UNITI:D STATES ENVIRONMENTAL PROTECTION AGENCY 

NATIONAL VEHI CLE AND FUEL EM I SSIONS LABORATORY 

2565 PLYMOUTH ROAD 

ANN ARBOR, MICHIGAN 48105-2498 

MEMORANDUM Sq:t. 12,2013 

SUBJECT: EPA & Ford Meeting on Issues Related to T ier 3 NPRM 

OFFICE OF 

AIR AND RADIATION 

FROM: Glenn W. Passavant, Office of Transportation and Air Quality ~ 

TO: Public Docket EPA-HQ-OAR-20 11-0135 

A. Introduction 

On August 26, 2013 EPA staff and representatives of Ford Motor Company met to discuss 

issues and questions related to the provisions ofthe Tier 3 NPRM. A copy of the 

agenda and attendees is attached . . 

B. Discussion: 

After personal introductions and some brief introductory remarks, discussions followed the 

agenda. The discussions were brief and basically followed Ford comments on the Tier 3 

NPRM where applicable. There were three areas where more detailed discussions 

occurred. 

R-factor: EPA summarized the current staff thinking on provisions for the final rule 

related to reducing the potential for a dual testing burden for early Tier 3/LEV III 

certifications for EDVs and FEDVs (A copy of the power point slide used is attached). 

Ford was generally supportive of these concepts and asked that EPA consider how a 

CA/177 states only vehicle would be affected and that EPA consider an IUVP option for 

EO only testing. Ford indicated that a 2020 MY for any new R-factor, GHG, and labeling 

provisions related to the new certification fuel provisions would be acceptable, but they 

need to see action on the final provisions by mid 2016. 

Evaporative emissions phase-in: Ford asked that EPA strongly consider including the 20% 

Tier 3 evap/20% leak standard compliance option for the 2017 model year in the final rule 

as there are lead time and capital cost implications for meeting the other options. Ford also 

asked that EPA link the use of the new Tier 3 certification fuel for evaporative/refueling 

emissions to compliance with Tier 3 evaporative emission standards rather than a 2020 

model year cut-off as proposed. Ford was also supportive of long-term reciprocity 

between ARB and EPA for evaporative emission testing. 

US06 PM standards: Based on new information from California which is available to 

Ford, EPA staff set forth the idea that the US06 PM standard should be 6 mg/mi with a 12 

mg /mi in-use standard in place during the phase-in (through the 2021 MY production). 

Ford expressed concern about variability and other unknowns with regard to US 06 PM 

testing and asked EPA to consider a less stringent standard and to retain the interim in-use 

standard concept. While Ford has provided data in the past, EPA asked them for any 

additional data they have on US06 PM. 
HDGE Certification Gasoline: Ford agreed that HDGEs using the engine dynamometer for 

emissions certification would have to be certified for emissions on Tier 3 certification fuel 

by the 2022 model year, but asked that EPA include an allowance for Tier 2 certification 

fuel carryover past 2022 for unique applications such as military vehicles (e.g., up to I% of 

total HDGE sales). 

ORVR for HDGVs: EPA confirmed that the NPRM did not cover ORVR for incomplete 

HDGVs, but Ford agreed that the requirements could cover all complete HDGVs 

independent ofGVWR beginning in the 2018 MY. 

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Passavant, Glenn 

From: 

Sent: 

Glodich, Jeffrey (J.M.) Oglodich@ford.com] 

Friday, June 14, 2013 2:34 PM 

To: 

Subject: 

Passavant, Glenn; Olechiw, Michael 

EPNFord Tier 3 Meeting 

Mike, Glenn, 

Agenda for Tuesday's meeting below. Thanks, 

Jeff 

Agenda for 6-18-13 

Elx FE 

Elx equation timing 

Phase-in/carry-over for FE (clarification) 

4WD Dynamometers 

4WD confirmations (timing, scope, purpose) 

Equivalency requirement (Part 1066, 22MY) 

Particulate Matter 

US06 20 mg/mi std for vehicles >6k 

HDV interim in-use 

HDVs 

Altitude I interim in-use 

SFTP 

E85 testing requirement (vs. attestation) 

Enrichment limits (clarification) 

Certification Fuel 

Priority: 9RVP 

Optional Alternative Cert Fuels 

Market Fuel 

Sulfur 

Sulfur Purge Cycle 

PM impact: sulfur, T90, aromatics ("PM Index") 

1 psi Waiver 

1 
Interim Approach Testing Burden 

• The interim approach reduces the testing burden by (1 )limiting the requirements for all F8Ns to 

test for criteria pollutants on E1X(only test if fail on ED}, (2) allowing litmus to be based on E1X 

results, and, (3) limiting IUVPto E1Xfor criteria pollutants and GiG 

• Unlike original staff ooncept, require: (1) 8JvS to be tested and pass criteria pollutants 

standards on ED (2-cyde), (2) require F8Ns to pass criteria pollutant standards on ED or test on 

E1Xif they fail. (3)s=A is pres:ribing whidl fuel is used in each test and when there are flexibilities 

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08/26/2013 

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LEV Ill/ T3 On E1 X 

for Qiteria 

Pollutants 

BJV 

X 

X 

X 

X 

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GHG' label/ 002/ FE Utmus(allow E1X 

on Tier 2 ~rt Fuel or 8) using 

FBJV (Bl) R=0.6 

5 cyde 2cyde 

X X X 

X X X 

X X 

X I I X 

O>ld CD fuel ------- - - 7 

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