[Federal Register Volume 76, Number 179 (Thursday, September 15, 2011)]
[Rules and Regulations]
[Pages 57105-57513]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2011-20740]
[[Page 57105]]
Vol. 76
Thursday,
No. 179
September 15, 2011
Part II
Environmental Protection Agency
-----------------------------------------------------------------------
40 CFR Parts 85, 86, 600, 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; Final Rule
Federal Register / Vol. 76, No. 179 / Thursday, September 15, 2011 /
Rules and Regulations
[[Page 57106]]
-----------------------------------------------------------------------
ENVIRONMENTAL PROTECTION AGENCY
40 CFR Parts 85, 86, 600, 1033, 1036, 1037, 1039, 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-9455-1]
RIN 2060-AP61; 2127-AK74
Greenhouse Gas Emissions Standards and Fuel Efficiency Standards
for Medium- and Heavy-Duty Engines and Vehicles
AGENCY: Environmental Protection Agency (EPA) and National Highway
Traffic Safety Administration (NHTSA), DOT.
ACTION: Final Rules.
-----------------------------------------------------------------------
SUMMARY: EPA and NHTSA, on behalf of the Department of Transportation,
are each finalizing rules to establish a comprehensive Heavy-Duty
National Program that will reduce greenhouse gas emissions and fuel
consumption 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 final fuel
consumption standards and EPA's final carbon dioxide (CO2)
emissions standards are tailored to each of three regulatory categories
of heavy-duty vehicles: Combination Tractors; Heavy-duty Pickup Trucks
and Vans; and Vocational Vehicles. The rules include separate standards
for the engines that power combination tractors and vocational
vehicles. Certain rules are exclusive to the EPA program. These include
EPA's final hydrofluorocarbon standards to control leakage from air
conditioning systems in combination tractors, and pickup trucks and
vans. These also include EPA's final nitrous oxide (N2O) and
methane (CH4) emissions standards that apply to all heavy-
duty engines, pickup trucks and vans.
EPA's final greenhouse gas emission standards under the Clean Air
Act will begin with model year 2014. NHTSA's final fuel consumption
standards under the Energy Independence and Security Act of 2007 will
be voluntary in model years 2014 and 2015, becoming mandatory with
model year 2016 for most regulatory categories. Commercial trailers are
not regulated in this phase of the Heavy-Duty National Program.
The agencies estimate that the combined standards will reduce
CO2 emissions by approximately 270 million metric tons and
save 530 million barrels of oil over the life of vehicles sold during
the 2014 through 2018 model years, providing over $7 billion in net
societal benefits, and $49 billion in net societal benefits when
private fuel savings are considered.
EPA is also finalizing provisions allowing light-duty vehicle
manufacturers to use CO2 credits to meet the light-duty
vehicle N2O and CH4 standards, technical
amendments to the fuel economy provisions for light-duty vehicles, and
a technical amendment to the criteria pollutant emissions requirements
for certain switch locomotives.
DATES: These final rules are effective on November 14, 2011. The
incorporation by reference of certain publications listed in this
regulation is approved by the Director of the Federal Register as of
November 14, 2011.
ADDRESSES: EPA and NHTSA have established dockets for this action under
Docket ID No. EPA-HQ-OAR-2010-0162 and NHTSA-2010-0079, respectively.
All documents in the docket are listed on the http://www.regulations.gov Web site. 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, is not
placed on the Internet and will be publicly available only in hard copy
form. Publicly available docket materials are available either
electronically through http://www.regulations.gov or in hard copy at
the following locations: EPA: EPA Docket Center, EPA/DC, EPA West
Building, 1301 Constitution Ave., NW., Room 3334, 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 Public
Reading Room is (202) 566-1744, and the telephone number for the Air
Docket is (202) 566-1742. 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.
FOR FURTHER INFORMATION CONTACT: NHTSA: Lily Smith, 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 contact the Office of Transportation and Air
Quality at OTAQPUBLICWEB@epa.gov.
SUPPLEMENTARY INFORMATION:
A. Does this action apply to me?
This action affects 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. 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
emissions standards and corporate average fuel economy standards issued
for light-duty model year 2012-2016 vehicles. Regulated categories and
entities include the following:
------------------------------------------------------------------------
Examples of
Category NAICS Code \a\ potentially affected
entities
------------------------------------------------------------------------
Industry...................... 336111 Motor Vehicle
336112 Manufacturers, Engine
and Truck
Manufacturers.
336120
Industry...................... 541514 Commercial Importers
811112 of Vehicles and
Vehicle Components.
811198
Industry...................... 336111 Alternative Fuel
Vehicle Converters.
336112
[[Page 57107]]
422720
454312
541514
541690
811198
Industry...................... 333618 Manufacturers,
336510 remanufacturers and
importers of
locomotives and
locomotive engines.
------------------------------------------------------------------------
Note:
\a\ North American Industry Classification System (NAICS).
This table is not intended to be exhaustive, but rather provides a
guide for readers regarding entities likely covered by these rules.
This table lists the types of entities that the agencies are aware may
be regulated by this action. Other types of entities not listed in the
table could also be regulated. To determine whether your activities are
regulated by this action, you should carefully examine the
applicability criteria in 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.
