[Federal Register Volume 65, Number 180 (Friday, September 15, 2000)]
[Notices]
[Pages 55967-55973]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 00-23776]
-----------------------------------------------------------------------
ENVIRONMENTAL PROTECTION AGENCY
[FRL-6870-3]
Retrofit/Rebuild Requirements for 1993 and Earlier Model Year
Urban Buses; Certification of Equipment on the Basis of Life Cycle Cost
Criteria
AGENCY: Environmental Protection Agency (EPA)
ACTION: Notice of certification by EPA of equipment on the basis of
compliance with the life cycle cost criteria of the Urban Bus Rebuild
Requirements.
-----------------------------------------------------------------------
SUMMARY: In accordance with 40 CFR 85.1407(c), this notice announces
the decision of EPA to expand the certification of certain equipment to
include compliance with the life cycle cost criteria of the Urban Bus
Rebuild Program (40 CFR Part 85, Subpart O).
A Federal Register notice dated December 3, 1998 (63 FR 66798)
announced that EPA certified the JM CCTTM Upgrade Kit to
comply with the 0.10 g/bhp-hr particulate matter (PM) standard of the
Urban Bus Rebuild Program. The kit is applicable to 1985 through 1993
model year Detroit Diesel Corporation (DDC) 6V92TA DDEC II urban bus
engines having electronic control of fuel injection. That certification
is not based on the optional compliance with life cycle cost criteria
of the program.
In documents dated January 26, 1999, JM provided life cycle cost
information to EPA for the CCT kit, as it applies to engines of model
years 1988 through 1993. A Federal Register notice (64 FR 11864) dated
March 10, 1999, announced that EPA had received the cost information
and made it available for public review, and asked for public comment.
EPA has reviewed JM's life cycle cost information as well as the
comments received, and with today's Federal Register notice is
expanding certification of the JM equipment to include compliance with
the life cycle cost criteria.
Today's Federal Register notice announces that JM's certification
is expanded to include compliance with the life cycle cost criteria,
and would therefore serve to ``trigger'' the 0.10 g/
[[Page 55968]]
bhp-hr standard for the applicable engines, if necessary. This is
discussed below in additional detail.
The impact of today's action on urban bus operators is discussed
further below.
Category XXI of Public Docket A-93-42, entitled ``Certification of
Urban Bus Retrofit/Rebuild Equipment'' contains JM's notification of
intent to certify, the new cost information, as well as other materials
specifically relevant to it. This docket is located at the address
below.
DATES: The date of today's Federal Register notice, September 15, 2000,
is the effective date of certification by EPA of the CCT kit described
herein, for compliance with the applicable life cycle cost criteria of
the urban bus rebuild program. This certification will obligate JM to
offer the equipment meeting the 0.10 g/bhp-hr standard within the
specified life cycle cost limits discussed below. The impact of today's
action on urban bus operators is discussed below.
FOR FURTHER INFORMATION CONTACT: William Rutledge, Certification and
Compliance Division (6403J), U.S. Environmental Protection Agency,
Ariel Rios Building, 1200 Pennsylvania Avenue NW, Washington, DC 20460.
Telephone: (202) 564-9297. Email Address: [email protected].
SUPPLEMENTARY INFORMATION:
I. Program Background
On April 21, 1993, EPA published final Retrofit/Rebuild
Requirements for 1993 and Earlier Model Year Urban Buses (58 FR 21359).
The retrofit/rebuild program is intended to reduce the ambient levels
of particulate matter (PM) in urban areas and is limited to 1993 and
earlier model year (MY) urban buses operating in metropolitan areas
with 1980 populations of 750,000 or more, whose engines are rebuilt or
replaced after January 1, 1995. Operators of the affected buses are
required to choose between two compliance options: Program 1 sets
particulate matter emissions requirements for each urban bus engine in
an operator's fleet which is rebuilt or replaced; Program 2 is a fleet
averaging program that establishes specific annual target levels for
average PM emissions from urban buses in an operator's fleet. In
general, to meet either of the two compliance options, operators of the
affected buses must use equipment that has been certified by EPA.
