EPA Greenhouse Gas Provisions
Applicable to Clean Alternative Fuel
Conversions of Heavy Duty Class 2b
and 3 Vehicles:
Frequently Asked Questions
This information is intended to assist manufacturers that convert
Heavy duty Class 2b and 3 vehicles to operate on alternative
fuels such as compressed natural gas fuel, liquified natural gas fuel,
propane gas fuel and even electric fuel for automotive use, in under-
standing the Heavy Duty (HD) class 2b and 3 vehicle Greenhouse
Gas (GHG) regulations. It is not a substitute for compliance with
GHG emission requirements in 40 CFR part 1037, subpart B, sections
1037.104, 1037.115 and 1037.150 and referenced sections in 40
CFR part 86, subpart S.
Note: As explained in Section XII of 80 FR 40137 July 13, 2015, Greenhouse Gas
Emissions and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and
Vehicles; Phase 2; Proposed Rule, footnote #41 states, "EPA is proposing to recodify
the Phase 1 requirements for pickups and vans from 40 CFR 1037.104 into 40 CFR
part 86, which is also the regulatory part that applies for light-duty vehicles." If
accepted as proposed, the regulatory cites that appear in this FAQ document will be
updated when the final rule is published.
These questions and answers present compliance information that is generally appli-
cable to HD class 2b and 3 vehicle conversions. The Appendix provides additional
information applicable to certain special conversion circumstances, such as conversion
to dual-fuel vehicles and Original Equipment Manufacturer (OEM) protocol-dependent
conversion options.
SEPA
United States
Environmental Protection
Agency
Office of Transportation and Air Quality
EPA-420-F-15-047
October 2015
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What are the OEM Class 2b & 3 HD GHG Rule Requirements?
To provide perspective, this section is a general discussion of the GHG regulations as they apply
to OEMs. A subsequent section of this document will address the special provisions that apply
specifically to Class 2b & 3 Alternative Fuel Conversion (AFC) manufacturers.
Ql. What GHG emissions does the HD vehicle GHG rule regulate?
GHG exhaust emissions include carbon dioxide (CO2), methane (CH4), and nitrous oxide
(N2O). Under the HD GHG rule, CO2 in-use and fleet average GHG compliance is based
solely on CO2 emissions (different from Light-Duty Vehicle (LDV) GHG where the compli-
ance is based on all carbon related exhaust emissions - called "CREE"). Compliance with the
HD CO2 standards is based on a CO2 emissions weighting of 55% of the city test results and
45% of the highway test results.
The HD GHG regulations also include individual standards for CH4 and N2O. Compliance for
CH4 and N2O is again based on emissions weighting of 55% of the city test results and 45% of
the highway test results (again, different from LDVs where only the city test results are used to
determine compliance to the N2O and CH4 standards).
The HD GHG rule also regulates GHG emissions caused by leakage from the air conditioning
(A/C) system (A/C refrigerants can be potent GHGs). OEMs must comply with A/C system
refrigerant leakage requirements. An AFC manufacturer that modifies the OEM A/C system
may require additional refrigerant leak compliance testing. Please check with an EPA Certifica-
tion Representative if you think this requirement applies to you.
Q2. When do the OEM Class 2b & 3 HD vehicle GHG regulations take effect?
The GHG Emissions Standards and Fuel Efficiency Standards for Medium- and Heavy-Duty
Engines and Vehicles Rule (HD GHG rule) is codified in 40 CFR 1037. Part 1037 established
GHG emission standards starting with model year (MY) 2014. OEMs may also elect to optionally
comply with the GHG standards in MY 2013,
Q3. What are the OEM Class 2b & 3 HD vehicle GHG exhaust emission compliance re-
quirements?
OEMs are required to meet in-use CO2 standards. The same standards are applicable to HD
GHG AFC manufacturers:
Compliance is demonstrated by meeting a standard equal to the vehicle subconfiguration CO2
emissions multiplied by 1.10. Unlike conventional emission standards, CO2 in-use standards
may not be available when needed by the AFC manufacturer that intends to convert one or
more specific OEM vehicle test group(s), shortly after the OEM vehicle test group(s) is/are
released into commerce. In that case, use the method described in Q8, Paragraph C,
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OEMs are also required to meet CH4 and N2O emission standards. Again, these same standards
are also applicable to HP GHG AFC manufacturers:
The CH4 and N2O standards are 0.05 g/mi and 0.05 g/mi, respectively.1 Compliance with the
standards is based on a 55% weighted city test result with a corresponding 45% weighted high-
way test result. The OEM may elect a higher alternate standard for CH4 and/or N2O (See Q8
Paragraph A). Standards apply at the EPA defined full useful life, meaning that deterioration
factors (DFs) need to be applied to low mileage test results (unless the OEM used fully aged
components).
