Working draft of the proposed new regulation on heavy-duty dual-fuel retrofit systems
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Initial draft version of the 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 and dual fuel retrofitted engines to be installed in heavy duty applications”.

Reference Number: GFV-28-03
Origin: LG Europe
Date: 11 September 2013
Proposal Status: Superseded
Related Documents:
GFV-27-04 | Working draft of the proposed new regulation on heavy-duty dual-fuel retrofit systems
GFV-29-02 | Working draft of the proposed new regulation on heavy-duty dual-fuel retrofit systems
Discussion(s):
Informal Group on Gaseous Fueled Vehicles | Session 28 | 12 Sep 2013

5. Mr. Castagnini began his presentation of document GFV 28-02 (PowerPoint format). He outlined the state of play of the current regulatory situation of the R.49 amendments for Euro V and Euro VI. The regulations apply to both CNG and LPG

6. Mr. Renaudin indicated that he is unable to discuss the substance of the materials being presented because they were put on the website only the night before the meeting. He also indicated that he cannot speak on substantive elements of the proposal. He can give personal comments on the text but nothing official from ACEA/OICA. He said that there are sensitive political issues that need to be resolved in principle before technical concepts and details can be discussed or resolved. He also indicated there are some good elements in the existing text that he has reviewed preliminarily, however, his sponsoring organizations have not been able to provide feedback or instructions to him but certainly we can brainstorm about the content of Mr. Castagnini’s proposal. Mr. Renaudin expected to be able to craft a first text together with other stakeholders and then start the real drafting work. He felt at this late stage elements of text presented today create a precedent to which ACEA has to react. Mr. Renaudin indicated formally that [neither] he (nor OICA) want to be in a negative position reacting to a text but really want to contribute to a text from the very beginning. Mr. Renaudin will not discuss the substance of text now.

7. Mr. Castagnini responded that the text is a work in progress and represents only a preliminary view of the proposed amendments and includes the agreed principles discussed since 25th GFV – Rome, March 2013.

8. Mr. Rijnders recognized the situation and the late timing of the documents on the website. Mr. Rijnders felt it was fair to have a free and open discussion of the important issues listed in the presentation from AEGPL in this GFV session today.

9. There was a general discussion among the participants about Mr. Renaudin’s concerns, whether a text can be discussed or only principles can be discussed. Mr. Martinez (European Commission) suggested that some of the principles already have been discussed and it is reasonable to discuss aspects of the text. Mr. Del Alamo (NGVA Europe) said that the text was produced in order to speed up the process. Mr. Seisler (NGV Global) supported this comment indicating that the text is a (English term) ‘straw man’ text for discussion only. Mr. Piccolo (AEGPL) added that there was no intention to by-pass any of the stakeholders by preparing a preliminary text. He indicated that the text is an opportunity to look at what is in the presentation of AEGPL/Mr. Castagnini. He said that the current drafting effort was an exercise to support brainstorming. (GAR note: a “straw man” is a proposal intended by its authors to stimulate discussion towards the development of a better proposal.)

10. Mr. Rijnders concluded that: 1) there still are some principles to be discussed, for example if the regulation would apply to non-road vehicles; and 2) there is a draft text and that the group should look at what can be used that will contribute to a common view and asked Mr. Castagini to continue his presentation.

11. Mr. Castagnini continued his presentation. He clarified that the text is a brainstorming exercise that represents a lot of work in order to get the drafting process started. It was agreed in the last GFV meeting to have the structure of a text for a new regulation. Many elements not presented also can be added in subsequent meetings of stakeholders. Mr. Castagnini recognized that they would want to consider approving a retrofit system installed on an existing vehicle as well as a retrofit of an engine that has been prepared and approved as a ‘retrofitted dual fuel engine’.

12. Further general discussion: Mr. Renaudin asked (Slide 3 of the presentation) if there are changes in the OEM engine that are included in the dual-fuel system. He referred in the presentation to the point 1) approval of a HDDF retrofit system versus point 2) approval of a retrofitted HDDF engine as a separate technical unit (as requested by OICA). There is a discussion amongst participants. Mr. Dekker suggested that there might be two levels of changes; one might be a change of components versus operational changes. Mr Piccolo proposed to focus only on changes (either material or operational) that can have an impact on diesel-mode, that can be regulated via performance tests aimed at ensuring that emissions in diesel mode remains compliant with the original emission stage. Mr. Renaudin made a distinction between the retrofit of an engine approved for dual-fuel operation versus an engine that is not been prepared (or type approved) for dual-fuel operation. Changes in the injection system, for example, might have dramatic consequences on the diesel operation. He felt that the type approval possibilities must be clarified and then we could look at the retrofit applications available to comply with the approval procedure and how the retrofit system will be added to the existing engine.

13. Mr. Martinez indicated that care must be taken that a retrofit engine/vehicle is not used to circumvent existing regulations (i.e. R.67) on a ‘new’ engine/vehicle, which is in agreement with comments of Mr. Renaudin. Mr. Seisler added that, in principle, the regulations must not be constructed so that the dual-fuel system suppliers are confronted with barriers so high that they cannot remain in business, still assuming that the converted vehicles are in full compliance with the emissions and other regulations. A principle is discussed (questioned) if the retrofitter becomes responsible for in-service conformity once the vehicle has been converted.

14. Mr. Castagnini (slide 4) said that two annexes to the regulation are planned: one for the retrofit system itself (currently drafted text) and one for the retrofitted engine (to be drafted later).

15. There is further discussion of a legal framework as to which company is required to be responsible for the vehicle once the engine is converted. Mr. Renaudin is concerned that the rules at the Euro VI level must be discussed. But it may make sense to develop the rules and legal requirements for Euro IV and V first, and then progress to Euro VI. There is agreement on this principle. Mr. Martinez suggested that the D-F retrofit topic be raised at an upcoming Motor Vehicle Emissions Group (MVEG) meeting. Given that the exclusion of vehicles from in- use conformity vehicle sampling refers to any type of major modifications, Mr. Piccolo asked to deal with this issue for any type of after-market modifications, thus, with all the representatives of this industry in the Motor Vehicle Emissions Group (MVEG) within the European Commission.

16. Issue of what D-F engine type would the retrofits be applicable. After discussion the general feeling is that the D-F retrofit would be applicable to Type B engines (not specifying categories 1,2 or 3).

17. Engine family: emissions tests shall be carried out on one or more engines (parent engine) of an engine family sharing pre-determined criteria. There is a broad discussion about type approval and being able to find an engine that already complies with the emission limits. But the converter will have to ensure that the converted vehicle is type approved. This may be a problem particularly for an older or out-of-date engine. This is a difficult issue to resolve at this time; and one that could continue to plague conversion system suppliers. The issue is left open for future consideration.

18. How to proceed with the development of the new regulation? Should the document structure be proposed first and then move to develop the text, or can they be done in parallel, in the first instance? The first concept is that the text will be in alignment to the UNECE regulatory style (as opposed to considering at first the European regulations). Mr. Rijnders suggested to Mr. Renaudin that he propose a structure, giving consideration to the work already provided by AEGPL (GFV-28-03). Mr. Castagnini added that the text they prepared reflects the content of his presentation today. It would be desirable to use or consider which text might be appropriate for future use. But the forward progress will rely on a first draft of a structure, considering some of the basic principles already discussed (and for future discussion), with ACEA/OICA suggesting appropriate text that also might take advantage of some of the AEGPL work that already has been done. At the next meeting of the HDDF TF we will start the writing of the new document, possibly considering useful elements of what already has been produced.