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

                 Implementation Workshop
                 Fourth 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,

          J      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
                 workshop. This 4th Edition includes most of the remaining GEM questions (AES,
United States
Environmental Protection
Office of Transportation and Air Quality
                    March 2012

  v <«.
           VSL and Weight Reduction) as well as the Averaging, Banking and Trading and Hybrid OBD
           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 pos-
           sible, 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
           review and 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 regulations. Although the answers provided in this  document interpret the regula-
           tions 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 determinative 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,

           Updates  since the 1st Edition:

               •  In the 2nd question in the Tire Rolling Resistance Q&A section, the agencies have
                  added an additional sentence of clarification to this previously posted response. This new
                  sentence reads as follows: "NHTSA has active on-going research to identify suitable ref-
                  erences labs to the ISO test procedure. Pending completion of the NHTSA research, it
                  is possible that the agencies will identify the appropriate reference lab. However, at this
                  time ..."
               •  In the 4th and 5th questions in the "GENERAL" section, the agencies have revised the
                  answers to include EPA's announcement  that, as of March 6, 2011 per guidance letter
                  CD-12-06, all HD GHG certification templates are now posted for industry use in sub-
                  mitting certification applications.
           General - Certification:

           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?

These templates are now been posted to As announced in EPA
guidance letter CD-12-06 on March 6, 2012, certification application templates are now ready
to be used by manufacturers submitting certification applications on or after this date.

           When will EPA be ready to receive certification documents from OEMs?

           Certification documents may be submitted at any time to your certification representative. As
           stated above, certification application templates are now available aid you in submitting applica-
           tion materials to EPA, per guidance letter CD-I2-06,
           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 (see §1036.205 for engines, or §1037.205 for vehicles). 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
(1 ^        additional information to confirm the submission,

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


    •   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
Please clarify?

The Family Certification Level (FCL) only applies for CO2 for Engines as described in
40CFR1036.108 and 1036.801. Vehicle manufacturers should use the Family Emission Limit
(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?
General - Averaging, Banking and Trading:

EPA approval of innovative technology credit test plans may be required well in advance of
typical certification preview meeting timing. Do EPA Ann Arbor and Washington DC staffs
have a process in place to review and approve these plans?

           Yes. EPA and NHTSA jointly review and approve innovative technology requests. We encourage
           manufacturers to approach us as early as possible in the process. Per §1037.610(d), we recom-
           mend you do not start collecting test data before you contact us to review your recommended
           test plan.
           EPA has stated with regard to GEM that "transmission improvements could potentially be
           evaluated as an innovative credit and thus be utilized for demonstrating compliance on that
           basis." Although the final regulation is "recent," has EPA undertaken any additional steps
           "post final rule" with regard to transmissions and innovative credits?

           We will approach this as a typical innovative technology request from a manufacturer as
           explained in §1037.610 and 49 CFR 535.7. These provisions may be applied for CO2 emission
           and fuel consumption reductions provided the test procedures  used to generate inputs for GEM
           do not already consider the benefit of the subject technology. The provisions also allow the
           improved technology to be used as either an improvement factor (i.e., improvement over base-
           line configuration), or as a separate credit (e.g., comparing in-use emission rate with and with-
           out the technology on the same or identical vehicle),

           Note that per §1037.610(d), you must send a request that includes a detailed description of the
           technology and a recommended test plan to EPA's DCO (the DCO has directed that your re-
           quest should go directly to your certification representative). §1037.610(d) goes on to state, "...
           For technologies for which the engine manufacturer could also claim credits (such as transmis-
           sions in certain circumstances), we may require you to include a letter from  the engine manu-
           facturer stating that it will not seek credits for the same technology." We recommend you do not
           start collecting test data before contacting us. Use the guidance in §1037.610 to inform what
           testing data and other information must be submitted to EPA for joint EPA/NHTSA review,
           Projected production weighted average was not included in final rule, nor was the requirement
           for that weighted average to meet the standard. Please explain why this is now different.

