Alternative Method for Calculating Off-Cycle Credits for Mercedes-Benz Vehicles Under the Light-Duty Greenhouse Gas Emissions Program, 60275-60279 [2013-23964]
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Federal Register / Vol. 78, No. 190 / Tuesday, October 1, 2013 / Notices
ROW could not be expanded to ensure
adequate clearances and access.
ENVIRONMENTAL PROTECTION
AGENCY
Mitigation Measures
Practicable methods to avoid or
minimize environmental impacts from
the selected alternative are adopted in
this Record of Decision. Western’s
standard practices and project-specific
protection measures, listed in the Final
EIS, will be implemented. Many of the
protection measures will be
implemented through design and the
project construction contract. A
Mitigation Action Plan will be prepared
that includes protective measures that
will be implemented during design,
construction, and routine maintenance
or Forest Service agreements.
[FRL–9901–57–OAR]
Comments on Final EIS
Western received two comment letters
on the Final EIS. Colorado Parks and
Wildlife submitted a letter reiterating
their preference to keep the project on
the existing ROW and further from the
sage grouse lek, and requesting that
Western ensure that wildlife resource
protection measures be implemented.
The Final EIS responded to these
comments and described protective
measures for wildlife. The
Environmental Protection Agency
commented that it was unclear whether
new sources of power would be needed
for the project. No new sources of power
would be needed for the project. The
resource mix would not be modified for
the project. Other comments on the
Final EIS included email comments
stating a preference for undergrounding
and requesting additional information
on the construction schedule.
emcdonald on DSK67QTVN1PROD with NOTICES
Decision
Western’s decision is to construct the
project along the preferred alternative
described in the Final EIS.1 This
satisfies Western’s statutory mission
while minimizing harm to the
environment. This decision is based on
the information in the Final EIS. This
Record of Decision was prepared
according to the requirements of the
Council on Environmental Quality’s
regulations for implementing NEPA (40
CFR parts 1500–1508) and DOE’s
procedures for implementing NEPA (10
CFR part 1021).
Dated: September 23, 2013.
Mark A. Gabriel,
Administrator.
[FR Doc. 2013–23988 Filed 9–30–13; 8:45 am]
BILLING CODE 6450–01–P
1 On November 16, 2011, DOE’s Acting General
Counsel delegated to Western’s Administrator all
the authorities of the General Counsel respecting
environmental impact statements.
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Alternative Method for Calculating OffCycle Credits for Mercedes-Benz
Vehicles Under the Light-Duty
Greenhouse Gas Emissions Program
Environmental Protection
Agency (EPA).
ACTION: Notice.
AGENCY:
In the light-duty vehicle
greenhouse gas rule for model year 2012
through 2016 vehicles, EPA established
a program to allow automobile
manufacturers to generate ‘‘off-cycle’’
carbon dioxide (CO2) credits by
employing technologies that achieve
CO2 reductions in the real world but are
not appropriately captured on the test
procedures used by manufacturers to
demonstrate compliance with the CO2
standards. Under one of the program
options, a manufacturer may develop
and submit to EPA for approval an
alternative demonstration methodology
justifying eligibility for off-cycle credits
and their amount. The regulations
concerning off-cycle credits require an
opportunity for public comment as part
of EPA’s review of such an alternative
methodology. EPA is requesting
comment on an alternative methodology
submitted by Mercedes-Benz for
determining off-cycle credits for the
following technologies: engine stopstart, high efficiency exterior lighting,
infrared glazing, and active seat
ventilation. The application is only for
off-cycle credits for Mercedes-Benz
vehicles for the 2012 through 2016
model years.
DATES: Comments must be received on
or before October 31, 2013.
ADDRESSES: Submit your comments,
identified by Docket ID No. EPA–HQ–
OAR–2013–0643, by one of the
following methods:
• On-Line at https://
www.regulations.gov: Follow the OnLine Instructions for Submitting
Comments.
• Email: a-and-r-docket@epa.gov.
• Fax: (202) 566–1741.
• Mail: Air and Radiation Docket,
Docket ID No. EPA–HQ–OAR–2013–
0643, U.S. Environmental Protection
Agency, Mailcode: 6102T, 1200
Pennsylvania Avenue NW., Washington,
DC 20460. Please include a total of two
copies.
• Hand Delivery: EPA Docket Center,
Public Reading Room, EPA West
Building, Room 3334, 1301 Constitution
Avenue NW., Washington, DC 20460.
Such deliveries are only accepted
SUMMARY:
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during the Docket’s normal hours of
operation, and special arrangements
should be made for deliveries of boxed
information.
On-Line Instructions for Submitting
Comments: Direct your comments to
Docket ID No. EPA–HQ–OAR–2013–
0643. EPA’s policy is that all comments
received will be included in the public
docket without change and may be
made available online at https://
www.regulations.gov, including any
personal information provided, unless
the comment includes information
claimed to be Confidential Business
Information (CBI) or other information
whose disclosure is restricted by statute.
Do not submit information that you
consider to be CBI or otherwise
protected through https://
www.regulations.gov or email.
The https://www.regulations.gov Web
site is an ‘‘anonymous access’’ system,
which means EPA will not know your
identity or contact information unless
you provide it in the body of your
comment. If you send an email
comment directly to EPA without going
through https://www.regulations.gov,
your email address will automatically
be captured and included as part of the
comment that is placed in the public
docket and made available on the
Internet. If you submit an electronic
comment, EPA recommends that you
include your name and other contact
information in the body of your
comment and with any disk or CD–ROM
you submit. If EPA cannot read your
comment due to technical difficulties
and cannot contact you for clarification,
EPA may not be able to consider your
comment. Electronic files should avoid
the use of special characters, any form
of encryption, and be free of any defects
or viruses. For additional information
about EPA’s public docket visit the EPA
Docket Center homepage at https://
www.epa.gov/epahome/dockets.htm.
Materials relevant to this proceeding
are contained in the Air and Radiation
Docket and Information Center,
maintained in Docket ID No. EPA–HQ–
OAR–2013–0643. Publicly available
docket materials are available either
electronically through https://
www.regulations.gov or in hard copy at
the Air and Radiation Docket in the EPA
Headquarters Library, EPA West
Building, Room 3334, located at 1301
Constitution Avenue NW., Washington,
DC. The Public Reading Room is open
to the public on all federal government
work days from 8:30 a.m. to 4:30 p.m.;
generally, it is open Monday through
Friday, excluding holidays. The
telephone number for the Reading Room
is (202) 566–1744. The Air and
Radiation Docket and Information
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Center’s Web site is https://www.epa.gov/
oar/docket.html. The electronic mail
(email) address for the Air and
Radiation Docket is: a-and-r-docket@
epa.gov, the telephone number is (202)
566–1742, and the fax number is (202)
566–9744. An electronic version of the
public docket is available through the
federal government’s electronic public
docket and comment system. You may
access EPA dockets at https://
www.regulations.gov. After opening the
https://www.regulations.gov Web site,
enter EPA–HQ–OAR–2013–0643 in the
‘‘Enter Keyword or ID’’ fill-in box to
view documents in the record. Although
a part of the official docket, the public
docket does not include Confidential
Business Information (CBI) or other
information whose disclosure is
restricted by statute.
EPA will keep the record open until
October 31, 2013. All information will
be available for inspection at the EPA
Air Docket No. EPA–HQ–OAR–2013–
0643. Persons with comments
containing proprietary information must
distinguish such information from other
comments to the greatest extent possible
and label it as ‘‘Confidential Business
Information’’ (‘‘CBI’’). If a person
making comments wants EPA to base its
decision on a submission labeled as CBI,
then a non-confidential version of the
document that summarizes the key data
or information should be submitted to
the public docket. To ensure that
proprietary information is not
inadvertently placed in the public
docket, submissions containing such
information should be sent directly to
the contact person listed below and not
to the public docket. Information
covered by a claim of confidentiality
will be disclosed by EPA only to the
extent allowed, and according to the
procedures set forth in 40 CFR part 2.
