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Beginning in 2007, heavy-duty engine manufacturers in the U.S. have been responsible for verifying the compliance on in-use vehicles with Not-to-Exceed (NTE) standards under the Heavy-Duty In-Use Testing Program (HDIUT). This in-use testing is conducted using Portable Emission Measurement Systems (PEMS) which are installed on the vehicles to measure emissions during real-world operation. A key component of the HDIUT program is the generation of measurement allowances which account for the relative accuracy of PEMS as compared to more conventional, laboratory based measurement techniques. A program to determine these measurement allowances for gaseous emissions was jointly funded by the U.S. Environmental Protection Agency (EPA), the California Air Resources Board (CARB), and various member companies of the Engine Manufacturer's Association (EMA).

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.