            §1037.725(b) requires that manufacturers include in their application a statement that to the
           best of their knowledge they will not have a negative balance of emissions credits when all emis-
           sions credits are calculated at the end of the year, or a statement that they will have a negative
           balance as allowed under §1037.745. Your certificate for a vehicle family for which you do not
           have sufficient CO2 credits will not be void if you can offset the deficit by using surplus credits
           within 3 model years,

           §1037.205(s) states that manufacturers must submit good-faith estimates of U.S.-directed
           production volumes by subfamily. This input is included in the Family Information worksheet
           of the HD GHG Vehicle Template.

           We are not requiring that you submit detailed calculations beyond that submitted  in the GEM
           output file in your application (See §1037.205(o)). However, per §1037.735(a), you must
           organize and maintain all records that form the basis of your credit determination. §1037.735(b)
           goes on to state, "You may not use  emission credits for any vehicles if you do not keep all the


           records. We may review your records at any time." Finally, you may store these records in any
           format on any media as long as you can promptly send us "organized, written records in English,
           if we ask for them."

           Advanced Technology or Innovative that has an override switch or mechanism, can the FE
           credit be taken despite the  override function?

           Emissions and fuel consumption credits for these technologies have to be evaluated on a
           case-by-case basis. Manufacturers must provide data indicating how often the technology will
           be used in practice and conditions under which it will be overridden. Per §1036.610(b)(3),
           §1037.610(b)(3) and 49 CFR 535.7 (by reference to §1037.610), the agencies may require you
           to discount the  benefit of this technology if, based on the information provided, the amount of
           time the system is expected  to be overridden is significant.
           As a tier 1 supplier, do you need an OEM sponsorship to determine credits for an innovative

           Innovative technology credits for CO2 emissions and fuel consumption apply to engine and
           vehicle configurations covered under a certificate issued by EPA. Thus, the credits are available
           to the certifier of the engine or vehicle which contains the innovative technology. The certifier
           generally has substantial control over the design and assembly of emission controls. This is
           usually the engine or vehicle manufacturer, however, in some limited cases the certifier can be
           a secondary manufacturer using the provisions set out in §1037.620(b).
           General- Hybrids and Heavy-duty OBD:

           What will be the process for adding new vehicle families during the year? For instance, add-
           ing a new hybrid system?

           If the engine manufacturer is the certifier, Part 1036 Subpart C defines the process to certify.
           Note that §1036.230(a) states that engines that are certified as hybrid engines or power packs
           may not be included in an engine family with engines with conventional powertrains. There-
           fore, hybrids will have to be in a separate engine family.

           If the vehicle manufacturer is the certifier, Part 1037 Subpart C defines the process to certify.
           Note that §1037.230(a)(2)(ii) states that you should group together vehicles that contain the
           same advanced technology (i.e., hybrids) into one vehicle family.
           Please confirm that the engine by itself does not need to be certified for GHG if it will be
           used as part of a hybrid system that is certified for GHG [See 76 FR 57249, top of first col-
           umn and bottom of first column which seem contradictory]?

           These two statements in the preamble are not contradictory. At the top of 76 FR 57249 we
           state that hybrid engines and vehicles certified under the provisions for GHG will  use certified

           engines (i.e., engines certified for criteria pollutants). At the bottom of 76 FR57249 we state
           that the engine will need to be certified for criteria pollutant performance, while the engine and
           hybrid system in combination may be certified for GHG performance (i.e., to capture the benefit
           of hybrid operation on GHG emissions).
           Therefore, the engine must be certified for non-GHG emissions if the engine is certified as an
           engine independent of a vehicle. If the engine is certified for GHG emissions as/within a com'
           plete vehicle (or as a combined engine and hybrid system), then a second independent engine
           certification (i.e., to GHG pollutants) is not needed. If the engine is not certified as/within a
           complete vehicle (e.g. the vehicle certification is independent of the engine's emissions perfor-
           mance) then the engine must be both GHG and criteria pollutant certified.
           How will the Running Change process be handled? Will notification be required to NHTSA
           also? What about changes that need individual submission (such as Hybrids)?

