ICCT 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
July 1, 2013
These comments are submitted by the International Council on Clean
Transportation (hereafter, “ICCT”). The ICCT is made up of leading government
officials and experts from major countries and regions around the world who participate
as individuals based on their experience with air quality and transportation issues. The
ICCT promotes best practices and comprehensive solutions to improve vehicle
emissions and efficiency, increase fuel quality and sustainability of alternative fuels,
reduce pollution from the in-use fleet, and curtail emissions of local air pollutants and
greenhouse gases (GHG) from international goods movement.

Overall Summary
The ICCT strongly supports the proposed Tier 3 standards and commends EPA for
taking 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 Europe
on 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 long
step along the road to a sustainable transportation system.

While there are a few areas in which the rule could be improved, overall the provisions
are reasonable. The costs to comply are modest and likely overstated by EPA. The
feasibility of the proposed Tier 3 standards has already been demonstrated by the
numerous vehicles that already meet the California LEV III standards and Tier 2 bin 2
standards. The two keys to low emissions are precise air/fuel control and rapid catalyst
light-off. Since the Tier 2 standards were adopted there have been major improvements
in both of these areas, making compliance with the proposed Tier 3 requirements
easier.

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 Europe
since 2009. Even Chile has required 15 ppm sulfur in gasoline since 2010. Given the
leadership shown by the US in most environmental areas, it is important for the US to
catch up on gasoline sulfur.

Our comments focus on ensuring that the final rule is as robust as possible. We have
two primary objectives: first, to help ensure that the most robust cost information is used
for vehicle emission control technology and reducing sulfur in gasoline; second, to
suggest improvements to the proposed SFTP standards and the adoption of E15
certification fuel, which have the potential to reduce the overall effectiveness of EPA's
programs. We also offer a number of comments on the heavy-duty provisions, future
FTP particulate standards, and some of the procedural issues.

A summary of all of our comments on the proposed rule, followed by additional detail on
each item:

1. Major advancements have occurred in vehicle emission control technology.
Catalysts have improved dramatically, fuel injection is more precise, feedback of
actual air/fuel ratio is faster, software algorithms to predict air/fuel ratio have
improved, and drive-by-wire systems allow air and fuel to be changed
simultaneously. Further, development of initial idle retard for cold starts can bring
the 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 than
assumed in the proposed rule. ICCT's analyses found that catalyst precious
metals will cost only about a third as much as estimated in the draft RIA and
Optimized CC Catalyst, Optimized Thermal Management, Secondary Air
Injection, and Hydrocarbon Adsorbers will not be needed on the vast majority of
vehicles 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. The
ICCT contracted with MathPro in 2011 to evaluate the cost of reducing sulfur
from 30 to 10 ppm. MathPro found that the cost would be 0.8 to 1.4 cents per
gallon, 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 average
NMHC+NOx emissions of less than 10 mg/mi, more than 80% below the
proposed limit of 50 mg/mi in 2025. Similarly, the proposed SFTP particulate
standards are 3.3 times higher for vehicles < 6000 GVWR and 6.7 times higher
for vehicles > 6000 GVWR than the proposed FTP standard. Setting the SFTP
standards properly is especially important for diesel engines, as diesel emission
control hardware requirements are largely set by the high load conditions on the
SFTP. SFTP NMHC+NOx standards should be set at no more than 20 mg/mi and
SFTP 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 in
small engines or in legacy vehicles. E15 is also specific to ethanol, which
encourages the use of food feedstocks instead of more environmentally friendly
feedstocks. Finally, E15 provides significant evaporate cooling, which
manufacturers could exploit to generate higher fuel economy on the tests than
the vehicles actually experience in use. The ICCT recommends that the test fuel
use E10.
5. The ICCT has similar concerns on any future use of engines using E30. In
addition, we are concerned that E30 could open the door to E30 credits against
the CAFE and GHG standards, similar to what has already occurred for FFVs. It
would be much better for EPA to focus on increasing the octane rating of all
gasoline.
6. The ICCT supports maintaining fuel-neutral criteria emissions standards for
heavy-duty vehicles. We also fully support extending chassis-based emission
requirements to all complete vehicles up to 14,000 gross vehicle weight and
extending the supplemental FTP requirements to complete vehicles between
8,500 and 14,000.
7. The ICCT supports updating the R-factor in the carbon balance equation for NHV
changes. Specifically, the R-factor determined by ORNL for Tier 2 vehicles
without the data outlier should be used, or R=0.96.
8. A key concern for natural gas vehicles is the atmospheric venting of natural gas
that occurs during refueling. It is very important that this venting of natural gas be
controlled and recaptured. The ICCT recommends that EPA develop and adopt
requirements for refueling emissions from all gaseous-fueled vehicles.
9. The ICCT recommends that EPA harmonize with both the CARB 1 mg/mile
particulate mass standard starting with 2025 and the European particulate
number standards. Currently, both requirements are hindered by the lack of
measurement precision, but continuing research into particulate measurement
should resolve these issues in the future.

1) Vehicle Emission Control Cost Assessments
The adoption of more stringent standards usually requires the improvement of current
technologies or the adoption of new ones. This results in additional cost to
manufacturers and the public. It is frequently difficult to assess the cost of improved
technology, as manufacturers regard cost information as confidential for competitive
reasons.

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
Cost
estimates were conducted for the main emission control technologies, using updated
assessments of technology actually being used, impacts of learning as manufacturing
volumes increase, and technology improvements that have made the systems simpler
or more efficient.


