Alternative Methods for Calculating Off-Cycle Credits Under the Light-Duty Vehicle Greenhouse Gas Emissions Program: Application From American Honda Motor Company |
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Topics: Honda
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Mary Manners
Environmental Protection Agency
20 August 2020
[Federal Register Volume 85, Number 162 (Thursday, August 20, 2020)]
[Notices]
[Pages 51428-51430]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2020-18207]
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ENVIRONMENTAL PROTECTION AGENCY
[EPA-HQ-OAR-2020-0404; FRL 10013-80-OAR]
Alternative Methods for Calculating Off-Cycle Credits Under the
Light-Duty Vehicle Greenhouse Gas Emissions Program: Application From
American Honda Motor Company
AGENCY: Environmental Protection Agency (EPA).
ACTION: Notice.
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SUMMARY: The Environmental Protection Agency (EPA) is requesting
comment on an application from Honda Motor Company (``Honda'') 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. Honda has
submitted an application that describes a methodology for determining
off-cycle credits from technologies described in their application.
Pursuant to applicable regulations, EPA is making this off-cycle credit
calculation methodology available for public comment.
DATES: Comments must be received on or before September 21, 2020.
ADDRESSES: Submit your comments, identified by Docket ID No. EPA-HQ-
OAR-2020-0404, 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 Once submitted, comments cannot be edited or withdrawn.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: Linc Wehrly, Office of Transportation
and Air Quality, Compliance Division, U.S. Environmental Protection
Agency, 2000 Traverwood Drive, Ann Arbor, MI 48105. Telephone: (734)
214-4286. Fax: (734) 214-4869. Email address: wehrly.linc@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
[[Page 51429]]
requirements, if 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 to
demonstrate reductions that exceed those available via use of the
predetermined list.
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\1\ See 40 CFR 86.1869-12(b).
\2\ See 40 CFR 86.1869-12(c).
\3\ See 40 CFR 86.1869-12(d).
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Under the regulations, a manufacturer seeking to demonstrate off-
cycle credits 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.
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\4\ See 40 CFR 86.1869-12(d)(2).
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II. Off-Cycle Credit Application: GHG Credit for Cold Storage
Evaporator
Using the alternative methodology approach discussed in their
application, Honda is applying for credits for all 2017 model year and
later Honda and Acura vehicles for a cold storage evaporator system
that results in idle start-stop credits beyond those provided in the
regulations. Honda's cold storage evaporators utilize a paraffin wax
material in the evaporator tank to sustain the evaporator's ability to
absorb heat from the cabin air when the engine is shut off,
consequently maintaining cooler air temperature and cabin comfort for a
longer period of time during engine shutoff as compared to the shorter
comfort period provided by a non-cold storage evaporator. The concept
behind this strategy is similar to the use of alternative passenger
warming technologies that maintain driver comfort longer during engine
off events at cold ambient temperatures in order to delay engine
startups for cabin heating. In particular, at ambient temperatures
where air conditioning is used for cooling the cabin, Honda's cold
storage evaporator implementation aims to reduce A/C compressor and
engine use during both extended engine off vehicle stops and multiple
short stops while also increasing the ambient temperature threshold
above which the idle start-stop system is disabled in order to maintain
cabin comfort.
Honda has provided a methodology for and test data from two
different types of operational test conditions--extended stops and
multiple stops--as well as an alternative calculation method that
yields higher credit values than the primary method. Using the lower
values from the primary evaluation and calculations, Honda is
requesting EPA approval of an off-cycle GHG credit of 1.0 grams
CO2 per mile for the Cold Storage Evaporator equipped in MY
18-19 Honda Odyssey, 1.2 g/mile for the MY 17-19 Honda Pilot and Acura
MDX & MY 19 Honda Passport AWD, 1.0 g/mi for the MY 19 Acura RDX AWD,
0.7 g/mi for MY 19 Honda Passport FWD and 0.6 g/mi for MY 17-19 Acura
TLX & MY 19 Acura RDX FWD.
EPA has previously approved credits determined by alternative GHG
credit calculation methods for idle start-stop systems for both
Mercedes and Hyunda-Kia. Details of the methodology, testing and
analysis can be found in Honda's application.
III. EPA Decision Process
EPA has reviewed the application for completeness and is now making
the application available for public review and comment as required by
the regulations. The off-cycle credit application submitted by Honda
(with confidential business information redacted) has 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 application for
off-cycle credits described in this notice, as specified by the
regulations. The manufacturer 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 request. EPA will make its decision available to
the public by placing a decision document in the docket and on EPA's
website at the same manufacturer-specific page shown above. While the
broad methodologies used by Honda could potentially be used for other
vehicles and by other manufacturers,
[[Page 51430]]
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: August 14, 2020.
Mary Manners,
Acting Director, Compliance Division, Office of Transportation and Air
Quality, Office of Air and Radiation.
[FR Doc. 2020-18207 Filed 8-19-20; 8:45 am]
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