# GM

- EPA Tier 3



# Meeting October 23, 2013Issue EPA Position (GM’s Last Understanding) GM’s Position 1. Certification Fuel • EPA Staff supports E10 @ 9 psi • Considering E15 trigger language • Support E10 @ 9 psi • If E15 trigger it should be 51% market penetration 2. Reciprocity • Accept CARB cert/fuel thru 2019 (exhaust) and thru 2021 (evap ) • Assuming EPA fuel is E10, starting 2020 (exhaust) and 2022 (evap ) a ccept CARB certification/fuel but reserve right to test on EPA fuel • Want to both certify and develop to one fuel • EPA should either fully harmonize fuels or commit to test on CARB fuel 3. FTP Fleet Average and Early Credit Provisions • As proposed in NPRM except allow proportional ratio based on US Volume/CA+177 Volume • GM supports generally but believes all CA+177 vehicles should be included in 2015 (don’t limit to < 6000 lbs) 4. Availability of Bins 3 and 4 • As proposed in NPRM available thru 2019 on NMOG+NOx basis • GM Supports 5. Acceptance of Early LEV III Certifications Nationwide • As proposed in NPRM except FE/GHG testing on E0 • GM supports but asks EPA to see if there’s any way to make available before FR signed given the delayIssue EPA Position (GM’s Last Understanding) GM’s Position 6. 4WD Dyno • EPA proposal recently communicated to industry • GM supports 7. R- Factor • Temporary program per Sept 25 EPA meeting with industry • E10 R- Factor may not be available until 2020 MY (depends on data) • Complete R- Factor rulemaking ASAP • Make E10 R- Factor available as soon as rulemaking is complete 8. Evap Phase-in • Will include option for 20% in 2017 MY • Will allow 2017 to be included in alternative phase-in calculation • GM supports both in which case alternative phase-in will be 1160 points 9. US06 PM • Proposed 10/20 and asked for comment on 10/10 mg/mi • CARB commented 4 mg/mi • EPA considering 6 mg/mi with 12 mg/mi in -use during phase-in • Premature to go lower than 10 • Want to maintain common standard between EPA and CARBIssue EPA Position (GM’s Last Understanding) GM’s Position 10. PM Measurement in support of 3 mg/mi FTP standard • Procedures outlined in latest 1066 draft recently shared with industry • Request no significant changes • GM is buying lab equipment based on these procedures 11. Preconditioning for In - Use Testing • EPA will allow manufacturers to take fuel samples, but no preconditioning on initial test • Fuel sample doesn’t address sulfur poisoning from prior tanks of fuel and isn’t very practical • Should allow preconditioning 12. In - Use Compliance Criteria • Do not plan to address in Tier 3 • Perhaps could address in future rulemaking (e.g., revisit of CAP2000 regulations) • IUCP compliance should be based on average emissions like CARB does (technically / statistically sound) 13. Evap Ethanol Adjustment Factor • NPRM proposed 10% factor as mandatory • Considering both factor level and whether it should be mandatory • GM supports use of actual with factor as an option • GM data suggests factor for diurnal of about 3%Issue EPA Position (GM’s Last Understanding) GM’s Position 14. Cert Fuel for FFV Evap Testing • For diurnal EPA will allow 9 psi E10 (i.e., same as non- FFVs) • For ORVR EPA will require Tier 2 indolene splash blended with ethanol to get E10 (~ 10 psi) • ORVR requirement is more burdensome than for non FFVs • Requires manufacturer to stock unique fuel just for this purpose 15. SFTP Standards for FFVs • New requirement that FFVs must test/comply on E85 • Unnecessary added burden for FFVs • E10 compliance is sufficient 16. Evap Durability Mileage Accumulation Fuel • ??? • Allow use of Tier 3 cert fuel (E10) for mileage accumulation for evap durability • Avoids burden of carrying a unique fuel for this purpose 17. Canister Bleed Test • Applicable at full useful life • Adopt as 4K standard only, consistent with LEV III 18. Interim In - Use Standards • No interim in -use standards available for MD FTP or LD/MD SFTP • Adopt same interim in -use standards as in LEV III • Standards very challenging esp. new GHG technologiesIssue EPA Position (GM’s Last Understanding) GM’s Position 19. PHEV test procedures • Harmonizing with CARB • Considering Alliance proposals • Who is replacing Chris Nevers who led this assignment for EPA? • Support Alliance proposals • Charge sustaining based tailpipe testing (not charge depletion) • Need common procedures between CARB and EPA