Passavant, Glenn From: Sent: To: Cc: Subject: Attachments: Glenn, steven .j.fornetti@gm .com Thursday, August 15, 20 1 3 3:26PM Passavant, Glenn james.ehlmann@gm.com Comments On EPA Interim Options to Address R-factor Fuel Economy R-Factor Analysis_August 7 2013_GM.pptx

Attached you will find our comments (in red) on EPA's. interim options to address R-factor, specifically on EPA's two slides entitled " Potential Interim Changes for Emission Testi ng on EXX". If you have any questions please let me know. Thanks, Steve Fornetti GM Compliance & Certification GM Milford Proving Ground Milford, Ml 48380-3726 Mailcode 483-331-500 (248) 41 0-3689 Nothing in this message is intended to constitute an electronic signature unless a specific statement to the contrary is included in this message. Confidentiality Note : This message is intended only for the person or entity to which it is addressed. Itmay contain confidential and/or privileged material. Any review, transmission, dissemination or other use, or taking ofany action in reliance upon this message by persons or entities other than the intended recipient is prohibited and may be unlawf ul. Ifyou received this message in error, please contact the sender and delete it from your computer.

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# GM INPUT Fuel Economy R-Factor: Discussion of ORNL Program and Overall R-Factor Value EPA-Alliance-Global Automakers R - Factor Discussion

August 7, 2013

_

U.S. EPA Presentation

U.S. EPA- Staff Draft Only- Do Not Quote

or Cite - For . Discussion Pu rposes Only

# Regulatory and Interim Options to Address R-Factor: 

# Potentia/Interim Changes for Emission Testing on EXX (until an EPA "RH

# factor action is completed)

• Allow FE and GHG testing (done as a set) on EO even if criteria pollutant emission testing is on EXX.

- Revise proposed §86.113-04(2)(i)(B) and §86.113-077(a)(l)) . 

### • Expand §86.1 13-07(a)(S) such that during transition period, it only requires vehicles to pass criteria pollutants on the emissions cert fuel (EXX) even if it uses EO for FE testing. There should also 

### be modification::, ::,umewhere 

### in 86.113-04(aj(2) . EPA needs to address 600.007(b){4) as well.

- AECD/Defeat Device policy still applies 

### • Only need to do EDV on EXX for criteria pollutants; not required to use this value in FE as is currently done. Agreed, however , manufacturer should have the option to use EDV EXX FE data if

. they wish. Need to address 600.007(a) in which EDV's automatically qualify as FE vehicles.

- Should use EO data from dual testing on EDV for fuel economy Dual testing should not be required, it should be at the manufacturer's option .

- In summary, manufacturers should not be required to us e any EDV data for fuel economy purpos es. But the use of EXX or EO EDV data for fuel economy purposes should be an option available to manufacturers.

08/07/2013 U.S. EPA- Staff Draft Only- Do Not Quote or Cite- For Discussion Purposes Only

# Regulatory and Interim Options to Address R-Factor: Potentia/Interim Changes for Emission Testing on EXX (until an EPA 

# NRHfactor action is completed) • Litmus on EXX for labeling tests, but also allow the use of EO. Currently allowed with "advanced approval" under 600.115-11(d). However, in this situation, EPA should nrnuirlo 

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# changes. (Guidance letter would be too late for 2015 MY LEV3 programs.) ·

- Manufacturer calculations only; not submitted/included in EPA database (Verify) due to R-Factor concerns on EXX



## - SG/CWF/NHV calculation method for EXX to be provided in guidance letter 

# • Same fuels used for certification must be used on IUVP for criteria pollutants and GHG. IUVP testing should only be required on the fuel used to certify for criteria pollutants. IUVP testing on .EO should only be done at the manufacturer/s option.

08/07/2013 U.S. EPA- Staff Draft Only- Do Not Quote or Cite - For Discussion Purposes On ly