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.