[Federal Register Volume 75, Number 229 (Tuesday, November 30, 2010)]
[Proposed Rules]
[Pages 74151-74456]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2010-28120]
[[Page 74151]]
-----------------------------------------------------------------------
Part II
Environmental Protection Agency
-----------------------------------------------------------------------
40 CFR Parts 85, 86, 1036, et al.
Department of Transportation
-----------------------------------------------------------------------
National Highway Traffic Safety Administration
49 CFR Parts 523, 534, and 535
Greenhouse Gas Emissions Standards and Fuel Efficiency Standards for
Medium- and Heavy-Duty Engines and Vehicles; Proposed Rule
Federal Register / Vol. 75 , No. 229 / Tuesday, November 30, 2010 /
Proposed Rules
[[Page 74152]]
-----------------------------------------------------------------------
ENVIRONMENTAL PROTECTION AGENCY
40 CFR Parts 85, 86, 1036, 1037, 1065, 1066, and 1068
DEPARTMENT OF TRANSPORTATION
National Highway Traffic Safety Administration
49 CFR Parts 523, 534, and 535
[EPA-HQ-OAR-2010-0162; NHTSA-2010-0079; FRL-9219-4]
RIN 2060-AP61; RIN 2127-AK74
Greenhouse Gas Emissions Standards and Fuel Efficiency Standards
for Medium- and Heavy-Duty Engines and Vehicles
AGENCIES: Environmental Protection Agency (EPA) and National Highway
Traffic Safety Administration (NHTSA), Department of Transportation
(DOT).
ACTION: Proposed rules.
-----------------------------------------------------------------------
SUMMARY: EPA and NHTSA, on behalf of the Department of Transportation,
are each proposing rules to establish a comprehensive Heavy-Duty
National Program that will reduce greenhouse gas emissions and increase
fuel efficiency for on-road heavy-duty vehicles, responding to the
President's directive on May 21, 2010, to take coordinated steps to
produce a new generation of clean vehicles. NHTSA's proposed fuel
consumption standards and EPA's proposed carbon dioxide
(CO2) emissions standards would be tailored to each of three
regulatory categories of heavy-duty vehicles: Combination Tractors;
Heavy-Duty Pickup Trucks and Vans; and Vocational Vehicles, as well as
gasoline and diesel heavy-duty engines. EPA's proposed
hydrofluorocarbon emissions standards would apply to air conditioning
systems in tractors, pickup trucks, and vans, and EPA's proposed
nitrous oxide (N2O) and methane (CH4) emissions
standards would apply to all heavy-duty engines, pickup trucks, and
vans. EPA is also requesting comment on possible alternative
CO2-equivalent approaches for model year 2012-14 light-duty
vehicles.
EPA's proposed greenhouse gas emission standards under the Clean
Air Act would begin with model year 2014. NHTSA's proposed fuel
consumption standards under the Energy Independence and Security Act of
2007 would be voluntary in model years 2014 and 2015, becoming
mandatory with model year 2016 for most regulatory categories.
Commercial trailers would not be regulated in this phase of the Heavy-
Duty National Program, although there is a discussion of the
possibility of future action for trailers.
DATES: Comments: Comments on all aspects of this proposal must be
received on or before January 31, 2011. Under the Paperwork Reduction
Act, comments on the information collection provisions must be received
by the Office of Management and Budget on or before December 30, 2010.
See the SUPPLEMENTARY INFORMATION section on ``Public Participation''
for more information about written comments.
Public Hearings: NHTSA and EPA will jointly hold two public
hearings on the following dates: November 15, 2010 in Chicago, IL; and
November 18, 2010 in Cambridge, MA, as announced at 75 FR 67059,
November 1, 2010. The hearing in Chicago will start at 11 a.m. local
time and continue until 5 p.m. or until everyone has had a chance to
speak. The hearing in Cambridge will begin at 10 a.m. and continue
until 5 p.m. or until everyone has had a chance to speak. See ``How Do
I Participate in the Public Hearings?'' below at B. (7) under the
SUPPLEMENTARY INFORMATION section on ``Public Participation'' for more
information about the public hearings.
ADDRESSES: Submit your comments, identified by Docket ID No. NHTSA-
2010-0079 and/or EPA-HQ-OAR-2010-0162, by one of the following methods:
http://www.regulations.gov: Follow the on-line
instructions for submitting comments.
E-mail: a-and-r-docket@epa.gov.
Fax: NHTSA: (202) 493-2251; EPA: (202) 566-9744.
Mail:
NHTSA: Docket Management Facility, M-30, U.S. Department of
Transportation, West Building, Ground Floor, Rm. W12-140, 1200 New
Jersey Avenue, SE., Washington, DC 20590.
EPA: Air Docket, Environmental Protection Agency, EPA Docket
Center, Mailcode: 6102T, 1200 Pennsylvania Ave., NW., Washington, DC
20460. In addition, please mail a copy of your comments on the
information collection provisions to the Office of Information and
Regulatory Affairs, Office of Management and Budget (OMB), Attn: Desk
Officer for EPA, 725 17th St., NW., Washington, DC 20503.
Hand Delivery:
NHTSA: West Building, Ground Floor, Rm. W12-140, 1200 New Jersey
Avenue, SE., Washington, DC 20590, between 9 a.m. and 5 p.m. Eastern
Time, Monday through Friday, except Federal Holidays.
EPA: EPA Docket Center, (Air Docket), U.S. Environmental Protection
Agency, EPA West Building, 1301 Constitution Ave., NW., Room: 3334,
Mail Code 2822T, Washington, DC. Such deliveries are only accepted
during the Docket's normal hours of operation, and special arrangements
should be made for deliveries of boxed information.
Instructions: Direct your comments to Docket ID No. NHTSA-2010-0079
and/or EPA-HQ-OAR-2010-0162. See the SUPPLEMENTARY INFORMATION section
on ``Public Participation'' for additional instructions on submitting
written comments.
Docket: All documents in the docket are listed in the http://www.regulations.gov index. Although listed in the index, some
information is not publicly available, e.g., confidential business
information or other information whose disclosure is restricted by
statute. Certain other material, such as copyrighted material, will be
publicly available only in hard copy in EPA's docket, but may be
available electronically in NHTSA's docket at regulations.gov. Publicly
available docket materials are available either electronically in
http://www.regulations.gov or in hard copy at the following locations:
NHTSA: Docket Management Facility, M-30, U.S. Department of
Transportation, West Building, Ground Floor, Rm. W12-140, 1200 New
Jersey Avenue, SE., Washington, DC 20590. The Docket Management
Facility is open between 9 a.m. and 5 p.m. Eastern Time, Monday through
Friday, except Federal holidays.
EPA: EPA Docket Center, EPA/DC, EPA West, Room 3334, 1301
Constitution Ave., NW., Washington, DC. The Public Reading Room is open
from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal
holidays. The telephone number for the Air Docket is (202) 566-1742.
FOR FURTHER INFORMATION CONTACT: NHTSA: Rebecca Yoon, Office of Chief
Counsel, National Highway Traffic Safety Administration, 1200 New
Jersey Avenue, SE., Washington, DC 20590. Telephone: (202) 366-2992.
EPA: Lauren Steele, Office of Transportation and Air Quality,
Assessment and Standards Division (ASD), Environmental Protection
Agency, 2000 Traverwood Drive, Ann Arbor, MI 48105; telephone number:
(734) 214-4788; fax number: (734) 214-4816; e-mail address:
steele.lauren@epa.gov, or Assessment and Standards Division Hotline;
telephone number; (734) 214-4636; e-mail asdinfo@epa.gov.
[[Page 74153]]
SUPPLEMENTARY INFORMATION:
Does this action apply to me?
This action would affect companies that manufacture, sell, or
import into the United States new heavy-duty engines and new Class 2b
through 8 trucks, including combination tractors, school and transit
buses, vocational vehicles such as utility service trucks, as well as
\3/4\-ton and 1-ton pickup trucks and vans.\1\ The heavy-duty category
incorporates all motor vehicles with a gross vehicle weight rating of
8,500 pounds or greater, and the engines that power them, except for
medium-duty passenger vehicles already covered by the greenhouse gas
standards and corporate average fuel economy standards issued for
light-duty model year 2012-2016 vehicles. This action also includes a
discussion of the possible future regulation of commercial trailers and
is requesting comment on possible alternative CO2-equivalent
approaches for model year 2012-14 light-duty vehicles. Potentially
affected categories and entities include the following:
---------------------------------------------------------------------------
\1\ For purposes of NHTSA's fuel consumption regulations, non-
commercial recreational vehicles will not be covered, even if they
would otherwise fall under these categories. See 49 U.S.C.
32901(a)(7).
[GRAPHIC] [TIFF OMITTED] TP30NO10.000
This table is not intended to be exhaustive, but rather provides a
guide for readers regarding entities likely to be regulated by this
proposal. This table lists the types of entities that the agencies are
now aware could potentially be regulated by this action. Other types of
entities not listed in the table could also be regulated. To determine
whether your activities may be regulated by this action, you should
carefully examine the applicability criteria in 40 CFR parts 1036 and
1037, 49 CFR parts 523, 534, and 535, and the referenced regulations.
You may direct questions regarding the applicability of this action to
the persons listed in the preceding FOR FURTHER INFORMATION CONTACT
section.
B. Public Participation
NHTSA and EPA request comment on all aspects of these joint
proposed rules. This section describes how you can participate in this
process.
(1) How do I prepare and submit comments?
In this joint proposal, there are many aspects of the program
common to both EPA and NHTSA. For the convenience of all parties,
comments submitted to the EPA docket (whether hard copy or electronic)
will be considered comments submitted to the NHTSA docket, and vice
versa. An exception is that comments submitted to the NHTSA docket on
the Draft Environmental Impact Statement will not be considered
submitted to the EPA docket. Therefore, the public only needs to submit
comments to either one of the two agency dockets. Comments that are
submitted for consideration by one agency should be identified as such,
and comments that are submitted for consideration by both agencies
should be identified as such. Absent such identification, each agency
will exercise its best judgment to determine whether a comment is
submitted on its proposal.
Further instructions for submitting comments to either the EPA or
NHTSA docket are described below.
[[Page 74154]]
NHTSA: Your comments must be written and in English. To ensure that
your comments are correctly filed in the Docket, please include the
Docket I.D No. NHTSA-2010-0079 in your comments. By regulation, your
comments must not be more than 15 pages long (49 CFR 553.21). NHTSA
established this limit to encourage you to write your primary comments
in a concise fashion. However, you may attach necessary additional
documents to your comments. There is no limit on the lenght of the
attachments. If you are submitting comments electronically as a PDF
(Adobe) file, we ask that the documents submitted be scanned using the
Optical Character Recognition (OCR) process, thus allowing the agencies
to search and copy certain portions of your submissions.\2\ Please note
that pursuant to the Data Quality Act, in order for the substantive
data to be relied upon and used by the agencies, it must meet the
information quality standards set forth in the OMB and Department of
Transportation (DOT) Data Quality Act quidelines. Accordingly, we
encourage you to consult the guidelines in preparing your comments.
OMB's guidelines may be accessed at http://www.whitehouse.gov/omb/fedreg/reproducible.html. DOT's guidelines may be access at http://regs.dot.gov.
---------------------------------------------------------------------------
\2\ Optical character recognition (OCR) is the process of
converting an image of text, such as a scanned paper document or
electronic fax file, into computer-editable text.
---------------------------------------------------------------------------
EPA: Direct your comments to Docket ID No EPA-HQ-OAR-2010-0162.
EPA's policy is that all comments received will be included in the
public docket without change and may be made available online at http://www.regulations.gov, including any personal information provided,
unless the comment includes information claimed to be Confidential
Business Information (CBI) or other information whose disclosure is
restricted by statute. Do not submit information that you consider to
be CBI or otherwise protected through http://www.regulations.gov or e-
mail. The http://www.regulations.gov Web site is an ``anonymous
access'' system, which means EPA will not know your identity or contact
information unless you provide it in the body of your comment. If you
send an e-mail comment directly to EPA without going through http://www.regulations.gov your e-mail address will be automatically captured
and included as part of the comment that is placed in the public docket
and made available on the Internet. If you submit an electronic
comment, EPA recommends that you include your name and other contact
information in the body of your comment and with any disk or CD-ROM you
submit. If EPA cannot read your comment due to technical difficulties
and cannot contact you for clarification, EPA may not be able to
consider your comment. Electronic files should avoid the use of special
characters, any form of encryption, and be free of any defects or
viruses. For additional information about EPA's public docket visit the
EPA Docket Center homepage at http://www.epa.gov/epahome/dockets.htm.
(2) Tips for Preparing Your Comments
When submitting comments, remember to:
Identify the rulemaking by docket number and other
identifying information (subject heading, Federal Register date and
page number).
Follow directions--The agencies may ask you to respond to
specific questions or organize comments by referencing a part or
section number from the Code of Federal Regulations.
Explain why you agree or disagree, suggest alternatives,
and substitute language for your requested changes.
Describe any assumptions and provide any technical
information and/or data that you used.
If you estimate potential costs or burdens, explain how
you arrived at your estimate in sufficient detail to allow for it to be
reproduced.
Provide specific examples to illustrate your concerns, and
suggest alternatives.
Explain your views as clearly as possible, avoiding the
use of profanity or personal threats.
Make sure to submit your comments by the comment period
deadline identified in the DATES section above.
(3) How can I be sure that my comments were received?
NHTSA: If you submit your comments by mail and wish Docket
Management to notify you upon its receipt of your comments, enclose a
self-addressed, stamped postcard in the envelope containing your
comments. Upon receiving your comments, Docket Management will return
the postcard by mail.
(4) How do I submit confidential business information?
Any CBI submitted to one of the agencies will also be available to
the other agency.\3\ However, as with all public comments, any CBI
information only needs to be submitted to either one of the agencies'
dockets and it will be available to the other. Following are specific
instructions for submitting CBI to either agency.
---------------------------------------------------------------------------
\3\ This statement constitutes notice to commenters pursuant to
40 CFR 2.209(c) that EPA will share confidential business
information received with NHTSA unless commenters expressly specify
that they wish to submit their CBI only to EPA and not to both
agencies.
---------------------------------------------------------------------------
NHTSA: If you wish to submit any information under a claim of
confidentiality, you should submit three copies of your complete
submission, including the information you claim to be CBI, to the Chief
Counsel, NHTSA, at the address given above under FOR FURTHER
INFORMATION CONTACT. When you send a comment containing CBI, you should
include a cover letter setting forth the information specified in our
CBI regulation. In addition, you should submit a copy from which you
have deleted the claimed CBI to the Docket by one of the methods set
forth above.
EPA: Do not submit CBI to EPA through http://www.regulations.gov or
e-mail. Clearly mark the part or all of the information that you claim
to be CBI. For CBI in a disk or CD-ROM that you mail to EPA, mark the
outside of the disk or CD-ROM as CBI and then identify electronically
within the disk or CD-ROM the specific information that is claimed as
CBI. In addition to one complete version of the comment that includes
information claimed as CBI, a copy of the comment that does not contain
the information claimed as CBI must be submitted for inclusion in the
public docket. Information so marked will not be disclosed except in
accordance with procedures set forth in 40 CFR part 2.
(5) Will the agencies consider late comments?
NHTSA and EPA will consider all comments received before the close
of business on the comment closing date indicated above under DATES. To
the extent practicable, we will also consider comments received after
that date. If interested persons believe that any new information the
agency places in the docket affects their comments, they may submit
comments after the closing date concerning how the agency should
consider that information for the final rules. However, the agencies'
ability to consider any such late comments in this rulemaking will be
limited due to the time frame for issuing the final rules.
If a comment is received too late for us to practicably consider in
developing the final rules, we will consider that comment as an
informal suggestion for future rulemaking action.
[[Page 74155]]
How can I read the comments submitted by other people?
You may read the materials placed in the dockets for this document
(e.g., the comments submitted in response to this document by other
interested persons) at any time by going to http://www.regulations.gov.
Follow the online instructions for accessing the dockets. You may also
read the materials at the NHTSA Docket Management Facility or the EPA
Docket Center by going to the street addresses given above under
ADDRESSES.
How do I participate in the public hearings?
EPA and NHTSA will jointly host two public hearings. The November
15 hearing will be held at the Millennium Knickerbocker Hotel Chicago,
163 East Walton Place (at N. Michigan Ave.), Chicago, Illinois 60611.
The November 18, 2010 hearing will be held at the Hyatt Regency
Cambridge, 575 Memorial Drive, Cambridge, Massachusetts 02139-4896. If
you would like to present oral testimony at a public hearing, we ask
that you notify both the NHTSA and EPA contact persons listed under FOR
FURTHER INFORMATION CONTACT at least ten days before the hearing. Once
the agencies learn how many people have registered to speak at the
public hearings, we will allocate an appropriate amount of time to each
participant, allowing time for necessary breaks. For planning purposes,
each speaker should anticipate speaking for approximately ten minutes,
although we may need to shorten that time if there is a large turnout.
We request that you bring three copies of your statement or other
material for the agencies' panels. To accommodate as many speakers as
possible, we prefer that speakers not use technological aids (e.g.,
audio-visuals, computer slideshows). In addition, we will reserve a
block of time for anyone else in the audience who wants to give
testimony.
Each hearing will be held at a site accessible to individuals with
disabilities. Individuals who require accommodations such as sign
language interpreters should contact the persons listed under FOR
FURTHER INFORMATION CONTACT section above no later than ten days before
the date of the hearing.
EPA and NHTSA will conduct the hearings informally, and technical
rules of evidence will not apply. We will arrange for a written
transcript of each hearing and keep the official records of the
hearings open for 30 days to allow you to submit supplementary
information. You may make arrangements for copies of a transcript
directly with the court reporter.
C. Additional Information About This Rulemaking
EPA's Advance Notice of Proposed Rulemaking for regulating
greenhouse gases under the CAA (see 73 FR 44353, July 30, 2008)
included a discussion of possible rulemaking paths for the heavy-duty
transportation sector. This notice of proposed rulemaking relies in
part on information that was obtained from that notice, which can be
found in Public Docket EPA-HQ-OAR-2008-0318. That docket is
incorporated into the docket for this action, EPA-HQ-OAR-2010-0162.
Table of Contents
A. Does this action apply to me?
B. Public Participation
C. Additional Information About This Rulemaking
I. Overview
A. Introduction
B. Building Blocks of the Heavy-Duty National Program
C. Summary of the Proposed EPA and NHTSA HD National Program
D. Summary of Costs and Benefits of the HD National Program
E. Program Flexibilities
F. EPA and NHTSA Statutory Authorities
G. Future HD GHG and Fuel Consumption Rulemakings
II. Proposed GHG and Fuel Consumption Standards for Heavy-Duty
Engines and Vehicles
A. What vehicles would be affected?
B. Class 7 and 8 Combination Tractors
C. Heavy-Duty Pickup Trucks and Vans
D. Class 2b-8 Vocational Vehicles
E. Other Standards Provisions
III. Feasibility Assessments and Conclusions
A. Class 7-8 Combination Tractor
B. Heavy-Duty Pickup Trucks and Vans
C. Class 2b-8 Vocational Vehicles
IV. Proposed Regulatory Flexibility Provisions
A. Averaging, Banking, and Trading Program
B. Additional Proposed Flexibility Provisions
V. NHTSA and EPA Proposed Compliance, Certification, and Enforcement
Provisions
A. Overview
B. Heavy-Duty Pickup Trucks and Vans
C. Heavy-Duty Engines
D. Class 7 and 8 Combination Tractors
E. Class 2b-8 Vocational Vehicles
F. General Regulatory Provisions
G. Penalties
VI. How would this proposed program impact fuel consumption, GHG
emissions, and climate change?
A. What methodologies did the agencies use to project GHG
emissions and fuel consumption impacts?
B. MOVES Analysis
C. What are the projected reductions in fuel consumption and GHG
emissions?
D. Overview of Climate Change Impacts From GHG Emissions
E. Changes in Atmospheric CO2 Concentrations, Global
Mean Temperature, Sea Level Rise, and Ocean pH Associated With the
Proposal's GHG Emissions Reductions
VII. How would this proposal impact Non-GHG emissions and their
associated effects?
A. Emissions Inventory Impacts
B. Health Effects of Non-GHG Pollutants
C. Environmental Effects of Non-GHG Pollutants
D. Air Quality Impacts of Non-GHG Pollutants
VIII. What are the agencies' estimated cost, economic, and other
impacts of the proposed program?
A. Conceptual Framework for Evaluating Impacts
B. Costs Associated With the Proposed Program
C. Indirect Cost Multipliers
D. Cost Per Ton of Emissions Reductions
E. Impacts of Reduction in Fuel Consumption
F. Class Shifting and Fleet Turnover Impacts
G. Benefits of Reducing CO2 Emissions
H. Non-GHG Health and Environmental Impacts
I. Energy Security Impacts
J. Other Impacts
K. Summary of Costs and Benefits From the Greenhouse Gas
Emissions Perspective
L. Summary of Costs and Benefits From the Fuel Efficiency
Perspective
IX. Analysis of Alternatives
A. What are the alternatives that the agencies considered?
B. How do these alternatives compare in overall GHG emissions
reductions, fuel efficiency and cost?
C. How would the agencies include commercial trailers, as
described in alternative 7?
X. Recommendations From the 2010 NAS Report
A. Overview
B. What were the major findings and recommendations of the 2010
NAS report, and how is the proposed HD national program consistent
with them?
XI. Statutory and Executive Order Reviews
XII. Statutory Provisions and Legal Authority
A. EPA
B. NHTSA
I. Overview
A. Introduction
EPA and NHTSA (``the agencies'') are announcing a first-ever
program to reduce greenhouse gas (GHG) emissions and improve fuel
efficiency in the heavy-duty highway vehicle sector. This broad
sector--ranging from large pickups to sleeper-cab tractors--together
represent the second largest contributor to oil consumption and GHG
emissions, after light-duty passenger cars and trucks.
In a recent memorandum to the Administrators of EPA and NHTSA (and
the Secretaries of Transportation and
[[Page 74156]]
Energy), the President stated that ``America has the opportunity to
lead the world in the development of a new generation of clean cars and
trucks through innovative technologies and manufacturing that will spur
economic growth and create high-quality domestic jobs, enhance our
energy security, and improve our environment.'' \4\ Earlier this year,
EPA and NHTSA established for the first time a national program to
sharply reduce GHG emissions and fuel consumption from passenger cars
and light trucks. Now, each agency is proposing rules that together
would create a strong and comprehensive Heavy-Duty National Program
(``HD National Program'') designed to address the urgent and closely
intertwined challenges of dependence on oil, energy security, and
global climate change. At the same time, the proposed program would
enhance American competitiveness and job creation, benefit consumers
and businesses by reducing costs for transporting goods, and spur
growth in the clean energy sector.
---------------------------------------------------------------------------
\4\ Improving Energy Security, American Competitiveness and Job
Creation, and Environmental Protection Through a Transformation of
Our Nation's Fleet of Cars And Trucks,'' Issued May 21, 2010,
published at 75 FR 29399, May 26, 2010.
---------------------------------------------------------------------------
A number of major HD truck and engine manufacturers representing
the vast majority of this industry, and the California Air Resources
Board (California ARB), sent letters to EPA and NHTSA supporting a HD
National Program based on a common set of principles. In the letters,
the stakeholders commit to working with the agencies and with other
stakeholders toward a program consistent with common principles,
including:
Increased use of existing technologies to achieve
significant GHG emissions and fuel consumption reductions;
A program that starts in 2014 and is fully phased in by
2018;
A program that works towards harmonization of methods for
determining a vehicle's GHG and fuel efficiency, recognizing the global
nature of the issues and the industry;
Standards that recognize the commercial needs of the
trucking industry; and
Incentives leading to the early introduction of advanced
technologies.
The proposed HD National Program builds on many years of heavy-duty
engine and vehicle technology development to achieve what the agencies
believe would be the greatest degree of GHG emission and fuel
consumption reduction appropriate, feasible, and cost-effective for the
model years in question. Still, by proposing to take aggressive steps
that are reasonably possible now, based on the technological
opportunities and pathways that present themselves during these model
years, the agencies and industry will also continue learning about
emerging opportunities for this complex sector to further reduce GHG
emissions and fuel consumption. For example, NHTSA and EPA have stopped
short of proposing fuel consumption and GHG emissions standards for
trucks based on use of hybrid powertrain technology. Similarly, we
expect that the agencies will participate in efforts to improve our
ability to accurately characterize the actual in-use fuel consumption
and emissions of this complex sector. As such opportunities emerge in
the coming years, we expect that we will propose a second phase of
provisions in the future to reinforce these developments and maximize
the achieved reductions in GHG emissions and fuel consumption reduction
for the mid- and longer-term time frame.
In the May 21 memorandum, the President requested the
Administrators of EPA and NHTSA to ``immediately begin work on a joint
rulemaking under the Clean Air Act (CAA) and the Energy Independence
and Security Act of 2007 (EISA) to establish fuel efficiency and
greenhouse gas emissions standards for commercial medium- and heavy-
duty vehicles beginning with the 2014 model year (MY), with the aim of
issuing a final rule by July 30, 2011.'' This proposed rulemaking is
consistent with this Presidential Memorandum, with each agency
proposing rules under its respective authority that together comprise a
coordinated and comprehensive HD National Program.
Heavy-duty vehicles move much of the nation's freight and carry out
numerous other tasks, including utility work, concrete delivery, fire
response, refuse collection, and many more. Heavy-duty vehicles are
primarily powered by diesel engines, although about 37 percent of these
vehicles are powered by gasoline engines. Heavy-duty trucks \5\ have
always been an important part of the goods movement infrastructure in
this country and have experienced significant growth over the last
decade related to increased imports and exports of finished goods and
increased shipping of finished goods to homes through Internet
purchases.
---------------------------------------------------------------------------
\5\ In this rulemaking, EPA and NHTSA use the term ``truck'' in
a general way, referring to all categories of regulated heavy-duty
highway vehicles (including buses). As such, the term is generally
interchangeable with ``heavy-duty vehicle.''
---------------------------------------------------------------------------
The heavy-duty sector is extremely diverse in several respects,
including types of manufacturing companies involved, the range of sizes
of trucks and engines they produce, the types of work the trucks are
designed to perform, and the regulatory history of different
subcategories of vehicles and engines. The current heavy-duty fleet
encompasses vehicles from the ``18-wheeler'' combination tractors one
sees on the highway to school and transit buses, to vocational vehicles
such as utility service trucks, as well as the largest pickup trucks
and vans.
For purposes of this preamble, the term ``heavy-duty'' or ``HD'' is
used to apply to all highway vehicles and engines that are not within
the range of light-duty vehicles, light-duty trucks, and medium-duty
passenger vehicles (MDPV) covered by the GHG and Corporate Average Fuel
Economy (CAFE) standards issued for MY 2012-2016.\6\ It also does not
include motorcycles. Thus, in this notice, unless specified otherwise,
the heavy-duty category incorporates all vehicles with a gross vehicle
weight rating above 8,500 pounds, and the engines that power them,
except for MDPVs.\7\ We note that the Energy Independence and Security
Act of 2007 requires NHTSA to set standards for ``commercial medium-
and heavy-duty on-highway vehicles and work trucks.'' \8\ NHTSA
interprets this to include all segments of the heavy-duty category
described above, except for recreational vehicles, such as motor homes,
since recreational vehicles are not commercial.
---------------------------------------------------------------------------
\6\ Light-Duty Vehicle Greenhouse Gas Emission Standards and
Corporate Average Fuel Economy Standards; Final Rule 75 FR
25323,(May 7, 2010).
\7\ The CAA defines heavy-duty as a truck, bus or other motor
vehicle with a gross vehicle weight rating exceeding 6,000 pounds
(CAA section 202(b)(3)). The term HD as used in this action refers
to a subset of these vehicles and engines.
\8\ 49 U.S.C. 32902(k)(2). ``Commercial medium- and heavy-duty
on-highway vehicles'' are defined as on-highway vehicles with a
gross vehicle weight rating of 10,000 pounds or more, while ``work
trucks'' are defined as vehicles rated between 8,500 and 10,000
pounds gross vehicle weight that are not MDPVs. See 49 U.S.C.
32901(a)(7) and (a)(19).
---------------------------------------------------------------------------
Setting GHG emissions standards for the heavy-duty sector will help
to address climate change, which is widely viewed as a significant
long-term threat to the global environment. As summarized in the
Technical Support Document for EPA's Endangerment and Cause or
Contribute Findings under Section 202(a) of the Clean Air Act,
anthropogenic emissions of GHGs are very likely (a 90 to 99 percent
probability) the cause of most of the
[[Page 74157]]
observed global warming over the last 50 years.\9\ The primary GHGs of
concern are carbon dioxide (CO2), methane (CH4),
nitrous oxide (N2O), hydrofluorocarbons (HFCs),
perfluorocarbons (PFCs), and sulfur hexafluoride (SF6).
Mobile sources emitted 31 percent of all U.S. GHGs in 2007
(transportation sources, which do not include certain off-highway
sources, account for 28 percent) and have been the fastest-growing
source of U.S. GHGs since 1990.\10\ Mobile sources addressed in the
recent endangerment and contribution findings under CAA section
202(a)--light-duty vehicles, heavy-duty trucks, buses, and
motorcycles--accounted for 23 percent of all U.S. GHG emissions in
2007.\11\ Heavy-duty vehicles emit CO2, CH4,
N2O, and HFCs and are responsible for nearly 19 percent of
all mobile source GHGs (nearly 6% of all U.S. GHGs) and about 25
percent of section 202(a) mobile source GHGs. For heavy-duty vehicles
in 2007, CO2 emissions represented more than 99 percent of
all GHG emissions (including HFCs).\12\
---------------------------------------------------------------------------
\9\ U.S. EPA. (2009). ``Technical Support Document for
Endangerment and Cause or Contribute Findings for Greenhouse Gases
Under Section 202(a) of the Clean Air Act'' Washington, DC,
available at Docket: EPA-HQ-OAR-2009-0171-11645, and at http://epa.gov/climatechange/endangerment.html.
\10\ U.S. Environmental Protection Agency. 2009. Inventory of
U.S. Greenhouse Gas Emissions and Sinks: 1990-2007. EPA 430-R-09-
004. Available at http://epa.gov/climatechange/emissions/downloads09/GHG2007entire_report-508.pdf .
\11\ See Endangerment TSD, Note 9, above, at pp. 180-194.
\12\ U.S. Environmental Protection Agency. 2009. Inventory of
U.S. Greenhouse Gas Emissions and Sinks: See Note 10, above.
---------------------------------------------------------------------------
Setting fuel consumption standards for the heavy-duty sector,
pursuant to NHTSA's EISA authority, will also improve our energy
security by reducing our dependence on foreign oil, which has been a
national objective since the first oil price shocks in the 1970s. Net
petroleum imports now account for approximately 60 percent of U.S.
petroleum consumption. World crude oil production is highly
concentrated, exacerbating the risks of supply disruptions and price
shocks. Tight global oil markets led to prices over $100 per barrel in
2008, with gasoline reaching as high as $4 per gallon in many parts of
the United States, causing financial hardship for many families and
businesses. The export of U.S. assets for oil imports continues to be
an important component of the historically unprecedented U.S. trade
deficits. Transportation accounts for about 72 percent of U.S.
petroleum consumption. Heavy-duty vehicles account for about 17 percent
of transportation oil use, which means that they alone account for
about 12 percent of all U.S. oil consumption.\13\
---------------------------------------------------------------------------
\13\ In 2009 Source: EIA Annual Energy Outlook 2010 released May
11, 2010.
---------------------------------------------------------------------------
In developing this joint proposal, the agencies have worked with a
large and diverse group of stakeholders representing truck and engine
manufacturers, trucking fleets, environmental organizations, and States
including the State of California.\14\ While our discussions covered a
wide range of issues and viewpoints, one widespread recommendation was
that the two agencies should develop a common Federal program with
consistent standards of performance regarding fuel consumption and GHG
emissions. The HD National Program we are proposing in this notice is
consistent with that goal. Further it is our expectation based on our
ongoing work with the State of California that the California ARB will
be able to adopt regulations equivalent in practice to those of this HD
National Program, just as it has done for past EPA regulation of heavy-
duty trucks and engines. NHTSA and EPA are committed to continuing to
work with California ARB throughout this rulemaking process to help
ensure our final rules can lead to that outcome.
---------------------------------------------------------------------------
\14\ Pursuant to DOT Order 2100.2, NHTSA will place a memorandum
recording those meetings that it attended and documents submitted by
stakeholders which formed a basis for this proposal and which can be
made publicly available in its docket for this rulemaking. DOT Order
2100.2 is available at http://www.reg-group.com/library/DOT2100-2.PDF.
---------------------------------------------------------------------------
In light of the industry's diversity, and consistent with the
recommendations of the National Academy of Sciences (NAS) as discussed
further below, the agencies are proposing a HD National Program that
recognizes the different sizes and work requirements of this wide range
of heavy-duty vehicles and their engines. NHTSA's proposed fuel
consumption standards and EPA's proposed GHG standards would apply to
manufacturers of the following types of heavy-duty vehicles and their
engines; the proposed provisions for each of these are described in
more detail below in this section:
Heavy-Duty Pickup Trucks and Vans.
Combination Tractors.
Vocational Vehicles.
As in the recent light-duty vehicle rule establishing CAFE and GHG
standards for MYs 2012-2016 light-duty vehicles, EPA's and NHTSA's
proposed standards for the heavy-duty sector are largely harmonized
with one another due to the close and direct relationship between
improving the fuel efficiency of these vehicles and reducing their
CO2 tailpipe emissions. For all vehicles that consume
carbon-based fuels, the amount of CO2 emissions is
essentially constant per gallon for a given type of fuel that is
consumed. The more efficient a heavy-duty truck is in completing its
work, the lower its environmental impact will be, because the less fuel
consumed to move cargo a given distance, the less CO2
emitted into the air. The technologies available for improving fuel
efficiency, and therefore for reducing both CO2 emissions
and fuel consumption, are one and the same.\15\ Because of this close
technical relationship, NHTSA and EPA have been able to rely on
jointly-developed assumptions, analyses, and analytical conclusions to
support the standards and other provisions that NHTSA and EPA are
proposing under our separate legal authorities.
---------------------------------------------------------------------------
\15\ However, as discussed below, in addition to addressing
CO2, the EPA's proposed standards also include provisions
to address other GHGs (nitrous oxide, methane, and air conditioning
refrigerant emissions), as required by the Endangerment Finding
under the CAA. See Section II.
---------------------------------------------------------------------------
The timelines for the implementation of the proposed NHTSA and EPA
standards are also closely coordinated. EPA's proposed GHG emission
standards would begin in model year 2014. In order to provide for the
four full model years of regulatory lead time required by EISA, as
discussed in Section I.B.(5) below, NHTSA's proposed fuel consumption
standards would be voluntary in model years 2014 and 2015, becoming
mandatory in model year 2016, except for diesel engine standards which
would be voluntary in model years 2014, 2015 and 2016, becoming
mandatory in model year 2017. Both agencies are also allowing early
compliance in model year 2013. A detailed discussion of how the
proposed standards are consistent with each agency's respective
statutory requirements and authorities is found later in this notice.
Neither EPA nor NHTSA is proposing standards at this time for GHG
emissions or fuel consumption, respectively, for heavy-duty commercial
trailers or for vehicles or engines manufactured by small businesses.
However, the agencies are considering proposing such standards in a
future rulemaking, and request comment on such an action later in this
preamble.
B. Building Blocks of the Heavy-Duty National Program
The standards that are being proposed in this notice represent the
first time
[[Page 74158]]
that NHTSA and EPA would regulate the heavy-duty sector for fuel
consumption and GHG emissions, respectively. The proposed HD National
Program is rooted in EPA's prior regulatory history, the SmartWay[reg]
Transport Partnership program, and extensive technical and engineering
analyses done at the Federal level. This section summarizes some of the
most important of these precursors and foundations for this HD National
Program.
(1) EPA's Traditional Heavy-Duty Regulatory Program
Since the 1980s, EPA has acted several times to address tailpipe
emissions of criteria pollutants and air toxics from heavy-duty
vehicles and engines. During the last 18 years, these programs have
primarily addressed emissions of particulate matter (PM) and the
primary ozone precursors, hydrocarbons (HC) and oxides of nitrogen
(NOX). These programs have successfully achieved significant
and cost-effective reductions in emissions and associated health and
welfare benefits to the nation. They have been structured in ways that
account for the varying circumstances of the engine and truck
industries. As required by the CAA, the emission standards implemented
by these programs include standards that apply at the time that the
vehicle or engine is sold as well as standards that apply in actual
use. As a result of these programs, new vehicles meeting current
emission standards will emit 98% less NOX and 99% less PM
than new trucks 20 years ago. The resulting emission reductions provide
significant public health and welfare benefits. The most recent EPA
regulations which were fully phased-in in 2010 are projected to provide
greater than $70 billion in health and welfare benefits annually in
2030 alone (66 FR 5002, January 18, 2001).
EPA's overall program goal has always been to achieve emissions
reductions from the complete vehicles that operate on our highways. The
agency has often accomplished this goal for many heavy-duty truck
categories through the regulation of heavy-duty engine emissions. A key
part of this success has been the development over many years of a
well-established, representative, and robust set of engine test
procedures that industry and EPA now routinely use to measure emissions
and determine compliance with emission standards. These test procedures
in turn serve the overall compliance program that EPA implements to
help ensure that emissions reductions are being achieved. By isolating
the engine from the many variables involved when the engine is
installed and operated in a HD vehicle, EPA has been able to accurately
address the contribution of the engine alone to overall emissions. The
agencies discuss below how the proposed program incorporates the
existing engine-based approach used for criteria emissions regulations,
as well as new vehicle-based approaches.
(2) NHTSA's Responsibilities To Regulate Heavy-Duty Fuel Efficiency
Under EISA
With the passage of the EISA in December 2007, Congress laid out a
framework developing the first fuel efficiency regulations for HD
vehicles. As codified at 49 U.S.C. 32902(k), EISA requires NHTSA to
develop a regulatory system for the fuel economy of commercial medium-
duty and heavy-duty on-highway vehicles and work trucks in three steps:
A study by NAS, a study by NHTSA, and a rulemaking to develop the
regulations themselves.\16\
---------------------------------------------------------------------------
\16\ The NAS study is described below, and the NHTSA study
accompanies this NPRM.
---------------------------------------------------------------------------
Specifically, section 102 of EISA, codified at 49 U.S.C.
32902(k)(2), states that not later than two years after completion of
the NHTSA study, DOT (by delegation, NHTSA), in consultation with the
Department of Energy (DOE) and EPA, shall develop a regulation to
implement a ``commercial medium-duty and heavy-duty on-highway vehicle
and work truck fuel efficiency improvement program designed to achieve
the maximum feasible improvement.'' NHTSA interprets the timing
requirements as permitting a regulation to be developed earlier, rather
than as requiring the agency to wait a specified period of time.
Congress specified that as part of the ``HD fuel efficiency
improvement program designed to achieve the maximum feasible
improvement,'' NHTSA must adopt and implement:
Appropriate test methods;
Measurement metrics;
Fuel economy standards; \17\ and
---------------------------------------------------------------------------
\17\ In the context of 49 U.S.C. 32902(k), NHTSA interprets
``fuel economy standards'' as referring not specifically to miles
per gallon, as in the light-duty vehicle context, but instead more
broadly to account as accurately as possible for MD/HD fuel
efficiency. While it is a metric that NHTSA considered for setting
MD/HD fuel efficiency standards, the agency recognizes that miles
per gallon may not be an appropriate metric given the work that MD/
HD vehicles are manufactured to do. NHTSA is thus proposing
alternative metrics as discussed further below.
---------------------------------------------------------------------------
Compliance and enforcement protocols.
Congress emphasized that the test methods, measurement metrics,
standards, and compliance and enforcement protocols must all be
appropriate, cost-effective, and technologically feasible for
commercial medium-duty and heavy-duty on-highway vehicles and work
trucks. NHTSA notes that these criteria are different from the ``four
factors'' of 49 U.S.C. 32902(f) \18\ that have long governed NHTSA's
setting of fuel economy standards for passenger cars and light trucks,
although many of the same factors are considered under each of these
provisions.
---------------------------------------------------------------------------
\18\ 49 U.S.C. 32902(f) states that ``When deciding maximum
feasible average fuel economy under this section, [NHTSA] shall
consider technological feasibility, economic practicability, the
effect of other motor vehicle standards of the Government on fuel
economy, and the need of the United States to conserve energy.''
---------------------------------------------------------------------------
Congress also stated that NHTSA may set separate standards for
different classes of HD vehicles, which the agency interprets broadly
to allow regulation of HD engines in addition to HD vehicles, and
provided requirements new to 49 U.S.C. 32902 in terms of timing of
regulations, stating that the standards adopted as a result of the
agency's rulemaking shall provide not less than four full model years
of regulatory lead time, and three full model years of regulatory
stability.
(3) National Academy of Sciences Report on Heavy-Duty Technology
As mandated by Congress in EISA, the National Research Council
(NRC) under NAS recently issued a report to NHTSA and to Congress
evaluating medium-duty and heavy-duty truck fuel efficiency improvement
opportunities, titled ``Technologies and Approaches to Reducing the
Fuel Consumption of Medium- and Heavy-Duty Vehicles.'' \19\ This study
covers the same universe of heavy-duty vehicles that is the focus of
this proposed rulemaking--all highway vehicles that are not light-duty,
MDPVs, or motorcycles. The agencies have carefully evaluated the
research supporting this report and its recommendations and have
incorporated them to the extent practicable in the development of this
rulemaking. NHTSA's and EPA's detailed assessments of each of the
relevant recommendations of the NAS
[[Page 74159]]
report are discussed in Section X of this preamble and in the NHTSA HD
study accompanying this notice of proposed rulemaking (NPRM).
---------------------------------------------------------------------------
\19\ Committee to Assess Fuel Economy Technologies for Medium-
and Heavy-Duty Vehicles; National Research Council; Transportation
Research Board (2010). ``Technologies and Approaches to Reducing the
Fuel Consumption of Medium- and Heavy-Duty Vehicles,'' (hereafter,
``NAS Report''). Washington, DC, The National Academies Press.
Available electronically from the National Academies Press Web site
at http://www.nap.edu/catalog.php?record--id=12845 (last accessed
September 10, 2010).
---------------------------------------------------------------------------
(4) The Recent NHTSA and EPA Light-Duty National GHG Program
On April 1, 2010, EPA and NHTSA finalized the first-ever National
Program for light-duty cars and trucks, which set GHG emissions and
fuel economy standards for model years 2012-2016. The agencies have
used the light-duty National Program as a model for this proposed HD
National Program in many respects. This is most apparent in the case of
heavy-duty pickups and vans, which are very similar to the light-duty
trucks addressed in the light-duty National Program both
technologically as well as in terms of how they are manufactured (i.e.,
the same company often makes both the vehicle and the engine). For
these vehicles, there are close parallels to the light-duty program in
how the agencies have developed our respective proposed standards and
compliance structures, although in this proposal each agency proposes
standards based on attributes other than vehicle footprint, as
discussed below.
Due to the diversity of the remaining HD vehicles, there are fewer
parallels with the structure of the light-duty program. However, the
agencies have maintained the same collaboration and coordination that
characterized the development of the light-duty program. Most notably,
as with the light-duty program, manufacturers will be able to design
and build to meet a closely coordinated Federal program, and avoid
unnecessarily duplicative testing and compliance burdens.
(5) EPA's SmartWay Program
EPA's voluntary SmartWay Transport Partnership program encourages
shipping and trucking companies to take actions that reduce fuel
consumption and CO2 by working with the shipping community
and the freight sector to identify low carbon strategies and
technologies, and by providing technical information, financial
incentives, and partner recognition to accelerate the adoption of these
strategies. Through the SmartWay program, EPA has worked closely with
truck manufacturers and truck fleets to develop test procedures to
evaluate vehicle and component performance in reducing fuel consumption
and has conducted testing and has established test programs to verify
technologies that can achieve these reductions. Over the last six
years, EPA has developed hands-on experience testing the largest heavy-
duty trucks and evaluating improvements in tire and vehicle aerodynamic
performance. In 2010, according to vehicle manufacturers, approximately
five percent of new combination heavy-duty trucks will meet the
SmartWay performance criteria demonstrating that they represent the
pinnacle of current heavy-duty truck reductions in fuel consumption.
In developing this HD National Program, the agencies have drawn
from the SmartWay experience, as discussed in detail both in Sections
II and III below (e.g., developing test procedures to evaluate trucks
and truck components) but also in the draft RIA (estimating performance
levels from the application of the best available technologies
identified in the SmartWay program). These technologies provide part of
the basis for the GHG emission and fuel consumption standards proposed
in this rulemaking for certain types of new heavy-duty Class 7 and 8
combination tractors.
In addition to identifying technologies, the SmartWay program
includes operational approaches that truck fleet owners as well as
individual drivers and their freight customers can incorporate, that
the NHTSA and EPA believe will complement the proposed standards. These
include such approaches as improved logistics and driver training, as
discussed in the draft RIA. This approach is consistent with the one of
the three alternative approaches that the NAS recommended be
considered. The three approaches were raising fuel taxes, liberalizing
truck size and weight restrictions, and encouraging incentives to
disseminate information to inform truck drivers about the relationship
between driving behavior and fuel savings. Taxes and truck size and
weight limits are mandated by public law; as such, these options are
outside EPA's and NHTSA's authority to implement. However,
complementary operational measures like driver training, which SmartWay
does promote, can complement the proposed standards and also provide
benefits for the existing truck fleet, furthering the public policy
objectives of addressing energy security and climate change.
(6.) Canada's Department of the Environment
The Government of Canada's Department of the Environment
(Environment Canada) assisted EPA's development of this proposed
rulemaking, by conducting emissions testing of heavy-duty vehicles at
Environment Canada test facilities to gather data on a range of
possible test cycles.
We expect the technical collaboration with Environment Canada to
continue as we address issues raised by stakeholders in response to
this NPRM, and as we continue to develop details of certain testing and
compliance verification procedures. We may also be able to begin to
develop a knowledge base enabling improvement upon this regulatory
framework for model years beyond 2018 (for example, improvements to the
means of demonstrating compliance). We also expect to continue our
collaboration with Environment Canada on compliance issues.
C. Summary of the Proposed EPA and NHTSA HD National Program
When EPA first addressed emissions from heavy-duty trucks in the
1980s, it established standards for engines, based on the amount of
work performed (grams of pollutant per unit of work, expressed as grams
per brake horsepower-hour or g/bhp-hr).\20\ This approach recognized
the fact that engine characteristics are the dominant determinant of
the types of emissions generated, and engine-based technologies
(including exhaust aftertreatment systems) need to be the focus for
addressing those emissions. Vehicle-based technologies, in contrast,
have less influence on overall truck emissions of the pollutants that
EPA has regulated in the past. The engine testing approach also
recognized the relatively small number of distinct heavy-duty engine
designs, as compared to the extremely wide range of truck designs. EPA
concluded at that time that any incremental gain in conventional
emission control that could be achieved through regulation of the
complete vehicle would be small in comparison to the cost of addressing
the many variants of complete trucks that make up the heavy-duty
sector--smaller and larger vocational vehicles for dozens of purposes,
various designs of combination tractors, and many others.
---------------------------------------------------------------------------
\20\ The term ``brake power'' refers to engine torque and power
as measured at the interface between the engine's output shaft and
the dynamometer. This contrasts with ``indicated power'', which is a
calculated value based on the pressure dynamics in the combustion
chamber, not including internal losses that occur due to friction
and pumping work. Since the measurement procedure inherently
measures brake torque and power, the proposed regulations refer
simply to g/hp-hr. This is consistent with our other emission
control programs, which generally include standards in g/kW-hr.
---------------------------------------------------------------------------
Addressing GHG emissions and fuel consumption from heavy-duty
trucks, however, requires a different approach. Reducing GHG emissions
and fuel consumption requires increasing the
[[Page 74160]]
inherent efficiency of the engine as well as making changes to the
vehicles to reduce the amount of work that the engine needs to do per
mile traveled. This thus requires a focus on the entire vehicle. For
example, in addition to the basic emissions and fuel consumption levels
of the engine, the aerodynamics of the vehicle can have a major impact
on the amount of work that must be performed to transport freight at
common highway speeds. The 2010 NAS Report recognized this need and
recommended a complete-vehicle approach to regulation. As described
elsewhere in this preamble, the proposed standards that make up the HD
National Program aim to address the complete vehicle, to the extent
practicable and appropriate under the agencies' respective statutory
authorities, through complementary engine and vehicle standards, in
order to reduce the complexity of the regulatory system and achieve the
greatest gains as soon as possible.
(1) Brief Overview of the Heavy-Duty Truck Industry
The heavy-duty truck sector spans a wide range of vehicles with
often unique form and function. A primary indicator of the extreme
diversity among heavy-duty trucks is the range of load-carrying
capability across the industry. The heavy-duty truck sector is often
subdivided by vehicle weight classifications, as defined by the
vehicle's gross vehicle weight rating (GVWR), which is a measure of the
combined curb (empty) weight and cargo carrying capacity of the
truck.\21\ Table I-1 below outlines the vehicle weight classifications
commonly used for many years for a variety of purposes by businesses
and by several Federal agencies, including the Department of
Transportation, the Environmental Protection Agency, the Department of
Commerce, and the Internal Revenue Service.
---------------------------------------------------------------------------
\21\ GVWR describes the maximum load that can be carried by a
vehicle, including the weight of the vehicle itself. Heavy-duty
vehicles also have a gross combined weight rating (GCWR), which
describes the maximum load that the vehicle can haul, including the
weight of a loaded trailer and the vehicle itself.
[GRAPHIC] [TIFF OMITTED] TP30NO10.001
In the framework of these vehicle weight classifications, the
heavy-duty truck sector refers to Class 2b through Class 8 vehicles and
the engines that power those vehicles.\22\ Unlike light-duty vehicles,
which are primarily used for transporting passengers for personal
travel, heavy-duty vehicles fill much more diverse operator needs.
Heavy-duty pickup trucks and vans (Classes 2b and 3) are used chiefly
as work truck and vans, and as shuttle vans, as well as for personal
transportation, with an average annual mileage in the range of 15,000
miles. The rest of the heavy-duty sector is used for carrying cargo
and/or performing specialized tasks. Commercial ``vocational''
vehicles, which may span Classes 2b through 8, vary widely in size,
including smaller and larger van trucks, utility ``bucket'' trucks,
tank trucks, refuse trucks, urban and over-the-road buses, fire trucks,
flat-bed trucks, and dump trucks, among others. The annual mileage of
these trucks is as varied as their uses, but for the most part tends to
fall in between heavy-duty pickups/vans and the large combination
tractors, typically from 15,000 to 150,000 miles per year, although
some travel more and some less. Class 7 and 8 combination tractor-
trailers--some equipped with sleeper cabs and some not--are primarily
used for freight transportation. They are sold as tractors and
sometimes run without a trailer in between loads, but most of the time
they run with one or more trailers that can carry up to 50,000 pounds
or more of payload, consuming significant quantities of fuel and
producing significant amounts of GHG emissions. The combination
tractor-trailers used in combination applications can travel more than
150,000 miles per year.
---------------------------------------------------------------------------
\22\ Class 2b vehicles designed as passenger vehicles (Medium
Duty Passenger Vehicles, MDPVs) are covered by the light-duty GHG
and fuel economy standards and not addressed in this rulemaking.
---------------------------------------------------------------------------
EPA and NHTSA have designed our respective proposed standards in
careful consideration of the diversity and complexity of the heavy-duty
truck industry, as discussed next.
(2) Summary of Proposed EPA GHG Emission Standards and NHTSA Fuel
Consumption Standards
As described above, NHTSA and EPA recognize the importance of
addressing the entire vehicle in reducing fuel consumption and GHG
emissions. At the same time, the agencies understand that the
complexity of the industry means that we will need to use different
approaches to achieve this goal, depending on the characteristics of
each general type of truck. We are therefore proposing to divide the
industry into three discrete regulatory categories for purposes of
setting our respective standards--combination tractors, heavy-duty
pickups and vans, and vocational vehicles--based on the relative degree
of homogeneity among trucks within each category. For each regulatory
category, the agencies are proposing related but distinct program
approaches reflecting the specific challenges that we see for
manufacturers in these segments. In the following paragraphs, we
discuss EPA's proposed GHG emission standards and NHTSA's proposed fuel
consumption standards for the three regulatory categories of heavy-duty
vehicles and their engines.
The agencies are proposing test metrics that express fuel
consumption and GHG emissions relative to the most important measures
of heavy-duty truck utility for each segment, consistent with the
recommendation of the 2010 NAS Report that metrics should reflect and
account for the work performed by various types of HD vehicles. This
approach differs from NHTSA's light-duty program that uses fuel economy
as the basis. The NAS committee discussed the difference between fuel
economy (a measure of how far a vehicle will go on a gallon of fuel)
and fuel consumption (the inverse measure, of how much fuel is consumed
in driving a given distance) as potential metrics for MD/HD
regulations. The committee concluded that fuel economy would not be a
good metric for judging the fuel efficiency of a heavy-duty vehicle,
and stated that NHTSA should alternatively consider fuel consumption as
the basis for its standards. As a result, for heavy-duty
[[Page 74161]]
pickup trucks and vans, EPA and NHTSA are proposing standards on a per-
mile basis (g/mile for the EPA standards, gallons/100 miles for the
NHTSA standards), as explained in Section I.C.(2)(b) below. For heavy-
duty trucks, both combination and vocational, the agencies are
proposing standards expressed in terms of the key measure of freight
movement, tons of payload miles or, more simply, ton-miles. Hence, for
EPA the proposed standards are in the form of the mass of emissions
from carrying a ton of cargo over a distance of one mile (g/ton-mi)).
Similarly, the proposed NHTSA standards are in terms of gallons of fuel
consumed over a set distance (one thousand miles), or gal/1,000 ton-
mile. Finally, for engines, EPA is proposing standards in the form of
grams of emissions per unit of work (g/bhp-hr), the same metric used
for the heavy-duty highway engine standards for criteria pollutants
today. Similarly, NHTSA is proposing standards for heavy-duty engines
in the form of gallons of fuel consumption per 100 units of work (gal/
100 bhp-hr).
Section II below discusses the proposed EPA and NHTSA standards in
greater detail.
(a) Class 7 and 8 Combination Tractors
Class 7 and 8 combination tractors and their engines contribute the
largest portion of the total GHG emissions and fuel consumption of the
heavy-duty sector, approximately 65 percent, due to their large
payloads, their high annual miles traveled, and their major role in
national freight transport.\23\ These vehicles consist of a cab and
engine (tractor or combination tractor) and a detachable trailer. In
general, reducing GHG emissions and fuel consumption for these vehicles
would involve improvements such as aerodynamics and tires and reduction
in idle operation, as well as engine-based efficiency improvements.
---------------------------------------------------------------------------
\23\ The vast majority of combination tractor-trailers are used
in highway applications, and these vehicles are the focus of this
proposed program. A small fraction of combination tractors are used
in off-road applications and are treated differently, as described
in Section II.
---------------------------------------------------------------------------
In general, the heavy-duty combination tractor industry consists of
tractor manufacturers (which manufacture the tractor and purchase and
install the engine) and trailer manufacturers. These manufacturers are
usually separate from each other. We are not aware of any manufacturer
that typically assembles both the finished truck and the trailer and
introduces the combination into commerce for sale to a buyer. The
owners of trucks and trailers are often distinct as well. A typical
truck buyer will purchase only the tractor. The trailers are usually
purchased and owned by fleets and shippers. This occurs in part because
trucking fleets on average maintain 3 trailers per tractor and in some
cases as many as 6 or more trailers per tractor. There are also large
differences in the kinds of manufacturers involved with producing
tractors and trailers. For HD highway tractors and their engines, a
relatively limited number of manufacturers produce the vast majority of
these products. The trailer manufacturing industry is quite different,
and includes a large number of companies, many of which are relatively
small in size and production volume. Setting standards for the products
involved--tractors and trailers--requires recognition of the large
differences between these manufacturing industries, which can then
warrant consideration of different regulatory approaches.
Based on these industry characteristics, EPA and NHTSA believe that
the most straightforward regulatory approach for combination tractors
and trailers is to establish standards for tractors separately from
trailers. As discussed below in Section IX, the agencies are proposing
standards for the tractors and their engines in this rulemaking, but
are not proposing standards for trailers in this rulemaking. The
agencies are requesting comment on potential standards for trailers,
but will address standards for trailers in a separate rulemaking.
As with the other regulatory categories of heavy-duty vehicles, EPA
and NHTSA have concluded that achieving reductions in GHG emissions and
fuel consumption from combination tractors requires addressing both the
cab and the engine, and EPA and NHTSA each are proposing standards that
reflect this conclusion. The importance of the cab is that its design
determines the amount of power that the engine must produce in moving
the truck down the road. As illustrated in Figure I-1, the loads that
require additional power from the engine include air resistance
(aerodynamics), tire rolling resistance, and parasitic losses
(including accessory loads and friction in the drivetrain). The
importance of the engine design is that it determines the basic GHG
emissions and fuel consumption performance of the engine for the
variety of demands placed on the engine, regardless of the
characteristics of the cab in which it is installed. The agencies
intend for the proposed standards to result in the application of
improved technologies for lower GHG emissions and fuel consumption for
both the cab and the engine.
[[Page 74162]]
[GRAPHIC] [TIFF OMITTED] TP30NO10.002
Accordingly, for Class 7 and 8 combination tractors, the agencies
are each proposing two sets of standards. For vehicle-related emissions
and fuel consumption, the agencies are proposing that tractor
manufacturers meet respective vehicle-based standards. Compliance with
the vehicle standard would typically be determined based on a
customized vehicle simulation model, called the Greenhouse gas
Emissions Model (GEM), which is consistent with the NAS Report
recommendations to require compliance testing for combination tractors
using vehicle simulation rather than chassis dynamometer testing. This
compliance model was developed by EPA specifically for this proposal.
It is an accurate and cost-effective alternative to measuring emissions
and fuel consumption while operating the vehicle on a chassis
dynamometer. Instead of using a chassis dynamometer as an indirect way
to evaluate real-world operation and performance, various
characteristics of the vehicle are measured and these measurements are
used as inputs to the model. These characteristics relate to key
technologies appropriate for this subcategory of truck--including
aerodynamic features, weight reductions, tire rolling resistance, the
presence of idle-reducing technology, and vehicle speed limiters. The
model would also assume the use of a representative typical engine,
rather than a vehicle-specific engine, because engines are regulated
separately and include an averaging, banking, and trading program
separate from the vehicle program. The model and appropriate inputs
would be used to quantify the overall performance of the vehicle in
terms of CO2 emissions and fuel consumption. The model's
development and design, as well as the sources for inputs and the
evaluation of the model's accuracy, are discussed in detail in Section
II below and in Chapter 4 of the draft RIA.
---------------------------------------------------------------------------
\24\Adapted from, Figure 4.1. Class 8 Truck Energy Audit,
Technology Roadmap for the 21st Century Truck Program: A Government-
Industry Research Partnership, 21CT-001, December 2000.
---------------------------------------------------------------------------
EPA and NHTSA also considered developing respective alternative
standards based on the direct testing of the emissions and fuel
consumption of the entire vehicle for this category of vehicles, as
measured using a chassis test procedure. This would be similar to the
proposed approach for standards for HD pickups and vans discussed
below. The agencies believe that such an approach warrants continued
consideration. However, the agencies are not prepared to propose
chassis-test-based standards at this time, primarily because of the
very small number of chassis-test facilities that currently exist, but
rather are proposing only the tractor standards and the engine-based
standards discussed above. The agencies seek comment on the potential
benefits and trade-offs of chassis-test-based standards for combination
tractors.
(1) Proposed Standards for Class 7 and 8 Combination Tractors
The vehicle standards that EPA and NHTSA are proposing for Class 7
and 8 combination tractor manufacturers are based on several key
attributes related to GHG emissions and fuel consumption that we
believe reasonably represent the many differences in utility among
these vehicles. The proposed standards differ depending on GVWR (i.e.,
whether the truck is Class 7 or Class 8), the height of the roof of the
cab, and whether it is a ``day cab'' or a ``sleeper cab.'' These later
two attributes are important because the height of the roof, designed
to correspond to the height of the trailer, significantly affects air
resistance, and a sleeper cab generally corresponds to the opportunity
for extended duration idle emission and fuel consumption improvements.
Thus, the agencies have created nine subcategories within the Class
7 and 8 combination tractor category based on the differences in
expected emissions and fuel consumption associated with the key
attributes of GVWR, cab type, and roof height. Table I-2 presents the
agencies' respective proposed standards for combination tractor
manufacturers for the 2017 model year for illustration.
BILLING CODE 6560-50-P
[[Page 74163]]
[GRAPHIC] [TIFF OMITTED] TP30NO10.003
In addition, the agencies are proposing separate performance
standards for the engines manufactured for use in these trucks. EPA's
proposed engine-based CO2 standards and NHTSA's proposed
engine-based fuel consumption standards would vary based on the
expected weight class and usage of the truck into which the engine
would be installed. EPA is also proposing engine-based N2O
and CH4 standards for manufacturers of the engines used in
combination tractors. EPA is proposing separate engine-based standards
for these GHGs because the agency believes that N2O and
CH4 emissions are technologically related solely to the
engine, fuel, and emissions aftertreatment systems, and the agency is
not aware of any influence of vehicle-based technologies on these
emissions. However, NHTSA is not incorporating standards related to
these GHGs due to their lack of influence on fuel consumption. EPA
expects that manufacturers of current engine technologies would be able
to comply with the proposed ``cap'' standards with little or no
technological improvements; the value of the standards would be to
prevent significant increases in these emissions as alternative
technologies are developed and introduced in the future. Compliance
with the proposed EPA engine-based CO2 standards and the
proposed NHTSA fuel consumption standards, as well as the proposed EPA
N2O and CH4 standards, would be determined using
the appropriate EPA engine test procedure, as discussed in Section II
below.
As with the other categories of heavy-duty vehicles, EPA and NHTSA
are proposing respective standards that would apply to Class 7 and 8
trucks at the time of production (as in Table I-2, above). In addition,
EPA is proposing separate standards that would apply for a specified
period of time in use. All of the proposed standards for these trucks,
as well as details about the proposed provisions for certification and
implementation of these standards, are discussed in more detail in
Sections II, III, IV, and V below and in the draft RIA.
(ii) EPA Proposed Air Conditioning Leakage Standard for Class 7 and 8
Combination Tractors
In addition to the proposed EPA tractor- and engine-based standards
for CO2 and engine-based standards for N2O, and
CH4 emissions, EPA is also proposing a separate standard to
reduce leakage of HFC refrigerant from cabin air conditioning systems
from combination tractors, to apply to the tractor manufacturer. This
standard would be independent of the CO2 tractor standard,
as discussed below. Because the current refrigerant used widely in all
these systems has a very high global warming potential, EPA is
concerned about leakage of refrigerant over time.\25\
---------------------------------------------------------------------------
\25\ The global warming potential for HFC-134a refrigerant of
1430 used in this proposal is consistent with the Intergovernmental
Panel on Climate Change Fourth Assessment Report.
---------------------------------------------------------------------------
Because the interior volume to be cooled for most of these truck
cabins is similar to that of light-duty trucks, the size and design of
current truck A/C systems is also very similar. The proposed compliance
approach for Class 7 and 8 tractors is therefore similar to that in the
light-duty rule in that these proposed standards are design-based.
Manufacturers would choose technologies from a menu of leak-reducing
technologies sufficient to comply with the standard, as opposed to
using a test to measure performance.
However, the proposed heavy-duty A/C provisions differ in two
important ways from those established in the light-duty rule. First,
the light-duty provisions were established as voluntary ways to
generate credits towards the CO2 g/mi standard, and EPA took
into account the expected use of such credits in establishing the
CO2 emissions standards. In this rule, EPA is proposing that
manufacturers actually meet a standard--as opposed to having the
opportunity to earn a credit--for A/C refrigerant leakage. Thus, for
this rule, refrigerant leakage is not accounted for in the development
of the proposed CO2 standards. We are taking this approach
here recognizing that while the benefits of leakage control are almost
identical between light-duty and heavy-duty vehicles on a per vehicle
basis, these benefits on a per mile basis expressed as a percentage of
overall GHG emissions are much smaller for heavy-duty vehicles due to
their much higher CO2 emissions rates and higher annual
mileage when compared to light-duty vehicles. Hence a credit-based
approach as done for light-duty vehicles would provide less motivation
for manufacturers to install low leakage systems even though such
systems represent a highly cost effective means to control GHG
emissions. The second difference relates the expression of the leakage
rate. The light-duty A/C leakage standard is expressed in terms of
grams per year. For this heavy-duty rule, however, because of the wide
variety of system designs and arrangements, a one-size-fits-all gram
per year standard would likely be much less relevant, so EPA believes
it is more appropriate to propose a standard in terms of percent of
total refrigerant leakage per year. This requires the total refrigerant
capacity of
[[Page 74164]]
the A/C system to be taken into account in determining compliance. EPA
believes that this proposed approach--a standard instead of a credit,
and basing the standard on percent leakage over time--is more
appropriate for heavy-duty tractors than the light-duty vehicle
approach and that it will achieve the desired reductions in refrigerant
leakage. Compliance with the standard would be determined through a
showing by the tractor manufacturer that its A/C system incorporated a
combination of low-leak technologies sufficient to meet the percent
leakage of the standard. This proposed ``menu'' of technologies is very
similar to that established in the light-duty GHG rule.\25\
---------------------------------------------------------------------------
\25\ At this time, EPA is considering approval of an alternative
refrigerant, HFO-1234yf, which has a very low GWP. The proposed A/C
leakage standard is designed to account for use of an alternative,
low-GWP refrigerant. If in the future this refrigerant is approved
and if it becomes widespread as a substitute for HFC-134a in mobile
A/C systems, EPA may propose to revise or eliminate the leakage
standard.
---------------------------------------------------------------------------
Finally, EPA is not proposing an A/C system efficiency standard in
this heavy-duty rulemaking, although an efficiency credit was a part of
the light-duty rule. The much larger emissions of CO2 from a
heavy-duty tractor as compared to those from a light-duty vehicle mean
that the relative amount of CO2 that could be reduced
through A/C efficiency improvements is very small. We request comment
on this decision and whether EPA should reflect A/C system efficiency
in the final program either as a credit or a stand-alone standard based
on the same technologies and performance levels as the light-duty
program.
A more detailed discussion of A/C related issues is found in
Section II of this preamble.
(b) Heavy-Duty Pickup Trucks and Vans (Class 2b and 3)
Heavy-duty vehicles with GVWR between 8,501 and 10,000 lb are
classified in the industry as Class 2b motor vehicles per the Federal
Motor Carrier Safety Administration definition. As discussed above,
Class 2b includes MDPVs that are regulated by the agencies under the
light-duty vehicle program, and the agencies are not considering
additional requirements for MDPVs in this rulemaking. Heavy-duty
vehicles with GVWR between 10,001 and 14,000 lb are classified as Class
3 motor vehicles. Class 2b and Class 3 heavy-duty vehicles (referred to
in this proposal as ``HD pickups and vans'') together emit about 20
percent of today's GHG emissions from the heavy-duty vehicle sector.
About 90 percent of HD pickups and vans are \3/4\-ton and 1-ton
pick-up trucks, 12- and 15-passenger vans, and large work vans that are
sold by vehicle manufacturers as complete vehicles, with no secondary
manufacturer making substantial modifications prior to registration and
use. These vehicle manufacturers are companies with major light-duty
markets in the United States, primarily Ford, General Motors, and
Chrysler. Furthermore, the technologies available to reduce fuel
consumption and GHG emissions from this segment are similar to the
technologies used on light-duty pickup trucks, including both engine
efficiency improvements (for gasoline and diesel engines) and vehicle
efficiency improvements.
For these reasons, EPA believes it is appropriate to propose GHG
standards for HD pickups and vans based on the whole vehicle, including
the engine, expressed as grams per mile, consistent with the way these
vehicles are regulated by EPA today for criteria pollutants. NHTSA
believes it is appropriate to propose corresponding gallons per 100
mile fuel consumption standards that are likewise based on the whole
vehicle. This complete vehicle approach being proposed by both agencies
for HD pickups and vans is consistent with the recommendations of the
NAS Committee in their 2010 Report. EPA and NHTSA also believe that the
structure and many of the detailed provisions of the recently finalized
light-duty GHG and fuel economy program, which also involves vehicle-
based standards, are appropriate for the HD pickup and van GHG and fuel
consumption standards as well, and this is reflected in the standards
each agency is proposing, as detailed in Section II.C. These proposed
commonalities include a new vehicle fleet average standard for each
manufacturer in each model year and the determination of these fleet
average standards based on production volume-weighted targets for each
model, with the targets varying based on a defined vehicle attribute.
Vehicle testing would be conducted on chassis dynamometers using the
drive cycles from the EPA Federal Test Procedure (Light-duty FTP or
``city'' test) and Highway Fuel Economy Test (HFET or ``highway''
test).\27\
---------------------------------------------------------------------------
\27\ The Light-duty FTP is a vehicle driving cycle that was
originally developed for certifying light-duty vehicles and
subsequently applied to HD chassis testing for criteria pollutants.
This contrasts with the Heavy-duty FTP, which refers to the
transient engine test cycles used for certifying heavy-duty engines
(with separate cycles specified for diesel and spark-ignition
engines).
---------------------------------------------------------------------------
For the light-duty GHG and fuel economy standards, the agencies
factored in vehicle size by basing the emissions and fuel economy
targets on vehicle footprint (the wheelbase times the average track
width).\28\ For those standards, passenger cars and light trucks with
larger footprints are assigned higher GHG and lower fuel economy target
levels in acknowledgement of their inherent tendency to consume more
fuel and emit more GHGs per mile. For HD pickups and vans, the agencies
believe that setting standards based on vehicle attributes is
appropriate, but feel that a weight-based metric provides a better
attribute than the footprint attribute utilized in the light-duty
vehicle rulemaking. Weight-based measures such as payload and towing
capability are key among the parameters that characterize differences
in the design of these vehicles, as well as differences in how the
vehicles will be utilized. Buyers consider these utility-based
attributes when purchasing a heavy-duty pick-up or van. EPA and NHTSA
are therefore proposing standards for HD pickups and vans based on a
``work factor'' that combines their payload and towing capabilities,
with an added adjustment for 4-wheel drive vehicles.
---------------------------------------------------------------------------
\28\ EISA requires CAFE standards for passenger cars and light
trucks to be attribute-based; see 49 U.S.C. 32902(b)(3)(A).
---------------------------------------------------------------------------
The agencies are proposing that each manufacturer's fleet average
standard would be based on production volume-weighting of target
standards for each vehicle that in turn are based on the vehicle's work
factor. These target standards would be taken from a set of curves
(mathematical functions), presented in Section II.C. EPA is also
proposing that the CO2 standards be phased in gradually
starting in the 2014 model year, at 15-20-40-60-100 percent in model
years 2014-2015-2016-2017-2018, respectively. The phase-in would take
the form of a set of target standard curves, with increasing stringency
in each model year, as detailed in Section II.C. The EPA standards
proposed for 2018 (including a separate standard to control air
conditioning system leakage) represent an average per-vehicle reduction
in GHGs of 17 percent for diesel vehicles and 12 percent for gasoline
vehicles, compared to a common baseline, as described in Sections II.C
and III.B of this preamble. Section II.C also discusses the rationale
behind the proposal of separate targets for diesel and gasoline vehicle
standards. EPA is also proposing a manufacturer's alternative
implementation schedule for
[[Page 74165]]
model years 2016-2018 that parallels and is equivalent to NHTSA's first
alternative described below.
NHTSA is proposing to allow manufacturers to select one of two fuel
consumption standards alternatives for model years 2016 and later. To
meet the EISA statutory requirement for three year regulatory
stability, the first alternative would define individual gasoline
vehicle and diesel vehicle fuel consumption target curves that would
not change for model years 2016 and later. The proposed target curves
for this alternative are presented in Section II.C. The second
alternative would use target curves that are equivalent to the EPA
program in each model year 2016 to 2018. Stringency for the
alternatives has been selected to allow a manufacturer, through the use
of the credit and deficit carry-forward provisions that the agencies
are also proposing, to rely on the same product plans to satisfy either
of these two alternatives, and also EPA requirements. NHTSA is also
proposing that manufacturers may voluntarily opt into the NHTSA HD
pickup and van program in model years 2014 or 2015. For these model
years, NHTSA's fuel consumption target curves are equivalent to EPA's
target curves.
The proposed EPA and NHTSA standard curves are based on a set of
vehicle, engine, and transmission technologies expected to be used to
meet the recently established GHG emissions and fuel economy standards
for model year 2012-2016 light-duty vehicles, with full consideration
of how these technologies would perform in heavy-duty vehicle testing
and use. All of these technologies are already in use or have been
announced for upcoming model years in some light-duty vehicle models,
and some are in use in a portion of HD pickups and vans as well. The
technologies include:
Advanced 8-speed automatic transmissions
Aerodynamic improvements
Electro-hydraulic power steering
Engine friction reductions
Improved accessories
Low friction lubricants in powertrain components
Lower rolling resistance tires
Lightweighting
Gasoline direct injection
Gasoline engine coupled cam phasing
Diesel aftertreatment optimization
Air conditioning system leakage reduction (for EPA program
only)
See Section III.B for a detailed analysis of these and other
potential technologies, including their feasibility, costs, and
effectiveness when employed for reducing fuel consumption and
CO2 emissions in HD pickups and vans.
A relatively small number of HD pickups and vans are sold by
vehicle manufacturers as incomplete vehicles, without the primary load-
carrying device or container attached. We are proposing that these
vehicles generally be regulated as Class 2b through 8 vocational
vehicles, as described in Section I.C(2)(c), because, like other
vocational vehicles, we have little information on baseline aerodynamic
performance and expectations for improvement. However, a sizeable
subset of these incomplete vehicles, often called cab-chassis vehicles,
are sold by the vehicle manufacturers in configurations with many of
the components that affect GHG emissions and fuel consumption identical
to those on complete pickup truck or van counterparts--including
engines, cabs, frames, transmissions, axles, and wheels. We are
proposing that these vehicles be included in the chassis-based HD
pickup and van program. These proposed provisions are described in
Section V.B.
In addition to proposed EPA CO2 emission standards and
the proposed NHTSA fuel consumption standards for HD pickups and vans,
EPA is also proposing standards for two additional GHGs, N2O
and CH4, as well as standards for air conditioning-related
HFC emissions. These standards are discussed in more detail in Section
II.E. Finally, EPA is proposing standards that would apply to HD
pickups and vans in use. All of the proposed standards for these HD
pickups and vans, as well as details about the proposed provisions for
certification and implementation of these standards, are discussed in
Section II.C.
(c) Class 2b-8 Vocational Vehicles
Class 2b-8 vocational vehicles consist of a wide variety of vehicle
types. Some of the primary applications for vehicles in this segment
include delivery, refuse, utility, dump, and cement trucks; transit,
shuttle, and school buses; emergency vehicles, motor homes,\29\ tow
trucks, among others. These vehicles and their engines contribute
approximately 15 percent of today's heavy-duty truck sector GHG
emissions.
---------------------------------------------------------------------------
\29\ Again, we note that NHTSA's proposed fuel consumption
standards would not apply to non-commercial vehicles like motor
homes.
---------------------------------------------------------------------------
Manufacturing of vehicles in this segment of the industry is
organized in a more complex way than that of the other heavy-duty
categories. Class 2b-8 vocational vehicles are often built as a chassis
with an installed engine and an installed transmission. Both the engine
and transmissions are typically manufactured by other manufacturers and
the chassis manufacturer purchases and installs them. Many of the same
companies that build Class 7 and 8 tractors are also in the Class 2b-8
chassis manufacturing market. The chassis is typically then sent to a
body manufacturer, which completes the vehicle by installing the
appropriate feature--such as dump bed, delivery box, or utility
bucket--onto the chassis. Vehicle body manufacturers tend to be small
businesses that specialize in specific types of bodies or specialized
features.
EPA and NHTSA are proposing that in this vocational vehicle
category the chassis manufacturers be the focus of the proposed GHG and
fuel consumption standards. They play a central role in the
manufacturing process, and the product they produce--the chassis with
engine and transmissions--includes the primary technologies that affect
emissions and fuel consumption. They also constitute a much more
limited group of manufacturers for purposes of developing a regulatory
program. In contrast, a focus on the body manufacturers would be much
less practical, since they represent a much more diverse set of
manufacturers, and the part of the vehicle that they add has a very
limited impact on opportunities to reduce GHG emissions and fuel
consumption (given the limited role that aerodynamics plays in the
types of lower speed operation typically found with vocational
vehicles). Therefore, the proposed standards in this vocational vehicle
category would apply to the chassis manufacturers of all heavy-duty
vehicles not otherwise covered by the HD pickup and van standards or
Class 7 and 8 combination tractor standards discussed above. The
agencies request comment on our proposed focus on chassis
manufacturers.
As discussed above, EPA and NHTSA have concluded that reductions in
GHG emissions and fuel consumption require addressing both the vehicle
and the engine. As discussed above for Class 7 and 8 combination
tractors, the agencies are each proposing two sets of standards for
Class 2b-8 vocational vehicles. For vehicle-related emissions and fuel
consumption, the agencies are proposing standards for chassis
manufacturers: EPA CO2 (g/ton-mile) standards and NHTSA fuel
consumption (gal/1,000 ton-mile) standards). Also as in the case of
Class 7 and 8 tractors, we propose to use GEM, a customized vehicle
simulation model, to determine compliance with the vocational vehicle
standards. The primary manufacturer-generated input
[[Page 74166]]
into the proposed compliance model for this category of trucks would be
a measure of tire rolling resistance, as discussed further below,
because tire improvements are the primary means of vehicle improvement
available at this time. The model would also assume the use of a
typical representative engine in the simulation, resulting in an
overall value for CO2 emissions and one for fuel
consumption. As is the case for combination tractors, the manufacturers
of the engines intended for vocational vehicles would be subject to
separate engine-based standards.
(i) Proposed Standards for Class 2b-8 Vocational Vehicles
Based on our analysis and research, the agencies believe that the
primary opportunity for reductions in vocational vehicle GHG emissions
and fuel consumption will be through improved engine technologies and
improved tire rolling resistance. For engines, as proposed for
combination tractors, EPA and NHTSA are proposing separate standards
for the manufacturers of engines used in Class 2b-8 vocational
vehicles. EPA's proposed engine-based CO2 standards and
NHTSA's proposed engine-based fuel consumption standards would vary
based on the expected weight class and usage of the truck into which
the engine would be installed. The agencies propose to use the
groupings EPA currently uses for other heavy-duty engine standards--
light heavy-duty, medium heavy-duty, and heavy heavy-duty, as discussed
in Section II below.
Tire rolling resistance is closely related to the weight of the
vehicle. Therefore, we propose that the vehicle-based standards for
these trucks vary according to one key attribute, GVWR. For this
initial HD rulemaking, we propose that these standards be based on the
same groupings of truck weight classes used for the engine standards--
light heavy-duty, medium heavy-duty, and heavy heavy-duty. These
groupings are appropriate for the proposed vehicle-based standards
because they parallel the general divisions among key engine
characteristics, as discussed in Section II.
The agencies intend to monitor the development of and production
feasibility of new vehicle-related GHG and fuel consumption reduction
improving technologies and consider including these technologies in
future rulemakings. As discussed below, we are including provisions to
account for and credit the use of hybrid technology as a technology
that can reduce emissions and fuel consumption. Hybrid technology can
currently be a cost-effective technology in certain specific vocational
applications, and the agencies want to recognize and promote the use of
this technology. We also are proposing a mechanism whereby credits can
be generated by use of other technologies not included in the
compliance model. (See Sections I.E and IV below.)
Table I-3 presents EPA's proposed CO2 standards and
NHTSA's proposed fuel consumption standards for chassis manufacturers
of Class 2b through Class 8 vocational vehicles for the 2017 model year
for illustrative purposes.
[GRAPHIC] [TIFF OMITTED] TP30NO10.004
At this time, NHTSA and EPA are not prepared to propose alternative
standards based on a whole-vehicle chassis test for vocational vehicles
in this initial heavy-duty rulemaking. As discussed above for
combination tractors, the primary reason is the very small number of
chassis-test facilities that currently exist. Thus, the agencies are
proposing only the compliance-model based standards and engine
standards discussed above, and seek comment on the appropriateness of
chassis-test-based standards for the vocational vehicle category.
For vocational vehicles using hybrid technology, the agencies are
proposing two specialized approaches to allow manufacturers to gain
credit for the emissions and fuel consumption reductions associated
with hybrid technology. One option to account for the reductions
associated with vocational vehicles using hybrid technology would
compare vehicle-based chassis tests with and without the hybrid
technology. The other option would allow a manufacturer to simulate the
operation of the hybrid system in an engine-based test. The options are
further discussed in Section IV.
The proposed program also provides for opportunities to generate
credits for technologies not measured by the GEM, again described more
fully in Section IV.
As mentioned above for Class 7 and 8 combination tractors, EPA
believes that N2O and CH4 emissions are
technologically related solely to the engine, fuel, and emissions
aftertreatment systems, and the agency is not aware of any influence of
vehicle-based technologies on these emissions. Therefore, for Class 2b-
8 vocational vehicles, EPA is not proposing separate vehicle-based
standards for these GHGs, but is proposing engine-based N2O
and CH4 standards for manufacturers of the engines to be
used in vocational vehicles. EPA expects that
[[Page 74167]]
manufacturers of current engine technologies would be able to comply
with the proposed ``cap'' standards with little or no technological
improvements; the value of the standards would be in that they would
prevent significant increases in these emissions as alternative
technologies are developed and introduced in the future. Compliance
with the proposed EPA engine-based CO2 standards and the
proposed NHTSA fuel consumption standards, as well as the proposed EPA
N2O and CH4 standards, would be determined using
the appropriate EPA engine test procedure, as discussed in Section II
below.
As with the other regulatory categories of heavy-duty vehicles, EPA
and NHTSA are proposing standards that would apply to Class 2b-8
vocational vehicles at the time of production, and EPA is proposing
standards for a specified period of time in use. All of the proposed
standards for these trucks, as well as details about the proposed
provisions for certification and implementation of these standards, are
discussed in more detail later in this notice and in the draft RIA.
EPA is not proposing A/C refrigerant leakage standards for Class
2b-8 vocational vehicles at this time, primarily because of the number
of entities involved in their manufacture and thus the potential for
different entities besides the chassis manufacturer to be involved in
the A/C system production and installation. EPA requests comment on how
A/C standards might practically be applied to manufacturers of
vocational vehicles.
(d) What Manufacturers Are Not Covered by the Proposed Standards?
EPA and NHTSA are proposing to temporarily defer the proposed
greenhouse gas emissions and fuel consumption standards for any
manufacturers of heavy-duty engines, manufacturers of combination
tractors, and chassis manufacturers for vocational vehicles that meet
the ``small business'' size criteria set by the Small Business
Administration. We are not aware of any manufacturers of HD pickups and
vans that meet these criteria. For each of the other categories and for
engines, we have identified a small number of manufacturers that would
appear to qualify as small businesses. The production of these
companies is small, and we believe that deferring the standards for
these companies at this time would have a negligible impact on the GHG
emission reductions and fuel consumption reductions that the program
would otherwise achieve. We request comment on our assumption that the
impact of these exemptions for small businesses will be small and
further whether it will be possible to circumvent the regulations by
creating new small businesses to displace existing manufacturers. We
discuss the specific deferral provisions in more detail in Section II.
The agencies will consider appropriate GHG emissions and fuel
consumption standards for these entities as part of a future regulatory
action.
D. Summary of Costs and Benefits of the HD National Program
This section summarizes the projected costs and benefits of the
proposed NHTSA fuel consumption and EPA GHG emissions standards. These
projections help to inform the agencies' choices among the alternatives
considered and provide further confirmation that the proposed standards
are an appropriate choice within the spectrum of choices allowable
under the agencies' respective statutory criteria. NHTSA and EPA have
used common projected costs and benefits as the bases for our
respective standards.
The agencies have analyzed in detail the projected costs and
benefits of the proposed GHG and fuel consumption standards. Table I-4
shows estimated lifetime discounted costs, benefits and net benefits
for all heavy-duty vehicles projected to be sold in model years 2014-
2018. These figures depend on estimated values for the social cost of
carbon (SCC), as described in Section VIII.G.
[GRAPHIC] [TIFF OMITTED] TP30NO10.005
[[Page 74168]]
Table I-5 shows the estimated lifetime reductions in CO2
emissions (in million metric tons (MMT)) and fuel consumption for all
heavy-duty vehicles sold in the model years 2014-2018. The values in
Table I-5 are projected lifetime totals for each model year and are not
discounted. The two agencies' standards together comprise the HD
National Program, and the agencies' respective GHG emissions and fuel
consumption standards, jointly, are the source of the benefits and
costs of the HD National Program.
Table I-5 are projected lifetime totals for each model year and are
not discounted. The two agencies' standards together comprise the HD
National Program, and the agencies' respective GHG emissions and fuel
consumption standards, jointly, are the source of the benefits and
costs of the HD National Program.
[GRAPHIC] [TIFF OMITTED] TP30NO10.007
Table I-6 shows the estimated lifetime discounted benefits for all
heavy-duty vehicles sold in model years 2014-2018. Although the
agencies estimated the benefits associated with four different values
of a one ton CO2 reduction ($5, $22, $36, $66), for the
purposes of this overview presentation of estimated benefits the
agencies are showing the benefits associated with one of these marginal
values, $22 per ton of CO2, in 2008 dollars and 2010
emissions. Table I-6 presents benefits based on the $22 value. Section
VIII.F presents the four marginal values used to estimate monetized
benefits of CO2 reductions and Section VIII presents the
program benefits using each of the four marginal values, which
represent only a partial accounting of total benefits due to omitted
climate change impacts and other factors that are not readily
monetized. The values in the table are discounted values for each model
year of vehicles throughout their projected lifetimes. The analysis
includes other economic impacts such as fuel savings, energy security,
and other externalities such as reduced accidents, congestion and
noise. However, the analysis supporting the proposal omits other
impacts such as benefits related to non-GHG emission reductions. The
lifetime discounted benefits are shown for one of four different SCC
values considered by EPA and NHTSA. The values in Table I-6 do not
include costs associated with new technology required to meet the GHG
and fuel consumption standards.
[GRAPHIC] [TIFF OMITTED] TP30NO10.008
Table I-7 shows the agencies' estimated lifetime fuel savings,
lifetime CO2 emission reductions, and the monetized net
present values of those fuel savings and CO2 emission
reductions. The gallons of fuel and CO2 emission reductions
are projected lifetime values for all vehicles sold in the model years
2014-2018. The estimated fuel savings in billions of barrels and the
GHG reductions in million metric tons of CO2 shown in Table
I-7 are totals for the five model years throughout their projected
lifetime and are not discounted. The monetized values shown in Table I-
7 are the summed values of the discounted monetized-fuel consumption
and
[[Page 74169]]
monetized-CO2 reductions for the five model years 2014-2018
throughout their lifetimes. The monetized values in Table I-7 reflect
both a 3 percent and a 7 percent discount rate as noted.
[GRAPHIC] [TIFF OMITTED] TP30NO10.009
Table I-8 shows the estimated incremental and total technology
outlays for all heavy-duty vehicles for each of the model years 2014-
2018. The technology outlays shown in Table I-8 are for the industry as
a whole and do not account for fuel savings associated with the
program.
[GRAPHIC] [TIFF OMITTED] TP30NO10.010
Table I-9 shows EPA's estimated incremental cost increase of the
average new heavy-duty vehicles for each model year 2014-2018. The
values shown are incremental to a baseline vehicle and are not
cumulative.
[GRAPHIC] [TIFF OMITTED] TP30NO10.011
BILLING CODE 6560-50-C
E. Program Flexibilities
For each of the heavy-duty vehicle and heavy-duty engine categories
for which we are proposing respective standards, EPA and NHTSA are also
proposing provisions designed to give manufacturers a degree of
flexibility in complying with the standards. These proposed provisions
have enabled the agencies to consider overall standards that are more
stringent and that would become effective sooner than we could consider
with a more rigid program, one in which all of a manufacturer's similar
vehicles or engines would be required to achieve the same emissions or
fuel consumption levels, and at the same time.\30\ We believe that
incorporating carefully structured regulatory flexibility provisions
into the overall program is an important way to achieve each agency's
goals for the program.
---------------------------------------------------------------------------
\30\ NHTSA notes that it has greater flexibility in the HD
program to include consideration of credits and other flexibilities
in determining appropriate and feasible levels of stringency than it
does in the light-duty CAFE program. Cf. 49 U.S.C. 32902(h), which
applies to light-duty CAFE but not heavy-duty fuel efficiency under
49 U.S.C. 32902(k).
---------------------------------------------------------------------------
NHTSA's and EPA's proposed flexibility provisions are essentially
identical to each other in structure and function. For combination
tractor and vocational vehicle categories and for heavy-duty engines,
we are proposing four primary types of flexibility--averaging, banking,
and trading (ABT) provisions, early credits, advanced technology
credits (including hybrid powertrains), and innovative technology
credit provisions. The proposed ABT provisions are patterned on
existing EPA ABT programs and would allow a vehicle manufacturer to
reduce CO2 emission and fuel consumption levels
[[Page 74170]]
further than the level of the standard for one or more vehicles to
generate ABT credits. The manufacturer could then use those credits to
offset higher emission or fuel consumption levels in other similar
vehicles, ``bank'' the credits for later use, or ``trade'' the credits
to another manufacturer. We are proposing similar ABT provisions for
manufacturers of heavy-duty engines. For HD pickups and vans, we are
proposing a fleet averaging system very similar to the light-duty GHG
and CAFE fleet averaging system.
To best ensure that the overall emission and fuel consumption
reductions of the program would be achieved and to minimize any effect
on the ability of the market to respond to consumer needs, the agencies
propose to restrict the use of averaging to limited sets of vehicles
and engines expected to have similar emission or fuel consumption
characteristics. For example, averaging would be allowed among Class 7
low-roof day cab vehicles, but not among those vehicles and Class 8
sleeper cabs or vocational vehicles. Also, we propose that credits
generated by vehicles not be applicable to engine compliance, and vice
versa. For HD pickups and vans, we propose that fleet averaging be
allowed with minimum restriction within the HD pickup and van category.
In addition to ABT, the agencies are proposing that a manufacturer
that reduces CO2 emissions and fuel consumption below
required levels prior to the beginning of the program be allowed to
generate the same number of credits (``early credits'') that they would
after the program begins.
The agencies are also proposing that manufacturers that show
improvements in CO2 emissions and fuel consumption and
incorporate certain technologies (including hybrid powertrains, Rankine
engines, or electric vehicles) be eligible for special ``advanced
technology'' credits. Unlike other credits in this proposal, the
advanced technology credits could be applied to any heavy-duty vehicle
or engine, and not be limited to the vehicle category generating the
credit.
The technologies eligible for advanced technology credits above
lend themselves to straightforward methodologies for quantifying the
emission or fuel consumption reductions. For other technologies which
can reduce CO2 and fuel consumption, but for which there do
not yet exist established methods for quantifying reductions, the
agencies still seek to encourage the development of such innovative
technologies, and are therefore proposing special ``innovative
technology'' credits. These innovative technology credits would apply
to technologies that are shown to produce emission and fuel consumption
reductions that are not adequately recognized on the current test
procedures and that are not yet in widespread use. Manufacturers would
need to quantify the reductions in fuel consumption and CO2
emissions that the technology could achieve, above and beyond those
achieved on the existing test procedures. As with ABT, we propose that
the use of innovative technology credits be only allowed among vehicles
and engines expected to have similar emissions and fuel consumption
characteristics (e.g., within each of the nine Class 7 & 8 combination
tractor subcategories, or within each of the three Class 2b-8
vocational vehicle subcategories).
A detailed discussion of each agency's ABT, early credit, advanced
technology, and innovative technology provisions for each regulatory
category of heavy-duty vehicles and engines is found in Section IV
below.
F. EPA and NHTSA Statutory Authorities
(1) EPA Authority
Title II of the CAA provides for comprehensive regulation of mobile
sources, authorizing EPA to regulate emissions of air pollutants from
all mobile source categories. When acting under Title II of the CAA,
EPA considers such issues as technology effectiveness, its cost (both
per vehicle, per manufacturer, and per consumer), the lead time
necessary to implement the technology, and based on this the
feasibility and practicability of potential standards; the impacts of
potential standards on emissions reductions of both GHGs and non-GHGs;
the impacts of standards on oil conservation and energy security; the
impacts of standards on fuel savings by customers; the impacts of
standards on the truck industry; other energy impacts; as well as other
relevant factors such as impacts on safety.
This proposal implements a specific provision from Title II,
section 202(a).\31\ Section 202(a)(1) of the CAA states that ``the
Administrator shall by regulation prescribe (and from time to time
revise) * * * standards applicable to the emission of any air pollutant
from any class or classes of new motor vehicles * * *, which in his
judgment cause, or contribute to, air pollution which may reasonably be
anticipated to endanger public health or welfare.'' With EPA's December
2009 final findings for greenhouse gases, section 202(a) authorizes EPA
to issue standards applicable to emissions of those pollutants from new
motor vehicles.
---------------------------------------------------------------------------
\31\ See 42 U.S.C. 7521(a).
---------------------------------------------------------------------------
Any standards under CAA section 202(a)(1) ``shall be applicable to
such vehicles * * * for their useful life.'' Emission standards set by
the EPA under CAA section 202(a)(1) are technology-based, as the levels
chosen must be premised on a finding of technological feasibility.
Thus, standards promulgated under CAA section 202(a) are to take effect
only ``after providing such period as the Administrator finds necessary
to permit the development and application of the requisite technology,
giving appropriate consideration to the cost of compliance within such
period'' (section 202(a)(2); see also NRDC v. EPA, 655 F.2d 318, 322
(DC Cir. 1981)). EPA is afforded considerable discretion under section
202(a) when assessing issues of technical feasibility and availability
of lead time to implement new technology. Such determinations are
``subject to the restraints of reasonableness'', which ``does not open
the door to `crystal ball' inquiry.'' NRDC, 655 F.2d at 328, quoting
International Harvester Co. v. Ruckelshaus, 478 F.2d 615, 629 (DC Cir.
1973). However, ``EPA is not obliged to provide detailed solutions to
every engineering problem posed in the perfection of the trap-oxidizer.
In the absence of theoretical objections to the technology, the agency
need only identify the major steps necessary for development of the
device, and give plausible reasons for its belief that the industry
will be able to solve those problems in the time remaining. The EPA is
not required to rebut all speculation that unspecified factors may
hinder `real world' emission control.'' NRDC, 655 F.2d at 333-34. In
developing such technology-based standards, EPA has the discretion to
consider different standards for appropriate groupings of vehicles
(``class or classes of new motor vehicles''), or a single standard for
a larger grouping of motor vehicles (NRDC, 655 F.2d at 338).
Although standards under CAA section 202(a)(1) are technology-
based, they are not based exclusively on technological capability. EPA
has the discretion to consider and weigh various factors along with
technological feasibility, such as the cost of compliance (see section
202(a)(2)), lead time necessary for compliance (section 202(a)(2)),
safety (see NRDC, 655 F.2d at 336 n. 31) and other impacts on
consumers, and energy impacts associated with use of the technology.
See George E. Warren Corp. v. EPA, 159
[[Page 74171]]
F.3d 616, 623-624 (DC Cir. 1998) (ordinarily permissible for EPA to
consider factors not specifically enumerated in the CAA). See also
Entergy Corp. v. Riverkeeper, Inc., 129 S.Ct. 1498, 1508-09 (2009)
(congressional silence did not bar EPA from employing cost-benefit
analysis under the Clean Water Act absent some other clear indication
that such analysis was prohibited; rather, silence indicated discretion
to use or not use such an approach as the agency deems appropriate).
In addition, EPA has clear authority to set standards under CAA
section 202(a) that are technology forcing when EPA considers that to
be appropriate, but is not required to do so (as compared to standards
set under provisions such as section 202(a)(3) and section 213(a)(3)).
EPA has interpreted a similar statutory provision, CAA section 231, as
follows:
While the statutory language of section 231 is not identical to
other provisions in title II of the CAA that direct EPA to establish
technology-based standards for various types of engines, EPA interprets
its authority under section 231 to be somewhat similar to those
provisions that require us to identify a reasonable balance of
specified emissions reduction, cost, safety, noise, and other factors.
See, e.g., Husqvarna AB v. EPA, 254 F.3d 195 (DC Cir. 2001) (upholding
EPA's promulgation of technology-based standards for small non-road
engines under section 213(a)(3) of the CAA). However, EPA is not
compelled under section 231 to obtain the ``greatest degree of emission
reduction achievable'' as per sections 213 and 202 of the CAA, and so
EPA does not interpret the Act as requiring the agency to give
subordinate status to factors such as cost, safety, and noise in
determining what standards are reasonable for aircraft engines. Rather,
EPA has greater flexibility under section 231 in determining what
standard is most reasonable for aircraft engines, and is not required
to achieve a ``technology forcing'' result (70 FR 69664 and 69676,
November 17, 2005).
This interpretation was upheld as reasonable in NACAA v. EPA, 489
F.3d 1221, 1230 (DC Cir. 2007). CAA section 202(a) does not specify the
degree of weight to apply to each factor, and EPA accordingly has
discretion in choosing an appropriate balance among factors. See Sierra
Club v. EPA, 325 F.3d 374, 378 (DC Cir. 2003) (even where a provision
is technology-forcing, the provision ``does not resolve how the
Administrator should weigh all [the statutory] factors in the process
of finding the `greatest emission reduction achievable' ''). Also see
Husqvarna AB v. EPA, 254 F.3d 195, 200 (DC Cir. 2001) (great discretion
to balance statutory factors in considering level of technology-based
standard, and statutory requirement ``to [give appropriate]
consideration to the cost of applying * * * technology'' does not
mandate a specific method of cost analysis); see also Hercules Inc. v.
EPA, 598 F.2d 91, 106 (DC Cir. 1978) (``In reviewing a numerical
standard the agencies must ask whether the agency's numbers are within
a zone of reasonableness, not whether its numbers are precisely
right''); Permian Basin Area Rate Cases, 390 U.S. 747, 797 (1968)
(same); Federal Power Commission v. Conway Corp., 426 U.S. 271, 278
(1976) (same); Exxon Mobil Gas Marketing Co. v. FERC, 297 F.3d 1071,
1084 (DC Cir. 2002) (same).
(a) EPA Testing Authority
Under section 203 of the CAA, sales of vehicles are prohibited
unless the vehicle is covered by a certificate of conformity. EPA
issues certificates of conformity pursuant to section 206 of the Act,
based on (necessarily) pre-sale testing conducted either by EPA or by
the manufacturer. The Heavy-duty Federal Test Procedure (Heavy-duty
FTP) and the Supplemental Engine Test (SET) are used for this purpose.
Compliance with standards is required not only at certification but
throughout a vehicle's useful life, so that testing requirements may
continue post-certification. Useful life standards may apply an
adjustment factor to account for vehicle emission control deterioration
or variability in use (section 206(a)).
(b) EPA established the Light-duty FTP for emissions measurement in
the early 1970s. In 1976, in response to the Energy Policy and
Conservation Act, EPA extended the use of the Light-duty FTP to fuel
economy measurement (See 49 U.S.C. 32904(c)). EPA can determine fuel
efficiency of a vehicle by measuring the amount of CO2 and
all other carbon compounds (e.g., total hydrocarbons and carbon
monoxide (CO)), and then, by mass balance, calculating the amount of
fuel consumed.
(b) EPA Enforcement Authority
Section 207 of the CAA grants EPA broad authority to require
manufacturers to remedy vehicles if EPA determines there are a
substantial number of noncomplying vehicles. In addition, section 205
of the CAA authorizes EPA to assess penalties of up to $37,500 per
vehicle for violations of various prohibited acts specified in the CAA.
In determining the appropriate penalty, EPA must consider a variety of
factors such as the gravity of the violation, the economic impact of
the violation, the violator's history of compliance, and ``such other
matters as justice may require.''
(2) NHTSA Authority
EISA authorizes NHTSA to create a fuel efficiency improvement
program for ``commercial medium- and heavy-duty on-highway vehicles and
work trucks'' \32\ by rulemaking, which is to include standards, test
methods, measurement metrics, and enforcement protocols. See 49 U.S.C.
32902(k)(2). Congress directed that the standards, test methods,
measurement metrics, and compliance and enforcement protocols be
``appropriate, cost-effective, and technologically feasible'' for the
vehicles to be regulated, while achieving the ``maximum feasible
improvement'' in fuel efficiency.
---------------------------------------------------------------------------
\31\ ``Commercial medium- and heavy-duty on-highway vehicles''
are defined at 49 U.S.C. 32901(a)(7), and ``work trucks'' are
defined at (a)(19).
---------------------------------------------------------------------------
Since this is the first rulemaking that NHTSA has conducted under
49 U.S.C. 32902(k)(2), the agency must interpret these elements and
factors in the context of setting standards, choosing metrics, and
determining test methods and compliance/enforcement mechanisms.
Congress also gave NHTSA the authority to set separate standards for
different classes of these vehicles, but required that all standards
adopted provide not less than four full model years of regulatory lead-
time and three full model years of regulatory stability.
In EISA, Congress required NHTSA to prescribe separate average fuel
economy standards for passenger cars and light trucks in accordance
with the provisions in 49 U.S.C. section 32902(b), and to prescribe
standards for work trucks and commercial medium- and heavy-duty
vehicles in accordance with the provisions in 49 U.S.C. section
32902(k). See 49 U.S.C. section 32902(b)(1). We note that Congress also
added in EISA a requirement that NHTSA shall issue regulations
prescribing fuel economy standards for at least 1, but not more than 5,
model years. See 49 U.S.C. section 32902(b)(3)(B). For purposes of the
fuel efficiency standards that the agency is proposing for HD vehicles
and engines, NHTSA believes that one permissible reading of the statute
is that Congress did not intend for the 5-year maximum limit to apply
to standards promulgated in accordance with 49 U.S.C. section 32902(k),
given the language in
[[Page 74172]]
32902(b)(1). Based on this interpretation, NHTSA proposes that the
standards ultimately finalized for HD vehicles and engines would remain
in effect indefinitely at their 2018 or 2019 model year levels until
amended by a future rulemaking action. In any future rulemaking action
to amend the standards, NHTSA would ensure not less than four full
model years of regulatory lead-time and three full model years of
regulatory stability. NHTSA seeks comment on this interpretation of
EISA.
