Submission requirements for evidence of conformity for light-duty vehicles: appendix C
Appendix C - Examples of Comparison Tables for Deemed Covered Vehicles
The following tables are examples of what could be submitted to demonstrate that a vehicle that is not specifically listed on an EPA certificate could be deemed covered by an EPA certificate. The first table is the simplest situation where the same vehicle is marketed under a different name in Canada. The second table shows what could be submitted when there is only a difference of body style, options, etc. Finally, the third table is an example of a more significant difference such as engine size, emission standard, etc.
Example 1 - Marketed with a different name
| EPA Certified Test Group-Evaporative/Refueling Family | Canadian Vehicle | |
|---|---|---|
|
Make and Model Name
|
Make, USCAR
|
Make, CanadaCAR
|
| Body Style (list body style + any standard/optional equipment differences between the two vehicles offered that could have an effect on emissions) | 4 Door Sedan | Same |
| Test Group Criteria (1 through 5, or "Other") | 9XXXXX00.0XXX | |
| 1. Durability Group | ||
| Combustion Cycle (e.g., 2-stroke, 4-stroke, Otto Cycle, Diesel Cycle) | Otto cycle | Same |
| Engine Type (e.g., piston, rotary, air-cooled, water-cooled) | Piston | Same |
| Fuel Used (e.g., gasoline, diesel, methanol, ethanol, CNG, LPG, flex-fuel) | Gasoline | Same |
| Basic Metering System (e.g., throttle body injection, port injection, CNG fuel mixer) | Port Injection | Same |
| Catalyst Construction (e.g., beads, monolith) | Monolith | Same |
| Precious metal composition of the catalyst by type of principal active material (e.g., platinum based ox-cat, palladium based ox-cat, platinum and rhodium 3-way cat, palladium and rhodium 3-way cat, platinum and palladium and rhodium 3-way cat) | Pt/Rh TWC | Same |
| Catalyst Grouping Statistic (GS) or other criteria (40 CFR 86.182001(b)(7)(i) or (ii)) | GS | Same |
| Other Durability Grouping strategy (based on 40 CFR 86.1820-01(c), (d), or (e) | N/A | N/A |
| 2. Engine Displacement (within 15 percent or 50 in3, whichever is larger) | 225 cubic inches | Same |
| 3. Number of cylinders or combustion chambers | 6 | Same |
| 4. Arrangement of cylinders or combustion chambers (e.g., in-line V, horizontally opposed) | V | Same |
| 5. Emission standards (same or more stringent) | Tier 2, Bin 5 | Same |
| Other: Grouping criteria based on 40 CFR 86.1827-01(b), (c), (d), or (e) | N/A | N/A |
| Evaporative/Refueling Family Criteria (for gasoline-or methanol-fueled vehicles) | 9XXXR0170YYY | |
| 1. Type of vapor storage device (e.g., canister, air cleaner, crankcase) | Canister | Same |
| 2. Basic Canister Design | ||
| Working capacity (within a 10 gram range) | 170 | Same |
| System configuration (Number of canisters, method of connection (e.g., series or parallel)) | 1 canister | Same |
| Canister geometry, construction and materials | Cylinder, 5-chamber, plastic | Same |
| 3. Fuel system | DFI (Direct Fuel Injection) | Same |
| 4. Type of refueling emission control system (e.g., integrated or non-integrated with evaporative control system | Integrated | Same |
| 5. Fillpipe sealing mechanism (e.g., mechanical, liquid, other) | Liquid | Same |
| 6. Vapor control system or method of controlling vapor flow through the vapor line to the canister (e.g., type of valve, vapor control strategy) | Vacuum, purge control valve | Same |
| 7. Purge control system (e.g., type of valve, purge control strategy) | Duty cycle controlled by ECM | Same |
| 8. Vapor hose material | 4-layer elastomer | Same |
| 9. Fuel tank material | Plastic | Same |
| Other: Grouping criteria based on 40 CFR 86.1821-01(c), (d), or (e) | N/A | N/A |
Statement
The Canadian vehicle described above has no features that could cause it to have a higher level of emissions than the vehicles tested for the issuance of the EPA certificate.