A key aspect of the program is the certification of retrofit/
rebuild equipment. Emissions requirements under either of the two
compliance options depend on the availability of retrofit/rebuild
equipment certified for each engine model. To be used for Program 1,
equipment must be certified as meeting a 0.10 g/bhp-hr PM standard or,
if equipment is not certified as meeting the 0.10 standard, as
achieving a 25 percent reduction in PM. Equipment used for Program 2
must be certified as providing some level of PM reduction that would in
turn be claimed by urban bus operators when calculating their average
fleet PM levels attained under the program. For Program 1, information
on life cycle costs must be submitted in the notification of intent to
certify in order for certification of the equipment to initiate (that
is, to ``trigger'') program requirements. To trigger program
requirements, the certifier must guarantee that the equipment will be
available to all affected operators for a life cycle cost of $7,940 or
less at the 0.10 PM level, or for a life cycle cost of $2,000 or less
for the 25 percent or greater reduction in PM emissions. Both of these
values are based on 1992 dollars and are increments above costs
associated with a standard rebuild. If EPA determines that the life
cycle cost limit is met, then certification is based on ``life cycle
cost'' in addition to reducing PM emissions.
Under program 2, operators calculate their average fleet emissions
using specified engine PM emission levels (as well as other factors).
The 0.10 g/bhp-hr PM standard was triggered on September 21, 1998.
As described in a Federal Register notice on September 21, 1998 (63 FR
50225), EPA certified the ETX-2002TM Emissions Rebuild Kit
supplied by the Engelhard Corporation. The ETX kit applies to 1988
through 1993 model year Detroit Diesel Corporation 6V92TA DDEC II
engines having electronic fuel control and rated at either 253 or 277
horsepower (hp). That certification means that transit operators using
compliance program 1 must use rebuild kits certified to the 0.10
standard when rebuilding or replacing the applicable engines after
March 22, 1999 (that is, 6 months after September 21, 1998).
The September 21, 1998 Federal Register notice states that
certification of Engelhard's ETX kit, as it applies to engines of model
years 1988 through 1990, is conditional pending demonstration by
Engelhard that any replacement engine control module (ECM) or any
replacement ECM program used in conjunction with the kit would not
adversely impact the emissions of NOX. In a letter dated
March 2, 1999, to Engelhard, EPA stated that the conditional status was
removed and that the ETX kit can be used by transit operators in
compliance with the requirement of the rebuild program. In a letter
dated March 29, 1999, EPA stated that due to confusion surrounding the
conditional certification, it will not take action against an operator
who does not install 0.10 kits between March 22, 1999 and May 21, 1999.
Further, EPA stated in the letter that it will extend this period of no
action past May 21, 1999, if the general counsel for a bus operator
certifies in writing to EPA that it has exercised due diligence since
September 21, 1998, to procure the necessary 0.10 kits, but could not
obtain them in time to begin installing 0.10 kits by May 22, 1999.
Certification of the JM CCT kit as complying with the life cycle
cost criteria will not establish new requirements for operators. This
is discussed further in Section V below.
II. Information Concerning Cost and Availability
EPA announced certification of the JM CCT Upgrade Kit in the
Federal Register on December 3, 1998 (63 FR 66798). That certification
is based on compliance with the 0.10 standard, but without
determination of compliance with the optional life cycle cost criteria.
That certification was described as ``conditional'' for some engine
applications, pending a demonstration that any replacement ECM or ECM
program used in conjunction with the certified kit would not adversely
impact the emissions of NOX in comparison to the ECM or ECM
program that is replaced. DDC provided information that allowed EPA to
remove the conditional status of the certification. Therefore, in a
letter to JM dated March 2, 1999, EPA removed the conditional status
and stated that the CCT Kit can be used by bus operators in compliance
with requirements of the Urban Bus Rebuild Program.
In documents signed January 26, 1999, JM provided life cycle cost
information in a revised section 6 of their notification of intent to
certify the CCT Upgrade Kit. JM presents data in support of their claim
that the life cycle cost of the CCT kit is less than $7,940 (in 1992
dollars) incremental to the cost of a standard rebuild. A Federal
Register notice (64 FR 11864) dated March 10, 1999, announced that EPA
had received the cost information and was making it available for
public review and public comment.
III. Summary and Analysis of Comments
Detroit Diesel Corporation (DDC), the original manufacturer of the
bus engines to which the CCT kit applies, was the
[[Page 55969]]
only party to provide comments. The following summarizes DDC's
comments, JM's responses to the comments, and EPA's position on the
issues raised by the comments.
a. DDC notes that JM states that the cost of the reprogramming, if
ECM reprogramming is necessary, would be included in the price of the
kit. However, JM does not explain how DDC distributors and dealers, who
would be doing the reprogramming, would be compensated for the
reprogramming if the reprogramming fee is paid to JM as part of the kit
price. The reprogramming fee is typically collected by the distributor
when the service is performed.