           Refer to §40 CFR 1036.225 and 1037.225, and 49 CFR 535.8(f) which outline the requirements
           for amending applications for certification for GHG and fuel consumption regulated engines and
           vehicles. This is a similar approach to the running change process used today for engine criteria

           A hybrid system cannot be added to an engine family that uses a conventional powertrain under
           the running changes criteria. Running changes are allowed within a hybrid engine or hybrid
           vehicle family using the criteria in §1036.230 and §1037.230,

           Running change applications are to be submitted to EPA only and must include the required
           information for both EPA and NHTSA. Manufacturers can start production as soon as they sub-
           mit the running change application (provided the family is already covered under a certificate).
           The caveat is that they must cease production and possibly recall if we deny the running change
           as described in 40 CFR 1036.225(e) and 40 CFR 1037.225(e).
Turnaround time for approvals on Running Changes involving Hybrids?

The timing of agency approval/denial of running changes will depend on the complexity of the
running change as well as the completeness of the data submission by the manufacturer. Incorri'
plete submissions will result in increased review times,

As described in the previous answer, §1037.225(e) and §1036.225(e) provide some relief for
manufacturers who wish to start production while the agency reviews their running change
           Hybrid battery deterioration was used as an example of deterioration factor applicability for
           vehicle certification. How will EPA define/approve DF test practices for vehicle components?

           This example was used in §1037. 241 (c). Should manufacturers (or EPA) determine that a non-
           zero deterioration factor is appropriate; the manufacturer must devise and execute a test plan



Yes, that is correct. See §1036.150(0-
In the peer review of the GEM, Dr. Flowers indicated that "the use of a generic powertrain
(engine and transmission) is problematic because a well-integrated powertrain can signifi-
cantly improve vehicle performance." While this meeting is focused on existing standards,
could you address for a moment where EPA may be heading with further development of the
GEM as a compliance mechanism especially with respect to the consideration of transmis-
sions and powertrains?

           As we noted in the preamble to the final rule (76 FR at 57133, September 15, 2011), we will
           fully consider a range of regulatory approaches in the next phase of a heavy-duty GHG rulemak-
           ing, which include the potential to expand compliance models to reflect engine and transmis-
           sion performance.
           No specific questions concerning HD Pickups and Van have been completed to date. See
           general questions.

           HDE Averaging, Banking and Trading:

           For Engines' Are low N2O credits available for MY 13 cert?

           If you certify your model year 2014, 2015, or 2016 engines to an N2O PEL less than 0.04 g/hp-hr,
           an<^ Provided your PEL is based on measured N2O emissions from your emission-data engines,
           you may generate additional CO2 credits by using the equation in §1036.150(i). Use this equa-
           tion in lieu of the equation in §1036.705,
           Please confirm that for engines certified to alternate phase-in of 1036.150(e), we are still
           allowed to generate "regular credits" (no 1.5 multiplier) for MY13 and later, just not "early
           credits" (1.5 multiplier).

           You are correct. 76 FR 57501 (February 15, 2011) states that, if a manufacturer chooses to use
           the alternative phase-in schedule to meet EPA standards and chooses to comply early with the
           NHTSA fuel consumption program, then the engines certified to these standards are not eligible
           for early credits [see 40 CFR 1036.150(e), 49 CFR 535.5(d)(5) and 535.7(d)(13)].

           40 CFR 1036.150(e) and 49 CFR 535.7(d)(13) state that engines certified to the alternative
           phase-in schedule are not eligible for early credits that may be increased by a multiple of 1.5
           [as allowed in 40 CFR 1036.150(a)(3) and 49 CFR 535.7(d)(14) for engines meeting the
           regular standards  and associated schedule]. 40 CFR 1036.150(e) and 49 CFR 535.7(d)(13) go
           on to state that credits for these engines are calculated using the table provided in paragraph
           §1036.150(e), and the equation provided in 49 CFR 535.5(d)(ll). These two cites do not
           provide a multiplier.
(1 ^        If I am certifying more than one power level for an engine, in order to use AB&T, am I
           required to both: a) test each power level?; and, b) place each engine power level into
           separate engine families?

