United States       Air and Radiation      EPA420-P-99-030
           Environmental Protection               October 1999
           Agency                    M6.HDE.003
vvEPA     Development and Use of
           Heavy-Duty NOx Defeat
           Device Emission Effects for
           MOBILES and MOBILE 6
                               > Printed on Recycled Paper

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                                                                            EPA420-P-99-030
                                                                                 October 1999
                                     of
                                 for
                                 Edward L. Glover
                          Assessment and Modeling Division
                              Office of Mobile Sources
                        U.S. Environmental Protection Agency
                                     NOTICE

    This technical report does not necessarily represent final EPA decisions or positions.
It is intended to present technical analysis of issues using data which are currently available.
         The purpose in the release of such reports is to facilitate the exchange of
      technical information and to inform the public of technical developments which
        may form the basis for a final EPA decision, position, or regulatory action.

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Introduction

       This document describes the methodology used to estimate excess NOx emissions produced
by heavy-duty diesel vehicles (HDDV) as the result of built-in defeat devices. Also, presented in the
document are emission estimates based on two programs designed to mitigate the effect of the defeat
device on fleet NOx emission levels.  These include the incorporation of more stringent HDDV
standards earlier than originally required (pull ahead), and accelerated engine rebuild programs
(rebuild) to get in-use engines into better compliance. The document describes two basic models.
The first model is an Excel spreadsheet model (Spreadsheet Model) used to calculate excess HDDV
NOx emission effects in units of tons per year.  Both a MOBILE6 and a MOBILES version of the
spreadsheet model were developed. The excess NOx emission results in tons from this spreadsheet
model are compared with the official EPA heavy-duty defeat device inventory emission results
prepared by EPA's Office of Compliance and Enforcement (OECA). The second model is the
heavy-duty defeat device module that is built into the MOBILE6 emission factor model.  It was
developed and programmed into MOBILE6 using parameters from the spreadsheet model.  The
specific methodologies, parameters, procedures and their incorporation in the MOBILE6 model (the
second model) are also discussed in this document.

       The defeat device parameters were also incorporated  in the MOBILES  version of the
Spreadsheet Model and into the MOBILES  model because of the need to create a baseline
comparison with MOBILES that included the emission effects of the defeat device . For example,
the effects of the defeat device were incorporated in the MOBILES Spreadsheet Model to create
Calendar Year  (CY) 1990  or CY1995 baseline NOx inventories that  included defeat  device
operation. A modified version of MOBILES that included the defeat device effects was also created
so that consistency could be maintained between past baseline inventories made with MOBILES and
future projections.

       The MOBILES version of the defeat device spreadsheet model and the defeat device module
that is built-in the MOBILES code is completely analogous to the MOBILE6 based spreadsheet
model and code module. The only differences are in the data parameters. These parameters include
the heavy-duty vehicle  conversion factors, the basic heavy-duty vehicle NOx  emission  factors
without the defeat device present, the VMT distribution by vehicle class, and the VMT distribution
by model year.   The only difference between the MOBILE6 and MOBILES values is that the
MOBILE6 values are updated to account for more recent data collection by EPA.

       For purposes of this  modeling, a defeat device is a vehicle  component or software which
allows excess emissions to be produced during operating modes which are not explicitly covered by
a certification test while still controlling emissions during the certification test. In the case of the
heavy-duty NOx defeat device,  the device was active (shut off emission control systems) during
steady-state operating modes such as cruising down the freeway, but was mostly inactive during
transient operation.  It was built into heavy-duty diesel vehicles beginning in the 1988 model year,
and completely removed by the 2000 model year.  In the late 1980's and  early 1990's the defeat
device was being phased into the fleet and was mostly confined to the heavy end of the heavy-duty


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diesels (8a and 8b vehicles). However, by the mid to late 1990's it was widespread on virtually all
of the heavy end engines and most of the medium and light end heavy-duty diesels.

       This document is NOT a legal document, or an official emission inventory document. These
official documents can be found in the official EPA Consent Decree documents and supporting
material.  This current document is merely an attempt to compile estimates of the impact of the
defeat device,  the proposed solutions from official sources, and fit it to the framework of the
MOBILE6 model. These results may differ from the official EPA emission estimates in tons per
year.  A reader interested in the fleet impact of the defeat device based on official sources should
refer to the official consent decree document.

       This document is structured into three principal parts. The first part describes the structure,
parameters, and use of the spreadsheet model. This part is composed of several sub-sections. These
include a description of the model's overall structure, the data parameters of the model, the control
parameters and a brief look at the results. The second part describes the implementation of the
Spreadsheet Model outputs and parameters into the existing MOBILE6 model  structure.  An
appendix at the end of the  paper presents the FORTRAN code used to implement the  algorithm.
Currently, the code has not been fully integrated into the MOBILE6 model; thus, results are not
available.  The third section briefly describes (in a very limited way) the use of the MOBILES and
MOBILE6 defeat device spreadsheet models to provide heavy-duty vehicle defeat device emission
effects for subsequent inventory modeling.
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1.     Heavy-Duty Diesel Vehicle Defeat Device Spreadsheet Model

       This section describes the overall structure, data parameters, and input / output structure of
the HDDV defeat device spreadsheet model (spreadsheet model).  The actual models are available
at the EPA OMS website as an Excel spreadsheet entitled "DefeatM6.xls" - MOBILE6, and
"DefeatMS .xls" - MOBILES.  Excel spreadsheets entitled "DDM6_Data.xls" and "DDM5_Data.xls"
are also available that contains a  summary of the important data parameters. Both of the data
spreadsheets are in exactly the same format,  and  should be viewed as a companion to this text
document.

1.1    Overview of the Basic Structure

       The spreadsheet model is a calculator  that weights the individual model year and vehicle
class emission factors with vehicle  miles traveled (VMT) inputs and sums these results into overall
yearly  excess NOx emission levels in tons.   The following data  parameters are  used in the
spreadsheet, and are defined in the subsequent sections. The term "MOBILE6/5" means MOBILE6
and MOBILES.

