Frequently Asked Questions:
EPA Greenhouse Gas Provisions for
Clean Alternative Fuel Conversions of
Light-Duty Vehicles and Medium-Duty
Passenger Vehicles
This information is intended to assist conversion manufacturers
in understanding the greenhouse gas regulations. It is not a sub-
stitute for compliance with EPA greenhouse gas requirements in 40
CFR parts 85, 86, and 600. Heavy-duty vehicle greenhouse gas
requirements will be described in a separate information sheet.
What are the current and proposed EPA greenhouse gas (GHG) regulations?
2012 Light-Duty Rule - GHG requirements for Original Equipment Manufacturers
(OEMs) and conversion manufacturers started in the 2012 model year (MY) and
apply to light-duty vehicles, trucks up to 8500 GVW, and medium-duty passenger
vehicles (passenger vehicles from 8500 to 10,000 GVW). The rules apply to conver-
sion manufacturers modifying 2012 and later MY OEM vehicles,
2014 Heavy-Duty Rule - GHG requirements for OEMs and conversion manufacturers
begin with the 2014 MY and apply to both chassis tested vehicles over 8500 but less
than 14,000 GVW (class 2b and 3 heavy-duty vehicles), and engine-dynamometer
tested heavy-duty engines which the engine manufacturer could reasonably expect to
be used for motive power in class 4-8 heavy-duty vehicles, as well as class 4-8 heavy-
duty vocational vehicles and commercial tractors,
2017 Light-Duty Proposed Rule - A proposed rule for light-duty vehicles for 2017
and later MYs was published in December 2011. The final rule is expected to be
published in 2012,
SEPA
United States
Environmental Protection
Agency
Office of Transportation and Air Quality
EPA-420-F-12-056
August 2012
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What are light-duty GHG emissions?
GHG exhaust emissions include carbon dioxide (CO2), methane (CH4), and nitrous oxide
(N2O). Compliance with GHG requirements is based on measurement of carbon related
exhaust emissions, or CREE. The specific components of CREE exhaust gases are fuel dependent
and are presented in the equations in 40 CFR part 600.113-12. Using a CNG fuel as an ex-
ample, CREE is the summation of CH , non-methane hydrocarbon (NMHC), carbon monoxide
(CO), and CO2, where CH4, NMHC, and CO are converted to CO2 equivalents.
The light-duty GHG regulations include individual standards for CH4 and N2O,
OEMs may also qualify for credits by reducing air-conditioning system leakage of GHG hydro-
fluorocarbons and by improving air conditioning system efficiency. These credits are then used
in determining overall compliance with fleet average CO2 standards.
Do the Small Business status and Conditional Exemption status described in Part 86,
subpart S regulations also apply to conversion manufacturers?
Yes. The exemption categories described in 40 CFR part 86.1801 (j) and (k) also apply to
conversion manufacturers,
Small Business Administration Exemption - If you employ less than 1000 employees
worldwide and are engaged in manufacturing you are exempt from GHG requirements.
Note that the Small Business Administration regulation requires the aggregation of
employees of related affiliate companies to determine qualification for this exemption.
You do not need EPA approval to qualify as Small Business Administration Exempt,
Conditional Exemption - If you employ over 1000 employees worldwide and your average
U.S. based sales for the three most recent consecutive model years are less than 5000 units
you may qualify as Conditionally Exempt from GHG requirements. Similar to OEMs,
conversion manufacturers need advance EPA approval to qualify as Conditionally Exempt,
Not Exempt - If you do not qualify as Small Business Administration Exempt or Condi-
tionally Exempt, you must meet the GHG requirements described in Q5 below and
presented in 40 CFR part 85.525(a)(2)(i).
Describe the requirements to demonstrate GHG compliance for the different exemption
status categories?
(1 ^ Small Business Administration Exemption - If you are Small Business Administration
Exempt, you have no GHG compliance or reporting requirements.
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Conditional Exemption - If EPA approved, you are not required to meet the OEM's in-use
CO2 standard described in 40 CFR part 85.525(a)(2)(i), but you are required to meet the
standards for CH4 and N2O of 0.030 g/mi and 0.010 g/mi, respectively. If you cannot meet
these standards you may exercise any of the options described in paragraphs A, B, C in Q8
below, or use the back-to-back methodology which is proposed to be added to 40 CFR part
85.525(a)(2)(i) as paragraph D in the Light-Duty 2017 GHG rule and discussed in Q9
below,
Not Exempt - If you are not exempt you must meet the in-use exhaust emission CO2
standard and the CH4 and N2O standards. You may exercise any of the compliance options
described in Q8 to meet the standards, or conduct back-to-back testing described in Q9,
What are the light-duty OEM GHG exhaust emission compliance requirements?
