Alternative Method for Calculating Off-Cycle Credits Under the Light-Duty Vehicle Greenhouse Gas Emissions Program: Applications From Fiat Chrysler Automobiles, Ford Motor Company, and General Motors Corporation |
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Byron Bunker
Environmental Protection Agency
June 3, 2015
[Federal Register Volume 80, Number 106 (Wednesday, June 3, 2015)]
[Notices]
[Pages 31598-31601]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2015-13503]
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ENVIRONMENTAL PROTECTION AGENCY
[FRL--9928-70-OAR]
Alternative Method for Calculating Off-Cycle Credits Under the
Light-Duty Vehicle Greenhouse Gas Emissions Program: Applications From
Fiat Chrysler Automobiles, Ford Motor Company, and General Motors
Corporation
AGENCY: Environmental Protection Agency (EPA).
ACTION: Notice.
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[[Page 31599]]
SUMMARY: The Environmental Protection Agency (EPA) is requesting
comment on applications from Fiat Chrysler Automobiles LLC (``FCA''),
Ford Motor Company (Ford) and General Motors Corporation (GM) 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 or
entirely 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''
carbon dioxide (CO2) credits. Under the regulations, a
manufacturer may apply for CO2 credits for 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. FCA and Ford have submitted applications that
describe methodologies for determining off-cycle credits from high
efficiency exterior lighting, solar reflective glass/glazing, solar
reflective paint, and active seat ventilation. Ford's application also
proposes methodologies for determining the off-cycle benefits from
active aerodynamic improvements (grill shutters), active transmission
warm-up, active engine warm-up technologies, and engine idle stop-
start. GM's application proposes a methodology to determine the real-
world benefits of an air conditioning compressor with variable
crankcase suction valve technology. Pursuant to applicable regulations,
EPA is making descriptions of the manufacturers' off-cycle credit
calculation methodologies available for public comment.
DATES: Comments must be received on or before July 6, 2015.
ADDRESSES: Submit your comments, identified by Docket ID No. EPA-HQ-
OAR-2015-0282, by one of the following methods:
http://www.regulations.gov: Follow the On-Line
Instructions for Submitting Comments.
Email: a-and-r-docket@epa.gov.
Fax: (202) 566-1741.
Mail: Air and Radiation Docket, Docket ID No. EPA-HQ- OAR-
2015-0282, U.S. Environmental Protection Agency, Mailcode: 22821T, 1200
Pennsylvania Avenue NW., Washington, DC 20460.
Hand Delivery: EPA Docket Center, Public Reading Room, EPA
West Building, Room 3334, 1301 Constitution Avenue NW., Washington, DC
20460. Attention Air and Radiation Docket ID No. EPA-HQ- OAR-2015-0282.
Such deliveries are only accepted during the Docket's normal hours of
operation, and special arrangements should be made for deliveries of
boxed information.
Online Instructions for Submitting Comments: Direct your comments
to Docket ID No. Attention Air and Radiation Docket ID No. EPA-HQ- OAR-
2015-0282. EPA's policy is that all comments received will be included
in the public docket without change and may be made available online at
www.regulations.gov, including any personal information provided,
unless the comment includes information claimed to be Confidential
Business Information (CBI) or other information whose disclosure is
restricted by statute. Do not submit information that you consider to
be CBI or otherwise protected through www.regulations.gov or email. The
www.regulations.gov Web site is an ``anonymous access'' system, which
means EPA will not know your identity or contact information unless you
provide it in the body of your comment. If you send an email comment
directly to EPA without going through www.regulations.gov, your email
address will be automatically captured and included as part of the
comment that is placed in the public docket and made available on the
Internet. If you submit an electronic comment, EPA recommends that you
include your name and other contact information in the body of your
comment and with any disk or CD-ROM you submit. If EPA cannot read your
comment due to technical difficulties and cannot contact you for
clarification, EPA may not be able to consider your comment. Electronic
files should avoid the use of special characters, any form of
encryption, and be free of any defects or viruses. For additional
information about EPA's public docket visit the EPA Docket Center
homepage at http://www.epa.gov/epahome/dockets.htm.
Docket: All documents in the docket are listed in the
www.regulations.gov index. Although listed in the index, some
information is not publicly available, e.g., CBI or other information
for which disclosure is restricted by statute. Certain other material,
such as copyrighted material, will be publicly available only in hard
copy. Publicly available docket materials are available either
electronically in www.regulations.gov or in hard copy at the Air and
Radiation Docket, EPA/DC, EPA WJC West, Room 3334, 1301 Constitution
Ave. NW., Washington, DC. The Public Reading Room is open from 8:30
a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The
telephone number for the Public Reading Room is (202) 566-1744, and the
telephone number for the Air and Radiation Docket is (202) 566-1742.
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.
SUPPLEMENTARY INFORMATION:
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 or entirely 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. In cases where 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
credits.\2\ The additional emission tests allow emission benefits to be
demonstrated over some elements of real-world driving not 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
[[Page 31600]]
using the 5-cycle methodology. Manufacturers may also use this option
for model years prior to 2014 to demonstrate off-cycle CO2
reductions for technologies that are on the predetermined list, or to
demonstrate reductions that exceed those available via use of the
predetermined list.
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\1\ See 40 CFR 86.1869-12(b).
\2\ See 40 CFR 86.1869-12(c).
\3\ See 40 CFR 86.1869-12(d).
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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
adequate.
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.
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\4\ See 40 CFR 86.1869-12(d)(2).
