1

Stout, Alan

From: Giedrius Ambrozaitis <gambrozaitis@autoalliance.org>

Sent: Thursday, November 13, 2014 10:50 AM

To: Laroo, Chris; Stout, Alan

Cc: Don Nagy

Subject: Updated Alliance Tier 3 Tech Amendment comments

Attachments: Alliance 2014-11-11 Tech Amendment Comments.docx

Chris, Alan - 

Attached are updated Alliance comments on the proposed tech amendments. 

Regards, 

Giedrius 

Alliance of Automobile Manufacturers 

(248) 915-8836

Right-click 

here to 

download 

pictures. To 

help protect 

your privacy, 

Outlo ok 

prevented 

auto matic 

download of 

this picture 

from the 

Internet.
Tech Amendment Comments 

1 

General question on DFR changes: There are 3 versions or revisions of the proposed direct final rule, 

dated Jul 7th, Sep 19th, and Oct 17th. These 3 versions are a bit confusing because the documents don’t 

line up section by section, so not sure what is in from a previous version and what is out? Example, the 

July 7th version has many important migration changes to Parts 1065 and 1066 which don’t appear in 

the subsequent versions. 

Comment: Can we get a consolidated version from EPA for review or clarify that older changes are 

retained unless updated in a subsequent version? Prefer a consolidated version. 

Additionally what is the cadence (timing) for getting comments back into EPA? 

Cold E0 and E10 fuels for FE & GHG testing: There does not appear to be an allowance for OEM’s to use 

existing Tier 2 E0 cold fuel (per §86.213 Table 1) with the higher RVP, for Tier 3 vehicles when operated 

over a 20oF cold test. §600.117 requires E0 fuel for FE and GHG thru 2019 as follows: 

§600.117 Interim provisions. 

“The following provisions apply instead of other provisions specified in this part through model 

year 2019:” 

“(a) Except as specified in paragraph (e) of this section, manufacturers must demonstrate 

compliance with greenhouse gas emission standards and determine fuel economy values using 

gasoline test fuel as specified in 40 CFR 86.113-04(a), regardless of any testing with Tier 3 test 

fuel under paragraph (b) of this section.” 

“(d) Manufacturers may perform testing with either gasoline test fuel specified in 40 CFR 

86.113-04 (a) or in 40 CFR 1065.710(b) to evaluate whether their vehicles meet the criteria for 

derived 5-cycle testing under 40 CFR 600.115; however, all five tests must use test fuel meeting 

the same specifications.” 

Comment: §86.113-04(a) specifies E0 low RVP fuel and not the higher RVP fuel required for cold testing 

per §86.213 Table 1. §1065.710’s E10 fuel does have the higher RVP fuel specification, but (again) the 

above (d) states “all five tests must use test fuel meeting the same specification”. This cannot be done 

since the E10 fuel RVP will be different for 20oF testing than 75oF testing? For both E0 and E10 fuels, 

this requirement is non-executable. 

EPA needs to clarify this sentence to allow different specifications for 20oF fuels. 

Additional guidance is provided in §86.1811-17 as follows: 

§86.1811-17 Exhaust emission standards for light-duty vehicles, light-duty trucks and 

medium -duty passenger vehicles. 

“(b) Tier 3 exhaust emission standards. Exhaust emissions may not exceed the Tier 3 exhaust 

emission standards, as follows: 

(11)(vi). For cold temperature testing and for high-altitude testing, you may use the E0 fuel 

specified in §86.113-04(a) or §86.213 instead of the E10 test fuel specified in §86.113-07. 

Comment: 86.113-07 changed to §86.113-15 in the Sep 19th version of the proposed DFR changes. 

Reading the above it appears that the 86.213 reference allows the higher RVP E0 fuel, but if so this 
Tech Amendment Comments 

2 

contradicts §600.117 language and 86.213(a)(2) doesn’t allow the higher E0 RVP fuel for Tier 3 vehicles 

(details follow). 