CH and N-.O standards (applicable to conditionally exempt and not exempt manufacturers):
Manufacturers are required to meet standards for CH4 and N2O of 0.030 g/mi and 0.010 g/mi,
respectively.1 Compliance with the standards is based only on FTP test results. Standards apply
at the EPA defined full useful life, meaning that deterioration factors (DFs) need to be applied to
low mileage test results. If there is no CH DF available, manufacturers may use an NMOG DF
to demonstrate compliance with the CH4 standard,
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Manufacturers may currently comply with the N2O standard by making a compliance statement
in their certification applications. This provision exists through the 2014 MY (proposed to be
extended through the 2016 MY).
Fleet average CO-, standards (not applicable to conversion manufacturers):
Manufacturers are required to meet fleet average CO2 standards using the vehicle specific CREE
measured emissions. The fleet average CO2 standards are based on vehicle "footprint" size (an
area in square feet determined from the product of vehicle specific track width and wheel base)
and the corresponding footprint size CO2 target values. Each manufacturer's fleet average CO2
standard will be unique due to differences in vehicle footprint size and a manufacturer's product
sales mix. The manufacturer's vehicle CREE fleet average emission results are used to demon'
strate compliance to the standard. CREE is the sum of a vehicle subconfiguration 55% weighted
rf FTP test result with a corresponding 45% Hwy test result. The FTP and Hwy CREE emissions
are reported at the EPA defined full useful life, meaning deterioration factors need to be applied
to low mileage test results. EPA GHG regulations define CO2 emissions as having zero deteriora-
tion over the EPA defined full useful life.
The fuel specific CREE calculation methodology is presented in 40 CFR part 600.1 13-12. Note
that CREE calculations adjust the carbon containing exhaust constituents by multiplying the
ft\ specific carbon pollutant in g/mi by the ratio of the molecular weight of CO2 to the molecular
weight of the other corresponding carbon pollutants. This methodology assumes that the carbon
containing exhaust emissions are completely converted to carbon dioxide, or carbon dioxide
J equivalent in the atmosphere,
40CFRpart86.1818-12(f)(l).
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Where are the light-duty GHG standards for conversion manufacturers described?
The GHG standards for conversion manufacturers are described in 40 CFR part 85.525, as
amended. The April 8, 2011 fuel conversion regulations were amended as part of the Heavy-
Duty GHG rule (76 Fed. Reg. 57106, Sep. 15, 2011).
What GHG provisions apply to conversion manufacturers who are not exempt from GHG
requirements?
As provided in greater detail in 40 CFR part 85.525(a)(2)(i), conversion manufacturer compli-
ance with GHG emission standards may require compliance with the OEM in-use CO2 exhaust
standard for the vehicle "subconfiguration" that is identical to the fuel conversion emission data
vehicle. If the subconfiguration-derived in-use CO2 standard is not available to the conversion
manufacturer, for example because the vehicle was not tested by the OEM for fuel economy,
then the fuel converted vehicle must comply with the OEM "model type" in-use CO2 standard,
Subconfiguration, as defined in 40 CFR part 600.002-93 means a unique combination within a
vehicle configuration of equivalent test weight, road-load horsepower, and any other operational
characteristics or parameters which the Administrator determines may significantly affect fuel
economy within a vehicle configuration. The terms vehicle configuration, equivalent test weight,
and road-load horsepower are further defined in 40 CFR part 600.002-93,
Model type, as defined in 40 CFR part 600.002-93 means a unique combination of car line, basic
engine, and transmission class. The terms car line, basic engine, and transmission class are further
defined in 40 CFR part 600.003-93.
40 CFR part 85.525(a)(2)(i) also provides that converters comply with standards for CH4 of
0.030 g/mi, and for N2O of 0.010 g/mi. Standards apply at full useful life, or 120K miles. Until
the 2015 MY, OEMs and conversion manufacturers may use a statement of compliance in lieu of
measuring and reporting N2O results.4
40 CFR part 85.525(a)(2)(i), paragraphs A-C, describe three options in lieu of meeting the
standards presented in Q5 above.