(a) NHTSA Testing Authority
49 U.S.C. 32902(k)(2) states that NHTSA must adopt and implement
appropriate, cost-effective, and technologically feasible test methods
and measurement metrics as part of the fuel efficiency improvement
program.
(b) NHTSA Enforcement Authority
49 U.S.C. 32902(k)(2) also states that NHTSA must adopt and
implement appropriate, cost-effective, and technologically feasible
compliance and enforcement protocols for the fuel efficiency
improvement program.
In 49 U.S.C. 32902(k)(2), Congress did not speak directly to the
``compliance and enforcement protocols'' it envisioned. Instead, it
left the matter generally to the Secretary. Congress' approach is
unlike CAFE enforcement for passenger cars and light trucks, where
Congress specified a program where a manufacturer either complies with
standards or pays civil penalties. But Congress did not specify in 49
U.S.C. 32902(k) what it precisely meant in directing NHTSA to develop
``compliance and enforcement protocols.'' It appears, therefore, that
Congress has assigned this matter to the agency's discretion.
The statute is silent with respect to how ``protocol'' should be
interpreted. The term ``protocol'' is imprecise. For example, in a case
interpreting section 301(c)(2) of the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA), the DC Circuit
noted that the word ``protocols'' has many definitions that are not
much help. Kennecott Utah Copper Corp., Inc. v. U.S. Dept. of Interior,
88 F.3d. 1191, 1216 (DC Cir. 1996). Section 301(c)(2) of CERCLA
prescribed the creation of two types of procedures for conducting
natural resources damages assessments. The regulations were to specify
(a) ``standard procedures for simplified assessments requiring minimal
field observation'' (the ``Type A'' rules), and (b) ``alternative
protocols for conducting assessments in individual cases'' (the ``Type
B'' rules).\33\ The court upheld the challenged provisions, which were
a part of a set of rules establishing a step-by-step procedure to
evaluate options based on certain criteria, and to make a decision and
document the results.
---------------------------------------------------------------------------
\33\ State of Ohio v. U.S. Dept. of Interior, 880 F.2d 432, 439
(DC Cir. 1989).
---------------------------------------------------------------------------
Taking the considerations above into account, including Congress'
instructions to adopt and implement compliance and enforcement
protocols, and the Secretary's authority to formulate policy and make
rules to fill gaps left, implicitly or explicitly, by Congress, the
agency interprets ``protocol'' in the context of EISA as authorizing
the agency to determine both whether manufacturers have complied with
the standards, and to establish the enforcement mechanisms and decision
criteria for non-compliance. NHTSA seeks comment on its interpretation
of this statutory requirement.
G. Future HD GHG and Fuel Consumption Rulemakings
This proposal represents a first regulatory step by NHTSA and EPA
to address the multi-faceted challenges of reducing fuel use and
greenhouse gas emissions from these vehicles. By focusing on existing
technologies and well-developed regulatory tools, the agencies are able
to propose rules that we believe will produce real and important
reductions in GHG emissions and fuel consumption within only a few
years. Within the context of this regulatory timeframe, our proposal is
very aggressive--with limited lead time compared to historic heavy-duty
regulations--but pragmatic in the context of technologies that are
available.
While we are now only proposing this first step, it is worthwhile
to consider how future regulations that may follow this step may be
constructed. Technologies such as hybrid drivetrains, advanced
bottoming cycle engines, and full electric vehicles are promoted in
this first step through incentive concepts as discussed in Section IV,
but we believe that these advanced technologies would not be necessary
to meet the proposed standards, which are premised on the use of
existing technologies. When we begin our future work to develop a
possible next set of regulatory standards, the agencies expect these
advanced technologies to be an important part of the regulatory program
and will consider them in setting the stringency of any standards
beyond the 2018 model year.
We will not only consider the progress of technology in our future
regulatory efforts, but the agencies are also committed to fully
considering a range of regulatory approaches. To more completely
capture the complex interactions of the total vehicle and the potential
to reduce fuel consumption and GHG emissions through the optimization
of those interactions may require a more sophisticated approach to
vehicle testing than we are proposing for the largest heavy-duty
vehicles. In future regulations, the agencies expect to fully evaluate
the potential to expand the use of vehicle compliance models to reflect
engine and drivetrain performance. Similarly, we intend to consider the
potential for complete vehicle testing using a chassis dynamometer, not
only as a means for compliance, but also as a complementary tool for
the development of more complex vehicle modeling approaches. In
considering these more comprehensive regulatory approaches, the
agencies will also reevaluate whether separate regulation of trucks and
engines remains necessary.
In addition to technology and test procedures, vehicle and engine
drive cycles are an important part of the overall approach to
evaluating and improving vehicle performance. EPA, working through the
WP.29 Global Technical Regulation process, has actively participated in
the development of a new World Harmonized Duty Cycle for heavy-duty
engines. EPA is committed to bringing forward these new procedures as
part of our overall comprehensive approach for controlling criteria and
GHG emissions. However, we believe the important issues and technical
work related to setting new criteria emissions standards appropriate
for the World Harmonized Duty Cycle are significant and beyond the
scope of this rulemaking. Therefore, the agencies are not proposing to
adopt these test procedures in this proposal, but we are ready to work
with interested stakeholders to adopt these procedures in a future
action.
As with this proposal, our future efforts will be based on
collaborative outreach with the stakeholder community and will be
focused on a program that delivers on our energy security and
environmental goals without restricting the industry's ability to
produce a very diverse range of vehicles serving a wide range of needs.
[[Page 74173]]
II. Proposed GHG and Fuel Consumption Standards for Heavy-Duty Engines
and Vehicles
This section describes the standards and implementation dates that
the agencies are proposing for the three categories of heavy-duty
vehicles. The agencies have performed a technology analysis to
determine the level of standards that we believe would be appropriate,
cost-effective, and feasible during the rulemaking timeframe. This
analysis, described in Section III and in more detail in the draft RIA
Chapter 2, considered:
The level of technology that is incorporated in current
new trucks,
The available data on corresponding CO2
emissions and fuel consumption for these vehicles,
Technologies that would reduce CO2 emissions
and fuel consumption and that are judged to be feasible and appropriate
for these vehicles through 2018 model year,
The effectiveness and cost of these technologies,
Projections of future U.S. sales for trucks, and
Forecasts of manufacturers' product redesign schedules.
A. What vehicles would be affected?
EPA and NHTSA are proposing standards for heavy-duty engines and
also for what we refer to generally as ``heavy-duty trucks.'' As noted
in Section I, for purposes of this preamble, the term ``heavy-duty'' or
``HD'' is used to apply to all highway vehicles and engines that are
not regulated by the light-duty vehicle, light-duty truck and medium-
duty passenger vehicle greenhouse gas and CAFE standards issued for MYs
2012-2016. Thus, in this notice, unless specified otherwise, the heavy-
duty category incorporates all vehicles rated with GVWR greater than
8,500 pounds, and the engines that power these vehicles, except for
MDPVs. The CAA defines heavy-duty vehicles as trucks, buses or other
motor vehicles with GVWR exceeding 6,000 pounds. See CAA section
202(b)(3). In the context of the CAA, the term HD as used in these
proposed rules thus refers to a subset of these vehicles and engines.
EISA section 103(a)(3) defines a `commercial medium- and heavy-duty on-
highway vehicle' as an on-highway vehicle with GVWR of 10,000 pounds or
more.\34\ EISA section 103(a)(6) defines a `work truck' as a vehicle
that is rated at between 8,500 and 10,000 pounds gross vehicle weight
and is not a medium-duty passenger vehicle.\35\ Therefore, the term
``heavy-duty trucks'' in this proposal refers to both work trucks and
commercial medium- and heavy-duty on-highway vehicles as defined by
EISA. Heavy-duty engines affected by the proposed standards are those
that are installed in commercial medium- and heavy-duty trucks, except
for the engines installed in vehicles certified to a complete vehicle
emissions standard based on a chassis test, which would be addressed as
a part of those complete vehicles, and except for engines used
exclusively for stationary power when the vehicle is parked. The
agencies' scope is the same with the exception of recreational vehicles
(or motor homes), as discussed above. EPA is proposing to include
recreational on-highway vehicles within their rulemaking, while NHTSA
is limiting their scope to commercial trucks which would not include
these vehicles.
---------------------------------------------------------------------------
\34\ Codified at 49 U.S.C. 32901(a)(7).
\35\ EISA Section 103(a)(6) is codified at 49 U.S.C.
32901(a)(19). EPA defines medium-duty passenger vehicles as any
complete vehicle between 8,500 and 10,000 pounds GVWR designed
primarily for the transportation of persons which meet the criteria
outlined in 40 CFR 86.1803-01. The definition specifically excludes
any vehicle that (1) Has a capacity of more than 12 persons total
or, (2) is designed to accommodate more than 9 persons in seating
rearward of the driver's seat or, (3) has a cargo box (e.g., pick-up
box or bed) of six feet or more in interior length. (See the Tier 2
final rulemaking, 65 FR 6698, February 10, 2000.)
---------------------------------------------------------------------------
EPA and NHTSA are proposing standards for each of the following
categories, which together comprise all heavy-duty vehicles and all
engines used in such vehicles.\36\ In order to most appropriately
regulate the broad range of heavy-duty vehicles, the agencies are
proposing to set separate engine and vehicle standards for the
combination tractors and the Class 2b through 8 vocational vehicles and
the engines installed in them. The engine standards and test procedures
for engines installed in the tractors and vocational vehicles are
discussed within the applicable vehicle sections.
---------------------------------------------------------------------------
\36\ Both agencies have authority to develop separate standards
for vehicle and engine categories, as appropriate. See CAA section
202(a)(1) (authority to establish standards for ``any class or
classes of new motor vehicles or engines'' and 49 U.S.C 32902(k)(2)
(authority to establish standards for HD vehicles that are
``appropriate, cost-effective, and technologically feasible'' that
are designed to achieve the ``maximum feasible improvement'' in fuel
efficiency; authority to establish ``separate standards for
different classes of vehicles under this subsection.'' NHTSA
interprets 49 U.S.C. 32902(k)(2) to include a grant of authority to
establish engines standards pursuant to the broader statement of
authority to establish standards that achieve the maximum feasible
improvement in fuel efficiency.
---------------------------------------------------------------------------
Class 7 and 8 Combination Tractors.
Heavy-Duty Pickup Trucks and Vans.
Class 2b through 8 Vocational Vehicles.
As discussed in Section IX, the agencies are not proposing GHG
emission and fuel consumption standards for trailers at this time. In
addition, the agencies are proposing to not set standards at this time
for engine, chassis, and vehicle manufacturers which are small
businesses (as defined). More detailed discussion of each regulatory
category is included in the subsequent sections below.
B. Class 7 and 8 Combination Tractors
EPA is proposing CO2 standards and NHTSA is proposing
fuel consumption standards for new Class 7 and 8 combination tractors.
The standards are for the tractor cab, with a separate standard for the
engines that are installed in the tractor. Together these standards
would achieve reductions up to 20 percent from tractors. As discussed
below, EPA is proposing to adopt the existing useful life definitions
for heavy-duty engines for the Class 7 and 8 tractors. NHTSA is
proposing fuel consumption standards for tractors, and engine standards
for heavy-duty engines for Class 7 and 8 tractors. The agencies'
analyses, as discussed briefly below and in more detail later in this
preamble and in the draft RIA Chapter 2, show that these standards are
appropriate and feasible under each agency's respective statutory
authorities.
EPA is also proposing standards to control N2O,
CH4, and HFC emissions from Class 7 and 8 combination
tractors. The proposed heavy-duty engine standards for both
N2O and CH4 and details of the standard are
included in the discussion in Section II. The proposed air conditioning
leakage standards applying to tractor manufacturers to address HFC
emissions are included in Section II.
The agencies are proposing CO2 emissions and fuel
consumption standards for the combination tractors that will focus on
reductions that can be achieved through improvements in the tractor
(such as aerodynamics), tires, and other vehicle systems. The agencies
are also proposing heavy-duty engine standards for CO2
emissions and fuel consumption that would focus on potential
technological improvements in fuel combustion and overall engine
efficiency.
The agencies have analyzed the feasibility of achieving the
CO2 and fuel consumption standards, based on projections of
what actions manufacturers are expected to take to reduce emissions and
fuel consumption. EPA and NHTSA also present the estimated costs and
benefits of the
[[Page 74174]]
standards in Section III. In developing the proposed rules, the
agencies have evaluated the kinds of technologies that could be
utilized by engine and tractor manufacturers, as well as the associated
costs for the industry and fuel savings for the consumer and the
magnitude of the CO2 and fuel savings that may be achieved.
EPA and NHTSA are proposing attribute-based standards for the Class
7 and 8 combination tractors, or, put another way, we are proposing to
set different standards for different subcategories of these tractors
with the basis for subcategorization being particular tractor
attributes. Attribute-based standards in general recognize the variety
of functions performed by vehicles and engines, which in turn can
affect the kind of technology that is available to control emissions
and reduce fuel consumption, or its effectiveness. Attributes that
characterize differences in the design of vehicles, as well as
differences in how the vehicles will be employed in-use, can be key
factors in evaluating technological improvements for reducing
CO2 emissions and fuel consumption. Developing an
appropriate attribute-based standard can also avoid interfering with
the ability of the market to offer a variety of products to meet
consumer demand. There are several examples of where the agencies have
utilized an attribute-based standard. In addition to the example of the
recent light-duty vehicle fuel economy and GHG rule, in which the
standards are based on the attribute of vehicle ``footprint,'' the
existing heavy-duty highway engine criteria pollutant emission
standards for many years have been based on a vehicle weight attribute
(Light Heavy, Medium Heavy, Heavy Heavy) with different useful life
periods, which is the same approach proposed for the engine GHG and
fuel consumption standards discussed below.
Heavy-duty combination tractors are built to move freight. The
ability of a truck to meet a customer's freight transportation
requirements depends on three major characteristics of the tractor: The
gross vehicle weight rating (which along with gross combined weight
rating (GCWR) establishes the maximum carrying capacity of the tractor
and trailer), cab type (sleeper cabs provide overnight accommodations
for drivers), and the tractor roof height (to mate tractors to trailers
for the most fuel-efficient configuration). Each of these attributes
impacts the baseline fuel consumption and GHG emissions, as well as the
effectiveness of possible technologies, like aerodynamics, and is
discussed in more detail below.
The first tractor characteristic to consider is payload which is
determined by a tractor's GVWR and GCWR relative to the weight of the
tractor, trailer, fuel, driver, and equipment. Class 7 trucks, which
have a GVWR of 26,001-33,000 pounds and a typical GCWR of 65,000
pounds, have a lesser payload capacity than Class 8 trucks. Class 8
trucks have a GVWR of greater than 33,000 pounds and a typical 80,000
pound GCWR. Consistent with the recommendation in the National Academy
of Sciences 2010 Report to NHTSA,\37\ the agencies are proposing a
load-specific fuel consumption metric (g/ton-mile and gal/1,000 ton-
mile) where the ``ton'' represents the amount of payload. Generally,
higher payload capacity trucks have better specific fuel consumption
and GHG emissions than lower payload capacity trucks. Therefore, since
the amount of payload that a Class 7 truck can carry is less than the
Class 8 truck's payload capacity, the baseline fuel consumption and GHG
emissions performance per ton-mile differs between the categories. It
is consequently reasonable to distinguish between these two vehicle
categories, so that the agencies are proposing separate standards for
Class 7 and Class 8 tractors.
---------------------------------------------------------------------------
\37\ See 2010 NAS Report, Note 19, Recommendation 2-1.
---------------------------------------------------------------------------
The agencies are not proposing to set a single standard for both
Class 7 and 8 tractors based on the payload carrying capabilities and
assumed typical payload levels of Class 8 tractors alone, as that would
quite likely have the perverse impact of increasing fuel consumption
and greenhouse gas emissions. Such a single standard would penalize
Class 7 vehicles in favor of Class 8 vehicles. However, the greater
capabilities of Class 8 tractors and their related greater efficiency
when measured on a per ton-mile basis is only relevant in the context
of operations where that greater capacity is needed. For many
applications such as regional distribution, the trailer payloads
dictated by the goods being carried are lower than the average Class 8
tractor payload. In those situations, Class 7 tractors are more
efficient than Class 8 tractors when measured by ton-mile of actual
freight carried. This is because the extra capabilities of Class 8
tractors add additional weight to vehicle that is only beneficial in
the context of its higher capabilities. The existing market already
selects for vehicle performance based on the projected payloads. By
setting separate standards the agencies do not advantage or
disadvantage Class 7 or 8 tractors relative to one another and continue
to allow trucking fleets to purchase the vehicle most appropriate to
their business practices.
The second characteristic that affects fuel consumption and GHG
emissions is the relationship between the tractor cab roof height and
the type of trailer used to carry the freight. The primary trailer
types are box, flat bed, tanker, bulk carrier, chassis, and low boys.
Tractor manufacturers sell tractors in three roof heights--low, mid,
and high. The manufacturers do this to obtain the best aerodynamic
performance of a tractor-trailer combination, resulting in reductions
of GHG emissions and fuel consumption, because it allows the frontal
area of the tractor to be similar in size to the frontal area of the
trailer. In other words, high roof tractors are designed to be paired
with a (relatively tall) box trailer while a low roof tractor is
designed to pull a (relatively low) flat bed trailer. The baseline
performance of a high roof, mid roof, and low roof tractor differs due
to the variation in frontal area which determines the aerodynamic drag.
For example, the frontal area of a low roof tractor is approximately 6
square meters, while a high roof tractor has a frontal area of
approximately 9.8 square meters. Therefore, as explained below, the
agencies are proposing that the roof height of the tractor determine
the trailer type required to be used to demonstrate compliance of a
truck with the fuel consumption and CO2 emissions standards.
As with vehicle weight classes, setting separate standards for each
tractor roof height helps ensure that all tractors are regulated to
achieve appropriate improvements, without inadvertently leading to
increased emissions and fuel consumption by shifting the mix of vehicle
roof heights offered in the market away from a level customarily tied
to the actual trailers vehicles will haul in-use.
Tractor cabs typically can be divided into two configurations--day
cabs and sleeper cabs. Line haul operations typically require overnight
accommodations due to Federal Motor Carrier Safety Administration hours
of operation requirements.\38\ Therefore,
[[Page 74175]]
some truck buyers purchase tractor cabs with sleeping accommodations,
also known as sleeper cabs, because they do not return to their home
base nightly. Sleeper cabs tend to have a greater empty curb weight
than day cabs due to the larger cab volume and accommodations, which
lead to a higher baseline fuel consumption for sleeper cabs when
compared to day cabs. In addition, there are specific technologies,
such as extended idle reduction technologies, which are appropriate
only for tractors which hotel--such as sleeper cabs. To respect these
differences, the agencies are proposing to create separate standards
for sleeper cabs and day cabs.
---------------------------------------------------------------------------
\38\ The Federal Motor Carrier Safety Administration's Hours-of-
Service regulations put limits in place for when and how long
commercial motor vehicle drivers may drive. They are based on an
exhaustive scientific review and are designed to ensure truck
drivers get the necessary rest to perform safe operations. See 49
CFR part 395, and see also http://www.fmcsa.dot.gov/rules-regulations/topics/hos/index.htm (last accessed August 8, 2010).
---------------------------------------------------------------------------
To account for the relevant combinations of these attributes, the
agencies therefore propose to segment combination tractors into the
following nine regulatory subcategories:
Class 7 Day Cab with Low Roof
Class 7 Day Cab with Mid Roof
Class 7 Day Cab with High Roof
Class 8 Day Cab with Low Roof
Class 8 Day Cab with Mid Roof
Class 8 Day Cab with High Roof
Class 8 Sleeper Cab with Low Roof
Class 8 Sleeper Cab with Mid Roof
Class 8 Sleeper Cab with High Roof
The agencies have not identified any Class 7 or Class 8 day cabs
with mid roof heights in the market today but welcome comments with
regard to this market characterization.
Adjustable roof fairings are used today on what the agencies
consider to be low roof tractors. The adjustable fairings allow the
operator to change the fairing height to better match the type of
trailer that is being pulled which can reduce fuel consumption and GHG
emissions during operation. The agencies propose to treat tractors with
adjustable roof fairings as low roof tractors and test with the fairing
down. The agencies welcome comments on this approach and data to
support whether to allow additional credits for their use.
The agencies are proposing to classify all vehicles with sleeper
cabs as tractors. The proposed rules would not allow vehicles with
sleeper cabs to be classified as vocational vehicles. This provision is
intended prevent the initial manufacture of straight truck vocational
vehicles with sleeper cabs that, soon after introduction into commerce,
would be converted to combination tractors, as a means to circumvent
the Class 8 sleeper cab regulations. The agencies welcome comments on
the likelihood of manufacturers using such an approach to circumvent
the regulations and the appropriate regulatory provisions the agencies
should consider to prevent such actions.
(1) What are the proposed Class 7 and 8 tractor and engine
CO2 emissions and fuel consumption standards and their
timing?
In developing the proposed tractor and engine standards, the
agencies have evaluated the current levels of emissions and fuel
consumption, the kinds of technologies that could be utilized by truck
and engine manufacturers to reduce emissions and fuel consumption from
tractors and engines, the associated lead time, the associated costs
for the industry, fuel savings for the consumer, and the magnitude of
the CO2 and fuel savings that may be achieved. The
technologies that the agencies considered while setting the proposed
tractor standards include improvements in aerodynamic design, lower
rolling resistance tires, extended idle reduction technologies, and
vehicle empty weight reduction. The technologies that the agencies
considered while setting the engine standards include engine friction
reduction, aftertreatment optimization, and turbocompounding, among
others. The agencies' evaluation indicates that these technologies are
available today, but have very low application rates in the market. The
agencies have analyzed the technical feasibility of achieving the
proposed CO2 and fuel consumption standards for tractors and
engines, based on projections of what actions manufacturers would be
expected to take to reduce emissions and fuel consumption to achieve
the standards. EPA and NHTSA also present the estimated costs and
benefits of the Class 7 and 8 combination tractor and engine standards
in Section III and in draft RIA Chapter 2.
(a) Tractor Standards
The agencies are proposing the following standards for Class 7 and
8 combination tractors in Table II-1, using the subcategorization
approach just explained. As noted, the agencies are not aware of any
mid roof day cab tractors at this time, but are proposing that any
Class 7 and 8 day cabs with a mid roof would meet the respective low
roof standards, based on the similarity in baseline performance and
similarity in expected improvement of mid roof sleeper cabs relative to
low roof sleeper cabs.
As explained below in Section III, EPA has determined that there is
sufficient lead time to introduce various tractor and engine
technologies into the fleet starting in the 2014 model year, and is
proposing standards starting for that model year predicated on
performance of those technologies. EPA is proposing more stringent
tractor standards for the 2017 model year which reflect the
CO2 emissions reductions required through the 2017 model
year engine standards. (As explained in Section II.B.(2)(h)(v) below,
engine performance is one of the inputs into the proposed compliance
model, and that input will change in 2017 to reflect the 2017 MY engine
standards.) The 2017 MY vehicle standards are not premised on tractor
manufacturers installing additional vehicle technologies. EPA's
proposed standards apply throughout the useful life period as described
in Section V. Similar to EPA's non-GHG standards approach,
manufacturers may generate and use credits from Class 7 and 8
combination tractors to show compliance with the standards.
NHTSA is proposing Class 7 and 8 tractor fuel consumption standards
that are voluntary standards in the 2014 and 2015 model years and
become mandatory beginning in the 2016 model year, as required by the
lead time and stability requirement within EISA. NHTSA is also
proposing new standards for the 2017 model year which reflect
additional improvements in only the heavy-duty engines. While NHTSA
proposes to use useful life considerations for establishing fuel
consumption performance for initial compliance and for ABT, NHTSA does
not intend to implement an in-use compliance program for fuel
consumption because it is not currently anticipated there will be
notable deterioration of fuel consumption over the useful life. NHTSA
believes that the vehicle and engine standards proposed for combination
tractors are appropriate, cost-effective, and technologically feasible
in the rulemaking timeframe based on our analysis detailed below in
Section III and in the Chapter 2 of the draft RIA.
EPA and NHTSA are not proposing to make the 2017 vehicle standards
more stringent based on the application of additional truck
technologies because projected application rates of truck technologies
used in setting the 2014 model year truck standard already reflect the
maximum application rates we believe appropriate for these vehicles
given their specific use patterns as described in Section III. We
considered setting more stringent standards for Class 7 and 8 tractors
based on the application of more advanced aerodynamic systems, such as
self-compensating side extenders or other advanced aerodynamic
technologies, but concluded that those
[[Page 74176]]
technologies would not be fully developed in the necessary lead time.
We request comment on this decision, supported by data as appropriate.
[GRAPHIC] [TIFF OMITTED] TP30NO10.012
Based on our analysis, the 2017 model year standards represent up
to a 20 percent reduction in CO2 emissions and fuel
consumption over a 2010 model year baseline, as detailed in Section
III.A.2.
---------------------------------------------------------------------------
\39\ Manufacturers may voluntarily opt-in to the NHTSA fuel
consumption program in 2014 or 2015. If a manufacturer opts-in, the
program becomes mandatory. See Section [add cross reference] below
for more information about NHTSA's voluntary opt-in program for MYs
2014 and 2015.
---------------------------------------------------------------------------
(i) Off-Road Tractor Standards
In developing the proposal EPA and NHTSA received comment from
manufacturers and owners that tractors sometimes have very limited on-
road usage. These trucks are defined to be motor vehicles under 40 CFR
85.1703, but they will spend the majority of their operations off-road.
Tractors, such as those used in oil fields, will experience little
benefit from improved aerodynamics and low rolling resistance tires.
The agencies are therefore proposing to allow a narrow range of these
de facto off-road trucks to be excluded from the proposed tractor
standards because the trucks do not travel at speeds high enough to
realize aerodynamic improvements and require special off-road tires
such as lug tires. The trucks must still use a certified engine, which
will provide fuel consumption and CO2 emission reductions to
the truck in all applications. To ensure the limited use of these
trucks, the agencies are proposing requirements that the vehicles have
off-road tires, have limited high speed operation, and are designed for
specific off-road applications.\40\ The agencies are proposing that a
truck must meet the following requirements to qualify for an exemption
from the vehicle standards for Class 7 and 8 tractors:
---------------------------------------------------------------------------
\40\ For purposes of compliance with NHTSA's safety regulations,
such as FMVSS Nos. 119 and 121, a manufacturer wishing for their
vehicle to classify as ``off-road'' would still need to work with
the relevant NHTSA office to declare its vehicle as ``off-road'' if
it uses public roads at any point in its service.
---------------------------------------------------------------------------
Installed tires which are lug tires or contain a speed
rating of less than or equal to 60 mph; and
Include a vehicle speed limiter governed to 55 mph, and
Contain Power Take-Off controls, or have axle
configurations other than 4x2, 6x2, or 6x4 and has GVWR greater than
57,000 pounds; and
Has a frame Resisting Bending Moment greater than
2,000,000 lb-in.\41\
---------------------------------------------------------------------------
\41\ The agencies have found based on standard truck
specifications, that vehicles designed for significant off-road
applications, such as concrete pumper and logging trucks have
resisting bending moment greater than 2,100,000 lb-in. (ranging up
to 3,580,000 lb-in.). The typical on highway tractors have resisting
bending moment of 1,390,000 lb-in.
---------------------------------------------------------------------------
EPA and NHTSA have concluded that the onroad performance losses and
additional costs to develop a truck which meets these specifications
will limit the exemption to trucks built for
[[Page 74177]]
the desired purposes.\42\ The agencies welcome comment on the proposed
requirements and exemptions.
---------------------------------------------------------------------------
\42\ The estimated cost for a lift axle is approximately
$10,000. Axles with weight ratings greater than a typical on-road
axle cost an additional $3,000.
---------------------------------------------------------------------------
(b) Engine Standards
EPA is proposing GHG standards and NHTSA is proposing fuel
consumption standards for new heavy-duty engines. The standards will
vary depending on the type of vehicle in which they are used, as well
as whether the engines are diesel or gasoline powered. This section
discusses the standards for engines used in Class 7 and 8 combination
tractors and also provides some overall background information. More
information is also provided in the discussion of the standards for
engines used in vocational vehicles.
EPA's existing criteria pollutant emissions regulations for heavy-
duty highway engines establish four regulatory categories that
represent the engine's intended and primary truck application.\43\ The
Light Heavy-Duty (LHD) diesel engines are intended for application in
Class 2b through Class 5 trucks (8,501 through 19,500 pounds GVWR). The
Medium Heavy-Duty (MHD) diesel engines are intended for Class 6 and
Class 7 trucks (19,501 through 33,000 pounds GVWR). The Heavy Heavy-
Duty (HDD) diesel engines are primarily used in Class 8 trucks (33,001
pounds and greater GVWR). Lastly, spark ignition engines (primarily
gasoline-powered engines) installed in incomplete vehicles less than
14,000 pounds GVWR and spark ignition engines that are installed in all
vehicles (complete or incomplete) greater than 14,000 pounds GVWR are
grouped into a single engine regulatory subcategory. The engines in
these four regulatory subcategories range in size between approximately
five liters and sixteen liters. The agencies welcome comments on
updating the definitions of each subcategory, such as the typical
horsepower levels, as described in 40 CFR 1036.140.
---------------------------------------------------------------------------
\43\ See 40 CFR 1036.140.
---------------------------------------------------------------------------
For the purposes of the GHG engine emissions and engine fuel
consumption standards that EPA and NHTSA are proposing, the agencies
intend to maintain these same four regulatory subcategories. This class
structure would enable the agencies to set standards that appropriately
reflect the technology available for engines for use in each type of
vehicle, and that are therefore technologically feasible for these
engines. This section discusses the MHD and HHD diesel engines used in
Class 7 and 8 combination tractors. Additional details regarding the
other heavy-duty engine standards are included in Section II.D.1.b.
EPA's proposed heavy-duty CO2 emission standards for
diesel engines installed in combination tractors are presented in Table
II-2. We should note that this does not cover gasoline or LHDD engines
as they are not used in Class 7 and 8 combination tractors. Similar to
EPA's non-GHG standards approach, manufacturers may generate and use
credits to show compliance with the standards. EPA is proposing to
adopt the existing useful life definitions for heavy-duty engines. The
EPA standards would become effective in the 2014 model year, with more
stringent standards becoming effective in model year 2017. Recently,
EPA's heavy-duty highway engine program for criteria pollutants
provided new emissions standards for the industry in three year
increments. Largely, the heavy-duty engine and truck manufacturer
product plans have fallen into three year cycles to reflect this
regulatory environment. The proposed two-step CO2 emission
standards recognize the opportunity for technology improvements over
this timeframe while reflecting the typical diesel truck manufacturers'
product plan cycles.
With respect to the lead time and cost of incorporating technology
improvements that reduce GHG emissions and fuel consumption, EPA and
NHTSA place important weight on the fact that during MYs 2014-2017
engine manufacturers are expected to redesign and upgrade their
products. Over these four model years there will be an opportunity for
manufacturers to evaluate almost every one of their engine models and
add technology in a cost-effective way, consistent with existing
redesign schedules, to control GHG emissions and reduce fuel
consumption. The time-frame and levels for the standards, as well as
the ability to average, bank and trade credits and carry a deficit
forward for a limited time, are expected to provide manufacturers the
time needed to incorporate technology that will achieve the proposed
GHG and fuel consumption reductions, and to do this as part of the
normal engine redesign process. This is an important aspect of the
proposed rules, as it will avoid the much higher costs that would occur
if manufacturers needed to add or change technology at times other than
these scheduled redesigns. This time period will also provide
manufacturers the opportunity to plan for compliance using a multi-year
time frame, again in accord with their normal business practice.
Further details on lead time, redesigns and technical feasibility can
be found in Section III.
NHTSA's fuel consumption standards, also presented in Table II-2,
would contain voluntary engine standards starting in 2014 model year,
with mandatory engine standards starting in 2017 model year, harmonized
with EPA's 2017 model year standards. A manufacturer may opt-in to
NHTSA's voluntary standards in 2014, 2015 or 2016. Once a manufacturer
opts-in, the standards become mandatory for the opt-in and subsequent
model years, and the manufacturer may not reverse its decision. To opt
into the program, a manufacturer must declare its intent to opt in to
the program at the same time it submits the Pre-Certification
Compliance Report. See 49 CFR 535.8 for information related to the Pre-
Certification Compliance Report. A manufacturer opting into the program
would begin tracking credits and debits beginning in the model year in
which they opt into the program.
[[Page 74178]]
[GRAPHIC] [TIFF OMITTED] TP30NO10.013
Combination tractors spend the majority of their operation at
steady state conditions, and will obtain in-use benefit of technologies
such as turbocompounding and other waste heat recovery technologies
during this kind of typical engine operation. Therefore, the engines
installed in tractors would be required to meet the standard based on
the steady-state SET test cycle, as discussed further in Section
II.B(2)(i).
The baseline HHD diesel engine performance in 2010 model year on
the SET is 490 g CO2/bhp-hr (4.81 gal/100 bhp-hr), as
determined from confidential data provided by manufacturers and data
submitted for the non-GHG emissions certification process. Similarly,
the baseline MHD diesel engine performance on the SET cycle is 518 g
CO2/bhp-hr (5.09 gallon/100-bhp-hr) in the 2010 model year.
Further discussion of the derivation of the baseline can be found in
Section III The diesel engine standards that EPA is proposing and the
voluntary standards being proposed by NHTSA for the 2014 model year
would require diesel engine manufacturers to achieve on average a three
percent reduction in fuel consumption and CO2 emissions over
the baseline 2010 model year performance for the engines. The agencies'
assessment of the findings of the 2010 NAS Report and other literature
sources indicates that there are technologies available to reduce fuel
consumption by this level in the proposed timeframe. These technologies
include improved turbochargers, aftertreatment optimization, low
temperature exhaust gas recirculation, and engine friction reductions.
Additional discussion on technical feasibility is included in Section
III below and in draft RIA Chapter 2.
Furthermore, the agencies are proposing that diesel engines further
reduce fuel consumption and CO2 emissions from the 2010
model year baseline in 2017 model year. The proposed reductions
represent on average a six percent reduction for MHD and HHD diesel
engines required to use the SET-based standard. The additional
reductions could likely be achieved through the increased refinement of
the technologies projected to be implemented for 2014, plus the
addition of turbocompounding or other waste heat recovery systems. The
agencies' analysis indicates that this type of advanced engine
technology would require a longer development time than the 2014 model
year, and we therefore are proposing to provide additional lead time to
allow for its introduction.
The agencies are aware that some truck and engine manufacturers
would prefer to align their product development plans for these engine
standards with their current plans to meet Onboard Diagnostic
regulations for EPA and California in 2013 and 2016. We believe our
proposed averaging, banking and trading provisions already provide
these manufacturers with considerable flexibility to manage their GHG
compliance plans consistent with the 2013 model year. Nevertheless, we
are requesting comment on whether EPA and NHTSA should provide
additional defined phase-in schedules that would more explicitly
accommodate this request. For example, we request comment on a phase-in
schedule with a standard of 485 g/bhp-hr for the model years 2013-2015
followed by a standard of 460 g/bhp-hr for 2016-18 model years with the
associated fuel consumption values for the NHTSA program. This phase-in
schedule is just one of many potential schedules that would provide
identical fuel savings and emissions reductions for the period from
2013-2018. If commenters wish to discuss a different phase-in schedule
than the one proposed by the agencies, we request that commenters
include a description of their preferred phase-in schedule, including
an analysis showing that it would be at least as effective (or more) as
the primary program for the period through the 2018 model year. We also
request comment on whether similar provisions should be made for the
vocational engine standards discussed later in this section.
In proposing this standard for heavy-duty diesel engines used in
Class 7 and 8 combination tractors, the agencies have examined the
current performance levels of the engines across the fleet. EPA and
NHTSA found that a large majority of the engines were generally
relatively close to the average baseline, with some above and some
below. We recognize, however, that when regulating a category of
engines for the first time, there will be individual products that may
deviate significantly from this baseline level of performance. For the
current fleet there is a relatively small group of engines that are
significantly worse than the average baseline for other engines. In
proposing the standards, the agencies have looked primarily at the
typical performance levels of the majority of the engines in the fleet,
and the increased performance that would be achieved through increased
spread of technology. The agencies also recognize that for the smaller
group of products, the same reduction from the industry baseline may
experience significant issues of available lead-time and cost because
these products may require a total redesign in order to meet the
standards. These are limited instances where certain engine families
have high atypically high baseline CO2 levels and limited
line of engines across which to average performance. See 75 FR 25414-
25419, which adopts temporary lead time allowance alternative standards
to
[[Page 74179]]
deal with a similar issue for a subset of light-duty vehicles. To
accommodate these situations, the agencies are proposing a regulatory
alternative whereby a manufacturer, for a limited period, would have
the option to comply with a unique standard based on a three percent
reduction from an individual engine's own 2011 model year baseline
level, rather than meeting the otherwise-applicable standard level. Our
assessment is that this three percent reduction is appropriate given
the potential for manufacturers to apply similar technology packages
with similar cost to what we have estimated for the primary program. We
do not believe this alternative needs to continue past the 2016 model
year since manufacturers will have had ample opportunity to benchmark
competitive products during redesign cycles and to make appropriate
changes to bring their product performance into line with the rest of
the industry. This alternative would not be available unless and until
a manufacturer had exhausted all available credits and credit
opportunities, and engines under the alternative standard could not
generate credits. We are proposing that manufacturers can select engine
families for this alternative standard without agency approval, but are
proposing to require that manufacturers notify the agency of their
choice and to include in that notification a demonstration that it has
exhausted all available credits and credit opportunities.
The agencies are also requesting comment on the potential to extend
this regulatory alternative for one additional year for a single engine
family with performance measured in that year as six percent beyond the
engine's own 2011 baseline level. We also request comment on the level
of reduction beyond the baseline that is appropriate in this
alternative. The three percent level reflects the aggregate improvement
beyond the baseline we are requiring of the entire industry. As this
provision is intended to address potential issues for legacy products
that we would expect to be replaced or significantly improved at the
manufacturer's next product redesign, we request comment if a two
percent reduction would be more appropriate. We would consider two
percent rather than three percent if we were convinced that making all
of the changes we have outlined in our assessment of the technical
feasibility of the standards was not possible for some engines due to
legacy design issues that will change in the future. We are proposing
that manufacturers making use of these provisions would need to exhaust
all credits within this subcategory prior to using this flexibility and
would not be able to generate emissions credits from other engines in
the same regulatory subcategory as the engines complying using this
alternate approach.
EPA and NHTSA considered setting even more stringent engine
standards for the 2017 model year based on the use of more
sophisticated waste heat recovery technologies such as bottoming cycle
engine designs. We are not proposing more stringent standards because
we do not believe this technology can be broadly available by 2017
model year. We request comment on the technological feasibility and
cost-effectiveness of more stringent standards in the timeframe of the
proposed standards.
(c) In-Use Standards
Section 202(a)(1) of the CAA specifies that EPA is to adopt
emissions standards that are applicable for the useful life of the
vehicle. The in-use standards that EPA is proposing would apply to
individual vehicles and engines. NHTSA is not proposing to adopt in-
use.
EPA is proposing that the in-use standards for heavy-duty engines
installed in tractors be established by adding an adjustment factor to
the full useful life emissions and fuel consumption results projected
in the EPA certification process. EPA is proposing a 2 percent
adjustment factor for the in-use standard to provide a reasonable
margin for production and test-to-test variability that could result in
differences between the initial emission test results and emission
results obtained during subsequent in-use testing. Details on the
development of the adjustment factor are included in draft RIA Chapter
3.
EPA is also proposing that the useful life for these engine and
vehicles with respect to GHG emissions be set equal to the respective
useful life periods for criteria pollutants. EPA proposes that the
existing engine useful life periods, as included in Table II-3:, be
broadened to include CO2 emissions and fuel consumption for
both engines and tractors (see 40 CFR 86.004-2).
[GRAPHIC] [TIFF OMITTED] TP30NO10.014
EPA and NHTSA request comments on the magnitude and need for an in-
use adjustment factor for the engine standard and the compliance model
(GEM) based tractor standard.
(2) Test Procedures and Related Issues
The agencies are proposing a complete set of test procedures to
evaluate fuel consumption and CO2 emissions from Class 7 and
8 tractors and the engines installed in them. The test procedures
related to the tractors are all new, while the engine test procedures
build substantially on EPA's current non-GHG emissions test procedures,
except as noted. This section discusses the proposed simulation model
developed for demonstrating compliance with the tractor standard and
the proposed engine test procedures.
(a) Truck Simulation Model
We are proposing to set separate engine and vehicle-based emission
standards to achieve the goal of reducing emissions and fuel
consumption for both trucks and engines. For the Class 7 and 8
tractors, engine manufacturers would be subject to the engine
standards, and Class 7 and 8 tractor manufacturers would be required to
install engines in their tractors certified for use in the tractor. The
tractor manufacturer would be subject to a separate vehicle-based
standard that would use a proposed truck simulation model to evaluate
the
[[Page 74180]]
impact of the tractor cab design to determine compliance with the
tractor standard.
A simulation model, in general, uses various inputs to characterize
a vehicle's properties (such as weight, aerodynamics, and rolling
resistance) and predicts how the vehicle would behave on the road when
it follows a driving cycle (vehicle speed versus time). On a second-by-
second basis, the model determines how much engine power needs to be
generated for the vehicle to follow the driving cycle as closely as
possible. The engine power is then transmitted to the wheels through
transmission, driveline, and axles to move the vehicle according to the
driving cycle. The second-by-second fuel consumption of the vehicle,
which corresponds to the engine power demand to move the vehicle, is
then calculated according to a fuel consumption map in the model.
Similar to a chassis dynamometer test, the second-by-second fuel
consumption is aggregated over the complete drive cycle to determine
the fuel consumption of the vehicle.
NHTSA and EPA are proposing to evaluate fuel consumption and
CO2 emissions respectively through a simulation of whole-
vehicle operation, consistent with the NAS recommendation to use a
truck model to evaluate truck performance. The agencies developed the
Greenhouse gas Emissions Model (GEM) for the specific purpose of this
proposal to evaluate truck performance. The GEM is similar in concept
to a number of vehicle simulation tools developed by commercial and
government entities. The model developed by the agencies and proposed
here was designed for the express purpose of vehicle compliance
demonstration and is therefore simpler and less configurable than
similar commercial products. This approach gives a compact and quicker
tool for vehicle compliance without the overhead and costs of a more
sophisticated model. Details of the model are included in Chapter 4 of
the draft RIA. The agencies are aware of several other simulation tools
developed by universities and private companies. Tools such as Argonne
National Laboratory's Autonomie, Gamma Technologies' GT-Drive, AVL's
CRUISE, Ricardo's VSIM, Dassault's DYMOLA, and University of Michigan's
HE-VESIM codes are publicly available. In addition, manufacturers of
engines, vehicles, and trucks often have their own in-house simulation
tools. The agencies welcome comments on other simulation tools which
could be used by the agencies. The use criteria for this model are that
it must be able to be managed by the agencies for compliance purposes,
has no cost to the end-user, is freely available and distributable as
an executable file, contains open source code to provide transparency
in the model's operation yet contains features which cannot be changed
by the user, and is easy to use by any user with minimal or no prior
experience.
GEM is designed to focus on the inputs most closely associated with
fuel consumption and CO2 emissions--i.e., on those which
have the largest impacts such as aerodynamics, rolling resistance,
weight, and others.
EPA has validated GEM based on the chassis test results from a
SmartWay certified tractor tested at Southwest Research Institute. The
validation work conducted on these three vehicles is representative of
the other Class 7 and 8 tractors. Many aspects of one tractor
configuration (such as the engine, transmission, axle configuration,
tire sizes, and control systems) are similar to those used on the
manufacturer's sister models. For example, the powertrain configuration
of a sleeper cab with any roof height is similar to the one used on a
day cab with any roof height. Overall, the GEM predicted the fuel
consumption and CO2 emissions within 4 percent of the
chassis test procedure results for three test cycles--the California
ARB Transient cycle, 65 mph cruise cycle, and 55 mph cruise cycle.
These cycles are the ones the agencies are proposing to utilize in
compliance testing. Test to test variation for heavy-duty vehicle
chassis testing can be higher than 4 percent based on driver variation.
The proposed simulation model is described in greater detail in Chapter
4 of the draft RIA and is available for download by interested parties
at (http://www.epa.gov/otaq/climate/regulations.htm). We request
comment on all aspects of this approach to compliance determination in
general and to the use of the GEM in particular.
The agencies are proposing that for demonstrating compliance, a
Class 7 and 8 tractor manufacturer would measure the performance of
specified tractor systems (such as aerodynamics and tire rolling
resistance), input the values into GEM, and compare the model's output
to the standard. The agencies propose that a tractor manufacturer would
provide the inputs for each of following factors for each of the
tractors it wished to certify under CO2 standards and for
establishing fuel consumption values: Coefficient of Drag, Tire Rolling
Resistance Coefficient, Weight Reduction, Vehicle Speed Limiter, and
Extended Idle Reduction Technology. These are the technologies on which
the agencies' own feasibility analysis for these vehicles is
predicated. An example of the GEM input screen is included in Figure
II-3.
The input values for the simulation model would be derived by the
manufacturer from test procedures proposed by the agencies in this
proposal. The agencies are proposing several testing alternatives for
aerodynamic assessment, a single procedure for tire rolling resistance
coefficient determination, and a prescribed method to determine tractor
weight reduction. The agencies are proposing defined model inputs for
determining vehicle speed limiter and extended idle reduction
technology benefits. The other aspects of vehicle performance are fixed
within the model as defined by the agencies and are not varied for the
purpose of compliance.
(b) Metric
Test metrics which are quantifiable and meaningful are critical for
a regulatory program. The CO2 and fuel consumption metric
should reflect what we wish to control (CO2 or fuel
consumption) relative to the clearest value of its use: In this case,
carrying freight. It should encourage efficiency improvements that will
lead to reductions in emissions and fuel consumption during real world
operation. The agencies are proposing standards for Class 7 and 8
combination tractors that would be expressed in terms of moving a ton
(2000 pounds) of freight over one mile. Thus, NHTSA's proposed fuel
consumption standards for these trucks would be represented as gallons
of fuel used to move one ton of freight 1,000 miles, or gal/1,000 ton-
mile. EPA's proposed CO2 vehicle standards would be
represented as grams of CO2 per ton-mile.
Similarly, the NAS panel concluded, in their report, that a load-
specific fuel consumption metric is appropriate for HD trucks. The
panel spent considerable time explaining the advantages of and
recommending a load-specific fuel consumption approach to regulating
the fuel efficiency of heavy-duty trucks. See NAS Report pages 20
through 28. The panel first points out that the nonlinear relationship
between fuel economy and fuel consumption has led consumers of light-
duty vehicles to have difficulty in judging the benefits of replacing
the most inefficient vehicles. The panel describes an example where a
light-duty vehicle can save the same 107 gallons per year (assuming
12,000 miles travelled per year) by improving one vehicle's fuel
efficiency from 14 to 16 mpg or improving another vehicle's fuel
efficiency from 35 to 50.8 mpg. The use
[[Page 74181]]
of miles per gallon leads consumers to undervalue the importance of
small mpg improvements in vehicles with lower fuel economy. Therefore,
the NAS panel recommends the use of a fuel consumption metric over a
fuel economy metric. The panel also describes the primary purpose of
most heavy-duty vehicles as moving freight or passengers (the payload).
Therefore, they concluded that the most appropriate way to represent an
attribute-based fuel consumption metric is to normalize the fuel
consumption to the payload.
With the approach to compliance NHTSA and EPA are proposing, a
default payload is specified for each of the tractor categories
suggesting that a gram per mile metric with a specified payload and a
gram per ton-mile metric would be effectively equivalent. The primary
difference between the metrics and approaches relates to our treatment
of mass reductions as a means to reduce fuel consumption and greenhouse
gas emissions. In the case of a gram per mile metric, mass reductions
are reflected only in the calculation of the work necessary to move the
vehicle mass through the drive cycle. As such it directly reduces the
gram emissions in the numerator since a vehicle with less mass will
require less energy to move through the drive cycle leading to lower
CO2 emissions. In the case of Class 7 and 8 tractors and our
proposed gram/ton-mile metric, reductions in mass are reflected both in
less mass moved through the drive cycle (the numerator) and greater
payload (the denominator). We adjust the payload based on vehicle mass
reductions because we estimate that approximately one third of the time
the amount of freight loaded in a trailer is limited not by volume in
the trailer but by the total gross vehicle weight rating of the
tractor. By reducing the mass of the tractor the mass of the freight
loaded in the tractor can go up. Based on this general approach, it can
be estimated that for every 1,200 pounds in mass reduction total truck
vehicle miles traveled and therefore trucks on the road could be
reduced by one percent. Without the use of a per ton-mile metric it
would not be clear or straightforward for the agencies to reflect the
benefits of mass reduction from large freight carrying vehicles that
are often limited in the freight they carry by the gross vehicle weight
rating of the truck. The agencies seek comment on the use of a per ton-
mile metric and also whether other metrics such as per cube-mile should
be considered instead.
(c) Truck Aerodynamic Assessment
The aerodynamic drag of a vehicle is determined by the vehicle's
coefficient of drag (Cd), frontal area, air density and speed. The
agencies are proposing to establish and use pre-defined values for the
input parameters to GEM which represent the frontal area and air
density, while the speed of the vehicle would be determined in GEM
through the proposed drive cycles. The agencies are proposing that the
manufacturer would determine a truck's Cd, a dimensionless measure of a
vehicle's aerodynamics, for input into the model through a combination
of vehicle testing and vehicle design characteristics. Quantifying
truck aerodynamics as an input to the GEM presents technical challenges
because of the proliferation of truck configurations, the lack of a
clearly preferable standardized test method, and subtle variations in
measured Cd values among various test procedures. Class 7 and 8 tractor
aerodynamics are currently developed by manufacturers using a range of
techniques, including vehicle coastdown testing, wind tunnel testing,
computational fluid dynamics, and constant speed tests as further
discussed below. Reflecting that each of these approaches has
limitations and no one approach appears to be superior to others, the
agencies are proposing to allow all three aerodynamic evaluation
methods to be used in demonstrating a vehicle's aerodynamic
performance. The agencies welcome comments on each of these methods.
The agencies are proposing that the coefficient of drag assessment
be a product of test data and vehicle characteristics using good
engineering judgment. The primary tool the agencies expect to use in
our own evaluation of aerodynamic performance is the coastdown
procedure described in SAE Recommended Practice J2263. Allowing
manufacturers to use multiple test procedures and modeling coupled with
good engineering judgment to determine aerodynamic performance is
consistent with the current approach used in determining representative
road load forces for light-duty vehicle testing (40 CFR 86.129-
00(e)(1)). The agencies anticipate that as we and the industry gain
experience with assessing aerodynamic performance of HD vehicles for
purposes of compliance a test-only approach may have advantages.
We believe this broad approach allowing manufacturers to use
multiple different test procedures to demonstrate aerodynamic
performance is appropriate given that no single test procedure is
superior in all aspects to other approaches. However, we also recognize
the need for consistency and a level playing field in evaluating
aerodynamic performance. To accomplish this, the agencies propose to
use a two-part approach that evaluates aerodynamic performance not only
through testing but through the application of good engineering
judgment and a technical description of the vehicles aerodynamic
characteristics. The first part of the proposed evaluation approach
uses a bin structure characterizing the expected aerodynamic
performance of tractors based on definable vehicle attributes. This bin
approach is described further below. The second proposed evaluation
element uses aerodynamic testing to measure the vehicle's aerodynamic
performance under standardized conditions. The agencies expect that the
SAE J2263 coastdown procedures will be the primary aerodynamic testing
tool but are interested in working with the regulated industry and
other interested stakeholders to develop a primary test approach.
Additionally, the agencies propose to have a process that would allow
manufacturers to demonstrate that another aerodynamic test procedure
should also be allowed for purposes of generating inputs used in
assessing a truck's performance. We are requesting comment on methods
that should form the primary aerodynamic testing tool, methods that may
be appropriate as alternatives, and the mechanism (including standards,
practices, and unique criteria) for the agencies to consider allowing
alternative aerodynamic test methods.
NHTSA and EPA are proposing that manufacturers use a two part
screening approach for determining the aerodynamic inputs to the GEM.
The first part would require the manufacturers to assign each vehicle
aerodynamic configuration to one of five aerodynamics bins created by
EPA and NHTSA as described below. The assignment by bin reflects the
aerodynamic characteristics of the vehicle. For each bin, EPA and NHTSA
have already defined a nominal Cd that will be used in the GEM and a
range of Cd values that would be expected from testing of vehicles
meeting this bin description. The second part would require the
manufacturer to then compare its own test results of aerodynamic
performance (as conducted in accordance with the agencies'
requirements) for the vehicle to confirm the actual aerodynamic
performance was consistent with the agencies' expectations for vehicles
within this
[[Page 74182]]
bin. If the predicted performance and actual observed performance
match, the Cd value as an input for the GEM is the nominal Cd value
defined for the bin. If, however, a manufacturer's test data
demonstrates performance that is better than projected for the assigned
bin a manufacturer may use the test data and good engineering judgment
to demonstrate to the agencies that this particular vehicle's
performance is in keeping with the performance level of a more
aerodynamic bin and with the agencies' permission may use the Cd value
of the more aerodynamic bin. Conversely, if the test data demonstrates
that the performance is worse than the projected bin, then the
manufacturer would use the Cd value from the less aerodynamic bin.
Using this approach, the bin structure can be seen as the agencies'
first effort to create a common measure of aerodynamic performance to
benchmark the various test methods manufacturers may use to demonstrate
aerodynamic performance. For example, if a manufacturer's test methods
consistently produce Cd values that are better than projected by the
agencies, EPA and NHTSA can use this information to further scrutinize
the manufacturer's test procedure, helping to ensure that all
manufacturers are competing on a level playing field.
The agencies are proposing aerodynamic technology bins which divide
the wide spectrum of tractor aerodynamics into five bins (i.e.,
categories). The first category, ``Classic,'' represents tractor bodies
which prioritize appearance or special duty capabilities over
aerodynamics. The Classic trucks incorporate few, if any, aerodynamic
features and may have several features which detract from aerodynamics,
such as bug deflectors, custom sunshades, B-pillar exhaust stacks, and
others. The second category for aerodynamics is the ``Conventional''
tractor body. The agencies consider Conventional tractors to be the
average new tractor today which capitalizes on a generally aerodynamic
shape and avoids classic features which increase drag. Tractors within
the ``SmartWay'' category build on Conventional tractors with added
components to reduce drag in the most significant areas on the tractor,
such as fully enclosed roof fairings, side extending gap reducers, fuel
tank fairings, and streamlined grill/hood/mirrors/bumpers. The
``Advanced SmartWay'' aerodynamic category builds upon the SmartWay
tractor body with additional aerodynamic treatments such as underbody
airflow treatment, down exhaust, and lowered ride height, among other
technologies. And finally, ``Advanced SmartWay II'' tractors
incorporate advanced technologies which are currently in the prototype
stage of development, such as advanced gap reduction, rearview cameras
to replace mirrors, wheel system streamlining, and advanced body
designs. The agencies recognize that these proposed aerodynamic bins
are static and referential and that there may be other technologies
that may provide similar aerodynamic benefit. In addition, it is
expected that aerodynamic equipment will advance over time and the
agencies may find it appropriate and necessary to revise the bin
descriptions.
Under this proposal, the manufacturer would then input into GEM the
Cd value specified for each bin as also defined in Table II-4. For
example, if a manufacturer tests a Class 8 sleeper cab high roof
tractor with features which are similar to a SmartWay tractor and the
test produces a Cd value of 0.59, then the manufacturer would assign
this tractor to the Class 8 Sleeper Cab High Roof SmartWay bin. The
manufacturer would then use the Cd value of 0.60 as the input to GEM.
[GRAPHIC] [TIFF OMITTED] TP30NO10.015
[[Page 74183]]
Coefficient of drag and frontal area of the tractor-trailer
combination go hand-in-hand to determine the force required to overcome
aerodynamic drag. As explained above, the agencies are proposing that
the Cd value is one of the GEM inputs which will be derived by the
manufacturer. However, the agencies are proposing to specify the
truck's frontal area for each regulatory category (i.e., each of the
seven subcategories which are proposed and listed in Table II-4 under
the Aerodynamic Input to GEM). The frontal area of a high roof tractor
pulling a box trailer will be determined primarily by the box trailer's
dimensions and the ground clearance of the tractor. The frontal area of
low and mid roof tractors will be determined by the tractor itself. An
alternate approach to the proposed frontal area specification is to
create the aerodynamic input table (as shown in Table II-4) with values
that represent the Cd multiplied by the frontal area. This approach
will provide the same aerodynamic load, but it will not allow the
comparison of aerodynamic efficiency across regulatory categories that
can be done with the Cd values alone. The agencies are interested in
comments regarding the frontal area of trucks, specifically whether the
specified frontal areas are appropriate and whether the use of standard
frontal areas may have unanticipated consequences.
EPA and NHTSA recognize that wind conditions, most notably wind
direction, have a greater impact on real world CO2 emissions
and fuel consumption of heavy-duty trucks than of light-duty vehicles.
As noted in the NAS report,\44\ the wind average drag coefficient is
about 15 percent higher than the zero degree coefficient of drag. The
agencies considered proposing the use of a wind averaged drag
coefficient in this regulatory program, but ultimately decided to
propose using coefficient of drag values which represent zero yaw
(i.e., representing wind from directly in front of the vehicle, not
from the side) instead. We are taking this approach recognizing that
wind tunnels are currently the only tool to accurately assess the
influence of wind speed and direction on a truck's aerodynamic
performance. The agencies recognize, as NAS did, that the results of
using the zero yaw approach may result in fuel consumption predictions
that are offset slightly from real world performance levels, not unlike
the offset we see today between fuel economy test results in the CAFE
program and actual fuel economy performance observed in-use. We believe
this approach will not impact technology effectiveness or change the
kinds of technology decisions made by the tractor manufacturers in
developing equipment to meet our proposed standards. However, the
agencies are interested in receiving comment on approaches to develop
wind averaged coefficient of drag values using computational fluid
dynamics, coastdown, and constant speed test procedures.
---------------------------------------------------------------------------
\44\ See 2010 NAS Report, Note 19, Finding 2-4 on page 39.
---------------------------------------------------------------------------
The methodologies the agencies are considering for aerodynamic
assessment include coastdown testing, wind tunnel testing,
computational fluid dynamics, and constant speed testing. The agencies
welcome information on a constant speed test procedure and how it could
be applied to determine aerodynamic drag. In addition, the agencies
seek comment on allowing multiple aerodynamic assessment methodologies
and the need for comparison of aerodynamic assessment methods to
determine method precision and accuracy.
(i) Coastdown Testing
The coastdown test procedure has been used extensively in the
light-duty industry to capture the road load force by coasting a
vehicle along a flat straightaway under a set of prescribed conditions.
Coast down testing has been used less extensively to obtain road load
forces for medium- and heavy-duty vehicles. EPA has conducted a
significant amount of test work to demonstrate that coastdown testing
per SAE J2263 produces reasonably repeatable test results for Class 7
and 8 tractor/trailer pairings, as described in draft RIA Chapter 3.
The agencies propose that a manufacturer which chooses this method
would determine a tractor's Cd value through analysis of the road load
force equation derived from SAE J2263 Revised 2008-12 test results, as
proposed in 40 CFR 1066.210.
(ii) Wind Tunnel Testing
A wind tunnel provides a stable environment yielding a more
repeatable test than coastdown. This allows the manufacturer to run
multiple baseline vehicle tests and explore configuration modifications
for nearly the same effort (e.g., time and cost) as conducting the
coastdown procedure. In addition, wind tunnels provide testers with the
ability to yaw the vehicle at positive and negative angles relative to
the original centerline of the vehicle to accurately capture the
influence of non-uniform wind direction on the Cd (e.g., wind averaged
Cd).
The agencies propose to allow the use of existing wind tunnel
procedures adopted by SAE International with some minor modifications
as discussed in Section V of this proposal. The agencies seek comments
on the appropriateness of using the existing SAE wind tunnel
procedures, and the modifications to these procedures, for this
regulatory purpose.
(iii) Computational Fluid Dynamics
Computational fluid dynamics, or CFD, capitalizes on today's
computing power by modeling a full size vehicle and simulating the
flows around this model to examine the fluid dynamic properties, in a
virtual environment. CFD tools are used to solve either the Navier-
Stokes equations that relate the physical law of conservation of
momentum to the flow relationship around a body in motion or a static
body with fluid in motion around it, or the Boltzman equation that
examines fluid mechanics and determines the characteristics of
discreet, individual particles within a fluid and relates this behavior
to the overall dynamics and behavior of the fluid. CFD analysis
involves several steps: Defining the model structure or geometry based
on provided specifications to define the basic model shape; applying a
closed surface around the structure to define the external model shape
(wrapping or surface meshing); dividing the control volume, including
the model and the surrounding environment, up into smaller, discreet
shapes (gridding); defining the flow conditions in and out of the
control volume and the flow relationships within the grid (including
eddies and turbulence); and solving the flow equations based on the
prescribed flow conditions and relationships.
This approach can be beneficial to manufacturers since they can
rapidly prototype (e.g., design, research, and model) an entire vehicle
without investing in material costs; they can modify and investigate
changes easily; and the data files can be re-used and shared within the
company or with corporate partners.
The accuracy of the outputs from CFD analysis is highly dependent
on the inputs. The CFD modeler decides what method to use for wrapping,
how fine the mesh cell and grid size should be, and the physical and
flow relationships within the environment. A balance must be achieved
between the number of cells, which defines how fine the mesh is, and
the computational times for a result (i.e., solution-time-efficiency).
All of these decisions affect the results of the CFD aerodynamic
assessment.
[[Page 74184]]
Because CFD modeling is dependent on the quality of the data input
and the design of the model, the agencies propose and seek comment on a
minimum set of criteria applicable to using CFD for aerodynamic
assessment in Section V.
(d) Tire Rolling Resistance Assessment
NHTSA and EPA are proposing that the tractor's tire rolling
resistance input to the GEM be determined by either the tire
manufacturer or tractor manufacturer using the test method adopted by
the International Organization for Standardization, ISO 28580:2009.\45\
The agencies believe the ISO test procedure is appropriate to propose
for this program because the procedure is the same one used by NHTSA in
its fuel efficiency tire labeling program \46\ and is consistent with
the direction being taken by the tire industry both in the United
States and Europe. The rolling resistance from this test would be used
to specify the rolling resistance of each tire on the steer and drive
axle of the vehicle. The results would be expressed as a rolling
resistance coefficient and measured as kilogram per metric ton (kg/
metric ton). The agencies are proposing that three tire samples within
each tire model be tested three times each to account for some of the
production variability and the average of the nine tests would be the
rolling resistance coefficient for the tire. The GEM would use a
combined tire rolling resistance, where 15 percent of the gross weight
of the truck and trailer would be distributed to the steer axle, 42.5
percent to the drive axles, and 42.5 percent to the trailer axles.\47\
The trailer tires' rolling resistance would be prescribed by the
agencies as part of the standardized trailer used for demonstrating
compliance at 6 kg/metric ton, which was the average trailer tire
rolling resistance measured during the SmartWay tire testing.\48\
---------------------------------------------------------------------------
\45\ ISO, 2009, Passenger Car, Truck, and Bus Tyres--Methods of
Measuring Rolling Resistance--Single Point Test and Correlation of
Measurement Results: ISO 28580:2009(E), First Edition, 2009-07-01.
\46\ NHTSA, 2009. ``NHTSA Tire Fuel Efficiency Consumer
Information Program Development: Phase 1--Evaluation of Laboratory
Test Protocols.'' DOT HS 811 119. June. (http://www.regulations.gov,
Docket ID: NHTSA-2008-0121-0019).
\47\ This distribution is equivalent to the Federal over-axle
weight limits for an 80,000 GVWR 5-axle tractor-trailer: 12,000
Pounds over the steer axle, 34,000 pounds over the tandem drive
axles (17,000 pounds per axle) and 34,000 pounds over the tandem
trailer axles (17,000 pounds per axle).
\48\ U.S. Environmental Protection Agency. SmartWay Transport
Partnership July 2010 e-update accessed July 16, 2010, from http://www.epa.gov/smartwaylogistics/newsroom/documents/e-update-july-10.pdf.
---------------------------------------------------------------------------
We acknowledge that the useful life of original equipment tires
used on tractors is shorter than the tractor's useful life. In this
proposal, we are treating the tires as if the owner replaces the tire
with tires that match the original equipment. Some owners opt for the
original tires under the assumption that this is the best product.
However, tractor tires are often retreaded or replaced. Steer tires on
a highway tractor might need replacement after 75,000 to 150,000 miles.
Drive tires might need retreading or replacement after 150,000 to
300,000 miles. Of course, tire removal miles can be much higher or
lower, depending upon a number of factors that affect tire removal
miles. These include the original tread depth; desired tread depth at
removal to maintain casing integrity; tire material and construction;
typical load; tire ``scrub'' due to urban driving and set back axles;
and, tire under-inflation. Since it is common for both medium- and
heavy-duty truck tires to be replaced and retreaded, we welcome
comments in this area. We are specifically seeking data for the rolling
resistance of retread and replacement heavy-duty tires and the typical
useful life of tractor tires.
(e) Weight Reduction Assessment
EPA and NHTSA are seeking to account for the emissions and fuel
consumption benefits of weight reduction as a control technology in
heavy-duty trucks. Weight reduction impacts the emissions and fuel
consumption performance of tractors in different ways depending on the
truck's operation. For trucks that cube-out, the weight reduction will
show a small reduction in grams of CO2 emitted or fuel
consumed per mile travelled. The benefit is small because the weight
reduction is minor compared to the overall weight of the combination
tractor and payload. However, a weight reduction in tractors which
operate at maximum gross vehicle weight rating would result in an
increase in payload capacity. Increased vehicle payload without
increased GVWR significantly reduces fuel consumption and
CO2 emissions per ton mile of freight delivered. It also
leads to fewer vehicle miles driven with a proportional reduction in
traffic accidents.
The empty curb weight of tractors varies significantly today. Items
as common as fuel tanks can vary between 50 and 300 gallons each for a
given truck model. Information provided by truck manufacturers
indicates that there may be as much as a 5,000 to 17,000 pound
difference in curb weight between the lightest and heaviest tractors
within a regulatory subcategory (such as Class 8 sleeper cab with a
high roof). Because there is such a large variation in the baseline
weight among trucks that perform roughly similar functions with roughly
similar configurations, there is not an effective way to quantify the
exact CO2 and fuel consumption benefit of mass reduction
using GEM because of the difficulty in establishing a baseline.
However, if the weight reduction is limited to tires and wheels, then
both the baseline and weight differentials for these are readily
quantifiable and well-understood. Therefore, the agencies are proposing
that the mass reduction that would be simulated be limited only to
reductions in wheel and tire weight. In the context of this heavy-duty
vehicle program with only changes to tires and wheels, the agencies do
not foresee any related impact on safety.\49\ The agencies welcome
comments regarding this approach and detailed data to further improve
the robustness of the agencies' assumed baseline truck tare/curb
weights for each regulatory category used within the model, as outlined
in draft RIA Chapter 3.5.
---------------------------------------------------------------------------
\49\ For more information on the estimated safety effects of
this proposed rule, see Chapter 9 of the draft RIA.
---------------------------------------------------------------------------
EPA and NHTSA are proposing to specify the baseline vehicle weight
for each regulatory category (including the tires and wheels), but
allow manufacturers to quantify weight reductions based on the wheel
material selection and single wide versus dual tires per Table II-5.
The agencies assume the baseline wheel and tire configuration contains
dual tires with steel wheels because these represent the vast majority
of new vehicle configurations today. The proposed weight reduction due
to the wheels and tires would be reflected in the payload tons by
increasing the specified payload by the weight reduction amount
discounted by two thirds to recognize that approximately one third of
the truck miles are travelled at maximum payload, as discussed below in
the payload discussion.
[[Page 74185]]
[GRAPHIC] [TIFF OMITTED] TP30NO10.016
(f) Extended Idle Reduction Technology Assessment
Extended idling from Class 8 heavy-duty long haul combination
tractors contributes to significant CO2 emissions and fuel
consumption in the United States. The Federal Motor Carrier Safety
Administration regulations require a certain amount of driver rest for
a corresponding period of driving hours.\50\ Extended idle occurs when
Class 8 long haul drivers rest in the sleeper cab compartment during
rest periods as drivers find it both convenient and less expensive to
rest in the truck cab itself than to pull off the road and find
accommodations. During this rest period a driver will idle the truck in
order to provide heating or cooling or run on-board appliances. In some
cases the engine can idle in excess of 10 hours. During this period,
the truck will consume approximately 0.8 gallons of fuel and emit over
8,000 grams of CO2 per hour. An average truck can consume 8
gallons of fuel and emit over 80,000 grams of CO2 during
overnight idling in such a case.
---------------------------------------------------------------------------
\50\ Federal Motor Carrier Safety Administration. Hours of
Service Regulations. Last accessed on August 2, 2010 at http://www.fmcsa.dot.gov/rules-regulations/topics/hos/.
---------------------------------------------------------------------------
Idling reduction technologies are available to allow for driver
comfort while reducing fuel consumptions and CO2 emissions.
Auxiliary power units, fuel operated heaters, battery supplied air
conditioning, and thermal storage systems are among the technologies
available today. The agencies are proposing to include extended idle
reduction technology as an input to the GEM for Class 8 sleeper cabs.
The manufacturer would input the value based on the idle reduction
technology installed on the truck. As discussed further in Section III,
if a manufacturer chooses to use idle reduction technology to meet the
standard, then it would require an automatic main engine shutoff after
5 minutes to help ensure the idle reductions are realized in-use. As
with all of the technology inputs discussed in this section, the
agencies are not mandating the use of idle reductions or idle shutdown,
but rather allowing their use as one part of a suite of technologies
feasible for reducing fuel consumption and meeting the proposed
standards. The proposed value (5 g CO2/ton-mile or 0.5 gal/
1,000 ton-mile) for the idle reduction technologies was determined
using an assumption of 1,800 idling hours per year, 125,000 miles
travelled, and a baseline idle fuel consumption of 0.8 gallons per
hour. Additional detail on the emission and fuel consumption reduction
values are included in draft RIA Chapter 2.
(g) Vehicle Speed Limiters
Fuel consumption and CO2 emissions increase proportional
to the square of vehicle speed.\51\ Therefore, lowering vehicle speeds
can significantly reduce fuel consumption and GHG emissions. A vehicle
speed limiter (VSL), which limits the vehicle's maximum speed, is a
simple technology that is utilized today. The feature is electronically
programmed and controlled. Manufacturers today sell trucks with vehicle
speed limiters and allow the customers to set the limit. However, as
proposed the GEM will not provide a fuel consumption reduction for a
limiter that can be overridden. In order to obtain a benefit for the
program, the manufacturer must preset the limiter in such a way that
the setting will not be capable of being easily overridden by the fleet
or the owner. As with other engine calibration aspects of emission
controls, tampering with a calibration would be considered unlawful by
EPA. If the manufacturer installs a vehicle speed limiter into a truck
that is not easily overridden, then the manufacturer would input the
vehicle speed limit setpoint into GEM.
---------------------------------------------------------------------------
\51\ See 2010 NAS Report, Note 19, Page 28. Road Load Force
Equation defines the aerodynamic portion of the road load as \1/2\ *
Coefficient of Drag * Frontal Area * air density * vehicle speed
squared.
---------------------------------------------------------------------------
(h) Defined Vehicle Configurations in the GEM
As discussed above, the agencies are proposing methodologies that
manufacturers would use to quantify the values to be input into the GEM
for these factors affecting truck efficiency: Coefficient of Drag, Tire
Rolling Resistance Coefficient, Weight Reduction, Vehicle Speed
Limiter, and Extended Idle Reduction Technology. The other aspects of
vehicle performance are fixed within the model and are not varied for
the purpose of compliance. The defined inputs being proposed include
the drive cycle, tractor-trailer combination curb weight, payload,
engine characteristics, and drivetrain for each vehicle type, and
others. We are seeking comments accompanied with data on the defined
model inputs as described in draft RIA Chapter 4.
(i) Vehicle Drive Cycles
As noted by the 2010 NAS Report,\52\ the choice of a drive cycle
used in compliance testing has significant consequences on the
technology that will be employed to achieve a standard as well as the
ability of the technology to achieve real world reductions in emissions
and improvements in fuel consumption. Manufacturers naturally will
design vehicles to ensure they satisfy regulatory standards. If the
agencies propose an ill-suited drive cycle for a regulatory category,
it may encourage GHG emissions and fuel consumption technologies which
satisfy the test but do not achieve the same benefits in use. For
example, requiring all trucks to use a constant speed highway drive
cycle will drive significant aerodynamic improvements. However, in the
real world a combination tractor used for local
[[Page 74186]]
delivery may spend little time on the highway, reducing the benefits
that would be achieved by this technology. In addition, the extra
weight of the aerodynamic fairings will actually penalize the GHG and
fuel consumption performance in urban driving and may reduce the
freight carrying capability. The unique nature of the kinds of
CO2 emissions control and fuel consumption technology means
that the same technology can be of benefit during some operation but
cause a reduced benefit under other operation.\53\ To maximize the GHG
emissions and fuel consumption benefits and avoid unintended reductions
in benefits, the drive cycle should focus on promoting technology that
produces benefits during the primary operation modes of the
application. Consequently, drive cycles used in GHG emissions and fuel
consumption compliance testing should reasonably represent the primary
actual use, notwithstanding that every truck has a different drive
cycle in-use.
---------------------------------------------------------------------------
\52\ See 2010 NAS Report, Note 19, Chapters 4 and 8.
\53\ This situation does not typically occur for heavy-duty
emission control technology designed to control criteria pollutants
such as PM and NOX.
---------------------------------------------------------------------------
The agencies are proposing a modified version of the California ARB
Heavy Heavy-duty Truck 5 Mode Cycle,\54\ using the basis of three of
the cycles which best mirror Class 7 and 8 combination tractor driving
patterns, based on information from EPA's MOVES model.\55\ The key
advantage of the California ARB 5 mode cycle is that it provides the
flexibility to use several different modes and weight the modes to fit
specific truck application usage patterns. EPA analyzed the five cycles
and found that some modifications to the modes appear to be needed to
allow sufficient flexibility in weightings. The agencies are proposing
the use of the Transient mode, as defined by California ARB, because it
broadly covers urban driving. The agencies are also proposing altered
versions of the High Speed Cruise and Low Speed Cruise modes which
would reflect only constant speed cycles at 65 mph and 55 mph
respectively. EPA and NHTSA relied on the EPA MOVES analysis of Federal
Highway Administration data to develop the proposed mode weightings to
characterize typical operations of heavy-duty trucks, per Table II-6
below.\56\ A detailed discussion of drive cycles is included in draft
RIA Chapter 3.\57\
---------------------------------------------------------------------------
\54\ California Air Resources Board. Heavy Heavy-duty Diesel
Truck chassis dynamometer schedule, Transient Mode. Last accessed on
August 2, 2010 at http://www.dieselnet.com/standards/cycles/hhddt.html.
\55\ EPA's MOVES (Motor Vehicle Emission Simulator). See http://www.epa.gov/otaq/models/moves/index.htm for additional information.
\56\ The Environmental Protection Agency. Draft MOVES2009
Highway Vehicle Population and Activity Data. EPA-420-P-09-001,
August 2009 http://www.epa.gov/otaq/models/moves/techdocs/420p09001.pdf.
\57\ In the light-duty vehicle rule, EPA and NHTSA based
compliance with tailpipe standards on use of the FTP and HFET, and
declined to use alternative tests. See 75 FR 25407. NHTSA is
mandated to use the FTP and HFET tests for CAFE standards, and all
relevant data was obtained by FTP and HFET testing in any case. Id.
Neither of these constraints exists for Class 7-8 tractors. The
little data which exist on current performance are principally
measured by the ARB Heavy Heavy-duty Truck 5 Mode Cycle testing, and
NHTSA is not mandated to use the FTP to establish heavy-duty fuel
economy standards. See 49 U.S.C. 32902(k)(2) authorizing NHTSA,
among other things, to adopt and implement appropriate ``test
methods, measurement metrics, * * * and compliance protocols''.
[GRAPHIC] [TIFF OMITTED] TP30NO10.017
(ii) Empty Weight and Payload
The total weight of the tractor-trailer combination is the sum of
the tractor curb weight, the trailer curb weight, and the payload. The
total weight of a truck is important because it in part determines the
impact of technologies, such as rolling resistance, on GHG emissions
and fuel consumption. The agencies are proposing to specify each of
these aspects of the vehicle.
The agencies developed the proposed tractor curb weight inputs from
actual tractor weights measured in two of EPA's test programs and based
on information from the manufacturers. The proposed trailer curb weight
inputs were derived from actual trailer weight measurements conducted
by EPA and weight data provided to ICF International by the trailer
manufacturers.\58\ Details of the individual weight inputs by
regulatory category are included in draft RIA Chapter 3.
---------------------------------------------------------------------------
\58\ ICF International. Investigation of Costs for Strategies to
Reduce Greenhouse Gas Emissions for Heavy-Duty On-road Vehicles.
July 2010. Pages 4-15. Docket Number EPA-HQ-OAR-2010-0162-0044.
---------------------------------------------------------------------------
There are several methods that the agencies have considered for
evaluating the GHG emissions and fuel consumption of tractors used to
carry freight. A key factor in these methods is the weight of the truck
that is assumed for purposes of the evaluation. In use, trucks operate
at different weights at different times during their operations. The
greatest freight transport efficiency (the amount of fuel required to
move a ton of payload) would be achieved by operating trucks at the
maximum load for which they are designed all of the time. However,
logistics such as delivery demands which require that trucks travel
without full loads, the density of payload, and the availability of
full loads of freight limit the ability of trucks to operate at their
highest efficiency all the time. M.J. Bradley analyzed the Truck
Inventory and Use Survey and found that approximately 9 percent of
combination tractor miles travelled empty, 61 percent are ``cubed-out''
(the trailer is full before the weight limit is reached), and 30
percent are ``weighed out'' (operating weight equal 80,000 pounds which
is the gross vehicle weight limit on the Federal Interstate Highway
System or greater than 80,000 pounds for vehicles traveling on roads
outside of the interstate system).\59\
---------------------------------------------------------------------------
\59\ M.J. Bradley & Associates. Setting the Stage for Regulation
of Heavy-Duty Vehicle Fuel Economy and GHG Emissions: Issues and
Opportunities. February 2009. Page 35. Analysis based on 1992 Truck
Inventory and Use Survey data, where the survey data allowed
developing the distribution of loads instead of merely the average
loads.
---------------------------------------------------------------------------
As described above, the amount of payload that a tractor can carry
depends on the category (or GVWR) of the vehicle. For example, a
typical Class 7 tractor can carry less payload than a Class 8 tractor.
The Federal Highway Administration developed Truck Payload Equivalent
Factors to inform the development of highway system strategies using
Vehicle Inventory and Use Survey (VIUS) and Vehicle Travel Information
System data. Their results
[[Page 74187]]
found that the average payload of a Class 8 truck ranged from 36,247 to
40,089 pounds, depending on the average distance travelled per day.\60\
The same results found that Class 7 trucks carried between 18,674 and
34,210 pounds of payload also depending on average distance travelled
per day. Based on this data, the agencies are proposing to prescribe a
fixed payload of 25,000 pounds for Class 7 tractors and 38,000 pounds
for Class 8 tractors for their respective test procedures. The agencies
are proposing a common payload for Class 8 day cabs and sleeper cabs
because the data available does not distinguish based on type of Class
8 tractor. These payload values represent a heavily loaded trailer, but
not maximum GVWR, since as described above the majority of tractors
``cube-out'' rather than ``weigh-out.'' Additional details on proposed
payloads are included in draft RIA Chapter 3.
---------------------------------------------------------------------------
\60\ The U.S. Federal Highway Administration. Development of
Truck Payload Equivalent Factor. Table 11. Last viewed on March 9,
2010 at http://ops.fhwa.dot.gov/freight/freight_analysis/faf/faf2_reports/reports9/s510_11_12_tables.htm.
---------------------------------------------------------------------------
(iii) Standardized Trailers
NHTSA and EPA are proposing that the tractor performance in the GEM
would be judged by assuming it is pulling a standardized trailer. The
agencies believe that an assessment of the tractor aerodynamics should
be conducted using a tractor-trailer combination to reflect the impact
of aerodynamic technologies in actual use, where tractors are designed
and used with a trailer. Assessing the tractor aerodynamics using only
the tractor would not be a reasonable way to assess in-use impacts. For
example, the in-use aerodynamic drag while pulling a trailer is
different than without the trailer and the full impact of an
aerodynamic technology on reducing emissions and fuel consumption would
not be reflected if the assessment is performed on a tractor without a
trailer.
In addition to assessing the tractor with a trailer, it is
appropriate to adopt a standardized trailer used for testing, and to
vary the standardized trailer by the regulatory category. This is
similar to the standardization of payload discussed above, as a way to
reasonably reflect in-use operating conditions. High roof tractors are
optimally designed to pull box trailers. The roof fairing on a tractor
is the feature designed to minimize the height differential between the
tractor and typical trailer to reduce the air flow disruption. Low roof
tractors are designed to carry flat bed or low-boy trailers. Mid roof
tractors are designed to carry tanker and bulk carrier trailers. The
agencies conducted a survey of tractor-trailer pairing in-use to
evaluate the representativeness of this premise. The survey of over
3,000 tractor-trailer combinations found that in 95 percent of the
combination tractors the tractor's roof height was paired appropriately
for the type of trailer that it was pulling.\61\ The agencies also have
evaluated the impact of pairing a low roof tractor with a box trailer
in coastdown testing and found that the aerodynamic force increases by
20 percent over a high roof tractor pulling the same box trailer.\62\
Therefore, drivers have a large incentive to use the appropriate
matching to reduce their fuel costs. However, the agencies recognize
that in operation tractors sometimes pull trailers other than the type
that it was designed to carry. The agencies are proposing the matching
of trailers to roof height for the test procedure. To do otherwise
would necessarily result in a standard reflecting substandard
aerodynamic performance, and thereby result in standards which are less
stringent than would be appropriate based on the reasonable assumption
that tractors will generally pair with trailer of appropriate roof
height. The other aspects of the test procedure such as empty trailer
weight, location of payload, and tractor-trailer gap are being proposed
for each regulatory category to provide consistent test procedures.
---------------------------------------------------------------------------
\61\ U.S. EPA. Truck and Trailer Roof Height Match Analysis
Memorandum from Amy Kopin to the Docket, August 9, 2010. Docket
Identification Number EPA-HQ-OAR-2010-0162-0045.
\62\ See the draft RIA Chapter 2 for additional detail.
---------------------------------------------------------------------------
(iv) Standardized Drivetrain
The agencies' assessment of the current vehicle configuration
process at the truck dealer's level is that the truck companies provide
tools to specify the proper drivetrain matched to the buyer's specific
circumstances. These dealer tools allow a significant amount of
customization for drive cycle and payload to provide the best
specification for the customer. The agencies are not seeking to disrupt
this process. Optimal drivetrain selection is dependent on the engine,
drive cycle (including vehicle speed and road grade), and payload. Each
combination of engine, drive cycle, and payload has a single optimal
transmission and final drive ratio. The agencies are proposing to
specify the engine's fuel consumption map, drive cycle, and payload;
therefore, it makes sense to also specify the drivetrain that matches.
(v) Engine Input to GEM
As the agencies are proposing separate engine and tractor
standards, the GEM will be used to assess the compliance of the tractor
with the tractor standard. To maintain the separate assessments, the
agencies are proposing to define the engine characteristics used in
GEM, including the fuel consumption map which provides the fuel
consumption at hundreds of engine speed and torque points. If the
agencies did not standardize the fuel map, then a tractor that uses an
engine with emissions and fuel consumption better than the standards
would require fewer vehicle reductions than those technically feasible
reductions being proposed. The agencies are proposing two distinct fuel
consumption maps for use in GEM. EPA proposes the first fuel
consumption map would be used in GEM for the 2014 through 2016 model
years and represents an average engine which meets the 2014 model year
engine CO2 emissions standards being proposed. NHTSA
proposes to use the same fuel map for its voluntary standards in the
2014 and 2015 model years, as well as its mandatory program in the 2016
model year. A second fuel consumption map would be used beginning in
2017 model year and represents an engine which meets the 2017 model
year CO2 emissions and fuel consumption standards and
accounts for the increased stringency in the proposed MY 2017 standard.
Effectively there is no change in stringency of the tractor vehicle
(not including the engine) and there is stability in the tractor
vehicle (not including engine) standards for the full rulemaking
period.\63\ These inputs are appropriate given the separate proposed
regulatory requirement that Class 7 and 8 combination tractor
manufacturers use only certified engines.
---------------------------------------------------------------------------
\63\ As noted earlier, use of the 2017 model year fuel
consumption map as a GEM input results in numerically more stringent
proposed vehicle standards for MY 2017.
---------------------------------------------------------------------------
(i) Engine Test Procedure
The NAS panel did not specifically discuss or recommend a metric to
evaluate the fuel consumption of heavy-duty engines. However, as noted
above they did recommend the use of a load-specific fuel consumption
metric for the evaluation of vehicles.\64\ An analogous metric for
engines would be the amount of fuel consumed per unit of work. Thus,
EPA is proposing that GHG emission standards for engines under the CAA
would be expressed as g/bhp-
[[Page 74188]]
hr; NHTSA's proposed fuel consumption standards under EISA, in turn,
would be represented as gal/100 bhp-hr. This metric is also consistent
with EPA's current standards for non-GHG emissions for these engines.
---------------------------------------------------------------------------
\64\ See NAS Report, Note 19, at page 39.
---------------------------------------------------------------------------
EPA's criteria pollutant standards for engines require that
manufacturers demonstrate compliance over the transient Heavy-duty FTP
test cycle; the steady-state SET test cycle; and the not-to-exceed test
(NTE test). EPA created this multi-layered approach to criteria
emissions control in response to engine designs that optimized
operation for lowest fuel consumption at the expense of very high
criteria emissions when operated off the regulatory cycle. EPA's use of
multiple test procedures for criteria pollutants helps to ensure that
manufacturers calibrate engine systems for compliance under all
operating conditions. With regard to GHG and fuel consumption control,
the agencies believe it is more appropriate to set standards based on a
single test procedure, either the Heavy-duty FTP or SET, depending on
the primary expected use of the engine. For engines used primarily in
line-haul combination tractor trailer operations, we believe the
steady-state SET procedure more appropriately reflects in-use engine
operation. By setting standards based on the most representative test
cycle, we can have confidence that engine manufacturers will design
engines for the best GHG and fuel consumption performance relative to
the most common type of expected engine operation. There is no
incentive to design the engines to give worse fuel consumption under
other types of operation, relative to the most common type of
operation, and we are not concerned if manufacturers further calibrate
these designs to give better in-use fuel consumption during other
operation, while maintaining compliance with the criteria emissions
standards as such calibration is entirely consistent with the goals of
our joint program.
Further, we are concerned that setting standards based on both
transient and steady-state operating conditions for all engines could
lead to undesirable outcomes. For example, turbocompounding is one
technology that the agencies have identified as a likely approach for
compliance against our proposed HHD SET standard described below.
Turbocompounding is a very effective approach to lower fuel consumption
under steady driving conditions typified by combination tractor trailer
operation and is well reflected in testing over the SET test procedure.
However, when used in driving typified by transient operation as we
expect for vocational vehicles and as is represented by the Heavy-duty
FTP, turbocompounding shows very little benefit. Setting an emission
standard based on the Heavy-duty FTP only for engines intended for use
in combination tractor trailers could lead manufacturers to not apply
turbocompounding because the full benefits are not demonstrated on the
Heavy-duty FTP even though it can be a highly cost-effective means to
reduce GHG emissions and lower fuel consumption in more steady state
applications.
The current non-GHG emissions engine test procedures also require
the development of regeneration emission rates and frequency factors to
account for the emission changes during a regeneration event (40 CFR
86.004-28). EPA and NHTSA are proposing to exclude the CO2
emissions and fuel consumption increases due to regeneration from the
calculation of the compliance levels over the defined test procedures.
We considered including regeneration in the estimate of fuel
consumption and GHG emissions and have decided not to do so for two
reasons. First, EPA's existing criteria emission regulations already
provide a strong motivation to engine manufacturers to reduce the
frequency and duration of infrequent regeneration events. The very
stringent 2010 NOX emission standards cannot be met by
engine designs that lead to frequent and extend regeneration events.
Hence, we believe engine manufacturers are already reducing
regeneration emissions to the greatest degree possible.
In addition to believing that regenerations are already controlled
to the extent technologically possible, we believe that attempting to
include regeneration emissions in the standard setting could lead to an
inadvertently lax emissions standard. In order to include regeneration
and set appropriate standards, EPA and NHTSA would have needed to
project the regeneration frequency and duration of future engine
designs in the timeframe of this proposal. Such a projection would be
inherently difficult to make and quite likely would underestimate the
progress engine manufacturers will make in reducing infrequent
regenerations. If we underestimated that progress, we would effectively
be setting a more lax set of standards than otherwise would be
expected. Hence in setting a standard including regeneration emissions
we faced the real possibility that we would achieve less effective
CO2 emissions control and fuel consumption reductions than
we will achieve by not including regeneration emissions. We are seeking
comments regarding regeneration emissions and what approach if any the
agencies should use in reflecting regeneration emissions in this
program.
In conclusion, for Class 7 and 8 tractors, compliance with the
vehicle standard would be determined by establishing values for the
variable inputs and using the prescribed inputs in GEM and compliance
against the engine standard using the SET engine cycle. The model would
produce CO2 and fuel consumption results that would be
compared against EPA's and NHTSA's respective standards.
(j) Chassis-Based Test Procedure
The agencies also considered proposing a chassis-based vehicle test
to evaluate Class 7 and 8 tractors based on a laboratory test of the
engine and vehicle together. A ``chassis dynamometer test'' for heavy-
duty vehicles would be similar to the Federal Test Procedure used today
for light-duty vehicles.
However, the agencies decided not to propose the use of a chassis
test procedure to demonstrate compliance for tractor standards due to
the significant technical hurdles to implementing such a program by the
2014 model year. The agencies recognize that such testing requires
expensive, specialized equipment that is not yet widespread within the
industry. The agencies have only identified approximately 11 heavy-duty
chassis sites in the United States today and rapid installation of new
facilities to comply with model year 2014 is not possible.\65\
---------------------------------------------------------------------------
\65\ For comparison, engine manufacturers typically own a large
number of engine dynamometer test cells for engine development and
durability (up to 100 engine dynamometers per manufacturer).
---------------------------------------------------------------------------
In addition, and of equal if not greater importance, because of the
enormous numbers of truck configurations that have an impact on fuel
consumption, we do not believe that it would be reasonable to require
testing of many combinations of tractor model configurations on a
chassis dynamometer. The agencies evaluated the options available for
one tractor model (provided as confidential business information from a
truck manufacturer) and found that the company offered three cab
configurations, six axle configurations, five front axles, 12 rear
axles, 19 axle ratios, eight engines, 17 transmissions, and six tire
sizes--where each of these options could impact the fuel consumption
and CO2 emissions of the
[[Page 74189]]
tractor. Even using representative grouping of tractors for purposes of
certification, this presents the potential for many different
combinations that would need to be tested if a standard was adopted
based on a chassis test procedure.
Although the agencies are not proposing the use of a complete
chassis based test procedure for Class 7 and 8 tractors, we believe
such an approach could be appropriate in the future, if more testing
facilities become available and if the agencies are able to address the
complexity of tractor configurations issue described above. We request
comments on the potential use of chassis based test procedures in the
future to augment or replace the model based approach we are proposing.
(3) Summary of Proposed Flexibility and Credit Provisions
EPA and NHTSA are proposing four flexibility provisions
specifically for heavy-duty tractor and engine manufacturers, as
discussed in Section IV below. These are an averaging, banking and
trading program for emissions and fuel consumption credits, as well as
provisions for early credits, advanced technology credits, and credits
for innovative vehicle or engine technologies which are not included as
inputs to the GEM or are not demonstrated on the engine SET test cycle.
The agencies are proposing that credits earned by manufacturers
under this ABT program be restricted for use to only within the same
regulatory subcategory for two reasons. First, relating credits between
categories is tenuous because of the differences in regulatory useful
lives. We want to avoid having credits from longer useful life
categories flooding shorter useful life categories, adversely impacting
compliance with CO2 or fuel consumption standards in the
shorter useful life category, and we have not based the level of the
standard on such impact on compliance. In addition, extending the use
of credits beyond these designated categories could inadvertently have
major impacts on the competitive market place, and we want to avoid
such results. For example, a manufacturer which has multiple engine
offerings over several regulatory categories could mix credits across
engine categories and shift the burden between them, possibly impacting
the competitive market place. Similarly, integrated manufacturers which
produce both engines and trucks could shift credits between engines and
trucks and have a similar effect. We would like to ensure that this
proposal reduces the CO2 emissions and fuel consumption but
does not inadvertently have such impacts on the market place. However,
we welcome comments on the extension of credits beyond the limitations
we are proposing.
The agencies are also proposing to provide provisions to
manufacturers for early credits, the use of advanced technologies and
innovative technologies which are described in greater detail in
Section IV.
(4) Deferral of Standards for Tractor and Engine Manufacturing
Companies That Are Small Businesses
EPA and NHTSA are proposing to defer greenhouse gas emissions and
fuel consumption standards for small tractor or engine manufacturers
meeting the Small Business Administration (SBA) size criteria of a
small business as described in 13 CFR 121.201.\66\ The agencies will
instead consider appropriate GHG and fuel consumption standards for
these entities as part of a future regulatory action. This includes
both U.S.-based and foreign small volume heavy-duty tractor or engine
manufacturers.
---------------------------------------------------------------------------
\66\ See Sec. 1036.150 and Sec. 1037.150.
---------------------------------------------------------------------------
The agencies have identified two entities that fit the SBA size
criterion of a small business.\67\ The agencies estimate that these
small entities comprise less than 0.5 percent of the total heavy-duty
combination tractors in the United States based on Polk Registration
Data from 2003 through 2007,\68\ and therefore that the exemption will
have a negligible impact on the GHG emissions and fuel consumption
improvements from the proposed standards.
---------------------------------------------------------------------------
\67\ The agencies have identified Ottawa Truck, Inc. and Kalmar
Industries USA as two potential small tractor manufacturers.
\68\ M.J. Bradley. Heavy-duty Vehicle Market Analysis. May 2009.
---------------------------------------------------------------------------
To ensure that the agencies are aware of which companies would be
exempt, we propose to require that such entities submit a declaration
to EPA and NHTSA containing a detailed written description of how that
manufacturer qualifies as a small entity under the provisions of 13 CFR
121.201.
C. Heavy-Duty Pickup Trucks and Vans
The primary elements of the EPA and NHTSA programs being proposed
for complete HD pickups and vans are presented in this section. These
provisions also cover incomplete HD pickups and vans that are sold by
vehicle manufacturers as cab-chassis (chassis-cab, box-delete, bed-
delete, cut-away van) vehicles, as discussed in detail in Section
V.B(1)(e). Section II.C(1) explains the proposed form of the
CO2 and fuel consumption standards, the proposed numerical
levels for those standards, and the proposed approach to phasing in the
standards over time. The proposed measurement procedure for determining
compliance is discussed in Section II.C(2), and the proposed EPA and
NHTSA compliance programs are discussed in Section II.C(3). Sections
II.C(4) discusses proposed implementation flexibility provisions.
Section II.E discusses additional standards and provisions for
N2O and CH4 emissions, for impacts from vehicle
air conditioning, and for ethanol-fueled and electric vehicles.
(1) What Are the Proposed Levels and Timing of HD Pickup and Van
Standards?
(a) Vehicle-Based Standards
About 90 percent of Class 2b and 3 vehicles are pickup trucks,
passenger vans, and work vans that are sold by the vehicle
manufacturers as complete vehicles, ready for use on the road. In
addition, most of these complete HD pickups and vans are covered by CAA
vehicle emissions standards for criteria pollutants today (i.e., they
are chassis tested similar to light-duty), expressed in grams per mile.
This distinguishes this category from other, larger heavy-duty vehicles
that typically have only the engines covered by CAA engine emission
standards, expressed in grams per brake horsepower-hour.\69\ As a
result, Class 2b and 3 complete vehicles share much more in common with
light-duty trucks than with other heavy-duty vehicles.
---------------------------------------------------------------------------
\69\ As discussed briefly in Section I and in more detail in
Section V, this regulatory category also covers some incomplete
Class 2b/3 vehicles.
---------------------------------------------------------------------------
Three of these commonalities are especially significant: (1) Over
95 percent of the HD pickups and vans sold in the United States are
produced by Ford, General Motors, and Chrysler--three companies with
large light-duty vehicle and light-duty truck sales in the United
States, (2) these companies typically base their HD pickup and van
designs on higher sales volume light-duty truck platforms and
technologies, often incorporating new light-duty truck design features
into HD pickups and vans at their next design cycle, and (3) at this
time most complete HD pickups and vans are certified to vehicle-based
rather than engine-based EPA standards. There is also the potential for
substantial GHG and fuel consumption reductions from vehicle design
improvements beyond engine changes (such as through optimizing
aerodynamics, weight, tires, and
[[Page 74190]]
brakes), and the manufacturer is generally responsible for both engine
and vehicle design. All of these factors together suggest that it is
appropriate and reasonable to set standards for the vehicle as a whole,
rather than to establish separate engine and vehicle GHG and fuel
consumption standards, as is proposed for the other heavy-duty
categories. This approach for complete vehicles is consistent with
Recommendation 8-1 of the NAS Report, which encourages the regulation
of ``the final stage vehicle manufacturers since they have the greatest
control over the design of the vehicle and its major subsystems that
affect fuel consumption.''
(b) Weight-Based Attributes
In setting heavy-duty vehicle standards it is important to take
into account the great diversity of vehicle sizes, applications, and
features. That diversity reflects the variety of functions performed by
heavy-duty vehicles, and this in turn can affect the kind of technology
that is available to control emissions and reduce fuel consumption, and
its effectiveness. EPA has dealt with this diversity in the past by
making weight-based distinctions where necessary, for example in
setting HD vehicle standards that are different for vehicles above and
below 10,000 lb GVWR, and in defining different standards and useful
life requirements for light-, medium-, and heavy-heavy-duty engines.
Where appropriate, distinctions based on fuel type have also been made,
though with an overall goal of remaining fuel-neutral.
The joint EPA GHG and NHTSA fuel economy rules for light-duty
vehicles accounted for vehicle diversity in that segment by basing
standards on vehicle footprint (the wheelbase times the average track
width). Passenger cars and light trucks with larger footprints are
assigned numerically higher target levels for GHGs and numerically
lower target levels for fuel economy in acknowledgement of the
differences in technology as footprint gets larger, such that vehicles
with larger footprints have an inherent tendency to burn more fuel and
emit more GHGs per mile of travel. Using a footprint-based attribute to
assign targets also avoids interfering with the ability of the market
to offer a variety of products to maintain consumer choice.
In developing this proposal, the agencies emphasized creating a
program structure that would achieve reductions in fuel consumption and
GHGs based on how vehicles are used and on the work they perform in the
real world, consistent with the NAS report recommendations to be
mindful of HD vehicles' unique purposes. Despite the HD pickup and van
similarities to light-duty vehicles, we believe that the past practice
in EPA's heavy-duty program of using weight-based distinctions in
dealing with the diversity of HD pickup and van products is more
appropriate than using vehicle footprint. Weight-based measures such as
payload and towing capability are key among the things that
characterize differences in the design of vehicles, as well as
differences in how the vehicles will be used. Vehicles in this category
have a wide range of payload and towing capacities. These weight-based
differences in design and in-use operation are the key factors in
evaluating technological improvements for reducing CO2
emissions and fuel consumption. Payload has a particularly important
impact on the test results for HD pickup and van emissions and fuel
consumption, because testing under existing EPA procedures for criteria
pollutants is conducted with the vehicle loaded to half of its payload
capacity (rather than to a flat 300 lb as in the light-duty program),
and the correlation between test weight and fuel use is strong.\70\
---------------------------------------------------------------------------
\70\ Section II.C(2) discusses our decision to propose that GHGs
and fuel consumption for HD pickups and vans be measured using the
same test conditions as in the existing EPA program for criteria
pollutants.
---------------------------------------------------------------------------
Towing, on the other hand, does not directly factor into test
weight as nothing is towed during the test. Hence only the higher curb
weight caused by heavier truck components would play a role in
affecting measured test results. However towing capacity can be a
significant factor to consider because HD pickup truck towing
capacities can be quite large, with a correspondingly large effect on
design.
We note too that, from a purchaser perspective, payload and towing
capability typically play a greater role than physical dimensions in
influencing purchaser decisions on which heavy-duty vehicle to buy. For
passenger vans, seating capacity is of course a major consideration,
but this correlates closely with payload weight.
Although heavy-duty vehicles are traditionally classified by their
GVWR, we do not believe that GVWR is the best weight-based attribute on
which to base GHG and fuel consumption standards for this group of
vehicles. GVWR is a function of not only payload capacity but of
vehicle curb weight as well; in fact, it is the simple sum of the two.
Allowing more GHG emissions from vehicles with higher curb weight tends
to penalize lightweighted vehicles with comparable payload capabilities
by making them meet more stringent standards than they would have had
to meet without the weight reduction. The same would be true for
another common weight-based measure, the gross vehicle combined weight,
which adds the maximum combined towing and payload weight to the curb
weight.
