Light-Duty Greenhouse Gas: Manufacturer Questions and EPA Answers


              Light-Duty Greenhouse Gas
&EPA
United States
Environmental Protection
Agency
Office of Transportation and Air Quality
            EPA-420-F-12-005
              January 2012

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Issue
No.
Subject
Regulation Reference
DRAFT Liqht-dutv Greenhouse Gas - Manufacturer Questions and EPA Answers - January 2012

Regulation
Issue
Manufacturer Questions
EPA Answers

1. Application for Certification
1.1
1.2
Application for
Certification -
Listing part
numbers in the
Par 2
Application
Application for
Certification -
Listing GHG
AECDs in the
Part 1 Application
86.1844-01(e)(1)
86.1803-01

For criteria pollutants,
manufacturers are required to list
AECDs in the Part I application.
Manufacturers are required to list
part numbers of emission related
components in the Part II
application. Manufacturers are
required to cover these AECDs
under the defect warranty.
Should the following components be listed on the
emission related parts list (Part 2 application) for future
MY vehicles due to GHG regulation?
• A/C system (including all sensors and actuators)
• Actuator of flexible aerodynamic devices
• Sensors and actuators of a cyclinder deactivation
system
• Components of an engine idle start/stop system
What is EPA's policy regarding AECD classification for
GHG?
For 201 2 and later model years, part numbers of GHG emission-related components
and AECDs used to comply with CO2 (CREE), CH4, N2O emission standards are
required to be listed in the Part 2 application; ref. 86.1844-01(e). For 2009-2011 model
years, manufacturers may include part numbers of GHG emission-related components
and AECDs in the early credit report required by 86.1 867-1 2(e), in lieu of including part
numbers in the 2009-201 1 Part 2 applications. Manufacturers may reference the
service manual of the vehicle in lieu of listing part numbers for sensors and actuators
for A/C systems, cylinder deactivation systems, stop-start systems, etc. provided the
system is listed in the applicable Part 2 application or early credit report. Note that the
service manual is required to be contained in the Part 2 application per 86.1844-
01(e)(5).
Auxiliary emission control devices (AECDs) are not discussed in the preamble
to the GHG final rule or the Response to Comments document. Manufacturers
should use good engineering judgment to determine which design elements for
greenhouse gas control meet the definition of an AECD outlined in 86.1803.
See EPA answer to question 1.1, above, for additional information about listing
part numbers of emission-related components and AECDs in the Part 2
application.
2. Credits - A/C Efficiency
2.1
2.2
2.3
A/C Efficiency
Credits - A/C Idle
Test
A/C Efficiency
Credits - A/C Idle
Test
A/C Efficiency
Credit
Calculation
86.165-12
86.165-12(d)(4)
86.1866-12(c)(3)
The preamble to the final rule (75 FR
25431) states that "EPA expects to
continue working with industry, the
California Air Resources Board, and
other stakeholders to move toward
ncreasingly robust performance tests
and methods for determining the
efficiency of mobile A/C systems and the
related impact on vehicle CO2
emissions, including a potential adapted
SC03 test."
Measure and record the continuous CO2
concentration for 600 seconds. Measure
the CO2 concentration continuously
using raw or dilute sampling procedures.
Multiply this concentration by the
continuous (raw or dilute) flow rate at
the emission sampling location to
determine the CO2 flow rate. Calculate
the CO2 cumulative flow rate
continuously over the test interval. This
cumulative value is the total mass of the
emitted CO2.

This requires us to have modal mass
method. However, our certification
equipment does not have ability for
modal mass method.

Does EPA intend to modify the idle test procedure for 1 4MY
and after certification?
If EPA will not change during above phase, is the projected
timing of new test procedure introduction at post 201 6MY?
Is it acceptable to use CVS method as an alternative to modal
mass method?
AC Efficiency Credit via Idle Test- Credits are provided if
CO2 increase is less than 21 .3 g/min. If a vehicle is not
equipped with AC at all, can we subtract 2 1.3 g/min?
EPA proposed several changes to the 201 4-201 6 A/C idle test requirements in the light-
duty 201 7 and later GHG/CAFE proposed rule; ref. 76 FR 74854, Dec 1 , 201 1 .
Proposed changes are outlined on pages 76 FR 75006-07 of the preamble to that
proposed rule, including:
1) revising the A/C idle test CO2 threshold values which are used to qualify for menu-
based A/C efficiency credits;
2) revising ambient temperature and humidity test conditions of the A/C idle test; and
3) allowing manufacturers to optionally qualify to use menu-based A/C efficiency credits
by reporting CO2 and other information on a new transient A/C test (the AC1 7 test) in
ieu of performing the A/C idle test. The AC17 test is described in the proposed
regulations at 86. 167-14.
The AC idle test is discussed in the preamble to the final rule, pages 75 FR 25429-31 .
Yes, it is acceptable to use a CVS system to measure CO2 emissions during the A/C
idle test. EPA revised the regulations in the 2013 FE Labeling final rule (76 FR 39478,
July 6, 2011) to clarify this requirement, adding the following sentence to the provisions
of 40 CFR 86.1 65-1 2(d)(4): "Alternatively, CO2 maybe measured and recorded using a
constant velocity sampling system as described in §§ 86.106-96(a)(2) and 86.109-94."
No, the GHG idle test and air conditioning credit provisions are not applicable to
vehicles not equipped with air conditioning. Please see the provisions of 40
CFR 86.1 866-1 2(c)(3). Those provisions provide that air conditioning efficiency
credits generated for an air conditioning system are based on the "Production"
of vehicles equipped with an air conditioning system where "Production = The
total number of passenger cars or light trucks, whichever is applicable,
produced with the air conditioninq system to which the efficiency credit value
from paragraph (c)(2) of this section applies." [Emphasis added.]
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Issue
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Subject
Regulation Reference
DRAFT Liqht-dutv Greenhouse Gas - Manufacturer Questions and EPA Answers - January 2012

