Home Page About Us Contribute




Escort, Inc.



Tweets by @CrittendenAuto






By accessing/using The Crittenden Automotive Library/CarsAndRacingStuff.com, you signify your agreement with the Terms of Use on our Legal Information page. Our Privacy Policy is also available there.

Alternative Method for Calculating Off-Cycle Credits Under the Light-Duty Vehicle Greenhouse Gas Emissions Program: Applications From Fiat Chrysler Automobiles and Toyota Motor North America

American Government Special Collections Reference Desk

American Government Topics:  Fiat Chrysler Automobiles, Toyota

Alternative Method for Calculating Off-Cycle Credits Under the Light-Duty Vehicle Greenhouse Gas Emissions Program: Applications From Fiat Chrysler Automobiles and Toyota Motor North America

Byron Bunker
Environmental Protection Agency
10 April 2018


[Federal Register Volume 83, Number 69 (Tuesday, April 10, 2018)]
[Notices]
[Pages 15383-15385]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2018-07356]


=======================================================================
-----------------------------------------------------------------------

ENVIRONMENTAL PROTECTION AGENCY

[FRL-9976-26-OAR]


Alternative Method for Calculating Off-Cycle Credits Under the 
Light-Duty Vehicle Greenhouse Gas Emissions Program: Applications From 
Fiat Chrysler Automobiles and Toyota Motor North America

AGENCY: Environmental Protection Agency (EPA).

ACTION: Notice.

-----------------------------------------------------------------------

SUMMARY: The Environmental Protection Agency (EPA) is requesting 
comment on applications from Fiat Chrysler Automobiles (FCA), and 
Toyota Motor North America (Toyota) for off-cycle carbon dioxide 
(CO2) credits under EPA's light-duty vehicle greenhouse gas 
emissions standards. ``Off-cycle'' emission reductions can be achieved 
by employing technologies that result in real-world benefits, but where 
that benefit is not adequately captured on the test procedures used by 
manufacturers to demonstrate compliance with emission standards. EPA's 
light-duty vehicle greenhouse gas program acknowledges these benefits 
by giving automobile manufacturers several options for generating 
``off-cycle'' CO2 credits. Under the regulations, a 
manufacturer may apply for CO2 credits for off-cycle 
technologies that result in off-cycle benefits. In these cases, a 
manufacturer must provide EPA with a proposed methodology for 
determining the real-world off-cycle benefit. These manufacturers have 
submitted applications that describe methodologies for determining off-
cycle credits from technologies described in their applications. 
Pursuant to applicable regulations, EPA is making the descriptions of 
each manufacturer's off-cycle credit calculation methodologies 
available for public comment.

DATES: Comments must be received on or before May 10, 2018.

ADDRESSES: Submit your comments, identified by Docket ID No. EPA-HQ- 
OAR-2018-0168, to the Federal eRulemaking Portal: https://www.regulations.gov. Follow the online instructions for submitting 
comments. Once submitted, comments cannot be edited or withdrawn. The 
EPA may publish any comment received to its public docket. Do not 
submit electronically any information you consider to be Confidential 
Business Information (CBI) or other information whose disclosure is 
restricted by statute. Multimedia submissions (audio, video, etc.) must 
be accompanied by a written comment. The written comment is considered 
the official comment and should include discussion of all points you 
wish to make. The EPA will generally not consider comments or comment 
contents located outside of the primary submission (i.e. on the web, 
cloud, or other file sharing system). For additional submission 
methods, the full EPA public comment policy, information about CBI or 
multimedia submissions, and general guidance on making effective 
comments, please visit https://www2.epa.gov/dockets/commenting-epa-dockets.

FOR FURTHER INFORMATION CONTACT: Roberts French, Environmental 
Protection Specialist, Office of Transportation and Air Quality, 
Compliance Division, U.S. Environmental Protection Agency, 2000 
Traverwood Drive, Ann Arbor, MI 48105. Telephone: (734) 214-4380. Fax: 
(734) 214-4869. Email address: french.roberts@epa.gov.

