UNITED ST ATES ENVIRONMENTAL PROTECTION AGENCY NATIONAL VEH I CL E AND FUEL E M I SSIONS LABORATORY 2565 PLYMO UTH ROAD ANN ARBOR, MICHIGAN 48105-2498

OFFICE OF AIRAND RADIATION MEMORANDUM 

### Sq:t. 11 , 2013 SUBJECT: EPA and Chrysler Meeting on Issues Related to Tier 3 NPRM FROM: Glenn W. Passavant, Office of Transportation and Air Quality 

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TO: Public Docket EPA-HQ-OAR-2011-0135
A. Introduction At their request, EPA staff met with representatives of the Chrys ler Corporation to discuss the issues and questions related to the provis i ons of the Tier 3 NPRM. The meeting was held on August 20, 20 13 at the EPA office building in Ann Arbor Michigan. A copy of the agenda and attendees is attached. Also attached is follow-up material provided by Chrysler. The meeting followed the agenda provided by Chrysler and Chrys ler's comments on the NPRM were heavily referenced in the discussions. This was not a decision meeting on any elements ofthe Tier 3 NPRM , but one designed primarily for Chrysler to raise questions and concerns about provisions ofthe NPRM or to seek clarifications as needed. EPA also sought feedback on several ideas. The content of most discussions was self evident based on the Chrysler agenda and comments. A few more points of detail are provided below. B. Summary of more detailed discussions: Lead time/Program Starting Point: Chrysler was concerned that the final rule use appropriate starting model years for vehicles above and below 6,000 lbs GVWR, consistent with the CAA. Chrysler asked EPA to consider another alternative idea for NMOG 

### + NOx phase-in and provided the additional written input which is attached. 1201150K miles durability: Chrysler supports providing the manufacturers the option to certify LDVs and light trucks of less than 3.759 pounds LVW to a 120 ,000 mile useful life, consistent wi th the position put forth in the Alliance of Automobi le Manufacturers comments on the NPRM. Specifically they want the option for vehicle family-by-vehicle fami ly useful life values
. R-factor: Chrysler was generally supportive ofthe EPA staffconcept for an interim approach for EDV and FEY testing and the R-factor value for LEV III/T3 vehic les certified on an E10 fuel. (See EPA docket memo regarding meeting with Alliance and Global Automakers dated September 11 , 20 13). They want certainty, that whatever approach is ultimately adopted by EPA would be in place through the 20 19 MY. Interim in -use standards: Chrysler is supportive of interim in -use standards for mediumduty including their heavy-duty pick-up trucks. Chrysler provided additional written inputwhich is attached. US06 PM standards: Based on new information from California which is available to Chrysler, EPA staff set forth the idea that the US06 PM standard should be 6mg/mi with a 12 mg /mi in

-use standard in place during the phase -in (through the 2021 MY production). Chrysler asked EPA to consider a standard of about 8 mg/mi. EPA asked Chrysler for any data
.they have on US06 PM. Chrysler provided additional written input which is attached. Low Sulfur Gasoline: Chrysler strongly supported the need for 10 ppm sulfur gasoline and provided summary points ofadditional written input which is attached. Certification Gasoline: Chrysler supports 9 RVP El 0. ORVR for HDGVs: EPA confirmed that the NPRM did not cover ORVR for incomplete HDGVs, but Chrysler agreed that the requirements could cover all complete HDGVs independent ofGVWR beginning in the 2018 MY. Chrysler agreed to provide EPA inf ormation on sales of incomplete HDGys above 8,500 lbs GWWR. INNOV A and Impingers in Place of FID Ethanol Adjustment Factor : Chrysler indicated that they had no reliable data for EPA to consider in assessing its decision on the role of INNOVA instruments in place of either an impinger /GC method based approach or a fixed adjustment factor for the FID response be used for future evaporative-type emission testing (hot soak + diurnal , running l oss, refueling, etc) on an ethanol based fuel.

2Chrysler Follow-up from Chrysler/EPA Tier 3 Meeting on August 20, 2013 NMOG+NOx Phase-in • Proposed alternative NMOG+NOx fleet average for vehicles 6,001-8 ,500 pounds GWJR to meet the Clean Air Act (CAA) required 4 year leadtime and 3 year stability requirements.

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2020 MY 2021 MY 2022 MY 2023 MY 2024 MY 2025 MY

• Step-down fleet average begins in the 2020 MY and completes in the 2025 MY

. 

### o 0.074 g/mi fleet average standard

. for the 2020 through 2022 MYs

. o 0.030 g/m i fleet average standard for the 2023 through 2025 MYs. • Phase-in meets the intent of the Tier 3 and LEV Ill regulations and complies with the CAA' s four year leadtime and 3 year stability requirements for vehicles >6 ,000 pounds GWJR. 

### o While the 0.074 g/mi fleet average standard is greater than the LEV Ill 0.065 and 0.056 g/mi fleet average standards in the 2021 and 2022 MYs respectively, the 0

.030 g/m i fleet average standard is less than the LEV Ill 0.047 and 0.038 g/m fleet average standards in the 2023 and 2024 MYs respectively. • Early credits can be generated in the 2018 and 2019 MYs using the proposed Tier 3 method where they are capped at an amount equal to the lesser of themanufactu rer's federal credits or the manufacturer' s LEV Ill credits multiplied by the ratio of 50-state sales to California only sales. Unused c redits would expire after five model years. • Credits can be generated in t he 2020 through 2024 MYs based on the fleet average emissions being less than the fleet average standard