Typically, DFs do not apply to CO2 emissions. However, Plug-In Electric Hybrid vehicles will
likely experience higher In-Use CO2 as the battery-pack performance deteriorates over its use-
ful life. In this particular case, the battery deterioration should be accounted for,
OEM fleet average CO2 emission standards do not apply to most HP GHG AFC manufacturers:
OEMs are required to meet fleet average CO2 standards using the vehicle specific CO2 mea-
sured emissions. Given that compliance with CO2 standards is a fleet averaging compliance
program, OEMs may exercise considerable flexibilities in achieving compliance through averag-
ing, banking, and trading of GHG credits. OEM compliance with fleet average CO2 standards
is based on each OEM's GHG report submitted to EPA. This report must be submitted to EPA
within 90 days of the end of the calendar year in which the certificate of compliance expired.
Most HD GHG Class 2b and 3 AFC manufacturers are currently Small Business exempt manu-
facturers. However, currently only 1 or 2 AFC manufacturers are not GHG exempt and are thus
required to comply with the same requirements as the OEM manufacturers.
Q4. How do HD GHG Class 2b & 3 Rules differ for AFC manufacturers?
With the exception that AFC manufacturers do not have to comply with a fleet average CO2
emission standard, the GHG standards generally apply in the same way to a converted vehicle
as they do to the OEM vehicle. That means that class 2b and 3 AFC manufacturers comply by
demonstrating that the converted vehicle meets the same GHG emission standards that the
OEM certified to. If an OEM elected to early comply with GHG standards in MY 2013, the
AFC manufacturer of that vehicle would also have to comply with the GHG standards of MY
2013.
Q5. Does the 'small business' status described in 40 CFR Part 1037, subpart B regulations
also apply to AFC manufacturers? Describe the requirements to demonstrate GHG compli-
ance for the different exemption status categories?
Yes. The exemption categories described in 40 CFR 1037.150 (c), subpart B, also apply to AFC
manufacturers.
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Small Business Administration (SBA) Exclusion:
If an AFC manufacturer employs less than 1,000 employees worldwide and is engaged in manu-
facturing, it is not subject to the GHG standards in §§1037.104 through 1037.106. Note that
qualification for this exclusion under the SBA regulation is determined by the aggregate number
of employees of all affiliate companies. Although the AFC manufacturer does not need EPA
approval to qualify as excluded, it must submit to EPA a written notification describing its SBA
qualification justification. Labels must also be affixed to its AFC vehicles stating that "This
vehicle is excluded under 40 CFR 1037.150 (c)". If an OEM is exempt as an SBA exclusion, the
AFC manufacturer would be exempt as well under 40 CFR 1037.150 (c ),
Conditional Exemption:
The GHG conditional exemption does not apply to HD vehicles (unlike light-duty vehicles),
Not Exempt:
If the AFC manufacturer does not qualify for SBA exclusion, it must meet the GHG require-
ments described in Ql-3 [above] and presented in 40 CFR 85.525(a)(2)(iii). This includes
meeting the in-use exhaust CO2, the CH4 and the N2O emission standards. The AFC manu-
facturer may exercise any of the compliance options described in Q8, paragraphs A, B or C to
meet the standards.
Q6. How do HD GHG requirements differ between OEMs and AFC manufacturers?
The GHG compliance requirements that exist for AFC manufacturers differ from the require-
ments for OEMs in a number of ways. AFC manufacturers:
1. Do not comply with a fleet average CO2 standard
2. Do not have the option to earn, bank, average, or trade credits
3. Do not submit pre- or final model year GHG compliance reports
4. Do not participate in any special credit programs available to the OEMs, such as early
credits, fleet average credits, or advanced technology vehicle credits.
Q7. Where are the HD GHG requirements for AFC manufacturers codified?
The GHG compliance requirements for AFC manufacturers are presented in 40 CFR Part
85.525, as amended. The April 8, 2011 AFC regulations were amended as part of the Heavy-
Duty GHG final rule and the Light-Duty GHG 2017 final rule. The Heavy-Duty GHG final rule
amendments were published in the Federal Register Vol. 76, FR 57106, September 15, 2011,
The Light-Duty GHG 2017 final rule amendments were published in the Federal Register Vol.
