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October24, 2013 SUBJECf: EPA and GM Meeting on Tier 3 NPRM FROM: Glenn W. Passavant, Office of Transportation and Air Quality TO: Public Docket EPA-HQ -OA R-20 11-0135 I Staff from EPA and GM met on October 23, 2013 at the EPA o ffice bui lding in Ann Arbor Michigan. EPA was represented by Bill Charmley, Mike Olechiw, Tony Fernandez, and Glenn Passavant. GM was represented by Bob Babik, Jim Ehlmann , and Andy Barren. T he purpose of the meeting was to di scuss EPA's T ier 3 NPRM and for GM to seek feedback and clarification from EPA staff on a number of issue s. The discu ssions at the meeting focu sed on the material provided by GM. Thes e materials are attached.Issue EPA Position {GM 's Last GM's Position Understanding) 

### 1. Certification Fuel 

### • EPA Staff supports ElO @ 9 psi 

### • Support ElO @ 9 psi 

## • Considering ElS trigger 

### • If ElS trigger it should be language 51% market penetration 2. Reciprocity 

### • Accept CARB cert/fuel thru 

### • Want to both certify and 2019 {exhaust) and thru 2021 develop to one fuel (evap) 

### • EPA should either fully 

### • Assuming EPA fuel is ElO, harmonize fuels or commit starting 2020 {exhaust) and to test on CARB fuel ' 2022(evap)acceptCARB certjfication/fue l but reserve right to test on EPA fuel 3. FTP Fleet Average and Early 

### • As proposed in NPRM except 

### • GM supports generally but Credit Provisions allow proportional ratio based believes all CA+177 vehicles on US Volume/CA+177 should be included in 2015 Volume {don't limit to< 6000 lbs) 4. Availability of Bins 3 and 4 

### • As proposed in NPRM 

### • GM Supports available thru 2019 on NMOG+NOx basis 5. Acceptance of Early LEV Ill 

### • As proposed in NPRM except 

### • GM supports but asks EPA Certifications Nationwide FE/GHG testing on EO to see ifthere's any way to make available before FR signed given the delayIssue EPA Position (GM's Last GM's Position Understanding) 6. 4WD Dyno 

### • EPA proposal recently 

### • GM supports communicated to industry 7. R
- Factor 

### • Temporary program per 

### • Complete R-Factor Sept 25 EPA meeting with rulemaking ASAP industry 

### • Make E10 R-Factor available 

### • E10 R-Factor may not be as soon as rulemaking is available until 2020 MY complete (depends on data) 8

. Evap Phase-in 

### • Will include option for 20% 

### • GM supports both in which in 2017 MY case alternative phase
-in 

### • Will allow 2017 to be will be 1160 points included in alternative phase-in calculation 9. US06 PM 

### • Proposed 10/20 and asked 

### • Premature to go lower than for comment on 10/10 10 mg/mi 

### • Want to maintain common 

### • CARB commented 4 mg/mi standard between EPA and 

### • EPA considering 6 mg/mi CARB with 12 mg/mi in
-use during phase-in

### Issue EPA Position {GM's Last GM's Position Understanding) 10. PM Measurement in 

### • Procedures outlined in 

### • Request no significant support of 3 mg/mi FTP latest 1066 draft recently changes standard shared with industry 

### • GM is buying lab equipment based on these



## . procedures 11. Preconditioning for In-Use 

### • EPA wifl allow 

### • Fuel sample doesn't Testing manufacturers to take fuel address su lfur poisoning i 

### samples, but no from prior tanks offuel and preconditioning on initial isn't very practical test 

### • Should allow preconditioning 12

. In-Use Compliance Criteria 

### • Do not plan to address in 

### • IUCP compliance should be Tier 3 based on average emissions 

### • Perhaps could address in like CARB does (technically future rulemaking (e.g., 

## I statistically sound) revisit of CAP2000 regulations) 13. Evap Ethanol Adjustment 

### • NPRM proposed 10% factor 

### • GM supports use of actual Factor as mandatory with factor as an option 

### • Considering both factor 

### • GM data suggests factor for level and whether it should diurnal of about 3% be mandatoryIssue EPA Position (GM 's Last GM 's Position Understanding) 14. Cert Fuel for FFV Evap 

### • For diurnal EPA will allow 

### • ORVR requirement is more Testing 9 psi E10 (i.e

., same as burdensome than for nonnon- FFVs) FFVs 

### • For ORVR EPA will require 

### • Requires manufacturer to Tier 2 indolene splash stock unique fuel just for this blended with ethanol to purpose get E10 ("' 10 psi) 15

. SFTP Standards for FFVs 

### • New requirement that 

### • Unnecessary added burden FFVs must test/comply on for FFVs E85 

### • E10 compliance is sufficient 16

. Eva p Durability Mileage 

### • 

## ??? • Allow use ofTier 3 cert fuel Accumulation Fuel (E10) for mileage accumulation for evap durability 

### • Avoids burden of carrying a unique fuel for this purpose 17

. Canister Bleed Test 

### • Applicable at full useful 

### • Adopt as 4K standard only, life consistent with LEV Ill 18

. I nterim I n-Use Standa rds 

### • No i nterim i n-use 

### • Adopt same interim i n-use standards available for MD standards as in LEV Ill FTP or LD/MD SFTP 

### • Standards very challenging esp
. new GHG t echnologiesIssue EPA Position (GM's Last GM's Position Understanding) 19. PHEV test procedures 

### • Harmonizing with CARB 

### • Support Alliance proposals 

### • Considering Alliance 

### • Charge sustaining based proposals tailpipe testing (not charge 

### • Who is replacing Chris depletion) Nevers who led this 

### • Need common procedures assignment for EPA? between CARB and EPA