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Tesla Model Y from Giga Texas is just one EPA approval away from first deliveries

Credit: Tesla

Hundreds of Tesla Model Y all-electric crossovers have been spotted in the lots of Gigafactory Texas in the past few weeks, with some being spotted on haulers to be driven to destinations not known. However, haulers will likely be back soon for another logistics mission: to pick up the “Austin-made” Model Ys and take them to customers for delivery.

Tesla will be able to begin delivering units of its Austin-made Model Y all-electric crossover from Gigafactory Texas following the EPA approval of the vehicle, the agency told Teslarati. Currently, the Model Y from Gigafactory Texas is being produced with Tesla’s newest 4680 battery cells and new structural battery pack, has not gained its Certificate of Conformity, a document needed for a vehicle to be introduced into commerce.

Certificates of Conformity are effectively approval by the EPA that a vehicle can enter the stream of commerce. If it is introduced into commerce, the vehicle must have a Certificate of Conformity. The certifications are valid for a single model year, and new model year vehicles make their way to the EPA’s testing facility in Ann Arbor, Michigan every year to confirm they align with the EPA’s emissions standards.

“Prior to offering a vehicle for sale, all carlines in the Light-duty sector must be certified and Fuel Economy test data representing each model type must be submitted to EPA,” the EPA said to Teslarati in a statement. “EPA can confirm that Tesla has received a Certificate of Conformity for the 2022 Model Y Long Range AWD, Model Y Performance AWD (Test Group NTSLV00.0L2Y) and a Certificate for the Model Y RWD (Test Group NTSLV00.0L1Y).” These test groups were certified by the EPA last year, with the 2022 Model Y Long Range AWD and Performance variants gaining their Certificate of Conformity on November 1, 2021. It does not expire until December 31, 2022. The 2022 Model Y RWD, which is the variant that Tesla ultimately did not sell, gained its Certificate of Conformity from the EPA on September 28.

(Credit: Jeff Roberts)

Tesla’s Model Y made in Austin will also be a 2022 Model Y, which would mean it would technically align with the EPA’s Certificates of Conformity, especially as the geographic location of manufacture does not determine whether a vehicle conforms to the EPA’s standards or not. “EPA does not use the build location as a descriptor for a new test group or Certificate of Conformity,” the agency said. Instead, updates in the vehicle’s battery pack can prompt the EPA to consider certifying a vehicle again, even if the changes occur to a car in the same model year. However, the changes made to the vehicle prompted the EPA to certify the Austin-made Model Y separately.

In its 2017 document titled, “EPA Test Procedures for Electric Vehicles and Plug-in Hybrids,” the agency says that Confirmatory Testing for vehicles with the same model year is determined on a case-by-case basis, and the EPA can make a choice to certify a vehicle based on the changes:

“Currently, EPA performs confirmatory testing on all new light-duty electric vehicles and plug-in hybrid vehicles at EPA’s emission testing laboratory in Ann Arbor Michigan. If the manufacturer makes changes to an EV or PHEV that was previously tested at EPA, EPA will decide on a case-by-case basis whether additional EPA confirmatory testing is needed.”

What were the changes Tesla made exactly? The EPA confirmed to us that it could not comment on the status “of preproduction vehicles that are pending new emissions certification until manufacturers introduce them into commerce,” which means the Model Y’s changes are confidential until the car earns its Certificate of Conformity. Tesla did not respond to our inquiries to clarify why the vehicle needed to go through the EPA’s conformity procedure once again. However, Tesla’s most recent Earnings Call provided plenty of color to what the changes that prompted a new certification process likely are, and it has to do with Tesla’s 4680 battery cell.

The Battery Pack likely required the EPA to certify the Model Y once again

During the Q4 2021 Earnings Call, Tesla said that “after final certification of Austin-made Model Y, we plan to start deliveries to customers.” Additionally, during the Earnings Call CEO Elon Musk stated that Tesla was “building the Model Ys with the structural battery pack and the 4680 cells, and we’ll start delivering after final certification of the vehicle, which should be fairly soon.” Read More.

Previous builds of the Model Y, even 2022 model year vehicles, which were built at the Fremont Factory, have not yet used Tesla’s 4680 battery pack or the structural battery pack. Instead, Model Ys built at Fremont in the United States have used the automaker’s previous cell chemistry, the 2170 cell. When the EPA certified Tesla’s 2022 model year vehicles in August 2021, the certifications were for the previous battery pack. Read More.

Tesla Model Y from Giga Texas will equip Structural Battery Pack, 4680 cells

The 4680 batteries differ significantly from the 2170 cell in power, range, and efficiency. Therefore, the Model Y from Texas will have ratings that are substantially different from previous builds from Fremont. The Model Y from Austin needs eMPG ratings for FuelEconomy.gov and Monroney stickers.

Once Tesla is granted a Certificate of Conformity for Model Ys that are set to be produced at Gigafactory Texas, the automaker will be able to deliver the vehicles to customers.

Documents obtained by Teslarati show Tesla’s application to have the Model Y’s AWD and Performance variants certified together, while the RWD build of the car was certified separately. The documents state that each variant of the car conformed with California Air and Resource Board (CARB) standards, as well as Federal Emissions Standards that States which do not align with the CARB standards utilize. Texas withdrew its intentions to adopt CARB standards in 2007, State documents revealed.

States that have adopted CARB standards are New York, Massachusetts, Vermont, Maine, Pennsylvania, Connecticut, Rhode Island, Washington, Oregon, New Jersey, Maryland, Delaware, and most recently, Colorado, which adopted the standards this year.

How long until the Tesla Model Y from Gigafactory Texas is approved by the EPA?

The EPA cannot predict the timing of the certification process, and it varies from vehicle to vehicle. Rough timeframes are available by determining when Tesla submitted an application for a vehicle and when the vehicle gained its Certificate of Conformity.

Tesla’s application for the 2022 Model Y Long Range AWD and Performance variants is dated for October 21, while the Certificate of Conformity is dated November 1. However, this vehicle had a previous model year and utilized the same battery pack. The timeframe may be quicker as the 4680 pack has not been previously tested by the EPA for a passenger vehicle.

When Tesla submitted its application for the 2021 Model Y, it was the first certification process for the vehicle. Tesla submitted the application on December 13, 2019, with the Model Y gaining its Certificate of Conformity about a month later on January 8.

If Tesla submitted its application for the new Model Y on January 26 when it announced it was awaiting certification, deliveries could be approved within the coming days.

4680 Battery Cell

In September 2020, Tesla held “Battery Day” to unveil a new cell and manufacturing design that would increase vehicle safety and structural integrity. Musk unveiled the 4680 cell, a new electric vehicle battery capable of more range, power, and performance while offering a longer life cycle. Tesla has been producing the cell in volume at a facility known as Kato Road near the company’s Fremont factory in Northern California. Until now, no customer has driven a Tesla vehicle equipping the 4680 cell. The Model Y built at the Texas factory will be the first Tesla vehicle to utilize the new 4680 battery pack. Read More.

The vehicle will also utilize Tesla’s structural battery pack, the automaker confirmed. The structural battery pack uses engineering similar to an aircraft wing to use negative mass to increase structural integrity and density. The packs will also use a structural adhesive and flame retardant, attaching cells to the floor and ceiling of the pack, increasing stiffness and preventing major deformation in the event of a crash. Read More.

I’d love to hear from you! If you have any comments, concerns, or questions, please email me at joey@teslarati.com. You can also reach me on Twitter @KlenderJoey, or if you have news tips, you can email us at tips@teslarati.com.

Tesla Model Y from Giga Texas is just one EPA approval away from first deliveries
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