           ABT credits are calculated based on the Family Certification Level (FCL) of the engine
           family. 1036.241 (a) states that an engine family is in compliance if the tested configuration(s),


           as defined in 1036.235(a), has (have) emission levels at or below the FCL. Per §1036.230 (refer-
           encing 40 CFR 86.001 -24, which then references 40 CFR 86.096-24), an engine's power rating
           is not a family-determining characteristic. Therefore, you may include multiple power ratings
           within a single engine family.
           The NOx/PM ABT is very different from HD GHG reporting. The difference is especially
           the need to report every serial number and every configuration which discourages agglomer-
           ating similar vehicles into one family. Is EPA prepared for a flood of GHG family certifica-

           We believe the vehicle family structure that was finalized represents the most expedient method
           for reconciling credits while reducing reporting burdens (see §1037.230). For each regulatory
           subcategory, each manufacturer needs to only have one vehicle family (for conventional vehicles).
           Differences in GHG performance are accounted for at the subfamily level and differences in
           GHG-related components are accounted for in the vehicle configuration level. The GEM-
           predicted emission level can be calculated using the EPA-supplied batch processing template at
           the vehicle configuration level. Manufacturers must only associate each VIN with a configura-
           tion, rather than enter each VIN in GEM,


           What level of detail must be reported to EPA with respect to the OEM definition of
           Vocational Tractor?

           In order for a vehicle to be reclassified as a vocational tractor, it must meet the definition
           in 40CFR1037.630(a)  and 49CFR523.2, meet the requirements in 40CFR1037.630(b) and
           49CFR535.5(c)(5), and include the language required to be added to the vehicle's emission
           control information label specified in 1037.630(c). In addition, there are production limits
           for vocational tractors. No manufacturers may produce more than 21,000 vehicles under
           1037.630(c) in any three consecutive model years. No pre-approval is normally required for
           on-road vocational tractors. A manufacturer is only required under 1037.630(b) to include in its
           application for certification a brief description of its basis for reclassifying certain of its tractors
           as vocational, citing the applicable vehicle and application types enumerated in 1037.630(a)(l),
           As specified in 1037.630(c), the manufacturer must keep records for three years to document
           its basis for believing the vehicles will be used as described in 1037.630(a). In the future, if EPA
           determines that a manufacturer is not applying the allowance in good faith, it may require the
           manufacturer obtain preliminary approval before using the allowance.
           What level of detail must be reported to EPA with respect to the OEM definition of Off
           Road Vehicle?

                    There is no requirement that OEMs obtain approval of off-road status (and consequent exemp-
                    tion from the vocational vehicle GHG standards). Criteria for meeting this exemption are
                    found at 40 CFR 1037.631 (a) and 49 CFR 523.2, but the manufacturer must report the basis of
                    its determination by the end of year, as outlined in 40 CFR 1037.63 l(c) and 49 CFR 535.8(h)
                    (6).  However, if the vehicles do not meet the criteria of the definition in the regulation, then
                    the manufacturer may ask for an exemption according to 40 CFR 1037.150(h)  and 49 CFR
                    535.8(h)(6)(ii). EPA will coordinate approval decisions withNHTSA,
                    We are a corporation made up of several business units or divisions that all produce voca-
                    tional vehicles. We have at least two divisions that are final stage manufacturers who produce
                    their own chassis. Will we be asking for one manufacturer number for the corporation, or
                    does each division get their own number?

                    It is normal practice among corporations to use one manufacturer code for all vehicle and engine
                    products regulated by EPA. Therefore, you should use one manufacturer code to encompass all
                    your products regulated by EPA. However, let your certification representative know if you think
                    this approach would be problematic for you,
                    Likewise, will we average compliance across the corporation for all vocational vehicles, or
                    does the averaging take place only within a division?

                    The averaging should take place across the corporate product lines. You may average within the
                    following three averaging sets:

                        •   Light heavy duty vehicle line
                        •   Medium heavy duty vehicle line
                        •   Heavy heavy duty vehicle line
                    Will we get separate vehicle certificates and engine certificates?

