## Summary	of	Interagency	Working	Comments	on	Draft	Language	un der

E . O .	13563	and 12866	Interagency	Review.		Subject	to	Further	Policy	Review. **Comments on U.S. Environmental Protection Agency Proposed Rule,**  **“ Control of Air Pollution from Motor Vehicles:**  **Tier 3 Motor Vehicle Emission and Fuel Standards ,** **” RIN**  **2060 -** **AQ86** 1) Gauging fuel consumption impacts - Suggest EPA assess the overall change to fuel economy within vehicle category . D id the State of California conduct a similar analysis in support of its LEV III rulemaking? I f so, suggest incorporating by reference, since this p roposal discusses essentially the same vehicle/technology/stringency combinations. a. How much will the high oxygen content of the new fuel affect fuel consumption? The new certification fuel means a priori lower fuel economy than that of the higher energy- d ensity current certification fuel . b. What additional exhaust control equipment weight will be added to achieve the new emissions limits and what will be the fuel economy penalty be compared to the baseline? 2) Refinery compliance costs and sulfur disposal a. What assumptions has EPA made concerning the by- product use of the sulfur removed from the refinery process? E lemental sulfur market remains relatively soft, so refiners may be tempted to back the sulfur down to heavier refined grades (a common practice over time) rather than extract it. b. Is the only feasib le receptacle for this heating oil ? As the recent stringent limits on hoteling emissions in U.S. ports and sulfur control for nonroad diesel have essentially eliminated bunker fuel, the old standby of bygone days, and “red” diesel as candidates. How did EPA consider the opportunity costs of not being able to use the higher sulfur fuel in these previously available markets? P lease describe the assumptions used, relative differences in value of products, and markets where EPA expects these products to now be used. c. With respect to increased stringency of gasoline sulfur limits, refiners were already producing or preparing to produce ultra - low sulfur gasoline for the California market; however, this sulfur reduction will not be without added cost in order to comply nationwide. 3) In what respects is the Tier 3 rule not align ed with the CARB LEV III rule? a. Will auto manufacturers be required to perform additional test procedures for the Tier 3 rule, that are not required under LEV III? If so, what are the costs to auto manufacturers of purchasing the equipment and/or running the tests that are required under Tier 3 but not required under LEV III? 4) How does EPA account for the increased costs to manufa cturers and consumers for repairing emissions control systems? As manufacturers are forced to add more intricate technologies to achieve more stringent emissions standards, the likelihood and frequency of problems that would require repair would presumably increase as well. Where does EPA address this issue in the rule?

## Summary	of	Interagency	Working	Comments	on	Draft	Language	un der

E . O .	13563	and 12866	Interagency	Review.		Subject	to	Further	Policy	Review. 5) Certification fuel revisions – Will EPA explain the rationale for the proposed change to the specifications of vehicle emission/fuel economy certification fuel ? The table below highlights key changes to the certification fuel specs: **Proposed Gasoline Emissions Test Fuel** Property Unit SPECIFICATION ASTM Reference Procedure General Testing LowTemperature Testing High Altitude

Testing Antiknock Index (R+M)/2 - 87.0 - 88.4 87.0 Minimum D2699 - 11 and D2700- 11 Sensitivity (R - M) - 7.5 Minimum Dry Vapor Pressure Equivalent ( DVPE) kPa (psi) 60.0 - 63.4 (8.7 -9.2) 77.2 -81.4

(11.2 - 11.8) 52.4-55.2

(7.6 -8.0) D5191 - 10b Distillation 10% evaporated °C (°F) 49 - 60 (120- 140) 43 -54

(110- 130) 49 - 60

(120- 140) D86 - 10a 50% evaporated °C (°F) 77 -88 (170- 190) 90% evaporated °C (°F) 154- 166 (310-330) Evaporated final boiling point °C (°F) 193 - 216 (380-420) Residue Milliliter 2.0 Maximum Total Aromatic Hydrocarbons vol. % 19.5 - 24.5

D5769 - 10 C6 Aromatics (benzene) vol. % 0.6 -0.8 C7 Aromatics (toluene) vol. % 4.4- 5.5 C8 Aromatics vol. % 5.5 - 6.9 C9 Aromatics vol. % 5.0 - 6.2 C10+ Aromatics vol. % 4.0 - 5.0 Olefins mass % 4.5 - 11.5 D6550- 10 Ethanol vol. % 14.6 - 15.0 D5599 -00 (Reapproved 2010) Total Content of Oxygenates Other than Ethanol vol. % 0.1 Maximum

## Summary	of	Interagency	Working	Comments	on	Draft	Language	un der

E . O .	13563	and 12866	Interagency	Review.		Subject	to	Further	Policy	Review. Sulfur mg/kg 8.0 - 11.0 D2622 - 10, D5453 -09 or D7039 -07 Lead g/liter 0.0026 Maximum D3237 -06 Phosphorus g/liter 0.0013 Maximum D3231 - 11 Copper Corrosion - No. 1 Maximum D130 - 10 Solvent-Washed Gum Content mg/100 ml 3.0 Maximum D381 -09 Oxidation Stability Minute 1,000 Minimum D525 -05 6) Etha nol by % volume - Will EPA explain the rationale for jumping from the expected choice of a 10%- by-volume ethanol fuel, now common throughout the U.S., to E15 ? K nowing that E15 has been shown to be less likely to volatilize its gasoline blendstock than E10, how does EPA anticipate this impacting ozone or other emissions? Has EPA conducted a sensitivity analysis to see what the implications on vehicle emissions and air quality impacts are for using E10 versus E15? W hat does EPA project concerning the penetration of E15 in gasoline blendstock? Is there a particular date by which EPA expects E15 to be commonly used like E10 is today? Please explain. 7) Will EPA also explain why a romatics and olefin percentages are adjusted ? I s it in anticipation of hi gher oxygenate content and/or octane rating ? Please explain. 8) Will EPA explain under what circumstances vehicle manufacturers may request approval for an alternative certification fuel such as a high - octane 30 percent ethanol by volume (E30) blend for vehicles ?