shaped to "optimize" the design of this device. The canister must have the ability to be adequately purged to assure proper driveability and emission control performance. As can be seen from Figure I, there is no space in the engine compartment of our existing 1987 model vehicles to locate a 6-7 liter canister. Nor do we foresee the possibility of making sufficient space for this large canister in future designs of these vehicles. Therefore, Toyota believes it is necessary to install the canister in the rear of the vehicle near the fuel tank. Figure II shows the luggage capacity reduction that could result from a requirement for on-board controls. An alternative design would lead to a reduction in the fuel tank capacity which would substantially reduce driving range. These would not be temporary "sacrifices" as EPA suggests. While Toyota will continue to improve the design of our vehicles, we believe these problems will not disappear when models are redesigned. Therefore, there will be an on-going inconvenience to owners of smaller vehicles. 2. TOYOTA RESPONSE TO EPA ANSWER 2. Manufacturers take great effort to design vehicles that prevent spillage and spitback of fuel. Toyota believes this is fundamental to vehicle operation. These efforts have been undertaken prior to any discussion by EPA about refueling controls. Toyota believes EPA's response to your question is speculative since our testing shows that refueling is more difficult in vehicles equipped with on-board systems than our existing models. While we do not believe this problem is insurmountable, it is, nevertheless, a serious concern that must be resolved prior to completion of design of an on-board system. A 10 gallon per minute dispensing rate may be a step in the right direction, but even lower rates may be necessary to avoid all spillage and spitback if on-board controls are imposed by EPA. Toyota has two fundamental comments on EPA's response to this question. The first involves safety; the second is leadtime. In many respects these two issues are interrelated, since system design and testing for compliance with safety standards are time consuming efforts. A. Safety EPA's answer to Question 6 says: "As a result of our meeting with IIHS and If this is the case, Toyota believes EPA should not issue proposed rules until the effects on vehicle safety can be fully determined. As noted in our comments on question 1, due to its large size, the refueling canister cannot be installed in the engine compartment. If the canister is installed in the rear of the vehicle the effect of the location of such a system must be carefully evaluated as NHTSA suggests. Sufficient time for design and testing of these systems under many types of impacts, not just FMVSS 301 compliance, will be needed before a manufacturer can begin production. This leads to high development costs and requires sufficient leadtime. B. Leadtime (1) It is unreasonable to consider that evaporative emission control technology can be easily expanded to refueling emission control technology. Although the evaporative emission control system had some design problems associated with it, generally these problems were minor by comparison to designing and integrating a system for on-board controls. This is because: The small-sized evaporative canister could be installed in the engine compartment without major redesign of the vehicle body. The technical problems related to purging the canister were much less severe for the evaporative system than for on-board controls. On the other hand, we face the following problems with on-board refueling control systems: о As noted above, it is very difficult to install a large-sized canister especially on small vehicles (the canister for refueling emission control is four to six times as large as for evaporative emission control.) It is very difficult to establish the on-board refueling emission control technology based on the technology used for evaporative emission control. This is due to concerns about design, durability and reliability of the on-board control system, as well as concerns over compatibility of the system with the existing emission control devices (e.g., purge rate). In addition, it is necessary to evaluate safety in various crash situations, and it is necessary to reexamine the "refuelability" of the vehicle as well as the fuel tank structure. It will take a considerable period of time to evaluate all of such subjects which are awaiting solution for each model with its own characteristics. (2) The demonstration of the on-board control system presented by several oil companies do not provide sufficient proof of technical possibility. In EPA's response to earlier questions, it referred to on-board systems developed by several oil companies. We recognize the efforts of API and the oil companies; however, these efforts indicate only a limited aspect of complying with an on-board control requirement. problems: These demonstration systems have the following The vehicles used in these demonstrations are those which are comparatively easy to install such control systems. However, in at least one of these demonstration vehicles, there may be significant safety problems associated with the location of the canister. It is uncertain that these demonstration We would like you to understand that these activities should be considered only as a preliminary survey, not a development of a system that would meet manufacturers' criteria for performance, durability, and safety. (3) We need at least three-years leadtime from the date of issuance of the final rule to the starting of a phase-in. Toyota will need three-years leadtime, which is the sum of two years for product development after the completion of research, and one year for emission and safety certification. At present, the research of the on-board control system has not been finished and the standard and test procedures have not been proposed. Therefore, we think that even a three-year lead time from the date of issuance of the final rule is risky. Another reason for our request of three-years leadtime is the necessity of making body structure changes to accommodate the on-board system. Toyota believes it will be necessary for us to modify the floor pan of many, if not all, of our vehicles to accommodate this large system. Changes to the floor pan are one of the longest leadtime items in a vehicle due to the fundamental role the floor pan pays in the structural integrity of the vehicle, the effect of any change on the suspension system and the complexity of retooling. 4. We need three full years for phase-in of any The adoption of on-board refueling emission control systems will require vehicle manufacturers to make design changes leading to enormous investments and additional components costs. The result will be added expense for consumers to bear. Therefore, in the event on-board control systems are required, a phase-in period must be provided to allow manufacturers necessary time to make body and structural modifications for each model according to its model change schedule. Otherwise, major structural changes may be required with insufficient time to amortize the sizeable expense of making such major changes. Since the usual model life is four to six years, a two year phase-in period, which is reportedly under consideration by EPA, is too short for manufacturers to accomplish the installation of on-board refueling emission control system on each model. With a two year phase-in, we estimate only half of many manufacturers' models will be able to install on-board control systems without necessitating very expensive mid-cycle structural changes. Therefore, a fourmodel year phase-in period (that is, a full-three years after the first model is equipped with a system) is necessary to avoid very high costs, or reduced model availability on the part of some companies. Figure III shows our usual model change pattern, assuming a four-year model life. As shown in this figure, the body structure is decided three years before starting regular production. This is normal for most manufacturers. Even for those vehicles which are being redesigned at this time, in many instances the body structure has already been decided and tooling has begun. Changes in vehicles during the latter portion of the design stage will be very complex and costly, due to the necessity to re-tool and retest these vehicles. the case of models which have a 6-year model life, this problem In will be even more serious. Therefore, the phase-in period must be extended further for the following models; i) ii) certain particular vehicles (e.g., all 4WD some models which have difficulty in adopting an on-board control system within EPA's proposed phase-in period (e.g., Land Cruiser). Those vehicles have small sales volumes and will have less effect on the total emissions. Therefore, if on-board controls should be required, both the manufacturer's burden on production and user's burden will increase. We We must restate our opposition to on-board controls because of the high cost and the technical problems associated with these systems. However, we are making these comments so that you might have an understanding of the difficulties manufacturers face in complying with any such requirement. hope that these comments will be useful to you as you consider EPA's responses to your questions. A copy of these comments will be sent to EPA under separate cover, since it is our understanding that a draft of an NPRM is undergoing internal review at EPA at this time. Sincerely, TOYOTA MOTOR CORPORATION Yoshima Hame General Manager Attachments |