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In 2015 the U.S. Environmental Protection Agency (EPA) and the U.S. Department of Transportation's National Highway Traffic Safety Administration (NHTSA) proposed a new steady-state engine dynamometer test procedure by which heavy-duty engine manufacturers would be required to create engine fuel rate versus engine speed and torque “maps”.[1] These maps would then be used within the agencies' Greenhouse Gas Emission Model (GEM)[2] for full vehicle certification to the agencies' proposed heavy-duty fuel efficiency and greenhouse gas (GHG) emissions standards. This paper presents an alternative to the agencies' proposal, where an engine is tested over the same duty cycles simulated in GEM. This paper explains how a range of vehicle configurations could be specified for GEM to generate engine duty cycles that would then be used for engine testing.