Alternative Methods for Calculating Off-Cycle Credits Under the Light-Duty Vehicle Greenhouse Gas Emissions Program: Applications From Toyota Motor North America |
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Topics: Toyota
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Byron J. Bunker
Environmental Protection Agency
1 April 2020
[Federal Register Volume 85, Number 63 (Wednesday, April 1, 2020)]
[Notices]
[Pages 18227-18228]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2020-06709]
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ENVIRONMENTAL PROTECTION AGENCY
[EPA-HQ- OAR-2019-0333; FRL-10007-19-OAR]
Alternative Methods for Calculating Off-Cycle Credits Under the
Light-Duty Vehicle Greenhouse Gas Emissions Program: Applications From
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 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. Toyota has 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 May 1, 2020.
ADDRESSES: Submit your comments, identified by Docket ID No. EPA-HQ-
OAR-2019-0333, 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 Once submitted, comments cannot be edited or withdrawn.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 https://www2.epa.gov/dockets/commenting-epa-dockets.
FOR FURTHER INFORMATION CONTACT: Linc Wehrly, Director, Light Duty
Vehicle Center, Compliance Division, Office of Transportation and Air
Quality, U.S. Environmental Protection Agency, 2000 Traverwood Drive,
Ann Arbor, MI 48105. Telephone: (734) 214-4286. Fax: (734) 214-4053.
Email address: wehrly.linc@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:
A manufacturer requesting off-cycle credits must develop a
methodology for demonstrating and determining the benefit of the off-
cycle technology and
[[Page 18228]]
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. Denso Electric Scroll Air Conditioning Compressor
Toyota is applying for off-cycle GHG credits for the use of the
Denso Electric Scroll Air Conditioning Compressor Variation B (ESB)
with pressure adjusting valve technology. This technology improves the
efficiency of the electric scroll compressor using a pressure adjusting
valve to optimize back pressure on the fixed scroll and reduce
mechanical losses. This is similar to the off cycle alternative method
technology for the belt driven Denso SES/SAS compressor, for which
credits were granted to Toyota in June 2018.\5\ The requested credit
amount was confirmed by Toyota through bench testing, following the
method in the Society of Automotive Engineers (SAE) procedure J2765, to
confirm air conditioning system power reduction of the technology
resulting from the reduced mechanical losses in the compressor. The SAE
J2766 standard (using the GREEN MAC Life Cycle Climate Performance
Model) was used to calculate the normalized grams CO2 per
mile improvement of the technology for the U.S. market. The
CO2 grams per mile improvement was derived from the bench
test results.
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\5\ ``EPA Decision Document: Off-cycle Credits for General
Motors and Toyota Motor Corporation.'' Compliance Division, Office
of Transportation and Air Quality, U.S. Environmental Protection
Agency. EPA-420-R-18-014, June 2018.
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Toyota is applying for a credit of 1.9 grams/mile for 2016 and
later model years for vehicles sold in the U.S. and equipped with the
Denso ESB air conditioning compressor. EPA considers this compressor
technology to be a technology that, if approved, will be subject to the
maximum limits for an A/C system of 5.0 g/mi for passenger automobiles
and 7.2 g/mi for light trucks specified in the regulations.\6\ Details
of the testing and analysis can be found in the manufacturer's
applications.
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\6\ See 40 CFR 86.1868-12 (b).
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B. Dual Layer HVAC Technology
Toyota is applying for off-cycle GHG credits for the use of a dual
layer (or 2-layer) HVAC technology. Ventilation and heat transfer
losses between the cabin and outside ambient are the key HVAC thermal
losses during warmup. Ventilation losses can be reduced by
recirculating the cabin air, but this has the adverse effect of
building up cabin humidity, which can then become a safety hazard due
to increased windshield fogging. Dual layer HVAC uses two separate
``layers'' of airflow within the vehicle and a two[hyphen]stage fan
that can recirculate air through the lower outlets while flowing fresh,
low humidity air through the upper ducts (includes the windshield
defroster). The module has a door that selects full fresh, full
recirculate, or dual layer mode based on logic parameters. Low humidity
air is needed to better defog the windshield and recirculated air
improves warm up performance. With the use of recirculated air less
engine heat is needed to warm the cabin, and both the cabin and the
engine warm up faster. Faster engine warmup improves vehicle
efficiency.
Toyota is applying for a credit of 0.6 grams/mile for 2016 and
later model years for vehicles sold in the U.S. and equipped with the
dual layer HVAC technology. 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 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 document, 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 25, 2020.
Byron J. Bunker,
Director, Compliance Division, Office of Transportation and Air
Quality, Office of Air and Radiation.
[FR Doc. 2020-06709 Filed 3-31-20; 8:45 am]
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