Passavant, Glenn 

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Glenn, 

steven .j. fornetti@g m. com 

Thursday, August 15, 2013 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 Testing on EXX". 

If you have any questions please let me know. 

Thanks, 

Steve F ornetti 

GM Compliance & Certification 

GM Milford Proving Ground 

Milford, Ml 48380-3726 

Mailcode 483-331-500 

(248) 41 0-3689 

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1 
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U.S. EPA- Staff Draft Only- Do Not Quote 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 Purposes 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 §86.113-07(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 use any EDV data for fuel economy purposes. 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08/07/2013 U.S. EPA- Staff Draft Only- Do Not Quote 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 NRH factor 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 +he """",...''""""',..",..1 ""nnll"_,,_l" ...,"',...-· ·-L ---· .1-.a.- - . . .L, _ __ .._ 

tJIVVIU'- \.11 CJUVCIII\..~U CfJfJIUVOI liiiUU!:)II I~I:)UidlUry lt::!Xl 

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 Only