RE: Docket ID No. EPA-HQ-OAR

Transcription

1 October 5, 2017 Submitted via Docket ID No. EPA-HQ-OAR Christopher Lieske Office of Transportation and Air Quality (OTAQ), Environmental Protection Agency 2000 Traverwood Drive Ann Arbor MI, RE: Docket ID No. EPA-HQ-OAR Request for Comment on Reconsideration of the Final Determination of the Mid-Term Evaluation of Greenhouse Gas Emissions Standards for Model Year Light-Duty Vehicles; Request for Comment on Model Year 2021 Greenhouse Gas Emissions Standards Dear Mr. Lieske The Aluminum Association (the Association ) thanks the Environmental Protection Agency (EPA) for the opportunity to provide comment on the recent Request for Comment on Reconsideration of the Final Determination of the Mid-Term Evaluation of Greenhouse Gas Emissions Standards for Model Year Light-Duty Vehicles; Request for Comment on Model Year 2021 Greenhouse Gas Emissions Standards as noticed at 82 FR on August 21, The Aluminum Association, based in Arlington, VA, represents US and foreign-based primary producers of aluminum, aluminum recyclers, and producers of fabricated aluminum products, as well as industry suppliers. The US aluminum industry directly employs 161,000 workers and indirectly employs an additional 551,000 workers. Its economic output directly generates $75 billion and indirectly generates an additional $111 billion in economic output. In total, the U.S. aluminum industry supports nearly 713,000 jobs and $186 billion in economic output, more than 1 percent of the US Gross Domestic Product. Within the Association, the Automotive Transportation Group (ATG) focuses on aluminum use in transportation applications and has a long history of technical interaction with automakers in 1

2 providing safe and cost-effective lightweighting solutions to automakers to help them comply with the EPA GHG emission reduction and NHTSA fuel efficiency standards. The ATG also has consistently engaged with EPA, the National Highway Transportation Safety Administration (NHTSA) and the California Air Resources Board (CARB) in the evaluation of vehicle mass reduction solutions as an integral component of these agencies ongoing regulatory efforts to reduce Greenhouse Gas (GHG) emissions and improve related fuel efficiency performance. As such, EPA s request for comment on reconsideration of the final determination of the Mid-Term Evaluation of Greenhouse Gas Emissions Standards for Model Year Light-Duty Vehicles and request for comment on the Model Year 2021 standards are both of significant interest to the ATG specifically, and to the Association more broadly. The Association notes that a key component of the notice is the request to provide information on additional studies and/or newly available information that were not available to EPA during the 2016 Mid Term Evaluation comment period. There are two additional studies meeting this criteria that the Association is providing for the docket to support the final determination and both are included as attachments to these comments. These are Full Size Pickup Lightweighting Study finalized by EDAG in February 2017 This study found that the use of advanced ATG grades of aluminum leads to an additional 72 lbs (10.6%) mass reduction compared with the NHTSA EDAG LWT proposed design for the cab, fenders, cargo box, doors, hood, and liftgate of a full size pickup. This is equivalent to a total mass saving of 46% when compared with the equivalent structures of the baseline vehicle MY 2014 Chevrolet Silverado Aluminum Content in North American Light Vehicles finalized by Ducker Worldwide in July 2017 This study found that the use of aluminum as a vehicle lightweighting solution is predicted to increase in from an average 397 lbs per vehicle in the 2015 model year to 466 lbs per vehicle in the 2020 model year. Further, the study found that 50% of this growth will be driven by aluminum used in closures, crash management systems, steering knuckles, and structural vacuum die cast parts. 2

