Greenhouse Gas Emissions Standards
                 and Fuel Efficiency Standards for
                 Medium- and Heavy-Duty Engines
                 and Vehicles

                 Implementation Workshop
                 Second 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 the answers EPA has completed to date to the
                 questions submitted by industry before, during and after the November 3, 2011 work-
United States
Environmental Protection
Office of Transportation and Air Quality
                  January 2012

           shop. This 2nd Edition includes most of the remaining Aerodynamic drag questions submitted
           by the industry. Note that some questions have been re-ordered to group questions on similar
           topics together as much as possible. The agencies intend to update this document on a regular
           basis as the answers to additional questions 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 answer 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,

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
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/

        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
         - (202) 343-9292
                  Navistar/International, Fiat Powertrain, Mitsubishi Fuso
                  Manufacturers new to certification should contact Greg for assignment of a
                  certification representative,

                  Jason Gumbs - Certification representative
         (202) 343-9271
                  Detroit Diesel/Daimler Trucks, Volvo (P/T & trucks)

                  Jay Smith - Certification representative
         - (734) 214-4302
                  PACCAR, Ford,  GM, Cummins, Isuzu
       Who will review and approve each portion of the certification data, both in the pre-certification
       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 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 Re-
       quest 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

           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.
           FEL vs. FCL
           The morning presentation stated that the FCL is used for certification and for credits, while
^•^        the FEL is used for audit purposes and in use testing.

               O*  1037.615 (e) calculate CO2 credits using FEL for electric vehicles,
               •  1037.705 (b) calculate CO2 credits using FEL
               •  1036.801: says FCL is used for CO2 and FEL is used for other emissions,
                   except CO2 and for CO2 FEL=FCL* 1.03

(1 J        Please clarify?

           The Family Certification Level (FCL) only applies for CO2 for Engines as described in
    J      40CFR1036.108 and 1036.801. Vehicle manufacturers should use the Family Emission Limit
   *      (FEL) as described in 1037.801.

           Product/Planning: What timing requirements does the agency anticipate HD GHG certifica-
           tion reviews will require for (1) Engines, (2) Vehicles? Since 1997, Engine certification has
           gone from 2-3 pages and a few days to , today, several hundreds of pages (both emissions and
           OBD) with multiple agency review (EPA/CARB) taking several months to get approvals.
           How many pages (or reams) does the EPA anticipate a vehicle certification application will
           be? And how long for EPA to review them?

           The manufacturer will need to fill out certification templates and provide the requested support-
           ing documentation. Length of the application package will be dependent upon complexity of
           emission control strategies (e.g., AECDs) or alternative test procedures used by the manufacturer.
           For a complete application (assuming that all preliminary approval items have already been
           resolved), a manufacturer can typically plan for at least 30-45 days after submitting the applica-
           tion. Incomplete applications can delay the processing time further.
           Model Year End Date: When do OEMs need to tell EPA of the actual end date of a model
           year versus the projected end date that is put on the certification worksheet?

           For purposes of meeting reporting obligations, end of model year is considered December 31st,
           If a manufacturer ends their production period earlier then December 31st, they should include
           the information in their end of year production reports.
           Does EPA have a guidance document site similar to the Applicability Determination Index
           for Stationary Source Regulations (NSR, PSD, MAIT, NSPS), but for Part 85, 86, 1036,
           1037 (mobile source ADI site). If not are there plans to establish one?



           No specific questions concerning HD Pickups and Van have been completed to date. See general

           No specific questions concerning HD Engines have been completed to date. See general questions,
           What level of detail must be reported to EPA with respect to the OEM definition of Vocational

           Will we get separate vehicle certificates and engine certificates?

           For class 2b/3 complete vehicles you will receive a vehicle certificate based on complete ve-
           hicle testing. For 2b-8 incomplete vehicles you will receive a vehicle certificate based on chas-
           sis 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
           program, 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.
What data is needed to approve early families? Vehicle Cert Label, GEM confirmation, etc ...?
What data to support GEM Outputs must be submitted? How much back-up data is required
to confirm GEM output?

Before submitting applications for certificate; it is recommended that each manufacturer directly
contact its certification representative to discuss those issues for which it needs EPA approval.
Note that while §1037.30 directs manufacturers to submit all reports and requests for approval
to EPA's designated compliance officer (DCO), the DCO has instructed that each manufacturer
go directly to its EPA certification representative to arrange to submit and discuss all informa-
tion required to facilitate the agency's approval process. It is highly recommended that this be
done early to give sufficient time for granting approvals and to avoid wasted application work
and testing.

