### UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
NATIONAL VEHICLE AND FUEL EMISSIONS LABORATORY

2000 TRAVERWOOD DRIVE ANN ARBOR, MI 48105-2498

OFFICE OF
AIR AND RADIATION



### August 7, 2012

MEMORANDUM

SUBJECT: American Honda Manufacturing Meeting with EPA and NHTSA Regarding Proposal for 2017-2025 Light-Duty (LD) Greenhouse Gas (GHG) Standards

FROM: Arvon L. Mitcham, Program Manager/Engineer

TO: EPA Docket #EPA-HQ-OAR-2010-0799

This memo documents a meeting held on March 22, 201 2 between representatives of American Honda Manufacturing (AHM or Honda), EPA, and NHTSA to discuss Honda’s comments on the LD GHG proposed rule. The meeting attendees include d the following:

Honda : Robert Bienenfeld, Pete Meier, Ayumu Matsuo, Wata ru Taga

EPA : Ed Nam, Linc Wehrly, Jeff Cherry, Arvon Mitcham, Byungho Lee, Robin Moran, Rob
French

NHTSA : Jim Tamm, Rebecca Yoon, Greg Powell, Volpe Center - Corralie Cooper, Kevin
Greene

The topics discussed included off-cycle credit tech nology such as: high efficiency exterior lighting, lighting and other electrical relays, eng ine heat recovery, active transmission and engine warm-up, electric heater circulation pump, solar re flective paint, glass and glazing, and a review of comments on general policy aspects (e.g., minimu m fleet percentages). All presentation materials for this meeting are in the docket. In a ddition, a copy of an e-mail from Robert

Bienenfeld of Honda with additional comments on the off-cycle program is attached, with Honda’s approval, to this memorandum.

### Attachment:

Additional E-Mail from Robert Bienenfeld of Honda F ollowing our March 22, 2012 Meeting on the Off-Cycle Credit Program for the 2017-2025 Ligh t-Duty (LD) Greenhouse Gas (GHG)

Standards

************

From: Robert_Bienenfeld@ahm.honda.com
To: Ed Nam/AA/USEPA/US@EPA, Robin Moran/AA/USEPA/US@EPA
Cc: William Charmley/AA/USEPA/US@EPA
Date: 04/11/2012 06:42 PM Subject: Electric Heat Circulation Pump

Ed, Robin:

At our Honda meeting to discuss off-cycle credits, you'll remember that
Honda indicated we believe we can meet the function al performance criteria of the Electric Heat Circulation Pump without actua lly installing one. We proposed that the language be modified to allow the off-cycle credit for the performance you are after, regardless of whethe r or not an Electric Heat Circulation Pump is installed. Robin specific ally asked for recommended language, so here are a few suggestions :

1. The definition could be modified to read someth ing like this: (B) Electric heater circulation pump means a pump o r other system installed in a stop-start equipped vehicle or in a hybrid ele ctric vehicle or plug-in hybrid electric vehicle. that continues to circ ulate hot coolant through the heater core when the engine is stopped during a stop-start event. This system must be calibrated to keep the engine off fo r 1 minute or more when the external ambient temperature is 30 deg F. An e lectric heater circulation pump continues to circulate hot coolant through the heater core when the engine is stopped during a stop-start even t. Any other system
which is installed that achieves the same functiona l performance of heating the cabin while the engine is off when the external temperature is 30 deg F would qualify for the same off-cycle credit as the Electric heater circulation pump.

rjb

Robert Bienenfeld Senior Manager, Environment and Energy Strategy Product Regulatory Office American Honda Motor Co., Inc.