Regulation
Issue
Manufacturer Questions
EPA Answers

Testing of vehicles that have dual
AC systems, or front and rear seat
cooling systems, or cooler box
options, are not addressed in the
regulation.
A/C Default to re-circulated air
mode:
Per the regulation, AC-CO2 credits
would not be applicable for a
system, as described below:
"When system does not default to
re-circulated air with closed-loop
control of the air supply, but
operators can select more efficient
AC operation with re-circulated air
with closed-loop control of the air
supply."
How do we demonstrate items for which demonstration is
required for AC efficiency credits? Does EPA plan to
publish a guidance letter in the near future on these
issues?
1 . Should the rear A/C system be operational when
conducting the A/C idle test?
2. Is 33% optional equipment criteria applicable to A/C
idle test vehicles?
Does EPA allow CO2 credit on applications which
activate a more efficient AC operation mode using re-
circulated air with closed-loop control of the air supply?
(For example, ECO type switch.)
A/C efficiency credit requirements are discussed in the preamble of the final
rule, pages 75 FR 25424-25 and 25427-31 .
Background: First, for use of A/C efficiency credits, manufacturers are
sometimes required to submit an engineering analysis to EPA for approval (for
closed-loop and open-loop systems which default to recirculated air at ambient
temperatures of 75deg F or higher). Deviations from the 75deg F are allowed if
accompanied bv an enaineerinq analysis. For example. EPA mav approve
credits for A/C systems which default to outside air for 10 seconds every 3
minutes to reduce cabin CO2 levels. Second, if using A/C efficiency credits for
1) improved condensers and/or evaporators and 2) oil separators,
manufacturers are required to submit an enaineerina analysis to EPA . Please
see EPA answers to questions 2.7 and 2.8, below.
Manufacturers should submit any required engineering analyses to EPA in a
letter to their EPA certification team member prior to or concurrently with the pre-
model year report.
EPA has no plans to publish a guidance letter on this issue.
The AC idle test is discussed in the preamble to the final rule, pages 75 FR
25429-31, and outlined in the regulations at 86. 165-1 2 and 86. 1866-1 2(c)(5).
1. For dual A/C systems, systems with cooler box options, systems with driver-
operated ECO buttons, etc., the A/C idle test should be conducted with the A/C
system in the default (key-off) mode. For example, if the A/C system normally
defaults on key-off to front A/C only, the A/C idle test should be conducted with
the front A/C on (and the rear A/C off). Conversely, if the A/C system does not
default on key-off to front A/C only, the A/C idle test should be conducted with
both front and rear A/C on.
2. For optional A/C equipment, manfacturers should contact their EPA
certification representative and obtain EPA approval prior to conducting the test.
The details of A/C idle test procedure for PHEVs, vehicles equipped with stop-
start system and new technology systems will be addressed in future guidance.
A/C efficiency credit requirements are discussed in the preamble of the final
rule, pages 75 FR 25424-25 and 25427-31. The provisions of 86. 1866-12(c) do
not allow EPA to approve special A/C efficiency credits (or partial credits) on a
case-by-case basis for A/C systems which are not listed in 86.1866-12(c) (orfor
variations of A/C systems which are listed in 86.1 866-1 2(c)(1)). Thus, A/C
systems would receive no credit if the driver-operated ECO button was
designed not to default to recirculated air upon key-off. Conversely, A/C
systems would receive full credit if the A/C system were designed to default
upon key-off to recirculated air.
Also see EPA answer to question 2.5, regarding the A/C idle test.
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Issue
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Regulation Reference
DRAFT Liqht-dutv Greenhouse Gas - Manufacturer Questions and EPA Answers - January 2012

Regulation
Issue
Manufacturer Questions
EPA Answers

Demonstration, certification and
approval process are unclear and
2012MY certification timing
presents a concern because
2012MY certification is already
underway.
Demonstration, certification and
approval process are unclear and
2012MY certification timing
presents a concern because
2012MY certification is already
underway.
1 . When and how should manufacturers demonstrate
COP of the system is improved higherthan 10%?
2. Regarding AC system which achieves 10% or higher
COP improvement, will EPA consider additional credit
beyond 1.1g?
When and how should manufacturers demonstrate Oil
Separator effectiveness?
(i.e. At least 50% of the oil entrained in the oil/refrigerant
mixture exiting the compressor returns it to the
compressor housing or )
A/C efficiency credit requirements are discussed in the preamble of the final
rule, pages 75 FR 25424-25 and 25427-31 .
1. See EPA answer to question 2.4 above. To receive the 1.1 g/mile credit for
improved condensers and/or evaporators, manufacturers should follow the
procedure outlined in 86.1866-12((c)(6)(v) (which requires the manufacturer to
submit an engineering analysis each model year for EPA approval). The
engineering analysis should compare the coefficient of performance (COP) of
the current model year system to the COP of the previous generation A/C
system used in that vehicle model or platform (where COP is measured
according to SAE procedure J2765). For example, if a new generation A/C
system goes into production in 2012-2014 model years, the 2012-2014
engineering analyses should compare the COP of the 2012-2014 system to the
COP of the 2011 system. Similarly, if a new generation A/C system goes into
production in the 2015 model year, the 2015 engineering analyses should
compare the COP of the 201 5 system to the COP of the 201 2-201 4 system.
2. The provisions of 86. 1866-1 2(c)(6)(v) do not allow EPA to approve special
A/C efficiency credits on a case-by-case basis for A/C systems which have a
COP improvement greater than 10%.
See EPA answer to question 2.4 above. A/C efficiency credit requirements are
discussed in the preamble of the final rule, pages 75 FR 25424-25 and 25427-
31. To receive the 0.6 g/mile credit for an improved oil separator,
manufacturers should follow the procedure outlined in 86.1866-12((c)(1)(viii)
(which requires the manufacturer to submit an engineering analysis each model
year for EPA approval).
The engineering analysis should compare the current model year oil control
system to the to the "baseline" oil control system used on the previous
generation A/C system used in that vehicle model or platform, as discussed in
question 2.7 above. For example, a manufacturer could measure the oil
circulation rate in the baseline configuration, and then compare it to the oil
circulation rate of the new configuration. As outlined in 86.1866-12(c)(6)(vi), if
the new configuration eliminates 50% of the oil that was circulating in the
baseline system, vehicles equipped with the new oil control system would qualify
for the 0.6 gr/mile "oil separator" credit.
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Issue
No.
Subject
Regulation Reference
DRAFT Liqht-dutv Greenhouse Gas - Manufacturer Questions and EPA Answers - January 2012

Regulation
Issue
Manufacturer Questions
EPA Answers

1. Starting with MY 201 4, A/C efficiency credits can only
be received if a certain efficiency is proven using a
special engine idle test procedure described in §86.165-
1 2. We are wondering how this procedure would work
with vehicles using an engine Start/Stop system. In this
case, the engine will not run in the first part of 10 min with
A/C off but will run in the second 10 min with A/C on,
which will always result in raising CO2 emissions above
21.3 g/min which means that no credit will be received.
Therefore, we think that for vehicles with an engine
Start/Stop system, the system should be deactivated
during the whole procedure (10 min idle with A/C off and
1 0 min idle with A/C on). Another option could be if the
approach for compressors driven by electricity is
transferred to vehicle with Start/Stop systems. In this
case, the system is deemed to be energy efficient if the
engine is stopped for a period off at least 2 minutes (p.
1353).
2. Regarding BEVs, it is our understanding that the
efficiency requirement is always met because the traction
engine is always off during "idle."
3. What about PHEVs? Mustthe engine off period of 2
min be demonstrated in the charge depleting or in the
charge sustaining mode?
The AC idle test is discussed in the preamble to the final rule, pages 75 FR
25429-31. For background information, please see EPA answers to questions
2. 1 , 2.2, 2.3 and 2.5 above. Especially see EPA answer 2. 1 above regarding
proposed changes to the 2014-2016 A/C idle test requirements.
1. Idle test requirements for vehicles equipped with stop-start systems will be
addressed in future EPA guidance. Our initial thoughts are that EPA approval
will be required and that each stop-start design will be evaluated on a case-by-
case basis (because each stop-start design is likely to have different operation
characteristics and calibration parameters).
2. EPA agrees that battery electric vehicles would meet the idle testing
requirement outlined in 86.1 866-1 2(c)(5)(iv) by design (and thus would not be
required to conduct the idle A/C test).
3. Idle test requirements for PHEVs will be addressed in future EPA guidance.
3. Credits - A/C Leakage
3.1
A/C Leakage
Credits -
Alternative
Refrigerants
86.1866-12(b)