       MOBILE6/5 Heavy-Duty Vehicle Conversion Factors
       MOBILE6/5 Basic Emission Factors WITHOUT Defeat Device Effects
       Basic Emission Factors WITH Defeat Device Effects
       Defeat Device Operating Parameter and Fleet Penetration Rates
       Total HDDV Vehicle Miles Traveled (VMT)
       MOBILE6/5 Distribution of VMT by Roadway Type, Vehicle Class and Model Year
       MOBILE6/5 HDDV Speed Correction Factors

       Several equations are used to weight together these parameters and sum the results. These
equations are shown in the section  labeled "Calculations".
1.2    Heavv-Dutv Vehicle Conversion Factors
       The HDDV conversion factors (CF) used in this model are shown in Excel Spreadsheet
DDM6_Data.xls (or DDM5_Data.xls) in worksheet CF. These conversion factors were taken from
MOBILE6 (or MOBILES) and are referenced in EPA report "Update Heavy-Duty Engine Emission
Conversion Factors for MOBILE6: Analysis  of BSFCs and Calculation of Heavy-Duty Engine
Emission Conversion Factors" - EPA420-P-98-015.   The conversion factors are used to convert
the basic heavy-duty diesel emission factors from g/bhp-hr into g/mi units. This is necessary so that
the four individual  heavy-duty diesel vehicle  class  emission factors and the individual  roadway
factors can be properly weighted together by VMT. Emission factors in units of g/bhp-hr cannot be
VMT weighted because the basis units are in bhp-hr rather than in miles.  The analogous conversion


M6.HDE.003-Defeat Device                                                     Page 3

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factors for the MOBILES model were taken from the MOBILES source code.

       The conversion factors are shown as a function of model year and vehicle class. The model
years range from 1964 through 2030. Each column in the worksheet CF contains a conversion factor
for one of the four heavy-duty vehicle classes: Light, Medium, Class 8a and ClassSb. In all cases,
the Light class conversion factors are composite values obtained by weighting the individual sub-
classes (light-heavy duty standard classes of 2b, 3,4 and 5) together with the Bus conversion factors
based on VMT. This was done because neither the Light or Bus class contain defeat device effects
in any appreciable quantity.

1.3    MOBILE6 Basic Emission Factors WITHOUT Defeat Device Effects

       The basic emission factors without defeat device effects used in the spreadsheet model are
shown in Excel Spreadsheet DDM6_Data.xls (or DDM5_Data.xls) in worksheet BEFs.  These are
the base emission levels for a particular model year and vehicle class if the defeat device is not
present or not working. The first five columns show the Without Defeat Device Emission factors.
These are shown as a function of vehicle class (Light, Medium,  8a and 8b), and as a function of
model year. Basic emission factors are shown for model years 1964 through 2030, and are in units
of grams per brake-horsepower-hr (g/bhp-hr or g/hp-hr). These values are the default emission levels
for HDDVs in MOBILE6, and are very heavily based on certification test results. The analogous
MOBILES values are also default emission levels and are based on certification test results.  The
reference for the MOBILE6 values is EPA report EPA420-R-99-010 - "Update of Heavy-Duty
Emission Levels (Model Years 1988 - 2004+) for Use in MOBILE6."  The MOBILES values were
taken from the MOBILES  model code.

1.4    MOBILE6 Basic Emission Factors WITH Defeat Device Effects

       The last four columns in worksheet BEFs of the Excel Spreadsheet DDM6_Data.xls (or
DDM5_Data.xls) show the basic NOx emission factors in g/bhp-hr units when the defeat device is
active and operating. Like the WITHOUT defeat device emission levels, the WITH defeat emission
levels are shown as a function of vehicle  class and model year.  The same WITH defeat device
emission levels are used in both the MOBILES and MOBILE6 spreadsheet model version.  The
"Light-Duty" class is unaffected by the defeat device so it shows the same NOx emission factors for
both "WITH" and "WITHOUT" defeat devices. NOx emission factors are shown for the model year
range of 1964 through 2030. One exception is the WITH defeat device NOx emission factors for
model years 2002 and 2003.  These are lower than the WITHOUT defeat device emission levels as
the result of "Pull Ahead" requirements for lower certification standards. For model years 2004 and
later, and model years 1987 and earlier, the WITH and WITHOUT defeat device emission levels are
equivalent, since there would be no defeat device effects on emissions for these model year engines.

       The defeat device  emission effects were  determined on an engine by engine basis using
available data and engineering judgement by experts familiar with engine control software. These
individual estimates were weighted together by engine family using diesel vehicle sales information
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to produce model year average emission levels (this document uses a summary of the individual
manufacturer results). The individual engine family or manufacturer specific engine control logic,
emission results and sales projections are proprietary in nature and were made available to the EPA
on a confidential basis as part of the Heavy-Duty Diesel Defeat Device Consent Decree. Thus, they
are not provided in this document nor are they publically available in any other source.

1.5    Defeat Device Operating Parameter and Fleet Penetration Rates

       The defeat device operating parameters and fleet penetration rates used in the spreadsheet
model are shown in worksheet "Fleet Fractions" of Excel  Spreadsheet DDM6_Data.xls (or
DDM5_Data.xls). These are shown as a function of vehicle class (light, medium, 8a and 8b), model
year, and roadway type. The three roadway types are Urban, Arterial, and Interstate.  There are four
sub-types within  each of these  three  broad classes,  and they are also  listed in spreadsheet
DD_Data.xls worksheet "Fleet Fractions."  The Urban type represents city driving which includes
considerable stop-and-go transient operation. The Arterial type represents driving on primary roads
in which there is both transient operation and steady-state operation.  The Interstate type represents
the operation which includes mostly steady state type driving at higher speeds. A zero (0.00) means
that the defeat device does not operate during that mode, and a  one  (1.00) would mean that it
operates all of the time in that mode. This information is on a fleet summary basis.  It was calculated
from individual engine family defeat device response data that was determined from proprietary and
confidential data submitted by the engine manufacturers, limited testing of affected engines, and
engineering judgment by experts in engine control and emission control software. As a general rule,
the Urban type contains relatively little defeat  device operation, and the Interstate type contains
considerable defeat device operation, as can be seen in the low fractions for Urban and the  high
fractions for Interstate. The defeat device operating fractions are also a function of model year.