Similar concerns about using weight-based attributes that include
vehicle curb weight were raised in the EPA/NHTSA proposal for light-
duty GHG and fuel economy standards: ``Footprint-based standards
provide an incentive to use advanced lightweight materials and
structures that would be discouraged by weight-based standards'', and
``there is less risk of `gaming' (artificial manipulation of the
attribute(s) to achieve a more favorable target) by increasing
footprint under footprint-based standards than by increasing vehicle
mass under weight-based standards--it is relatively easy for a
manufacturer to add enough weight to a vehicle to decrease its
applicable fuel economy target a significant amount, as compared to
increasing vehicle footprint'' (74 FR 49685, September 28, 2009). The
agencies believe that using payload and towing capacities as the
weight-based attributes would avoid the above-mentioned disincentive
for the use of lightweighting technology by taking vehicle curb weight
out of the standards determination.
After taking these considerations into account, EPA and NHTSA have
decided to propose standards for HD pickups and vans based on a ``work
factor'' attribute that combines vehicle payload capacity and vehicle
towing capacity, in pounds, with an additional fixed adjustment for
four-wheel drive (4wd) vehicles. This adjustment would account for the
fact that 4wd, critical to enabling the many off-road heavy-duty work
applications, adds roughly 500 lb to the vehicle weight. Under our
proposal, target GHG and fuel consumption standards would be determined
for each vehicle with a unique work factor. These targets would then be
production weighted and summed to derive a manufacturer's annual fleet
average standards.
To ensure consistency and help preclude gaming, we are proposing
that payload capacity be defined as GVWR minus curb weight, and towing
capacity as GCWR minus GVWR. We are proposing that, for purposes of
determining the work factor, GCWR be defined according to SAE
Recommended Practice J2807 APR2008, GVWR be defined consistent with
EPA's criteria pollutants program, and curb weight be defined as in 40
CFR
[[Page 74191]]
86.1803-01. We request comment on the need to establish additional
regulations or guidance to ensure that these terms are determined and
applied consistently across the HD pickup and van industry for the
purpose of determining standards.
Based on analysis of how CO2 emissions and fuel
consumption correlate to work factor, we believe that a straight line
correlation is appropriate across the spectrum of possible HD pickups
and vans, and that vehicle distinctions such as Class 2b versus Class 3
need not be made in setting standards levels for these vehicles.\71\ We
request comment on this proposed approach.
---------------------------------------------------------------------------
\71\ Memorandum from Anthony Neam and Jeff Cherry, U.S.EPA, to
docket EPA-HQ-OAR-2010-0162, October 18, 2010.
---------------------------------------------------------------------------
We note that payload/towing-dependent gram per mile and gallon per
100 mile standards for HD pickups and vans parallel the gram per ton-
mile and gallon per 1,000 ton-mile standards being proposed for Class 7
and 8 combination tractors and for vocational vehicles. Both approaches
account for the fact that more work is done, more fuel is burned, and
more CO2 is emitted in moving heavier loads than in moving
lighter loads. Both of these load-based approaches avoid penalizing
truck designers wishing to reduce GHG emissions and fuel consumption by
reducing the weight of their trucks. However, the sizeable diversity in
HD work truck and van applications, which go well beyond simply
transporting freight, and the fact that the curb weights of these
vehicles are on the order of their payload capacities, suggest that
setting simple gram/ton-mile and gallon/ton-mile standards for them is
not appropriate. Even so, we believe that our proposal of payload-based
standards for HD pickups and vans is consistent with the NAS Report's
recommendation in favor of load-specific fuel consumption standards.
These attribute-based CO2 and fuel consumption standards
are meant to be relatively consistent from a stringency perspective.
Vehicles across the entire range of the HD pickup and van segment have
their respective target values for CO2 emissions and fuel
consumption, and therefore all HD pickups and vans would be affected by
the standard. With the proposed attribute-based standards approach, EPA
and NHTSA believe there should be no significant effect on the relative
distribution of vehicles with differing capabilities in the fleet,
which means that buyers should still be able to purchase the vehicle
that meets their needs.
(c) Proposed Standards
The agencies are proposing standards based on a technology analysis
performed by EPA to determine the appropriate HD pickup and van
standards. This analysis, described in detail in draft RIA Chapter 2,
considered:
The level of technology that is incorporated in current
new HD pickups and vans,
The available data on corresponding CO2
emissions and fuel consumption for these vehicles,
Technologies that would reduce CO2 emissions
and fuel consumption and that are judged to be feasible and appropriate
for these vehicles through the 2018 model year,
The effectiveness and cost of these technologies for HD
pickup and vans,
Projections of future U.S. sales for HD pickup and vans,
and
Forecasts of manufacturers' product redesign schedules.
Based on this analysis, EPA is proposing the CO2
attribute-based target standards shown in Figure II-1 and II-2, and
NHTSA is proposing the equivalent attribute-based fuel consumption
target standards, also shown in Figure II-1 and II-2, applicable in
model year 2018. These figures also shows phase-in standards for model
years before 2018, and their derivation is explained below, along with
alternative implementation schedules to ensure equivalency between the
EPA and NHTSA programs while meeting statutory obligations. Also, for
reasons discussed below, separate targets are being established for
gasoline-fueled (and any other Otto-cycle) vehicles and diesel-fueled
(and any other Diesel-cycle) vehicles. The targets would be used to
determine the production-weighted standards that apply to the combined
diesel and gasoline fleet of HD pickups and vans produced by a
manufacturer in each model year.
[[Page 74192]]
[GRAPHIC] [TIFF OMITTED] TP30NO10.018
---------------------------------------------------------------------------
\72\ The NHTSA proposal provides voluntary standards for model
years 2014 and 2015. Target line functions for 2016-2018 are for the
second NHTSA alternative described in Section II.C(d)(ii).
---------------------------------------------------------------------------
[[Page 74193]]
[GRAPHIC] [TIFF OMITTED] TP30NO10.019
Described \73\ mathematically, EPA's and NHTSA's proposed functions
are defined by the following formulae:
\73\ The NHTSA proposal provides voluntary standards for model
years 2014 and 2015. Target line functions for 2016-2018 are for the
second NHTSA alternative described in Section II.C(d)(ii).
EPA CO2 Target (g/mile) = [a x WF] + b
NHTSA Fuel Consumption Target (gallons/100 miles) = [c x WF] + d
Where:
WF = Work Factor = [0.75 x (Payload Capacity + xwd)] + [0.25 x
Towing Capacity]
Payload Capacity = GVWR (lb)-Curb Weight (lb)
xwd = 500 lb if the vehicle is equipped with 4wd, otherwise equals 0
lb
Towing Capacity = GCWR (lb)-GVWR (lb)
Coefficients a, b, c, and d are taken from Table II-7 or Table II-
8.\74\
---------------------------------------------------------------------------
\74\ The NHTSA proposal provides voluntary standards for model
years 2014 and 2015. Target line functions for 2016-2018 are for the
second NHTSA alternative described in Section II.C(d)(ii).
---------------------------------------------------------------------------
[[Page 74194]]
[GRAPHIC] [TIFF OMITTED] TP30NO10.020
[GRAPHIC] [TIFF OMITTED] TP30NO10.021
These targets are based on a set of vehicle, engine, and
transmission technologies assessed by the agencies and determined to be
feasible and appropriate for HD pickups and vans in the 2014-2018
timeframe. Much of the information used to make this technology
assessment was developed for the recent 2012-2016 MY light-duty vehicle
rule. See Section III.B for a detailed analysis of these vehicle,
engine and transmission technologies, including their feasibility,
costs, and effectiveness in HD pickups and vans.
To calculate a manufacturer's HD pickup and van fleet average
standard, the agencies are proposing that separate target curves be
used for gasoline and diesel vehicles. The agencies estimate that in
2018 the target curves will achieve 15 and 10 percent reductions in
CO2 and fuel consumption for diesel and gasoline vehicles,
respectively, relative to a common baseline for current (model year
2010) vehicles. An additional two percent reduction in GHGs would be
achieved by the EPA program from a proposed direct air conditioning
leakage standard. These reductions are based on the agencies'
assessment of the feasibility of incorporating technologies (which
differ significantly for gasoline and diesel powertrains) in the 2014-
2018 model years, and on the differences in relative efficiency in the
current gasoline and diesel vehicles. The resulting reductions
represent roughly equivalent stringency
[[Page 74195]]
levels for gasoline and diesel vehicles, which is important in ensuring
our proposed program maintains product choices available to vehicle
buyers.
The NHTSA fuel consumption target curves and the EPA GHG target
curves are equivalent. The agencies established the target curves using
the direct relationship between fuel consumption and CO2
using conversion factors of 8,887 g CO2/gallon for gasoline
and 10,180 g CO2/gallon for diesel fuel.
It is expected that measured performance values for CO2
would generally be equivalent to fuel consumption. However, as
explained below in Section II. E. (3), EPA is proposing an alternative
for manufacturers to demonstrate compliance with N2O and
CH4 emissions standards through the calculation of a
CO2-equivalent (CO2eq) emissions level that would
be compared to the CO2-based standards, similar to the
recently promulgated light-duty GHG standards for model years 2012-
2016. For test families that do not use this compliance alternative,
the measured performance values for CO2 and fuel consumption
would be equivalent because the same test runs and measurement data
would be used to determine both values, and calculated fuel consumption
would be based on the same conversion factors that are used to
establish the relationship between the CO2 and fuel
consumption target curves (8887 g CO2/gallon for gasoline
and 10,180 g CO2/gallon for diesel fuel). In this case, for
example, if a manufacturer's fleet average measured compliance value
exactly meets the fleet average CO2 standard, it will also
exactly meet the fuel consumption standard. The proposed NHTSA fuel
consumption program will not use a CO2eq metric. Measured
performance to standards would be based on the measurement of
CO2 with no adjustment for N2O and
CH4. For manufacturers that choose to use the EPA
CO2eq approach, compliance with the CO2 standard
would not be directly equivalent to compliance with the NHTSA fuel
consumption standard.
(d) Proposed Implementation Plan
(i) EPA Program Phase-In MY 2014-2018
EPA is proposing that the GHG standards be phased in gradually over
the 2014-2018 model years, with full implementation effective in the
2018 model year. Therefore, 100 percent of a manufacturer's vehicle
fleet would need to meet a fleet-average standard that would become
increasingly more stringent each year of the phase-in period. For both
gasoline and diesel vehicles, this phase-in would be 15-20-40-60-100
percent in model years 2014-2015-2016-2017-2018, respectively. These
percentages reflect stringency increases from a baseline performance
level for model year 2010, determined by the agencies based on EPA and
manufacturer data. Because these vehicles are not currently regulated
for GHG emissions, this phase-in takes the form of target line
functions for gasoline and diesel vehicles that become increasingly
stringent over the phase-in model years. These year-by-year functions
have been derived in the same way as the 2018 function, by taking a
percent reduction in CO2 from a common unregulated baseline.
For example, in 2014 the reduction for both diesel and gasoline
vehicles would be 15% of the fully-phased-in reductions. Figures II-1
and II-2, and Table II-7, reflect this phase-in approach.
EPA is also proposing to provide manufacturers with an optional
alternative implementation schedule in model years 2016 through 2018,
equivalent to NHTSA's proposed first alternative for standards that do
not change over these model years, described below. Under this option
the phase-in would be 15-20-67-67-67-100 percent in model years 2014-
2015-2016-2017-2018-2019, respectively. Table II-8, above, provides the
coefficients ``a'' and ``b'' for this manufacturer's alternative. As
explained below, the stringency of this alternative was established by
NHTSA such that a manufacturer with a stable production volume and mix
over the model year 2016-2018 period could use Averaging, Banking and
Trading to comply with either alternative and have a similar credit
balance at the end of model year 2018.
Under the above-described alternatives, each manufacturer would
need to demonstrate compliance with the applicable fleet average
standard using that year's target function over all of its HD pickups
and vans starting in 2014. EPA also requests comment on a different
regulatory approach to the phase-in, intended to reduce the testing and
certification burden on manufacturers during the 2014-2017 phase-in
years, while achieving GHG reductions on the same schedule as the
proposed phase-in. In this alternative approach, each manufacturer
would be required to demonstrate compliance with the final 2018
targets, but only over a predefined percentage of its HD pickup and van
production. The remaining vehicles produced each year would not be
regulated for GHGs. Thus this approach would have the effect of setting
final standards in 2014 that do not vary over time, but with an
annually increasing set of regulated vehicles. The percentage of
regulated vehicles would increase each year, to 100 percent in 2018. We
think it likely that manufacturers would leave the highest emitting
vehicles unregulated for as long as possible under this approach,
because these vehicles would tend to be the costliest to redesign or
may simply be phased out of production. We therefore expect that, to be
equivalent, the percentage penetration each year would be higher than
the 15-20-40-60 percent penetrations required under the proposed
approach. EPA requests comment on this regulatory alternative, and on
what percentage penetrations are appropriate to achieve equivalent
program benefits.
(ii) NHTSA Program Phase-In 2016 and Later
NHTSA is proposing to allow manufacturers to select one of two fuel
consumption standard alternatives for model years 2016 and later.
Manufacturers would select an alternative at the same time they submit
the model year 2016 Pre-Certification Compliance Report; and, once
selected, the alternative would apply for model years 2016 and later,
and could not be reversed. To meet the EISA statutory requirement for
three years of regulatory stability, the first alternative would define
a fuel consumption target line function for gasoline vehicles and a
target line function for diesel vehicles that would not change for
model years 2016 and later. The proposed target line function
coefficients are provided in Table II-8.
The second alternative would be equivalent to the EPA target line
functions in each model year starting in 2016 and continuing
afterwards. Stringency of fuel consumption standards would increase
gradually for the 2016 and later model years. Relative to a model year
2010 unregulated baseline, for both gasoline and diesel vehicles,
stringency would be 40, 60, and 100 percent of the 2018 target line
function in model years 2016, 2017, and 2018, respectively.
The stringency of the target line functions in the first
alternative for model years 2016-2017-2018-2019 is 67-67-67-100
percent, respectively, of the 2018 stringency in the second
alternative. The stringency of the first alternative was established so
that a manufacturer with a stable production volume and mix over the
model year 2016-2018 period, could use Averaging, Banking and Trading
to comply with
[[Page 74196]]
either alternative and have a similar credit balance at the end of
model year 2018 under the EPA and NHTSA programs.
NHTSA also requests comment on a different regulatory approach that
would parallel the above-described EPA regulatory alternative involving
certification of a pre-defined percentage of a manufacturer's HD pickup
and van production.
(iii) NHTSA Voluntary Standards Period
NHTSA is proposing that manufacturers may voluntarily opt into the
NHTSA HD pickup and van program in model years 2014 or 2015. If a
manufacturer elects to opt into the program, the program would become
mandatory and the manufacturer would not be allowed to reverse this
decision. To opt into the program, a manufacturer must declare its
intent to opt in to the program at the same time it submits the Pre-
Certification Compliance Report. See proposed regulatory text for 49
CFR 535.8 for information related to the Pre-Certification Compliance
Report. If a manufacturer elects to opt into the program in 2014, the
program would be mandatory for 2014 and 2015. A manufacturer would
begin tracking credits and debits beginning in the model year in which
they opt into the program. The handling of credits and debits would be
the same as for the mandatory program.
For manufacturers that opt into NHTSA's HD pickup and van fuel
consumption program in 2014 or 2015, the stringency would increase
gradually each model year. Relative to a model year 2010 unregulated
baseline, for both gasoline and diesel vehicles, stringency would be
15-20 percent of the model year 2018 target line function (under the
NHTSA second alternative) in model years 2014-2015, respectively. The
corresponding absolute standards targets levels are provided in Figure
II-1 and II-2, and the accompanying equations.
NHTSA also requests comment on a different regulatory approach that
would parallel the above-described EPA regulatory alternative involving
certification of a pre-defined percentage of a manufacturer's HD pickup
and van production.
(2) What are the proposed HD pickup and van test cycles and procedures?
EPA and NHTSA are proposing that HD pickup and van testing be
conducted using the same heavy-duty chassis test procedures currently
used by EPA for measuring criteria pollutant emissions from these
vehicles, but with the addition of the highway fuel economy test cycle
(HFET) currently required only for light-duty vehicle GHG emissions and
fuel economy testing. Although the highway cycle driving pattern would
be identical to that of the light-duty test, other test parameters for
running the HFET, such as test vehicle loaded weight, would be
identical to those used in running the current EPA Federal Test
Procedure for complete heavy-duty vehicles.
The GHG and fuel consumption results from vehicle testing on the
Light-duty FTP and the HFET would be weighted by 55 percent and 45
percent, respectively, and then averaged in calculating a combined
cycle result. This result corresponds with the data used to develop the
proposed work factor-based CO2 and fuel consumption
standards, since the data on the baseline and technology efficiency was
also developed in the context of these test procedures. The addition of
the HFET and the 55/45 cycle weightings are the same as for the light-
duty CO2 and CAFE programs, as we believe the real world
driving patterns for HD pickups and vans are not too unlike those of
light-duty trucks, and we are not aware of data specifically on these
patterns that would lead to a different choice of cycles and
weightings. More importantly, we believe that the 55/45 weightings will
provide for effective reductions of GHG emissions and fuel consumption
from these vehicles, and that other weightings, even if they were to
more precisely match real world patterns, are not likely to
significantly improve the program results.
Another important parameter in ensuring a robust test program is
vehicle test weight. Current EPA testing for HD pickup and van criteria
pollutants is conducted with the vehicle loaded to its Adjusted Loaded
Vehicle Weight (ALVW), that is, its curb weight plus \1/2\ of the
payload capacity. This is substantially more challenging than loading
to the light-duty vehicle test condition of curb weight plus 300
pounds, but we believe that this loading for HD pickups and vans to \1/
2\ payload better fits their usage in the real world and would help
ensure that technologies meeting the standards do in fact provide real
world reductions. The choice is likewise consistent with use of an
attribute based in considerable part on payload for the standard. We
see no reason to set test load conditions differently for GHGs and fuel
consumption than for criteria pollutants, and we are not aware of any
new information (such as real world load patterns) since the ALVW was
originally set this way that would support a change in test loading
conditions. We are therefore proposing to use ALVW for test vehicle
loading in GHG and fuel consumption testing.
EPA and NHTSA request comment on the proposed test cycles,
weighting factors, test loading conditions, and other factors that are
important for establishing an effective GHG and fuel consumption test
program. Additional provisions for our proposed testing and compliance
program are provided in Section V.B.
(3) How are the HD pickup and van standards structured?
EPA and NHTSA are proposing fleet average standards for new HD
pickups and vans, based on a manufacturer's new vehicle fleet makeup.
In addition, EPA is proposing in-use standards that would apply to the
individual vehicles in this fleet over their useful lives. The
compliance provisions for these proposed fleet average and in-use
standards for HD pickups and vans are largely based on the recently
promulgated light-duty GHG and fuel economy program, as described below
and in greater detail in Section V.B. We request comment on any
compliance provisions we have taken from the light-duty program that
commenters feel would not be appropriate for HD pickups and vans or
that should be adjusted in some way to better regulate HD GHGs and fuel
consumption cost-effectively.
(a) Fleet Average Standards
In this proposal we outline how each manufacturer would have a GHG
standard and a fuel consumption standard unique to its new HD pickup
and van fleet in each model year, depending on the load capacities of
the vehicle models produced by that manufacturer, and on the U.S.-
directed production volume of each of those models in that model year.
Vehicle models with larger payload/towing capacities would have
individual targets at numerically higher CO2 and fuel
consumption levels than lower payload/towing vehicles would, as
discussed in Section II.C(1). The fleet average standard for a
manufacturer would be a production-weighted average of the work factor-
based targets assigned to unique vehicle configurations within each
model type produced by the manufacturer in a model year.
The fleet average standard with which the manufacturer must comply
would be based on its final production figures for the model year, and
thus a final assessment of compliance would occur after production for
the model year ended. Because compliance with the fleet average
standards depends on
[[Page 74197]]
actual test group production volumes, it is not possible to determine
compliance at the time the manufacturer applies for and receives an EPA
certificate of conformity for a test group. Instead, at certification
the manufacturer would demonstrate a level of performance for vehicles
in the test group, and make a good faith demonstration that its fleet,
regrouped by unique vehicle configurations within each model type, is
expected to comply with its fleet average standard when the model year
is over. EPA would issue a certificate for the vehicles covered by the
test group based on this demonstration, and would include a condition
in the certificate that if the manufacturer does not comply with the
fleet average, then production vehicles from that test group will be
treated as not covered by the certificate to the extent needed to bring
the manufacturer's fleet average into compliance. As in the light-duty
program, additional ``model type'' testing would be conducted by the
manufacturer over the course of the model year to supplement the
initial test group data. The emissions and fuel consumption levels of
the test vehicles would be used to calculate the production-weighted
fleet averages for the manufacturer, after application of the
appropriate deterioration factor to each result to obtain a full useful
life value. See generally 75 FR 25470-25472.
EPA and NHTSA do not currently anticipate notable deterioration of
CO2 emissions and fuel consumption performance, and are
therefore proposing that an assigned deterioration factor be applied at
the time of certification: an additive assigned deterioration factor of
zero, or a multiplicative factor of one would be used. EPA and NHTSA
anticipate that the deterioration factor would be updated from time to
time, as new data regarding emissions deterioration for CO2
are obtained and analyzed. Additionally, EPA and NHTSA may consider
technology-specific deterioration factors, should data indicate that
certain control technologies deteriorate differently than others. See
also 75 FR 25474.
(b) In-Use Standards
Section 202(a)(1) of the CAA specifies that EPA set emissions
standards that are applicable for the useful life of the vehicle. The
in-use standards that EPA is proposing would apply to individual
vehicles. NHTSA is not proposing to adopt in-use standards because it
is not required under EISA, and because it is not currently anticipated
that there will be any notable deterioration of fuel consumption. For
the EPA proposal, compliance with the in-use standard for individual
vehicles and vehicle models will not impact compliance with the fleet
average standard, which will be based on the production weighted
average of the new vehicles.
EPA is proposing that the in-use standards for HD pickups and vans
be established by adding an adjustment factor to the full useful life
emissions and fuel consumption results used to calculate the fleet
average. EPA is also proposing that the useful life for these vehicles
with respect to GHG emissions be set equal to their useful life for
criteria pollutants: 11 years or 120,000 miles, whichever occurs first
(40 CFR 86.1805-04(a)).
As discussed above, we are proposing that certification test
results obtained before and during the model year be used directly to
calculate the fleet average emissions for assessing compliance with the
fleet average standard. Therefore, this assessment and the fleet
average standard itself do not take into account test-to-test
variability and production variability that can affect measured in-use
levels. For this reason, EPA is proposing an adjustment factor for the
in-use standard to provide some margin for production and test-to-test
variability that could result in differences between the initial
emission test results used to calculate the fleet average and emission
results obtained during subsequent in-use testing. EPA is proposing
that each model's in-use CO2 standard would be the model-
specific level used in calculating the fleet average, plus 10 percent.
This is the same as the approach taken for light-duty vehicle GHG in-
use standards (See 75 FR 25473-25474).
As it does now for heavy-duty vehicle criteria pollutants, EPA
would use a variety of mechanisms to conduct assessments of compliance
with the proposed in-use standards, including pre-production
certification and in-use monitoring once vehicles enter customer
service. The full useful life in-use standards would apply to vehicles
that had entered customer service. The same standards would apply to
vehicles used in pre-production and production line testing, except
that deterioration factors would not be applied.
(4) What HD pickup and van flexibility provisions are being proposed?
This proposal contains substantial flexibility in how manufacturers
can choose to implement the EPA and NHTSA standards while preserving
their timely benefits for the environment and energy security. Primary
among these flexibilities are the gradual phase-in schedule,
alternative compliance paths, and corporate fleet average approach
described above. Additional flexibility provisions are described
briefly here and in more detail in Section IV.
As explained in Section II.C(3), we are proposing that at the end
of each model year, when production for the model year is complete, a
manufacturer calculate its production-weighted fleet average
CO2 and fuel consumption. Under this proposed approach, a
manufacturer's HD pickup and van fleet that achieves a fleet average
CO2 or fuel consumption level better than its standard would
be allowed to generate credits. Conversely, if the fleet average
CO2 or fuel consumption level does not meet its standard,
the fleet would incur debits (also referred to as a shortfall).
A manufacturer whose fleet generates credits in a given model year
would have several options for using those credits to offset emissions
from other HD pickups and vans. These options include credit carry-
back, credit carry-forward, and credit trading. These provisions exist
in the 2012-2016 MY light-duty vehicle National Program, and similar
provisions are part of EPA's Tier 2 program for light-duty vehicle
criteria pollutant emissions, as well as many other mobile source
standards issued by EPA under the CAA. The manufacturer would be able
to carry back credits to offset a deficit that had accrued in a prior
model year and was subsequently carried over to the current model year,
with a limitation on the carry-back of credits to three years,
consistent with the light-duty program. We are proposing that, after
satisfying any need to offset pre-existing deficits, a manufacturer may
bank remaining credits for use in future years. We are also proposing
that manufacturers may certify their HD pickup and van fleet a year
early, in MY 2013, to generate credits against the MY 2014 standards.
This averaging, banking, and trading program for HD pickups and vans is
discussed in more detail in Section IV.A. For reasons discussed in
detail in that section, we are not proposing any credit transferability
to or from other credit programs, such as the light-duty GHG and fuel
consumption programs or the proposed heavy-duty engine ABT program.
Consistent with the President's May 21, 2010 directive to promote
advanced technology vehicles, we are proposing and seeking comment on
flexibility provisions that would parallel similar provisions adopted
in the light-duty program. These include credits for advance technology
vehicles such as electric vehicles, and credits for
[[Page 74198]]
innovative technologies that are shown by the manufacturer to provide
GHG and fuel consumption reductions in real world driving, but not on
the test cycle. See Section IV.B.
We believe that it may also be appropriate to take steps to
recognize the benefits of flexible-fueled vehicles (FFVs) and dedicated
alternative-fueled vehicles based on the approach taken by EPA in the
light-duty vehicle rule for later models years (2016 and later).
However, unlike in that rule, we do not believe it is appropriate to
create a provision for additional credits similar to the 2012-2015
light-duty program because the HD sector does not have the incentives
mandated in EISA for light-duty vehicles. In fact, since heavy-duty
vehicles were not included in the EISA incentives for FFVs,
manufacturers have not in the past produced FFV heavy-duty vehicles. On
the other hand, we do seek comment on how to properly recognize the
impact of the use of alternative fuels, and E85 in particular, in HD
pickups and vans, including the proper accounting for alternative fuel
use in FFVs in the real world.\75\ As proposed, FFV performance would
be determined in the same way as for light-duty vehicles, with a 50-50
weighting of alternative and conventional fuel test results through MY
2015, and a manufacturer-determined weighting based on demonstrated
fuel use in the real world after MY 2015 (defaulting to an assumption
of 100 percent conventional fuel use). For dedicated alternative fueled
vehicles, NHTSA proposes that vehicles be tested with the alternative
fuel, and a petroleum equivalent fuel consumption level be calculated
based on the Petroleum Equivalency Factor (PEF) that is determined by
the Department of Energy. However, we are accepting comment on whether
to provide a flexibility program similar to the program we currently
offer for light-duty FFV vehicles.
---------------------------------------------------------------------------
\75\ E85 is a blended fuel consisting of nominally 15 percent
gasoline and 85 percent ethanol.
---------------------------------------------------------------------------
D. Class 2b-8 Vocational Vehicles
Class 2b-8 vocational vehicles consist of a very wide variety of
configurations including delivery, refuse, utility, dump, cement,
transit bus, shuttle bus, school bus, emergency vehicle, motor
homes,\76\ and tow trucks, among others. The agencies are defining that
Class 2b-8 vocational vehicles are all heavy-duty vehicles which are
not included in the Heavy-duty Pickup Truck and Van or the Class 7 and
8 Tractor categories, with the exception of vehicles for which the
agencies are deferring setting of standards, such as small business
manufacturers. In addition, recreational vehicles are included under
EPA's proposed standards but are not included under NHTSA's proposed
standards.
---------------------------------------------------------------------------
\76\ See above for discussion of applicability of NHTSA's
standards to non-commercial vehicles.
---------------------------------------------------------------------------
As mentioned in Section I, vocational vehicles undergo a complex
build process. Often an incomplete chassis is built by a chassis
manufacturer with an engine purchased from an engine manufacturer and a
transmission purchased from another manufacturer. A body manufacturer
purchases an incomplete chassis which is then completed by attaching
the appropriate features to the chassis.
The agencies face difficulties in establishing the baseline
CO2 and fuel consumption performance for the wide variety of
vocational vehicles which makes it difficult to try and set different
standards for a large number of potential regulatory categories. The
diversity in the vocational vehicle segment can be primarily attributed
to the variety of vehicle bodies rather than to the chassis. For
example, a body builder can build either a Class 6 bucket truck or a
Class 6 delivery truck from the same Class 6 chassis. The aerodynamic
difference between these two vehicles due to their bodies will lead to
different baseline fuel consumption and GHG emissions. However, the
baseline fuel consumption and emissions due to the components included
in the common chassis (such as the engine, drivetrain, frame, and
tires) will be the same between these two types of complete vehicles.
Furthermore, the agencies evaluated the aerodynamic improvement
opportunities for vocational vehicles. For example, the aerodynamics of
a fire truck are impacted significantly by the equipment such as
ladders located on the exterior of the truck. The agencies found little
opportunity to improve the aerodynamics of the equipment on the truck.
The agencies also evaluated the aerodynamic opportunities discussed in
the NAS report. The panel found that there was no fuel consumption
reduction opportunity through aerodynamic technologies for bucket
trucks, transit buses, and refuse trucks \77\ primarily due to the low
vehicle speed in normal operation. The panel did report that there are
opportunities to reduce the fuel consumption of straight trucks by
approximately 1 percent for trucks which operate at the average speed
typical of a pickup and delivery truck (30 mph), although the
opportunity is greater for trucks which operate at higher speeds.\78\
To overcome the lack of baseline information from the different vehicle
applications without sacrificing much fuel consumption or GHG emission
reduction potential, the agencies propose to set standards for the
chassis manufacturers of vocational vehicles (instead of the body
builders) and the engine manufacturers.
---------------------------------------------------------------------------
\77\ See 2010 NAS Report, Note 19, page 133.
\78\ See 2010 NAS Report, Note 19, page 110.
---------------------------------------------------------------------------
EPA is proposing CO2 standards and NHTSA is proposing
fuel consumption standards for manufacturers of chassis for new
vocational vehicles and for manufacturers of heavy-duty engines
installed in these vehicles. The proposed heavy-duty engine standards
for CO2 emissions and fuel consumption would focus on
potential technological improvements in fuel combustion and overall
engine efficiency and those proposed controls would achieve most of the
emission reductions. Further reductions from the Class 2b-8 vocational
vehicle itself are possible within the timeframe of these proposed
regulations. Therefore, the agencies are also proposing separate
standards for vocational vehicles that will focus on additional
reductions that can be achieved through improvements in vehicle tires.
The agencies' analyses, as discussed briefly below and in more detail
later in this preamble and in the draft RIA Chapter 2, show that these
proposed standards appear appropriate under each agency's respective
statutory authorities. Together these standards are estimated to
achieve reductions of up to 11 percent from vocational vehicles.
EPA is also proposing standards to control N2O and
CH4 emissions from Class 2b-8 vocational vehicles. The
proposed heavy-duty engine standards for both N2O and
CH4 and details of the standard are included in the
discussion in Section II. EPA is not proposing air conditioning leakage
standards applying to chassis manufacturers to address HFC emissions.
As discussed further below, the agencies propose to set
CO2 and fuel consumption standards for these chassis based
on tire rolling resistance improvements and for the engines based on
engine technologies. The fuel consumption and GHG emissions impact of
tire rolling resistance is impacted by the mass of the vehicle. However
the impact of mass on rolling resistance is relatively small so the
agencies propose to aggregate several vehicle weight categories under a
single category for setting the standards. The agencies propose to
divide the vocational vehicle segment into three broad regulatory
categories--Light
[[Page 74199]]
Heavy-Duty (Class 2b through 5), Medium Heavy-Duty (Class 6 and 7), and
Heavy Heavy-Duty (Class 8) which is consistent with the nomenclature
used in the diesel engine classification. The agencies are interested
in comment on this segmentation strategy (subcategorization). As the
agencies move towards future heavy-duty fuel consumption and GHG
regulations for post-2017 model years, we intend to gather GHG and fuel
consumption data for specific vocational applications which could be
used to establish application-specific standards in the future.
(1) What are the proposed CO2 and fuel consumption standards
and their timing?
In developing the proposed standards, the agencies have evaluated
the current levels of emissions and fuel consumption, the kinds of
technologies that could be utilized by manufacturers to reduce
emissions and fuel consumption and the associated lead time, the
associated costs for the industry, fuel savings for the consumer, and
the magnitude of the CO2 and fuel savings that may be
achieved. The technologies that the agencies considered while setting
the proposed vehicle-level standards include improvements in lower
rolling resistance tires. The technologies that the agencies considered
while setting the engine standards include engine friction reduction,
aftertreatment optimization, among others. The agencies' evaluation
indicates that these technologies are available today in the heavy-duty
tractor and light-duty vehicle markets, but have very low application
rates in the vocational market. The agencies have analyzed the
technical feasibility of achieving the proposed CO2 and fuel
consumption standards, based on projections of what actions
manufacturers would be expected to take to reduce emissions and fuel
consumption to achieve the standards, and believe that the proposed
standards are cost-effective and technologically feasible and
appropriate within the rulemaking time frame. EPA and NHTSA also
present the estimated costs and benefits of the proposed vocational
vehicle standards in Section III.
(a) Proposed Chassis Standards
As shown in Table II-9, EPA is proposing the following
CO2 standards for the 2014 model year for the Class 2b
through Class 8 vocational vehicle chassis. Similarly, NHTSA is
proposing the following fuel consumption standards for the 2016 model
year, with voluntary standards beginning in the 2014 model year. For
the EPA GHG program, the proposed standard applies throughout the
useful life of the vehicle.
EPA and NHTSA are proposing more stringent vehicle standards for
the 2017 model year which reflect the CO2 emissions
reductions required through the 2017 model year engine standards. As
explained in Section II. D. (2)(c)(iv) below, engine performance is one
of the inputs into the compliance model, and that input will change in
2017 to reflect the 2017 MY engine standards. The 2017 MY vehicle
standards are not premised on manufacturers installing additional
vehicle technologies.
[GRAPHIC] [TIFF OMITTED] TP30NO10.022
(i) Off-Road Vocational Vehicle Standards
In developing the proposal EPA and NHSTA received comment from
manufacturers and owners that certain vocational vehicles sometimes
have very limited on-road usage. These trucks are defined to be motor
vehicles under 40 CFR 85.1703, but they will spend the majority of
their operations off-road. Trucks, such as those used in oil fields,
will experience little benefit from low rolling resistance tires. The
agencies are therefore proposing to allow a narrow range of these de
facto off-road trucks to be excluded from the proposed vocational
vehicle standards because the trucks require special off-road tires
such as lug tires. The trucks must still use a certified engine, which
will provide fuel consumption and CO2 emission reductions to
the truck in all
[[Page 74200]]
applications. To insure that these trucks are in fact used chiefly off-
road, the agencies are proposing requirements that the vehicles have
off-road tires, have limited high speed operation, and are designed for
specific off-road applications. The agencies are specifically proposing
that a truck must meet the following requirements to qualify for an
exemption from the vocational vehicle standards:
---------------------------------------------------------------------------
\79\ Manufacturers may voluntarily opt-in to the NHTSA fuel
consumption program in 2014 or 2015. If a manufacturer opts-in, the
program becomes mandatory.
---------------------------------------------------------------------------
Installed tires which are lug tires or contain a speed
rating of less than or equal to 60 mph; and
Include a vehicle speed limiter governed to 55 mph.
EPA and NHTSA have concluded that the on-road performance losses
and additional costs to develop a truck which meets these
specifications will limit the exemption to trucks built for the desired
purposes. The agencies welcome comment on the proposed requirements and
exemptions.
(b) Proposed Heavy-duty Engine Standards
EPA is proposing GHG standards \80\ and NHTSA is proposing fuel
consumption standards for new heavy-duty engines installed in
vocational vehicles. The standards will vary depending on whether the
engines are diesel or gasoline powered. The agencies' analyses, as
discussed briefly below and in more detail later in this preamble and
in the draft RIA Chapter 2, show that these standards are appropriate
and feasible under each agency's respective statutory authorities.
---------------------------------------------------------------------------
\80\ Specifically, EPA is proposing CO2,
N2O, and CH4 emissions standards for new
heavy-duty engines over an EPA specified useful life period (see
Section II. E. for the N2O and CH4 standards).
---------------------------------------------------------------------------
The agencies have analyzed the feasibility of achieving the GHG and
fuel consumption standards, based on projections of what actions
manufacturers are expected to take to reduce emissions and fuel
consumption. EPA and NHTSA also present the estimated costs and
benefits of the heavy-duty engine standards in Section III. In
developing the proposed rules, the agencies have evaluated the kinds of
technologies that could be utilized by engine manufacturers compared to
a baseline engine, as well as the associated costs for the industry and
fuel savings for the consumer and the magnitude of the GHG and fuel
consumption savings that may be achieved.
With respect to the lead time and cost of incorporating technology
improvements that reduce GHG emissions and fuel consumption, the
agencies place important weight on the fact that during MYs 2014-2017,
engine manufacturers are expected to redesign and upgrade their
products only once. Over these four model years there will be an
opportunity for manufacturers to evaluate almost every one of their
engine models and add technology in a cost-effective way to control GHG
emissions and reduce fuel consumption. The time-frame and levels for
the standards, as well as the ability to average, bank and trade
credits and carry a deficit forward for a limited time, are expected to
provide manufacturers the time needed to incorporate technology that
will achieve the proposed GHG and fuel consumption reductions, and to
do this as part of the normal engine redesign process. This is an
important aspect of the proposed rules, as it will avoid the much
higher costs that would occur if manufacturers needed to add or change
technology at times other than these scheduled redesigns. This time
period will also provide manufacturers the opportunity to plan for
compliance using a multi-year time frame, again in accord with their
normal business practice. Further details on lead time, redesigns and
technical feasibility can be found in Section III.
EPA's existing criteria pollutant emissions regulations for heavy-
duty highway engines establish four regulatory categories (three for
compression-ignition or diesel engines and one for spark ignition or
gasoline engines) that represent the engine's intended and primary
truck application, as shown in Table II-10 (40 CFR 1036.140). The
agencies welcome comments on the existing definition of the regulatory
categories (such as typical horsepower levels) as described in 40 CFR
1036.140. All heavy-duty engines are covered either under the heavy-
duty pickup truck and van category or under the heavy-duty engine
standards.
[GRAPHIC] [TIFF OMITTED] TP30NO10.023
For the purposes of the GHG engine emissions and engine fuel
consumption standards that EPA and NHTSA are proposing, the agencies
intend to maintain these same four regulatory subcategories for GHG
engine emissions standards and fuel consumption standards. This
category structure would enable the agencies to set standards that
appropriately reflect the technology available for engines for use in
each type of vehicle.
(i) Diesel Engine Standards
EPA's proposed heavy-duty diesel engine CO2 emission
standards are presented in Table II-11. Similar to EPA's non-GHG
standards approach, manufacturers may generate and use credits to show
compliance with the standards. The EPA standards become effective in
2014 model year, with more stringent standards becoming effective in
model year 2017. Recently, EPA's
[[Page 74201]]
non-GHG heavy-duty engine program provided new emissions standards for
the industry in three year increments. Largely, the heavy-duty engine
and truck manufacturer product plans have fallen into three year cycles
to reflect this environment. The proposed two-step CO2
emission standards recognize the opportunity for technology
improvements over this timeframe while reflecting the typical diesel
truck manufacturer product plan cycles.
NHTSA's fuel consumption standards, also presented in Table II-11,
would contain voluntary engine standards starting in 2014 model year,
with mandatory engine standards starting in 2017 model year,
synchronizing with EPA's 2017 model year standards. A manufacturer may
opt-in to NHTSA's voluntary standards in 2014, 2015 or 2016. Once a
manufacturer opts-in, the standards become mandatory for the opt-in and
subsequent model years, and the manufacturer may not reverse its
decision. To opt into the program, a manufacture must declare its
intent to opt in to the program with documented communication of the
intent, at the same time it submits the Pre-Certification Compliance
Report. See 49 CFR 535.8 for information related to the Pre-
Certification Compliance Report. A manufacturer opting into the program
would begin tracking credits and debits beginning in the model year in
which they opt into the program.
The agencies are proposing the same standard level for the Light
Heavy and Medium Heavy diesel engine categories. The agencies found
that there is an overlap in the displacement of engines which are
currently certified as LHDD or MHDD. The agencies developed the
baseline 2010 model year CO2 emissions from data provided to
EPA by the manufacturers during the non-GHG certification process.
Analysis of CO2 emissions from 2010 model year LHD and MHDD
diesel engines showed little difference between LHD and MHD diesel
engine baseline CO2 performance, which overall averaged 630
g CO2/bhp-hr (6.19 gal/100 bhp-hr),\81\ in the 2010 model
year. Furthermore, the technologies available to reduce fuel
consumption and CO2 emissions from these two categories of
engines are similar. The agencies are proposing to maintain these two
separate engine categories with the same standard level (instead of
combining them into a single category) to respect the different useful
life periods associated with each category. The agencies are proposing
to evaluate compliance with the LHD/MHD diesel engine standards based
on the Heavy-duty FTP cycle.
---------------------------------------------------------------------------
\81\ Calculated using the conversion 10,180 g CO2/
gallon for diesel fuel.
---------------------------------------------------------------------------
The agencies found a difference in the baseline 2010 model year
CO2 and fuel consumption performance between the LHD/MHD
diesel engines, which averaged 630 g CO2/bhp-hr (6.19 gal/
100 bhp-hr),\82\ and the HHD diesel engines, which averaged 584 g
CO2/bhp-hr (5.74 gal/100 bhp-hr). The HHD diesel engine data
is also based on manufacturer submitted CO2 data for non-GHG
emissions certification process. In addition, the agencies believe that
there may be some technologies available to reduce fuel consumption and
CO2 emissions that may not be appropriate for both the LHD/
MHD diesel and the HHD diesel engines, such as turbocompounding.
Therefore, the agencies are proposing a standard level for HHD diesel
engines which differs from the LHD/MHD diesel engine standard level
likewise to be evaluated on the Heavy-duty FTP cycle.
---------------------------------------------------------------------------
\82\ Calculated using the conversion 10,180 g CO2/
gallon for diesel fuel.
---------------------------------------------------------------------------
We are proposing standards based on the Heavy-duty FTP cycle for
engines used in vocational vehicles reflecting their primary use in
transient operating conditions typified by both frequent accelerations
and decelerations as well as some steady cruise conditions as
represented on the Heavy-duty FTP. The primary reason the agencies are
proposing to set two separate HHD diesel engine standards--one for HHD
diesel engines used in tractors and the other for HHD diesel engines
used in vocational vehicles--is to encourage engine manufacturers to
install technologies appropriate to the intended use of the engine with
the vehicle. Tractors spend the majority of their operation at steady
state conditions, and will obtain in-use benefit of technologies such
as turbocompounding and other waste heat recovery technologies during
this kind of typical engine operation. Therefore, the engines installed
in line haul tractors would be required to meet the standard based on
the SET, which is a steady state test cycle. On the other hand,
vocational vehicles such as urban delivery trucks spend more time
operating in transient conditions and may not realize the benefit of
this type of technology in-use. The use of the Heavy-duty FTP for these
engines would focus engine design on technologies that realize in-use
benefits during the kind of operation typical for these engines.
Therefore, we are proposing that engines installed in vocational
vehicles be required to meet the standard and demonstrate compliance
over the transient Heavy-duty FTP cycle. The levels of the standards
reflect the difference in baseline emissions for the different test
procedures.
As noted in Section II.B above, the engine standards that EPA is
proposing and the voluntary standards being proposed by NHTSA for the
2014 model year would require diesel engine manufacturers to achieve on
average a three percent reduction in fuel consumption and
CO2 emissions over the baseline 2010 model year performance
for the HHD diesel engines and a five percent reduction for the LHD and
MHD diesel engines. The agencies' assessment of the NAS report and
other literature sources indicates that there are technologies
available to reduce fuel consumption by this level in the proposed
timeframe in a cost-effective manner. These technologies include
improved turbochargers, aftertreatment optimization, low temperature
exhaust gas recirculation, and engine friction reductions. Additional
discussion on technical feasibility is included in Section III below
and in draft RIA Chapter 2.
Additionally, the agencies are proposing that diesel engines
further reduce fuel consumption and CO2 emissions in the
2017 model year. The proposed 2017 model year standards for the LHD and
MHD diesel engines represent a 9 percent reduction from the 2010 model
year. The proposed reductions represent on average a five percent
decrease over the 2010 baseline for HHD diesel engines required to test
compliance using the Heavy-duty FTP test cycle. The additional
reductions may be achieved through the increased development of the
technologies evaluated for the 2014 model year standard. See draft RIA
Chapter 2. The agencies' analysis indicates that this type of advanced
engine development will require a longer development time than the 2014
model year and therefore are proposing to provide additional lead time
to allow for its introduction.
Similar to EPA's non-GHG standards approach, manufacturers may
generate and use credits by the same engine subcategory to show
compliance with both agencies' standards.
[[Page 74202]]
[GRAPHIC] [TIFF OMITTED] TP30NO10.024
In proposing these standards for diesel engines used in vocational
vehicles, the agencies have looked primarily at the typical performance
levels of the majority of engines in the fleet. As explained above in
Section II.B, we also recognize that when regulating a category of
products for the first time, there will be individual products that may
deviate from this baseline level of performance. Recognizing that for
these products a reduction from the industry baseline may be more
costly than the agencies have assumed or perhaps even not feasible in
the lead time available for these standards, EPA and NHTSA are
proposing a regulatory alternative whereby a manufacturer could comply
with a unique standard based on a five percent reduction from the
products own 2011 baseline level. Our assessment is that this five
percent reduction is appropriate and technologically feasible given the
manufacturers' ability to apply similar technology packages with
similar cost to what we have estimated for the primary program. For
this purpose, the agencies do not see that potential obstacles are
greater or lesser for engine standards which are based on the SET
procedure or Heavy-duty FTP cycle. We do not believe this alternative
needs to continue past 2016 since manufacturers will have had ample
opportunity to benchmark competitive products and make appropriate
changes to bring their product performance into line with the rest of
the industry.
However, we are requesting comment on the potential to extend this
regulatory alternative for one additional year for a single engine
family with performance measured in that year as nine percent beyond
the engine's own 2011 model year baseline level. We also request
comment on the level of reduction beyond the baseline that is
appropriate in this alternative. The five percent level reflects the
aggregate improvement beyond the baseline we are requiring of the
entire industry. As this provision is intended to address potential
issues for legacy products that we would expect to be replaced or
significantly improved at the manufacturer's next product change, we
request comment if a two percent reduction would be more appropriate.
We would consider two percent rather than five percent if we were
convinced that making all of the changes we have outlined in our
assessment of the technical feasibility of the standards was not
possible for some engines due to legacy design issues that will change
in the next design cycle. We are proposing that manufacturers making
use of these provisions would need to exhaust all credits within this
subcategory prior to using this flexibility and would not be able to
generate emissions credits from other engines in the same regulatory
subcategory as the engines complying using this alternate approach.
(ii) Gasoline Engine Standard
Heavy-duty gasoline engines are also used in vocational vehicle
applications. The number of engines certified in the past for this
segment of vehicles is very limited and has ranged between three and
five engine models. Unlike the purpose-built heavy-duty diesel engines
typical of this segment, these gasoline engines are developed for
heavy-duty pickup trucks and vans primarily, but are also sold as loose
engines to vocational vehicle manufacturers. Therefore, the agencies
evaluated these engines in parallel with the heavy-duty pickup truck
and van standard development. As with the pickup truck and van segment,
the agencies anticipate that the manufacturers will have only one
engine re-design within the 2014-18 model years under consideration
within this proposal. In our meetings with all three of the major
manufacturers in this segment, confidential future product plans were
shared with the agencies. Reflecting those plans and our estimates for
when engine changes will be made in alignment with those product plans,
we have concluded that the 2016 model year reflects the most logical
model year start date for the heavy-duty gasoline engine standards. In
order to meet the standards we are proposing for heavy-duty pickups and
vans, we project that all manufacturers will have redesigned their
gasoline engine offerings by the start of the 2016 model year. Given
the small volume of loose gasoline engine sales relative to complete
heavy-duty pickup sales, we think it is appropriate to set the timing
for the heavy-duty gasoline engine standard in line with our
projections for engine redesigns to meet the heavy-duty pickup truck
standards. Therefore, NHTSA's proposed fuel consumption standard and
EPA's proposed CO2 standard for heavy-duty gasoline engines
are first effective in the 2016 model year.
The baseline 2010 model year CO2 performance of these
heavy-duty gasoline engines over the Heavy-duty FTP cycle is 660 g
CO2/bhp-hr (6.48 gal/100 bhp-hr) in 2010 based on non-GHG
certification data provided to EPA by the manufacturers. The agencies
propose that manufacturers achieve a five percent reduction in
CO2 in the 2016 model year over the 2010 MY baseline through
use of technologies such as coupled cam phasing, engine friction
reduction, and stoichiometric gasoline direct injection. Additional
detail on technology feasibility is included in Section III and in the
draft RIA Chapter 2.
NHTSA is proposing a 7.05 gallon/100 bhp-hr standard for fuel
consumption while EPA is proposing a 627 g CO2/bhp-hr
standard tested over the Heavy-duty FTP, effective in the 2016 model
year. Similar to EPA's non-GHG standards approach, manufacturers may
generate and use credits by the same engine subcategory to show
compliance with both agencies' standards.
In the preceding section on diesel engines, we describe an
alternative compliance approach for diesel engines based on
improvements from an engine's own baseline of performance. We are not
making a similar proposal for gasoline engines, but we request comment
on the need for and appropriateness of such an approach. Comments
suggesting the need for a
[[Page 74203]]
similar approach should include specific recommendations on how the
approach would work and the technical reasons why such an approach
would be necessary in order to make the gasoline engine standards
feasible.
(c) In-Use Standards
Section 202(a)(1) of the CAA specifies that emissions standards are
to be applicable for the useful life of the vehicle. The in-use
standards that EPA is proposing would apply to individual vehicles and
engines. NHTSA is not proposing to adopt in-use standards that would
apply to the vehicles and engines in a similar fashion.
EPA is proposing that the in-use standards for heavy-duty engines
installed in vocational vehicles be established by adding an adjustment
factor to the full useful life emissions and fuel consumption results.
EPA is proposing a 2 percent adjustment factor for the in-use standard
to provide some margin for production and test-to-test variability that
could result in differences between the initial emission test results
and emission results obtained during subsequent in-use testing.
EPA is proposing that the useful life for these engine and vehicles
with respect to GHG emissions be set equal to the respective useful
life periods for criteria pollutants. EPA proposes that the existing
engine useful life periods, as included in Table II-12, be broadened to
include CO2 emissions and fuel consumption for both engines
and tractors (see 40 CFR 86.004-2). While NHTSA proposes to use useful
life considerations for establishing fuel consumption performance for
initial compliance and for ABT, NHTSA does not intend to implement an
in-use compliance program for fuel consumption, because it is not
required under EISA and because it is not currently anticipated there
will be notable deterioration of fuel consumption over the engines'
useful life.
[GRAPHIC] [TIFF OMITTED] TP30NO10.025
EPA requests comments on the magnitude and need for an in-use
adjustment factor for the engine standard and the compliance model GEM,
based chassis standard.
(2) Test Procedures and Related Issues
The agencies are proposing test procedures to evaluate fuel
consumption and CO2 emissions of vocational vehicles in a manner very
similar to Class 7 and Class 8 combination tractors. This section
describes a simulation model for demonstrating compliance, engine test
procedures, and a test procedure for evaluating hybrid powertrains (a
potential means of generating credits, although not part of the
technology on which the proposed standard is premised).
(a) Computer Simulation Model
As previously mentioned, to achieve the goal of reducing emissions
and fuel consumption for both trucks and engines, we are proposing to
set separate engine and vehicle-based emission standards. For the
vocational vehicles, engine manufacturers would be subject to the
engine standards, and chassis manufacturers would be required to
install certified engines in their chassis. The chassis manufacturer
would be subject to a separate vehicle-based standard that would use
the proposed truck simulation model to evaluate the impact of the tire
design to determine compliance with the truck standard.
A simulation model, in general, uses various inputs to characterize
a vehicle's properties (such as weight, aerodynamics, and rolling
resistance) and predicts how the vehicle would behave on the road when
it follows a driving cycle (vehicle speed versus time). On a second-by-
second basis, the model determines how much engine power needs to be
generated for the vehicle to follow the driving cycle as closely as
possible. The engine power is then transmitted to the wheels through
transmission, driveline, and axles to move the vehicle according to the
driving cycle. The second-by-second fuel consumption of the vehicle,
which corresponds to the engine power demand to move the vehicle, is
then calculated according to the fuel consumption map embedded in the
compliance model. Similar to a chassis dynamometer test, the second-by-
second fuel consumption is aggregated over the complete drive cycle to
determine the fuel consumption of the vehicle.
NHTSA and EPA are proposing to evaluate fuel consumption and
CO2 emissions respectively through a simulation of whole-
vehicle operation, consistent with the NAS recommendation to use a
truck model to evaluate truck performance. The agencies developed the
GEM for the specific purpose of this proposal to evaluate truck
performance. The GEM is similar in concept to a number of vehicle
simulation tools developed by commercial and government entities. The
model developed by the agencies and proposed here was designed for the
express purpose of vehicle compliance demonstration and is therefore
simpler and less configurable than similar commercial products. This
approach gives a compact and quicker tool for evaluating vehicle
compliance without the overhead and costs of a more complicated model.
Details of the model are included in Chapter 4 of the draft RIA.
GEM is designed to focus on the inputs most closely associated with
fuel consumption and CO2 emissions--i.e., on those which
have the largest impacts such as aerodynamics, rolling resistance,
weight, and others.
EPA and NHTSA have validated GEM based on the chassis test results
from three SmartWay certified tractors tested at Southwest Research
Institute. The validation work conducted on these three vehicles is
representative of the other Class 7 and 8 tractors. Many
[[Page 74204]]
aspects of one tractor configuration (such as the engine, transmission,
axle configuration, tire sizes, and control systems) are similar to
those used on the manufacturer's sister models. For example, the
powertrain configuration of a sleeper cab is similar to the one used on
a straight truck. Details of the validation testing and its
representativeness are included in draft RIA Chapter 4. Overall, the
GEM predicted the fuel consumption and CO2 emissions within
4 percent of the chassis test procedure results for three test cycles--
the California ARB Transient cycle, the California ARB High Speed
Cruise cycle, and the Low Speed Cruise cycle. These cycles are very
similar to the ones the agencies are proposing to utilize in compliance
testing. Test to test variation for heavy-duty vehicle chassis testing
can be higher than 4 percent based on driver variation. The proposed
simulation model is described in greater detail in draft RIA Chapter 4
and is available for download by interested parties at (http://www.epa.gov/otaq/). We request comment on all aspects of this approach
to compliance determination in general and to the use of the GEM in
particular.
The agencies are proposing that for demonstrating compliance, a
chassis manufacturer would measure the performance of tires, input the
values into GEM, and compare the model's output to the standard. Tires
are the only technology on which the agencies' own feasibility analysis
for these vehicles is predicated. An example of the GEM input screen is
included in Figure II-3. The input values for the simulation model
would be derived by the manufacturer from tire test procedure proposed
by the agencies in this proposal. The agencies are proposing that the
remaining model inputs would be fixed values that are pre-defined by
the agencies and are detailed in the draft RIA Chapter 4, including the
engine fuel consumption map to be used in the simulation.
[GRAPHIC] [TIFF OMITTED] TP30NO10.026
(b)Tire Rolling Resistance Assessment
As with the Class 7 and 8 combination tractors, NHTSA and EPA are
proposing that the vocational vehicle's tire rolling resistance input
to the GEM be determined using the ISO 28580:2009 test method.\83\ The
agencies believe the ISO test procedure is appropriate to propose for
this program because the procedure is the same one used by the NHTSA
tire fuel efficiency labeling program \84\ and is consistent with the
direction being taken by the tire industry both in the United States
and Europe, and with the EPA SmartWay program. The rolling resistance
from this test would be used to specify the rolling resistance of each
tire on the steer and drive axle of the vehicle. The results would be
expressed as a rolling resistance coefficient and measured as kilogram
per ton (kg/metric ton). The agencies are proposing that three tire
samples within each tire model be tested three times each to account
for some of the production variability and the average of the three
tests would be the rolling resistance coefficient for the tire.
---------------------------------------------------------------------------
\83\ ISO, 2009, Passenger Car, Truck, and Bus Tyres--Methods of
Measuring Rolling Resistance--Single Point Test and Correlation of
Measurement Results: ISO 28580:2009(E), First Edition, 2009-07-01.
\84\ NHTSA, 2009. ``NHTSA Tire Fuel Efficiency Consumer
Information Program Development: Phase 1--Evaluation of Laboratory
Test Protocols.'' DOT HS 811 119. June. (http://www.regulations.gov,
Docket ID: NHTSA-2008-0121-0019).
---------------------------------------------------------------------------
(c)Defined Vehicle Configurations in the GEM
As discussed above, the agencies are proposing a methodology that
chassis manufacturers would use to quantify the tire rolling resistance
values to be input into the GEM. Moreover, the agencies are proposing
to define the remaining
[[Page 74205]]
GEM inputs (i.e., specify them by rule), which may differ by the
regulatory subcategory (for reasons described in the draft RIA). The
defined inputs being proposed include the drive cycle, aerodynamics,
truck curb weight, payload, engine characteristics, and drivetrain for
each vehicle type, among others.
(i) Metric
Based on NAS's recommendation and feedback from the heavy-duty
truck industry, NHTSA and EPA are proposing standards for vocational
vehicles that would be expressed in terms of moving a ton of payload
over one mile. Thus, NHTSA's proposed fuel consumption standards for
these trucks would be represented as gallons of fuel used to move one
ton of payload one thousand miles, or gal/1,000 ton-mile. EPA's
proposed CO2 vehicle standards would be represented as grams
of CO2 per ton-mile.
(ii) Drive cycle
The drive cycle being proposed for the vocational vehicles consists
of the same three modes proposed for the Class 7-8 combination
tractors. The agencies are thus proposing the use of the Transient
mode, as defined by California ARB in the HHDDT cycle, a constant speed
cycle at 65 mph and a 55 mph constant speed mode. However, we are
proposing different weightings for each mode than proposed for Class 7
and 87 and 8 combination tractors, given the known difference in
driving patterns between these two categories of vehicles. (The same
reasoning underlies the agencies' proposal to use the Heavy-duty FTP
cycle to evaluate compliance with the standards for diesel engines used
in vocational vehicles.)
The variety of vocational vehicle applications makes it challenging
to establish a single cycle which is representative of all such trucks.
However, in aggregate, the vocational vehicles typically operate over
shorter distances and spend less time cruising at highway speeds than
combination tractors. The agencies evaluated two sources for mode
weightings, as detailed in draft RIA Chapter 3. The agencies are
proposing the mode weightings based on the vehicle speed
characteristics of single unit trucks used in EPA's MOVES model which
were developed using Federal Highway Administration data to distribute
vehicle miles traveled by road type.\85\ The proposed weighted
CO2 and fuel consumption value consists of 37 percent of 65
mph Cruise, 21 percent of 55 mph Cruise, and 42 percent of Transient
performance, which are reflected in the GEM.
---------------------------------------------------------------------------
\85\ The Environmental Protection Agency. Draft MOVES2009
Highway Vehicle Population and Activity Data. EPA-420-P-09-001,
August 2009 http://www.epa.gov/otaq/models/moves/techdocs/420p09001.pdf.
---------------------------------------------------------------------------
(iii) Empty Weight and Payload
The total weight of the vehicle is the sum of the tractor curb
weight and the payload. The agencies are proposing to specify each of
these aspects of the vehicle. The agencies developed the truck curb
weight inputs based on industry information developed by ICF.\86\ The
proposed curb weights are 10,300 pounds for the LH trucks, 13,950
pounds for the MH trucks, and 29,000 pounds for the HH trucks.
---------------------------------------------------------------------------
\86\ ICF International. ``Investigation of Costs for Strategies
to Reduce Greenhouse Gas Emissions for Heavy-Duty On-Road
Vehicles.'' July 2010. Pages 16-20. Docket ID EPA-HQ-OAR-
2010-0162-0044.
---------------------------------------------------------------------------
NHTSA and EPA are also proposing the following payload requirement
for each regulatory category. The payloads were developed from Federal
Highway statistics based on averaging the payloads for the weight
categories represented within each vehicle subcategory.\87\ The
proposed payload requirement is 5,700 pounds for the Light Heavy-Duty
trucks, 11,200 pounds for Medium Heavy-Duty trucks, and 38,000 pounds
for Heavy Heavy-Duty trucks. Additional information is available in
draft RIA Chapter 3.
---------------------------------------------------------------------------
\87\ The U.S. Federal Highway Administration. Development of
Truck Payload Equivalent Factor. Table 11. Last viewed on March 9,
2010 at http://ops.fhwa.dot.gov/freight/freight_analysis/faf/faf2_reports/reports9/s510_11_12_tables.htm.
---------------------------------------------------------------------------
(iv) Engine
As the agencies are proposing separate engine and truck standards,
the GEM will be used to assess the compliance of the chassis with the
vehicle standard. To maintain the separate assessments, the agencies
are proposing to use fixed values that are pre-defined by the agencies
for the engine characteristics used in GEM, including the fuel
consumption map which provides the fuel consumption at hundreds of
engine speed and torque points. If the agencies did not standardize the
fuel map, then a truck that uses an engine with emissions and fuel
consumption better than the standards would require fewer vehicle
reductions than those being proposed. The agencies are proposing that
the engine characteristics used in GEM be representative of a diesel
engine, because it represents the largest fraction of engines in this
market.
The agencies are proposing two distinct sets of fuel consumption
maps for use in GEM. The first fuel consumption map would be used in
GEM for the 2014 through 2016 model years and represent a diesel engine
which meets the 2014 model year engine CO2 emissions
standards. A second fuel consumption map would be used beginning in the
2017 model year and represents a diesel engine which meets the 2017
model year CO2 emissions and fuel consumption standards and
accounts for the increased stringency in the proposed MY 2017
standard). Effectively there is no change in stringency of the
vocational vehicle standard (not including the engine) so that there is
stability in the vocational vehicle (not including engine) standards
for the full rulemaking period. These inputs are reasonable (indeed,
seemingly necessitated) given the separate proposed regulatory
requirement that vocational vehicle chassis manufacturers use only
certified engines.
(v) Drivetrain
The agencies' assessment of the current vehicle configuration
process at the truck dealer's level is that the truck companies provide
software tools to specify the proper drivetrain matched to the buyer's
specific circumstances. These dealer tools allow a significant amount
of customization for drive cycle and payload to provide the best
specification for the customer. The agencies are not seeking to disrupt
this process. Optimal drivetrain selection is dependent on the engine,
drive cycle (including vehicle speed and road grade), and payload. Each
combination of engine, drive cycle, and payload has a single optimal
transmission and final drive ratio. The agencies are proposing to
specify the engine's fuel consumption map, drive cycle, and payload;
therefore, it makes sense to specify the drivetrain that matches.
In conclusion, for vocational vehicles, compliance would be
determined by establishing values for the tire rolling resistance and
using the prescribed inputs in GEM. The model would produce
CO2 and fuel consumption results that would be compared
against EPA's and NHTSA's respective standards.
(d) Engine Test Procedures
The NAS panel did not specifically discuss or recommend a metric to
evaluate the fuel consumption of heavy-duty engines. However, as noted
above they did recommend the use of a load-specific fuel consumption
metric for the
[[Page 74206]]
evaluation of vehicles.\88\ An analogous metric for engines would be
the amount of fuel consumed per unit of work. Thus, EPA is proposing
that GHG emission standards for engines under the CAA would be
expressed as g/bhp-hr: similarly, NHTSA's proposed fuel consumption
standards under EISA would be represented as gallons of fuel per 100
horsepower-hour (gal/100 bhp-hr). EPA's metric is also consistent with
EPA's current standards for non-GHG emissions for these engines.
---------------------------------------------------------------------------
\88\ See 2010 NAS Report, Note 19, page 39.
---------------------------------------------------------------------------
EPA's criteria pollutant standards for engines currently require
that manufacturers demonstrate compliance over the transient FTP cycle;
over the steady-state SET procedure; and during not-to-exceed testing.
EPA created this multi-layered approach to criteria emissions control
in response to engine designs that optimized operation for lowest fuel
consumption at the expense of very high criteria emissions when
operated off the regulatory cycle. EPA's use of multiple test
procedures for criteria pollutants helps to ensure that manufacturers
calibrate engine systems for compliance under all operating conditions.
With regard to GHG and fuel consumption control, the agencies believe
it is more appropriate to set standards based on a single test
procedure, either the Heavy-duty FTP or SET, depending on the primary
expected use of the engine.
As discussed above, it is critical to set standards based on the
most representative test cycles in order for performance in-use to
obtain the intended (and feasible) air quality benefits. We further
explained why the Heavy-duty FTP is the appropriate test cycle for
engines used in vocational vehicles, and the steady-state SET procedure
the most appropriate for engines used in combination tractors. We are
not concerned if off-cycle manufacturers further calibrate these
designs to give better in-use fuel consumption while maintaining
compliance with the criteria emissions standards as such calibration is
entirely consistent with the goals of our joint program. Further, we
believe that setting standards based on both transient and steady-state
operating conditions for all engines could lead to undesirable
outcomes. For example, as noted earlier, turbocompounding is one
technology that the agencies have identified as a likely approach for
compliance with our proposed HHD SET standard described below.
Turbocompounding is a very effective approach to lower fuel consumption
under steady driving conditions typified by combination tractor trailer
operation and is well reflected in testing over the SET test procedure.
However, when used in driving typified by transient operation as we
expect for vocational vehicles and as is represented by the Heavy-duty
FTP, turbocompounding shows very little benefit. Setting an emission
standard based on the Heavy-duty FTP for engines intended for use in
combination tractor trailers could lead manufacturers to not apply
turbocompounding even though it can be a highly cost effective means to
reduce GHG emissions and lower fuel consumption.
The current non-GHG emissions engine test procedures also require
the development of regeneration emission rates and frequency factors to
account for the emission changes during a regeneration event (40 CFR
86.004-28). EPA and NHTSA are proposing to exclude the CO2
emissions and fuel consumption increases due to regeneration from the
calculation of the compliance levels over the defined test procedures.
We considered including regeneration in the estimate of fuel
consumption and GHG emissions and have decided not to do so for two
reasons. First, EPA's existing criteria emission regulations already
provide a strong motivation to engine manufacturers to reduce the
frequency and duration of infrequent regeneration events. The very
stringent 2010 NOX emission standards cannot be met by
engine designs that lead to frequent and extended regeneration events.
Hence, we believe engine manufacturers are already reducing
regeneration emissions to the greatest degree possible. In addition to
believing that regenerations are already controlled to the extent
technologically possible, we believe that attempting to include
regeneration emissions in the standard setting could lead to an
inadvertently lax emissions standard. In order to include regeneration
and set appropriate standards, EPA and NHTSA would have needed to
project the regeneration frequency and duration of future engine
designs in the timeframe of this proposal. Such a projection would be
inherently difficult to make and quite likely would underestimate the
progress engine manufacturers will make in reducing infrequent
regenerations. If we underestimated that progress, we would effectively
be setting a more lax set of standards than otherwise would be
expected. Hence in setting a standard including regeneration emissions
we faced the real possibility that we would achieve less effective
CO2 emissions control and fuel consumption reductions than
we will achieve by not including regeneration emissions. We are seeking
comments regarding regeneration emissions and what approach if any the
agencies should use in reflecting regeneration emissions in this
program.
(e) Hybrid Powertrain Technology
Although the proposed vocational vehicle standards are not premised
on use of hybrid powertrains, certain vocational vehicle applications
may be suitable candidates for use of hybrids due to the greater
frequency of stop-and-go urban operation and their use of power take-
off (PTO) systems. Examples are vocational vehicles used predominantly
in stop-start urban driving (e.g., delivery trucks). As an incentive,
the agencies are proposing to provide credits for the use of hybrid
powertrain technology as described in Section IV. The agencies are
proposing that any credits generated using such technologies could be
applied to any heavy-duty vehicle or engine, and not be limited to the
vehicle category generating the credit. Section IV below also details
the proposed approach to account for the use of a hybrid powertrain
when evaluating compliance with the truck standard. In general,
manufacturers can derive the fuel consumption and CO2
emissions reductions based on comparative test results using the
proposed chassis testing procedures. We are proposing the same three
drive cycles and cycle weightings discussed for the vocational vehicles
to evaluate trucks that use hybrid powertrains to power the vehicle
during motive operation (such as pickup and delivery trucks and transit
buses). However, we are proposing an additional PTO test cycle for
trucks which use a PTO to power equipment while the vehicle is either
idling or moving (such as bucket or refuse trucks). The reductions due
to the hybrid technology would be calculated relative to the same type
of vehicle with a conventional powertrain tested using the same
protocol.
(3) Summary of Proposed Flexibility and Credit Provisions
EPA and NHTSA are proposing a number of flexibility provisions for
vocational vehicle chassis manufacturers and engine manufacturers, as
discussed in Section IV below. These provisions are all based on an
averaging, banking and trading program for emissions and fuel
consumption credits. They include provisions to encourage the
introduction of advanced technologies such as hybrid drivetrains,
provisions to
[[Page 74207]]
incentivize early compliance with the proposed standards, and
provisions to allow compliance using innovative technologies
unanticipated by the agencies in developing this proposal.
(4) Deferral of Standards for Small Chassis Manufacturing and Small
Engine Companies
EPA and NHTSA are proposing to defer greenhouse gas emissions and
fuel consumption standards from small vocational vehicle chassis
manufacturers meeting the SBA size criteria of a small business as
described in 13 CFR 121.201 (see 40 CFR 1036.150 and 1037.150). The
agencies will instead consider appropriate GHG and fuel consumption
standards for these entities as part of a future regulatory action.
This includes both U.S.-based and foreign small volume heavy-duty truck
and engine manufacturers.
The agencies have identified ten chassis entities that appear to
fit the SBA size criterion of a small business.\89\ The agencies
estimate that these small entities comprise less than 0.5 percent of
the total heavy-duty vocational vehicle market in the United States
based on Polk Registration Data from 2003 through 2007,\90\ and
therefore that the exemption will have a negligible impact on the GHG
emissions and fuel consumption improvements from the proposed
standards.
---------------------------------------------------------------------------
\89\ The agencies have identified Lodal, Indiana Phoenix,
Autocar LLC, HME, Giradin, Azure Dynamics, DesignLine International,
Ebus, Krystal Koach, and Millenium Transit Services LLC as potential
small business chassis manufacturers.
\90\ M.J. Bradley. Heavy-duty Vehicle Market Analysis. May 2009.
---------------------------------------------------------------------------
EPA and NHTSA have also identified three engine manufacturing
entities that appear to fit the SBA size criteria of a small business
based on company information included in Hoover's.\91\ Based on 2008
and 2009 model year engine certification data submitted to EPA for non-
GHG emissions standards, the agencies estimate that these small
entities comprise less than 0.1 percent of the total heavy-duty engine
sales in the United States. The proposed exemption from the standards
established under this proposal would have a negligible impact on the
GHG emissions and fuel consumption reductions otherwise due to the
standards.
---------------------------------------------------------------------------
\91\ The agencies have identified Baytech Corporation, Clean
Fuels USA, and BAF Technologies, Inc. as three potential small
businesses.
---------------------------------------------------------------------------
To ensure that the agencies are aware of which companies would be
exempt, we propose to require that such entities submit a declaration
to EPA and NHTSA containing a detailed written description of how that
manufacturer qualifies as a small entity under the provisions of 13 CFR
121.201.
E. Other Standards Provisions
In addition to proposing CO2 emission standards for
heavy-duty vehicles and engines, EPA is also proposing separate
standards for N2O and CH4 emissions.\92\ NHTSA is
not proposing comparable separate standards for these GHGs because they
are not directly related to fuel consumption in the same way that
CO2 is, and NHTSA's authority under EISA exclusively relates
to fuel efficiency. N2O and CH4 are important
GHGs that contribute to global warming, more so than CO2 for
the same amount of emissions due to their high Global Warming Potential
(GWP).\93\ EPA is proposing N2O and CH4 standards
which apply to HD pickup trucks and vans as well as to all heavy-duty
engines. EPA is not proposing N2O and CH4
standards for the Class 7 and 8 tractor or Class 2b-8 chassis
manufacturers because these emissions would be controlled through the
engine program.
---------------------------------------------------------------------------
\92\ NHTSA's statutory responsibilities relating to reducing
fuel consumption are directly related to reducing CO2
emissions, but not to the control of other GHGs.
\93\ N2O has a GWP of 298 and CH4 has a
GWP of 25 according to the IPCC Fourth Assessment Report.
---------------------------------------------------------------------------
EPA is requesting comment in Section II.E.4 below on possible
alternative CO2 equivalent approaches to provide near-term
flexibility for 2012-14 MY light-duty vehicles.
Almost universally across current engine designs, both gasoline-
and diesel-fueled, N2O and CH4 emissions are
relatively low today and EPA does not believe it would be appropriate
or feasible to require reductions from the levels of current gasoline
and diesel engines. This is because for the most part, the same
hardware and controls used by heavy-duty engines and vehicles that have
been optimized for nonmethane hydrocarbon (NMHC) and NOX
control indirectly result in highly effective control of N2O
and CH4. Additionally, unlike criteria pollutants, specific
technologies beyond those presently implemented in heavy-duty vehicles
to meet existing emission requirements have not surfaced that
specifically target reductions in N2O or CH4.
Because of this, reductions in N2O or CH4 beyond
current levels in most heavy-duty applications would occur through the
same mechanisms that result in NMHC and NOX reductions and
would likely result in an increase in the overall stringency of the
criteria pollutant emission standards. Nevertheless, it is important
that future engine technologies or fuels not currently researched do
not result in increases in these emissions, and this is the intent of
the proposed ``cap'' standards. The proposed standards would act to cap
emissions at today's levels to ensure that manufacturers maintain
effective N2O and CH4 emissions controls
currently used should they choose a different technology path from what
is currently used to control NMHC and NOX but also largely
successful methods for controlling N2O and CH4.
As discussed below, some technologies that manufacturers may adopt for
reasons other than reducing fuel consumption or GHG emissions could
increase N2O and CH4 emissions if manufacturers
do not address these emissions in their overall engine and
aftertreatment design and development plans. Manufacturers will be able
to design and develop the engines and aftertreatment to avoid such
emissions increases through appropriate emission control technology
selections like those already used and available today. Because EPA
believes that these standards can be capped at the same level,
regardless of type of HD engine involved, the following discussion
relates to all types of HD engines regardless of the vehicles in which
such engines are ultimately used. In addition, since these standards
are designed to cap current emissions, EPA is proposing the same
standards for all of the model years to which the rules apply.
EPA believes that the proposed N2O and CH4
cap standards would accomplish the primary goal of deterring increases
in these emissions as engine and aftertreatment technologies evolve
because manufacturers will continue to target current or lower
N2O and CH4 levels in order to maintain typical
compliance margins. While the cap standards are set at levels that are
higher than current average emission levels, the control technologies
used today are highly effective and there is no reason to believe that
emissions will slip to levels close to the cap, particularly
considering compliance margin targets. The caps will protect against
significant increases in emissions due to new or poorly implemented
technologies. However, we also believe that an alternative compliance
approach that allows manufacturers to convert these emissions to
CO2eq emission values and combine them with CO2
into a single compliance value would also be appropriate, so long as it
did not undermine the stringency of the CO2 standard. As
described below, EPA is proposing that such an alternative
[[Page 74208]]
compliance approach be available to manufacturers to provide certain
flexibilities for different technologies.
EPA requests comments on the approach to regulating N2O
and CH4 emissions including the appropriateness of ``cap''
standards, the technical bases for the levels of the proposed
N2O and CH4 standards, the proposed test
procedures, and the proposed timing for the standards. In addition, EPA
seeks any additional emissions data on N2O and
CH4 from current technology engines.
EPA is basing its proposed N2O and CH4
standards on available test data. We are soliciting additional data,
and especially data for in-use vehicles and engines that would help to
better characterize changes in emissions of these pollutants throughout
their useful lives, for both gasoline and diesel applications. As is
typical for EPA emissions standards, we are proposing that
manufacturers should establish deterioration factors to ensure
compliance throughout the useful life. We are not at this time aware of
deterioration mechanisms for N2O and CH4 that
would result in large deterioration factors, but neither do we believe
enough is known about these mechanisms to justify proposing assigned
factors corresponding to no deterioration, as we are proposing for
CO2, or for that matter to any predetermined level. We are
therefore asking for comment on this subject.
In addition to N2O and CH4 standards, this
section also discusses air conditioning-related provisions and EPA's
proposal to extend certification requirements to all-electric HD
vehicles and vehicles and engines designed to run on ethanol fuel.
(1) What is EPA's proposed approach to controlling N2O?
N2O is a global warming gas with a GWP of 298. It
accounts for about 0.3% of the current greenhouse gas emissions from
heavy-duty trucks.\94\
---------------------------------------------------------------------------
\94\ Value adapted from ``Inventory of U.S. Greenhouse Gas
Emissions and Sinks: 1990-2007. April 2009.
---------------------------------------------------------------------------
N2O is emitted from gasoline and diesel vehicles mainly
during specific catalyst temperature conditions conducive to
N2O formation. Specifically, N2O can be generated
during periods of emission hardware warm-up when rising catalyst
temperatures pass through the temperature window when N2O
formation potential is possible. For current heavy-duty gasoline
engines with conventional three-way catalyst technology, N2O
is not generally produced in significant amounts because the time the
catalyst spends at the critical temperatures during warm-up is short.
This is largely due to the need to quickly reach the higher
temperatures necessary for high catalyst efficiency to achieve emission
compliance of criteria pollutants. N2O formation is
generally only a concern with diesel and potentially with future
gasoline lean-burn engines with compromised NOX emissions
control systems. If the risk for N2O formation is not
factored into the design of the controls, these systems can but need
not be designed in a way that emphasizes efficient NOX
control while allowing the formation of significant quantities of
N2O. However, these future advanced gasoline and diesel
technologies do not inherently require N2O formation to
properly control NOX. Pathways exist today that meet
criteria emission standards that would not compromise N2O
emissions in future systems as observed in current production engine
and vehicle testing \95\ which would also work for future diesel and
gasoline technologies. Manufacturers would need to use appropriate
technologies and temperature controls during future development
programs with the objective to optimize for both NOX and
N2O control. Therefore, future designs and controls at
reducing criteria emissions would need to take into account the balance
of reducing these emissions with the different control approaches while
also preventing inadvertent N2O formation, much like the
path taken in current heavy-duty compliant engines and vehicles.
Alternatively, manufacturers who find technologies that reduce criteria
or CO2 emissions but see increases N2O emissions
beyond the cap could choose to offset N2O emissions with
reduction in CO2 as allowed in the proposed CO2eq
option discussed in Section II.E.3.
---------------------------------------------------------------------------
\95\ Memorandum ``N2O Data from EPA Heavy-Duty
Testing''.
---------------------------------------------------------------------------
EPA is proposing an N2O emission standard that we
believe would be met by current-technology gasoline and diesel vehicles
at essentially no cost. EPA believes that heavy-duty emission standards
since 2008 model year, specifically the very stringent NOX
standards for both engine and chassis certified engines, directly
result in stringent N2O control. It is believed that the
current emission control technologies used to meet the stringent
NOX standards achieve the maximum feasible reductions and
that no additional technologies are recognized that would result in
additional N2O reductions. As noted, N2O
formation in current catalyst systems occurs, but their emission levels
are inherently low, because the time the catalyst spends at the
critical temperatures during warm-up when N2O can form is
short. At the same time, we believe that the proposed standard would
ensure that the design of advanced NOX control systems for
future diesel and lean-burn gasoline vehicles would control
N2O emission levels. While current NOX control
approaches used on current heavy-duty diesel vehicles do not compromise
N2O emissions and actually result in N2O control,
we believe that the proposed standards would discourage any new
emission control designs for diesels or lean-burn gasoline vehicles
that achieve criteria emissions compliance at the cost of increased
N2O emissions. Thus, the proposed standard would cap
N2O emission levels, with the expectation that current
gasoline and diesel vehicle control approaches that comply with heavy-
duty vehicle emission standards for NOX would not increase
their emission levels, and that the cap would ensure that future diesel
and lean-burn gasoline vehicles with advanced NOX controls
would appropriately control their emissions of N2O.
(a) Heavy-Duty Pickup Truck and Van N2O Exhaust Emission
Standard
EPA is proposing a per-vehicle N2O emission standard of
0.05 g/mi, measured over the Light-duty FTP and HFET drive cycles.
Similar to the CO2 standard approach, the N2O
emission level of a vehicle would be a composite of the Light-duty FTP
and HFET cycles with the same 55 percent city weighting and 45 percent
highway weighting. The standard would become effective in model year
2014 for all HD pickups and vans that are subject to the proposed
CO2 emission requirements. Averaging between vehicles would
not be allowed. The standard is designed to prevent increases in
N2O emissions from current levels, i.e., a no-backsliding
standard.
The proposed N2O level is approximately two times the
average N2O level of current gasoline and diesel heavy-duty
trucks that meet the NOX standards effective since 2008
model year.\96\ Manufacturers typically use design targets for
NOX emission levels at approximately 50% of the standard, to
account for in-use emissions deterioration and normal testing and
production variability, and we expect manufacturers to utilize a
similar approach for N2O emission compliance. We are not
proposing a more stringent
[[Page 74209]]
standard for current gasoline and diesel vehicles because the stringent
heavy-duty NOX standards already result in significant
N2O control, and we do not expect current N2O levels to rise
for these vehicles particularly with expected manufacturer compliance
margins.
---------------------------------------------------------------------------
\96\ Memorandum ``N2O Data from EPA Heavy-Duty
Testing''.
---------------------------------------------------------------------------
Diesel heavy-duty pickup trucks and vans with advanced emission
control technology are in the early stages of development and
commercialization. As this segment of the vehicle market develops, the
proposed N2O standard would require manufacturers to
incorporate control strategies that minimize N2O formation.
Available approaches include using electronic controls to limit
catalyst conditions that might favor N2O formation and
considering different catalyst formulations. While some of these
approaches may have associated costs, EPA believes that they will be
small compared to the overall costs of the advanced NOX
control technologies already required to meet heavy-duty standards.
The light-duty GHG rule requires that manufacturers begin testing
for N2O by 2015 model year. The manufacturers of complete
pickup trucks and vans (Ford, General Motors, and Chrysler) are already
impacted by the light-duty GHG rule and will therefore have this
equipment and capability in place for the timing of this proposal.
Overall, we believe that manufacturers of HD pickups and vans (both
gasoline and diesel) would meet the proposed standard without
implementing any significantly new technologies, only further
refinement of their existing controls, and we do not expect there to be
any significant costs associated with this standard.
(b) Heavy-Duty Engine N2O Exhaust Emission Standard
EPA is also proposing a per engine N2O emissions
standard of 0.05 g/bhp-hr for heavy-duty engines which become effective
in 2014 model year. These standards remain the same over the useful
life of the engine. The N2O emissions would be measured over
the Heavy-duty FTP cycle because it is believed that this cycle poses
the highest risk for N2O formation versus the additional
heavy-duty compliance cycles. Averaging between vehicles would not be
allowed. The standard is designed to prevent increases in
N2O emissions from current levels, i.e., a no-backsliding
standard.
The proposed N2O level is twice the average
N2O level of current diesel engines as demonstrated in the
ACES Study and in EPA's testing of two additional engines with
selective catalytic reduction aftertreatement systems.\97\
Manufacturers typically use design targets for NOX emission
levels of about 50% of the standard, to account for in-use emissions
deterioration and normal testing and production variability, and
manufacturers are expected to utilize a similar approach for
N2O emission compliance. EPA requests comment on the
agency's technical assessment of current and potential future
N2O formation in heavy-duty engines, as presented here.
---------------------------------------------------------------------------
\97\ Coordinating Research Council Report: ACES Phase 1 of the
Advanced Collaborative Emissions Study, 2009. (This study included
detailed chemical characterization of exhaust species emitted from
four 2007 model year heavy heavy diesel engines.)
---------------------------------------------------------------------------
Engine emissions regulations do not currently require testing for
N2O. The Mandatory GHG Reporting final rule requires
reporting of N2O and requires that manufacturers either
measure N2O or use a compliance statement based on good
engineering judgment in lieu of direct N2O measurement (74
FR 56260, October 30, 2009). The light-duty GHG final rule allows
manufacturers to provide a compliance statement based on good
engineering judgment through the 2014 model year, but requires
measurement beginning in 2015 model year (75 FR 25324, May 7, 2010).
EPA is proposing a consistent approach for heavy-duty engine
manufacturers which allows them to delay direct measurement of
N2O until the 2015 model year. EPA welcomes comments on
whether there are differences in the heavy-duty market which would
warrant a different approach.
Manufacturers without the capability to measure N2O by
the 2015 model year would need to acquire and install appropriate
measurement equipment in response to this proposed program. EPA has
established four separate N2O measurement methods, all of
which are commercially available today. EPA expects that most
manufacturers would use photo-acoustic measurement equipment, which EPA
estimates would result in a one-time cost of about $50,000 for each
test cell that would need to be upgraded.
Overall, EPA believes that manufacturers of heavy-duty engines,
both gasoline and diesel, would meet the proposed standard without
implementing any new technologies, and beyond relatively small
facilities costs for any companies that still need to acquire and
install N2O measurement equipment, EPA does not project that
manufacturers would incur significant costs associated with this
proposed N2O standard.
EPA is not proposing any vehicle-level N2O standards for
heavy-duty trucks (combination and vocational) in this proposal. The
N2O emissions would be controlled through the heavy-duty
engine portion of the program. The only requirement of those truck
manufacturers to comply with the N2O requirements is to
install a certified engine.
(2) What is EPA's proposed approach to controlling CH4?
CH4 is greenhouse gas with a GWP of 25. It accounts for
about 0.03% of the greenhouse gases from heavy-duty trucks.\98\
---------------------------------------------------------------------------
\98\ Value adapted from ``Inventory of U.S. Greenhouse Gas
Emissions and Sinks: 1990-2007. April 2009.
---------------------------------------------------------------------------
EPA is proposing a standard that would cap CH4 emission
levels, with the expectation that current heavy-duty vehicles and
engines meeting the heavy-duty emission standards would not increase
their levels as explained earlier due to robust current controls and
manufacturer compliance margin targets. It would ensure that emissions
would be addressed if in the future there are increases in the use of
natural gas or any other alternative fuel. EPA believes that current
heavy-duty emission standards, specifically the NMHC standards for both
engine and chassis certified engines directly result in stringent
CH4 control. It is believed that the current emission
control technologies used to meet the stringent NMHC standards achieve
the maximum feasible reductions and that no additional technologies are
recognized that would result in additional CH4 reductions.
The level of the standard would generally be achievable through normal
emission control methods already required to meet heavy-duty emission
standards for hydrocarbons and EPA is therefore not attributing any
cost to this part of the proposal. Since CH4 is produced in
gasoline and diesel engines similar to other hydrocarbon components,
controls targeted at reducing overall NMHC levels generally also work
at reducing CH4 emissions. Therefore, for gasoline and
diesel vehicles, the heavy-duty hydrocarbon standards will generally
prevent increases in CH4 emissions levels. CH4
from heavy-duty vehicles is relatively low compared to other GHGs
largely due to the high effectiveness of the current heavy-duty
standards in controlling overall HC emissions.
EPA believes that this level for the standard would be met by
current gasoline and diesel trucks and vans, and would prevent
increases in future CH4
[[Page 74210]]
emissions in the event that alternative fueled vehicles with high
methane emissions, like some past dedicated compressed natural gas
vehicles, become a significant part of the vehicle fleet. Currently EPA
does not have separate CH4 standards because, unlike other
hydrocarbons, CH4 does not contribute significantly to ozone
formation.\99\ However, CH4 emissions levels in the gasoline
and diesel heavy-duty truck fleet have nevertheless generally been
controlled by the heavy-duty HC emission standards. Even so, without an
emission standard for CH4, future emission levels of
CH4 cannot be guaranteed to remain at current levels as
vehicle technologies and fuels evolve.
---------------------------------------------------------------------------
\99\ But see Ford Motor Co. v. EPA, 604 F. 2d 685 (DC Cir. 1979)
(permissible for EPA to regulate CH4 under CAA section
202(b)).
---------------------------------------------------------------------------
In recent model years, a small number of heavy-duty trucks and
engines were sold that were designed for dedicated use of natural gas.
While emission control designs on these recent dedicated natural gas-
fueled vehicles demonstrate CH4 control can be as effective
as gasoline or diesel equivalent vehicles, natural gas-fueled vehicles
have historically produced significantly higher CH4
emissions than gasoline or diesel vehicles. This is because the fuel is
predominantly methane, and most of the unburned fuel that escapes
combustion without being oxidized by the catalyst is emitted as
methane. However, even if these vehicles meet the heavy-duty
hydrocarbon standard and appear to have effective CH4
control by nature of the hydrocarbon controls, the heavy-duty standards
do not require CH4 control and therefore some natural gas
vehicle manufacturers have invested very little effort into methane
control. While the proposed CH4 cap standard should not
require any different emission control designs beyond what is already
required to meet heavy-duty hydrocarbon standards on a dedicated
natural gas vehicle (i.e., feedback controlled 3-way catalyst), the cap
will ensure that systems provide robust control of methane much like a
gasoline-fueled engine. We are not proposing more stringent
CH4 standards because we believe that the controls used to
meet current heavy-duty hydrocarbon standards should result in
effective CH4 control when properly implemented. Since
CH4 is already measured under the current heavy-duty
emissions regulations (so that it may be subtracted to calculate NMHC),
the proposed standard would not result in additional testing costs. EPA
requests comment on whether the proposed cap standard would result in
any significant technological challenges for manufacturers of natural
gas vehicles.
(a) Heavy-Duty Pickup Truck and Van CH4 Standard
EPA is proposing a CH4 emission standard of 0. 05 g/mi
as measured on the Light-duty FTP and HFET drive cycles, to apply
beginning with model year 2014 for HD pickups and vans subject to the
proposed CO2 standards. Similar to the CO2
standard approach, the CH4 emission level of a vehicle would
be a composite of the Light-duty FTP and HFET cycles with the same 55%
city weighting and 45% highway weighting.
The level of the proposed standard is approximately two times the
average heavy-duty gasoline and diesel truck and van levels.\100\ As
with N2O, this proposed level recognizes that manufacturers
typically set emissions design targets with a compliance margin of
approximately 50% of the standard. Thus, we believe that the proposed
standard should be met by current gasoline vehicles with no increase
from today's CH4 levels. Similarly, since current diesel
vehicles generally have even lower CH4 emissions than
gasoline vehicles, we believe that diesels would also meet the proposed
standard with a larger compliance margin resulting in no change in
today's CH4 levels.
---------------------------------------------------------------------------
\100\ Memorandum ``CH4 Data from 2010 and 2011 Heavy-
Duty Vehicle Certification Tests''.
---------------------------------------------------------------------------
(b) Heavy-Duty Engine CH4 Exhaust Emission Standard
EPA is proposing a heavy-duty engine CH4 emission
standard of 0.05 g/hp-hr as measured on the Heavy-duty FTP, to apply
beginning in model year 2014. The proposed standard would cap
CH4 emissions at a level currently achieved by diesel and
gasoline heavy-duty engines. The level of the standard would generally
be achievable through normal emission control methods already required
to meet 2007 emission standards for NMHC and EPA is therefore not
attributing any cost to this part of this proposal (see 40 CFR 86.007-
11).
The level of the proposed CH4 standard is twice the
average CH4 emissions from the four diesel engines in the
ACES study.\101\ As with N2O, this proposed level recognizes
that manufacturers typically set emission design targets at about 50%
of the standard. Thus, EPA believes the proposed standard would be met
by current diesel and gasoline engines with little if any technological
improvements. The agency believes a more stringent CH4
standard is not necessary due to effective CH4 controls in
current heavy-duty technologies, since, as discussed above for
N2O, EPA believes that the challenge of complying with the
CO2 standards should be the primary focus of the
manufacturers.
---------------------------------------------------------------------------
\101\ Coordinating Researth Council Report: ACES Phase 1 of the
Advanced Collaborative Emissions Study, 2009.
---------------------------------------------------------------------------
CH4 is measured under the current 2007 regulations so
that it may be subtracted to calculate NMHC. Therefore EPA expects that
the proposed standard would not result in additional testing costs.
EPA is not proposing any vehicle-level CH4 standards for
heavy-duty trucks (combination or vocational) in this proposal. The
CH4 emissions would be controlled through the heavy-duty
engine portion of the program. The only requirement of these truck
manufacturers to comply with the CH4 requirements is to
install a certified engine.
(3) Alternative CO2 Equivalent Option
If a manufacturer is unable to meet the N2O or
CH4 cap standards, EPA is proposing that the manufacturer
may choose to comply using CO2 credits. In other words, a
manufacturer could offset any N2O emissions or any
CH4 emissions by taking steps to further reduce
CO2. A manufacturer choosing this option would convert its
measured N2O and CH4 test results in excess of
the applicable standards into CO2eq to determine the amount
of CO2 credits required. For example, a manufacturer would
use 25 Mg of positive CO2 credits to offset 1 Mg of negative
CH4 credits or use 298 Mg of positive CO2 credits
to offset 1 Mg of negative N2O credits.\102\ By using the
Global Warming Potential of N2O and CH4, the
proposed approach recognizes the inter-correlation of these elements in
impacting global warming and is environmentally neutral to meeting the
proposed individual emissions caps.
---------------------------------------------------------------------------
\102\ N2O has a GWP of 298 and CH4 has a
GWP of 25 according to the IPCC Fourth Assessment Report.
---------------------------------------------------------------------------
The proposed NHTSA fuel consumption program will not use
CO2eq, as suggested above. Measured performance to the NHTSA
fuel consumption standards will be based on the measurement of
CO2 with no adjustment for N2O and/or
CH4. For manufacturers that use the EPA alternative
CO2eq credit, compliance to the EPA CO2 standard
will not be directly equivalent to compliance to the NHTSA fuel
consumption standard.
[[Page 74211]]
(4) Light-Duty Vehicle N2O and CH4 Standards
For light-duty vehicles, as part of the MY 2012-2016 rulemaking,
EPA finalized standards for N2O and CH4 which
take effect with MY 2012. 75 FR at 25421-24. Similar to the heavy-duty
standards discussed in Section II.E above, the light-duty vehicle
standards for N2O and CH4 were established to cap
emissions and prevent future emissions increases, and were generally
not expected to result in the application of new technologies for
current vehicle designs or significant costs for the manufacturers. EPA
also finalized an alternative CO2 equivalent standard
option, which manufacturers may choose to use in lieu of complying with
the otherwise-applicable N2O and CH4 standards.
The CO2-equivalent standard option allows manufacturers to
fold all N2O and CH4 emissions, on a
CO2-equivalent basis, along with CO2 into their
otherwise applicable CO2 emissions standard level. For
flexible-fueled vehicles, the N2O and CH4
standards must be met on both fuels (e.g., both gasoline and E-85).
EPA has learned since the standards were finalized that some
manufacturers may have difficulty meeting the N2O and/or
CH4 standards in the early years of the program for a few of
the vehicle models in their existing fleet. This is problematic in the
near-term because there is little lead time to implement unplanned
redesigns of vehicles to meet the standards. In such cases,
manufacturers may need to either drop vehicle models from their fleet
or to comply using the CO2 equivalent alternative. On a
CO2 equivalent basis, folding in all N2O and
CH4 emissions would add 3-4 g/mile or more to a
manufacturer's overall fleet-average CO2 emissions level
because the alternative standard must be used for the entire fleet, not
just for the problem vehicles. This could be especially challenging in
the early years of the program for manufacturers with little compliance
margin because there is very limited lead time to develop strategies to
address these additional emissions. EPA believes this poses a
legitimate issue of sufficiency of lead time in the short term (as well
as an issue of cost, since EPA assumed that the N2O and
CH4 standards were essentially cost free) but expects that
manufacturers would be able to make technology changes (e.g.,
calibration or catalyst changes) to the few vehicle models not
currently meeting the N2O and/or CH4 standards in
the course of their planned vehicle redesign schedules in order to meet
the standards.
Because EPA intended for these standards to be caps with little
anticipated near-term impact on manufacturer's current product lines,
EPA believes that it would be appropriate to provide additional
flexibility in the near-term to allow manufacturers to meet the
N2O and CH4 standards. EPA requests comments on
the option of allowing manufacturers to use the CO2
equivalent approach for one pollutant but not the other for their
fleet--that is, allowing a manufacturer to fold in either
CH4 or N2O as part of the CO2-
equivalent standard. For example, if a manufacturer is having trouble
complying with the CH4 standard but not the N2O
standard, the manufacturer could use the N2O equivalent
option including CH4, but choose to comply separately with
the applicable N2O cap standard. EPA requests comments on
allowing this approach in the light-duty program for MYs 2012-2014 as
an additional flexibility to help manufacturers address any near-term
issues that they may have with the N2O and CH4
standards.
EPA also requests comments on possible alternative approaches of
providing additional near-term flexibility. For example, as discussed
in Section II.E above, EPA is proposing for HD vehicles and engines to
allow manufacturers to use CO2 credits, on a CO2
equivalent basis, to offset N2O and CH4 emissions
above the applicable standard. EPA requests comment on whether this
approach would be appropriate for the light-duty program as an
additional flexibility. Again, the additional flexibility would be
limited to MYs 2012-2014 for the reasons discussed above. EPA notes
that, after considering all relevant comments, provisions to address
this issue may be finalized in an action independent of the heavy-duty
rulemaking process in the interest of finalizing the provisions as soon
as possible to provide manufacturers with certainty for MY 2012 light-
duty vehicles.
(5) EPA's Proposed Standards for Direct Emissions From Air Conditioning
Air conditioning systems contribute to GHG emissions in two ways--
direct emissions through refrigerant leakage and indirect exhaust
emissions due to the extra load on the vehicle's engine to provide
power to the air conditioning system. HFC refrigerants, which are
powerful GHG pollutants, can leak from the A/C system.\103\ This
includes the direct leakage of refrigerant as well as the subsequent
leakage associate with maintenance and servicing, and with disposal at
the end of the vehicle's life.\104\ The most commonly used refrigerant
in automotive applications--R134a, has a high GWP of 1430.\105\ Due to
the high GWP of R134a, a small leakage of the refrigerant has a much
greater global warming impact than a similar amount of emissions of
CO2 or other mobile source GHGs.
---------------------------------------------------------------------------
\103\ The United States has submitted a proposal to the Montreal
Protocol which, if adopted, would phase-out production and
consumption of HFCs.
\104\ The U.S. EPA has reclamation requirements for refrigerants
in place under Title VI of the Clean Air Act.
\105\ The global warming potentials used in the NPRM analysis
are consistent with Intergovernmental Panel on Climate Change (IPCC)
Fourth Assessment Report. At this time, the global warming potential
values from the IPCC Second Assessment Report have been agreed upon
as the official U.S. framework for addressing climate change. The
global warming potential values from the IPCC Second Assessment
Report are used in the official U.S. greenhouse gas inventory
submission to the climate change framework. When inventories are
recalculated for the final rule, changes in global warming potential
may lead to adjustments.
---------------------------------------------------------------------------
Heavy-duty air conditioning systems today are similar to those used
in light-duty applications. However, differences may exist in terms of
cooling capacity (such that sleeper cabs have larger cabin volumes than
day cabs), system layout (such as the number of evaporators), and the
durability requirements due to longer truck life. However, the
component technologies and costs to reduce direct HFC emissions are
similar between the two types of vehicles.
The quantity of GHG refrigerant emissions from heavy-duty trucks
relative to the CO2 emissions from driving the vehicle and
moving freight is very small. Therefore, a credit approach is not
appropriate for this segment of vehicles because the value of the
credit is too small to provide sufficient incentive to utilize feasible
and cost-effective air conditioning leakage improvements. For the same
reason, including air conditioning leakage improvements within the main
standard would in many instances result in lost control opportunities.
Therefore, EPA is proposing that truck manufacturers be required to
meet a low leakage requirement for all air conditioning systems
installed in 2014 model year and later trucks, with one exception. The
agency is not proposing leakage standards for Class 2b-8 Vocational
Vehicles at this time due to the complexity in the build process and
the potential for different entities besides the chassis manufacturer
to be involved in the air conditioning system production and
installation, with consequent difficulties in developing a regulatory
system.
EPA is proposing a leakage standard which is a ``percent
refrigerant leakage
[[Page 74212]]
per year'' to assure that high-quality, low-leakage components are used
in each air conditioning system design. The agency believes that a
single ``gram of refrigerant leakage per year'' would not fairly
address the variety of air conditioning system designs and layouts
found in the heavy-duty truck sector. EPA is proposing a standard of
1.50 percent leakage per year for Heavy-duty Pickup Trucks and Vans and
Class 7 and 87 and 8 Tractors. The proposed standard was derived from
the vehicles with the largest system refrigerant capacity based on the
Minnesota GHG Reporting database.\106\ The average percent leakage per
year of the 2010 model year vehicles is 2.7 percent. This proposed
level of reduction is roughly comparable to that necessary to generate
credits under the light-duty vehicle program. See 75 FR 25426-25427.
