EPA Clean Diesel Engine Implementation Workshop

Kevin OttoCummins Inc.

August 6-7, 2003

Implications of On-Board Diagnostics for Engine Manufacturers

0

5

10

15

20

1970 1975 1980 1985 1990 1995 2000 2005 2010 2015

Model Year

Oxi

des

of

Nit

rog

en (

g/b

hp

-hr)

0.0

0.5

1.0

1.5

2.0

Particu

late Matter (g

/bh

p-h

r)PM

EPA Heavy-Duty Engine Emission Standards

Steady StateTest

NOx + HC

Transient TestNOx(Unregulated)

PM (Unregulated)

NOx

NOx + HC

NOx

PMUrban Bus PM

NOx

84%

90%

90% in 2 steps

90%

KMO - 8/6/2003 - 4

Future Emissions Standards

• Compliance represents a significant task • Reducing NOx and PM the additional 90% will

require more resources than the 84% and 90% already delivered

• Already are implementing a manufacturer led in-use compliance program

Testing required in 2007 with pilot to begin in 2005 In-use emission test 25% of our engine families per year Approximately 10 vehicles per family

KMO - 8/6/2003 - 5

Emission Reduction Strategies

• Particulates and Hydrocarbons

Oxydation Catalyst PM Filtration

• NOx Selective Catalytic

Reduction (SCR) NOx Adsorbers Exhaust Gas

Recirculation (EGR) Combustion

System and Fuel Injection Equipment Improvements

KMO - 8/6/2003 - 6

July 25 CARB HD OBD Draft Regulation

- Concerns from a quick review• Compliance Date of 2007 Vehicle Model

Year is specified, not Engine Model Year• Diagnostic Monitoring of all electrical inputs

and outputs, plus major systems for: Engine, Aftertreatment, Transmission and

Vehicle Systems Major System Monitors that are Vehicle

Dependent– This presents a calibration issue for items like vehicle

cooling/electrical systems and transmissions

KMO - 8/6/2003 - 7

July 25 CARB HD OBD Draft Regulation

- Concerns from a quick review• Engine OEM responsible for the certification process

including vehicle functions OBD test cycles for validation/demonstration Significant pre- and post-production requirements

• Specified Scan Tool protocol and connector Does not allow J1939 or existing connector

• Different service language and process vs. today’s

Confirmed fault, pending, readiness, continuous, non-continuous, etc.

Emissions vs. other faults Impact on technician training and procedures

KMO - 8/6/2003 - 8

Who is Responsible for OBD Certification?

• Engine manufacturer should be responsible for OBD on the engine and corresponding aftertreatment system

Multiplexed sensors and systems present additional challenges

• Engine manufacturer should not be held responsible for OBD requirements beyond its expertise and influence

Engine Powertrain Truck OEM Customer

Body Builder

X

KMO - 8/6/2003 - 9

Magnitude and Complexity of OBD Work(Cummins Example)

Year EnginePlatforms

Ratings/Engine

OEM's ComplexityIndex

2003 1 4 1 4

2005/7 4 5 3 60

When>14K GVWincluded

10

CI/SI

7 5 350

• Bodybuilder scenario adds additional complexity

KMO - 8/6/2003 - 10

Resources and Timing

• Significant resources are required to implement

• The Industry has insufficient leadtime to fully implement OBD compliance

Light Duty OBD II promulgated in 1989 and implemented in 1996

Time of over 6 years with several years prior experience on OBD I

Current draft regulation allows 3 - 5 years for Heavy Duty

KMO - 8/6/2003 - 11

Recommendation

• Cummins advocates a phased implementation approach to Heavy Duty in-use compliance assurance

First phase should be the manufacturer run in-use test program

OBD requirements should be deferred to a later phase

• Cummins would like to be involved in further discussions on the listed concerns