| 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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