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Alternative Methods for Calculating Off-Cycle Credits Under the Light-Duty Vehicle Greenhouse Gas Emissions Program: Application From American Honda Motor Company


American Government Topics:  Honda

Alternative Methods for Calculating Off-Cycle Credits Under the Light-Duty Vehicle Greenhouse Gas Emissions Program: Application From American Honda Motor Company

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]
BILLING CODE 6560-50-P




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