Ford E450 Emission recall #15E05

This is speculation and nothing more-

I found the CA test results for my '11. The Federal certification does not list results. There may be completely different tune for the CA model.
http://www.fleet.ford.com/resources/ford/general/programs/emissions/2011_a0101599.pdf

Assuming it wasn't a direct cheat, and I am not, the one marginal category was HC. The NOX and CO results were far under allowable.

On this engine the ECU cannot control cam timing, or EGR (not equipped). It can control ignition timing, idle speed, fuel injection parameters.

Assuming the unburned HC is the marginal issue here, a logical place to work is cold start. Pull back timing a couple degrees for a few minutes at start and crack up the fast idle a tad. Possibly hold transmission gears a little longer. This to light off the converter faster. It is my observation that my engine is a little slow to light the converter. A solution like this could mean all the rest of the duty cycle is unchanged after a couple minutes of cold operation.

Of course this is grabbing for straws. But I can't believe in general it is off by much.

I received a notice for my 2011 E450. What am I missing, have the EPA testing procedures recently changed because my unit has been annually passing the Texas emission test.

Got one today for my 2012 E450

Hmm there were some related to trailer brake controller on 14 and newer models, one issued June 16. But I have not seen any for emissions. I'll keep checking. Saw mention in Ford truck enthusiast forum..must be brand new.
15E05

Affected vehicles: 2011-2016 E-Series Cutaway and Stripped Chassis vehicles equipped with a 6.8L 2V gas engine

Situation: In some of the affected vehicles, the 6.8L 2V gas engine may not comply with government emissions standards when tested using the latest EPA test procedures.

We got one for our 2015.