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 |
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Topics: Hyundai, Kia
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Byron Bunker
Environmental Protection Agency
14 August 2019
[Federal Register Volume 84, Number 157 (Wednesday, August 14, 2019)]
[Notices]
[Pages 40403-40405]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2019-17473]
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ENVIRONMENTAL PROTECTION AGENCY
[FRL-9998-14-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.
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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.
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, 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
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
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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. 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:
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\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.
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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
effectiveness);
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
determined.
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.
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Mercedes (as Hyundai-Kia
Input approved by (proposed in
EPA) application)
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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
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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 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
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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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