1
EstimatedCostofEmissionReductionTechnologiesforLight-DutyVehicles,ICCT,March2012.
http://theicct.org/estimated-cost-emission-reduction-technologies-ldvs
ICCT reviewed the emission control cost estimates in the draft RIA and compared them
against the results of our study. Our review indicates that, for some technologies, recent
cost reductions were not accounted for in the proposed rule. It appears that EPA is
using outdated and overstated cost estimates in many cases. Following is ICCT's
assessment of the direct manufacturing cost estimates in Table 2-5 from the draft
Regulatory Impact Analysis (RIA), reproduced here as Table 1.

Table 1. 2017MY Incremental Technology Direct Manufacturing Costs by Gasoline
Engine Type (2010$)
TECHNOLOGY
GASOLINE ENGINE TYPE
I4 V6 V8 HDV8
Catalyst loading (PGM) $61 $81 $101 $51
Optimized CC Catalyst $20 $40 $61 $61
Optimized Thermal management $30 $30 $30 $30
Secondary Air Injection NR $101 $101 N/R
Engine Calibration $2 $2 $2 $2
Hydrocarbon Adsorber NR NR $152 NR
Evap. Emission control $17 $17 $17 $17
NR: Not required

Catalyst Loading (PGM)

Table 2-5 in the draft RIA shows that the incremental direct manufacturing costs for
catalyst loading, Precious Group Metal Loading (PGM), from Tier 2, range from $61 for
a 4-cylinder engine to $81 for a V8. However, ICCT's 2012 study found that precious
metal loadings have been dramatically decreasing over time. For example, a 4-cylinder
2.0 L vehicle meeting Tier 2 standards only had $71 of precious metals total. While the
proposed rule did not specify the assumed percent increase in precious metal loadings,
it is clear that EPA is overestimating the cost of additional catalyst loadings compared to
today's applications.

One of the main reasons for manufacturers to avoid high PGM loading is the high and
extremely volatile cost of precious metals. PGM market price data is presented in
Figure 1. The annual average market price of Pt has escalated from about $12/g in
1992 to about $52/g in 2010. Rh prices reached prices above $200 per gram in 2008,
and fell to $79 in 2010. The volatility of precious metal prices is due, in part, to the
inelastic supply of Rh and Pd. While it is possible to increase Pt mining in response to
additional demand, Rh and Pd are largely byproducts of Pt and nickel mining and it is
not economical to increase mining just for additional Rh and Pd.



Figure 1 – PGM annual average market price, nominal values. From: Platinum
Today

Thus, the market has driven manufacturers to keep working on methods to reduce PGM
loading without having any impact on catalyst effectiveness or durability. ICCT's 2012
report assessed the precious metal reductions that have occurred though about 2010.
Table 2 summarizes ICCT's assessment of the amount of precious metal loading used
by 2010 vehicles meeting Tier 2 emission standards. This table assumes that the
catalyst volume is equivalent to engine size. This assumption is consistent with the
gasoline automotive catalyst literature, which varies between 0.8 and 1.1. Also, note
that PGM prices used for Table 2 have been updated from ICCT's 2012 report and use
the average price during one year (June 2012 –May 2013).

Table 2. Cost of PGM loading for catalyst used in Tier 2 gasoline vehicles


TIER 2
LOADING
PGM PRICE
PGM COST
PER LITER
PGM COST PER VEHICLE
g/L $/g $/L I-4, 2.0L V-6, 3.0L V-8, 4.0L
Pt 0.1 $50 5.0 $10 $15 $20
Pd 1.6 $22 35.2 $70.4 $105.6 $140.8
Rh 0.1 $39 3.9 $7.8 $11.7 $15.6
Total Costs 44.1 $88.2 $132.3 $176.4


The annual vehicle emission control technology review by Tim Johnson of Corning, a
renowned international expert on automotive catalysts, estimates that Tier 2 PGM
loadings have been reduced by 70% from Tier 1 levels, even thought emissions have
dropped by more than 90%.
2
This supports the PGM loadings in Table 2, if not
suggesting that the loadings in Table 2 are conservative.

In addition, a summary of recently published SAE papers on automotive catalyst
developments is presented below. These papers demonstrate that additional reductions
in precious metal loadings are expected in the future and that a 30 mg/mile NMOG+NOx
would not require a large increase in precious metal loadings.

Rohart et al. studied how new materials can be used to reduce PGM loading on TWC
applications.
3
A brief introduction to TWC technology presented in their report helps the
reader understand the evolution of materials for better performance. The first
generations of TWC relied on a simple mixture of ceria and PGMs; while now zirconia is
added to achieve better OSC performance under severe temperature conditions. Ceria-
zirconia mixed oxides materials achieved widespread adoption in TWCs by the 1990s.
High thermal stability demanded by closed coupled catalyst is a key property of
Zirconium based materials.

Researchers from Honda and Johnson Matthey demonstrated that precious metal
usage could be reduced by 25% with respect to current Tier 2 Bin 5 catalysts while
simultaneously lowering emissions to meet the new California LEVIII SULEV30
standard, using an improved layered catalyst.
4
. Their design is based on a Pd only
catalyst for the close-coupled (CC) position and a Pd/Rh improved catalyst for the
underfloor (UF) position. This design demands S<10 ppm fuel quality. The
researchers investigated several options for OSC materials, namely Ceria for the CC
catalyst and Zirconia on the UF catalyst, as well as Pd distribution among CC and UF
positions and washcoat layering. The total PGM loading (CC+UF) was reduced by 25%,
while Rh loading was reduced by 50%. The potential for SULEV30 compliance was
confirmed by testing the prototype TWC system under Supplemental FTP testing
(SFTP). Figure 1 illustrates the main results of the study.