In response, JM states that it intends to reprogram ECMs at its
facilities at Stewart & Stevenson (a DDC distributor as well as JM
distributor). JM's payment for reprogramming will be by JM to Stewart &
Stevenson and will remain imbedded in the price of those kits that
require the ECM program (that is, the certification word code, CWC) to
be changed.
Regarding DDC's point, EPA requested JM to include the price of the
reprogramming in the purchase price of the kit to insure that the price
of the kit includes all components that are not part of a standard
rebuild (it is thereby accounted for in the life cycle cost analysis).
In this way, bus operators will not be faced with the potential for
additional costs above the purchase price of the kit, for an emission-
related component.
b. DDC also states that JM should identify those engines that will
receive ECM reprogramming. Further, DDC believes that the ECM
reprogramming costs should be shown separately from the CCT hardware
costs.
JM states that all 1985 through 1990 model year engines, and any
1991 through 1993 model year engine with a CWC other than 259, 260,
261, 262, 263, or 264, will be required to upgrade its CWC. Also, as
noted previously, EPA requested JM to include the price of the
reprogramming in the purchase price of the kit.
c. DDC notes that JM's test of the CCT kit consisted of a cold-
start test followed by two hot-start tests. To calculate the fuel
consumption (that is, brake specific fuel consumption, BSFC, measured
in units of pounds of fuel per brake-horsepower-hour) of the CCT kit,
JM combined the cold-start test with the second hot-start test, and
completely ignored the first hot-start test, even though it is valid.
DDC states that it sees no justification for ignoring the valid first
hot-start test. DDC states that the first hot-start test should be used
(in conjunction with the cold-start test), unless JM provides some
sound rationale for bypassing it.
In reply, JM states that after a cold-start test, the test
laboratory routinely conducts two hot-start tests in the event that the
first is invalid. JM contends that, because the second hot-start is a
valid test, it can be used to calculate the fuel consumption.
EPA notes that it is not improper to use the second hot-start test
if the first test is not valid. However, in this situation, the first
test has been presented as valid and, was used by JM to demonstrate
compliance with the 0.10 standard in its certification application
dated March 6, 1998. EPA notes that it is consistent with the
regulations governing the transient test procedure to use the first
hot-start test. 40 CFR 86.1327-90 (``Engine dynamometer test
procedures; overview'') establishes the basic sequence for the
transient engine test, and 86.1330-90 shows a diagram of the overall
test sequence. Section 86.1336-84 (``Engine starting, restarting, and
shutdown'') provides direction for re-running the hot-cycle when the
test sequence is impacted by engine stalls and malfunctions in the
required test equipment. In no case are there provisions in the Part 86
test procedures for the arbitrary selection of hot-start cycles. Use of
a valid first hot-start test is consistent with EPA's procedures in
other, new engine, test programs (for example, during selective
enforcement audits). Therefore, EPA is using the first hot-start with
the cold start test to determine the composite fuel consumption of
engines equipped with the CCT kit. For the purposes of the analysis
discussed below, the fuel consumption value of engines equipped with
the CCT kit is 0.489 lb/bhp-hr.
d. DDC notes that JM presents baseline fuel consumption data for
1991 through 1993 model year engines. After comparing this to the fuel
consumption for the CCT kit, JM notes a 0.4 percent difference, but
dismisses the difference as being ``within accepted experimental
error.'' DDC notes that the urban bus regulation (40 CFR 85.1404) does
not include provisions for ``rounding off'' or ignoring differences
that may be the result of testing uncertainty. DDC states that the BSFC
difference reflected by the actual test data is the best estimate of
the fuel consumption impact of the CCT kit, and must be used in
computing the life cycle cost.
In response, JM states that a fuel consumption difference of 0.4
percent is within the ``experimental'' error of the test cells at the
laboratory. JM also states that it is following the customary practice
of EPA in rounding down numbers.
EPA has no customary practice of ``rounding down'' test data.