If no claim of confidentiality
accompanies the submission when EPA
receives it, EPA will make it available
to the public without further notice to
the person making comments.
FOR FURTHER INFORMATION CONTACT:
Roberts French, Environmental
Protection Specialist, Office of
Transportation and Air Quality,
Compliance Division, U.S.
Environmental Protection Agency, 2000
Traverwood Drive, Ann Arbor, MI
48105. Telephone: (734) 214–4380. Fax:
(734) 214–4869. Email address:
french.roberts@epa.gov.
SUPPLEMENTARY INFORMATION:
In the model year (MY) 2012–2016
light-duty vehicle greenhouse gas (GHG)
rule, EPA established an option for
14:45 Sep 30, 2013
1 75
FR 25438–25440, May 7, 2010.
FR 62832–62839, October 15, 2012.
3 40 CFR 86.1869–12(c).
4 40 CFR 86.1869–12(c).
5 40 CFR 86.1869–12(d).
6 40 CFR 86.1869–12(d) and (e).
2 77
I. Background
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manufacturers to generate credits by
employing technologies that achieve
carbon dioxide (CO2) reductions in the
real world but are not captured on the
2-cycle test procedures used to
determine compliance with the fleet
average standards (i.e., ‘‘off-cycle’’
credits). EPA adopted the off-cycle
credit option to encourage the
introduction of these types of
technologies, believing that off-cycle
CO2 reductions should be considered in
determining a manufacturer’s fleet
average, and that a credit mechanism is
an effective way to achieve this.
The MY 2012–2016 rule provided two
ways for manufacturers to demonstrate
the off-cycle emissions reduction
capabilities of a technology and generate
off-cycle credits, either through 5-cycle
testing (which captures elements of realworld driving not captured by the 2cycle compliance tests, including high
speeds, rapid accelerations, and cold
temperature operation) or an alternative
demonstration methodology developed
by the manufacturer and approved by
EPA.1 The MY 2017–2025 light-duty
GHG rule streamlined the off-cycle
credits program and provided a third
pathway for credits, a pre-determined
credits list that may be used beginning
in MY 2014.2
The first pathway for a manufacturer
to demonstrate off-cycle technology is to
conduct 5-cycle emissions testing with
and without the technology applied to
the vehicle.3 If the off-cycle emissions
benefit of the technology is able to be
adequately captured through 5-cycle
testing, the manufacturer must conduct
testing per the regulations, and submit
the data to EPA.4 This methodology was
proposed in detail in the rulemakings,
which included an opportunity for
public comment, and therefore
manufacturers’ applications for credits
using the 5-cycle process do not
undergo additional public review.
The second pathway allows
manufacturers to demonstrate off-cycle
emissions reduction technology using
an alternative methodology developed
by the manufacturer in cases where the
real world benefit of the technology
cannot be adequately demonstrated
using the 5-cycle test procedures.5 The
regulations regarding the alternative
methodology, excerpted below, specify
the data and information needed to
support a manufacturer’s off-cycle credit
application.6 The alternative
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methodology must be approved by EPA
prior to the manufacturer generating
credits. Also, as part of the EPA review,
the alternative methodology must be
made available for public comment.7
EPA will consider public comments as
part of its final decision to approve or
deny the credit request.
The regulations for the alternative
methodology provided at 40 CFR
86.1869–12(d)(1)(i)–(iv) specify that the
alternative demonstration program must
be approved in advance by the
Administrator and should be based on
modeling, on-road testing, on-road data
collection, or other approved analytical
or engineering methods, and should be
robust, verifiable, and capable of
demonstrating the real-world emissions
benefit of the technology with strong
statistical significance. Further, the
alternative program should result in a
demonstration of baseline and
controlled emissions over a wide range
of driving conditions and vehicles in
order to minimize issues of data
uncertainty. Additionally, the
regulations at 40 CFR 86.1869–
12(e)(1)(ii)–(iii) and (e)(2)(i)–(iv) provide
specificity regarding the data and
information that must be submitted to
EPA as part of an application for credits
using an alternative demonstration
methodology.
As noted above, as part of the MY
2017–2025 rule, EPA adopted a list of
pre-approved off-cycle technologies and
credits that manufacturers can use
beginning in MY 2014.8 This third
option was included in the MY 2017–
2025 rule because certain types of offcycle credits are amenable to
quantification without further
demonstration, and EPA’s specification
of these credits therefore significantly
streamlines the off-cycle credits
program and reduces the testing and
data burden that the program otherwise
entails. Manufacturers using the preapproved list only need to provide EPA
at the time of certification with
information demonstrating that their
technology meets applicable definitions
and qualifies for credits. There are no
testing or other requirements for
demonstrating emissions reductions.
Manufacturers may however use the 5cycle or alternative methodology
pathways in MY 2014 and later to
demonstrate that their technology
achieves greater off-cycle emissions
reductions than are provided by the predefined list. Also, manufacturers would
need to use the 5-cycle or alternative
methodology pathways to demonstrate
eligibility for credits for technologies
7 40
8 40
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CFR 86.1869–12(d)(2).
CFR 86.1869–12(a).
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that are not on the list, as well as the
extent of the credits.
Mercedes-Benz is applying for credits
for model years prior to MY 2014 and
for credits in excess of the credits on the
pre-approved list. The technologies
cannot be adequately demonstrated over
the 5-cycle test and therefore MercedesBenz has applied for credits under the
alternative methodology approach
discussed above.
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II. Mercedes-Benz Off-Cycle Credit
Application and Alternative
Methodology
Mercedes-Benz has applied for offcycle credits using the alternative
demonstration methodology pathway
for the following technologies: engine
stop-start, high efficiency exterior
lighting, infrared glazing, and active seat
ventilation. The application covers MY
2012–2016 vehicles. EPA has reviewed
the application for completeness and is
now making the application available
for public review and comment per the
regulations.9 The Mercedes-Benz offcycle credit application with
confidential business information
redacted has been placed in docket
EPA–HQ– OAR–2013–0643 and on
EPA’s Web site at https://www.epa.gov/
otaq/regs/ld-hwy/greenhouse/ldghg.htm.
A summary of Mercedes’ alternative
methodology for each of the four
technologies is provided below. For
context and comparison, in
summarizing the Mercedes-Benz
alternative methodology, EPA provides
some background on how the MercedesBenz methodology compares to that
developed by EPA in the MY 2017–2025
light-duty GHG rulemaking for the preapproved list of off-cycle credits, which
is contained in the Joint Technical
Support Document (TSD), Chapter 5.10
A. Engine Stop-Start
Mercedes-Benz is applying for engine
idle stop-start credit covering all of their
MY 2012–2016 U.S. model product
range (e.g., small/mid-size/large cars
and light-duty trucks) (See Section II–III
of Mercedes-Benz Application).
Mercedes-Benz is following a similar
methodology to the one EPA described
in the TSD for the MY2017–2025 rule,
but with unique inputs for idle time and
stop-start system effectiveness which
includes parameters related to
9 § 86.1869–12(e)(3).
10 Joint Technical Support Document: Final
Rulemaking for 2017–2025 Light-duty Vehicle
Greenhouse Gas Emission Standards for Corporate
Average Fuel Economy Standards, United States
Environmental Protection Agency and National
Highway Traffic Safety Administration, August
2012, EPA–420–R–12–901.
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Mercedes’ unique control strategy for its
stop-start system.11
The basic methodology entails the
following steps: estimate or measure the
total idle fraction as a percentage of all
vehicle operation in the real-world;
estimate or measure the percentage of
idle fraction that the stop-start system is
enabled out of all the available idle time
(i.e., eligible stop-start percentage or
stop-start system effectiveness);
determine the benefit of the stop-start
system in grams per mile based on A–
B testing (i.e., technology on and off);
and multiply the eligible real world
stop-start time (relative to the 2-cycle
eligible time) by the stop-start system
benefit to estimate the engine idle stopstart credit.
In lieu of the EPA default idle time
derived from the MOVES model,
Mercedes-Benz is proposing to apply a
unique idle time specific to its vehicles.
