Alternative Method for Calculating Off-Cycle Credits Under the Light-Duty Vehicle Greenhouse Gas Emissions Program: Applications From Fiat Chrysler Automobiles and Toyota Motor North America |
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Topics: Fiat Chrysler Automobiles, Toyota
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Byron Bunker
Environmental Protection Agency
10 April 2018
[Federal Register Volume 83, Number 69 (Tuesday, April 10, 2018)]
[Notices]
[Pages 15383-15385]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2018-07356]
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ENVIRONMENTAL PROTECTION AGENCY
[FRL-9976-26-OAR]
Alternative Method for Calculating Off-Cycle Credits Under the
Light-Duty Vehicle Greenhouse Gas Emissions Program: Applications From
Fiat Chrysler Automobiles and Toyota Motor North America
AGENCY: Environmental Protection Agency (EPA).
ACTION: Notice.
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SUMMARY: The Environmental Protection Agency (EPA) is requesting
comment on applications from Fiat Chrysler Automobiles (FCA), and
Toyota Motor North America (Toyota) 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. These manufacturers have
submitted applications that describe methodologies for determining off-
cycle credits from technologies described in their applications.
Pursuant to applicable regulations, EPA is making the descriptions of
each manufacturer's off-cycle credit calculation methodologies
available for public comment.
DATES: Comments must be received on or before May 10, 2018.
ADDRESSES: Submit your comments, identified by Docket ID No. EPA-HQ-
OAR-2018-0168, to the Federal eRulemaking Portal: https://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 https://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.
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 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, as long as 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 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 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
[[Page 15384]]
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
1. High-Efficiency Alternator
FCA is requesting GHG credits for alternators with improved
efficiency relative to a baseline alternator. This request is for the
2009 and later model years. Automotive alternators convert mechanical
energy from a combustion engine into electrical energy that can be used
to power a vehicle's electrical systems. Alternators inherently place a
load on the engine, which results in increased fuel consumption and
CO2 emissions. High efficiency alternators use new
technologies to reduce the overall load on the engine yet continue to
meet the electrical demands of the vehicle systems, resulting in lower
fuel consumption and lower CO2 emissions. Some comments on
EPA's proposed rule for GHG standards for the 2016-2025 model years
suggested that EPA provide a credit for high-efficiency alternators on
the pre-defined list in the regulations. While EPA agreed that high-
efficiency alternators can reduce electrical load and reduce fuel
consumption, and that these impacts are not seen on the emission test
procedures because accessories that use electricity are turned off, EPA
noted the difficulty in defining a one-size-fits-all credit due to lack
of data.\5\ FCA proposes a methodology that would scale credits based
on the efficiency of the alternator; alternators with efficiency (as
measured using an accepted industry standard procedure) above a
specified baseline value could get credits of 0.14 grams/mile per
percent improvement in alternator efficiency. This methodology is
similar to that proposed by Ford and published for comment in June of
2017, as well as that proposed by GM in this Federal Register
notice.\6\ Details of the testing and analysis can be found in the
manufacturer's application.
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\5\ See 77 FR 62730, October 15, 2012.
\6\ See 82 FR 27819, June 19, 2017.
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2. Active Engine Warm-Up and Active Transmission Warm-Up
Using the alternative methodology approach discussed above, FCA is
applying for credits for model years prior to 2014, and thus prior to
when the list of default credits became available. FCA has applied for
off-cycle credits using the alternative demonstration methodology
pathway for active transmission warmup and active engine warmup. EPA
has already approved credits for these technologies for model years
prior to 2014.\7\ FCA's request is consistent with previously approved
methodologies and credits. The application covers active engine warmup
used in 2011-2013 model year vehicles, and active transmission warmup
used in 2013 model year vehicles. These technologies are described in
the predetermined list of credits available in the 2014 and later model
years. The methodologies described by FCA are 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, as shown in the table below:
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\7\ ``EPA Decision Document: Off-cycle Credits for Fiat Chrysler
Automobiles, Ford Motor Company, and General Motors Corporation.''
Compliance Division, Office of Transportation and Air Quality, U.S.
Environmental Protection Agency. EPA-420-R-15-014, September 2015.
