Greenhouse Gas Emissions Standards
and Fuel Efficiency Standards for
Medium- and Heavy-Duty Engines
and Vehicles
Implementation Workshop
First Edition
The Environmental Protection Agency (EPA) along with the
Department of Transportation's National Highway Traffic
Safety Administration (NHTSA) organized and sponsored an
implementation workshop in Ann Arbor, MI on November 3, 2011.
The objective of this workshop was to provide guidance to heavy-
duty (HD) engine and vehicle manufacturers who wish to exercise
the option for early compliance under new greenhouse gas (GHG)
and fuel consumption (EC) regulations (see 76 FR 57106) for model
year 2013 products. By so doing, manufacturers are able to secure
early credits which will enable a more efficient phase-in of compliant
products and, by so doing, will provide cleaner and more fuel efficient
technologies to the marketplace sooner.
The HD GHG and FC Implementation Workshop included a number of presenta-
tions describing the processes manufacturers would need to follow to certify vehicles
and technologies, test certified products, exercise available compliance flexibilities
and report information to the agencies. During the course of the workshop, questions
were submitted to the EPA/NHTSA panel on note cards from the audience. Agency
representatives answered a number of technical questions during the workshop.
This document contains a record of: 1) answers given to those technical questions
during the workshop which are included in this document to provide a complete
SEPA
United States
Environmental Protection
Agency
Office of Transportation and Air Quality
EPA-420-F-11-042
December 2011
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record of our positions with respect to implementation of this rule, and; 2) answers to several
additional questions that went unanswered at the workshop due to time constraints. Answers
to the remaining questions are not included in this first update since the workshop. The agen-
cies intend to update this document on a regular basis as the answers to these additional ques-
tions are developed and as new questions that continue to come in over time are received and
answered. Finally, wherever possible, when many questions are received that warrant the same
answer, we have listed all these questions together under one question number in order to an-
swer them once.
This document was prepared by EPA's Office of Transportation and Air Quality (OTAQ) with
input from NHTSA. Regulated parties may use this document to aid in achieving compliance
with the regulations for heavy-duty vehicles (40 CFR Part 86, 1037; and, 49 CFR Part 523,534
and 535) and heavy-duty engines (40 CFR Part 1036; and, 49 CFR Part 523, 534 and 535).
However, this document does not in any way alter the requirements in EPA's or NHTSA's regu-
lations. Although the answers provided in this document interpret the regulations and indicate
general plans for implementation of the regulations at this time, some of the responses may
change as additional information becomes available, or as the agencies further consider certain
issues. The questions and answers contained in this document do not establish or change the
legal rights or obligations of manufacturers in complying with EPA and NHTSA regulations.
Further, this document does not establish binding rules or requirements and is not fully determi-
native of the issues addressed. Moreover, Agency decisions in any particular case will be made
applying the law and regulations on the basis of specific facts.
GENERAL:
What is the anticipated timeline to get early certification?
Manufacturers should begin now collecting data and information required to submit a complete
application for certification, carry out pre-certification meetings with the agencies and begin the
application process. If manufacturers have prepared complete applications, EPA and NHTSA
will be ready to conduct application reviews and possibly issue certificates by the first quarter of
calendar year 2012,
When will the Designated Compliance Officer (DCO) be named?
Per 1037.801, the DCO is defined as the manager of the Heavy-Duty and Nonroad Engine
Group. Due to a recent reorganization of EPA's Office of Transportation and Air Quality, the
name of the Heavy-Duty and Nonroad Engine Group has been changed to the Diesel Engine
Compliance Center. The manager of the Diesel Engine Compliance Center is the DCO. The
fl) current DCO, Justin Greuel, can be reached at 202-343-9626. Each engine/truck manufacturer
is assigned an EPA certification representative in the Diesel Engine Compliance Center who
should be your first line of contact with EPA,
For 2b/3 Pick Ups and Vans, the certification representative is the same assigned for your LDV/
LDT/MDPVs.
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For HD Engines, the certification representative is the same assigned for your criteria pollution
engine certification.