GHG credit for refrigerant with low
GWP is defined in the regulation
and GHG standards were based
on availability of available
alternative refrigerants (i.e. HFO-
1234yf).
Currently HFO-1234yf is costly and has limited availability.
What is EPA's role in ensuring availability of these low
GWP alternative refrigerants?
Title IV refrigerant regulations are discussed in the preamble to the final rule
(pages 75 FR 25431-32) and in the preamble to the 2017 and later light-duty
GHG/CAFE proposed rule, (pages 76 FR 75002-05, Dec 1,2011). EPA's
Stratospheric Protection Division; Office of Air Programs (located in
Washington, D.C.) is responsible for approving new refrigerants.
4. Credits - General Questions
4.1
4.2
Credits- Good
Faith Effort to
Purchase
Credits
Credit
Calculations -
Vehicle Lifetime
Miles
86.1801(k)(3)
86.1865-12(k)(4);
86.1866-12(b), (c),
"To be exempted from the
standards , the manufacturer
must submit and documentation
of good-faith effort to purchase
credits from other manufacturers."
Final GHG rule.
Obtaining GHG credits.
Credit/debt calculation.
Proof of effort expended to obtain credits - due diligence - what
s expected of an small volume manufacturers to prove this?
For credit/debit calculation we believe the 195,264 miles
assigned lifetime is unrealistic and creates an unnecessary
burden. Does (we suggest) a small volume manufacturer have
the opportunity to justify a realistic vehicle lifetime based on
customer usage profiles?
Conditional exemption from greenhouse gas requirements is discussed in the preamble
of the final rule, pages 75 FR 2541 9-21 and 75 FR 25483. This question will be
addressed on a case-by-case basis for each small volume manufacturer and possibly in
future EPA guidance.
The basis for the 1 95,264 lifetime VMT for cars and 225,865 for trucks is outlined on
pages 4-76 and 5-35 of the EPA Response to Comments document available at
http://Www.epa.gov/otaq/climate/regulations.htmS1-1 . The car and truck lifetime VMT
mileages are used only to facilitate credit transfers between car and truck credit
programs. Thus, the important feature of these VMT values is the ratio of the car and
ruck lifetime VMT values, and not the absolute value of the lifetime VMT mileages. The
absolute values of the car and truck lifetime VMT values, by themselves, do not create
any additional burden for manufacturers. For this reason, regulations do not provide
small volume manufacturers with an oportunity to use alternative lifetime VMT values.
Page 4

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Issue
No.
Subject
Regulation Reference
DRAFT Liqht-dutv Greenhouse Gas - Manufacturer Questions and EPA Answers - January 2012

Regulation
Issue
Manufacturer Questions
EPA Answers

Purpose and Scope of this Guidance Document
This document was prepared by EPA's Office of Transportation and Air Quality (OTAQ). It contains a record of EPA positions with respect to implementation of EPA requirements in the light-duty greenhouse gas rule (75 FR 25324, May 7, 2010 and any
subsequent revisions to that rule which became effective on or before December 12, 2011). This document contains a record of the answers to the technical questions which EPA received from the light-duty automobile industry before and after EPA's September 23,
2010 light-duty greenhouse gas workshop. Regulated parties may use this document to aid in achieving compliance with the regulations for light-duty vehicles (40 CFR Parts 85, 86 and 600).
This document does not in any way alter the requirements in EPA regulations. 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 agency further considers 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
regulations. Further, this document does not establish binding rules or requirements and is not fully determinative of the issues addressed. Moreover, EPA decisions in any particular case will be made applying the law and regulations on the basis of specific facts.
5. Durability Requirements
5.1
5.2
Durability -
Alternative DFs
for N20, CH4,
CREE
Durability
demonstration
procedures for
GHG emission
standards.
86.1823-08(m)(2)(Ni)&(3)
86.1823-08(m)
m)(2)(iii) For the 201 2 through 201 4
model years only, manufacturers may
N2O, the alternative DF to be used to
adjust FTP and HFET emissions is the
additive or multiplicative DF determined
for (or derived from, using good
engineering judgment) NOX emissions
according to the provisions of this
section. For CH4, the alternative DF to
be used to adjust FTP and HFET
emissions is the additive or
multiplicative DF determined for (or
derived from, using good engineering
udgment) NMOG or NMHC emissions
according to the provisions of this
section.

Because additive deterioration factors
(DFs) are absolute values of emission
deterioration for each emission
constituent, it is difficult to apply an
additive DF for an emission
constitutuent as it is to other emission
constituent, which has a different
emission standard.
Timeline for demonstration.
We think we need compensation when we use an additive DF
for other emission constituents with different emission
standards. Is this acceptable? For example of NOx and N2O,
additive DF for N2O = additive DF for NOx/(NOx std./N2O std.)
1 . Because 201 2MY durability has begun, is it acceptable
to demonstrate by MY report timing (90 days after the end
of 20 12 MY)?
2. Applicability: Is this applicable to AC components and
system, off-cycle technology and so on during 2009-
2011 MY?
3. Demonstration Procedure: When and how should AC
durability demonstration be performed?
4. Will EPA provide standard procedures for eligible AC
and off-cycle technologies, or will EPA require
manufacturers to consider original durability procedure
and get EPA's approval before getting AC credit
approval?