                    For class 2b/3 complete vehicles you will receive a vehicle certificate based on complete vehicle
                    testing. For 2b-8 incomplete vehicles you will receive a vehicle certificate based on chassis
                    modeling. For class 7-8s tractors/vocational vehicles you will receive a vehicle certificate based
                    on chassis modeling. For engines in vehicles not included in the 2b/3 complete vehicle pro-
                    gram, which are subject to the engine provisions, you will receive an engine certificate based on
                    engine testing.  If you are the manufacturer of both the engine and the chassis, and intend to
                    certify as a vocational vehicle, you will receive an engine certificate based on engine testing and
                    a vehicle certificate based on chassis modeling.
                    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:

           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
           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
           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
£1 \        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
   J      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 representing the
                    highest  projected sales volumes. The manufacturer must have sufficient  aerodynamic data to
                    support  these GEM runs,

                        • 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 alter-
                  native 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.
/i -\        What level of detail will EPA require for vehicle height data and calculation for Regulatory
^•^i        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 §1037.801,
           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
           tractor". 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
(1 J               the 70" low and mid-roof sleepers on Model 386 tractors)?

           Use the high-roof sleeper version of the low or mid-roof sleepers on each model for determining
    J      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
            Aerodynamic 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 fairings 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?
               •  ARE: 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
            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 simi-
            larly 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,
            Tire Rolling Resistance:
 j  i
TTT        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
     J         b) What is the procedure if the tire data is not available in a timely manner from the
                  tire manufacturer?

               c)   Tire CRR Database: What is EPA's plan to harmonize the data if the same tire shows
                  different results? The tire manufacturers data appears to be mostly relevant to a broad
                  range of vehicle OEM's. Would it not be beneficial to the EPA's GHG certification
                  process to streamline tire rolling resistance data into a common database possibly
                  managed through an industry group like Truck & Engine Manufacturer's Associa-
                  tion or the Tire Manufacturers Association? Will EPA or NHTSA be developing and
                  maintaining a data base of certified tire CRR values, or will each vehicle OEM needs
                  to work with each tire manufacturer to identify the valid values? If EPA does not
                  maintain this data base, how will vehicle manufactures validate the CRR values they
                  are using in their application?

               a)  The certificate holder (i.e., the chassis 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 chassis 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 and NHTSA do not intend to establish a common database at this time. Consid-
                  eration may be given in the future. However, the agencies may conduct confirmatory
                  testing (e.g., if we observe outlier data from the same tire model). §1037.520(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 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? Who are they? How will tire manufac-
turer's CRR values be checked to verify that they correlate with the standard labs?

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. NHTSA has active on-
going research to identify suitable references labs to the ISO test procedure. Pending completion
of the NHTSA research, it is possible that the agencies will identify the appropriate reference
lab. However, at this time, EPA and NHTSA have test results showing that two independent
tire testing laboratories in the United States, Smithers-Rapra and Standards Testing Labora-
tory, have tire rolling resistance test  machines 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 manufacturer request a test laboratory to which it may correlate its test
results, the agencies will accept tire data generated by or correlated to either of these two
laboratories. In addition, should either agency decide to confirm or compliance test tires so
certified, the agency will use one of these two laboratories for the testing.


           What plans are there for compliance auditing by EPA and/or NHTSA on vehicle certifica-
           tions and component inputs into the GEM?

               •  E.g. Tire rolling resistance production variation and/or changes versus certified value?
               •  What are the liabilities for non-compliances and penalties, i.e. assessments from both
                  EPA and NHTSA separately?

           The agencies may validate any component inputs, as necessary, through compliance testing.
           For tires, if the manufacturer chose to do correlation testing with either of the labs identified by
           the agencies in the previous question, we may check whether the tests CRR data show that, per
           §1037.520(c)(l), the manufacturer's results were not biased low. EPA or NHTSA may perform a
           paperwork  audit, checking for the existence of lab tire test reports. However, if one truck OEM
           reports CRR values for a tire model that are significantly different from the values for the same
           model submitted by other truck OEMs, then EPA may consider a test program to verify the CRR
           value for that particular tire.

           Both agencies have compliance review and enforcement responsibilities for their respective
           regulatory requirements. See Section V.G. of the final rule (76 FR 57290) for a description of
           the penalty programs associated with non-compliance with each agency's requirements.
           Tire Rolling Resistance data (CRR) - Suppliers cannot complete testing in time for cert
           application submittal so will use existing test data or interpolated data. Will EPA allow
           placeholder information for Tire Rolling Resistance 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 will be used? Does all info need to be in
           before a Certificate is issued? Can there be gaps in Tire Rolling Resistance data? Is there an
           opportunity to update information?