Table of Contents
A. Does this action apply to me?
I. Overview
A. Introduction
B. Building Blocks of the Heavy-Duty National Program
C. Summary of the Final 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. Final GHG and Fuel Consumption Standards for Heavy-Duty Engines
and Vehicles
A. What vehicles will 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
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. Final Regulatory Flexibility Provisions
A. Averaging, Banking, and Trading Program
B. Additional Flexibility Provisions
V. NHTSA and EPA 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 will this 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
Program's GHG Emissions Reductions
VII. How will this final action 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 final program?
A. Conceptual Framework for Evaluating Impacts
B. Costs Associated With the Final 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. The Effect of Safety Standards and Voluntary Safety
Improvements on Vehicle Weight
L. Summary of Costs and Benefits
M. Employment Impacts
IX. Analysis of the Alternatives
A. What are the alternatives that the agencies considered?
B. How do these alternatives compare in overall GHG emissions
reductions and fuel efficiency and cost?
C. What is the agencies' decision regarding trailer standards?
X. Public Participation
XI. NHTSA's Record of Decision
A. The Agency's Decision
B. Alternatives Considered by NHTSA in Reaching Its Decision,
Including the Environmentally Preferable Alternative
C. Factors Balanced by NHTSA in Making Its Decision
D. How the Factors and Considerations Balanced by NHTSA Entered
Into Its Decision
E. The Agency's Preferences Among Alternatives Based on Relevant
Factors, Including Economic and Technical Considerations and Agency
Statutory Missions
F. Mitigation
XII. Statutory and Executive Order Reviews
XIII. 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 fuel consumption
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 from
the mobile source sector, after light-duty passenger cars and trucks.
These are the second joint rules issued by the agencies, following on
the April 1, 2010 standards to sharply reduce GHG emissions and fuel
consumption from MY 2012-2016 passenger cars and light trucks
(published on May 7, 2010 at 75 FR 25324).
In a May 21, 2010 memorandum to the Administrators of EPA and NHTSA
(and the Secretaries of Transportation and 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.'' 1 2 In the
[[Page 57108]]
May 2010 memorandum, the President specifically 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
on-highway vehicles and work trucks beginning with the 2014 model year
(MY).'' In this final rulemaking, each agency is addressing this
Memorandum by adopting rules under its respective authority that
together comprise a coordinated and comprehensive HD National Program
designed to address the urgent and closely intertwined challenges of
reduction of dependence on oil, achievement of energy security, and
amelioration of global climate change.
---------------------------------------------------------------------------
\1\ 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.
\2\ The May 2010 Presidential Memorandum also directed EPA and
NHTSA, in close coordination with the California Air Resources
Board, to build on the National Program for 2012-2016 MY light-duty
vehicles by developing and proposing coordinated light-duty vehicle
standards for MY 2017-2025. The agencies have taken an initial step
in this process, releasing a Joint Notice of Intent and Initial
Joint Technical Assessment Report in September 2010 (75 FR 62739),
and a Supplemental Notice of Intent (75 FR 76337). The agencies plan
to issue a full light-duty vehicle proposal to extend the National
Program to MY 2017-2025 in September 2011.
---------------------------------------------------------------------------
At the same time, the final program will enhance American
competitiveness and job creation, benefit consumers and businesses by
reducing costs for transporting goods, and spur growth in the clean
energy sector.
The HD National Program the agencies are finalizing today reflects
a collaborative effort between the agencies, a range of public interest
nongovernmental organizations (NGOs), the state of California and the
regulated industry. At the time of the President's announcement, 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 the creation
of a HD National Program based on a common set of principles. In the
letters, the stakeholders committed 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 final rules adopted today reflect these principles. The final
HD National Program also builds on many years of heavy-duty engine and
vehicle technology development to achieve what the agencies believe is
the greatest degree of fuel consumption and GHG emission reduction
appropriate, technologically and economically feasible, and cost-
effective for model years 2014-2018. In addition to taking 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 fuel
consumption and GHG emission through future regulatory steps.
Similarly, 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 technologies progress in the
coming years and as the agencies improve the regulatory tools to
evaluate real world vehicle performance, we expect that we will develop
a second phase of regulations to reinforce these initial rules and
achieve further reductions in GHG emissions and fuel consumption
reduction for the mid- and longer-term time frame (beyond 2018). The
agencies are committed to working with all interested stakeholders in
this effort and to the extent possible working towards alignment with
similar programs being developed in Canada, Mexico, Europe, China, and
Japan. In doing so, we will continue to evaluate many of the structural
and technical decisions we are making in today's final action in the
context of new technologies and the new regulatory tools that we expect
to realize in the future.
The regulatory program we are finalizing today is largely unchanged
from the proposal the agencies made on November 30, 2010 (See 75 FR
741512). The structure of the program and the stringency of the
standards are essentially the same as proposed. We have made a number
of changes to the testing requirements and reporting requirements to
provide greater regulatory certainty and better align the NHTSA and EPA
portions of the program. In response to comments, we have also made
some changes to the averaging, banking and trading (ABT) provisions of
the program that will make implementation of this final program more
flexible for manufacturers. We have added provisions to further
encourage the development of advanced technologies and to provide a
more straightforward mechanism to certify engines and vehicles using
innovative technologies. Finally in response to comments, we have made
some technical changes to our emissions compliance model that results
in different numeric standards for both combination tractors and
vocational vehicles to more accurately characterize emissions while
maintaining the same overall stringency and therefore expected costs
and benefits of the 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.\3\ Heavy-duty trucks \4\ have
long 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.
---------------------------------------------------------------------------
\3\ References in this preamble to ``gasoline'' engines (and the
vehicles powered by them) generally include other Otto-cycle engines
as well, such as those fueled by ethanol and natural gas, except in
contexts that are clearly gasoline-specific.
\4\ 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.\5\ It also does not
include
[[Page 57109]]
motorcycles. Thus, in this rulemaking, 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.\6\
---------------------------------------------------------------------------
\5\ Light-Duty Vehicle Greenhouse Gas Emission Standards and
Corporate Average Fuel Economy Standards; Final Rule 75 FR 25323,
May 7, 2010.