Paragraph A - If the OEM complied with the fleet averaging option for CH4 and N2O
using the OCREE methodology, the conversion manufacturer may demonstrate compli-
ance with standards by using the OCREE methodology in lieu of meeting the standalone
standards for CH4 and N2O. The fuel conversion OCREE test result must be less or equal
to the OEM OCREE test result.
/i \ Paragraph B - If the OEM used an "alternative" higher standard for CH4 and/or N2O, the
^•^ conversion manufacturer can demonstrate compliance by meeting the OEM alternative
higher standard. For example, an OEM could select a CH4 standard of 0.060 g/mi. The
conversion manufacturer would then be able to demonstrate compliance against this 0.060
g/mi standard.
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40 CFR part 86. 1829(b)(l)(iii)
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Paragraph C - Some types of converted vehicles will emit less CO2 than the OEM vehicle.
This option converts the difference between the manufacturer's "in-use CO2 exhaust emis-
sion standard" and the measured CO2 value for the converted configuration into equiva-
lents of CH4 and/or N2O g/mi emissions. These equivalents are then used to reduce the
CH and/or N2O emissions from the fuel converted vehicle and thereby show compliance
to the CH4 and/or N2O standards. This option is also available to conversion manufacturers
using an OEM's alternative higher standard. For GHG purposes, the method assumes 25 g/
mi of CO2 is equivalent to 1 g/mi of CH4, and 298 g/mi of CO2 is equivalent to 1 g/mi of
N2O.
Example of compliance with CH Standard: Assume an OEM's in-use CO2 exhaust
emission standard equals 400 g/mi CO2. Assume the corresponding fuel conversion test
vehicle produces the following CO2 and CH4 emission results:
CO2 = 325 g/mi
CH4 = 0.070 g/mi
Using the difference in CO2 test results and equating 25 g/mi CO2 to 1 g/mi CH4:
400-325 = 75 g/mi CO2
(75 g/mi CO2)/(25 g/mi CO2) yields a 3.000 g/mi CH4 "equivalent"
QJ
Reducing the fuel conversion CH4 test results by the GHG equivalent:
0.070 g/mi CH4 - 3.000 g/mi CH4 = a negative CH4 result
In this example, the negative adjusted fuel conversion CH4 result would be reported as
0.000 g/mi CH4, thus complying with the CH4 standard of 0.030 g/mi,
What if the OEM in-use standard is not available when the conversion manufacturer needs it?
The OEM in-use CO2 standard based on subconfiguration or model type may not be available
at the time the conversion manufacturer needs it. The OEM in-use CO2 standards will typically
not be available until April of the calendar year following the end of the model year. For
example, 2012 OEM in-use CO2 values will become available in April of 2013,
EPA has proposed in the 2017 GHG rulemaking to add a fourth option (Paragraph D) to 40
CFR part 85.525(a)(2)(i)(76 Fed. Reg. 74854, Dec. 1, 2011). This option is called the back-to-
back compliance testing option. GHG emissions would be measured before and after the fuel
conversion. Because CO2 emissions may be lower when the vehicle is operating on the alterna-
tive fuel, it may be possible to demonstrate that higher CH4 emissions when operating on CNG,
for example, are more than offset with lower CO2 emissions. The calculation methodology used
in the back-to-back testing is proposed to be the optional CREE reporting method (OCREE),
CP
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How do the light-duty GHG regulations impact OBD compliance for conversion
manufacturers?
There are no OBD GHG compliance requirements for OEMs or conversion manufacturers.
Where will the OEM in-use CO2 standards be published?
EPA is working to make these data available on an EPA website,
What are the Verify Data System GHG entry requirements?
Small Business Administration Exemption Data Entry - In addition to the other emission
test results, enter the FTP CH4 test result in the Verify Test Information dataset. Enter a
CREE or OCREE value of 0.0
Do not enter standards or DFs for CH4, N2O, CREE or OCREE in the Verify Test Group
dataset.
