MFMORANDUM 

l.NTB)STAlES ENVRON\IENTAL PROT£CT100 AGENCY 

N6.~ VEHICLE /lKJ FLB.. EMISSIONS LJ!aRC\lt:RY 

2!l35 PLYMOUTH ROAD 

~ ~ ~ 481(&2496 

October 24, 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 

discuss EPA's T ier 3 NPRM and for GM to seek feedback and clarification 

from EPA staff on a number of issues. The discussions at the meeting 

focu sed on the material provided by GM. These 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/fuel 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 N PRM • 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 if there's any way to 

make available before FR 

signed given the delay 
Issue EPA Position (GM's Last G M'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 sulfur poisoning i 

samples, but no from prior tanks of fuel 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 mandatory 
Issue 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 of Tier 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. Interim In-Use Standards • No interim in-use • Adopt same interim in-use 

standards available for MD standards as in LEV Ill 

FTP or LD/MD SFTP • Standards very challenging 

esp. new GHG t echnologies 
Issue EPA Position (GM's Last G M'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