| First Name | Keith |
|---|---|
| Last Name | Cavallini |
| Email Address | keith@greendieselengineering.com |
| Affiliation | |
| Subject | Text 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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| Original File Name | |
| Date and Time Comment Was Submitted | 2020-12-03 05:34:38 |
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