\6\ The CAA defines heavy-duty as a truck, bus or other motor
vehicles 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.
---------------------------------------------------------------------------
The agencies proposed to cover all segments of the heavy-duty
category above, except with respect to recreational vehicles (RVs or
motor homes). 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.'' \7\ The standards
that EPA is finalizing today cover recreational on-highway vehicles,
while NHTSA proposed not to include recreational vehicles based on an
interpretation of the term ``commercial medium- and heavy-duty on-
highway commercial'' vehicles. NHTSA stated in the NPRM that
recreational vehicles are non-commercial, and therefore outside of the
term and the scope of its rule.
---------------------------------------------------------------------------
\7\ 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).
---------------------------------------------------------------------------
Oshkosh Corporation commented that this interpretation did not
match the statutory definition of the term in EISA, which defines
``commercial medium- and heavy-duty on-highway vehicle'' by weight
only,\8\ and that therefore the agency's interpretation of the term
should be explicitly broadened to include all vehicles, and more than
only vehicles that are not engaged in interstate commerce as defined by
the Federal Motor Carrier Safety Administration in 49 CFR part 202.
Alternatively, Oshkosh suggested that if NHTSA followed the definition
provided in EISA, which makes no direct reference to the concept of
``commercial,'' there would be no logical reason to exclude RVs based
on that definition.
---------------------------------------------------------------------------
\8\ See 49 U.S.C. 32902(k)(2), Note 7 above.
---------------------------------------------------------------------------
NHTSA has considered Oshkosh's comment and reconsidered its
interpretation that effectively read words into the statutory
definition. Given the very wide variety of vehicles contained in the HD
fleet, reading those words into the definition and thereby excluding
certain types of vehicles could create illogical results, i.e.,
treating similar vehicles differently. Therefore, NHTSA will adhere to
the statutory definition contained in EISA for this rulemaking.
However, as RVs were not included by NHTSA in the proposed regulation
in the NPRM, they are not within the scope and must be excluded in
NHTSA's portion of the final program. Accordingly, NHTSA will address
this issue in the next rulemaking. However, as noted, RVs are subject
to the CO2 standards for vocational vehicles.
Setting fuel consumption standards for the heavy-duty sector,
pursuant to NHTSA's EISA authority, will also improve our energy and
national 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 49-51
percent of U.S. petroleum consumption. World crude oil production is
highly concentrated, exacerbating the risks of supply disruptions and
price shocks as the recent unrest in North Africa and the Persian Gulf
highlights. Recently, oil prices have been over $100 per barrel,
gasoline and diesel fuel prices in excess of $4 per gallon, causing
financial hardship for many families and businesses. The export of U.S.
assets in exchange 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.\9\
---------------------------------------------------------------------------
\9\ In 2009 Source: EIA Annual Energy Outlook 2010 released May
11, 2010.
---------------------------------------------------------------------------
Setting GHG emissions standards for the heavy-duty sector will help
to ameliorate climate change. The EPA Administrator found after a
thorough examination of the scientific evidence on the causes and
impact of current and future climate change, and careful review of
public comments, that the science compellingly supports a positive
finding that atmospheric concentrations of six greenhouse gases taken
in combination result in air pollution which may reasonably be
anticipated to endanger both public health and welfare and that the
combined emissions of these greenhouse gases from new motor vehicles
and engines contributes to the greenhouse gas air pollution that
endangers public health and welfare. In her finding, the Administrator
carefully studied and relied heavily upon the major findings and
conclusions from the recent assessments of the U.S. Climate Change
Science Program and the U.N. Intergovernmental Panel on Climate Change.
74 FR 66496, December 15, 2009. 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 observed global warming over the last 50 years.\10\ 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.\11\ Mobile sources addressed in EPA's
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.\12\ Heavy-duty vehicles
emit CO2, CH4, N2O, and HFCs and are
responsible for nearly 19 percent of all mobile source GHGs (nearly 6
percent 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).\13\
---------------------------------------------------------------------------
\10\ 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.
\11\ 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.
\12\ See Endangerment TSD, Note 10, above, at pp. 180-194.
\13\ U.S. Environmental Protection Agency. 2009. Inventory of
U.S. Greenhouse Gas Emissions and Sinks: See Note 11, above.
---------------------------------------------------------------------------
In developing this HD National program, 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\ Further, it is our
expectation based on our ongoing work with the State of California that
the California ARB will
[[Page 57110]]
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 have been working with
California ARB to enable that outcome.
---------------------------------------------------------------------------
\14\ Pursuant to DOT Order 2100.2, NHTSA has docketed a
memorandum recording those meetings that it attended and documents
submitted by stakeholders which formed a basis for this action 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 adopting 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 final fuel
consumption standards and EPA's final GHG standards apply to
manufacturers of the following types of heavy-duty vehicles and their
engines; the final 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 light-duty 2012-2016 MY vehicle rule, EPA's and NHTSA's
final 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 exhaust 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 that truck emits
directly 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
adopting under our separate legal authorities.
---------------------------------------------------------------------------
\15\ However, as discussed below, in addition to addressing
CO2, the EPA's final standards also include provisions to
address other GHGs (nitrous oxide, methane, and air conditioning
refrigerant emissions). See Section II.
---------------------------------------------------------------------------
This program is based on standards for direct exhaust emissions
from engines and vehicles. In characterizing the overall emissions
impacts, benefits and costs of the program, analyses of air pollutant
emissions from upstream sources have been conducted. In this action,
the agencies use the term upstream to include emissions from the
production and distribution of fuel. A summary of the analysis of
upstream emissions can be found in Section VI.C of this preamble, and
further details are available in Chapter 5 of the RIA.