2
Johnson,T.,"VehicularEmissionsinReview,"SAEInt.J.Engines6(2):2013,doi:10.4271/2013-
01-0538.
3
Rohart,E.,Larcher,O.,Allain,M.,Ottaviani,E.etal.,"HighThermostableHybridZirconia
MaterialsforLowLoadingPreciousMetalCatalystTechnology,"SAETechnicalPaper2005-01-
1107,2005,doi:10.4271/2005-01-1107
4
Matsuzono,Y.,kuroki,K.,Nishi,T.,Suzuki,N.etal.,"DevelopmentofAdvancedandLowPGM
TWCSystemforLEV2PZEVandLEV3SULEV30,"SAE2012-01-1242,2012

Figure 2 Emission test results with respect to (a) FTP target and (b) SFTP target
for LEV3 SULEV30 and 25% lower PGM loading than current LEV2 PZEV levels
[2012-01-1242].

Ball and Moser, of Umicore, studied the emission performance of two PZEV vehicles to
understand PGM loading of LEVIII vehicles.
5
The researcher group evaluated the cost
increments due to PGM loading at different emission levels on two PFI models. Their
data shows that moving from LEV70 (70 mg/mile NMOG+NOx) to SULEV30 (30
mg/mile NMOG + NOx) on a 2.4 L PFI vehicle, with secondary air injection, will result in
an increase of $26 in PGM costs. This is a third of what EPA has estimated for an I-4
and will imply a ~32% increase in PGM loading. The second 2.0 L PFI vehicle, without
secondary air injection, requires additional ~$11 in PGM costs, implying a ~16% extra
PGM loading in total. Total catalyst size increased between 40% and 200%. This would
have a small additional impact on substrate, washcoat and canning costs, of about $4 to
$20. It was determined that the placement of PGM and advanced catalyst technologies
are critical for low cost emission solutions.

PGM nano-catalyst technology can reduce the precious metal loading by 90%, while
improving thermal aging resistance, as demonstrated by Mazda researchers.
6
In a
conventional TWC, the PGM is deposited on the surface of the support material; particle
sintering (agglomeration into larger particles) occurs with thermal aging, resulting in
thermal deterioration. The new developed catalyst contains nano-sized PGM particles

5
Ball,D.andMoser,D.,"ColdStartCalibrationofCurrentPZEVVehiclesandtheImpactofLEV-
IIIEmissionRegulations,"SAETechnicalPaper2012-01-1245,2012,doi:10.4271/2012-01-
1245.
6
Iwakuni,H.,Miyoshi,S.,andTakami,A.,"DevelopmentofPGMSingleNanoCatalyst
Technology,"SAETechnicalPaper2009-01-1079,2009,doi:10.4271/2009-01-1079.
and specially designed washcoat materials. This development helps avoid thermal
sintering after constant high temperature exposure (Figure 3). Tests on the Japanese
10-15 mode show that the nano-PGM TWC performance was equivalent to the
traditional TWC, even with 1/10 of the original PGM loading. The size of the nano
particle remained constant even after 300 hours of thermal aging (Figure 4). OSC
loading was increased with the new nano-PGM technology and washcoat. This new
design was introduced in the Japanese market in MY2008.


Figure 3 Concept PGM single nano catalyst technology (SAE 2009-01-1079).

Figure 4 PGM Particle size after engine bench aging observed with TEM (SAE
2009-01-1079)

In summary, the literature shows that improvements in technology have reduced PGM
loadings and allowed more efficient TWCs. In fact, the literature suggests that ultralow
PGM loading is possible, with adequate durability and sulfur tolerance, by improving the
OSC formulation, washcoat layering and PGM zoning.

The trends of reducing PGM loading in parallel with more stringent standards suggest
that 30 mg/mile of NOMG+NOx can be achieved at very little extra PGM costs.
Assuming that the PGM loading increases an average of 20%, which is the average
value found in Ball and Moser’s work, the incremental costs of PGM loading should
range between $18 and $36 for Tier 3 vehicles, as presented in Table 3. This is about a
third of the cost assumptions in the draft RIA. Note that these cost estimates are still
very conservative, as other papers suggest that the PGM loadings for Tier 3 vehicles
can be reduced with respect to current Tier 2 Bin 5 PGM loading levels.

Table 3 – Total and Incremental expected PGM costs per vehicle for 30 mg/mile
NMOG+NOx
ITEM
TIER 3 - PGM COST PER VEHICLE
30 MG/MILE NMOG+NOX
$/L I-4, 2.0L V-6, 3.0L V-8, 4.0L
Total costs $106 $159 $212
Incremental costs with respect to Tier 2 Bin 5 $18 $27 $36



Optimized CC Catalyst, Optimized Thermal Management, Secondary Air Injection,
and Hydrocarbon Adsorber

Table 2-5 of the RIA lists substantial costs for Optimized CC Catalyst, Optimized
Thermal Management, Secondary Air Injection, and Hydrocarbon Adsorbers. While
these cost estimates are not unreasonable, the EPA is greatly overstating the need for
these technologies and the Technology Application Rates in Table 2-11 of the draft RIA
are far too high.

This is, in part, because EPA underestimates the benefits of fast catalyst light-off
strategies. These are discussed in section 1.4.1.2.1 of the draft RIA (page 1-23), but the
discussion does not quantify how much faster this technique can light off the catalyst. In
practice, ignition retard and higher air flow rates are already being used on some
production vehicles to light off the catalyst during the initial 20 second idle period. This
reduces, if not eliminates, the need for optimized close-coupled catalysts, improved
thermal management, secondary air injection, and hydrocarbon adsorbers. Given the
leadtime allowed by the proposed Tier 3 rule, this strategy can be effectively
implemented in all vehicles and will dramatically reduce the need for other measures to
reduce catalyst lightoff times.