To estimate the total idle time as a
percentage of all vehicle operation,
Mercedes-Benz conducted a field study
in calendar years 2010–2011 including
29 instrumented customer vehicles,
randomly selected from the MercedesBenz customer base. The field study was
performed for a period of 13 months in
eight states: California, New York, New
Jersey, Florida, Texas, Illinois, Virginia,
and Arizona. These eight states
represented about 65% of the MercedesBenz sales volume. The remaining 35%
of the Mercedes-Benz sales fleet was
distributed in the other 42 states not
included in the idle fraction study.
During the course of the study, the
vehicles accumulated 311,118 miles.
The 29 vehicle sample broadly
represents the Mercedes-Benz models
equipped with stop-start technology
sold in the United States. Based on this
study, Mercedes-Benz estimated that its
vehicles have a 23.83% total idle
fraction as a percentage of all vehicle
operation.
To provide further support for its idle
fraction estimate, Mercedes-Benz
acquired an independent estimate of
idle fraction for its vehicles from
Progressive Insurance. Progressive
Insurance has about 1.4 million vehicles
in its ‘‘Snapshot’’ Program covering 44
states (excluding California, North
Carolina, Tennessee, Indiana, Arkansas,
and Hawaii), over a six month period.12
In the Progressive data set, there are
17,484 Mercedes-Benz vehicles which
are represented in proportion to current
industry sales shares. Based on the
Progressive data set, the Mercedes-Benz
11 MY2017–2025 Technical Support Document,
Chapter 5, Section 5.2.8.1.
12 Of these states, only California is a major
market for Mercedes-Benz.
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vehicles are estimated to have an idle
fraction of 23.9%. This is almost exactly
the same as the 23.83% idle fraction
found in the Mercedes-Benz study
discussed above and used by MercedesBenz in their analysis. Further, since the
Progressive Insurance data covers 37 out
of the other 42 states not included in the
Mercedes-Benz idle fraction study, this
data implies that the other 35% of the
sales volume not represented by the
Mercedes-Benz data has consistent idle
fractions. Mercedes indicated that none
of the other 42 states, except for
Pennsylvania, have equivalent sales
volumes to the states used in the idle
fraction study. As such, Mercedes-Benz
concludes that the idle fraction for the
other 35% of the sales volume, if
different, would not have significantly
altered the idle fraction estimate.
To estimate the percentage of idle
fraction during which the stop-start
system is enabled, Mercedes-Benz used
EPA’s methodology in Chapter 5 of the
Technical Support Document (TSD) for
the MY2017–2025 rule, with inputs
specific to Mercedes-Benz vehicles and
control strategies.
The following background is provided
to give some additional context on how
EPA derived off-cycle credits for stopstart systems for the pre-approved menu
in the MY 2017–2025 rulemaking. EPA
constrained stop-start system
effectiveness based on three operating
temperature ranges: cold temperatures
below 40 degrees Fahrenheit, midtemperatures between 40 and 80 degrees
Fahrenheit, and hot temperatures above
80 degrees. For the cold temperature
range, EPA assumed that passenger
demand for heat would reduce stop-start
effectiveness unless the vehicle
possesses an electric heater circulation
pump, or equivalent system, that
supplies sufficient heat during engine
off operation. For the hot temperature
range, EPA assumed that passenger
demand for air conditioning (A/C)
would render the stop-start system
inoperable, unless the manufacturer has
some supplemental system to support
cabin cooling. For all the temperature
ranges, EPA assumed that the stop-start
system always defaults on when the
vehicle is keyed on. EPA assumed the
overall system effectiveness would be
reduced to 87.75% due to these
temperature effects.
Mercedes Benz’s stop-start system has
several design features that differ from
those used by EPA for the pre-approved
menu analysis. As described in Section
III of the Mercedes-Benz application,
Mercedes-Benz took these factors into
account in analyzing its system
performance. First, the Mercedes-Benz
stop-start system includes an electric
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heater circulation pump that maintains
cabin heating in cold temperatures, and
thus enables stop-start capability when
heat is demanded. Second, the
Mercedes-Benz system has a
supplemental 12 volt battery system that
supplies power for all the electrical
components and accessories. This
allows the main battery to support
restarting and also enables stop-start
capability even when A/C is demanded.
Mercedes-Benz also made an adjustment
to account for OBD and stop-start
interactions, which limits the
availability of stop-start during the first
170 seconds of vehicle operation. These
adjustments resulted in an estimated
fraction of effectiveness (i.e., when the
system is active) of about 91.32%,
compared to EPA’s generic estimate of
87.75%.
In addition, the Mercedes-Benz
system includes an ‘‘EcoButton’’ that
allows customers to disable the stopstart system. An estimate of the
frequency of use of the EcoButton to
disable the stop-start system is included
in the Mercedes-Benz calculations.
Finally, the Mercedes-Benz stop-start
system has a maximum engine off
duration of three minutes; therefore, the
stop-start system would not be active
after an idle period exceeds three
minutes. Based on these features,
Mercedes-Benz reduced its eligible idle
time of 23.83% to a total eligible idle
time of 21.22% using the 91.32%
system effectiveness discussed above,
and an additional discount of 2.5% for
EcoButton usage and idles exceeding
the Mercedes-Benz system’s 3 minute
engine off duration.
To determine the CO2 emissions
benefit of the stop-start system,
Mercedes-Benz performed testing of
Mercedes-Benz vehicles equipped with
stop-start in different vehicle categories
with the stop-start system on and off.
Based on this testing, Mercedes-Benz
measured a benefit of: 9.8 g/mi CO2 for
small size cars, 8.1 g/mi CO2 for midsize cars, 16.9 g/mi CO2 for large size
cars, and 15.2 g/mi CO2 for light-duty
trucks (e.g., SUVs). These g/mile GHG
improvement values reflect the
operational effectiveness of the
Mercedes-Benz system during the 2cycle testing. The effectiveness (i.e., the
time the engine is off compared to the
total idle time in the cycle) of the stopstart system over the 2-cycle test ranged
from 67.3% to 80.4%.
Based on the eligible stop-start idle
fraction of 21.22%, compared with 10%
idle fraction over the 2-cycle tests, and
the emissions benefits measured above,
Mercedes-Benz calculated an engine
stop-start credit of 11.0 g/mi CO2 for
small size cars; 9.1 g/mi CO2 for mid-
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size cars; 19.0 g/mi CO2 for large size
cars; and 17.1 g/mi CO2 for light-duty
trucks (for example, for small cars, these
credits were derived as: (9.8 g/mi CO2
× 0.2122/0.10) ¥ 9.8 g/mi CO2 = 11.0
g/mi CO2).
High Efficiency Exterior Lighting
Mercedes-Benz is applying for offcycle credits for high efficiency exterior
lighting for their MY 2012–2016 U.S.
model product range with the following
lighting elements: low beam head lights,
high beam head lights, parking/position,
front turn signal, front side marker, tail
lights, rear turn signal, and license plate
(See Section IV of the Mercedes-Benz
application). This list of lighting
elements is consistent with that
specified by EPA for the pre-approved
list in the MY 2017–2025 rule.13
To calculate the high efficiency
exterior lighting credits, Mercedes-Benz
used the EPA methodology set forth in
the TSD for the MY2017–2025 rule.14
Specifically, Mercedes-Benz used the
MY 2017–2025 rule baseline wattage
values for each lighting element listed
above and the time of day (e.g., day
time, night time) usage rates from a
study performed by Schoettle et al. 15
and inserted the wattage values from the
Mercedes-Benz high efficiency exterior
lighting to determine the wattage
savings for each lighting element. In
most cases, the Mercedes-Benz wattage
savings for each lighting element
exceeded the wattage savings projected
in the MY 2017–2025 rule (exceptions:
parking/position lights at 70% savings
versus 78% in the MY 2017–2025 rule;
license plate light at 86% versus 90% in
the MY 2017–2025 rule).