The timelines for the implementation of the final NHTSA and EPA
standards are also closely coordinated. EPA's final GHG emission
standards will 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 0 below, NHTSA's final fuel consumption standards
will be voluntary in model years 2014 and 2015, becoming mandatory in
model year 2016, except for diesel engine standards which will be
voluntary in model years 2014, 2015 and 2016, becoming mandatory in
model year 2017. Both agencies are also allowing for early compliance
in model year 2013. A detailed discussion of how the final standards
are consistent with each agency's respective statutory requirements and
authorities is found later in this preamble.
Allison Transmission stated that sufficient time must be taken
before issuing the final rules in order to ensure that the standards
are supportable. As explained in Sections II and III below, as well as
in the RIA, the agencies believe there is sufficient lead time to meet
all of the standards adopted in today's rules. For those areas for
which the agencies have determined that insufficient time is available
to develop appropriate standards, such as for trailers, the agencies
are not including regulations as part of this initial program.
NHTSA received several comments related to the timing of the
implementation of its fuel consumption standards. The Engine
Manufacturers Association (EMA), the National Automobile Dealers
Association (NADA), The Volvo Group (Volvo), and Navistar argued that
the timing of NHTSA's standards violated the lead time requirement of
49 U.S.C. 32902(k)(3)(A), which states that standards under the new
medium- and heavy-duty program shall have ``not less than 4 full model
years of regulatory lead-time.'' The commenters seemed to interpret the
voluntary program as the imposition of regulation upon industry. NADA
described NHTSA's standards during the voluntary period as
``mandates.''
NHTSA has reviewed this issue and believes that the regulatory
schedule is consistent with the lead time requirement of Section
32902(k)(3). To clarify, NHTSA will not be imposing a mandatory
regulatory program until 2016, and none of the voluntary standards will
be ``mandates.'' As described in later sections, the voluntary
standards would only apply to a manufacturer if it makes the voluntary
and affirmative choice to opt-in to the program. \16\ Mandatory NHTSA
standards will first come into effect in 2016, giving industry four
full years of lead time with the NHTSA fuel consumption standards.
---------------------------------------------------------------------------
\16\ Prior to or at the same time that a manufacturer submits
its first application for a certificate of conformity; See Section V
below.
---------------------------------------------------------------------------
EMA, NADA, and Navistar also argued that the proposed standards
would violate the stability requirement of 49 U.S.C. 32902(k)(3)(B),
which states that they shall have ``not less than 3 full model years of
regulatory stability.'' EMA stated that since there are HD emission
standards taking effect in 2013, the 2014 implementation date for this
rule would violate the stability requirements. NADA argued that the MY
2014-2017/2018 phase-in period was inadequate to fulfill the stability
requirement.
Congress has not spoken directly to the meaning of the words
``regulatory stability.'' NHTSA believes that the ``regulatory
stability'' requirement exists to ensure that manufacturers will not be
subject to new standards in repeated rulemakings too rapidly, given
that Congress did not include a minimum duration period for the MD/HD
standards.\17\ NHTSA further believes that standards, which as set
provide for increasing stringency during the period that the standards
are applicable under this rule to be the maximum feasible during the
regulatory period, are within the meaning of the statute. In this
statutory context, NHTSA interprets the phrase ``regulatory stability''
in Section 32902(k)(3)(B) as requiring that the standards remain in
effect for three years before they may be increased by amendment. It
does not prohibit standards which contain pre-determined stringency
increases.
---------------------------------------------------------------------------
\17\ In contrast, light-duty standards must remain in place for
``at least 1, but not more than 5, model years.'' 23902(b)(3)(B).
---------------------------------------------------------------------------
As laid out in Section II below, NHTSA's final standards follow
different phase-in schedules based on differences between the
regulatory categories. Consistent with NHTSA's statutory obligation to
implement a program designed to achieve the maximum feasible fuel
efficiency improvement, the standards increase in stringency based upon
increasing fleet penetration rates for the available technologies. The
NPRM proposed phase-in schedules aligned with EPA's,
[[Page 57111]]
some of which followed pre-determined stringency increases. The NPRM
also noted that NHTSA was considering alternate standards that would
not change in stringency during the time frame when the regulations are
effective for those standards that increased throughout the mandatory
program. As described in Section II below, the final rule includes the
proposed alternate standards for those standards that follow such a
stringency phase-in path. Therefore, NHTSA believes that the final rule
provides ample stability for each standard.
Each standard, associated phase-in schedule, and alternative
standard implemented by this final rule was noticed in the NPRM. Those
fuel consumption standards that become mandatory in 2017 will remain in
effect through at least 2019. This further ensures that the fuel
consumption standards in this rule will remain in effect for at least
three years, providing the statutorily-mandated three full years of
regulatory stability, and ensuring that manufacturers will not be
subject to new or amended standards too rapidly. (The greenhouse gas
emission standards remain in effect unless and until amended in all
later model years in any case.) Therefore, NHTSA believes the
commenters' concern about regulatory stability is addressed in the
structure of the rule.
Neither EPA nor NHTSA is adopting 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.
The agencies recognize that aerodynamic and tire rolling resistance
improvements to trailers represent a significant opportunity to reduce
fuel consumption and GHGs as evidenced, among other things, by the work
of the EPA SmartWay program. While we are deferring action today on
setting trailer standards, the agencies are committed to moving forward
to create a regulatory program for trailers that would complement the
current vehicle program. See Section IX for more details on the
agencies' decisions regarding trailers, and Sections II and XII for
more details on the agencies' decisions regarding small businesses.