SUPPLEMENTARY INFORMATION: 

I. Background

    EPA's light-duty vehicle greenhouse gas (GHG) program provides 
three pathways by which a manufacturer may accrue off-cycle carbon 
dioxide (CO2) credits for those technologies that achieve 
CO2 reductions in the real world but where those reductions 
are not adequately captured on the test used to determine compliance 
with the CO2 standards, and which are not otherwise 
reflected in the standards' stringency. The first pathway is a 
predetermined list of credit values for specific off-cycle technologies 
that may be used beginning in model year 2014.\1\ This pathway allows 
manufacturers to use conservative credit values established by EPA for 
a wide range of technologies, with minimal data submittal or testing 
requirements, as long as the technologies meet EPA regulatory 
definitions. In cases where the off-cycle technology is not on the menu 
but additional laboratory testing can demonstrate emission benefits, a 
second pathway allows manufacturers to use a broader array of emission 
tests (known as ``5-cycle'' testing because the methodology uses five 
different testing procedures) to demonstrate and justify off-cycle 
CO2 credits.\2\ The additional emission tests allow emission 
benefits to be demonstrated over some elements of real-world driving 
not adequately captured by the GHG compliance tests, including high 
speeds, hard accelerations, and cold temperatures. These first two 
methodologies were completely defined through notice and comment 
rulemaking and therefore no additional process is necessary for 
manufacturers to use these methods. The third and last pathway allows 
manufacturers to seek EPA approval to use an alternative methodology 
for determining the off-cycle CO2 credits.\3\ This option is 
only available if the benefit of the technology cannot be adequately 
demonstrated using the 5-cycle methodology. Manufacturers may also use 
this option for model years prior to 2014 to demonstrate off-cycle 
CO2 reductions for technologies that are on the 
predetermined list, or to demonstrate reductions that exceed those 
available via use of the predetermined list.
---------------------------------------------------------------------------

    \1\ See 40 CFR 86.1869-12(b).
    \2\ See 40 CFR 86.1869-12(c).
    \3\ See 40 CFR 86.1869-12(d).
---------------------------------------------------------------------------

    Under the regulations, a manufacturer seeking to demonstrate off-
cycle credits

[[Page 15384]]

with an alternative methodology (i.e., under the third pathway 
described above) must describe a methodology that meets the following 
criteria:
     Use modeling, on-road testing, on-road data collection, or 
other approved analytical or engineering methods;
     Be robust, verifiable, and capable of demonstrating the 
real-world emissions benefit with strong statistical significance;
     Result in a demonstration of baseline and controlled 
emissions over a wide range of driving conditions and number of 
vehicles such that issues of data uncertainty are minimized;
     Result in data on a model type basis unless the 
manufacturer demonstrates that another basis is appropriate and 
adequate.
    Further, the regulations specify the following requirements 
regarding an application for off-cycle CO2 credits:
     A manufacturer requesting off-cycle credits must develop a 
methodology for demonstrating and determining the benefit of the off-
cycle technology, and carry out any necessary testing and analysis 
required to support that methodology.
     A manufacturer requesting off-cycle credits must conduct 
testing and/or prepare engineering analyses that demonstrate the in-use 
durability of the technology for the full useful life of the vehicle.
     The application must contain a detailed description of the 
off-cycle technology and how it functions to reduce CO2 
emissions under conditions not represented on the compliance tests.
     The application must contain a list of the vehicle 
model(s) which will be equipped with the technology.
     The application must contain a detailed description of the 
test vehicles selected and an engineering analysis that supports the 
selection of those vehicles for testing.
     The application must contain all testing and/or simulation 
data required under the regulations, plus any other data the 
manufacturer has considered in the analysis.
    Finally, the alternative methodology must be approved by EPA prior 
to the manufacturer using it to generate credits. As part of the review 
process defined by regulation, the alternative methodology submitted to 
EPA for consideration must be made available for public comment.\4\ EPA 
will consider public comments as part of its final decision to approve 
or deny the request for off-cycle credits.
---------------------------------------------------------------------------

    \4\ See 40 CFR 86.1869-12(d)(2).
---------------------------------------------------------------------------

II. Off-Cycle Credit Applications

A. Fiat Chrysler Automobiles

1. High-Efficiency Alternator
    FCA is requesting GHG credits for alternators with improved 
efficiency relative to a baseline alternator. This request is for the 
2009 and later model years. Automotive alternators convert mechanical 
energy from a combustion engine into electrical energy that can be used 
to power a vehicle's electrical systems. Alternators inherently place a 
load on the engine, which results in increased fuel consumption and 
CO2 emissions. High efficiency alternators use new 
technologies to reduce the overall load on the engine yet continue to 
meet the electrical demands of the vehicle systems, resulting in lower 
fuel consumption and lower CO2 emissions. Some comments on 
EPA's proposed rule for GHG standards for the 2016-2025 model years 
suggested that EPA provide a credit for high-efficiency alternators on 
the pre-defined list in the regulations. While EPA agreed that high-
efficiency alternators can reduce electrical load and reduce fuel 
consumption, and that these impacts are not seen on the emission test 
procedures because accessories that use electricity are turned off, EPA 
noted the difficulty in defining a one-size-fits-all credit due to lack 
of data.\5\ FCA proposes a methodology that would scale credits based 
on the efficiency of the alternator; alternators with efficiency (as 
measured using an accepted industry standard procedure) above a 
specified baseline value could get credits of 0.14 grams/mile per 
percent improvement in alternator efficiency. This methodology is 
similar to that proposed by Ford and published for comment in June of 
2017, as well as that proposed by GM in this Federal Register 
notice.\6\ Details of the testing and analysis can be found in the 
manufacturer's application.
---------------------------------------------------------------------------