           There are minimum test data requirements per §1037.520(c) that must be in before a Certifi-
           cate will be issued. Per §1037.520(c)(l), measure tire rolling resistance (RR) as specified in
           ISO28580 (incorporated by reference in §1037.810), and use good engineering judgment to
           ensure that your test results are not biased low. Per §1037.520(c)(2), for each tire design tested,
           measure RR of at least three different tires of that specific design and size, performing the test
           at least once for each tire. Sufficient tire RR data/assessments must be available at the time
           of certification to conduct the 10 GEM runs. If during the year, the OEM wants to offer a tire
           model that causes the GEM result of the vehicle configuration to go outside  of the declared
           range of subfamily FELs, then they must do a running change. Finally, the OEM must have all of
           the tire RR information available and input into the appropriate GEM runs for each configura-
           tion for the End of Year (EOY) report. The manufacturers must test at least one tire size for each
           tire model, and may apply engineering analysis assessments for other tire sizes within the same
           Note also, that §1037.520(c)(3) states that, "If the [vehicle manufacturer] obtains [its] test
           results from the tire manufacturer or from another third party, [it] must obtain a signed state-
           ment from them verifying that the tests were conducted according to the requirements of this
           part. Such statements are deemed to be submissions to EPA."


             For certain vocational vehicles, they are sold today with tires specified by the customer, by
             brand, size, and tread pattern. This means that a particular model truck could be sold with
             any of over 100 combinations of front and rear CRR values. How will we handle this? Is
             each combination considered a subcategory since each would have a unique FEL value?

             Having hundreds of combinations of tires does not mean they each will have unique FELs. For
             example, a vocational chassis manufacturer should model vehicle configurations with highest
             and lowest rolling resistance combinations. The spread between these two values will determine
             the number of subfamilies (and thus FELs) within the family. Manufacturers will then group
             tires/tire combinations into configurations that meet each FEL,
             What level of detail will EPA require for the: (a) Range of tires offered for a given model,
             and (b) Tire testing and data?

             You are required to have sufficient tire CRR data to conduct the 10 GEM runs at the time of
             certification. If during the year, the truck OEM wants to offer a tire model that causes the GEM
             result of the tractor configuration to go outside of the declared range of subfamily FELs, then
             they must do a running change. Otherwise, the OEM must have all of the tire RR information
             available and input into the appropriate GEM runs for each configuration for the EOY report.
           I noticed a requirement for 24,000 miles/2 year warranty on tires? Certain vocational vehicle
           applications will wear out tires sooner. Large fire apparatus and urban use will wear out tires
           in 8000 miles. Garbage truck won't make 24,000 miles. How will EPA address this?

           The tire must be free from defects during the warranty period, but the regulation does not place
           a requirement on wear. §1037.120 details the emission'related warranty requirements. The
           warranty period requires that "(1) It is designed, built, and equipped so it conforms at the time
           of sale to the ultimate purchaser with the requirements of this part. (2) It is free from defects in
           materials and workmanship that cause the  vehicle to fail to conform to the requirements of this
           part during the applicable warranty period." Finally, as we have stated in the final rule preamble
           (76 FR 57278), "As proposed, tires are only required to be warranted for the first life of the tires
           (vehicle manufacturers are not expected to cover replacement tires)."
             For vocational vehicles, what warranty are you looking for? Since tires are the only variable
             and they are a consumable item the vehicle warranty will not be applicable to meeting
             In the event the tires are the only emission control component on the vehicle (as in some voca-
  fl)        tional vehicles), the tire warranty (§1037.120) is all that is required to satisfy this requirement,
  ^^        See also the answer to the preceding question,

/i \

           What are the criteria for EPA/NHTSA to approve the vehicle manufacturers' tire information
           to the owners/users/fleets for replacement of low RR tires?

