Comments on U.S. Environmental Protection Agency Proposed Rule, "Control of Air Pollution from Motor Vehicles: Tier 3 Motor Vehicle Emission and Fuel Standards," RIN 2060-AQ86

   1) Gauging fuel consumption impacts - Suggest EPA assess the overall change to fuel economy within vehicle category.  Did the State of California conduct a similar analysis in support of its LEV III rulemaking?  If so, suggest incorporating by reference, since this proposal discusses essentially the same vehicle/technology/stringency combinations.
         a. How much will the high oxygen content of the new fuel affect fuel consumption?  The new certification fuel means a priori lower fuel economy than that of the higher energy-density current certification fuel.  
         b. What additional exhaust control equipment weight will be added to achieve the new emissions limits and what will be the fuel economy penalty be compared to the baseline?  

   2) Refinery compliance costs and sulfur disposal 

         a. What assumptions has EPA made concerning the by-product use of the sulfur removed from the refinery process?  Elemental sulfur market remains relatively soft, so refiners may be tempted to back the sulfur down to heavier refined grades (a common practice over time) rather than extract it.  
         b. Is the only feasible receptacle for this heating oil?  As the recent stringent limits on hoteling emissions in U.S. ports and sulfur control for nonroad diesel have essentially eliminated bunker fuel, the old standby of bygone days, and "red" diesel as candidates.  How did EPA consider the opportunity costs of not being able to use the higher sulfur fuel in these previously available markets?  Please describe the assumptions used, relative differences in value of products, and markets where EPA expects these products to now be used. 
         c. With respect to increased stringency of gasoline sulfur limits, refiners were already producing or preparing to produce ultra-low sulfur gasoline for the California market; however, this sulfur reduction will not be without added cost in order to comply nationwide.  
            

   3) In what respects is the Tier 3 rule not aligned with the CARB LEV III rule? 
         a. Will auto manufacturers be required to perform additional test procedures for the Tier 3 rule, that are not required under LEV III? If so, what are the costs to auto manufacturers of purchasing the equipment and/or running the tests that are required under Tier 3 but not required under LEV III?

   4) How does EPA account for the increased costs to manufacturers and consumers for repairing emissions control systems? As manufacturers are forced to add more intricate technologies to achieve more stringent emissions standards, the likelihood and frequency of problems that would require repair would presumably increase as well. Where does EPA address this issue in the rule?

   5) Certification fuel revisions  -  Will EPA explain the rationale for the proposed change to the specifications of vehicle emission/fuel economy certification fuel?  The table below highlights key changes to the certification fuel specs:

                     Proposed Gasoline Emissions Test Fuel
                                   Property
                                     Unit
                                 SPECIFICATION
                           ASTM Reference Procedure


                                    General
                                    Testing
                            Low-Temperature Testing
                             High Altitude Testing

Antiknock Index (R+M)/2
                                       -
                                  87.0 - 88.4
                                 87.0 Minimum
D2699-11 and D2700-11
Sensitivity (R-M)
                                       -
                                  7.5 Minimum

Dry Vapor Pressure Equivalent (DVPE)
                                   kPa (psi)
                                   60.0-63.4
                                   (8.7-9.2)
                                  77.2-81.4 
                                  (11.2-11.8)
                                   52.4-55.2
                                   (7.6-8.0)
D5191-10b
Distillation
                                                                 10% evaporated
                                   °C (°F)
                                     49-60
                                   (120-140)
                                     43-54
                                   (110-130)
                                     49-60
                                   (120-140)
D86-10a
                                                                 50% evaporated
                                   °C (°F)
                                77-88 (170-190)

                                                                 90% evaporated
                                   °C (°F)
                               154-166 (310-330)

                                                 Evaporated final boiling point
                                   °C (°F)
                               193-216 (380-420)

Residue
                                  Milliliter
                                  2.0 Maximum

Total Aromatic Hydrocarbons
                                    vol. %
                                   19.5-24.5
D5769-10
                                                         C6 Aromatics (benzene)
                                    vol. %
                                    0.6-0.8

                                                         C7 Aromatics (toluene)
                                    vol. %
                                    4.4-5.5

                                                                   C8 Aromatics
                                    vol. %
                                    5.5-6.9

                                                                   C9 Aromatics
                                    vol. %
                                    5.0-6.2

                                                                 C10+ Aromatics
                                    vol. %
                                    4.0-5.0

Olefins
                                     mass %
                                    4.5-11.5
D6550-10
Ethanol
                                    vol. %
                                   14.6-15.0
D5599-00 (Reapproved 2010)
Total Content of Oxygenates Other than Ethanol
                                    vol. %
                                  0.1 Maximum

Sulfur
                                     mg/kg
                                   8.0-11.0
D2622-10, D5453-09 or D7039-07
Lead
                                    g/liter
                                0.0026 Maximum
D3237-06
Phosphorus
                                    g/liter
                                0.0013 Maximum
D3231-11
Copper Corrosion
                                       -
                                 No. 1 Maximum
D130-10
Solvent-Washed Gum Content
                                   mg/100 ml
                                  3.0 Maximum
D381-09
Oxidation Stability
                                    Minute
                                 1,000 Minimum
D525-05

   6) Ethanol by % volume - Will EPA explain the rationale for jumping from the expected choice of a 10%-by-volume ethanol fuel, now common throughout the U.S., to E15?  Knowing that E15 has been shown to be less likely to volatilize its gasoline blendstock than E10, how does EPA anticipate this impacting ozone or other emissions?  Has EPA conducted a sensitivity analysis to see what the implications on vehicle emissions and air quality impacts are for using E10 versus E15?  What does EPA project concerning the penetration of E15 in gasoline blendstock?  Is there a particular date by which EPA expects E15 to be commonly used like E10 is today?  Please explain.

   7) Will EPA also explain why aromatics and olefin percentages are adjusted?  Is it in anticipation of higher oxygenate content and/or octane rating?  Please explain.  

   8) Will EPA explain under what circumstances vehicle manufacturers may request approval for an alternative certification fuel such as a high-octane 30 percent ethanol by volume (E30) blend for vehicles?  

   
