Aftermarket Wary of EPA's Tier III Emissions Proposal

Jan. 1, 2020
  The Environmental Protection Agency's Tier III tailpipe proposal will have a big effect on the aftermarket if the agency finalizes its new emissions reduction initiative.   

The Environmental Protection Agency's (EPA's) Tier III tailpipe proposal issued at the tail end of March will have a big effect on the aftermarket if the agency finalizes its new emissions reduction initiative.

The agency wants to reduce tailpipe emissions of pollutants such as nitrogen oxides (NOx), volatile organic compounds (VOC), and particulate matter (PM2.5) so that the EPA requirements dovetail closely with California's low emission vehicle (LEV) III program. That way auto manufacturers don't have to make "California" cars, which they sell in California and the other 10 states with LEV III compliance, and "EPA" cars sold elsewhere.

In December 2012 EPA approved the California Air Resources Board’s (CARB’s) LEV III program to start in 2015. The EPA Tier III would be phased in over five years starting in 2017. Those tailpipe standards would be implemented over the same timeframe as the greenhouse gas/fuel efficiency standards for light-duty vehicles, as part of a comprehensive approach toward regulating emissions from motor vehicles. GHG emissions include carbon dioxide and methane.

How does this Tier III/LEV III alignment affect the aftermarket? The EPA states in its proposed rule: "Consistency among the federal and California programs means that special versions of vehicles with different emission control hardware and calibrations would not be necessary for different geographic areas. Consistency among programs would also eliminate the need to supply aftermarket parts for repair of multiple versions of a vehicle.

Asked whether that sentence refers to parts beyond catalytic converters which would no longer need to be sold in the aftermarket, an EPA spokeswoman answered: "The answer is yes, it does refer to a wider variety of aftermarket parts including catalytic converters, engine controllers and/or engine calibrations, engine manifold and exhaust parts, and secondary air parts."

Officials at the Manufacturers of Emission Controls Association and Automotive Aftermarket Industry Association did not respond to email and phone requests for comments.

The EPA's main means for synchronizing its Tier 3 emission standards with California's LEV III standards to force refiners to reduce the amount of sulfur they use in gasoline from the current 30 parts per million (ppm) average down to a 10-ppm average. Europe and Japan already have imposed gasoline sulfur caps of 10 ppm, and the State of California is already averaging 10 ppm sulfur with a per gallon cap of 20 ppm.

But the EPA doesn't think the availability of low-sulfur gasoline alone will in and of itself get autos in 2017 to the proposed, lower VOC, NOx and PM levels. The effectiveness of current vehicle emissions control systems depends in large part on the time it takes for the catalyst to light off, which is typically defined as the catalyst reaching a temperature of 250°C.

So manufacturers will have to come up with new technologies to improve catalyst "light-off." The EPA expects manufacturers would add technologies that provide heat from combustion more readily to the catalyst or improve the catalyst efficiency at lower temperatures. These technologies include calibration changes, thermal management, close-coupled catalysts, catalyst platinum group metals (PGM) loading and strategy, and secondary air injection, all of which generally improve emission performance of all pollutants. In some cases where the catalyst light-off and efficiency are not enough to address the cold start emissions, hydrocarbon absorbers may be applied to trap hydrocarbons until such time that the catalyst is lit off.

In addition to changes in engine emissions technology, automakers also will have to upgrade evaporative emissions systems. The EPA proposal includes more stringent emission standards for hot soak plus diurnal emissions (two- and three-day tests), plus a new canister bleed standard and testing requirement for measuring emissions from the fuel tank and the evaporative canister.

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About the Author

Stephen Barlas

Stephen Barlas has been a full-time freelance Washington editor since 1981, reporting for trade, professional magazines and newspapers on regulatory agency, congressional and White House actions and issues. He also does a column for Automotive Engineering, the monthly publication from the Society of Automotive Engineers. He covers the full range of auto industry issues unfolding in Washington, from regulatory rulings on and tax incentives for ethanol fuel to DOE research and development aid for electric plug-ins and lithium ion battery commercialization to congressional changes in CAFE standards to NHTSA safety rulings on such things as roof crush standards and data recorders.

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