No pass/fail determinations will be displayed as part of the Test Group Information dataset
for CH4, N2O, CREE or OCREE because no standards were entered for these GHG
emissions,
Conditional Exemption Data Entry - In addition to the other emission test results, enter
the FTP CH test result in the Verify Test Information dataset. Enter a CREE or OCREE
value of 0.0
Do not enter CO2 in-use standards or DFs for CREE or OCREE in the Verify Test Group
dataset. Do not enter an N2O standard if meeting the standard is based on a compliance
statement. Enter the CH4 standard only if the fuel conversion CH4 test result passes the
0.030 g/mi standard or the higher OEM alternative CH standard.
A "Pass" determination will be displayed in the Certification Summary Information (CSI)
report if the CH4 result meets the CH4 standard, or the higher OEM alternative CH4 stan-
dard. No pass/fail determination will be displayed for N2O, CREE, or OCREE because no
standards were entered for these GHG emissions.
If the back'tO'back testing option was exercised to show compliance with the CH
standard, the comparisons of the before and after fuel conversion tests are based on the
OCREE calculation methodology. These comparisons should be reported in Manufacturer
(1 ^ Test Comments so they will appear on the Verify CSI report. EPA will examine these
results to determine that GHG emissions have not been increased.
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Not Exempt Data Entry -
A) Compliance is demonstrated against the OEM standards
Enter in the Verify Test Information dataset the fuel conversion test results for CREE or
OCREE, and CH . Conversion manufacturers will need to apply DFs to their emission
results using EPA assigned DFs if necessary. A "Pass" determination will be displayed in
the Certification Summary Information (CSI) report if the CH4 result meets the CH4
standard, or the higher OEM alternative CH standard. Even though CREE or OCREE
standards and test results were entered, Verify will not return a pass/fail determination,
EPA will examine the OEM CREE or OCREE standards and fuel conversion CREE or
OCREE test results to confirm that GHG emissions have not been increased,
If the OEM reports an in-use CO2 standard based on CREE methodology, enter in the
Verify Test Group dataset the OEM in-use CO2 CREE standard (based on subconfiguration
or model type) as the fuel conversion test vehicle CREE standard. Enter the CH4 standard
if the conversion CH result will meet the CH standard or the optional OEM higher CH
standard. Do not enter an N2O standard if meeting the standard is based on a compliance
statement.
If the OEM reports an in-use CO2 standard based on OCREE methodology, enter the
OEM in-use CO2 OCREE standard (based on subconfiguration or model type) as the fuel
conversion test vehicle OCREE standard. Do not enter CH4 or N2O standards because the
OEM chose to use the OCREE compliance option.
If the fuel conversion CH4 test result does not meet the CH4 standard or the optional
higher OEM CH4 standard, and the OEM has reported a CREE in-use CO2 standard, do
not enter a CH4 standard. In this case, compliance with the CH4 standard may be deter-
mined using the CO2 equivalence approach described in Paragraph C in Q6 above. Dem-
onstrating that the CH4 result passes the CH4 standard using the approach in Paragraph
C should be shown in Manufacturer Test Comments so that the test results will appear on
the CSI document. EPA will examine the results to determine that the CH4 standard, or
the higher OEM alternative CH4 standard has been met.
B) Compliance is demonstrated using the back-to-back testing option
Enter in the Verify Test Information dataset the CH4 and OCREE alternative fuel test re-
suits. Enter the pre -conversion OCREE results, for example based on testing with gasoline,
in Manufacturer Test Comments so they appear on the CSI document. DFs need not be
applied to the pre and post conversion OCREE test results,
Do not enter standards or DFs for CH4, CREE, or OCREE in the Verify Test Group
dataset. Do not enter an N2O standard if meeting the standard is based on a compliance
statement.
A compliance demonstration using the back-to-back testing option is based on showing
that the GHG emissions from the converted test vehicle have not been increased,
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Are there other unique Verify data entries, or questions to be ignored, given the program-
matic differences between conventional certification (40 CFR part 86 regulations) and fuel
conversion regulations (40 CFR part 85 regulations)?
Yes. In the Certificate Request module, do not respond by answering Yes or No to the question
"Has the Greenhouse Gas Pre-Model year report been submitted to EPA for this model year and
does it meet all the requirements of 40 CFR 600.514 or 40 CFR 1037.104? This question is only
applicable for OEMs,
How will GHG reporting be handled for conversion manufacturers submitting notifications
under the Intermediate Age Vehicle program?
EPA data forms and Excel spreadsheets are being revised to accept reporting of GHG emissions,
but at present EPA will assess compliance by examining the test results submitted to support the
IAV notification.
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