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DiCicco, Dominic (D.M.)

From: DiCicco, Dominic (D.M.)

Sent: Friday, November 22, 2013 4:09 PM

To: McDonald, Joseph (McDonald.Joseph@epa.gov)

Cc: Olechiw, Michael (olechiw.michael@epa.gov); 'machiele.paul@epa.gov'; 

'Fernandez.Antonio@epa.gov'

Subject: Additional data as requested. RE: Ford Supplemental Comments on Tier 3 for Docket 

No. EPA-HQ-OAR-2011-0135

Mr. McDonald, 

Thank you for your review. 

The following two data tables are provided in response to your request for additional information regarding 

“Attachment 2: Tier 2 Sulfur Test Program – Ford Motor Company Summary Report”. 

Table 1 provides the average weighted FTP Bag values corresponding to the data found in Figure 4: NMHC+NOx FTP 

Tailpipe Emissions Summary for 2.0L GTDI Explorer. 

Table 2 provides the FTP Bag values for the lowest 10 ppm sulfur and highest 26.5 ppm sulfur data represented in Figure 

5: Cumulative FTP mass for NMHC+NOx Tailpipe Emissions for 2.0L GTDI Explorer. 

We, too, observe a significant impact upon NOx emissions relative to NMHC; however, it is important to note that 

overall hydrocarbon conversion efficiency is also degraded due to the sulfur contamination of the catalyst. Ultimately, 

the higher 26.5 ppm sulfur (NMHC+NOx) test result would have resulted in a failed In-Use Verification Protocol (IUVP) 

test under the proposed Tier 3 standards. 

 We cannot stress enough that we believe that a 10 ppm sulfur limit is both appropriate and essential based on the 

available data. 

 Additionally, actions to reduce summer gasoline vapor pressure and increase the minimum gasoline octane rating

continue to be needed to enable manufacturers to achieve future requirements. 
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Again, Thank you for your time and including this material in the Tier 3 docket. 

Best Regards, 

Dominic DiCicco 

Manager, Environmental Policy and Fuel Quality 

Sustainability & Vehicle Environmental Matters 

Ford Motor Company 

One American Road 

Dearborn, Michigan 48126-2701 

O 313-594-2916 

F 313-594-0338 

ddicicco@ford.com 

From: McDonald, Joseph [mailto:McDonald.Joseph@epa.gov] 

Sent: Wednesday, November 20, 2013 12:02 PM 

To: DiCicco, Dominic (D.M.) 

Cc: Olechiw, Michael; Machiele, Paul; Fernandez, Antonio 

Subject: RE: Ford Supplemental Comments on Tier 3 for Docket No. EPA-HQ-OAR-2011-0135 

Importance: High 

Dear Mr. DiCicco: 

Thank you for your submission of supplemental comments regarding gasoline sulfur impacts on exhaust emissions on 

behalf of Ford Motor Company. I have reviewed the document attachments and I have some additional questions 

regarding “Attachment 2: Tier 3 Sulfur Test Program - Ford Motor Company Summary Report”. Would it be possible to 

provide the relative contributions of NOx and NMHC for the composite results in “Figure 4” and for either the 

cumulative results in “Figure 5” or separately tabulated for each of the FTP phases? In other data, we have been seeing 

a more significant impact for NOx emissions than for NMOG and I would like to see if Ford’s test results were 

similar. We also have sufficient information within your fuel analysis (Appendix A) for EPA to estimate the NMOG 

emissions from your NMHC results if they can be reported separately from NOx. This would allow us to see overall 

NMOG+NOx emissions levels from your submitted results. 

Respectfully submitted, 

Joseph McDonald 

Senior Mechanical Engineer 

U.S. EPA 

ORD/NRMRL & OAR/OTAQ 

MS 690, 26W. Martin Luther King Dr. 

Cincinnati, Ohio 45268 USA 

Telephone (USA): 513-569-7421 

Cellular Telephone: 734-780-1808 

E-mail: mcdonald.joseph@epa.gov
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From: DiCicco, Dominic (D.M.) [mailto:ddicicco@ford.com] 

Sent: Wednesday, November 20, 2013 11:05 AM 

To: Olechiw, Michael; Machiele, Paul; McDonald, Joseph; Fernandez, Antonio 

Subject: Ford Supplemental Comments on Tier 3 for Docket No. EPA-HQ-OAR-2011-0135 

Dear Mr. Olechiw and Mr. Machiele and Mr. McDonald and Mr. Fernandez, 

Included are Ford Supplemental Comments on Tier 3 Docket No. EPA-HQ-OAR-2011-0135. 

In summary, 

These supplemental comments add important data to the record that should be considered by EPA as it sets limits on 

the sulfur content of gasoline. We believe that a 10 ppm sulfur limit is both appropriate and essential based on the data

in these comments, as well as other data and information presented by the Alliance of Automobile Manufacturers and 

many of our competitors in the auto industry. 

We note that, in addition to sulfur reductions, there are other fuel quality improvements needed to enable automobile 

manufacturers to achieve future standards imposed on motor vehicles. For example, reduced summer gasoline vapor 

pressure is needed to assist in achieving Tier 3 evaporative emission regulations, and an increase in the minimum 

gasoline octane rating is needed to enable manufacturers to achieve future fuel economy requirements and reductions 

in greenhouse gases. We urge EPA to take action on all fuel quality improvements necessary to support upcoming 

vehicle standards. 

If there are specific questions regarding these recommendations or any clarifications or comments provided within the 

documents, please feel free to contact me at 313-594-2916 for further discussions. 

Thank you for your time and including this material in the Tier 3 docket. 

(If possible, please reply email with a receipt confirmation.) 

Best Regards, 

Dominic DiCicco 

Manager, Environmental Policy and Fuel Quality 

Sustainability & Vehicle Environmental Matters 

Ford Motor Company 

One American Road 

Dearborn, Michigan 48126-2701 

O 313-594-2916 

F 313-594-0338 

ddicicco@ford.com