       The columns entitled "Fleet Fraction" show the percent of a particular model year and vehicle
class that is equipped with the defeat device or affected by the legal settlement.  A value of zero
means for that particular combination of vehicle class and model there are no defeat devices, and a
value of unity (1.0) means that in that model year, all vehicles of that class were equipped  with
defeat devices. In general, the data suggests that the defeat device  penetration began slowly in the
1988 model year on the heavier class diesels, and slowly progressed to encompass most of the fleet.
Virtually full penetration  seems to have occurred by the mid 1990's  on the heavier engines.
Penetration drops off abruptly around calendar year 2000, presumably due to the settlement.  The
only exception to this rule is for the case of the 2002 and 2003 model years.  These model  year
groups contain a coded factor to calculate the impact of "Pull Ahead."  No defeat devices will be
produced in those model years. The MOBILE6 With Defeat Device operating parameters and fleet
penetration rates were used in the MOBILES version directly.
1.6    Total VMT Estimates

       The  Total VMT  Estimates are  shown in  worksheet  Total_VMT  of  Spreadsheet


M6.HDE.003-Defeat Device                                                       Page 5

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DDM6_Data.xls (or DDM5_Data.xls). Separate values are shown for calendar years 1988 through
2010. The VMT values were obtained from the EPA Trends model, and are typical HDDV VMT
levels used in Air Quality modeling.  Linear equations are used to project future VMT levels. The
Total VMT estimate is an important factor in determining the total tons of NOx produced by the
defeat devices.  However, it is not explicitly used in the MOBILE6 model inputs because MOBILE6
does not produce NOx emissions in units of tons (only in grams per mile). The same Total VMT
estimates were used for both the MOBILE6 and MOBILES models.
1.7    Distribution of VMT by Roadway Type. Vehicle Class and Model Year
1.7.1   Distribution of VMT by Roadway Type

       The VMT distribution by Roadway Type used in the spreadsheet model is shown in
worksheet "Road_VMTDist" of Excel Spreadsheet DDM6_Data.xls (or DDM5_Data.xls).  In
general, there are three basic facility types - Urban, Arterial and Interstate. Within each of these
three basic types, there are four individual roadway types (a total of 12 roadway types). The VMT
weighted distribution for each roadway type by vehicle class is shown at the top of worksheet
Road_VMTDist. These values were obtained from the report "Documentation of Mobile Source
Inventories Used in O AQPS Trends Report" by EH Pechan under EPA Contract 68-D3 -003 5. They
are used to properly weight the impact of the defeat device by vehicle class  for each of the 12
roadway types.  The values for the VMT  distribution  by roadway type were used in both the
MOBILE6 and MOBILES versions.
1.7.2   Distribution of VMT by Vehicle Class

       The  next  small table in  the  worksheet  Road_VMTDist of  DDM6_Data.xls (or
DDM5_Data.xls) contains the vehicle class distribution, which distributes VMT by vehicle class.
It is combined with the defeat device roadway distribution, to create a VMT distribution by roadway
type and vehicle class.  Different values were used for the MOBILES spreadsheet model. The
MOBILES values contained a somewhat higher fraction of VMT allocated to the 8a class of heavy-
duty diesel vehicle, and thus accounted for one of the biggest differences between the MOBILE6 and
MOBILES NOx defeat device inventories.
1.7.3   Distribution of VMT by Vehicle Class and Roadway

       The table at the bottom of Road_VMTDist is a combined VMT distribution by Vehicle Class
and Roadway type. It is the product of the previous two tables and is used directly in the calculation
of defeat device effects. Mathematically, each row in the table sums to unity for a given roadway
type. Different values are computed for the MOBILE6 and MOBILES models due to the different
M6.HDE.003~Defeat Device                                                      Page 6

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VMT distribution by vehicle class.
1.7.4   Distribution of VMT by Model Year

       The VMT distribution by age and vehicle class used in the spreadsheet model is shown in
worksheet "TF" of Excel Spreadsheets DDM6_Data.xls and DDM5_Data.xls. The TF represents
Travel Fraction, and is used to distribute the defeat device emission effects by model year / age. The
values are the standard MOBILE6 travel fractions calculated from MOBILE6 parameters such as
diesel fleet penetration, annual mileage  accumulation rates by vehicle class, and registration
distributions by vehicle class.  The primary reference for these parameters is EPA report "Update
of Heavy-Duty Emission Levels (Model Years 1988 - 2004+) for Use in MOBILE6" - EPA report
EPA420-R-99-010. The MOBILES distribution was taken from the MOBILES computer code. It
differs from the MOBILE6 distribution because it is a single distribution that represents all four of
the vehicle classes; whereas, for MOBILE6, separate age distributions are used for each of the four
vehicle classes.
1.8    MOBILE6/5 HDDV Speed Correction Factors

       An average speed is associated with each of the twelve roadway types. The average speed
information was obtained from the report "Documentation of Mobile Source Inventories Used in
OAQPS Trends Report" by EH Pechan under EPA Contract 68-D3-0035.  The twelve roadway
types and the average speeds are listed below in Table 1. The letters I, A and U in parentheses stand
for Interstate, Arterial and Urban, respectively.  These average speeds are based on an analysis EH
Pechan did in 1991 on DOT data.

       In this analysis, speed correction factors are used only to model the effect of speed on the
heavy-duty emissions which are associated with "without defeat device operation."  The "with defeat
device heavy-duty emission factors" implicitly contain speed  correction factors, and need no
additional speed correction.  This implicit relationship is an assumption that the defeat device
emission effects inherently contain all of the remaining speed related NOx  emission effects that
occur as the result of vehicle operation outside of the certification test cycle, and the certification
cycle's average speed of 20 MPH. The basis for this assumption is that the defeat device effects are
a strong function of speed and typically only occur during the steady-state higher  speed activity of
the trucks. Also, based on the limited test and engineering data, it is not feasible to separate defeat
device NOx emission effects from normal speed correction NOx emission  effects.

       The average speed for each roadway type is used to calculate the NOx speed correction
factors. The speed correction factor equation used in this analysis is the standard MOBILE5/6
equation for heavy-duty diesels (the same value is used in both MOBILE6 and MOBILES.  It is not
a function of roadway type. The speed correction factors are calculated for each of the roadway types
by inserting the appropriate average speed into Equation 1 below:
M6.HDE.003~Defeat Device                                                       Page 7

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      NOx Speed CF =  0.676 - 0.0480*speed + 0.00071 *speed**2                Eqn 1
'**2' means squared.
M6.HDE.003~Defeat Device                                                  Page 8

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Table 1
Roadway Types and Average Speeds

Roadway Number and Name
1. Rural Interstate (I)
2. Rural Other Principal Arterial (I)
3. Urban Interstate (I)
4. Urban Freeway & Expressway (I)
5. Rural Minor Arterial (A)
6. Rural Major Collector (A)
7. Rural Minor Collector (A)
8. Rural Local (A)
9. Urban Other Principal Arterial (U)
10. Urban Minor Arterial (U)
11. Urban Collector (U)
12. Urban Local (U)
Average Speed (MPH)
40
35
35
35
30
25
25
25
15
15
15
15
1.9    Calculations

1.9.1   With Defeat Device Emission Calculation

       The calculations in the spreadsheet model DefeatM6.xls (or DefeatMS .xls) are fairly simple
and straightforward in concept, although quite voluminous due to the need to duplicate them twice
for each of the twelve roadway types (24 times). The following general method and equations were
used:

1.      The Without Defeat Device emission factors are speed corrected, but the With Defeat Device
       are not speed corrected because the defeat device inherently contains NOx speed effects.