Additionally, DDC is correct in that the program regulation does not
address rounding of numbers or ignoring differences when assigned to
``experimental'' (that is, test-to-test) error. However, the issue
specifically related to the 0.4 percent is no longer relevant because
the fuel consumption value determined by EPA for the CCT kit, as
discussed previously, is not the value based on the second hot-start
test as JM presents in its analysis. The impact of any difference in
fuel consumption, of course, remains relevant with regard to
determining the life cycle cost of the kit. EPA is not familiar with
any analyses of the test-to-test error of the laboratory at which the
testing was conducted.
EPA believes that it is reasonable to determine (and apply) the
fuel consumption impact to one-tenth of a percentage point. This is
consistent with the practice used during the certification process of
the Engelhard ETX kit. The impact of fuel consumption is discussed
below in the section titled ``EPA Determination of Life Cycle Cost''.
e. JM separately evaluates the fuel consumption impact of its kit
on 1990 model year engines because the NOX standard for the
1990 model year dropped from 10.7 to 6.0 g/bhp-hr. JM states that it is
accepted in industry that reductions in NOX are achieved at
the expense of fuel consumption. For evaluating the impact, JM cites
original DDC new engine certification data to establish a baseline fuel
consumption for 1990 model year engines, and compares this data with
the fuel consumption of the CCT kit to determine the impact of the CCT
on these engines. DDC notes that in 1990, it only produced engines
configured to operate on diesel fuel #1, and to compare this data with
data run with the CCT using diesel fuel #2, as JM has done, results in
a biased and inappropriate comparison because the energy content of
diesel #1 is about 1 percent higher than diesel #2. Therefore, DDC
states that it is appropriate to correct the 1990 baseline fuel
consumption upward by 1 percent to correct for fuel type differences
before making the fuel consumption evaluation.
In response, JM recognizes the accuracy of DDC's statement and
concurs that the 1990 model year engine's baseline fuel consumption
should be increased by 1 percent.
[[Page 55970]]
EPA notes that the comment and response by JM are no longer
specifically relevant. While in general it appears to be reasonable to
determine the impact of fuel consumption based on grouping together
those engines having the same NOX standard (such as the 1988
California engines and 1990 federal engines), EPA does not rely on the
specific test data from the original DDC new engine certification. The
impact of fuel consumption is discussed below in the section titled
``EPA Determination of Life Cycle Cost''.
f. JM also separately evaluates the fuel consumption impact of its
kit on 1988 and 1989 model year California engines because the
NOX standard in California for those years is 6.0 g/bhp-hr,
and JM states that it is a widely accepted fact in the industry that
there is a trade off between NOX and fuel consumption. JM
notes that the fuel consumption of the 1988 and 1989 model year
California engines would have been comparable to the 1990 model year
federal engine because all had the same 6.0 g/bhp-hr NOX
standard. For evaluating the impact, JM did not develop baseline data,
but instead cites data supplied by Engelhard Corporation in its
application for certification of its ETX kit. Engelhard tested a 1988
6V92TA DDEC II California configuration to establish a baseline fuel
consumption for the 1988-1989 California engines of 0.481 lb/bhp-hr. JM
compares this data with the fuel consumption of the CCT kit to
determine the impact of the CCT kit on these engines. DDC notes that
the original DDC certification testing of the 1988 California 6V92 DDEC
engine rated at 277 horsepower yielded fuel consumption of 0.462 lb/
bhp-hr.
In response, JM argues that the fuel consumption of 0.481 lb/bhp-
hr, developed for Engelhard using a 1988 California engine, is more
``real life'' than DDC's value of 0.462 lb/bhp-hr for the same engine,
and therefore appropriate for evaluating the impact of its CCT kit.
While DDC has not provided any background information on its test
of the 1988 California certification engine, EPA expects that it was
conducted in a DDC test cell in 1987. However, EPA believes that it is
reasonable to compare data that is developed at the same laboratory.
Therefore, to determine the fuel consumption impact, EPA is relying on
the 0.481 lb/bhp-hr (developed for Engelhard) because it was conducted
at the same test laboratory (Southwest Research Institute, SwRI) as the
CCT test. The impact of fuel consumption is discussed below in the
section titled ``EPA Determination of Life Cycle Cost''.
g. DDC notes that for the urban bus rebuild certification of their
own 25 percent reduction kit for 6V92 DDEC engines, they provided fuel
consumption values of 0.449 and 0.470 lb/bhp-hr for 1988 and 1991 model
year engines, respectively. While both of these values are lower than
the corresponding values developed by JM, the fuel consumption penalty
(from the 1988 to 1991 model year) is about 5 percent in both cases
(actually 4.7 percent based on EPA calculation). DDC states that the
fuel consumption penalty that JM develops for the impact of the CCT kit
on 1988 and 1989 model year federal engines appears appropriate, but
when additional differences between the CCT kit and the 1991 baseline
are accounted for, DDC believes that the actual fuel consumption
penalty is approximately 6.5 percent.