final rule (76 FR 39478, July 6, 2011). The regulation changes are shown in redlinetext
n column 4. Note that EPA inadvertantly overwrote those changes in the Heavy-duty
GHG final rule (76 FR 57106, Sept 15, 2011). As a result, the language in column 4 is
now contained in the light-duty 201 7 and later GHG/CAFE proposed rule; ref. 76 FR
74854, Dec 1,2011.
We also revised paragraph 86.1823-08(m)(3) in the Heavy-duty GHG final rule (76 FR
571 06, Sept 1 5, 201 1 ) to clarify that 1 ) manufacturers may determine city and highway
CREE (or OCREE) DFs instead of determining DFs for each individual constituent that
s contained in CREE (or OCREE); and 2) manufacturers may use the applicable FTP
city) DF for the highway test for an emission constituent. Note that the provision to use
the FTP DFs for highway tests does not apply to the alternative method of determining
CO2 DFs outlined in the provisions of 86.1823-08(m)(1)(iii).
For example, paragraph (m)(3) was revised in the Heavy-duty GHG final rule to read in
part: "....FTP-based deterioration factors shall be determined for carbon-related
exhaust emissions (CREE), hydrocarbons and CO according to the provisions of
paragraphs (a) through (I) of this section. The FTP-based deterioration factor shall be
used to determine full useful life emissions for both the FTP (city) and HFET (highway)
test cycles. The manufacturer may at its option determine separate deteriorationfactors
for the FTP and HFET test cycles...."
1 . No, not allowed by current regulations.
2. Durability requirements for air conditioning systems and components (and
other credit-generating components) are outlined in the preamble to the final
rule (page 75 FR 25425) and in 40 CFR 86.1823-08(m)(4) which reads as
follows: "Manufacturers will attest to the durability of components and systems
used to meet the CO2 standards. Manufacturers may submit engineering data
to provide durability demonstration." Thus, deterioration factors are not
applicable to emission-related components used to obtain A/C leakage or A/C
efficiency credits .
3. Durability demonstration for A/C and other credit components should be
performed prior to certification. The attestation required by 86.1823-08(m)(4)
should be included in the initial Part 1 application for certification.
4. EPA will not provide standard durability procedures for eligible AC and off-
cycle technologies. Durability requirements for CO2 (CREE), N2O, CH4,
methanol, ethanol, HCHO, and C2H4O emissions are addressed in 86. 1823-
08(a) through (m), similar to other criteria pollutants. See parts 2 and 3 of this
question for durability requirements for credit components such as A/C leakage,
A/C efficiency and off-cycle components.
6. Early Credits (2009-2011 Model Years)
6.1
Early A/C Credit
Provisions
86.1867(b)(2)
Manufacturers that are required to
comply with California greenhouse gas
requirements in model years 2009-2011
(for California and section 177 states)
may not generate early air conditioning
credits for vehicles sold in California and
the section 177 states as determined in
paragraph (a)(2)(i) of this section
As you know, most manufacturers
have to comply with Pavleyl during
2009-2011 MY. [EPA comment: Small
& intermediate mfrs don't have to meet
CARB 2009-2011 GHG requirements.]
Then, most manufacturers cannot
obtain in A/C credit if they select
pathway2, right? And it's strange that
pathwayl can generate A/C credit,
which uses Pavleyl 's standard.

EPA revised the regulations in the 2013 FE Labeling final rule (76 FR 39478, July 6,
2011) deleting this requirement. The provisions of 40 CFR 86.1867(b)(2) were revised
to read:
"Manufacturers that select Pathway 4 as described in paragraph (a)(4) of this section
may not generate early air conditioning credits for vehicles sold in California and the
section 177 states as determined in paragraph (a)(2)(i) of this section. Manufacturers
not participating in one of the early fleet average credit pathways described in this
section may generate early air conditioning credits only for vehicles sold in states other
than in California and the section 1 77 states as determined in paragraph (a)(2)(i) of this
section."
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DRAFT Light-duty Greenhouse Gas - Manufacturer Questions and EPA Answers - January 2012
„ . . ,
Sublet
Regulation Reference
Regulation
Issue
Manufacturer Questions
EPA Answers
Purpose and Scope of this Guidance Document
This document was prepared by EPA's Office of Transportation and Air Quality (OTAQ). It contains a record of EPA positions with respect to implementation of EPA requirements in the light-duty greenhouse gas rule (75 FR 25324, May 7, 2010 and any
subsequent revisions to that rule which became effective on or before December 12, 2011). This document contains a record of the answers to the technical questions which EPA received from the light-duty automobile industry before and after EPA's September 23,
2010 light-duty greenhouse gas workshop. Regulated parties may use this document to aid in achieving compliance with the regulations for light-duty vehicles (40 CFR Parts 85, 86 and 600).

This document does not in any way alter the requirements in EPA regulations. 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 agency further considers 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
regulations. Further, this document does not establish binding rules or requirements and is not fully determinative of the issues addressed. Moreover, EPA decisions in any particular case will be made applying the law and regulations on the basis of specific facts.
Early Credit
Trading
86.1865-12(k); 86.1867-
Final GHG rule.
Early Credit Trading
Are manufacturers allowed to trade early credits (generated
during 2009-2011 MY) to other OEM's?
Early credit provisions are outlined in the preamble of the final rule (75 FR 25441-44)
md in 86.1867-12. Averaging, banking and trading provisions are outlined in the
preamble of the final rule (75 FR 25412-14) and in 86.1865-12(k). If a manufacturer
selected pathways 1, 2, or 3, credits earned in 2009 may not be traded to other mfrs
including A/C leakage, A/C efficiency, advanced technology, and off-cycle credits), ref.
75 FR 25442. All other credits may be traded to other mfrs (ref. 86.1865-12(k)(7) and
75 FR 25414) subject to the limitations of 86.1865-12(k)(9); reporting requirements of
86.1865-12(l)(2), etc. Note that the provisions of 86.1865(k)(9)(iv) prohibit a
manufacturer from trading credits which will result in the manufacturer having a debit at
the end of the model year that the credit was traded.
Early Credit
Provisions -
Production vs.
Actual Sales Data
86.1867-12 introductory
paragraph and 86.1867-
Pathway 1 states that "Total U.S.
model year sales data will be used,
instead of production data," as
well as the preamble stating,
..manufacturers using Pathway 1
or 2 will use year-end car and truck
sales in each category."
For Pathway 1, we believe total U.S. production should be
also allowed, as this is consistent with the CAFE
calculation procedure.

Can we use total U.S. production for early credit
calculation of pathway 1?
Early credit provisions are outlined in the preamble of the final rule (75 FR
25441-44) and in 86.1867-12. Currently the introductory text in paragraph of
86.1867 reads in part "The terms "sales" and "sold" as used in this section shall
mean vehicles produced and delivered for sale in the states and territories of
the United States." This introductory paragraph conflicts with paragraph
86.1867-12(a)(1)(iii)(A) which reads "Total U.S. model year sales data will be
used, instead of production data."

EPA agrees that for Pathways 1, 2, 3 and 4, tracking production data (instead of
sales data) is an acceptable method of tracking vehicles delivered to the point of
irst sale (which is the dealer). Therefore, EPA revised the regulations in the
2013 FE Labeling final rule (76 FR 39478, July 6, 2011), deleting the
requirement to use sales data in paragraph 86.1867-12(a)(1)(iii)(A).
7. High Altitude Requirements
High Altitude
Standards
86.1818(d);
86.1841(a)(3)
86.1810-09(f),(2)
Our understanding is that CO2, N2O
and CH4 must comply with high
altitude standards similar to other
emission pollutants. Is our
understanding correct?
However, how should we prove the compliance with CO2 high
:ude standards because in-use CO2 standard is decided as
1.1 x {New vehicle CO2}.
High altitude greenhouse gas requirements are discussed in the preamble of the final
rule on page 75 FR 25484. CO2/CREE, N2O, and CH4 standards are all altitude
standards, ref 86.1810-09(f). In-use standards for high altitude testing are outlined in
86.1818(d).

As background information for this question, EPA compared high 8- low altitude IUVP
CO2 data. Out of 102 matching pairs of high and low altitude IUPV vehicles, three high
ill IUVP vehicles had CO2 levels 10% higher than the matching low altitude IUPV
vehicle.

For certification N2O and CH4 compliance, manufacturers have the option to test a
vehicle at high altitude or submit a compliance statement in the application in lieu of
testing. However, the compliance statement does not apply to CO2 (CREE) because
there are no CO2 (CREE) certification standards. See EPA answer to question 7.2
regarding the requirement to submit an engineering evaluation indicating that for N2O,
CH4 and CO2 (CREE), common calibration approaches are used at high altitude.