For the final credit amounts,
Mercedes-Benz multiplied the wattage
savings times the usage rates and a
constant of 0.032 g/mi CO2/watt (based
on data showing a 100 watt savings
equates to 3.2 g/mi CO2 savings) for a
credit of 1.1 g/mi CO2 total for all the
high-efficiency exterior lighting
elements used over the range of
Mercedes-Benz models. In comparison,
the default credit value for high
efficiency exterior lighting in the
MY2017–2025 rule is 1.0 g/mi CO2.
13 40
CFR 86.1869–12(a)(ii).
Technical Support Document,
Chapter 5, Section 5.2.3.
15 Schoettle, B., et al., ‘‘LEDS and Power
Consumption of Exterior Automotive Lighting:
Implications for Gasoline and Electric Vehicles,’’
University of Michigan Transportation Research
Institute, October, 2008. For the MY2017–2025
Rule, the high efficiency exterior lighting wattage
for one lighting element, low beam head lights, was
revised based on manufacturer comment.
14 MY2017–2025
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Infrared Glazing
Mercedes-Benz is applying for offcycle credits for infrared glazing for the
MY 2012–2013 S-Class, ML-Class and
GL-Class vehicles that utilize infrared
glazing technology (See Section IV of
Mercedes-Benz’s application). The
infrared glazing technology absorbs and/
or reflects a percentage of the infrared
solar energy emitted from the sun and
reduces the amount of solar heat load
transmitted into the cabin; this is
termed ‘‘total solar transmittance’’ or
‘‘Tts.’’ The Tts is usually expressed as
a percentage and defined as the amount
of solar energy that passes through the
glazing, including energy absorbed and
subsequently re-radiated to the interior,
to the amount of solar energy imparted
on the surface of glazing.16 The higher
this number, the more solar energy is
allowed to penetrate into the passenger
cabin. Therefore, a lower Tts number is
better since less solar energy will
penetrate the passenger cabin and,
consequently, the interior cabin
temperature is reduced. Infrared glazing
technologies improve passenger
comfort, reducing the need for air
conditioning (A/C) usage, which in turn,
reduces vehicle fuel consumption.
EPA’s analysis relied on a study
performed by the National Renewable
Energy Laboratory (NREL)
demonstrating that a one degree
centigrade reduction in cabin air
temperature results in a 2.2% reduction
in CO2 emissions resulting from a
reduction in passenger compartment
temperature and reduced A/C usage.17
To calculate the infrared glazing
credits, Mercedes-Benz used the
methods set forth in Chapter 5 of the
TSD for the MY 2017–2025 rule.18 This
method utilizes the International
Organization for Standardization’s (ISO)
standard #13837 for measuring the solar
transmittance of infrared glazing 19 and
a formula for estimating the effect of the
solar performance of glazing
technologies developed by EPA and
California Air Resources Board with
16 Title 17 California Code of Regulations
§ 95600–95605: ‘‘Cool Car Standards and Test
Procedures—2012 and Subsequent Model-Year
Passenger Cars, Light-Duty Trucks, and MediumDuty Vehicles.’’; Air Resources Board; May 8, 2009
(see:https://www.arb.ca.gov/regact/2009/coolcars09/
coolcarsappa.pdf).
17 Rugh, J., Farrington, R. ‘‘Vehicle Ancillary Load
Reduction Project Close-Out Report,’’ National
Renewable Energy Laboratory Technical Report
NREL/TP–540–42454, January, 2008.
18 MY2017–2025 Technical Support Document,
Chapter 5, Section 5.2.10.
19 International Organization for
Standardization’s (ISO) 13837: ‘‘Road vehicles—
Safety glazing materials—Method for the
determination of solar transmittance,’’ April 15,
2008.
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Federal Register / Vol. 78, No. 190 / Tuesday, October 1, 2013 / Notices
input from the National Renewable
Energy Laboratory (NREL) and the
Enhanced Performance Glass
Automotive Association (EPGAA).
Specifically, the contribution of each
glass/glazing location to the overall
interior temperature reduction is
estimated using its measured Tts,
relative to a baseline level, and the area
of the glass/glazing location relative to
the overall glass area. 20
The infrared glazing used by
Mercedes-Benz has the same Tts
performance levels as the baseline Tts
levels specified in the MY2017–2025
rule: 62% for all glazing locations,
except for rooflites and rear side
glazings of crossovers, SUVs, and
minivans, which have a baseline Tts of
40%. Based on the Tts levels for
Mercedes Benz’s infrared glazing and
the formula described above, MercedesBenz calculated a credit of 0.8 to 1.7 g/
mi CO2 for the infrared glazing used
over the range of Mercedes-Benz
models. In comparison, the default
credit values for infrared glazing in the
MY2017–2025 rule are scalable
depending on such factors as the
amount of glass in the vehicle and the
performance of the glazing, up to a
maximum of 2.9 g/mi CO2 for cars and
3.9 g/mi CO2 for trucks.
emcdonald on DSK67QTVN1PROD with NOTICES
Active Seat Ventilation
Mercedes-Benz is applying for offcycle credits for applicable vehicles that
have active seat ventilation on both the
front row’ driver and passenger seats
(See Section IV of Mercedes-Benz’s
application).21 The Mercedes-Benz
active seat ventilation technology has
the capability to both pull air away from
and push air to the seating surface.
To calculate the active seat ventilation
credits, Mercedes-Benz used the
methods set forth in Chapter 5 of the
MY 2017–2025 TSD.22 Based on the
NREL study mentioned above, a 7.5%
reduction in air conditioning (A/C)
related emissions could be achieved by
lowering the surface temperature of the
vehicle seats.23
Based on the seat location criteria,
capability, and the methodology
described above, Mercedes-Benz
estimated a credit of 1.0 g/mi CO2 for
cars and 1.3 g/mi CO2 for trucks for the
active seat ventilation technology used
over the range of Mercedes-Benz
models. These values are identical to
the default values in the pre-approved
off-cycle credit list in the MY 2017–
CFR 86.1869–12(b)(1)(viii)(A).
CFR 86.1869–12(b)(4)(viii).
22 MY2017–2025 Technical Support Document,
Chapter 5, Section 5.2.11.
23 Ibid 12.
2025 rule. Therefore, Mercedes-Benz
concludes that its active seat ventilation
system achieves equivalent performance
to that assumed in the MY 2017–2025
rule. Mercedes-Benz could use the preapproved list to claim these credits
beginning in MY 2014, but since they
are seeking credits to begin in MY 2012,
and because these technologies are not
measurable through the 5-cycle testing
pathway, Mercedes-Benz is applying for
these credits through this alternative
technology pathway.
III. EPA Decision Process
EPA is providing a 30-day comment
period on this application for an
alternative methodology for off-cycle
credits, as specified by the regulations.
The manufacturer may submit a written
rebuttal of comments for EPA’s
consideration, or may revise its
application in response to comments;
EPA would review a revised application
as if it were a new application.24 After
reviewing any public comments and any
rebuttal of comments submitted by
Mercedes-Benz, EPA will make a final
decision regarding the credit request.
EPA will make its decision available to
the public by placing a decision
document in the docket as specified in
the MY 2017–2025 rule.25 and on EPA’s
Web site at https://www.epa.gov/otaq/
regs/ld-hwy/greenhouse/ld-ghg.htm.
An EPA decision to approve Mercedes
Benz’s off-cycle credit request would
only apply to the vehicles specified in
the Mercedes-Benz application for MYs
2012–2016. Such decision would not
apply to other Mercedes-Benz vehicles
or vehicles from other manufacturers.
While the broad methodology used by
Mercedes-Benz could potentially be
used for other vehicles and by other
manufacturers, the vehicle specific data
needed to demonstrate the off-cycle
emissions reductions would likely be
different. In such cases, a new
application would be required,
including an opportunity for public
comment.
Dated: September 20, 2013.
Byron Bunker,
Director, Compliance Division, Office of
Transportation and Air Quality, Office of Air
and Radiation.