Section 1037.205 and the certification application template provided by EPA will identify all
information and data the manufacturer must submit at the time of application. §1037.150 and
§535.5(b)(2) and (c)(2) provide guidance specifically for approving early families. The manu-
facturer is responsible to review the reporting requirements and recordkeeping requirements in
the regulations (including 40CFR1037.250, 730, 735 and 825; and 49CFR535.8) to assure it
has submitted all required information not identified by the template. Typically these additional
documents are submitted in .pdf or other secure format. The manufacturer is also required to
keep any backup data and information necessary to support the data and information submitted
during application submission.
           Aerodynamic drag data - all evaluations cannot be completed in time for cert application
           submission or new variants or models are anticipated or in process but we cannot generate
           final aero assessment. As a result, will EPA allow placeholder information for Aerodynamic
           drag data during the certification process if it is updated during the course of the model year?
           The new data would be used for year-end and final compliance  reporting. If so, what process
£1 J        will be used? Does all info need to be in before Certificate is issued? Can there be gaps in
           Aerodynamics data? Is there an opportunity to update information? Do we need to supply
           the CdA test on our GEM  input file if we already supply the Bin? (bins are easy to calculate
    J      for every vehicle, but CdA's are difficult)

Manufacturers have expressed concern that the time needed to secure approval for alternative
aerodynamic demonstration methods and generate the needed data will cause delay in certifica-
tion of vehicle families before the 2014 model year. While application data using manufacturer
selected FELs and projected production figures can be used by the agencies as an indicator of
what to expect, no final compliance determination or final credit determination can be estab-
lished until the end of the model year and would have to be based on actual vehicle configura-
tions and production data.

Therefore, for manufacturers wishing to certify vehicle families for the 2013 model year, where
a manufacturer can use existing aerodynamic data and good engineering judgment to establish
reasonable bin assignments for all of its vehicle families, but has insufficient time to generate
the necessary data through coastdown and alternate methods before the model year production
begins, EPA can apply §1037.521 which allows manufacturers to determine drag area using an
alternate method, and §1066.10(c) which states, "...We [EPA] may allow or require you to use
procedures other than those specified in this part for laboratory testing, field testing, or both, as
described in 40 CFR 1065.10(c).... If we require you to request approval to use other procedures
under this paragraph (c), you may not use them until we approve your request."

EPA has determined that, for vehicle families that a manufacturer chooses to certify for the 2013
model year, should a manufacturer require additional time to generate all the required data, we
will allow the manufacturer to submit,  as part of its application, any data and/or information
that they have and their rationale showing that good engineering judgment assures their vehicle
configuration assignments to Aerodynamic Bins for all their GEM model runs are accurate. If
EPA agrees with the manufacturer's assessment as submitted, we can approve the certification

Therefore, for 2013 model year vehicle families, manufacturers will not be required to generate
all data before receiving their certificate.  However, manufacturers using this approach will be
required to  carry out the requisite testing during the model year, such that all required data is
reported to EPA in the end-of-year report, at which time any early credits earned will be allocated.
Since no credit deficits can be generated in model year 2013, there is no risk to the environment
should testing not be completed; credits would simply not be earned by the manufacturer. While
§1066.10(c) states that we may allow you to continue to use this process beyond the 2013
model year, it is our expectation that this will be unnecessary in model year 2014 and beyond
because, as just explained, manufacturers will have established test programs that allow them to
generate the required data. The agencies  expect manufacturers to have sufficient aerodynamic
data to perform and submit the GEM inputs and outputs at the time of application for certificates
for model year 2014 and beyond.

For the 2014 model year and beyond, there are minimum  test data requirements to run the
GEM model, using the direction in §1037.520 and §1037.521. Per §1037.205(o), at the time
the manufacturer  applies for certification, it is required to submit GEM assessments from 10
unique GEM configurations. It is required to  include configurations with the best CO2 emissions,
worst CO2 emissions, and 8 additional  GEM runs that should include a configuration represent-
ing the highest projected sales volumes. The manufacturer must have sufficient aerodynamic
data to support these GEM runs.


  V <«.
                If manufacturers must meet the 10 GEM run requirement using configurations that,
                based upon good engineering judgment, are substantially aerodynamically equivalent,
                they may base the Cd input for GEM on the same aerodynamic testing/assessment.
                If manufacturers prefer to use an alternative aerodynamics test method, they must test a
                vehicle over both the coastdown test method and the alternative test method preferred
                by the manufacturer (e.g., wind tunnel testing, computational fluid dynamic modeling or
                constant speed road load testing) to generate its correction factor. The manufacturer can
                then make alternative method assessments that have been corrected back to the coast-
                down «baseline» method using this correction factor in lieu of additional coastdown test-
                ing. §1037.521 (c) states, "You  must obtain preliminary approval before using any meth-
                ods other than coastdown testing to determine drag coefficients. Send your request for
                approval to the Designated Compliance Officer [DCO]." Again, the DCO has instructed
                that you send your request for approval directly to your EPA certification representative.
                If manufacturers determine that a new sub-family is warranted during a model year, then
                they must file a running change including all relevant test data.
         What is the approval process for a manufacturer to request an Alternative Aerodynamic
         Demonstration procedure?