For Combination Tractors and Vocational Vehicles, your assigned certification representative is
as follows:
Greg Orehowsky - Team leader and Certification Representative
Orehowsky.gregory@epa.gov - (202) 343-9292
Navistar/International, Fiat Powertrain, Mitsubishi Fuso
Manufacturers new to certification should contact Greg for assignment of a certifica-
tion representative
Jason Gumbs - Certification representative
Gumbs.jason@epa.gov- (202) 343-9271
Detroit Diesel/Daimler Trucks, Volvo (P/T & trucks)
Jay Smith - Certification representative
Smith.jay@epa.gov - (734) 214-4302
PACCAR, Ford, GM, Cummins, Isuzu
Who will review and approve each portion of the certification data, both in the pre-certifica-
tion meeting and in the application?
The review process for pre-certification and certification application review will be handled by
various agency staff with your assigned certification representative as the focal point. Technical
experts within EPA and NHTSA will be used for various aspects of the review process as needed
(e.g., aerodynamics and tire consultation).
When will EPA be ready to provide certification templates?
Templates have been reviewed at the Certification Workshop. These templates will be posted to
epa.gov/otaq/certdat2.htm as soon as the HD GHG Information Collection Request is approved
by the Office of Management and Budget,
When will EPA be ready to receive certification documents from OEMs?
Certification documents using the new templates can be submitted at any time after templates
are posted. Posting will occur as soon as the HD GHG Regulation Information Collection
ft\ Request is approved by the Office of Management and Budget,
J Will there be fees? What will the GHG certification fees be for engines and vehicles and
hybrids?
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The Heavy Duty Greenhouse Gas Rule does not establish new fees. Thus, OEMs of HD engines
and pickup trucks/vans will continue to pay a fee for criteria pollutant certification, but at this
time there are no new fees associated with certification to heavy duty greenhouse gas standards,
A consequence is that OEMs of vehicles not subject to criteria pollutant certification require-
ments (i.e., vocational chassis, combination tractors, and Class 4 & 5 certifying as HD Pickups/
Vans) do not pay certification fees.
What system, if any, will be used for submission of early certification and future certification
applications and supporting data?
The early credit certification will be done using FileMaker Pro for engines. Minor revisions to
the engine FileMaker Pro templates will accommodate engine GHG certification data. New
Excel'based templates for HD Pickups/Vans, Combination Tractors and Vocational Vehicles
have been created. Certification information for all sectors will be submitted using the Central
Data Exchange (CDX) system.
Will EPA provide templates for certification documentation and support data?
Yes. Certification application templates will be provided. However, be sure to discuss this with
your Certification Representative as some support documentation may need to be provided to
EPA through the CDX in ,pdf or similar format,
What level of detail will EPA require for each aspect/topic that requires data?
The templates will define the information you need to provide to EPA and NHTSA to comply
with regulations. To the extent that the templates are unclear to you, we encourage you to work
with your Certification Representative. Manufacturers must also keep the necessary back-up
data and information should EPA require additional information to confirm the submission.
EEL vs. FCL
The morning presentation stated that the FCL is used for certification and for credits, while
the EEL is used for audit purposes and in use testing.
1037.615 (e) calculate CO2 credits using EEL for electric vehicles.
Oğ 1037.705 (b) calculate CO2 credits using EEL
1036.801: says FCL is used for CO2 and FEL is used for other emissions,
except CO2 and for CO2 FEL=FCL*1.03
Please clarify?
The Family Certification Level (FCL) only applies for CO2 for Engines as described in
40CFR1036.108 and 1036.801. Vehicle manufacturers should use the Family Emission Limit
J (FEL) as described in 1037.801.
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In order for a vehicle to be reclassified as a vocational tractor, it must meet the definition
in 40CFR1037.630(a) and 49CFR523.2, meet the requirements in 40CFR1037.630(b) and
49CFR535.5(c)(5), and include the language required to be added to the vehicle's emission con-
trol information label specified in 1037.630(c). In addition, there are production limits for voca-
tional tractors. No manufacturers may produce more than 21,000 vehicles under 1037.630(c) in
any three consecutive model years. No pre-approval is normally required for on-road vocational
tractors. A manufacturer is only required under 1037.630(b) to include in its application for
certification a brief description of its basis for reclassifying certain of its tractors as vocational,
citing the applicable vehicle and application types enumerated in 1037.630(a)(l). As specified
in 1037.630(c), the manufacturer must keep records for three years to document its basis for
believing the vehicles will be used as described in 1037.630(a). In the future, if EPA determines
that a manufacturer is not applying the allowance in good faith, it may require the manufacturer
obtain preliminary approval before using the allowance.