Since refrigerant leakage past the compressor shaft seal is the
dominant source of leakage in belt-driven air conditioning systems, the
agency is seeking comment on whether the stringency of a single
``percent refrigerant leakage per year'' standard fairly addresses the
range of system refrigerant capacities likely to be used in heavy-duty
trucks.\107\ Since systems with less refrigerant may have a larger
percentage of their annual leakage from the compressor shaft seal than
systems with more refrigerant capacity, their relative percent
refrigerant leakage per year could be higher, and a more extensive
application of leakage reducing technologies could be needed to meet
the standard). EPA welcomes comments relative to the stringency of the
standard, and on whether manufacturers who adopt measures that improve
the global warming impact of leakage emissions substantially beyond
that achieved by the proposed standard should in some way be credited
for this improvement.
---------------------------------------------------------------------------
\106\ The Minnesota refrigerant leakage data can be found at
http://www.pca.state.mn.us/climatechange/mobileair.html#leakdata.
\107\ Society of Automotive Engineers Surface Vehicle Standard
J2727, issued August 2008, http://www.sae.org.
---------------------------------------------------------------------------
Manufacturers can choose to reduce A/C leakage emissions in two
ways. First, they can utilize leak-tight components. Second,
manufacturers can largely eliminate the global warming impact of
leakage emissions by adopting systems that use an alternative, low-GWP
refrigerant. EPA believes that reducing A/C system leakage is both
highly cost-effective and technologically feasible. The availability of
low leakage components is being driven by the air conditioning program
in the light-duty GHG rule which apply to 2012 model year and later
vehicles. The cooperative industry and government Improved Mobile Air
Conditioning program has demonstrated that new-vehicle leakage
emissions can be reduced by 50 percent by reducing the number and
improving the quality of the components, fittings, seals, and hoses of
the A/C system.\108\ All of these technologies are already in
commercial use and exist on some of today's systems, and EPA does not
anticipate any significant improvements in sealing technologies for
model years beyond 2014. However, EPA does anticipate that updates to
the SAE J2727 standard will be forthcoming (to address new materials
and components which perform better than those originally used in the
SAE analysis), and that it will be appropriate to include these updates
in the regulations concerning refrigerant leakage.
---------------------------------------------------------------------------
\108\ Team 1--Refrigerant Leakage Reduction: Final Report to
Sponsors, SAE, 2007.
---------------------------------------------------------------------------
Consistent with the 2012-2016 light-duty GHG rule, we are
estimating costs for leakage control at $18 (2008$) in direct
manufacturing costs. Including a low complexity indirect cost
multiplier (ICM) of 1.14 results in costs of $21 in the 2014 model
year. Time based learning is considered appropriate for A/C leakage
control, so costs in the 2017 model year would be $19. These costs are
applied to all heavy-duty pickups and vans, and to all combination
tractors. EPA views these costs as minimal and the reductions of potent
GHGs to be easily feasible and reasonable in the lead times provided by
the proposed rules.
EPA proposes that manufacturers demonstrate improvements in their
A/C system designs and components through a design-based method. The
proposed method for calculating A/C leakage is based closely on an
industry-consensus leakage scoring method, described below. This
leakage scoring method is correlated to experimentally-measured leakage
rates from a number of vehicles using the different available A/C
components. Under the proposed approach, manufacturers would choose
from a menu of A/C equipment and components used in their vehicles in
order to establish leakage scores, which would characterize their A/C
system leakage performance and calculate the percent leakage per year
as this score divided by the system refrigerant capacity.
Consistent with the light-duty GHG rule, EPA is proposing that a
manufacturer would compare the components of its A/C system with a set
of leakage-reduction technologies and actions that is based closely on
that being developed through the Improved Mobile Air Conditioning
program and SAE International (as SAE Surface Vehicle Standard J2727,
``HFC-134a, Mobile Air Conditioning System Refrigerant Emission
Chart,'' August 2008 version). See generally 75 FR 25426. The SAE J2727
approach was developed from laboratory testing of a variety of A/C
related components, and EPA believes that the J2727 leakage scoring
system generally represents a reasonable correlation with average real-
world leakage in new vehicles. Like the cooperative industry-government
program, our proposed approach would associate each component with a
specific leakage rate in grams per year that is identical to the values
in J2727 and then sum together the component leakage values to develop
the total A/C system leakage. However, in the heavy-duty truck program,
the total A/C leakage score would then be divided by the value of the
total refrigerant system capacity to develop a percent leakage per
year.
EPA believes that the design-based approach would result in
estimates of likely leakage emissions reductions that would be
comparable to those that would eventually result from performance-based
testing. At the same time, comments are encouraged on all developments
that may lead to a robust, practical, performance-based test for
measuring A/C refrigerant leakage emissions.
CO2 emissions are also associated with air conditioner
efficiency, since air conditioners create load on the engine. See 74 FR
49529. However, EPA is not proposing to set air conditioning efficiency
standards for vocational vehicles and combination tractors. The
CO2 emissions due to air conditioning systems in these
heavy-duty trucks are minimal compared to their overall emissions of
CO2. For example, EPA conducted modeling of a Class 8
sleeper cab using GEM to evaluate the impact of air conditioning and
found that it leads to approximately 1 gram of CO2/ton-
mile. Therefore, a projected 24% improvement of the air conditioning
system (the level projected in the light-duty GHG rulemaking), would
only reduce CO2 emissions by less than 0.3 g CO2/
ton-mile, or approximately 0.3 percent of the baseline Class 8 sleeper
cab CO2 emissions.
EPA is not specifying a specific in-use standard for leakage, as
neither test procedures nor facilities exist to measure refrigerant
leakage from a vehicle's air conditioning system. However, consistent
with the light-duty GHG rule, where we require that manufacturers
attest to the durability of
[[Page 74213]]
components and systems used to meet the CO2 standards (see
75 FR 25689), we will require that manufacturers of heavy-duty vehicles
attest to the durability of these systems, and provide an engineering
analysis which demonstrates component and system durability.
(6) Indirect Emissions From Air Conditioning
As just noted, in addition to direct emissions from refrigerant
leakage, air conditioning systems also create indirect exhaust
emissions due to the extra load on the vehicle's engine to provide
power to the air conditioning system. These indirect emissions are in
the form of the additional CO2 emitted from the engine when
A/C is being used due to the added loads. Unlike direct emissions which
tend to be a set annual leak rate not directly tied to usage, indirect
emissions are fully a function of A/C usage.
Due to the complexity of the heavy-duty market, it is difficult to
estimate with any degree of precision what the actual impact of
indirect emissions are across the vastly different applications and
duty cycles of heavy-duty trucks. Depending on application, geographic
location and even seasonal usage relationships, A/C systems usage will
vary differently across the heavy-duty fleet and therefore efficiency
improvements will also result in different indirect emission
reductions. Moreover, as just stated, indirect A/C emissions from
vocational vehicles and combination tractors are very small relative to
total GHG emissions from these vehicles. For these reasons, EPA is not
proposing an indirect emission standard like we have proposed for
direct emissions from heavy-duty vehicles.
Instead, EPA is seeking comment on the applicability of an indirect
emissions credit for A/C system efficiency improvements specifically in
the heavy-duty pickup trucks and vans (i.e., Class 2b and 3). These
vehicles are most closely related to their light-duty counterparts that
have an indirect emissions credit program established under the 2012-
2016 MY Light-duty Vehicle Rule. It is likely that the light-duty and
heavy-duty vehicles can share components used to improve the A/C system
efficiency and reduce indirect A/C emissions. EPA also seeks comment on
the level of the credit and if the fleet CO2 target
standards should be adjusted accordingly to reflect expected A/C
efficiency improvements similar to the approach used in the light-duty
rule.
(7) Ethanol-Fueled and Electric Vehicles
Current EPA emissions control regulations explicitly apply to
heavy-duty engines and vehicles fueled by gasoline, methanol, natural
gas and liquefied petroleum gas. For multi-fueled vehicles they call
for compliance with requirements established for each consumed fuel.
This contrasts with EPA's light-duty vehicle regulations that apply to
all vehicles generally, regardless of fuel type. We are proposing to
revise the heavy-duty vehicle and engine regulations to make them
consistent with the light-duty vehicle approach, applying standards for
all regulated criteria pollutants and GHGs regardless of fuel type,
including application to all-electric vehicles (EVs). This provision
would take effect in the 2014 model year, and be optional for
manufacturers in earlier model years. However, to satisfy the CAA
section 202(a)(3) lead time constraints, the provision would remain
optional for all criteria pollutants through the 2015 model year.
This change would primarily affect manufacturers of ethanol-fueled
vehicles (designed to operate on fuels containing at least 50 percent
ethanol) and EVs. Flex-fueled vehicles (FFVs) designed to run on both
gasoline and fuel blends with high ethanol content would also be
impacted, as they would need to comply with requirements for operation
both on gasoline and ethanol.
We are proposing that the specific regulatory requirements for
certification on ethanol follow those already established for methanol,
such as certification to NMHC equivalent standards and waiver of
certain requirements. We would expect testing to be done using the same
E85 test fuel as is used today for light-duty vehicle testing, an 85/15
blend of commercially-available ethanol and gasoline vehicle test fuel.
EV certification would also follow light-duty precedents, primarily
calling on manufacturers to exercise good engineering judgment in
applying the regulatory requirements, but would not be allowed to
generate NOX or PM credits.
This proposed provision is not expected to result in any
significant added burden or cost. It is already the practice of HD FFV
manufacturers to voluntarily conduct emissions testing for these
vehicles on E85 and submit the results as part of their certification
application, along with gasoline test fuel results. No changes in
certification fees are being proposed in connection with this proposed
provision. We expect that there would be strong incentives for any
manufacturers seeking to market these vehicles to also want them to be
certified: (1) Uncertified vehicles would carry a disincentive to
potential purchasers who typically have the benefit to the environment
as one of their reasons for considering alternative fuels, (2)
uncertified vehicles would not be eligible for the substantial credits
they could likely otherwise generate, (3) EVs have no tailpipe or
evaporative emissions and thus need no added hardware to put them in a
certifiable configuration, and (4) emissions controls for gasoline
vehicles and FFVs are also effective on dedicated ethanol-fueled
vehicles, and thus costly development programs and specialized
components would not be needed; in fact the highly integrated nature of
modern automotive products make the emission control systems essential
to reliable vehicle performance.
Regarding technological feasibility, as mentioned above, HD FFV
manufacturers already test on E85 and the resulting data shows that
they can meet emissions standards on this fuel. Furthermore, there is a
substantial body of certification data on light-duty FFVs (for which
testing on ethanol is already a requirement), showing existing emission
control technology is capable of meeting even the more stringent Tier 2
standards in place for light-duty vehicles. EPA requests comment on
this proposed application of its emission standards to HD vehicles and
engines, regardless of the fuels they operate on.
III. Feasibility Assessments and Conclusions
In this section, NHTSA and EPA discuss several aspects of our joint
technical analyses. These analyses are common to the development of
each agency's proposed standards. Specifically we discuss: the
development of the baseline used by each agency for assessing costs,
benefits, and other impacts of the standards, the technologies the
agencies evaluated and their costs and effectiveness, and the
development of the proposed standards based on application of
technology in light of the attribute based distinctions and related
compliance measurement procedures. We also discuss consideration of
standards that are either more or less stringent than those proposed.
This proposal is based on the need to obtain significant oil
savings and GHG emissions reductions from the transportation sector,
and the recognition that there are appropriate and cost-effective
technologies to achieve such reductions feasibly. The decision on what
standard to set is guided by each agency's statutory
[[Page 74214]]
requirements, and is largely based on the need for reductions, the
effectiveness of the emissions control technology, the cost and other
impacts of implementing the technology, and the lead time needed for
manufacturers to employ the control technology. The availability of
technology to achieve reductions and the cost and other aspects of this
technology are therefore a central focus of this proposed rulemaking.
Here, the focus of the standards is on applying fuel efficiency and
emissions control technology to reduce fuel consumption, CO2
and other greenhouse gases. Vehicles combust fuel to generate power
that is used to perform two basic functions: (1) Transport the truck
and its payload, and (2) operate various accessories during the
operation of the truck such as the PTO units. Engine-based technology
can reduce fuel consumption and CO2 emissions by improving
engine efficiency, which increases the amount of power produced per
unit of fuel consumed. Vehicle-based technology can reduce fuel
consumption and CO2 emissions by increasing the vehicle
efficiency, which reduces the amount of power demanded from the engine
to perform the truck's primary functions.
Our technical work has therefore focused on both engine efficiency
improvements and vehicle efficiency improvements. In addition to fuel
delivery, combustion, and aftertreatment technology, any aspect of the
truck that affects the need for the engine to produce power must also
be considered. For example, the drag due to aerodynamics and the
resistance of the tires to rolling both have major impacts on the
amount of power demanded of the engine while operating the vehicle.
The large number of possible technologies to consider and the
breadth of vehicle systems that are affected mean that consideration of
the manufacturer's design and production process plays a major role in
developing the proposed standards. Engine and vehicle manufacturers
typically develop many different models based on a limited number of
platforms. The platform typically consists of a common engine or truck
model architecture. For example, a common engine platform may contain
the same configuration (such as inline), number of cylinders,
valvetrain architecture (such as overhead valve), cylinder head design,
piston design, among other attributes. An engine platform may have
different calibrations, such as different power ratings, and different
aftertreatment control strategies, such as exhaust gas recirculation
(EGR) or selective catalytic reduction (SCR). On the other hand, a
common vehicle platform has different meanings depending on the market.
In the heavy-duty pickup truck market, each truck manufacturer usually
has only a single pickup truck platform (for example the F series by
Ford) with common chassis designs and shared body panels, but with
variations on load capacity of the axles, the cab configuration, tire
offerings, and powertrain options. Lastly, the combination tractor
market has several different platforms and the trucks within each
platform (such as LoneStar by Navistar) have less commonality. Tractor
manufacturers will offer several different options for bumpers,
mirrors, aerodynamic fairing, wheels, and tires, among others. However,
some areas such as the overall basic aerodynamic design (such as the
grill, hood, windshield, and doors) of the tractor are tied to tractor
platform.
The platform approach allows for efficient use of design and
manufacturing resources. Given the very large investment put into
designing and producing each truck model, manufacturers of heavy-duty
pickup trucks and vans typically plan on a major redesign for the
models every 5 years or more. Recently, EPA's non-GHG heavy-duty engine
program provided new emissions standards every three model years.
Heavy-duty engine and truck manufacturer product plans typically have
fallen into three year cycles to reflect this regime. While the recent
non-GHG emissions standards can be handled generally with redesigns of
engines and trucks, a complete redesign of a new heavy-duty engine or
truck typically occurs on a slower cycle and often does not align in
time due to the fact that the manufacturer of engines differs from the
truck manufacturer. At the redesign stage, the manufacturer will
upgrade or add all of the technology and make most other changes
supporting the manufacturer's plans for the next several years,
including plans related to emissions, fuel efficiency, and safety
regulations.
A redesign of either engine or truck platforms often involves a
package of changes designed to work together to meet the various
requirements and plans for the model for several model years after the
redesign. This often involves significant engineering, development,
manufacturing, and marketing resources to create a new product with
multiple new features. In order to leverage this significant upfront
investment, manufacturers plan vehicle redesigns with several model
years of production in mind. Vehicle models are not completely static
between redesigns as limited changes are often incorporated for each
model year. This interim process is called a refresh of the vehicle and
it generally does not allow for major technology changes although more
minor ones can be done (e.g., small aerodynamic improvements, etc).
More major technology upgrades that affect multiple systems of the
vehicle thus occur at the vehicle redesign stage and not in the time
period between redesigns.
As discussed below, there are a wide variety of CO2 and
fuel consumption reducing technologies involving several different
systems in the engine and vehicle that are available for consideration.
Many can involve major changes to the engine or vehicle, such as
changes to the engine block and cylinder heads or changes in vehicle
shape to improve aerodynamic efficiency. Incorporation of such
technologies during the periodic engine, transmission or vehicle
redesign process would allow manufacturers to develop appropriate
packages of technology upgrades that combine technologies in ways that
work together and fit with the overall goals of the redesign. By
synchronizing with their multi-year planning process, manufacturers can
avoid the large increase in resources and costs that would occur if
technology had to be added outside of the redesign process. We
considered redesign cycles both in our costing and in assessing the
lead time required.
As described below, the vast majority of technology required by
this proposal is commercially available and already being utilized to a
limited extent across the fleet. Therefore the majority of the emission
and fuel consumption reductions which would result from these proposed
rules would result from the increased use of these technologies. EPA
and NHTSA also believe that these proposed rules would encourage the
development and limited use of more advanced technologies, such as
advanced aerodynamics and hybrid powertrains in some vocational vehicle
applications.
In evaluating truck efficiency, NHTSA and EPA have excluded
fundamental changes in the engine or trucks' performance. Put another
way, none of the technology pathways underlying the proposed standards
involve any alteration in vehicle utility. For example, the agencies
did not consider approaches that would necessitate reductions in engine
power or otherwise limit truck performance. The agencies have thus
limited the assessment of technical feasibility and resultant
[[Page 74215]]
vehicle cost to technologies which maintain freight utility.
The agencies worked together to determine component costs for each
of the technologies and build up the costs accordingly. For costs, the
agencies considered both the direct or ``piece'' costs and indirect
costs of individual components of technologies. For the direct costs,
the agencies followed a bill of materials approach utilized by the
agencies in the light-duty fuel economy and GHG final rule. A bill of
materials, in a general sense, is a list of components or sub-systems
that make up a system--in this case, an item of technology which
reduces GHG emissions and fuel consumption. In order to determine what
a system costs, one of the first steps is to determine its components
and what they cost. NHTSA and EPA estimated these components and their
costs based on a number of sources for cost-related information. In
general, the direct costs of fuel consumption-improving technologies
for heavy-duty pickups and vans are consistent with those used in the
2012-2016 MY light-duty GHG rule, except that the agencies have scaled
up certain costs where appropriate to accommodate the larger size and/
or loads placed on parts and systems in the heavy-duty classes relative
to the light-duty classes. For loose heavy-duty engines, the agencies
have consulted various studies and have exercised engineering judgment
when estimating direct costs. For technologies expected to be added to
vocational vehicles and combination tractors, the agencies have again
consulted various studies and have used engineering judgment to arrive
at direct cost estimates. Once costs were determined, they were
adjusted to ensure that they were all expressed in 2008 dollars using a
ratio of gross domestic product deflators for the associated calendar
years.
Indirect costs were accounted for using the ICM approach explained
in Chapter 2 of the draft RIA, rather than using the traditional Retail
Price Equivalent (RPE) multiplier approach. For the heavy-duty pickup
truck and van cost projections in this proposal, the agencies have used
ICMs developed for light-duty vehicles (with the exception that here
return on capital has been incorporated into the ICMs, where it had not
been in the light-duty rule) primarily because the manufacturers
involved in this segment of the heavy-duty market are the same
manufacturers that build light-duty trucks. For the Class 7 and 8
tractor, vocational vehicle, and heavy-duty engine cost projections in
this proposal, EPA contracted with RTI International to update EPA's
methodology for accounting for indirect costs associated with changes
in direct manufacturing costs for heavy-duty engine and truck
manufacturers.\109\ In addition to the indirect cost multipliers
varying by complexity and time frame, there is no reason to expect that
the multipliers would be the same for engine manufacturers as for truck
manufacturers. The report from RTI provides a description of the
methodology, as well as calculations of new indirect cost multipliers.
The multipliers used here include a factor of 5 percent of direct costs
representing the return on capital for heavy-duty engines and truck
manufacturers. These indirect cost multipliers are intended to be used,
along with calculations of direct manufacturing costs, to provide
improved estimates of the full additional costs associated with new
technologies.
---------------------------------------------------------------------------
\109\ RTI International. Heavy-duty Truck Retail Price
Equivalent and Indirect Cost Multipliers. July 2010.
---------------------------------------------------------------------------
Details of the direct and indirect costs, and all applicable ICMs,
are presented in Chapter 2 of the draft RIA. In addition, for details
on the ICMs, please refer to the RTI report that has been placed in the
docket. The agencies request comment on all aspects of the cost
analysis, including the adjustment factors used in the RTI analysis--
the levels associated with R&D, warranty, etc.--and whether those are
appropriate or should be revised. If commenters suggest revisions, the
agencies request supporting arguments and/or documentation.
EPA and NHTSA believe that the emissions reductions called for by
the proposed standards are technologically feasible at reasonable costs
within the lead time provided by the proposed standards, reflecting our
projections of widespread use of commercially available technology.
Manufacturers may also find additional means to reduce emissions and
lower fuel consumption beyond the technical approaches we describe
here. We encourage such innovation through provisions in our
flexibility program as discussed in Section IV.
The agencies request comment on the methods and assumptions used to
estimate costs, benefits, and technology cost-effectiveness for the
main proposal and all of the alternatives. The agencies also seek
comment on whether finalizing a different alternative stringency level
for certain regulatory categories would be appropriate given agency
estimates of costs and benefits.
The remainder of this section describes the technical feasibility
and cost analysis in greater detail. Further detail on all of these
issues can be found in the joint draft RIA Chapter 2.
A. Class 7-8 Combination Tractor
Class 7 and 8 tractors are used in combination with trailers to
transport freight.\110\ The variation in the design of these tractors
and their typical uses drive different technology solutions for each
regulatory subcategory.
---------------------------------------------------------------------------
\110\ ``Tractor'' is defined in proposed section 1037.801 to
mean ``a vehicle capable of pulling trailers that is not intended to
carry significant cargo other than cargo in the trailer, or any
other vehicle intended for the primary purpose of pulling a
trailer.''
---------------------------------------------------------------------------
EPA and NHTSA collected information on the cost and effectiveness
of fuel consumption and CO2 emission reducing technologies
from several sources. The primary sources of information were the
recent National Academy of Sciences report of Technologies and
Approaches to Reducing the Fuel Consumption of Medium- and Heavy-Duty
Vehicles,\111\ TIAX's assessment of technologies to support the NAS
panel report,\112\ EPA's Heavy-duty Lumped Parameter Model,\113\ the
analysis conducted by the Northeast States Center for a Clean Air
Future, International Council on Clean Transport, Southwest Research
Institute and TIAX for reducing fuel consumption of heavy-duty long
haul combination tractors (the NESCCAF/ICCT study),\114\ and the
technology cost analysis conducted by ICF for EPA.\115\ Following on
the EISA of 2007, the National Research Council appointed a NAS
committee to assess technologies for improving fuel efficiency of
heavy-duty vehicles to support NHTSA's rulemaking. The 2010 NAS report
assessed current and future technologies for reducing fuel consumption,
how the technologies could be implemented, and
[[Page 74216]]
identified the potential cost of such technologies. The NAS panel
contracted TIAX to perform an assessment of technologies and their
associated capital costs which provide potential fuel consumption
reductions in heavy-duty trucks and engines. Similar to the Lumped
Parameter model which EPA developed to assess the impact and
interactions of GHG and fuel consumption reducing technologies for
light-duty vehicles, EPA developed a new version to specifically
address the effectiveness and interactions of the proposed pickup truck
and light heavy-duty engine technologies. The NESCAFF/ICCT study
assessed technologies available in the 2012 through 2017 to reduce
CO2 emissions and fuel consumption of line haul combination
tractors and trailers. Lastly, the ICF report focused on the capital,
maintenance, and operating costs of technologies currently available to
reduce CO2 emissions and fuel consumption in heavy-duty
engines, combination tractors, and vocational vehicles.
---------------------------------------------------------------------------
\111\ Committee to Assess Fuel Economy Technologies for Medium-
and Heavy-Duty Vehicles; National Research Council; Transportation
Research Board (2010). Technologies and Approaches to Reducing the
Fuel Consumption of Medium- and Heavy-Duty Vehicles. (``The NAS
Report'') Washington, DC, The National Academies Press. Available
electronically from the National Academy Press Web site at http://www.nap.edu/catalog.
\112\ TIAX, LLC. Assessment of Fuel Economy Technologies for
Medium- and Heavy-Duty Vehicles. November 2009.
\113\ U.S. EPA. Heavy-duty Lumped Parameter Model.
\114\ NESCCAF, ICCT, Southwest Research Institute, and TIAX.
Reducing Heavy-Duty Long Haul Combination Truck Fuel Consumption and
CO2 Emissions. October 2009.
\115\ ICF International. ``Investigation of Costs for Strategies
to Reduce Greenhouse Gas Emissions for Heavy-Duty On-Road
Vehicles.'' July 2010. Docket Number EPA-HQ-OAR-2010-0162-0044.
---------------------------------------------------------------------------
(1) What technologies did the agencies consider to reduce the
CO2 emissions and fuel consumption of tractors?
Manufacturers can reduce CO2 emissions and fuel
consumption of combination tractors through use of, among others,
engine, aerodynamic, tire, extended idle, and weight reduction
technologies. The standards are premised on use of these technologies.
The agencies note that SmartWay trucks are available today which
incorporate the technologies that the agencies are considering as the
basis for the standards in this proposal. We will also discuss other
technologies that could potentially be used, such as vehicle speed
limiters, although we are not basing the proposed standards on their
use for the model years covered by this proposal, for various reasons
discussed below.
In this section we discuss the baseline tractor and engine
technologies for the 2010 model year, and then discuss the kinds of
technologies that could be used to improve performance relative to this
baseline.
(a) Baseline Tractor & Tractor Technologies
Baseline tractor: The agencies developed the baseline tractor to
represent the average 2010 model year tractor. Today there is a large
spread in aerodynamics in the new tractor fleet. Trucks sold may
reflect classic styling, or may be sold with conventional or SmartWay
aerodynamic packages. Based on our review of current truck model
configurations and Polk data provided through MJ Bradley,\116\ we
believe the aerodynamic configuration of the baseline new truck fleet
is approximately 25 percent classic, 70 percent conventional, and 5
percent SmartWay (as these configurations are explained above in
Section II.B. (2)(c)). The baseline Class 7 and 8 day cab tractor
consists of an aerodynamic package which closely resembles the
``conventional'' package described in Section II.B. (2)(c), baseline
tire rolling resistance of 7.8 kg/metric ton for the steer tire and 8.2
kg/metric ton,\117\ dual tires with steel wheels on the drive axles,
and no vehicle speed limiter. The baseline tractor for the Class 8
sleeper cabs contains the same aerodynamic and tire rolling resistance
technologies as the baseline day cab, does not include vehicle speed
limiters, and does not include an idle reduction technology. The
agencies assume the baseline transmission is a 10 speed manual.
---------------------------------------------------------------------------
\116\ MJ Bradley. Heavy-duty Market Analysis. May 2009. Page 10.
\117\ US Environmental Protection Agency. SmartWay Transport
Partnership July 2010 e-update accessed July 16, 2010, from http://www.epa.gov/smartwaylogistics/newsroom/documents/e-update-july-10.pdf.
---------------------------------------------------------------------------
Performance from this baseline can be improved by the use of the
following technologies:
Aerodynamic technologies: There are opportunities to reduce
aerodynamic drag from the tractor, but it is difficult to assess the
benefit of individual aerodynamic features. Therefore, reducing
aerodynamic drag requires optimizing of the entire system. The
potential areas to reduce drag include all sides of the truck--front,
sides, top, rear and bottom. The grill, bumper, and hood can be
designed to minimize the pressure created by the front of the truck.
Technologies such as aerodynamic mirrors and fuel tank fairings can
reduce the surface area perpendicular to the wind and provide a smooth
surface to minimize disruptions of the air flow. Roof fairings provide
a transition to move the air smoothly over the tractor and trailer.
Side extenders can minimize the air entrapped in the gap between the
tractor and trailer. Lastly, underbelly treatments can manage the flow
of air underneath the tractor. As discussed in the TIAX report, the
coefficient of drag (Cd) of a SmartWay sleeper cab high roof tractor is
approximately 0.60, which is a significant improvement over a truck
with no aerodynamic features which has a Cd value of approximately
0.80.\118\ The GEM demonstrates that an aerodynamic improvement of a
Class 8 high roof sleeper cab with a Cd value from 0.60 (which
represents a SmartWay tractor) provides a 5% reduction in fuel
consumption and CO2 emissions over a truck with a Cd of
0.68.
---------------------------------------------------------------------------
\118\ TIAX. ``Assessment of Fuel Economy Technologies for
Medium- and Heavy-Duty Vehicles'', TIAX LLC, November 19, 2009. Page
4-50.
---------------------------------------------------------------------------
Lower Rolling Resistance Tires: A tire's rolling resistance results
from the tread compound material, the architecture and materials of the
casing, tread design, the tire manufacturing process, and its operating
conditions (surface, inflation pressure, speed, temperature, etc.).
Differences in rolling resistance of up to 50% have been identified for
tires designed to equip the same vehicle. The baseline rolling
resistance coefficient for today's fleet is 7.8 kg/metric ton for the
steer tire and 8.2 kg/metric ton for the drive tire, based on sales
weighting of the top three manufacturers based on market share.\119\
Since 2007, SmartWay trucks have had steer tires with rolling
resistance coefficients of less than 6.6 kg/metric ton for the steer
tire and less than 7.0 kg/metric ton for the drive tire.\120\ Low
rolling resistance (LRR) drive tires are currently offered in both dual
assembly and single wide-base configurations. Single wide tires can
offer both the rolling resistance reduction along with improved
aerodynamics and weight reduction. The GEM demonstrates that replacing
baseline tractor tires with tires which meet the SmartWay level
provides a 4% reduction in fuel consumption and CO2
emissions over the prescribed test cycle.
---------------------------------------------------------------------------
\119\ See SmartWay, Note 117, above.
\120\ Ibid.
---------------------------------------------------------------------------
Weight Reduction: Reductions in vehicle mass reduce fuel
consumption and GHGs by reducing the overall vehicle mass to be
accelerated and also through increased vehicle payloads which can allow
additional tons to be carried by fewer trucks consuming less fuel and
producing lower emissions on a ton-mile basis. Initially, the agencies
considered evaluating vehicle mass reductions on a total vehicle basis
for tractors and vocational trucks.\121\ The agencies considered
defining a baseline vehicle curb weight and the GEM model would have
used the vehicle's actual curb weight to calculate the increase or
decrease in fuel consumption related to the overall vehicle mass
relative to that baseline. After considerable evaluation
[[Page 74217]]
of this issue, including discussions with the industry, we decided it
would not be possible to define a single vehicle baseline mass for the
tractors and for vocational trucks that would be appropriate and
representative. Actual vehicle curb weights for these classes of
vehicles vary by thousands of pounds dependent on customer features
added to vehicles and critical to the function of the vehicle in the
particular vocation in which it is used. This is true of vehicles such
as Class 8 tractors considered in this section that may appear to be
relatively homogenous but which in fact are quite heterogeneous.
---------------------------------------------------------------------------
\121\ The agencies are using the approach of evaluating total
vehicle mass for heavy-duty pickups and vans. where we have more
data on the current fleet vehicle mass.
---------------------------------------------------------------------------
This reality led us to the solution we are proposing. We reflect
mass reductions for specific technology substitutions (e.g., installing
aluminum wheels instead of steel wheels) where we can with confidence
verify the mass reduction information provided by the manufacturer even
though we cannot estimate the actual curb weight of the vehicle. In
this way, we are accounting for mass reductions where we can accurately
account for its benefits. In the future, if we are able to develop an
appropriate vehicle mass baseline for the diversity of vehicles within
a segment and therefore could reasonable project overall mass
reductions that would not inadvertently reduce customer utility, we
would consider setting standards that take into account overall vehicle
mass reductions. The agencies' baseline tire and wheel package consists
of dual tires with steel wheels. A tractor's empty curb weight can be
reduced from the replacement of dual tires with single wide tires and
with the replacement of steel wheels with high strength steel or
aluminum. Analysis of literature indicates that there is opportunity to
reduce typical tractor curb weights by 80 to 670 pounds, or up to
roughly 3 percent, through the use of lighter weight wheels and single
wide tires, as described in draft RIA Chapter 2. High strength steel,
aluminum, and light weight aluminum alloys provide opportunities to
reduce the truck's mass relative to steel wheels. In addition, single
wide tires (a single wide-based tire which replaces two standard tires
in each wheel position) provide the opportunity to reduce the overall
mass of wheels and tires due to the replacement of dual tires with
singles. On average, these technologies together can reduce weight by
over 400 pounds. A weight reduction of this magnitude applied to a
truck which travels at 70,000 pounds will have a minimal impact on fuel
consumption. However, for trucks which operate at the maximum GVWR
which occurs approximately for one third of truck miles travelled, a
reduced tare weight will allow for additional payload to be carried.
The GEM demonstrates that a weight reduction of 400 pounds applied to
the payload tons for one third of the trips provides a 0.3 percent
reduction in fuel consumption and CO2 emissions over the
prescribed test cycle.
Extended Idle Reduction: Auxiliary power units (APU)s, fuel
operated heaters, battery supplied air conditioning, and thermal
storage systems are among the technologies available today to reduce
main engine extended idling from sleeper cabs. Each of these
technologies reduces the baseline fuel consumption during idling from a
truck without this equipment (the baseline) from approximately 0.8
gallons per hour (main engine idling fuel consumption rate) to
approximately 0.2 gallons per hour for an APU.\122\ EPA and NHTSA agree
with the TIAX assessment of a 6 percent reduction in overall fuel
consumption reduction.\123\
---------------------------------------------------------------------------
\122\ See the draft RIA Chapter 2 for details.
\123\ See the 2010 NAS Report, Note 111, above, at 128.
---------------------------------------------------------------------------
Vehicle Speed Limiters: Fuel consumption and GHG emissions increase
proportional to the square of vehicle speed. Therefore, lowering
vehicle speeds can significantly reduce fuel consumption and GHG
emissions. A vehicle speed limiter, which limits the vehicle's maximum
speed, is a simple technology that is utilized today by some fleets
(though the typical maximum speed setting is often higher than 65 mph).
The GEM shows that using a vehicle speed limiter set at 62 mph will
provide a 4 percent reduction in fuel consumption and CO2
emissions over the prescribed test cycles over a baseline vehicle
without a VSL or one set above 65 mph.
Transmission: As discussed in the 2010 NAS report, automatic and
automated manual transmissions may offer the ability to improve vehicle
fuel consumption by optimizing gear selection compared to an average
driver. However, as also noted in the report and in the supporting TIAX
report, the improvement is very dependent on the driver of the truck,
such that reductions ranged from 0 to 8 percent.\124\ Well-trained
drivers would be expected to perform as well or even better than an
automatic transmission since the driver can see the road ahead and
anticipate a changing stoplight or other road condition that an
automatic transmission can not anticipate. However, poorly-trained
drivers that shift too frequently or not frequently enough to maintain
optimum engine operating conditions could be expected to realize
improved in-use fuel consumption by switching from a manual
transmission to an automatic or automated manual transmission. While we
believe there may be real benefits in reduced fuel consumption and GHG
emissions through the application of automatic or automated manual
transmission technology, we are not proposing to reflect that potential
improvement in our standard setting nor in our compliance model. We
have taken this approach because we cannot say with confidence what
level of performance improvement to expect. However, we welcome
comments on this decision supported where possible with data. If a
clear measure of performance improvement can be defined for the use of
automatic or automated manual transmission technologies, we will
consider reflecting the technology in setting the stringency of the
standards and in determining compliance with the standards.
---------------------------------------------------------------------------
\124\ See TIAX, Note 112, above at 4-70.
---------------------------------------------------------------------------
Low Friction Transmission, Axle, and Wheel Bearing Lubricants: The
2010 NAS report assessed low friction lubricants for the drivetrain as
a 1 percent improvement in fuel consumption based on fleet
testing.\125\ The light-duty fuel economy and GHG final rule and the
pickup truck portion of this program estimate that low friction
lubricants can have an effectiveness value between 0 and 1 percent
compared to traditional lubricants. However, it is not clear if in many
heavy-duty applications these low friction lubricants could have
competing requirements like component durability issues requiring
specific lubricants with different properties than low friction. The
agencies are interested in comments on whether low friction lubricants
should be included in the technologies modeled in GEM to obtain
certification values for fuel consumption and CO2 emissions
and how manufacturers could ensure the use of these lubricants for the
full useful life of the truck.
---------------------------------------------------------------------------
\125\ See the 2010 NAS Report, Note 111, page 67.
---------------------------------------------------------------------------
Hybrid: Hybrid powertrain development in Class 7 and 8 tractors has
been limited to a few manufacturer demonstration vehicles to date. One
of the key benefit opportunities for fuel consumption reduction with
hybrids is less fuel consumption when a vehicle is idling, which are
already included as a separate technology in the agencies' technology
assessment. NAS estimated that hybrid systems would cost approximately
$25,000 per truck in the 2015 through 2020 timeframe and
[[Page 74218]]
provide a potential fuel consumption reduction of 10 percent, of which
6 percent is idle reduction which can be achieved through other idle
reduction technologies.\126\ The limited reduction potential outside of
idle reduction for Class 8 sleeper cab tractors is due to the mostly
highway operation and limited start-stop operation. Due to the high
cost and limited benefit during the model years at issue in this
proposal, the agencies are not including hybrids in assessing standard
stringency (or as an input to GEM). However as discussed in Section IV,
the agencies are providing incentives to encourage the introduction of
advanced technologies including hybrid powertrains in appropriate
applications.
---------------------------------------------------------------------------
\126\ See the 2010 NAS Report, Note 111, page 128.
---------------------------------------------------------------------------
Management: The 2010 NAS report noted many operational
opportunities to reduce fuel consumption, such as driver training and
route optimization. The agencies have included discussion of several of
these strategies in draft RIA Chapter 2, but are not using these
approaches or technologies in the standard setting process. The
agencies are looking to other resources, such as EPA's SmartWay
Transport Partnership and regulations that could potentially be
promulgated by the Federal Highway Administration and the Federal Motor
Carrier Safety Administration, to continue to encourage the development
and utilization of these approaches.
(b) Baseline Engine & Engine Technologies
The baseline engine for the Class 8 tractors is a Heavy Heavy-Duty
Diesel engine with 15 liters of displacement which produces 455
horsepower. The agencies are using a smaller baseline engine for the
Class 7 tractors because of the lower combined weights of this class of
vehicles require less power, thus the baseline is an 11L engine with
350 horsepower. The agencies developed the baseline diesel engine as a
2010 model year engine with an aftertreatment system which meets EPA's
0.2 grams of NOX/bhp-hr standard with an SCR system along with EGR and
meets the PM emissions standard with a diesel particulate filter with
active regeneration. The baseline engine is turbocharged with a
variable geometry turbocharger. The following discussion of
technologies describes improvements over the 2010 model year baseline
engine performance, unless otherwise noted. Further discussion of the
baseline engine and its performance can be found in Section III.A.2.6
below.
Engine performance for CO2 emissions and fuel consumption can be
improved by use of the following technologies:
Turbochargers: Improved efficiency of a turbocharger compressor or
turbine could reduce fuel consumption by approximately 1 to 2 percent
over variable geometry turbochargers in the market today.\127\ The 2010
NAS report identified technologies such as higher pressure ratio radial
compressors, axial compressors, and dual stage turbochargers as design
paths to improve turbocharger efficiency.
---------------------------------------------------------------------------
\127\ TIAX Assessment of Fuel Economy Technologies for Medium
and Heavy-duty Vehicles, Report to National Academy of Sciences, Nov
19, 2009, Page 4-2.
---------------------------------------------------------------------------
Low Temperature Exhaust Gas Recirculation: Most medium- and heavy-
duty vehicle diesel engines sold in the U.S. market today use cooled
EGR, in which part of the exhaust gas is routed through a cooler
(rejecting energy to the engine coolant) before being returned to the
engine intake manifold. EGR is a technology employed to reduce peak
combustion temperatures and thus NOX. Low-temperature EGR uses a larger
or secondary EGR cooler to achieve lower intake charge temperatures,
which tend to further reduce NOX formation. If the NOX requirement is
unchanged, low-temperature EGR can allow changes such as more advanced
injection timing that will increase engine efficiency slightly more
than 1 percent.\128\ Because low-temperature EGR reduces the engine's
exhaust temperature, it may not be compatible with exhaust energy
recovery systems such as turbocompounding or a bottoming cycle.
---------------------------------------------------------------------------
\128\ TIAX Assessment of Fuel Economy Technologies for Medium
and Heavy-duty Vehicles, Report to National Academy of Sciences, Nov
19, 2009, Page 4-13.
---------------------------------------------------------------------------
Engine Friction Reduction: Reduced friction in bearings, valve
trains, and the piston-to-liner interface will improve efficiency. Any
friction reduction must be carefully developed to avoid issues with
durability or performance capability. Estimates of fuel consumption
improvements due to reduced friction range from 0.5 to 1.5
percent.\129\
---------------------------------------------------------------------------
\129\ TIAX, Assessment of Fuel Economy Technologies for Medium-
and Heavy-duty Vehicles, Final Report, Nov. 19, 2009, pg 4-15.
---------------------------------------------------------------------------
Selective catalytic reduction: This technology is common on 2010
the medium- and heavy-duty diesel engines used in Class 7 and 8
tractors (and the agencies therefore are considering it as part of the
baseline engine, as noted above). Because SCR is a highly effective
NOX aftertreatment approach, it enables engines to be
optimized to maximize fuel efficiency, rather than minimize engine-out
NOX. 2010 SCR systems are estimated to result in improved
engine efficiency of approximately 3 to 5 percent compared to a 2007
in-cylinder EGR-based emissions system and by an even greater
percentage compared to 2010 in-cylinder approaches.\130\ As more
effective low-temperature catalysts are developed, the NOX conversion
efficiency of the SCR system will increase. Next-generation SCR systems
could then enable additional efficiency improvements; alternatively,
these advances could be used to maintain efficiency while down-sizing
the aftertreatment. We estimate that continued optimization of the
catalyst could offer 1 to 2 percent reduction in fuel use over 2010
model year systems in the 2014 model year.\131\ The agencies estimate
an additional 1 to 2 percent reduction may be feasible in the 2017
model year through additional refinement.
---------------------------------------------------------------------------
\130\ Stanton, D. ``Advanced Diesel Engine Technology
Development for High Efficiency, Clean Combustion.'' Cummins, Inc.
Annual Progress Report 2008 Vehicle Technologies Program: Advanced
Combustion Engine Technologies, US Department of Energy. Pp 113-116.
December 2008.
\131\ TIAX Assessment of Fuel Economy Technologies for Medium
and Heavy-duty Vehicles, Report to National Academy of Sciences, Nov
19, 2009, pg. 4-9.
---------------------------------------------------------------------------
Improved Combustion Process: Fuel consumption reductions in the
range of 1 to 3 percent over the baseline diesel engine are identified
in the 2010 NAS report through improved combustion chamber design,
higher fuel injection pressure, improved injection shaping and timing,
and higher peak cylinder pressures.\132\
---------------------------------------------------------------------------
\132\ TIAX. Assessment of Fuel Economy Technologies for Medium-
and Heavy-Duty Vehicles. November 2009. Page 4-13.
---------------------------------------------------------------------------
Reduced Parasitic Loads: Accessories that are traditionally gear or
belt driven by a vehicle's engine can be optimized and/or converted to
electric power. Examples include the engine water pump, oil pump, fuel
injection pump, air compressor, power-steering pump, cooling fans, and
the vehicle's air-conditioning system. Optimization and improved
pressure regulation may significantly reduce the parasitic load of the
water, air and fuel pumps. Electrification may result in a reduction in
power demand, because electrically powered accessories (such as the air
compressor or power steering) operate only when needed if they are
electrically powered, but they impose a parasitic demand all the time
if they are engine driven. In other cases, such as cooling fans or an
engine's water pump, electric power allows the accessory to run at
speeds independent of engine
[[Page 74219]]
speed, which can reduce power consumption. The TIAX study used 2 to 4
percent fuel consumption improvement for accessory electrification,
with the understanding that electrification of accessories will have
more effect in short-haul/urban applications and less benefit in line-
haul applications.\133\
---------------------------------------------------------------------------
\133\ TIAX. November 2009. Page 3-5.
---------------------------------------------------------------------------
Mechanical Turbocompounding: Mechanical turbocompounding adds a low
pressure power turbine to the exhaust stream in order to extract
additional energy, which is then delivered to the crankshaft. Published
information on the fuel consumption reduction from mechanical
turbocompounding varies between 2.5 and 5 percent.\134\ Some of these
differences may depend on the operating condition or duty cycle that
was considered by the different researchers. The performance of a
turbocompounding system tends to be highest at full load and much less
or even zero at light load.
---------------------------------------------------------------------------
\134\ NESCCAF/ICCT study (p. 54) and TIAX (2009, pp. 3-5).
---------------------------------------------------------------------------
Electric Turbocompounding: This approach is similar in concept to
mechanical turbocompounding, except that the power turbine drives an
electrical generator. The electricity produced can be used to power an
electrical motor supplementing the engine output, to power electrified
accessories, or to charge a hybrid system battery. None of these
systems have been demonstrated commercially, but modeled results by
industry and DOE have shown improvements of 3 to 5 percent.\135\
---------------------------------------------------------------------------
\135\ K. G. Duleep of Energy and Environmental Analysis, R.
Kruiswyk, 2008, pp. 212-214, NESCCAF/ICCT, 2009, p. 54.
---------------------------------------------------------------------------
Bottoming Cycle: An engine with bottoming cycle uses exhaust or
other heat energy from the engine to create power without the use of
additional fuel. The sources of energy include the exhaust, EGR, charge
air, and coolant. The estimates for fuel consumption reduction range up
to 10 percent as documented in the 2010 NAS report.\136\ However, none
of the bottoming cycle or Rankine engine systems has been demonstrated
commercially and are currently in only the research stage.
---------------------------------------------------------------------------
\136\ See 2010 NAS Report, Note 111, page 57.
---------------------------------------------------------------------------
(2) Projected Technology Package Effectiveness and Cost
(a) Class 7 and 8 Combination Tractors
EPA and NHTSA project that CO2 emissions and fuel
consumption reductions can be feasibly and cost-effectively achieved in
these rules' timeframes through the increased application of
aerodynamic technologies, LRR tires, weight reduction, extended idle
reduction technologies, vehicle speed limiters, and engine
improvements. As discussed above, the agencies believe that hybrid
powertrains in tractors will not be cost-effective in the time frame of
the rules. The agencies also are not proposing to include drivetrain
technologies in the standard setting process, as discussed in Section
II.
The agencies evaluated each technology and estimated the most
appropriate application rate of technology into each tractor
subcategory. The next sections describe the effectiveness of the
individual technologies, the costs of the technologies, the projected
application rates of the technologies into the regulatory
subcategories, and finally the derivation of the proposed standards.
(i) Baseline Tractor Performance
The agencies developed the baseline tractor for each subcategory to
represent an average 2010 model year tractor configured as noted
earlier. The approach taken by the agencies was to define the
individual inputs to GEM. For example, the agencies evaluated the
industry's tractor offerings and concluded that the average tractor
contains a generally aerodynamic shape (such as roof fairings) and
avoids classic features such as exhaust stacks at the B-pillar, which
increase drag. The agencies consider a baseline truck as having
``conventional'' aerodynamic package, though today there is a large
spread in aerodynamics in the new tractor fleet. As noted earlier, our
assessment of the baseline new truck fleet aerodynamics represents
approximately 25 percent classic, 70 percent conventional, and 5
percent SmartWay. This mix of vehicle aerodynamics provides a Cd
performance level slightly greater than the ``conventional aerodynamic
package'' Cd value (for example the baseline high roof tractor has a Cd
of 0.69 while the same tractor category with a conventional aerodynamic
package has a Cd of 0.68). The baseline rolling resistance coefficient
for today's fleet is 7.8 kg/metric ton for the steer tire and 8.2 kg/
metric ton for the drive tire, based on sales weighting of the top
three manufacturers based on market share.\137\ The agencies use the
inputs described in GEM to derive the baseline CO2 emissions
and fuel consumption of Class 7 and 8 tractors. The results are
included in Table III-2.
---------------------------------------------------------------------------
\137\ U.S. Environmental Protection Agency. SmartWay Transport
Partnership July 2010 e-update accessed July 16, 2010, from http://www.epa.gov/smartwaylogistics/newsroom/documents/e-update-july-10.pdf.
---------------------------------------------------------------------------
[[Page 74220]]
[GRAPHIC] [TIFF OMITTED] TP30NO10.027
[GRAPHIC] [TIFF OMITTED] TP30NO10.028
(ii) Tractor Technology Package Effectiveness
The agencies' assessment of the proposed technology effectiveness
was developed through the use of the GEM in coordination with chassis
testing of three SmartWay certified Class 8 sleeper cabs. The agencies
developed technology performance characteristics for each subcategory,
described below. Each technology consists of an input parameter which
is in turn modeled in GEM. Table III-3 describes our proposed model
inputs for the range of Class 7 and 8 tractor aerodynamic packages and
vehicle technologies. This was combined with a projected technology
application rate to determine the stringency of the proposed standard.
The aerodynamic packages are categorized as Classic, Conventional,
SmartWay, Advanced SmartWay, and Advanced SmartWay II. The Classic
aerodynamic package refers to traditional styling such as a flat front,
exposed air cleaners and exhaust stacks, among others. The conventional
package refers to an overall aerodynamic appearance and best represents
the aerodynamics of the majority of new tractor sales. The SmartWay
aerodynamic package includes technologies such as roof fairings,
aerodynamic hoods, aerodynamic mirrors, chassis fairings, and cab
extenders. The Advanced SmartWay and Advanced SmartWay II packages
reflect different degrees of new aerodynamic technology development
such as active air management. A more complete description of these
aerodynamic packages is included in Chapter 2 of the draft RIA. In
general, the coefficient of drag values for each package and tractor
subcategory were developed from EPA's coastdown testing of tractor-
trailer combinations, the 2010 NAS report, and SAE papers.
The rolling resistance coefficient for the tires was developed from
SmartWay's tire testing to develop the SmartWay certification. The
benefits for the extended idle reductions were developed from
literature, SmartWay work, and the 2010 NAS report. The weight
reductions were developed from manufacturer information.
[[Page 74221]]
[GRAPHIC] [TIFF OMITTED] TP30NO10.029
(iii) Tractor Technology Application Rates
As explained above, vehicle manufacturers often introduce major
product changes together, as a package. In this manner the
manufacturers can optimize their available resources, including
engineering, development, manufacturing and marketing activities to
create a product with multiple new features. In addition, manufacturers
recognize that a truck design will need to remain competitive over the
intended life of the design and meet future regulatory requirements. In
some limited cases, manufacturers may implement an individual
technology outside of a vehicle's redesign cycle.
---------------------------------------------------------------------------
\138\ Vehicle speed limiters are an applicable technology or all
Class 7 and 8 tractors, however the standards are not premised on
the use of this technology.
---------------------------------------------------------------------------
With respect to the levels of technology application used to
develop the proposed standards, NHTSA and EPA established technology
application constraints. The first type of constraint was established
based on the application of fuel consumption and CO2
emission reduction technologies into the different types of tractors.
For example, idle reduction technologies are limited to Class 8 sleeper
cabs using the assumption that day cabs are not used for overnight
hoteling. A second type of constraint was applied to most other
technologies and limited their application based on factors reflecting
the real world operating conditions that some combination tractors
encounter. This second type of constraint was applied to the
aerodynamic, tire, and vehicle speed limiter technologies. Table III-4
specifies the application rates that EPA and NHTSA used to develop the
proposed standards.
The impact of aerodynamics on a truck's efficiency increases with
vehicle speed. Therefore, the usage pattern of the truck will determine
the benefit of various aerodynamic technologies. Sleeper cabs are often
used in line haul applications and drive the majority of their miles on
the highway travelling at speeds greater than 55 mph. The industry has
focused aerodynamic technology development, including SmartWay
tractors, on these types of trucks. Therefore the agencies are
proposing the most aggressive aerodynamic technology application to
this regulatory subcategory. All of the major manufacturers today offer
at least one SmartWay truck model. The 2010 NAS Report on heavy-duty
trucks found that manufacturers indicated that aerodynamic improvements
which yield 3 to 4 percent fuel consumption reduction or 6 to 8 percent
reduction in Cd values, beyond technologies used in today's SmartWay
trucks are achievable.\139\ EPA and NHTSA are proposing that the
aerodynamic application rate for Class 8 sleeper cab high roof cabs
(i.e., the degree of technology application on which the stringency of
the proposed standard is premised) to consist of 20 percent of Advanced
SmartWay, 70 percent SmartWay, and 10 percent conventional reflecting
our assessment of the fraction of tractors in this segment that can
[[Page 74222]]
successfully apply these aerodynamic packages. The small percentage of
conventional truck aerodynamics reflects applications including
tractors serving as refuse haulers which spend a portion of their time
off-road at the landfill and generally operate at lower speeds with
frequent stops--further reducing the benefit of aggressive aerodynamic
technologies. Features such as chassis skirts are prone to damage in
off-road applications; therefore we are not proposing standards that
are based on all trucks having chassis skirts or achieving GHG
reductions premised on use of such technology. The 90 percent of
tractors that we project can either be SmartWay or Advanced SmartWay
equipped reflects the bulk of Class 8 high roof sleeper cab
applications. We are not projecting a higher fraction of Advanced
SmartWay aerodynamic systems because of the limited lead time for the
program and the need for these more advanced technologies to be
developed and demonstrated before being applied across a wider fraction
of the fleet. Our averaging, banking and trading provisions provide
manufacturers with the flexibility to implement these technologies over
time even though the standard changes in a single step. We request
comment on our assessment of the potential for use of Advanced SmartWay
technologies and the need for a fraction of these vehicles to continue
to remain configured as conventional cabs due to their occasional use
off-road.
---------------------------------------------------------------------------
\139\ TIAX. Assessment of Fuel Economy Technologies for Medium-
and Heavy-Duty Vehicles. November 2009. Page 4-40.
---------------------------------------------------------------------------
The proposed aerodynamic application for the other tractor
regulatory categories is less aggressive than for the Class 8 sleeper
cab high roof. The agencies recognize that there are truck applications
which require on/off-road capability and other truck functions which
restrict the type of aerodynamic equipment applicable. We also
recognize that these types of trucks spend less time at highway speeds
where aerodynamic technologies have the greatest benefit. The 2002 VIUS
data ranks trucks by major use.\140\ The heavy trucks usage indicates
that up to 35 percent of the trucks may be used in on/off-road
applications or heavier applications. The uses include construction (16
percent), agriculture (12 percent), waste management (5 percent), and
mining (2 percent). Therefore, the agencies analyzed the technologies
to evaluate the potential restrictions that would prevent 100 percent
application of SmartWay technologies for all of the tractor regulatory
subcategories.
---------------------------------------------------------------------------
\140\ U.S. Department of Energy. Transportation Energy Data
Book, Edition 28-2009. Table 5.7.
---------------------------------------------------------------------------
Trucks designed for on/off-road application may be restricted in
the ability to improve the aerodynamic design of the bumper, chassis
skirts, air cleaners, and other aspects of the truck which would
typically be needed to move a conventional truck into the SmartWay bin.
First, off-road applications may require the use of steel bumpers which
tend to be less aerodynamic than plastic designs. Second, ground
clearance may be an issue for some off road applications due to poor
road surface quality. This may pose a greater likelihood that those
items such as chassis skirts would incur damage in use and therefore
would not be a technology desirable in these applications. Third, the
trucks used in off-road applications may also experience dust which
requires an additional air cleaner to manage the dirt. Fourth, some
trucks are used in applications which require heavier load capacity,
such as those with gross combined weights of greater than 80,000
pounds, which is today's Federal highway limit. Often these trucks are
configured with different axle combinations than those traditionally
used on-road. These trucks may contain either a lift axle or spread
axle which allows for greater carrying capability. Both of these
configurations limit the design and effectiveness of chassis skirts.
Lastly, some work trucks require the use of PTO operation or access to
equipment which may limit the application of side extenders and chassis
skirts.
The agencies considered the on/off-road restriction to aerodynamic
technology application, used VIUS estimate of approximately 35 percent
of tractors may be used in this type of application, and used
confidential data provided by truck manufacturers regarding the
fraction of their current sales which go into the various applications,
to project the aerodynamic application rates for each tractor category.
For example, the agencies project that day cabs with low roofs will be
used more often in these on/off-road applications than day cabs with
high roof. Therefore, the agencies project technology application rate
for conventional aerodynamics in day cab low roof as 40 percent while
it would be 30 percent in day cab high roofs tractors. The agencies
have also estimated that the development of advanced aerodynamic
technologies would be applied first to high roof sleeper cabs and then
follow with the other tractor categories. Therefore, the agencies
propose to use a 10 percent application rate of the Advanced SmartWay
aerodynamic technology package to the other tractor categories. The
agencies welcome comment on our assessment of application rates and are
interested in data that provide estimates on truck sales to the various
applications where aerodynamics are less effective or restricted.
At least one LRR tire model is available today that meets the
rolling resistance requirements of the SmartWay and Advanced SmartWay
tire packages so the 2014 MY should afford manufacturers sufficient
lead time to install these packages. However, tire rolling resistance
is only one of several performance criteria that affect tire selection.
The characteristics of a tire also influence durability, traction
control, vehicle handling, comfort, and retreadability. A single
performance parameter can easily be enhanced, but an optimal balance of
all the criteria will require improvements in materials and tread
design at a higher cost, as estimated by the agencies. Tire design
requires balancing performance, since changes in design may change
different performance characteristics in opposing directions. Similar
to the discussion regarding lesser aerodynamic technology application
in tractor segments other than sleeper cab high roof, the agencies
believe that the proposed standards should not be premised on 100
percent application of LRR tires in all tractor segments. The agencies
are proposing to base their analyses on application rates that vary by
category and match the application rates used for the aerodynamic
packages to reflect the on/off-road application of some tractors which
require a different balancing of traction versus rolling resistance. We
believe on- versus off-road traction (primarily tread pattern) is the
only tire performance parameter which trades off with tire rolling
resistance so significantly that tire manufacturers would be unable to
develop tires meeting both the assumed lower rolling resistance
performance while maintaining or improving other characteristics of
tire performance. We seek comment on our assessment.
Weight reductions can be achieved through single wide tires
replacing dual tires and lighter weight wheel material. Single wide
tires can reduce weight by over 160 pounds per axle. Aluminum wheels
used in lieu of steel wheels will reduce weight by over 80 pounds for a
dual wheel axle. Light weight aluminum steer wheels and aluminum single
wide drive wheels and tires package available today would provide a 670
pound weight reduction over the baseline steel steer and dual drive
wheels. The
[[Page 74223]]
agencies recognize that not all tractors can or will use single wide
tires, and therefore are proposing a weight reduction package of 400
pounds. The agencies are proposing to use a 100 percent application
rate for this weight reduction package. The agencies are unaware of
reasons why a combination of lower weight wheels or tires cannot be
applied to all combination tractors, but welcome comments.
Idle reduction technologies provide significant reductions in fuel
consumption and CO2 emissions for Class 8 sleeper cabs and
are available on the market today, and therefore will be available in
the 2014 model year. There are several different technologies available
to reduce idling. These include APUs, diesel fired heaters, and battery
powered units. Our discussions with manufacturers indicate that idle
technologies are sometimes installed in the factory, but it is also a
common practice to have the units installed after the sale of the
truck. We would like to continue to incentivize this practice while
providing certainty that the overnight idle operations will be
eliminated. Therefore, we are allowing the installation of only an
automatic engine shutoff, without override capability, to qualify for
idle emission reductions in GEM to allow for aftermarket installations
of idle reduction technology. We are proposing a 100 percent
application rate for this technology for Class 8 sleeper cabs (note
that the current fleet is estimated to have a 30 percent application
rate). The agencies are unaware of reasons why extended idle reduction
technologies could not be applied to all tractors with a sleeper cab,
but welcome comments.
Vehicle speed limiters may be used as a technology to meet the
standard, but in setting the standard we assumed a 0 percent
application rate of vehicles speed limiters. Although we believe
vehicles speed limiters are a simple, easy to implement, and
inexpensive technology, we want to leave the use of vehicles speed
limiters to the truck purchaser. Since truck fleets purchase trucks
today with owner set vehicle speed limiters, we considered not
including VSLs in our compliance model. However, we have concluded that
we should allow the use of VSLs that cannot be overridden by the
operator as a means of compliance for vehicle manufacturers that wish
to offer it and truck purchasers that wish to purchase the technology.
In doing so, we are providing another means of meeting that standard
that can lower compliance cost and provide a more optimal vehicle
solution for some truck fleets. For example, a local beverage
distributor may operate trucks in a distribution network of primarily
local roads. Under those conditions, aerodynamic fairings used to
reduce aerodynamic drag provide little benefit due to the low vehicle
speed while adding additional mass to the vehicle. A vehicle
manufacturer could choose to install a VSL set at 55 mph for this
customer. The resulting truck modeled in GEM could meet our proposed
emission standard without the use of any specialized aerodynamic
fairings. The resulting truck would be optimized for its intended
application and would be fully compliant with our program all at a
lower cost to the ultimate truck purchaser. We are seeking comment on
the use of VSLs that cannot be overridden by the end-user as a means of
compliance with our proposed standards.
We have chosen not to assume the use of a mandatory vehicle speed
limiter in our proposal because of concerns about how to set a
realistic application rate that avoids unintended adverse impacts.
Although we expect there will be some use of VSL, currently it is used
when the fleet involved decides it is feasible and practicable and
increases the overall efficiency of the freight system for that fleet
operator. However, at this point the agencies are not in a position to
determine in how many additional situations use of a VSL would result
in similar benefits to overall efficiency. Setting a mandatory expected
use of such VSL carries the risk of requiring VSL in situations that
are not appropriate from an efficiency perspective. To avoid such
possibility, the agencies are not premising the proposed standards on
use of VSL, and instead will rely on the industry to select VSL when
circumstances are appropriate for its use. Implementation of this
program may provide greater information for using this technology in
standard setting in the future. Many stakeholders including the
American Trucking Association have advocated for more widespread use of
vehicle speed limits to address fuel efficiency and greenhouse gas
emissions. We welcome comments on our decision not to premise the
emission standards on the use of VSLs.
Table III-4 provides the proposed application rates of each
technology broken down by weight class, cab configuration, and roof
height.
[[Page 74224]]
[GRAPHIC] [TIFF OMITTED] TP30NO10.030
(iv) Derivation of the Proposed Tractor Standards
The agencies used the technology inputs and proposed technology
application rates in GEM to develop the proposed fuel consumption and
CO2 emissions standards for each subcategory of Class 7 and
8 combination tractors. The agencies derived a scenario truck for each
subcategory by weighting the individual GEM input parameters included
in Table III-3 by the application rates in Table III-4. For example,
the Cd value for a Class 8 Sleeper Cab High Roof scenario case was
derived as 10 percent times 0.68 plus 70 percent times 0.60 plus 20
percent times 0.55, which is equal to a Cd of 0.60. Similar
calculations were done for tire rolling resistance, weight reduction,
idle reduction, and vehicle speed limiters. To account for the two
proposed engine standards, the agencies assumed a compliant engine in
GEM. In other words, EPA is proposing the use of a 2014 model year fuel
consumption map in GEM to derive the 2014 model year tractor standard
and a 2017 model year fuel consumption map to derive the 2017 model
year tractor standard.\141\ The agencies then ran GEM with a single set
of vehicle inputs, as shown in Table III-5, to derive the proposed
standards for each subcategory. Additional detail is provided in the
draft RIA Chapter 2.
---------------------------------------------------------------------------
\141\ As explained further in Section V below, EPA would use
these inputs in GEM even for engines electing to use the alternative
engine standard.
---------------------------------------------------------------------------
[[Page 74225]]
[GRAPHIC] [TIFF OMITTED] TP30NO10.031
The level of the 2014 and 2017 model year proposed standards and
percent reduction from the baseline for each subcategory is included in
Table III-6.
[GRAPHIC] [TIFF OMITTED] TP30NO10.032
A summary of the proposed technology package costs is included in
Table III-7 with additional details available in the draft RIA Chapter
2.
[[Page 74226]]
[GRAPHIC] [TIFF OMITTED] TP30NO10.033
(v) Reasonableness of the Proposed Standards
The proposed standards are based on aggressive application rates
for control technologies which the agencies regard as the maximum
feasible for the reasons given in Section (iii) above; see also draft
RIA Chapter 2.5.8.2. These technologies, at the estimated application
rates, are available within the lead time provided, as discussed in
draft RIA Chapter 2.5. Use of these technologies would add only a small
amount to the cost of the vehicle, and the associated reductions are
highly cost effective, an estimated $10 per ton of CO2eq per
vehicle in 2030 without consideration of the substantial fuel
savings.\142\ This is even more cost effective than the estimated cost
effectiveness for CO2eq removal and fuel economy
improvements under the light-duty vehicle rule, already considered by
the agencies to be a highly cost effective reduction.\143\ Moreover,
the cost of controls is recovered due to the associated fuel savings,
as shown in the payback analysis included in Table VIII-8 located in
Section VIII below. Thus, overall cost per ton of the rule, considering
fuel savings, is negative--fuel savings associated with the rule more
than offset projected costs by a wide margin. See Table VIII-5 in
Section VIII below. Given that the standards are technically feasible
within the lead time afforded by the 2014 model year, are inexpensive
and highly cost effective even without accounting for the fuel savings,
and have no apparent adverse potential impacts (e.g., there are no
projected negative impacts on safety or vehicle utility), the proposed
standards represent a reasonable choice under section 202(a) of the CAA
and under NHTSA's EISA authority at 49 U.S.C. 32902(k)(2).
---------------------------------------------------------------------------
\142\ See Section VIII.D below.
\143\ The light-duty rule had an estimated cost per ton of $50
when considering the vehicle program costs only and a cost of -$210
per ton considering the vehicle program costs along with fuel
savings in 2030. See 75 FR 25515, Table III.H.3-1.
---------------------------------------------------------------------------
(vi) Alternative Tractor Standards Considered
The agencies are not proposing tractor standards less stringent
than the proposed standards because the agencies believe these
standards are appropriate, highly cost effective, and technologically
feasible within the rulemaking time frame. We welcome comments
supplemented with data on each aspect of this determination most
importantly on individual technology efficacy to reduce fuel
consumption and GHGs as well was our estimates of individual technology
cost and lead-time.
The agencies considered proposing tractor standards which are more
stringent than those proposed reflecting increased application rates of
the technologies discussed. We also considered setting more stringent
standards based on the inclusion of hybrid powertrains in tractors. We
stopped short of proposing more stringent standards based on higher
application rates of improved aerodynamic controls and tire rolling
resistance because we concluded that the technologies would not be
compatible with the use profile of a subset of tractors which operate
in offroad conditions. The agencies welcome comment on the application
rates for each type of technology and for each tractor category. We
have not proposed more stringent standards for tractors based on the
use of hybrid vehicle technologies, believing that additional
development and therefore lead-time is needed to develop hybrid systems
and battery technology for tractors that operate primarily in highway
cruise operations. We know,
[[Page 74227]]
for example, that hybrid systems are being researched to capture and
return energy for tractors that operate in gently rolling hills.
However, it is not clear to us today that these systems will be
generally applicable to tractors in the timeframe of this regulation.
We seek comment on our assessment on the appropriateness of setting
standards based on the use of hybrid technologies. Further, the
agencies request comment supported by data regarding additional
technologies not considered by the agencies in proposing these
standards.
(b) Tractor Engines
(i) Baseline Engine Performance
As noted above, EPA and NHTSA developed the baseline medium and
heavy heavy-duty diesel engine to represent a 2010 model year engine
compliant with the 0.2 g/bhp-hr NOX standard for on-highway
heavy-duty engines.
The agencies developed baseline SET values for medium and heavy
heavy-duty diesel engines based on 2009 model year confidential
manufacturer data and from testing conducted by EPA. The agencies
adjusted the pre-2010 data to represent 2010 model year engine maps by
using predefined technologies including SCR and other systems that are
being used in current 2010 model year production. If an engine utilized
did not meet the 0.2 g/bhp-hr NOX level, then the individual
engine's CO2 result was adjusted to accommodate
aftertreatment strategies that would result in a 0.2 g/bhp-hr
NOX emission level as described in draft RIA Chapter
2.4.2.1. The engine CO2 results were then sales weighted
within each regulatory subcategory to develop an industry average 2010
model year reference engine. While most of the engines fell within a
few percent of this baseline at least one engine was more than six
percent above this average baseline.
[GRAPHIC] [TIFF OMITTED] TP30NO10.034
(ii) Engine Technology Package Effectiveness
The MHD and HHD diesel engine technology package for the 2014 model
year includes engine friction reduction, improved aftertreatment
effectiveness, improved combustion processes, and low temperature EGR
system optimization. The agencies considered improvements in parasitic
and friction losses through piston designs to reduce friction, improved
lubrication, and improved water pump and oil pump designs to reduce
parasitic losses. The aftertreatment improvements are available through
lower backpressure of the systems and optimization of the engine-out
NOX levels. Improvements to the EGR system and air flow
through the intake and exhaust systems, along with turbochargers can
also produce engine efficiency improvements. We note that individual
technology improvements are not additive due to the interaction of
technologies. The agencies assessed the impact of each technology over
each of the 13 SET modes to project an overall weighted SET cycle
improvement in the 2014 model year of 3 percent, as detailed in draft
RIA Chapter 2.4.2.9 through 2.4.2.14. All of these technologies
represent engine enhancements already developed beyond the research
phase and are available as ``off the shelf'' technologies for
manufacturers to add to their engines during the engine's next design
cycle. We have estimated that manufacturers will be able to implement
these technologies on or before the 2014 engine model year. The
agencies proposal therefore reflects a 100 percent application rate of
this technology package. The agencies gave consideration to proposing a
more stringent standard based on the application of turbocompounding, a
mechanical means of waste heat recovery, but concluded that
manufacturers would have insufficient lead-time to complete the
necessary product development and validation work necessary to include
this technology across the industry by model year 2014.
As explained earlier, EPA's heavy-duty highway engine standards for
criteria pollutants apply in three year increments. The heavy-duty
engine manufacturer product plans have fallen into three year cycles to
reflect these requirements. The agencies are proposing to set fuel
consumption and CO2 emission standards recognizing the
opportunity for technology improvements over this timeframe while
reflecting the typical heavy-duty engine manufacturer product plan
redesign and refresh cycles. Thus, the agencies are proposing to set a
more stringent standard for heavy-duty engines beginning in the 2017
model year.
The MHDD and HHDD engine technology package for the 2017 model year
includes the continued development of the 2014 model year technology
package including refinement of the aftertreatment system plus
turbocompounding. The agencies calculated overall reductions in the
same manner as for the 2014 model year package. The weighted SET cycle
improvements lead to a 6 percent reduction on the SET cycle, as
detailed in draft RIA Chapter 2.4.2.12. The agencies' proposal is
premised on a 100 percent application rate of this technology package.
We gave consideration to proposing an even more stringent standard
based on the use of advanced Rankine cycle (also called bottoming
cycle) engine technology but concluded that there is insufficient lead-
time between now and 2017 for this promising technology to be developed
and applied generally to all heavy-duty engines.\144\ Therefore, these
technologies were not included in determining the stringency of the
proposed standards. However, we do believe the bottoming cycle approach
represents a significant opportunity to reduce fuel consumption and GHG
emissions in the future. EPA and NHTSA are therefore both proposing
provisions described in Section IV to create incentives for
manufacturers to
[[Page 74228]]
continue to invest to develop this technology.
---------------------------------------------------------------------------
\144\ TIAX noted in their report to the NAS committee that the
engine improvements beyond 2015 model year included in their report
are highly uncertain, though they include Rankine cycle type waste
heat recovery as applicable sometime between 2016 and 2020 (page 4-
29).
---------------------------------------------------------------------------
(iii) Derivation of Engine Standards
EPA developed the proposed 2014 model year CO2 emissions
standards (based on the SET cycle) for diesel engines by applying the
three percent reduction from the technology package (just explained
above) to the 2010 model year baseline values determined using the SET
cycle. EPA developed the 2017 model year CO2 emissions
standards for diesel engines while NHTSA similarly developed the 2017
model year diesel engine fuel consumption standards by applying the 6
percent reduction from the 2017 model year technology package
(reflecting performance of turbocompounding plus the 2014 MY technology
package) to the 2010 model year baseline values. The proposed standards
are included in Table III-9.
[GRAPHIC] [TIFF OMITTED] TP30NO10.035
(iv) Engine Technology Package Costs
EPA has historically used two different approaches to estimate the
indirect costs (sometimes called fixed costs) of regulations including
costs for product development, machine tooling, new capital investments
and other general forms of overhead that do not change with incremental
changes in manufacturing volumes. Where the Agency could reasonably
make a specific estimate of individual components of these indirect
costs, EPA has done so. Where EPA could not readily make such an
estimate, EPA has instead relied on the use of markup factors referred
to as indirect cost multipliers (ICMs) to estimate these indirect costs
as a ratio of direct manufacturing costs. In general, EPA has used
whichever approach it believed could provide the most accurate
assessment of cost on a case by case basis. The agencies' general
approach used elsewhere in this proposal (for HD pickup trucks,
gasoline engines, combination tractors, and vocational vehicles)
estimates indirect costs based on the use of ICMs. See also 75 FR
25376. We have used this approach generally because these standards are
based on installing new parts and systems purchased from a supplier. In
such a case, the supplier is conducting the bulk of the research and
development on the new parts and systems and including those costs in
the purchase price paid by the original equipment manufacturer. In this
situation, we believe that the ICM approach provides an accurate and
clear estimate of the additional indirect costs borne by the
manufacturer.
For the heavy-duty diesel engine segment, however, the agencies do
not consider this model to be the most appropriate because the primary
cost is not expected to be the purchase of parts or systems from
suppliers or even the production of the parts and systems, but rather
the development of the new technology by the original equipment
manufacturer itself. Most of the technologies the agencies are
projecting the heavy-duty engine manufacturers will use for compliance
reflect modifications to existing engine systems rather than wholesale
addition of technology (e.g., improved turbochargers rather than adding
a turbocharger where it did not exist before as was done in our light-
duty joint rulemaking in the case of turbo-downsizing). When the bulk
of the costs come from refining an existing technology rather than a
wholesale addition of technology, a specific estimate of indirect costs
may be more appropriate. For example, combustion optimization may
significantly reduce emissions and cost a manufacturer millions of
dollars to develop but will lead to an engine that is no more expensive
to produce. Using a bill of materials approach would suggest that the
cost of the emissions control was zero reflecting no new hardware and
ignoring the millions of dollars spent to develop the improved
combustion system. Details of the cost analysis are included in the
draft RIA Chapter 2.
The agencies developed the engineering costs for the research and
development of diesel engines with lower fuel consumption and
CO2 emissions. The aggregate costs for engineering hours,
technician support, dynamometer cell time, and fabrication of prototype
parts are estimated at $6,750,000 per manufacturer per year over the
five years covering 2012 through 2016. In aggregate, this averages out
to $280 per engine during 2012 through 2016 using an annual sales value
of 600,000 light-, medium- and heavy-HD engines. The agencies also are
estimating costs of $100,000 per engine manufacturer per engine class
(light-, medium- and heavy-HD) to cover the cost of purchasing photo-
acoustic measurement equipment for two engine test cells. This would be
a one-time cost incurred in the year prior to implementation of the
standard (i.e., the cost would be incurred in 2013). In aggregate, this
averages out to $4 per engine in 2013 using an annual sales value of
600,000 light-, medium- and heavy-HD engines.
Where we projected that additional new hardware was needed to the
meet the proposed standards, we developed the incremental costs for
those technologies and marked them up using the ICM approach. Table
III-10 below summarizes those estimates of cost on a per item basis.
All costs shown in Table III-18 include a low complexity ICM of 1.11
and time based learning is considered applicable to each technology.
[[Page 74229]]
[GRAPHIC] [TIFF OMITTED] TP30NO10.036
The overall diesel engine technology package cost for a medium HD
engine being placed in a combination tractor is $223 in the 2014 model
year and $1,027 in the 2017 model year; for a heavy HD engine being
placed in a combination tractor these costs are $145 and $955 in the
2014 and 2017 model years, respectively. The differences for the medium
HD engines are the valve train friction reduction costs of $78 in 2014
($71 in 2017) that are not applied to heavy HD engines.
(v) Reasonableness of the Proposed Standards
The proposed engine standards appear to be reasonable and
consistent with the agencies' respective statutory authorities. With
respect to the 2014 and 2017 MY standards, all of the technologies on
which the standards are predicated have already been demonstrated in
some capacity and their effectiveness is well documented. The proposal
reflects a 100 percent application rate for these technologies. The
costs of adding these technologies remain modest across the various
engine classes as shown in Table III-10. Use of these technologies
would add only a small amount to the cost of the vehicle,\145\ and the
associated reductions are highly cost effective, an estimated $6 per
ton of CO2eq per vehicle.\146\ This is even more cost
effective than the estimated cost effectiveness for CO2eq
removal under the light-duty vehicle rule, already considered by the
agencies to be a highly cost effective reduction.\147\ Even the more
expensive 2017 MY proposed standard still represents only a small
fraction of the vehicle's total cost and is even more cost effective
than the light-duty vehicle rule. Moreover, costs are more than offset
by fuel savings. Accordingly, EPA and NHTSA view these standards as
reflecting an appropriate balance of the various statutory factors
under section 202(a) of the CAA and under NHTSA's EISA authority at 49
U.S.C. 32902(k)(2).
---------------------------------------------------------------------------
\145\ Sample 2010 MY day cabs are priced at $89,000 while 2010
MY sleeper cabs are priced at $113,000. See page 3 of ICF's
``Investigation of Costs for Strategies to Reduce Greenhouse Gas
Emissions for Heavy-Duty On-Road Vehicles.'' July 2010.
\146\ See Tractor CO2 savings and technology costs
for Alternative 2 in Section IX.B.
\147\ The light-duty rule had an estimated cost per ton of $50
when considering the vehicle program costs only and a cost of -$210
per ton considering the vehicle program costs along with fuel
savings in 2030. See 75 FR 25515, Table III.H.3-1.
---------------------------------------------------------------------------
(vi) Temporary Alternative Standard for Certain Engine Families
As discussed above in Section II.B (1)(b), notwithstanding the
general reasonableness of the proposed standards, the agencies
recognize that heavy-duty engines have never been subject to GHG or
fuel consumption (or fuel economy) standards and that such control has
not necessarily been an independent priority for manufacturers. The
result is that there are a group of legacy engines with emissions
higher than the industry baseline for which compliance with the
proposed 2014 MY standards may be more challenging and for which there
may simply be inadequate lead time. The issue is not whether these
engines' GHG and fuel consumption performance cannot be improved by
utilizing the technology packages on which the proposed standards are
based. Those technologies can be utilized by all engines and the same
degree of reductions obtained. Rather the underlying base engine
components of these engines reflect designs that are decades old and
therefore have base performance levels below what is typical for the
industry as a whole today. Manufacturers have been gradually replacing
these legacy products with new engines. Engine
[[Page 74230]]
manufacturers have indicated to the agencies they will have to align
their planned replacement of these products with our proposed standards
and at the same time add additional technologies beyond those
identified by the agencies as the basis for the proposed standard.
Because these changes will reflect a larger degree of overall engine
redesign, manufacturers may not be able to complete this work for all
of their legacy products prior to model year 2014. To pull ahead these
already planned engine replacements would be impossible as a practical
matter given the engineering structure and lead-times inherent in the
companies' existing product development processes. We have also
concluded that the use of fleet averaging would not address the issue
of legacy engines because each manufacturer typically produces only a
limited line of MHDD and HHDD engines. (Because there are ample
fleetwide averaging opportunities for heavy-duty pickups and vans, the
agencies do not perceive similar difficulties for these vehicles.)
Facing a similar issue in the light-duty vehicle rule, EPA adopted
a Temporary Lead Time Allowance provision whereby a limited number of
vehicles of a subset of manufacturers would meet an alternative
standard in the early years of the program, affording them sufficient
lead time to meet the more stringent standards applicable in later
model years. See 75 FR 25414-25418. The agencies are proposing a
similar approach here. As explained above in Section II B. (1) (b), the
agencies are proposing a regulatory alternative whereby a manufacturer,
for a limited period, would have the option to comply with a unique
standard requiring the same level of reduction of emissions (i.e.,
percent removal) and fuel consumption as otherwise required, but the
reduction would be measured from its own 2011 model year baseline. We
are thus proposing an optional standard whereby manufacturers would
elect to have designated engine families meet a standard of 3%
reduction from their 2011 baseline emission and fuel consumption levels
for that engine family. Our assessment is that this three percent
reduction is appropriate based on use of similar technology packages at
similar cost as we have estimated for the primary program. As explained
earlier, we are not proposing that the option to select an alternative
standard continues past the 2016 MY. By this time, the engines should
have gone through a redesign cycle which will allow manufacturers to
replace those legacy engines which resulted in abnormally high baseline
emission and fuel consumption levels and to achieve the MY 2017
standards which would be feasible using the technology package set out
above (optimized NOX aftertreatment, improved EGR, reductions in
parasitic losses, and turbocharging). Manufacturers would, of course,
be free to adopt other technology paths which meet the proposed MY 2017
standards.
Since the alternative standard is premised on the need for
additional lead time, manufacturers would first have to utilize all
available flexibilities which could otherwise provide that lead time.
Thus, the alternative would not be available unless and until a
manufacturer had exhausted all available credits and credit
opportunities, and engines under the alternative standard could not
generate credits. See 75 FR 25417-25419 (similar approach for vehicles
which are part of Temporary Lead Time Allowance under the light-duty
vehicle rule). We are proposing that manufacturers can select engine
families for this alternative standard without agency approval, but are
proposing to require that manufacturers notify the agency of their
choice and to include in that notification a demonstration that it has
exhausted all available credits and credit opportunities. Manufacturers
would also have to demonstrate their 2011 baseline calculations as part
of the certification process for each engine family for which the
manufacturer elects to use the alternative standard. See Section
V.C.1(b)(i) below.
(vii) Alternative Engine Standards Considered
The agencies are not proposing engine standards less stringent than
the proposed standards because the agencies believe these proposed
standards are appropriate, highly cost effective, and technologically
feasible, as just described. We welcome comments supplemented with data
on each aspect of this determination most importantly on individual
engine technology efficacy to reduce fuel consumption and GHG
emissions. Comments should also address our estimates of individual
technology cost and lead-time.
The agencies considered proposing engine standards which are more
stringent. Since the proposed standards reflect 100 percent utilization
of the various technology packages, some additional technology would
have to be added. The agencies are proposing 2017 model year standards
based on the use of turbocompounding. The agencies considered the
inclusion of more advanced heat recovery systems, such as Rankine or
bottoming cycles, which would provide further reductions. However, the
agencies are not proposing this level of stringency because our
assessment is that these technologies would not be available for
production by the 2017 model year. The agencies welcome comments on
whether waste heat recovery technologies are appropriate to consider
for the 2017 model year standard, or if not, then when would they be
appropriate.
B. Heavy-Duty Pickup Trucks and Vans
This section describes the process the agencies used to develop the
standards the agencies are proposing for HD pickups and vans. We
started by gathering available information about the fuel consumption
and CO2 emissions from recent model year vehicles. The core
portion of this information comes primarily from EPA's certification
databases, CFEIS and VERIFY, which contain the publicly available data
\148\ regarding emission and fuel economy results. This information is
not extensive because manufacturers have not been required to chassis
test HD diesel vehicles for EPA's criteria pollutant emissions
standards, nor have they been required to conduct any testing of heavy-
duty vehicles on the highway cycle. Nevertheless, enough certification
activity has occurred for diesels under EPA's optional chassis-based
program, and, due to a California NOX requirement for the
highway test cycle, enough test results have been voluntarily reported
for both diesel and gasoline vehicles using the highway test cycle, to
yield a reasonably robust data set. To supplement this data set, for
purposes of this rulemaking EPA initiated its own testing program using
in-use vehicles. This program and the results from it thus far are
described in a memorandum to the docket for this rulemaking.\149\
---------------------------------------------------------------------------
\148\ http://www.epa.gov/otaq/certdata.htm.
\149\ Memorandum from Cleophas Jackson, U.S. EPA, to docket EPA-
HQ-OAR-2010-0162, ``Heavy-Duty Greenhouse Gas and Fuel Consumption
Test Program Summary'', September 20, 2010.
---------------------------------------------------------------------------
Heavy-duty pickup trucks and vans are sold in a variety of
configurations to meet market demands. Among the differences in these
configurations that affect CO2 emissions and fuel
consumption are curb weight, GVWR, axle ratio, and drive wheels (two-
wheel drive or four-wheel drive). Because the currently-available test
data set does not capture all of these configurations, it is necessary
to extend that data set across the product mix using adjustment
factors. In this way a test result from, say a truck with two-wheel
drive, 3.73:1 axle ratio, and 8000 lb test weight, can
[[Page 74231]]
be used to model emissions and fuel consumption from a truck of the
same basic body design, but with 4wd, a 4.10:1 axle ratio, and 8,500 lb
test weight. The adjustment factors are based on data from testing in
which only the parameters of interest are varied. These parameterized
adjustments and their basis are also described in a memorandum to the
docket for this rulemaking.\150\
---------------------------------------------------------------------------
\150\ Memorandum from Anthony Neam and Jeff Cherry, U.S. EPA, to
docket EPA-HQ-OAR-2010-0162, October 18, 2010.
---------------------------------------------------------------------------
The agencies requested and received from each of the three major
manufacturers confidential information for each model and
configuration, indicating the values of each of these key parameters as
well as the annual production (for the U.S. market). Production figures
are useful because, under our proposed standards for HD pickups and
vans, compliance is judged on the basis of production-weighted
(corporate average) emissions or fuel consumption level, not individual
vehicle levels. For consistency and to avoid confounding the analysis
with data from unusual market conditions in 2009, the production and
vehicle specification data is from the 2008 model year. We made the
simplifying assumption that these sales figures reasonably approximate
future sales for purposes of this analysis.
One additional assessment was needed to make the data set useful as
a baseline for the standards selection. Because the appropriate
standards are determined by applying efficiency-improving technologies
to the baseline fleet, it is necessary to know the level of penetration
of these technologies in the latest model year (2010). This information
was also provided confidentially by the manufacturers. Generally, the
agencies found that the HD pickup and van fleet was at a roughly
consistent level of technology application, with (1) the transition
from 4-speed to 5- or 6-speed automatic transmissions mostly
accomplished, (2) coupled cam phasing to achieve variable valve control
on gasoline engines likewise mostly in place, and (3) substantial
remaining potential for optimizing catalytic diesel NOX
aftertreatment to improve fuel economy (the new heavy-duty
NOX standards having taken effect in the 2010 model year).
Taking this 2010 baseline fleet, and applying the technologies
determined to be feasible and appropriate by the 2018 model year, along
with their effectiveness levels, the agencies could then make a
determination of appropriate proposed standards. The assessment of
feasibility, described immediately below, takes into account the
projected costs of these technologies. The derivation of these costs,
largely based on analyses developed in the light-duty GHG and fuel
economy rulemaking, are described in Section III.B(3).
Our assessment concluded that the technologies that the agencies
considered feasible and appropriate for HD pickups and vans could be
consistently applied to essentially all vehicles across this sector by
the 2018 model year. Therefore we did not apply varying penetration
rates across vehicle types and models in developing and evaluating the
proposed standards.
Since the manufacturers of HD pickups and vans generally only have
one basic pick-up truck and van with different versions ((i.e.,
different wheel bases, cab sizes, two-wheel drive, four-wheel drive,
etc.) and do not have the flexibility of the light-duty fleet to
coordinate model improvements over several years, changes to the HD
pickups and vans to meet new standards must be carefully planned with
the redesign cycle taken into account. The opportunities for large-
scale changes (e.g., new engines, transmission, vehicle body and mass)
thus occur less frequently than in the light-duty fleet, typically at
spans of 8 or more years. However, opportunities for gradual
improvements not necessarily linked to large scale changes can occur
between the redesign cycles. Examples of such improvements are upgrades
to an existing vehicle model's engine, transmission and aftertreatment
systems. Given this long redesign cycle and our understanding with
respect to where the different manufacturers are in that cycle, the
agencies have initially determined that the full implementation of the
proposed standards would be feasible and appropriate by the 2018 model
year.
Although we did not determine that it was necessary for feasibility
to apply varying technology penetration levels to different vehicles,
we did decide that a phased implementation schedule would be
appropriate to accommodate manufacturers' redesign workload and product
schedules, especially in light of this sector's relatively low sales
volumes and long product cycles. We did not determine a specific cost
of implementing the final standards immediately in 2014 without a
phase-in, but we assessed it to be much higher than the cost of the
phase-in we are proposing, due to the workload and product cycle
disruptions it would cause, and also due to manufacturers' resulting
need to develop some of these technologies for heavy-duty applications
sooner than or simultaneously with light-duty development efforts. See
generally 75 FR 25467-25468 explaining why attempting major changes
outside the redesign cycle period raises very significant issues of
both feasibility and cost. On the other hand, waiting until 2018 before
applying any new standards could miss the opportunity to achieve
meaningful and cost-effective early reductions not requiring a major
product redesign when the largest changes and reductions are expected
to occur.
The proposed phase-in schedule, 15-20-40-60-100 percent in 2014-
2015-2016-2017-2018, respectively, was chosen to strike a balance
between meaningful reductions in the early years (reflecting the
technologies' penetration rates of 15 and 20 percent) and providing
manufacturers with needed lead time via a gradually accelerating ramp-
up of technology penetration.\151\ By expressing the proposed phase-in
in terms of increasing fleetwide stringency for each manufacturer,
while also providing for credit generation and use (including
averaging, carry-forward, and carry-back), we believe our proposal
affords manufacturers substantial flexibility to satisfy the phase-in
through a variety of pathways: the gradual application of technologies
across the fleet (averaging a fifth of total production in each year),
greater application levels on only a portion of the fleet, or a mix of
the two.
---------------------------------------------------------------------------
\151\ The NHTSA proposal provides voluntary standards for model
years 2014 and 2015. NHTSA and EPA also propose to provide an
alternative standards phase-in that meets EISA's requirement for
three years of regulatory stability. See Section II.C.d.ii for a
more detailed discussion.
---------------------------------------------------------------------------
We considered setting more stringent standards that would require
the application of additional technologies by 2018. We expect, in fact,
that some of these technologies may well prove feasible and cost-
effective in this timeframe, and may even become technologies of choice
for individual manufacturers. This dynamic has played out in EPA
programs before and highlights the value of setting performance-based
standards that leave engineers the freedom to find the most cost-
effective solutions.
However, the agencies do believe that at this stage there is not
enough information to conclude that the additional technologies provide
an appropriate basis for standard-setting. For example, we believe that
42V stop-start systems can be applied to gasoline vehicles with
significant GHG and fuel
[[Page 74232]]
consumption benefits, but we recognize that there is uncertainty at
this time over the cost-effectiveness of these systems in heavy-duty
applications, and over customer acceptance of vehicles with high GCWR
towing large loads that would routinely stop running at idle. Hybrid
electric technology likewise could be applied to heavy-duty vehicles,
and in fact has already been so applied on a limited basis. However,
the development, design, and tooling effort needed to apply this
technology to a vehicle model is quite large, and seems less likely to
prove cost-effective in this timeframe, due to the small sales volumes
relative to the light-duty sector. Here again, potential customer
acceptance would need to be better understood because the smaller
engines that facilitate much of a hybrid's benefit are typically at
odds with the importance pickup trucks buyers place on engine
horsepower and torque, whatever the vehicle's real performance.
We also considered setting less stringent standards calling for a
more limited set of applied technologies. However, our assessment
concluded with a high degree of confidence that the technologies on
which the proposed standards are premised are clearly available at
reasonable cost in the 2014-2018 timeframe, and that the phase-in and
other flexibility provisions allow for their application in a very
cost-effective manner, as discussed in this section below.
More difficult to characterize is the degree to which more or less
stringent standards might be appropriate because of under- or over-
estimating effectiveness of the technologies whose performance is the
basis of the proposed standards. Our basis for these estimates is
described in Section III.B.(1)(1) . Because for the most part these
technologies have not yet been applied to HD pickups and vans, even on
a limited basis, we are relying to some degree on engineering judgment
in predicting their effectiveness. Even so, we believe that we have
applied this judgment using the best information available, primarily
from our recent rulemaking on light-duty vehicle GHGs and fuel economy,
and have generated a robust set of effectiveness values.
We solicit comment and new information that would aid the agencies
in establishing the appropriate level of stringency for the HD pickup
and van standards, and on all facets of the assessment described here
and elsewhere in these rulemaking proposals.
(1) What technologies did the agencies consider?
The agencies considered over 35 vehicle technologies that
manufacturers could use to improve the fuel consumption and reduce
CO2 emissions of their vehicles during MYs 2014-2018. The
majority of the technologies described in this section is readily
available, well known, and could be incorporated into vehicles once
production decisions are made. Other technologies considered may not
currently be in production, but are beyond the research phase and under
development, and are expected to be in production in highway vehicles
over the next few years. These are technologies which are capable of
achieving significant improvements in fuel economy and reductions in
CO2 emissions, at reasonable costs. The agencies did not
consider technologies in the research stage because there is
insufficient time for such technologies to move from research to
production during the model years covered by this proposal.
The technologies considered in the agencies' analysis are briefly
described below. They fall into five broad categories: Engine
technologies, transmission technologies, vehicle technologies,
electrification/accessory technologies, and hybrid technologies.
In this class of trucks and vans, diesel engines are installed in
about half of all vehicles. The ratio between gasoline and diesel
engine purchases by consumers has tended to track changes in the
overall cost of oil and the relative cost of gasoline and diesel fuels.
When oil prices are higher, diesel sales tend to increase. This trend
has reversed when oil prices fall or when diesel fuel prices are
significantly higher than gasoline. In the context of our technology
discussion for heavy-duty pickups and vans, we are treating gasoline
and diesel engines separately so each has a set of baseline
technologies. We discuss performance improvements in terms of changes
to those baseline engines. Our cost and inventory estimates contained
elsewhere reflect the current fleet baseline with an appropriate mix of
gasoline and diesel engines. Note that we are not basing the proposed
standards on a targeted switch in the mix of diesel and gasoline
vehicles. We believe our proposed standards require similar levels of
technology development and cost for both diesel and gasoline vehicles.
Hence the proposed program does not force, nor does it discourage,
changes in a manufacturer's fleet mix between gasoline and diesel
vehicles. Although we considered setting a single standard based on the
performance level possible for diesel vehicles, we are not proposing
such an approach because the potential disruption in the HD pickup and
van market from a forced shift would not be justified. Types of engine
technologies that improve fuel efficiency and reduce CO2
emissions include the following:
Low-friction lubricants--low viscosity and advanced low
friction lubricant oils are now available with improved performance and
better lubrication. If manufacturers choose to make use of these
lubricants, they would need to make engine changes and possibly conduct
durability testing to accommodate the low-friction lubricants.
Reduction of engine friction losses--can be achieved
through low-tension piston rings, roller cam followers, improved
material coatings, more optimal thermal management, piston surface
treatments, and other improvements in the design of engine components
and subsystems that improve engine operation.
Cylinder deactivation--deactivates the intake and exhaust
valves and prevents fuel injection into some cylinders during light-
load operation. The engine runs temporarily as though it were a smaller
engine which substantially reduces pumping losses.
Variable valve timing--alters the timing of the intake
valve, exhaust valve, or both, primarily to reduce pumping losses,
increase specific power, and control residual gases.
Stoichiometric gasoline direct-injection technology--
injects fuel at high pressure directly into the combustion chamber to
improve cooling of the air/fuel charge within the cylinder, which
allows for higher compression ratios and increased thermodynamic
efficiency.
Diesel engine improvements and diesel aftertreatment
improvements--improved EGR systems and advanced timing can provide more
efficient combustion and, hence, lower fuel consumption. Aftertreatment
systems are a relatively new technology on diesel vehicles and, as
such, improvements are expected in coming years that allow the
effectiveness of these systems to improve while reducing the fuel and
reductant demands of current systems.
Types of transmission technologies considered include:
Improved automatic transmission controls--optimizes shift
schedule to maximize fuel efficiency under wide ranging conditions, and
minimizes losses associated with torque converter slip through lock-up
or modulation.
[[Page 74233]]
Six-, seven-, and eight-speed automatic transmissions--the
gear ratio spacing and transmission ratio are optimized for a broader
range of engine operating conditions.
Types of vehicle technologies considered include:
Low-rolling-resistance tires--have characteristics that
reduce frictional losses associated with the energy dissipated in the
deformation of the tires under load, therefore improving fuel
efficiency and reducing CO2 emissions.
Aerodynamic drag reduction--is achieved by changing
vehicle shape or reducing frontal area, including skirts, air dams,
underbody covers, and more aerodynamic side view mirrors.
Mass reduction and material substitution--Mass reduction
encompasses a variety of techniques ranging from improved design and
better component integration to application of lighter and higher-
strength materials. Mass reduction is further compounded by reductions
in engine power and ancillary systems (transmission, steering, brakes,
suspension, etc.). The agencies recognize there is a range of diversity
and complexity for mass reduction and material substitution
technologies and there are many techniques that automotive suppliers
and manufacturers are using to achieve the levels of this technology
that the agencies have modeled in our analysis for this proposal.
Types of electrification/accessory and hybrid technologies
considered include:
Electric power steering and Electro-Hydraulic power
steering--are electrically assisted steering systems that have
advantages over traditional hydraulic power steering because it
replaces a continuously operated hydraulic pump, thereby reducing
parasitic losses from the accessory drive.
Improved accessories--may include high efficiency
alternators, electrically driven (i.e., on-demand) water pumps and
cooling fans. This excludes other electrical accessories such as
electric oil pumps and electrically driven air conditioner compressors.
Air Conditioner Systems--These technologies include
improved hoses, connectors and seals for leakage control. They also
include improved compressors, expansion valves, heat exchangers and the
control of these components for the purposes of improving tailpipe
CO2 emissions as a result of A/C use.\152\
---------------------------------------------------------------------------
\152\ See draft RIA Chapter 2.3 for fuller technology
descriptions.
---------------------------------------------------------------------------
How did the agencies determine the costs and effectiveness of each of
these technologies?
Building on the technical analysis underlying the 2012-2016 MY
light-duty vehicle rule, the agencies took a fresh look at technology
cost and effectiveness values for purposes of this proposal. For costs,
the agencies reconsidered both the direct or ``piece'' costs and
indirect costs of individual components of technologies. For the direct
costs, the agencies followed a bill of materials (BOM) approach
employed by NHTSA and EPA in the light-duty rule.
For two technologies, stoichiometric gasoline direct injection
(SGDI) and turbocharging with engine downsizing, the agencies relied to
the extent possible on the available tear-down data and scaling
methodologies used in EPA's ongoing study with FEV, Incorporated. This
study consists of complete system tear-down to evaluate technologies
down to the nuts and bolts to arrive at very detailed estimates of the
costs associated with manufacturing them.\153\
---------------------------------------------------------------------------
\153\ U.S. Environmental Protection Agency, ``Draft Report--
Light-Duty Technology Cost Analysis Pilot Study,'' Contract No. EP-
C-07-069, Work Assignment 1-3, September 3, 2009.
---------------------------------------------------------------------------
For the other technologies, considering all sources of information
and using the BOM approach, the agencies worked together intensively to
determine component costs for each of the technologies and build up the
costs accordingly. Where estimates differ between sources, we have used
engineering judgment to arrive at what we believe to be the best cost
estimate available today, and explained the basis for that exercise of
judgment.
Once costs were determined, they were adjusted to ensure that they
were all expressed in 2008 dollars using a ratio of gross domestic
product (GDP) values for the associated calendar years,\154\ and
indirect costs were accounted for using the new approach developed by
EPA and used in the 2012-2016 light-duty rule. NHTSA and EPA also
reconsidered how costs should be adjusted by modifying or scaling
content assumptions to account for differences across the range of
vehicle sizes and functional requirements, and adjusted the associated
material cost impacts to account for the revised content, although some
of these adjustments may be different for each agency due to the
different vehicle subclasses used in their respective models.
---------------------------------------------------------------------------
\154\ NHTSA examined the use of the CPI multiplier instead of
GDP for adjusting these dollar values, but found the difference to
be exceedingly small--only $0.14 over $100.
---------------------------------------------------------------------------
Regarding estimates for technology effectiveness, NHTSA and EPA
used the estimates from the 2012-2016 light-duty rule as a baseline but
adjusted them as appropriate, taking into account the unique
requirement of the heavy-duty test cycles to test at curb weight plus
half payload versus the light-duty requirement of curb plus 300 lb. The
adjustments were made on an individual technology basis by assessing
the specific impact of the added load on each technology when compared
to the use of the technology on a light-duty vehicle. The agencies also
considered other sources such as the 2010 NAS Report, recent CAFE
compliance data, and confidential manufacturer estimates of technology
effectiveness. NHTSA and EPA engineers reviewed effectiveness
information from the multiple sources for each technology and ensured
that such effectiveness estimates were based on technology hardware
consistent with the BOM components used to estimate costs. Together,
the agencies compared the multiple estimates and assessed their
validity, taking care to ensure that common BOM definitions and other
vehicle attributes such as performance and drivability were taken into
account.
The agencies note that the effectiveness values estimated for the
technologies may represent average values applied to the baseline fleet
described earlier, and do not reflect the potentially-limitless
spectrum of possible values that could result from adding the
technology to different vehicles. For example, while the agencies have
estimated an effectiveness of 0.5 percent for low friction lubricants,
each vehicle could have a unique effectiveness estimate depending on
the baseline vehicle's oil viscosity rating. Similarly, the reduction
in rolling resistance (and thus the improvement in fuel efficiency and
the reduction in CO2 emissions) due to the application of
LRR tires depends not only on the unique characteristics of the tires
originally on the vehicle, but on the unique characteristics of the
tires being applied, characteristics which must be balanced between
fuel efficiency, safety, and performance. Aerodynamic drag reduction is
much the same--it can improve fuel efficiency and reduce CO2
emissions, but it is also highly dependent on vehicle-specific
functional objectives. For purposes of this NPRM, NHTSA and EPA believe
that employing average values for technology effectiveness estimates is
an appropriate way of recognizing the potential variation in the
specific benefits that individual manufacturers
[[Page 74234]]
(and individual vehicles) might obtain from adding a fuel-saving
technology. However, the agencies seek comment on whether additional
levels of specificity beyond that already provided would improve the
analysis for the final rules, and if so, how those levels of
specificity should be analyzed.
The following section contains a detailed description of our
assessment of vehicle technology cost and effectiveness estimates. The
agencies note that the technology costs included in this NPRM take into
account only those associated with the initial build of the vehicle.