Comments / Additional Information
By taking into consideration features such as the heaviest test weight, the highest roadload horsepower and the highest N/V ratio available, this vehicle does not represent the "worst case" in this test group. Similarly, this vehicle is not the "worst case" evap vehicle in the evap/ORVR family because it has not the lowest cumulative purge to tank volume ratio.
Example 2 - Different Body Style
| EPA Certified Test Group-Evaporative/Refueling Family | Vehicle XYZ (Canadian Concept) | |
|---|---|---|
|
Make and Model Name
|
Make, Model
|
Same
|
| Body Style (list body style + any standard/optional equipment differences between the two vehicles offered that may affect emissions) | 4 Door Sedan | 2 Door Sedan |
| Test Group Criteria (1 through 5, or "Other") | 9XXXXX00.0XXX | |
| 1. Durability Group | ||
| Combustion Cycle (e.g., 2-stroke, 4-stroke, Otto Cycle, Diesel Cycle) | Otto cycle | Same |
| Engine Type (e.g., piston, rotary, air-cooled, water-cooled) | Piston | Same |
| Fuel Used (e.g., gasoline, diesel, methanol, ethanol, CNG, LPG, flex-fuel) | Gasoline | Same |
| Basic Metering System (e.g., throttle body injection, port injection, CNG fuel mixer) | Port Injection | Same |
| Catalyst Construction (e.g., beads, monolith) | Monolith | Same |
| Precious metal composition of the catalyst by type of principal active material (e.g., platinum based ox-cat, palladium based ox-cat, platinum and rhodium 3-way cat, palladium and rhodium 3-way cat, platinum and palladium and rhodium 3-way cat) | Pt/Rh TWC | Same |
| Catalyst Grouping Statistic (GS) or other criteria (40 CFR 86.182001(b)(7)(i) or (ii)) | GS | Same |
| Other Durability Grouping strategy (based on 40 CFR 86.1820-01(c), (d), or (e) | N/A | N/A |
| 2. Engine Displacement (within 15 percent or 50 in³, whichever is larger) | 225 cubic inches | Same |
| 3. Number of cylinders or combustion chambers | 6 | Same |
| 4. Arrangement of cylinders or combustion chambers (e.g., in-line V, horizontally opposed) | V | Same |
| 5. Emission standards (same or more stringent) | Tier 2, Bin 5 | Same |
| Other: Grouping criteria based on 40 CFR 86.1827-01(b), (c), (d), or (e) | N/A | N/A |
| Evaporative/Refueling Family Criteria (for gasoline- or methanol-fueled vehicles) | 9XXXR0170YYY | |
| 1. Type of vapor storage device (e.g., canister, air cleaner, crankcase) | Canister | Same |
| 2. Basic Canister Design | ||
| Working capacity (within a 10 gram range) | 170 | Same |
| System configuration (Number of canisters, method of connection (e.g., series or parallel)) | 1 canister | Same |
| Canister geometry, construction and materials | Cylinder, 5-chamber, plastic | Same |
| 3. Fuel system | DFI (Direct Fuel Injection) | Same |
| 4. Type of refueling emission control system (e.g., integrated or non-integrated with evaporative control system | Integrated | Same |
| 5. Fillpipe sealing mechanism (e.g., mechanical, liquid, other) | Liquid | Same |
| 6. Vapor control system or method of controlling vapor flow through the vapor line to the canister (e.g., type of valve, vapor control strategy) | Vacuum, purge control valve | Same |
| 7. Purge control system (e.g., type of valve, purge control strategy) | Duty cycle controlled by ECM | Same |
| 8. Vapor hose material | 4-layer elastomer | Same |
| 9. Fuel tank material | Plastic | Same |
| Other: Grouping criteria based on 40 CFR 86.1821-01(c), (d), or (e) | N/A | N/A |
Statement
The Canadian vehicle described above has no features that could cause it to have a higher level of emissions than the vehicles or engines tested for the issuance of the EPA certificate.
Comments / Additional Information
By taking into consideration features such as the heaviest test weight, the highest roadload horsepower and the highest N/V ratio available, this vehicle does not represent the "worst case" in this test group. Similarly, this vehicle is not the "worst case" evap vehicle in the evap/ORVR family because it has not the lowest cumulative purge to tank volume ratio. The 2 door sedan weight (1500 kg) is less than the 4 door (1550 kg) offered in the U.S. The reduced weight would reduce the load on the engine.
