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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 Bunker
Environmental Protection Agency
14 August 2019

[Federal Register Volume 84, Number 157 (Wednesday, August 14, 2019)]
[Pages 40403-40405]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2019-17473]




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 
application. Pursuant to applicable regulations, EPA is making 
Hyundai's and Kia's off-cycle credit calculation methodologies 
available for public comment.

DATES: Comments must be received on or before September 13, 2019.

ADDRESSES: Submit your comments, identified by Docket ID No. EPA-HQ- 
OAR-2019-0459, 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 
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 

    \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

[[Page 40404]]

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. High-Efficiency Alternators

    Using the alternative methodology approach discussed above, Hyundai 
and Kia are applying for credits for model years 2010 and later for 
off-cycle credits using the alternative demonstration methodology 
pathway for high-efficiency alternators. 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. Since then, however a 
methodology has been developed that scales credits based on the 
efficiency of the alternator; alternators with efficiency (as measured 
using an accepted industry standard procedure) above a baseline value 
could get credits. EPA has previously approved credits for high-
efficiency alternators using this methodology for Ford Motor Company, 
General Motors Corporation, Fiat Chrysler Automobiles, and Toyota Motor 
Company. Details of the testing and analysis can be found in the 
manufacturer's applications.

B. Hyundai and Kia Stop-Start System

    Hyundai and Kia applied for engine idle stop-start credit covering 
2012-2016 model year vehicles with stop-start technology, including 
hybrid electric vehicles and plug-in hybrid electric vehicles. Based on 
the analysis presented in their application, they are requesting a 
credit of 3.7 grams/mile for vehicles with stop-start technology that 
are not hybrids, and 3.8 grams/mile for hybrid electric and plug-in 
hybrid electric vehicles.
    The methodology used by Hyundai and Kia was essentially the same as 
that used by Mercedes and approved by EPA in September of 2014.\5\ This 
methodology is based on the following analyses:

    \5\ ``EPA Decision Document: Mercedes-Benz Off-cycle Credits for 
MYs 2012-2016.'' U.S. Environmental Protection Agency, EPA-420-R-14-
025, September 2014.

     Estimate or measure the total idle fraction as a 
percentage of all vehicle operation in the real-world;
     Estimate or measure the percentage of idle fraction that 
the stop-start system is enabled out of all the available idle time 
(i.e., eligible stop-start percentage or stop-start system 
     Determine the benefit of the stop-start system in grams 
per mile based on A-B emissions testing (i.e., technology on and off);
     Multiply the eligible real world stop-start time (relative 
to the 2-cycle eligible time) by the stop-start system benefit to 
estimate the idle stop-start credit; and,
     For vehicles that allow the driver to disable the stop-
start system, the frequency of disablement by the driver must be 
    The Mercedes application and EPA's Decision Document are both 
available on EPA's website; however, for convenience the table below 
shows a comparison of the key inputs to the methodologies approved by 
EPA for Mercedes and proposed by Hyundai and Kia.

                                           Mercedes (as     Hyundai-Kia
                  Input                     approved by    (proposed in
                                               EPA)        application)
Idle Time Fraction......................            22.7            22.7
System Effectiveness....................             52%           59.4%
Driver Disablement......................             11%            1.6%
Credit (g/mi)...........................        ~3.5-4.5         3.7-3.8

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 manufacturer (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

[[Page 40405]]

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: August 5, 2019.
Byron J. Bunker,
Director, Compliance Division, Office of Transportation and Air 
Quality, Office of Air and Radiation.
[FR Doc. 2019-17473 Filed 8-13-19; 8:45 am]

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