The agencies seek comment on the additional lifetime costs, if any,
associated with the implementation of advanced technologies including
maintenance and replacement costs. Based on comments, the agencies may
decide to conduct additional analysis for the final rules regarding
operating, maintenance and replacement costs.
(a) Engine Technologies
NHTSA and EPA have reviewed the engine technology estimates used in
the 2012-2016 light-duty rule. In doing so NHTSA and EPA reconsidered
all available sources and updated the estimates as appropriate. The
section below describes both diesel and gasoline engine technologies
considered for this proposal.
(i) Low Friction Lubricants
One of the most basic methods of reducing fuel consumption in both
gasoline and diesel engines is the use of lower viscosity engine
lubricants. More advanced multi-viscosity engine oils are available
today with improved performance in a wider temperature band and with
better lubricating properties. This can be accomplished by changes to
the oil base stock (e.g., switching engine lubricants from a Group I
base oils to lower-friction, lower viscosity Group III synthetic) and
through changes to lubricant additive packages (e.g., friction
modifiers and viscosity improvers). The use of 5W-30 motor oil is now
widespread and auto manufacturers are introducing the use of even lower
viscosity oils, such as 5W-20 and 0W-20, to improve cold-flow
properties and reduce cold start friction. However, in some cases,
changes to the crankshaft, rod and main bearings and changes to the
mechanical tolerances of engine components may be required. In all
cases, durability testing would be required to ensure that durability
is not compromised. The shift to lower viscosity and lower friction
lubricants will also improve the effectiveness of valvetrain
technologies such as cylinder deactivation, which rely on a minimum oil
temperature (viscosity) for operation.
Based on the 2012-2016 MY light-duty vehicle rule, and previously-
received confidential manufacturer data, NHTSA and EPA estimated the
effectiveness of low friction lubricants to be between 0 to 1 percent.
In the light-duty rule, the agencies estimated the cost of moving
to low friction lubricants at $3 per vehicle (2007$). That estimate
included a markup of 1.11 for a low complexity technology. For HD
pickups and vans, we are using the same base estimate but have marked
it up to 2008 dollars using the GDP price deflator and have used a
markup of 1.17 for a low complexity technology to arrive at a value of
$4 per vehicle. As in the light-duty rule, learning effects are not
applied to costs for this technology and, as such, this estimate
applies to all model years.155 156
---------------------------------------------------------------------------
\155\ Note that throughout the cost estimates for this HD
analysis, the agencies have used slightly higher markups than those
used in the 2012-2016 MY light-duty vehicle rule. The new, slightly
higher ICMs include return on capital of roughly 6%, a factor that
was not included in the light-duty analysis.
\156\ Note that the costs developed for low friction lubes for
this analysis reflect the costs associated with any engine changes
that would be required as well as any durability testing that may be
required.
---------------------------------------------------------------------------
(ii) Engine Friction Reduction
In addition to low friction lubricants, manufacturers can also
reduce friction and improve fuel consumption by improving the design of
both diesel and gasoline engine components and subsystems.
Approximately 10 percent of the energy consumed by a vehicle is lost to
friction, and just over half is due to frictional losses within the
engine.\157\ Examples include improvements in low-tension piston rings,
piston skirt design, roller cam followers, improved crankshaft design
and bearings, material coatings, material substitution, more optimal
thermal management, and piston and cylinder surface treatments.
Additionally, as computer-aided modeling software continues to improve,
more opportunities for evolutionary friction reductions may become
available.
---------------------------------------------------------------------------
\157\ ``Impact of Friction Reduction Technologies on Fuel
Economy,'' Fenske, G. Presented at the March 2009 Chicago Chapter
Meeting of the `Society of Tribologists and Lubricated Engineers'
Meeting, March 18th, 2009. Available at: http://www.chicagostle.org/program/2008-2009/Impact%20of%20Friction%20Reduction%20Technologies%20on%20Fuel%20Economy%20-%20with%20VGs%20removed.pdf (last accessed July 9, 2009).
---------------------------------------------------------------------------
All reciprocating and rotating components in the engine are
potential candidates for friction reduction, and minute improvements in
several components can add up to a measurable fuel efficiency
improvement. The 2012-2016 light-duty final rule, the 2010 NAS Report,
and NESCCAF and Energy and Environmental Analysis reports, as well as
confidential manufacturer data, indicate a range of effectiveness for
engine friction reduction to be between 1 to 3 percent. NHTSA and EPA
continue to believe that this range is accurate.
Consistent with the 2012-2016 MY light-duty vehicle rule, the
agencies estimate the cost of this technology at $14 per cylinder
compliance cost (2008$), including the low complexity ICM markup value
of 1.17. Learning impacts are not applied to the costs of this
technology and, as such, this estimate applies to all model years. This
cost is multiplied by the number of engine cylinders.
(iii) Coupled Cam Phasing
Valvetrains with coupled (or coordinated) cam phasing can modify
the timing of both the inlet valves and the exhaust valves an equal
amount by phasing the camshaft of an overhead valve engine.\158\ For
overhead valve engines, which have only one camshaft to actuate both
inlet and exhaust valves, couple cam phasing is the only variable valve
timing implementation option available and requires only one cam
phaser.\159\
---------------------------------------------------------------------------
\158\ Although couple cam phasing appears only in the single
overhead cam and overhead valve branches of the decision tree, it is
noted that a single phaser with a secondary chain drive would allow
couple cam phasing to be applied to direct overhead cam engines.
Since this would potentially be adopted on a limited number of
direct overhead cam engines NHTSA did not include it in that branch
of the decision tree.
\159\ It is also noted that coaxial camshaft developments would
allow other variable valve timing options to be applied to overhead
valve engines. However, since they would potentially be adopted on a
limited number of overhead valve engines, NHTSA did not include them
in the decision tree.
---------------------------------------------------------------------------
Based on the 2012-2016 light-duty final rule, previously-received
confidential manufacturer data, and the NESCCAF report, NHTSA and EPA
estimated the effectiveness of couple cam phasing to be between 1 and 4
percent. NHTSA and EPA reviewed this estimate for purposes of the NPRM,
and continue to find it accurate.
In the 2012-2016 light-duty final rule, the agencies estimated a
$41 cost per cam phaser not including any markup (2007$). NHTSA and EPA
believe that this estimate remains accurate. Using the new indirect
cost multiplier of 1.17, for a low complexity technology, the
compliance cost per cam phaser would be $46 (2008$) in the 2014 model
year. Time-based learning is applied to this
[[Page 74235]]
technology. This technology was considered for gasoline engines only.
(iv) Cylinder Deactivation
In conventional spark-ignited engines throttling the airflow
controls engine torque output. At partial loads, efficiency can be
improved by using cylinder deactivation instead of throttling. Cylinder
deactivation can improve engine efficiency by disabling or deactivating
(usually) half of the cylinders when the load is less than half of the
engine's total torque capability--the valves are kept closed, and no
fuel is injected--as a result, the trapped air within the deactivated
cylinders is simply compressed and expanded as an air spring, with
reduced friction and heat losses. The active cylinders combust at
almost double the load required if all of the cylinders were operating.
Pumping losses are significantly reduced as long as the engine is
operated in this ``part-cylinder'' mode.
Cylinder deactivation control strategy relies on setting maximum
manifold absolute pressures or predicted torque within which it can
deactivate the cylinders. Noise and vibration issues reduce the
operating range to which cylinder deactivation is allowed, although
manufacturers are exploring vehicle changes that enable increasing the
amount of time that cylinder deactivation might be suitable. Some
manufacturers may choose to adopt active engine mounts and/or active
noise cancellations systems to address Noise Vibration and Harshness
(NVH) concerns and to allow a greater operating range of activation.
Cylinder deactivation is a technology keyed to more lightly loaded
operation, and so may be a less likely technology choice for
manufacturers designing for effectiveness in the loaded condition
required for testing, and in the real world that involves frequent
operation with heavy loads.
Cylinder deactivation has seen a recent resurgence thanks to better
valvetrain designs and engine controls. General Motors and Chrysler
Group have incorporated cylinder deactivation across a substantial
portion of their V8-powered lineups.
Effectiveness improvements scale roughly with engine displacement-
to-vehicle weight ratio: the higher displacement-to-weight vehicles,
operating at lower relative loads for normal driving, have the
potential to operate in part-cylinder mode more frequently.
NHTSA and EPA adjusted the 2012-2016 light-duty final rule
estimates using updated power to weight ratings of heavy-duty trucks
and confidential business information and confirmed a range of 3 to 4
percent for these vehicles, though as mentioned above there is
uncertainty over how often this technology would be exercised on the
test cycles, and a lower range may be warranted for HD vehicles.
NHTSA and EPA consider the costs for this technology to be
identical to that for V8 engines on light-duty trucks. As such, the
agencies have used the cost used in the 2012-2016 light-duty final
rule. Using the new markup of 1.17 for a low complexity technology
results in an estimate of $193 (2008$) in the 2014 model year. Time
based learning is applied to this technology. This technology was
considered for gasoline engines only.
(v) Stoichiometric Gasoline Direct Injection
SGDI engines inject fuel at high pressure directly into the
combustion chamber (rather than the intake port in port fuel
injection). SGDI requires changes to the injector design, an additional
high pressure fuel pump, new fuel rails to handle the higher fuel
pressures and changes to the cylinder head and piston crown design.
Direct injection of the fuel into the cylinder improves cooling of the
air/fuel charge within the cylinder, which allows for higher
compression ratios and increased thermodynamic efficiency without the
onset of combustion knock. Recent injector design advances, improved
electronic engine management systems and the introduction of multiple
injection events per cylinder firing cycle promote better mixing of the
air and fuel, enhance combustion rates, increase residual exhaust gas
tolerance and improve cold start emissions. SGDI engines achieve higher
power density and match well with other technologies, such as boosting
and variable valvetrain designs.
Several manufacturers have recently introduced vehicles with SGDI
engines, including GM and Ford and have announced their plans to
increase dramatically the number of SGDI engines in their portfolios.
The 2012-2016 light-duty final rule estimated the range of 1 to 2
percent for SGDI. NHTSA and EPA reviewed this estimate for purposes of
the NPRM, and continue to find it accurate.
Consistent with the 2012-2016 light-duty final rule, NHTSA and EPA
cost estimates for SGDI take into account the changes required to the
engine hardware, engine electronic controls, ancillary and NVH
mitigation systems. Through contacts with industry NVH suppliers, and
manufacturer press releases, the agencies believe that the NVH
treatments will be limited to the mitigation of fuel system noise,
specifically from the injectors and the fuel lines. For this analysis,
the agencies have estimated the costs at $395 (2008$) in the 2014 model
year. Time based learning is applied to this technology. This
technology was considered for gasoline engines only, as diesel engines
already employ direct injection.
(b) Diesel Engine Technologies
Diesel engines have several characteristics that give them superior
fuel efficiency compared to conventional gasoline, spark-ignited
engines. Pumping losses are much lower due to lack of (or greatly
reduced) throttling. The diesel combustion cycle operates at a higher
compression ratio, with a very lean air/fuel mixture, and turbocharged
light-duty diesels typically achieve much higher torque levels at lower
engine speeds than equivalent-displacement naturally-aspirated gasoline
engines. Additionally, diesel fuel has a higher energy content per
gallon.\160\ However, diesel fuel also has a higher carbon to hydrogen
ratio, which increases the amount of CO2 emitted per gallon
of fuel used by approximately 15 percent over a gallon of gasoline.
---------------------------------------------------------------------------
\160\ Burning one gallon of diesel fuel produces about 15
percent more carbon dioxide than gasoline due to the higher density
and carbon to hydrogen ratio.
---------------------------------------------------------------------------
Based on confidential business information and the 2010 NAS Report,
two major areas of diesel engine design will be improved during the
2014-2018 timeframe. These areas include aftertreatment improvements
and a broad range of engine improvements.
(i) Aftertreatment Improvements
The HD diesel pickup and van segment has largely adopted the SCR
type of aftertreatment system to comply with criteria pollutant
emission standards. As the experience base for SCR expands over the
next few years, many improvements in this aftertreatment system such as
construction of the catalyst, thermal management, and reductant
optimization will result in a significant reduction in the amount of
fuel used in the process. This technology was not considered in the
2012-2016 light-duty final rule. Based on confidential business
information, EPA and NHTSA estimate the reduction in CO2 as
a result of these improvements at 3 to 5 percent.
The agencies have estimated the cost of this technology at $25 for
each percentage improvement in fuel consumption. This estimate is based
on
[[Page 74236]]
the agencies' belief that this technology is, in fact, a very cost
effective approach to improving fuel consumption. As such, $25 per
percent improvement is considered a reasonable cost. This cost would
cover the engineering and test cell related costs necessary to develop
and implement the improved control strategies that would allow for the
improvements in fuel consumption. Importantly, the engineering work
involved would be expected to result in cost savings to the
aftertreatment and control hardware (lower platinum group metal
loadings, lower reductant dosing rates, etc.). Those savings are
considered to be included in the $25 per percent estimate described
here. Given the 4 percent average expected improvement in fuel
consumption results in an estimated cost of $110 (2008$) for a 2014
model year truck or van. This estimate includes a low complexity ICM of
1.17 and time based learning from 2012 forward.
(ii) Engine Improvements
Diesel engines in the HD pickup and van segment are expected to
have several improvements in their base design in the 2014-2018
timeframe. These improvements include items such as improved combustion
management, optimal turbocharger design, and improved thermal
management. This technology was not considered in the 2012-2016 light-
duty final rule. Based on confidential business information, EPA and
NHTSA estimate the reduction in CO2 as a result of these
improvements at 4 to 6 percent.
The cost for this technology includes costs associated with low
temperature exhaust gas recirculation, improved turbochargers and
improvements to other systems and components. These costs are
considered collectively in our costing analysis and termed ``diesel
engine improvements.'' The agencies have estimated the cost of diesel
engine improvements at $147 based on the cost estimates for several
individual technologies. Specifically, the direct manufacturing costs
we have estimated are: improved cylinder head, $9; turbo efficiency
improvements, $16; EGR cooler improvements, $3; higher pressure fuel
rail, $10; improved fuel injectors, $13; improved pistons, $2; and
reduced valve train friction, $94. All values are in 2008 dollars and
are applicable in the 2014MY. Applying a low complexity ICM of 1.17
results in a cost of $172 (2008$) applicable in the 2014MY. We consider
time based learning to be appropriate for these technologies.
(c) Transmission Technologies
NHTSA and EPA have also reviewed the transmission technology
estimates used in the 2012-2016 light-duty final rule. In doing so,
NHTSA and EPA considered or reconsidered all available sources and
updated the estimates as appropriate. The section below describes each
of the transmission technologies considered for this proposal.
(i) Improved Automatic Transmission Control (Aggressive Shift Logic and
Early Torque Converter Lockup)
Calibrating the transmission shift schedule to upshift earlier and
quicker, and to lock-up or partially lock-up the torque converter under
a broader range of operating conditions can reduce fuel consumption and
CO2 emissions. However, this operation can result in a
perceptible degradation in NVH. The degree to which NVH can be degraded
before it becomes noticeable to the driver is strongly influenced by
characteristics of the vehicle, and although it is somewhat subjective,
it always places a limit on how much fuel consumption can be improved
by transmission control changes. Given that the Aggressive Shift Logic
and Early Torque Converter Lockup are best optimized simultaneously due
to the fact that adding both of them primarily requires only minor
modifications to the transmission or calibration software, these two
technologies are combined in the modeling. We consider these
technologies to be present in the baseline, since 6-speed automatic
transmissions are installed in the majority of Class 2b and 3 trucks in
the 2010 model year timeframe.
(ii) Automatic 6- and 8-Speed Transmissions
Manufacturers can also choose to replace 4- 5- and 6-speed
automatic transmissions with 8-speed automatic transmissions.
Additional ratios allow for further optimization of engine operation
over a wider range of conditions, but this is subject to diminishing
returns as the number of speeds increases. As additional planetary gear
sets are added (which may be necessary in some cases to achieve the
higher number of ratios), additional weight and friction are
introduced. Also, the additional shifting of such a transmission can be
perceived as bothersome to some consumers, so manufacturers need to
develop strategies for smooth shifts. Some manufacturers are replacing
4- and 5-speed automatics with 6-speed automatics already, and 7- and
8-speed automatics have entered production in light-duty vehicles,
albeit in lower-volume applications in luxury and performance oriented
cars.
As discussed in the light-duty final GHG rule, confidential
manufacturer data projected that 6-speed transmissions could
incrementally reduce fuel consumption by 0 to 5 percent from a 4-speed
automatic transmission, while an 8-speed transmission could
incrementally reduce fuel consumption by up to 6 percent from a 4-speed
automatic transmission. GM has publicly claimed a fuel economy
improvement of up to 4 percent for its new 6-speed automatic
transmissions.\161\
---------------------------------------------------------------------------
\161\ General Motors, news release, ``From Hybrids to Six-
Speeds, Direct Injection And More, GM's 2008 Global Powertrain
Lineup Provides More Miles with Less Fuel'' (released Mar. 6, 2007).
Available at http://www.gm.com/experience/fuel_economy/news/2007/adv_engines/2008-powertrain-lineup-082707.jsp (last accessed Sept.
18, 2008).
---------------------------------------------------------------------------
NHTSA and EPA reviewed and revised these effectiveness estimates
based on actual usage statistics and testing methods for these vehicles
along with confidential business information. When combined with
improved automatic transmission control, the agencies estimate the
effectiveness for a conversion from a 4 to a 6-speed transmission to be
5.3% and a conversion from a 6 to 8-speed transmission to be 1.7%.
While 8-speed transmissions were not considered in the 2012-2016 light-
duty final rule, they are considered as a technology of choice for this
analysis in that manufacturers are expected to upgrade the 6-speed
automatic transmissions being implemented today with 8-speed automatic
transmissions in the 2014-2018 timeframe. For this proposal, we are
estimating the cost of an 8-speed automatic transmission at $231
(2008$) relative to a 6-speed automatic transmission in the 2014 model
year. This estimate is based from the 2010 NAS Report and we have
applied a low complexity ICM of 1.17 and time based learning. This
technology applies to both gasoline and diesel trucks and vans.
(d) Electrification/Accessory Technologies
(i) Electrical Power Steering or Electrohydraulic Power Steering
Electric power steering (EPS) or Electrohydraulic power steering
(EHPS) provides a potential reduction in CO2 emissions and
fuel consumption over hydraulic power steering because of reduced
overall accessory loads. This eliminates the parasitic losses
[[Page 74237]]
associated with belt-driven power steering pumps which consistently
draw load from the engine to pump hydraulic fluid through the steering
actuation systems even when the wheels are not being turned. EPS is an
enabler for all vehicle hybridization technologies since it provides
power steering when the engine is off. EPS may be implemented on most
vehicles with a standard 12V system. Some heavier vehicles may require
a higher voltage system which may add cost and complexity.
The 2012-2016 light-duty final rule estimated a 1 to 2 percent
effectiveness based on the 2002 NAS report for light-duty vehicle
technologies, a Sierra Research report, and confidential manufacturer
data. NHTSA and EPA reviewed these effectiveness estimates and found
them to be accurate, thus they have been retained for purposes of this
NPRM.
NHTSA and EPA adjusted the EPS cost for the current rulemaking
based on a review of the specification of the system. Adjustments were
made to include potentially higher voltage or heavier duty system
operation for HD pickups and vans. Accordingly, higher costs were
estimated for systems with higher capability. After accounting for the
differences in system capability and applying the ICM markup of low
complexity technology of 1.17, the estimated costs for this proposal
are $108 for a MY 2014 truck or van (2008$). As EPS systems are in
widespread usage today, time-based learning is deemed applicable. EHPS
systems are considered to be of equal cost and both are considered
applicable to gasoline and diesel engines.
(ii) Improved Accessories
The accessories on an engine, including the alternator, coolant and
oil pumps are traditionally mechanically-driven. A reduction in
CO2 emissions and fuel consumption can be realized by
driving them electrically, and only when needed (``on-demand'').
Electric water pumps and electric fans can provide better control
of engine cooling. For example, coolant flow from an electric water
pump can be reduced and the radiator fan can be shut off during engine
warm-up or cold ambient temperature conditions which will reduce warm-
up time, reduce warm-up fuel enrichment, and reduce parasitic losses.
Indirect benefit may be obtained by reducing the flow from the
water pump electrically during the engine warm-up period, allowing the
engine to heat more rapidly and thereby reducing the fuel enrichment
needed during cold starting of the engine. Further benefit may be
obtained when electrification is combined with an improved, higher
efficiency engine alternator. Intelligent cooling can more easily be
applied to vehicles that do not typically carry heavy payloads, so
larger vehicles with towing capacity present a challenge, as these
vehicles have high cooling fan loads.\162\
---------------------------------------------------------------------------
\162\ In the CAFE model, improved accessories refers solely to
improved engine cooling. However, EPA has included a high efficiency
alternator in this category, as well as improvements to the cooling
system.
---------------------------------------------------------------------------
The agencies considered whether to include electric oil pump
technology for the rulemaking. Because it is necessary to operate the
oil pump any time the engine is running, electric oil pump technology
has insignificant effect on efficiency. Therefore, the agencies decided
to not include electric oil pump technology for this proposal.
NHTSA and EPA jointly reviewed the estimates of 1 to 2 percent
effectiveness estimates used in the 2012-2016 light-duty final rule and
found them to be accurate for Improved Electrical Accessories.
Consistent with the 2012-2016 light-duty final rule, the agencies have
estimated the cost of this technology at $88 (2008$) including a low
complexity ICM of 1.17. This cost is applicable in the 2014 model year.
Improved accessory systems are in production currently and thus time-
based learning is applied. This technology was considered for diesel
trucks and vans only.
(e) Vehicle Technologies
(i) Mass Reduction
Reducing a vehicle's mass, or down-weighting the vehicle, decreases
fuel consumption by reducing the energy demand needed to overcome
forces resisting motion, and rolling resistance. Manufacturers employ a
systematic approach to mass reduction, where the net mass reduction is
the addition of a direct component or system mass reduction plus the
additional mass reduction taken from indirect ancillary systems and
components, as a result of full vehicle optimization, effectively
compounding or obtaining a secondary mass reduction from a primary mass
reduction. For example, use of a smaller, lighter engine with lower
torque-output subsequently allows the use of a smaller, lighter-weight
transmission and drive line components. Likewise, the compounded weight
reductions of the body, engine and drivetrain reduce stresses on the
suspension components, steering components, wheels, tires and brakes,
allowing further reductions in the mass of these subsystems. The
reductions in unsprung masses such as brakes, control arms, wheels and
tires further reduce stresses in the suspension mounting points. This
produces a compounding effect of mass reductions.
Estimates of the synergistic effects of mass reduction and the
compounding effect that occurs along with it can vary significantly
from one report to another. For example, in discussing its estimate, an
Auto-Steel Partnership report states that ``These secondary mass
changes can be considerable--estimated at an additional 0.7 to 1.8
times the initial mass change.''Sec. \163\ This means for each one
pound reduction in a primary component, up to 1.8 pounds can be reduced
from other structures in the vehicle (i.e., a 180 percent factor). The
report also discusses that a primary variable in the realized secondary
weight reduction is whether or not the powertrain components can be
included in the mass reduction effort, with the lower end estimates
being applicable when powertrain elements are unavailable for mass
reduction. However, another report by the Aluminum Association, which
primarily focuses on the use of aluminum as an alternative material for
steel, estimated a factor of 64 percent for secondary mass reduction
even though some powertrain elements were considered in the
analysis.\164\ That report also notes that typical values for this
factor vary from 50 to 100 percent. Although there is a wide variation
in stated estimates, synergistic mass reductions do exist, and the
effects result in tangible mass reductions. Mass reductions in a single
vehicle component, for example a door side impact/intrusion system, may
actually result in a significantly higher weight savings in the total
vehicle, depending on how well the manufacturer integrates the
modification into the overall vehicle design. Accordingly, care must be
taken when reviewing reports on weight reduction methods and practices
to ascertain if compounding effects have been considered or not.
---------------------------------------------------------------------------
\163\ ``Preliminary Vehicle Mass Estimation Using Empirical
Subsystem Influence Coefficients,'' Malen, D.E., Reddy, K. Auto-
Steel Partnership Report, May 2007, Docket EPA-HQ-OAR-2009-0472-
0169. Accessed on the Internet on May 30, 2009 at: http://www.a-sp.org/database/custom/Mass%20Compounding%20-%20Final%20Report.pdf.
\164\ ``Benefit Analysis: Use of Aluminum Structures in
Conjunction with Alternative Powertrain Technologies in
Automobiles,'' Bull, M. Chavali, R., Mascarin, A., Aluminum
Association Research Report, May 2008, Docket EPA-HQ-OAR-2009-0472-
0168. Accessed on the Internet on April 30, 2009 at: http://www.autoaluminum.org/downloads/IBIS-Powertrain-Study.pdf.
---------------------------------------------------------------------------
[[Page 74238]]
Mass reduction is broadly applicable across all vehicle subsystems
including the engine, exhaust system, transmission, chassis,
suspension, brakes, body, closure panels, glazing, seats and other
interior components, engine cooling systems and HVAC systems. It is
estimated that up to 1.25 kilograms of secondary weight savings can be
achieved for every kilogram of weight saved on a vehicle when all
subsystems are redesigned to take into account the initial primary
weight savings.165 166
---------------------------------------------------------------------------
\165\ ``Future Generation Passenger Compartment-Validation (ASP
241)'' Villano, P.J., Shaw, J.R., Polewarczyk, J., Morgans, S.,
Carpenter, J.A., Yocum, A.D., in ``Lightweighting Materials--FY 2008
Progress Report,'' U.S. Department of Energy, Office of Energy
Efficiency and Renewable Energy, Vehicle Technologies Program, May
2009, Docket EPA-HQ-OAR-2009-0472-0190.
\166\ ``Preliminary Vehicle Mass Estimation Using Empirical
Subsystem Influence Coefficients,'' Malen, D.E., Reddy, K. Auto-
Steel Partnership Report, May 2007, Docket EPA-HQ-OAR-2009-0472-
0169. Accessed on the Internet on May 30, 2009 at: http://www.a-sp.org/database/custom/Mass%20Compounding%20-%20Final%20Report.pdf.
---------------------------------------------------------------------------
Mass reduction can be accomplished by proven methods such as:
Smart Design: Computer aided engineering (CAE) tools can
be used to better optimize load paths within structures by reducing
stresses and bending moments applied to structures. This allows better
optimization of the sectional thicknesses of structural components to
reduce mass while maintaining or improving the function of the
component. Smart designs also integrate separate parts in a manner that
reduces mass by combining functions or the reduced use of separate
fasteners. In addition, some ``body on frame'' vehicles are redesigned
with a lighter ``unibody'' construction.
Material Substitution: Substitution of lower density and/
or higher strength materials into a design in a manner that preserves
or improves the function of the component. This includes substitution
of high-strength steels, aluminum, magnesium or composite materials for
components currently fabricated from mild steel.
Reduced Powertrain Requirements: Reducing vehicle weight
sufficiently allows for the use of a smaller, lighter and more
efficient engine while maintaining or increasing performance.
Approximately half of the reduction is due to these reduced powertrain
output requirements from reduced engine power output and/or
displacement, changes to transmission and final drive gear ratios. The
subsequent reduced rotating mass (e.g., transmission, driveshafts/
halfshafts, wheels and tires) via weight and/or size reduction of
components are made possible by reduced torque output requirements.
Automotive companies have largely used weight savings in
some vehicle subsystems to offset or mitigate weight gains in other
subsystems from increased feature content (sound insulation,
entertainment systems, improved climate control, panoramic roof, etc.).
Lightweight designs have also been used to improve vehicle
performance parameters by increased acceleration performance or
superior vehicle handling and braking.
Many manufacturers have already announced proposed future products
plans reducing the weight of a vehicle body through the use of high
strength steel body-in-white, composite body panels, magnesium alloy
front and rear energy absorbing structures reducing vehicle weight
sufficiently to allow a smaller, lighter and more efficient engine.
Nissan will be reducing average vehicle curb weight by 15% by
2015.\167\ Ford has identified weight reductions of 250 to 750 lb per
vehicle as part of its implementation of known technology within its
sustainability strategy between 2011 and 2020.\168\ Mazda plans to
reduce vehicle weight by 220 pounds per vehicle or more as models are
redesigned. 169, 170 Ducker International estimates that the
average curb weight of light-duty vehicle fleet will decrease
approximately 2.8% from 2009 to 2015 and approximately 6.5% from 2009
to 2020 via changes in automotive materials and increased change-over
from previously used body-on-frame automobile and light-truck designs
to newer unibody designs.167 While the opportunity for mass reductions
available to the light-duty fleet may not in all cases be applied
directly to the heavy-duty fleet due to the different designs for the
expected duty cycles of a ``work'' vehicle, mass reductions are still
available particularly to areas unrelated to the components necessary
for the work vehicle aspects.
---------------------------------------------------------------------------
\167\ ``Lighten Up!,'' Brooke, L., Evans, H. Automotive
Engineering International, Vol. 117, No. 3, March 2009.
\168\ ``2008/9 Blueprint for Sustainability,'' Ford Motor
Company. Available at: http://www.ford.com/go/sustainability (last
accessed February 8, 2010).
\169\ ``Mazda to cut vehicle fuel consumption 30 percent by
2015,'' Mazda press release, June 23, 2009. Available at: http://www.mazda.com/publicity/release/2008/200806/080623.html(last
accessed February 8, 2010).
\170\ ``Mazda: Don't believe hot air being emitted by hybrid
hype,'' Greimel, H. Automotive News, March 30, 2009.
---------------------------------------------------------------------------
Due to the payload and towing requirements of these heavy-duty
vehicles, engine downsizing was not considered in the estimates for
CO2 reduction in the area of mass reduction/material
substitution. NHTSA and EPA estimate that a 3 percent mass reduction
with no engine downsizing results in a 1 percent reduction in fuel
consumption. In addition, a 5 and 10 percent mass reduction with no
engine downsizing result in an estimated CO2 reduction of
1.6 and 3.2 percent respectively. These effectiveness values are 50% of
the 2012-2016 light-duty final rule values due to the elimination of
engine downsizing for this class of vehicle.
Consistent with the 2012-2016 light-duty final rule, the agencies
have estimated the cost of mass reduction at $1.32 per pound (2008$).
For this analysis, the agencies are estimating a 5% mass reduction or,
given the baseline weight of current trucks and vans, are estimating
costs of $462, $544, $513, and $576 for Class 2b gasoline, 2b diesel, 3
gasoline, 3 diesel trucks and vans, respectively. All values are in
2008 dollars, are applicable in the 2014 model year and include a low
complexity ICM of 1.17. Time based learning is considered applicable to
mass reduction technologies.
The agencies have recently completed work on an Interim Joint
Technical Assessment Report that considers light-duty GHG and fuel
economy standards for the years 2017 through 2025.\171\ In that report,
the agencies have used updated cost estimates for mass reduction which
were not available in time for use in this analysis but could be used
in the final analysis. The agencies request comment on which mass
reduction costs--those used in this draft analysis or those used in the
Joint Technical Assessment Report--would be most appropriate for Class
2b & 3 trucks and vans along with supporting information.
---------------------------------------------------------------------------
\171\ ``Interim Joint Technical Assessment Report: Light-Duty
Vehicle Greenhouse Gas Emission Standards and Corporate Average Fuel
Economy Standards for Model Years 2017-2025;'' September 2010;
available at http://epa.gov/otaq/climate/regulations/ldv-ghg-tar.pdf
and in the docket for this rule.
---------------------------------------------------------------------------
(ii) Low Rolling Resistance Tires
Tire rolling resistance is the frictional loss associated mainly
with the energy dissipated in the deformation of the tires under load
and thus influences fuel efficiency and CO2 emissions. Other
tire design characteristics (e.g., materials, construction, and tread
design) influence durability, traction (both wet and dry grip), vehicle
handling, and ride comfort in addition to rolling resistance. A typical
LRR tire's attributes would include: increased tire inflation
[[Page 74239]]
pressure, material changes, and tire construction with less hysteresis,
geometry changes (e.g., reduced aspect ratios), and reduction in
sidewall and tread deflection. These changes would generally be
accompanied with additional changes to suspension tuning and/or
suspension design.
EPA and NHTSA estimated a 1 to 2 percent increase in effectiveness
with a 10 percent reduction in rolling resistance, which was based on
the 2010 NAS Report findings and consistent with the 2012-2016 light-
duty final rule.
Based on the 2012-2016 light-duty final rule and the 2010 NAS
Report, the agencies have estimated the cost for LRR tires to be $6 per
Class 2b truck or van, and $9 per Class 3 truck or van.\172\ The higher
cost for the Class 3 trucks and vans is due to the predominant use of
dual rear tires and, thus, 6 tires per truck. Due to the commodity-
based nature of this technology, cost learning is not applied. This
technology is considered applicable to both gasoline and diesel.
---------------------------------------------------------------------------
\172\ ``Tires and Passenger Vehicle Fuel Economy,''
Transportation Research Board Special Report 286, National Research
Council of the National Academies, 2006, Docket EPA-HQ-OAR-2009-
0472-0146.
---------------------------------------------------------------------------
(iii) Aerodynamic Drag Reduction
Many factors affect a vehicle's aerodynamic drag and the resulting
power required to move it through the air. While these factors change
with air density and the square and cube of vehicle speed,
respectively, the overall drag effect is determined by the product of
its frontal area and drag coefficient, Cd. Reductions in these
quantities can therefore reduce fuel consumption and CO2
emissions. Although frontal areas tend to be relatively similar within
a vehicle class (mostly due to market-competitive size requirements),
significant variations in drag coefficient can be observed. Significant
changes to a vehicle's aerodynamic performance may need to be
implemented during a redesign (e.g., changes in vehicle shape).
However, shorter-term aerodynamic reductions, with a somewhat lower
effectiveness, may be achieved through the use of revised exterior
components (typically at a model refresh in mid-cycle) and add-on
devices that currently being applied. The latter list would include
revised front and rear fascias, modified front air dams and rear
valances, addition of rear deck lips and underbody panels, and lower
aerodynamic drag exterior mirrors.
The 2012-2016 light-duty final rule estimated that a fleet average
of 10 to 20 percent total aerodynamic drag reduction is attainable
which equates to incremental reductions in fuel consumption and
CO2 emissions of 2 to 3 percent for both cars and trucks.
These numbers are generally supported by confidential manufacturer data
and public technical literature. For the heavy-duty truck category, a 5
to 10 percent total aerodynamic drag reduction was considered due to
the different structure and use of these vehicles equating to
incremental reductions in fuel consumption and CO2 emissions
of 1 to 2 percent.
Consistent with the 2012-2016 light-duty final rule, the agencies
have estimated the cost for this technology at $54 (2008$) including a
low complexity ICM of 1.17. This cost is applicable in the 2014 model
year to both gasoline and diesel trucks and vans.
(3) What are the projected technology packages' effectiveness and cost?
The assessment of the proposed technology effectiveness was
developed through the use of the EPA Lumped Parameter model developed
for the light-duty rule. Many of the technologies were common with the
light-duty assessment but the effectiveness of individual technologies
was appropriately adjusted to match the expected effectiveness when
implemented in a heavy-duty application. The model then uses the
individual technology effectiveness levels but then takes into account
technology synergies. The model is also designed to prevent double
counting from technologies that may directly or indirectly impact the
same physical attribute (e.g., pumping loss reductions).
To achieve the levels of the proposed standards for gasoline and
diesel powered heavy-duty vehicles, the technology packages were
determined to generally require the technologies previously discussed
respective to unique gasoline and diesel technologies. Although some of
the technologies may already be implemented in a portion of heavy-duty
vehicles, none of the technologies discussed are considered ubiquitous
in the heavy-duty fleet. Also, as would be expected, the available test
data shows that some vehicle models will not need the full complement
of available technologies to achieve the proposed standards.
Furthermore, many technologies can be further improved (e.g.,
aerodynamic improvements) from today's best levels, and so allow for
compliance without needing to apply a technology that a manufacturer
might deem less desirable.
Technology costs for HD pickup trucks and vans are shown in Table
III-11.
[[Page 74240]]
[GRAPHIC] [TIFF OMITTED] TP30NO10.037
(4) Reasonableness of the Proposed Standards
The proposed standards are based on the application of the control
technologies described in this section. These technologies are
available within the lead time provided, as discussed in draft RIA
Chapter 2.3. These controls are estimated to add costs of approximately
$1,249 to $1,592 for MY 2018 heavy-duty pickups and vans. Reductions
associated with these costs and technologies are considerable,
estimated at a 12 percent reduction of CO2eq emissions from
the MY 2010 baseline for gasoline engine-equipped vehicles and 17
percent for diesel engine equipped vehicles, estimated to result in
reductions of 21 MMT of CO2eq emissions over the lifetimes
of 2014 through 2018 MY vehicles.\173\ The reductions are cost
effective, estimated at $100 per ton of CO2eq removed in
2030.\174\ This cost is consistent with the light-duty rule which was
estimated at $100 per ton of CO2eq removed in 2020 excluding
fuel savings. Moreover, taking into account the fuel savings associated
with the program, the cost becomes -$200 per ton of CO2eq in
2030. The cost of controls is fully recovered due to the associated
fuel savings, with a payback period within the fifth and sixth year of
ownership, as shown in Table VIII-6 below. Given the large, cost
effective emission reductions based on use of feasible technologies
which are available in the lead time provided, plus the lack of adverse
impacts on vehicle safety or utility, EPA and NHTSA regard these
proposed standards as appropriate and consistent with our respective
statutory authorities under CAA section 202(a) and NHTSA's EISA
authority under 49 U.S.C. 32902(k)(2).
---------------------------------------------------------------------------
\166\ See Table VI-4.
\167\ See Table VIII-3.
---------------------------------------------------------------------------
C. Class 2b-8 Vocational Vehicles
Vocational vehicles cover a wide variety of applications which
influence both the body style and usage patterns. They also are built
using a complex process, which includes additional parties such as body
builders. These factors have led the agencies to propose a vehicle
standard for vocational vehicles for the first phase of the program
that relies on less extensive addition of technology as well as
focusing on the chassis manufacturer as the manufacturer subject to the
standard. We believe that future rulemakings will consider increased
stringency and possibly more application-specific standards. The
agencies are proposing standards for the diesel and gasoline engines
used in vocational vehicles, similar to those discussed above for Class
7 and 8 tractors.
(1) What technologies did the agencies consider to reduce the
CO2 emissions and fuel consumption of vocational vehicles?
Similar to the approach taken with tractors, the agencies evaluated
aerodynamic, tire, idle reduction, weight reduction, hybrid powertrain,
and engine technologies and their impact on reducing fuel consumption
and GHG emissions. The engines used in vocational vehicles include both
gasoline and diesel engines, thus, each type is discussed separately
below. As explained in Section II.D.1.b, the proposed regulatory
structure for heavy-duty engines separates the compression ignition (or
``diesel'') engines into three regulatory subcategories--light heavy,
medium heavy, and heavy heavy diesel
[[Page 74241]]
engines--while spark ignition (or ``gasoline'') engines are a single
regulatory subcategory. Therefore, the subsequent discussion will
assess each type of engine separately.
(a) Vehicle Technologies
Vocational vehicles typically travel fewer miles than combination
tractors. They also tend to be used in more urban locations (with
consequent stop and start drive cycles). Therefore the average speed of
vocational vehicles is significantly lower than tractors. This has a
significant effect on the types of technologies that are appropriate to
consider for reducing CO2 emissions and fuel consumption.
The agencies considered the type of technologies for vocational
vehicles based on the energy losses of a typical vocational vehicle.
The technologies are similar to the ones considered for tractors.
Argonne National Lab conducted an energy audit using simulation tools
to evaluate the energy losses of vocational vehicles, such as a Class 6
pickup and delivery truck. Argonne found that 74 percent of the energy
losses are attributed to the engine, 13 percent to tires, 9 percent to
aerodynamics, two percent to transmission losses, and the remaining
four percent of losses to axles and accessories for a medium-duty truck
traveling at 30 mph.\175\
---------------------------------------------------------------------------
\175\ Argonne National Lab. Evaluation of Fuel Consumption
Potential of Medium and Heavy-duty Vehicles through Modeling and
Simulation. October 2009. Page 89.
---------------------------------------------------------------------------
Low Rolling Resistance Tires: Tires are the second largest
contributor to energy losses of vocational vehicles, as found in the
energy audit conducted by Argonne National Lab (as just mentioned). The
range of rolling resistance of tires used on vocational vehicles today
is large. This is in part due to the fact that the competitive pressure
to improve rolling resistance of vocational vehicle tires has been less
than that found in the line haul tire market. In addition, the drive
cycles typical for these applications often lead truck buyers to value
tire traction and durability more heavily than rolling resistance.
Therefore, the agencies concluded that a regulatory program that seeks
to optimize tire rolling resistance in addition to traction and
durability can bring about fuel consumption and CO2 emission
reductions from this segment. The 2010 NAS report states that rolling
resistance impact on fuel consumption reduces with mass of the vehicle
and with drive cycles with more frequent starts and stops. The report
found that the fuel consumption reduction opportunity for reduced
rolling resistance ranged between one and three percent in the 2010
through 2020 timeframe.\176\ The agencies estimate that average rolling
resistance from tires in 2010 model year can be reduced by 10 percent
by 2014 model year based on the tire development achievements over the
last several years in the line haul truck market which would lead to a
2 percent reduction in fuel consumption based on GEM.
---------------------------------------------------------------------------
\176\ See 2010 NAS Report, Note 111, page 146.
---------------------------------------------------------------------------
Aerodynamics: The Argonne National lab work shows that aerodynamics
have less of an impact on vocational vehicle energy losses than do
engines or tires. In addition, the aerodynamic performance of a
complete vehicle is significantly influenced by the body of the truck.
The agencies are not proposing to regulate body builders in this phase
of regulations for the reasons discussed in Section II. Therefore, we
are not basing any of the proposed standards for vocational vehicles on
aerodynamic improvements. Nor would aerodynamic performance be input
into GEM to demonstrate compliance.
Weight Reduction: NHTSA and EPA are also not basing any of the
proposed standards on use of vehicle weight reduction. Thus, vehicle
mass reductions would not be input into GEM. The vocational vehicle
models are not designed to be application-specific. Therefore weight
reductions are difficult to quantify.
Drivetrain: Optimization of vehicle gearing to engine performance
through selection of transmission gear ratios, final drive gear ratios
and tire size can play a significant role in reducing fuel consumption
and GHGs. Optimization of gear selection versus vehicle and engine
speed accomplished through driver training or automated transmission
gear selection can provide additional reductions. The 2010 NAS report
found that the opportunities to reduce fuel consumption in heavy-duty
vehicles due to transmission and driveline technologies in the 2015
timeframe ranged between 2 and 8 percent.\177\ Initially, the agencies
considered reflecting transmission choices and technology in our
standard setting process for both tractors and vocational vehicles (see
previous discussion above on automated transmissions for tractors). We
have however decided not to do so for the following reasons.
---------------------------------------------------------------------------
\177\ See 2010 NAS Report, Note 111, pp 134 and 137.
---------------------------------------------------------------------------
The primary factors that determine optimum gear selection are
vehicle weight, vehicle aerodynamics, vehicle speed, and engine
performance typically considered on a two dimensional map of engine
speed and torque. For a given power demand (determined by speed,
aerodynamics and vehicle mass) an optimum transmission and gearing
setup will keep the engine power delivery operating at the best speed
and torque points for highest engine efficiency. Since power delivery
from the engine is the product of speed and torque a wide range of
torque and speed points can be found that deliver adequate power, but
only a smaller subset will provide power with peak efficiency. Said
more generally, the design goal is for the transmission to deliver the
needed power to the vehicle while maintaining engine operation within
the engine's ``sweet spot'' for most efficient operation. Absent
information about vehicle mass and aerodynamics (which determines road
load at highway speeds) it is not possible to optimize the selection of
gear ratios for lowest fuel consumption. Truck and chassis
manufacturers today offer a wide range of tire sizes, final gear ratios
and transmission choices so that final bodybuilders can select an
optimal combination given the finished vehicle weight, general
aerodynamic characteristics and expected average speed. In order to set
fuel efficiency and GHG standards that would reflect these
optimizations, the agencies would need to regulate a wide range of
small entities that are final bodybuilders, would need to set a large
number of uniquely different standards to reflect the specific weight
and aerodynamic differences and finally would need test procedures to
evaluate these differences that would not themselves be excessively
burdensome. Finally, the agencies would need the underlying data
regarding effectively all of the vocational trucks produced today in
order to determine the appropriate standards. Because the market is
already motivated to reach these optimizations themselves today,
because we have insufficient data to determine appropriate standards,
and finally, because we believe the testing burden would be
unjustifiably high, we are not proposing to reflect transmission and
gear ratio optimization in our GEM model or in our standard setting.
We are broadly seeking comment on our reasons for not reflecting
these technology choices including recommendations for ways that the
agencies could effectively reflect transmission related improvements.
The agencies welcome comment on transmission and driveline technologies
[[Page 74242]]
specific to the vocational vehicle market that can achieve fuel
consumption and GHG emissions reductions.
Idle Reduction: Episodic idling by vocational vehicles occurs
during the workday, unlike the overnight idling of combination
tractors. Vocational vehicle idling can be divided into two typical
types. The first type is idling while waiting--such as during a pickup
or delivery. This type of idling can be reduced through automatic
engine shut-offs. The second type of idling is to accomplish PTO
operation, such as compacting garbage or operating a bucket. The
agencies have found only one study that quantifies the emissions due to
idling conducted by Argonne National Lab based on 2002 VIUS data.\178\
EPA conducted a work assignment to assist in characterizing PTO
operations. The study of a utility truck used in two different
environments (rural and urban) and a refuse hauler found that the PTO
operated on average 28 percent of time relative to the total time spent
driving and idling. The use of hybrid powertrains to reduce idling is
discussed below.
---------------------------------------------------------------------------
\178\ Gaines, Linda, A. Vyas, J. Anderson (Argonne National
Laboratory). Estimation of Fuel Use by Idling Commercial Trucks.
January 2006.
---------------------------------------------------------------------------
Hybrid Powertrains: Several types of vocational vehicles are well
suited for hybrid powertrains. Vehicles such as utility or bucket
trucks, delivery vehicles, refuse haulers, and buses have operational
usage patterns with either a significant amount of stop-and-go activity
or spend a large portion of their operating hours idling the main
engine to operate a PTO unit. The industry is currently developing
three types of hybrid powertrain systems--hydraulic, electric, and
plug-in electric. The hybrids developed to date have seen fuel
consumption and CO2 emissions reductions between 20 and 50
percent in the field. However, there are still some key issues that are
restricting the penetration of hybrids, including overall system cost,
battery technology, and lack of cost-effective electrified accessories.
The agencies are proposing to include hybrid powertrains as a
technology to meet the vocational vehicle standard, as described in
Section IV. However, the agencies are not proposing a vocational
vehicle standard predicated on using a specific penetration of hybrids.
We have not predicated the standards based on the use of hybrids
reflecting the still nascent level of technology development and the
very small fraction of vehicle sales they would be expected to account
for in this timeframe--on the order of only a percent or two. Were we
to overestimate the number of hybrids that could be produced, we would
set a standard that is not feasible. We believe that it is more
appropriate given the status of technology development and our high
hopes for future advancements in hybrid technologies to encourage their
production through incentives. The agencies welcome comments on this
approach.
(b) Gasoline Engine Technologies
The gasoline (or spark ignited) engines certified and sold as loose
engines into the heavy-duty truck market are typically large V8 and V10
engines produced by General Motors and Ford. The basic engine
architecture of these engines is the same as the versions used in the
heavy-duty pickup trucks and vans. Therefore, the technologies analyzed
by the agencies mirror the gasoline engine technologies used in the
heavy-duty pickup truck analysis in Section III.B above.
Building on the technical analysis underlying the 2012-2016 MY
light-duty vehicle rule, the agencies took a fresh look at technology
effectiveness values for purposes of this proposal using a starting
point the estimates from that rule. The agencies then considered the
impact of test procedures (such as higher test weight of HD pickup
trucks and vans) on the effectiveness estimates. The agencies also
considered other sources such as the 2010 NAS Report, recent CAFE
compliance data, and confidential manufacturer estimates of technology
effectiveness. NHTSA and EPA engineers reviewed effectiveness
information from the multiple sources for each technology and ensured
that such effectiveness estimates were based on technology hardware
consistent with the BOM components used to estimate costs.
The agencies note that the effectiveness values estimated for the
technologies may represent average values, and do not reflect the
potentially-limitless spectrum of possible values that could result
from adding the technology to different vehicles. For example, while
the agencies have estimated an effectiveness of 0.5 percent for low
friction lubricants, each vehicle could have a unique effectiveness
estimate depending on the baseline vehicle's oil viscosity rating. For
purposes of this NPRM, NHTSA and EPA believe that employing average
values for technology effectiveness estimates is an appropriate way of
recognizing the potential variation in the specific benefits that
individual manufacturers (and individual engines) might obtain from
adding a fuel-saving technology. However, the agencies seek comment on
whether additional levels of specificity beyond that already provided
would improve the analysis for the final rules, and if so, how those
levels of specificity should be analyzed.
Baseline Engine: Similar to the gasoline engine used as the
baseline in the light-duty GHG rule, the agencies assumed the baseline
engine in this segment to be a naturally aspirated, overhead valve V8
engine. The following discussion of effectiveness is generally in
comparison to 2010 baseline engine performance.
The technologies the agencies considered include the following:
Engine Friction Reduction: In addition to low friction lubricants,
manufacturers can also reduce friction and improve fuel consumption by
improving the design of engine components and subsystems. Examples
include improvements in low-tension piston rings, piston skirt design,
roller cam followers, improved crankshaft design and bearings, material
coatings, material substitution, more optimal thermal management, and
piston and cylinder surface treatments. The 2010 NAS, NESCCAF \179\ and
EEA \180\ reports as well as confidential manufacturer data used in the
light-duty vehicle rulemaking suggested a range of effectiveness for
engine friction reduction to be between 1 to 3 percent. NHTSA and EPA
continue to believe that this range is accurate.
---------------------------------------------------------------------------
\179\ Northeast States Center for a Clean Air Future. ``Reducing
Greenhouse Gas Emissions from Light-Duty Motor Vehicles.'' September
2004.
\180\ Energy and Environmental Analysis, Inc. ``Technology to
Improve the Fuel Economy of Light Duty Trucks to 2015.'' May 2006.
---------------------------------------------------------------------------
Coupled Cam Phasing: Valvetrains with coupled (or coordinated) cam
phasing can modify the timing of both the inlet valves and the exhaust
valves an equal amount by phasing the camshaft of a single overhead cam
engine or an overhead valve engine. Based on the 2012-2016 MY light-
duty vehicle rule, previously-received confidential manufacturer data,
and the NESCCAF report, NHTSA and EPA estimated the effectiveness of
couple cam phasing CCP to be between 1 and 4 percent. NHTSA and EPA
reviewed this estimate for purposes of the NPRM, and continue to find
it accurate.
Cylinder Deactivation: In conventional spark-ignited engines
throttling the airflow controls engine torque output. At partial loads,
efficiency can be improved by using cylinder deactivation instead of
throttling. Cylinder deactivation can improve engine efficiency by
disabling or deactivating (usually) half of the
[[Page 74243]]
cylinders when the load is less than half of the engine's total torque
capability--the valves are kept closed, and no fuel is injected--as a
result, the trapped air within the deactivated cylinders is simply
compressed and expanded as an air spring, with reduced friction and
heat losses. The active cylinders combust at almost double the load
required if all of the cylinders were operating. Pumping losses are
significantly reduced as long as the engine is operated in this ``part
cylinder'' mode. Effectiveness improvements scale roughly with engine
displacement-to-vehicle weight ratio--the higher displacement-to-weight
vehicles, operating at lower relative loads for normal driving, have
the potential to operate in part-cylinder mode more frequently.
Therefore, the agencies reduced the effectiveness assumed from this
technology for trucks because of the lower displacement-to-weight ratio
relative to light-duty vehicles. NHTSA and EPA adjusted the 2010 light-
duty vehicle final rule estimates using updated power to weight ratings
of heavy-duty trucks and confidential business information and
confirmed a range of 3 to 4 percent for these vehicles.
Stoichiometric gasoline direct injection: SGDI (also known as
spark-ignition direct injection engines) inject fuel at high pressure
directly into the combustion chamber (rather than the intake port in
port fuel injection). Direct injection of the fuel into the cylinder
improves cooling of the air/fuel charge within the cylinder, which
allows for higher compression ratios and increased thermodynamic
efficiency without the onset of combustion knock. Recent injector
design advances, improved electronic engine management systems and the
introduction of multiple injection events per cylinder firing cycle
promote better mixing of the air and fuel, enhance combustion rates,
increase residual exhaust gas tolerance and improve cold start
emissions. SGDI engines achieve higher power density and match well
with other technologies, such as boosting and variable valvetrain
designs. The 2012-2016 MY light-duty vehicle final rule estimated the
effectiveness of SGDI to be between 2 and 3 percent. NHTSA and EPA
revised these estimated accounting for the use and testing methods for
these vehicles along with confidential business information estimates
received from manufacturers while developing the proposal. Based on
these revisions, NHTSA and EPA estimate the range of 1 to 2 percent for
SGDI.
(c) Diesel Engine Technologies
Different types of diesel engines are used in vocational vehicles,
depending on the application. They fall into the categories of Light,
Medium, and Heavy Heavy-duty Diesel engines. The Light Heavy-duty
Diesel engines typically range between 4.7 and 6.7 liters displacement.
The Medium Heavy-duty Diesel engines typically have some overlap in
displacement with the Light Heavy-duty Diesel engines and range between
6.7 and 9.3 liters. The Heavy Heavy-duty Diesel engines typically are
represented by engines between 10.8 and 16 liters.
Baseline Engine: There are three baseline diesel engines, a Light,
Medium, and a Heavy Heavy-duty Diesel engine. The agencies developed
the baseline diesel engine as a 2010 model year engine with an
aftertreatment system which meets EPA's 0.2 grams of NOX/
bhp-hr standard with an SCR system along with EGR and meets the PM
emissions standard with a diesel particulate filter with active
regeneration. The engine is turbocharged with a variable geometry
turbocharger. The following discussion of technologies describes
improvements over the 2010 model year baseline engine performance,
unless otherwise noted. Further discussion of the baseline engine and
its performance can be found in Section III.C.2.(c)(i) below. The
following discussion of effectiveness is generally in comparison to
2010 baseline engine performance, and is in reference to performance in
terms of the Heavy-duty FTP that would be used for compliance for these
engine standards. This is in comparison to the steady state SET
procedure that would be used for compliance purposes for the engines
used in Class 7 and 8 tractors. See Section II.B.2.(i) above.
Turbochargers: Improved efficiency of a turbocharger compressor or
turbine could reduce fuel consumption by approximately 1 to 2 percent
over today's variable geometry turbochargers in the market today. The
2010 NAS report identified technologies such as higher pressure ratio
radial compressors, axial compressors, and dual stage turbochargers as
design paths to improve turbocharger efficiency.
Low Temperature Exhaust Gas Recirculation: Most LHDD, MHDD, and
HHDD engines sold in the U.S. market today use cooled EGR, in which
part of the exhaust gas is routed through a cooler (rejecting energy to
the engine coolant) before being returned to the engine intake
manifold. EGR is a technology employed to reduce peak combustion
temperatures and thus NOX. Low-temperature EGR uses a larger
or secondary EGR cooler to achieve lower intake charge temperatures,
which tend to further reduce NOX formation. If the
NOX requirement is unchanged, low-temperature EGR can allow
changes such as more advanced injection timing that will increase
engine efficiency slightly more than one percent. Because low-
temperature EGR reduces the engine's exhaust temperature, it may not be
compatible with exhaust energy recovery systems such as turbocompound
or a bottoming cycle.
Engine Friction Reduction: Reduced friction in bearings, valve
trains, and the piston-to-liner interface will improve efficiency. Any
friction reduction must be carefully developed to avoid issues with
durability or performance capability. Estimates of fuel consumption
improvements due to reduced friction range from 0.5 to 1.5
percent.\181\
---------------------------------------------------------------------------
\181\ TIAX, Assessment of Fuel Economy Technologies for Medium-
and Heavy-duty Vehicles, Final Report, Nov. 19, 2009, pg. 4-15.
---------------------------------------------------------------------------
Selective catalytic reduction: This technology is common on 2010
heavy-duty diesel engines. Because SCR is a highly effective
NOX aftertreatment approach, it enables engines to be
optimized to maximize fuel efficiency, rather than minimize engine-out
NOX. 2010 SCR systems are estimated to result in improved
engine efficiency of approximately 4 to 5 percent compared to a 2007
in-cylinder EGR-based emissions system and by an even greater
percentage compared to 2010 in-cylinder approaches.\182\ As more
effective low-temperature catalysts are developed, the NOX
conversion efficiency of the SCR system will increase. Next-generation
SCR systems could then enable still further efficiency improvements;
alternatively, these advances could be used to maintain efficiency
while down-sizing the aftertreatment. We estimate that continued
optimization of the catalyst could offer 1 to 2 percent reduction in
fuel use over 2010 model year systems in the 2014 model year.\183\ The
agencies also estimate that continued refinement and optimization of
the SCR systems could provide an additional 2 percent reduction in the
2017 model year.
---------------------------------------------------------------------------
\182\ Stanton, D. ``Advanced Diesel Engine Technology
Development for High Efficiency, Clean Combustion.'' Cummins, Inc.
Annual Progress Report 2008 Vehicle Technologies Program: Advanced
Combustion Engine Technologies, U.S. Department of Energy. Pp. 113-
116. December 2008.
\183\ TIAX Assessment of Fuel Economy Technologies for Medium
and Heavy-duty Vehicles, Report to National Academy of Sciences, Nov
19, 2009, pg. 4-9.
---------------------------------------------------------------------------
[[Page 74244]]
Improved Combustion Process: Fuel consumption reductions in the
range of 1 to 4 percent are identified in the 2010 NAS report through
improved combustion chamber design, higher fuel injection pressure,
improved injection shaping and timing, and higher peak cylinder
pressures.\184\
---------------------------------------------------------------------------
\184\ See 2010 NAS Report, Note 111, page 56.
---------------------------------------------------------------------------
Reduced Parasitic Loads: Accessories that are traditionally gear or
belt driven by a vehicle's engine can be optimized and/or converted to
electric power. Examples include the engine water pump, oil pump, fuel
injection pump, air compressor, power-steering pump, cooling fans, and
the vehicle's air-conditioning system. Optimization and improved
pressure regulation may significantly reduce the parasitic load of the
water, air and fuel pumps. Electrification may result in a reduction in
power demand, because electrically powered accessories (such as the air
compressor or power steering) operate only when needed if they are
electrically powered, but they impose a parasitic demand all the time
if they are engine driven. In other cases, such as cooling fans or an
engine's water pump, electric power allows the accessory to run at
speeds independent of engine speed, which can reduce power consumption.
The TIAX study used 2 to 4 percent fuel consumption improvement for
accessory electrification, with the understanding that electrification
of accessories will have more effect in short-haul/urban applications
and less benefit in line-haul applications.\185\
---------------------------------------------------------------------------
\185\ TIAX. 2009. Pages 3-5.
---------------------------------------------------------------------------
(2) What is the projected technology package's effectiveness and cost?
(a) Vocational Vehicles
(i) Baseline Vocational Vehicle Performance
The baseline vocational vehicle model is defined in GEM, as
described in draft RIA Chapter 4.4.6. The agencies used a baseline
rolling resistance coefficient for today's vocational vehicle fleet of
9 kg/metric ton.\186\ Further vehicle technology is not included in
this baseline, as discussed below in the discussion of the baseline
vocational vehicle. The baseline engine fuel consumption represents a
2010 model year diesel engine, as described in draft RIA Chapter 4.
Using these values, the baseline performance of these vehicles is
included in Table III-12.
---------------------------------------------------------------------------
\186\ The baseline tire rolling resistance for this segment of
vehicles was derived for the proposal based on the current baseline
tractor and passenger car tires. The baseline tractor drive tire has
a rolling resistance of 8.2 kg/metric ton based on SmartWay testing.
The average passenger car has a tire rolling resistance of 9.75 kg/
metric ton based on a presentation made to CARB by the Rubber
Manufacturer's Association. Additional details are available in the
draft RIA Chapter 2.
[GRAPHIC] [TIFF OMITTED] TP30NO10.038
(ii) Vocational Vehicle Technology Package
The proposed program for vocational vehicles for this phase of
regulatory standards is limited to performance of tire and engine
technologies. Aerodynamics technology, weight reduction, drive train
improvement, and hybrid power trains are not included for the reasons
discussed above in Section III.C(1). The agencies are seeking comment
on the appropriateness of this approach.
The assessment of the proposed technology effectiveness was
developed through the use of the GEM. To account for the two proposed
engine standards, EPA is proposing the use of a 2014 model year fuel
consumption map in GEM to derive the 2014 model year truck standard and
a 2017 model year fuel consumption map to derive the 2017 model year
truck standard. (These fuel consumption maps reflect the main standards
proposed for HD diesel engines, not the alternative standards.) EPA
estimates that the rolling resistance of tires can be reduced by 10
percent in the 2014 model year. The vocational vehicle standards for
all three regulatory categories were determined using a tire rolling
resistance coefficient of 8.1 kg/metric ton with a 100 percent
application rate by the 2014 model year. The set of input parameters
which are modeled in GEM are shown in Table III-13.
[GRAPHIC] [TIFF OMITTED] TP30NO10.039
[[Page 74245]]
The agencies developed the proposed standards by using the engine
and tire rolling resistance inputs in the GEM, as shown in Table III-
13. The percent reductions shown in Table III-14 reflect improvements
over the 2010 model year baseline vehicle with a 2010 model year
baseline engine.
[GRAPHIC] [TIFF OMITTED] TP30NO10.040
(iii) Technology Package Cost
EPA and NHTSA developed the costs of LRR tires based on the ICF
report. The estimated cost per truck is $155 (2008$) for LHD and MHD
trucks and $186 (2008$) for HHD trucks. These costs include a low
complexity ICM of 1.14 and are applicable in the 2014 model year.
(iv) Reasonableness of the Proposed Standards
The proposed standards would not only add only a small amount to
the vehicle cost, but are highly cost effective, an estimated $20 ton
of CO2eq per vehicle in 2030.\187\ This is even less than
the estimated cost effectiveness for CO2eq removal under the
light-duty vehicle rule, already considered by the agencies to be a
highly cost effective reduction.\188\ Moreover, the modest cost of
controls is recovered almost immediately due to the associated fuel
savings, as shown in the payback analysis included in Table VIII-7.
Given that the standards are technically feasible within the lead time
afforded by the 2014 model year, are inexpensive and highly cost
effective, and do not have other adverse potential impacts (e.g., there
are no projected negative impacts on safety or vehicle utility), the
proposed standards represent a reasonable choice under section 202(a)
of the CAA and NHTSA's EISA authority under 49 U.S.C. 32902(k)(2), and
the agencies believe that the standards are consistent with their
respective authorities.
---------------------------------------------------------------------------
\187\ See Section VIII.D.
\188\ The light-duty rule had an estimated cost per ton of $50
when considering the vehicle program costs only and a cost of -$210
per ton considering the vehicle program costs along with fuel
savings in 2030. See 75 FR 25515, Table III.H.3-1.
---------------------------------------------------------------------------
(v) Alternative Vehicle Standards Considered
The agencies are not proposing vehicle standards less stringent
than the proposed standards because the agencies believe these
standards are highly cost effective, as just explained.
The agencies considered proposing truck standards which are more
stringent reflecting the inclusion of hybrid powertrains in those
vocational vehicles where use of hybrid powertrains is appropriate. The
agencies estimate that a 25 percent utilization rate of hybrid
powertrains in MY 2017 vocational vehicles would add, on average,
$30,000 to the cost of each vehicle and more than double the cost of
the rule for this sector. See the draft RIA at Chapter 6.1.8. The
emission reductions associated with these very high costs appear to be
modest. See the draft RIA Table 6-14. In addition, the agencies are
proposing flexibilities in the form of generally applicable credit
opportunities for advanced technologies, to encourage use of hybrid
powertrains. See Section IV.C.2 below. The agencies welcome comments on
whether hybrid powertrain technologies are appropriate to consider for
the 2017 model year standard, or if not, then when would they be
appropriate.
(b) Gasoline Engines
(i) Baseline Gasoline Engine Performance
EPA and NHTSA developed the reference heavy-duty gasoline engines
to represent a 2010 model year engine compliant with the 0.2 g/bhp-hr
NOX standard for on-highway heavy-duty engines.
NHTSA and EPA developed the baseline fuel consumption and
CO2 emissions for the gasoline engines from manufacturer
reported CO2 values used in the certification of non-GHG
pollutants. The baseline engine for the analysis was developed to
represent a 2011 model year engine, because this is the most current
information available. The average CO2 performance of the
heavy-duty gasoline engines was 660 g/bhp-hour, which will be used as a
baseline. The baseline gasoline engines are all stoichiometric port
fuel injected V-8 engines without cam phasers or other variable valve
timing technologies. While they may reflect some degree of static valve
timing optimization for fuel efficiency they do not reflect the
potential to adjust timing with engine speed.
(ii) Gasoline Engine Technology Package Effectiveness
The gasoline engine technology package includes engine friction
reduction, coupled cam phasing, and SGDI to produce an overall five
percent reduction from the reference engine based on the Heavy-duty
Lumped Parameter model. The agencies are projecting a 100% application
rate of
[[Page 74246]]
this technology package to the heavy-duty gasoline engines, which
results in a CO2 standard of 627 g/bhp-hr and a fuel
consumption standard of 7.05 gallon/100 bhp-hr. As discussed in Section
II.D.b.ii, the agencies propose that the gasoline engine standards
begin in the 2016 model year based on the agencies' projection of the
engine redesign schedules of the small number of engines in this
category.
(iii) Gasoline Engine Technology Package Cost
For costs, the agencies reconsidered both the direct or ``piece''
costs and indirect costs of individual components of technologies. For
the direct costs, the agencies followed a BOM approach employed by
NHTSA and EPA in the 2012-2016 LD rule. NHTSA and EPA are proposing to
use the marked up gasoline engine technology costs developed for the HD
Pickup Truck and Van segment because they are made by the same
manufacturers (primarily by Ford and GM) and, the same products simply
sold as loose engines rather than complete vehicles. Hence the engine
cost estimates are fundamentally the same. The costs are summarized in
Table III-15. The costs shown in Table III-15 include a low complexity
ICM of 1.17 and are applicable in the 2016 model year. No learning
effects are applied to engine friction reduction costs, while time
based learning is considered applicable to both coupled cam phasing and
SGDI.
[GRAPHIC] [TIFF OMITTED] TP30NO10.041
(iv) Reasonableness of the Proposed Standard
The proposed engine standards appear to be reasonable and
consistent with the agencies' respective authorities. With respect to
the 2016 MY standard, all of the technologies on which the standards
are predicated have been demonstrated and their effectiveness is well
documented. The proposal reflects a 100 percent application rate for
these technologies. The costs of adding these technologies remain
modest across the various engine classes as shown in Table III-15. Use
of these technologies would add only a small amount to the cost of the
vehicle,\189\ and the associated reductions are highly cost effective,
an estimated $30 per ton of CO2eq per vehicle.\190\ This is
even more cost effective than the estimated cost effectiveness for
CO2eq removal and fuel economy improvement under the light-
duty vehicle rule, already considered by the agencies to be a highly
cost effective reduction.\191\ Accordingly, EPA and NHTSA view these
standards as reflecting an appropriate balance of the various statutory
factors under section 202(a) of the CAA and under NHTSA's EISA
authority at 49 U.S.C. 32902(k)(2).
---------------------------------------------------------------------------
\189\ Sample 2010 MY vocational vehicles range in price between
$40,000 for a Class 4 work truck to approximately $200,000 for a
Class 8 refuse hauler. See pages 16-17 of ICF's ``Investigation of
Costs for Strategies to Reduce Greenhouse Gas Emissions for Heavy-
Duty On-Road Vehicles.'' July 2010.
\190\ See Vocational Vehicle CO2 savings and
technology costs for Alternative 2 in Section IX.B.
\191\ The light-duty rule had an estimated cost per ton of $50
when considering the vehicle program costs only and a cost of -$210
per ton considering the vehicle program costs along with fuel
savings in 2030. See 75 FR 25515, Table III.H.3-1.
---------------------------------------------------------------------------
(v) Alternative Gasoline Engine Standards Considered
The agencies are not proposing gasoline standards less stringent
than the proposed standards because the agencies believe these
standards are feasible in the lead time provided, inexpensive, and
highly cost effective. We welcome comments supplemented with data on
each aspect of this determination most importantly on individual
gasoline engine technology efficacy to reduce fuel consumption and GHGs
as well was our estimates of individual technology cost and lead-time.
The proposed rule reflects 100 percent penetration of the
technology package on whose performance the standard is based, so some
additional technology would need to be added to obtain further
improvements. The agencies considered proposing gasoline engine
standards which are more stringent reflecting the inclusion of cylinder
deactivation and other advanced technologies. However, the agencies are
not proposing this level of stringency because our assessment is that
these technologies would not be available for production by the 2017
model year. The agencies welcome comments on whether other gasoline
technologies are appropriate to consider for the 2017 model year
standard, or if not, then when would they be appropriate.
(c) Diesel Engines
(i) Baseline Diesel Engine Performance
EPA and NHTSA developed the baseline heavy-duty diesel engines to
represent a 2010 model year engine compliant with the 0.2 g/bhp-hr
NOX standard for on-highway heavy-duty engines.
The agencies utilized 2007 through 2011 model year CO2
certification levels from the Heavy-duty FTP cycle as the basis for the
baseline engine CO2 performance. The pre-2010 data are
subsequently adjusted to represent 2010 model year engine maps by using
predefined technologies including SCR and other systems that are being
used in current 2010 production. The engine CO2 results were
then sales weighted within each regulatory subcategory to develop an
industry average 2010 model year reference engine, as shown in Table
III-16. The level of CO2 emissions and fuel consumption of
these engines varies significantly, where the engine with the highest
CO2 emissions is estimated to be 20 percent greater than the
sales weighted average. Details of this analysis are included in draft
RIA Chapter 2.
[[Page 74247]]
[GRAPHIC] [TIFF OMITTED] TP30NO10.042
(ii) Diesel Engine Packages
The diesel engine technology packages for the 2014 model year
include engine friction reduction, improved aftertreatment
effectiveness, improved combustion processes, and low temperature EGR
system optimization. The improvements in parasitic and friction losses
come through piston designs to reduce friction, improved lubrication,
and improved water pump and oil pump designs to reduce parasitic
losses. The aftertreatment improvements are available through lower
backpressure of the systems and optimization of the engine-out
NOX levels. Improvements to the EGR system and air flow
through the intake and exhaust systems, along with turbochargers can
also produce engine efficiency improvements. It should be pointed out
that individual technology improvements are not additive to each other
due to the interaction of technologies. The agencies assessed the
impact of each technology over the Heavy-duty FTP and project an
overall cycle improvement in the 2014 model year of 3 percent for HHD
diesel engines and 5 percent for LHD and MHD diesel engines, as
detailed in draft RIA Chapter 2.4.2.9 and 2.4.2.10. EPA used a 100
percent application rate of this technology package to determine the
level of the proposed 2014 MY standards
Recently, EPA's heavy-duty highway engine program for criteria
pollutants provided new emissions standards for the industry in three
year increments. The heavy-duty engine manufacturer product plans have
fallen into three year cycles to reflect this environment. EPA is
proposing set CO2 emission standards recognizing the
opportunity for technology improvements over this timeframe while
reflecting the typical heavy-duty engine manufacturer product plan
cycles. Thus, the agencies are proposing to establish initial standards
for the 2014 model year and a more stringent standard for heavy-duty
engines beginning in the 2017 model year.
The 2017 model year technology package for LHD and MHD diesel
engine includes continued development and refinement of the 2014 model
year technology package, in particular the additional improvement to
aftertreatment systems. This package leads to a projected 9 percent
reduction for LHD and MHD diesel engines in the 2017 model year. The
HHD diesel engine technology packages for the 2017 model year include
the continued development of the 2014 model year technology package
plus turbocompounding. A similar approach to evaluating the impact of
individual technologies as taken to develop the overall reduction of
the 2014 model year package was taken with the 2017 model year package.
The Heavy-duty FTP cycle improvements lead to a 5 percent reduction on
the cycle for HHDD, as detailed in draft RIA Chapter 2.4.2.13. The
agencies used a 100 percent application rate of the technology package
to determine the proposed 2017 MY standards. The agencies believe that
bottom cycling technologies are still in the development phase and will
not be ready for production by the 2017 model year.\192\ Therefore,
these technologies were not included in determining the stringency of
the proposed standards. However, we do believe the bottoming cycle
approach represents a significant opportunity to reduce fuel
consumption and GHG emissions in the future. EPA and NHTSA are
therefore both proposing provisions described in Section IV to create
incentives for manufacturers to continue to invest to develop this
technology.
---------------------------------------------------------------------------
\192\ TIAX noted in their report to the NAS panel that the
engine improvements beyond 2015 model year included in their report
are highly uncertain, though they include waste heat recovery in the
engine package for 2016 through 2020 (page 4-29).
---------------------------------------------------------------------------
The overall projected improvements in CO2 emissions and
fuel consumption over the baseline are included in Table III-17.
[GRAPHIC] [TIFF OMITTED] TP30NO10.043
(iii) Technology Package Costs
NHTSA and EPA jointly developed costs associated with the engine
technologies to assess an overall package cost for each regulatory
category. Our engine cost estimates for diesel engines used in
vocational vehicles include a separate analysis of the incremental part
costs, research and development activities, and additional equipment,
such as emissions equipment to measure N2O emissions. Our
general approach used elsewhere in this proposal (for HD pickup trucks,
gasoline engines, Class 7 and 8 tractors, and Class 2b-8 vocational
vehicles) estimates a direct manufacturing cost for a part and marks it
up based on a factor to account for indirect costs. See also 75 FR
25376. We believe that approach is
[[Page 74248]]
appropriate when compliance with proposed standards is achieved
generally by installing new parts and systems purchased from a
supplier. In such a case, the supplier is conducting the bulk of the
research and development on the new parts and systems and including
those costs in the purchase price paid by the original equipment
manufacturer. The indirect costs incurred by the original equipment
manufacturer need not include much cost to cover research and
development since the bulk of that effort is already done. For the MHD
and HHD diesel engine segment, however, the agencies believe we can
make a more accurate estimate of technology cost using this alternate
approach because the primary cost is not expected to be the purchase of
parts or systems from suppliers or even the production of the parts and
systems, but rather the development of the new technology by the
original equipment manufacturer itself. Therefore, the agencies believe
it more accurate to directly estimate the indirect costs. EPA commonly
uses this approach in cases where significant investments in research
and development can lead to an emission control approach that requires
no new hardware. For example, combustion optimization may significantly
reduce emissions and cost a manufacturer millions of dollars to develop
but will lead to an engine that is no more expensive to produce. Using
a bill of materials approach would suggest that the cost of the
emissions control was zero reflecting no new hardware and ignoring the
millions of dollars spent to develop the improved combustion system.
Details of the cost analysis are included in the draft RIA Chapter 2.
To reiterate, we have used this different approach because the MHD and
HHD diesel engines are expected to comply in large part via technology
changes that are not reflected in new hardware but rather knowledge
gained through laboratory and real world testing that allows for
improvements in control system calibrations--changes that are more
difficult to reflect through direct costs with indirect cost
multipliers.
The agencies developed the engineering costs for the research and
development of diesel engines with lower fuel consumption and
CO2 emissions. The aggregate costs for engineering hours,
technician support, dynamometer cell time, and fabrication of prototype
parts are estimated at $6,750,000 per manufacturer per year over the
five years covering 2012 through 2016. In aggregate, this averages out
to $280 per engine during 2012 through 2016 using a very rough annual
sales value of 600,000 LHD, MHD and HHD diesel engines. The agencies
also are estimating costs of $100,000 per engine manufacturer per
engine class (LHD, MHD and HHD diesel) to cover the cost of purchasing
photo-acoustic measurement equipment for two engine test cells. This
would be a one-time cost incurred in the year prior to implementation
of the standard (i.e., the cost would be incurred in 2013). In
aggregate, this averages out to $4 per engine in 2013 using a very
rough annual sales value of 600,000 LHD, MHD and HHD diesel engines.
EPA also developed the incremental piece cost for the components to
meet each of the 2014 and 2017 standards. These costs shown in Table
III-18 which include a low complexity ICM of 1.11; time based learning
is considered applicable to each technology.
[[Page 74249]]
[GRAPHIC] [TIFF OMITTED] TP30NO10.044
The overall costs for each diesel engine regulatory subcategory are
included in Table III-19.
[GRAPHIC] [TIFF OMITTED] TP30NO10.045
(iv) Reasonableness of the Proposed Standards
The proposed engine standards appear to be reasonable and
consistent with the agencies' respective authorities. With respect to
the 2014 and 2017 MY standards, all of the technologies on which the
standards have already been demonstrated and their effectiveness is
well documented. The proposal reflects a 100 percent application rate
for these technologies. The costs of adding these technologies remain
modest across the various engine classes as shown in Table III-19. Use
of these technologies would add only a small amount to the cost of the
vehicle,\193\ and the associated reductions are highly cost effective,
an estimated $30 per ton of CO2eq per vehicle.\194\ This is
even more cost effective than the estimated cost effectiveness for
CO2eq removal and fuel economy improvement under the light-
duty vehicle rule, already considered by
[[Page 74250]]
the agencies to be a highly cost effective reduction.\195\ Accordingly,
EPA and NHTSA view these standards as reflecting an appropriate balance
of the various statutory factors under section 202(a) of the CAA and
under NHTSA's EISA authority at 49 U.S.C. 32902(k)(2).
---------------------------------------------------------------------------
\193\ Sample 2010 MY vocational vehicles range in price between
$40,000 for a Class 4 work truck to approximately $200,000 for a
Class 8 refuse hauler. See pages 16-17 of ICF's ``Investigation of
Costs for Strategies to Reduce Greenhouse Gas Emissions for Heavy-
Duty On-Road Vehicles.'' July 2010.
\194\ See Vocational Vehicle CO2 savings and
technology costs for Alternative 2 in Section IX.B.
\195\ The light-duty rule had a cost per ton of $50 when
considering the vehicle program costs only and a cost of -$210 per
ton considering the vehicle program costs along with fuel savings in
2030. See 75 FR 25515, Table III.H.3-1.
---------------------------------------------------------------------------
(v) Alternative Diesel Engine Standards Considered
Other than the specific proposal related to legacy engine products,
the agencies are not proposing diesel engine standards less stringent
than the proposed standards because the agencies believe these
standards are highly cost effective. We welcome comments supplemented
with data on each aspect of this determination most importantly on
individual engine technology efficacy to reduce fuel consumption and
GHGs as well as our estimates of individual technology cost and lead-
time.
The agencies considered proposing diesel engine standards which are
more stringent reflecting the inclusion of other advanced technologies.
However, the agencies are not proposing this level of stringency
because our assessment is that these technologies would not be
available for production by the 2017 model year. The agencies welcome
comments on whether other diesel engine technologies are appropriate to
consider for the 2017 model year standard, or if not, then when would
they be appropriate.
IV. Proposed Regulatory Flexibility Provisions
This section discusses proposed flexibility provisions intended to
achieve the goals of the overall program while providing alternate
pathways to achieve those goals. The primary flexibility provisions the
agencies are proposing for combination tractors and vocational vehicles
relate to a program of Averaging, Banking, and Trading of credits that
EPA and NHTSA are proposing in association with each agency's
respective CO2 and fuel consumption standards (see Section
II above). For HD pickups and vans, the primary flexibility provision
is the fleet averaging program patterned after the LD GHG and CAFE
rule. EPA is not proposing an emission credit program associated with
the proposed N2O, CH4, or HFC standards. This
section also describes proposed flexibility provisions that would apply
in specific circumstances.
A. Averaging, Banking, and Trading Program
Averaging, Banking, and Trading (ABT) of emissions credits have
been an important part of many EPA mobile source programs under CAA
Title II, including engine and vehicle programs. ABT programs can be
important because they can help to address many issues of technological
feasibility and lead-time, as well as considerations of cost. ABT
programs are not just add-on provisions included to help reduce costs,
but are usually an integral part of the standard setting itself. An ABT
program is important because it provides manufacturers flexibilities
that assist the development and implementation of new technologies
efficiently and therefore enables new technologies to be implemented at
a more progressive pace than without ABT. A well-designed ABT program
can provide important environmental benefits and at the same time
increase flexibility for and reduce costs to the regulated industry.
Section II above describes EPA's proposed GHG emission standards
and NHTSA's proposed fuel consumption standards. For each of these
respective sets of standards, the agencies are also proposing ABT
provisions consistent with each agency's statutory authority. The
agencies have worked closely together to design these proposed
provisions to be essentially identical to each other in form and
function. Because of this fundamental similarity, the remainder of this
section refers to these provisions collectively as ``the ABT program''
except where agency-specific distinctions are required.
As discussed in detail below, the structure of this proposed GHG
ABT program for HD engines is based closely on earlier ABT programs for
HD engines; the proposed program for HD pickups and vans is built on
the existing light-duty GHG program flexibility provisions; and we
propose first-time ABT provisions for combination tractors and
vocational vehicles that are as consistent as possible with our other
HD vehicle regulations. The flexibility provisions associated with this
new regulatory category are intended to systematically build upon the
structure of the existing programs.
As an overview, ``averaging'' means the exchange of emission
credits between engine families or truck families within a given
manufacturer's regulatory subcategory. For example within each
regulatory subcategory, engine manufacturers divide their product line
into ``engine families'' that are comprised of engines expected to have
similar emission characteristics throughout their useful life.
Averaging allows a manufacturer to certify one or more engine families
within the same regulatory subcategory at levels above the applicable
emission standard. The increased emissions over the standard would need
to be offset by one or more engine families within that manufacturer's
regulatory subcategory that are certified below the same emission
standard, such that the average emissions from all the manufacturer's
engine families, weighted by engine power, regulatory useful life, and
production volume, are at or below the level of the emission standard.
(The inclusion of engine power, useful life, and production volume in
the averaging calculations allows the emissions credits or debits to be
expressed in total emissions over the useful life of the credit-using
or generating engine sales.) Total credits for each regulatory
subcategory within each model year are determined by summing together
the credits calculated for every engine family within that specific
regulatory subcategory.
``Banking'' means the retention of emission credits by the
manufacturer for use in future model year averaging or trading.
``Trading'' means the exchange of emission credits between
manufacturers, which can then be used for averaging purposes, banked
for future use, or traded to another manufacturer.
In the current HD program for criteria pollutants, manufacturers
are restricted to only averaging, banking and trading credits generated
within a regulatory subcategory, and we are proposing to continue this
restriction in the GHG and fuel consumption program. However, the
agencies are evaluating--and therefore request comment on--potential
alternative approaches in which fewer restrictions are placed on the
use of credits for averaging, banking, and trading. Particularly, the
agencies request comment on removing prohibitions on averaging and
trading between some or all regulatory categories in this proposal, and
on removing restrictions between some or all regulatory subcategories
that are within the same regulatory category (e.g., allowing trading of
credits between class 7 day cabs and class 8 sleeper cabs).
In the past, we have followed the practice of allowing averaging
and trading between like products because we have recognized that the
estimation of emissions credits is not an absolutely precise process,
and actual emissions reductions or increases ``in use'' would vary due
to differences in vehicle duty cycles, maintenance practices and any
[[Page 74251]]
number of other factors. By restricting credit averaging and trading to
only allow averaging and trading between like products, the agencies
gain some degree of assurance that the operation and use of the
vehicles generating credits and consuming credits would be similar. The
agencies also note that some industry participants have expressed
concern that allowing credit averaging, banking and trading across
different products may create an unlevel playing field for the
regulated industry. Specifically, engine and truck manufacturers have
commonly expressed to us a concern that some manufacturers with a wide
range of product offerings spanning a number of regulatory categories
would be able to use the ABT program provisions to generate credits in
regulatory class markets where they face less competition and then use
those credits to compete unfairly in other regulatory categories where
they face greater competition. Finally, in the context of regulating
criteria pollutants that can have localized and regional impacts, we
have been concerned about the unintended consequence of unrestricted
credit averaging or trading on local or regional concentrations of
pollutants, whereby emissions reductions might become concentrated in
some localities or regions to the detriment of other areas needing the
reductions.
The agencies are evaluating the possibility of placing fewer
restrictions on averaging and trading because increasing the
flexibility offered to manufacturers to average, bank, and trade
credits across regulatory subcategories and categories could
potentially significantly reduce the overall cost of the program.
Specifically, we request comment on the extent to which a difference--
or unexpected difference--in the marginal costs of compliance per
gallon of fuel saved or ton of GHG reduced across categories or
subcategories, combined with provision for averaging and trading across
categories and subcategories, can allow manufacturers to achieve the
same overall reduction in fuel use and emissions at lower cost.
While trading restrictions in the context of past EPA rulemakings
have been motivated in part by the local or regional nature of the
pollutant being regulated, in this instance, opportunities for greater
flexibility may exist in light of the fact that greenhouse gases are a
global pollutant for which local consequences are related to global,
not local or regional atmospheric concentrations. However, trading
ratios may need to be established for averaging and trading across
categories, and potentially across subcategories, to ensure that
averaging and trading across categories and subcategories does not lead
to a net increase in emissions or fuel use in light of differences in
vehicle use patterns across categories and subcategories. Further, it
is possible to design trading ratios that ensure a net reduction in
emissions and fuel use as a result of averaging and trading. The
agencies also request comment on the potential additional savings in
costs (beyond those already calculated in this proposal) due to
increased flexibility in averaging and trading provisions, on how such
averaging and trading flexibilities could be designed to ensure
environmental neutrality, on whether trading ratios should be designed
to achieve a net reduction in emissions and fuel use as a result of
trading, on the concerns that have been raised by some regarding
impacts on intra-industry competition, and on how to address the above
identified concerns about dissimilarities in operation and use of
vehicles.
(1) Heavy-duty Engines
For the heavy-duty engine ABT program, EPA and NHTSA are proposing
to use EPA's existing regulatory engine classifications as the
subcategory designations under this engine ABT program. The proposed
regulations use the term ``averaging set'' which aligns with the
regulatory subcategories or regulatory class in the context that they
define the same set of products. The existing diesel engine
subcategories are light-heavy-duty (LHD), medium-heavy-duty (MHD), and
heavy-heavy-duty (HHD). LHD diesel engines are primarily used in
vehicles with a GVWR below 19,500 lb. Vehicle body types in this group
might include any heavy-duty vehicle built for a light-duty truck
chassis, van trucks, multi-stop vans, recreational vehicles, and some
single axle straight trucks. Vehicles containing these engines would
normally include personal transportation, light-load commercial hauling
and delivery, passenger service, agriculture, and construction
applications.
MHD diesel engines are normally used in vehicles whose GVWR varies
from 19,501-33,000 lb. Vehicles containing these engines typically
include school buses, tandem axle straight trucks, city tractors, and a
variety of special purpose vehicles such as small dump trucks, and
trash compactor trucks. Normally the applications for these vehicles
would include commercial short haul and intra-city delivery and pickup.
HHD diesel engines are intended for use in vehicles which exceed
33,000 lb GVWR. Vehicles containing engines of this type are normally
tractors, trucks, and buses used in inter-city, long-haul applications.
HHD engines are generally regarded as designed for rebuild and have a
long useful life period. LHD and MHD engines are typically not intended
for rebuild, though some MHD engines are designed for rebuild, and have
a shorter useful life.
Gasoline or spark ignited engines for heavy-duty vehicles fall into
one separate regulatory subcategory. These engines are typically
installed in trucks with a GVWR ranging from 8,500 pounds to 19,500
pounds although they can be installed into trucks of any size.
The compliance program we are proposing would adopt a slightly
different method for generating a manufacturer's CO2
emission and fuel consumption credit or deficit. The manufacturer's
certification test result would serve as the basis for the generation
of the manufacturer's Family Certification Level (FCL). The FCL is a
new term we propose for this program to differentiate the purpose of
this credit generation technique from the Family Emission Limit (FEL)
previously used in a similar context in other EPA rules. A manufacturer
could define its FCL at any level at or above the certification test
result. Credits for the ABT program would be generated when the FCL is
compared to its CO2 and fuel consumption standard, as
discussed in Section II. The credits earned in this section would be
restricted to the engine subcategory and not tradable with other engine
subcategories consistent with EPA's past practice for ABT programs as
described previously. Credit calculation for the proposed Engine ABT
and program would be generated, either positive or negative, according
to Equation IV-1 and Equation IV-2:
Equation IV-1: Proposed HD Engine CO2 credit (deficit)
HD Engine CO2 credit (deficit) (metric tons) = (Std-FCL) x
(CF) x (Volume) x (UL) x (10-6)
Where:
Std = the standard associated with the specific engine regulatory
subcategory (g/bhp-hr)
FCL = Family Certification Level for the engine family
CF = a transient cycle conversion factor in bhp-hr/mile which is the
integrated total cycle brake horsepower-hour divided by the
equivalent mileage of the Heavy-duty FTP cycle. For gasoline heavy-
duty engines, the equivalent mileage is 6.3 miles. For diesel heavy-
duty engines, the equivalent mileage is 6.5 miles. The agencies are
proposing that the CF
[[Page 74252]]
determined by the Heavy-duty FTP cycle be used for engines
certifying to the SET standard.
Volume = (projected or actual) production volume of the engine
family
UL = useful life of the engine (miles)
10-6 converts the grams of CO2 to metric tons
Equation IV-2: Proposed HD Engine Fuel Consumption credit (deficit) in
gallons
HD Engine Fuel Consumption credit (deficit) (gallons) = (Std - FCL) x
(CF) x (Volume) x (UL) x 102
Where:
Std = the standard associated with the specific engine regulatory
subcategory (gallon/100 bhp-hr)
FCL = Family Certification Level for the engine family (gallon/100
bhp-hr)
CF = a transient cycle conversion factor in bhp-hr/mile which is the
integrated total cycle brake horsepower-hour divided by the
equivalent mileage of the Heavy-duty FTP cycle. For gasoline heavy-
duty engines, the equivalent mileage is 6.3 miles. For diesel heavy-
duty engines, the equivalent mileage is 6.5 miles. The agencies are
proposing that the CF determined by the Heavy-duty FTP cycle be used
for engines certifying to the SET standard.
Volume = (projected or actual) production volume of the engine
family
UL = useful life of the engine (miles)
102 = conversion to gallons
To calculate credits or deficits, manufacturers would determine an
FCL for each engine family they have designated for the ABT program. We
have defined engine families in 40 CFR 1036.230 and manufacturers may
designate how to group their engines for certification and compliance
purposes. The FCL may be above (negative) or below (positive) its
standard and would be used to establish the CO2 credits
earned (or used) in Equation IV-1. The proposed CO2 and fuel
consumption standards are associated with specific regulatory
subcategories as described in Sections II.B and II.D (gasoline, light
heavy-duty diesel, medium heavy-duty diesel, and heavy heavy-duty
diesel). In the ABT program, engines certified with an FCL below the
standard generate positive credits (g/bhp-hr and gal/100 bhp-hr). As
discussed in Section II.B and II.D, engine families for which a
manufacturer elects to use the alternative standard of a percent
reduction from the engine family's 2011 MY baseline would be ineligible
to either generate or use credits.
The volume used in Equations IV-1 and IV-2 refers to the total
number of eligible engines sold per family participating in the ABT
program during that model year. The useful life values in Equation IV-1
are proposed to be the same as the regulatory classifications
previously used for the engine subcategories. Thus, the agencies
propose that for LHD diesel engines and gasoline engines, the useful
life values would be 110,000 miles; for MHD diesel engines, 185,000
miles; and for HHD diesel engines, 435,000 miles.
As noted above, credits generated by engine manufacturers under
this ABT program would be restricted for use only within their engine
subcategory based on performance against the standard as defined in
Section II.B and II.D. Thus, LHD diesel engine manufacturers could only
use their LHD diesel engine credits for averaging, banking and trading
with LHD diesel engines, not with MHD diesel or HHD diesel engines.
This limitation is consistent with ABT provisions in EPA's existing
criteria pollutant program for engines and would help assure that
credits earned to reduce GHG emissions and fuel consumption would be
used to limit their growth and not circumvent the intent of the
regulations. EPA and NHTSA are concerned that extending the use of
credits beyond these designated subcategories could also create an
advantage for large or integrated manufacturers that currently does not
exist in the market. A manufacturer that produces both engines and
heavy-duty highway vehicles could mix credits across engine and vehicle
categories, shifting the burden between the sectors, not equally shared
in either sector, to gain an advantage over competitors that are not
integrated. Similarly, large volume manufacturers of engines can shift
credits between heavy heavy-duty diesel engines and light heavy-duty
diesel engines to gain an advantage in one subcategory over other
manufacturers that may not have multiple engine offerings over several
regulatory engine subcategories. Finally, relating credits between
subcategories of engines could be problematic because of the
differences in regulatory useful lives. The agencies want to avoid
having credits from longer useful life categories flooding shorter
useful life categories, adversely impacting compliance with the
proposed CO2 and fuel consumption standards in the shorter
useful life category. The agencies would like to ensure that this
regulation reduces CO2 emissions and improves fuel
consumption in each engine subcategory while not interfering with the
ability of manufacturers to engage in free trade and competition.
Limiting credit ABT to the regulatory subcategory and not between
engines and vehicles would help prevent a competitive advantage due
solely to the regulatory structure. Although the reasons for
restricting engine credits to the same engine subcategory seem
persuasive to us, the agencies welcome comments on the extension of
credits beyond the limitations we are proposing.\196\
---------------------------------------------------------------------------
\196\ These concerns were not present in the 2012-2016 MY light-
duty vehicle rule, where most manufacturers offer diverse product
lines and there is not as much disparity among useful lives. That
rule consequently does not restrict CO2 credit trading
opportunities between light-duty vehicle sectors.
---------------------------------------------------------------------------
Under previous ABT programs for other rulemakings, EPA has allowed
manufacturers to carry forward deficits from engines for a set period
of time. The agencies are proposing to allow manufacturers of engines
to carry forward deficits for up to three years before reconciling the
short-fall. However, manufacturers would need to use credits, once
credits are generated, to offset a shortfall before credits may be
banked or traded for additional model years. This restriction reduces
the chance of manufacturers passing forward deficits before reconciling
shortfalls and exhausting those credits before reconciling past
deficits. We will accept comments on alternative approaches for
reconciling deficit shortfalls in the engine category.
As described in Section II above, EPA is proposing that a
manufacturer may choose to comply with the N2O or
CH4 cap standards using CO2 credits. A
manufacturer choosing this option would convert its N2O or
CH4 test results into CO2eq to determine the
amount of CO2 credits required. This approach recognizes the
inter-correlation of these elements in impacting global warming. This
option does not apply to the NHTSA fuel consumption program. To account
for the different global warming potential of these GHGs, EPA proposes
that manufacturers determine the amount of CO2 credits
required by multiplying the shortfall by the GWP. For example, a
manufacturer would use 25 kg of positive CO2 credits to
offset 1 kg of negative CH4 credits. Or a manufacturer would
use 298 kg of positive CO2 credits to offset 1 kg of
negative N2O credits. In general we do not expect
manufacturers to use this provision. However, we are providing this
alternative as a flexibility in the event an engine manufacturer has
trouble meeting the CH4 and/or N2O emission caps.
There are not ABT credits for performance that falls below the
CH4 or N2O caps.
Additional flexibilities for engines are discussed later in Section
IV(B).
[[Page 74253]]
(2) Class 7 and 8 Combination Tractors
In addition to the engine ABT program described above, the agencies
are also proposing a vehicle ABT program to facilitate reductions in
GHG emissions and fuel consumption based on combination tractor design
changes and improvements. For this category, the structure of the
proposed ABT program should create incentives for tractor manufacturers
to advance new, clean technologies, or existing technologies earlier
than they would otherwise.
As explained in Sections II and III above, combination tractor
manufacturers are divided into nine regulatory subcategories under
these proposed rules, as shown in the following table:
[GRAPHIC] [TIFF OMITTED] TP30NO10.046
The proposed regulations use the term ``averaging set'' which
aligns with the regulatory subcategories or regulatory class in the
context that they define the same set of products. Vehicle credits for
tractors in these classifications would be earned on a g/ton-mile or
gallon/1,000 ton-mile basis for tractors which are below the standard.
Credits generated within regulatory subcategories would be tradable
between truck manufacturers in that specific regulatory subcategory
only. Credits would not be fungible between engine and vehicle
regulatory categories. This is similar to the restrictions we have
described above for engine manufacturers.
This limitation would help ensure that credits earned to reduce GHG
emissions and fuel consumption would be used to limit their growth and
not circumvent the intent of our regulation. As with engine credits, we
are concerned that extending the use of credits to be transferred or
traded to other classes may create an advantage for large or integrated
manufacturers that currently does not exist in the market. We would
like to ensure that this regulation reduces the emission of
CO2 and fuel consumption but does not effectively penalize
non-integrated manufacturers and those with limited participation in
the market. ABT provides manufacturers the flexilibility to deal with
unforeseen shifts in the marketplace that affect sales volumes. This
structure allows for a straightforward compliance program for each
sector independently with aspects that are also independently
quantifiable and verifiable. Credit calculation for the proposed Class
7 and 8 tractor CO2 and fuel consumption credits would be
generated, either positive or negative, according to Equation IV-3 and
Equation IV-4:
Equation IV-3: The Proposed Class 7 and 8 Tractor CO2 Credit
(Deficit)
Class 7 and 8 Tractor CO2 credit (deficit)(metric tons) =
(Std-FEL) x (Payload Tons) x (Volume) x (UL) x (10-6)
Where:
Std = the standard associated with the specific tractor regulatory
class (g/ton-mile)
Payload tons = the prescribed payload for each class in tons (12.5
tons for Class 7 and 19 tons for Class 8)
FEL = Family Emission Limit for the tractor family which is equal to
the output from GEM (g/ton-mile)
Volume = (projected or actual) production volume of the tractor
family
UL = useful life of the tractor (435,000 miles for Class 8 and
185,000 miles for Class 7)
10-6 converts the grams of CO2 to metric tons
Equation IV-4: Proposed Class 7 and 8 Tractor Fuel Consumption credit
(deficit) in gallons:
Class 7 and 8 Tractor Fuel Consumption credit (deficit)(gallons) =
(Std-FEL) x (Payload Tons) x (Volume) x (UL) x 103
Where:
Std = the standard associated with the specific tractor regulatory
subcategory (gallons/1,000 ton-mile)
Payload tons = the prescribed payload for each class in tons (12.5
tons for Class 7 and 19 tons for Class 8)
FEL = Family Emission Limit for the tractor family (gallons/1,000
ton-mile)
Volume = (projected or actual) production volume of the tractor
family
UL = useful life of the tractor (435,000 miles for Class 8 and
185,000 miles for Class 7)
103 = conversion to gallons
Similar to the proposed Heavy-duty Engine ABT program described in
the previous section, we are proposing that tractor manufacturers would
be able to carry forward credit deficits from their regulatory
subcategories for three years before reconciling the shortfall.
However, just as in the engine category, manufacturers would need to
use credits once those credits have been generated to offset a
shortfall before those credits can be banked or traded for additional
model years. This restriction reduces the chance of tractor
manufacturers passing forward deficits before reconciling their
shortfalls and exhausting those credits before reconciling past
deficits. Manufacturers of vehicles that generate a deficit at the end
of the model year could carry that deficit forward for three years
following the model year for which that deficit was generated. Deficits
would need to be reconciled at the reporting dates for year three. We
will accept comments on alternative approaches of reconciling deficit
shortfalls.
Additional flexibilities for Class 7 and 8 combination tractors are
discussed later in Section IV.B.
(3) Class 2b-8 Vocational Vehicles
Similar to the Class 7 and 8 combination tractor manufacturers, we
are offering a limited ABT program for Class 2b-8 vocational chassis
manufacturers. Vehicle credits would be generated for those
manufacturers that introduce products into the market with rolling
resistance improvements which are better than required to meet the
proposed vehicle standards, The certification of the chassis would be
based on the use of LRR tires. Credit calculation for the proposed
Class 2b-8 vocational vehicle CO2 and fuel consumption
credits (deficits) would be generated, either positive or negative,
according to Equation IV-5 and Equation IV-6:
Equation IV-5: The proposed Vocational Vehicle CO2 vehicle
credit (deficit)
Vocational Vehicle CO2 credit (deficit) (metric tons) =
(Std-FEL) x
[[Page 74254]]
(Payload Tons) x (Sales Volume) x (UL) x (10-6)
Where:
Std = the standard associated with the specific vocational vehicle
subcategory (g/ton-mile)
Payload tons = the prescribed payload for each subcategory in tons
(2.85 tons for LHD, 5.6 tons for MHD, and 19 tons for HHD vehicles)
FEL = Family Emission Limit for the vehicle family (g/ton-mile)
Volume = (projected or actual) production volume of the vehicle
family
UL = useful life of the vehicle (110,000 miles for LHD, 185,000
miles for MHD, or 435,000 miles for HHD vehicles)
10-6 converts the grams of CO2 to metric tons
Equation IV-6: Proposed Vocational Vehicle Fuel Consumption credit
(deficit) in gallons
Vocational Vehicle Fuel Consumption credit for (deficit) (gallons) =
(Std-FEL) x (Payload Tons) x (Sales Volume) x (UL) x 103
Where:
Std = the standard associated with the specific vocational vehicle
regulatory subcategory (gallon/1,000 ton-mile)
Payload tons = the prescribed payload for each regulatory
subcategory in tons (2.85 tons for LHD, 5.6 tons for MHD, and 19
tons for HHD vehicles)
FEL = Family Emission Limit for the vehicle family (gallon/1,000
ton-mile)
Volume = (projected or actual) production volume of the vehicle
family
UL = useful life of the vehicle (110,000 miles for LHD, 185,000
miles for MHD, or 435,000 miles for HHD vehicles)
10\3\ converts to gallons
Also, similar to the proposed heavy-duty engine and tractor ABT
programs, the vehicle credits generated within each regulatory
subcategory would be allowed to be averaged, banked, or traded between
chassis manufacturers within their existing subcategories. For
vocational vehicles the proposed vehicle subcategories are based on the
vehicle's GVWR. We are proposing three vehicle subcategories LHD with a
GVWR less than or equal to 19,500 pounds, MHD vehicles with a GVWR
greater than 19,500 and less than or equal to 33,000 pounds, and HHD
vehicles with a GVWR greater than 33,000 pounds. These three weight
categories would form the subcategories for vocational vehicles and are
found in 40 CFR 1037.230. The proposed regulations use the term
``averaging set'' which aligns with the regulatory categories or
regulatory class in the context that they define the same set of
products.
