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Comment 1 for Procedures for the Exemption of Add-On and Modified Part(s) for On Road Vehicles/Engines (ampts2020) - 15-1.

First NameKeith
Last NameCavallini
Email Addresskeith@greendieselengineering.com
Affiliation
SubjectText clarification on page 21 (c)
Comment
In the modified text, page 21, section (c), it discusses a
manufacturer might need to provide data to compare in-use
monitoring performance ratio (IUMPR) data of the OBD system stock
vs. modified.  Has/is CARB releasing the procedure to run this type
of testing?  IUMPR is mandated by EPA/CARB, but it is not field
monitored to a large degree.  Many OEM applications do not meet or
are right at the minimum thresholds.  It could take many thousand
miles of mileage accumulation at various
temperatures/altitudes/loads for the ratios to even register and be
cost prohibitive and burdensome for small manufacturers of
after-market components.  The large OEMs have fleets of vehicles
dedicated for this type of activity and small companies do not have
the same resources.

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Date and Time Comment Was Submitted 2020-12-03 05:34:38

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