Comment Log Display

Technical comments on regulatory documents:
Appendix A:
- Page 10 paragraph 13 CCR 1958(i): The requirement to provide all
the items listed in (A), (B) and (C) represents an unnecessary
burden as some of the information is not relevant to environmental
performance and some information is not applicable to the US
market.  Also; it is not a simple copy/paste of a type approval as
California HMC will be significantly different from the European
HMC mainly due to the difference in evaporative requirements; the
California HMC most likely won't be type approved in Europe. 
Sections 0.2, 0.3, 0.4.2, 0.5, whole section B from 0.7 to 0.11.2
and 0.13 are not applicable to the US Market.  The whole section 2
contains a lot more information than required only for an emission
regulation.  The relevant information should continue to be the
information required in the current CARB application format and
information currently requested in the EV-CIS CSI.7 template.

Appendix B1:
- Page 9 paragraph C.12.2: Same comments than for 13 CCR 1958(i)
- Page 11 paragraph 8.3: The service accumulation option 4 is
allowing bench aging durability testing.  No proposed regulatory
text seems to describe any IUVP "In Use Verification Program" if
option 4 is selected.  IUVP must be clear and described in the
regulatory text if required.  The only area where IUVP seems to be
mentioned is in the Economic Analysis Appendix C.
- Page 13 paragraph D. 17: Not clear what is the CARB certification
test fuel to be used.  The paragraph seems to lead toward a CARB
LEV IV certification test fuel.  Several HMC manufacturers are
currently certifying off-road recreational vehicles and/or marine
products which are tested with CARB LEV III certification test
fuel.  It will be an additional burden for laboratories and
manufacturers to keep two sets of certification test fuel.  The
difference between the CARB LEV IV and CARB LEV III remains in a
specification "13-15 vol. % Multi-substituted Alkyl Aromatic
Hydrocarbons" for CARB LEV III versus "5.2-6.4 vol. % C7 Aromatics
(toluene)" for CARB LEV IV.  There is not enough time for
understanding the impact of this difference on the tailpipe
emissions for all engine technologies covered by HMC, OFRV and
Marine.  If the impact on HMC is marginal: the CARB certification
test fuel should be CARB LEV III or CARB LEV IV.

Appendix B-2:
- Page 2 paragraph 1.1.5.1: No comment only if it is made clear
that there is no tip test for three-wheels HMC.
- Page 2 paragraph 1.4: Same comments than for Appendix B1 Page 13
paragraph D. 17.  Additionally; the RVP is the same between CARB
LEV III and CARB LEV IV, it is theoretically expected to have no or
negligible impact on evaporative emission.
- Page 6 paragraph 4: This part of the sentence "unless each
evaporative emissions-related parts has undergone equivalent
durability testing for exhaust" should be clarified for each
exhaust durability options:
    ->1 "Per US EPA 86.426-78 which is half of useful life with 4
exhaust emission test and first test at 3,500km for Class III", 
    ->2 "Full mileage accumulation per EU 134/2014, Annex VI,
section 3.1"
    ->3 "Partial mileage accumulation per EU 134/2014, Annex VI,
section 3.2"
    ->4 "Bench aging durability test per EU 134/2014, Annex VI,
section 3.6, Appendix 3 to Annex VI, and Appendix 4 to Annex VI"
- Page 6 paragraph 4: Because the TP-901 is a procedure only for
fuel tanks; the sentence "The evaporative emissions control system
must satisfy..." should be replaced by "The fuel tank must
satisfy...".
- Page 6 and 7 paragraph 4 combined with Figure 2 of page 8: This
whole section is confusing.  It should be clear what must be
performed.  The following example is not the only confusing point:
The Figure 2 shows a path if full mileage is performed that goes
directly to the Section 4.3 and 4.4 but there is this sentence "A
vehicle that has completed the full useful life service
accumulation with the evaporative components installed throughout
the duration of service accumulation may be exempt from the
vibration durability requirements (Section 4.1.1), whichever are
applicable": where this sentence seems to still request Section
4.1.2 which seems to be in conflict with Figure 2.  Also; the
section 4.1.1 is about thermal cycling and section 4.1.2 is about
vibration.  The whole section 4 should be improved for clarity.
- Page 10 paragraph 4.3: It is understood that three-wheels HMCs
are more stable and less likely to tip over as opposed to HMCs
having two wheels.  For clarity; it should be added that the tip
test does not apply to three-wheel HMCs.
- Page 25 and 26 paragraph 10.2.1: Clarity should be improved since
it refers to "150 cycles of load with a mixture of 50 percent
gasoline (or butane) vapor/air" but then the term "fuel exposure"
is used.  Does the fuel exposure is the exposure to the "50 percent
gasoline (or butane) vapor/air"?  A proposal would be to replace
this sentence "The initial BWC should be established before fuel
exposure of between 10 and 100 BWC cycles and the final BWC should
be established after 150 cycles of fuel exposure by performing not
more than 10 BWC cycles" by this sentence "The initial BWC should
be established before the 50 percent gasoline (or butane) vapor/air
mixture exposure of between 10 and 100 BWC cycles and the final BWC
should be established after 150 cycles of the 50 percent gasoline
(or butane) vapor/air mixture exposure by performing not more than
10 BWC cycles".

Appendix C:
- The end of page 22 and beginning of page 23 refers to an "In Use
Verification Program (IUVP)" for manufacturers selecting the
catalyst bench aging.  The "IUVP" requirement should be described
and made clear in the Appendix B1.  Comment linked with the comment
on Appendix B1 Page 2 paragraph 1.4