Similar to the proposed Heavy-duty Engine ABT program above,
vocational chassis manufacturers would be able to carry forward
deficits for three years before reconciling the shortfall. However,
just as in the engine category, manufacturers would need to use credits
earned once those credits have been generated to offset a shortfall
before those credits can be banked or traded for additional model
years. This restriction reduces the chance of chassis manufacturers
passing forward deficits before reconciling their shortfalls and
exhausting those credits before reconciling past deficits.
Manufacturers of vocational vehicles that generate a deficit at the end
of the model year could carry that deficit forward for three years
following the model year for which that deficit was generated. Deficits
would need to be reconciled at the reporting dates for year three. We
will accept comments on alternative approaches of reconciling deficit
shortfalls.
(4) Heavy-Duty Pickup Truck and Van Flexibility Provisions
EPA and NHTSA are proposing specific flexibility provisions for
manufacturers of HD pickups and vans, similar to provisions adopted in
the recent rulemaking for light-duty car and truck GHGs and fuel
economy. Additional flexibilities that apply to the broad range of
heavy-duty vehicles, including HD pickups and vans, are discussed in
Section IV.B. All of these flexibilities would help enable new
technologies to be implemented faster and more cost-effectively than
without a flexibility program, and also help manufacturers deal with
unexpected shifts in sales.
A manufacturer's credit or debit balance would be determined by
calculating their fleet average performance and comparing it to the
manufacturer's CO2 and fuel consumption standards, as
determined by their fleet mix, for a given model year. A target
standard is determined for each vehicle with a unique payload, towing
capacity and drive configuration. These unique targets, weighted by
their associated production volumes, are summed at the end of the model
year to derive the production volume-weighted manufacturer annual fleet
average standard. A manufacturer would generate credits if its fleet
average CO2 or fuel consumption level is lower than its
standard and would generate debits if its fleet average CO2
or fuel consumption level is above that standard. The end-of-year
reports would provide appropriate data to reconcile pre-compliance
estimates with final model year figures. Similar to the light-duty GHG
program, the agencies would address any ultimate deficits by a possible
void of certificates on a sufficient number of vehicles to address the
shortfall. Enforcement action would entail penalty or other relief as
appropriate or applicable.
In addition to production weighting, we are proposing that the EPA
credit calculations include a factor for the vehicle useful life, in
miles, in order to allow the expression of credits in metric tons, as
in the light-duty GHG program. The NHTSA credit calculation would use
standard and performance levels in fuel consumption units (gallons per
100 miles), as opposed to fuel economy units (mpg) as done in the
light-duty program, along with the vehicle useful life, in miles,
allowing the expression of credits in gallons. We propose that other
provisions for the generation, tracking, trading, and use of the
credits be the same as those adopted in the light-duty GHG program,
including a 5-year limit on credit carry-forward to future model years
and a 3-year limit on deficit carry-forward (or credit carry-back).
The total model year fleet credit (debit) calculations would use
the following equations:
CO2 Credits (Mg) = [(CO2 Std-CO2 Act)
x Volume x UL] / 1,000,000
Fuel Consumption Credits (gallons) = (FC Std-FC Act) x Volume x UL x
100
Where:
CO2 Std = Fleet average CO2 standard (g/mi)
FC Std = Fleet average fuel consumption standard (gal/100 mile)
CO2 Act = Fleet average actual CO2 value (g/
mi)
FC Act = Fleet average actual fuel consumption value (gal/100 mile)
Volume = the total production of vehicles in the regulatory class
UL = the useful life for the regulatory class (miles)
We are proposing that HD pickups and vans comprise a self-contained
averaging set, such that credits earned may be used freely for other HD
pickups and vans but not for other vehicles or engines, and credits
generated by other vehicles or engines may not be used to demonstrate
compliance for HD pickups and vans. We believe this approach is
appropriate because the HD pickup and van fleet is relatively small and
the balanced fleetwide averaging concept is critical for obtaining the
desired technology development in the 2014-2018 timeframe, so that the
potential for large credit flows into or out of this vehicle category
would create unwarranted market uncertainty, which in turn could
jeopardize the impetus to develop needed technologies. An exception to
this approach is proposed for advanced technology credits as discussed
in Section IV.B(2).
[[Page 74255]]
As described above, HD pickup and van manufacturers would be able
to carry forward deficits from their fleet-wide average for three years
before reconciling the shortfall. Manufacturers would be required to
provide a plan in their pre-model year reports showing how they would
resolve projected credit deficits. However, just as in the engine
category, manufacturers would need to use credits earned once those
credits have been generated to offset a shortfall before those credits
can be banked or traded for additional model years. This restriction
reduces the chance of vehicle manufacturers passing forward deficits
before reconciling their shortfalls and exhausting those credits before
reconciling past deficits. We request comments on all aspects of the
proposed HD pickup and van credit program.
B. Additional Proposed Flexibility Provisions
The agencies are also proposing provisions to facilitate reductions
in GHG emissions and fuel consumption beginning in the 2014 model year.
While we view our proposed ABT and flexibility structure as sufficient
to encourage reduction efforts by heavy-duty highway engine and vehicle
manufacturers, we understand that other efforts may enhance the overall
GHG and fuel consumption reduction we anticipate achieving. Therefore
we propose the following flexibilities to create additional
opportunities for manufacturers to reduce their GHG emissions and fuel
consumption. These opportunities would help provide additional
incentives for manufacturers to innovate and to develop new strategies
and cleaner technologies.
(1) Early Credit Option
The agencies are proposing that manufacturers of HD engines,
combination tractors, and vocational vehicles be eligible to generate
early credits if they demonstrate improvements in excess of the
proposed standards prior to model year they become effective. The start
dates for EPA's GHG standards and NHTSA's fuel consumption standards
vary by regulatory category (see Section II for the model years when
the standards become effective). Specifically, manufacturers would need
to certify their engines or vehicles to the standards at least six
months before the start of the first model year of the mandatory
standards. The limitations on the use of credits in the ABT programs--
i.e., limiting averaging to within each the regulatory category and
vehicle or engine subcategory--would apply for the proposed early
credits as well.
NHTSA and EPA also request comment on whether a credit multiplier,
specifically a multiplier of 1.5, would be appropriate to apply to
early credits from HD engines, combination tractors, and vocational
vehicles, as a greater incentive for early compliance. Additionally,
the agencies seek comment on whether or not a requirement that HD
engines, combination tractors, and vocational vehicles that are
eligible to generate early credits, be allowed to do so only if they
certify prior to June 1, 2013 should a multiplier of 1.5 be applied to
early credits.
We are proposing that manufacturers of HD pickups and vans who
demonstrate improvements for model year 2013 such that their fleet
average emissions and fuel consumption are lower than the model year
2014 standards be eligible for early credits. Under the proposed
structure for the fleet average standards, this credit opportunity
would entail certifying a manufacturer's entire HD pickup and van fleet
in model year 2013, and assessing this fleet against the model year
2014 target levels discussed in Section II. The agencies consider the
proposed availability of early credits to be a valuable complement to
the overall program to the extent that they encourage early
implementation of effective technologies. We request comment on ways
the early credit opportunities can be tailored to accomplish this
objective and protect against unanticipated windfalls.
(2) Advanced Technology Credits
EPA and NHTSA are proposing targeted provisions that we expect
would promote the implementation of advanced technologies.
Specifically, manufacturers that incorporate these technologies would
be eligible for special credits that could be applied to other heavy-
duty vehicles or engines, including those in other heavy-duty
categories. We seek comment on any conversion factors that may be
needed. Technologies that we propose to make eligible are:
Hybrid powertrain designs that include energy storage
systems.
Rankine cycle engines.
All-electric vehicles.
Fuel cell vehicles.
NHTSA and EPA request comment on whether a credit multiplier,
specifically a multiplier of 1.5, would be appropriate to apply to
advanced technology credits, as a greater incentive for their
introduction. NHTSA and EPA request comment on the list of technologies
identified as advanced technologies and whether additional technologies
should be added to the list. NHTSA and EPA also request comment on
whether credits generated from vehicles complying prior to 2014 and
using Advanced SmartWay or Advanced SmartWay II aerodynamic
technologies should be designated as Advanced Technology Credits.
(a) All-Electric Vehicles and HD Pickup Truck and Van Hybrids
For HD pickup and van hybrids, we propose that testing would be
done using adjustments to the test procedures developed for light-duty
hybrids. NHTSA and EPA are also proposing that all-electric and other
zero emission vehicles produced in model years before 2014 be able to
earn credits for use in the 2014 and later HD pickup and van compliance
program, provided the vehicles are covered by an EPA certificate of
conformity for criteria pollutants. These credits would be calculated
based on the 2014 diesel standard targets corresponding to the
vehicle's work factor, and treated as though they were earned in 2014
for purposes of credit life. Manufacturers would not have to early-
certify their entire HD pickup and van fleet in a model year as for
other early-complying vehicles. NHTSA and EPA are also proposing that
model year 2014 and later EVs and other zero emission vehicles be
factored into the fleet average GHG and fuel consumption calculations
based on the diesel standards targets for their model year and work
factor. If advanced technology credits generated by pickups and vans
are used in another HD vehicle category, these credits would, of
course, be subtracted from the manufacturer's pickup and van category
credit balance.
In the 2012-2016 MY Light-Duty Vehicle Rule, EPA discussed at
length the issue of whether to account for upstream emissions of GHGs
in assessing the amount of credit to offer to various types of electric
vehicles--that is, GHG emissions associated with generation of the
electricity needed to power the electric vehicle. See 75 FR 25434-
25436. Although acknowledging that such emissions would not be
accounted for if electric vehicle GHG emissions are assessed at zero
for credit generating purposes, EPA believed that this was the
appropriate course in order to provide an incentive for
commercialization of this extremely promising technology. At the same
time, EPA adopted a cumulative cap whereby upstream emissions would be
accounted for if sales of EVs exceeded a given amount.
[[Page 74256]]
The agencies believe that these same considerations apply to heavy-
duty vehicles. Indeed, the agencies believe that introduction of EVs
into the heavy-duty fleet would be less frequent than for light-duty
vehicles, so that there is less risk of dilution of the main standards
by unexpectedly high introduction of EVs into the heavy-duty fleet and
at least an equally compelling reason to provide an incentive for the
technology's commercial introduction. Given the unlikelihood of
significant penetration of the technology in the model years of these
standards, the agencies similarly do not see a need to adopt the type
of cumulative caps which would trigger an upstream emission accounting
procedure as in the light-duty vehicle rule. The agencies solicit
comment on these issues, however.
(b) Vocational Vehicle and Tractor Hybrids
For vocational vehicles or combination tractors incorporating
hybrid powertrains, we propose two methods for establishing the number
of credits generated, each of which is discussed next. The agencies are
not aware of models that have been adequately peer reviewed with data
that can assess this technology without the conclusion of a comparison
test of the actual physical product.
(i) Chassis Dynamometer Evaluation
For hybrid certification to generate credits we propose to utilize
chassis testing as an effective way to compare the CO2
emissions and fuel consumption performance of conventional and hybrid
vehicles. We are proposing that heavy-duty hybrid vehicles be certified
using ``A to B'' vehicle chassis dynamometer testing. This concept
allows a hybrid vocational vehicle manufacturer to directly quantify
the benefit associated with use of its hybrid system on an application-
specific basis. The concept would entail testing the conventional
vehicle, identified as ``A'', using the cycles as defined in Section V.
The ``B'' vehicle would be the hybrid version of vehicle ``A''. The
``B'' vehicle would need to be the same exact vehicle model as the
``A'' vehicle. As an alternative, if no specific ``A'' vehicle exists
for the hybrid vehicle that is the exact vehicle model, the most
similar vehicle model would need to be used for testing. We propose to
define the ``most similar vehicle'' as a vehicle with the same
footprint, same payload, same testing capacity, the same engine power
system, the same intended service class, and the same coefficient of
drag.
To determine the benefit associated with the hybrid system for GHG
performance, the weighted CO2 emissions results from the
chassis test of each vehicle would define the benefit as described
below:
1. (CO2--A-CO2--B)/(CO2--A) = --------
(Improvement Factor)
2. Improvement Factor x GEM CO2 Result--B = -------- (g/ton
mile benefit)
Similarly, the benefit associated with the hybrid system for fuel
consumption would be determined from the weighted fuel consumption
results from the chassis tests of each vehicle as described below:
3. (Fuel Consumption--A-Fuel Consumption--B)/(Fuel Consumption--A) = --
------ (Improvement Factor)
4. Improvement Factor x GEM Fuel Consumption Result--B = --------
(gallon/1,000 ton mile benefit)
The credits for the hybrid vehicle would be calculated as described
in the ABT program by Equation IV-5 and Equation IV-6, except that the
result from Equation 2 above replaces the (Std-FEL) value. We are
proposing that the tons of CO2 or gallons of fuel credits
generated by a hybrid vehicle could flow into any regulatory
subcategory.
The agencies are proposing two sets of duty cycles to evaluate the
benefit depending on the vehicle application to assess hybrid vehicle
performance--without and with PTO systems. The key difference between
these two sets of vehicles is that one set (e.g., delivery trucks) does
not operate a PTO while the other set (e.g., bucket and refuse trucks)
does.
The first set of duty cycles would apply to the hybrid powertrains
used to improve the motive performance of the vehicles without a PTO
system (such as pickup and delivery trucks). The typical operation of
these vehicles is very similar to the overall drive cycles proposed in
Section II. Therefore, the agencies are proposing to use the same
vehicle drive cycle weightings for testing these vehicles, as shown in
Table IV-2.
[GRAPHIC] [TIFF OMITTED] TP30NO10.047
The second set of duty cycles apply to testing hybrid vehicles used
in applications such as utility and refuse trucks tend to have
additional benefits associated with use of stored energy, which avoids
main engine operation and related CO2 emissions and fuel
consumption during PTO operation. To appropriately address benefits,
exercising the conventional and hybrid vehicles using their PTO would
help to quantify the benefit to GHG emissions and fuel consumption
reductions. The duty cycle proposed to quantify the hybrid
CO2 and fuel consumption impact over this broader set of
operation would be the three primary drive cycles plus a PTO duty
cycle. Our proposed PTO cycle is based on consideration of using
alternate, appropriate duty cycles with Administrator approval in a
public process. The PTO duty cycle as proposed takes into account the
sales impact and population of utility trucks and refuse haulers. As
described in draft RIA Chapter 3, the agencies are proposing to add an
additional PTO cycle to measure the improvement achieved for this type
of hybrid powertrain application. The proposed weightings for the
hybrids with PTO are included in Table IV-3. The agencies welcome
comments on the proposed drive cycle weightings and the proposed PTO
cycle.
[[Page 74257]]
[GRAPHIC] [TIFF OMITTED] TP30NO10.048
(ii) Engine Dynamometer Evaluation
The engine test procedure we are proposing for hybrid evaluation
involves exercising the conventional engine and hybrid-engine system
based on an engine testing strategy. The basis for the system control
volume, which serves to determine the valid test article, would need to
be the most accurate representation of real world functionality. An
engine test methodology would be considered valid to the extent the
test is performed on a test article that does not mischaracterize
criteria pollutant performance or actual system performance. Energy
inputs should not be based on simulation data which is not an accurate
reflection of actual real world operation. It is clearly important to
be sure credits are generated based on known physical systems. This
includes testing using recovered vehicle kinetic energy. Additionally,
the duty cycle over which this engine-hybrid system would be exercised
would need to reflect the use of the application, while not promoting a
proliferation of duty cycles which prevent a standardized basis for
comparing hybrid system performance. The agencies are proposing the use
of the Heavy-duty FTP cycle for evaluation of hybrid vehicles, which is
the same test cycle proposed for engines used in vocational vehicles.
For powerpack testing, which includes the engine and hybrid systems in
a pre-transmission format, the engine based testing is applicable for
determination of brake-specific emissions benefit versus the engine
standard. For post-transmission powertrain systems and vehicles, the
comparison evaluation based on the Improvement Factor and the GEM
result based on a vehicle drive trace in a powertrain test cell or
chassis dynamometer test cell seem to accurately reflect the
performance improvements associated with these test configurations. It
is important that introduction of clean technology be incentivized
without compromising the program intent of real world improvements in
GHG and fuel consumption performance. The agencies seek comments on the
most appropriate test procedures to accurately reflect the performance
improvement associated with hybrid systems tested using these or other
protocols.
(3) Innovative Technology Credits
NHTSA and EPA are proposing a credit opportunity intended to apply
to new and innovative technologies that reduce fuel consumption and
CO2 emissions, but for which the reduction benefits are not
captured over the test procedure used to determine compliance with the
standards (i.e., the benefits are ``off-cycle''). See 75 FR 25438-25440
where EPA adopted a similar credit program for MY 2012-2016 light-duty
vehicles. In this case, the `test procedure' includes not only the
Heavy-duty FTP and SET procedures used to measure compliance with the
engine standards, but also the GEM. Eligible innovative technologies
would be those that are newly introduced in one or more vehicle models
or engines, but that are not yet widely implemented in the heavy-duty
fleet. This could include known technologies not yet widely utilized in
a particular subcategory. Further, any credits for these off-cycle
technologies would need to be based on real-world fuel consumption and
GHG reductions that can be measured with verifiable test methods and
representing driving conditions typical of the vehicle application.
We would not consider technologies to be eligible for these credits
if the technology has a significant impact on CO2 emissions
and fuel consumption over the primary test cycles or are the
technologies on whose performance the various vehicle and engine
standards are premised. However, EPA and NHTSA are aware of some
emerging and innovative technologies and concepts in various stages of
development with CO2 emissions and fuel consumption
reduction potential that might not be adequately captured on the
proposed certification test cycles, and we believe that some of these
technologies might merit some additional CO2 and fuel
consumption credit generating potential for the manufacturer. Examples
include predictive cruise control, gear-down protection, and active
aerodynamic features not exercised in the certification test, such as
adjustable ride height for pickup trucks. We believe it would be
appropriate to provide an incentive to encourage the introduction of
these types of technologies and that a credit mechanism is an effective
way to do so. This optional credit opportunity would be available
through the 2018 model year reflecting that technologies may be common
by then, but the agencies welcome comment on the need to extend beyond
model year 2018.
EPA and NHTSA propose that credits generated using innovative
technologies be restricted within the subcategory where the credit was
generated. The agencies request comments whether credits generated
using innovative technologies should be fungible across vehicle and
engine categories.
We are proposing that manufacturers quantify CO2 and
fuel consumption reductions associated with the use of the off-cycle
technologies such that the credits could be applied based on the
proposed metrics (such as g/mile and gal/100 mile for pickup trucks, g/
ton-mile and gal/1,000 ton-mile for tractors and vocational vehicles,
and g/bhp-hr and gal/100 bhp-hr for engines). Credits would have to be
based on real additional reductions of CO2 emissions and
fuel consumption and would need to be quantifiable and verifiable with
a repeatable methodology. Such submissions of data should be submitted
to EPA and NHTSA, and would be subject to a public evaluation process
in which the public would have opportunity for comment. See 75 FR
25440. We propose that the technologies upon which the credits are
based would be subject to full useful life compliance provisions, as
with other emissions controls. Unless the manufacturer can demonstrate
that the technology would not be subject to in-use deterioration over
the useful life of the vehicle, the manufacturer would have to account
for deterioration in the estimation of the credits in order to ensure
that the credits are based on real in-use emissions reductions over the
life of the vehicle.
In cases where the benefit of a technological approach to reducing
CO2 emissions and fuel consumption cannot be adequately
represented using existing test cycles, EPA and NHTSA would review and
approve as appropriate test procedures and analytical approaches to
estimate the effectiveness of the technology for the purpose of
generating credits. The demonstration program should be robust,
verifiable, and capable of demonstrating the real-world emissions
benefit of the technology with strong statistical significance. See 75
FR
[[Page 74258]]
25440. For HD pickups and vans, EPA and NHTSA believe that the 5-cycle
approach currently used in EPA's fuel economy labeling program for
light-duty vehicles may provide a suitable test regimen, provided it
can be reliably conducted on the dynamometer and can capture the impact
of the off-cycle technology (see 71 FR 77872, December 27, 2006). EPA
established the 5-cycle test methods to better represent real-world
factors impacting fuel economy, including higher speeds and more
aggressive driving, colder temperature operation, and the use of air
conditioning.
The CO2 and fuel consumption benefit of some
technologies may be able to be demonstrated with a modeling approach.
In other cases manufacturers might have to design on-road test programs
that are statistically robust and based on real-world driving
conditions. Whether the approach involves on-road testing, modeling, or
some other analytical approach, the manufacturer would be required to
present a proposed methodology to EPA and NHTSA. EPA and NHTSA would
approve the methodology and credits only if certain criteria were met.
Baseline emissions and control emissions would need to be clearly
demonstrated over a wide range of real-world driving conditions and
over a sufficient number of vehicles to address issues of uncertainty
with the data. Data would need to be on a vehicle model-specific basis
unless a manufacturer demonstrated model-specific data was not
necessary. Approval of the approach to determining a CO2 and
fuel consumption benefit would not imply approval of the results of the
program or methodology; when the testing, modeling, or analyses are
complete the results would likewise be subject to EPA and NHTSA review
and approval. The agencies believe that suppliers and vehicle
manufacturers could work together to develop testing, modeling, or
analytical methods for certain technologies, similar to the SAE
approach used for A/C refrigerant leakage scores. As with the similar
procedure for alternative off-cycle credits under the 2012-2016 MY
light-duty vehicle program, the agencies would include an opportunity
for public comment as part of any approval process.
The agencies request comments on the proposed approach for off-
cycle emissions credits, including comments on how best to structure
the program. EPA and NHTSA particularly request comments on how the
case-by-case approach to assessing off-cycle innovative technology
credits could best be designed, including ways to ensure the
verification of real-world emissions benefits and to ensure
transparency in the process of reviewing manufacturers' proposed test
methods.
V. NHTSA and EPA Proposed Compliance, Certification, and Enforcement
Provisions
A. Overview
(1) Proposed Compliance Approach
This section describes EPA's and NHTSA's proposed program to ensure
compliance with EPA's proposed emission standards for CO2,
N2O, and CH4 and NHTSA's proposed fuel
consumption standards, as described in Section II. To achieve the goals
projected in this proposal, it is important for the agencies to have an
effective and coordinated compliance program for our respective
standards. As is the case with the Light-Duty GHG and CAFE program, the
proposed compliance program for heavy-duty vehicles and engines has two
central priorities. (1) To address the agencies' respective statutory
requirements; and (2) to streamline the compliance process for both
manufacturers and the agencies by building on existing practice
wherever possible, and by structuring the program such that
manufacturers can use a single data set to satisfy the requirements of
both agencies. It is also important to consider the provisions of EPA's
existing criteria pollutant program in the development of the approach
used for heavy-duty certification and compliance. The existing EPA
heavy-duty highway engine emissions program has an established
infrastructure and methodology that would allow effective integration
with this proposed GHG and fuel consumption program, without needing to
create new unique processes in many instances. The compliance program
would also need to address the importance of the impact of new control
methods for heavy-duty vehicles as well as other control systems and
strategies that may extend beyond the traditional purview of the
criteria pollutant program.
The proposed heavy-duty compliance program would use a variety of
mechanisms to conduct compliance assessments, including preproduction
certification and postproduction, in-use monitoring once vehicles enter
customer service. Specifically, the agencies are establishing a
compliance program that utilizes existing EPA testing protocols and
certification procedures. Under the provisions of this program,
manufacturers would have significant opportunity to exercise
implementation flexibility, based on the program schedule and design,
as well as the credit provisions that are being proposed in the program
for advanced technologies. This proposal includes a process to foster
the use of innovative technologies, not yet contemplated in the current
certification process. EPA would continue to conduct compliance preview
meetings which provide the agency an opportunity to review a
manufacturer's new product plans and ABT projections. Given the nature
of the proposed compliance program which would involve both engine and
vehicle compliance for some categories, it would be necessary for
manufacturers to begin pre-certification meetings with EPA early enough
to address issues of certification and compliance for both integrated
and non-integrated product offerings.
Based on feedback EPA and NHTSA received during the Light-Duty GHG
comment period, both agencies would seek to ensure transparency in the
compliance process. In addition to providing information in published
reports annually regarding the status of credit balances and compliance
on an industry basis, EPA and NHTSA seek comment on additional
strategies for providing information useful to the public regarding
industry's progress toward reducing GHG emissions and fuel consumption
from this sector while protecting sensitive business information.
(a) Heavy-Duty Pickup Trucks and Vans
The proposed compliance regulations (for certification, testing,
reporting, and associated compliance activities) for heavy-duty pickup
trucks and vans closely track both current practices and the recently
adopted greenhouse gas regulations for light-duty vehicles and trucks.
Thus they would be familiar to manufacturers. EPA already oversees
testing, collects and processes test data, and performs calculations to
determine compliance with both CAFE and CAA standards for Light-Duty.
For Heavy-Duty products that closely parallel light-duty pick-ups and
vans, under a coordinated approach, the compliance mechanisms for both
programs for NHTSA and EPA would be consistent and non-duplicative for
GHG pollutant standards and fuel consumption requirements. Vehicle
emission standards established under the CAA apply throughout a
vehicle's full useful life.
Under EPA existing criteria pollutant emission standard program for
heavy-duty pickup trucks and vans, vehicle manufacturers certify a
group of vehicles called a test group. A test group
[[Page 74259]]
typically includes multiple vehicle lines and model types that share
critical emissions-related features. The manufacturer generally selects
and tests a single vehicle, typically considered ``worst case'' for
criteria pollutant emissions, which is allowed to represent the entire
test group for certification purposes. The test vehicle is the one
expected to be the worst case for the emission standard at issue.
Emissions from the test vehicle are assigned as the value for the
entire test group. However, the compliance program in the recent GHG
regulations for light-duty vehicles, which is essentially the well
established CAFE compliance program, allows and may require
manufacturers to perform additional testing at finer levels of vehicle
models and configurations in order to get more precise model-level fuel
economy and CO2 emission levels. This same approach would be
applied to heavy-duty pickups and vans. Additionally, like the light-
duty program, approved use of analytically derived fuel economy would
be allowed to predict the fuel efficiency and CO2 levels of
some vehicles in lieu of testing when deemed appropriate by the
agencies. The degree to which analytically derived fuel economy would
be allowed and the design of the adjustment factors would be determined
by the agencies.
(b) Heavy-Duty Engines
Heavy-duty engine certification and compliance for traditional
criteria pollutants has been established by EPA in its current general
form since 1985. In developing a program to address GHG pollutants, it
is important to build upon the infrastructure for certification and
compliance that exists today. At the same time, it is necessary to
develop additional tools to address compliance with GHG emissions
requirements, since the proposed standard reflect control strategies
that extend beyond those of traditional criteria pollutants. In so
doing, the agencies are proposing use of EPA's current engine test
based strategy--currently used for criteria pollutant compliance--to
also measure compliance for GHG emissions. The agencies are also
proposing to add new strategies to address vehicle specific designs and
hardware which impact GHG emissions. The traditional engine approach
would largely match the existing criteria pollutant control strategy.
This would allow the basic tools for certification and compliance,
which have already been developed and implemented, to be expanded for
carbon dioxide, methane, and nitrous oxide. Engines with similar
emissions control technology may be certified in engine families, as
with criteria pollutants.
For EPA, the proposed approach for certification would follow the
current process, which would require manufacturer submission of
certification applications, approval of the application, and receipt of
the certificate of conformity prior to introduction into commerce of
any engines. EPA proposes the certificate of conformity be a single
document that would be applicable for both criteria pollutants and
greenhouse gas pollutants. NHTSA would assess compliance with its fuel
consumption standards based on the results of the EPA GHG emissions
compliance process for each engine family.
(c) Class 7 and 8 Combination Tractors and Class 2b-8 Vocational
Vehicles
Currently, except for HD pickups and vans, EPA does not directly
regulate exhaust emissions from heavy-duty vehicles as a complete
entity. Instead, a compliance assessment of the engine is undertaken as
described above. Vehicle manufacturers installing certified engines are
required to do so in a manner that maintains all functionality of the
emission control system. While no process exists for certifying these
heavy-duty vehicles, the agencies believe that a process similar to the
one we propose for use for heavy-duty engines can be applied to the
vehicles.
The agencies are proposing related certification programs for
heavy-duty vehicles. Manufacturers would divide their vehicles into
families and submit applications to each agency for certification for
each family. However, the demonstration of compliance would not require
emission testing of the complete vehicle, but would instead involve a
computer simulation model, GEM. This modeling tool uses a combination
of manufacturer-specified and agency-defined vehicle parameters to
estimate vehicle emissions and fuel consumption. This model would then
be exercised over certain drive cycles. EPA and NHTSA are proposing the
duty cycles over which Class 7 and 8 combination tractors would be
exercised to be: 65 mile per hour steady state cruise cycle, the 55
mile per hour steady state cruise cycle, and the California ARB
transient cycle. Additional details regarding these duty cycles will be
addressed in Section V.D(1)(b) below. Over each duty cycle, the
simulation tool would return the expected CO2 emissions, in
g/ton-mile, and fuel consumption, gal/1,000 ton-mile, which would then
be compared to the standards.
B. Heavy-Duty Pickup Trucks and Vans
(1) Proposed Compliance Approach
EPA and NHTSA are proposing new emission standards to control
greenhouse gases (GHGs) and reduce fuel consumption from heavy-duty
trucks between a gross vehicle weight rating between 8,500 and 14,000
pounds that are not already covered under the MY 2012-2016 light-duty
truck and medium-duty passenger vehicle GHG standards. In this section
``trucks'' now refers to heavy-duty pickup trucks and vans between
8,500 and 14,000 pounds not already covered under the above light-duty
rule.
First, EPA is proposing fleet average emission standards for
CO2 on a gram per mile (g/mile) basis and NHTSA is proposing
fuel consumption standards on a gal/100 mile basis that would apply to
a manufacturer's fleet of heavy-duty trucks and vans with a GVWR from
8,500 pounds to 14,000 pounds (Class 2b and 3). CO2 is the
primary pollutant resulting from the combustion of vehicular fuels, and
the amount of CO2 emitted is highly correlated to the amount
of fuel consumed. In addition, the EPA is proposing separate emissions
standards for three other GHG pollutants: CH4,
N2O, and HFC. CH4 and N2O emissions
relate closely to the design and efficient use of emission control
hardware (i.e., catalytic converters). The standards for CH4
and N2O would be set as caps that would limit emissions
increases and prevent backsliding from current emission levels. In lieu
of meeting the caps, EPA is optionally proposing that manufacturer
could offset any N2O emissions or any CH4
emissions above the cap by taking steps to further reduce
CO2. Separately, EPA is proposing to set standards to
control the leakage of HFCs from air conditioning systems. EPA and
NHTSA are requesting comment on the opportunity for manufacturers to
earn credits toward the fleet-wide average CO2 and fuel
consumption standards for improvements to air conditioning system
efficiency that reduce the load on the engine and thereby reduce
CO2 emissions and fuel consumption.
Previously, complete vehicles with a Gross Vehicle Weight Rating of
8,500-14,000 pounds could be certified according to 40 CFR part 86,
subpart S. These heavy-duty chassis certified vehicles were required to
pass emissions on both the Light-duty FTP and HFET (California
certified only
[[Page 74260]]
requirement).\197\ These proposed rules would use the same testing
procedures already required for heavy-duty chassis certification,
namely the Light-duty FTP and the HFET but extend the requirement for
chassis certification for CO2 emissions to diesel-powered
vehicles. Currently, chassis certification is a gasoline requirement
and a diesel option. Using the data from these two tests, EPA and NHTSA
would compare the CO2 emissions and fuel consumption results
against the attribute-based target. The attribute upon which the
CO2 standard would be based would be a function of vehicle
payload, vehicle towing capacity and two-wheel versus four-wheel drive
configuration as discussed in Section II.C(1)(b) of this notice. The
attribute-based standard targets would be used to determine a
manufacturer fleet standard and would be subject to an average banking
and trading scheme similar to the light-duty GHG rule.
---------------------------------------------------------------------------
\197\ Diesel engines are engine-certified with the option to
chassis certification Federally and for California.
---------------------------------------------------------------------------
This proposal would require nearly all heavy-duty trucks between
8,500 and 14,000 pounds gross vehicle weight rating that are not
already covered under the light-duty truck and medium-duty passenger
vehicle GHG standards to have a CO2, CH4 and
N2O values assigned to them, either from actual chassis
dynamometer testing or from the results of a representative vehicle in
the test group with appropriate adjustments made for differences. This
requirement would apply based on whether the vehicle manufacturer sold
the vehicle as a complete or nearly complete vehicle.\198\
Manufacturers would be allowed to exclude vehicles they sell to
secondary manufacturers without cabs (often known as rolling chassis),
as well as a very small number of vehicles sold with cabs.
Specifically, a manufacturer could certify up to two percent of its
vehicles with complete cabs, or up to 2,000 vehicles if its total sales
in this category was less than 100,000, as vocational vehicles. To the
extent manufacturers are allowed to engine certify for criteria
pollutant (non-GHG) requirements today, they would be allowed to
continue to do so under the proposed regulations.
---------------------------------------------------------------------------
\198\ The proposed regulations would use the term ``cab-complete
vehicle'' to refer to incomplete vehicles sold with complete cabs,
but lacking a cargo carrying container.
---------------------------------------------------------------------------
Because the program being proposed for heavy-duty pickup trucks and
vans is so similar to the program recently adopted for light-duty
trucks and codified in 40 CFR part 86, subpart S, EPA is proposing to
apply most of those subpart S regulatory provisions to heavy-duty
pickup trucks and vans and to not recodify them in the new part 1037.
Most of the new part 1037 would not apply for heavy-duty pickup trucks
and vans. How 40 CFR part 86 applies, and which provisions of the new
40 CFR part 1037 apply for heavy-duty pickup trucks and vans is
described in Sec. 1037.104.
(a) Certification Process
CAA section 203(a)(1) prohibits manufacturers from introducing a
new motor vehicle into commerce unless the vehicle is covered by an
EPA-issued certificate of conformity. Section 206(a)(1) of the CAA
describes the requirements for EPA issuance of a certificate of
conformity, based on a demonstration of compliance with the emission
standards established by EPA under section 202 of the Act. The
certification demonstration requires emission testing, and must be done
for each model year.\199\
---------------------------------------------------------------------------
\199\ CAA Section 206(a)(1).
---------------------------------------------------------------------------
Under existing heavy-duty chassis certification and other EPA
emission standard programs, vehicle manufacturers certify a group of
vehicles called a test group. A test group typically includes multiple
vehicle car lines and model types that share critical emissions-related
features.\200\ The manufacturer generally selects and tests one vehicle
to represent the entire test group for certification purposes. The test
vehicle is the one expected to be the worst case for the criteria
emission standard at issue.
---------------------------------------------------------------------------
\200\ The specific test group criteria are described in 40 CFR
86.1827-01, car lines and model types have the meaning given in 40
CFR 86.1803-01.
---------------------------------------------------------------------------
EPA requires the manufacturer to make a good faith demonstration in
the certification application that vehicles in the test group will both
(1) comply throughout their useful life within the emissions bin
assigned, and (2) contribute to fleetwide compliance with the
applicable emissions standards when the year is over. EPA issues a
certificate for the vehicles included in the test group based on this
demonstration, and includes a condition in the certificate that if the
manufacturer does not comply with the fleet average, then production
vehicles from that test group will be treated as not covered by the
certificate to the extent needed to bring the manufacturer's fleet
average into compliance with the applicable standards.
The certification process often occurs several months prior to
production and manufacturer testing may occur months before the
certificate is issued. The certification process for the existing
heavy-duty chassis program is an efficient way for manufacturers to
conduct the needed testing well in advance of certification, and to
receive certificates in a time frame which allows for the orderly
production of vehicles. The use of conditions on the certificate has
been an effective way to ensure that manufacturers comply throughout
their useful life and meet fleet standards when the model year is
complete and the accounting for the individual model sales is
performed. EPA has also adopted this approach as part of its LD GHG
compliance program.
EPA is proposing to similarly condition each certificate of
conformity for the GHG program upon a manufacturer's good faith
demonstration of compliance with the manufacturer's fleetwide average
CO2 standard. The following discussion explains how EPA
proposes to integrate the proposed vehicle certification program into
the existing certification program.
An integrated approach with NHTSA will be undertaken to allow
manufacturers a single point of entry to address certification and
compliance. Vehicle manufacturers would initiate the formal
certification process with their submission of application for a
certificate of conformity to EPA.
(b) Certification Test Groups and Test Vehicle Selection
For heavy-duty chassis certification to the criteria emission
standards, manufacturers currently as mentioned above divide their
fleet into ``test groups'' for certification purposes. The test group
is EPA's unit of certification; one certificate is issued per test
group. These groupings cover vehicles with similar emission control
system designs expected to have similar emissions performance (see 40
CFR 86.1827-01). The factors considered for determining test groups
include Gross Vehicle Weight, combustion cycle, engine type, engine
displacement, number of cylinders and cylinder arrangement, fuel type,
fuel metering system, catalyst construction and precious metal
composition, among others. Vehicles having these features in common are
generally placed in the same test group.\201\
---------------------------------------------------------------------------
\201\ EPA provides for other groupings in certain circumstances,
and can establish its own test groups in cases where the criteria do
not apply. See 40 CFR 86.1827-01(b), (c) and (d).
---------------------------------------------------------------------------
EPA is proposing to retain the current test group structure for
heavy-duty pickups and vans in the certification requirements for
CO2. At the time of
[[Page 74261]]
certification, manufacturers would use the CO2 emission
level from the Emission Data Vehicle as a surrogate to represent all of
the models in the test group. However, following certification further
testing would generally be allowed for compliance with the fleet
average CO2 standard as described below. EPA's issuance of a
certificate would be conditioned upon the manufacturer's subsequent
model level testing and attainment of the actual fleet average, much
like light-duty CAFE and GHG compliance requires. Under the current
program, complete heavy-duty Otto-cycle vehicles under 14,000 pounds
Gross Vehicle Weight Rating are required to chassis certify (see 40 CFR
86.1801-01(a)). The current program allows complete heavy-duty diesel
vehicles under 14,000 pounds GVWR to optionally chassis certify (see 40
CFR 86.1863-07(a)). As discussed earlier, these proposed rules would
now require all HD vehicles under 14,000 pounds GVWR to chassis certify
except as noted in Section II.
EPA recognizes that the existing heavy-duty chassis test group
criteria do not necessarily relate to CO2 emission levels.
See 75 FR 25472. For instance, while some of the criteria, such as
combustion cycle, engine type and displacement, and fuel metering, may
have a relationship to CO2 emissions, others, such as those
pertaining to the some exhaust aftertreatment features, may not. In
fact, there are many vehicle design factors that impact CO2
generation and emissions but are not major factors included in EPA's
test group criteria.\202\ Most important among these may be vehicle
weight, horsepower, aerodynamics, vehicle size, and performance
features. To remedy this, EPA is considering allowing manufacturers
provisions similar to the LD GHG rule that would yield more accurate
CO2 estimates than only using the test group emission data
vehicle CO2 emissions.
---------------------------------------------------------------------------
\202\ EPA noted this potential lack of connection between fuel
economy testing and testing for emissions standard purposes when it
first adopted fuel economy test procedures. See 41 FR 38677, Sept.
10, 1976.
---------------------------------------------------------------------------
EPA believes that the current test group concept is appropriate for
N2O and CH4 because the technologies that would
be employed to control N2O and CH4 emissions may
generally be the same as those used to control the criteria pollutants.
However, manufacturers would determine if this approach is adequate
method for N2O and CH4 emissions compliance or if
testing on additional vehicles is required to ensure the entire fleet
meet applicable standards.
As just discussed, the ``worst case'' vehicle a manufacturer
selects as the Emissions Data Vehicle to represent a test group under
the existing regulations (40 CFR 86.1828-01) may not have the highest
levels of CO2 in that group. For instance, there may be a
heavier, more powerful configuration that would have higher
CO2, but may, due to the way the catalytic converter has
been matched to the engine, actually have lower NOX, CO, PM
or HC emissions. Therefore, EPA is proposing to require a single
Emission Data Vehicle that would represent the test group for both
criteria pollutant and CO2 certification. The manufacturer
would be allowed to initially apply the Emission Data Vehicle's
CO2 emissions value to all models in the test group, even if
other models in the test group are expected to have higher
CO2 emissions. However, as a condition of the certificate,
this surrogate CO2 emissions value would generally be
replaced with actual, model-level CO2 values based on
results from additional testing that occurs later in the model year
much like the light-duty CAFE program, or through the use of approved
methods for analytically derived fuel economy. This model level data
would become the official certification test results (as per the
conditioned certificate) and would be used to determine compliance with
the fleet average. Only if the test vehicle is in fact the worst case
CO2 vehicle for the test group could the manufacturer elect
to apply the Emission Data Vehicle emission levels to all models in the
test group for purposes of calculating fleet average emissions.
Manufacturers would be unlikely to make this choice, because doing so
would ignore the emissions performance of vehicle models in their fleet
with lower CO2 emissions and would unnecessarily inflate
their CO2 fleet average. Testing at the model level would
necessarily increase testing burden beyond the minimum Emission Data
Vehicle testing.
EPA requests comment regarding whether the existing heavy-duty
chassis test group can adequately represent CO2 emissions
for certification purposes, and whether the Emission Data Vehicle's
CO2 emission level is an appropriate surrogate for all
vehicles in a test group at the time of certification, given that the
certificate would be conditioned upon additional model level testing
occurring during the year and that the surrogate CO2
emission values would be replaced with model-level emissions data from
those tests. Comments should also address EPA's desire to minimize the
up-front pre-production testing burden and whether the proposed
efficiencies would be balanced by the requirement to test all model
types in the fleet by the conclusion of the model year in order to
establish the fleet average CO2 levels.
As explained in Sections II and III, there are two standards that
the manufacturer would be subject to, the fleet average standard and
the in-use standard for the useful life of the vehicle. Compliance with
the fleet average standard is based on production weighted averaging of
the test data that applies for each model, For each model, the in-use
standard is set at 10 percent higher than the level used for that model
in calculating the fleet average. The certificate covers both of these
standards, and the manufacturer has to demonstrate compliance with both
of these standards for purposes of receiving a certificate of
conformity. The certification process for the in-use standard is
discussed above.
(c) Pre-Model Year (or Compliance Plan) Reporting
EPA and NHTSA are proposing that manufacturers submit a compliance
plan for their entire fleet prior to the certification of any test
group in a given model year. Preferably, this compliance plan would be
submitted at the manufacturer's annual certification preview meeting.
This preview meeting is typically held before the earliest date that
the model year can begin. The earliest a model year can begin is
January 2nd of the calendar year prior to the model year. This plan
would include the manufacturer's estimate of its attribute-based
standard, along with a demonstration of compliance with the standard
based on projected model-level CO2 emissions and fuel
consumption, and production estimates. This information would be
similar to the information submitted to NHTSA and EPA in the pre-model
year report required for CAFE compliance for light-duty vehicles.
Included in the compliance plan, manufacturers seeking to take
advantage of credit flexibilities would include these in their
compliance demonstration. Similarly, the compliance demonstration would
need to include a credible plan for addressing deficits accrued in
prior model years. EPA and NHTSA would review the compliance plan for
technical viability and conduct a certification preview discussion with
the manufacturer. The agencies would view the compliance plan as part
of the manufacturer's good faith demonstration, but understands that
initial projections can vary considerably from the reality of final
production and emission results. In
[[Page 74262]]
addition, the compliance plan must be approved by the EPA Administrator
prior to any certificate of compliance being issued. The agencies
request comment on the proposal to evaluate manufacturer compliance
plans prior to the beginning of model year certification.
(d) Demonstrating Compliance With the Proposed Standards
(i) CO2 and Fuel Consumption Fleet Standards
As noted, attribute-based CO2 standards result in each
manufacturer having a fleet average CO2 standard unique to
its heavy-duty truck fleet of GVWR between 8,500-14,000 pounds and that
standard would be separate from the standard for passenger cars, light-
trucks, and other heavy-duty trucks. The standards depend on those
attributes corresponding to the relative capability, or ``work
factor'', of the vehicle models produced by that manufacturer. The
proposed attributes used to determine the stringency of the
CO2 standard are payload and towing capacity as described in
Section II.C of this notice. Generally, fleets with a mix of vehicles
with increased payloads or greater towing capacity (or utilizing four
wheel drive configurations) would face numerically less stringent
standards (i.e., higher CO2 grams/mile standards) than
fleets consisting of less powerful vehicles. (However, the standards
would be expected to be equally challenging and achieve similar percent
reductions.) Although a manufacturer's fleet average standard could be
estimated throughout the model year based on projected production
volume of its vehicle fleet, the final compliance values would be based
on the final model year production figures. A manufacturer's
calculation of fleet average emissions at the end of the model year
would be based on the production-weighted average emissions of each
model in its fleet. The payload and towing capacity inputs used to
determine manufacturer compliance with these proposed rules would be
the advertised values.
The agencies propose to use the same general vehicle category
definitions that are used in the current EPA HD chassis certification
(See 40 CFR 86.1816-05). The new vehicle category definitions differ
slightly from the EPA definitions for Heavy-duty Vehicle definitions
for the existing program, as well as other EPA vehicle programs.
Mainly, manufacturers would be able to test, and possibly model, more
configurations of vehicles than were historically in a given test
group. The existing criteria pollutant program requires the worst case
configuration be tested for emissions certification. For HD chassis
certification, this usually meant only testing the vehicle with the
highest ALVW, road-load, and engine displacement within a given test
group. This worst case configuration may only represent a small
fraction of the test group production volume. By testing the worst
case, albeit possibly small volume, vehicle configuration, the EPA had
a reasonable expectation that all represented vehicles would pass the
given emissions standards. Since CO2 standards are a fleet
standard based on a combination of sales volume and work factor (i.e.,
payload and towing capability), it may be in a manufacturer's best
interest to test multiple configurations within a given test group to
more accurately estimate the fleet average CO2 emission
levels and not accept the worst case vehicle test results as
representative of all models. Additionally, vehicle models for which a
manufacturer desires to use analytically derived fuel economy (ADFE) to
estimate CO2 emission levels may need additional actual test
data for vehicle models of similar but not identical configurations.
The agencies are requesting comment on allowing the manufacturer to
test as many configurations within a test group as the manufacturer
requires in order to best represent the volumes of each configuration
within that test group. The agencies are also requesting comment on
using an ADFE approach similar to that used by light-duty vehicles, as
explained in the light-duty vehicle/light-duty truck EPA guidance
document CCD-04-06 titled ``Updated Analytically Derived Fuel Economy
(ADFE) Policy for 2005 MY and Later'', but expanded to a greater
fraction of possible subconfigurations and using lower confidence
limits than used for light-duty vehicles and light-duty trucks.
The agencies are proposing the use of ADFE similar to that allowed
for light-duty vehicles in 40 CFR 600.006-08(e). This provision would
allow EPA and NHTSA to accept analytical expressions to generate
CO2 and fuel economy that have been approved in advance by
the agencies.
For model years 2014 through 2017, or earlier if a manufacturer is
certifying in order to generate early credits, EPA is proposing the
equation and parameter values as expressed in Section II C or assigning
a CO2 level to an individual vehicle's relevant attributes.
These CO2 values would be production weighted to determine
each manufacturer's fleet average. Each parameter would change on an
annual basis, resulting in the annual increase in stringency. For the
function used to describe the proposed standard, see Section II.C of
this notice.
The GHG and fuel economy rulemaking for light-duty vehicles adopted
a carbon balance methodology used historically to determine fuel
consumption for the light-duty labeling and CAFE programs, whereby the
carbon-related combustion products HC and CO are included on an
adjusted basis in the compliance calculations, along with
CO2. The resulting carbon-related exhaust emissions (CREE)
of each test vehicle is calculated and it is this value, rather than
simply CO2 emissions, that is used in compliance
determinations. The difference between the CREE and CO2 is
typically very small.
NHTSA and EPA are not proposing to adopt the CREE methodology for
HD pickups and vans, and so are not proposing to adjust CO2
emissions to further account for additional HC and CO. The basis of the
CREE methodology in historical labeling and CAFE programs is not
relevant to HD pickups and vans, because these historical programs do
not exist for HD vehicles. Furthermore, test data used in this proposal
for standards-setting has not been adjusted for this effect, and so it
would create an inconsistency, albeit a small one, to apply it for
compliance with the numerical standards we are proposing. Finally, it
would add complexity to the program with little real world benefit. We
request comment on this proposed approach.
(ii) CO2 In-Use Standards and Testing
Section 202(a)(1) of the CAA requires emission standards to apply
to vehicles throughout their statutory useful life. Section II.B(3)(b)
of this proposal discusses in-use standards.
Currently, EPA regulations require manufacturers to conduct in-use
testing as a condition of certification for heavy-duty trucks between
8,500 and 14,000 gross vehicle weight that are chassis certified. The
vehicles are tested to determine the in-use levels of criteria
pollutants when they are in their first and third years of service.
This testing is referred to as the In-Use Verification Program, which
was first implemented as part of EPA's CAP 2000 certification program
(see 64 FR 23906, May 4, 1999).
EPA is requesting comment on applying the in-use program already
set forth in the 2012-2016 MY light-duty vehicle rule to heavy-duty
pickups and vans. The In-Use Verification Program for heavy-duty
pickups and vans would follow the same general provisions of the light-
duty program in regard to
[[Page 74263]]
testing, vehicle selection, and reporting. See 75 FR 25474-25476.
(e) Cab-Chassis Vehicles and Complete Class 4 Vehicles
As discussed in Section I.C(2)(a), we are proposing to include most
cab-chassis Class 2b and 3 vehicles in the complete HD pickup and van
program. Because their numbers are relatively small, and to reduce the
testing and compliance tracking burden to manufacturers, we would treat
these vehicles as equivalent to the complete van or truck product they
are derived from. The manufacturer would determine which complete
vehicle configuration it produces most closely matches the cab-chassis
product leaving its facility, and would include each of these cab-
chassis vehicles in the fleet averaging calculations as though it were
identical to the corresponding complete vehicle.
Any in-use testing of these vehicles would do likewise, with
loading of the tested vehicle to a total weight equal to the ALVW of
the corresponding complete vehicle configuration. If the secondary
manufacturer had altered or replaced any vehicle components in a way
that would substantially affect CO2 emissions from the
tested vehicle (e.g., axle ratio has been changed for a special purpose
vehicle), the vehicle manufacturer could request that EPA not test the
vehicle or invalidate a test result. Secondary (finisher) manufacturers
would not be subject to requirements under this provision, other than
to comply with anti-tampering regulations. However, if they modify
vehicle components in such a way that GHG emissions and fuel
consumption are substantially affected, they become manufacturers
subject to the standards under this proposal.
We realize that this approach does not capture the likely loss of
aerodynamic efficiency involved in converting these vehicles from
standard pickup trucks or vans to ambulances and the like, and thus it
could assign them lower GHG emissions and fuel consumption than they
deserve. However, we feel that this approach strikes a fair balance
between the alternatives--grouping these vehicles with vocational
vehicles subject only to engine standards and tire requirements, or
creating a complex and burdensome program that forces vehicle
manufacturers to track, and perhaps control, a plethora of vehicle
configurations they currently do not manage. We request comment on this
proposed provision and any suggestions for ways to improve it.
Some complete Class 4 trucks are very similar to complete Class 3
pickup truck models, including their overall vehicle architecture and
use of the same basic engines. EPA and NHTSA request comment on whether
these vehicles should be regulated as part of the HD pickup and van
category and thereby be subject to that regulatory regime (i.e.,
standard stringency, chassis-based compliance for entire vehicle,
credit opportunities limited to HD pickup and van subcategory, etc.),
instead of as vocational vehicles as currently proposed. Comment is
also requested on whether such chassis certification should be allowed
as a manufacturer's option instead, and on whether vehicles so
certified for GHG emissions and fuel consumption should also be allowed
to certify to chassis-based criteria pollutant standards as well.
Commenters are asked to address the environmental impacts of this
potential change.
(2) Proposed Labeling Provisions
HD pickups and vans currently have vehicle emission control
information labels showing compliance with criteria pollutant
standards, similar to emission control information labels for engines.
As with engines, we believe this label is sufficient.
(3) Other Certification Issues
(a) Carryover Certification Test Data
EPA's proposed certification program for vehicles allows
manufacturers to carry certification test data over from one model year
to the next, when no significant changes to models are made. EPA will
also apply this policy to CO2, N2O and
CH4 certification test data.
(b) Compliance Fees
The CAA allows EPA to collect fees to cover the costs of issuing
certificates of conformity for the classes of vehicles and engines
covered by this proposal. On May 11, 2004, EPA updated its fees
regulation based on a study of the costs associated with its motor
vehicle and engine compliance program (69 FR 51402). At the time that
cost study was conducted the current rulemaking was not considered.
At this time the extent of any added costs to EPA as a result of
this proposal is not known. EPA will assess its compliance testing and
other activities associated with the rule and may amend its fees
regulations in the future to include any warranted new costs.
C. Heavy-Duty Engines
(1) Proposed Compliance Approach
Section 203 of the CAA requires that all motor vehicles and engines
sold in the United States to carry a certificate of conformity issued
by the U.S. EPA. For heavy-duty engines, the certificate specifies that
the engine meets all requirements as set forth in the regulations (40
CFR part 86, subpart N, for criteria pollutants) including the
requirement that the engine be compliant with emission standards. This
demonstration is completed through emission testing as well as
durability testing to determine the level of emissions deterioration
throughout the useful life of the engine. In addition to compliance
with emission standards, manufacturers are also required to warrant
their products against emission defects, and demonstrate that a service
network is in place to correct any such conditions. The engine
manufacturer also bears responsibility in the event that an emission-
related recall is necessary. Finally, the engine manufacturer is
responsible for tracking and ensuring correct installation of any
emission related components installed by a second party (i.e., vehicle
manufacturer). EPA believes this compliance structure is also valid for
administering the proposed GHG regulations for heavy-duty engines.
(a) Certification Process
In order to obtain a certificate of conformity, engine
manufacturers must complete a compliance demonstration, normally
consisting of test data from relatively new (low-hour) engines as well
as supporting documentation, showing that their product meets emission
standards and other regulatory requirements. To account for aging
effects, low-hour test results are coupled with testing-based
deterioration factors (DFs), which provide a ratio (or offset) of end-
of-life emissions to low-hour emissions for each pollutant being
measured. These factors are then applied to all subsequent low-hour
test data points to predict the emissions behavior at the end of the
useful life.
For purposes of this compliance demonstration and certification,
engines with similar engine hardware and emission characteristics
throughout their useful life may be grouped together in engine
families, consistent with current criteria-pollutant certification
procedures. Examples of such characteristics are the combustion cycle,
aspiration method, and aftertreatment system. Under this system, the
worst-case engine (``parent rating'') is selected based on having the
highest fuel feed per engine stroke, and all emissions testing is
completed on this model. All other models within the family (``child
ratings'') are expected to have emissions at or below the parent model
and therefore in compliance with emission standards. Any engine within
the family
[[Page 74264]]
can be subject to selective enforcement audits, in-use, confirmatory,
or other compliance testing.
We are proposing to continue to use this approach for the selection
of the worst-case engine (``parent rating'') for fuel consumption and
GHG emissions as well. We believe this is appropriate because this
worst case engine configuration would be expected to have the highest
in-use fuel consumption and GHG emissions within the family. We note
that lower engine ratings contained within this family would be
expected to have a higher fuel consumption rate when measured over the
Federal Test Procedures as expressed in terms of fuel consumption per
brake horsepower hour. This higher fuel consumption rate is misleading
in the context of comparing engines within a single engine family. This
seeming contradiction can be most easily understood in terms of an
example. For a typical engine family a top rating could be 500
horsepower with a number of lower engine ratings down to 400 horsepower
or lower included within the family. When installed in identical trucks
the 400 and 500 horsepower engines would be expected to operate
identically when the demanded power from the engines is 400 horsepower
or less. So in the case where in-use driving never included
acceleration rates leading to horsepower demand greater than 400
horsepower, the two trucks with the 400 and 500 horsepower engines
would give identical fuel consumption and GHG performance. When the
desired vehicle acceleration rates were high enough to require more
than 400 horsepower, the 500 horsepower truck would accelerate faster
than the 400 horsepower truck resulting in higher average speeds and
higher fuel consumption and GHG emissions measured on a per mile or per
ton-mile basis. Hence, the higher rated engine family would be expected
to have the highest in-use fuel consumption and CO2
emissions.
The reason that the lower engine ratings appear to have worse fuel
consumption relates to our use of a brake specific work metric. The
brake specific metric measures power produced from the engine and
delivered to the vehicle ignoring the parasitic work internal to the
engine to overcome friction and air pumping work within the engine. The
fuel consumed and GHG emissions produced to overcome this internal work
and to produce useful (brake) work are both measured in the test cycle
but only the brake work is reflected in the calculation of the fuel
consumption rate. This is desirable in the context of reducing fuel
consumption as this approach rewards engine designs that minimize this
internal work through better engine designs. The less work that is
needed internal to the engine, the lower the fuel consumption will be.
If we included the parasitic work in the calculation of the rate, we
would provide no incentive to reduce internal friction and pumping
losses. However, when comparing two engines within the very same family
with identical internal work characteristics, this approach gives a
misleading comparison between two engines as described above. This is
the case because both engines have an identical fuel consumption rate
to overcome internal work but different rates of brake work with the
higher horsepower rating having more brake work because the test cycle
is normalized to 100 percent of the engine's rated power. The fuel
consumed for internal work can be thought of as a fixed offset
identical between both engines. When this fixed offset is added to the
fuel consumed for useful (brake) work over the cycle, it increases the
overall fuel consumption (the numerator in the rate) without adding any
work to the denominator. This fixed offset identical between the two
engines has a bigger impact on the lower engine rating. In the extreme
this can be seen easily. As the engine ratings decrease and approach
zero, the brake work approaches zero and the calculated brake specific
fuel consumption approaches infinity. For these reasons, we are
proposing that the same selection criteria, as outlined in 40 CFR part
86, subpart N, be used to define a single engine family designation for
both criteria pollutant and GHG emissions. Further, we are proposing
that for fuel consumption and CO2 emissions only any
selective enforcement audits, in-use, confirmatory, or other compliance
testing would be limited to the parent rating for the family. This
approach is being contemplated for administrative convenience and we
seek comments on alternatives to address compliance testing. Consistent
with the current regulations, manufacturers may electively subdivide a
grouping of engines which would otherwise meet the criteria for a
single family if they have evidence that the emissions are different
over the useful life.
The agency utilizes a 12-digit naming convention for all mobile-
source engine families (and test groups for vehicles). This convention
is also shared by the California Air Resources Board which allows
manufacturers to potentially use a single family name for both EPA and
California ARB certification. Of the 12 digits, 9 are EPA-defined and
provide identifying characteristics of the engine family. The first
digit represents the model year, through use of a predefined code. For
example, ``A'' corresponds to the 2010 model year and ``B'' corresponds
to the 2011 model year. The 5th position corresponds to the industry
sector code, which includes such examples as light-duty vehicle (V) and
heavy-duty diesel engines (H). The next three digits are a unique
alphanumeric code assigned to each manufacturer by EPA. The next four
digits describe the displacement of the engine; the units of which are
dependent on the industry segment and a decimal may be used when the
displacement is in liters. For engine families with multiple
displacements, the largest displacement is used for the family name.
For on-highway vehicles and engines, the tenth character is reserved
for use by California ARB. The final characters (including the 10th
character in absence of California ARB guidance) left to the
manufacturer to determine, such that the family name forms a unique
identifying characteristic of the engine family.
This convention is well understood by the regulated industries,
provides sufficient detail, and is flexible enough to be used across a
wide spectrum of vehicle and engine categories. In addition, the
current harmonization with other regulatory bodies reduces
complications for affected manufacturers. For these reasons, we are not
proposing any major changes to this naming convention for this
proposal. There may be additional categories defined for the 5th
character to address heavy-duty vehicle test groups, however that will
be discussed later.
As with criteria pollutant standards, the heavy-duty diesel
regulatory category is subdivided into three regulatory subcategories,
depending on the GVW of the vehicle in which the engine will be used.
These regulatory subcategories are defined as light-heavy-duty (LHD)
diesel, medium heavy-duty (MHD) diesel, and heavy heavy-duty (HHD)
diesel engines. All heavy-duty gasoline engines are grouped into a
single subcategory. Each of these regulatory subcategories are expected
to be in service for varying amounts of time, so they each carry
different regulatory useful lives. For this reason, expectations for
demonstrating useful life compliance differ by subcategory,
particularly as related to deterioration factors.
Light heavy-duty diesel engines (and all gasoline heavy-duty
engines) have
[[Page 74265]]
the same regulatory useful life as a light-duty vehicle (110,000
miles), which is significantly shorter than the other heavy-duty
regulatory subcategories. Therefore, we believe it is appropriate to
maintain commonality with the light-duty GHG rule. During the light-
duty GHG rulemaking, the conclusion was reached that no significant
deterioration would occur over the useful life. Therefore, EPA is
proposing to specify that manufacturers would use assigned DFs for
CO2 and the values would be zero (for additive DFs) and one
(for multiplicative DFs). EPA is interested in data that addresses this
issue.
For the medium heavy-duty and heavy heavy-duty diesel engine
segments, the regulatory useful lives are significantly longer (185,000
and 435,000 miles, respectively). For this reason, the agency is not
convinced that engine/aftertreatment wear will not have a negative
impact on GHG emissions. To address useful life compliance for MHD and
HHD diesel engines certified to GHG standards, we believe the criteria
pollutant approach for developing DFs is appropriate. Using
CO2 as an example, many of the engine deterioration concerns
previously identified will affect CO2 emissions. Reduced
compression, as a result of wear, will cause higher fuel consumption
and increase CO2 production. In addition, as aftertreatment
devices age (primarily particulate traps), regeneration events may
become more frequent and take longer to complete. Since regeneration
commonly requires an increase in fuel rate, CO2 emissions
would likely increase as well. Finally, any changes in EGR levels will
affect heat release rates, peak combustion temperatures, and
completeness of combustion. Since these factors could reasonably be
expected to change fuel consumption, CO2 emissions would be
expected to change accordingly.
HHD diesel engines may also require some degree of aftertreatment
maintenance throughout their useful life. For example, one major heavy-
duty engine manufacturer specifies that their diesel particulate
filters be removed and cleaned at intervals between 200,000 and 400,000
miles, depending on the severity of service. Another major engine
manufacturer requires servicing diesel particulate filters at 300,000
miles. This maintenance or lack thereof if service is neglected, could
have serious negative implications to CO2 emissions. In
addition, there may be emissions-related warranty implications for
manufacturers to ensure that if rebuilding or specific emissions
related maintenance is necessary, it will occur at the prescribed
intervals. Therefore, it is imperative that manufacturers are detailed
in their maintenance instructions. The agency currently seeks public
comment on how to properly address this issue.
Lean-NOX aftertreatment devices may also facilitate GHG
reductions by allowing engines to run with higher engine-out
NOX levels in exchange for more efficient calibrations. In
most cases, these aftertreatment devices require a consumable
reductant, such as diesel exhaust fluid, which requires periodic
maintenance by the vehicle operator. Without such maintenance, the
emission control system may be compromised and compliance with emission
standards may be jeopardized. Such maintenance is considered to be
critical emission related maintenance and manufacturers must therefore
demonstrate that it is likely to be completed at the required
intervals. One example of such a demonstration is an engine power de-
rate strategy that will limit engine power or vehicle speed in absence
of this required maintenance.
If the manufacturer determines that maintenance is necessary on
critical emission-related components within the useful life period,
they must have a reasonable basis for ensuring that this maintenance
will be completed as scheduled. This includes any adjustment, cleaning,
repair, or replacement of critical emission-related components.
Typically, the agency has only allowed manufacturers to schedule such
maintenance if the manufacturer can demonstrate that the maintenance is
reasonably likely to be done at the recommended intervals. This
demonstration may be in the form of survey data showing at least 80
percent of in-use engines get the prescribed maintenance at the correct
intervals. Another possibility is to provide the maintenance free of
charge. We see no reason to depart from this approach for GHG-related
critical emission-related components; however the agency welcomes
commentary on this approach.
(b) Demonstrating Compliance With the Proposed Standards
(i) CO2 Standards
The final test results (adjusted for deterioration, if applicable)
form the basis for the Family Certification Limit (FCL), which the
manufacturer must specify to be at or above the certification test
results. This FCL becomes the emission standard for the family and any
certification or confirmatory testing must show compliance with this
limit. In addition, manufacturers may choose an FCL at any level above
their certified emission level to provide a larger compliance margin.
If subsequent certification or confirmatory testing reveals emissions
above the FCL, the new, higher result becomes the FCL.
The FCL is also used to determine the Family Emission Limit (FEL),
which serves as the emission limit for any subsequent field testing
conducted after the time of certification. This would primarily include
selective enforcement audits, but also may include in-use testing and/
or production line testing for GHGs. The FEL differs from the FCL in
that it includes an EPA-defined compliance margin; currently proposed
to be 2 percent. Under this scenario the FEL would always be 2 percent
higher than the FCL.
Engine Emission Testing
Under current non-GHG engine emissions regulations, manufacturers
are required to demonstrate compliance using two test methods: The
heavy-duty transient cycle and the heavy-duty steady state test. Each
test is an engine speed versus engine torque schedule intended to be
run on an engine dynamometer. Over each test, emissions are sampled
using the equipment and procedures outlined in 40 CFR part 1065, which
includes provisions for measuring CO2, N2O, and
CH4. Emissions may be sampled continuously or in a batch
configuration (commonly known as ``bag sampling'') and the total mass
of emissions over each cycle are normalized by the engine power
required to complete the cycle. Following each test, a validation check
is made comparing actual engine speed and torque over the cycle to the
commanded values. If these values do not align well, the test is deemed
invalid.
The transient Heavy-duty FTP cycle is characteristic of typical
urban stop-and-go driving. Also included is a period of more steady
state operation that would be typical of short cruise intervals at 45
to 55 miles per hour. Each transient test consists of two 20 minute
tests separated by a ``soak'' period of 20 minutes. The first test is
run with the engine in a ``cold'' state, which involves letting the
engine cool to ambient conditions either by sitting overnight or by
forced cooling provisions outlined in Sec. 86.1335-90 (or 40 CFR part
1036). This portion of the test is meant to assess the ability of the
engine to control emissions during the period prior to reaching normal
operating temperature. This is commonly a challenging area in criteria
pollutant emission control, as cold combustion chamber surfaces tend to
inhibit mixing and vaporization of
[[Page 74266]]
fuel and aftertreatment devices do not tend to function well at low
temperatures.
Following the first test, the engine is shut off for a period of 20
minutes, during which emission analyzer checks are performed and
preparations are made for the second test (also known as the ``hot''
test). After completion of the second test, the results from the cold
and hot tests are weighted and a single composite result is calculated
for each pollutant. Based on typical in-use duty cycles, the cold test
results are given a \1/7\ weighting and the hot test results are given
a \6/7\ weighting. Deterioration factors are applied to the final
weighted results and the results are then compared to the emission
standards.
Prior to 2007, compliance only needed to be demonstrated over the
Heavy-duty FTP. However, a number of events brought to light the fact
that this transient cycle may not be as well suited for engines which
spend much of their duty cycle at steady cruise conditions, such as
those used in line-haul semi-trucks. As a result, the steady-state SET
procedure was added, consisting of 13 steady-state modes. During each
mode, emissions were sampled for a period of five minutes. Weighting
factors were then applied to each mode and the final weighted results
were compared to the emission standards (including deterioration
factors). In addition, emissions at each mode could not exceed the NTE
emission limits. Alternatively, manufacturers could run the test as a
ramped-modal cycle. In this case, the cycle still consists of the same
speed/torque modes, however linear progressions between points are
added and instead of weighting factors, each mode is sampled for
various amounts of time. The result is a continuous cycle lasting
approximately 40 minutes. With the implementation of part 1065 test
procedures in 2010, manufacturers are now required to run the modal
test as a ramped-modal cycle. In addition, the order of the speed/
torque modes in the ramped-modal cycle have changed for 2010 and later
engines.
It is well known that fuel consumption, and therefore
CO2 emissions, are highly dependent on the drive cycle over
which they are measured. Steady cruise conditions, such as highway
driving, tend to be more efficient, having lower fuel consumption and
CO2 emissions. In contrast, highly transient operation, such
as city driving, tends to lead to lower efficiency and therefore higher
fuel consumption and CO2 emissions. One example of this is
the difference between EPA-measured city and highway fuel economy
ratings assigned to all new light-duty passenger vehicles.
For this heavy-duty engine and vehicle proposal, we believe it is
important to assess CO2 emissions and fuel consumption over
both transient and steady state test cycles, as all vehicles will
operate in conditions typical of each cycle at some point in their
useful life. However, due to the drive cycle dependence of
CO2 emissions, we do not believe it is reasonable to have a
single CO2 standard which must be met for both cycles. A
single CO2 standard would likely prove to be too lax for
steady-state conditions while being too strict for transient
conditions. Therefore, the agencies are recommending that all heavy-
duty engines be tested over both transient and steady-state tests.
However, only the results from either the transient or steady-state
test cycles would be used to assess compliance with GHG standards,
depending on the type of vehicle in which the engine will be used.
Engines that will be used in Class 7 and 8 tractors would use the
ramped-modal cycle for GHG certification, and engines used in
vocational vehicles would use the Heavy-duty FTP cycle. In both cases,
results from the other test cycle would be reported but not used for a
compliance decision. Engines will continue to be required to show
criteria pollutant compliance over both cycles, in addition to NTE
requirements.
The agencies propose that manufacturers submit both composite data
sets, as well as modal data for criteria and GHG pollutants for engine
certification. This would include submission of discrete mode results
from the continuous analyzer data collected during the ramped-modal
cycle test. This would also include providing both cold start and hot
start transient heavy-duty FTP emissions results, as well as the
composite emissions at the time of certification. In an effort to
improve the accuracy of the simulation model being used for assessing
CO2 and fuel consumption performance and overall engine
emissions performance, gaseous pollutants sampled using continuous
analyzers (including but not limited to emissions results for
CO2, CO, and NOX) would need to provide the
constituent data from each of the test modes. The agencies welcome
comment on this proposed requirement. As explained above in Section II,
the agencies are proposing an alternative standard whereby
manufacturers may elect that certain of their engine families meet an
alternative percent reduction standard, measured from the engine
family's 2011 baseline, instead of the main 2014 MY standard. As part
of the certification process, manufacturers electing this standard
would not only have to notify the agency of the election but also
demonstrate the derivation of the 2011 baseline CO2 emission
level for the engine family. Manufacturers would also have to
demonstrate that they have exhausted all credit opportunities.
Durability Testing
Another element of the current certification process is the
requirement to complete durability testing to establish DFs. As
previously mentioned, manufacturers are required to demonstrate that
their engines comply with emission standards throughout the regulatory
compliance period of the engine. This demonstration is commonly made
through the combination of low-hour test results and testing based
deterioration factors.
For engines without aftertreatment devices, deterioration factors
primarily account for engine wear as service is accumulated. This
commonly includes wear of valves, valve seats, and piston rings, all of
which reduce in-cylinder pressure. Oil control seals and gaskets also
deteriorate with age, leading to higher lubricating oil consumption.
Additionally, flow properties of EGR systems may change as deposits
accumulate and therefore alter the mass of EGR inducted into the
combustion chamber. These factors, amongst others, may serve to reduce
power, increase fuel consumption, and change combustion properties; all
of which affect pollutant emissions.
For engines equipped with aftertreatment devices, DFs take into
account engine deterioration, as described above, in addition to aging
affects on the aftertreatment devices. Oxidation catalysts and other
catalytic devices rely on active precious metals to effectively convert
and reduce harmful pollutants. These metals may become less active with
age and therefore pollutant conversion efficiencies may decrease.
Particulate filters may also experience reduced trapping efficiency
with age due to ash accumulation and/or degradation of the filter
substrate, which may lead to higher tailpipe PM measurements and/or
increased regeneration frequency. If a pollutant is predominantly
controlled by aftertreatment, deterioration of emission control depends
on the continued operation of the aftertreatment device much more so
than on consistent engine-out emissions.
At this time, we anticipate that most engine component wear will
not have a significant negative impact on CO2 emissions.
However, wear and aging of
[[Page 74267]]
aftertreatment devices may or may not have a significant negative
impact on CO2 emissions. In addition, future engine or
aftertreatment technologies may experience significant deterioration in
CO2 emissions performance over the useful life of the
engine. For these reasons, we believe that the use of DFs for
CO2 emissions is both appropriate and necessary. As with
criteria pollutant emissions, these DFs are preferably developed
through testing the engine over a representative duty cycle for an
extended period of time. This is typically either half or full useful
life, depending on the regulatory class. The DFs are then calculated by
comparing the high-hour to low-hour emission levels, either by division
or subtraction (for multiplicative & additive DFs, respectively).
This testing process may be a significant cost to an engine
manufacturer, mainly due to the amount of time and resources required
to run the engine out to half or full useful life. For this reason,
durability testing for the determination of DFs is not commonly
repeated from model year to model year. In addition, some DFs may be
allowed to carry over between families sharing a common architecture
and aftertreatment system. EPA prefers to have manufacturers develop
testing-based DFs for their products, and we are proposing that this be
the case for the final rule. However, we do understand that for the
reasons stated above, it may be impractical to expect manufacturers to
have testing-based deterioration factors available for this proposal.
Therefore, we are willing to consider requiring the use of assigned DFs
for CO2. Under this possibility, we suggest that
manufacturers would be required to submit any CO2 data from
durability testing to aid in developing more accurate assigned DFs.
IRAFs/Regeneration Impacts on CO2
Heavy-duty engines may be equipped with exhaust aftertreatment
devices which require periodic ``regeneration'' to return the device to
a nominal state. A common example is a diesel particulate filter, which
accumulates PM as the engine is operated. When the PM accumulation
reaches a threshold such that exhaust backpressure is significantly
increased, exhaust temperature is actively increased to oxidize the
stored PM. The increase in exhaust temperature is commonly facilitated
through late combustion phasing and/or raw fuel injection into the
exhaust system upstream of the filter. Both methods impact emissions
and therefore must be accounted for at the time of certification. In
accordance with Sec. 86.004-28(i), this type of event would be
considered infrequent because in most cases they only occur once every
30 to 50 hours of engine operation (rather than once per transient test
cycle), and therefore adjustment factors must be applied at
certification to account for these effects.
Similar to DFs, these adjustment factors are based off of
manufacturer testing; however this testing is far less time consuming.
Emission results are measured from two test cycles: With and without
regeneration occurring. The differences in emission results are used,
along with the frequency at which regeneration is expected to occur, to
develop upward and downward adjustment factors. Upward adjustment
factors are added to all emission results derived from a test cycle in
which regeneration did not occur. Similarly, downward adjustment
factors are subtracted from results based on a cycle which did
experience a regeneration event. Each pollutant will have a unique set
of adjustment factors and additionally, separate factors are commonly
developed for transient and steady-state test cycles.
The impact of regeneration events on criteria pollutants varies by
pollutant and the aftertreatment device(s) used. In general, the
adjustment factor can have a very significant impact on compliance with
the NOX standard. For this reason, heavy-duty vehicle and
engine manufacturers are already very well motivated to extend the
regeneration frequency to as long an interval as possible and to reduce
the regeneration as much as possible. Both of these actions
significantly reduce the impact of regeneration on CO2
emissions and fuel consumption. We do not believe that adding an
adjustment factor for infrequent regeneration to the CO2 or
fuel efficiency standards would provide a significant additional
motivation for manufacturers to reduce regenerations. Moreover, doing
so would add significant and unnecessary uncertainty to our projections
of CO2 and fuel consumption performance in 2014 and beyond.
In addressing that uncertainty, the agencies would have to set less
stringent fuel efficiency and CO2 standards for heavy-duty
trucks and engines. Therefore, we are not proposing to include an
infrequent regeneration adjustment factor for CO2 or fuel
efficiency in this program. The agencies are seeking public commentary
on this approach.
Auxiliary Emission Control Devices
As part of the engine control strategy, there may be devices or
algorithms which reduce the effectiveness of emission control systems
under certain limited circumstances. These strategies are referred to
as Auxiliary Emission Control Devices (AECDs). One example would be the
reduced use of EGR during cold engine operation. In this case, low
coolant temperatures may cause the electronic control unit to reduce
EGR flow to improve combustion stability. Once the engine warms up,
normal EGR rates are resumed and full NOX control is
achieved.
At the time of certification, manufacturers are required to
disclose all AECDs and provide a full explanation of when the AECD is
active, which sensor inputs effect AECD activation, and what aspect of
the emission control system is affected by the AECD. Manufacturers are
further required to attest that their AECDs are not ``defeat-devices,''
which are intentionally targeted at reducing emission control
effectiveness.
Several common AECDs disclosed for criteria pollutant certification
will have a similarly negative influence on GHG emissions as well. One
such example is cold-start enrichment, with provides additional fueling
to stabilize combustion shortly after initially starting the engine.
From a criteria pollutant perspective, HC emissions can reasonably be
expected to increase as a result. From a GHG perspective, the extra
fuel does not result in a similar increase in power output and
therefore the efficiency of the engine is reduced, which has a negative
impact on CO2 emissions. In addition, there may be AECDs
that uniquely reduce GHG emission control effectiveness. Therefore,
consistent with today's certification procedures, we are proposing that
a comprehensive list of AECDs covering both criteria pollutant, as well
as GHG emissions is required at the time of certification.
(ii) EPA's N2O and CH4 Standards
In 2009, EPA issued rules requiring manufacturers of mobile-source
engines to report the emissions of CO2, N2O, and
CH4 (74 FR 56260, October 30, 2009). While CO2 is
commonly measured during certification testing, CH4 and
N2O are not. CH4 has traditionally not been
included in criteria pollutant regulations because it is a relatively
stable molecule and does not contribute significantly to ground-level
ozone formation. In addition, N2O is commonly a byproduct of
lean-NOX aftertreatment systems. Until recently, these types
of systems were not widely used on heavy-duty engines and therefore
N2O emissions were insignificant. Both species, while
emitted in small quantities relative to
[[Page 74268]]
CO2, have much higher global warming potential than
CO2 and therefore must be considered as part of a
comprehensive GHG regulation.
EPA is proposing that CH4 and N2O be reported
at the time of certification. We are proposing to allow manufacturers
to use a compliance statement based on good engineering judgment for
the first year of the program in lieu of direct measurement of
N2O. However, beginning in the 2015 model year, the agency
is proposing to require the direct measurement of N2O for
certification. The intent of the CH4 and N2O
standards are more focused on prevention of future increases in these
compounds, rather than forcing technologies that reduce these
pollutants. As one example, we envision manufacturers satisfying this
requirement by continuing to use catalyst designs and formulations that
appropriately control N2O emissions rather than pursuing a
catalyst that may increase N2O. In many ways this becomes a
design-based criterion in that the decision of one catalyst over
another will effectively determine compliance with N2O
standards over the useful life of the engine. As noted in Section II
above, we are not at this time aware of deterioration mechanisms for
N2O and CH4 that would result in large
deterioration factors, but neither do we believe enough is known about
these mechanisms to justify proposing assigned factors corresponding to
no deterioration. We are therefore asking for comment on this subject.
(c) Additional Compliance Provisions
(i) Warranty & Defect Reporting
Under section 207 of the CAA, engine manufacturers are required to
warrant that their product is free from defects that would cause the
engine to not comply with emission standards. This warranty must be
applicable from when the engine is introduced into commerce through a
period generally defined as half of the regulatory useful life
(specified in hours and years, whichever comes first). The exact time
of this warranty is dependent on the regulatory class of the engine. In
addition, components that are considered ``high cost'' are required to
have an extended warranty. Examples of such components would be exhaust
aftertreatment devices and electronic control units.
Current warranty provisions in 40 CFR part 86 define the warranty
periods and covered components for heavy-duty engines. The current list
of components is comprised of any device or system whose failure would
result in an increase in criteria pollutant emissions. At this point,
we believe this list to be adequate for addressing GHG emissions as
well. However, there may be instances where the failure of a component
or system may reduce the efficiency of the engine while not increasing
criteria pollutant emissions. In this case, the component or system may
be inappropriately left off the list of covered components. Therefore
we are seeking public comment on what devices and/or systems may need
to be added to the warranted component list to adequately address GHG
emissions. The following list identifies items commonly defined as
critical emission-related components:
Electronic control units.
Aftertreatment devices.
Fuel metering components.
EGR-System components.
Crankcase-ventilation valves.
All components related to charge-air compression and
cooling.
All sensors and actuators associated with any of these
components.
When a manufacturer experiences an elevated rate of failure of an
emission control device, they are required to submit defect reports to
the EPA. These reports will generally have an explanation of what is
failing, the rate of failure, and any possible corrections taken by the
manufacturer. Based on how successful EPA believes the manufacturer to
be in addressing these failures, the manufacturer may need to conduct a
product recall. In such an instance, the manufacturer is responsible
for contacting all customers with affected units and repairing the
defect at no cost to them. We believe this structure for the reporting
of criteria pollutant defects, and recalls, is appropriate for
components related to complying with GHG emissions as well.
(ii) Maintenance
Engine manufacturers are required to outline maintenance schedules
that ensure their product will remain in compliance with emission
standards throughout the useful life of the engine. This schedule is
required to be submitted as part of the application for certification.
Maintenance that is deemed to be critical to ensuring compliance with
emission standards is classified as ``critical emission-related
maintenance.'' Generally, manufacturers are discouraged from specifying
that critical emission-related maintenance is needed within the
regulatory useful life of the engine. However, if such maintenance is
unavoidable, manufacturers must have a reasonable basis for ensuring it
is performed at the correct time. This may be demonstrated through
several methods including survey data indicating that at least 80% of
engines receive the required maintenance in-use or manufacturers may
provide the maintenance at no charge to the user. During durability
testing of the engine, manufacturers are required to follow their
specified maintenance schedule.
Maintenance relating to components relating to reduction of GHG
emissions are not expected to present unique challenges. Therefore, we
are not proposing any changes to the provisions for the specification
of emission-related maintenance as outlined in 40 CFR part 86.
(2) Proposed Enforcement Provisions
(a) Emission Control Information Labels
Current provisions for engine certification require manufacturers
to equip their product with permanent emission control information
labels. These labels list important characteristics, parameters, and
specifications related to the emissions performance of the engine.
These include, but are not limited to, the manufacturer, model,
displacement, emission control systems, and tune-up specifications. In
addition, this label also provides a means for identifying the engine
family name, which can then be referenced back to certification
documents. This label provides essential information for field
inspectors to determine that an engine is in fact in the certified
configuration.
We do not anticipate any major changes needing to be made to
emission control information labels as a result of new GHG standards
and a single label is appropriate for both criteria pollutant and GHG
emissions purposes. Perhaps the most significant addition would be the
inclusion of Family Certification Levels or Family Emission Limits for
GHG pollutants, if the manufacturer is participating in averaging,
banking, and trading. In addition, the label will need to indicate
whether the engine is certified for use in vocational vehicles,
tractors, or both.
(b) In-Use Standards
In-use testing of engines provides a number of benefits for
ensuring useful life compliance. In addition to verifying compliance
with emission standards at any given point in the useful life, it can
be used along with manufacturer defect reporting, to indentify
components failing at a higher than normal rate. In this case, a
product recall or other service campaign can be initiated and the
problem can be rectified. Another key benefit of in-use testing is the
discouragement of control strategies
[[Page 74269]]
catered to the certification test cycles. In the past, engine
manufacturers were found to be producing engines that performed
acceptably over the certification test cycle, while changing to
alternate operating strategies ``off-cycle'' which caused increases in
criteria pollutant emissions. While these strategies are clearly
considered defeat devices, in-use testing provides a meaningful way of
ensuring that such strategies are not active under normal engine
operation.
Currently, manufacturers of certified heavy-duty engines are
required to conduct in-use testing programs. The intent of these
programs is to ensure that their products are continuing to meet
criteria pollutant emission standards at various points within the
useful life of the engine. Since initial certification is based on
engine dynamometer testing, and removing in-use engines from their
respective vehicles is often impractical, a unique testing procedure
was developed. This includes using portable emission measurement
systems (PEMS) and testing the engine over typical in-situ drive routes
rather than a prescribed test cycle. To assess compliance, emission
results from a well defined area of the speed/torque map of the engine,
known as the NTE zone, are compared to the emission standards. To
account for potential increases in measurement and operational
variability, certain allowances are applied to the standard which
results in the standard for NTE measurements (NTE limit) to be at or
above the duty cycle emission standards.
In addition, EPA also conducts an annual in-use testing program of
heavy-duty engines. Testing procured vehicles with specific engines
over well-defined drive routes using a constant trailer load allows for
a consistent comparison of in-use emissions performance. If potential
problems are identified in-situ, the engine may be removed from the
vehicle and tested using an engine dynamometer over the certification
test cycles. If deficiencies are confirmed the agency will either work
with the manufacturer to take corrective action or proceed with
enforcement action against the manufacturer.
The GHG reporting rule requires manufacturers to submit
CO2 data from all engine testing (beginning in the 2011
model year), which we believe is equally applicable to in-use
measurements. Methods of CO2 in-situ measurement are well
established and most, if not all, PEMS devices measure and record
CO2 along with criteria pollutants. CH4 and
N2O present in-situ measurement challenges that may be
impractical to overcome for this testing, and therefore it is not
recommended that they be included in in-use testing requirements at
this time. While measurement of CO2 may be practical and
important, implementing an NTE emission standard for CO2 is
challenging. As previously discussed, CO2 emissions are
highly dependent on the drive cycle of the vehicle, which does not lend
itself well to the NTE-based test procedure. Therefore, we propose that
manufacturers be required to submit CO2 data from in-use
testing, in both g/bhp-hr and g/ton-mile, but these data will be used
for reference purposes only (there would be no NTE limit/standard for
CO2).
(3) Other Certification Provisions
(a) Carryover/Carry Across Certification Test Data
EPA's current certification program for heavy-duty engines allows
manufacturers to carry certification test data over and across
certification testing from one model year to the next, when no
significant changes to models are made. EPA is proposing to also apply
this policy to CO2, N2O and CH4
certification test data.
(b) Certification Fees
The CAA allows EPA to collect fees to cover the costs of issuing
certificates of conformity for the classes of engines covered by this
proposal. On May 11, 2004, EPA updated its fees regulation based on a
study of the costs associated with its motor vehicle and engine
compliance program (69 FR 51402). At the time that cost study was
conducted, the current rulemaking was not considered. At this time the
extent of any added costs to EPA as a result of this proposal is not
known. EPA will assess its compliance testing and other activities
associated with the rule and may amend its fees regulations in the
future to include any warranted new costs.
(c) Onboard Diagnostics
Beginning in the 2013 model year, manufacturers will be required to
equip heavy-duty engines with on-board diagnostic systems. These
systems monitor the activity of the emission control system and issue
alerts when faults are detected. These diagnostic systems are currently
being developed based around components and systems that influence
criteria pollutant emissions. Consistent with the light-duty vehicle
GHG rule, we believe that monitoring of these components and systems
for criteria pollutant emissions will have an equally beneficial effect
on CO2 emissions. Therefore, we do not anticipate the
necessity of having any unique onboard diagnostic provisions for heavy-
duty GHG emissions. We are seeking comment on this topic, however.
(d) Applicability of Current High Altitude Provisions to Greenhouse
Gases
EPA is proposing that engines covered by this proposal must meet
CO2, N2O and CH4 standards at elevated
altitudes. The CAA requires emission standards under section 202 for
heavy-duty engines to apply at all altitudes. EPA does not expect
engine CO2, CH4, or N2O emissions to
be significantly different at high altitudes based on engine
calibrations commonly used at all altitudes. Therefore, EPA proposes
that it retain its current high altitude regulations so manufacturers
will not normally be required to submit engine CO2 test data
for high altitude. Instead, they will be required to submit an
engineering evaluation indicating that common calibration approaches
will be utilized at high altitude. Any deviation in emission control
practices employed only at altitude will need to be included in the
AECD descriptions submitted by manufacturers at certification. In
addition, any AECD specific to high altitude will be required to
include emissions data to allow EPA evaluate and quantify any emission
impact and validity of the AECD.
(e) Emission-Related Installation Instructions
Engine manufacturers are currently required to provide detailed
installation instructions to vehicle manufacturers. These instructions
outline how to properly install the engine, aftertreatment, and other
supporting systems, such that the engine will operate in its certified
configuration. At the time of certification, manufacturers may be
required to submit these instructions to EPA to verify that sufficient
detail has been provided to the vehicle manufacturer.
We do not anticipate any major changes to this documentation as a
result of regulating GHG emissions. The most significant impact will be
the addition of language prohibiting vehicle manufacturers from
installing engines into vehicle categories in which they are not
certified for. An example would be a tractor manufacturer installing an
engine certified for only vocational vehicle use. Explicit instructions
on behalf of the engine manufacturer that such acts are prohibited will
serve as sufficient notice to the vehicle manufacturers and failure to
follow
[[Page 74270]]
such instructions will in the vehicle manufacturer being in non-
compliance.
(f) Alternate CO2 Emission and Fuel Consumption Standards
Under the proposed rule, engine manufacturers have the option of
certifying to CO2 emission and fuel consumption standards
that are 5 percent below a baseline value established from their 2011
model-year products. If a manufacturer elects to participate in this
program they must indicate this on their certification application. In
addition, sufficient details must be submitted regarding the baseline
engine such that the agency can verify that the correct optional
CO2 emission and fuel consumption standards have been
calculated. This data will need to include the engine family name of
the baseline engine, so references to the original certification
application can be made, as well as test data showing the
CO2 emissions and fuel consumption of the baseline engine.
D. Class 7 and 8 Combination Tractors
(1) Proposed Compliance Approach
In addition to requiring engine manufacturers to certify their
engines, manufacturers of Class 7 and 8 combination tractors must also
certify that their vehicles meet the proposed CO2 emission
and fuel consumption standards. This vehicle certification will ensure
that efforts beyond just engine efficiency improvements are undertaken
to reduce GHG emissions and fuel consumption. Some examples include
aerodynamic improvements, rolling resistance reduction, idle reduction
technologies, and vehicle speed limiting systems.
Unlike engine certification however, this certification would be
based on a load-specific basis (g/ton-mile or gal/1,000 ton-mile as
opposed to work-based, or g/bhp-hr). This would take into account the
anticipated vehicle loading that would be experienced in use and the
associated affects on fuel consumption and CO2 emissions.
Vehicle manufacturers would also be required to warrant their products
against emission defects, and demonstrate that a service network is in
place to correct any such conditions. The vehicle manufacturer also
bears responsibility in the event that an emission-related recall is
necessary.
(a) Certification Process
In order to obtain a certificate of conformity for the tractor,
vehicle manufacturers would complete a compliance demonstration,
showing that their product meets emission standards as well as other
regulatory requirements. For purposes of this demonstration, vehicles
with similar emission characteristics throughout their useful life are
grouped together in test groups, similar to EPA's light-duty emissions
certification program. Examples of characteristics that would define a
test group for heavy-duty vehicles are wheel and tire package,
aerodynamic profile, tire rolling resistance, and engine model. Under
this system, the worst-case vehicle would be selected based on having
the highest fuel consumption, and all other models within the family
are assumed to have emissions and fuel consumption at or below the
parent model and therefore in compliance with CO2 emission
and fuel consumption standards. Any vehicle within the family can be
subject to selective enforcement auditing in addition to confirmatory
or other administrator testing.
We anticipate test groups for Class 7 and 8 combination tractors to
utilize the standardized 12-digit naming convention, as outlined in the
engine certification section of this chapter. As with engines, each
certifying vehicle manufacturer will have a unique three digit code
assigned to them. Currently, there is no 5th digit (industry sector)
code for this class of vehicles, for which we propose to use the next
available character, ``2.'' Since we are proposing that the engine is
one of several test-group defining features, we still believe it is
appropriate to include engine displacement in the family name. If the
test-group consists includes multiple engine models with varying
displacements, the largest would be specified in the test-group name,
consistent with current practices. The remaining characters would
remain available for California ARB and/or manufacturer use, such that
the result is a unique test-group name.
Class 7 and 8 tractors share several common traits, such as the
trailer attachment provisions, number of wheels, and general
construction. However, further inspection reveals key differences
related to GHG emissions. Payloads hauled by Class 7 tractors are
significantly less than Class 8 tractors. In addition, Class 8 vehicles
may have provisions for hoteling (``sleeper cabs''), which results in
an increase in size as well as the addition of comfort features like
power and climate control for use while the truck is parked. Both
segments may have various degrees of roof fairing to provide better
aerodynamic matching to the trailer being pulled. This is a feature
which can help reduce CO2 emissions significantly when
properly matched to the trailer, but can also increase CO2
emissions if improperly matched. Based on these differences, it is
reasonable to expect differences in CO2 emissions, and
therefore these properties form the basis for the proposed combination
tractor regulatory subcategories.
The various combinations of payload, cab size, and roof profile
result in nine proposed regulatory subcategories for Class 7 and 8
trucks. These include Class 7 (day cabs), Class 8 (day cabs), and Class
8 (sleeper cabs), each with high, mid, and low roof profiles. The Class
7 tractors would have a regulatory useful life of 185,000 miles while
Class 8 tractors would have a regulatory life of 435,000 miles and must
meet CO2 emission standards throughout this period.
(b) Demonstrating Compliance With the Proposed Standards
(i) CO2 and Fuel Consumption Standards
Consistent with existing certification processes for light-duty
vehicles and heavy-duty pickups and vans, emissions testing of the
complete vehicle would be the preferred method for demonstrating
compliance with vehicle emission standards. However, vehicle-level
certification is new to the heavy-duty vehicle segment above 14,000 lb.
Therefore, most vehicle manufacturers are not adequately equipped to
conduct vehicle-level emission testing for Class 7 and 8 combination
tractors. Chassis dynamometers, emission sampling equipment, and staff
engineering support are a few of the factors that would add significant
cost to vehicle development in a relatively short amount of time, which
may make the prospect of vehicle testing quite onerous. In addition to
the infrastructure and testing facilities the industry would need to
add, the agencies have not completed the extensive work ultimately
desirable for us to propose new test procedures and standards based on
the use of a chassis test procedure. Moreover, as explained in Section
II.C, because of the enormous numbers of truck configurations that have
an impact on fuel consumption, we do not believe that it would be
reasonable, at least initially, to require testing of many combinations
of tractor model configurations on a chassis dynamometer. Recognizing
these constraints related to time, staffing, and capital, we are
proposing only a vehicle simulation model option for demonstrating
compliance at the time of certification. However, we do believe that a
chassis based test procedure as
[[Page 74271]]
currently utilized for vehicles below 14,000 pounds could be a better
long-term approach to regulate all heavy-duty vehicles and we are
seeking comment on a chassis based approach.
Model
Vehicle modeling will be conducted using the agencies' simulation
model, GEM, which is described in detail in Chapter 4 of the draft RIA.
Basically, this model functions by defining a vehicle configuration and
then exercises the model over various drive cycles. Several
initialization files are needed to define a vehicle, which include
mechanical attributes, control algorithms, and driver inputs. The
majority of these inputs will be predetermined by EPA and NHTSA for the
purposes of vehicle certification. The net results from GEM are
CO2 emissions and fuel consumption values over the proposed
drive cycles. The CO2 emission result will be used for
demonstrating compliance with vehicle CO2 standards while
the fuel consumption result will be used for demonstrating compliance
with the fuel consumption standards.
The vehicle manufacturer will be responsible for entering
aerodynamic properties of the vehicle, the weight reduction, tire
properties, idle reduction systems, and vehicle speed limiting systems.
For GEM inputs relating to weight reduction and aerodynamics, the
agencies are proposing the use of lookup tables based on typical
performance levels across the industry. These lookup tables do not have
data directly related to CO2, but rather provide the
appropriate coefficients for the model to assess CO2- and
fuel consumption-related performance. The agencies will enter the
appropriate engine map reflecting use of a certified engine in the
truck (and will enter the same value even if an engine family is
certified to the temporary percent reduction alternative standard, in
order to evaluate vehicle performance independently of engine
performance.) We believe this approach reduces the testing burden
placed upon manufacturers, yet adequately assesses improvements
associated with select technologies. The model will be publicly
available and will be found on EPA's Web site.
The agency reserves the right to independently evaluate the inputs
to the model via Administrator testing to validate those model inputs.
The agency also reserves the right to evaluate vehicle performance
using the inputs to the model provided by the manufacturer to confirm
the performance of the system using GEM. This could include generating
emissions results using the GEM and the inputs as provided by the
manufacturer based on the agency's own runs. This could also include
conducting comparable testing to verify the inputs provided by the
manufacturer. In the event of such testing or evaluation, the
Administrator's results become the official certification results. The
exception being that the manufacturer may continue to use their data as
initially submitted, provided it represents a worst-case condition over
the Administrator's results.
To better facilitate the entry of only the appropriate parameters,
the agencies will provide a graphical user interface in the model for
entering data specific to each vehicle. This graphical user interface
allows the end user to avoid interacting directly with the model and
any associated coding. It is expected that this template will be
submitted to EPA as part of the certification process for each
certified vehicle configuration.
For certification, the model will exercise the vehicle over three
test cycles; one transient and two steady-state. For the transient
test, we are proposing to use the heavy-heavy-duty diesel truck (HHDDT)
transient test cycle, which was developed by the California Air
Resources Board and West Virginia University to evaluate heavy-duty
vehicles. The transient mode simulates urban, start-stop driving,
featuring 1.8 stops per mile over the 2.9 mile duration. The two steady
state test points are reflective of the tendency for some of these
vehicles to operate for extended periods at highway speeds. Based on
data from the EPA's MOVES database, and common highway speed limits, we
are proposing these two points to be 55 and 65 mph.
The model will predict the total emissions results from each
segment using the unique properties entered for each vehicle. These
results are then normalized to the payload and distance covered, so as
to yield a gram/ton-mile result, as well as a fuel consumption (gal/
1,000 ton-mile) result for each test cycle. As with engine and vehicle
testing, certification will be based on a parent rating for the test
group, representing the worst-case fuel consumption and CO2
emissions. However, vehicle manufacturers will also have the
opportunity to model sub-configurations to determine any benefits that
are available on only a select number of vehicles within a test group.
The results from all three tests are then combined using weighting
factors, which reflect typical usage patterns. The typical usage
characteristics of Class 7 and 8 tractors with day cabs differ
significantly from Class 8 tractors with sleeper cabs. The trucks with
day cabs tend to operate in more urban areas, have a limited travel
range, and tend to return to a common depot at the end of each shift.
Class 8 sleeper cabs, however, are typically used for long distance
trips which consist of mostly highway driving in an effort to cover the
highest mileage in the shortest time. For these reasons, we propose
that the cycles are weighted differently for these two groups of
vehicles. For Class 7 and 8 trucks with day cabs, we propose weights of
64%, 17%, and 19% (65 mph, 55 mph, and transient, resp.). For Class 8
with sleeper cabs, the high speed cruise tendency results in proposed
weights of 86%, 9%, and 5% (65 mph, 55 mph, and transient,
respectively). These final, weighted emission results are compared to
the emission standard to assess compliance.
Durability Testing
As with engine certification, a manufacturer must provide evidence
of compliance through the regulatory useful life of the vehicle.
Factors influencing vehicle-level GHG performance over the life of the
vehicle fall into two basic categories: Vehicle attributes and
maintenance items. Each category merits different treatment from the
perspective of assessing useful life compliance, as each has varying
degrees of manufacturer versus owner/operator responsibility.
The category of vehicle attributes generally refers to aerodynamic
features, such as fairings, side-skirts, air dams, air foils, etc,
which are installed by the manufacturer to reduce aerodynamic drag on
the vehicle. These features have a significant impact on GHG emissions
and their emission reduction properties are assessed early in the
useful life (at the time of certification). These features are expected
to last the full life of the vehicle without becoming detached,
cracked/broken, misaligned, or otherwise not in the original state. In
the absence of the aforementioned failure modes, the performance of
these features is not expected to degrade over time and the benefit to
reducing GHG emissions is expected to last for the life of the vehicle
with no special maintenance requirements. To assess useful life
compliance, we recommend a design-based approach which would ensure
that the manufacturer has robustly designed these features so they can
reasonably be expected to last the useful life of the vehicle.
The category of maintenance items refers to items that are
replaced, renewed, cleaned, inspected, or otherwise addressed in the
preventative maintenance schedule specified by the
[[Page 74272]]
vehicle manufacturer. Items that have a direct influence on GHG
emissions are primarily lubricants. Synthetic engine oil may be used by
vehicle manufacturers to reduce the GHG emissions of their vehicles.
Manufacturers may specify that these fluids be changed throughout the
useful life of the vehicle. If this is the case, the manufacturer
should have a reasonable basis that the owner/operator will use fluids
having the same properties. This may be accomplished by requiring (in
service documentation, labeling, etc) that only these fluids can be
used as replacements.
If the vehicle remains in its original certified condition
throughout its useful life, it is not believed that GHG emissions would
increase as a result of service accumulation. This is based on the
assumption that as components wear, the rolling resistance due to
friction is likely to stay the same or decrease. With all other
components remaining equal (tires, aerodynamics, etc), the overall drag
force would stay the same or decrease, thus not significantly changing
GHG emissions at the end of useful life. It is important to remember
however, that this vehicle assessment does not take into account any
engine-related wear affects, which may in fact increase GHG emissions
over time.