2.      The speed correction factor was calculated using Equation 1 and the appropriate speed from
       Table 1.

3.      For each model year, roadway type, and vehicle class, Equation 2 is used to calculate a basic

M6.HDE.003-Defeat Device                                                       Page 9

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       fleet emission factor that is a weighted average of the With and Without defeat device rates.
       Fleet = [NO_DD*(l-DD_equip)*SpeedCF  + NO_DD*DD_equip*(l-DDmode)*SpeedCF
                           + DD*DD_equip*DDmode] * CF                             Eqn 2

Where:

NO_DD is the basic emission factor if no defeat device is present (from worksheet BEFs of
DD_Data.xls).

DD is the basic emission factor if a defeat device is present and operating (from worksheet BEFs of
DD_Data.xls).

DD_equip is the fraction of the fleet which has a defeat device installed on it (from worksheet Fleet
Fractions ofDD_Data.xls).

DD_mode is the VMT fraction in a given roadway type mode that the defeat device is in operation
(from worksheet Fleet Fractions ofDD_Data.xls).

SpeedCF is the appropriate speed correction factor for the given roadway number (calculated from
Equation 1).

CF is the appropriate heavy-duty conversion factor to convert the emission rate in grams/bhp-hr into
grams/mile.  It is a function of vehicle class (from worksheet CF ofDD_Data.xls).

Fleet is the fleet average NOx emission level with defeat devices for a given roadway type mode and
model year in units of g/mile
1.9.2   Without Defeat Device Emission Calculation

       The Without Defeat Device emission calculation is analogous to the With Defeat Device
calculation. Equation 3 is used to calculate the NOx emission level for a particular permutation of
roadway, model year, vehicle class and speed.
       The Without Defeat Device emission factor is speed corrected using the appropriate speed
correction factor for a given roadway number. Equation 1 is multiplied by the Without Defeat Device
basic emission factors found in DD Data.xls sheet BEFs.
M6.HDE.003-Defeat Device                                                      Page 10

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       Fleet2 = [ NO_DD* SpeedCF * CF]                                           Eqn 3


NO_DD is the emission factor if no defeat device is present.

SpeedCF is the appropriate speed correction factor.

CF is the appropriate heavy-duty conversion factor to convert the emission rate into grams/mile. It
is a function of vehicle class.

Fleet2 is the fleet average NOx emission level without defeat devices for a given mode and model
year in units of g/mile



1.9.3   Overall NOx Defeat Device Tons

       The defeat device spreadsheet model found in DefeatM6.xls and DefeatM5.xls calculates
total  excess NOx tons for a given calendar year and other inputs.  The model only calculates the
excess NOx tons for a speed of 20 mph.  The calculation procedure is described below using
Equations 4, 5 and 6. The values in brackets are parameters for the value. For example, Fleet is a
function of vehicle class (icls), roadway type (iroad), and model year (imy).

       DD(icls,iroad,imy)   =     Fleet(iels,iroad,imy) -  Fleet2(icls,iroad,imy)      Eqn 4

Where:

DD(icls,iroad,imy) is the net defeat device NOx emission effect for each combination of vehicle
class(light, medium, 8a and 8b), roadway type(12 types), and model year.

Fleet(icls,iroad,imy) is the With Defeat Device NOx emission level for each vehicle class, roadway
type, and model year calculated using Equation 2.

Fleet2(icls,iroad,imy) is the Without Defeat Device NOx emission level for each vehicle class,
roadway type, and model year calculated using Equation 3.
       The total FtDDV excess NOx emissions in tons for a given calendar year are calculated using
Equation 5.
DD_Tons  = Y, [DD(icls,iroad,imy)*TF(icls,imy)*TotalVMT(iroad,icls)*Constant]      Eqn 5
M6.HDE.003-Defeat Device                                                      Page 11

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Where:

The summation is over the four vehicle classes (light, medium, 8a and 8b).

DD(icls,iroad,imy) the net defeat device effect calculated from Equation 4.

TF(icls,imy) is the model year VMT distribution for each vehicle class.

TotalVMT(iroad,icls) is the total VMT in millions of miles for a given combination of roadway
type and vehicle class.

Constant contains the conversion factors from grams to tons per calendar year.


1.10    Rebuild Program Inputs to the Excess NOx Emission Spreadsheet Model

       Most heavy-duty diesel engines are rebuilt after their initial  useful  life has elapsed.
Typically, this  occurs around the 350,000 mile point, and often includes replacing engine parts that
affect NOx emissions.  The practice of rebuilding is considerably more cost-effective to the truck
owner than  scrapping the engine.  Because the rebuild practice is so  widespread, the engine
manufacturing industry agreed as part of the Consent Decree to rebuild a portion of the fleet in such
a way as to reduce the effect of the defeat device on rebuilt engines.  This NOx excess spreadsheet
model will reflect the effects of the rebuild program.

       The following parameters are defined and used in the MOBILE6 and MOBILES spreadsheet
models to account for rebuilds.

Rebuild Fraction - This is the fraction of the eligible fleet that will be rebuilt.  Currently this
fraction is assumed to be 0.90.

Model Year Range - Two options were available in the consent decree. The one which is modeled
in the spreadsheet model includes only the 1994 through 1998 model years.  The other rebuild option
(not modeled)  includes the 1993 model year.

After Rebuild Emission Level - This is the NOx emission level that the rebuilt engines will emit
in units of g/bhp-hr, and is set equal to 7.00 g/bhp-hr. The other rebuild option (not modeled) in the
consent decree set this level at 7.50 g/bhp-hr. These were conservative values because the consent
decree set these standards as "not-to-exceed" levels.

Years of Use Before Rebuild - This is the number of years prior to the first rebuild.
       12 years for a medium duty
        5 years for a 8 a truck


M6.HDE.003~Defeat Device                                                       Page 12

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       3 years for a 8b truck
Also, no rebuild credit is given before calendar year 2000. Thus, a 1994 model year 8b engine will
not be lowered to the 7.00 g/bhp-hr standard upon its first rebuild in 1997.

       The effects of rebuild are implemented in the model by replacing the With Defeat Device
Emission levels with the rebuild emission level of 7.00 g/bhp-hr on the fraction of the fleet that is
rebuilt. The default value for the fraction of the fleet that is rebuilt is 90% of the 1994 through 1998
model years.

