Evap testing at high altitude Alan Stout Alan Stout to: Frank Krich, james .ehlmann, Rudy, Sara (S.J.),

susan.collet, Robert_Bienenfeld, klaus.land, Johnson, Stuart 05/09/2011 02:15 PM Bcc: Alan Stout Dear colleagues, We have been made aware that a recent change in the EPA regulations in §86.1810-09 inadvertently changed the way we describe manufactu rers’ responsibilities to comply with evaporative emission standards at high-altitude con ditions. Our understanding is that the intent initially was to adopt California’s LEV II evaporat ive emission standards in the CFR, but only at low-altitude conditions, keeping the less stringentTier 2 standards in place at high-altitude conditions. In the final rule adopting light-duty greenhouse ga s standards, we addressed the altitude-related requirements in §86.1810-09 by restructuring paragr aphs and rewording requirements in a way that eliminated evaporative emission standards at h igh-altitude conditions. This was not intended and, in fact, is contrary to other regulatory provi sions (such as those in §86.1829-01). We plan to make this correction in the upcoming fin al rule related to fuel economy labels. The draft regulatory text to accomplish this is copied below. Given that the proposal for the labeling rule has already been published, we are eager to in form potentially affected parties that there is a need for this correction. Feel free to let us know if this approach raises any concerns. On a separate and less time-sensitive note, we are pursuing a range of issues related to the upcoming Tier 3 rule. This correction gives us the opportunity to invite your input also on the proper approach to applying evaporative emissions a t high-altitude conditions. We would have an interest in aligning with California’s emission standards, but they again do not have plans to extend their standards to high-altitude conditions. It may be appropriate for us to adopt Tier 3 standards that apply equally at low- and high-altitude conditions, especially with the expected time frame for the Tier 3 standards. On the other hand, we would be open to considering the viability and effectiveness of allowing manufacture rs to comply through an engineering analysis demonstrating that evaporative emission controls ar e no less effective at higher altitude. Alan

_______________ 1. Section 86.1810-09 is amended by revising paragraph (f)(1) to read as follows: § 86.1810-09 General standards; increase in emiss ions; unsafe condition; waivers . * * * * * (f) * * *(1) All emission standards apply at low altitude co nditions and at high altitude conditions, with

the following exceptions: (i) The supplemental exhaust emission standards as described in § 86.1811

– 04(f) apply only at low altitude conditions; (ii) The cold temperature NMHC emission standards a s described in § 86.1811

– 10(g) apply only at low altitude conditions; (iii) The evaporative emission standards specified in § 86.1811-09(e) apply at low altitude conditions. The evaporative emission standards spe cified in § 86.1811-04(e) continue to apply at high altitude conditions for 2009 and late r model year vehicles. * * * * *

2. Section 86.1811-09 is amended by revising paragr aph (e) introductory text to read as follows: § 86.1811-09 Emission standards for light-duty ve hicles, light-duty trucks and medium-duty passenger vehicles.

* * * * * (e) Evaporative emission standards . Evaporative emissions from gasoline-fueled, natur al gas-fueled, liquefied petroleum gas-fueled, ethanol -fueled and methanol-fueled vehicles must not exceed the standards in this paragraph (e) at low altitude conditions. The evaporative emissi on standards specified in § 86.1811-04(e)(1) continue to apply at high altitude conditions. The standards apply equally to certification and in-use vehicles.
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