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Off-cycle Off-cycle
Technology credit--cars credit--trucks
(grams/mile) (grams/mile)
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Active transmission warm-up............. 1.5 3.2
Active engine warm-up................... 1.5 3.2
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3. Variable Crankcase Suction Valve Technology in Denso AC Compressors
Using the alternative methodology approach discussed above, FCA is
applying for credits for an air conditioning compressor manufactured by
Denso that results in air conditioning efficiency credits beyond those
provided in the regulations. This request is for the 2019 and
subsequent model years. This compressor, known as 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 addition of a variable crankcase suction valve allows a larger mass
flow under maximum capacity and
[[Page 15385]]
compressor start-up conditions (when high flow is ideal), and then it
can reduce to smaller openings with reduced mass flow in mid- or low-
capacity conditions. The refrigerant exiting the crankcase is thus
optimized across the range of operating conditions, reducing the
overall energy consumption of the air conditioning system. EPA first
approved credits for General Motors (GM) for the use of the Denso SAS
compressor in 2015,\8\ and has subsequently approved such credits for
BMW, Ford, and Hyundai.\9\
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\8\ ``EPA Decision Document: Off-cycle Credits for Fiat Chrysler
Automobiles, Ford Motor Company, and General Motors Corporation.''
Compliance Division, Office of Transportation and Air Quality, U.S.
Environmental Protection Agency. EPA-420-R-15-014, September 2015.
\9\ EPA Decision Document: Off-cycle Credits for BMW Group, Ford
Motor Company, and Hyundai Motor Company.'' Compliance Division,
Office of Transportation and Air Quality, U.S. Environmental
Protection Agency. EPA-420-R-17-010, December 2017.
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The credits calculated for the Denso SAS compressor would be in
addition to the credits of 1.7 grams/mile for variable-displacement A/C
compressors already allowed under EPA regulations.\10\ However, it is
important to note that EPA regulations place a limit on the cumulative
credits that can be claimed for improving the efficiency of A/C
systems. The rationale for this limit is that the additional fuel
consumption of A/C systems can never be reduced to zero, and the limits
established by regulation reflect the maximum possible reduction in
fuel consumption projected by EPA. These limits, or caps, on credits
for A/C efficiency, must also be applied to A/C efficiency credits
granted under the off-cycle credit approval process. In other words,
cumulative A/C efficiency credits for an A/C system--from the A/C
efficiency regulations and those granted via the off-cycle
regulations--must comply with the stated limits.
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\10\ See 40 CFR 86.1868-12.
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FCA is requesting an off-cycle GHG credit of 1.1 grams
CO2 per mile for the Denso SAS compressor. FCA cited the
bench test modeling analysis referenced in the original GM application,
which demonstrated a benefit of 1.1 grams/mile. Like other
manufacturers, FCA also ran vehicle tests using the AC17 test. Eight
tests were conducted on a 2014 Dodge Charger, resulting in a calculated
benefit of 3.16 grams/mile, thus substantiating the bench test results.
Based on these results, FCA is requesting a credit of 1.1 grams/mile
for all FCA vehicles equipped with the Denso SAS compressor with
variable crankcase suction valve technology, starting with 2019 model
year vehicles. Details of the testing and analysis can be found in the
manufacturer's application.
B. Toyota Motor North America
Toyota Motor North America (Toyota) is requesting GHG credits for
alternators with improved efficiency relative to a baseline alternator.
This request is for the 2017 and later model years. Automotive
alternators convert mechanical energy from a combustion engine into
electrical energy that can be used to power a vehicle's electrical
systems. Alternators inherently place a load on the engine, which
results in increased fuel consumption and CO2 emissions.
High efficiency alternators use new technologies to reduce the overall
load on the engine yet continue to meet the electrical demands of the
vehicle systems, resulting in lower fuel consumption and lower
CO2 emissions. Some comments on EPA's proposed rule for GHG
standards for the 2016-2025 model years suggested that EPA provide a
credit for high-efficiency alternators on the pre-defined list in the
regulations. While EPA agreed that high-efficiency alternators can
reduce electrical load and reduce fuel consumption, and that these
impacts are not seen on the emission test procedures because
accessories that use electricity are turned off, EPA noted the
difficulty in defining a one-size-fits-all credit due to lack of
data.\11\ Toyota proposes a methodology that would scale credits based
on the efficiency of the alternator; alternators with efficiency (as
measured using an accepted industry standard procedure) above a
specified baseline value could get credits of 0.1 to 2.0 grams/mile
depending on the overall improvement in alternator efficiency. This
methodology is similar to that proposed by Ford and published for
comment in June of 2017.\12\ Details of the testing and analysis can be
found in the manufacturer's application.
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\11\ See 77 FR 62730, October 15, 2012.
\12\ See 82 FR 27819, June 19, 2017.
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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 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 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: March 23, 2018.
Byron Bunker,
Director, Compliance Division, Office of Transportation and Air
Quality, Office of Air and Radiation.
[FR Doc. 2018-07356 Filed 4-9-18; 8:45 am]
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