Another factor is that thermal management in exhaust systems is already widespread. If
additional thermal management is needed, as noted by EPA in their draft RIA,
integration of the exhaust manifold into the cylinder head is an effective way to further
reduce catalyst light-off times. Not only does this allow the catalyst to be mounted
directly to the cylinder head for faster warmup, it is also a cost reduction.

Variable valve timing (VVT) reduces NOx emissions during hot, running operation and
improves idle stability, allowing more aggressive idle retard strategies to help light off
the catalyst. As VVT has already been adopted on most engines due to its efficiency
benefits, these emission control improvements are virtually free.

Another factor is that sulfur affects the efficiency, not just of future Tier 3 vehicles, but of
existing Tier 2 vehicles as well. Thus, removing sulfur will allow current catalyst systems
to operate more efficiently, even before considering catalyst improvements.

Warmed-up NOx catalyst conversion efficiency is strongly affected by air/fuel ratio
control. HC and CO oxidation can be maintained during brief rich excursions using
oxygen stored on the catalyst substrate. No similar mechanism exists for NOx reduction
during lean excursions. Every lean excursion - no matter how small or how brief -
negatively impacts NOx reduction.
7
Thus, the key to controlling warmed-up NOx
reduction is absolute control of the air/fuel ratio at stoichiometric. The catalyst
improvements discussed in section 1.4.1.3 of the draft RIA (page 1-28) are relatively
unimportant. Drive-by-wire systems are a key element of precise air/fuel control; the
other requirements are mainly better software algorithms. As drive-by-wire systems
have already been widely adopted for drivability and efficiency reasons, the cost of
reducing warmed-up NOx emissions is very low.

The draft RIA states (page 1-24):
It is anticipated that to meet the proposed Tier 3 SFTP standards, manufacturers
will need to ensure that fuel enrichment is not required on the US06 portion of the
FTP.
This statement is not accurate. The impacts of fuel enrichment on engine out HC and
NOx and on HC and NOx catalyst conversion efficiency are relatively modest.
8
Rich
operation results in large increases in engine-out CO emissions, but engine-out HC
emissions increase only modestly and NOx emissions decrease. In fact, engine-out CO
concentrations are an excellent way to calculate air/fuel ratio. Rich operation also
degrades HC and NOx conversion efficiency, but again the degradation is modest. It is
CO conversion efficiency that plummets during rich operation. HC is oxidized
preferentially to CO and oxygen storage on the substrate and the reduction of NOx
provides enough oxygen to maintain surprisingly high levels of HC oxidation with rich
air/fuel ratios for several seconds. Thus, as long as the SFTP CO standards are not
reduced, manufacturers will be able to use limited amounts of enrichment during the
US06 cycle without significantly impacting their ability to comply with the SFTP
standards.


7
John German, "Observations Concerning Current Motor Vehicle Emissions", SAE 950812,
Feb. 1995.
8
Ibid.
Finally, EPA also appears to be placing too much emphasis on early LEVII-SULEV
vehicles, some of which used secondary air injection or HC adsorbers to ensure
compliance. These were the first vehicles to comply with lower emission standards and
they were relatively low volume. Due to the short development time and low production
volume, in some cases it was easier and cheaper for manufacturers to add existing
hardware than to invest the engineering resources to fully optimize precise air/fuel
control and fast light-off strategies, or to develop new hardware. It is also important to
note that many manufacturers were able to meet the LEVII-SULEV standards without
such additional hardware, even on their first attempt.

As manufacturers move towards compliance of all vehicles with the proposed Tier 3
standards, the order of magnitude higher sales will create a major incentive for
manufacturers to find cheaper solutions. There is also a considerable amount of
additional leadtime, allowing manufacturers to devote substantial engineering resources
and build upon their early experience with meeting low emission standards. It will not be
difficult for manufacturers to develop and implement emission control systems that do
not require these expensive add-on security blankets.

In summary, while EPA's cost estimates for Optimized CC Catalyst, Optimized Thermal
Management, Secondary Air Injection, and Hydrocarbon Adsorbers are reasonable,
these technologies will either not be needed or alternative technologies that are lower
cost than those estimated by EPA will be used, if not an actual cost reduction. In
addition, the cost for increased precious metal loadings will only be about a third of the
costs estimated in the draft RIA.

2) Gasoline Sulfur Reduction Cost
The cost of reducing gasoline sulfur from 30 ppm to 10 ppm is very modest. The ICCT
contracted with MathPro in 2011 to evaluate the cost of reducing sulfur from 30 to 10
ppm. MathPro found that the cost would be 0.8 to 1.4 cents per gallon. The cost
estimates include revamping the FCC naphtha hydrotreaters, historical rates of return
on investment, supplying the additional hydrogen needed, replacing small losses in both
gasoline volume and octane, and expanding sulfur recovery.

In fact, these cost estimates are likely overstated, as MathPro assumed that all existing
FCC naphtha hydrotreating capacity would require revamping even though many
hydrotreaters installed to meet the Tier 2 sulfur requirements are already capable of
meeting the 10 ppm standard.