The agencies have analyzed in detail the projected costs, fuel
savings, and benefits of the final GHG and fuel consumption standards.
Table I-1 shows estimated lifetime discounted program costs (including
technological outlays), fuel savings, and benefits for all heavy-duty
vehicles projected to be sold in model years 2014-2018 over these
vehicles' lives. Section I.D includes additional information about this
analysis.
Table I-1--Estimated Lifetime Discounted Costs, Fuel Savings, Benefits,
and Net Benefits for 2014-2018 Model Year Heavy-Duty Vehicles a b
[Billions, 2009$]
------------------------------------------------------------------------
------------------------------------------------------------------------
Lifetime Present Value \c\--3% Discount Rate
------------------------------------------------------------------------
Program Costs.................................................. $8.1
Fuel Savings................................................... 50
Benefits....................................................... 7.3
Net Benefits\d\................................................ 49
------------------------------------------------------------------------
Annualized Value \e\--3% Discount Rate
------------------------------------------------------------------------
Annualized Costs............................................... 0.4
Fuel Savings................................................... 2.2
Annualized Benefits............................................ 0.4
Net Benefits \d\............................................... 2.2
------------------------------------------------------------------------
Lifetime Present Value \c\--7% Discount Rate
------------------------------------------------------------------------
Program Costs.................................................. 8.1
Fuel Savings................................................... 34
Benefits....................................................... 6.7
Net Benefits \d\............................................... 33
------------------------------------------------------------------------
Annualized Value \e\--7% Discount Rate
------------------------------------------------------------------------
Annualized Costs............................................... 0.6
Fuel Savings................................................... 2.6
Annualized Benefits............................................ 0.5
Net Benefits \d\............................................... 2.5
------------------------------------------------------------------------
Notes:
a The agencies estimated the benefits associated with four different
values of a one ton CO2 reduction (model average at 2.5% discount
rate, 3%, and 5%; 95th percentile at 3%), which each increase over
time. For the purposes of this overview presentation of estimated
costs and benefits, however, we are showing the benefits associated
with the marginal value deemed to be central by the interagency
working group on this topic: the model average at 3% discount rate, in
2009 dollars. Section VIII.F provides a complete list of values for
the 4 estimates.
b Note that net present value of reduced GHG emissions is calculated
differently than other benefits. The same discount rate used to
discount the value of damages from future emissions (SCC at 5, 3, and
2.5 percent) is used to calculate net present value of SCC for
internal consistency. Refer to Section VIII.F for more detail.
c Present value is the total, aggregated amount that a series of
monetized costs or benefits that occur over time is worth now (in year
2009 dollar terms), discounting future values to the present.
d Net benefits reflect the fuel savings plus benefits minus costs.
e The annualized value is the constant annual value through a given time
period (2012 through 2050 in this analysis) whose summed present value
equals the present value from which it was derived.
B. Building Blocks of the Heavy-Duty National Program
The standards that are being adopted in this notice represent the
first time that NHTSA and EPA are regulating the heavy-duty sector for
fuel consumption and GHG emissions, respectively. The 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 percent less NOX and 99
percent 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, the
monetized health and welfare benefits alone are projected to be greater
than $70 billion in 2030--benefits far exceeding compliance costs and
not including the unmonetized benefits resulting from reductions in air
toxics and ozone precursors (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 roads. 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
[[Page 57112]]
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 final program
incorporates the existing engine-based approach used for criteria
pollutant 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 efficiency of commercial
medium-duty and heavy-duty on-highway vehicles and work trucks in three
steps: a study by NAS, a study by NHTSA,\18\ and a rulemaking to
develop the regulations themselves.
---------------------------------------------------------------------------
\18\ Factors and Considerations for Establishing a Fuel
Efficiency Regulatory Program for Commercial Medium- and Heavy-Duty
Vehicles, October 2010, available at http://www.nhtsa.gov/staticfiles/rulemaking/pdf/cafe/NHTSA_Study_Trucks.pdf.
---------------------------------------------------------------------------
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; \19\ and
---------------------------------------------------------------------------
\19\ 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 finalizing
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) \20\ that have long governed NHTSA's
setting of fuel economy standards for passenger cars and light trucks,
although many of the same issues are considered under each of these
provisions.
---------------------------------------------------------------------------
\20\ 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
In April 2010 as mandated by Congress in EISA, the National
Research Council (NRC) under NAS 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.''
\21\ This study covers the same universe of heavy-duty vehicles that is
the focus of this final 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.
---------------------------------------------------------------------------
\21\ 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 Website
at http://www.nap.edu/catalog.php?record_id=12845 (last accessed
September 10, 2010).
---------------------------------------------------------------------------
The NAS report is far reaching in its review of the technologies
that are available and which may become available in the future to
reduce fuel consumption from medium and heavy-duty vehicles. In
presenting the full range of technical opportunities the report
includes technologies which may not be available until 2020 or even
further into the future. As such, the report provides not only a
valuable list of off the shelf technologies from which the agencies
have drawn in developing this near-term 2014-2018 program consistent
with statutory authorities and with the set of principles set forth by
the President, but the report also provides a road map the agencies can
use as we look to develop future regulations for this sector. A review
of the technologies in the NAS report makes clear that there are not
only many technologies readily available today to achieve important
reductions in fuel consumption, like the ones we used in developing the
2014-2018 program, but there are also great opportunities for even
larger reductions in the future through the development of advanced
hybrid drive systems and sophisticated engine technologies such as
Rankine waste heat recovery. The agencies will again make extensive use
of this report when we move forward to develop the next phase of
regulations for medium and heavy-duty vehicles.
