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Comments on Tier 3 LDV NPRM

Comments on Tier 3 LDV NPRM

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International Council on Clean Transportation: Comments in Response to the Proposed Rulemaking Issued by the Environmental Protection Agency on Control of Air Pollution from Motor Vehicles, Tier 3 Motor Vehicle Emissions and Fuel Standards, Docket ID No. EPA–HQ–OAR– 2011–0135
International Council on Clean Transportation: Comments in Response to the Proposed Rulemaking Issued by the Environmental Protection Agency on Control of Air Pollution from Motor Vehicles, Tier 3 Motor Vehicle Emissions and Fuel Standards, Docket ID No. EPA–HQ–OAR– 2011–0135

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10/10/2013

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 ICCT Comments in Response to the Proposed Rulemaking Issued by theEnvironmental Protection Agency on Control of Air Pollution from MotorVehicles:Tier 3 Motor Vehicle Emissions and Fuel Standards
 
Docket ID No. EPA–HQ–OAR– 2011–0135July 1, 2013
These comments are submitted by the
International Council on CleanTransportation (hereafter, “ICCT”).
The ICCT is made up of leading governmentofficials and experts from major countries and regions around the world who participateas individuals based on their experience with air quality and transportation issues. TheICCT promotes best practices and comprehensive solutions to improve vehicleemissions and efficiency, increase fuel quality and sustainability of alternative fuels,reduce pollution from the in-use fleet, and curtail emissions of local air pollutants andgreenhouse gases (GHG) from international goods movement.
Overall Summary
The ICCT strongly supports the proposed Tier 3 standards and commends EPA fortaking the proposed steps to improve public health. The standards will maintain U.S.leadership in light duty vehicle emission control and allow the US to catch up to Europeon gasoline fuel quality. Not only will the requirements improve public heath in the US,they will help accelerate introduction of inexpensive emission controls in other countries.We applaud EPA, along with the California Air Resources Board, for taking another longstep along the road to a sustainable transportation system.While there are a few areas in which the rule could be improved, overall the provisionsare reasonable. The costs to comply are modest and likely overstated by EPA. Thefeasibility of the proposed Tier 3 standards has already been demonstrated by thenumerous vehicles that already meet the California LEV III standards and Tier 2 bin 2standards. The two keys to low emissions are precise air/fuel control and rapid catalystlight-off. Since the Tier 2 standards were adopted there have been major improvementsin both of these areas, making compliance with the proposed Tier 3 requirementseasier.The ICCT also commends the EPA for proposing to reduce gasoline sulfur to 10 ppm.Japan and South Korea have required 10 ppm sulfur in gasoline since 2007 and Europesince 2009. Even Chile has required 15 ppm sulfur in gasoline since 2010. Given theleadership shown by the US in most environmental areas, it is important for the US tocatch up on gasoline sulfur.
 
Our comments focus on ensuring that the final rule is as robust as possible. We havetwo primary objectives: first, to help ensure that the most robust cost information is usedfor vehicle emission control technology and reducing sulfur in gasoline; second, tosuggest improvements to the proposed SFTP standards and the adoption of E15certification fuel, which have the potential to reduce the overall effectiveness of EPA'sprograms. We also offer a number of comments on the heavy-duty provisions, futureFTP particulate standards, and some of the procedural issues.A summary of all of our comments on the proposed rule, followed by additional detail oneach item:1.
 
Major advancements have occurred in vehicle emission control technology.Catalysts have improved dramatically, fuel injection is more precise, feedback ofactual air/fuel ratio is faster, software algorithms to predict air/fuel ratio haveimproved, and drive-by-wire systems allow air and fuel to be changedsimultaneously. Further, development of initial idle retard for cold starts can bringthe catalyst above light-off temperature before the initial 20-second idle is done.As these and other improvements are primarily due to better software algorithms,meeting the vehicle standards will be easier and will cost much less thanassumed in the proposed rule. ICCT's analyses found that catalyst preciousmetals will cost only about a third as much as estimated in the draft RIA andOptimized CC Catalyst, Optimized Thermal Management, Secondary AirInjection, and Hydrocarbon Adsorbers will not be needed on the vast majority ofvehicles or will cost much less than estimated in the draft RIA.2.
 