What level of detail must be reported to EPA with respect to the OEM definition of Off
Road Vehicle?
There is no requirement that OEMs obtain approval of off-road status (and consequent exemp-
tion from the vocational vehicle GHG standards). Criteria for meeting this exemption are
found at 40 CFR 1037.631 (a) and 49 CFR 523.2, but the manufacturer must report the basis of
its determination by the end of year, as outlined in 40 CFR 1037.631 (c) and 49 CFR 535.8(h)
(6). However, if the vehicles do not meet the criteria of the definition in the regulation, then
the manufacturer may ask for an exemption according to 40 CFR 1037.150(h) and 49 CFR
535.8(h)(6)(ii). EPA will coordinate approval decisions with NHTSA.
We are a corporation made up of several business units or divisions that all produce voca-
tional vehicles. We have at least two divisions that are final stage manufacturers who produce
their own chassis. Will we be asking for one manufacturer number for the corporation, or
does each division get their own number?
It is normal practice among corporations to use one manufacturer code for all vehicle and engine
products regulated by EPA. Therefore, you should use one manufacturer code to encompass all
your products regulated by EPA. However, let your certification representative know if you think
this approach would be problematic for you.
Likewise, will we average compliance across the corporation for all vocational vehicles, or
does the averaging take place only within a division?
fl) The averaging should take place across the corporate product lines. You may average within the
following three averaging sets:
Light heavy duty vehicle line
Medium heavy duty vehicle line
Heavy heavy duty vehicle line
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In the vocational Subcategory there are many small manufacturers for vehicles but only a
few big tire manufacturers.
a) What is the tire manufacturer's responsibility to provide tire data to the vehicle
manufacturers?
b) What is the procedure if the tire data is not available in a timely manner from
the tire manufacturer?
c) What is EPA's plan to harmonize the data if the same tire shows different
results?
a) The certificate holder (i.e., the vehicle manufacturer) is responsible for establish-
ing agreements with tire manufacturers for the proper collection of tire data to
provide to EPA. According to 1037.650, tire manufacturers providing such data to
vehicle manufacturers are liable for the accuracy and representativeness of the test
data,
b) If the tire manufacturer does not submit tire data to the vehicle manufacturer, the
vehicle manufacturer should make alternate arrangements to develop or obtain
tire data on their own and in accordance with 1037.520(c),
c) EPA has no plan to harmonize tire data, but the agency can conduct confirmatory
testing (e.g., if we observe outlier data from the same tire model). 1037.520(c)
(1) states that tire rolling resistance be measured, "... as specified in ISO 28580
(incorporated by reference in 1037.810), except as specified in this paragraph (c)."
Use good engineering judgment to ensure that your test results are not biased low.
You may ask us to identify a reference test laboratory to which you may correlate
your test results." (See Question 19 for further agency guidance with respect to tire
test laboratories)
Are there Recognized test labs for Tire RR? Has the reference facility for determining tire
rolling resistance per ISO28580 been determined?
At this time, EPA and NHTSA are unaware of any laboratories with a reference machine that
has been certified specifically for use with the ISO 28580 test protocol. However, EPA and
NHTSA have test results showing that two independent tire testing laboratories in the United
States, Smithers-Rapra and Standards Testing Laboratory, have tire rolling resistance test ma-
chines that correlate well to each other. Both these independent laboratories have been used
by the federal government and by industry to conduct tire testing for other federally-mandated
programs. Therefore, until ISO certified tire machines are available, should a vehicle manufac-
turer request a test laboratory to which it may correlate its test results, EPA will accept tire data
generated by or correlated to either of these two laboratories. In addition, should EPA decide to
confirm or compliance test tires so certified, EPA will use one of these two laboratories for the
testing.
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Will we get separate vehicle certificates and engine certificates?
For class 2b/3 complete vehicles you will receive a vehicle certificate based on complete vehicle
testing. For 2t>8 incomplete vehicles you will receive a vehicle certificate based on chassis
modeling. For class 7'8s tractors/vocational vehicles you will receive a vehicle certificate based
on chassis modeling. For engines in vehicles not included in the 2b/3 complete vehicle pn>
gram, which are subject to the engine provisions, you will receive an engine certificate based
on engine testing. If you are the manufacturer of both the engine and the chassis, and intend to
certify as a vocational vehicle, you will receive an engine certificate based on engine testing and
a vehicle certificate based on chassis modeling.
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