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Alternative Methods for Calculating Off-Cycle Credits Under the Light-Duty Vehicle Greenhouse Gas Emissions Program: Applications From Hyundai Motor Company and Kia Motors Corporation

American Government Topics:  Hyundai, Kia

Alternative Methods for Calculating Off-Cycle Credits Under the Light-Duty Vehicle Greenhouse Gas Emissions Program: Applications From Hyundai Motor Company and Kia Motors Corporation

Byron J. Bunker
Environmental Protection Agency
21 February 2020

[Federal Register Volume 85, Number 35 (Friday, February 21, 2020)]
[Pages 10162-10164]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2020-03510]



[EPA-HQ-OAR-2020-0073; FRL-10005-61-OAR]

Alternative Methods for Calculating Off-Cycle Credits Under the 
Light-Duty Vehicle Greenhouse Gas Emissions Program: Applications From 
Hyundai Motor Company and Kia Motors Corporation

AGENCY: Environmental Protection Agency (EPA).

ACTION: Notice.


SUMMARY: EPA is requesting comment on applications from Hyundai Motor 
Company (``Hyundai'') and Kia Motors Corporation (``Kia'') for off-
cycle carbon dioxide (CO2) credits under EPA's light-duty 
vehicle greenhouse gas emissions standards. ``Off-cycle'' emission 
reductions can be achieved by employing technologies that result in 
real-world benefits, but where that benefit is not adequately captured 
on the test procedures used by manufacturers to demonstrate compliance 
with emission standards. EPA's light-duty vehicle greenhouse gas 
program acknowledges these benefits by giving automobile manufacturers 
several options for generating ``off-cycle'' CO2 credits. 
Under the regulations, a manufacturer may apply for CO2 
credits for off-cycle technologies that result in off-cycle benefits. 
In these cases, a manufacturer must provide EPA with a proposed 
methodology for determining the real-world off-cycle benefit. Hyundai 
and Kia have submitted applications that describe methodologies for 
determining off-cycle credits from technologies described in their 
applications. Pursuant to applicable regulations, EPA is making these 
off-cycle credit calculation methodologies available for public 

DATES: Comments must be received on or before March 23, 2020.

ADDRESSES: Submit your comments, identified by Docket ID No. EPA-HQ- 
OAR-2020-0073, to the Federal eRulemaking Portal: http://www.regulations.gov. Follow the online instructions for submitting 
comments. Once submitted, comments cannot be edited or withdrawn. The 
EPA may publish any comment received to its public docket. Do not 
submit electronically any information you consider to be Confidential 
Business Information (CBI) or other information whose disclosure is 
restricted by statute. Multimedia submissions (audio, video, etc.) must 
be accompanied by a written comment. The written comment is considered 
the official comment and should include discussion of all points you 
wish to make. The EPA will generally not consider comments or comment 
contents located outside of the primary submission (i.e. on the web, 
cloud, or other file sharing system). For additional submission 
methods, the full EPA public comment policy, information about CBI or 
multimedia submissions, and general guidance on making effective 
comments, please visit http://www2.epa.gov/dockets/commenting-epa-dockets.

FOR FURTHER INFORMATION CONTACT: Roberts French, Environmental 
Protection Specialist, Office of Transportation and Air Quality, 
Compliance Division, U.S. Environmental Protection Agency, 2000 
Traverwood Drive, Ann Arbor, MI 48105. Telephone: (734) 214-4380. Fax: 
(734) 214-4869. Email address: french.roberts@epa.gov.


I. Background

    EPA's light-duty vehicle greenhouse gas (GHG) program provides 
three pathways by which a manufacturer may accrue off-cycle carbon 
dioxide (CO2) credits for those technologies that achieve 
CO2 reductions in the real world but where those reductions 
are not adequately captured on the test used to determine compliance 
with the CO2 standards, and which are not otherwise 
reflected in the standards' stringency. The first pathway is a 
predetermined list of credit values for specific off-cycle technologies 
that may be used beginning in model year 2014.\1\ This pathway allows 
manufacturers to use conservative credit values established by EPA for 
a wide range of technologies, with minimal data submittal or testing 
requirements, if the technologies meet EPA regulatory definitions. In 
cases where the off-cycle technology is not on the menu but additional 
laboratory testing can demonstrate emission benefits, a second pathway 
allows manufacturers to use a broader array of emission tests (known as 
``5-cycle'' testing because the methodology uses five different testing 
procedures) to demonstrate and justify off-cycle CO2

