Potential PHEV Test Procedure Chan

DRAFT – 11/1/2013

EPA/ARB/Industry Tier 3 Discussio

Meeting

November 6, 2013 2PM

D. Good, Compliance Division
PHEV Test Procedures – Net Ene

Change (NEC) Correction for CS TeChange (NEC) Correction for CS Te

• EPA Tier 3 NPRM proposed no change to manufacturers use of a NEC corre

during CS testing, between +/-1 and +/-5 % of total fuel energy

– Prior EPA app q p g p g p roval re

quired 

per existin

g

para

gra

ph 40 CFR 600.116-12( )( ) b

5). 

– Correct only CREE, CO2, fuel consumption/MPG; disregard any effect on criteria p– Ref. 40 CFR 1066.501 as proposed in the Tier 3 rule– Example NEC Correction from SAE J1711 Appendix C:

• Alliance comment:

– NEC correction factors, within limits in T3 proposal, should be allowed without EPA – Manufacturer should declare their intent to use NEC correction during the cert prev

• EPA sees no compelling need to revise 600.116-12(b)(5)

– Prior approval is needed to maintain level playing field for all manufacturers, etc.

• ARB/EPA/Industry discussion in Oct 30, 2013 Webinar: 

– Expand NEC Tolerance from +/- 1% to +5% / -1% (allow worst case manufacturer t

– Discuss EPA/ARB confirmatory testing
PHEV CD Test Procedures – Double Cold 

• Tier 3 proposed not applying Utility Factors to Charge Depleting criteria emis

• Using UFs on criteria pollutants could mask high emission rates in exten

Penalty and Charge Depleting Criteria Emi

Using UFs on criteria pollutants could mask high emission rates in exten

mode operation

• Currently EPA assures criteria pollutant compliance on CD tests through 

device policy 

• Alliance comment:

– Utility Factors should be applied to charge depleting criteria emissions

– Manufacturers should be able to attest to charge depleting compliance

– Vehicles must operate in a similar manner when operating at the same A

and load point in either charge sustaining or charge depleting mode.

• ARB Method ARB Method

– Stop/Start:

• Stop the CD test as soon as the engine starts and soak 10 minutes• Resume CD test with a new UDDS cycle• Engine should start soon after beginning UDDS capturing single cold start• A l t d d PHEV i i l l ti t d t i tifi ti 

Apply stan

dar

d PHEV mass emissions calculation to 

d

etermine certification c

g/mi = 0.43(UDDScd /distancecd) + 0.57(

UDDScs_hot start/distancecs_hot s
PHEV CD Test Procedures – Double Cold 

P lt d CD C it i E i i ( ti Penalty an

d CD

C

riteria 

E

missions 

(conti

Modular Method:• This app p y y roach addresses the double cold start 

penalt

y that could onl

y be 

experienced with a PHEV if conditions were just right.

• This approach may not address a blended mode PHEV that cycles the engin

throughout CD testing enough to exhibit multiple cold starts. 

g/mi = 0 43( g/mi

=

0.43(UDDS /distance ) + 0 57(UDDS /distance ) cd /distancecd) +

0.57(UDDScs_hot start/distancecs_hot start)

• The UDDScd is the single worst UDDS (ARB 1-bag UDDS),(EPA 2-bag UDD• The UDDScs is the CS hot-start UDDS (Bag 2 of the ARB Charge sustaining 

3 and 4 of the EPA Charge sustaining test) 

• The distances are those associated with each UDDS sample period The distances are those associated with each UDDS sample period• Pro: Eliminates double cold possibility, uses existing test data, can be used 

Fuel economy tests are “meeting standard”

• Con: Provision required to address blended mode PHEVs (such as limiting t

substitution of CS hot bag to only one CD bag) effect are unknown (this metsubstitution of CS hot bag to only one CD bag), effect are unknown (this met

been applied to any data, yet) 

How should EPA/ARB assure emission compliance during C

– Re

q yp ( ) p ; uire this type of (worst case) CD test data as 

part of certification ; or

– Not require worst case CD data but assure compliance via defeat device policy; or– Require manufacturers to make a statement of compliance that CD tests comply w

pollutant emission standards

– Also require assurance that vehicles operate in a similar manner when operating a

APU speed and load point in either charge sustaining or charge depleting mode
PHEV Test Procedures – In Use CREE sta

• Proposed 

– Existing regulation (not Tier 3) establishes the In Existing regulation (not Tier 3) establishes the In-use CREE standard by multiplying 

use CREE standard by multiplying 

value of a given vehicle by 1.1

– PHEVs use the combined (55% city/45% highway) composite (utilitized CD and CS

In-use standards and certification values---increased by 10%. 

• Tier 3 comments from one manufacturer:

– PHEV CREE values are lar

gy p p g( el

y de

pendent u

pon CD ran

ge (Rcda) g

 and the resultin

g 

– A small change in the Rcda can cause a major change in the in-use compliance lev

• Manufacturers have very little experience in battery deterioration

• Suggest separate in-use standards for CD and CS operation 

• EPA Concerns: EPA Concerns:

– Completely separating CD and CS modes for PHEVs would lead to no CD range d

consequences, since the CREE cert level during CD is usually zero and is indepenexamined independently of CS

– The In-use liability is largely due to the “zero” upstream credit allowed for electricity

• Any electric range lost is essentially replacing “zero” with XXX g/mi• Assigning some value to upstream for In-use would lessen the impact of battery degradation 

upstream “credit” as proposed in the original GHG rule

• Options:

– Base PHEV In-use standard on the electric range (Rcda in SAE J1711)

• For example, Rcda of in-use vehicles could be no less than 90% of the Rcda of the certifica

– Derive PHEV In Derive PHEV In-use standard using upstream emission calculation procedure use standard using upstream emission calculation procedure– No change to existing regulations – Base PHEV In-use standard on 110% of the co

CREE value used in the manufacturers greenhouse gas Model Year Report

– Other ideas?