1.11    MOBILE6 Model Results

       This section presents the overall NOx excess emission results in tons per calendar year from
the MOBILE6 based Spreadsheet model. Figure 1 shows the excess NOx emissions for a range of
calendar years with and without the effects of rebuilding the 1994 through 1998 model year engines.
The effect of "Pull Ahead" is present in both the With and Without rebuild curves.

       Figure 2 shows a comparison of the MOBILE6 Spreadsheet model excess NOx emission
results with the original EPA Office  of Enforcement Model (OECA Model).  The differences
between the two models in terms total excess NOx tons stems from a difference in approach and the
use of different basic parameters.  This difference is sizable for some calendar years between 1995
and 2000.

       The approach taken for the two models is somewhat different. The OECA model starts with
basic NOx emission and market share information on each engine family, and weights these together
by market share, defeat device penetration within a given engine family, vehicle scrappage rates, and
VMT information. These weighted NOx emission values for each engine family are then  summed
together on a calendar year basis to produce the fleet NOx excess emission totals in tons.  Because
of the proprietary nature of many of these inputs such as proj ected market share for individual engine
manufacturer and individual engine families, neither this model  or its data parameters can  be
released.  The OECA model also reports only the increase in fleet NOx emissions due to the defeat
device by calendar year. No model year  specific results are possible.  It also does not include a
heavy-duty vehicle fleet estimate of NOx emissions if no defeat device were present (base level), nor
does it provide a combined base and defeat device fleet emission level in tons by calendar year.

       The approach taken for the  Spreadsheet models (MOBILE6 and MOBILES) is different from
the OECA model.  Instead of summing the individual engine family contributions to the total excess
NOx emission level, these individual engine family parameters (emission level, operation in defeat
device by roadway type, and penetration of defeat device) were combined into fleet average values
by model year and vehicle class using fleet average sales and proj ected sales information. The actual
and projected sales numbers were generally consistent between the OECA and M6/M5 Spreadsheet
models; however, discrepancies arose when aggregating specific engine information into fleet
average vehicle information segregated into the four heavy-duty diesel vehicle  classes. Recent
model year sales and future proj ected sales were the most problematic. The Spreadsheet model also


M6.HDE.003~Defeat Device                                                      Page 13

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contains Without  defeat device (base) emission levels by model  year.  These are from the
MOBILE6/5 heavy-duty vehicle data parameters.  For the MOBILE6 Spreadsheet model, the NOx
emission effect of the defeat device is essentially the difference between the With and Without
Defeat Device emission factors. The final With defeat device emission levels and the Without defeat
device emission levels are shown in worksheet BEFs of DDM6_Data.xls. The process used to
                                     Figure 1
            Heavy-duty Diesel Vehicle Excess NOx by Calendar Year
     1,400,000
          1985       1990        1995        2000       2005

                                   Calendar Year
                                                           2010
                                                                     2015
                                                                               2020
develop the "With Defeat Device" fleet average emission levels by model year is not shown due
restrictions on publishing proprietary data.

       The MOBILE6 Spreadsheet model and the OECA model also differ in the data parameters
that were used to build the models. The  Spreadsheet model uses MOBILE6 emission and VMT
parameters, while the OECA model uses some MOBILES based parameters. These include different
conversion factors (CF), different VMT distribution by vehicle class, and different total VMT levels.
M6.HDE.003-Defeat Device
Page 14

-------
                                   Figure 2
               Heavy-duty Diesel Vehicle Excess NOx Projections
             Comparison of MOBILE6 and OECA Model Approaches
                                            Projections Include Rebuild and
                                                 Pull-Ahead Effects
                    1990
                             1995
                                     2000      2005      2010

                                     Calendar Year
                                                               2015
                                                                        2020
M6.HDE.003-Defeat Device
Page 15

-------
2.0    Defeat Device Model Implementation in FORTRAN

       This brief section and the following Appendix discuss the integration of the HDDV defeat
device NOx emission spreadsheet model into the MOBILE6 code.  It is presented in this document
for readers who are interested in seeing the exact code. This may be important since the Spreadsheet
model will not produce results in the same units as the MOBILE6 defeat device implementation.
During this integration, every attempt was made to preserve as much continuity between the two
models as possible. However, this was not always possible since MOBILE6 reports emissions as
emission factors in units of grams per mile while the spreadsheet model produced an emission result
in terms of tons. Because of this basic difference, perfect agreement will never be attained between
the two models.

       The primary difference between the two models is the use of VMT to weight different vehicle
classes, roadway types, and model years together.   MOBILE6 generally will not use these
parameters since the output is in terms of grams per mile for specific vehicle classes, roadway types,
and model years.  When the MOBILE6 model is called to produce average gram per mile emission
factors that include a number of model years, vehicle classes or roadway types, the same VMT
parameters will be used as presented earlier in this document in Section 1.0. The list of parameters
which overlap between the two models are the Conversion Factors and the speed correction factors.

       The basic HDDV NOx excess  emission  factors which are used in MOBILE6 are the
difference between the With and Without defeat device emission levels. These delta emission values
(difference between With and Without Defeat Device) are analogous to the values calculated in
Equation 4, and are in units of g/mi. They can be found in the MOBILE6 BLOCK DATA in Module
DDNOBD in array NEFFCT.  Also, found in Module DDNOBD are the defeat device operating
parameters and the fleet penetration rates.

       The basic defeat device data and other parameters are utilized in subroutine "Defeat" This
subroutine takes the basic emission and defeat device operating parameters and calculates a new
average fleet NOx emission level for MOBILE6 that includes the effect of the defeat device for the
various roadway types, affected model years, calendar years,  and vehicle classes.
M6.HDE.003-Defeat Device                                                     Page 16

-------
3.0   Use of the MOBILE6 and MOBILES Spreadsheet Models

      The MOBILE6 and MOBILES Heavy-duty Diesel Vehicle NOx Defeat Device Spreadsheet
models (Spreadsheet Model) were used in four emission inventory and air quality applications to
model the NOx emissions associated with the heavy-duty defeat device.  These applications are:

1.     Regional Ozone Transport Rule (ROTR)
2.     Revised Regional Ozone Transport Rule (RROTR)
3.     Tier2 Rulemaking (Tier2)
4.     Southern Appalachian Ozone Modeling (SAOM)
      In all four of these cases, the output of the Spreadsheet model that was used in subsequent
modeling were ratios of "With Defeat Device" NOx emissions and "Without Defeat Device" NOx
emissions for various calendar years, roadway types, and speeds. For all cases, separate ratios were
computed for each of the twelve roadway types, and for thirteen different speeds (in five mile per
hour increments) ranging from 5 MPH to 65 MPH.  A set of these ratios was generated for a series
of calendar years that included CY1995 and CY1996 as a baseline, and CY2004,  CY2007 and
CY2010. For both the MOBILE6 and MOBILES Spreadsheet models, the ratios can be found in the
sub-worksheet DD_Summary.