    \5\ See 77 FR 62730, October 15, 2012.
    \6\ See 82 FR 27819, June 19, 2017.
---------------------------------------------------------------------------

2. Active Engine Warm-Up and Active Transmission Warm-Up
    Using the alternative methodology approach discussed above, FCA is 
applying for credits for model years prior to 2014, and thus prior to 
when the list of default credits became available. FCA has applied for 
off-cycle credits using the alternative demonstration methodology 
pathway for active transmission warmup and active engine warmup. EPA 
has already approved credits for these technologies for model years 
prior to 2014.\7\ FCA's request is consistent with previously approved 
methodologies and credits. The application covers active engine warmup 
used in 2011-2013 model year vehicles, and active transmission warmup 
used in 2013 model year vehicles. These technologies are described in 
the predetermined list of credits available in the 2014 and later model 
years. The methodologies described by FCA are consistent with those 
used by EPA to establish the predetermined list of credits in the 
regulations, and would result in the same credit values as described in 
the regulations, as shown in the table below:
---------------------------------------------------------------------------

    \7\ ``EPA Decision Document: Off-cycle Credits for Fiat Chrysler 
Automobiles, Ford Motor Company, and General Motors Corporation.'' 
Compliance Division, Office of Transportation and Air Quality, U.S. 
Environmental Protection Agency. EPA-420-R-15-014, September 2015.

------------------------------------------------------------------------
                                             Off-cycle       Off-cycle
               Technology                  credit--cars   credit--trucks
                                           (grams/mile)    (grams/mile)
------------------------------------------------------------------------
Active transmission warm-up.............             1.5             3.2
Active engine warm-up...................             1.5             3.2
------------------------------------------------------------------------

3. Variable Crankcase Suction Valve Technology in Denso AC Compressors
    Using the alternative methodology approach discussed above, FCA is 
applying for credits for an air conditioning compressor manufactured by 
Denso that results in air conditioning efficiency credits beyond those 
provided in the regulations. This request is for the 2019 and 
subsequent model years. This compressor, known as the Denso SAS 
compressor, improves the internal valve system within the compressor to 
reduce the internal refrigerant flow necessary throughout the range of 
displacements that the compressor may use during its operating cycle. 
The addition of a variable crankcase suction valve allows a larger mass 
flow under maximum capacity and

[[Page 15385]]

compressor start-up conditions (when high flow is ideal), and then it 
can reduce to smaller openings with reduced mass flow in mid- or low-
capacity conditions. The refrigerant exiting the crankcase is thus 
optimized across the range of operating conditions, reducing the 
overall energy consumption of the air conditioning system. EPA first 
approved credits for General Motors (GM) for the use of the Denso SAS 
compressor in 2015,\8\ and has subsequently approved such credits for 
BMW, Ford, and Hyundai.\9\
---------------------------------------------------------------------------

    \8\ ``EPA Decision Document: Off-cycle Credits for Fiat Chrysler 
Automobiles, Ford Motor Company, and General Motors Corporation.'' 
Compliance Division, Office of Transportation and Air Quality, U.S. 
Environmental Protection Agency. EPA-420-R-15-014, September 2015.
    \9\ EPA Decision Document: Off-cycle Credits for BMW Group, Ford 
Motor Company, and Hyundai Motor Company.'' Compliance Division, 
Office of Transportation and Air Quality, U.S. Environmental 
Protection Agency. EPA-420-R-17-010, December 2017.
---------------------------------------------------------------------------

    The credits calculated for the Denso SAS compressor would be in 
addition to the credits of 1.7 grams/mile for variable-displacement A/C 
compressors already allowed under EPA regulations.\10\ However, it is 
important to note that EPA regulations place a limit on the cumulative 
credits that can be claimed for improving the efficiency of A/C 
systems. The rationale for this limit is that the additional fuel 
consumption of A/C systems can never be reduced to zero, and the limits 
established by regulation reflect the maximum possible reduction in 
fuel consumption projected by EPA. These limits, or caps, on credits 
for A/C efficiency, must also be applied to A/C efficiency credits 
granted under the off-cycle credit approval process. In other words, 
cumulative A/C efficiency credits for an A/C system--from the A/C 
efficiency regulations and those granted via the off-cycle 
regulations--must comply with the stated limits.
---------------------------------------------------------------------------