JM responded that it stands by its analysis that shows there is no
fuel consumption penalty associated with upgrading a 1991 model year
DDEC engine to a CCT Upgrade Kit configuration, and would agree to use
DDC's 5 percent penalty for upgrading 1988 and 1989 model year engines
to the CCT kit configuration.
EPA notes that the specific fuel consumption penalty of 4.7 percent
(to which DDC and JM refer as 5 percent), is based on comparing data
from 1988 and 1991 model year engines that DDC developed for its
original new engine certification. However, the data do not represent
engine configurations of the same horsepowers, and neither test
represents actual use of the CCT kit. To calculate the fuel consumption
penalty for the CCT kit, EPA believes that it is reasonable to compare
data from the testing conducted for JM on the CCT kit and the engine
rebuilt to a 1991 model year configuration. Both tests were conducted
for JM using engines of the same horsepower (277 Hp) in the same test
cell of the same laboratory. As discussed later in the section titled
``EPA Determination of Life Cycle Cost,'' our analysis shows that a 6.5
percent fuel consumption penalty is appropriate.
IV. EPA Determination of Life Cycle Cost
Section 85.1403(b)(1)(ii) describes the elements that must be
considered when analyzing life cycle cost of equipment, including
equipment purchase price, incremental fuel cost, installation costs,
maintenance costs, and costs of any fuel additives required. To trigger
the 0.10 g/bhp-hr standard, the life cycle cost of equipment can be no
more than the limit of $7,940 (in 1992 dollars), incremental to the
cost of a standard rebuild.
In this section, EPA analyzes the life cycle costs using a
methodology similar to that described in both the Federal Register
notice of March 14, 1997 (62 FR 12166), which describes the
certification of Engelhard's ETX kit applicable to DDC's 6V92TA engines
with mechanical unit injectors (MUI), and the Federal Register notice
of September 21, 1998 (63 FR 50225), which describes the certification
of Engelhard's ETX kit applicable to DDC's 6V92TA engines with
electronic unit injectors (DDEC).
The analysis first determines the cost of a ``weighted'' rebuild
because the kit is used in conjunction with a standard rebuild and
contains parts that are typically replaced during a standard rebuild.
The weighted rebuild considers that all operators do not rebuild
engines the same way, and therefor reflects, on a weighted basis, that
some operators rebuild using non-original equipment parts and some
operators rebuild certain components in-house. For the weighted
rebuild, cost information is ``corrected'' to a 1992 time-frame, which
is the time period for which the life cycle cost limit of $7,940 of the
regulation is based. EPA then uses the cost of a weighted rebuild for
determining an offset for the parts supplied in the CCT kit (that is,
JM's first supply option) that are typically replaced during a standard
rebuild. The offset is then added to any additional installation costs
and fuel penalty, to determine a maximum purchase price such that the
life cycle cost of the equipment meets the life cycle cost limit. In
other words, in order to comply with the life cycle cost criteria, the
maximum purchase price, when added to the fuel consumption penalty and
additional installation cost, and offset for parts in the CCT kit, can
be no more than $7,940 (in 1992 dollars), incremental to the cost of a
standard rebuild. In the final step, the maximum purchase price in 1992
dollars is converted to current value using the appropriate consumer
price indices.
A. Cost of a Weighted Rebuild
The life cycle cost analysis is based on JM's first supply option,
as described in the December 3, 1998 Federal Register notice, because
only one supply option needs to comply with the life cycle cost
criteria and, the first supply option provides virtually all emissions-
related components typically replaced during a standard rebuild. In the
first supply option, JM is to provide the following parts: CEM II
catalytic muffler, patented engine camshafts, CCT cylinder kits, 0.015
offset key, fuel
[[Page 55971]]
injectors, 40T blower gear, turbo charger, blower assembly, blower
bypass valve, and if necessary, the ECM program. The cylinder heads and
gasket kit are not included with the CCT kit because these parts,
although typically replaced during a standard rebuild, are the same
regardless of model year.
