comments on Mr. Castagnini’s presentation

40. Mr. Whelan (CAP): Developing a competent retrofit system is a very expensive process (in the range of a million dollars). The retrofit will not perform to the same degree as an OEM system. Thus, if all the requirements are to be fulfilled, the retrofit systems could be too expensive to get into the market.

41. Mr. Rijnders clarified that a completely new regulation is recommended as opposed to amending R.115.

42. Mr. Del Alamo raises the issue that a new Stakeholder Consultation at the European Commission (comments due 8 April 2013) on the revision of Directive 97/68/EC on Non-Road Mobile Machinery includes dual-fuel engines. He clarifies that that this would apply to new, OEM vehicles and not to retrofits.

43. Mr. Renaudin supported the idea of creating a new and separate retrofit regulation but first for road vehicles and at a later time to include non-road machinery. He suggested to write the new regulation in a modular structure, so there could be common dual-fuel principles and different annexes for different applications. For example, a separate annex for non-road vehicles (if it is accepted) should be developed at a later time without affecting other parts of the regulation.

44. Mr. Piccolo preferred that the dual-fuel retrofit regulatory work begins in parallel to the current dual-fuel regulatory work.

45. Mr. Rijnders expressed interest in supporting additional dual-fuel work but stated that the non-road machinery is not within the mandate of GFV. Mr. Dekker agreed that dealing with non-road machinery is completely different than over-the-road vehicles.

46. Mr. Renaudin suggested that the scope also could include the approval of a retrofit system for a single engine separate from the vehicle. Mr. Castagnini observed that currently there is no request from the industry for this solution, but it can be taken into account if it doesn’t delay other parts.

47. After many views were aired and discussed, Mr. Rijnders suggested that the debate be continued later in the GFV meeting (the second meeting day) so that the HDDF discussion can proceed since the work on the amendment to R.49 is on a very tight deadline and that GFV approval of the HDDF work is required, as a priority.