For in-use, the IUVP vehicle tested at high altitude must pass the in-use CO2 standard,
which is the city/highway combined CO2 (CREE) for the matching subconfiguration
represented with test data (or model type CO2 (CREE) if the IUVP configuration does
not match any tested configuration) multiplied by a factor of 1.1.
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Regulation
Issue
Manufacturer Questions
EPA Answers

Purpose and Scope of this Guidance Document
This document was prepared by EPA's Office of Transportation and Air Quality (OTAQ). It contains a record of EPA positions with respect to implementation of EPA requirements in the light-duty greenhouse gas rule (75 FR 25324, May 7, 2010 and any
subsequent revisions to that rule which became effective on or before December 12, 2011). This document contains a record of the answers to the technical questions which EPA received from the light-duty automobile industry before and after EPA's September 23,
2010 light-duty greenhouse gas workshop. Regulated parties may use this document to aid in achieving compliance with the regulations for light-duty vehicles (40 CFR Parts 85, 86 and 600).
This document does not in any way alter the requirements in EPA regulations. 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 agency further considers 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
regulations. Further, this document does not establish binding rules or requirements and is not fully determinative of the issues addressed. Moreover, EPA decisions in any particular case will be made applying the law and regulations on the basis of specific facts.
7.2
High Altitude
Standards
181 0-09 (f)
86.1829-01(b)(1)(ii)
86. 1810-09 (f) Altitude
requirements...
(2) For vehicles that comply with the
cold temperature NMHC
standards... and the CO2, N2O and
CH4 exhaust emission standards
described in 86.1818-12,
manufacturers must submit an
engineering evaluation indicating
that common calibration approaches
are utilized at high altitudes (except
when there are specific high altitude
calibration needs to deviate from low
altitude emission control practices).
Any deviation from the low altitude
emission control practices must be
included in the AECD descriptions
submitted at certification. Any AECD
specific to high altitude must require
engineering emission data for EPA
evaluation to quantify any emission
impact and validity of the AECD.
Our understanding is that CO2,
N2O and CH4 emissions also have
to meet compliance with high
altitude standards, similar to the
other emission constituents.
1. Can EPA confirm this understanding? If this
understanding is correct, can EPA clarify how a
manufacturer should prove CO2 high altitude compliance
since the in-use CO2 standard will be determined as 1.1 x
New vehicle CO2.
2. EPA answered this on slide 68, bullets, subbullet 1-
"Engineering evaluation required in Part 1 forCO2, CH4,
N2O: Common calibration approaches are used at high
altitudes." However, since EPA already requires
compliance with emission standards at altitude, there is
no need for a further compliance statement that the
calibration approaches are the same at high altitude as at
low altitude. Indeed, the opposite may be true to ensure
compliance with emission standards at high altitude. We
recommend this subbullet be deleted.
High altitude greenhouse gas requirements are discussed in the preamble of
the final rule on page 75 FR 25484 and in 86.1810-09(f).
1. EPA agrees with your understanding thatCO2/CREE, N2O, and CH4
standards are all altitude standards, ref 86.1810-09(f). The second part of this
question is answered in question 7.1, above.
2. EPA believes that it is appropriate to require in the Part 1 application the high
altitude compliance statement required by 86.1829-01(b)(1)(ii) and an
engineering evaluation that common calibration approaches are used at high
altitude required by 86.1810-09(f). However EPA agrees with the comment that
sometimes different high altitude calibration approaches may be needed.
Therefore, EPA intends to clarify the provisions of 86.1810-09(f) (as shown in
the redline text in column 4 at the next opportunity.
In those cases where common calibration approaches are different at high and
low altitude, the high-altitude calibration approach should be included in the
AECD description in the Part 1 application as required by 86.1 844-0 1(d)(11).
EPA would consider the requirement to use common calibration approaches at
high altitude to be satisfied in cases were a vehicle used similar calibrations,
software and elements of design at low and high altitudes during hot/cold starts,
hot/cold ambient conditions, hot/cold engine operation, etc. Calibration
approaches, for example, would include (but are not limited to) idle speeds,
spark advance, air/fuel ratio, valve timing, transmission shift and lock-up
schedules and EGR calibration strategy. For hybrid vehicles, calibration
approaches would also include the electric operation strategy of the vehicle.
8. In-Use Requirements
8.1
8.2
In-Use
Requirements -
Emission
Related Defect
Definition
In-use
Standards for
PHEV/EV
vehicles
85.1902(b)(2)
86.1866-12(a)(2)
"A defect in the design, materials, or
workmanship in one or more
emissions control or emission-
related parts, components, systems,
software or elements of design which
must function properly to assure
continued compliance with vehicle
emission requirements, including
compliance with CO2, CH4, N2O,
and carbon- related exhaust
emission standards."

The preamble describes this
regulatory change (that is, the
adding of paragraph 2) as: (1) A
minor clarification, (2) Effective
beginning with the 2012 model
year and (3) Requiring the
reporting of defects related to GHG
emissions.

Do you interpret this change as 1) preserving the existing
definition from the 1977 rule that defines an emission-
related defect and 2) expanding the definition also to
include defects that affect GHG emissions? I am
concerned that some may misinterpret this new regulation
to suddenly require the reporting of defects that do not
affect emissions (Appendix VIII is not mentioned, and the
'assured continued compliance" phrase only adds words
to describe the part, not what the defect could upset), and
to create a new definition of a defect related to non-GHG
emissions (that is, believing the original definition in
paragraph 1 is obsolete via a broader definition in
paragraph 2). We are happy to offer several ways to
improve the clarity, either by tweaking_very few words, or
re-writing the section. Whatever the outcome, I believe it
would be helpful if the regulatory text in paragraph 2:
Required reporting for defects that_affect compliance
Related specifically to 2012 and later GHG emission
defects (preserving paragraph 1 for non-GHG related
defects).
How will the 1.1 in-use standard be applied to EVs and
PH EVs? We assume it won't affect EVs up to the
200K/300KO g/m cap. ..but, how about after the cap?
How about PHEVs?
EPA intended to preserve the existing definition from the 1977 rule that defines
an emission-related defect and expand the definition also to include defects that
affect GHG emissions. EPA revised the regulations in the 2013 FE Labeling
final rule (76 FR 39478, July 6, 2011) to amend the definition contained in 40
CFR 85.1902 (b) (2) as follows:
"A defect in the design, materials, or workmanship in one or more emissions
control or emission-related parts, components, systems, software or elements of
design which must function properly to assure continued compliance with
greenhouse gas emission standards."
The 1.1 in-use standard will apply to all of your product line subject to GHG —
please read the regulations and preamble for the details of what in-use standard
applies to what vehicles. Of course, EVs, fuel cell vehicles and the electric
portion of PHEVs are entitled to use zero CREE emissions — so there won't be
much point in EPA performing confirmatory testing of EVs and fuel cell vehicles-
orthe electric portion of PHEVs. After a manufacturer exceeds the production
volume limits in 86.1866-12(a)(2), the 1.1 standard will be determined/applied to
EVs, PHEVs and fuel cell vehicles similar to the way it is determined/applied to
conventional vehicles.
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Regulation
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Manufacturer Questions
EPA Answers