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ENVIRONMENTAL PROTECTION
AGENCY
[FRL–9901–55–OCFO]
Notice of Open Meeting of the
Environmental Financial Advisory
Board (EFAB)
Environmental Protection
Agency (EPA).
ACTION: Notice.
AGENCY:
The United States
Environmental Protection Agency’s
(EPA) Environmental Financial
Advisory Board (EFAB) will hold a full
board meeting on October 22–23, 2013.
EFAB is an EPA advisory committee
chartered under the Federal Advisory
Committee Act (FACA) to provide
advice and recommendations on
environmental financing issues. EFAB
focuses its advice and recommendations
on promoting sustainability by reducing
environmental costs; increasing public
and private investment; and building
state, local, and tribal financial capacity.
The purpose of the meeting is to hear
from informed speakers on
environmental finance issues, review
Agency challenges and priorities;
discuss progress with EFAB work
projects currently underway; review and
consider requests for assistance from
EPA offices as well as suggestions from
EFAB members; and, to develop EFAB’s
FY 2014 Strategic Action Agenda.
Environmental Finance topics
expected to be discussed include:
Transit-Oriented Development in
Sustainable Communities; Drinking
Water Pricing and Infrastructure
Investment; and Green Infrastructure.
The meeting is open to the public,
however, seating is limited. All
members of the public who wish to
attend the meeting must register in
advance, no later than Friday, October
11, 2013.
DATES: Full Board Meeting is scheduled
for Tuesday, October 22, 2013 from
10:15 a.m. to 5:00 p.m. and Wednesday,
October 23, 2013 from 8:30 a.m. to 3:00
p.m.
ADDRESSES: EPA Potomac Yards North
Bldg., 2733 S. Crystal City Drive, Room
4120, Arlington, VA 22202.
SUMMARY:
Registration and Information Contact
To register for this meeting or get
further information, please contact
Sandra Williams, U.S. EPA, at (202)
564–4999 or williams.sandra@epa.gov.
For information on access or services for
individuals with disabilities, please
contact Sandra Williams. To request
accommodations of a disability, contact
Sandra Williams, preferably at least 10
E:\FR\FM\01OCN1.SGM
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Agencies
[Federal Register Volume 78, Number 190 (Tuesday, October 1, 2013)]
[Notices]
[Pages 60275-60279]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2013-23964]
=======================================================================
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ENVIRONMENTAL PROTECTION AGENCY
[FRL-9901-57-OAR]
Alternative Method for Calculating Off-Cycle Credits for
Mercedes-Benz Vehicles Under the Light-Duty Greenhouse Gas Emissions
Program
AGENCY: Environmental Protection Agency (EPA).
ACTION: Notice.
-----------------------------------------------------------------------
SUMMARY: In the light-duty vehicle greenhouse gas rule for model year
2012 through 2016 vehicles, EPA established a program to allow
automobile manufacturers to generate ``off-cycle'' carbon dioxide
(CO2) credits by employing technologies that achieve
CO2 reductions in the real world but are not appropriately
captured on the test procedures used by manufacturers to demonstrate
compliance with the CO2 standards. Under one of the program
options, a manufacturer may develop and submit to EPA for approval an
alternative demonstration methodology justifying eligibility for off-
cycle credits and their amount. The regulations concerning off-cycle
credits require an opportunity for public comment as part of EPA's
review of such an alternative methodology. EPA is requesting comment on
an alternative methodology submitted by Mercedes-Benz for determining
off-cycle credits for the following technologies: engine stop-start,
high efficiency exterior lighting, infrared glazing, and active seat
ventilation. The application is only for off-cycle credits for
Mercedes-Benz vehicles for the 2012 through 2016 model years.
DATES: Comments must be received on or before October 31, 2013.
ADDRESSES: Submit your comments, identified by Docket ID No. EPA-HQ-
OAR-2013-0643, by one of the following methods:
On-Line at https://www.regulations.gov: Follow the On- Line
Instructions for Submitting Comments.
Email: a-and-r-docket@epa.gov.
Fax: (202) 566-1741.
Mail: Air and Radiation Docket, Docket ID No. EPA-HQ-OAR-
2013- 0643, U.S. Environmental Protection Agency, Mailcode: 6102T, 1200
Pennsylvania Avenue NW., Washington, DC 20460. Please include a total
of two copies.
Hand Delivery: EPA Docket Center, Public Reading Room, EPA
West Building, Room 3334, 1301 Constitution Avenue NW., Washington, DC
20460. Such deliveries are only accepted during the Docket's normal
hours of operation, and special arrangements should be made for
deliveries of boxed information.
On-Line Instructions for Submitting Comments: Direct your comments
to Docket ID No. EPA-HQ-OAR-2013- 0643. EPA's policy is that all
comments received will be included in the public docket without change
and may be made available online at https://www.regulations.gov,
including any personal information provided, unless the comment
includes information claimed to be Confidential Business Information
(CBI) or other information whose disclosure is restricted by statute.
Do not submit information that you consider to be CBI or otherwise
protected through https://www.regulations.gov or email.
The https://www.regulations.gov Web site is an ``anonymous access''
system, which means EPA will not know your identity or contact
information unless you provide it in the body of your comment. If you
send an email comment directly to EPA without going through https://www.regulations.gov, your email address will automatically be captured
and included as part of the comment that is placed in the public docket
and made available on the Internet. If you submit an electronic
comment, EPA recommends that you include your name and other contact
information in the body of your comment and with any disk or CD-ROM you
submit. If EPA cannot read your comment due to technical difficulties
and cannot contact you for clarification, EPA may not be able to
consider your comment. Electronic files should avoid the use of special
characters, any form of encryption, and be free of any defects or
viruses. For additional information about EPA's public docket visit the
EPA Docket Center homepage at https://www.epa.gov/epahome/dockets.htm.
Materials relevant to this proceeding are contained in the Air and
Radiation Docket and Information Center, maintained in Docket ID No.
EPA-HQ- OAR-2013-0643. Publicly available docket materials are
available either electronically through https://www.regulations.gov or
in hard copy at the Air and Radiation Docket in the EPA Headquarters
Library, EPA West Building, Room 3334, located at 1301 Constitution
Avenue NW., Washington, DC. The Public Reading Room is open to the
public on all federal government work days from 8:30 a.m. to 4:30 p.m.;
generally, it is open Monday through Friday, excluding holidays. The
telephone number for the Reading Room is (202) 566-1744. The Air and
Radiation Docket and Information
[[Page 60276]]
Center's Web site is https://www.epa.gov/oar/docket.html. The electronic
mail (email) address for the Air and Radiation Docket is: a-and-r-docket@epa.gov, the telephone number is (202) 566-1742, and the fax
number is (202) 566-9744. An electronic version of the public docket is
available through the federal government's electronic public docket and
comment system. You may access EPA dockets at https://www.regulations.gov. After opening the https://www.regulations.gov Web
site, enter EPA-HQ-OAR-2013-0643 in the ``Enter Keyword or ID'' fill-in
box to view documents in the record. Although a part of the official
docket, the public docket does not include Confidential Business
Information (CBI) or other information whose disclosure is restricted
by statute.
EPA will keep the record open until October 31, 2013. All
information will be available for inspection at the EPA Air Docket No.
EPA-HQ-OAR-2013-0643. Persons with comments containing proprietary
information must distinguish such information from other comments to
the greatest extent possible and label it as ``Confidential Business
Information'' (``CBI''). If a person making comments wants EPA to base
its decision on a submission labeled as CBI, then a non-confidential
version of the document that summarizes the key data or information
should be submitted to the public docket. To ensure that proprietary
information is not inadvertently placed in the public docket,
submissions containing such information should be sent directly to the
contact person listed below and not to the public docket. Information
covered by a claim of confidentiality will be disclosed by EPA only to
the extent allowed, and according to the procedures set forth in 40 CFR
part 2. If no claim of confidentiality accompanies the submission when
EPA receives it, EPA will make it available to the public without
further notice to the person making comments.