Allison Transmission commented that NHTSA (implicitly, both
agencies) had improperly relied on the NAS report and failed to do
sufficient independent analysis, which Allison claimed did not meet the
statutory obligation to provide an adequate basis for the rule. First,
an agency does not improperly delegate its authority or judgment merely
by using work performed by outside parties as the factual basis for its
decision making. See U.S. Telecom Ass'n v. FCC, 359 F.3d 554, 568 (DC
Cir. 2004); United Steelworkers of Am. v. Marshall, 647 F.2d 1189,
1216-17 (DC Cir. 1980). Here, although EPA and NHTSA carefully
considered the NAS report, the agencies' consideration and use of the
report was not uncritical and the agencies exercised reasonable
independent judgment in developing the proposed and final rules.
Consistent with EISA's direction, NAS submitted a report evaluating MD/
HD fuel economy standards to NHTSA in March of 2010.
[[Page 57113]]
Indeed, many commenters argued that the agencies should have adopted
more of the NAS report recommendations. The agencies reviewed the
findings and recommendations of the NAS report when developing the
proposed rules, as was clearly intended by Congress, but also conducted
an independent study, as described throughout the record to the
proposal and summarized in Section X of the NPRM, 75 FR at 74351-56. In
conducting its analysis of the NAS report, the agencies found that
several key recommendations, such as the use of fuel efficiency
metrics, were the best approach to implementing the new program.
However, the agencies rejected other recommendations of the NAS report,
for example, by proposing separate regulation of engines and vehicles
and the regulation of large manufacturers.
(4) The NHTSA and EPA Light-Duty National GHG and Fuel Economy Program
On May 7, 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 (See 75 FR 25324). The
agencies have used the light-duty National Program as a model for this
final 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 final standards and
compliance structures, although, as discussed below, the technologies
applied to light-duty trucks are not invariably applicable to heavy-
duty pickups and vans at the same penetration rates in the lead time
afforded in this heavy-duty action. Another difference is that each
agency adopts 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 vehicles to meet a closely coordinated, harmonized national
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 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 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 final standards. These
include such approaches as improved logistics and driver training, as
discussed in the 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, relaxing 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 final standards and also provide benefits for the
existing truck fleet, furthering the public policy objectives of
addressing energy security and climate change.
(6) Environment Canada
The Government of Canada's Department of the Environment
(Environment Canada) assisted EPA's development of this rulemaking by
conducting emissions testing of heavy-duty vehicles at their test
facilities to gather data on a range of possible test cycles, and to
evaluate the impact of certain emissions reduction technologies.
Environment Canada also facilitated the evaluation of heavy-duty
vehicle aerodynamic properties at Canada's National Research Council
wind tunnel, and during coastdown testing.
We expect the technical collaboration with Environment Canada to
continue as we implement testing and compliance verification procedures
for this rulemaking. We may also 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.
Collaboration with Environment Canada is taking place under the
Canada-U.S. Air Quality Committee.
C. Summary of the Final 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).\22\ This
[[Page 57114]]
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.
---------------------------------------------------------------------------
\22\ 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 final regulations refer simply
to g/hp-hr. This is consistent with EPA's 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 inherent efficiency of the
engine as well as making changes to the vehicles to reduce the amount
of work demanded from the engine in order to move the truck down the
road. A focus on the entire vehicle is thus required. 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. For this first rulemaking, the agencies proposed a
complementary engine and vehicle approach in order to achieve the
maximum feasible near-term reductions.
NHTSA received comments on the proposal to create complementary
engine and vehicle standards. Volvo and Daimler argued that EISA
limited NHTSA's authority to the regulation of completed vehicles and
did not give NHTSA authority to regulate engines. 49 U.S.C. 32902(k)(2)
grants NHTSA broad authority to regulate this sector, stating simply
that the Secretary ``shall determine in a rulemaking proceeding how to
implement a commercial medium- and heavy-duty on-highway vehicle and
work truck fuel efficiency improvement program designed to achieve the
maximum feasible improvement,'' considering appropriateness, cost-
effectiveness, and technological feasibility. NHTSA does not believe
that this language precludes the regulation of engines, but rather
explicitly leaves the regulatory approach to the agency's expertise and
discretion. See 75 FR at 74173 n. 36. Considering the factors described
in the NPRM and in Sections III and IV below, NHTSA continues to
believe that the separate regulation of engines and vehicles is both
consistent with the agency's statutory mandate to determine how to
implement a regulatory program designed to achieve the maximum feasible
improvement and facilitates coordination with EPA's efforts to reduce
greenhouse gas emissions. The Clean Air act, of course, mandates
standards for both ``new motor vehicles'' and ``new motor vehicle
engines'', so there is no issue of authority for separate engine
standards under the EPA GHG program. CAA section 202(a)(1).
As described elsewhere in this preamble, the final standards under
the HD National Program address the complete vehicle, to the extent
practicable and appropriate under the agencies' respective statutory
authorities, through complementary engine and vehicle standards. The
agencies continue to believe that this complementary engine and vehicle
approach is the best way to achieve near term reductions from the
heavy-duty sector. However, we also recognize as did the NAS committee
and a wide range of industry and environmental commenters, that in
order to fully capture the multi-faceted synergistic aspects of engine
and vehicle design a more comprehensive complete vehicle standard may
be appropriate in the future. The agencies are committed to fully
exploring such a possibility and to developing the testing and modeling
tools necessary to enable such a regulatory approach. We intend to work
with all interested stakeholders as we move forward.
(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.\23\ Table I-2 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.
---------------------------------------------------------------------------
\23\ 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.