A separate study carried out by Baker and O’Brien for the American Petroleum institute
(API) estimated that production of 10 ppm sulfur gasoline would increase the marginal
refining cost by 6–9 cents/gallon. However, there are two main reasons why these
marginal cost estimates in the API study are unrealistic and should not be used.
First, in the Baker and O’Brien methodology, the indicated marginal cost is the highest
cost of sulfur control that would be incurred by the least efficient refinery or refineries in
the US. The petroleum market in the US is regional, i.e., there is not a single market. It
is possible that the least efficient and highest cost refinery may be in, for example,
PADD 4 and have a particular market to itself. That refinery might be able to pass the
marginal costs on to producers in that market but will not have any effects in the rest of
the US. However, this is not the typical case, as most refineries are not so isolated. High
cost refineries that are not isolated will not be able to pass the marginal costs onto
consumers, due to competition from other efficient refineries. As a result, it is the
average costs, not the marginal costs that represent the actual increase in the refining
cost.
Second, the API marginal costs are upwardly biased. Baker and O’Brien overestimated
the investment costs for FCC naphtha hydrotreating, as indicated by MathPro's informal
contacts with companies involved in refinery upgrading. Their survey showed that
investment costs used by MathPro are in a reasonable range.
If the average refining costs are considered instead of marginal costs and Baker and
O’Brien’s investment costs for FCC naphtha hydrotreating are properly adjusted, Baker
and O-Brien's estimated refining costs would be similar to those estimated by MathPro.
There are two additional very important points. First, reducing gasoline sulfur will result
in large emission reductions not just from future Tier 3 vehicles, but also from the entire
in-use fleet. The impacts of sulfur on older vehicles, in grams/mile, are fully as large as
on Tier 3 vehicles, if not larger. As most of the sulfur impacts on catalysts are reversible,
reducing gasoline sulfur will result in immediate and very large reductions of in-use
emissions.

Second, analyses of catalyst precious-metal loadings and cost are generally done
without considering changes in fuel sulfur. Reducing gasoline sulfur will enable
reductions in catalyst precious-metal loadings, further reducing the cost of compliance
and offsetting much of the cost of reducing fuel sulfur.

3) SFTP Standards
For the most part, the overall stringency of the proposed rules is adequate and the
provisions, including leadtime and credit provisions, are appropriate. However, ICCT is
extremely concerned that the SFTP requirements are far less stringent than the FTP
requirements. While the proposed Tier 3 SFTP standards are a major improvement over
the SFTP standards for Tier 2, the Tier 2 SFTP standards were unchanged in stringency
from the Tier 1 SFTP standards and, thus, completely ineffective. Thus, despite the
large reduction in the SFTP standard levels, the proposed SFTP standards are still far
too lenient and will not achieve the objectives of the SFTP standards to reduce in-use
emissions.

To demonstrate our concerns, we have analyzed the stringency of the proposed SFTP
standards in two different ways. The first method compares the proposed SFTP
standards against current SFTP emission levels. The second method compares the
proposed SFTP standards against the proposed FTP standards.

Current SFTP emission levels

Figure 1-5 in the draft RIA (page 1-18), reproduced below, demonstrates that the
average SFTP NMHC+NOx emissions for current vehicles certified to Tier 2 bin 2 or
LEVII-SULEV emission standards (the orange bars) is less than 10 mg/mi, and the
highest emissions seen is about 42.5 mg/mi. The proposed SFTP NMHC+NOx standard
drops from 103 mg/mi in 2017 to 50 mg/mi in 2025. So, the proposed standard for 2017
is more than 10 times the average emissions of current vehicles and the proposed 2025
standard is more than 5 times the average emissions of current vehicles.


Proposed SFTP versus proposed FTP standards
The original SFTP standards, adopted in 1996 and applied to Tier 1 vehicles, found that
the incremental emissions on the SC03 and US06 cycles was similar in magnitude to
the incremental emissions from the cold start on the FTP. Thus, SFTP standards for
Tier 1 vehicles were set at the same numeric level as the FTP standards.

As the SFTP standards are hot, running emissions only, it is appropriate to separate the
FTP requirements into cold start emissions and hot, running emissions. The proposed

1-18

Figure 1-5: Mean and Maximum Composite SFTP Results for HC+NO
X
for Test Groups
certified to Bin-2 and Bin-3 Standards (bars and error-bars represent means and maxima
for sets of test groups, respectively)
1.4 Technology Description for NMOG+NO
X
Control
A range oI technology options exist to reduce NMOG and NO
X
emissions Irom both
gasoline Iueled spark ignition and diesel engines below the current Tier 2 standards. Available
options include modiIications to the engine calibration, engine design, exhaust system and aIter
treatment systems. The diIIerent available options have unique beneIits and limitations. This
section describes the technical challenge to reducing emissions Irom current levels, describes
available technologies Ior reducing emissions, estimates the potential emissions reduction oI the
diIIerent technologies, describes iI there are other ancillary beneIits to engine and vehicle
perIormance with the technology, and reviews the limits oI each technology. Except where
noted, these technologies are applicable to all gasoline vehicles covered by this proposed rule.
Unique diesel technologies are addressed in Section 1.4.2.
1.4.1 Summary oI the Technical Challenge Ior NMOG¹NO
X
control
The proposed Tier 3 rule would require vehicle manuIacturers to reduce the level oI both
NMOG and NO
X
emissions Irom the existing Tier 2 Ileet by approximately 80 percent over the
FTP by 2025. The FTP measures emissions during cold start, hot start, and warmed-up vehicle
city driving. The majority oI NMOG and NO
X
emissions Irom gasoline Iueled vehicles
measured during the FTP test occur during the cold start phase. Figure 1-1, above, graphically
demonstrates when NMOG and NO
X
emissions are produced during a cold start. As shown in
the Iigure, approximately 90 percent oI the NMOG emissions occur during the Iirst 50 seconds
aIter the cold start. In addition, about 60 percent oI the NO
X
emissions occur during this same
50 second period. Unlike NMOG which is mostly controlled aIter the Iirst 50 seconds, NO
X

emissions tend to be released throughout the remainder oI the FTP test. Achieving the proposed
Tier 3 NMOG¹NO
X
FTP emissions standard may require manuIacturers to reduce both cold start
NMOG and NO
X
emissions and Iurther reduce NO
X
emissions when the vehicle is warmed up.
NMHC+NOx FTP standards are 30 mg/mile. The draft RIA states (page 1-6):
"Based on modal analysis of a gasoline powered vehicle being operated on the
FTP cycle, approximately 90 percent of the NMOG emissions occur during the
first 50 seconds after a cold start. In addition, about 60 percent of the NO
X
emissions occur in these early seconds."

