ShinerBock wrote:
Cummins uses J1995 just like all engine manufactures that only make an engine and cannot control the intake and exhaust system of the vehicle the engine will be put in. This does not mean that Cummins(or any other engine manufacturer) cannot simulate the intake and exhaust system that these engines are going in, but they still can only do a J1995 certification since they only manufacture the engine, not the vehicle.
I'm not buying the notion that Cummins only certifies engines, irrespective of application.
This thread began with a towing contest between some type of Ford (irrelevant) pitted against a recent model (2017? 2018?) Ram 3500. So to be safe let's look at a 2017 Model Year Ram 3500 with a Cummins ISB 6.7L diesel engine.
Remembering that Cummins only builds engines, not vehicles, we already know that Cummins put the ISB 6.7L engine into many other vehicles in model year 2017 besides the Ram 3500. For example, there is the Ram 2500, 4500, and 5500. There is also the Freightliner M2-106 and 108SD; the International Durastar, Workstar, and new HV series; the Autocar ACMD XPert (small refuse truck), ACX XPeditor (big refuse truck) and ACTT XSpotter (yard goat); the BlueBird Vision and All American (school buses); the dozens of motorhome manufacturers who outfit their class A coaches with the ISB 6.7L; the dozens of stationary power applications, off road equipment, airport shuttle busses, municipal busses... you get the idea.
In fact, you established the idea, in this thread, that Cummins builds and certifies the engine without respect to the vehicle, "because they cannot control the intake and exhaust system that the engine will be put in."
I do a lot of mind numbing paperwork in fleet certification compliance, in the strictest emissions state in this nation. I can guarantee you that Cummins separately certified one of many iterations of their ISB 6.7L engine specifically to the 2017 Ram 3500, and that certification applies to no other vehicle... not even the RAM 2500, 4500, or 5500.
The exhaust, and the specific components of the exhaust, are identified and named in the certification. The intake is described. The GVWR and the tare weight of the vehicle is described. The specific horsepower levels (there are three... 350hp, 370hp, and 385hp) are tested individually. Every iteration of the 3500 is tested separately, whether 4x4 or 4x2, along with each of the three available transmissions, tested in all possible configurations, both Federal as well as California.
In fact, Cummins paid California $23,000 just to get the CARB certification, and that certification did not apply to any other Ram Cummins vehicle other than the Ram 3500 and the six possible drivetrain configurations that vehicle is available in. And it was Cummins, not FCA, that wrote the check and signed the Certification.
The EPA requires that engine manufacturers identify their engines with Family numbers, and the Cummins ISB 6.7L has many many many different family numbers and durability groups, each that is certified separately.
Because the Ram 3500 is 14,000 GVWR and under, and because it is sold as a completed vehicle, it has to be chassis certified, with the entire intake and exhaust system identified and tested.
The notion that Cummins is certifying engines for Ram pickups as engines only, without regard to the regulated emission system components of the vehicle, is not supported by the 34 page application that Cummins submitted to the EPA back in 2015 to get their engine in the RAM 3500 certified for model year 2017, nor the hundreds of applications that Cummins submits every year, for every Engine Family number, of every Engine they make, whether for destined for fire apparatus, compressor duty, or racing Fords up mountains with trailer in tow.