The cost of reducing gasoline sulfur from 30 ppm to 10 ppm is very modest. TheICCT contracted with MathPro in 2011 to evaluate the cost of reducing sulfurfrom 30 to 10 ppm. MathPro found that the cost would be 0.8 to 1.4 cents pergallon, and these results are likely to be conservative.3.
 
The SFTP standards are too lenient and, as proposed, will not be effective.Current vehicles certified to Tier 2 bin 2 or LEVII-SULEV have averageNMHC+NOx emissions of less than 10 mg/mi, more than 80% below theproposed limit of 50 mg/mi in 2025. Similarly, the proposed SFTP particulatestandards are 3.3 times higher for vehicles < 6000 GVWR and 6.7 times higherfor vehicles > 6000 GVWR than the proposed FTP standard. Setting the SFTPstandards properly is especially important for diesel engines, as diesel emissioncontrol hardware requirements are largely set by the high load conditions on theSFTP. SFTP NMHC+NOx standards should be set at no more than 20 mg/mi andSFTP particulate standards at no more than 6 mg/mi.4.
 
While the ICCT supports using a more representative fuel for certification testing,E15 is not representative of in-use fuel. E15 can cause damage if it is used insmall engines or in legacy vehicles. E15 is also specific to ethanol, whichencourages the use of food feedstocks instead of more environmentally friendlyfeedstocks. Finally, E15 provides significant evaporate cooling, whichmanufacturers could exploit to generate higher fuel economy on the tests than
 
the vehicles actually experience in use. The ICCT recommends that the test fueluse E10.5.
 
The ICCT has similar concerns on any future use of engines using E30. Inaddition, we are concerned that E30 could open the door to E30 credits againstthe CAFE and GHG standards, similar to what has already occurred for FFVs. Itwould be much better for EPA to focus on increasing the octane rating of allgasoline.6.
 
The ICCT supports maintaining fuel-neutral criteria emissions standards forheavy-duty vehicles. We also fully support extending chassis-based emissionrequirements to all complete vehicles up to 14,000 gross vehicle weight andextending the supplemental FTP requirements to complete vehicles between8,500 and 14,000.7.
 
The ICCT supports updating the R-factor in the carbon balance equation for NHVchanges. Specifically, the R-factor determined by ORNL for Tier 2 vehicleswithout the data outlier should be used, or R=0.96.8.
 
A key concern for natural gas vehicles is the atmospheric venting of natural gasthat occurs during refueling. It is very important that this venting of natural gas becontrolled and recaptured. The ICCT recommends that EPA develop and adoptrequirements for refueling emissions from all gaseous-fueled vehicles.9.
 
The ICCT recommends that EPA harmonize with both the CARB 1 mg/mileparticulate mass standard starting with 2025 and the European particulatenumber standards. Currently, both requirements are hindered by the lack ofmeasurement precision, but continuing research into particulate measurementshould resolve these issues in the future.
1) Vehicle Emission Control Cost Assessments
The adoption of more stringent standards usually requires the improvement of currenttechnologies or the adoption of new ones. This results in additional cost tomanufacturers and the public. It is frequently difficult to assess the cost of improvedtechnology, as manufacturers regard cost information as confidential for competitivereasons.As emission control technology cost estimates had not been updated in 10 to 15 years,the ICCT conducted a study to update emission control costs, published last year.
1
Costestimates were conducted for the main emission control technologies, using updatedassessments of technology actually being used, impacts of learning as manufacturingvolumes increase, and technology improvements that have made the systems simpleror more efficient.
1
 
EstimatedCostofEmissionReductionTechnologiesforLight-DutyVehicles,ICCT,March2012.http://theicct.org/estimated-cost-emission-reduction-technologies-ldvs
 

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