The Tier 2 bin 2 standards were 10 mg/mi for NMHC and 20 mg/mi for NOx. Using this
ratio and applying it to the cold start emission ratios from the draft RIA, 70% of
NMHC+NOx emissions on the FTP are from the cold start (90% x 1/3 + 60% x 2/3). This
means that about 30% of NMHC+NOx FTP emissions are from hot, running operation
and, thus, account for about 9 mg/mi of the proposed FTP standards.

The proposed NMHC+NOx SFTP standards are 50 mg/mi, or 5.5 times higher than the
hot, running emissions portion of the FTP standards. This is so lenient as to be
essentially no off-cycle control. And this is with respect to current vehicles, much less for
2025 with several additional generations of emission control development.

Similarly, compared with the proposed FTP PM standards, the proposed SFTP PM
standards are 3.3 times higher for vehicles < 6,000 GVWR and 6.7 times higher for
vehicles > 6,000 GVWR. Again, this is so lenient as to be almost completely ineffective.

Discussion

After application of the standard 50 percent compliance margin, hot, running
NMHC+NOx emissions on the FTP are about 4.5 mg/mi. Current SFTP NMHC+NOx
emissions from Tier 2 bin 2 and LEVII-SULEV vehicles are a bit less than twice this
amount. This is a reasonable ratio between SFTP and hot, running FTP emissions.
This, in turn, indicates that the hot, running FTP comparison supports the analysis of
SFTP emissions from current vehicles.

Both the current SFTP data and the proposed hot, running emissions on the FTP
support actual SFTP NMHC+NOx emissions of less than 10 mg/mi. After adding the
standard x2 in-use compliance margin, the SFTP NMHC+NOx standard should be set
at no more than 20 mg/mi.

As cold starts have a relatively small impact on particulate emissions, the same times
two factor found for SFTP NMHC+NOx emissions should also be applied to particulate
emissions. This means that the SFTP PM standard should be set at no more than 6
mg/mi.

Further, there is no reason why light-duty vehicles over 6,000 GVWR should be held to
less stringent particulate standards. This violates the premise established with the Tier 2
emission standards that all light-duty vehicles should be held to the same emission
standards. It is especially important that GVWR not be used to discriminate between
different standards, as GVWR is easily gamed.

Setting appropriate SFTP standards is especially important for diesel vehicles. The cold
start in the FTP largely determines the emission control system design for gasoline
vehicles. The primary need for SFTP gasoline engine standards is to ensure that proper
calibrations are used off-cycle and that emissions remain reasonable in-use. However,
for diesel engines, the emission control system design is largely determined by high
load operation. Thus, while the proposed SFTP requirements would likely not impact
gasoline hardware design, ineffective SFTP standards could lead to selection of diesel
emission control systems that are less effective in-use.

In fact, this has already been seen in Europe, where Euro IV and Euro V heavy-duty
vehicles equipped with selective catalytic reduction (SCR) systems have significantly
elevated emissions of nitrogen oxides (NOx) during in-use driving, particularly when
operating in urban traffic. In some cases, actual in-use urban emission levels may be as
high as or higher than those from much older vehicles with engines certified to more
lenient emission standards.
9
This illustrates the importance of setting emission
standards using representative test procedures and appropriate standards.

4) Certification Test Fuel
The ICCT is concerned about the proposed revision to use E15 for the certification test
fuel. While the ICCT supports using a more representative fuel for certification testing,
E15 is not representative of in-use fuel. E10 is representative of current in-use fuels and
should be used for emission and fuel economy testing.

In addition to violating the principle of using representative fuels, the ICCT has a
number of serious concerns with E15: E15 can cause damage if it is used in small
engines or in legacy vehicles; it is specific to ethanol (as opposed to drop-in biofuel
pathways), which encourages the use of food feedstocks such as maize instead of more
environmentally friendly feedstocks; and it provides significant evaporative cooling,
which manufacturers could exploit to generate higher fuel economy on the tests than the
vehicles would actually experience in use.

The problems and potential damage if E15 is used in small engines and legacy vehicles
has been well documented by Honda and other vehicle manufacturers and will not be
repeated here. However, our concerns in this area are exacerbated by the lack of
systems to provide proper fuel and prevent misfueling in-use. For example, EPA has not
proposed a system to separate the use of E15 for newer vehicles and E10 for older
vehicles. A system where E15 is used for regular fuel and E10 for premium fuel would
encourage misfueling of small engines and legacy vehicles, as customers choose E15

9
Lowell,D.andKamakate,F.,"Urbanoff-cycleNOxemissionsfromEuroIV/Vtrucksandbuses",
April2012.http://theicct.org/urban-cycle-nox-emissions-euro-ivv-trucks-and-buses
just because it is cheaper. If E10 is used for regular fuel and E15 is used for premium
fuel, this would discourage the use of E15 in vehicles that could safety use it and would
make it impossible for older vehicles requiring premium to be refueled properly. Thus,
for the refueling system to work properly, it appears that service stations must provide
separate pumps for both E10 and E15 for both regular and premium. This is not likely to
happen unless EPA requires it. Until EPA addresses the refueling situation with
regulations, refueling will almost certainly be marked by confusion and misfueling.