§86.213 doesn’t appear to allow traditional higher RVP E0 fuel for Tier 3 vehicles as follows: 

§86.213(a)(2): “You may use the test fuel specified in this paragraph (a)(2) for vehicles that are 

not yet subject to exhaust testing with an ethanol-blend test fuel under §86.113.” 

Comment: CFR sections §600.117, §86.1811-17, and §86.213(a)(2) need to be modified to clearly allow 

high RVP E0 and E10 fuel, for cold testing, for Tier 3 vehicles when required to test on E0 fuel for FE and 

GHG, per §600.117. 

Cold temperature testing coast down procedures: In the October 17th version of proposed DFR changes 

many changes or clarifications were made to §1066.305. 

Comment: Preferred approach would be to replace §1066.305(b) with a new provision referencing 

J2264 as follows: 

§1066.305(b): “For cold temperature testing described in subpart H of this part, determine 

road-load target coefficients using SAE J2264 section 6.11.” 

If §1066.305(b) is not replaced, then suggest adding a provision allowed by J2264 as follows: 

§1066.305(b)(3): ”You may set coefficients (Dx) as derived at 68-86°F for testing at 20°F (-7°C), if 

consistent with good engineering judgment.” 

Canister purge air specification added: In the Sep 19th version of the proposed DFR changes, a new 

requirement was added for canister working capacity determination as follows: 

§86.132-96 Vehicle preconditioning. 

(h)(1) adds “(C) Perform the purge steps in this paragraph (h)(1)(iv) using dry nitrogen or air 

controlled to an absolute humidity at or below 25 grains per pound dry air.”

Comment: Recommend this requirement be removed because (1) it is burdensome (facility 

modifications), (2) has not been discussed by industry evaporative experts, and (3) is not the same 

process used for canister loading in certification testing (50 ± 25 grains / pound) or reflect real world 

operation. 

One option could be to instead of specifying a tight purge air requirement, to instead add statement to 

canister working capacity determination section, to use good engineering judgment on the purge air 

specifications. 

No equation in Part 1066 for determining emission rate in grams / mi: In a recent review of Part 1066 

we noticed there is no equation for determining emission rate (grams / mile) except for the FTP cycle. 

This would be a generic equation like that found in §1065.650 as follows except in grams / mile: 

§1065.650 Emission calculations. 

“(b) Brake-specific emissions over a test interval. We specify three alternative ways to calculate 

brake-specific emissions over a test interval, as follows: 
Tech Amendment Comments 

3 

(1) For any testing, you may calculate the total mass of emissions, as described in paragraph (c) 

of this section, and divide it by the total work generated over the test interval, as described in 

paragraph (d) of this section, using the following equation:” 

 

Part 1066 provides verbal guidance but no equation as follows: 

§1066.15 Overview of test procedures.

“This section outlines the procedures to test vehicles that are subject to emission standards. 

(a) The standard-setting part describes the emission standards that apply. Evaporative and 

refueling emissions are generally in the form of grams total hydrocarbon equivalent per test. We 

set exhaust emission standards in g/mile (or g/km), for the following constituents: 

* * * * 

(c) The provisions of this part apply for chassis dynamometer testing where vehicle speed is 

controlled to follow a prescribed duty cycle while simulating vehicle driving through the 

dynamometer's road-load settings. We generally set exhaust emission standards over test 

intervals and/or drive schedules, as follows: 

(1) Vehicle operation. Testing involves measuring emissions and miles travelled while operating 

the vehicle on a chassis dynamometer. Refer to the definitions of “duty cycle” and “test 

interval” in §1066.1001. Note that a single drive schedule may have multiple test intervals and 

require weighting of results from multiple test intervals to calculate a composite distance-based 

emission value to compare to the standard. 

(d) Refer to subpart G of this part and the standard-setting part for calculations to determine 

g/mile emission rates.” 

§1066.601 Overview. 

