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2000 Town Center—Suite 1140, Southfield, MI 48075 • Phone 248.357.4717 • Fax 248.357.4740 • www.autoalliance.org July 20, 2010

Karl Simon Director, Compliance and Inno vative Strategies Division U.S. EPA Office of Transpor tation and Air Quality

Ariel Rios Building 1200 Pennsylvania Avenue, N. W.

Mail Code: 6405J Washington, DC 20460

­­ Delivered via email ­­

RE: Request for approval of new scheduled maintenance under §86.1834

­ 01(b)(7)(ii))

for Model Years 2011 and 2012

Dear Mr. Simon:

The Alliance of Automobile Manuf acturers (Alliance) requests th at EPA reapprove as new scheduled maintenance the refill of DEF at service intervals (o il change intervals) for Model

Years 2011 and 2012.

On November 9, 2009 (74 Fed Re g 57671), EPA granted approvals t o Alliance requests for a

new scheduled maintenance for th e refill of Diesel Exhaust Flui d (DEF) for Selective Catalytic Reduction (SCR) technologies and use of the service interval (o il change interval) as the proper DEF refill interval, fo r Model Years 2009 and 2010.

Since that November 2009 approval , SCR technology and the urea infrastructure have continued to develop and mature. DEF is more broadly and readil y available and more vehicle

manufacturers have introduced li ght duty vehicle models with SC R technology. However, the

core characteristics of SCR and DEF have not changed and it con tinues to remain technologically necessary to repl enish the SCR system with DEF at intervals shorter than 100,000 miles.2

The allowable DEF refill interval should continue to be set at the service interval (oil change interval) due to space constraints with packaging of the DEF ta nk and due to the negative impacts to fuel economy and perf ormance from adding weight to t he vehicle. A DEF refill interval set at the oil change interval results in a DEF tank s ize which addresses the packaging and weight challenges on the vehicle, achieves a reasonable mai ntenance interval for drivers, and coincides with the widely known oil change interval.

Therefore, the Alliance requests that EPA reapprove the  schedu led maintenance interval of DEF refill for light duty and cha ssis certified vehicles up to 14,000 GVWR for Model Year 2011

and 2012 that coincides with the manufacturer's service interva l (oil change interval).

The following is further detailed substantiation for this reque st:

This request is for maintenance which did not exist prior to th e 1980 model year.  We

recommend that the maintenance ca tegory for DEF refill be emiss ion‐related, critical

maintenance.  We further recomme nd that, for Model years 2011 a nd 2012, the technologically necessary SCR mai ntenance interval (i.e., DEF t ank refill interval) be set the same as the service interval (oil change interval) in miles.

1) Reasons for why DEF refill is an emission

­ related, critical maintenance

EPA noted in CISD 07‐07 that sinc e the SCR catalyst does not fu nction without the use of a reducing agent, 40 CFR § 86.1834‐01(b)(4)(ii)(F) and §86.00 4‐25(b)(4)(iii)(F) would apply to the SCR catalyst and all of the associated hardw are, including but not limited to the reducing agent, the reducing agent storage tank, the dosing valve, and all lines and hoses. We agree with EP A that DEF refill is an emissi on‐related, critical

maintenance.

2) Reasons for why the technologically necessary SCR maintenance interval should be

the same as the service interval for Model Years 2011 and 2012

The reasons for why the technolo gically necessary SCR maintenan ce interval should be

set the same as the service inte rval (oil change interval) are: vehicles will be designed and equipped to ensure vehicle co mpliance with emission standar ds; DEF will be readily available and accessible to drivers; maintenance is lik ely to be performed; there are engineering constraints on p ackaging a large DEF tank on li ght duty vehicles; and there is a significant penalty o n fuel economy and performance associated with carrying both a larger DEF tank a nd the weight of a large quant ity of DEF.

a) Vehicles will be designed and equipped to ensure compliance with emissions

standards

i) Driver Warning Manufacturers will equip vehicles with an escalating audible an d visual warning chain that provides adequate tim e to re‐fill the DEF. USCAR has developed a recommended practice for manufacturers to use as a standardized warning chain. This warning chain has also been adopted as an SAE industry‐wid e recommended3

practice. SAE has also standardiz ed the DEF indicator symbol. M anufacturers will use an escalating mix of DEF level indicator, messages in the i nstrument cluster, engine shutdown lamp, or audible warnings to warn the driver of low DEF levels.

ii) Driver Inducement Manufacturers will equip vehicles with escalating and sufficien tly onerous levels of

inducement to ensure that the DE F is refilled. This escalating inducement also includes identification of incorrect reducing agent.

iii) Tamper Resistant Design Manufacturers will design the SCR system to be tamper resistant consistent with the EPA’s March 27, 2007 guidance letter. The actions listed be low will trigger illumination of a warning lamp:

• Disconnected DEF tank level sensor

• Blocked DEF line or dosing valve

• Disconnected DEF dosing valve

• Disconnected DEF pump

• Disconnected SCR wiring harness

• Disconnected NOx sensor (that is incorporated with the SCR syst em)

• Disconnected DEF quality sensor

iv) Freeze Protection Manufacturers will design and equ ip vehicles with DEF Dosing Fr eeze Protection Systems which will prevent or minimize SCR performance degradat ion due to freezing of DEF. This can includ e DEF tank heaters, line heater s, and location of tank within a heated space.

b) DEF will be readily available and accessible to drivers

i) DEF is available at dealerships, gas stations and truck stops

The manufacturers of SCR vehicles have worked with franchised d ealerships to supply DEF to their customers. Se veral of these manufacturers h ave agreements with gasoline station chains to ensure availability of DEF at t hose refill stations. In addition, many companies have announced publicly their intentio n to stock DEF. (For an up‐to‐date and complete list please see the Recent News & Headlines section

at http://www.factsaboutscr.com/ .)