77, FR 62624, October 15, 2012.
In addition EPA published a direct final rule (technical amendments) on June 17, 2013. The
heavy duty technical amendments were published in the Federal Register Vol. 78, FR 36370,
June 17, 2013.
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Q8. What Class 2b and 3 HD GHG provisions apply to AFC manufacturers?
Provisions applicable to HD class 2b and 3 conversions are set forth in 40 CFR part 85.525(a)
(2)(iii). AFC manufacturer compliance with GHG emission standards requires compliance with
the OEM in-use CO2 exhaust standard for the vehicle "subconfiguration" that is identical to the
AFC manufacturer's emission data vehicle,
Subconfiguration, as defined in 40 CFR part 1037.104 (d)(12) means a unique combination
within a vehicle configuration of equivalent test weight, road-load horsepower, and any other
operational characteristics or parameters which the EPA determines may significantly affect
CO2 emissions within a vehicle configuration. The terms equivalent test weight, and road-load
horsepower are further defined in 40 CFR part 600.002-93. The term vehicle configuration is
further defined in 40 CFR part 1037.104 (d)(12).
40 CFR part 85.525(a)(2)(iii) also requires that the AFC manufacturer meet standards for CH4
of 0.050 g/mi, and for N2O of 0.050 g/mi. The CH4 and N2O standards apply at full useful life,
or 120K miles.
40 CFR part 85.525(a)(2)(iii), paragraphs A-C, describe three options in lieu of meeting the
standards presented in Q5 above,
Paragraph A:
If the OEM used an "alternative" higher standard for CH4 and/or N2O, the AFC manufacturer
may demonstrate compliance by meeting the OEM alternative higher standard. For example, an
OEM may select a CH4 standard of 0.080 g/mi. The AFC manufacturer would then demonstrate
compliance against this 0.080 g/mi standard,
Paragraph B:
Some types of alternative fuel converted vehicles will emit less CO2 than the OEM vehicle.
This option takes the difference between the manufacturer's "in-use CO2 exhaust emission stan-
dard" and the measured CO2 value for the converted configuration and calculates equivalents
of CH4 and/or N2O g/mi emissions. These equivalents are then used to reduce the CH4 and/
or N2O emissions from the alternative fuel converted vehicle and thereby show compliance to
the CH4 and/or N2O cap standards. This option is also available to AFC manufacturers using
an OEM's alternative higher standard. For GHG purposes, the method assumes 25 g/mi of CO2
equates to 1 g/mi of CH4, and 298 g/mi of CO2 equates to 1 g/mi of N2O,
Example of compliance with CH4 standard: Assume an OEM's in-use CO2 standard for the
equivalent fuel conversion test vehicle equals 400 g/mi CO2. Assume the fuel conversion test
vehicle produces the following CO2 and CH4 emission results when tested on the alternative
fuel:
CO2 = 325 g/mi
CH4 = 0.070 g/mi
a
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Using the difference in CO2 test results and equating 25 g/mi CO2 to 1 g/mi CH4:
400-325 = 75g/miCO2
(75 g/mi CO2)/(25 g/mi CO2) yields a 3.000 g/mi CH4 "equivalent"
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 easily demonstrating compliance with the CH4 standard of 0.050 g/mi,
Paragraph C:
AFC manufacturers may also comply with the GHG standards by comparing emission test re-
sults from the vehicle before and after the alternative fuel conversion. This option is called the
back'to-back testing option. Because CO2 emissions may be lower when the vehicle is operat-
ing on the alternative 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
sum of in-use CO2 emissions, and CH4 and N2O emissions shall be calculated for pre- and
post-conversion FTP test results, where CH4 and N2O are weighted by their global warming
potential of 25 and 298, respectively. The post-conversion sum of these emissions must be lower
than the sum of the pre-conversion emissions. If the OEM used a compliance statement in lieu
of generating N2O emissions (which is allowed through MY 2014), then the AFC manufacturer
may also disregard the N2O emissions in the calculations.
The OEM in-use CO2 standards based on vehicle subconfiguration data may not be available at
the time the AFC manufacturer needs it. For example, some MY 2014 OEM in-use CO2 values
may not be available until April of 2015. If the OEM in-use CO2 standard is not available when
the AFC manufacturer plans to conduct emission compliance testing, the only option available
to demonstrate compliance to the GHG standards is the back-to-back testing option provided
in this Paragraph C,
EPA will make the in-use CO2 emissions data available as it is received on the following EPA
website: http://www.epa.gov/oms/consumer/fuels/altfuels/altfuels.htm under the heading, "Other
Information",
Q9. How do the heavy-duty GHG regulations impact OBD compliance for AFC
manufacturers?