      The four individual applications also differed in their requirements for the ratios. The ratios
that were computed for the ROTR were MOBILES With Defeat Device NOx (numerator) over
MOBILES Without Defeat Device NOx (denominator).  These ratios include the effects of "Pull
Ahead," but did not include "Engine Rebuild Effects" in the With Defeat Device NOx levels. The
ratios that were computed for the RROTR were MOBILES With Defeat Device NOx over MOBILES
Without Defeat Device NOx ,  including the effects of "Pull Ahead," and the "Engine Rebuild
Effects" in the numerator.  The ratios that were computed for the Tier2 rulemaking were MOBILE6
With Defeat Device NOx over MOBILES Without Defeat Device NOx. These ratios include both
the effects of "Pull Ahead," and the "Engine Rebuild Effects" in the numerator.  Finally, the ratios
that were computed for the SAOM work were MOBILE6 With Defeat Device NOx over MOBILES
Without Defeat Device NOx.  However, these ratios did not include the effects of "Pull Ahead," or
the "Engine Rebuild Effects."

      Figure 3 shows a set of With and Without Defeat Device Ratios for Calendar Year 2010. It
includes both Rebuild and Pull Ahead provisions. The ratios are the MOBILE6 With Defeat Device
Emission Factors over the MOBILES Without Defeat Device Emission Factors. In general, the ratios
are typically 1.0 or less. The small numbers reflect relatively little defeat device activity in CY2010,
and the relative difference between MOBILE6 parameters and MOBILES parameters such as CF,
TF, Basic Emission Rates, and VMT distributions. Ratios less than 1.0 can occur due to differences
between MOBILE6 and MOBILES and as the result of "Pull Ahead."  They occur when MOBILE6
parameters produce lower excess NOx emission levels than analogous MOBILES parameters.
M6.HDE.003~Defeat Device                                                    Page 17

-------
       Figure 4 shows a similar set of With and Without Defeat Device Ratios for Calendar Year
2007.  It also includes both Rebuild and Pull Ahead provisions.  However, in Figure 4 both the
numerator and the denominator are both based on MOBILE6. These ratios clearly isolate the effect
of the defeat device, and suggest that it can be as high as 20 to 30 percent of the CY 2007 fleet for
some roadways.
M6.HDE.003~Defeat Device                                                    Page 18

-------
                                                                                     TABLES
Facility   Description
Interstate  Rural Interstate
Interstate  Rural Other Prin Arterial
Interstate  Urban Interstate
Interstate  Urban Other Freeways
Arterial    Rural Mnor Arterial
Arterial    Rural Major Collector
Arterial    Rural Mnor Collector
Arterial    Rural Local
Urban     Urban Other Prin Arterial
Urban     Urban Mnor Arterial
Urban     Urban Cdlector
Urban     UrbanLoca1
 Facility  Description
 Interstate Rural Interstate
 Interstate Rural Other Prin Arterial
 Interstate Urban Interstate
 Interstate Urban Other Freeways
 Merial   Rural Mnor Arterial
 Merial   Rural Major Cdlector
 Merial   Rural Mnor Cdlector
 Merial   Rural Local
 Urban    Urban Other Prin Arterial
 Urban    Urban Mnor Arterial
 Utan    Urban Cdlector
 Urban    UrbanLoca1



Roadway*
1
2
3
4
5
6
7
8
9
10
11
12
2010
Fleet wDD
Speed
5
0.8803
0.8803
0.8805
0.8804
0.8591
0.8592
0.8599
0.8585
0.8319
0.8325
0.8297
0.8321
2010
Fleet wDD
Speed
10
0.9253
0.9253
0.9257
0.9255
0.8724
0.8725
0.8730
0.8718
0.8325
0.8332
0.8304
0.8328
2010
FleetwDD
Speed
15
0.9685
0.9685
0.9691
0.9687
0.8851
0.8853
0.8856
0.8846
0.8332
0.8338
0.8311
0.8335
2010
FleetwDD
Speed
20
1.0062
1.0062
1.0070
1.0065
0.8963
0.8964
0.8967
0.8958
0.8338
0.8344
0.8316
0.8340
2010
ReetwDD
Speed
25
1.0350
1.0350
1.0360
1.0353
0.9048
0.9050
0.9051
0.9043
0.8342
0.8348
0.8321
0.8345
2010
ReetwDD
Speed
30
1.0521
1.0522
1.0532
1.0525
0.9099
0.9100
0.9101
0.9094
0.8344
0.8351
0.8323
0.8347
2010
ReetwDD
Speed
35
1.0557
1.0558
1.0568
1.0561
0.9110
0.9111
0.9111
0.9105
0.8345
0.8351
0.8324
0.8348
2010
ReetwDD
Speed
40
1.0455
1.0456
1.0466
1.0459
0.9079
0.9081
0.9082
0.9074
0.8343
0.8350
0.8322
0.8346
2010
ReetwDD
Speed
45
1.0225
1.0225
1.0234
1.0228
0.9011
0.9013
0.9014
0.9006
0.8340
0.8346
0.8319
0.8343
2010
ReetwDD
Speed
50
0.9890
0.9891
0.9898
0.9893
0.8912
0.8914
0.8916
0.8907
0.8335
0.8341
0.8314
0.8338
2010
ReetwDD
Speed
55
0.9483
0.9483
0.9488
0.9485
0.8792
0.8793
0.8797
0.8786
0.8329
0.8335
0.8308
0.8332
2010 2010
ReetwDD ReetwDD
Speed Speed
60 65
0.9038 0.8591
0.9038 0.8591
0.9041 0.8591
0.9039 0.8591
0.8660 0.8528
0.8662 0.8529
0.8667 0.8537
0.8654 0.8522
0.8322 0.8315
0.8329 0.8322
0.8301 0.8294
0.8325 0.8318
TABLE 4