               •  Question goes to replacement within the tire's emissions warranty period of 2 years
                  or 24,000 miles, and replacement after this time.
               •  Question goes to the form of the information that is provided to the owners/users/
                  fleets for post emissions warranty useful life for tire replacements, i.e. at this point,
                  any replacement tire can be used regardless of the tire CRR properties.
               •  What are the tire-related rules concerning the OEM-certification with LRR tires and
                  the possible changing &/or replacing of tires by the owners/users/fleets after delivery?
               •  What support and/or recommendations might be requested from the tire industry, e.g.
                  models of tire CRR information from other countries, use of Smart Way verified LRR
                  tires, etc.?

           Per §1037.125(1) the vehicle manufacturer is required to supply instructions that will enable
           the owner to replace tires so that the vehicle conforms to the original certified configuration,
           This can be  a list of suggested tire models that have rolling resistances similar to the OE tire (i.e.
           SmartWay verified tires, etc). This can also be an explanation of what rolling resistances the
           replacement tires should have and how the owner can determine the rolling resistance value for
           replacement tires (i.e. tire manufacturer websites, literature, etc). Per §1037.125(h), we  expect
           this information to either be contained in the owner's manual or a supplemental document to
           the owner's manual,
           Are the provisions from the EPA regarding "tampering" of emissions system applicable,
           especially within useful life/emissions warranty for tires (2 years or 24,000 miles)?

               •   What are the worn tire aspects and concerns for needed removals?
               •   What are the provisions available for the use of new vehicles for field evaluation tire
                  placements, e.g. as it is being done today?

           Per §1037.125(i) the vehicle manufacturer is required to supply instructions that will enable
           the owner to replace tires so that the vehicle conforms to the original certified configuration.
           This can be a list of suggested tire models that have rolling resistances similar to the OE tire (i.e.
           SmartWay verified tires, etc). This can also be an explanation of what rolling resistances the
           replacement tires should have and how the owner can determine the rolling resistance value for
           replacement tires (i.e. tire manufacturer websites, literature, etc). We expect this information to
           either be contained in the owner's manual or a supplemental document to the owner's manual,
           See also the answer to the previous question.
           What are the criteria for the inclusion of the tires as part of the emissions label on the vehicle?

           If you use tires that meet the definition of "low rolling resistance" in §1037.801 then you need
           to indicate this by printing the appropriate abbreviation (see Appendix III to Part 1037) on the
           ECI label.


    (a) To gain credit the certifier must make its VSL system substantially tamper- resistant (see
       1037.520(d)), and must ensure that its AES system is generally compliant with the
       adjustable parameters provisions as stated in 1037.660(d) and as defined in §1037.115(a)
       with reference to 40 CFR Part 86-22,

       This tamper resistant approach should preclude customers from changing VSL or AES
       settings without the manufacturer's (i.e., original certifier) involvement. Note that certi-
       fiers cannot set VSLs to an artificially low setting with the expectation that the customer
       will adjust it upwards upon delivery. However, if a vehicle has been sold and the pur-
       chaser requires some adjustment to VSL settings before the vehicle is delivered to said
       purchaser, the certifier may make the adjustment and pro-rate the benefit of this change
       in its EOY Report. There are also VSL soft tops or expiration features that are subject to
       proration provisions,

       In the case of your second owner example, if the vehicle's Vehicle Speed Limiter (VSL)
       has not reached the expiration point (in miles), §1037.655(d)(l) states, "No person may
       disable a vehicle speed limiter prior to its expiration point." Note that §1037.640(a)
       states that designs with VSL soft tops, or expiration features are also subject to proration
       provisions. For VSL, the certifier must use the equation in 1037.640(d)(2) to calculate
       the prorated effective speed needed for GEM calculations, and for EOY reporting,

       As an alternative to increasing the VSL, the vehicle owner could request that the ve-
       hicle manufacturer (certifier) provide the VSL with a soft-top feature,

    (b) To gain credit for an AES system, the manufacturer (i.e., the holder of the certificate)
       must ensure that the general adjustable parameter provisions also apply to AES operat-
       ing parameters per §1037.660(d). This would assure that the manufacturer has applied
       tamper resistant methods to its vehicles which would preclude the second owner from
       changing the AES settings if the vehicle mileage is less than the expiration point,