JM notes that the CCT kit is sold to complement a standard engine
rebuild. The balance of the specified parts for the standard rebuild
(excluding standard cams) can be acquired from traditional DDC parts
sources. A cost offset is provided in the analysis for the parts in the
CCT kit that are normally replaced during a standard engine rebuild.
The costs for the parts normally replaced during a standard engine
rebuild has been previously determined for certification of the
Engelhard's ETX kit (63 FR 50225; September 21, 1998).
As explained in the September 21, 1998 Federal Register, for the
determination of the cost of a weighted rebuild, EPA assumes that some
parts used in the rebuild of some engines are original equipment (OE)
parts, others are non-OE parts, and that some transits re-manufacture
certain components in-house. Table 1 below summarizes the cost of a
weighted rebuild as presented in the September Federal Register, and
indicates the parts costs that are offset because they are provided in
the CCT kit for the first supply option.
Table 1.--Parts Normally Replaced During Standard Rebuild
[1992 dollars]
------------------------------------------------------------------------
Weighted Parts offset
Items rebuild\1\ by CCT kit
------------------------------------------------------------------------
1--Cylinder Kit......................... 1,540 1,540
2--Gasket Kit........................... 147 ..............
3--Fuel Injectors....................... 1,450 1,450
4--LB Camshaft.......................... 606 606
5--RB Camshaft.......................... 519 519
6--Blower Ass'y......................... 302 302
7--Turbo Ass'y.......................... 424 424
8--Heads Ass'y.......................... 1,079 ..............
9--ECM Program.......................... (\2\) (\2\)
-------------------------------
Totals.............................. 6,067 4,841
------------------------------------------------------------------------
\1\ As determined on September 21, 1998 (63 FR 50225) in conjunction
with certification of the Engelhard ETX kit for DDEC engines.
\2\ Not required.
EPA received no comments regarding the costs related to the
standard or weighted rebuild. Therefore, EPA continues to use the costs
from the Federal Register notice developed for the Engelhard
certifications indicated above. There may be uncertainties and
assumptions involved with this ``weighted'' approach, but EPA believes
that, based on the available information, the cost of a standard
rebuild of a DDC 6V92TA DDEC engine is best approximated by the
weighted rebuild costs shown above in Table 1, for the purposes of
determining the maximum purchase price for the CCT Upgrade Kit.
B. Incremental Fuel Cost
Life cycle costs can be impacted by the fuel consumption associated
with the use of retrofit equipment using diesel fuel. A review of test
data is used to determine any fuel consumption penalty. As noted above,
EPA gives preference to data developed for JM, based on engines of 277
horsepower, and tested at the same laboratory. Table 2 below lists the
test data that is used to make the determination of incremental fuel
cost for the CCT kit.
Table 2.--Baseline and CCT Fuel Consumption Data
----------------------------------------------------------------------------------------------------------------
BSFC
Engine description (Hp) NOX level/ Test laboratory Tested for Test date BSFC1 penalty
NOX Std (percent)
----------------------------------------------------------------------------------------------------------------
CCT Kit (277)................. 5.0/5.0 SwRI, cell 16.... JM............. 01/07/98...... 0.489
1991 50-state (277)........... 4.9/5.0 SwRI, cell 16.... JM............. 02/13/98...... 0.483 1.2
1988 Calif (277).............. 5.5/6.0 SwRI, cell 7..... Engelhard...... 02/19/97...... 0.481 1.7
1988 fed (277)................ 8.4/10.7 SwRI, cell 16.... JM............. 03/05/97...... 0.459 6.5
----------------------------------------------------------------------------------------------------------------
1 Brake-specific fuel consumption measured in units of pounds of fuel per brake horsepower-hour (lb/bhp-hr).
EPA determines the fuel consumption impact of the CCT kit on three
test engines, each complying with a distinct NOX exhaust
emission standard. The NOX standard for all 1991 through
1993 model year engines is 5.0 g/bhp-hr. The standard for 1988 through
1990 California engines and 1990 federal engines is 6.0 g/bhp-hr. The
standard for 1988 and 1989 federal engines is 10.7 g/bhp-hr. Data
provided by JM with its application for certification dated March 6,
1998, indicate that CCT-equipped engines comply with the 5.0 g/bhp-hr
NOX standard and therefore the CCT kit can be used on
engines originally certified to comply with any of the noted standards.
EPA recognizes that the available fuel consumption data is limited, but
believes it adequate for the purpose of determining the life cycle cost
analysis.