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II. Off-Cycle Credit Applications
A. Fiat Chrysler Automobiles
Using the alternative methodology approach discussed above, Fiat
Chrysler Automobiles (FCA) is applying for credits for model years
prior to 2014, and thus prior to when the list of default credits
becomes available. FCA has applied for off-cycle credits using the
alternative demonstration methodology pathway for the following
technologies: High efficiency exterior lighting, solar reflective
glass/glazing, solar reflective paint, and active seat ventilation. The
application covers 2009-2013 model year vehicles. All of these
technologies are described in the predetermined list of credits
available in the 2014 and later model years. The methodologies
described by FCA are generally consistent with those used by EPA to
establish the predetermined list of credits in the regulations, and
would result in the same credit values as described in the regulations.
The magnitude of these credits is determined by specification or
calculations in the regulations based on vehicle-specific measurements
(e.g., the area of glass or the lighting locations using the specified
technologies), but would be no higher than the following established
regulatory caps:
------------------------------------------------------------------------
Off-Cycle Credit-- Off-Cycle Credit--
Technology Cars (grams/ Trucks (grams/
mile) mile)
------------------------------------------------------------------------
High efficiency lighting.......... 1.0 1.0
Solar reflective glass/glazing.... 2.9 3.9
Solar reflective paint............ 0.4 0.5
Active seat ventilation........... 1.0 1.3
------------------------------------------------------------------------
B. Ford Motor Company
Using the alternative methodology approach discussed above, Ford
Motor Company (Ford) is applying for credits for model years prior to
2014, and thus prior to when the list of default credits becomes
available. Ford has applied for off-cycle credits using the alternative
demonstration methodology pathway for the following technologies: High
efficiency exterior lighting, solar reflective glass/glazing, solar
reflective paint, active seat ventilation, active aerodynamics, active
transmission warm-up, active engine warm-up, and engine idle start-
stop. All of these technologies are described in the predetermined list
of credits available in the 2014 and later model years. The application
covers 2012 and 2013 model year vehicles. The methodologies described
by Ford are generally equivalent to those used by EPA to establish the
predetermined list of credits in the regulations, and would result in
the same credit values as described in the regulations. The magnitude
of these credits is determined by specification or calculations in the
regulations based on vehicle-specific measurements (e.g., the area of
glass or the lighting locations using the specified technologies), but
would be no higher than the following established regulatory caps:
------------------------------------------------------------------------
Off-cycle Off-cycle
Technology credit--cars credit--trucks
(grams/mile) (grams/mile)
------------------------------------------------------------------------
High efficiency lighting.......... 1.0 1.0
Solar reflective glass/glazing.... 2.9 3.9
Solar reflective paint............ 0.4 0.5
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Active seat ventilation........... 1.0 1.3
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Active aerodynamics............... Based on measured reduction in the
coefficient of drag
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Active transmission warm-up....... 1.5 3.2
Active engine warm-up............. 1.5 3.2
Engine idle start-stop............ 2.5 4.4
------------------------------------------------------------------------
C. General Motors Corporation
Using the alternative methodology approach discussed above, GM is
applying for credits for model years 2013 through 2015. These credits
are for a component of the air conditioning system that results in air
conditioning efficiency credits beyond those provided in the
regulations. GM has applied for off-cycle credits for the Denso SAS air
conditioner compressor with variable crankcase suction valve
technology. GM is requesting an off-cycle GHG credit of 1.1 grams
CO2 per mile for this technology. EPA currently provides
Mobile Air Conditioner (MAC) GHG credits for reduced reheat using an
externally-controlled variable displacement compressor (EVDC), which
provides significant efficiency improvements compared to the baseline
fixed displacement compressors that were the norm at the time EPA
created the GHG program. Under the 2012-2016 light-duty GHG program,
the credit for using an EVDC is 1.7 grams of CO2 per mile.
GM has a new EVDC design from Denso that further improves the
efficiency of the MAC compressor through the addition of a variable
crankcase suction valve (variable CS valve). The Denso SAS compressor
improves the internal valve system within the compressor to reduce the
internal refrigerant flow necessary throughout the range of
displacements that the compressor may use during its operating cycle.
The variable CS valve can provide a larger mass flow under maximum
capacity and compressor start-up conditions, when high flow is ideal,
then reduce to smaller openings with reduced mass flow in mid or low
capacity conditions. The refrigerant exiting the crankcase is optimized
across the range of operating conditions, creating benefits for the
energy consumption of the MAC system.
The ``5-cycle'' methodology would not adequately measure the real
world GHG reduction benefits of either the EVDC or the variable CS
valve. Only one of the five tests is conducted with the air conditioner
on and that test cycle represents worse case conditions (e.g., high
temperature, solar load, and humidity) and would not represent the real
world benefits of the technology. Therefore, GM has chosen to determine
the appropriate off-cycle credits through use of an alternative
methodology.
GM worked with Denso to perform bench testing of EDVC with and
without the variable CS valve and quantified the difference. Based on
this analysis, GM determined an off-cycle credit of 1.1 grams of
CO2 per mile were appropriate. GM substantiated these
results by also performing vehicle tests using the AC17 test procedure.
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 FCA, Ford, and GM (with confidential business information
redacted) have been placed in the public docket (see ADDRESSES section
above) and on EPA's Web site at http://www.epa.gov/otaq/regs/ld-hwy/greenhouse/ld-ghg.htm. EPA is providing a 30-day comment period on the
applications for off-cycle credits described in this notice, 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 Web site at
http://www.epa.gov/otaq/regs/ld-hwy/greenhouse/ld-ghg.htm. 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: May 27, 2015.
Byron Bunker,
Director, Compliance Division, Office of Transportation and Air
Quality, Office of Air and Radiation.
[FR Doc. 2015-13503 Filed 6-2-15; 8:45 am]
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