When establishing/calculating in-
use CO2 standards, EPA says that
the value should be based on the
subconfiguration value and if no
subconfiguration value is available,
the value should be based on
model tvoe.
Emission Related Defect Definition:
"A defect in the design, materials, or workmanship in one
or more emissions control or emission-related parts,
components, systems, software or elements of design
which must function properly to assure continued
compliance with vehicle emission requirements, including
compliance with CO2, CH4, N2O, and carbon-related
exhaust emission standards;"
1 . Would EPA require to count each claim or failure of a
system or part which is in the vehicle to reduce CO2 as
an emission related defect?
2. Even if the system results in small CO2 benefit (less
than 10%) and the CO2 standard will not be failed?
When determining whether data exists for the
subconfiguration, are we only to consider actual test data
or do we also include data substitutions and/or analytically
derived data?
See answer 8.1 above regarding the Emission Related Defect Definition.
1. Manufacturers should treat each claim or failure separately, except for system
failures (e.g. when three components in the cylinder deactivation system fail and
all have more than 25 failures).
2. As is the case with current defect reporting requirements, manufacturers are
required to report defects in emission-related parts, components, systems,
software or elements of design; regardless of whether the defect causes the
vehicle to exceed applicable emission standards.
In-use standards are discussed in the preamble to the final rule, page 75 FR
25476-77 and in the provisions of 86.1818-12(d). As discussed in those
provisions, the GHG data used to determine in-use standards include all
carline/subconfiguration data used to demonstrate compliance with the CO2
(CREE) fleet average emission standards, including data substitution data,
engine code equivalency data, analytically derived CREE data, etc.
9. Miscellaneous Questions
9.1
9.2
9.3
Miscellaneous -
CAFE
Miscellaneous -
CREE
(Intermingling of
CO2 and CREE
terms)
Miscellaneous -
Footprint
Tolerances
600.5 12-08(c)(8)
86.1803-01 and 600.002-
08 - Definition of Carbon-
related exhaust
emissions
86.1803-01 and 600.002-
08 - Definition of
Footprint
CAFE Model year report

CAFE footprint standards
calculator.

Where does the EPA reformed CAFE calculator fit into this
ruling?
Why are CO2 equivalents mentioned sometimes and
sometimes CREE?
When does EPA or NHTSA plan to publish acceptable or
default tolerances for the footprint values? Is this
something EPA can answer on its own or does this have
to come from NHTSA?
The reformed CAFE footprint Calculator (Excel spreadsheet) is currently used to
determine the CAFE standards for 2008-2016 reformed CAFEs. EPA supplied this
calculator (entitled EPA 2008-2016 Reformed CAFE STD Calculator.9-30-10.xls) to the
Industry in October, 201 0. EPA anticipates that the Excel spreadsheet calculator will be
replaced by EPA's Verify data base system for 2012 model year CAFEs (and 2012

The intermingling of CO2 and CREE terms are discussed in the Response to
comments document page 5-460. The GHG regulations refer to CO2 standards
(although CREE emissions are measured and compared to the CO2 standards)
because CO2 standards are easier for the general public to understand. In
addition, the definition of carbon- related exhaust emissions (CREE) outlined in
600.002-08 provides some clarification as follows: "For example, carbon-
related exhaust emissions (weighted 55 percent city and 45 percent highway)
are used to demonstrate compliance with fleet average CO2 emission
standards outlined in 86.1818(c) of this chapter."
EPA is concerned about the design tolerances of footprint measurements and
will work with NHTSA to address this issue in the future. NHTSA published a
recommended laboratory test procedure to measure footprints, ref. TP-537-01,
Mar 30, 2009 available at
http://www.nhtsa.gov/DOT/NHTSAA/ehicle%20Safety/Test%20Procedures/Asso
ciated%20Files/TP-537-01.pdf. EPA would consider it to be a violation of the
terms of the certificate if a manufacturer's production footprint measurements
were noteably different (e.g. resulting in smaller production footprints) than the
footprint measurements submitted in the model year report.
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Regulation
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Manufacturer Questions
EPA Answers

86.1818-12(d)
600.1 13-12(g)(4)
86.135-12(d)

Previously, the provisions of 86.135-
00(d) read as follows:
Practice runs over the prescribed
driving schedule may be performed
at test point, provided an emission
sample is not taken, for the purpose
of finding the appropriate throttle
action to maintain the proper speed-
time relationship, or to permit
sampling system adjustment. Both
smoothing of speed variations and
excessive accelerator pedal
perturbations are to be avoided.
When using two-roll dynamometers
a truer speed-time trace may be
obtained by minimizing the rocking of
the vehicle in the rolls; the rocking of
the vehicle changes the tire rolling
radius on each roll. This rocking may
be minimized by restraining the
vehicle horizontally (or nearly so) by
using a cable and winch.

1. 86.1818-12(d)ln-useCO2
exhaust emission standards., there
is an incorrect reference to
"600. 113-08(g)(4)", should be
"600.113-12(g)(4)".
2. In600.113-12(g)(4), there is an
incorrect reference to "600.1 13(a)
and (b)", 600.1 13(a) and (b) deal
with calculating FTP and HWFE
fuel economy not CREE.
The description in 40CFR
86. 135(d) of the GHG final rule
reverts to the description from the
1990 MY version. We believe this
was an oversight. Details of text
below:
Current 86. 135-12(d) reads as
follows:
Practice runs over the prescribed
driving schedule may be
performed attest point, provided
an emission sample is not taken,
for the purpose of finding the
minimum throttle action to maintain
the proper speed-time relationship,
or to permit sampling system
adjustment. Note: When using two-
roll dynamometers a truer speed-
time trace may be obtained by
minimizing the rocking of the
vehicle in the rolls; the rocking of
the vehicle changes the tire rolling
radius on each roll. This rocking
may be minimized by restraining
the vehicle horizontally (or nearly
sol bv usina a cable and winch.
Is EPA implementing a fleet-average CREE calculation
program into Verify?
How would EPA inform manufacturers as to what inputs
to the system will be required (i.e. meetings, workshop).
EPA typos, as noted in the Reference column.
Request that EPA amend the regulatory text to reflect the
previous/correct language contained in 86.135-00(d).
Yes, EPA will be working with manufacturers throughout 2010, 201 1 and 2012
to implement GHG changes into EPA's Verify data base system. EPA has been
working with the Verify contractor over the past year. A brief outline of planned
Verify changes was provided at the September 23, 2010 EPA/Industry GHG
workshop-see slide 83 of the presentation. EPA held the first webinar meeting
on November 17, 2010. EPA deployed some GHG data base changes on May
13, October 14 and December 16, 2011. The next deployment is scheduled for
May or June of 2012.
Additional information about upcoming Verify changes and upcoming meetings
will be provided via the EPA list server.
1. EPA revised the regulations in the 2013 FE Labeling final rule (76 FR 39478,
July 6, 2011), revising the incorrect reference from 600.113-08(g)(4) to 600.1 13-
_12.(g)(4).
2. EPA agrees with the comment regarding the provisions of 600.1 13-12(g)(4)
which incorrectly reference 600.1 13-12(a) and(b). EPA revised the regulations
n the 2013 FE Labeling final rule (76 FR 39478, July 6, 2011), revising the
ncorrect reference from 600.1 13-12(a) and (b) to 600. 11 3-1 2(h) through (n).
EPA agrees with the comment and will revise the regulations at the next
opportunity.
10. Penalties
10.1
Penalties
preamble to the final rule
section III.E.4 and 6
(pages 75 FR 25473-77
and 25482