Roadway*
1
2
3
4
5
6
7
8
9
10
11
12
2007
ReetwDD
Speed
5
0.8623
0.8623
0.8626
0.8624
0.8398
0.8399
0.8406
0.8394
0.8189
0.8194
0.8170
0.8190
2007
FleetwDD
Speed
10
0.9233
0.9233
0.9239
0.9235
0.8583
0.8584
0.8589
0.8579
0.8199
0.8204
0.8179
0.8199
2007
ReetwDD
Speed
15
0.9818
0.9818
0.9827
0.9821
0.8760
0.8761
0.8764
0.8757
0.8208
0.8213
0.8189
0.8209
2007
FleetwDD
Speed
20
1.0329
1.0330
1.0341
1.0333
0.8915
0.8916
0.8917
0.8912
0.8216
0.8221
0.8197
0.8217
2007
ReetwDD
Speed
25
1.0720
1.0721
1.0733
1.0724
0.9034
0.9035
0.9034
0.9031
0.8222
0.8227
0.8203
0.8223
2007
ReetwDD
Speed
30
1.0952
1.0953
1.0967
1.0957
0.9104
0.9105
0.9104
0.9102
0.8226
0.8231
0.8207
0.8227
2007
ReetwDD
Speed
35
1.1001
1.1002
1.1016
1.1006
0.9119
0.9120
0.9118
0.9117
0.8227
0.8232
0.8208
0.8228
2007
ReetwDD
Speed
40
1.0863
1.0863
1.0877
1.0867
0.9077
0.9078
0.9077
0.9074
0.8225
0.8230
0.8205
0.8225
2007
ReetwDD
Speed
45
1.0550
1.0551
1.0563
1.0555
0.8982
0.8983
0.8983
0.8980
0.8220
0.8225
0.8200
0.8220
2007
ReetwDD
Speed
50
1.0097
1.0097
1.0107
1.0100
0.8845
0.8845
0.8847
0.8842
0.8212
0.8218
0.8193
0.8213
2007
ReetwDD
Speed
55
0.9544
0.9544
0.9551
0.9546
0.8677
0.8678
0.8682
0.8674
0.8204
0.8209
0.8184
0.8204
2007 2007
ReetwDD ReetwDD
Speed Speed
60 65
0.8941 0.8335
0.8942 0.8335
0.8945 0.8336
0.8943 0.8335
0.8495 0.8311
0.8496 0.8312
0.8501 0.8320
0.8491 0.8306
0.8194 0.8184
0.8199 0.8190
0.8175 0.8165
0.8195 0.8185
M6.HDE.003-Defeat Device
Page 19

-------
                                   Appendix
    FORTRAN Code Used to Implement the Defeat Device Emission Effects in MOBILE6
      SUBROUTINE DEFEAT(MY,ICY,IV,IROAD,IPULL,IBUILD,VVHDDV,RBLEV,DDNOX)
C
C
C..Rebuild modeling options using variable IBUILD.
C    IBUILD =0  -  Default option - Rebuild effects are  included at  a
C                                    90% penetration for  MY 1993-98
C    IBUILD = 1  -  No Rebuild effects are included.
C    IBUILD = 2  -  Rebuild effects are included  for MY 1993-98  at a
C                   user specified level  (RBLEV).
C
C    IPULL =0   -  Default option - Pull ahead effects are included  for
C                   MY 2002 and 2003. Negative emission increases.
C    IPULL = 1   -  Pull ahead effects are not included for MY 2002 and
C                   2003.  Defeat Device Effects  are 0.0.
C
      USE DDDATA
      IMPLICIT NONE
      INTEGER, INTENT(IN)
      INTEGER, INTENT(IN)
      INTEGER, INTENT(IN)
      INTEGER, INTENT(IN)
      INTEGER, INTENT(IN)
      INTEGER, INTENT(IN)
      INTEGER, INTENT(IN)
MY
ICY
IV
IROAD
IPULL
IBUILD
VVHDDV
      INTEGER :: IMY, IVV                       ! Local variables
C
      REAL, INTENT(IN)   :: RBLEV
      REAL, INTENT(OUT)   :: DDNOX
C
      REAL ::  DDNOXX                            ! Local variables
C
C
      IF(MY.LT.1988.OR.MY.GT.2003.OR.ICY.LT.1988.OR.
     *   IROAD.EQ.4.OR.VVHDDV.EQ.0) THEN
        DDNOX  =0.0                            !  Out  of Range:  No  defeat  device
effects
        RETURN
      ELSEIF((MY.EQ.2002.OR.MY.EQ.2003).AND.IPULL.EQ.1) THEN
        DDNOX  =0.0                             ! Out  of Range  if  no pull ahead
effects
        RETURN
      END IF
C
      IF(MY.GE.2004) THEN
         IMY =  1
      ELSEIF(MY.LE.1987) THEN
         IMY =18
      ELSE
         IMY =  2004 - MY + 1
      END IF
C
C
      IF(IV.GE.16.OR.IV.LE.19) THEN


M6.HDE.003-Defeat Device                                                Page 20

-------
         IVV = 1
      ELSEIF(IV.EQ.26.OR.IV.EQ.27)  THEN
         IVV = 1
      ELSEIF(IV.EQ.20.OR.IV.EQ.21)  THEN
         IVV = 2
      ELSEIF(IV.EQ.22) THEN
         IVV = 3
      ELSEIF(IV.EQ.23) THEN
         IVV = 4
      END IF

      IF(IBUILD.EQ.2  .AND.  (RBLEV.GT.0.AND.RBLEV.LE.0.90)  )  THEN
        DDNOXX = RBLEV*( (RBLD(IMY,IVV) -0.10*NEFFCT(IMY,IVV) )/O . 90)
      "            +  (1-RBLEV)*NEFFCT(IMY,IVV)
      ELSEIF(IBUILD.EQ.2  .AND.  RBLEV.GT.0.90)  THEN
        DDNOXX = RBLD(IMY,IVV)
      ELSEIF(IBUILD.EQ.1  .OR.  (RBLEV.LE.0.AND.IBUILD.EQ.2)  )  THEN
        DDNOXX = NEFFCT(IMY,IVV)
      ELSE
        DDNOXX = RBLD(IMY,IVV)
      END IF

      IF(IROAD.EQ.1) THEN
         DDNOX = DDNOXX *  FLEET(IMY,IVV)  * URBAN(IMY,IVV)
      ELSEIF(IROAD.EQ.2)  THEN
         DDNOX = DDNOXX *  FLEET(IMY,IVV)  * ARTERL(IMY,IVV)
      ELSEIF(IROAD.EQ.3)  THEN
         DDNOX = DDNOXX *  FLEET(IMY,IVV)  * EXPRES(IMY,IVV)
      END IF

