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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); 'machie le.paul@epa.gov'; 'Fernandez.Antonio@epa.gov' Subject: Additional data as requested. RE: Ford Supplementa l 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 respo nse to your request for additional information rega rding “Attachment 2: Tier 2 Sulfur Test Program – Ford Mo tor Company Summary Report”.

Table 1 provides the average weighted FTP Bag value s 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 repr esented in Figure 5: Cumulative FTP mass for NMHC+NOx Tailpipe Emissi ons for 2.0L GTDI Explorer.

We, too, observe a significant impact upon NOx emis sions relative to NMHC; however, it is important to note that overall hydrocarbon conversion efficiency is also d egraded due to the sulfur contamination of the cata lyst. Ultimately, the higher 26.5 ppm sulfur (NMHC+NOx) test result w ould 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 ac hieve future requirements.2 Again, Thank you for your time and including this m aterial 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, Anton io Subject: RE: Ford Supplemental Comments on Tier 3 for Docke t No. EPA-HQ-OAR-2011-0135 Importance: High

Dear Mr. DiCicco:

Thank you for your submission of supplemental comme nts regarding gasoline sulfur impacts on exhaust em issions on behalf of Ford Motor Company. I have reviewed the document attachments and I have some additional que stions 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 eit her the cumulative results in “Figure 5” or separately tabu lated for each of the FTP phases? In other data, w e have been seeing a more significant impact for NOx emissions than fo r NMOG and I would like to see if Ford’s test resul ts were similar. We also have sufficient information withi n your fuel analysis (Appendix A) for EPA to estima te the NMOG emissions from your NMHC results if they can be rep orted separately from NOx. This would allow us to see overall NMOG+NOx emissions levels from your submitted resul ts.

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.gov3 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 t he record that should be considered by EPA as it se ts 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 inform ation presented by the Alliance of Automobile Manuf acturers and many of our competitors in the auto industry.

We note that, in addition to sulfur reductions, the re are other fuel quality improvements needed to en able automobile manufacturers to achieve future standards imposed o n motor vehicles. For example, reduced summer gasoline vapor

pressure is needed to assist in achieving Tier 3 evaporativ e emission regulations, and an increase in the minimum gasoline octane rating is needed to enable manufacturers to achieve futur e 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 rec ommendations or any clarifications or comments prov ided within the documents, please feel free to contact me at 313-59 4-2916 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 con firmation.)

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