To further ensure the quality of DEF at these retail locations, the American

Petroleum Institute is administe ring a DEF quality control prog ram with the support of distributor and reta iler licensing agreements. ( http://www.apidef.org/ )

ii) An organized industry

­ wide SCR Stakeholder Group is ensuring wide availability of DEF DEF infrastructure development i s making significant progress. Industry‐wide standards for DEF infrastructure, a necessary enabler for the w idespread availability of DEF, have been put in place, including ISO DEF specifications, API's DEF quality standard, SAE DEF spe cifications, and USCAR and SAE warning chain4

standards. The SCR Stakeholder G roup has established itself as a focal point for infrastructure development discu ssions by EPA, DOE, DEF produce rs, suppliers,

distributors and users of DEF.

iii) Drivers can locate DEF through DOE’s NREL locator website DOE/NREL has established a locator website ( http://www.afdc.energy.gov/afdc/locator/def/ ) for drivers to use to locate supplies of DEF. Over 5,000 locations are included on the locat or website. Other companies are also creating DEF l ocator websites which will be available to the public.

iv) Public awareness of availability is increasing through DEF public relations

activities Numerous press releases and public relations activities have be en distributed related to the development of DE F infrastructure. (For an up‐to ‐date and complete list please see the Recent News & Headlines section at http://www.factsaboutscr.com/ .)

c) Maintenance is likely to be performed on schedule

There are a number of reasons wh y the DEF refill maintenance is likely to be performed. Vehicles will be equipped with an escalating warning chain which will audibly and visually signal that the maintenance needs to be pe rformed. In the unlikely event that the warnings are not heeded and the maintenance is n ot performed, the performance of the vehicle will be noticeably and significantly degraded.

d) Engineering constraints with packaging preclude packaging of a large quantity of

DEF on light duty vehicles It is impractical to equip light duty vehicles with a DEF tank( s) sufficient in size to achieve the 100,000 mile scheduled maintenance requirement. The amount of space required for such a DEF quantity would make the vehicle uncompe titive and less

marketable.

Light duty vehicles are constrai ned in the amount of space that can be dedicated to a DEF tank. In addition to the DEF tank, SCR vehicles must packag e an SCR catalyst, SCR mixer and DEF dosing and heating mechanisms.  For example, one SCR light duty vehicle in current production (BMW 335d) provides 6.1 gallons o f DEF to achieve the DEF refill interval set at the oil change interval. Assuming a 6 gallon to 10,000 mile oil change interval ratio, to be a ble to accommodate a 100,000 mile scheduled maintenance requirement would require 60 gallons of DEF. The sp ace required to accommodate such a DEF quantity would be approximately 8 cubic feet (60 gallons times 0.1337 gallons per cubic f oot), which is three‐quarters o f the entire trunk volume of the vehicle (12 cubic feet). T his would also be almost equiv alent to installing 4 extra fuel tanks (in addition to the ex isting fuel tank of 16.1 gallo ns). To reduce the existing

usable volume to such an extent would result in an uncompetitiv e vehicle in terms of usable passenger or cargo volume.5

In addition to the DEF tank(s), vehicles must also package the SCR catalyst, SCR mixer and DEF dosing and heating mecha nisms. The space required for t hese additional catalysts and devices, as well as their packaging requirements (e.g., heat transfer requirements from the SCR catalyst), limit the locations and sp ace available in the undercarriage for use for increased DEF capacity.

e) The fuel economy and performance penalty is significant with large DEF volume It is impractical for light duty vehicles to carry the weight o f a DEF tank sufficient in
size to achieve the 100,000 mile s cheduled maintenance requirem ent. The addition of such a weight to a light duty veh icle would significantly reduc e the fuel economy and the performance of the vehicle.

The weight of such a DEF quantity would be 540 lbs (60 gallons times 9 lbs per gallon) using the example above. This is in addition to the weight of t he actual DEF tank(s) itself, mountings and necessary c hassis or suspension reinforce ments to support the increased weight. According to the EPA and DOE website Fuelecon omy.gov ( http://www.fueleconomy.go v/feg/lightweight.shtml ), for every 10% of weight

eliminated from a vehicle's tota l weight, fuel economy improves by seven percent. Using this ratio, the addition o f 540 lbs to a 3800 lb curb wei ght vehicle would reduce fuel economy by 9.8%.

Also, the handling performance ( acceleration, br aking, turning) and the available passenger space, cargo carrying an d/or towing capacity of the v ehicle would be negatively affected. The combina tion of reduced fuel economy an d reduced vehicle performance would result in an u ncompetitive vehicle which is l ess marketable.

For these reasons, the Alliance r equests that EPA reapprove the scheduled maintenance interval of DEF refill for light duty and chassis certified veh icles (up to 14,000 GVWR) for

Model Year 2011 and 2012 that coi ncides with the manufacturer's service interval (oil change interval).

Sincerely,

Giedrius Ambrozaitis Director, Environmental Affairs

cc: Linc Wehrly, Compliance and I nnovative Strategies Division Laura Baker, Compliance and I nnovative Strategies Divisio n