FOR FURTHER INFORMATION CONTACT: Roberts French, Environmental
Protection Specialist, Office of Transportation and Air Quality,
Compliance Division, U.S. Environmental Protection Agency, 2000
Traverwood Drive, Ann Arbor, MI 48105. Telephone: (734) 214-4380. Fax:
(734) 214-4869. Email address: french.roberts@epa.gov.
SUPPLEMENTARY INFORMATION:
I. Background
In the model year (MY) 2012-2016 light-duty vehicle greenhouse gas
(GHG) rule, EPA established an option for manufacturers to generate
credits by employing technologies that achieve carbon dioxide
(CO2) reductions in the real world but are not captured on
the 2-cycle test procedures used to determine compliance with the fleet
average standards (i.e., ``off-cycle'' credits). EPA adopted the off-
cycle credit option to encourage the introduction of these types of
technologies, believing that off-cycle CO2 reductions should
be considered in determining a manufacturer's fleet average, and that a
credit mechanism is an effective way to achieve this.
The MY 2012-2016 rule provided two ways for manufacturers to
demonstrate the off-cycle emissions reduction capabilities of a
technology and generate off-cycle credits, either through 5-cycle
testing (which captures elements of real-world driving not captured by
the 2-cycle compliance tests, including high speeds, rapid
accelerations, and cold temperature operation) or an alternative
demonstration methodology developed by the manufacturer and approved by
EPA.\1\ The MY 2017-2025 light-duty GHG rule streamlined the off-cycle
credits program and provided a third pathway for credits, a pre-
determined credits list that may be used beginning in MY 2014.\2\
---------------------------------------------------------------------------
\1\ 75 FR 25438-25440, May 7, 2010.
\2\ 77 FR 62832-62839, October 15, 2012.
---------------------------------------------------------------------------
The first pathway for a manufacturer to demonstrate off-cycle
technology is to conduct 5-cycle emissions testing with and without the
technology applied to the vehicle.\3\ If the off-cycle emissions
benefit of the technology is able to be adequately captured through 5-
cycle testing, the manufacturer must conduct testing per the
regulations, and submit the data to EPA.\4\ This methodology was
proposed in detail in the rulemakings, which included an opportunity
for public comment, and therefore manufacturers' applications for
credits using the 5-cycle process do not undergo additional public
review.
---------------------------------------------------------------------------
\3\ 40 CFR 86.1869-12(c).
\4\ 40 CFR 86.1869-12(c).
---------------------------------------------------------------------------
The second pathway allows manufacturers to demonstrate off-cycle
emissions reduction technology using an alternative methodology
developed by the manufacturer in cases where the real world benefit of
the technology cannot be adequately demonstrated using the 5-cycle test
procedures.\5\ The regulations regarding the alternative methodology,
excerpted below, specify the data and information needed to support a
manufacturer's off-cycle credit application.\6\ The alternative
methodology must be approved by EPA prior to the manufacturer
generating credits. Also, as part of the EPA review, the alternative
methodology must be made available for public comment.\7\ EPA will
consider public comments as part of its final decision to approve or
deny the credit request.
---------------------------------------------------------------------------
\5\ 40 CFR 86.1869-12(d).
\6\ 40 CFR 86.1869-12(d) and (e).
\7\ 40 CFR 86.1869-12(d)(2).
---------------------------------------------------------------------------
The regulations for the alternative methodology provided at 40 CFR
86.1869-12(d)(1)(i)-(iv) specify that the alternative demonstration
program must be approved in advance by the Administrator and should be
based on modeling, on-road testing, on-road data collection, or other
approved analytical or engineering methods, and should be robust,
verifiable, and capable of demonstrating the real-world emissions
benefit of the technology with strong statistical significance.
Further, the alternative program should result in a demonstration of
baseline and controlled emissions over a wide range of driving
conditions and vehicles in order to minimize issues of data
uncertainty. Additionally, the regulations at 40 CFR 86.1869-
12(e)(1)(ii)-(iii) and (e)(2)(i)-(iv) provide specificity regarding the
data and information that must be submitted to EPA as part of an
application for credits using an alternative demonstration methodology.
As noted above, as part of the MY 2017-2025 rule, EPA adopted a
list of pre-approved off-cycle technologies and credits that
manufacturers can use beginning in MY 2014.\8\ This third option was
included in the MY 2017-2025 rule because certain types of off-cycle
credits are amenable to quantification without further demonstration,
and EPA's specification of these credits therefore significantly
streamlines the off-cycle credits program and reduces the testing and
data burden that the program otherwise entails. Manufacturers using the
pre-approved list only need to provide EPA at the time of certification
with information demonstrating that their technology meets applicable
definitions and qualifies for credits. There are no testing or other
requirements for demonstrating emissions reductions. Manufacturers may
however use the 5-cycle or alternative methodology pathways in MY 2014
and later to demonstrate that their technology achieves greater off-
cycle emissions reductions than are provided by the pre-defined list.
Also, manufacturers would need to use the 5-cycle or alternative
methodology pathways to demonstrate eligibility for credits for
technologies
[[Page 60277]]
that are not on the list, as well as the extent of the credits.
---------------------------------------------------------------------------
\8\ 40 CFR 86.1869-12(a).
---------------------------------------------------------------------------
Mercedes-Benz is applying for credits for model years prior to MY
2014 and for credits in excess of the credits on the pre-approved list.
The technologies cannot be adequately demonstrated over the 5-cycle
test and therefore Mercedes-Benz has applied for credits under the
alternative methodology approach discussed above.
II. Mercedes-Benz Off-Cycle Credit Application and Alternative
Methodology
Mercedes-Benz has applied for off-cycle credits using the
alternative demonstration methodology pathway for the following
technologies: engine stop-start, high efficiency exterior lighting,
infrared glazing, and active seat ventilation. The application covers
MY 2012-2016 vehicles. EPA has reviewed the application for
completeness and is now making the application available for public
review and comment per the regulations.\9\ The Mercedes-Benz off-cycle
credit application with confidential business information redacted has
been placed in docket EPA-HQ- OAR-2013-0643 and on EPA's Web site at
https://www.epa.gov/otaq/regs/ld-hwy/greenhouse/ld-ghg.htm.
---------------------------------------------------------------------------
\9\ Sec. 86.1869-12(e)(3).
---------------------------------------------------------------------------
A summary of Mercedes' alternative methodology for each of the four
technologies is provided below. For context and comparison, in
summarizing the Mercedes-Benz alternative methodology, EPA provides
some background on how the Mercedes-Benz methodology compares to that
developed by EPA in the MY 2017-2025 light-duty GHG rulemaking for the
pre-approved list of off-cycle credits, which is contained in the Joint
Technical Support Document (TSD), Chapter 5.\10\
---------------------------------------------------------------------------
\10\ Joint Technical Support Document: Final Rulemaking for
2017-2025 Light-duty Vehicle Greenhouse Gas Emission Standards for
Corporate Average Fuel Economy Standards, United States
Environmental Protection Agency and National Highway Traffic Safety
Administration, August 2012, EPA-420-R-12-901.
---------------------------------------------------------------------------
A. Engine Stop-Start
Mercedes-Benz is applying for engine idle stop-start credit
covering all of their MY 2012-2016 U.S. model product range (e.g.,
small/mid-size/large cars and light-duty trucks) (See Section II-III of
Mercedes-Benz Application). Mercedes-Benz is following a similar
methodology to the one EPA described in the TSD for the MY2017-2025
rule, but with unique inputs for idle time and stop-start system
effectiveness which includes parameters related to Mercedes' unique
control strategy for its stop-start system.\11\
---------------------------------------------------------------------------
\11\ MY2017-2025 Technical Support Document, Chapter 5, Section
5.2.8.1.
---------------------------------------------------------------------------
The basic methodology entails the following steps: estimate or
measure the total idle fraction as a percentage of all vehicle
operation in the real-world; estimate or measure the percentage of idle
fraction that the stop-start system is enabled out of all the available
idle time (i.e., eligible stop-start percentage or stop-start system
effectiveness); determine the benefit of the stop-start system in grams
per mile based on A-B testing (i.e., technology on and off); and
multiply the eligible real world stop-start time (relative to the 2-
cycle eligible time) by the stop-start system benefit to estimate the
engine idle stop-start credit.