[[Page 10163]]

credits.\2\ The additional emission tests allow emission benefits to be 
demonstrated over some elements of real-world driving not adequately 
captured by the GHG compliance tests, including high speeds, hard 
accelerations, and cold temperatures. These first two methodologies 
were completely defined through notice and comment rulemaking and 
therefore no additional process is necessary for manufacturers to use 
these methods. The third and last pathway allows manufacturers to seek 
EPA approval to use an alternative methodology for determining the off-
cycle CO2 credits.\3\ This option is only available if the 
benefit of the technology cannot be adequately demonstrated using the 
5-cycle methodology. Manufacturers may also use this option to 
demonstrate reductions that exceed those available via use of the 
predetermined list.

    \1\ See 40 CFR 86.1869-12(b).
    \2\ See 40 CFR 86.1869-12(c).
    \3\ See 40 CFR 86.1869-12(d).

    Under the regulations, a manufacturer seeking to demonstrate off-
cycle credits with an alternative methodology (i.e., under the third 
pathway described above) must describe a methodology that meets the 
following criteria:
     Use modeling, on-road testing, on-road data collection, or 
other approved analytical or engineering methods;
     Be robust, verifiable, and capable of demonstrating the 
real-world emissions benefit with strong statistical significance;
     Result in a demonstration of baseline and controlled 
emissions over a wide range of driving conditions and number of 
vehicles such that issues of data uncertainty are minimized;
     Result in data on a model type basis unless the 
manufacturer demonstrates that another basis is appropriate and 
    Further, the regulations specify the following requirements 
regarding an application for off-cycle CO2 credits:
     A manufacturer requesting off-cycle credits must develop a 
methodology for demonstrating and determining the benefit of the off-
cycle technology and carry out any necessary testing and analysis 
required to support that methodology.
     A manufacturer requesting off-cycle credits must conduct 
testing and/or prepare engineering analyses that demonstrate the in-use 
durability of the technology for the full useful life of the vehicle.
     The application must contain a detailed description of the 
off-cycle technology and how it functions to reduce CO2 
emissions under conditions not represented on the compliance tests.
     The application must contain a list of the vehicle 
model(s) which will be equipped with the technology.
     The application must contain a detailed description of the 
test vehicles selected and an engineering analysis that supports the 
selection of those vehicles for testing.
     The application must contain all testing and/or simulation 
data required under the regulations, plus any other data the 
manufacturer has considered in the analysis.
    Finally, the alternative methodology must be approved by EPA prior 
to the manufacturer using it to generate credits. As part of the review 
process defined by regulation, the alternative methodology submitted to 
EPA for consideration must be made available for public comment.\4\ EPA 
will consider public comments as part of its final decision to approve 
or deny the request for off-cycle credits.

    \4\ See 40 CFR 86.1869-12(d)(2).

II. Off-Cycle Credit Applications

A. Active Climate Control Seats

    Hyundai and Kia are applying for off-cycle GHG credits for the use 
of active climate control seat technologies. Climate Control Seats 
(CCS) are a seat technology that utilizes motorized blowers, 
thermoelectric devices, and seating surfaces designed for high airflow 
to move chilled air through the seat and onto the occupant. In Hyundai 
and Kia vehicle applications, the CCS contains two thermoelectric 
chillers: One in the seat back, one in the seat cushion. The seat 
cushion contains one blower motor with air ducts to direct blower air 
flow through both the seat cushion and seat back. The technology 
provides active cooling, which occurs when the blower motor passes 
ambient cabin air across the integrated thermoelectric chillers; the 
chilled air then moves through the seating surfaces and onto the 
vehicle occupant. The technology allows vehicle occupants to reach 
equivalent thermal comfort at a higher cabin ambient temperature 
compared to a baseline seat, and therefore has the potential to reduce 
A/C system fuel use more than ventilated seats.
    General Motors (GM) previously applied for credits for this 
technology, and EPA approved these credits for GM in 2018.\5\ GM's 
methodology referenced a 2017 study conducted by the National Renewable 
Energy Laboratory (NREL) in partnership with Gentherm, the manufacturer 
of the CCS system.\6\ This study found that the CCS technology reduced 
air conditioner loads by 17%, substantially more than the 7.5% 
reduction for the older technology tested by NREL in 2005 and used to 
derive the menu-based credit in the regulations. Applying this 17% 
reduction to the EPA baseline A/C emissions (13.8 for cars and 17.2 for 
trucks) results in off-cycle credit for CCS systems of 2.3 grams/mile 
for passenger cars and 2.9 grams/mile for trucks (instead of the 
default credits of 1.0 and 1.3 grams/mile, respectively). EPA considers 
the CCS system to be a thermal control technology that, if approved, 
will be subject to the maximum per vehicle limits of 3.0 g/mi for 
passenger automobiles and 4.3 g/mi for light trucks specified in the 

