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 propo sed tech amendments. Regards, Giedrius Alliance of Automobile Manufacturers

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## 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 ver sions 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 chang es to Parts 1065 and 1066 which don’t appear in the subsequent versions.

Comment: Can we get a consolidated version from EPA for rev iew or clarify that older changes are retained unless updated in a subsequent version? P refer a consolidated version. Additionally what is the cadence (timing) for getti ng 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 f or FE and GHG thru 2019 as follows: §600.117 Interim provisions. “The following provisions apply instead of other pr ovisions specified in this part through model year 2019:” “(a) Except as specified in paragraph (e) of this s ection, manufacturers must demonstrate compliance with greenhouse gas emission standards a nd 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; howev er, all five tests must use test fuel meeting the same specifications.”

Comment: §86.113-04(a) specifies E0 low RVP fuel and not th e higher RVP fuel required for cold testing per §86.213 Table 1. §1065.710’s E10 fuel does hav e 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 t esting than 75oF testing? For both E0 and E10 fuel s, this requirement is non-executable. EPA needs to clarify this sentence to allow differe nt specifications for 20oF fuels. Additional guidance is provided in §86.1811-17 as f ollows: §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 emi ssions 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 ve rsion 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) does n’t allow the higher E0 RVP fuel for Tier 3 vehicle s (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 parag raph (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 Tie r 3 vehicles when required to test on E0 fuel for F E and GHG, per §600.117. Cold temperature testing coast down procedures: In the October 17 th version of proposed DFR changes many changes or clarifications were made to §1066.3 05.

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 secti on 6.11.” If §1066.305(b) is not replaced, then suggest addin g a provision allowed by J2264 as follows: §1066.305(b)(3) : ”You may set coefficients (Dx) as derived at 68-8 6°F for testing at 20°F (-7°C), if consistent with good engineering judgment.” Canister purge air specification added: In the Sep 19 th 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 pa ragraph (h)(1)(iv) using dry nitrogen or air controlled to an absolute humidity at or below 25 g rains per pound dry air.”

Comment: Recommend this requirement be removed because (1) it is burdensome (facility modifications), (2) has not been discussed by indu stry evaporative experts, and (3) is not the same process used for canister loading in certification testing (50 ± 25 grains / pound) or reflect real wo rld operation. One option could be to instead of specifying a tigh t purge air requirement, to instead add statement t o canister working capacity determination section, to use good engineering judgment on the purge air specifications. No equation in Part 1066 for determining emission r ate in grams / mi: In a recent review of Part 1066 we noticed there is no equation for determining emi ssion 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 f ollows:

## Tech Amendment Comments

3 (1) For any testing, you may calculate the total ma ss of emissions, as described in paragraph (c) of this section, and divide it by the total work ge nerated 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 vehic les that are subject to emission standards. (a) The standard-setting part describes the emissio n standards that apply. Evaporative and refueling emissions are generally in the form of gr ams 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 d ynamometer 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 e missions 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 s chedule may have multiple test intervals and require weighting of results from multiple test int ervals 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 determi ne 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 u sing 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 f or 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 bag s or PM filters (like US06 tests), where gaseous an d PM emissions may be collected differently.

## Tech Amendment Comments

4 Other issues: §86.113-04(a) Table 1 - E0 fuel properties, footnot e 5; Noticed RVP psi to kpa has inconsistent unit conversions, for altitude min = 52 and max = 55.4 k pa. For non-evaporative testing min = 54.8 and max = 63.7 kpa.

Comment: Using RVP in psi as the baseline, calculated altit ude RVP’s would be 52.4 and 55.2 kpa (respectively) and non-evaporative would be min = 5 5.2 and max = 63.4 kpa. §1065.710(c) Table 2 – E0 fuel properties; Noticed RVP psi to kPa has inconsistent unit conver sion, for altitude min = 52 kpa.

Comment: Using RVP in psi as the baseline, calculated altitu de 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 19 th version of the proposed DFR changes, the units for hydrocarbon composition are listed as “m 3 / m 3 ”, replacing “volume %”

Comment: We believe volume % should be retained as more des criptive and consistent with 1065.710 table 1. Hybrid Test Procedures: There is an issue of properly applying SAE J1711 se ctions 3.9.1 and Appendix C provisions in CFR §600.116–12 and §1066.501. Sugge st 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 per cent Net Energy Change as specified in Section 3.8 of SAE J1711. We may approve alternate Net Energy Chan ge 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 u se 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 o f criteria pollutants. Additionally, if we approve an alternate End-of-Test criterion or Net Energy Chang e tolerances for a specific vehicle, we may use the alternate criterion or tolerances for any testing w e conduct on that vehicle. Subpart F—Electric Vehicles and Hybrid Electric Veh icles § 1066.501 Overview. (a) Correct Apply the results for Net Energy Change of the RESS as f ollows: (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

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## Tech Amendment Comments

5 (iii) For charge sustaining tests, Appendix C of SAE J1711 may be used to correct fin al fuel economy values, CO2 emissions, and carbon-related e xhaust emissions, but may not be used to correct measured values for criteria pollutant emis sions.