The ICCT is also concerned that E15 will encourage biofuels made from food crops,
instead of advanced biofuels. It is not currently cost effective to make ethanol out of
cellulose, thus simply increasing the ethanol blend wall is effectively a mandate for more
food-based biofuels that can easily be turned into ethanol. Several pathways for
producing advanced biofuel from feedstocks such as cellulose will likely be able to
deliver drop-in fuels. As drop-in fuels have a higher value in the market than ethanol, it
is also possible that cellulose can be more profitably turned into drop-in fuels. E15
would work against this by incentivizing ethanol, not drop-in fuels. Insofar as wider use
of E15 supports increased use of maize and sugarcane ethanol rather than driving
investment into advanced drop-in fuel pathways, the net result will be that E15 would
tend to increase food prices (and hence worldwide food insecurity), decrease
biodiversity due to land use change, create yet another roadblock for advanced, lower
carbon, biofuels and deliver less carbon reductions than would be available from
commercializing biofuels from cellulosic wastes and energy crops.

The ICCT's third concern is specific to fuel economy testing. 15% ethanol content
provides significant evaporative cooling in the cylinder. This would allow manufacturers
to advance ignition timing or make other modifications to improve fuel economy on the
test cycles—and which would not be likely to be achieved in-use.

The advantages of even E10 were demonstrated in a test program to maximize engine
power on a variety of fuels. Grassroots Motorsports (December 2012) tested a Mazda
Miata on the following fuels, using a standalone computer to tune the vehicle for each
fuel on a Dynapack dynamometer to make the most power:

Table 4: Results of Mazda Miata testing by Grassroots Motorsports
OCTANE ETHANOL
POWER
(HP)
TORQUE
(FT-LB)
87 E10 135 117
93 E10 136 124
93 0 134 122
100 0 137 123
105 0 137 124
-- E85 143 128

The charge cooling effect of E10 boosted performance on 93-octane fuel by about 1.5%
and virtually matched the performance of 100 and 105-octane race gasoline. GRM
couldn't redesign the engine and they were only able to revise spark timing, camshaft
timing, and air/fuel ratio at WOT. The higher charge cooling with E15 would allow
manufacturers to do even more optimizing—and they could also optimize the design of
the engine over all operation.

It is important that the fuel used for certification and fuel economy testing be
representative of in-use fuel. However, that fuel is currently E10, which is what should
be used for EPA's testing. E15 is not currently representative of in-use fuel and its use
for EPA testing has several major problems, which should be avoided.

5) Provisions for E30 Vehicles
The draft proposal requested comments on the use of E30 in certification testing:

"we are proposing to allow vehicle manufacturers to request approval for an
alternative certification fuel such as a high-octane 30 percent ethanol by volume
(E30) blend for vehicles they might design or optimize for use on such a fuel."
The ICCT is supportive of all ways to increase efficiency. In particular, the ICCT would
strongly support increasing the minimum required octane for all gasoline.

Despite this, the ICCT could support the E30 provision only if the vehicles actually used
E30 the vast majority of the time in-use. However, this would create major infrastructure
difficulties: how would the E30 infrastructure be developed in advance of offering E30-
capable vehicles? It also has potentially troubling consequences related to food-based
high-iLUC ethanol, as discussed above with respect to E15.

An entirely new infrastructure would be needed for E30, which means a huge chicken-
and-egg problem. Just like with E85, one way to attempt to solve this is to offer credits
to E30 vehicles, whether or not they actually use E30 in-use. The ICCT is extremely
concerned that this will become another loophole, with large credits against the
CO
2
/CAFE standards granted and little use in the real world, reducing the benefits of the
standards. Our concerns are magnified by the recent EPA Manufacturer Guidance
Letter on E85 usage, which proposed to grant flexible-fueled vehicles a 20% E85 usage
rate (F-factor), even though E85 usage in the real world has remained steady at 1.1%
since 1998.

Our infrastructure concerns are exacerbated by the fact that E30 has 10% lower energy
content than gasoline. Certainly some of this can be recaptured with higher efficiency,
but it won't be a 10% efficiency improvement. Thus, customers will be able to travel
further on gasoline (or E10 or E15) than with E30, unless the vehicle is designed so that
it does not run well on E10 or E15.

Which raises another concern with vehicles designed for E30. A recent SAE paper on
the impacts of ethanol blends reviewed what happens when a vehicle designed for E30
is run on 87-octane gasoline:
10


"With engine downsizing, the reduction in full load torque with regular grade 91
RON fuel will be proportional to the amount of downsizing, and can result in
unacceptable vehicle performance attributes for aggressive levels of downsizing."

This loss of performance on regular fuel just makes the chicken-and-egg problem
worse. Engines that require E30 are going to be a tough sell in the market.

Given the infrastructure concerns, E30 must offer substantial efficiency benefits to justify
the investment in a new infrastructure. Thus, the key question is: What is the efficiency
benefit of running on E30 compared to alternative technologies? The Stein 2013 SAE
paper concluded: "From an engine standpoint, the primary motivation for increasing
ethanol content is improved knock resistance."
11
However, high EGR rates also offer
improved knock resistance. If E30 basically duplicates the benefits of boosted-EGR, it is
hard to see how creation of a new infrastructure can be justified.

Given all of the above, E30 should only be allowed if the manufacturer can demonstrate
that the vehicle will almost always be refueled with E30 in-use. Given the historical
abuse of similar provisions, such as FFV credits and the recent proposal for 20% F-
factor for FFVs, the ICCT is very concerned about the potential to also abuse this
provision.

What is really needed is higher octane for regular fuel, regardless of the ethanol
content. For example, the Mazda had to reduce the compression ratio of the Skyactiv
engine for the US market, compared with Europe. Also OEMs simply won't try to sell a
mass-market non-luxury vehicle that requires mid- or high-grade gasoline in the US.

Unfortunately, when fuel providers added ethanol to gasoline in the past, the fuel
providers took out the non-ethanol octane elements - so that, in practice, there has
never been a gain in octane through increased ethanol blends. It is likely that E15 will
be the same—we won't actually get more octane. Rather than focus on ethanol
requirements, the EPA should raise the minimum octane requirements for all gasoline.