In case model type CREE emissions go over the in-use
standard level, re-calculation of the fleet average or/and a
recall is possible, correct?
If CO2 improvement measures are available/feasible,
certain models can be recalled and appropriate fixes will
be applied. ..what if there is no fix/remedy available?
Please read the preamble to the final rule section III.E.4 and 6 (pages 75 FR
25473-77 and 25482). Also, those subjects are addressed in the EPA
Response to comments document pages 5-359 to 5-362 and on slide 67 of the
presentation given at the Sept 23, 2010 EPA/Industry greenhouse workshop.
EPA typically doesn't place any up-front restrictions on EPA enforcement
actions — because each enforcement action has special needs, conditions, etc,
and is handled on a case-by-case basis.
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Regulation
Issue
Manufacturer Questions
EPA Answers

Reporting requirements.

Are Pre-MY and final MY reports required for small volume
manufacturer with an exemption?
Can this be handled as part of Certification Preview or is a
VERIFY module roll out planned?
What does EPA require in the TLAAS application (other
than documentation that the manufacturer's does not
comply with GHG standards without using the TLAAS
program)?
Exemptions from greenhouse gas requirements are discussed in the preamble of the
final rule, pages 75 FR 25419-21, 75 FR 25424, and 75 FR 25483. Manufacturers
qualifying for a Small Business Administration (SBA) exemption under 86.1801-12(j) are
"exempt from the greenhouse gas emission standards specified in 86.1818-12 and in
associated provisions in this part and in part 600 of this chapter;" ref. 86.1801-12(j).
Thus, manufacturers qualifying for a SBA exemption are not required to submit pre-
model year report or a GHG model year report to EPA (but may be required to submit a
CAFE model year report to EPA). For SBA exemptions, manufacturers are not required
to submit a declaration to EPA outlining how they qualify for the exemption, but are
required to provide in the Part 1 application "the applicable intermediate and full useful
life emission standards to which the test group is to be certified;" ref. 40 CFR 86.1844-
01(d)(7). Note that current EPA regulations do not provide SBA-exempt manufacturers
with the option to certify to GHG standards (or to earn GHG credits). However, in the
light-duty 201 7 and later GHG/CAFE proposed rule, EPA proposed that beginning with
model year 2014, SBA-exempt manufacturers may optionally meet applicable GHG
standards and thus, may earn CO2 credits under the primary GHG program); ref. 76 FR
74994, Dec 1,2011.
Manufacturers qualifying for a conditional exemption under 86.1801-12(k) "may request
a conditional exemption from compliance with the emission standards described in
86.1818-12, paragraphs (c) through (e) and associated provisions in this part and in part
600 of this chapter." ref. 40 CFR 86.1801-12(k). Note that this exemption does not
exempt manufacturers from meeting N2O and CH4 emission standards. As outlined in
paragraph 86.1801(k)(3), manufacturers requesting a conditional exemption are
required to submit a declaration to EPA at least 30 days prior to the introduction of
vehicles into commerce. If EPA subsequently approves the mfr's request for exemption,
the mfr is not required to submit a pre-model year report or a GHG model year report to
EPA (but will likely be required to submit a CAFE report to EPA).
TLAAS requirements are discussed in the preamble to the final rule, pages 75
FR 25414-19. Manufacturers using TLAAS provisions are not required to
submit a TLAAS declaration to EPA, however they should outline in the pre-
model year report the details of how they qualify for TLAAS program, including
how they comply with the provisions of 86.1818-12(e)(3) and 86.1865-
12(k)(7)(iii). There is no specific "TLAAS application," however, TLAAS-related
information should be included in the application for for certification, the pre-
model year report and the final model year report. The final model year report
should provide the TLAAS standards, compliance level, qualifications, credit
use, etc, ref. 86. 1865-12(l)(2) and 600.512-12.
In addition, EPA intends to incorporate TLAAS greenhouse gas data reporting
requirements into the GHG/CAFE module of EPA's Verify data base system.
We will schedule several meetings and testing sessions with manufacturers
prior to and during the initial start-up of the new Verify GHG/CAFE module.
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Regulation
Issue
Manufacturer Questions
EPA Answers

Which specific vehicles do we need to maintain records
for under §86. 1865-1 2 (l)(1)(ii)? Is this required for all
vehicles produced beginning in MY 201 2 or only for IUVP
tested vehicles? We believe this requirement will be very
difficult and burdensome to maintain for all vehicles and
we believe it should only be required for IUVP vehicles.
Many other manufacturers may have the same concern in
maintaining records for all vehicles. Please clarify if this
requirement is only for IUVP vehicles and when this
requirement takes effect.
According to §86.1865 (I), reporting of MYs 2009-201 1
must be done the first time with the MY 20 12 report, e.g.
by 05/0 1/20 13.
According to §86.1867(e), reporting of MYs 2009-201 1
must be done at latest 90 days after the end of the 2011
model year.
According to §600. 51 2 (a), the MY report must be
submitted at latest 90 days after the end of the model
year.
Does 586.1865 fh contain an error?
These requirements are intended for all production vehicles. As outlined in the
provisions of 86.1865(l)(iii), "Records may be stored in any format and on any
media, as long as manufacturers can promptly send EPA organized written
records in English if requested by the Administrator." These requirements are
very similar to current recordkeeping requirements outlined in 86.1862-04(a).
No. There is not an error, but there are two separate things going on. 86.1865
deals with the annual model year report, which are requirements that don't start
until the close of the 2012 model year. 86.1865-12(1) is simply saying that when
you submit your annual report for the first model year of the program (2012),
you need to include certain elements relating to your early credits (if any). But
86.1867 requires a single summary report for all early credits that includes data
from all model years 2009-201 1. Note that the content from the 2009-2011
early model year report (which is due in early 2012) will be included in the final
2012 model year report -due in early 2013.
12. Testing
12.1
12.2
Testing -
Analytically
Derived
C02/CREE
Testing -
Manufacturer
Confirmatory
Testing
86.1835-01 (b)(1)(vi)
86.1835-01(b)(3)
When the following condition is met,
manufacturers have to conduct mfr
confirmatory test:
"The exhaust carbon-related exhaust
emissions of the test as measured in
accordance with the procedures in 40
CFR Part 600 are lower than expected
based on procedures approved by the
Administrator."
The manufacturer shall conduct a retest
of the FTP or highway test if the
difference between the fuel economy of
the confirmatory test and the original
manufacturer's test equals or exceeds
three percent."

