Document 15mg8Mx56gBXaVNGxrkrprR85

Message From: Sent: To: CC: Subject: Daguillard, Robert [/0=EXCHANGELABS/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=BBE9682B940C4F2C90732E4D37355DD4-DAGUILLARD,] 12/19/2017 5:20:56 PM EricTaubi Press [/o-EXCTrcrng'eLaus/uu-txcnaTigsrHuiTrrrnsCT'ative Group (FYDIBOHF23SPDLT)/cn=Recipients/cn=b293283291dc44eOb5dlc36be9281d8a-Press] Subject: Re: From NY Times: Press Inquiry about Fuel: ethanol, RFS, fuel efficiency Eric, for attribution to "an EPA spokesperson," please: Answer: For the fuel economy label, today all manufacturers are required to test the vehicle with the high octane Tier 2 test fuel (E0 high octane gasoline). As discussed in EPA's Tier 3 final rule, EPA intends to transition manufacturers to the E10/87 octane fuel for the fuel economy label through a future rulemaking, and under that future approach EPA believes manufacturers would have the ability to use the E10/91 octane fuel for premium fuel only vehicles. More detail: As a result of the Tier 3 vehicle and gasoline fuel rulemaking, for criteria pollutant emissions testing companies are required to use an E10, 87 octane test fuel, unless the manufacturer conditions the warranty on the use of premium fuel, then the vehicle must be labeled as "premium fuel only", and then the manufacturer can test the vehicle for criteria pollutant emissions using an E10, 91 octane test fuel. More information on the Tier 3 Final rule is here: https://www.epa.gov/regulations-emissions-vehicles-and-engines/final-rule-control-air-pollution-motor-vehiclestier-3 From: Eric Taub j g Sent: Thursday, December''T4;'2'0I7'5:47PF! To: Jones, Enesta <Jones.Enesta@epa.gov> Cc: eric@taub.com; Press <Press@epa.gov> Subject: Re: From NY Times: Press Inquiry about Fuel: ethanol, RFS, fuel efficiency Thanks. One thing not clear: can a test use High octane if the vehicle doesn't require it AND the test is for fuel economy NOT for emissions? from my iPhone On Dec 14, 2017, at 14:29, Jones, Enesta <Jones.Enesta@epa.gov> wrote: Hi Eric, attributable to an EPA spokesperson: Tailpipe and Evaporative Emission Testing - Although EPA used to test light-duty gasoline-fueled vehicles using EPA unleaded gasoline or California Phase II test fuel (neither of which contains ethanol), the final rule for Tier 3 emission standards updated the federal emissions test fuel to contain E10 to better match today's in-use gasoline. The Tier 3 requirements went into effect beginning with the 2017 model year vehicles and are being phased in from 2017 to 2019 model years. Beginning with the 2020 model year, almost all gasoline vehicles will be tested for emissions on Tier 3 or LEV3 (E10) gasoline. The Tier 3 test fuel specifications, which can be found at 40 CFR 86.113 and 40 CFR 1065.710(a) (Table 1), apply to Tier 3 new vehicle certification, assembly line, and in-use testing. For more information about EPA's Tier 3 emission requirements, please visit https://www.epa.gov/regulations-emissions-vehicles-and-engines/final-rulecontrol-air-pollution-motor-vehicles-tier-3. Sierra Club v. EPA 18cv3472 NDCA Tier 13 ED 002061 00022405-00001 Fuel Economy Testing - Although Tier 3 vehicles are required to be tested on E10 test fuel for tailpipe and evaporative emissions beginning with the 2017 model year, EPA has not yet developed procedures to calculate fuel economy (mpg) values for vehicles tested on E10 test fuel. EPA is currently working on a rulemaking which will propose regulations to calculate fuel economy (mpg) values for vehicles tested on E10 test fuel. Thus, we expect that E10 test fuel will soon be required for fuel economy testing (similar to EPA Tier 3 emission testing requirements), e.g. beginning with 2020 model year vehicles. For fuel economy testing, EPA's test fuel for light-duty gasoline-fueled vehicles does not currently contain ethanol or other oxygenates. However, EPA does account for the impact of low-level ethanol blends in our fuel economy estimates. Ethanol has a lower energy density than gasoline--about 1/3 less energy per gallon. That means a car operating on E10 (10 percent ethanol and 90 percent gasoline) would require about 3 percent more fuel to travel one mile than a car operating on gasoline and thus have about 3 percent lower fuel economy. EPA adjusts the fuel economy label estimates downward by about 10-15 percent (city) and 25-30 percent (highway) to account for a variety of factors that are not currently accounted for during laboratory fuel economy testing, such as tire under-inflation, wind, hills, vehicle speeds and road conditions. It also includes a 1.5 percent downward adjustment to account for the average national ethanol content. Vehicles that are going to be sold in California or States that have adopted California emission standards must be certified to meet California's emission standards. The Vehicle Emissions Control Information (VECI) label, found under the hood of all cars and light-trucks, will list if the vehicle is certified to meet California emission standards.) Vehicles certified to meet California LEV3 emission standards for 2015 to 2025 model years are required to be tested for tailpipe emissions using E10 test fuel. (For more information, please visit www.arb.ca.gov/msprog/levprog/leviii/leviii.htm.) Octane Requirements of EPA Test Fuel - Prior to 2017 model year, EPA emission and fuel economy testing was performed on EO high octane gasoline test fuel. For Emission Testing: Beginning with the 2017 model year (and being phased in from 2017 to 2019 model years), EPA emission testing will be performed on Tier 3 E10 low octane or California LEV3 E10 low octane gasoline test fuel. High octane E10 gasoline test fuel may be used for emission testing only for vehicles which the manufacturer conditions the vehicle warranty on the use of high octane (premium grade) gasoline. From: Eric Taub [ Ex. 6 j Sent: Monday, December 11, 2017 2:39 PM To: Daguillard, Robert <Daguillard.Robert(5)epa.gov> Subject: From NY Times: Press Inquiry about Fuel: ethanol, RFS, fuel efficiency Hello Robert, Further to our brief chat, I'd like to know if a vehicle manufacturer, when testing a model for fuel efficiency standards, needs to use a specific octane grade of fuel in the tests. For example if one vehicle only "recommends" as opposed to "requires" 91 octane fuel, can they use 87 octane in the test? Similarly if a vehicle says only 87 octane fuel is required, can they use 91 octane fuel, as a way perhaps to boost their stated fuel economy numbers? As I mentioned I'm also considering expanding my piece to include a general prcis as to how fuel efficiency is tested in general, but we can talk about that in the coming days. Thanks, EricTaub NY Times Sierra Club v. EPA 18cv3472 NDCA Tier 13 ED 002061 00022405-00002 EricTaub <image001.jpg> eric@taub.com Ex. 6 Sierra Club v. EPA 18cv3472 NDCA Tier 13 ED 002061 00022405-00003