    \5\ ``EPA Decision Document: Off-cycle Credits for General 
Motors and Toyota Motor Corporation.'' Compliance Division, Office 
of Transportation and Air Quality, U.S. Environmental Protection 
Agency. EPA-420-R-18-014, June 2018.
    \6\ ``Impact of Active Climate Control Seats on Energy Use, Fuel 
Use, and CO2 Emissions: Test and Analysis.'' Cory 
Kreutzer, John Rugh, Bidzina Kekelia, Gene Titov, Strategic 
Partnership Project Report, Contract No. DE-AC36-08GO28308, May 
    \7\ See 40 CFR 86.1869-12(b)(1)(viii).

    Hyundai and Kia use the Gentherm seat technology, thus they 
similarly referenced the NREL report and have requested credits 
identical to those already approved for GM. Their requests are for 2012 
and later model year vehicles using this technology. If approved, these 
credits would be for vehicles using this technology in both front 
seating locations, consistent with the NREL evaluation and the credits 
granted to GM.

B. Air Conditioning Compressor With Variable Orifice Valve Technology

    Hyundai and Kia are applying for off-cycle GHG credits for the use 
of the Hanon air conditioner compressor with variable orifice valve 
technology. The Hanon compressor design improves the internal valve 
system to reduce the internal refrigerant flow necessary throughout the 
range of displacements that the compressor uses during its operating 
cycle. This is achieved through the addition of a variable orifice 
valve. Conventional compressors have a fixed orifice, so the flow of 
refrigerant exiting the crankcase is fixed. The sizing of the orifice 
is a compromise among the conditions when either a high or low rate of 
flow would be more ideal. However, variable orifice valve technology 
can provide a larger mass flow under maximum capacity and compressor 
start-up conditions by opening the valve, when high flow is ideal; it 
can then reduce to smaller openings with reduced mass flow in

[[Page 10164]]

mid or low capacity conditions. Thus, overall, the refrigerant exiting 
the crankcase is optimized across the range of operating conditions, 
improving system efficiency and therefore lowering indirect 
CO2 emissions due to use of the air conditioning system.
    Hyundai and Kia are applying for credits for the 2021 and later 
model years for vehicles sold in the U.S. and equipped with the Hanon 
A/C compressor with variable orifice valve technology. The credits 
requested range from 1.5 g/mi to 1.8 g/mi, depending on the specifics 
of the A/C system. EPA considers this compressor technology to be a 
technology that, if approved, will be subject to the maximum limits for 
an A/C system of 5.0 g/mi for passenger automobiles and 7.2 g/mi for 
light trucks specified in the regulations.\8\ Details of the testing 
and analysis can be found in the manufacturer's applications.

    \8\ See 40 CFR 86.1868-12(b).

III. EPA Decision Process

    EPA has reviewed the applications for completeness and is now 
making the applications available for public review and comment as 
required by the regulations. The off-cycle credit applications 
submitted by the manufacturers (with confidential business information 
redacted) have been placed in the public docket (see ADDRESSES section 
above) and on EPA's website at https://www.epa.gov/vehicle-and-engine-certification/compliance-information-light-duty-greenhouse-gas-ghg-standards.
    EPA is providing a 30-day comment period on the applications for 
off-cycle credits described in this document, as specified by the 
regulations. The manufacturers may submit a written rebuttal of 
comments for EPA's consideration, or may revise an application in 
response to comments. After reviewing any public comments and any 
rebuttal of comments submitted by manufacturers, EPA will make a final 
decision regarding the credit requests. EPA will make its decision 
available to the public by placing a decision document (or multiple 
decision documents) in the docket and on EPA's website at the same 
manufacturer-specific pages shown above. While the broad methodologies 
used by these manufacturers could potentially be used for other 
vehicles and by other manufacturers, the vehicle specific data needed 
to demonstrate the off-cycle emissions reductions would likely be 
different. In such cases, a new application would be required, 
including an opportunity for public comment.

    Dated: February 11, 2020.
Byron J. Bunker,
Director, Compliance Division, Office of Transportation and Air 
Quality, Office of Air and Radiation.
[FR Doc. 2020-03510 Filed 2-20-20; 8:45 am]

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