GM-EPA Tier 3 

Meeting

October 23, 2013
Issue 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) accept 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 delay
Issue 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 

CARB
Issue 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 nonFFVs

• 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 technologies
Issue 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