摘要: |
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 demonstrated 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 goal. The MY 2012-2016 rule provides two ways for manufacturers to demonstrate the off-cycle emissions reduction capabilities of a technology and thereby 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 as well as hot temperature operation), or through an alternative demonstration methodology developed by the manufacturer and approved by EPA.2 The alternative methodology approach 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. 3 The regulations regarding the alternative methodology specify the data and information needed to support a manufacturer’s off-cycle credit application.4 The alternative methodology proposed by the manufacturer 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. 5 |