Table I-2--Vehicle Weight Classification
--------------------------------------------------------------------------------------------------------------------------------------------------------
Class 2b 3 4 5 6 7 8
--------------------------------------------------------------------------------------------------------------------------------------------------------
GVWR (lb)........................ 8,501-10,000 10,001-14,000 14,001-16,000 16,001-19,500 19,501-26,000 26,001-33,000 > 33,001
--------------------------------------------------------------------------------------------------------------------------------------------------------
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.\24\ 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. ``Vocational'' vehicles, which may
span Classes 2b through 8, vary widely in size, including smaller and
larger van trucks, utility ``bucket'' trucks, tank
[[Page 57115]]
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.
---------------------------------------------------------------------------
\24\ 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 standards in careful
consideration of the diversity and complexity of the heavy-duty truck
industry, as discussed next.
(2) Summary of Final 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 dividing 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 adopting related but distinct program
approaches reflecting the specific challenges that we see in these
segments. In the following paragraphs, we discuss EPA's final GHG
emission standards and NHTSA's final fuel consumption standards for the
three regulatory categories of heavy-duty vehicles and their engines.
The agencies are adopting 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 instead consider fuel consumption as the
metric for its standards. As a result, for heavy-duty pickup trucks and
vans, EPA and NHTSA are finalizing standards on a per-mile basis (g/
mile for the EPA standards, gallons/100 miles for the NHTSA standards),
as explained in Section 0 below. For heavy-duty trucks, both
combination and vocational, the agencies are adopting standards
expressed in terms of the key measure of freight movement, tons of
payload miles or, more simply, ton-miles. Hence, for EPA the final
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 final
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 adopting 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 finalizing 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 final 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.\25\ 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
will involve improvements in aerodynamics and tires and reduction in
idle operation, as well as engine-based efficiency improvements.
---------------------------------------------------------------------------
\25\ The on-highway Class 7 and 8 combination tractors
constitute the vast majority of this regulatory category, and form
the backbone of this HD National Program. A small fraction of
combination tractors are used in off-road applications and are
regulated 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 not the same entity. 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 adopting
standards for the tractors and their engines in this rulemaking, but
did not propose and are not adopting standards for trailers.
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 adopting 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,
[[Page 57116]]
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 final standards to result in the application of improved
technologies for lower GHG emissions and fuel consumption for both the
cab and the engine.
---------------------------------------------------------------------------
\26\ 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.
[GRAPHIC] [TIFF OMITTED] TR15SE11.000
Accordingly, for Class 7 and 8 combination tractors, the agencies
are each finalizing two sets of standards. For vehicle-related
emissions and fuel consumption, tractor manufacturers are required to
meet vehicle-based standards. Compliance with the vehicle standard will
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 final action. 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 also assumes the use
of a representative typical engine, rather than a vehicle-specific
engine, because engines are regulated separately. Using these inputs,
the model will 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, are
discussed in detail in Section II below and in Chapter 4 of the RIA.
(i) Final Standards for Class 7 and 8 Combination Tractors and Their
Engines
The vehicle standards that EPA and NHTSA are adopting 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 and
performance among these vehicles. The final 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. We received a number of comments
supporting this approach and no comments that provided a compelling
reason to change our approach in this final action.
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. The agencies are setting
standards beginning in 2014 model year with more stringent standards
following in 2017 model year. Table I-3 presents the agencies'
respective standards for combination tractor manufacturers for the 2017
model year. The standards represent an overall fuel consumption and
CO2 emissions reduction up to 23 percent from the tractors
and the engines installed in them when compared to a baseline 2010
model year tractor and engine without idle shutdown technology. The
standard values shown below differ somewhat from the proposal,
reflecting refinements made to the GEM in response to comments. These
changes did not impact our estimates of the relative effectiveness of
the various control technologies modeled in this final action nor the
overall cost or benefits or cost effectiveness estimated for these
final vehicle standards.
As proposed, the agencies are exempting certain types of tractors
which operate off-road to be exempt
[[Page 57117]]
from the combination tractor vehicle standards (although standards
would still apply to the engines installed in these vehicles). The
criteria for tractors to be considered off-road have been amended
slightly from those proposed, in response to public comment. The
agencies have also recognized, again in response to public comment,
that some combination tractors operate in a manner essentially the same
as vocational vehicles and have created a subcategory of ``vocational
tractors'' as a result. Vocational tractors will be subject to the
standards for vocational vehicles rather than the combination tractor
standards. See Section II.B of this preamble.
Table I-3--Heavy-Duty Combination Tractor EPA Emissions Standards (G CO2/Ton-Mile) and NHTSA Fuel Consumption
Standards (GAL/1,000 Ton-Mile)
----------------------------------------------------------------------------------------------------------------
Day cab Sleeper cab
--------------------------------------------------------
Class 7 Class 8 Class 8
----------------------------------------------------------------------------------------------------------------
2017 Model Year CO2 Grams per Ton-Mile
----------------------------------------------------------------------------------------------------------------
Low Roof............................................... 104 80 66
Mid Roof............................................... 115 86 73
High Roof.............................................. 120 89 72
----------------------------------------------------------------------------------------------------------------
2017 Model Year Gallons of Fuel per 1,000 Ton-Mile
----------------------------------------------------------------------------------------------------------------
Low Roof............................................... 10.2 7.8 6.5
Mid Roof............................................... 11.3 8.4 7.2
High Roof.............................................. 11.8 8.7 7.1
----------------------------------------------------------------------------------------------------------------
In addition, the agencies are finalizing separate performance
standards for the engines manufactured for use in these trucks. EPA's
engine-based CO2 standards and NHTSA's engine-based fuel
consumption standards are implemented using EPA's existing test
procedures and regulatory structure for criteria pollutant emissions
from medium- and heavy-duty engines. As at proposal, the final engine
standards vary depending on engine size linked to intended vehicle
service class. Consistent with our proposal, the agencies are
finalizing an interim alternative compression ignition engine standard
for model years 2014-2016. This alternative standard is designed to
provide a glide path for legacy diesel engine products that may not be
able to comply with the final engine standards for model years 2014-16
given the short (approximately 2-year) lead time of this program. We
believe this alternative standard is appropriate for a first-ever
program when the overall baseline performance of the industry is quite
varied and where the short lead time means that not every product can
be brought into compliance by 2014. The alternative standard only
applies through and including model year 2016.