There are no OBD GHG compliance requirements for OEMs or AFC manufacturers,
Q10. What are the requirements for entering GHG data into the Verify data system?
General data entry requirements:
A) Compliance is demonstrated against the GHG standards
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Enter in the Verify Test Information dataset the AFC manufacturer's test results for CO2, N2O,
and CH4. AFC manufacturers will need to enter DFs for their N2O, and CH4 emission results
using EPA assigned DFs if necessary. A "Pass" determination will be displayed in the Certifi-
cation summary Information (CSI) report if the CH4 result meets the CH4 standard, or the
higher CH4 standard in the OEM application. A "Pass" determination will be displayed in the
Certification summary Information (CSI) report if the N2O result meets the N2O standard, or
the higher N2O standard in the OEM application. Even though in-use CO2 standards and test
results were entered, Verify will not return a pass/fail determination. EPA staff will examine the
CO2 standards and the AFC manufacturer's CO2 test results to confirm that GHG emissions
pass the standards.
If the OEM in-use CO2 standard is available, enter that CO2 value in the Verify Test Group da-
taset as the AFC manufacturer's test vehicle CO2 standard. Enter the CH4 standard if the AFC
manufacturer's CH4 result will meet the CH4 standard or the optional higher CH4 standard in
the OEM application. Enter the N2O standard if the AFC manufacturer's N2O result will meet
the N2O standard or the optional higher N2O standard in the OEM application. Through MY
2014, the AFC manufacturer may use a compliance statement instead of an actual N2O stan-
dard. If the compliance statement is used in lieu of a N2O standard, do not enter a N2O stan-
dard. After MY 2014, the AFC manufacturer must meet either the N2O emission standard or
the higher N2O standard in the OEM application, and that value shall be entered in the Verify
Test Group dataset.
If the AFC manufacturer's CH4 test result does not meet the CH4 standard or the optional
higher OEM CH4 standard, and the OEM has reported an in-use CO2 standard, do not enter
a CH4 standard. In this case, compliance with the CH4 standard may be determined using the
CO2 equivalence approach described in Paragraph C in Q8 above. Demonstrating that the CH4
result passes the CH4 standard using the approach in Paragraph C should be shown in Manufac-
turer Test Comments so they 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.
If the AFC manufacturer's N2O test result does not meet the N2O standard or the optional
higher OEM N2O standard, and the OEM has reported an in-use CO2 standard, do not enter
a N2O standard. In this case, compliance with the N2O standard may be determined using the
CO2 equivalence approach described in Paragraph C in Q8 above. Demonstrating that the N2O
result passes the N2O standard using the approach in Paragraph C should be shown in Manu-
facturer Test Comments so they will appear on the CSI document. Alternatively, through MY
2014, the AFC manufacturer may use a N2O compliance statement in lieu of the N2O standard,
EPA staff will examine the results to determine that the N2O standard, or the higher OEM al-
ternative N2O standard has been met, or that a N2O compliance statement has been submitted
(which is only allowed through MY 2014).
B) Compliance is demonstrated using the back-to-back testing option
Enter in the Verify Test Information dataset the CH4, N2O and CO2 test results for the AFC
manufacturer's vehicle operating on the alternative fuel. Enter the pre-conversion CO2 results,
for example, based on testing with the OEM fuel, in Manufacturer Test Comments so they ap-
pear on the CSI document. DFs need not be applied to the pre and post conversion CO2 test
results,
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Do not enter standards or DFs for CH4, N2O or CO2 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 AFC manufacturer's test vehicle have not been increased,
If an AFC manufacturer qualifies for a Small Business Administration exclusion:
In addition to the other criteria pollutant emission test results, enter the city and highway
CH4 test results in the Verify Test Information dataset. It must enter a CO2 value of 0.0 g/mile
(Verify requires data entry into this field) so that Verify will be able to issue a certificate to the
AFC manufacturer.
Do not enter standards or DFs for CH4, N2O or CO2 in the Verify Test Group dataset,
No pass/fail determinations will be displayed as part of the Test Group Information dataset for
CH4, N2O or CO2 because no standards were entered for these GHG emissions,
Conditional Exemption Data Entry:
Does not apply to HD vehicles.