10
Stein,R.,Anderson,J.,andWallington,T.,"AnOverviewoftheEffectsofEthanol-GasolineBlends
onSIEnginePerformance,FuelEfficiency,andEmissions,"SAEInt.J.Engines6(1):470-487,2013,
doi:10.4271/2013-01-1635
11
Ibid.
6) Heavy-Duty Standards
It is ICCT's position that technology-neutral performance standards are critical in any
transportation policy, especially one that involves multiple and alternative fuels that can
all be utilized as part of meeting emissions and energy objectives. Thus, we are
supportive of maintaining fuel neutral criteria emissions standards for heavy-duty
vehicles.

The ICCT fully supports extending chassis-based emission requirements to all complete
vehicles up to 14,000 gross vehicle weight. The trend since the first standards were
adopted in the 1970s has been to increase the GVW of pickup and other light trucks
above the threshold for light-duty emission standards. This has especially been a
problem for diesel engines in pickup trucks, which are only sold above 8,500 GVW in
order to avoid the light-duty emission standards. Extending the threshold to 14,000
GVW will ensure emission standards are applied appropriately to all complete vehicles.

Similarly, the ICCT fully supports extending the supplemental FTP requirements to
complete vehicles between 8,500 and 14,000, which were previously exempt.

As noted by EPA, companies with much larger sales of light-duty trucks build most of
these vehicles and frequently share major design characteristics and potential
emissions control technologies with their LDT counterparts. Combined with the less-
stringent standards proposed by EPA (as compared to light-duty vehicles), compliance
with the proposed heavy-duty standards should be feasible at reasonable cost.

7) R-Factor for Carbon Balance Equation
The R-factor is an adjustment made by EPA to maintain compatibility with the test
procedures used in 1975 for calculating fuel economy, as required by the 1975 EPCA.
The R-factor is used to adjust the FE test results for changes in the net heating value
(NHV) of the test fuel. EPA is accomplishing this by incorporating the R-factor into the
carbon balance equation, instead of doing the adjustment after calculation of the fuel
economy.

Specifically, the R-factor is the sensitivity of the fuel economy to changes in NHV.
Ethanol blends reduce the NHV of the test fuel. To the extent that NHV affects engine
efficiency, this change must be accounted for under the 1975 EPCA.

Current, an R-factor of 0.6 is in the regulations. This was based upon data submitted by
GM and others in 1985 on primarily carbureted vehicles. In the past there was not a lot
of variation in fuel properties of indolence, so this R-factor had a minor effect and there
was no need to revisit it.

However, switching to E10 as the test fuel will cause a much larger change in the NHV -
about 3.5% for E10 (and over 5% for E15). Using an R-factor of 0.6 would give an
artificial upward adjustment of over 2% (0.4 x 5%) to E15 vehicles.

ICCT commends EPA for having the foresight to readdress the R-factor. A contractor
report for EPA by ORNL, based upon test data on recent vehicles using E0, E10, E15,
and E20, calculated R-factors for the entire fleet, Tier 2 vehicles only, and with and
without exclusion of an outlier vehicle.
12


The existing R-factor is clearly outdated and needs to be replaced. Vehicles certified to
Tier 2 are representative of current vehicles and are the closest representation of future
Tier 3 vehicles, so data from older non-Tier 2 vehicles should not be used. The Honda
Accord data is clearly an outlier and is likely the result of an error in testing. It is
standard practice in statistics to exclude such obvious outliers. Thus, the ICCT
recommends that the R-factor found in the report for Tier 2 vehicles without the outlier,
0.96, be adopted in the final rule.

8) Refueling Emissions of Natural Gas Vehicles
The impact of refueling emissions on all alternative fuel vehicles, especially gaseous-
fueled vehicles, should be assessed. A key concern for natural gas vehicles, in
particular, is the atmospheric venting of natural gas that occurs during refueling. Natural
gas not only contains criteria hydrocarbon pollutants, it also contains a large percentage
of methane with a 100-year global warming potential 25 times that of CO2. It is very
important that this venting of natural gas be controlled and recaptured.

The ICCT recommends that EPA develop and adopt requirements for refueling
emissions from gaseous-fueled vehicles.

9) FTP Particulate Emission Standards
The FTP supports the proposed FTP particulate standards. These would largely
harmonize EPA's requirements with CARB's.

One key difference between the Tier 3 proposal and the LEV III rule is that under LEV
III, automakers must meet a tailpipe emission standard of 1 mg/mi beginning in 2025.
Instead, the Tier 3 proposal extends only to model year 2023, citing concerns expressed
in the CA LEV III rulemaking with regard to the state of PM measurement capability to
enable testing and compliance with a 1 mg/mi standard.. The ICCT strongly

12
Sluder, C. and West, B., "PreliminaryExaminationofEthanolFuelEffectsonEPA’sR-factorfor
VehicleFuelEconomy",ORNLreportforEPA,June2013
recommends that EPA harmonize with the LEV III particulate standards beginning in
2025. This will allow plenty of time to develop more accurate particulate measurement
methods.

A notable omission from the proposed particulate standards is a particle number limit
standard, similar to already adopted requirements in Europe. Although the proposal
cites the 2010 US EPA Integrated Risk Assessment for Particulate Matter, which
highlights evidence of a causal association between PN exposure and adverse health
impacts, the document notes a desire for further research to find more robust
associations between PN exposure and health impacts. The ICCT strongly encourages
EPA to investigate harmonization with the European particulate number standards in the
future. California is likely to pursue particle number measurement methods to ensure
compliance with 1 mg/mi, which carries the possibility of a transition to a particle
number limit in future rulemakings.

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