      RETURN
      END
M6.HDE.003-Defeat Device                                                 Page 21

-------
      MODULE DDDATA

      IMPLICIT NONE
      SAVE
C
C
C
C
C
C
C
C
C
C.
C
C
C
C
C.
C
C
C.
C
C
C.
C
C
C.
C
C
C.
C
C.
C
C
C.
C
C
C
C

C
C

C

C
INTEGER, PARAMETER : : NCY =
INTEGER, PARAMETER : : NVCLS
REAL, DIMENSION (NCY, NVCLS)
REAL, DIMENSION (NCY, NVCLS)
REAL, DIMENSION (NCY, NVCLS)
REAL, DIMENSION (NCY, NVCLS)
REAL, DIMENSION (NCY, NVCLS)
REAL, DIMENSION (NCY, NVCLS)
INTEGER, DIMENSION (NVCLS)

L8
= 4
NEFFCT
URBAN
ARTERL
EXPRES
FLEET
RBLD
IRBLD
 Dimension 18  reflects  the  MY's  and 4  reflects  the  vehicle  classes.
 In RBLD - 7  reflects the MY's and 4 reflects the vehicle classes.

 Values  for NEFFCT are  the  increase in NOx emission levels
 as the  result of  the heavy-duty NOx defeat device.

 Light duty includes all diesel  except classes  6,7,8a and 8b.

.First entry  is for model year 2004.  Last entry is
 model year 1987 and earlier.  Negatives  reflect Pull ahead effects.
 Value of Zero is  assigned  if no Pull  Ahead or  effect.   There  are  no
 effects for  model years 2004+ or 1987 and earlier.

.URBAN is the  fraction  of the time that the defeat  device operates
 when an equipped  vehicle is  operating in Urban type driving.

.ARTERL  is the fraction of  the time that  the defeat device  operates
 when an equipped  vehicle is  operating in Arterial  type  driving.

.EXPRES  is the fraction of  the time that  the defeat device  operates
 when an equipped  vehicle is  operating in Expressway type driving.

.FLEET is the  fraction  of the fleet that  is equipped with a defeat
 device.

.First year is 1999+ and last is 1993  and earlier.
 Rebuilds only in  1994  through 1998 MYs for Plan A.
.7.00 g/bhp-hr is  the rebuild emission target.
 Rebuild effect is the  difference between the value and  7.00.

.IRBLD is the  age  of a  vehicle when the first rebuild is done.
 parameters are available for the four vehicle  classes.
 These parameters  are currently  implicit  in the results;  thus,
 the array IRBLD is not currently used in Defeat.

    DATA IRBLD / 99, 12, 5,  3 /
    DATA NEFFCT/
 LIGHT DIESELS  &  BUSES
   *0.0000,  -1.6300,  -0.4075,  15*0.0000,
 MEDIUM DIESELS (CLS  6  & 7)
   * 0.0000,  -1.8500,-0.4625,  0.0000,  0.2420,
   * 0.3295,   3.3623, 2.7163,  2.7408,
M6.HDE.003-Defeat Device
                                                                     Page 22

-------


c




c




c

c

c




c




c




c

c

c




c




c




c
c

c

c




c


8A




8B






*
*

*
*
*
*

*
*
*
*


2.9136, 2.
0.0680, 0.
HEAVY-DUTIES
4900,
7890,

0.0000, -1.8400, -
1.4863, 8.
7.1260, 6.
8.8713, 8.
HEAVY-DUTIES
0.0000, -1.
1.9520, 8.
7.1022, 6.
8.8179, 7.

DATA RBLD/
LIGHT DIESELS &

*
2377,
9118,
3125,

8400,-
2617,
8980,
8961,


BUSES
0.0000, -1.6300, -
MEDIUM DIESELS




8A




8B






*
*
*
*

*
*
*
*

*
*
*
*


0.0000, -1.
0.3295, 3.
2.4424, 2.
0.0680, 0.
HEAVY-DUTIES
(CLS 6
8500,-
3152,
4000,
7890,

0.0000, -1.8400, -
1.4863, 3.
2.8636, 2.
8.8713, 8.
HEAVY-DUTIES
0.0000, -1.
1.9520, 3.
2.8612, 2.
8.8179, 7.

DATA URBAN/
LIGHT DIESELS &

*
0.0000, 1.
MEDIUM DIESELS




8A




8B







*
*
*
*

*
*
*
*

*
*
*
*



0.0000, 1.
0.0009, 0.
0.0692, 0.
0.0000, 0.
HEAVY-DUTIES
0.0000, 1.
0.0210, 0.
0.0468, 0.
0.0295, 0.
HEAVY-DUTIES
0.0000, 1.
0.0267, 0.
0.0487, 0.
0.0363, 0.


DATA ARTERL/
LIGHT DIESELS &

*
0.0000, 1.
MEDIUM DIESELS




8A
*
*
*
*

0.0000, 1.
0.2000, 0.
0.3516, 0.
0.0000, 0.
HEAVY-DUTIES
8118,
8422,
3125,

8400,-
8142,
8408,
8961,


BUSES
OOOO,
(CLS 6
OOOO,
0009,
1200,
OOOO,

OOOO,
0210,
0341,
0612,

OOOO,
0267,
0362,
0753,



BUSES
OOOO,
(CLS 6
OOOO,
2000,
6100,
OOOO,

2
1

0
7
7
8

0
7
7
8



0

0
2
2
1

0
2
7
8

0
2
7
8






0
0
0


0
0
0


0
0
0







0
0
0

.5700,
.5000,

.4600,
.1143,
.4985,
.9200,

.4600,
.2067,
.3978,
.9200,



.4075,
& 7)
.4625,
.4226,
.5700,
.5000,

.4600,
.8624,
.4985,
.9200,

.4600,
. 8717,
.3978,
.9200,



1.0000,
& 7)
1.0000,
.0042,
.1200,
.0000,

1.0000,
.0083,
.0271,
.0000,

1.0000,
.0116,
.0299,
.0000,




1.0000,
& 7)
1.0000,
.0385,
.6100,
.0000,

0
1

0
6
7
8

0
6
7
8



.0680,
.5000,

.0000,
.9407,
.9025,
.9200,

.0000,
.9501,
.7489,
.9200,




0

1


0

1


0



15*0.0000

0
2
0
1

0
2
7
8

0
2
7
8




.0000,
.4251,
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M6.HDE.003-Defeat Device
Page 23

-------




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      END MODULE  DDDATA
M6.HDE.003-Defeat Device
Page 24

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