    \10\ See 40 CFR 86.1868-12.
---------------------------------------------------------------------------

    FCA is requesting an off-cycle GHG credit of 1.1 grams 
CO2 per mile for the Denso SAS compressor. FCA cited the 
bench test modeling analysis referenced in the original GM application, 
which demonstrated a benefit of 1.1 grams/mile. Like other 
manufacturers, FCA also ran vehicle tests using the AC17 test. Eight 
tests were conducted on a 2014 Dodge Charger, resulting in a calculated 
benefit of 3.16 grams/mile, thus substantiating the bench test results. 
Based on these results, FCA is requesting a credit of 1.1 grams/mile 
for all FCA vehicles equipped with the Denso SAS compressor with 
variable crankcase suction valve technology, starting with 2019 model 
year vehicles. Details of the testing and analysis can be found in the 
manufacturer's application.

B. Toyota Motor North America

    Toyota Motor North America (Toyota) is requesting GHG credits for 
alternators with improved efficiency relative to a baseline alternator. 
This request is for the 2017 and later model years. Automotive 
alternators convert mechanical energy from a combustion engine into 
electrical energy that can be used to power a vehicle's electrical 
systems. Alternators inherently place a load on the engine, which 
results in increased fuel consumption and CO2 emissions. 
High efficiency alternators use new technologies to reduce the overall 
load on the engine yet continue to meet the electrical demands of the 
vehicle systems, resulting in lower fuel consumption and lower 
CO2 emissions. Some comments on EPA's proposed rule for GHG 
standards for the 2016-2025 model years suggested that EPA provide a 
credit for high-efficiency alternators on the pre-defined list in the 
regulations. While EPA agreed that high-efficiency alternators can 
reduce electrical load and reduce fuel consumption, and that these 
impacts are not seen on the emission test procedures because 
accessories that use electricity are turned off, EPA noted the 
difficulty in defining a one-size-fits-all credit due to lack of 
data.\11\ Toyota proposes a methodology that would scale credits based 
on the efficiency of the alternator; alternators with efficiency (as 
measured using an accepted industry standard procedure) above a 
specified baseline value could get credits of 0.1 to 2.0 grams/mile 
depending on the overall improvement in alternator efficiency. This 
methodology is similar to that proposed by Ford and published for 
comment in June of 2017.\12\ Details of the testing and analysis can be 
found in the manufacturer's application.
---------------------------------------------------------------------------

    \11\ See 77 FR 62730, October 15, 2012.
    \12\ See 82 FR 27819, June 19, 2017.
---------------------------------------------------------------------------

III. EPA Decision Process

    EPA has reviewed the applications for completeness and is now 
making the applications available for public review and comment as 
required by the regulations. The off-cycle credit applications 
submitted by the manufacturers (with confidential business information 
redacted) have been placed in the public docket (see ADDRESSES section 
above) and on EPA's website at https://www.epa.gov/vehicle-and-engine-certification/compliance-information-light-duty-greenhouse-gas-ghg-standards.
    EPA is providing a 30-day comment period on the applications for 
off-cycle credits described in this notice, as specified by the 
regulations. The manufacturers may submit a written rebuttal of 
comments for EPA's consideration, or may revise an application in 
response to comments. After reviewing any public comments and any 
rebuttal of comments submitted by manufacturers, EPA will make a final 
decision regarding the credit requests. EPA will make its decision 
available to the public by placing a decision document (or multiple 
decision documents) in the docket and on EPA's website at the same 
manufacturer-specific pages shown above. While the broad methodologies 
used by these manufacturers could potentially be used for other 
vehicles and by other manufacturers, the vehicle specific data needed 
to demonstrate the off-cycle emissions reductions would likely be 
different. In such cases, a new application would be required, 
including an opportunity for public comment.

    Dated: March 23, 2018.
Byron Bunker,
Director, Compliance Division, Office of Transportation and Air 
Quality, Office of Air and Radiation.
[FR Doc. 2018-07356 Filed 4-9-18; 8:45 am]
BILLING CODE 6560-50-P

Connect with The Crittenden Automotive Library

The Crittenden Automotive Library at Google+ The Crittenden Automotive Library on Facebook The Crittenden Automotive Library on Instagram The Crittenden Automotive Library at The Internet Archive The Crittenden Automotive Library on Pinterest The Crittenden Automotive Library on Twitter The Crittenden Automotive Library on Tumblr  
 
 


The Crittenden Automotive Library

Home Page    About Us    Contribute