UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

NATIONAL VEHI CLE AND FUEL EMI SSIONS LABORATORY 

2565 PLYMOUTH ROAD 

ANN ARBOR, MICHIGAN 48105-2498 

OFFICE OF 

AI RAND 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 {)-u_rf 

TO: Public Docket EPA-HQ-OAR-2011-0135 

A. Introduction 

At their request,EPA staff met with representatives of the Chrysler Corporation to discuss 

the issues and questions related to the provisions of the Tier 3 NPRM. The meeting was 

held on August 20, 2013 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 Chrysler's comments on the 

NPRM were heavily referenced in the discussions. This was not a decision meeting on any 

elements of the Tier 3 NPRM, but one designed primarily for Chrysler to raise questions 

and concerns about provisions of the 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 with the position put forth in the Alliance of Automobile Manufacturers 

comments on the NPRM. Specifically they want the option for vehicle family-by-vehicle 

family useful life values. 

R-factor: Chrysler was generally supportive of the EPA staff concept for an interim 

approach for EDV and FEY testing and the R-factor value for LEV III/T3 vehicles 

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 input 
which 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 of additional 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 

information 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 

INNOV A 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 loss, refueling, etc) on an ethanol based fuel. 

2 
Chrysler 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. 

0.07 

0.06 

0.05 .E 

-

0) 

0.04 

0.03 

0.02 

0.01 

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/mi 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/mi 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 the 
manufacturer's federal credits or the manufacturer's LEV Ill credits multiplied by the 

ratio of 50-state sales to California only sales. Unused credits would expire after five 

model years. 

• Credits can be generated in the 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. 

• Chrysler 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 

representative 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 investigate and 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 (FE) 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 will 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 adversely 

affect FE and 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. During 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 extremely 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 catalyst. 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 1 0-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 penalty 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 In-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 standards 
and 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 1 0, 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. 

• Manufacturers 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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Chrysler/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 durability- 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 National 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