| Comment | Thank for the opportunity to comment on the Proposed Amendments to
the Heavy Duty Engine and Vehicle Omnibus Regulation and Associated
Amendments.
Some of the proposed amendments enable a phase in for low load
cycle and clean idle regulations.
I wish to call attention to a recently published technical paper
from Achates Power showing that testing and analysis of a 10.6L
heavy duty diesel opposed-piston engine indicates the engine is
able to comply with the 2027 low load cycle and clean idle
regulations with a substantial margin (as well as the FTP and RMC
regulations). I've attached the technical note. It can also be
found here:
https://achatespower.com/wp-content/uploads/2021/06/Achates-Power-Ultralow-NOx-at-Low-Loads-and-Idle.pdf
Regards,
Larry Fromm
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