Alternative Method for Calculating Off-Cycle Credits Under the Light-Duty Vehicle Greenhouse Gas Emissions Program: Applications From General Motors and Toyota Motor North America |
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Topics: General Motors, Toyota
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Byron Bunker
Environmental Protection Agency
26 February 2018
[Federal Register Volume 83, Number 38 (Monday, February 26, 2018)]
[Notices]
[Pages 8262-8264]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2018-03846]
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ENVIRONMENTAL PROTECTION AGENCY
[FRL-9974-37-OAR]
Alternative Method for Calculating Off-Cycle Credits Under the
Light-Duty Vehicle Greenhouse Gas Emissions Program: Applications From
General Motors and Toyota Motor North America
AGENCY: Environmental Protection Agency (EPA).
ACTION: Notice.
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SUMMARY: EPA is requesting comment on applications General Motors (GM),
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'' carbon dioxide (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 two manufacturers
have submitted applications that describe methodologies for determining
off-cycle credits. The off-cycle technologies vary by manufacturer and
include thermal control technologies such as high efficiency
alternators, an efficient air conditioning compressor, and active
climate control seats. Pursuant to applicable regulations, EPA is
making descriptions of each manufacturer's off-cycle credit calculation
methodologies available for public comment.
DATES: Comments must be received on or before March 28, 2018.
ADDRESSES: Submit your comments, identified by Docket ID No. EPA-HQ-
OAR-2017-0754, 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.
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
[[Page 8263]]
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 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. General Motors
1. High-Efficiency Alternator
General Motors (GM) is requesting GHG credits for alternators with
improved efficiency relative to a baseline alternator. This request is
for the 2010 to 2016 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\ GM 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 0.16 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.\6\ Details of the testing and analysis can be
found in the manufacturer's application.
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\5\ See 77FR 62730, October 15, 2012.
\6\ See 82 FR 27819, June 19, 2017.
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2. Active Climate Control Seats
GM is also applying for off-cycle GHG credits for the use of active
climate control seat technologies. Based on GM's analysis, they are
requesting credits equal to 2.3 grams CO2 per mile for
passenger cars and 2.9 grams CO2 per mile for trucks on all
models that use these seats in both front seating locations. This
request is for a larger amount of credit than could be earned by these
designs using the pre-defined regulatory ``menu'' of default off-cycle
credits for ventilated seats (1.0 and 1.3 grams/mile for cars and
trucks, respectively).
The technology used by GM uses a combination of ventilation fans
and cooling devices. Active cooling to the seat back is provided by the
installation of thermoelectric devices (TED) and a blower which
provides positive, temperature controlled airflow pushed towards the
occupant. The seat cushion also features a blower operating in a pull
mode, drawing the air surrounding the occupant into the seat cushion.
The foams in both seating surfaces include a textile spacer fabric that
facilitates lateral airflow under occupant load. The seat covers are
made of cloth and backed by an additional layer of textile spacer
fabric to promote airflow to the occupant.
GM performed a series of simulations on three vehicle platforms,
demonstrating credit values of 1.7 and 2.1 grams/mile for cars and
trucks,
[[Page 8264]]
respectively. The analysis also accounted for emissions associated with
the power consumption of the ventilated seat technology. The request is
for these credit levels for 2010-2016 models using active climate
control seat technology in both front seating locations.
B. Toyota Motor North America (Toyota)
Using the alternative methodology approach discussed above, Toyota
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 2013 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 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,\7\ and has
subsequently approved such credits for BMW, Ford, and Hyundai.\8\
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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.
\8\ 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.\9\ 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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\9\ See 40 CFR 86.1868-12.
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Toyota is requesting an off-cycle GHG credit of 1.1 grams
CO2 per mile for the Denso SAS compressor. Toyota cited the
bench test modeling analysis referenced in the original GM application,
which demonstrated a benefit of 1.1 grams/mile. Like other
manufacturers, Toyota also ran vehicle tests using the AC17 test. Six
tests were conducted on a Toyota Corolla, resulting in a calculated
benefit of 1.4 grams/mile, thus substantiating the bench test results.
Based on these results, Toyota is requesting a credit of 1.1 grams/mile
for all Toyota vehicles equipped with the Denso SAS compressor with
variable crankcase suction valve technology, starting with 2013 model
year vehicles. Details of the testing and analysis can be found in the
manufacturer's application.
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 GM and Toyota (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: February 6, 2018.
Byron Bunker,
Director, Compliance Division Office of Transportation and Air Quality
Office of Air and Radiation.
[FR Doc. 2018-03846 Filed 2-23-18; 8:45 am]
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