For the reasons explained above, we believe that for the first
phase of this program, it is most important to ensure that the vehicle
remain in its certified configuration throughout the useful life. This
can most effectively be accomplished through engineering analysis and
specific maintenance instructions provided by the vehicle manufacturer.
The vehicle manufacturer would be primarily responsible for providing
engineering analysis demonstrating that vehicle attributes will last
for the full life of the vehicle. In addition they will be required to
submit the recommended maintenance schedule (and other service related
documentation), showing that fluids meeting original equipment
properties are required as replacements.
(ii) EPA's Air Conditioning Leakage Standards
Heavy-duty vehicle air conditioning systems contribute to GHG
emissions in two ways. First, operation of the air conditioning unit
places an accessory load on the engine, which increases fuel
consumption. Second, most modern refrigerants are HFC-based, which have
significant global warming potential (GWP = 1430). For heavy-duty
vehicles, the load added by the air conditioning system is
comparatively small compared to other power requirements of the
vehicle. Therefore, we are not targeting any GHG reduction due to
decreased air conditioning usage or higher efficiency A/C units for
this proposal. However, refrigerant leakage, even in very small
quantities, can have significant adverse effects on GHG emissions.
Refrigerant leakage is a concern for heavy-duty vehicles, similar
to light-duty vehicles. To address this, EPA is proposing a design-
based standard for reducing refrigerant leakage from heavy-duty
vehicles. This standard is based off using the best practices for
material selection and interface sealing, as outlined in SAE
publication J2727. Based on design criteria in this publication, a
leakage ``score'' can be assessed and an estimated annual leak rate can
be made for the A/C system based on the refrigerant capacity.
At the time of certification, manufacturers would be required to
outline the design of their system, including specifying materials and
construction methods. They will also need to supply the leakage score
developed using SAE J2727 and the refrigerant volume of their system to
determine the leakage rate per year. If the certifying manufacturer
does not complete installation of the air conditioning unit, detailed
instructions must be provided to the final installer which ensures that
the A/C system is assembled to meet the low-leakage standards. These
instructions will also need to be provided at the time of
certification, and manufacturers must retain all records relating to
auditing of the final assembler.
(c) In-Use Standards
As previously addressed, the drive-cycle dependence of
CO2 emissions makes NTE-based in-use testing impractical. In
addition, we believe the reporting of CO2 data from the
criteria pollutant in-use testing program will be helpful in future
rulemaking efforts. For these reasons, we are not proposing an NTE-
based in-use testing program for Class 7 and 8 combination tractors
during this proposal.
In the absence of NTE-based in-use testing, provisions are
necessary for verifying that production vehicles are in the certified
configuration, and remain so throughout the useful life. Perhaps the
easiest method for doing this is to verify the presence of installed
emission-related components. This would basically consist of a vehicle
audit against what is claimed in the certification application. This
includes verifying the presence of aerodynamic components, such as
fairings, side-skirts, and gap-reducers. In addition, the presence of
idle-reduction and speed limiting devices would be verified. The
presence of LRR tires could be verified at the point of initial sale;
however verification at other points throughout the useful life would
be non-enforceable for the reasons mentioned previously.
The category of wear items primarily relates to tires. It is
expected that vehicle manufacturers will equip their trucks with LRR
tires, as they may provide a substantial reduction in GHG emissions.
The tire replacement intervals for this class of vehicle is normally in
the range of 50,000 to 100,000 miles, which means the owner/operator
will be replacing the tires at several points within the useful life of
the vehicle. We believe that as LRR tires become more common on new
equipment, the aftermarket prices of these tires will also decrease.
Along with decreasing tire prices, the fuel savings realized through
use of LRR tires will ideally provide enough incentive for owner/
operators to continue purchasing these tires. The inventory modeling in
this proposal reflects the continued use of LRR tires through the life
of the vehicle. We seek comment on this and all aspects of our
inventory modeling.
(2) Proposed Enforcement Provisions
As identified above, a significant amount of vehicle-level GHG
reduction is anticipated to come from the use of components
specifically designed to reduce GHG emissions. Examples of such
components include LRR tires, aerodynamic fairings, idle reduction
systems, and vehicle speed limiters. At the time of certification,
vehicle manufacturers will specify which components will be on their
vehicle when introduced into commerce. Based on this list of components
reported to EPA the GHG performance of the vehicle will be assessed,
typically through modeling, and a certificate of conformity may be
issued. As described in the in-use testing section, it is important to
have the ability to determine if the vehicle is in the certified
configuration both at the time of sale, as well as at any point within
the useful life.
Perhaps the most practical and basic method of verifying that a
vehicle is in its certified configuration is through a vehicle
emissions control information label, similar to that used for engines
and light-duty vehicles. This label would list identifying features of
the vehicle, including model year, vehicle model, certified engine
family, vehicle manufacturer, test group, and GHG emissions category.
In addition, this label would list emission-related
[[Page 74273]]
components that an inspector could reference in the event of a field
inspection. Possible examples may include LRR (for LRR tires), ARF
(aerodynamic roof fairing), and ARM (aerodynamic rearview mirrors).
With this information, inspectors could verify the presence and
condition of attributes listed as part of the certified configuration.
Similarly, on current emission control information labels,
manufacturers list abbreviations, which are defined in SAE J1930, for
each emission control device. Examples include three-way catalyst
(TWC), electronic control (EC), and heated oxygen sensor
(HO2S). Unfortunately we are not aware of a similar,
existing list of vehicle emission control devices and features likely
to be used on heavy-duty vehicles. At this point, it is also difficult
to develop such a list due to the wide array of devices and features
vehicle manufacturers may use in the future. Therefore, we are
currently seeking comment on how to best define a list of emission
control devices and features for use in this vehicle GHG certification
label.
At the time of certification, manufacturers will be required to
submit an example of their vehicle emission control label such that EPA
can verify that all critical elements are present. Such elements
include the vehicle family/test group name, emission control system
identifiers described above, regulatory sub-category of the vehicle,
and Family Emission Limits to which the vehicle is certified to. In
addition to the label, manufacturers will also need to describe where
the unique vehicle identification number and date of production can be
found on the vehicle.
(3) Other Certification Provisions
(a) Warranty
Section 207 of the CAA requires manufacturers to warrant their
products to be free from defects that would otherwise cause non-
compliance with emission standards. In addition, this warranty must
ensure that the vehicle remains in this configuration throughout its
useful life. For purposes of this regulation, vehicle manufacturers
must warrant all components installed which act to reduce
CO2 emissions at the time of initial sale. This includes all
aerodynamic features, tires, idle reduction systems, speed limiting
system, and other equipment added to reduce CO2 emissions.
In addition, the manufacturer must ensure these components and systems
remain functional for the useful life of the vehicle. The exception
being tires, which are only required to be warranted for the first life
of the tires (vehicle manufacturers are not expected to cover
replacement tires). For aerodynamic features, such as fairings or side-
skirts, the manufacturer must warrant against failures which are not
the result operator damage. However, these components should be
designed to withstand possible damage from normal driving, which may
include stone impingement and other minor impact with small debris.
The vehicle manufacturer is also required to warrant the A/C system
for the useful life of the vehicle against design or manufacturing
defects causing refrigerant leakage in excess of the standard.
At the time of certification, manufacturers must supply a copy of
the warranty statement that will be supplied to the end customer. This
document should outline what is covered under the GHG emissions related
warranty as well as the length of coverage. Customers must also have
clear access to the terms of the warranty, the repair network, and the
process for obtaining warranty service.
(b) Maintenance
Vehicle manufacturers are required to outline maintenance schedules
that ensure their product will remain in compliance with emission
standards throughout the useful life of the vehicle. For heavy-duty
vehicles, such maintenance may include fluid/lubricant service, fairing
adjustments, or service to the GHG emission control system. This
schedule is required to be submitted as part of the application for
certification. Maintenance that is deemed to be critical to ensuring
compliance with emission standards is classified as ``critical
emission-related maintenance.'' Generally, manufacturers are
discouraged from specifying that critical emission-related maintenance
is needed within the regulatory useful life of the engine. However, if
such maintenance is unavoidable, manufacturers must have a reasonable
basis for ensuring it is performed at the correct time. This may be
demonstrated through several methods including survey data indicating
that at least 80% of engines receive the required maintenance in-use or
manufacturers may provide the maintenance at no charge to the user.
(c) Certification Fees
Similar to engine certification, the agency will assess
certification fees for heavy-duty vehicles. The proceeds from these
fees are used to fund the compliance and certification activities
related to GHG regulation for this regulatory category. In addition to
the certification process, other activities funded by certification
fees include EPA-administered in-use testing, selective enforcement
audits, and confirmatory testing. At this point, the exact costs
associated with the heavy-duty vehicle GHG compliance are not well
known. EPA will assess its compliance program associated with this
proposal and assess the appropriate level of fees. We anticipate that
fees will be applied based on test groups, following the light-duty
vehicle approach.
(d) Requirements For Conducting Aerodynamic Assessment Using Allowed
Methods
The requirements for conducting aerodynamic assessment using
allowed methods includes two key components: Adherence to a minimum set
of standardized criteria for each allowed method and submittal of
aerodynamic values and supporting information on an annual basis for
the purposes of certifying vehicles to a particular aerodynamic bin as
discussed in the Section II.
First, we are proposing requirements for conducting each of the
allowed aerodynamic assessment methods. We will cite approved and
published standards and practices, where feasible, but will attempt to
propose criteria where none exists or where more current research
indicates otherwise. We are requesting comment on the proposed
requirements for each allowed method, standards and practices that
should be used, and any unique criteria that we are proposing. A
description of the requirements for each method is discussed later in
this section. The manufacturer would be required to provide information
showing that they meet these requirements and attest to the accuracy of
the information provided.
Second, to ensure continued compliance, manufacturers would be
required to provide a minimum set of information on an annual basis at
certification time (1) to support continued use of an aerodynamic
assessment method and (2) to assign an aerodynamic value based on the
applicable aerodynamic bins. The information supplied to the agencies
should be based on an approved aerodynamic assessment method and adhere
to the requirements for conducting aerodynamic assessment mentioned
above.
Regardless of the method, all testing should be performed with a
tractor-trailer combination to mimic real world
[[Page 74274]]
usage. Accordingly, it is important to match the type of tractor with
the correct trailer. Although, as discussed elsewhere in this proposal,
the correct tractor-trailer combination is not always present or
tractor-only operation may occur, the majority of operation in the real
world involves correctly matched tractor-trailer combinations and we
will attempt to reflect that here. Therefore, the following guidelines
should be used when performing an aerodynamic assessment:
For a Class 7 and 8 tractor truck with a low roof, a
standard flatbed trailer must be used;
For a Class 7 and 8 tractor truck with a mid roof, a
standard tanker trailer must be used;
For a Class 7 and 8 tractor truck with a high roof, a
standard box trailer must be used.
The definitions of each standard trailer are proposed in Sec.
1037.501(g). This ensures consistency and continuity in the aerodynamic
assessments, and maintains the overlap with real world operation.
Standardized Criteria for Aerodynamic Assessment Methods
(i) Coastdown Procedure Requirements
For coastdown testing, the test runs should be conducted in a
manner consistent with SAE J2263 with additional modifications as
described in the 40 CFR part 1066, subpart C, and in Chapter 3 of the
draft RIA using the mixed model analysis method. The agencies seek
comment on the use of these protocols and the modifications that are
described.
Since the coastdown procedure is the primary aerodynamic assessment
method, the manufacturer would be required to conduct the coastdown
procedure according to the requirements in this proposal and supply the
following to the agency for approval:
Facility information: Name and location, description and/
or background/history, equipment and capability, track and facility
elevation, and track size/length;
Test conditions for each test result including date and
time, wind speed and direction, ambient temperature and humidity,
vehicle speed, driving distance, manufacturer name, test vehicle/model
type, model year, applicable model engine family, tire type and rolling
resistance, test weight and driver name(s) and/or ID(s);
Average Cd result as calculated in 40 CFR 1037.520(b) from
valid tests including, at a minimum, ten valid test results, with no
maximum number, standard deviation, calculated error and error bands,
and total number of tests, including number of voided or invalid tests.
(ii) Wind Tunnel Testing Requirements
Wind tunnel testing would conform to the following procedures and
modifications, where applicable, including:
SAE J1252, ``SAE WIND TUNNEL TEST PROCEDURE FOR TRUCKS AND
BUSES'' (July 1981) except that article 5.2 that specifies a minimum
Reynolds number of 0.7 x 10\6\ is not included and is superseded, for
the purposes of this rulemaking, by a minimum Reynolds number of 1.0 x
10\6\ and, for reduced-scale wind tunnel testing, a one-eighth (\1/
8\th) or larger scale model of a heavy-duty tractor and trailer must be
used and of sufficient design to simulate airflow through the radiator
inlet grill;
J1594, ``VEHICLE AERODYNAMICS TERMINOLOGY'' (December
1994); and
J2071, ``AERODYNAMIC TESTING OF ROAD VEHICLES--OPEN THROAT
WIND TUNNEL ADJUSTMENT'' (June 1994).
In addition, the wind tunnel used for aerodynamic assessment would
be a recognized facility by the Subsonic Aerodynamic Testing
Association. The agencies seek comment on the use of these protocols
and the modifications described and the need for membership in this
testing association.
For wind tunnel testing, we are proposing that manufacturers
perform wind tunnel testing and the coastdown procedure, according to
the requirements proposed in this notice, on the same tractor model and
provide the results for both methods. The wind tunnel tests should be
conducted at a zero yaw angle and, if so equipped, utilizing the
moving/rolling floor (i.e., the moving/rolling floor should be on
during the test as opposed to static) for comparison to the coastdown
procedure, which corrects to a zero yaw angle for the oncoming wind.
The manufacturer would be required to supply the following:
Facility information: Name and location, description and
background/history, layout, wind tunnel type, diagram of wind tunnel
layout, structural and material construction;
Wind tunnel design details: Corner turning vane type and
material, air settling, mesh screen specification, air straightening
method, tunnel volume, surface area, average duct area, and circuit
length;
Wind tunnel flow quality: Temperature control and
uniformity, airflow quality, minimum airflow velocity, flow uniformity,
angularity and stability, static pressure variation, turbulence
intensity, airflow acceleration and deceleration times, test duration
flow quality, and overall airflow quality achievement;
Test/Working section information: Test section type (e.g.,
open, closed, adaptive wall) and shape (e.g., circular, square, oval),
length, contraction ratio, maximum air velocity, maximum dynamic
pressure, nozzle width and height, plenum dimensions and net volume,
maximum allowed model scale, maximum model height above road, strut
movement rate (if applicable), model support, primary boundary layer
slot, boundary layer elimination method and photos and diagrams of the
test section;
Fan section description: Fan type, diameter, power,
maximum rotational speed, maximum tip speed, support type, mechanical
drive, sectional total weight;
Data acquisition and control (where applicable):
Acquisition type, motor control, tunnel control, model balance, model
pressure measurement, wheel drag balances, wing/body panel balances,
and model exhaust simulation;
Moving ground plane or Rolling Road (if applicable):
Construction and material, yaw table and range, moving ground length
and width, belt type, maximum belt speed, belt suction mechanism,
platen instrumentation, temperature control, and steering; and
Facility correction factors and purpose.
(iii) CFD Requirements
Currently, there is no existing standard, protocol or methodology
governing the use of CFD. Therefore, we are coupling the use of CFD
with empirical measurements from coastdown and wind tunnel procedures.
However, we think it is important to require a minimum set of criteria
that all CFD analysis should follow for the purpose of these rules and
to produce a consistent set of results to maintain compliance. Since
there are primarily two-types of CFD software code, Navier-Stokes based
and Lattice-Boltzman based, we are outlining two sets of criteria to
address both types. Therefore, the agencies propose that manufacturers
use commercially-available CFD software code with a turbulence model
enabled and Navier-Stokes formula solver, where applicable. Further
details and criteria for each type of commercially-available CFD
software code follows immediately and general criteria for all CFD
analysis are subsequently described.
For Navier-Stokes based CFD code, manufacturers must perform an
[[Page 74275]]
unstructured, time-accurate analysis using a mesh grid size with total
surface elements greater than or equal to 5 million cells/nodes, a
near-vehicle cell size of less than or equal to 10 millimeters (mm), a
near-wall cell size of less than or equal to 1mm,\203\ and a volume
element size of less than or equal to 5 mm; using hexagonal or
polyhedral mesh cell shapes. All Navier-Stokes based CFD analysis
should be performed with a k-epsilon (k-[egr]) or a shear stress
transport k-omega (SST k-[omega]) turbulence model and mesh deformation
enabled with boundary layer resolution of +/- 95%. Finally, Navier-
Stokes based CFD analysis for the purposes of determining the Cd should
be performed once result convergence is achieved and manufacturers
should be able to demonstrate convergence by supplying multiple,
successive convergence values.
---------------------------------------------------------------------------
\203\ See Lecture Notes in Applied and Computational Mechanics,
The Aerodynamics of Heavy Vehicles II: Trucks, Buses, and Trains;
DOI: 10.1007/978-3-540-85070-0--33; ``Applicability of Commercial
CFD tools for assessment of heavy vehicle aerodynamic
characteristics'' as created by the University of Chicago as
Operator of Argonne National Laboratory (``Argonne'') under contract
No. W-31-109-ENG-38 with the U.S. Department of Energy.
---------------------------------------------------------------------------
For Lattice-Boltzman based CFD code, the agencies propose that
manufacturers perform an unstructured, time-accurate analysis using a
mesh grid size with total surface elements greater than or equal to 5
million cells/nodes, a near-vehicle cell size of less than or equal to
10 millimeters (mm), a near-wall cell size of less than or equal to
1mm, and a volume element size of less than or equal to 5 mm; using
cubic volume elements and triangle and/or quadrilateral surface
elements.
Finally, in general for CFD, all analysis should be conducted
assuming zero yaw angle for comparison to the coastdown test procedure.
In addition, the ambient conditions assumed for the CFD analysis should
be defined according to the environmental conditions that the
manufacturer is seeking to simulate. For simulating a wind tunnel test,
the CFD analysis should accurately model that wind tunnel and assume a
wind tunnel blockage ratio consistent with SAE J1252 or that matches
the selected wind tunnel, whichever is lower. For simulation of open
road conditions similar to that experienced during coastdown test
procedures, the CFD analysis should assume a blockage ratio of less
than or equal 0.2%.
The agencies seek comment on the use of CFD commercial or open
source code and the criteria set forth above for conducting the
analysis.
Finally, in general for each of the allowed aerodynamic assessment
methods, we are requesting comment on the list of information that must
be provided for facilities and test conditions.
Annual Testing and Data Submittal for Aerodynamic Assessment
Once the manufacturer has performed acceptance demonstration, the
aerodynamic assessment can be used to generate Cd values for all
vehicle models the manufacturer plans to certify and introduce into
commerce. For each model, the manufacturer would supply a predicted Cd
based for each of the other models in the manufacturer's fleet and the
other conditions used to determine the base Cd. This reduces burden on
the manufacturer to perform aerodynamic assessment but provides data
for all the models in a manufacturer's fleet. If a manufacturer has
previously performed aerodynamic assessment on the other models, the
manufacturer may submit an experimental Cd in lieu of a predicted Cd.
The aerodynamic assessment data would be used by the manufacturer
who would input the Cd value from the look-up table, based on the
results from the aerodynamic assessment, into GEM and determine a GHG
emissions and fuel consumption level.
Since the agency may input the data into the model, manufacturers
would provide the information described above for acceptance
demonstration for the purposes of annual certification. In addition,
the manufacturer would supply manufacturer fleet information to the
agency for annual certification purposes along with the acceptance
demonstration parameters: manufacturer name, model year, model line (if
different than manufacturer name), model name, engine family, engine
displacement, transmission name and type, number of axles, axle ratio,
vehicle dimensions, including frontal area, predicted or measured
coefficient of drag, assumptions used in developing the predicted or
measured Cd. justification for carry-across of aerodynamic assessment
data, photos of the model line-up, if available, and model applications
and usage options.
We are requesting comment on the annual testing requirements and
the burden on manufacturers to satisfy the requirements.
(e) Aerodynamic Assessment Validation and Compliance
Although the procedures above should ensure accuracy in the
aerodynamic assessment, it is always beneficial to perform confirmation
or validation post-certification. The agencies would like to ensure a
level playing field among the manufacturers and the different
aerodynamic assessment methods. The agencies hope to finalize a method
for doing so after working through the comments from all stakeholders
in a collaborative manner.
The agencies envision that a program for aerodynamic assessment
could consist of two parts: (1) Validation of the manufacturer source
data by performing an audit of the manufacturer's aerodynamic
assessment methods and tools as described in this proposal using a
reference truck and/or (2) vehicle confirmatory evaluation using a
vehicle recruited from the in-use fleet and performing the aerodynamic
assessment discussed in this proposal, either using the manufacturer's
facility and tools or using the agency's facility and tools. We are
seeking comment on the all aspects of an aerodynamic assessment
validation and compliance.
E. Class 2b-8 Vocational Vehicles
(1) Proposed Compliance Approach
Like Class 7 and 8 combination tractors, heavy-duty vocational
vehicles would be required to have both engine and complete vehicle
certificates of conformity. As discussed in the engine certification
section, engines that will be used in vocational vehicles would need to
be certified using the Heavy-duty FTP cycle for GHG pollutants and show
compliance through the useful life of the engine. This certification is
in addition to the current requirements for obtaining a certificate of
conformity for criteria pollutant emissions.
For this proposal, the majority of the GHG reduction for vocational
vehicles is expected to come from the use of LRR tires as well as
increased utilization of hybrid powertrain systems. Other technologies
such as aerodynamic improvements and vehicle speed limiting systems are
not as relevant for this class of vehicles, since the typical duty
cycle is much more urban, consisting of lower speeds and frequent
stopping. Idle reduction strategies are expected to be encompassed by
hybrid technology, which we anticipate will ultimately handle PTO
operation. Therefore, for this initial proposal, certification of
heavy-duty vocational vehicles with conventional powertrains will focus
on quantifying GHG benefits due to the use of LRR tires.
[[Page 74276]]
(a) Certification Process
Vehicles would be divided into test groups for purposes of
certification. As with Class 7 and 8 combination tractors, these are
groups of vehicles within a given regulatory category that are expected
to share common emission characteristics. Vocational vehicle regulatory
subcategories share the same structure as those used for heavy-duty
engine criteria pollutant certification and are based on GVWR. This
includes light-heavy (LHD) with a GVWR at or below 19,500 pounds,
medium-heavy (MHD) with a GVWR above 19,500 pounds and at or below
33,000 pounds, and heavy-heavy (HHD) with a GVWR above 33,000 pounds.
Other test group features may include the type of tires used, intended
application, and number of wheels.
As with Class 7 and 8 combination tractors, we anticipate using the
standardized 12-digit naming convention to identify vocational vehicle
test groups. As with engines and Class 7 and 8 combination tractors,
each certifying vehicle manufacturer would have a unique three digit
code assigned to them. Currently, there is no 5th digit (industry
sector) code for this class of vehicles, for which we propose to use
the next available character, ``3.'' Since we are proposing that the
engine is one of several test-group defining features, we still believe
it is appropriate to include engine displacement in the family name. If
the test-group consists includes multiple engine models with varying
displacements, the largest would be specified in the test-group name,
consistent with current practices. The remaining characters would
remain available for California ARB and/or manufacturer use, such that
the result is a unique test-group name.
Each test group would need to demonstrate compliance with emission
standards using the GEM approach. Additional provisions are available
for certification of hybrid vehicles or vehicles using unique
technologies, which was detailed in Section IV. If the test group
consists of multiple models, only result from the worst-case model is
necessary for certification. However, manufacturers would need to
submit an engineering evaluation demonstrating that the test group has
been assembled appropriately and that the test model indeed reflects
the worst-case model. Also, manufacturers should plan on submitting
tire rolling resistance properties to EPA at the time of certification.
Finally the data from each of the certification cycles described below
will need to be submitted at the time of certification.
(b) Demonstrating Compliance With the Proposed Standards
(i) CO2 and Fuel Consumption Standards
Model
For this proposal, the agencies are proposing that demonstrating
compliance with GHG and fuel consumption standards would primarily
involve demonstrating the use of LRR tires and quantifying the
associated CO2 and fuel consumption benefit. Similar to
Class 7 and 8 combination tractors, this will be done using GEM.
However, the input parameters entered by the vehicle manufacturer would
be limited to the properties of the tires. GEM will use the tire data,
along with inputs reflecting a baseline truck and engine, to generate a
complete vehicle model. The test weight used in the model will be based
on the vehicle class, as identified above. Light-heavy-duty vehicles
will have a test weight of 16,000 pounds; 25,150 pounds for medium
heavy-duty vehicles; and heavy heavy-duty vocational vehicles will use
a test weight of 67,000 pounds. The model would then be exercised over
the HHDDT transient cycle as well as 55 and 65 mph steady-state cruise
conditions. The results of each of the three tests would be weighted at
37%, 21%, and 42% for 65 mph, 55 mph, and transient tests,
respectively.
It may seem more expedient and just as accurate to require
manufacturers use tires meeting certain industry standards for
qualifying tires as having LRR. In addition, CO2 and fuel
consumption benefits could be quantified for different ranges of
coefficients of rolling resistance to provide a means for comparison to
the standard. However, we believe that as technology advances, other
aspects of vocational vehicles may warrant inclusion in future
rulemakings. For this reason, we believe it is important to have the
certification framework in place to accommodate such additions. While
the modeling approach may seem to be overly complicated for this phase
of the rules, it also serves to create a certification pathway for
future rulemakings and therefore we believe this is the best approach.
Should innovative technologies be considered that are currently beyond
the scope of the model, it would be necessary for the manufacturer to
conduct A to B testing which reflects the improvement associated with
the new technology. The test protocol to be used and the basis of this
assessment will require a public vetting process which would likely
include notice and comment.
In-use Standards
The category of wear items primarily relates to tires. It is
expected that vehicle manufacturers will equip their trucks with LRR
(LRR) tires, since the proposed vehicle standard is predicated on LRR
tires' performance. The tire replacement intervals for this class of
vehicle is normally in the range of 50,000 to 100,000 miles, which
means the owner/operator will be replacing the tires at several points
within the useful life of the vehicle. We believe that as LRR tires
become more common on new equipment, the aftermarket prices of these
tires will also decrease. Along with decreasing tire prices, the fuel
savings realized through use of LRR tires will ideally provide enough
incentive for owner/operators to continue purchasing these tires. The
inventory modeling in this proposal reflects the continued use of LRR
tires through the life of the vehicle. We seek comment on this and all
aspects of our inventory modeling.
(ii) Evaporative Emission Standards
Evaporative and refueling emissions from heavy-duty highway engines
and vehicles are currently regulated under 40 CFR part 86. Even though
these emission standards apply to the same engines and vehicles that
must meet exhaust emission standards, we require a separate certificate
for complying with evaporative and refueling emission standards. An
important related point to note is that the evaporative and refueling
emission standards always apply to the vehicle, while the exhaust
emission standards may apply to either the engine or the vehicle. For
vehicles other than pickups and vans, the standards proposed in this
notice to address greenhouse gas emissions apply separately to engines
and to vehicles. Since we plan to apply both greenhouse gas standards
and evaporative/refueling emission standards to vehicle manufacturers,
we believe it would be advantageous to have the regulations related to
their certification requirements written together as much as possible.
EPA regards these proposed changes as discrete, minimal, and for the
most part clarifications to the existing standards. Except as
specifically proposed here, EPA is not soliciting comment on, or
otherwise considering whether to make changes to those standards.
Accordingly, EPA will not consider any comments directed to any aspect
of these standards other than those specifically proposed here.
We are generally not proposing to change the evaporative or
refueling emission standards, but we have come
[[Page 74277]]
across several provisions that warrant clarification or correction:
When adopting the most recent evaporative emission change
we did not carry through the changes to the regulatory text applying
evaporative emission standards for methanol-fueled compression-ignition
engine. The proposed regulations correct this by applying the new
standards to all fuels that are subject to standards.
We are proposing provisions to address which standards
apply when an auxiliary (nonroad) engine is installed in a motor
vehicle, which is currently not directly addressed in the highway
regulation. The proposed approach would require testing complete
vehicles with any auxiliary engines (and the corresponding fuel-system
components). Incomplete vehicles would be tested without the auxiliary
engines, but any such engines and the corresponding fuel-system
components would need to meet the standards that apply under our
nonroad program as specified in 40 CFR part 1060.
We are proposing to remove the option for secondary
vehicle manufacturers to use a larger fuel tank capacity than is
specified by the certifying manufacturer without re-certifying the
vehicle. Secondary vehicle manufacturers needing a greater fuel tank
capacity would need to either work with the certifying manufacturer to
include the larger tank, or go through the effort to re-certify the
vehicle itself. Our understanding is that this provision has not been
used and would be better handled as part of certification rather than
managing a separate process. We are proposing corresponding changes to
the emission control information label.
Rewriting the regulations in a new part in conjunction
with the greenhouse gas standards allows for some occasions of improved
organization and clarity, as well as updating various provisions. For
example, we are proposing a leaner description of evaporative emission
families that does not reference sealing methods for carburetors or air
cleaners. We are also clarifying how evaporative emission standards
affect engine manufacturers and proposing more descriptive provisions
related to certifying vehicles above 26,000 pounds GVWR using
engineering analysis.
Since we adopted evaporative emission standards for
gaseous-fuel vehicles, we have developed new approaches for design-
based certification (see, for example, 40 CFR 1060.240). We request
comment on changing the requirements related to certifying gaseous-fuel
vehicles to design-based certification. This would allow for a simpler
assessment for certifying these vehicles without changing the standards
that apply.
(2) Proposed Labeling Provisions
It is crucial that a means exist for allowing field inspectors to
identify whether a vehicle is certified, and if so, whether it is in
the certified configuration. As with engines and tractors, we believe
an emission control information label is a logical first step in
facilitating this identification. For vocational vehicles, the engine
will have a label that is permanently affixed to the engine and
identify the engine as certified for use in a certain regulatory
subcategory of vehicle (i.e., MHD, etc.).
The vehicle will also have a label listing the test group, engine
family, and range of tire rolling resistances that the vehicle is
certified to use. In addition, if any other emission related components
are present, such as hybrid powertrains, key components will also need
to be specified on the label. Like the engine label, this will need to
be permanently affixed to the vehicle in an area that is clearly
accessible to the owner/operator.
At the time of certification, manufacturers will be required to
submit an example of their vehicle emission control label such that EPA
can verify that all critical elements are present. Such elements
include the vehicle family/test group name, emission control system
identifiers described above, regulatory sub-category of the vehicle,
and Family Emission Limits to which the vehicle is certified to. In
addition to the label, manufacturers will also need to describe where
the unique vehicle identification number and date of production can be
found on the vehicle.
(3) Other Certification Issues
Warranty
As with other heavy-duty engine and vehicle regulatory categories,
vocational vehicle chassis manufacturers would be required to warrant
their product to be free from defects that would adversely affect
emissions. This warranty also covers the failure of emission related
components for the useful life of the vehicle. For vocational chassis,
the key emission related component addressed in this proposal is the
tires.
Manufacturers of chassis for vocational vehicles would be required
to warrant tires to be free from defects at the time of initial sale.
As with Class 7 and 8 combination tractors, we expect the chassis
manufacturer to only warrant tires the original tires against
manufacturing or design-related defects. This tire warranty would not
cover replacement tires or damage from road hazards or improper
inflation.
As with Class 7 and 8 combination tractors, all warranty
documentation would be submitted to EPA at the time of certification.
This should include the warranty statement provided to the owner/
operator, description of the service repair network, list of covered
components (both conventional and high-cost), and length of coverage.
EPA Certification Fees
Similar to engine and tractor-trailer vehicle certification, the
agency will assess certification fees for vocational vehicles. The
proceeds from these fees are used to fund the compliance and
certification activities related to GHG regulation for this industry
segment. In addition to the certification process, other activities
funded by certification fees include EPA-administered in-use testing,
selective enforcement audits, and confirmatory testing. At this point,
the exact costs associated with the heavy-duty vehicle GHG compliance
are not well known. EPA will assess its compliance program associated
with this proposal and assess the appropriate level of fees. We
anticipate that fees will be applied based on test groups, following
the light-duty vehicle approach.
Maintenance
Vehicle manufacturers are required to outline maintenance schedules
that ensure their product will remain in compliance with emission
standards throughout the useful life of the vehicle. For heavy-duty
vehicles, such maintenance may include fluid/lubricant service, fairing
adjustments, or service to the GHG emission control system. This
schedule is required to be submitted as part of the application for
certification. Maintenance that is deemed to be critical to ensuring
compliance with emission standards is classified as ``critical
emission-related maintenance.'' Generally, manufacturers are
discouraged from specifying that critical emission-related maintenance
is needed within the regulatory useful life of the engine. However, if
such maintenance is unavoidable, manufacturers must have a reasonable
basis for ensuring it is performed at the correct time. This may be
demonstrated through several methods including survey data indicating
that at least 80% of engines receive the required maintenance in-use or
manufacturers may provide the maintenance at no charge to the user.
[[Page 74278]]
F. General Regulatory Provisions
(1) Statutory Prohibited Acts
Section 203 of the CAA describes acts that are prohibited by law.
This section and associated regulations apply equally to the greenhouse
gas standards as to any other regulated emission. Acts that are
prohibited by section 203 of the CAA include the introduction into
commerce or the sale of an engine or vehicle without a certificate of
conformity, removing or otherwise defeating emission control equipment,
the sale or installation of devices designed to defeat emission
controls, and other actions. In addition, vehicle manufacturers, or any
other party, may not make changes to the certified engine that would
result in it not being in the certified configuration.
EPA proposes to apply Sec. 86.1854-12 to heavy-duty vehicles and
engines; this codifies the prohibited acts spelled out in the statute.
Although it is not legally necessary to repeat what is in the CAA, EPA
believes that including this language in the regulations provides
clarity and improves the ease of use and completeness of the
regulations. Since this change merely codifies provisions that already
apply, there is no burden associated with the change.
(2) Regulatory Amendments Related to Heavy-Duty Engine Certification
We are proposing to adopt the new engine-based greenhouse gas
standards in 40 CFR part 1036 and the new vehicle-based standards in 40
CFR part 1037. We are proposing to continue to rely on 40 CFR parts 85
and 86 for conventional certification and compliance provisions related
to criteria pollutants, but the proposed regulations include a variety
of amendments that would affect the provisions that apply with respect
to criteria pollutants. We are not intending to change the stringency
of, or otherwise substantively change any existing standards.
The introduction of new parts in the CFR is part of a long-term
plan to migrate all the regulatory provisions related to highway and
nonroad engine and vehicle emissions to a portion of the CFR called
Subchapter U, which consists of 40 CFR parts 1,000 through 1299. We
have already adopted emission standards, test procedures, and
compliance provisions for several types of engines in 40 CFR parts 1033
through 1074. We intend eventually to capture all the regulatory
requirements related to heavy-duty highway engines and vehicles in
these new parts. Moving regulatory provisions to the new parts allows
us to publish the regulations in a way that is better organized,
reflects updates to various certification and compliance procedures,
provides consistency with other engine programs, and is written in
plain language. We have already taken steps in this direction for
heavy-duty highway engines by adopting the engine-testing procedures in
40 CFR part 1065 and the provisions for selective enforcement audits in
40 CFR part 1068.
EPA solicits comment on these proposed drafting changes and
additions. This solicitation relates solely to the appropriate
migration, translation, and enhancement of existing provisions. EPA is
not soliciting comment on the substance of these existing rules, and is
not proposing to amend, reconsider, or otherwise re-examine these
provisions' substantive effect.
The rest of this section describes the most significant of these
proposed redrafting changes. The proposal includes several changes to
the certification and compliance procedures, including the following:
We propose to require that engine manufacturers provide
installation instructions to vehicle manufacturers (see Sec.
1036.130). We expect this is already commonly done; however, the
regulatory language spells out a complete list of information we
believe is necessary to properly ensure that vehicle manufacturers
install engines in a way that is consistent with the engine's
certificate of conformity.
Sec. 1036.30, Sec. 1036.250, and Sec. 1036.825 spell
out several detailed provisions related to keeping records and
submitting information to us.
We wrote the greenhouse gas regulations to divide heavy-
duty engines into ``spark-ignition'' and ``compression-ignition''
engines, rather than ``Otto-cycle'' and ``diesel'' engines, to align
with our terminology in all our nonroad programs. This will likely
involve no effective change in categorizing engines except for natural
gas engines. To address this concern, we would include a provision in
Sec. 1036.150 to allow manufacturers to meet standards for spark-
ignition engines if they were regulated as Otto-cycle engines in 40 CFR
part 86, and vice versa.
Sec. 1036.205 describes a new requirement for imported
engines to describe the general approach to importation (such as
identifying authorized agents and ports of entry), and identifying a
test lab in the United States where EPA can perform testing on
certified engines. These steps are part of our ongoing effort to ensure
that we have a compliance and enforcement program that is as effective
for imported engines as for domestically produced engines. We have
already adopted these same provisions for several types of nonroad
engines.
Sec. 1036.210 specifies a process by which manufacturers
are able to get preliminary approval for EPA decisions for questions
that require lead time for preparing an application for certification.
This might involve, for example, preparing a plan for durability
testing, establishing engine families, identifying adjustable
parameters, and creating a list of scheduled maintenance items.
Sec. 1036.225 describes how to amend an application for
certification.
We are proposing to apply the exemption and recall
provisions as written in 40 CFR part 1068 instead of the comparable
provisions in 40 CFR part 85. This involves only minor changes relative
to current practice.
We are aware that it may be appropriate to move several additional
provisions in 40 CFR parts 85 and 86 to subchapter U. For example,
highway engine manufacturers may find it preferable to use the same
parameters specified for defining nonroad engine families for
certifying highway engines. To the extent that the nonroad provisions
would apply appropriately for highway engines, we and the manufacturers
would benefit from a consistent approach to certifying both types of
engines in a way that does not compromise the degree of emission
control achieved under the existing standards.
Another area of particular interest is defect reporting. Existing
regulations require manufacturers to report defects to EPA whenever the
same defect occurs at least 25 times. This approach can be somewhat
onerous for manufacturers making high-volume products. For example, for
an engine model with annual sales above 25,000, this represents a
defect rate of less than 0.1 percent. In contrast, the approach to
defect reporting in Sec. 1068.501 accommodates the high sales volumes
associated with highway engines, basing requirements on a percentage of
defective products, rather than setting a fixed number for all engine
families. This flexibility is paired with the explicit direction for
the manufacturer to actively monitor warranty claims, customer
complaints, and other sources of information to evaluate and track
potential defects. We believe this aligns both with the manufacturers'
interest in producing quality products and EPA's interest in addressing
any quality concerns that arise from the need to repair in-use engines
and vehicles.
[[Page 74279]]
(3) Test Procedures For Measuring Emissions From Heavy-Duty Vehicles
We are proposing a new part 1066 that would contain a general
chassis-based test procedures in for measuring emissions from a variety
of vehicles, including vehicles over 14,000 pounds GVWR. However, we
are not proposing to apply these procedures broadly at this time. The
test procedures in 40 CFR part 86 would continue to apply for vehicles
under 14,000 pounds GVWR. Rather, the proposed part 1066 procedures
would apply only for any testing that would be required for larger
vehicles. This could include ``A to B'' hybrid vehicle testing and
coastdown testing. Nevertheless, we will likely consider in the future
applying these procedures also for other heavy-duty vehicle testing and
for light-duty vehicles, highway motorcycles, and/or nonroad
recreational vehicles that rely on chassis-based testing.
As noted above, engine manufacturers are already using the test
procedures in 40 CFR part 1065 instead of those originally adopted in
40 CFR part 86. The new procedures are written to apply generically for
any type of engine and include the current state of technology for
measurement instruments, calibration procedures, and other practices.
We are proposing the chassis-based test procedures in part 1066 to have
a similar structure.
The proposed procedures in part 1066 reference large portions of
part 1065 to align test specifications that apply equally to engine-
based and vehicle-based testing, such as CVS and analyzer
specifications and calibrations, test fuels, calculations, and
definitions of many terms. Since several highway engine manufacturers
were involved in developing the full range of specified procedures in
part 1065, we are confident that many of these provisions are
appropriate without modification for vehicle testing.
The remaining test specifications needed in part 1066 are mostly
related to setting up, calibrating, and operating a chassis
dynamometer. This also includes the coastdown procedures that are
required for establishing the dynamometer load settings to ensure that
the dynamometer accurately simulates in-use driving.
Current testing requirements related to dynamometer specifications
rely on a combination of regulatory provisions, EPA guidance documents,
and extensive know-how from industry experience that has led to a good
understanding of best practices for operating a vehicle in the
laboratory to measure emissions. We attempted in this proposal to
capture this range of material, organizing these specifications and
verification and calibration procedures to include a complete set of
provisions to ensure that a dynamometer meeting these specifications
would allow for carefully controlled vehicle operation such that
emission measurements are accurate and repeatable. We request comment
on the range of proposed requirements related to designing, building,
and operating chassis dynamometers. For example, we believe that the
proposed verification and calibration procedures in part 1066, subpart
B, for diameter, speed, torque, acceleration, base inertia, friction
loss, and other parameters are all necessary to ensure proper
dynamometer operation. It may be that some of these checks are
redundant, or could be achieved with different procedures. There may
also be additional checks needed to remove possibilities for inadequate
accuracy or precision.
The procedures are written with the understanding that heavy-duty
highway manufacturers have, and need to have, single-roll electric
dynamometers for testing. We are aware that this is not the case for
other applications, such as all-terrain vehicles. We are not adopting
specific provisions for testing with hydrokinetic dynamometers, we are
already including a provision acknowledging that we may approve the use
of dynamometers meeting alternative specifications if that is
appropriate for the type of vehicle being tested and for the level of
stringency represented by the corresponding emission standards.
Drafting a full set of test specifications highlights the mixed use
of units for testing. Some chassis-based standards and procedures are
written based largely on the International System of Units (SI), such
as gram per kilometer (g/km) standards and kilometers per hour (kph)
driving, while others are written based largely on English units (g/
mile standards and miles per hour driving). The proposal includes a mix
of SI and English units with instructions about converting units
appropriately. However, most of the specifications and examples are
written in English units. While this seems to be the prevailing
practice for testing in the United States, we understand that vehicle
testing outside the United States is almost universally done in SI
units. In any case, dynamometers are produced with the capability of
operating in either English or SI units. We believe there would be a
substantial advantage toward the goal of achieving globally harmonized
test procedures if we would write the test procedures based on SI
units. This would also in several cases allow for more straightforward
calculations, and reduced risk of rounding errors. For comparison, part
1065 is written almost exclusively in SI units. We request comment on
the use of units throughout part 1066.
A fundamental obstacle toward using SI units is the fact that some
duty cycles are specified based on speeds in miles per hour. To address
this, it would be appropriate to convert the applicable driving
schedules to meter-per-second (m/s) values. Converting speeds to the
nearest 0.01 m/s would ensure that the prescribed driving cycle does
not change with respect to driving schedules that are specified to the
nearest 0.1 mph. The regulations would include the appropriate mph (or
kph) speeds to allow for a ready understanding of speed values (see 40
CFR part 1037, Appendix I). This would, for example, allow for drivers
to continue to follow a mph-based speed trace. The 2 mph
tolerance on driving speeds could be converted to 1.0 m/s,
which corresponds to an effective speed tolerance of 2.2
mph. This may involve a tightening or loosening of the existing speed
tolerance, depending on whether manufacturers used the full degree of
flexibility allowed for a mph tolerance value that is specified without
a decimal place. Similarly, the Cruise cycles for heavy-duty vehicles
could be specified as 24.5 0.5 m/s (54.8 1.1
mph) and 29.0 0.5 m/s (64.9 1.1 mph).
G. Penalties
As part of the fuel efficiency improvement program to be created
through this rulemaking, NHTSA is proposing civil penalties for non-
compliance with fuel consumption standards. NHTSA's authority under
EISA, as codified at 49 U.S.C. 32902(k), requires the agency to
determine appropriate measurement metrics, test procedures, standards,
and compliance and enforcement protocols for HD vehicles. NHTSA
interprets its authority to develop an enforcement program to include
the authority to determine and assess civil penalties for non-
compliance, that would impose penalties determined based on the
discussion that follows.
NHTSA proposes that in cases of non-compliance, the agency would
establish civil penalties based on consideration of the following
factors:
Actual fuel consumption performance related to the
applicable standard.
Estimated cost to comply with the regulation and
applicable standard.
[[Page 74280]]
Quantity of vehicles or engines not complying.
Manufacturer's history of non-compliance.
The civil penalty should act as a deterrent.
The financial condition of the manufacturer.
Civil penalties paid for non-compliance of the same
vehicles under the EPA GHG program.
NHTSA recognizes that EPA also has authority to impose civil
penalties for non-compliance with GHG regulations. It is not the intent
of either agency to impose duplicative civil penalties, and in the case
of non-compliance with fuel consumption regulations, NHTSA intends to
give consideration to civil penalties imposed by EPA for GHG non-
compliance, as EPA would give consideration to civil penalties imposed
by NHTSA in the case of non-compliance with GHG regulations.\204\
---------------------------------------------------------------------------
\204\ EPA discussed a similar situation concerning consideration
of civil penalties imposed by NHTSA for CAFE violations for light-
duty vehicles, in the final rule establishing the 2012-2016 MY
standards. See 75 FR 25324 and 25482, May 7, 2010.
---------------------------------------------------------------------------
The proposed civil penalty amount NHTSA could impose would not
exceed the limit that EPA is authorized to impose under the CAA. The
potential maximum civil penalty for a manufacturer would be calculated
as follows in Equation V-1:
Equation V-1: Aggregate Maximum Civil Penalty
Aggregate Maximum Civil Penalty for a Non-Compliant Regulatory Category
= (CAA Limit) x (production volume within the regulatory category)
NHTSA seeks comments related to this proposal for a civil penalty
program under EISA.
EPA has occasionally in the past conducted rulemakings to provide
for nonconformance penalties--monetary penalties that allow a
manufacturer to sell engines or vehicles that do not meet an emissions
standard. Nonconformance penalties are authorized for heavy-duty
engines and vehicles under section 206(g) of the CAA. Three basic
criteria have been established by rulemaking for determining the
eligibility of emissions standards for nonconformance penalties in any
given model year: (1) The emissions standard in question must become
more difficult to meet, (2) substantial work must be required in order
to meet the standard, and (3) a technological laggard must be likely to
develop (40 CFR 86.1103-87). A technological laggard is a manufacturer
who cannot meet a particular emissions standard due to technological
(not economic) difficulties and who, in the absence of nonconformance
penalties, might be forced from the marketplace. The process to
determine if these criteria are met and to establish penalty amounts
and conditions is carried out via rulemaking, as required by the CAA.
The CAA (in section 205) also lays out requirements for the assessment
of civil penalties for noncompliance with emissions standards.
As discussed in detail in Section III, the agencies have determined
that the proposed GHG and fuel consumption standards are readily
feasible, and we do not believe a technological laggard will emerge in
any sector covered by these proposed standards. In addition to the
standards being premised on use of already-existing, cost-effective
technologies, there are a number of flexibilities and alternative
standards built into the proposal. However, we do request comment
regarding this assessment and on whether or not it would be appropriate
for EPA and NHTSA to initiate rulemaking activity to set nonconformance
penalties for the proposed standards, subject to their respective
statutory authorities. Should nonconformance penalties be warranted,
the benefits of establishing them would be threefold: (1) The EPA and
NHTSA programs would continue to be equivalent, allowing manufacturers
to sell the same vehicles and engines to satisfy both programs, (2)
competitiveness in the affected HD sector would be maintained,
preserving jobs and consumer choices, and (3) nonconformance penalties
would be set through a transparent public process, involving notice and
public hearing.
VI. How would this proposed program impact fuel consumption, GHG
emissions, and climate change?
A. What methodologies did the agencies use to project GHG emissions and
fuel consumption impacts?
EPA and NHTSA used EPA's official mobile source emissions inventory
model named Motor Vehicle Emissions Simulator (MOVES2010),\205\, to
estimate emission and fuel consumption impacts of these proposed rules.
MOVES has capability to take in user inputs to modify default data to
better estimate emissions for different scenarios, such as different
regulatory alternatives, state implementation plans (SIPs), geographic
locations, vehicle activity, and microscale projects.
---------------------------------------------------------------------------
\205\ MOVES homepage: http://www.epa.gov/otaq/models/moves/index.htm. Version MOVES2010 was used for emissions impacts analysis
for this proposal. Current version as of September 14, 2010 is an
updated version named MOVES2010a, available directly from the MOVES
homepage. To replicate results from this proposal, MOVES2010 must be
used.
---------------------------------------------------------------------------
The agencies performed multiple MOVES runs to establish reference
case and control case emission inventories and fuel consumption values.
The agencies ran MOVES with user input databases that reflected
characteristics of the proposed rules, such as emissions improvements
and recent sales projections. Some post-processing of the model output
was required to ensure proper results. The agencies ran MOVES for non-
GHGs, CO2, CH4, and N2O for calendar
years 2005, 2018, 2030, and 2050. Additional runs were performed for
just the three greenhouse gases and for fuel consumption for every
calendar year from 2014 to 2050, inclusive, which fed the economy-wide
modeling, monetized benefits estimation, and climate impacts analysis.
The agencies also used MOVES to estimate emissions and fuel
consumption impacts for the other alternatives considered and described
in Section IX.
B. MOVES Analysis
(1) Inputs and Assumptions
(a) Reference Run Updates
Since MOVES2010 vehicle sales and activity data were developed from
AEO2006, EPA first updated these data using sales and activity
estimates from AEO2010. EPA also updated the fuel supply information in
MOVES to reflect a 100% E10 ``gasoline'' fuel supply to reflect the
Renewable Fuels Standard.\206\ MOVES2010 defaults were used for all
other parameters to estimate the reference case emissions inventories.
---------------------------------------------------------------------------
\206\ Renewable Fuels Standard available at http://www.epa.gov/otaq/fuels/renewablefuels/index.htm.
---------------------------------------------------------------------------
(b) Control Run Updates
EPA developed additional user input data for MOVES runs to estimate
control case inventories. To account for improvements of engine and
vehicle efficiency, EPA developed several user inputs to run the
control case in MOVES. Since MOVES does not operate based on Heavy-duty
FTP cycle results, EPA used the percent reduction in engine
CO2 emissions expected due to the proposed rules to develop
energy inputs for the control case runs. Also, EPA used the percent
reduction in aerodynamic drag coefficient and tire rolling resistance
coefficient expected from the proposed rules to develop road load input
for the control case. The fuel supply update used in the reference case
was used in the control case. Details of all the MOVES runs, input
[[Page 74281]]
data tables, and post-processing are available in the docket (EPA-HQ-
OAR-2010-0162).
Table VI-1 and Table VI-2 describe the estimated expected
reductions from these proposed rules, which were input into MOVES for
estimating control case emissions inventories.
[GRAPHIC] [TIFF OMITTED] TP30NO10.049
Since nearly all HD pickup trucks and vans will be certified on a
chassis dynamometer, the CO2 reductions for these vehicles
will not be represented as engine and road load reduction components,
but total vehicle CO2 reductions. These estimated reductions
are described in Table VI-3.
---------------------------------------------------------------------------
\207\ Section II discusses an alternative engine standard
proposed for the HD diesel engines in the 2014, 2015, and 2016 model
years. To the extent that engines using this alternative would be
expected to have baseline emissions greater than the industry
average, the reduction from the industry average projected in this
proposal could be reduced.
[GRAPHIC] [TIFF OMITTED] TP30NO10.050
[[Page 74282]]
(C) What are the projected reductions in fuel consumption and GHG
emissions?
EPA and NHTSA expect significant reductions in GHG emissions and
fuel consumption from these proposed rules--emission reductions from
both downstream (tailpipe) and upstream (fuel production and
distribution) sources, and fuel consumption reductions from more
efficient vehicles. Increased vehicle efficiency and reduced vehicle
fuel consumption would also reduce GHG emissions from upstream sources.
The following subsections summarize the GHG emissions and fuel
consumption reductions expected from these proposed rules.
(1) Downstream (Tailpipe)
EPA used MOVES to estimate downstream GHG inventories from these
proposed rules. We expect reductions in CO2 from all heavy-
duty vehicle categories. The reductions come from engine and vehicle
improvements. EPA expects CH4 and N2O emissions
to increase very slightly because of a rebound in vehicle miles
traveled (VMT) and because significant vehicle reductions of these two
GHGs are not expected from these proposed rules. Overall, downstream
GHG emissions will be reduced significantly, and is described in the
following subsections.
For CO2 and fuel consumption, the total energy
consumption ``pollutant'' was run in MOVES rather than CO2
itself. The energy was converted to fuel consumption based on fuel
heating values assumed in the Renewable Fuels Standard and used in the
development of MOVES emission and energy rates. These values are
117,250 kJ/gallon for E10 \208\ and 138,451 kJ/gallon for diesel.\209\
To calculate CO2, the agencies assumed a CO2
content of 8,576 g/gallon for E10 and 10,180 g/gallon for diesel. Table
VI-4 shows the fleet-wide GHG reductions and fuel savings from
reference case to control case through the lifetime of model year 2014
through 2018 heavy-duty vehicles. Table VI-5 shows the downstream GHG
emissions reductions and fuel savings in 2018, 2030, and 2050.
---------------------------------------------------------------------------
\208\ Renewable Fuels Standards assumptions of 115,000 BTU/
gallon gasoline (E0) and 76,330 BTU/gallon ethanol (E100) weighted
90% and 10%, respectively, and converted to kJ at 1.055 kJ/BTU.
\209\ MOVES2004 Energy and Emission Inputs. EPA420-P-05-003,
March 2005. http://www.epa.gov/otaq/models/ngm/420p05003.pdf.
[GRAPHIC] [TIFF OMITTED] TP30NO10.051
(2) Upstream (Fuel Production and Distribution)
Upstream GHG emission reductions associated with the production and
distribution of fuel were projected using emission factors from DOE's
``Greenhouse Gases, Regulated Emissions, and Energy Use in
Transportation'' (GREET1.8) model, with some modifications consistent
with the Light-Duty Greenhouse Gas rulemaking. More information
regarding these modifications can be found in the draft RIA Chapter 5.
These estimates include both international and domestic emission
reductions, since reductions in foreign exports of finished gasoline
and/or crude would make up a significant share of the fuel savings
resulting from the GHG standards. Thus, significant portions of the
upstream GHG emission reductions will occur outside of the United
States; a breakdown and discussion of projected international versus
domestic reductions is included in the draft RIA Chapter 5. GHG
emission reductions from upstream sources can be found in Table VI-6.
[[Page 74283]]
[GRAPHIC] [TIFF OMITTED] TP30NO10.052
(3) HFC Emissions
Based on projected HFC emission reductions due to the proposed AC
leakage standards, EPA estimates the HFC reductions to be 118,885
metric tons of CO2eq in 2018, 355,576 metric tons of
CO2eq emissions in 2030 and 417,584 metric tons
CO2eq in 2050, as detailed in draft RIA Chapter 5.3.4.
(4) Total (Upstream + Downstream + HFC)
Table VI-7 combines downstream results from Table VI-5, upstream
results Table VI-6, and HFC results to show total GHG reductions for
calendar years 2018, 2030, and 2050.
[GRAPHIC] [TIFF OMITTED] TP30NO10.053
D. Overview of Climate Change Impacts From GHG Emissions
Once emitted, GHGs that are the subject of this regulation can
remain in the atmosphere for decades to centuries, meaning that (1)
their concentrations become well-mixed throughout the global atmosphere
regardless of emission origin, and (2) their effects on climate are
long lasting. GHG emissions come mainly from the combustion of fossil
fuels (coal, oil, and gas), with additional contributions from the
clearing of forests and agricultural activities. Transportation
activities, in aggregate, are the second largest contributor to total
U.S. GHG emissions (27 percent) despite a decline in emissions from
this sector during 2008.\210\
---------------------------------------------------------------------------
\210\ U.S. EPA (2010) Inventory of U.S. Greenhouse Gas Emissions
and Sinks: 1990-2007. EPA-430-R-10-006, Washington, DC.
---------------------------------------------------------------------------
This section provides a summary of observed and projected changes
in GHG emissions and associated climate change impacts. The source
document for the section below is the Technical Support Document (TSD)
\211\ for EPA's Endangerment and Cause or Contribute Findings Under the
Clean Air Act (74 FR 66496, December 15, 2009). Below is the Executive
Summary of the TSD which provides technical support for the
endangerment and cause or contribute analyses concerning GHG emissions
under section 202(a) of the CAA. The TSD reviews observed and projected
changes in climate based on current and projected atmospheric GHG
concentrations and emissions, as well as the related impacts and risks
from climate change that are projected in the absence of GHG mitigation
actions, including this proposal and other U.S. and global actions. The
TSD was updated and revised based on expert technical review and public
comment as part of EPA's rulemaking process for the final Endangerment
Findings. The key findings synthesized here and the information
throughout the TSD are primarily drawn from the assessment reports of
the Intergovernmental Panel on Climate Change (IPCC), the U.S. Climate
Change Science Program (CCSP), the U.S. Global Change Research Program
(USGCRP), and NRC.\212\
---------------------------------------------------------------------------
\211\ See Endangerment TSD, Note 9 above.
\212\ For a complete list of core references from IPCC, USGCRP/
CCSP, NRC and others relied upon for development of the TSD for
EPA's Endangerment and Cause or Contribute Findings see section
1(b), specifically, Table 1.1 of the TSD Docket: EPA-HQ-OAR-2009-
0171-11645.
---------------------------------------------------------------------------
In May 2010, the NRC published its comprehensive assessment,
``Advancing the Science of Climate Change.'' \213\ It concluded that
``climate change is occurring, is caused largely by human activities,
and poses significant risks for--and in many cases is already
affecting--a broad range of human and natural systems.'' Furthermore,
the NRC stated that this conclusion is based on findings that are
``consistent with the conclusions of recent assessments by the U.S.
Global Change Research Program, the Intergovernmental Panel on Climate
Change's Fourth Assessment Report, and other assessments of the state
of scientific knowledge on climate change.'' These are the same
assessments that served as the primary scientific references underlying
the Administrator's Endangerment Finding. Importantly, this recent NRC
assessment represents another independent and critical inquiry of the
state of climate change science, separate and apart from the previous
IPCC and USGCRP assessments. The NRC assessment is a clear affirmation
that the scientific underpinnings of the Administrator's Endangerment
Finding are robust, credible, and appropriately characterized by EPA.
---------------------------------------------------------------------------
\213\ National Research Council (NRC) (2010). Advancing the
Science of Climate Change. National Academy Press. Washington, DC.
---------------------------------------------------------------------------
(1) Observed Trends in Greenhouse Gas Emissions and Concentrations
The primary long-lived GHGs directly emitted by human activities
include CO2, CH4, N2O, HFCs, PFCs, and
SF6. Greenhouse gases have a warming effect by trapping heat
in the atmosphere that would otherwise escape to space. In 2007, U.S.
GHG emissions were 7,150
[[Page 74284]]
teragrams \214\ of CO2 equivalent \215\
(TgCO2eq). The dominant gas emitted is CO2,
mostly from fossil fuel combustion. Methane is the second largest
component of U.S. emissions, followed by N2O and the fluorinated gases
(HFCs, PFCs, and SF6). Electricity generation is the largest emitting
sector (34% of total U.S. GHG emissions), followed by transportation
(27%) and industry (19%).
---------------------------------------------------------------------------
\214\ One teragram (Tg) = 1 million metric tons. 1 metric ton =
1,000 kilograms = 1.102 short tons = 2,205 pounds.
\215\ Long-lived GHGs are compared and summed together on a
CO2-equivalent basis by multiplying each gas by its
global warming potential (GWP), as estimated by IPCC. In accordance
with United Nations Framework Convention on Climate Change (UNFCCC)
reporting procedures, the U.S. quantifies GHG emissions using the
100-year timeframe values for GWPs established in the IPCC Second
Assessment Report.
---------------------------------------------------------------------------
Transportation sources under section 202(a) \216\ of the CAA
(passenger cars, light-duty trucks, other trucks and buses,
motorcycles, and passenger cooling) emitted 1,649 TgCO2eq in
2007, representing 23% of total U.S. GHG emissions. U.S. transportation
sources under section 202(a) made up 4.3% of total global GHG emissions
in 2005,\217\ which, in addition to the United States as a whole,
ranked only behind total GHG emissions from China, Russia, and India
but ahead of Japan, Brazil, Germany, and the rest of the world's
countries. In 2005, total U.S. GHG emissions were responsible for 18%
of global emissions, ranking only behind China, which was responsible
for 19% of global GHG emissions. The scope of this proposal focuses on
GHG emissions under section 202(a) from heavy-duty source categories
(see Section V).
---------------------------------------------------------------------------
\216\ Source categories under Section 202(a) of the CAA are a
subset of source categories considered in the transportation sector
and do not include emissions from non-highway sources such as boats,
rail, aircraft, agricultural equipment, construction/mining
equipment, and other off-road equipment.
\217\ More recent emission data are available for the United
States and other individual countries, but 2005 is the most recent
year for which data for all countries and all gases are available.
---------------------------------------------------------------------------
The global atmospheric CO2 concentration has increased
about 38% from pre-industrial levels to 2009, and almost all of the
increase is due to anthropogenic emissions. The global atmospheric
concentration of CH4 has increased by 149% since pre-
industrial levels (through 2007); and the N2O concentration
has increased by 23% (through 2007). The observed concentration
increase in these gases can also be attributed primarily to
anthropogenic emissions. The industrial fluorinated gases, HFCs, PFCs,
and SF6, have relatively low atmospheric concentrations but
the total radiative forcing due to these gases is increasing rapidly;
these gases are almost entirely anthropogenic in origin.
Historic data show that current atmospheric concentrations of the
two most important directly emitted, long-lived GHGs (CO2
and CH4) are well above the natural range of atmospheric
concentrations compared to at least the last 650,000 years. Atmospheric
GHG concentrations have been increasing because anthropogenic emissions
have been outpacing the rate at which GHGs are removed from the
atmosphere by natural processes over timescales of decades to
centuries.
(2) Observed Effects Associated With Global Elevated Concentrations of
GHGs
Greenhouse gases, at current (and projected) atmospheric
concentrations, remain well below published exposure thresholds for any
direct adverse health effects and are not expected to pose exposure
risks (i.e., breathing/inhalation).
The global average net effect of the increase in atmospheric GHG
concentrations, plus other human activities (e.g., land-use change and
aerosol emissions), on the global energy balance since 1750 has been
one of warming. This total net heating effect, referred to as forcing,
is estimated to be +1.6 (+0.6 to +2.4) watts per square meter (W/
m2), with much of the range surrounding this estimate due to
uncertainties about the cooling and warming effects of aerosols.
However, as aerosol forcing has more regional variability than the
well-mixed, long-lived GHGs, the global average might not capture some
regional effects. The combined radiative forcing due to the cumulative
(i.e., 1750 to 2005) increase in atmospheric concentrations of
CO2, CH4, and N2O is estimated to be
+2.30 (+2.07 to +2.53) W/m2. The rate of increase in
positive radiative forcing due to these three GHGs during the
industrial era is very likely to have been unprecedented in more than
10,000 years.
Warming of the climate system is unequivocal, as is now evident
from observations of increases in global average air and ocean
temperatures, widespread melting of snow and ice, and rising global
average sea level. Global mean surface temperatures have risen by 1.3
0.32 [deg]F (0.74 [deg]C 0.18 [deg]C) over
the last 100 years. Eight of the 10 warmest years on record have
occurred since 2001. Global mean surface temperature was higher during
the last few decades of the 20th century than during any comparable
period during the preceding four centuries.
Most of the observed increase in global average temperatures since
the mid-20th century is very likely due to the observed increase in
anthropogenic GHG concentrations. Climate model simulations suggest
natural forcing alone (i.e., changes in solar irradiance) cannot
explain the observed warming.
U.S. temperatures also warmed during the 20th and into the 21st
century; temperatures are now approximately 1.3 [deg]F (0.7 [deg]C)
warmer than at the start of the 20th century, with an increased rate of
warming over the past 30 years. Both the IPCC \218\ and the CCSP
reports attributed recent North American warming to elevated GHG
concentrations. In the CCSP (2008) report,\219\ the authors find that
for North America, ``more than half of this warming [for the period
1951-2006] is likely the result of human-caused greenhouse gas forcing
of climate change.''
---------------------------------------------------------------------------
\218\ Hegerl, G.C. et al. (2007) Understanding and Attributing
Climate Change. In: Climate Change 2007: The Physical Science Basis.
Contribution of Working Group I to the Fourth Assessment Report of
the Intergovernmental Panel on Climate Change [Solomon, S., D. Qin,
M. Manning, Z. Chen, M. Marquis, K.B. Averyt, M. Tignor, and H.L.
Miller (eds.)]. Cambridge University Press, Cambridge, United
Kingdom and New York, NY, USA.
\219\ CCSP (2008) Reanalysis of Historical Climate Data for Key
Atmospheric Features: Implications for Attribution of Causes of
Observed Change. A Report by the U.S. Climate Change Science Program
and the Subcommittee on Global Change Research [Randall Dole, Martin
Hoerling, and Siegfried Schubert (eds.)]. National Oceanic and
Atmospheric Administration, National Climatic Data Center,
Asheville, NC, 156 pp.
---------------------------------------------------------------------------
Observations show that changes are occurring in the amount,
intensity, frequency and type of precipitation. Over the contiguous
United States, total annual precipitation increased by 6.1% from 1901
to 2008. It is likely that there have been increases in the number of
heavy precipitation events within many land regions, even in those
where there has been a reduction in total precipitation amount,
consistent with a warming climate.
There is strong evidence that global sea level gradually rose in
the 20th century and is currently rising at an increased rate. It is
not clear whether the increasing rate of sea level rise is a reflection
of short-term variability or an increase in the longer-term trend.
Nearly all of the Atlantic Ocean shows sea level rise during the last
50 years with the rate of rise reaching a maximum (over 2 millimeters
[mm] per year) in a band along the U.S. east coast running east-
northeast.
Satellite data since 1979 show that annual average Arctic sea ice
extent has shrunk by 4.1% per decade. The size and speed of recent
Arctic summer sea ice loss is highly anomalous relative to the previous
few thousands of years.
[[Page 74285]]
Widespread changes in extreme temperatures have been observed in
the last 50 years across all world regions, including the United
States. Cold days, cold nights, and frost have become less frequent,
while hot days, hot nights, and heat waves have become more frequent.
Observational evidence from all continents and most oceans shows
that many natural systems are being affected by regional climate
changes, particularly temperature increases. However, directly
attributing specific regional changes in climate to emissions of GHGs
from human activities is difficult, especially for precipitation.
Ocean CO2 uptake has lowered the average ocean pH
(increased acidity) level by approximately 0.1 since 1750. Consequences
for marine ecosystems can include reduced calcification by shell-
forming organisms, and in the longer term, the dissolution of carbonate
sediments.
Observations show that climate change is currently affecting U.S.
physical and biological systems in significant ways. The consistency of
these observed changes in physical and biological systems and the
observed significant warming likely cannot be explained entirely due to
natural variability or other confounding non-climate factors.
(3) Projections of Future Climate Change With Continued Increases in
Elevated GHG Concentrations
Most future scenarios that assume no explicit GHG mitigation
actions (beyond those already enacted) project increasing global GHG
emissions over the century, with climbing GHG concentrations. Carbon
dioxide is expected to remain the dominant anthropogenic GHG over the
course of the 21st century. The radiative forcing associated with the
non-CO2 GHGs is still significant and increasing over time.
Future warming over the course of the 21st century, even under
scenarios of low-emission growth, is very likely to be greater than
observed warming over the past century. According to climate model
simulations summarized by the IPCC,\220\ through about 2030, the global
warming rate is affected little by the choice of different future
emissions scenarios. By the end of the 21st century, projected average
global warming (compared to average temperature around 1990) varies
significantly depending on the emission scenario and climate
sensitivity assumptions, ranging from 3.2 to 7.2 [deg]F (1.8 to 4.0
[deg]C), with an uncertainty range of 2.0 to 11.5 [deg]F (1.1 to 6.4
[deg]C).
---------------------------------------------------------------------------
\220\ Meehl, G.A. et al. (2007) Global Climate Projections. In:
Climate Change 2007: The Physical Science Basis. Contribution of
Working Group I to the Fourth Assessment Report of the
Intergovernmental Panel on Climate Change [Solomon, S., D. Qin, M.
Manning, Z. Chen, M. Marquis, K.B. Averyt, M. Tignor and H.L. Miller
(eds.)]. Cambridge University Press, Cambridge, United Kingdom and
New York, NY, USA.
---------------------------------------------------------------------------
All of the United States is very likely to warm during this
century, and most areas of the United States are expected to warm by
more than the global average. The largest warming is projected to occur
in winter over northern parts of Alaska. In western, central and
eastern regions of North America, the projected warming has less
seasonal variation and is not as large, especially near the coast,
consistent with less warming over the oceans.
It is very likely that heat waves will become more intense, more
frequent, and longer lasting in a future warm climate, whereas cold
episodes are projected to decrease significantly.
Increases in the amount of precipitation are very likely in higher
latitudes, while decreases are likely in most subtropical latitudes and
the southwestern United States, continuing observed patterns. The mid-
continental area is expected to experience drying during summer,
indicating a greater risk of drought.
Intensity of precipitation events is projected to increase in the
United States and other regions of the world. More intense
precipitation is expected to increase the risk of flooding and result
in greater runoff and erosion that has the potential for adverse water
quality effects.
It is likely that hurricanes will become more intense, with
stronger peak winds and more heavy precipitation associated with
ongoing increases of tropical sea surface temperatures. Frequency
changes in hurricanes are currently too uncertain for confident
projections.
By the end of the century, global average sea level is projected by
IPCC \221\ to rise between 7.1 and 23 inches (18 and 59 centimeter
[cm]), relative to around 1990, in the absence of increased dynamic ice
sheet loss. Recent rapid changes at the edges of the Greenland and West
Antarctic ice sheets show acceleration of flow and thinning. While an
understanding of these ice sheet processes is incomplete, their
inclusion in models would likely lead to increased sea level
projections for the end of the 21st century.
---------------------------------------------------------------------------
\221\ IPCC (2007) Summary for Policymakers. In: Climate Change
2007: The Physical Science Basis. Contribution of Working Group I to
the Fourth Assessment Report of the Intergovernmental Panel on
Climate Change [Solomon, S., D. Qin, M. Manning, Z. Chen, M.
Marquis, K.B. Averyt, M. Tignor and H.L. Miller (eds.)]. Cambridge
University Press, Cambridge, United Kingdom and New York, NY, USA.
---------------------------------------------------------------------------
Sea ice extent is projected to shrink in the Arctic under all IPCC
emissions scenarios.
(4) Projected Risks and Impacts Associated With Future Climate Change
Risk to society, ecosystems, and many natural Earth processes
increase with increases in both the rate and magnitude of climate
change. Climate warming may increase the possibility of large, abrupt
regional or global climatic events (e.g., disintegration of the
Greenland Ice Sheet or collapse of the West Antarctic Ice Sheet). The
partial deglaciation of Greenland (and possibly West Antarctica) could
be triggered by a sustained temperature increase of 2 to 7 [deg]F (1 to
4[deg] C) above 1990 levels. Such warming would cause a 13 to 20 feet
(4 to 6 meter) rise in sea level, which would occur over a time period
of centuries to millennia.
The CCSP \222\ reports that climate change has the potential to
accentuate the disparities already evident in the American health care
system, as many of the expected health effects are likely to fall
disproportionately on the poor, the elderly, the disabled, and the
uninsured. The IPCC \223\ states with very high confidence that climate
change impacts on human health in U.S. cities will be compounded by
population growth and an aging population.
---------------------------------------------------------------------------
\222\ Ebi, K.L., J. Balbus, P.L. Kinney, E. Lipp, D. Mills, M.S.
O'Neill, and M. Wilson (2008) Effects of Global Change on Human
Health. In: Analyses of the effects of global change on human health
and welfare and human systems. A Report by the U.S. Climate Change
Science Program and the Subcommittee on Global Change Research.
[Gamble, J.L. (ed.), K.L. Ebi, F.G. Sussman, T.J. Wilbanks,
(Authors)]. U.S. Environmental Protection Agency, Washington, DC,
USA, pp. 2-1 to 2-78.
\223\ Field, C.B. et al. (2007) North America. In: Climate
Change 2007: Impacts, Adaptation and Vulnerability. Contribution of
Working Group II to the Fourth Assessment Report of the
Intergovernmental Panel on Climate Change [M.L. Parry, O.F.
Canziani, J.P. Palutikof, P.J. van der Linden and C.E. Hanson
(eds.)]. Cambridge University Press, Cambridge, United Kingdom and
New York, NY, USA.
---------------------------------------------------------------------------
Severe heat waves are projected to intensify in magnitude and
duration over the portions of the United States where these events
already occur, with potential increases in mortality and morbidity,
especially among the elderly, young, and frail.
Some reduction in the risk of death related to extreme cold is
expected. It is not clear whether reduced mortality from cold will be
greater or less than increased heat-related mortality in the United
States due to climate change.
[[Page 74286]]
Increases in regional ozone pollution relative to ozone levels
without climate change are expected due to higher temperatures and
weaker circulation in the United States and other world cities relative
to air quality levels without climate change. Climate change is
expected to increase regional ozone pollution, with associated risks in
respiratory illnesses and premature death. In addition to human health
effects, tropospheric ozone has significant adverse effects on crop
yields, pasture and forest growth, and species composition. The
directional effect of climate change on ambient particulate matter
levels remains uncertain.
Within settlements experiencing climate change, certain parts of
the population may be especially vulnerable; these include the poor,
the elderly, those already in poor health, the disabled, those living
alone, and/or indigenous populations dependent on one or a few
resources. Thus, the potential impacts of climate change raise
environmental justice issues.
The CCSP \224\ concludes that, with increased CO2 and
temperature, the life cycle of grain and oilseed crops will likely
progress more rapidly. But, as temperature rises, these crops will
increasingly begin to experience failure, especially if climate
variability increases and precipitation lessens or becomes more
variable. Furthermore, the marketable yield of many horticultural crops
(e.g., tomatoes, onions, fruits) is very likely to be more sensitive to
climate change than grain and oilseed crops.
---------------------------------------------------------------------------
\224\ Backlund, P., A. Janetos, D.S. Schimel, J. Hatfield, M.G.
Ryan, S.R. Archer, and D. Lettenmaier (2008) Executive Summary. In:
The Effects of Climate Change on Agriculture, Land Resources, Water
Resources, and Biodiversity in the United States. A Report by the
U.S. Climate Change Science Program and the Subcommittee on Global
Change Research. Washington, DC., USA, 362 pp.
---------------------------------------------------------------------------
Higher temperatures will very likely reduce livestock production
during the summer season in some areas, but these losses will very
likely be partially offset by warmer temperatures during the winter
season.
Cold-water fisheries will likely be negatively affected; warm-water
fisheries will generally benefit; and the results for cool-water
fisheries will be mixed, with gains in the northern and losses in the
southern portions of ranges.
Climate change has very likely increased the size and number of
forest fires, insect outbreaks, and tree mortality in the interior
West, the Southwest, and Alaska, and will continue to do so. Over North
America, forest growth and productivity have been observed to increase
since the middle of the 20th century, in part due to observed climate
change. Rising CO2 will very likely increase photosynthesis
for forests, but the increased photosynthesis will likely only increase
wood production in young forests on fertile soils. The combined effects
of expected increased temperature, CO2, nitrogen deposition,
ozone, and forest disturbance on soil processes and soil carbon storage
remain unclear.
Coastal communities and habitats will be increasingly stressed by
climate change impacts interacting with development and pollution. Sea
level is rising along much of the U.S. coast, and the rate of change
will very likely increase in the future, exacerbating the impacts of
progressive inundation, storm-surge flooding, and shoreline erosion.
Storm impacts are likely to be more severe, especially along the Gulf
and Atlantic coasts. Salt marshes, other coastal habitats, and
dependent species are threatened by sea level rise, fixed structures
blocking landward migration, and changes in vegetation. Population
growth and rising value of infrastructure in coastal areas increases
vulnerability to climate variability and future climate change.
Climate change will likely further constrain already over-allocated
water resources in some regions of the United States, increasing
competition among agricultural, municipal, industrial, and ecological
uses. Although water management practices in the United States are
generally advanced, particularly in the West, the reliance on past
conditions as the basis for current and future planning may no longer
be appropriate, as climate change increasingly creates conditions well
outside of historical observations. Rising temperatures will diminish
snowpack and increase evaporation, affecting seasonal availability of
water. In the Great Lakes and major river systems, lower water levels
are likely to exacerbate challenges relating to water quality,
navigation, recreation, hydropower generation, water transfers, and
binational relationships. Decreased water supply and lower water levels
are likely to exacerbate challenges relating to aquatic navigation in
the United States.
Higher water temperatures, increased precipitation intensity, and
longer periods of low flows will exacerbate many forms of water
pollution, potentially making attainment of water quality goals more
difficult. As waters become warmer, the aquatic life they now support
will be replaced by other species better adapted to warmer water. In
the long term, warmer water and changing flow may result in
deterioration of aquatic ecosystems.
Ocean acidification is projected to continue, resulting in the
reduced biological production of marine calcifiers, including corals.
Climate change is likely to affect U.S. energy use and energy
production and physical and institutional infrastructures. It will also
likely interact with and possibly exacerbate ongoing environmental
change and environmental pressures in settlements, particularly in
Alaska where indigenous communities are facing major environmental and
cultural impacts. The U.S. energy sector, which relies heavily on water
for hydropower and cooling capacity, may be adversely impacted by
changes to water supply and quality in reservoirs and other water
bodies. Water infrastructure, including drinking water and wastewater
treatment plants, and sewer and stormwater management systems, will be
at greater risk of flooding, sea level rise and storm surge, low flows,
and other factors that could impair performance.
Disturbances such as wildfires and insect outbreaks are increasing
in the United States and are likely to intensify in a warmer future
with warmer winters, drier soils, and longer growing seasons. Although
recent climate trends have increased vegetation growth, continuing
increases in disturbances are likely to limit carbon storage,
facilitate invasive species, and disrupt ecosystem services.
Over the 21st century, changes in climate will cause species to
shift north and to higher elevations and fundamentally rearrange U.S.
ecosystems. Differential capacities for range shifts and constraints
from development, habitat fragmentation, invasive species, and broken
ecological connections will alter ecosystem structure, function, and
services.
(5) Present and Projected U.S. Regional Climate Change Impacts
Climate change impacts will vary in nature and magnitude across
different regions of the United States.
Sustained high summer temperatures, heat waves, and declining air
quality are
[[Page 74287]]
projected in the Northeast,\225\ Southeast,\226\ Southwest,\227\ and
Midwest.\228\ Projected climate change would continue to cause loss of
sea ice, glacier retreat, permafrost thawing, and coastal erosion in
Alaska.
---------------------------------------------------------------------------
\225\ Northeast includes West Virginia, Maryland, Delaware,
Pennsylvania, New Jersey, New York, Connecticut, Rhode Island,
Massachusetts, Vermont, New Hampshire, and Maine.
\226\ Southeast includes Kentucky, Virginia, Arkansas,
Tennessee, North Carolina, South Carolina, southeast Texas,
Louisiana, Mississippi, Alabama, Georgia, and Florida.
\227\ Southwest includes California, Nevada, Utah, western
Colorado, Arizona, New Mexico (except the extreme eastern section),
and southwest Texas.
\228\ The Midwest includes Minnesota, Wisconsin, Michigan, Iowa,
Illinois, Indiana, Ohio, and Missouri.
---------------------------------------------------------------------------
Reduced snowpack, earlier spring snowmelt, and increased likelihood
of seasonal summer droughts are projected in the Northeast,
Northwest,\229\ and Alaska. More severe, sustained droughts and water
scarcity are projected in the Southeast, Great Plains,\230\ and
Southwest.
---------------------------------------------------------------------------
\229\ The Northwest includes Washington, Idaho, western Montana,
and Oregon.
\230\ The Great Plains includes central and eastern Montana,
North Dakota, South Dakota, Wyoming, Nebraska, eastern Colorado,
Nebraska, Kansas, extreme eastern New Mexico, central Texas, and
Oklahoma
---------------------------------------------------------------------------
The Southeast, Midwest, and Northwest in particular are expected to
be impacted by an increased frequency of heavy downpours and greater
flood risk.
Ecosystems of the Southeast, Midwest, Great Plains, Southwest,
Northwest, and Alaska are expected to experience altered distribution
of native species (including local extinctions), more frequent and
intense wildfires, and an increase in insect pest outbreaks and
invasive species.
Sea level rise is expected to increase storm surge height and
strength, flooding, erosion, and wetland loss along the coasts,
particularly in the Northeast, Southeast, and islands.
Warmer water temperatures and ocean acidification are expected to
degrade important aquatic resources of islands and coasts such as coral
reefs and fisheries.
A longer growing season, low levels of warming, and fertilization
effects of carbon dioxide may benefit certain crop species and forests,
particularly in the Northeast and Alaska. Projected summer rainfall
increases in the Pacific islands may augment limited freshwater
supplies. Cold-related mortality is projected to decrease, especially
in the Southeast. In the Midwest in particular, heating oil demand and
snow-related traffic accidents are expected to decrease.
Climate change impacts in certain regions of the world may
exacerbate problems that raise humanitarian, trade, and national
security issues for the United States. The IPCC \231\ identifies the
most vulnerable world regions as the Arctic, because of the effects of
high rates of projected warming on natural systems; Africa, especially
the sub-Saharan region, because of current low adaptive capacity as
well as climate change; small islands, due to high exposure of
population and infrastructure to risk of sea level rise and increased
storm surge; and Asian mega-deltas, such as the Ganges-Brahmaputra and
the Zhujiang, due to large populations and high exposure to sea level
rise, storm surge and river flooding. Climate change has been described
as a potential threat multiplier with regard to national security
issues.
---------------------------------------------------------------------------
\231\ Parry, M.L. et al. (2007) Technical Summary. In: Climate
Change 2007: Impacts, Adaptation and Vulnerability. Contribution of
Working Group II to the Fourth Assessment Report of the
Intergovernmental Panel on Climate Change [M.L. Parry, O.F.
Canziani, J.P. Palutikof, P.J. van der Linden, and C.E. Hanson
(eds.)], Cambridge University Press, Cambridge, United Kingdom, pp.
23S78.
---------------------------------------------------------------------------
E. Changes in Atmospheric CO2 Concentrations, Global Mean
Temperature, Sea Level Rise, and Ocean pH Associated with the
Proposal's GHG Emissions Reductions
EPA examined \232\ the reductions in CO2 and other GHGs
associated with this proposal and analyzed the projected effects on
atmospheric CO2 concentrations, global mean surface
temperature, sea level rise, and ocean pH which are common variables
used as indicators of climate change. The analysis projects that the
preferred alternative of this proposal will reduce atmospheric
concentrations of CO2, global climate warming and sea level
rise. Although the projected reductions and improvements are small in
overall magnitude by themselves, they are quantifiable and would
contribute to reducing the risks associated with climate change.
---------------------------------------------------------------------------
\232\ Using the Model for the Assessment of Greenhouse Gas
Induced Climate Change (MAGICC) 5.3v2, http://www.cgd.ucar.edu/cas/wigley/magicc/), EPA estimated the effects of this proposal's
greenhouse gas emissions reductions on global mean temperature and
sea level. Please refer to Chapter 8.4 of the RIA for additional
information.
---------------------------------------------------------------------------
EPA determines that the projected reductions in atmospheric
CO2, global mean temperature and sea level rise are
meaningful in the context of this proposal. In addition, EPA has
conducted an analysis to evaluate the projected changes in ocean pH in
the context of the changes in emissions from this proposal. The results
for projected atmospheric CO2 concentrations are estimated
to be reduced by 0.693 to 0.784 part per million by volume (ppmv)
(average of 0.732 ppmv), global mean temperature is estimated to be
reduced by 0.002 to 0.004[deg]C, sea-level rise is projected to be
reduced by approximately 0.012-0.048 cm based on a range of climate
sensitivities, and ocean pH will increase by 0.0003 pH units by 2100.
(1) Estimated Projected Reductions in Atmospheric CO2
Concentration, Global Mean Surface Temperatures, Sea Level Rise, and
Ocean pH
EPA estimated changes in the atmospheric CO2
concentration, global mean temperature, and sea level rise out to 2100
resulting from the emissions reductions in this proposal using the GCAM
(Global Change Assessment Model, formerly MiniCAM), integrated
assessment model \233\ coupled with the Model for the Assessment of
Greenhouse Gas Induced Climate Change (MAGICC, version 5.3v2).\234\
GCAM was used to create the globally and temporally consistent set of
climate relevant variables required for running MAGICC. MAGICC was then
used to estimate the projected change in these variables over time.
Given the magnitude of the estimated emissions reductions associated
with the rule, a simple climate model such as MAGICC is reasonable for
estimating the atmospheric and climate response. This widely-used, peer
reviewed modeling tool was also used to project temperature and sea
level rise under different emissions scenarios in the Third and Fourth
Assessments of the IPCC.
---------------------------------------------------------------------------
\233\ GCAM is a long-term, global integrated assessment model of
energy, economy, agriculture and land use, that considers the
sources of emissions of a suite of GHG's, emitted in 14 globally
disaggregated regions, the fate of emissions to the atmosphere, and
the consequences of changing concentrations of greenhouse related
gases for climate change. GCAM begins with a representation of
demographic and economic developments in each region and combines
these with assumptions about technology development to describe an
internally consistent representation of energy, agriculture, land-
use, and economic developments that in turn shape global emissions.
Brenkert A, S. Smith, S. Kim, and H. Pitcher, 2003: Model
Documentation for the MiniCAM. PNNL-14337, Pacific Northwest
National Laboratory, Richland, Washington.
\234\ Wigley, T.M.L. 2008. MAGICC 5.3.v2 User Manual. UCAR--
Climate and Global Dynamics Division, Boulder, Colorado. http://www.cgd.ucar.edu/cas/wigley/magicc/.
---------------------------------------------------------------------------
The integrated impact of the following pollutant and greenhouse gas
emissions changes are considered: CO2, CH4,
N2O, NOX, CO2 and SO2, and
volatile organic compounds (VOC). For CO, SO2, and
NOX, emissions reductions were estimated for 2018, 2030, and
2050 (provided in Section VII.A). For CO2, CH4,
and N2O an annual time-series of
[[Page 74288]]
(upstream + downstream) emissions reductions estimated from the
proposal were input directly. The GHG emissions reductions, from
Section VI.C, were applied as net reductions to a global reference case
(or baseline) emissions scenario in GCAM to generate an emissions
scenario specific to this proposal. EPA linearly scaled emissions
reductions between a zero input value in 2013 and the value supplied
for 2018 to produce the reductions for 2014-2018. A similar scaling was
used for 2019-2029 and 2031-2050. The emissions reductions past 2050
were scaled with total U.S. road transportation fuel consumption from
the GCAM reference scenario. Road transport fuel consumption past 2050
does not change significantly and thus emissions reductions remain
relatively constant from 2050 through 2100. Specific details about the
reference case scenario and how the emissions reductions were applied
to generate the scenario can be found in the proposal's RIA, Chapter
8.4.
MAGICC is a global model and is primarily concerned with climate,
therefore the impact of short-lived climate forcing agents (e.g.,
O3) are not explicitly simulated as in regional air quality
models. While many precursors related to short-lived climate forcers
such as ozone are considered, MAGICC simulates the longer term effect
on climate from long-lived GHGs. The impacts to ground-level ozone and
other non-GHGs are discussed in Section VII of this proposal and the
draft RIA Chapter 8.2. Some aerosols, such as black carbon, cause a
positive forcing or warming effect by absorbing incoming solar
radiation. There remain some significant scientific uncertainties about
black carbon's total climate effect,\235\ as well as concerns about how
to treat the short-lived black carbon emissions alongside the long-
lived, well-mixed greenhouse gases in a common framework (e.g., what
are the appropriate metrics to compare the warming and/or climate
effects of the different substances, given that, unlike greenhouse
gases, the magnitude of aerosol effects can vary immensely with
location and season of emissions). Further, estimates of the direct
radiative forcing of individual species are less certain than the total
direct aerosol radiative forcing.
---------------------------------------------------------------------------
\235\ The range of uncertainty in the current magnitude of black
carbon's climate forcing effect is evidenced by the ranges presented
by the IPCC Fourth Assessment Report (2007) and the more recent
study by Ramanathan, V. and Carmichael, G. (2008) Global and
regional climate changes due to black carbon. Nature Geoscience,
1(4): 221-227.
---------------------------------------------------------------------------
There is no single accepted methodology for transforming black
carbon emissions into temperature change or CO2eq emissions.
The interaction of black carbon (and other co-emitted aerosol species)
with clouds is especially poorly quantified, and this factor is key to
any attempt to estimate the net climate impacts of black carbon. While
black carbon is likely to be an important contributor to climate
change, it would be premature to include quantification of black carbon
climate impacts in an analysis of the proposed standards at this time.
Changes in atmospheric CO2 concentration, global mean
temperature, and sea level rise for both the reference case and the
emissions scenarios associated with this proposal were computed using
MAGICC. To calculate the reductions in the atmospheric CO2
concentrations as well as in temperature and sea level resulting from
this proposal, the output from the policy scenario associated with the
preferred approach of this proposal was subtracted from an existing
Global Change Assessment Model (GCAM, formerly MiniCAM) reference
emission scenario. To capture some key uncertainties in the climate
system with the MAGICC model, changes in atmospheric CO2,
global mean temperature and sea level rise were projected across the
most current IPCC range of climate sensitivities which ranges from 1.5
[deg]C to 6.0 [deg]C.\236\ This range reflects the uncertainty for
equilibrium climate sensitivity for how much global mean temperature
would rise if the concentration of carbon dioxide in the atmosphere
were to double. The information for this range come from constraints
from past climate change on various time scales, and the spread of
results for climate sensitivity from ensembles of models.\237\ Details
about this modeling analysis can be found in the draft RIA Chapter 8.4.
---------------------------------------------------------------------------
\236\ In IPCC reports, equilibrium climate sensitivity refers to
the equilibrium change in the annual mean global surface temperature
following a doubling of the atmospheric equivalent carbon dioxide
concentration. The IPCC states that climate sensitivity is
``likely'' to be in the range of 2 [deg]C to 4.5 [deg]C, ``very
unlikely'' to be less than 1.5 [deg]C, and ``values substantially
higher than 4.5[deg] C cannot be excluded.'' IPCC WGI, 2007, Climate
Change 2007--The Physical Science Basis, Contribution of Working
Group I to the Fourth Assessment Report of the IPCC, http://www.ipcc.ch/.
\237\ Meehl, G.A. et al. (2007) Global Climate Projections. In:
Climate Change 2007: The Physical Science Basis. Contribution of
Working Group I to the Fourth Assessment Report of the
Intergovernmental Panel on Climate Change [Solomon, S., D. Qin, M.
Manning, Z. Chen, M. Marquis, K.B. Averyt, M. Tignor and H.L. Miller
(eds.)]. Cambridge University Press, Cambridge, United Kingdom and
New York, NY, USA.
---------------------------------------------------------------------------
The results of this modeling, summarized in Table VI-8, show small
but quantifiable reductions in atmospheric CO2
concentrations, projected global mean temperature and sea level
resulting from this proposal, across all climate sensitivities. As a
result of the emission reductions from the proposed standards for this
proposal, the atmospheric CO2 concentration is projected to
be reduced by an average of 0.732 ppmv, the global mean temperature is
projected to be reduced by approximately 0.002-0.004 [deg]C by 2100,
and global mean sea level rise is projected to be reduced by
approximately 0.012-0.050 cm by 2100. The range of reductions in global
mean temperature and sea level rise is larger because CO2
concentrations are not tightly coupled to climate sensitivity, whereas
the magnitude of temperature change response to CO2 changes
(and therefore sea level rise) is tightly coupled to climate
sensitivity in the MAGICC model.
[[Page 74289]]
[GRAPHIC] [TIFF OMITTED] TP30NO10.054
The reductions are small relative to the IPCC's 2100 ``best
estimates'' \238\ for global mean temperature increases (1.1--6.4
[ordm]C) and sea level rise (0.18-0.59m) for all global GHG emissions
sources for a range of emissions scenarios.\239\ These ``best
estimates'' are assessed from a hierarchy of models that encompass a
simple climate model, several Earth Models of Intermediate Complexity,
and a large number of Atmosphere-Ocean Global Circulation Models and
are based on the six major scenarios described in the Special Report on
Emissions Scenarios, not including dynamical ice sheet behavior that
would lead to an increase in sea level rise. Further discussion of
EPA's modeling analysis is found in the draft RIA, Chapter 8.
---------------------------------------------------------------------------
\238\ IPCC's ``best estimates'' at the end of the 21st century
from Table TS.6 in the Technical Summary: Contribution of Working
Group I (Solomon et al., 2007).
\239\ IPCC (2007) Climate Change 2007: The Physical Science
Basis. Contribution of Working Group I to the Fourth Assessment
Report of the Intergovernmental Panel on Climate Change [Solomon,
S., D. Qin, M. Manning, Z. Chen, M. Marquis, K.B. Averyt, M. Tignor,
and H.L. Miller (eds.)]. Cambridge University Press, Cambridge,
United Kingdom and New York, NY, USA.
---------------------------------------------------------------------------
EPA used the Program CO2SYS,\240\ version 1.05 to estimate
projected changes in ocean pH for tropical waters based on the
atmospheric CO2 concentration change (reduction) resulting
from this proposal. The program performs calculations relating
parameters of the CO2 system in seawater. EPA used the
program to calculate ocean pH as a function of atmospheric
CO2 concentrations, among other specified input conditions.
Based on the projected atmospheric CO2 concentration
reductions (0.731 ppmv by 2100 for a climate sensitivity of 3.0) that
would result from this proposal, the program calculates an increase in
ocean pH of 0.0003 pH units. Thus, this analysis indicates the
projected decrease in atmospheric CO2 concentrations from
the preferred approach associated with this proposal would result in an
increase in ocean pH. For additional validation, results were generated
from the atmospheric CO2 concentration change for each
climate sensitivity case (1.5 to 6.0) and using different known
constants from the literature. A comprehensive discussion of the
modeling analysis associated with ocean pH is provided in the draft
RIA, Chapter 8.
---------------------------------------------------------------------------
\240\ Lewis, E., and D. W. R. Wallace. 1998. Program Developed
for CO2 System Calculations. ORNL/CDIAC-105. Carbon
Dioxide Information Analysis Center, Oak Ridge National Laboratory,
U.S. Department of Energy, Oak Ridge, Tennessee.
---------------------------------------------------------------------------
(2) Proposal's Effect on Climate
As a substantial portion of CO2 emitted into the
atmosphere is not removed by natural processes for millennia, each unit
of CO2 not emitted into the atmosphere avoids essentially
permanent climate change on centennial time scales. Reductions in
emissions in the near-term are important in determining long-term
climate stabilization and associated impacts experienced not just over
the next decades but in the coming centuries and millennia.\241\ Though
the magnitude of the avoided climate change projected here is small,
these reductions would represent a reduction in the adverse risks
associated with climate change (though these risks were not formally
estimated for this proposal) across a range of equilibrium climate
sensitivities.
---------------------------------------------------------------------------
\241\ National Research Council (NRC) (2010). Climate
Stabilization Targets. Committee on Stabilization Targets for
Atmospheric Greenhouse Gas Concentrations; Board on Atmospheric
Sciences and Climate, Division of Earth and Life Sciences, National
Academy Press. Washington, DC.
---------------------------------------------------------------------------
EPA's analysis of the proposal's impact on global climate
conditions is intended to quantify these potential reductions using the
best available science. While EPA's modeling results of the effect of
this proposal alone show small differences in climate effects
(CO2 concentration, temperature, sea-level rise, ocean pH),
when expressed in terms of global climate endpoints and global GHG
emissions, yield results that are repeatable and consistent within the
modeling frameworks used.
VII. How Would This Proposal Impact Non-GHG Emissions and Their
Associated Effects?
A. Emissions Inventory Impacts
(1) Upstream Impacts of the Program
Increasing efficiency in heavy-duty vehicles would result in
reduced fuel demand and therefore reductions in the emissions
associated with all processes involved in getting petroleum to the
pump. These projected upstream emission impacts on criteria pollutants
are summarized in Table VII-1. Table VII-2 shows the corresponding
projected impacts on upstream air toxic emissions in 2030.
[[Page 74290]]
[GRAPHIC] [TIFF OMITTED] TP30NO10.055
To project these impacts, EPA estimated the impact of reduced
petroleum volumes on the extraction and transportation of crude oil as
well as the production and distribution of finished gasoline and
diesel. For the purpose of assessing domestic-only emission reductions
it was necessary to estimate the fraction of fuel savings attributable
to domestic finished gasoline and diesel, and of this fuel what
fraction is produced from domestic crude. For this analysis EPA
estimated that 50 percent of fuel savings is attributable to domestic
finished gasoline and diesel and that 90 percent of this gasoline and
diesel originated from imported crude. Emission factors for most
upstream emission sources are based on the GREET1.8 model, developed by
DOE's Argonne National Laboratory but in some cases the GREET values
were modified or updated by EPA to be consistent with the National
Emission Inventory. These updates are consistent with those used for
the upstream analysis included in the Light-Duty GHG rulemaking. More
information on the development of the emission factors used in this
analysis can be found in draft RIA Chapter 5.
(2) Downstream Impacts of the Program
While these proposed rules do not regulate non-GHG pollutants, EPA
expects reductions in downstream emissions of most non-GHG pollutants.
These pollutants include NOX, SO2, CO, and HC.
The primary reason for this is the improvements in road load
(aerodynamics and tire rolling resistance) under the proposal. Another
reason is that emissions from certain pollutants (e.g., SO2)
are proportional to fuel consumption. For vehicle types not affected by
road load improvements, non-GHG emissions may increase very slightly
due to VMT rebound. EPA also anticipates the use of APUs in combination
tractors for GHG reduction purposes during extended idling. These units
exhibit different non-GHG emissions characteristics compared to the on-
road engines they would replace during extended idling. EPA used MOVES
to determine non-GHG emissions inventories for baseline and control
cases. Further information about the MOVES analysis is available in
Section VI and RIA Chapter 5. The improvements in road load, use of
APUs, and VMT rebound were included in the MOVES runs and post-
processing. Table VII-3 summarizes the downstream criteria pollutant
impacts of this proposal. Most of the impacts shown are through
projected increased APU use. Because APUs are required to meet much
less stringent PM2.5 standards than on-road engines, the
projected widespread use of APUs leads to higher PM2.5.
Table VII-4 summarizes the downstream air toxics impacts of this
proposal.
[[Page 74291]]
[GRAPHIC] [TIFF OMITTED] TP30NO10.056
(3) Total Impacts of the Program
As shown in Table VII-5 and Table VII-6, the agencies estimate that
this program would result in reductions of NOX, VOC, CO,
SOX, and air toxics. For NOX, VOC, and CO, much
of the net reductions are realized through the use of APUs, which emit
these pollutants at a lower rate than on-road engines during extended
idle operation. Additional reductions are achieved in all pollutants
through reduced road load (improved aerodynamics and tire rolling
resistance), which reduces the amount of work required to travel a
given distance. For SOX, downstream emissions are roughly
proportional to fuel consumption; therefore a decrease is seen in both
upstream and downstream sources. The downstream increase in
PM2.5 due to APU use is mostly negated by upstream
PM2.5 reductions, though our calculations show a slight net
increase in 2030 and 2050.\242\
---------------------------------------------------------------------------
\242\ Although the net impact is small when aggregated to the
national level, it is unlikely that the geographic location of
increases in downstream PM2.5 emissions will coincide
with the location of decreases in upstream PM2.5
emissions. Impacts of the emissions changes will be included in the
air quality modeling that will be completed for the final
rulemaking.
[GRAPHIC] [TIFF OMITTED] TP30NO10.057
[[Page 74292]]
B. Health Effects of Non-GHG Pollutants
In this section we discuss health effects associated with exposure
to some of the criteria and air toxic pollutants impacted by the
proposed heavy-duty vehicle standards.
(1) Particulate Matter
(a) Background
Particulate matter is a generic term for a broad class of
chemically and physically diverse substances. It can be principally
characterized as discrete particles that exist in the condensed (liquid
or solid) phase spanning several orders of magnitude in size. Since
1987, EPA has delineated that subset of inhalable particles small
enough to penetrate to the thoracic region (including the
tracheobronchial and alveolar regions) of the respiratory tract
(referred to as thoracic particles). Current National Ambient Air
Quality Standards (NAAQS) use PM2.5 as the indicator for
fine particles (with PM2.5 referring to particles with a
nominal mean aerodynamic diameter less than or equal to 2.5 [mu]m), and
use PM10 as the indicator for purposes of regulating the
coarse fraction of PM10 (referred to as thoracic coarse
particles or coarse-fraction particles; generally including particles
with a nominal mean aerodynamic diameter greater than 2.5 [mu]m and
less than or equal to 10 [mu]m, or PM10-2.5). Ultrafine
particles are a subset of fine particles, generally less than 100
nanometers (0.1 [mu]m) in aerodynamic diameter.
Fine particles are produced primarily by combustion processes and
by transformations of gaseous emissions (e.g., SOX,
NOX, and VOC) in the atmosphere. The chemical and physical
properties of PM2.5 may vary greatly with time, region,
meteorology, and source category. Thus, PM2.5 may include a
complex mixture of different pollutants including sulfates, nitrates,
organic compounds, elemental carbon and metal compounds. These
particles can remain in the atmosphere for days to weeks and travel
hundreds to thousands of kilometers.
(b) Health Effects of PM
Scientific studies show ambient PM is associated with a series of
adverse health effects. These health effects are discussed in detail in
EPA's Integrated Science Assessment for Particulate Matter (ISA).\243\
Further discussion of health effects associated with PM can also be
found in the draft RIA for this proposal. The ISA summarizes evidence
associated with PM2.5, PM10-2.5, and ultrafine
particles.