In lieu of the EPA default idle time derived from the MOVES model,
Mercedes-Benz is proposing to apply a unique idle time specific to its
vehicles. To estimate the total idle time as a percentage of all
vehicle operation, Mercedes-Benz conducted a field study in calendar
years 2010-2011 including 29 instrumented customer vehicles, randomly
selected from the Mercedes-Benz customer base. The field study was
performed for a period of 13 months in eight states: California, New
York, New Jersey, Florida, Texas, Illinois, Virginia, and Arizona.
These eight states represented about 65% of the Mercedes-Benz sales
volume. The remaining 35% of the Mercedes-Benz sales fleet was
distributed in the other 42 states not included in the idle fraction
study. During the course of the study, the vehicles accumulated 311,118
miles. The 29 vehicle sample broadly represents the Mercedes-Benz
models equipped with stop-start technology sold in the United States.
Based on this study, Mercedes-Benz estimated that its vehicles have a
23.83% total idle fraction as a percentage of all vehicle operation.
To provide further support for its idle fraction estimate,
Mercedes-Benz acquired an independent estimate of idle fraction for its
vehicles from Progressive Insurance. Progressive Insurance has about
1.4 million vehicles in its ``Snapshot'' Program covering 44 states
(excluding California, North Carolina, Tennessee, Indiana, Arkansas,
and Hawaii), over a six month period.\12\ In the Progressive data set,
there are 17,484 Mercedes-Benz vehicles which are represented in
proportion to current industry sales shares. Based on the Progressive
data set, the Mercedes-Benz vehicles are estimated to have an idle
fraction of 23.9%. This is almost exactly the same as the 23.83% idle
fraction found in the Mercedes-Benz study discussed above and used by
Mercedes-Benz in their analysis. Further, since the Progressive
Insurance data covers 37 out of the other 42 states not included in the
Mercedes-Benz idle fraction study, this data implies that the other 35%
of the sales volume not represented by the Mercedes-Benz data has
consistent idle fractions. Mercedes indicated that none of the other 42
states, except for Pennsylvania, have equivalent sales volumes to the
states used in the idle fraction study. As such, Mercedes-Benz
concludes that the idle fraction for the other 35% of the sales volume,
if different, would not have significantly altered the idle fraction
estimate.
---------------------------------------------------------------------------
\12\ Of these states, only California is a major market for
Mercedes-Benz.
---------------------------------------------------------------------------
To estimate the percentage of idle fraction during which the stop-
start system is enabled, Mercedes-Benz used EPA's methodology in
Chapter 5 of the Technical Support Document (TSD) for the MY2017-2025
rule, with inputs specific to Mercedes-Benz vehicles and control
strategies.
The following background is provided to give some additional
context on how EPA derived off-cycle credits for stop-start systems for
the pre-approved menu in the MY 2017-2025 rulemaking. EPA constrained
stop-start system effectiveness based on three operating temperature
ranges: cold temperatures below 40 degrees Fahrenheit, mid-temperatures
between 40 and 80 degrees Fahrenheit, and hot temperatures above 80
degrees. For the cold temperature range, EPA assumed that passenger
demand for heat would reduce stop-start effectiveness unless the
vehicle possesses an electric heater circulation pump, or equivalent
system, that supplies sufficient heat during engine off operation. For
the hot temperature range, EPA assumed that passenger demand for air
conditioning (A/C) would render the stop-start system inoperable,
unless the manufacturer has some supplemental system to support cabin
cooling. For all the temperature ranges, EPA assumed that the stop-
start system always defaults on when the vehicle is keyed on. EPA
assumed the overall system effectiveness would be reduced to 87.75% due
to these temperature effects.
Mercedes Benz's stop-start system has several design features that
differ from those used by EPA for the pre-approved menu analysis. As
described in Section III of the Mercedes-Benz application, Mercedes-
Benz took these factors into account in analyzing its system
performance. First, the Mercedes-Benz stop-start system includes an
electric
[[Page 60278]]
heater circulation pump that maintains cabin heating in cold
temperatures, and thus enables stop-start capability when heat is
demanded. Second, the Mercedes-Benz system has a supplemental 12 volt
battery system that supplies power for all the electrical components
and accessories. This allows the main battery to support restarting and
also enables stop-start capability even when A/C is demanded. Mercedes-
Benz also made an adjustment to account for OBD and stop-start
interactions, which limits the availability of stop-start during the
first 170 seconds of vehicle operation. These adjustments resulted in
an estimated fraction of effectiveness (i.e., when the system is
active) of about 91.32%, compared to EPA's generic estimate of 87.75%.
In addition, the Mercedes-Benz system includes an ``EcoButton''
that allows customers to disable the stop-start system. An estimate of
the frequency of use of the EcoButton to disable the stop-start system
is included in the Mercedes-Benz calculations. Finally, the Mercedes-
Benz stop-start system has a maximum engine off duration of three
minutes; therefore, the stop-start system would not be active after an
idle period exceeds three minutes. Based on these features, Mercedes-
Benz reduced its eligible idle time of 23.83% to a total eligible idle
time of 21.22% using the 91.32% system effectiveness discussed above,
and an additional discount of 2.5% for EcoButton usage and idles
exceeding the Mercedes-Benz system's 3 minute engine off duration.
To determine the CO2 emissions benefit of the stop-start
system, Mercedes-Benz performed testing of Mercedes-Benz vehicles
equipped with stop-start in different vehicle categories with the stop-
start system on and off. Based on this testing, Mercedes-Benz measured
a benefit of: 9.8 g/mi CO2 for small size cars, 8.1 g/mi
CO2 for mid-size cars, 16.9 g/mi CO2 for large
size cars, and 15.2 g/mi CO2 for light-duty trucks (e.g.,
SUVs). These g/mile GHG improvement values reflect the operational
effectiveness of the Mercedes-Benz system during the 2-cycle testing.
The effectiveness (i.e., the time the engine is off compared to the
total idle time in the cycle) of the stop-start system over the 2-cycle
test ranged from 67.3% to 80.4%.
Based on the eligible stop-start idle fraction of 21.22%, compared
with 10% idle fraction over the 2-cycle tests, and the emissions
benefits measured above, Mercedes-Benz calculated an engine stop-start
credit of 11.0 g/mi CO2 for small size cars; 9.1 g/mi
CO2 for mid-size cars; 19.0 g/mi CO2 for large
size cars; and 17.1 g/mi CO2 for light-duty trucks (for
example, for small cars, these credits were derived as: (9.8 g/mi
CO2 x 0.2122/0.10) - 9.8 g/mi CO2 = 11.0 g/mi
CO2).
High Efficiency Exterior Lighting
Mercedes-Benz is applying for off-cycle credits for high efficiency
exterior lighting for their MY 2012-2016 U.S. model product range with
the following lighting elements: low beam head lights, high beam head
lights, parking/position, front turn signal, front side marker, tail
lights, rear turn signal, and license plate (See Section IV of the
Mercedes-Benz application). This list of lighting elements is
consistent with that specified by EPA for the pre-approved list in the
MY 2017-2025 rule.\13\
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\13\ 40 CFR 86.1869-12(a)(ii).
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To calculate the high efficiency exterior lighting credits,
Mercedes-Benz used the EPA methodology set forth in the TSD for the
MY2017-2025 rule.\14\ Specifically, Mercedes-Benz used the MY 2017-2025
rule baseline wattage values for each lighting element listed above and
the time of day (e.g., day time, night time) usage rates from a study
performed by Schoettle et al. \15\ and inserted the wattage values from
the Mercedes-Benz high efficiency exterior lighting to determine the
wattage savings for each lighting element. In most cases, the Mercedes-
Benz wattage savings for each lighting element exceeded the wattage
savings projected in the MY 2017-2025 rule (exceptions: parking/
position lights at 70% savings versus 78% in the MY 2017-2025 rule;
license plate light at 86% versus 90% in the MY 2017-2025 rule).
