| Comment | For certification, ARB currently requires multiple tests for
heavy-duty diesel conversions to alternative fuels. This is true
for either dedicated alt fuel or dual-fuel (diesel-alt fuel
mixture) conversions. These test cycles are run on a HD engine
dynamometer and include Federal Test Procedure (FTP), European
Stationary Cycle (ESC), Not-to-exceed (NTE) and Supplemental
Emission Test (SET). US EPA requires only the FTP. CEE believes
that this additional cost, up to four times, is a significant
barrier to companies who wish to certify their systems in
California.
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