---------------------------------------------------------------------------
\243\ U.S. EPA (2009) Integrated Science Assessment for
Particulate Matter (Final Report). U.S. Environmental Protection
Agency, Washington, DC, EPA/600/R-08/139F, Docket EPA-HQ-OAR-2010-
0162.
---------------------------------------------------------------------------
The ISA concludes that health effects associated with short-term
exposures (hours to days) to ambient PM2.5 include
mortality, cardiovascular effects, such as altered vasomotor function
and hospital admissions and emergency department visits for ischemic
heart disease and congestive heart failure, and respiratory effects,
such as exacerbation of asthma symptoms in children and hospital
admissions and emergency department visits for chronic obstructive
pulmonary disease and respiratory infections.\244\ The ISA notes that
long-term exposure to PM2.5 (months to years) is associated
with the development/progression of cardiovascular disease, premature
mortality, and respiratory effects, including reduced lung function
growth, increased respiratory symptoms, and asthma development.\245\
The ISA concludes that the currently available scientific evidence from
epidemiologic, controlled human exposure, and toxicological studies
supports a causal association between short- and long-term exposures to
PM2.5 and cardiovascular effects and mortality. Furthermore,
the ISA concludes that the collective evidence supports likely causal
associations between short- and long-term PM2.5 exposures and
respiratory effects. The ISA also concludes that the scientific
evidence is suggestive of a causal association for reproductive and
developmental effects and cancer, mutagenicity, and genotoxicity and
long-term exposure to PM2.5.\246\
---------------------------------------------------------------------------
\244\ See U.S. EPA, 2009 Final PM ISA, Note 243, at Section
2.3.1.1.
\245\ See U.S. EPA 2009 Final PM ISA, Note 243, at page 2-12,
Sections 7.3.1.1 and 7.3.2.1.
\246\ See U.S. EPA 2009 Final PM ISA, Note 243, at Section
2.3.2.
---------------------------------------------------------------------------
For PM10-2.5, the ISA concludes that the current
evidence is suggestive of a causal relationship between short-term
exposures and cardiovascular effects, such as hospitalization for
ischemic heart disease. There is also suggestive evidence of a causal
relationship between short-term PM10-2.5 exposure and
mortality and respiratory effects. Data are inadequate to draw
conclusions regarding the health effects associated with long-term
exposure to PM10-2.5.\247\
---------------------------------------------------------------------------
\247\ See U.S. EPA 2009 Final PM ISA, Note 243, at Section
2.3.4, Table 2-6.
---------------------------------------------------------------------------
For ultrafine particles, the ISA concludes that there is suggestive
evidence of a causal relationship between short-term exposures and
cardiovascular effects, such as changes in heart rhythm and blood
vessel function. It also concludes that there is suggestive evidence of
association between short-term exposure to ultrafine particles and
respiratory effects. Data are inadequate to draw conclusions regarding
the health effects associated with long-term exposure to ultrafine
particles.\248\
---------------------------------------------------------------------------
\248\ See U.S. EPA 2009 Final PM ISA, Note 243, at Section
2.3.5, Table 2-6.
---------------------------------------------------------------------------
(2) Ozone
(a) Background
Ground-level ozone pollution is typically formed by the reaction of
VOC and NOX in the lower atmosphere in the presence of
sunlight. These pollutants, often referred to as ozone precursors, are
emitted by many types of pollution sources, such as highway and nonroad
motor vehicles and engines, power plants, chemical plants, refineries,
makers of consumer and commercial products, industrial facilities, and
smaller area sources.
The science of ozone formation, transport, and accumulation is
complex. Ground-level ozone is produced and destroyed in a cyclical set
of chemical reactions, many of which are sensitive to temperature and
sunlight. When ambient temperatures and sunlight levels remain high for
several days and the air is relatively stagnant, ozone and its
precursors can build up and result in more ozone than typically occurs
on a single high-temperature day. Ozone can be transported hundreds of
miles downwind from precursor emissions, resulting in elevated ozone
levels even in areas with low local VOC or NOX emissions.
(b) Health Effects of Ozone
The health and welfare effects of ozone are well documented and are
assessed in EPA's 2006 Air Quality Criteria Document and 2007 Staff
Paper.249 250 People who are more susceptible to effects
associated with exposure to ozone can include children, the elderly,
and individuals with respiratory disease such as asthma. Those with
greater exposures to ozone, for instance due to time spent outdoors
(e.g., children and outdoor workers), are of particular concern. Ozone
can irritate the respiratory system, causing coughing, throat
irritation, and breathing discomfort. Ozone can reduce
[[Page 74293]]
lung function and cause pulmonary inflammation in healthy individuals.
Ozone can also aggravate asthma, leading to more asthma attacks that
require medical attention and/or the use of additional medication.
Thus, ambient ozone may cause both healthy and asthmatic individuals to
limit their outdoor activities. In addition, there is suggestive
evidence of a contribution of ozone to cardiovascular-related morbidity
and highly suggestive evidence that short-term ozone exposure directly
or indirectly contributes to non-accidental and cardiopulmonary-related
mortality, but additional research is needed to clarify the underlying
mechanisms causing these effects. In a recent report on the estimation
of ozone-related premature mortality published by NRC, a panel of
experts and reviewers concluded that short-term exposure to ambient
ozone is likely to contribute to premature deaths and that ozone-
related mortality should be included in estimates of the health
benefits of reducing ozone exposure.\251\ Animal toxicological evidence
indicates that with repeated exposure, ozone can inflame and damage the
lining of the lungs, which may lead to permanent changes in lung tissue
and irreversible reductions in lung function. The respiratory effects
observed in controlled human exposure studies and animal studies are
coherent with the evidence from epidemiologic studies supporting a
causal relationship between acute ambient ozone exposures and increased
respiratory-related emergency room visits and hospitalizations in the
warm season. In addition, there is suggestive evidence of a
contribution of ozone to cardiovascular-related morbidity and non-
accidental and cardiopulmonary mortality.
---------------------------------------------------------------------------
\249\ U.S. EPA. (2006). Air Quality Criteria for Ozone and
Related Photochemical Oxidants (Final). EPA/600/R-05/004aF-cF.
Washington, DC: U.S. EPA. Docket EPA-HQ-OAR-2010-0162.
\250\ U.S. EPA. (2007). Review of the National Ambient Air
Quality Standards for Ozone: Policy Assessment of Scientific and
Technical Information, OAQPS Staff Paper. EPA-452/R-07-003.
Washington, DC, U.S. EPA. Docket EPA-HQ-OAR-2010-0162.
\251\ National Research Council (NRC), 2008. Estimating
Mortality Risk Reduction and Economic Benefits from Controlling
Ozone Air Pollution. The National Academies Press: Washington, DC
Docket EPA-HQ-OAR-2010-0162
---------------------------------------------------------------------------
(3) Nitrogen Oxides and Sulfur Oxides
(a) Background
Nitrogen dioxide (NO2) is a member of the NOX
family of gases. Most NO2 is formed in the air through the
oxidation of nitric oxide (NO) emitted when fuel is burned at a high
temperature. SO2, a member of the sulfur oxide
(SOX) family of gases, is formed from burning fuels
containing sulfur (e.g., coal or oil derived), extracting gasoline from
oil, or extracting metals from ore.
SO2 and NO2 can dissolve in water droplets
and further oxidize to form sulfuric and nitric acid which react with
ammonia to form sulfates and nitrates, both of which are important
components of ambient PM. The health effects of ambient PM are
discussed in Section VII. B. (1) (b) of this preamble. NOX
and NMHC are the two major precursors of ozone. The health effects of
ozone are covered in Section VII. B. (2)(b).
(b) Health Effects of NO2
Information on the health effects of NO2 can be found in
the EPA Integrated Science Assessment (ISA) for Nitrogen Oxides.\252\
The EPA has concluded that the findings of epidemiologic, controlled
human exposure, and animal toxicological studies provide evidence that
is sufficient to infer a likely causal relationship between respiratory
effects and short-term NO2 exposure. The ISA concludes that
the strongest evidence for such a relationship comes from epidemiologic
studies of respiratory effects including symptoms, emergency department
visits, and hospital admissions. The ISA also draws two broad
conclusions regarding airway responsiveness following NO2
exposure. First, the ISA concludes that NO2 exposure may
enhance the sensitivity to allergen-induced decrements in lung function
and increase the allergen-induced airway inflammatory response
following 30-minute exposures of asthmatics to NO2
concentrations as low as 0.26 ppm. In addition, small but significant
increases in non-specific airway hyperresponsiveness were reported
following 1-hour exposures of asthmatics to 0.1 ppm NO2.
Second, exposure to NO2 has been found to enhance the
inherent responsiveness of the airway to subsequent nonspecific
challenges in controlled human exposure studies of asthmatic subjects.
Enhanced airway responsiveness could have important clinical
implications for asthmatics since transient increases in airway
responsiveness following NO2 exposure have the potential to
increase symptoms and worsen asthma control. Together, the
epidemiologic and experimental data sets form a plausible, consistent,
and coherent description of a relationship between NO2
exposures and an array of adverse health effects that range from the
onset of respiratory symptoms to hospital admission.
---------------------------------------------------------------------------
\252\ U.S. EPA (2008). Integrated Science Assessment for Oxides
of Nitrogen--Health Criteria (Final Report). EPA/600/R-08/071.
Washington, DC: U.S.EPA. Docket EPA-HQ-OAR-2010-0162 .
---------------------------------------------------------------------------
Although the weight of evidence supporting a causal relationship is
somewhat less certain than that associated with respiratory morbidity,
NO2 has also been linked to other health endpoints. These
include all-cause (nonaccidental) mortality, hospital admissions or
emergency department visits for cardiovascular disease, and decrements
in lung function growth associated with chronic exposure.
(c) Health Effects of SO2
Information on the health effects of SO2 can be found in
the EPA Integrated Science Assessment for Sulfur Oxides.\253\
SO2 has long been known to cause adverse respiratory health
effects, particularly among individuals with asthma. Other potentially
sensitive groups include children and the elderly. During periods of
elevated ventilation, asthmatics may experience symptomatic
bronchoconstriction within minutes of exposure. Following an extensive
evaluation of health evidence from epidemiologic and laboratory
studies, the EPA has concluded that there is a causal relationship
between respiratory health effects and short-term exposure to
SO2. Separately, based on an evaluation of the epidemiologic
evidence of associations between short-term exposure to SO2
and mortality, the EPA has concluded that the overall evidence is
suggestive of a causal relationship between short-term exposure to
SO2 and mortality.
---------------------------------------------------------------------------
\253\ U.S. EPA. (2008). Integrated Science Assessment (ISA) for
Sulfur Oxides--Health Criteria (Final Report). EPA/600/R-08/047F.
Washington, DC: U.S. Environmental Protection Agency. Docket EPA-HQ-
OAR-2010-0162.
---------------------------------------------------------------------------
(4) Carbon Monoxide
Information on the health effects of CO can be found in the EPA
Integrated Science Assessment (ISA) for Carbon Monoxide.\254\ The ISA
concludes that ambient concentrations of CO are associated with a
number of adverse health effects.\255\ This section provides a summary
of the health effects associated with exposure to ambient
concentrations of CO.\256\
---------------------------------------------------------------------------
\254\ U.S. EPA, 2010. Integrated Science Assessment for Carbon
Monoxide (Final Report). U.S. Environmental Protection Agency,
Washington, DC, EPA/600/R-09/019F, 2010. Available at http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=218686. Docket EPA-HQ-
OAR-2010-0162.
\255\ The ISA evaluates the health evidence associated with
different health effects, assigning one of five ``weight of
evidence'' determinations: causal relationship, likely to be a
causal relationship, suggestive of a causal relationship, inadequate
to infer a causal relationship, and not likely to be a causal
relationship. For definitions of these levels of evidence, please
refer to Section 1.6 of the ISA.
\256\ Personal exposure includes contributions from many
sources, and in many different environments. Total personal exposure
to CO includes both ambient and nonambient components; and both
components may contribute to adverse health effects.
---------------------------------------------------------------------------
[[Page 74294]]
Human clinical studies of subjects with coronary artery disease
show a decrease in the time to onset of exercise-induced angina (chest
pain) and electrocardiogram changes following CO exposure. In addition,
epidemiologic studies show associations between short-term CO exposure
and cardiovascular morbidity, particularly increased emergency room
visits and hospital admissions for coronary heart disease (including
ischemic heart disease, myocardial infarction, and angina). Some
epidemiologic evidence is also available for increased hospital
admissions and emergency room visits for congestive heart failure and
cardiovascular disease as a whole. The ISA concludes that a causal
relationship is likely to exist between short-term exposures to CO and
cardiovascular morbidity. It also concludes that available data are
inadequate to conclude that a causal relationship exists between long-
term exposures to CO and cardiovascular morbidity.
Animal studies show various neurological effects with in-utero CO
exposure. Controlled human exposure studies report inconsistent neural
and behavioral effects following low-level CO exposures. The ISA
concludes the evidence is suggestive of a causal relationship with both
short- and long-term exposure to CO and central nervous system effects.
A number of epidemiologic and animal toxicological studies cited in
the ISA have evaluated associations between CO exposure and birth
outcomes such as preterm birth or cardiac birth defects. The
epidemiologic studies provide limited evidence of a CO-induced effect
on preterm births and birth defects, with weak evidence for a decrease
in birth weight. Animal toxicological studies have found associations
between perinatal CO exposure and decrements in birth weight, as well
as other developmental outcomes. The ISA concludes these studies are
suggestive of a causal relationship between long-term exposures to CO
and developmental effects and birth outcomes.
Epidemiologic studies provide evidence of effects on respiratory
morbidity such as changes in pulmonary function, respiratory symptoms,
and hospital admissions associated with ambient CO concentrations. A
limited number of epidemiologic studies considered copollutants such as
ozone, SO2, and PM in two-pollutant models and found that CO
risk estimates were generally robust, although this limited evidence
makes it difficult to disentangle effects attributed to CO itself from
those of the larger complex air pollution mixture. Controlled human
exposure studies have not extensively evaluated the effect of CO on
respiratory morbidity. Animal studies at levels of 50-100 ppm CO show
preliminary evidence of altered pulmonary vascular remodeling and
oxidative injury. The ISA concludes that the evidence is suggestive of
a causal relationship between short-term CO exposure and respiratory
morbidity, and inadequate to conclude that a causal relationship exists
between long-term exposure and respiratory morbidity.
Finally, the ISA concludes that the epidemiologic evidence is
suggestive of a causal relationship between short-term exposures to CO
and mortality. Epidemiologic studies provide evidence of an association
between short-term exposure to CO and mortality, but limited evidence
is available to evaluate cause-specific mortality outcomes associated
with CO exposure. In addition, the attenuation of CO risk estimates
which was often observed in copollutant models contributes to the
uncertainty as to whether CO is acting alone or as an indicator for
other combustion-related pollutants. The ISA also concludes that there
is not likely to be a causal relationship between relevant long-term
exposures to CO and mortality.
(5) Air Toxics
Heavy-duty vehicle emissions contribute to ambient levels of air
toxics known or suspected as human or animal carcinogens, or that have
noncancer health effects. The population experiences an elevated risk
of cancer and other noncancer health effects from exposure to the class
of pollutants known collectively as ``air toxics.'' \257\ These
compounds include, but are not limited to, benzene, 1,3-butadiene,
formaldehyde, acetaldehyde, acrolein, diesel particulate matter and
exhaust organic gases, polycyclic organic matter, and naphthalene.
These compounds were identified as national or regional risk drivers in
past National-scale Air Toxics Assessments and have significant
inventory contributions from mobile sources.\258\
---------------------------------------------------------------------------
\257\ U.S. EPA. 2002 National-Scale Air Toxics Assessment.
http://www.epa.gov/ttn/atw/nata12002/risksum.html. Docket EPA-HQ-
OAR-2010-0162.
\258\ U.S. EPA 2009. National-Scale Air Toxics Assessment for
2002. http://www.epa.gov/ttn/atw/nata2002/. Docket EPA-HQ-OAR-2010-
0162.
---------------------------------------------------------------------------
(a) Diesel Exhaust
Heavy-duty diesel engines emit diesel exhaust, a complex mixture
composed of carbon dioxide, oxygen, nitrogen, water vapor, carbon
monoxide, nitrogen compounds, sulfur compounds and numerous low-
molecular-weight hydrocarbons. A number of these gaseous hydrocarbon
components are individually known to be toxic, including aldehydes,
benzene and 1,3-butadiene. The diesel particulate matter present in
diesel exhaust consists of fine particles (< 2.5 [mu]m), including a
subgroup with a large number of ultrafine particles (< 0.1 [mu]m).
These particles have a large surface area which makes them an excellent
medium for adsorbing organics and their small size makes them highly
respirable. Many of the organic compounds present in the gases and on
the particles, such as polycyclic organic matter, are individually
known to have mutagenic and carcinogenic properties.
Diesel exhaust varies significantly in chemical composition and
particle sizes between different engine types (heavy-duty, light-duty),
engine operating conditions (idle, accelerate, decelerate), and fuel
formulations (high/low sulfur fuel). Also, there are emissions
differences between on-road and nonroad engines because the nonroad
engines are generally of older technology. After being emitted in the
engine exhaust, diesel exhaust undergoes dilution as well as chemical
and physical changes in the atmosphere. The lifetime for some of the
compounds present in diesel exhaust ranges from hours to days.\259\
---------------------------------------------------------------------------
\259\ U.S. EPA (2002). Health Assessment Document for Diesel
Engine Exhaust. EPA/600/8-90/057F Office of Research and
Development, Washington DC. Retrieved on March 17, 2009 from http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=29060. Docket EPA-HQ-
OAR-2010-0162.
---------------------------------------------------------------------------
(i) Diesel Exhaust: Potential Cancer Effects
In EPA's 2002 Diesel Health Assessment Document (Diesel HAD),\260\
exposure to diesel exhaust was classified as likely to be carcinogenic
to humans by inhalation from environmental exposures, in accordance
with the revised draft 1996/1999 EPA cancer guidelines. A number of
other agencies (National Institute for Occupational Safety and Health,
the International Agency for Research on Cancer, the World Health
Organization, California EPA, and the U.S. Department of Health and
Human Services) have made similar classifications. However, EPA also
concluded in the Diesel HAD that it is not possible currently to
calculate a cancer unit risk for diesel exhaust due to a variety of
factors that limit the
[[Page 74295]]
current studies, such as limited quantitative exposure histories in
occupational groups investigated for lung cancer.
---------------------------------------------------------------------------
\260\ See U.S. EPA (2002) Diesel HAD, Note 259, at pp. 1-1, 1-2.
---------------------------------------------------------------------------
For the Diesel HAD, EPA reviewed 22 epidemiologic studies on the
subject of the carcinogenicity of workers exposed to diesel exhaust in
various occupations, finding increased lung cancer risk, although not
always statistically significant, in 8 out of 10 cohort studies and 10
out of 12 case-control studies within several industries. Relative risk
for lung cancer associated with exposure ranged from 1.2 to 1.5,
although a few studies show relative risks as high as 2.6.
Additionally, the Diesel HAD also relied on two independent meta-
analyses, which examined 23 and 30 occupational studies respectively,
which found statistically significant increases in smoking-adjusted
relative lung cancer risk associated with exposure to diesel exhaust of
1.33 to 1.47. These meta-analyses demonstrate the effect of pooling
many studies and in this case show the positive relationship between
diesel exhaust exposure and lung cancer across a variety of diesel
exhaust-exposed occupations.261 262
---------------------------------------------------------------------------
\261\ Bhatia, R., Lopipero, P., Smith, A. (1998). Diesel
exposure and lung cancer. Epidemiology, 9(1), 84-91. Docket EPA-HQ-
OAR-2010-0162.
\262\ Lipsett, M. Campleman, S. (1999). Occupational exposure to
diesel exhaust and lung cancer: a meta-analysis. Am J Public Health,
80(7), 1009-1017. Docket EPA-HQ-OAR-2010-0162.
---------------------------------------------------------------------------
In the absence of a cancer unit risk, the Diesel HAD sought to
provide additional insight into the significance of the diesel exhaust-
cancer hazard by estimating possible ranges of risk that might be
present in the population. An exploratory analysis was used to
characterize a possible risk range by comparing a typical environmental
exposure level for highway diesel sources to a selected range of
occupational exposure levels. The occupationally observed risks were
then proportionally scaled according to the exposure ratios to obtain
an estimate of the possible environmental risk. A number of
calculations are needed to accomplish this, and these can be seen in
the EPA Diesel HAD. The outcome was that environmental risks from
diesel exhaust exposure could range from a low of 10-4 to
10-5 to as high as 10-3, reflecting the range of
occupational exposures that could be associated with the relative and
absolute risk levels observed in the occupational studies. Because of
uncertainties, the analysis acknowledged that the risks could be lower
than 10-4 or 10-5, and a zero risk from diesel
exhaust exposure was not ruled out.
(ii) Diesel Exhaust: Other Health Effects
Noncancer health effects of acute and chronic exposure to diesel
exhaust emissions are also of concern to the EPA. EPA derived a diesel
exhaust reference concentration (RfC) from consideration of four well-
conducted chronic rat inhalation studies showing adverse pulmonary
effects.263 264 265 266 The RfC is 5 [mu]g/m\3\ for diesel
exhaust as measured by diesel particulate matter. This RfC does not
consider allergenic effects such as those associated with asthma or
immunologic effects. There is growing evidence, discussed in the Diesel
HAD, that exposure to diesel exhaust can exacerbate these effects, but
the exposure-response data are presently lacking to derive an RfC. The
EPA Diesel HAD states, ``With [diesel particulate matter] being a
ubiquitous component of ambient PM, there is an uncertainty about the
adequacy of the existing [diesel exhaust] noncancer database to
identify all of the pertinent [diesel exhaust]-caused noncancer health
hazards.'' (p. 9-19). The Diesel HAD concludes ``that acute exposure to
[diesel exhaust] has been associated with irritation of the eye, nose,
and throat, respiratory symptoms (cough and phlegm), and
neurophysiological symptoms such as headache, lightheadedness, nausea,
vomiting, and numbness or tingling of the extremities.'' \267\
---------------------------------------------------------------------------
\263\ Ishinishi, N. Kuwabara, N. Takaki, Y., et al. (1988).
Long-term inhalation experiments on diesel exhaust. In: Diesel
exhaust and health risks. Results of the HERP studies. Ibaraki,
Japan: Research Committee for HERP Studies; pp. 11-84. Docket EPA-
HQ-OAR-2010-0162.
\264\ Heinrich, U., Fuhst, R., Rittinghausen, S., et al. (1995).
Chronic inhalation exposure of Wistar rats and two different strains
of mice to diesel engine exhaust, carbon black, and titanium
dioxide. Inhal Toxicol, 7, 553-556. Docket EPA-HQ-OAR-2010-0162.
\265\ Mauderly, J.L., Jones, R.K., Griffith, W.C., et al.
(1987). Diesel exhaust is a pulmonary carcinogen in rats exposed
chronically by inhalation. Fundam. Appl. Toxicol., 9, 208-221.
Docket EPA-HQ-OAR-2010-0162.
\266\ Nikula, K.J., Snipes, M.B., Barr, E.B., et al. (1995).
Comparative pulmonary toxicities and carcinogenicities of
chronically inhaled diesel exhaust and carbon black in F344 rats.
Fundam. Appl. Toxicol, 25, 80-94. Docket EPA-HQ-OAR-2010-0162.
\267\ See U.S. EPA (2002), Diesel HAD at Note 259, at p. 9-9.
---------------------------------------------------------------------------
(iii) Ambient PM2.5 Levels and Exposure to Diesel Exhaust PM
The Diesel HAD also briefly summarizes health effects associated
with ambient PM and discusses the EPA's annual PM2.5 NAAQS
of 15 [mu]g/m\3\. There is a much more extensive body of human data
showing a wide spectrum of adverse health effects associated with
exposure to ambient PM, of which diesel exhaust is an important
component. The PM2.5 NAAQS is designed to provide protection
from the noncancer and premature mortality effects of PM2.5
as a whole.
(iv) Diesel Exhaust PM Exposures
Exposure of people to diesel exhaust depends on their various
activities, the time spent in those activities, the locations where
these activities occur, and the levels of diesel exhaust pollutants in
those locations. The major difference between ambient levels of diesel
particulate and exposure levels for diesel particulate is that exposure
accounts for a person moving from location to location, proximity to
the emission source, and whether the exposure occurs in an enclosed
environment.
Occupational Exposures
Occupational exposures to diesel exhaust from mobile sources can be
several orders of magnitude greater than typical exposures in the non-
occupationally exposed population.
Over the years, diesel particulate exposures have been measured for
a number of occupational groups. A wide range of exposures have been
reported, from 2 [mu]g/m\3\ to 1,280 [mu]g/m\3\, for a variety of
occupations. As discussed in the Diesel HAD, the National Institute of
Occupational Safety and Health has estimated a total of 1,400,000
workers are occupationally exposed to diesel exhaust from on-road and
nonroad vehicles.
Elevated Concentrations and Ambient Exposures in Mobile Source-Impacted
Areas
Regions immediately downwind of highways or truck stops may
experience elevated ambient concentrations of directly-emitted
PM2.5 from diesel engines. Due to the unique nature of
highways and truck stops, emissions from a large number of diesel
engines are concentrated in a small area. Studies near roadways with
high truck traffic indicate higher concentrations of components of
diesel PM than other locations.268 269 270 High ambient
particle
[[Page 74296]]
concentrations have also been reported near trucking terminals, truck
stops, and bus garages.271 272 273 Additional discussion of
exposure and health effects associated with traffic is included below
in Section VII.B.(5)(j).
---------------------------------------------------------------------------
\268\ Zhu, Y.; Hinds, W.C.; Kim, S.; Shen, S.; Sioutas, C.
(2002). Study of ultrafine particles near a major highway with
heavy-duty diesel traffic. Atmospheric Environment 36: 4323-4335.
Docket EPA-HQ-OAR-2010-0162.
\269\ Lena, T.S; Ochieng, V.; Holgu[iacute]n-Veras, J.; Kinney,
P.L. (2002). Elemental carbon and PM2.5 levels in an
urban community heavily impacted by truck traffic. Environ Health
Perspect 110: 1009-1015. Docket EPA-HQ-OAR-2010-0162.
\270\ Soliman, A.S.M.; Jacko, J.B.; Palmer, G.M. (2006).
Development of an empirical model to estimate real-world fine
particulate matter emission factors: the Traffic Air Quality model.
J Air & Waste Manage Assoc 56: 1540-1549. Docket EPA-HQ-OAR-2010-
0162.
\271\ Davis, M.E.; Smith, T.J.; Laden, F.; Hart, J.E.; Ryan,
L.M.; Garshick, E. (2006). Modeling particle exposure in U.S.
trucking terminals. Environ Sci Techol 40: 4226-4232. Docket EPA-HQ-
OAR-2010-0162.
\272\ Miller, T.L.; Fu, J.S.; Hromis, B.; Storey, J.M. (2007).
Diesel truck idling emissions--measurements at a PM2.5 hot spot.
Proceedings of the Annual Conference of the Transportation Research
Board, paper no. 07-2609. Docket EPA-HQ-OAR-2010-0162.
\273\ Ramachandran, G.; Paulsen, D.; Watts, W.; Kittelson, D.
(2005). Mass, surface area, and number metrics in diesel
occupational exposure assessment. J Environ Monit 7: 728-735. Docket
EPA-HQ-OAR-2010-0162.
---------------------------------------------------------------------------
(b) Benzene
The EPA's Integrated Risk Information System (IRIS) database lists
benzene as a known human carcinogen (causing leukemia) by all routes of
exposure, and concludes that exposure is associated with additional
health effects, including genetic changes in both humans and animals
and increased proliferation of bone marrow cells in
mice.274 275 276 EPA states in its IRIS database that data
indicate a causal relationship between benzene exposure and acute
lymphocytic leukemia and suggest a relationship between benzene
exposure and chronic non-lymphocytic leukemia and chronic lymphocytic
leukemia. The International Agency for Research on Carcinogens (IARC)
has determined that benzene is a human carcinogen and the U.S.
Department of Health and Human Services (DHHS) has characterized
benzene as a known human carcinogen.277 278
---------------------------------------------------------------------------
\274\ U.S. EPA. 2000. Integrated Risk Information System File
for Benzene. This material is available electronically at http://www.epagov/iris/subst/0276.htm. Docket EPA-HQ-OAR-2010-0162.
\275\ International Agency for Research on Cancer. 1982.
Monographs on the evaluation of carcinogenic risk of chemicals to
humans, Volume 29. Some industrial chemicals and dyestuffs, World
Health Organization, Lyon, France, p. 345-389. Docket EPA-HQ-OAR-
2010-0162.
\276\ Irons, R.D.; Stillman, W.S.; Colagiovanni, D.B.; Henry,
V.A. 1992. Synergistic action of the benzene metabolite hydroquinone
on myelopoietic stimulating activity of granulocyte/macrophage
colony-stimulating factor in vitro, Proc. Natl. Acad. Sci. 89:3691-
3695. Docket EPA-HQ-OAR-2010-0162.
\277\ See IARC, Note 275, above.
\278\ U.S. Department of Health and Human Services National
Toxicology Program 11th Report on Carcinogens available at: http://ntp.niehs.nih.gov/go/16183. Docket EPA-HQ-OAR-2010-0162.
---------------------------------------------------------------------------
A number of adverse noncancer health effects including blood
disorders, such as preleukemia and aplastic anemia, have also been
associated with long-term exposure to benzene.279 280 The
most sensitive noncancer effect observed in humans, based on current
data, is the depression of the absolute lymphocyte count in
blood.281 282 In addition, recent work, including studies
sponsored by the Health Effects Institute (HEI), provides evidence that
biochemical responses are occurring at lower levels of benzene exposure
than previously known.283 284 285 286 EPA's IRIS program has
not yet evaluated these new data.
---------------------------------------------------------------------------
\279\ Aksoy, M. (1989). Hematotoxicity and carcinogenicity of
benzene. Environ. Health Perspect. 82: 193-197. Docket EPA-HQ-OAR-
2010-0162.
\280\ Goldstein, B.D. (1988). Benzene toxicity. Occupational
medicine. State of the Art Reviews. 3: 541-554. Docket EPA-HQ-OAR-
2010-0162.
\281\ Rothman, N., G.L. Li, M. Dosemeci, W.E. Bechtold, G.E.
Marti, Y.Z. Wang, M. Linet, L.Q. Xi, W. Lu, M.T. Smith, N. Titenko-
Holland, L.P. Zhang, W. Blot, S.N. Yin, and R.B. Hayes (1996).
Hematotoxicity among Chinese workers heavily exposed to benzene. Am.
J. Ind. Med. 29: 236-246. Docket EPA-HQ-OAR-2010-0162.
\282\ U.S. EPA (2002). Toxicological Review of Benzene
(Noncancer Effects). Environmental Protection Agency, Integrated
Risk Information System, Research and Development, National Center
for Environmental Assessment, Washington DC. This material is
available electronically at http://www.epa.gov/iris/ubst/0276.htm.
Docket EPA-HQ-OAR-2010-0162.
\283\ Qu, O.; Shore, R.; Li, G.; Jin, X.; Chen, C.L.; Cohen, B.;
Melikian, A.; Eastmond, D.; Rappaport, S.; Li, H.; Rupa, D.;
Suramaya, R.; Songnian, W.; Huifant, Y.; Meng, M.; Winnik, M.; Kwok,
E.; Li, Y.; Mu, R.; Xu, B.; Zhang, X.; Li, K. (2003). HEI Report
115, Validation & Evaluation of Biomarkers in Workers Exposed to
Benzene in China. Docket EPA-HQ-OAR-2010-0162.
\284\ Qu, Q., R. Shore, G. Li, X. Jin, L.C. Chen, B. Cohen, et
al. (2002). Hematological changes among Chinese workers with a broad
range of benzene exposures. Am. J. Industr. Med. 42: 275-285. Docket
EPA-HQ-OAR-2010-0162.
\285\ Lan, Qing, Zhang, L., Li, G., Vermeulen, R., et al.
(2004). Hematotoxically in Workers Exposed to Low Levels of Benzene.
Science 306: 1774-1776. Docket EPA-HQ-OAR-2010-0162.
\286\ Turtletaub, K.W. and Mani, C. (2003). Benzene metabolism
in rodents at doses relevant to human exposure from Urban Air.
Research Reports Health Effect Inst. Report No.113. Docket EPA-HQ-
OAR-2010-0162.
---------------------------------------------------------------------------
(c) 1,3-Butadiene
EPA has characterized 1,3-butadiene as carcinogenic to humans by
inhalation.287 288 The IARC has determined that 1,3-
butadiene is a human carcinogen and the U.S. DHHS has characterized
1,3-butadiene as a known human carcinogen.289 290 There are
numerous studies consistently demonstrating that 1,3-butadiene is
metabolized into genotoxic metabolites by experimental animals and
humans. The specific mechanisms of 1,3-butadiene-induced carcinogenesis
are unknown; however, the scientific evidence strongly suggests that
the carcinogenic effects are mediated by genotoxic metabolites. Animal
data suggest that females may be more sensitive than males for cancer
effects associated with 1,3-butadiene exposure; there are insufficient
data in humans from which to draw conclusions about sensitive
subpopulations. 1,3-butadiene also causes a variety of reproductive and
developmental effects in mice; no human data on these effects are
available. The most sensitive effect was ovarian atrophy observed in a
lifetime bioassay of female mice.\291\
---------------------------------------------------------------------------
\287\ U.S. EPA (2002). Health Assessment of 1,3-Butadiene.
Office of Research and Development, National Center for
Environmental Assessment, Washington Office, Washington, DC. Report
No. EPA600-P-98-001F. This document is available electronically at
http://www.epa.gov/iris/supdocs/buta-sup.pdf. Docket EPA-HQ-OAR-
2010-0162.
\288\ U.S. EPA (2002). Full IRIS Summary for 1,3-butadiene
(CASRN 106-99-0). Environmental Protection Agency, Integrated Risk
Information System (IRIS), Research and Development, National Center
for Environmental Assessment, Washington, DC http://www.epa.gov/iris/subst/0139.htm. Docket EPA-HQ-OAR-2010-0162.
\289\ International Agency for Research on Cancer (1999).
Monographs on the evaluation of carcinogenic risk of chemicals to
humans, Volume 71, Re-evaluation of some organic chemicals,
hydrazine and hydrogen peroxide and Volume 97 (in preparation),
World Health Organization, Lyon, France. Docket EPA-HQ-OAR-2010-
0162.
\290\ U.S. Department of Health and Human Services (2005).
National Toxicology Program 11th Report on Carcinogens available at:
ntp.niehs.nih.gov/index.cfm?objectid=32BA9724-F1F6-975E-7FCE50709CB4C932. Docket EPA-HQ-OAR-2010-0162.
\291\ Bevan, C.; Stadler, J.C.; Elliot, G.S.; et al. (1996).
Subchronic toxicity of 4-vinylcyclohexene in rats and mice by
inhalation. Fundam. Appl. Toxicol. 32:1-10. Docket EPA-HQ-OAR-2010-
0162.
---------------------------------------------------------------------------
(d) Formaldehyde
Since 1987, EPA has classified formaldehyde as a probable human
carcinogen based on evidence in humans and in rats, mice, hamsters, and
monkeys.\292\ EPA is currently reviewing recently published
epidemiological data. For instance, research conducted by the National
Cancer Institute found an increased risk of nasopharyngeal cancer and
lymphohematopoietic malignancies such as leukemia among workers exposed
to formaldehyde.293 294
[[Page 74297]]
In an analysis of the lymphohematopoietic cancer mortality from an
extended follow-up of these workers, the National Cancer Institute
confirmed an association between lymphohematopoietic cancer risk and
peak exposures.\295\ A recent National Institute of Occupational Safety
and Health study of garment workers also found increased risk of death
due to leukemia among workers exposed to formaldehyde.\296\ Extended
follow-up of a cohort of British chemical workers did not find evidence
of an increase in nasopharyngeal or lymphohematopoietic cancers, but a
continuing statistically significant excess in lung cancers was
reported.\297\ Recently, the IARC re-classified formaldehyde as a human
carcinogen (Group 1).\298\
---------------------------------------------------------------------------
\292\ U.S. EPA (1987). Assessment of Health Risks to Garment
Workers and Certain Home Residents from Exposure to Formaldehyde,
Office of Pesticides and Toxic Substances, April 1987. Docket EPA-
HQ-OAR-2010-0162.
\293\ Hauptmann, M.; Lubin, J. H.; Stewart, P.A.; Hayes, R.B.;
Blair, A. 2003. Mortality from lymphohematopoetic malignancies among
workers in formaldehyde industries. Journal of the National Cancer
Institute 95: 1615-1623. Docket EPA-HQ-OAR-2010-0162.
\294\ Hauptmann, M.; Lubin, J.H.; Stewart, P.A.; Hayes, R.B.;
Blair, A. 2004. Mortality from solid cancers among workers in
formaldehyde industries. American Journal of Epidemiology 159: 1117-
1130. Docket EPA-HQ-OAR-2010-0162.
\295\ Beane Freeman, L.E.; Blair, A.; Lubin, J.H.; Stewart,
P.A.; Hayes, R.B.; Hoover, R.N.; Hauptmann, M. 2009. Mortality from
lymphohematopoietic malignancies among workers in formaldehyde
industries: The National Cancer Institute cohort. J. National Cancer
Inst. 101: 751-761. Docket EPA-HQ-OAR-2010-0162.
\296\ Pinkerton, L.E. 2004. Mortality among a cohort of garment
workers exposed to formaldehyde: an update. Occup. Environ. Med. 61:
193-200. Docket EPA-HQ-OAR-2010-0162.
\297\ Coggon, D, EC Harris, J Poole, KT Palmer. 2003. Extended
follow-up of a cohort of British chemical workers exposed to
formaldehyde. J National Cancer Inst. 95:1608-1615. Docket EPA-HQ-
OAR-2010-0162.
\298\ International Agency for Research on Cancer. 2006.
Formaldehyde, 2-Butoxyethanol and 1-tert-Butoxypropan-2-ol. Volume
88. (in preparation), World Health Organization, Lyon, France.
Docket EPA-HQ-OAR-2010-0162.
---------------------------------------------------------------------------
Formaldehyde exposure also causes a range of noncancer health
effects, including irritation of the eyes (burning and watering of the
eyes), nose and throat. Effects from repeated exposure in humans
include respiratory tract irritation, chronic bronchitis and nasal
epithelial lesions such as metaplasia and loss of cilia. Animal studies
suggest that formaldehyde may also cause airway inflammation--including
eosinophil infiltration into the airways. There are several studies
that suggest that formaldehyde may increase the risk of asthma--
particularly in the young.299 300
---------------------------------------------------------------------------
\299\ Agency for Toxic Substances and Disease Registry (ATSDR).
1999. Toxicological profile for Formaldehyde. Atlanta, GA: U.S.
Department of Health and Human Services, Public Health Service.
http://ww.atsdr.cdc.gov/toxprofiles/tp111.html. Docket EPA-HQ-OAR-
2010-0162.
\300\ WHO (2002). Concise International Chemical Assessment
Document 40: Formaldehyde. Published under the joint sponsorship of
the United Nations Environment Programme, the International Labour
Organization, and the World Health Organization, and produced within
the framework of the Inter-Organization Programme for the Sound
Management of Chemicals. Geneva. Docket EPA-HQ-OAR-2010-0162.
---------------------------------------------------------------------------
(e) Acetaldehyde
Acetaldehyde is classified in EPA's IRIS database as a probable
human carcinogen, based on nasal tumors in rats, and is considered
toxic by the inhalation, oral, and intravenous routes.\301\
Acetaldehyde is reasonably anticipated to be a human carcinogen by the
U.S. DHHS in the 11th Report on Carcinogens and is classified as
possibly carcinogenic to humans (Group 2B) by the
IARC.302 303 EPA is currently conducting a reassessment of
cancer risk from inhalation exposure to acetaldehyde.
---------------------------------------------------------------------------
\301\ U.S. EPA. 1991. Integrated Risk Information System File of
Acetaldehyde. Research and Development, National Center for
Environmental Assessment, Washington, DC. Available at http://www.epa.gov/iris/subst/0290.htm. Docket EPA-HQ-OAR-2010-0162.
\302\ U.S. Department of Health and Human Services National
Toxicology Program 11th Report on Carcinogens available at:
ntp.niehs.nih.gov/index.cfm?objectid=32BA9724-F1F6-975E-7FCE50709CB4C932. Docket EPA-HQ-OAR-2010-0162.
\303\ International Agency for Research on Cancer. 1999. Re-
evaluation of some organic chemicals, hydrazine, and hydrogen
peroxide. IARC Monographs on the Evaluation of Carcinogenic Risk of
Chemical to Humans, Vol 71. Lyon, France. Docket EPA-HQ-OAR-2010-
0162.
---------------------------------------------------------------------------
The primary noncancer effects of exposure to acetaldehyde vapors
include irritation of the eyes, skin, and respiratory tract.\304\ In
short-term (4 week) rat studies, degeneration of olfactory epithelium
was observed at various concentration levels of acetaldehyde
exposure.305 306 Data from these studies were used by EPA to
develop an inhalation reference concentration. Some asthmatics have
been shown to be a sensitive subpopulation to decrements in functional
expiratory volume (FEV1 test) and bronchoconstriction upon acetaldehyde
inhalation.\307\ The agency is currently conducting a reassessment of
the health hazards from inhalation exposure to acetaldehyde.
---------------------------------------------------------------------------
\304\ See Integrated Risk Information System File of
Acetaldehyde, Note 301, above.
\305\ Appleman, L.M., R.A. Woutersen, V.J. Feron, R.N. Hooftman,
and W.R.F. Notten. 1986. Effects of the variable versus fixed
exposure levels on the toxicity of acetaldehyde in rats. J. Appl.
Toxicol. 6: 331-336. Docket EPA-HQ-OAR-2010-0162
\306\ Appleman, L.M., R.A. Woutersen, and V.J. Feron. 1982.
Inhalation toxicity of acetaldehyde in rats. I. Acute and subacute
studies. Toxicology. 23: 293-297. Docket EPA-HQ-OAR-2010-0162.
\307\ Myou, S.; Fujimura, M.; Nishi K.; Ohka, T.; and Matsuda,
T. 1993. Aerosolized acetaldehyde induces histamine-mediated
bronchoconstriction in asthmatics. Am. Rev. Respir.Dis. 148 (4 Pt
1): 940-3. Docket EPA-HQ-OAR-2010-0162.
---------------------------------------------------------------------------
(f) Acrolein
Acrolein is extremely acrid and irritating to humans when inhaled,
with acute exposure resulting in upper respiratory tract irritation,
mucus hypersecretion and congestion. The intense irritancy of this
carbonyl has been demonstrated during controlled tests in human
subjects, who suffer intolerable eye and nasal mucosal sensory
reactions within minutes of exposure.\308\ These data and additional
studies regarding acute effects of human exposure to acrolein are
summarized in EPA's 2003 IRIS Human Health Assessment for
acrolein.\309\ Evidence available from studies in humans indicate that
levels as low as 0.09 ppm (0.21 mg/m\3\) for five minutes may elicit
subjective complaints of eye irritation with increasing concentrations
leading to more extensive eye, nose and respiratory symptoms.\310\
Lesions to the lungs and upper respiratory tract of rats, rabbits, and
hamsters have been observed after subchronic exposure to acrolein.\311\
Acute exposure effects in animal studies report bronchial hyper-
responsiveness.\312\ In a recent study, the acute respiratory irritant
effects of exposure to 1.1 ppm acrolein were more pronounced in mice
with allergic airway disease by comparison to non-diseased mice which
also showed decreases in respiratory rate.\313\ Based on these animal
data and demonstration of similar effects in humans (e.g., reduction in
respiratory rate), individuals with compromised respiratory function
(e.g., emphysema, asthma) are expected to be at increased risk of
developing adverse responses to strong respiratory irritants such as
acrolein.
---------------------------------------------------------------------------
\308\ U.S. EPA (U.S. Environmental Protection Agency). (2003).
Toxicological review of acrolein in support of summary information
on Integrated Risk Information System (IRIS) National Center for
Environmental Assessment, Washington, DC. EPA/635/R-03/003. p. 10.
Available online at: http://www.epa.gov/ncea/ris/toxreviews/0364tr.pdf. Docket EPA-HQ-OAR-2010-0162.
\309\ See U.S. EPA 2003 Toxicological review of acrolein, Note
308, above.
\310\ See U.S. EPA 2003 Toxicological review of acrolein, Note
308, at p. 11.
\311\ Integrated Risk Information System File of Acrolein.
Office of Research and Development, National Center for
Environmental Assessment, Washington, DC. This material is available
at http://www.epa.gov/iris/subst/0364.htm. Docket EPA-HQ-OAR-2010-
0162.
\312\ See U.S. 2003 Toxicological review of acrolein, Note 308,
at p. 15.
\313\ Morris J.B., Symanowicz P.T., Olsen J.E., et al. 2003.
Immediate sensory nerve-mediated respiratory responses to irritants
in healthy and allergic airway-diseased mice. J Appl Physiol
94(4):1563-1571. Docket EPA-HQ-OAR-2010-0162.
---------------------------------------------------------------------------
EPA determined in 2003 that the human carcinogenic potential of
acrolein could not be determined because the available data were
inadequate. No information was available on the carcinogenic effects of
[[Page 74298]]
acrolein in humans and the animal data provided inadequate evidence of
carcinogenicity.\314\ The IARC determined in 1995 that acrolein was not
classifiable as to its carcinogenicity in humans.\315\
---------------------------------------------------------------------------
\314\ U.S. EPA. 2003. Integrated Risk Information System File of
Acrolein. Research and Development, National Center for
Environmental Assessment, Washington, DC. This material is available
at http://www.epa.gov/iris/subst/0364.htm Docket EPA-HQ-OAR-2010-
0162.
\315\ International Agency for Research on Cancer. 1995.
Monographs on the evaluation of carcinogenic risk of chemicals to
humans, Volume 63. Dry cleaning, some chlorinated solvents and other
industrial chemicals, World Health Organization, Lyon, France.
Docket EPA-HQ-OAR-2010-0162.
---------------------------------------------------------------------------
(g) Polycyclic Organic Matter
Polycyclic organic matter is generally defined as a large class of
organic compounds which have multiple benzene rings and a boiling point
greater than 100[deg] Celsius. Many of the compounds included in the
class of compounds known as polycyclic organic matter are classified by
EPA as probable human carcinogens based on animal data. One of these
compounds, naphthalene, is discussed separately below. Polycyclic
aromatic hydrocarbons are a subset of polycyclic organic matter that
contains only hydrogen and carbon atoms. A number of polycyclic
aromatic hydrocarbons are known or suspected carcinogens. Recent
studies have found that maternal exposures to polycyclic aromatic
hydrocarbons (a subclass of polycyclic organic matter) in a population
of pregnant women were associated with several adverse birth outcomes,
including low birth weight and reduced length at birth, as well as
impaired cognitive development at age three.316 317 EPA has
not yet evaluated these recent studies.
---------------------------------------------------------------------------
\316\ Perera, F.P.; Rauh, V.; Tsai, W-Y.; et al. (2002). Effect
of transplacental exposure to environmental pollutants on birth
outcomes in a multiethnic population. Environ Health Perspect. 111:
201-205. Docket EPA-HQ-OAR-2010-0162.
\317\ Perera, F.P.; Rauh, V.; Whyatt, R.M.; Tsai, W.Y.; Tang,
D.; Diaz, D.; Hoepner, L.; Barr, D.; Tu, Y.H.; Camann, D.; Kinney,
P. (2006). Effect of prenatal exposure to airborne polycyclic
aromatic hydrocarbons on neurodevelopment in the first 3 years of
life among inner-city children. Environ Health Perspect 114: 1287-
1292. Docket EPA-HQ-OAR-2010-0162.
---------------------------------------------------------------------------
(h) Naphthalene
Naphthalene is found in small quantities in gasoline and diesel
fuels. Naphthalene emissions have been measured in larger quantities in
both gasoline and diesel exhaust compared with evaporative emissions
from mobile sources, indicating it is primarily a product of
combustion. EPA released an external review draft of a reassessment of
the inhalation carcinogenicity of naphthalene based on a number of
recent animal carcinogenicity studies.\318\ The draft reassessment
completed external peer review.\319\ Based on external peer review
comments received, additional analyses are being undertaken. This
external review draft does not represent official agency opinion and
was released solely for the purposes of external peer review and public
comment. The National Toxicology Program listed naphthalene as
``reasonably anticipated to be a human carcinogen'' in 2004 on the
basis of bioassays reporting clear evidence of carcinogenicity in rats
and some evidence of carcinogenicity in mice.\320\ California EPA has
released a new risk assessment for naphthalene, and the IARC has
reevaluated naphthalene and re-classified it as Group 2B: possibly
carcinogenic to humans.\321\ Naphthalene also causes a number of
chronic non-cancer effects in animals, including abnormal cell changes
and growth in respiratory and nasal tissues.\322\
---------------------------------------------------------------------------
\318\ U. S. EPA. 2004. Toxicological Review of Naphthalene
(Reassessment of the Inhalation Cancer Risk), Environmental
Protection Agency, Integrated Risk Information System, Research and
Development, National Center for Environmental Assessment,
Washington, DC. This material is available electronically at http://www.epa.gov/iris/subst/436.htm. Docket EPA-HQ-OAR-2010-0162.
\319\ Oak Ridge Institute for Science and Education. (2004).
External Peer Review for the IRIS Reassessment of the Inhalation
Carcinogenicity of Naphthalene. August 2004. http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=84403. Docket EPA-HQ-OAR-2010-0162.
\320\ National Toxicology Program (NTP). (2004). 11th Report on
Carcinogens. Public Health Service, U.S. Department of Health and
Human Services, Research Triangle Park, NC. Available from: http://ntp-server.niehs.nih.gov. Docket EPA-HQ-OAR-2010-0162.
\321\ International Agency for Research on Cancer. (2002).
Monographs on the Evaluation of the Carcinogenic Risk of Chemicals
for Humans. Vol. 82. Lyon, France. Docket EPA-HQ-OAR-2010-0162.
\322\ U.S. EPA. 1998. Toxicological Review of Naphthalene,
Environmental Protection Agency, Integrated Risk Information System,
Research and Development, National Center for Environmental
Assessment, Washington, DC. This material is available
electronically at http://www.epa.gov/iris/subst/0436.htm. Docket
EPA-HQ-OAR-2010-0162.
---------------------------------------------------------------------------
(i) Other Air Toxics
In addition to the compounds described above, other compounds in
gaseous hydrocarbon and PM emissions from heavy-duty vehicles will be
affected by this proposal. Mobile source air toxic compounds that would
potentially be impacted include ethylbenzene, propionaldehyde, toluene,
and xylene. Information regarding the health effects of these compounds
can be found in EPA's IRIS database.\323\
---------------------------------------------------------------------------
\323\ U.S. EPA Integrated Risk Information System (IRIS)
database is available at: http://www.epa.gov/iris.
---------------------------------------------------------------------------
(j) Exposure and Health Effects Associated With Traffic
Populations who live, work, or attend school near major roads
experience elevated exposure concentrations to a wide range of air
pollutants, as well as higher risks for a number of adverse health
effects. While the previous sections of this preamble have focused on
the health effects associated with individual criteria pollutants or
air toxics, this section discusses the mixture of different exposures
near major roadways, rather than the effects of any single pollutant.
As such, this section emphasizes traffic-related air pollution, in
general, as the relevant indicator of exposure rather than any
particular pollutant.
Concentrations of many traffic-generated air pollutants are
elevated for up to 300-500 meters downwind of roads with high traffic
volumes.\324\ Numerous sources on roads contribute to elevated roadside
concentrations, including exhaust and evaporative emissions, and
resuspension of road dust and tire and brake wear. Concentrations of
several criteria and hazardous air pollutants are elevated near major
roads. Furthermore, different semi-volatile organic compounds and
chemical components of particulate matter, including elemental carbon,
organic material, and trace metals, have been reported at higher
concentrations near major roads.
---------------------------------------------------------------------------
\324\ Zhou, Y.; Levy, J.I. (2007). Factors influencing the
spatial extent of mobile source air pollution impacts: A meta-
analysis. BMC Public Health 7: 89. doi:10.1186/1471-2458-7-89 Docket
EPA-HQ-OAR-2010-0162.
---------------------------------------------------------------------------
Populations near major roads experience greater risk of certain
adverse health effects. The Health Effects Institute published a report
on the health effects of traffic-related air pollution.\325\ It
concluded that evidence is ``sufficient to infer the presence of a
causal association'' between traffic exposure and exacerbation of
childhood asthma symptoms. The HEI report also concludes that the
evidence is either ``sufficient'' or ``suggestive but not sufficient''
for a causal association between traffic exposure and new childhood
asthma cases. A review of asthma studies by Salam et al. (2008)
[[Page 74299]]
reaches similar conclusions.\326\ The HEI report also concludes that
there is ``suggestive'' evidence for pulmonary function deficits
associated with traffic exposure, but concluded that there is
``inadequate and insufficient'' evidence for causal associations with
respiratory health care utilization, adult-onset asthma, chronic
obstructive pulmonary disease symptoms, and allergy. A review by
Holguin (2008) notes that the effects of traffic on asthma may be
modified by nutrition status, medication use, and genetic factors.\327\
---------------------------------------------------------------------------
\325\ HEI Panel on the Health Effects of Air Pollution. (2010).
Traffic-related air pollution: A critical review of the literature
on emissions, exposure, and health effects. [Online at http://www.healtheffects.org.] Docket EPA-HQ-OAR-2010-0162.
\326\ Salam, M.T.; Islam, T.; Gilliland, F.D. (2008). Recent
evidence for adverse effects of residential proximity to traffic
sources on asthma. Current Opin Pulm Med 14: 3-8. Docket EPA-HQ-OAR-
2010-0162.
\327\ Holguin, F. (2008). Traffic, outdoor air pollution, and
asthma. Immunol Allergy Clinics North Am 28: 577-588. Docket EPA-HQ-
OAR-2010-0162.
---------------------------------------------------------------------------
The HEI report also concludes that evidence is ``suggestive'' of a
causal association between traffic exposure and all-cause and
cardiovascular mortality. There is also evidence of an association
between traffic-related air pollutants and cardiovascular effects such
as changes in heart rhythm, heart attack, and cardiovascular disease.
The HEI report characterizes this evidence as ``suggestive'' of a
causal association, and an independent epidemiological literature
review by Adar and Kaufman (2007) concludes that there is ``consistent
evidence'' linking traffic-related pollution and adverse cardiovascular
health outcomes.\328\
---------------------------------------------------------------------------
\328\ Adar, S.D.; Kaufman, J.D. (2007). Cardiovascular disease
and air pollutants: Evaluating and improving epidemiological data
implicating traffic exposure. Inhal Toxicol 19: 135-149. Docket EPA-
HQ-OAR-2010-0162.
---------------------------------------------------------------------------
Some studies have reported associations between traffic exposure
and other health effects, such as birth outcomes (e.g., low birth
weight) and childhood cancer. The HEI report concludes that there is
currently ``inadequate and insufficient'' evidence for a causal
association between these effects and traffic exposure. A review by
Raaschou-Nielsen and Reynolds (2006) concluded that evidence of an
association between childhood cancer and traffic-related air pollutants
is weak, but noted the inability to draw firm conclusions based on
limited evidence.\329\
---------------------------------------------------------------------------
\329\ Raaschou-Nielsen, O.; Reynolds, P. (2006). Air pollution
and childhood cancer: A review of the epidemiological literature.
Int J Cancer 118: 2920-2929. Docket EPA-HQ-OAR-2010-0162.
---------------------------------------------------------------------------
There is a large population in the United States living in close
proximity of major roads. According to the Census Bureau's American
Housing Survey for 2007, approximately 20 million residences in the
United States, 15.6% of all homes, are located within 300 feet (91 m)
of a highway with 4+ lanes, a railroad, or an airport.\330\ Therefore,
at current population of approximately 309 million, assuming that
population and housing are similarly distributed, there are over 48
million people in the United States living near such sources. The HEI
report also notes that in two North American cities, Los Angeles and
Toronto, over 40% of each city's population live within 500 meters of a
highway or 100 meters of a major road. It also notes that about 33% of
each city's population resides within 50 meters of major roads.
Together, the evidence suggests that a large U.S. population lives in
areas with elevated traffic-related air pollution.
---------------------------------------------------------------------------
\330\ U.S. Census Bureau (2008). American Housing Survey for the
United States in 2007. Series H-150 (National Data), Table 1A-7.
[Accessed at http://www.census.gov/hhes/www/housing/ahs/ahs07/ahs07.html on January 22, 2009] Docket EPA-HQ-OAR-2010-0162.
---------------------------------------------------------------------------
People living near roads are often socioeconomically disadvantaged.
According to the 2007 American Housing Survey, a renter-occupied
property is over twice as likely as an owner-occupied property to be
located near a highway with 4+ lanes, railroad or airport. In the same
survey, the median household income of rental housing occupants was
less than half that of owner-occupants ($28,921/$59,886). Numerous
studies in individual urban areas report higher levels of traffic-
related air pollutants in areas with high minority or poor
populations.331 332 333
---------------------------------------------------------------------------
\331\ Lena, T.S.; Ochieng, V.; Carter, M.; Holgu[iacute]n-Veras,
J.; Kinney, P.L. (2002). Elemental carbon and PM2.5 levels in an
urban community heavily impacted by truck traffic. Environ Health
Perspect 110: 1009-1015. Docket EPA-HQ-OAR-2010-0162.
\332\ Wier, M.; Sciammas, C.; Seto, E.; Bhatia, R.; Rivard, T.
(2009). Health, traffic, and environmental justice: collaborative
research and community action in San Francisco, California. Am J
Public Health 99: S499-S504. Docket EPA-HQ-OAR-2010-0162.
\333\ Forkenbrock, D.J. and L.A. Schweitzer, Environmental
Justice and Transportation Investment Policy. Iowa City: University
of Iowa, 1997. Docket EPA-HQ-OAR-2010-0162.
---------------------------------------------------------------------------
Students may also be exposed in situations where schools are
located near major roads. In a study of nine metropolitan areas across
the United States, Appatova et al. (2008) found that on average greater
than 33% of schools were located within 400 m of an Interstate, U.S.,
or State highway, while 12% were located within 100 m.\334\ The study
also found that among the metropolitan areas studied, schools in the
Eastern United States were more often sited near major roadways than
schools in the Western United States.
---------------------------------------------------------------------------
\334\ Appatova, A.S.; Ryan, P.H.; LeMasters, G.K.; Grinshpun,
S.A. (2008). Proximal exposure of public schools and students to
major roadways: A nationwide U.S. survey. J Environ Plan Mgmt Docket
EPA-HQ-OAR-2010-0162.
---------------------------------------------------------------------------
Demographic studies of students in schools near major roadways
suggest that this population is more likely than the general student
population to be of non-white race or Hispanic ethnicity, and more
often live in low socioeconomic status locations.335 336 337
There is some inconsistency in the evidence, which may be due to
different local development patterns and measures of traffic and
geographic scale used in the studies.\334\
---------------------------------------------------------------------------
\335\ Green, R.S.; Smorodinsky, S.; Kim, J.J.; McLaughlin, R.;
Ostro, B. (2004). Proximity of California public schools to busy
roads. Environ Health Perspect 112: 61-66. Docket EPA-HQ-OAR-2010-
0162.
\336\ Houston, D.; Ong, P.; Wu, J.; Winer, A. (2006). Proximity
of licensed child care facilities to near-roadway vehicle pollution.
Am J Public Health 96: 1611-1617. Docket EPA-HQ-OAR-2010-0162.
\337\ Wu, Y.; Batterman, S. (2006). Proximity of schools in
Detroit, Michigan to automobile and truck traffic. J Exposure Sci
Environ Epidemiol 16: 457-470. Docket EPA-HQ-OAR-2010-0162.
---------------------------------------------------------------------------
C. Environmental Effects of Non-GHG Pollutants
In this section we discuss some of the environmental effects of PM
and its precursors such as visibility impairment, atmospheric
deposition, and materials damage and soiling, as well as environmental
effects associated with the presence of ozone in the ambient air, such
as impacts on plants, including trees, agronomic crops and urban
ornamentals, and environmental effects associated with air toxics.
(1) Visibility
Visibility can be defined as the degree to which the atmosphere is
transparent to visible light.\338\ Visibility impairment is caused by
light scattering and absorption by suspended particles and gases.
Visibility is important because it has direct significance to people's
enjoyment of daily activities in all parts of the country. Individuals
value good visibility for the well-being it provides them directly,
where they live and work, and in places where they enjoy recreational
opportunities. Visibility is also highly valued in significant natural
areas, such as national parks and wilderness areas, and special
emphasis is given to protecting visibility in these
[[Page 74300]]
areas. For more information on visibility see the final 2009 PM
ISA.\339\
---------------------------------------------------------------------------
\338\ National Research Council, 1993. Protecting Visibility in
National Parks and Wilderness Areas. National Academy of Sciences
Committee on Haze in National Parks and Wilderness Areas. National
Academy Press, Washington, DC. Docket EPA-HQ-OAR-2010-0162. This
book can be viewed on the National Academy Press Web site at http://www.nap.edu/books/0309048443/html/.
\339\ See U.S. EPA 2009. Final PM ISA, Note 243.
---------------------------------------------------------------------------
EPA is pursuing a two-part strategy to address visibility. First,
EPA has concluded that PM2.5 causes adverse effects on visibility in
various locations, depending on PM concentrations and factors such as
chemical composition and average relative humidity, and has set
secondary PM2.5 standards.\340\ The secondary PM2.5
standards act in conjunction with the regional haze program. EPA's
regional haze rule (64 FR 35714) was put in place in July 1999 to
protect the visibility in Mandatory Class I Federal areas. There are
156 national parks, forests and wilderness areas categorized as
Mandatory Class I Federal areas (62 FR 38680-38681, July 18,
1997).\341\ Visibility can be said to be impaired in both PM2.5
nonattainment areas and Mandatory Class I Federal areas.
---------------------------------------------------------------------------
\340\ The existing annual primary and secondary PM2.5
standards have been remanded and are being addressed in the
currently ongoing PM NAAQS review.
\341\ These areas are defined in CAA section 162 as those
national parks exceeding 6,000 acres, wilderness areas and memorial
parks exceeding 5,000 acres, and all international parks which were
in existence on August 7, 1977.
---------------------------------------------------------------------------
(2) Plant and Ecosystem Effects of Ozone
Elevated ozone levels contribute to environmental effects, with
impacts to plants and ecosystems being of most concern. Ozone can
produce both acute and chronic injury in sensitive species depending on
the concentration level and the duration of the exposure. Ozone effects
also tend to accumulate over the growing season of the plant, so that
even low concentrations experienced for a longer duration have the
potential to create chronic stress on vegetation. Ozone damage to
plants includes visible injury to leaves and impaired photosynthesis,
both of which can lead to reduced plant growth and reproduction,
resulting in reduced crop yields, forestry production, and use of
sensitive ornamentals in landscaping. In addition, the impairment of
photosynthesis, the process by which the plant makes carbohydrates (its
source of energy and food), can lead to a subsequent reduction in root
growth and carbohydrate storage below ground, resulting in other, more
subtle plant and ecosystems impacts.
These latter impacts include increased susceptibility of plants to
insect attack, disease, harsh weather, interspecies competition and
overall decreased plant vigor. The adverse effects of ozone on forest
and other natural vegetation can potentially lead to species shifts and
loss from the affected ecosystems, resulting in a loss or reduction in
associated ecosystem goods and services. Lastly, visible ozone injury
to leaves can result in a loss of aesthetic value in areas of special
scenic significance like national parks and wilderness areas. The final
2006 Ozone Air Quality Criteria Document presents more detailed
information on ozone effects on vegetation and ecosystems.
(3) Atmospheric Deposition
Wet and dry deposition of ambient particulate matter delivers a
complex mixture of metals (e.g., mercury, zinc, lead, nickel, aluminum,
cadmium), organic compounds (e.g., polycyclic organic matter, dioxins,
furans) and inorganic compounds (e.g., nitrate, sulfate) to terrestrial
and aquatic ecosystems. The chemical form of the compounds deposited
depends on a variety of factors including ambient conditions (e.g.,
temperature, humidity, oxidant levels) and the sources of the material.
Chemical and physical transformations of the compounds occur in the
atmosphere as well as the media onto which they deposit. These
transformations in turn influence the fate, bioavailability and
potential toxicity of these compounds. Atmospheric deposition has been
identified as a key component of the environmental and human health
hazard posed by several pollutants including mercury, dioxin and
PCBs.\342\
---------------------------------------------------------------------------
\342\ U.S. EPA (2000). Deposition of Air Pollutants to the Great
Waters: Third Report to Congress. Office of Air Quality Planning and
Standards. EPA-453/R-00-0005. Docket EPA-HQ-OAR-2010-0162.
---------------------------------------------------------------------------
Adverse impacts on water quality can occur when atmospheric
contaminants deposit to the water surface or when material deposited on
the land enters a waterbody through runoff. Potential impacts of
atmospheric deposition to waterbodies include those related to both
nutrient and toxic inputs. Adverse effects to human health and welfare
can occur from the addition of excess nitrogen via atmospheric
deposition. The nitrogen-nutrient enrichment contributes to toxic algae
blooms and zones of depleted oxygen, which can lead to fish kills,
frequently in coastal waters. Deposition of heavy metals or other
toxics may lead to the human ingestion of contaminated fish, impairment
of drinking water, damage to the marine ecology, and limits to
recreational uses. Several studies have been conducted in U.S. coastal
waters and in the Great Lakes Region in which the role of ambient PM
deposition and runoff is investigated.343 344 345 346 347
---------------------------------------------------------------------------
\343\ U.S. EPA (2004). National Coastal Condition Report II.
Office of Research and Development/Office of Water. EPA-620/R-03/
002. Docket EPA-HQ-OAR-2010-0162.
\344\ Gao, Y., E.D. Nelson, M.P. Field, et al. 2002.
Characterization of atmospheric trace elements on PM2.5 particulate
matter over the New York-New Jersey harbor estuary. Atmos. Environ.
36: 1077-1086. Docket EPA-HQ-OAR-2010-0162.
\345\ Kim, G., N. Hussain, J.R. Scudlark, and T.M. Church. 2000.
Factors influencing the atmospheric depositional fluxes of stable
Pb, 210Pb, and 7Be into Chesapeake Bay. J. Atmos. Chem. 36: 65-79.
Docket EPA-HQ-OAR-2010-0162.
\346\ Lu, R., R.P. Turco, K. Stolzenbach, et al. 2003. Dry
deposition of airborne trace metals on the Los Angeles Basin and
adjacent coastal waters. J. Geophys. Res. 108(D2, 4074): AAC 11-1 to
11-24. Docket EPA-HQ-OAR-2010-0162.
\347\ Marvin, C.H., M.N. Charlton, E.J. Reiner, et al. 2002.
Surficial sediment contamination in Lakes Erie and Ontario: A
comparative analysis. J. Great Lakes Res. 28(3): 437-450. Docket
EPA-HQ-OAR-2010-0162.
---------------------------------------------------------------------------
Atmospheric deposition of nitrogen and sulfur contributes to
acidification, altering biogeochemistry and affecting animal and plant
life in terrestrial and aquatic ecosystems across the United States.
The sensitivity of terrestrial and aquatic ecosystems to acidification
from nitrogen and sulfur deposition is predominantly governed by
geology. Prolonged exposure to excess nitrogen and sulfur deposition in
sensitive areas acidifies lakes, rivers and soils. Increased acidity in
surface waters creates inhospitable conditions for biota and affects
the abundance and nutritional value of preferred prey species,
threatening biodiversity and ecosystem function. Over time, acidifying
deposition also removes essential nutrients from forest soils,
depleting the capacity of soils to neutralize future acid loadings and
negatively affecting forest sustainability. Major effects include a
decline in sensitive forest tree species, such as red spruce (Picea
rubens) and sugar maple (Acer saccharum), and a loss of biodiversity of
fishes, zooplankton, and macro invertebrates.
In addition to the role nitrogen deposition plays in acidification,
nitrogen deposition also leads to nutrient enrichment and altered
biogeochemical cycling. In aquatic systems increased nitrogen can alter
species assemblages and cause eutrophication. In terrestrial systems
nitrogen loading can lead to loss of nitrogen sensitive lichen species,
decreased biodiversity of grasslands, meadows and other sensitive
habitats, and increased potential for invasive species. For a broader
explanation of the topics treated here, refer to the description in
Section 7.1.2 of the draft RIA.
[[Page 74301]]
Adverse impacts on soil chemistry and plant life have been observed
for areas heavily influenced by atmospheric deposition of nutrients,
metals and acid species, resulting in species shifts, loss of
biodiversity, forest decline and damage to forest productivity.
Potential impacts also include adverse effects to human health through
ingestion of contaminated vegetation or livestock (as in the case for
dioxin deposition), reduction in crop yield, and limited use of land
due to contamination.
Atmospheric deposition of pollutants can reduce the aesthetic
appeal of buildings and culturally important articles through soiling,
and can contribute directly (or in conjunction with other pollutants)
to structural damage by means of corrosion or erosion. Atmospheric
deposition may affect materials principally by promoting and
accelerating the corrosion of metals, by degrading paints, and by
deteriorating building materials such as concrete and limestone.
Particles contribute to these effects because of their electrolytic,
hygroscopic, and acidic properties, and their ability to adsorb
corrosive gases (principally sulfur dioxide).
(4) Environmental Effects of Air Toxics
Emissions from producing, transporting and combusting fuel
contribute to ambient levels of pollutants that contribute to adverse
effects on vegetation. Volatile organic compounds, some of which are
considered air toxics, have long been suspected to play a role in
vegetation damage.\348\ In laboratory experiments, a wide range of
tolerance to VOCs has been observed.\349\ Decreases in harvested seed
pod weight have been reported for the more sensitive plants, and some
studies have reported effects on seed germination, flowering and fruit
ripening. Effects of individual VOCs or their role in conjunction with
other stressors (e.g., acidification, drought, temperature extremes)
have not been well studied. In a recent study of a mixture of VOCs
including ethanol and toluene on herbaceous plants, significant effects
on seed production, leaf water content and photosynthetic efficiency
were reported for some plant species.\350\
---------------------------------------------------------------------------
\348\ U.S. EPA. 1991. Effects of organic chemicals in the
atmosphere on terrestrial plants. EPA/600/ 3-91/001. Docket EPA-HQ-
OAR-2010-0162.
\349\ Cape JN, ID Leith, J Binnie, J Content, M Donkin, M
Skewes, DN Price AR Brown, AD Sharpe. 2003. Effects of VOCs on
herbaceous plants in an open-top chamber experiment. Environ.
Pollut. 124:341-343. Docket EPA-HQ-OAR-2010-0162.
\350\ Cape JN, ID Leith, J Binnie, J Content, M Donkin, M
Skewes, DN Price AR Brown, AD Sharpe. 2003. Effects of VOCs on
herbaceous plants in an open-top chamber experiment. Environ.
Pollut. 124:341-343. Docket EPA-HQ-OAR-2010-0162.
---------------------------------------------------------------------------
Research suggests an adverse impact of vehicle exhaust on plants,
which has in some cases been attributed to aromatic compounds and in
other cases to nitrogen oxides.351 352 353 The impacts of
VOCs on plant reproduction may have long-term implications for
biodiversity and survival of native species near major roadways. Most
of the studies of the impacts of VOCs on vegetation have focused on
short-term exposure and few studies have focused on long-term effects
of VOCs on vegetation and the potential for metabolites of these
compounds to affect herbivores or insects.
---------------------------------------------------------------------------
\351\ Viskari E-L. 2000. Epicuticular wax of Norway spruce
needles as indicator of traffic pollutant deposition. Water, Air,
and Soil Pollut. 121:327-337. Docket EPA-HQ-OAR-2010-0162.
\352\ Ugrekhelidze D, F Korte, G Kvesitadze. 1997. Uptake and
transformation of benzene and toluene by plant leaves. Ecotox.
Environ. Safety 37:24-29. Docket EPA-HQ-OAR-2010-0162.
\353\ Kammerbauer H, H Selinger, R Rommelt, A Ziegler-Jons, D
Knoppik, B Hock. 1987. Toxic components of motor vehicle emissions
for the spruce Picea abies. Environ. Pollut. 48:235-243. Docket EPA-
HQ-OAR-2010-0162.
---------------------------------------------------------------------------
D. Air Quality Impacts of Non-GHG Pollutants
(1) Current Levels of Non-GHG Pollutants
This proposal may have impacts on ambient concentrations of
criteria and air toxic pollutants. Nationally, levels of
PM2.5, ozone, NOX, SOX, CO and air
toxics are declining.\354\ However, approximately 127 million people
lived in counties that exceeded any NAAQS in 2008.\355\ These numbers
do not include the people living in areas where there is a future risk
of failing to maintain or attain the NAAQS. It is important to note
that these numbers do not account for potential SO2,
NO2 or Pb nonattainment areas which have not yet been
designated. Also, EPA is currently reviewing the standards for PM and
CO, and those standards could be made more protective, which would
increase the number of people living in nonattainment areas.
---------------------------------------------------------------------------
\354\ U.S. EPA (2010). Our Nation's Air: Status and Trends
through 2008. Office of Air Quality Planning and Standards, Research
Triangle Park, NC. Publication No. EPA 454/R-09-002. http://www.epa.gov/airtrends/2010/. Docket EPA-HQ-OAR-2010-0162.
\355\ See U.S. EPA Trends, Note 354.
---------------------------------------------------------------------------
Further, the majority of Americans continue to be exposed to
ambient concentrations of air toxics at levels which have the potential
to cause adverse health effects.356 357 The levels of air
toxics to which people are exposed vary depending on where people live
and work and the kinds of activities in which they engage, as discussed
in detail in U.S. EPA's recent mobile source air toxics rule.\358\
---------------------------------------------------------------------------
\356\ U.S. Environmental Protection Agency (2007). Control of
Hazardous Air Pollutants from Mobile Sources; Final Rule. 72 FR
8434, February 26, 2007.
\357\ See U.S. EPA 2010, Light-Duty 2012-2016 MY Vehicle Rule,
Note 6.
\358\ See U.S. EPA 2007, Note 356.
---------------------------------------------------------------------------
(2) Impacts of Proposed Standards on Future Ambient Concentrations of
PM2.5, Ozone and Air Toxics
Full-scale photochemical air quality modeling is necessary to
accurately project levels of criteria pollutants and air toxics. For
the final rulemaking, a national-scale air quality modeling analysis
will be performed to analyze the impacts of the standards on
PM2.5, ozone, and selected air toxics (i.e., benzene,
formaldehyde, acetaldehyde, acrolein and 1,3-butadiene). The length of
time needed to prepare the necessary emissions inventories, in addition
to the processing time associated with the modeling itself, has
precluded us from performing air quality modeling for this proposal.
Sections VII.A and VII.B of the preamble present projections of the
changes in criteria pollutant and air toxics emissions due to the
proposed vehicle standards; the basis for those estimates is set out in
Chapter 6 of the draft RIA. The atmospheric chemistry related to
ambient concentrations of PM2.5, ozone and air toxics is
very complex, and making predictions based solely on emissions changes
is extremely difficult. However, based on the magnitude of the
emissions changes predicted to result from the proposed standards, EPA
expects that there will be a relatively small change in ambient air
quality, pending a more comprehensive analysis for the final
rulemaking.
For the final rulemaking, EPA intends to use a 2005-based Community
Multi-scale Air Quality (CMAQ) modeling platform as the tool for the
air quality modeling. The CMAQ modeling system is a comprehensive
three-dimensional grid-based Eulerian air quality model designed to
estimate the formation and fate of oxidant precursors, primary and
secondary PM concentrations and deposition, and air toxics, over
regional and urban spatial scales (e.g., over the contiguous United
States).359 360 361 362
[[Page 74302]]
The CMAQ model is a well-known and well-established tool and is
commonly used by EPA for regulatory analyses, for instance the recent
ozone NAAQS proposal, and by States in developing attainment
demonstrations for their State Implementation Plans.\363\ The CMAQ
model version 4.7 was most recently peer-reviewed in February of 2009
for the U.S. EPA.\364\
---------------------------------------------------------------------------
\359\ U.S. Environmental Protection Agency, Byun, D.W., and
Ching, J.K.S., Eds, 1999. Science algorithms of EPA Models-3
Community Multiscale Air Quality (CMAQ modeling system, EPA/600/R-
99/030, Office of Research and Development). Docket EPA-HQ-OAR-2010-
0162.
\360\ Byun, D.W., and Schere, K.L., 2006. Review of the
Governing Equations, Computational Algorithms, and Other Components
of the Models-3 Community Multiscale Air Quality (CMAQ) Modeling
System, J. Applied Mechanics Reviews, 59 (2), 51-77. Docket EPA-HQ-
OAR-2010-0162.
\361\ Dennis, R.L., Byun, D.W., Novak, J.H., Galluppi, K.J.,
Coats, C.J., and Vouk, M.A., 1996. The next generation of integrated
air quality modeling: EPA's Models-3, Atmospheric Environment, 30,
1925-1938. Docket EPA-HQ-OAR-2010-0162.
\362\ Carlton, A., Bhave, P., Napelnok, S., Edney, E., Sarwar,
G., Pinder, R., Pouliot, G., and Houyoux, M. Model Representation of
Secondary Organic Aerosol in CMAQv4.7. Ahead of Print in
Environmental Science and Technology. Accessed at: http://pubs.acs.org/doi/abs/10.1021/es100636q?prevSearch=CMAQ&searchHistoryKey Docket EPA-HQ-OAR-2010-
0162.
\363\ U.S. EPA (2007). Regulatory Impact Analysis of the
Proposed Revisions to the National Ambient Air Quality Standards for
Ground-Level Ozone. EPA document number 442/R-07-008, July 2007.
Docket EPA-HQ-OAR-2010-0162
\364\ Allen, D. et al. (2009). Report on the Peer Review of the
Atmospheric Modeling and Analysis Division, National Exposure
Research Laboratory, Office of Research and Development, U.S. EPA.
http://www.epa.gov/asmdnerl/peer/reviewdocs.html. Docket EPA-HQ-OAR-
2010-0162.
_____________________________________-
CMAQ includes many science modules that simulate the emission,
production, decay, deposition and transport of organic and inorganic
gas-phase and particle-phase pollutants in the atmosphere. EPA intends
to use the most recent version of CMAQ which reflects updates to
version 4.7 to improve the underlying science. These include aqueous
chemistry mass conservation improvements, improved vertical convective
mixing and lowered CB05 mechanism unit yields for acrolein from 1,3-
butadiene tracer reactions which were updated to be consistent with
laboratory measurements.
VIII.What are the agencies' estimated cost, economic, and other impacts
of the proposed program?
In this section, we present the costs and impacts of the proposed
HD National Program. It is important to note that NHTSA's proposed fuel
consumption standards and EPA's proposed GHG standards would both be in
effect, and each would lead to average fuel economy increases and GHG
emission reductions. The two agencies' proposed standards would
comprise the HD National Program.
The net benefits of the proposed HD National Program consist of the
effects of the program on:
The vehicle program costs (costs of complying with the
vehicle CO2 standards)
Fuel savings associated with reduced fuel usage resulting
from the program
The economic value of reductions in greenhouse gas
emissions,
The reductions in other (non-GHG) pollutants,
Costs associated with increases in noise, congestion, and
accidents resulting from increased vehicle use,
The economic value of improvements in U.S. energy security
impacts,
Benefits associated with increased vehicle use due to the
``rebound'' effect.
We also present the cost-effectiveness of the standards, or the
cost per ton of emissions reduced. A few effects of the program, such
as the effects on other pollutants, are not included here. We plan to
add the effects of other pollutants to the analysis for the final
rules.
The program may have other effects that are not included here. The
agencies seek comment on whether any costs or benefits are omitted from
this analysis, so that they can be explicitly recognized in the final
rules. In particular, as discussed in Section III and in Chapter 2 of
the draft RIA, the technology cost estimates developed here take into
account the costs to hold other vehicle attributes, such as size and
performance, constant. In addition, the analysis assumes that the full
technology costs are passed along to vehicle buyers. With these
assumptions, because welfare losses are monetary estimates of how much
buyers would have to be compensated to be made as well off as in the
absence of the change,\365\ the price increase measures the loss to the
buyer.\366\ Assuming that the full technology cost gets passed along to
the buyer as an increase in price, the technology cost thus measures
the welfare loss to the buyer. Increasing fuel economy would have to
lead to other changes in the vehicles that buyers find undesirable for
there to be additional losses not included in the technology costs.
---------------------------------------------------------------------------
\365\ This approach describes the economic concept of
compensating variation, a payment of money after a change that would
make a consumer as well off after the change as before it. A related
concept, equivalent variation, estimates the income change that
would be an alternative to the change taking place. The difference
between them is whether the consumer's point of reference is her
welfare before the change (compensating variation) or after the
change (equivalent variation). In practice, these two measures are
typically very close together.
\366\ Indeed, it is likely to be an overestimate of the loss to
the consumer, because the consumer has choices other than buying the
same vehicle with a higher price; she could choose a different
vehicle, or decide not to buy a new vehicle. The consumer would
choose one of those options only if the alternative involves less
loss than paying the higher price. Thus, the increase in price that
the consumer faces would be the upper bound of loss of consumer
welfare, unless there are other changes to the vehicle due to the
fuel economy improvements that make the vehicle less desirable to
consumers.
---------------------------------------------------------------------------
The costs estimates include the costs of holding other vehicle
attributes, such as performance, constant. The 2010 light-duty GHG/CAFE
rule, discussed that if other vehicle attributes are not held constant,
then the cost estimates do not capture the impacts of these
changes.\367\ The light duty rule also discussed other potential issues
that could affect the calculation of the welfare impacts of these types
of changes, such as behavioral issues affecting the demand for
technology investments, investment horizon uncertainty, and the rate at
which truck owners trade off higher vehicle purchase price against
future fuel savings. The agencies seek comments, including supporting
data and quantitative analyses, if possible, of any additional impacts
of the proposed standards on vehicle attributes and performance, and
other potential aspects that could positively or negatively affect the
welfare implications of this proposed rulemaking, not addressed in this
analysis.
---------------------------------------------------------------------------
\367\ Environmental Protection Agency and Department of
Transportation, ``Light-Duty Vehicle Greenhouse Gas Emissions
Standards and Corporate Average Fuel Economy Standards; Final
Rule,'' Federal Register 75(88) (May 7, 2010). See especially
sections III.H.1 (pp. 25510-25513) and IV.G.6 (pp. 25651-25657).
---------------------------------------------------------------------------
The total monetized benefits (excluding fuel savings) under the
program are projected to be $1.5 to $7.9 billion in 2030, depending on
the value used for the social cost of carbon. These benefits are
summarized below in Table VIII-25. The costs of the program in 2030 are
estimated to be approximately $1.9 billion for new engine and truck
technology less $19 billion in savings realized by trucking operations
through fewer fuel expenditures (calculated using pre-tax fuel prices).
These costs are summarized below in Table VIII-24. The present value of
the total monetized benefits (excluding fuel savings) under the program
are expected to range from $23 billion to $150 billion with a 3%
discount rate; with a 7% discount rate, the total monetized benefits
are expected to range from $15 billion to
[[Page 74303]]
$140 billion. These values, summarized in Table VIII-25, depend on the
value used for the social cost of carbon. The present value of costs of
the program for new engine and truck technology, in Table VIII-24, are
expected to be $42 billion using a 3% discount rate, and $23 billion
with a 7% discount rate, less fuel savings (calculated using pre-tax
fuel prices) of $350 billion with a 3% discount rate, and $150 billion
with a 7% discount rate. Total present net benefits (in Table VIII-26)
are thus expected to range from $330 billion to $460 billion with a 3%
discount rate, and $150 billion to $270 billion with a 7% discount
rate.
The estimates developed here are measured against a baseline fuel
economy associated with MY 2010 vehicles. The extent to which fuel
economy improvements may have occurred in the absence of the rules
affect the net benefits associated with the rule. If trucks would have
ended up installing technologies to achieve the fuel savings and
reduced GHG emissions in the absence of this proposal, then both the
costs and benefits of these fuel savings could be attributed to market
forces, not the rules. At this time, the agencies do not have estimates
of the extent of fuel-saving technologies that might have been adopted
in the absence of this proposal. We seek comment on whether the
agencies should use an alternative baseline based on data provided by
commenters to estimate the degree to which the technologies discussed
in this proposal would have been adopted in the absence of this
proposal.
EPA has undertaken an analysis of the economy-wide impacts of the
proposed heavy-duty truck fuel efficiency and GHG standards as an
exploratory exercise that EPA believes could provide additional
insights into the potential impacts of the program.\368\ These results
were not a factor regarding the appropriateness of the proposed
standards. It is important to note that the results of this modeling
exercise are dependent on the assumptions associated with how
manufacturers would make fuel efficiency improvements and how trucking
operations would respond to increases in higher vehicle costs and
improved vehicle fuel efficiency as a result of the proposed program.
---------------------------------------------------------------------------
\368\ See Memorandum to Docket, ``Economy-Wide Impacts of
Proposed Heavy-Duty Truck Greenhouse Gas Emissions and Fuel
Efficiency Standards'', October 8, 2010. Docket EPA-HQ-OAR-2010-
0162.
---------------------------------------------------------------------------
Further information on these and other aspects of the economic
impacts of our rules are summarized in the following sections and are
presented in more detail in the draft RIA for this proposed rulemaking.
A. Conceptual Framework for Evaluating Impacts
This regulation is motivated primarily by the goals of reducing
emissions of greenhouse gases and promoting U.S. energy security by
reducing consumption and imports of petroleum-based fuels. These
motivations involve classic externalities, meaning that private
decisions do not incorporate all of the costs associated with these
problems; these costs are not borne completely by the households or
businesses whose actions are responsible for them. In the absence of
some mechanism to ``internalize'' these costs--that is, to transfer
their burden to individuals or firms whose decisions impose them--
individuals and firms will consume more petroleum-based fuels than is
socially optimal. Externalities are a classic motivation for government
intervention in markets. These externalities, as well as effects due to
changes in emissions of other pollutants and other impacts, are
discussed in Sections VIII.H-VIII.J.
In some cases, these classic externalities are by themselves enough
to justify the costs of imposing fuel efficiency standards. For some
discount rates and some projected social costs of carbon, however, the
reductions in these external costs are less than the costs of new fuel
saving technologies needed to meet the standards. (See Tables 9-18 and
9-19 in the draft RIA.) Nevertheless, this regulation reduces trucking
companies' fuel costs; according to our estimates, these savings in
fuel costs are by themselves sufficient to pay for the technologies
over periods of time considerably shorter than vehicles' expected
lifetimes under the assumptions used for this analysis (e.g., AEO 2010
projected fuel prices). If these estimates are correct, then the entire
value of the reductions in external costs represents additional net
benefits of the rule, beyond those resulting from the fact that the
value of fuel savings exceeds the costs of technologies necessary to
achieve them.
It is often asserted that there are cost-effective fuel-saving
technologies that truck companies are not taking advantage of. This is
commonly known as the ``energy gap'' or ``energy paradox.'' Standard
economic theory suggests that in normally functioning competitive
markets, interactions between vehicle buyers and producers would lead
producers to incorporate all cost-effective technology into the
vehicles that they offer, without government intervention. Unlike in
the light-duty vehicle market, the vast majority of vehicles in the
medium- and heavy-duty truck market are purchased and operated by
businesses with narrow profit margins, and for which fuel costs
represent a substantial operating expense.
Even in the presence of uncertainty and imperfect information--
conditions that hold to some degree in every market--we generally
expect firms to attempt to minimize their costs in an effort to survive
in a competitive marketplace, and therefore to make decisions that are
in the best interest of the company and its owners and/or shareholders.
In this case, the benefits of the rules would be due exclusively to
reducing the economic costs of externalities resulting from fuel
production and consumption. However, as discussed below in Section
VIII.E, the agencies have estimated that the application of fuel-saving
technologies in response to the proposed standards would, on average,
yield private returns to truck owners of 140% to 420% (see Table VIII-
21 below). The agencies have also estimated that the application of
these technologies would be significantly lower in the absence of the
proposed standards (i.e., under the ``no action'' regulatory
alternative), meaning that truck buyers and operators ignore
opportunities to make investments in higher fuel economy that appear to
offer significant cost savings.
There are several possible explanations in the economics literature
for why trucking companies do not adopt technologies that would be
expected to increase their profits: there could be a classic market
failure in the trucking industry--market power, externalities, or
asymmetric or incomplete (i.e., missing market) information; there
could be institutional or behavioral rigidities in the industry (union
rules, standard operating procedures, statutory requirements, loss
aversion, etc.), whereby participants collectively do not minimize
costs; or the engineering estimates of fuel savings and costs for these
technologies might overstate their benefits or understate their costs
in real-world applications.
To try to understand why trucking companies have not adopted these
seemingly cost-effective fuel-saving technologies, the agencies have
surveyed published literature about the energy paradox, and held
discussions with numerous truck market participants. Below, we have
listed five categories of possible explanations derived from these
sources. Collectively, these five hypotheses may explain the apparent
inconsistency between the
[[Page 74304]]
engineering analysis, which finds a number of cost-effective methods of
improving fuel economy, and the observation that many of these
technologies are not widely adopted.
These hypotheses include imperfect information in the original and
resale markets, split incentives, uncertainty about future fuel prices,
and adjustment and transactions costs. As the discussion will indicate,
some of these explanations suggest failures in the private market for
fuel-saving technology in addition to the externalities caused by
producing and consuming fuel that are the primary motivation for the
rules. Other explanations suggest market-based behaviors that may imply
additional costs of regulating truck fuel efficiency that are not
accounted for in this analysis. Anecdotal evidence from various
segments of the trucking industry suggests that many of these
hypotheses may play a role in explaining the puzzle of why truck
purchasers appear to under-invest in fuel economy, although different
explanations may apply to different segments, or even different
companies. The published literature does not appear to include
empirical analysis or data related to this question.
The agencies invite comment on these explanations, and on any data
or information that could be used to investigate the role of any or all
of these five hypotheses in explaining this energy paradox as it
applies specifically to trucks. The agencies also request comment and
information regarding any other hypotheses that could explain the
appearance that cost-effective fuel-saving technologies have not been
widely incorporated into trucks.
(1) Information Issues in the Original Sale Markets
One potential hypothesis for why the trucking industry does not
adopt what appear to be inexpensive fuel saving technologies is that
there is inadequate or unreliable information available about the
effectiveness of many fuel-saving technologies for new vehicles. As the
NAS report notes, ``Reliable, peer-reviewed data on fuel saving
performance is available only for a few technologies in a few
applications. As a result, the committee had to rely on information
from a wide range of sources, * * * including many results that have
not been duplicated by other researchers or verified over a range of
duty cycles.'' If reliable information on the effectiveness of many new
technologies is absent, truck buyers will understandably be reluctant
to spend additional money to purchase vehicles equipped with unproven
technologies.
This lack of information can manifest itself in multiple ways. For
instance, the problem may arise purely because collecting reliable
information on technologies is costly (also see Section VIII.A.5 on
transaction costs). Moreover, information has aspects of a public good,
in that no single firm has the incentive to do the costly
experimentation to determine whether or not particular technologies are
cost-effective, while all firms benefit from the knowledge that would
be gained from that experimentation. Similarly, if multiple firms must
conduct the same tests to get the same information, costs could be
reduced by some form of coordination of information gathering.
There are several possible reasons why trucking firms may
experience difficulty gathering or interpreting information about fuel-
saving technologies. It may be difficult for truck drivers and fleet
operators to separate the individual effects of various technologies
and operating strategies from one another, particularly when they tend
to be used in conjunction. It may also be difficult for truck operators
to assess the applicability of even objective and reliable test results
to their own specific vehicle configurations and operating practices;
at the same time, the effects of specific technologies or operating
practices may vary with geography, season of the year, or other
factors. In highly competitive markets, any firm that conducts tests of
fuel efficiency is unlikely to share results with other firms. If so,
then cost-effective technological improvements may not be adopted
because they cannot be reliably distinguished from inefficient
technologies.
To some extent, information about the effectiveness of some
selected technologies does exist, and it suggests that some
technologies appear to be very cost-effective in some situations. The
SmartWay Transport Partnership is a complementary partnership between
EPA and the freight goods industry (shippers, truck and rail carriers,
and logistics companies) whose aim is to provide better information on
fuel-efficient, low-carbon technologies and operational practices to
help accelerate their deployment. SmartWay initially focused on
evaluating and testing technologies for use in over-the-road class 8
tractor-trailers, commonly operated by the large, national trucking
fleets. For this reason, more information is available about the
configuration and operation of these types of trucks. Many of the
technologies that SmartWay selected for evaluation can also save fuel
and reduce greenhouse gas emissions in other types of trucks and
trucking operations. However, due to the wide diversity among other
types of trucks and truck operations, and lack of precise information
about the effectiveness of technologies in each one of these types of
truck and trucking operations, it is difficult for the program to
provide good information that is specific to each company. This makes
it much more challenging to improve market confidence in fuel-saving
technologies for these other truck types in the same way that SmartWay
has done with its existing partners. SmartWay will continue to serve as
a test bed for emerging technologies and as a conduit for technical
information by developing and sharing information on other types of
medium- and heavy-duty vehicles, helping to build market confidence in
innovative financial, technical and operational solutions for medium-
and heavy-duty vehicles across the freight goods industry, and
promoting retrofit fuel-saving technologies within the existing legacy
fleet. Information provision, such as the efforts of the SmartWay
program, is a direct, non-regulatory approach to addressing the problem
of the availability and reliability of results, as long as truck
purchasers are able and willing to act on the information.
While its effect on information is indirect, we expect the
requirement for the use of new technologies included in this proposal
will circumvent these information issues, resulting in their adoption,
thus providing more readily available information about their benefits.
The agencies appreciate, however, that the diversity of truck uses,
driving situations, and driver behavior willl lead to variation in the
fuel savings that individual trucks or fleets experience from using
specific technologies.
(2) Information Issues in the Resale Market
In addition to issues in the new vehicle market, a second
hypothesis for why trucking companies may not adopt what appear to be
cost-effective technologies to save fuel is that the resale market may
not reward the addition of fuel-saving technology to vehicles
adequately to ensure their original purchase by new truck buyers. This
inadequate payback for users beyond the original owner may contribute
to the short payback period that new purchasers appear to expect.\369\
The agencies seek data and information on the extent to which costs of
fuel-
[[Page 74305]]
saving equipment can be recovered in the resale truck market.
---------------------------------------------------------------------------
\369\ See NAS 2010, Note 111, at p. 188.
---------------------------------------------------------------------------
Some of this unwillingness to pay for fuel-saving technology may be
due to the extension of the information problems in the new vehicle
market into resale markets. Buyers in the resale market have no more
reason to trust information on fuel-saving technologies than buyers in
the original market. Because actual fuel economy of trucks on the road
depends on many factors, including geography and driving styles or
habits, even objective sources such as logs of truck performance for
used vehicles may not provide reliable information about the fuel
economy that potential purchasers of used trucks will experience.
A related possibility is that vehicles will be used for different
purposes by their second owners than those for which they were
originally designed. For instance, a vehicle originally purchased for
long hauls might be used by its second owner instead for regional or
intrastate trips, in which case some of the fuel-saving measures that
proved effective in its original use may not be equally effective in
these new uses. If information were more widely available and reliable,
then purchasers in the resale market would seek vehicles with
technologies that best suited their purposes, and buyers would be
matched with sellers so that used vehicles would be used primarily for
purposes in which their fuel-saving technologies were most valuable.
It is also possible, though, that the fuel savings experienced by
the secondary purchasers may not match those experienced by their
original owners if the optimal secondary new use of the vehicle does
not earn as many benefits from the technologies. In that case, the
premium for fuel-saving technology in the secondary market should
accurately reflect its value to potential buyers participating in that
market, even if it is lower than its value in the original market, and
the market has not failed. Because the information necessary to
optimize use in the secondary market may not be readily available or
reliable, however, buyers in the resale market may have less ability
than purchasers of new vehicles to identify and gain the advantages of
new fuel-saving technologies, and may thus be even less likely to pay a
premium for them.
For these reasons, purchasers' willingness to pay for fuel-economy
technologies may be even lower in the resale market than in the
original equipment market. Even when fuel-saving technologies will
provide benefits in the resale markets, purchasers of used vehicles may
not be willing to compensate their original owners fully for their
remaining value. As a result, the purchasers of original equipment may
expect the resale market to provide inadequate appropriate compensation
for the new technologies, even when those technologies would reduce
costs for the new buyers. This information issue may partially explain
what appears to be the very short payback periods required for new
technologies in the new vehicle market.
(3) Split Incentives in the Medium- and Heavy-Duty Truck Industry
A third hypothesis explaining the energy paradox as applied to
trucking involves split incentives. When markets work effectively,
signals provided by transactions in one market are quickly transmitted
to related markets and influence the decisions of buyers and sellers in
those related markets. For instance, in a well-functioning market
system, changes in the expected future price of fuel should be
transmitted rapidly to those who purchase trucks, who will then
reevaluate the amount of fuel-saving technology to purchase for new
vehicles. If for some reason a truck purchaser will not be directly
responsible for future fuel costs, or the individual who will be
responsible for fuel costs does not decide which truck characteristics
to purchase, then those price signals may not be transmitted
effectively, and incentives can be described as ``split.''
One place where such a split may occur is between the owners and
operators of trucks. Because they are generally responsible for
purchasing fuel, truck operators have strong incentives to economize on
its use, and are thus likely to support the use of fuel-saving
technology. However, the owners of trucks or trailers are often
different from operators, and may be more concerned about their
longevity or maintenance costs than about their fuel efficiency when
purchasing vehicles. As a result, capital investments by truck owners
may be channeled into equipment that improves vehicles' durability or
reduces their maintenance costs, rather than into fuel-saving
technology. If operators can choose freely among the trucks they drive,
competition among truck owners to employ operators would encourage
owners to invest in fuel-saving technology. However, if truck owners
have more ability to choose among operators, then market signals for
improved fuel savings that would normally be transmitted to truck
owners may be muted.
Anecdotal information about large truck fleets suggests that, even
within a company, the office or department responsible for truck
purchases is often different from that responsible for purchasing fuel.
Therefore, the employees who purchase trucks may have strong incentives
to lower their initial capital cost, but not equally strong incentives
to lower operating costs.
Single-wide tires, which save fuel and allow more payload (thus
increasing revenue), offer another example of split incentives. They
require a different driving style; those concerned about retaining
drivers may resist their purchase, because drivers may not like the
slightly different ``feel'' of wheel torque needed. Maintenance and
repair staff may resist them because the tires may not be as available
as they would like on the road, or they may need to change road service
providers. Finally, those who resell the trucks may believe that the
resale market will not value the tires. While financial pressures
should provide incentives for greater coordination, especially when
fuel costs are a large share of operating costs, it may be difficult
institutionally to change budgeting procedures and to coordinate across
offices. Thus, even within a company incentives for fuel savings may
not be fully transmitted to those responsible for purchasing decisions.
In addition, the NAS report notes that split incentives can arise
between tractor and trailer operators.\370\ Trailers affect the fuel
efficiency of shipping, but trailer owners do not face strong
incentives to coordinate with truck owners. Although some trucking
fleets own or lease their own trailers, a significant part of the
trucking business is ``drop and hook'' service, in which trucking
fleets pick up and drop off trailers and containers. These trailers and
containers can belong to shippers, other trucking companies, leasing
companies, or ocean-going vessel lines, in which cases their owners may
not face strong incentives to economize on fuel consumption by tractor
operators. Though tractor operators should, in principle, have some
ability to arrange tractor-trailer combinations that provide increased
fuel efficiency, the value of the resulting fuel savings may be small
relative to the complexity and cost involved. EPA and NHTSA are not
proposing to regulate trailers in this proposal.
---------------------------------------------------------------------------
\370\ See NAS 2010, Note 111, at p. 182.
---------------------------------------------------------------------------
By itself, information provision may be inadequate to address the
potential underinvestment in fuel economy
[[Page 74306]]
resulting from such split incentives. In this setting, regulation may
contribute to fuel savings that otherwise may be difficult to achieve.
The agencies seek evidence and data on the extent to which split
incentives affect purchasing choices in truck markets. For example, are
trailer buyers that do not own their own tractors less likely to
purchase aerodynamic trailers than those that purchase and drive both
tractors and trailers?
(4) Uncertainty About Future Cost Savings
Another hypothesis for the lack of adoption of seemingly fuel
saving technologies may be uncertainty about future fuel prices or
truck maintenance costs. When purchasers have less than perfect
foresight about future operating expenses, they may implicitly discount
future savings in those costs due to uncertainty about potential
returns from investments that reduce future costs. In contrast, the
immediate costs of the fuel-saving or maintenance-reducing technologies
are certain and immediate, and thus not subject to discounting. In this
situation, both the expected return on capital investments in higher
fuel economy and potential variance about its expected rate may play a
role in a firm's calculation of its payback period on such investments.
In the context of energy efficiency investments for the home,
Metcalf and Rosenthal (1995) and Metcalf and Hassett (1995) observe
that households weigh known, up-front costs that are essentially
irreversible against an unknown stream of future fuel savings.\371\
Uncertainty about the value of future energy savings may make risk-
averse households reluctant to invest in energy-saving technologies
that appear to offer attractive economic returns. These authors find
that it is possible to replicate the observed adoption rates for
household energy efficiency improvements by incorporating the effect of
uncertainty about the value of future energy savings into an empirical
model. Notably, in this situation, requiring households to adopt
technologies more quickly may make them worse off by imposing
additional risk on them.
---------------------------------------------------------------------------
\371\ Metcalf, G., and D. Rosenthal (1995). ``The `New' View of
Investment Decisions and Public Policy Analysis: An Application to
Green Lights and Cold Refrigerators,'' Journal of Policy Analysis
and Management 14: 517-531. Hassett and Metcalf (1995). ``Energy