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, 2012 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 included the following: 

Honda: Robert Bienenfeld, Pete Meier, Ayumu Matsuo, Wataru 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 technology such as: high efficiency exterior 

lighting, lighting and other electrical relays, engine heat recovery, active transmission and engine 

warm-up, electric heater circulation pump, solar reflective paint, glass and glazing, and a review 

of comments on general policy aspects (e.g., minimum fleet percentages). All presentation 

materials for this meeting are in the docket. In addition, 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 Following our March 22, 2012 Meeting on 

the Off-Cycle Credit Program for the 2017-2025 Light-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 functional performance criteria 

of the Electric Heat Circulation Pump without actually installing one. We 

proposed that the language be modified to allow the off-cycle credit for 

the performance you are after, regardless of whether or not an Electric 

Heat Circulation Pump is installed. Robin specifically asked for 

recommended language, so here are a few suggestions: 

1. The definition could be modified to read something like this: 

(B) Electric heater circulation pump means a pump or other system installed 

in a stop-start equipped vehicle or in a hybrid electric vehicle or plug-in 

hybrid electric vehicle. that continues to circulate 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 for 1 minute or more when 

the external ambient temperature is 30 deg F. An electric heater 

circulation pump continues to circulate hot coolant through the heater core 

when the engine is stopped during a stop-start event. Any other system 

which is installed that achieves the same functional 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.