3 Aluminum content by vehicle segment in 2020 will range from 362 lbs per vehicle in the passenger car segment to 523 lbs per vehicle in the light truck segment. Looking out to the 2028 model year, aluminum use is predicted to contribute more than 50% of the total vehicle mass reduction across all scenarios modeled and up to 16% of total vehicle weight. The study reflects that aluminum remains the fastest growing automotive material and is entering its most unprecedented growth phase since Ducker has been tracking the shifting mix of automotive materials. There are also three additional studies that are in process but not yet finalized that the Association would like to call to EPA s attention. These are scheduled to be finalized by the end of 2017 in sufficient time to inform EPA s decision-making on the final mid-term evaluation determination. These are Automotive Aluminum Recycling a Grave to Gate Analysis (Update) by Worcester Polytechnic Institute s Center for Resource Recovery and Recycling This study is an update to further define the percentage of automotive aluminum which is recycled at the end of vehicle life. The original study found that 91.3% of automotive aluminum was recycled at the end of vehicle life and this revised study is more thoroughly assessing the aluminum recycling value chain to provide a more accurate value. Automotive Life Cycle Assessment (LCA) Study by the Aluminum Association ATG The Aluminum Association periodically conducts LCA studies of industry-wide activities. In order to specifically delineate the attributes of aluminum used in transportation applications, this study is focusing on the life cycle of aluminum in the North American passenger vehicle and light truck market segments. LCA Study of Lightweight Vehicle Doors by Magna International This is a follow-up to the 2015 study conducted by Magna International and Ford Motor Company to assess lightweight vehicle concepts using a 2013 Ford Fusion as the base vehicle. Comparative life cycle assessment is being made of vehicle door options to help inform material selection for future vehicle designs. 3

4 Once these studies are finalized, the Aluminum Association will forward them on to EPA for consideration in the final determination process. Through studies such as those noted above coupled with significant automaker engagement, the aluminum industry continues to provide and improve lightweighting solutions to help meet rigorous Greenhouse Gas (GHG) and fuel efficiency regulations. However, the benefits of lightweighting with aluminum go far beyond the regulatory requirements in these areas. Customer satisfaction due to the attributes of aluminum lightweighted vehicles in the areas of safety performance, braking, handling, corrosion resistance, and noise, vibration, and harshness (NVH) continues to improve and the benefit of these attributes continues to drive demand for these vehicles independent of the fact that they are lightweighted. In terms of the mid-term review to inform the revised final determination, the aluminum industry requests the following - Predictability and consistency in regulatory conditions A strength of the 2012 regulation was the inclusion of proposed standards through This approach has benefited automakers and suppliers as many automotive technologies take more than 5 years to engineer, develop, validate and establish production capacity. Clarity in the standards has been instrumental in supporting the unprecedented improvements in efficient technologies seen over the past five years and in order for that improvement to continue there must be predictability and certainty in the future MY standards. Consideration of the impacts of changes to the existing MY 2021 standards MY 2021 standard changes at this point, adjusted either up or down, would significantly increase uncertainty in the aluminum industry. The Association asks that the full potential impact of any change be well understood before any action is taken. Reducing stringency could result in adverse economic impact, including loss of jobs, given the substantial investments made by automakers and aluminum suppliers based on the finalized MY 2021 standards. One National Program to include EPA, NHTSA, and California/states 4

5 The alignment of fuel efficiency standards between EPA, NHTSA, and CARB is important to establish the regulatory certainty needed for continued improvement in vehicle technologies. The EPA must continue to work closely with NHTSA and CARB with a focus on inter-agency collaboration to provide the automobile industry and its suppliers with the optimal alignment, consistency, and certainty contemplated by the One National Program concept. Direction on model years Clarity in the standards has been instrumental in supporting the unprecedented improvements in efficient technologies seen over the past five years. As such, the aluminum industry recommends that the agencies consider including a greenhouse gas and fuel economy standard forecast out to 2030 as part of the final determination on the MY regulation. The Aluminum Association appreciates the opportunity to provide these comments to EPA as it pursues completion of its final determination in the mid-term review process. If you have any questions concerning them or would like to discuss them in greater detail, please do not hesitate to contact me or the Association s Director of Regulatory Affairs, Curt Wells, at or at cwells@aluminum.org. Sincerely, Heidi Brock President and CEO The Aluminum Association CC: NHTSA Docket Attachments: Full Size Pickup Lightweighting Study - EDAG Aluminum Content in North American Light Vehicles Ducker 5