. Unused credits would expire after five model years. Allowed to carry deficits in the credit balance for up to three model years . • Credits can be traded between**vehicles ~3** **750** pounds LVW and 6 ,000 pounds GVWR , and vehicles 6 , 001-8 ,500 pounds GVWR. • Chrys ler questions how EPA' s Tier 3 alternative phase
- in provision of 40/70/ 100% beginning in the 2019 MY meets the CAA 3 year stability requirement when the effect of this phase-in is a declining fleet average. For example, in the 2019 MY 40% of a manufacturer' s vehicles have to meet a fleet average of 0

. 030 g/mi while the remaining 60 % generate some other fleet average which equates to an overall fleet average for the 2019 MY

. This overall fleet average declines again in the 2020 MY until 100% of the manufacturer' s vehicles meet the 0

. 030 g/mi fleet average in the 2021 MY. US06 PM Standards • ARB and EPA are rushing to establish a US06 PM standard that may not be representat ive of all vehicle technologies , especially GDI vehicles. • Most of the testing performed was done on PFI vehicles, not GDI vehicles. Of the GDI vehicles that were tested, most of them were at low mileage

. None of the vehicles tested were diesels. • ARB and EPA need to spend more time to thoroughly in vestigate a nd test a larger number of different GDI vehicle technologies and employ statistical analysis based on good engineering judgment to determine what would be a feasible standard for all vehicle technologies based on the future outlook of technologies to meet the fuel economy ( F E) and greenhouse gas (GHG) s.tandards

. • Low power-to-weight vehicles and trucks in the 6 ,001-8 ,500 pound GVWR category that employ GDI technology to meet FE and GHG standards w ill be most challenged to meet the PM standards under consideration

. • Establishing a single PM standard for both the <6 ,000 pound GVWR vehicles and the 6 ,001-8 ,500 pound GVWR vehicles may not be technically feasible and may drive a particulate filter in the exhaust after treatment system which would adversel y affect FE a nd GHG emissions and add cost. SHED E10 Data with INNOVA • Chrysler does not have reliable data that we can share with EPA at this time. We will consider sharing data with EPA in the future

.Low Sulfur Gasoline Requirement • 10 ppm sulfur gasoline is essential to comply with the proposed Tier 3 standards. • During the development and implementation of the Tier 2 standards, the FE requirements were a constant value and there were no GHG standards. Accordingly , manufacturers could focus their resources and technologies on meeting the Tier 2 standards. • The Tier 3, FE and GHG standards are creating a paradigm shift that EPA must recognize. Duri ng the development and implementation of the stringent Tier 3 standards , manufacturers will also be taxed to comply with the extremely challenging FE standards and GHG standards

. • Low sulfur gasoline is imperative to maintain the extreme ly low certification emission levels in
- use for the useful life of the vehicle

. Without low sulfur gasoline, vehicles on the road are not achieving their full emissions benefit as designed with the hardware and software that manufacturers developed and implemented • There is also a well-known phenomenon called " NOx creep " where vehicle NOx emissions gradually increase due to sulfur buildup on the cata lyst. NOx creep on vehicles driven on public highways has been witnessed in government and vehicle manufacturer test labs and it takes aggressive drive cycles to remove the sulfur from the catalysts. The fact that these vehicles come into the test labs with NOx creep provides evidence that vehicles need low sulfur gasoline to maintain certified · emission levels

. • Advanced lean burn GDI systems are an enabling technology to meet the 2025 MY FE and GHG standards

. • Low sulfur, at 10 -ppm or lower, is a prerequisite for lean-burn GDI systems achieving FE and GHG benefits as well as meeting the Tier 3 standards. • Without low sulfur gasoline, lean burn GDI systems incur significant FE and corresponding GHG pena lty due to more frequent sulfur regenerations events. • 10 ppm sulfur gasoline not only enables vehicles equipped with advanced technologies to achieve intended emission benefits, it has an immediate and significant effect on the 250 million vehicles on the road today , lowering emissions and helping states achieve attainment of National Ambient Air Quality Standards (NAAQS) for ozone. Interim I n-Use Standards • Tier 3 does not provide interim in-use standards for 8,501-14,000 pounds GVWR vehicles. • Interim in-use standards are typically applied in the first few years of vehicle model introduction when it must comply with more stringent new standards or it is being exposed to new standards for the first time (e.g., more stringent new FTP standardsand for the first time new SFTP standards for vehicles 8 , 001 to 14,000 pounds GWJR). • No manufacturer has certified any trucks in the 8,501-10,000 pound GWJR category that meet the four new Tier 3 Bins of 250 , 200 , 170 and 150 or the 10 ,001-14 , 000 pound GWJR category that meet the four new Tier 3 Bins of 400, 270, 230 and 200. • Interim in-use standards have been used in the past to allow manufacturers to introduce vehicles sooner, gain valuable knowledge on those vehicles and minimize in-use liability

. • Manufactu rers must certify their vehicles to the certification standard regardless of the interim in-use standards

.

Frank A. Krich Chrysler Group LLC August 23 , 2013

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# 2t? l 3Chrysler/EPA Tier 3 Meeting Agenda August20,2013 

### Note : Organization listed first has the lead in the meeting

. • Introductions- All • Leadtime/Program Starting Point- EPNAII • 120/150K miles durab i lity- Chrysler/All • R-Factor- EPA/All • Interim in-use standards- Chrysler/All • US06 PM standards- EPNAII • · Other- All • Regulatory timing- EPA o 

### OMS o Final Rule publication • Tier 3 Principle: One Nationa l Program
- Chrysler/All o Low sulfur gasoline o 

### One certification fuel (E1 0) • Next steps - All • Wrap-up/Summary- All • Adjourn

Frank 

### A Krich Chrysler Group LLC August 16, 2013