Example 3 - Technical Differences
| EPA Certified Test Group-Evaporative/Refueling Family | Vehicle XYZ (Canadian Concept) | |
|---|---|---|
|
Make and Model Name
|
Make, Model
|
Same
|
| Body Style (list body style + any standard/optional equipment differences between the two vehicles offered that may affect emissions) | 4 Door Sedan | Same |
| Test Group Criteria (1 through 5, or "Other") | 9XXXXX00.0XXX | |
| 1. Durability Group | ||
| Combustion Cycle (e.g., 2-stroke, 4-stroke, Otto Cycle, Diesel Cycle) | Otto cycle | Same |
| Engine Type (e.g., piston, rotary, air-cooled, water-cooled) | Piston | Same |
| Fuel Used (e.g., gasoline, diesel, methanol, ethanol, CNG, LPG, flex-fuel) | Gasoline | Same |
| Basic Metering System (e.g., throttle body injection, port injection, CNG fuel mixer) | Port Injection | Same |
| Catalyst Construction (e.g., beads, monolith) | Monolith | Same |
| Precious metal composition of the catalyst by type of principal active material (e.g., platinum based ox-cat, palladium based ox-cat, platinum and rhodium 3-way cat, palladium and rhodium 3-way cat, platinum and palladium and rhodium 3-way cat) | Pt/Rh TWC | Same |
| Catalyst Grouping Statistic (GS) or other criteria (40 CFR 86.182001(b)(7)(i) or (ii)) | **1** GS | **2** Same |
| Other Durability Grouping strategy (based on 40 CFR 86.1820-01(c), (d), or (e) | **3** N/A | **4** N/A |
| 2. Engine Displacement (within 15 percent or 50 in³, whichever is larger) (50 in³ = 0.819L = 819cc) | 225 cubic inches | **5** 176 cubic inches |
| 3. Number of cylinders or combustion chambers | 6 | Same |
| 4. Arrangement of cylinders or combustion chambers (e.g., in-line V, horizontally opposed) | V | Same |
| 5. Emission standards (same or more stringent) | Tier 2, Bin 5 | **6** Tier 2, Bin 3 All vehicles in the Canadian test group are certified to Tier 2 Bin 3 |
| Other: Grouping criteria based on 40 CFR 86.1827-01(b), (c), (d), or (e) | **7** | **8** |
| Evaporative/Refueling Family Criteria (for gasoline- or methanol-fueled vehicles) | 9XXXR0170YYY | |
| 1. Type of vapor storage device (e.g., canister, air cleaner, crankcase) | Canister | Same |
| 2. Basic Canister Design | ||
| Working capacity (within a 10 gram range) | 170 | **9** 180 |
| System configuration (Number of canisters, method of connection (e.g., series or parallel)) | 1 canister | Same |
| Canister geometry, construction and materials | Cylinder, 5-chamber, plastic | Same |
| 3. Fuel system | DFI (Direct Fuel Injection) | Same |
| 4. Type of refueling emission control system (e.g., integrated or non-integrated with evaporative control system | Integrated | Same |
| 5. Fillpipe sealing mechanism (e.g., mechanical, liquid, other) | Liquid | Same |
| 6. Vapor control system or method of controlling vapor flow through the vapor line to the canister (e.g., type of valve, vapor control strategy) | Vacuum, purge control valve | Same |
| 7. Purge control system (e.g., type of valve, purge control strategy) | Duty cycle controlled by ECM | Same |
| 8. Vapor hose material | 4-layer elastomer | Same |
| 9. Fuel tank material | Plastic | Same |
| Other: Grouping criteria based on 40 CFR 86.1821-01(c), (d), or (e) | **10** | **11** |
Statement
The Canadian vehicle described above has no features that could cause it to have a higher level of emissions than the vehicles or engines tested for the issuance of the EPA certificate.
Comments / Additional Information
By taking into consideration features such as the heaviest test weight, the highest roadload horsepower and the highest N/V ratio available, this vehicle does not represent the "worst case" in this test group. Similarly, this vehicle is not the "worst case" evap vehicle in the evap/ORVR family because it has not the lowest cumulative purge to tank volume ratio.
List of changes that are allowed but would require justification/explanation