         A request to EPA to use an alternative aerodynamic method should include the following:

            •   You (the certificate requestor) should first contact your certification representative
                (as delegated by EPA's DCO) to state your intention to request use of an Alternative
                Aerodynamic Demonstration procedure. At this point, you should provide a technical
                description of your proposed alternate method and your plan for validating this method
                against coastdown testing,
            •   Per §1037.521, you must obtain preliminary approval before using any method other
                than coastdown testing, and describe how to adjust the drag area provided by the al-
                ternative  test method to be equivalent to the corresponding drag area that would have
                been measured using the coastdown procedure. You must keep records of the information
                specified in §1037.521 (c) and unless directed otherwise, include this information with
                your request for approval to the DCO. In this case, the DCO has instructed that you
                send your request for approval, to your assigned certification representative,
            •   Your certification representative will convene appropriate EPA staff to provide technical
                support in evaluation of the proposed alternative aerodynamic test method,
         What level of detail will EPA require for vehicle height data and calculation for Regulatory
         Subcategory determination?
-~        You must keep records of these and other relevant certification data and calculations per EPA
         Reporting and Recordkeeping requirements provided in 40CFR1037.825 as well as NHTSA
         Reporting Requirements provided in 49CFR535.8(h). However, with regards to what needs
         to be submitted in the certification application, it will be sufficient to identify your vehicle as
         either a high, low, or mid roof tractor. Manufacturers must determine the roof height of tractors
         in accordance with § 103 7.801.

           For determining Low and Mid-roof aero relative to §1037.520 (b)(3), the bin for the low
           and mid-roof sleepers is assigned "based on the drag area bin of an equivalent high-roof trac-
           tor". The question is, does an "equivalent high-roof tractor" mean:

               1.  Pick one model/high-roof sleeper configuration to represent the entire family (Model
                  386 with 70" sleeper is used for all other model and sleeper combinations), or
              2.  Pick one high-roof sleeper configuration to represent the entire model within the
                  family (70" sleeper is used for all other sleeper lengths on the Model 386), or
              3.  Use the high-roof sleeper version of the low or mid-roof  sleepers on each model for
                  determining low and mid-roof aero bin (70" sleeper on Model 386 is used only for
                  the 70" low and mid-roof sleepers on Model 386 tractors)?

           Use the higlvroof sleeper version of the low or mid-roof sleepers on each model for determining
           low and mid-roof aero bin (70" sleeper on Model 386 is used only for the 70" low and mid-roof
           sleepers on Model 386 tractors).
           Will EPA need to witness coastdown testing?

           No. However, the manufacturer may want to submit its coastdown test plan to its certification
           representative prior to testing,
           §1037.140 requires nominal design roof heights to be included on the door label. This
           section notes using the average of the smallest and largest tires offered for the model in the
           calculation. Is the same approach to be used for rear suspension heights, frame rail section/
           height, and cab mounting heights?

           §1037.140 does not require any labeling for the exact roof heights and/or weights. §1037.135(c)
           (4) requires that the regulatory subcategory be included on the label (e.g., "Class 8 High Roof
           Sleeper Cab"). The manufacturer should consult the definition of "Roof Height" in §1037.801
           for selection of the appropriate regulatory subcategory,
           Refined definitions for Emission Control System description codes for door label for Aerody-
           namic Components:

              •   ATS: does an under cab fairing only qualify, or does it take a mid-chassis section also, or
                  if it full fairings only (wheel-to-wheel) ? How do full fairings on one side and partial fair-
                  ings on the other fit in (leaving open space for an APU)?
              •   TGR: how long does the gap reducing fairing need to be to qualify or does it just need to
                  exist per OEM definition?
ft\           •   ARF: Does a full height sleeper roof require this code or is it just for add on fairings?

           §1037.135(c)(6) requires that manufacturers include the label identifier abbreviation for all
    J      vehicle emission control components they use in or on their vehicles as specified in Appendix
           III to Part 1037 — Emission Control Identifiers. Since the intent of these identifiers is to provide


inspectors with a means for simply verifying the presence of a component, we do not believe
overly detailed identifiers are necessary, particularly for tires and aerodynamic components. We
believe that identifying tires and aerodynamic components in a general sense will prove similarly
effective in determining if a vehicle has been built as intended or if it has been modified prior to
being offered for sale. Please contact your certification representative if you do not find a suitable
label identifier for your chassis emission control system in Appendix III,
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
   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 establishing
       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 manu-
       facturers 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). 1 037.5 20(c)(l) 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 the next question and
       answer 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