Alternative Methods for Calculating Off-Cycle Credits Under the Light-Duty Vehicle Greenhouse Gas Emissions Program: Applications From Ford Motor Company, American Honda Motor Company, and Nissan North America, Inc. |
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Byron J. Bunker
Environmental Protection Agency
6 February 2020
[Federal Register Volume 85, Number 25 (Thursday, February 6, 2020)]
[Notices]
[Pages 6945-6947]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2020-02370]
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ENVIRONMENTAL PROTECTION AGENCY
[FRL-10004-93-OAR]
Alternative Methods for Calculating Off-Cycle Credits Under the
Light-Duty Vehicle Greenhouse Gas Emissions Program: Applications From
Ford Motor Company, American Honda Motor Company, and Nissan North
America, Inc.
AGENCY: Environmental Protection Agency (EPA).
ACTION: Notice.
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SUMMARY: EPA is requesting comment on applications from Ford Motor
Company (``Ford''), Honda Motor Company (``Honda''), and Nissan North
America, Inc. (Nissan) 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. Ford, Honda, and Nissan
have submitted applications that describe methodologies for determining
off-cycle credits from technologies described in their applications.
Pursuant to applicable regulations, EPA is making these off-cycle
credit calculation methodologies available for public comment.
DATES: Comments must be received on or before March 9, 2020.
ADDRESSES: Submit your comments, identified by Docket ID No. EPA-HQ-
OAR-2020-0015, 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 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:
[[Page 6946]]
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. Valeo Air Conditioning Compressor With Variable Bleed Valve
Using the alternative methodology approach discussed above, Ford is
applying for credits for an air conditioning compressor manufactured by
Valeo that results in air conditioning efficiency credits beyond those
provided in the regulations. Valeo's air conditioning compressor with
variable bleed valve improves energy consumption compared to the
current generation compressor technology. Current technology is a
compromise of all load conditions. The variable bleed valve improves
the coefficient of performance under low and mid load conditions
decreasing CO2 emissions. The variable bleed valve is
designed to vary the bleed valve diameter, making it smaller to control
internal control gas for improved coefficient of performance, but also
be able to increase for liquid start up conditions. The optimized
valves reduce losses within the A/C compressor increasing efficiency.
The additional variable bleed valve improves the compressor over
previous externally-controlled variable displacement compressor
designs.
The credits calculated for the Valeo air conditioning compressor
with variable bleed valve would be in addition to the credits of 1.7
grams/mile for variable-displacement A/C compressors already allowed
under EPA regulations.\5\ 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, and EPA has typically
required that A/C-related technologies for which credits are sought
through the off-cycle program must also comply with these limits. The
rationale for the limits 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 for a typical A/C system. To date, EPA has required
that these limits, or caps, on credits for A/C efficiency be applied to
A/C efficiency credits granted under the off-cycle credit approval
process. In other words, EPA has required that cumulative A/C
efficiency credits for an A/C system--from the A/C efficiency
regulations and those granted via the off-cycle regulations--comply
with the stated limits.
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\5\ See 40 CFR 86.1868-12.
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The Ford application contains a detailed analysis supporting their
conclusion that the variable bleed valve is complementary to other A/C
efficiency technologies and, as such, should not be limited by the cap.
However, the fundamental approach of the A/C efficiency improvement
program is premised on limits to the overall impact of the A/C system
on CO2 and fuel economy, and EPA therefore established caps
based on a finite level of improvement (i.e. A/C operation will always
use some energy, fuel or electric power) that is achievable. These caps
or limits to improvements in A/C efficiency were considered when
establishing the GHG standards. Had the Agency believed that
improvements beyond the menu were possible, the caps may have been
different and the level of the final GHG standard may have been set to
a different stringency level. While we still believe that the
opportunity for improvements has a theoretical limit, we understand
that technologies may exist outside of the A/C credit menu that go
beyond the current cap limits and that provide real-world
CO2 reductions.
Since both the total impact of the A/C system on CO2
used to establish the GHG standards was premised on some nominal car
and truck levels not specific to any vehicle, it is difficult to use
the test results on any individual technology to determine what a new
cap or limit should be, since the A/C system operates with interactions
across all A/C components and parts of the system. This is consistent
with Ford's identification of system interactions with the Denso SAS
and Valeo VBV compressors and the A/C menu technologies. The Agency
believes a reasonable balance may be to continue to use the nominal
values for the total impact of the A/C system (11.9 grams per mile for
cars and 17.2 grams per mile for truck), but then use AC17 test results
to establish a higher cap or limit on the additional technologies
beyond the menu technologies. The results of the AC17 test could be
used to establish a ratio of CO2 emissions or energy used
with the technology improvements to total A/C usage without the
technologies. This ratio could then be used with the previously
established values mentioned above for the average car or truck A/C
usage impacts to establish a new, A/C system-specific, cap that
accounts for the actual A/C-related emissions of the system and all the
A/C efficiency technologies. This is a conceptual framework that
manufacturers might use to support off-cycle petitions for A/C system
credits. The Agency requests comment on this or similar approaches that
make use of the AC17 test procedure to demonstrate A/C-related credits
and determine an expanded cap on credits. EPA continues to evaluate
Ford's rationale and will make a final decision after evaluating any
public comments received on this issue.
B. High-Efficiency Alternators
Using the alternative methodology approach discussed above, Honda
and Nissan are applying for credits for model years 2017 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
[[Page 6947]]
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, Hyundai, Kia, and Toyota Motor
Company. Details of the testing and analysis can be found in the
manufacturer's applications.
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 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: January 27, 2020.
Byron J. Bunker,
Director, Compliance Division, Office of Transportation and Air
Quality, Office of Air and Radiation.
[FR Doc. 2020-02370 Filed 2-5-20; 8:45 am]
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