Ql 1. How will GHG compliance reporting be handled for AFC manufacturers submitting
notification applications under the Intermediate Age Vehicle/Engine and/or the Outside Use-
ful Life Vehicle/Engine program(s)?
All but 1 or 2 AFC manufacturers are currently SBA excluded. SBA excluded manufacturers
are exempt from GHG compliance requirements. However, they must notify their Designated
Compliance Officer each model year before introducing these excluded vehicles into U.S.
commerce. The notification should include a description of the manufacturer's qualification
as a small business under 13 CFR 121.201. Excluded vehicles must be labeled with the following
statement: "This vehicle is excluded under 40 CFR 1037.150(c )". This exclusion statement
may be added the existing conversion label. GHG excluded AFC manufacturers must comply
with the reporting and recordkeeping requirements specified in §85.535(e) and (f).
Any AFC manufacturers that are not excluded from GHG demonstration will have to show
compliance with the in-use CO2, CH4 and N2O GHG emission standards, using any of the
Options in Q8 (above). These AFC manufacturers must comply with the recordkeeping require-
ments in 40 CFR 1037.150(b) through (d), and they must label each vehicle that they convert
and keep VIN #'s for up to 8 years,
AFC manufacturers that market conversion systems for use on vehicles/ engines other than the
test group/engine families and evaporative/refueling families covered by the compliance demon'
stration and notification may be liable for a tampering violation.
o
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APPENDIX
Dual-fuel vehicle conversions:
The GHG compliance information in this document applies if the OEM's original emissions
calibration is unaltered in the conversion to a dual-fuel configuration.
If the conversion involves any changes to the OEM's calibration strategies, the AFC manufacturer
must provide test results demonstrating that the converted vehicles/engines meet all applicable
emission standards and a good engineering judgment analysis explaining why the changes are
necessary and why they will not increase in-use emissions deterioration,
Testing options for HP 2b and 3 conversion compliance demonstrations:
AFC manufacturers must generally use the same test procedure to demonstrate compliance with
the HD GHG regulations that the OEM used to certify. The information in this Q/A document
is applicable to chassis test procedures. The table below summarizes applicability to various ve-
hicle types, based on certification testing options available to the OEM,
Vehicle Type
Complete
Incomplete
Class 4 +
SI
CIMY2017& earlier
CIMY2018&later
SI and CI
SI
Test Procedure
OEM
chassis
chassis or engine
chassis
chassis or engine
chassis or engine
AFC
Manufacturer
chassis
same as OEM
chassis
same as OEM
same as OEM
Q/A Applicable?
yes
maybe*
yes
maybe
maybe
o
Complete HD Compression Ignition Vehicle Certification Election:
OEM's must certify spark ignition HD 2b and 3 vehicles using the chassis certification process.
For model years prior to 2018, OEM's may also optionally elect to certify complete compression
ignition HD Class 2b and 3 vehicles using the chassis certification process (instead of engine
dynamometer certification). As adopted, beginning in model year 2018, the Tier 3 Motor
Vehicle Emission and Fuel Standards final rule requires that OEM's certify complete HD
compression ignition class 2b and 3 vehicles using the chassis certification process.
Prior to model year 2018, if the OEM elected to certify compression ignition HD complete
vehicles using the chassis process, the Q&A's contained in this document also apply to those
compression ignition fuel conversion complete vehicles. For model years 2018 and later the
Q&A's contained in this document apply to compression ignition fuel conversion HD 2b and 3
complete vehicles,
Incomplete HD Spark and Compression Ignition Vehicle Certification Election:
OEM's may also optionally elect to certify incomplete spark ignition and/or compression ignition
HD Class 2b and 3 vehicles using the chassis certification process. If the OEM certified these
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vehicles using the chassis process, the Q&A's contained in this document also apply to those
incomplete spark and compression ignition fuel conversion vehicles,
Spark Ignition HP Vehicle Class 4 and Above Optional Chassis Test GHG Election:
OEM's may also optionally elect to chassis test complete and/or incomplete spark ignition HD
Class 4 and above vehicles to demonstrate compliance to the greenhouse gas requirements.
Chassis vehicle testing is conducted on a similar "sister vehicle". If the OEM elected to comply
with the GHG requirements using the chassis test process, the Q&A's contained in this document
also apply to those classes of HD fuel conversion vehicles.
Further Infromation
For further information, please contact:
complianceinfo@epa.gov
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