“(a) This subpart describes calculations used to determine emission rates. See the standardsetting part and the other provisions of this part to determine which equations apply for your 

testing. This subpart describes how to ...” 

Comment: But the above Subpart G references do not provide a calculation for grams / mile, with 

subsequent definition of terms like using measured grams and measured distance. 1066 does mention 

these parameters elsewhere as measurements versus using nominal distance for example. 

This calculation does not appear to be in Part 86, Subpart B either, probably due to it being obvious 

what is meant. This comment is not important for this DFR, but should be considered for a future 

rulemaking. Also some further thought needs to be put into how to introduce this equation w.r.t. test

interval, as some test intervals may have split bags or PM filters (like US06 tests), where gaseous and PM 

emissions may be collected differently. 
Tech Amendment Comments 

4 

Other issues: 

§86.113-04(a) Table 1 - E0 fuel properties, footnote 5; Noticed RVP psi to kpa has inconsistent unit 

conversions, for altitude min = 52 and max = 55.4 kpa. For non-evaporative testing min = 54.8 and max

= 63.7 kpa. 

Comment: Using RVP in psi as the baseline, calculated altitude RVP’s would be 52.4 and 55.2 kpa 

(respectively) and non-evaporative would be min = 55.2 and max = 63.4 kpa. 

§1065.710(c) Table 2 – E0 fuel properties; Noticed RVP psi to kPa has inconsistent unit conversion, for 

altitude min = 52 kpa. 

Comment: Using RVP in psi as the baseline, calculated altitude minimum RVP would be 52.4 kpa.

§1065.710(c) Table 2 – E0 fuel properties; Noticed for all RVP’s have no psi reference, just kpa.

Comment: For consistency to §86.113, §86.213 and §1066.710(b) Table 1 – E10 fuels, suggest adding psi 

references in addition to kpa.

§1065.710(c) Table 2 – fuels volume %; In the September 19th version of the proposed DFR changes, the 

units for hydrocarbon composition are listed as “m3 / m3”, replacing “volume %” 

Comment: We believe volume % should be retained as more descriptive and consistent with 1065.710 

table 1. 

Hybrid Test Procedures: There is an issue of properly applying SAE J1711 sections 3.9.1 and Appendix C 

provisions in CFR §600.116–12 and §1066.501. Suggest modifying these sections as follows: 

§ 600.116–12 Special procedures related to electric vehicles and hybrid electric vehicles. 

(b)(5)The End-of-Test criterion is based on a 1 percent Net Energy Change as specified in Section 3.8 of 

SAE J1711. We may approve alternate Net Energy Change tolerances as specified in Section 3.9.1 or 

Appendix C of SAE J1711 if the 1 percent threshold is insufficient or inappropriate for marking the end of 

charge-depleting operation. For charge-sustaining tests, we may approve the use of alternate Net 

Energy Change tolerances as specified in Appendix C of SAE J1711 to correct final fuel economy values,

CO2 emissions, and carbon-related exhaust emissions. For charge-sustaining tests, do not use alternate

Net Energy Change tolerances to correct emissions of criteria pollutants. Additionally, if we approve an 

alternate End-of-Test criterion or Net Energy Change tolerances for a specific vehicle, we may use the

alternate criterion or tolerances for any testing we conduct on that vehicle. 

Subpart F—Electric Vehicles and Hybrid Electric Vehicles 

§ 1066.501 

Overview. 

(a) Correct Apply the results for Net Energy Change of the RESS as follows: 

(ii) We may approve the use of the alternate End-of-Test criterion in Section 3.9.1 of SAE J1711 

and the Net Energy Change correction in Appendix C of SAE J1711 if the specified criterion and 

correction are insufficient or inappropriate for establishing the transition between chargedepleting and charge-sustaining operation. 
Tech Amendment Comments 

5 

(iii) For charge sustaining tests, Appendix C of SAE J1711 may be used to correct final fuel 

economy values, CO2 emissions, and carbon-related exhaust emissions, but may not be used to 

correct measured values for criteria pollutant emissions.