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.

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.

54. As was discussed in the first part of the meeting on the previous day, the modular structure of the draft has been suggested, providing three different type of approvals:
1) approval of a HDDF retrofit system;
2) approval of a HDDF retrofitted engine; and
3) approval of a HDDF retrofit vehicle regarding the installation of a retrofit HDDF engine.

The main text includes scope, general provisions and general definitions. All specific topics regarding the three different (above mentioned) approvals have been moved to the appropriate Annexes in the first draft text produced by AEGPL.

55. The group expressed concerns about possible loopholes with respect to R49 when approving a HDDF retrofitted engine and HDDF retrofit vehicle with a retrofitted HDDF engine. Since the most important part is related to HDDF retrofit systems, the group decided to delete Annex 2 and Annex 3 from AEGPL proposal and to develop Annex 1. Future meetings will focus on and complete the discussion on HDDF retrofit systems. The group agrees to take the AEGPL text as starting point for further development.

56. The Annex 1 (HDDF Retrofit systems) of AEGPL proposal was presented. Mr. Castagnini explained the difference between updated text and previous versions.

57. Specific retrofit systems definitions (definitions applicable only to HDDF retrofit systems) were moved from the main text to Annex 1, in order to avoid confusion with other type approvals. The requirements to allow parent engines not meeting the baseline emissions would be enforced. OBD data should be monitored and no detected malfunction shall be active. The group recognized the difficulties of finding an existing engine that meets the emission limits, especially if the engine was certified to a previous emission level than the current Euro level. But the importance of having the engine fulfill the baseline emission limit is clearly recognized. The group agrees to find a solution to this challenging problem.

58. A general discussion took place about the ability to find a diesel engine in compliance with the emissions limits and the impacts of performing a conversion to dual-fuel, as well as how to include this in regulatory language (if possible). System suppliers spend a great deal of money and energy trying to find compliant engines that can be converted if they are going to improve the emissions over diesel. There are a variety of solutions possible but in this forum there was general brainstorming solutions proposed. For example, Mr. Bleuler (TUV) proposed to allow wider engine family definitions in order to reduce the difficulties of finding parent engines that are in compliance with baseline emission limits.

59. AEGPL: If it is agreed that the original emission limits must be maintained (or improved) in the dual-fuel mode even when the parent engine is not compliant in the diesel mode, AEGPL asked to evaluate the possibility, in these cases, to allow for some tolerance of the limits in line with those accepted during COP or ISC (to be investigated). In addition, creating a less stringent engine family definition would ease the practical problems faced by retrofit system manufacturers when searching for compliant diesel engines.

60. Annex 1: OBD requirements have been defined. Since there is no communication between the ECU and dual-fuel ECE, a switch back to diesel mode is prescribed in case of any detected malfunction.

61. Annex 1: Extension of the application range requires a simplified test sequence that can be performed either on a representative engine equipped with the HDDF retrofit system or on a vehicle equipped with the representative engine and the HDDF retrofit system (to be defined).

62. Annex 1: Installation manual shall consist of two parts: 1) describing the HDDF retrofit system and a list of components; and 2) installation instructions for the specific vehicle. This installation of the manual for the parent vehicle must be
supplied to the regulatory authority

63. Annex 1: End user manual informs the end-user about the characteristics and safety features of the installed HDDF retrofit system.

64. Other Annexes will be defined over time after the completion of Annex 1.

65. Written remarks received from AECC, John May. Annex 1, 3.1 were discussed (AECC was not able to be present at the meeting). “If the parent engine is not equipped with one or more devices listed above, engines with these devices are
allowed.” "In this case they should not be allowed to be part of the same engine family.” Mr. Dekker indicates that, in the light of their experience, sometimes a retrofitted engine in dual-fuel mode performs worse in the presence of EGR than in
absence, for instance. More discussion on the family definition is required.

66. Furthermore AECC mentioned in their written comments that they agree with the possibility to consider CH4 as a GHG contributor.

67. Annex 1: 6.3.2 Limit values and relevant pollutants for ESC and ETC cycles: that this needs to be clearer that this applies to the emissions both before and after retrofitting; that the manufacturer cannot be allowed to choose whether or not to include deterioration; and durability of the retrofitted system should have to be demonstrated, rather than simply taking assigned deterioration factors (DFs). There was a broad and general discussion of this issue.

68. AEGPL explained its proposal: The application of DF’s and the testing with deteriorated components (aged after a durability test as in REC) have to be an alternative in order to avoid a double durability burden. This is based on the consideration that R. 49 DF’s (05 and 06 series of amendments) in the dual-fuel mode have been confirmed to be identical to those applied in diesel mode. In other words, the language for the OEMs allows them to choose to include deterioration factors, so why not the retrofitters as well?

69. Discussion: if the concern regards the guarantee that the retrofit system is generically durable, the respect of endurance testing and requirements set out in R67/01 and R 110 could be already satisfactory. As for environmental aspects, that observation offers also an alternative solution to the application of DF’s: engine emission tests could be carried out fitting gas components aged in accordance with R67/01 or R 110 endurance tests. But this requires further discussion. There are concerns about the complication and the cost of the testing protocols that would be imposed on retrofit suppliers.

70. Mr. Rijnders indicated that the AECC remarks are valid and further discussion will be required.

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.