As discussed above, EPA is using the first hot-start in conjunction
with the cold-start test, to determine the fuel consumption of the
engine equipped with the CCT kit. Therefore, the purposes of this
analysis, the fuel consumption of CCT-equipped engines is taken as
0.489 lb/bhp-hr.
The test of the engine configured to a 1991 model year
configuration indicates a baseline fuel consumption of 0.483 lb/
[[Page 55972]]
bhp-hr. Therefore, EPA calculates that the CCT kit, on 1991 through
1993 model year engines, increases fuel consumption by 1.2 percent.
EPA believes that it is reasonable to determine the impact of fuel
consumption on all engines meeting the same 6.0 g/hp-hr NOX
standard, which includes the 1988 through 1990 California engines and
the 1990 federal engines. JM did not conduct a baseline test on an
engine that was designed to 6.0 g/bhp-hr NOX standard.
However, data available from testing a 1988 model year California
engine at Southwest Research Institute for Engelhard, indicates a
baseline value of 0.481 lb/bhp-hr for engines designed to the 6.0 g/
bhp-hr standard. Therefore, EPA calculates that the CCT kit, on 1988
through 1990 California engines and 1990 federal engines, increases
fuel consumption by 1.7 percent.
The test conducted for JM on the 1988 model year federal engine
indicate a baseline fuel consumption of 0.459 lb/bhp-hr. Comparing this
value with the CCT fuel consumption of 0.489 lb/bhp-hr, indicates a
fuel consumption penalty of 6.5 percent when upgrading a 1988 model
year engine to the CCT kit.
The impacts on fuel consumption are summarized below in Table 3
along with the increased life cycle fuel costs calculated pursuant to
the formula prescribed at 40 CFR 85.1403(b)(1). The impact of the fuel
consumption penalty on life cycle costs is included in the summary
below.
Table 3.--Fuel Consumption Impact of CCT Upgrade Kit
[1992 dollars]
----------------------------------------------------------------------------------------------------------------
Fuel Fuel penalty
NOX Standard consumption per 40 CFR
Applicable engine model year (g/bhp-hr) impact 85.1403(b)(1)
(percent) (in 1992 $)
----------------------------------------------------------------------------------------------------------------
1991-1993 50-state.............................................. 5.0 1.2 338
1988-1990 Calif & 1990 50-state................................. 6.0 1.7 479
1988-1989 fed................................................... 10.7 6.5 1,831
----------------------------------------------------------------------------------------------------------------
C. Installation Costs
As defined at 40 CFR 85.1403 (b)(1)(ii)(B), the installation cost
of certified equipment is ``the labor cost of installing the equipment
on an urban bus engine, incremental to a standard rebuild, based on a
labor rate of $35 per hour'' (in 1992 dollars). JM states that the
labor required to rebuild an engine will be the same for a standard
rebuild and the CCT kit, with the exception of the additional labor
required for installation of the CEM II catalytic muffler. The CEM II
installation is essentially identical to the replacement of an OE
muffler, and will not exceed 2 hours labor. Using the labor rate of
$35.00 per hour, as specified at 40 CFR 85.1403, the two hours is
valued at $70 (in 1992 dollars) and is incremental to the cost of a
standard rebuild.
D. Maintenance Costs
JM states that the CCT kit requires no maintenance for the CEM II
and no additional maintenance above and beyond normal DDC maintenance
requirements for a standard rebuild. EPA has no information to conclude
that any additional maintenance is necessary for the CEM II catalyst
muffler, or would increase life cycle costs. Therefore, no additional
maintenance costs are listed for the CCT kit.
E. Costs of Fuel Additives
No fuel additives are required for the CCT kit.
F. Total Life Cycle Cost
As noted previously, the regulation at 40 CFR 85.1403 requires that
the life cycle cost be no more than $7,940 (in 1992 dollars)
incremental to the cost of a standard rebuild, for equipment that
triggers the 0.10 g/bhp-hr standard. Table 4 below itemizes the life
cycle cost elements determined above for the CCT kit for each of the
following groups of applicable engines: 1991 through 1993 model year
50-state engines, 1988-1990 model year California and 1990 model year
federal engines, and 1988-1989 model year federal (49-state) engines.
The maximum purchase price shown in Table 4 is determined by adjusting
the life cycle cost ceiling for the parts offset, installation cost,
and fuel penalty.