       For post-useful life vehicles, §1037.655(d) provides examples of prohibited modifica-
       tions. One such example provides that no person may disable a VSL prior to the vehicle
       expiration mileage. Extrapolating this example, the agencies have determined that the
       same condition holds true for AES. The second owner cannot change or disable the AES
       settings if the vehicle mileage is  less than the expiration point or if there is no expiration
       point. If the certifier is in doubt with respect to its own situation, it should consult with
       its EPA certification representative,

       As a result, the second owner should take into account that the engine will continue to
       shutdown during extended idling, and as such this second owner may have to purchase
       an idle reduction technology to meet his/her heating and cooling needs,
Controlling vehicle speed inevitably involves specifications for max overshoot when entering
the controlled state, as well as a max deviation within the steady state control band. What is
the EPA's expectation for the max overshoot and max steady state control band they will allow

  j '
             given that both will allow for temporary, brief excursions above the GHG vehicle speed limit
             specified by the customer?

             Each manufacturer should discuss the characteristics of its control system with its certification
             representative. This may include maximum momentary overshoot in vehicle speed, duration
             and steady-state accuracy. As noted in the heavy-duty final rule (76 FR 57156), NHTSA has
             previewed the possibility of a proposed safety rulemaking for VSLs in 2012 which may prescribe
             a lower speed tolerance and/or different overshoot parameters (76 FR 78),
             Acceptable settings of AES system for temperature health and safety variables?

             Based on the fact that many strategies can and will be deployed by manufacturers with regards
             to their AES and idle reduction strategies (i.e., hoteling operation, cab insulation, etc.), each
             manufacturer should discuss their strategy with their certification representative to give EPA
             assurance their strategy provides the expected idling reduction while maintaining a safe envi-
             ronment for the occupants,
What level of detail will EPA require for each aspect/topic that requires data? Specifically the
technical details on VSL; on AES; and, on weight reduction parts and systems?

For all of these systems, you must keep records of these and other relevant certification data and
calculations per EPA Reporting and Recordkeeping requirements provided in 40 CFR 1037.825
as well as NHTSA Reporting Requirements provided in 49 CFR 535.8(h). However, with regards
to what needs to be submitted to EPA in the certification application, see the Commercial Tractor
and Vocational Vehicle Certification Application template.

Refer also to 40CFR1037.660(d)  adjustable parameters provisions that apply generally to AES
with some exceptions as explained. Furthermore, for VSL, 1037.520(d) states, "Use good
engineering judgment to ensure the limiter is tamper resistant. We may require you to obtain
preliminary approval for your designs."

The certification application template will direct manufacturers to the level of specificity
required (in terms of settings/expiration points/etc). To the extent manufacturers need to dem-
onstrate tamper resistance or describe adjustable parameters, they will need to work with their
certification representative. See the answer to previous questions regarding the level of detail
             Are all parts used in weight reduction calculation considered Emission-Related parts?

             §1037.120(c) states that, "Your emission-related warranty does not need to cover components
             whose failure would not increase a vehicle's emissions of any regulated pollutant."


If a component is eligible for aluminum and high strength steel weight, but if the component
is also available in plastic (or some other material lighter than steel), can we  come to the
Agency with a procedure for weight reduction credits other than the one in §1037.520(e)
(3) but  also not the same as the innovative technology provisions, which are burdensome
and unlikely to demonstrate any actual fuel savings to a statistically significant level (given
test to test variability)?

The agencies did not have enough data to determine that a plastic hood would  weigh a certain
number of pounds less than a steel hood. Therefore, we could not add plastic components to
Table 4  of §1037.520(e)(2). The innovative technology section §1037.610(b) states that, "The
provision of this section may be applied as either an improvement factor or as a separate credit,
consistent with good engineering judgment." While this section also recommends that you base
your credit/adjustment on A to B testing of a pair of vehicles, in a specific case where you feel
good engineering judgment would be better characterized by some other test, you may send your
request to your certification representative, including a detailed description of the technology
and a recommended test plan per §1037.610(d). We recommend that you do not begin collecting
test data for  submission to EPA before contacting your certification representative.