Do we have to obtain EPA approval for each model's
analytically derived CREE estimation procedure? By when?
If the fuel economy difference between both tests are within
three percent, how should we calculate official CREE?
The use of analytically derived CREE data is discussed in the preamble to the final rule,
page 75 FR 25470. EPA will clarify in a future guidance letter the policy for 1) the use of
analytically derived CREE and fuel economy data and 2) CREE cut points policy, ref.
CISD-09-18 and CCD-04-06. Preliminary thoughts for the cut points guidance letter are
that additional CREE cutpoints will not be needed (and the fuel economy cutpoints
outlined in CISD-09-18 will be used for both fuel economy and CREEretesting).
For official CREE data, mfrs should use the same data as determined to be the official
data for FE testing. In this case, EPA policy is outlined in the flow chart in EPA
guidance letter VPCD-99-06 (page 1 4)— and the mfr's confirmatory test would be the
'official" test for FE and CREE.
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Issue
Manufacturer Questions
EPA Answers

Apparently the issue of daytime
running lights came up in the GHG
rule. The current procedure is to
allow DRLs to be disconnected
during the test. As I recall EPA didn't
incorporate any change in the final
GHG rule but said it would consider
this an make changes if appropriate
in the future.

When calculating upstream emissions
for AW credits, there is no clear
calculation of EC(for EV), ECF,
CREE_CDED, CREE_CDGAS,
CREE CS(forPHV),CREE up(for
FCV)inS600.111-08(f).
When calculating PHEV upstream
emissions (=CREEcd+CREEcs), the
UF(Utiliy Factor) is not applied.
Background: EPA implemented
the policy of not using daytime
running lights (DRL) on the test
based upon NHTSA's decision to
ignore CAFE effect of DRL, thus
providing an incentive to
encourage DRLs for safety
reasons.
The complexity of N20 testing
requirements raise significant
concerns, for example:
(i) Facilities - require significant
upgrades specific to analyzers and
software, and
(ii) Lab Efficiency - collection of DF
and cert data will constrain lab
throughput due to potential void
and maintenance issues.
Will EPA clarify these regulations in the future?
Will EPA decide/modify calculations in GHG label rulemaking
this summer?
So has EPA considered this and is any change in the
works? What is the earliet model year that might be
affected if you make a change?
Will EPA accept extended use of N2O compliance
statement beyond 2014 MY?
CREE calculations for EVs, PHEVs, & fuel cell vehicles are outlined in the preamble to
the final rule, pages 75 FR 25434-38. Upstream emission requirements for EVs,
PHEVs, and fuel cell vehicles are outlined in the provisions of 40 CFR 600.11 3-1 2(m).
For EVs and PHEVs, the provisions of 600.1 13-12(m)(1) and (m)(2) were revised in the
2013 FE Labeling final rule (76 FR 39478, July 6, 2011).
Daytime running lights are not discussed in the final GHG rule, nor did EPA
receive any comments related to EPA's daytime running light policy. At this
time, EPA has no plans to revise the testing policy for vehicles equipped with
daytime running lights outlined in EPA guidance letter CD-94-02, February 9,
1994. If EPA decides to revise that policy, EPA will provide adequate lead time
to affected manufacturers.
N2O and N2O analyzer requirements are discussed in the preamble of the final
rule (pages 75 FR 25421-24) and in the preamble to the light-duty 2017 and
later GHG/CAFE proposed rule; ref. 76 FR 74993-94, Dec 1 , 201 1 .
In the 2017 and later light-duty GHG/CAFE proposed rule, EPA proposed to
extend the use of an N2O compliance statement for two additional years
(through model year 201 6). Thus, as proposed, manufacturers will be required
to measure N2O emissions beginning with the 2017 model year in orderto
demonstrate compliance with the N2O emission standard.
13. Warranty
13.1
13.2
13.3
Warranty - A/C
Credit
Components
Warranty - A/C
Credit
Components
Warranty - A/C
Credit
Components
Sections 207(a) and 207(i)
of the CAA
Sections 207(a) and 207(i)
of the CAA
Sections 207(a) and 207(i)
of the CAA

There was no modification in the
section of warranty parts list, on the
other hand, EPA requires the A/C
warranty of 2yr/24k in the preamble.
From 201 2MY, AC systems
generating GHG credit must
provide 2yr./24K mile defect
warranty.
Does EPA require the inclusion of A/C system into warranty
parts list of 2yr/2.4k, which was proposed in the preamble of
NPRM?
Will EPA modify the warranty parts lists?
If so, will EPA add only the A/C system to 2yr/24k parts lists?
Will EPA add other systems? Will EPA add any new systems to
the 8yr/80,000 mile warranty requirements?
Does this mean mfrs. must offer 15yrs/150K mile
warranty to such AC systems for PZEVs in California?
Does this mean mfrs. have to offer 7 years/70K mile
warranty to applicable AC systems if it is high-priced
warranted parts in California?
EPA warranty requirements for light-duty vehicles and trucks are discussed in the
preamble of the final rule, pages 75 FR 25486-87. EPA warranty requirements for
MDPVs are outlined in the provisions of 40 CFR 86.004-2. The defect warranty is
required to cover emission-related components necessary to meet CO2 (CREE), CH4,
N2O emission standards and emission-related components used to obtain optional
GHG credits (including credits for reduction of air-conditioning refrigerant leakage
and/or improving air conditioning system efficiency). The duration of the defect
warranty depends on the applicable class of vehicles (e.g. for 2-year/24,000 miles for
light-duty vehicles/trucks or 5 years/50,000 miles for MDPVs).
A/C warranty requirements are manufacturer and model year specific (depending on the
A/C systems which generate A/C leakage and efficiency credits). Therefore, EPA has
no plans to modify the warranty parts list provided on the web at
http://www.epa.gov/otaq/consumeryWarr95fs.txt. Also, please see the EPA answer to
question 13.1, above.
For Federal A/C warranty requirements, please seethe EPA answer to question 13.1,
above. For California warranty requirements, please consult with CARB.
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Issue
No.
Subject
Regulation Reference
DRAFT Liqht-dutv Greenhouse Gas - Manufacturer Questions and EPA Answers - January 2012

Regulation
Issue
Manufacturer Questions
EPA Answers

Devices listed as auxilliary
emission control devices (AECDs)
in part I application require listing
of part numbers of emission
related components and these
AECDs in part II and also them to
be covered by the defect warranty.
Can EPA comment on whether or not manufacturers
must offer defect warranties on GHG AECDs, even
though certification application requirements have not
been changed in the GHG rule making?
Please see EPA answers to questions 1.1 and 13.1 above, for information
about listing part numbers in the Part 2 application and for information about the
defect warranty requirements for GHG AECDs. Warranty requirements for light-
duty vehicles and trucks are discussed in the preamble of the final rule, pages
75 FR 25486-87. The defect warranty and EPA defect reporting requirements
apply to AECDs and emission-related components necessary to meet CO2
(CREE), CH4, N2O emission standards and to AECDs and emission-related
components used to obtain optional CO2 (CREE) credits.
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