Table 4.--Summary of Life Cycle Costs for the CCT Kit
[1992 dollars]
------------------------------------------------------------------------
Applicable engine model year
--------------------------------------
1988-1990
1991-1993 Calif & 1988-1989
50-state 1990 fed fed
------------------------------------------------------------------------
Maximum Purchase Price........... 12,373 12,232 10,880
Offset for CCT parts normally (4,841) (4,841) (4, 841)
replaced during a std rebuild...
Installation Cost................ 70 70 70
Fuel Penalty..................... 338 479 1,831
Total Life Cycle Cost............ 7,940 7,940 7,940
------------------------------------------------------------------------
Table 4 displays the maximum purchase prices for the CCT kits, in
1992 dollars. The total life cycle cost is the sum of the listed items.
An ``offset'' (that is, a credit) is provided to the life cycle cost of
the CCT kit because certain components provided in the kit offset costs
for parts which otherwise are replaced during a standard engine
rebuild. The values for the individual rebuild parts that are offset by
the CCT kit parts, are listed previously in conjunction with the
determination of a weighted rebuild and itemized in Table 1. To
determine the incremental life cycle cost, these ``offset'' costs are
subtracted, as shown in Table 4. As shown in the table, the total
incremental
[[Page 55973]]
life cycle cost is no more than the ceiling specified in the program
regulations, $7,940 in 1992 dollars. Current values of the maximum
purchase prices are discussed below.
G. Current Maximum Purchase Price for the CCT Upgrade Kit
Table 6 below shows the maximum purchase price (in 1992 dollars) as
determined above. The current (August 1999) maximum purchase prices are
also shown in Table 6, and are calculated using a multiplicative ratio
of Consumer Price Indices (CPI). Table 5 below lists the relevant CPIs.
The average CPI for 1992 is 140.3, as specified by the program
regulation. The August 1999 CPI, for all items and all urban consumers,
is 167.1. These CPI values are provided by the U.S. Department of
Labor, Bureau of Labor Statistics.
Table 5.--Consumer Price Indices
------------------------------------------------------------------------
Average CPI for CPI
----------------------------------------------------------------
1992.................................................. 140.3
August 1999........................................... 167.1
------------------------------------------------------------------------
Table 6.--Current Maximum CCT Kit Purchase Price
------------------------------------------------------------------------
August 1999
Applicable engine model year 1992 maximum maximum
purchase price purchase price
------------------------------------------------------------------------
1991-1993 50-state...................... $12,373 $14,736
1988-1990 Calif & 1990 fed.............. 12,232 14,569
1988-1989 fed........................... 10,880 12,958
------------------------------------------------------------------------
JM, in a letter to EPA dated October 22, 1999, guarantees to make
CCT Upgrade kits available to all affected urban bus operators for no
more than the maximum August 1999 purchase prices shown in Table 6.
V. Impact on Transit Operator
Today's Federal Register notice announces that the JM CCT Upgrade
Kit is certified to comply with the optional life cycle cost criteria
of the Urban Bus Rebuild Program. EPA has reviewed the available
information and comments received to determine that there is adequate
demonstration of compliance with the life cycle cost criteria of 40 CFR
85.1403(b) and 85.1407(a).
Affected urban bus operators who choose to comply with compliance
program 1 are currently required to use equipment certified to meet the
0.10 g/bhp-hr PM standard. As discussed above, this current requirement
has been previously triggered by certification of equipment supplied by
the Engelhard Corporation.
The Johnson Matthey CCT kit has already been certified to comply
with the 0.10 g/bhp-hr standard and can be used by all operators
towards compliance with the current urban bus program requirements.
Operators that choose to comply with compliance program 2 and use this
equipment would claim the PM certification level for the CCT kit (0.10
g/bhp-hr) when calculating their Fleet Level Attained (FLA).
If the current trigger of the 0.10 g/bhp-hr standard becomes
ineffective, then certification of JM's CCT Upgrade Kit on the basis of
life cycle cost would trigger program requirements for bus operators
that have chosen to comply with program 1, to use equipment certified
to the 0.10 g/bhp-hr standard when applicable engines are rebuilt or
replaced. The requirement would be effective for any applicable engine
rebuilt or replaced six months after September 15, 2000.
Dated: September 8, 2000.
Robert Perciasepe,
Assistant Administrator for Air and Radiation.
[FR Doc. 00-23776 Filed 9-14-00; 8:45 am]
BILLING CODE 6560-50-U