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\14\ MY2017-2025 Technical Support Document, Chapter 5, Section
5.2.3.
\15\ Schoettle, B., et al., ``LEDS and Power Consumption of
Exterior Automotive Lighting: Implications for Gasoline and Electric
Vehicles,'' University of Michigan Transportation Research
Institute, October, 2008. For the MY2017-2025 Rule, the high
efficiency exterior lighting wattage for one lighting element, low
beam head lights, was revised based on manufacturer comment.
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For the final credit amounts, Mercedes-Benz multiplied the wattage
savings times the usage rates and a constant of 0.032 g/mi
CO2/watt (based on data showing a 100 watt savings equates
to 3.2 g/mi CO2 savings) for a credit of 1.1 g/mi
CO2 total for all the high-efficiency exterior lighting
elements used over the range of Mercedes-Benz models. In comparison,
the default credit value for high efficiency exterior lighting in the
MY2017-2025 rule is 1.0 g/mi CO2.
Infrared Glazing
Mercedes-Benz is applying for off-cycle credits for infrared
glazing for the MY 2012-2013 S-Class, ML-Class and GL-Class vehicles
that utilize infrared glazing technology (See Section IV of Mercedes-
Benz's application). The infrared glazing technology absorbs and/or
reflects a percentage of the infrared solar energy emitted from the sun
and reduces the amount of solar heat load transmitted into the cabin;
this is termed ``total solar transmittance'' or ``Tts.'' The Tts is
usually expressed as a percentage and defined as the amount of solar
energy that passes through the glazing, including energy absorbed and
subsequently re-radiated to the interior, to the amount of solar energy
imparted on the surface of glazing.\16\ The higher this number, the
more solar energy is allowed to penetrate into the passenger cabin.
Therefore, a lower Tts number is better since less solar energy will
penetrate the passenger cabin and, consequently, the interior cabin
temperature is reduced. Infrared glazing technologies improve passenger
comfort, reducing the need for air conditioning (A/C) usage, which in
turn, reduces vehicle fuel consumption. EPA's analysis relied on a
study performed by the National Renewable Energy Laboratory (NREL)
demonstrating that a one degree centigrade reduction in cabin air
temperature results in a 2.2% reduction in CO2 emissions
resulting from a reduction in passenger compartment temperature and
reduced A/C usage.\17\
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\16\ Title 17 California Code of Regulations Sec. 95600-95605:
``Cool Car Standards and Test Procedures--2012 and Subsequent Model-
Year Passenger Cars, Light-Duty Trucks, and Medium-Duty Vehicles.'';
Air Resources Board; May 8, 2009 (see:https://www.arb.ca.gov/regact/2009/coolcars09/coolcarsappa.pdf).
\17\ Rugh, J., Farrington, R. ``Vehicle Ancillary Load Reduction
Project Close-Out Report,'' National Renewable Energy Laboratory
Technical Report NREL/TP-540-42454, January, 2008.
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To calculate the infrared glazing credits, Mercedes-Benz used the
methods set forth in Chapter 5 of the TSD for the MY 2017-2025
rule.\18\ This method utilizes the International Organization for
Standardization's (ISO) standard 13837 for measuring the solar
transmittance of infrared glazing \19\ and a formula for estimating the
effect of the solar performance of glazing technologies developed by
EPA and California Air Resources Board with
[[Page 60279]]
input from the National Renewable Energy Laboratory (NREL) and the
Enhanced Performance Glass Automotive Association (EPGAA).
Specifically, the contribution of each glass/glazing location to the
overall interior temperature reduction is estimated using its measured
Tts, relative to a baseline level, and the area of the glass/glazing
location relative to the overall glass area. \20\
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\18\ MY2017-2025 Technical Support Document, Chapter 5, Section
5.2.10.
\19\ International Organization for Standardization's (ISO)
13837: ``Road vehicles--Safety glazing materials--Method for the
determination of solar transmittance,'' April 15, 2008.
\20\ 40 CFR 86.1869-12(b)(1)(viii)(A).
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The infrared glazing used by Mercedes-Benz has the same Tts
performance levels as the baseline Tts levels specified in the MY2017-
2025 rule: 62% for all glazing locations, except for rooflites and rear
side glazings of crossovers, SUVs, and minivans, which have a baseline
Tts of 40%. Based on the Tts levels for Mercedes Benz's infrared
glazing and the formula described above, Mercedes-Benz calculated a
credit of 0.8 to 1.7 g/mi CO2 for the infrared glazing used
over the range of Mercedes-Benz models. In comparison, the default
credit values for infrared glazing in the MY2017-2025 rule are scalable
depending on such factors as the amount of glass in the vehicle and the
performance of the glazing, up to a maximum of 2.9 g/mi CO2
for cars and 3.9 g/mi CO2 for trucks.
Active Seat Ventilation
Mercedes-Benz is applying for off-cycle credits for applicable
vehicles that have active seat ventilation on both the front row'
driver and passenger seats (See Section IV of Mercedes-Benz's
application).\21\ The Mercedes-Benz active seat ventilation technology
has the capability to both pull air away from and push air to the
seating surface.
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\21\ 40 CFR 86.1869-12(b)(4)(viii).
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To calculate the active seat ventilation credits, Mercedes-Benz
used the methods set forth in Chapter 5 of the MY 2017-2025 TSD.\22\
Based on the NREL study mentioned above, a 7.5% reduction in air
conditioning (A/C) related emissions could be achieved by lowering the
surface temperature of the vehicle seats.\23\
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\22\ MY2017-2025 Technical Support Document, Chapter 5, Section
5.2.11.
\23\ Ibid 12.
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Based on the seat location criteria, capability, and the
methodology described above, Mercedes-Benz estimated a credit of 1.0 g/
mi CO2 for cars and 1.3 g/mi CO2 for trucks for
the active seat ventilation technology used over the range of Mercedes-
Benz models. These values are identical to the default values in the
pre-approved off-cycle credit list in the MY 2017-2025 rule. Therefore,
Mercedes-Benz concludes that its active seat ventilation system
achieves equivalent performance to that assumed in the MY 2017-2025
rule. Mercedes-Benz could use the pre-approved list to claim these
credits beginning in MY 2014, but since they are seeking credits to
begin in MY 2012, and because these technologies are not measurable
through the 5-cycle testing pathway, Mercedes-Benz is applying for
these credits through this alternative technology pathway.
III. EPA Decision Process
EPA is providing a 30-day comment period on this application for an
alternative methodology for off-cycle credits, as specified by the
regulations. The manufacturer may submit a written rebuttal of comments
for EPA's consideration, or may revise its application in response to
comments; EPA would review a revised application as if it were a new
application.\24\ After reviewing any public comments and any rebuttal
of comments submitted by Mercedes-Benz, EPA will make a final decision
regarding the credit request. EPA will make its decision available to
the public by placing a decision document in the docket as specified in
the MY 2017-2025 rule.\25\ and on EPA's Web site at https://www.epa.gov/otaq/regs/ld-hwy/greenhouse/ld-ghg.htm.
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\24\ 40 CFR 86.1869-12(e)(3)(iii).
\25\ 40 CFR 86.1869-12(e)(4)(iii).
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An EPA decision to approve Mercedes Benz's off-cycle credit request
would only apply to the vehicles specified in the Mercedes-Benz
application for MYs 2012-2016. Such decision would not apply to other
Mercedes-Benz vehicles or vehicles from other manufacturers. While the
broad methodology used by Mercedes-Benz could potentially be used for
other vehicles and by other manufacturers, the vehicle specific data
needed to demonstrate the off-cycle emissions reductions would likely
be different. In such cases, a new application would be required,
including an opportunity for public comment.
Dated: September 20, 2013.
Byron Bunker,
Director, Compliance Division, Office of Transportation and Air
Quality, Office of Air and Radiation.
[FR Doc. 2013-23964 Filed 9-30-13; 8:45 am]
BILLING CODE 6560-50-P