Separately, EPA is adopting standards for combination tractors that
apply in use. EPA is also finalizing engine-based N2O and
CH4 standards for manufacturers of the engines used in these
combination tractors. EPA is finalizing separate engine-based standards
for N2O and CH4 because the agency believes that
emissions of these GHGs 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. NHTSA is not incorporating standards for N2O and
CH4 because these emissions do not impact fuel consumption
in a significant way. The standards that EPA is finalizing for
N2O and CH4 are less stringent than those we
proposed, reflecting new data provided to EPA in comments on the
proposal showing that the current baseline level of N2O and
CH4 emissions varies more than EPA had expected. EPA expects
that manufacturers of current engine technologies will be able to
comply with the final N2O and CH4 ``cap''
standards with little or no technological improvements; the value of
the standards will be to prevent significant increases in these
emissions as alternative technologies are developed and introduced in
the future. Compliance with the final EPA engine-based CO2
standards and the final NHTSA engine-based fuel consumption standards,
as well as the final EPA N2O and CH4 standards,
will be determined using the appropriate EPA engine test procedure, as
discussed in Sections II.B, II.D, and II.E below.
As with the other categories of heavy-duty vehicles, EPA and NHTSA
are finalizing respective standards that will apply to Class 7 and 8
tractors at the time of production (as in Table I-3, above). In
addition, EPA is finalizing separate standards that will apply for a
specified period of time in use. All of the standards for these
vehicles, as well as details about the provisions for certification and
implementation of these standards, are discussed in more detail in
Sections II, III, IV, and V below and in the RIA.
(ii) EPA's Final Air Conditioning Leakage Standard for Class 7 and 8
Combination Tractors
In addition to the final EPA tractor- and engine-based standards
for CO2 and engine-based standards for N2O, and
CH4 emissions, EPA is finalizing a separate standard to
reduce leakage of HFC refrigerant from cabin air conditioning (A/C)
systems from combination tractors, to apply to the tractor
manufacturer. This standard is independent of the CO2
tractor standard, as discussed below in Section II.E.5. Because the
current refrigerant used widely in all these systems has a very high
global warming potential, EPA is concerned about leakage of
refrigerant.\27\
---------------------------------------------------------------------------
\27\ The global warming potential for HFC-134a refrigerant of
1430 used in this program is consistent with the Intergovernmental
Panel on Climate Change Fourth Assessment Report.
---------------------------------------------------------------------------
Because the interior volume to be cooled for most tractor cabins is
similar to that of light-duty vehicles, the size and design of current
tractor A/C systems is also very similar. The compliance approach for
Class 7 and 8 tractors is therefore similar to that in the light-duty
rule in that these standards are design-based. Manufacturers will
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 final 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
[[Page 57118]]
generate credits towards the CO2 g/mi standard, and EPA took
into account the expected use of such credits in determining the
stringency of the CO2 emissions standards. In the HD
National Program, EPA is requiring that manufacturers actually meet a
standard--as opposed to having the opportunity to earn a credit--for A/
C refrigerant leakage. Thus, refrigerant leakage control is not
separately accounted for in the final heavy-duty 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 to the
expression of the leakage rate. The light-duty A/C leakage standard is
expressed in terms of grams per year. For EPA's heavy-duty program,
however, because of the wide variety of system designs and
arrangements, a one-size-fits-all gram per year standard would not be
appropriate, so EPA is adopting a standard in terms of annual mass
leakage rate for A/C systems with refrigerant capacities less than or
equal to 733 grams and percent of total refrigerant leakage per year
for A/C systems with refrigerant capacities greater than 733 grams. The
percent of total refrigerant leakage per year requires the total
refrigerant capacity of the A/C system to be taken into account in
determining compliance. EPA believes that this approach--a standard
instead of a credit, and basing the standard on percent or mass of
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 will be
determined through a showing by the tractor manufacturer that its A/C
system incorporates a combination of low-leak technologies sufficient
to meet the leakage rate of the applicable standard. The ``menu'' of
technologies is very similar to that established in the light-duty
2012-2016 MY vehicle rule.\28\
---------------------------------------------------------------------------
\28\ EPA has approved an alternative refrigerant, HFO-1234yf,
which has a very low GWP, for use in light-duty vehicle mobile A/C
systems. The final heavy-duty vehicle A/C leakage standard is
designed to account for use of an alternative, low-GWP refrigerant.
If in the future this refrigerant is approved for heavy-duty
applications and if it becomes widespread as a substitute for HFC-
134a in heavy-duty vehicle mobile A/C systems, EPA may propose to
revise or eliminate the leakage standard.
---------------------------------------------------------------------------
Finally, the agencies did not propose and are not adopting 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.
A more detailed discussion of A/C related issues is found in
Section II.E.5 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 rule, and the agencies are not adopting 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
these rules as ``HD pickups and vans'') together emit about 15 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
pickup 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 adopt 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 adopt corresponding gallons per 100 mile
fuel consumption standards that are likewise based on the whole
vehicle. This complete vehicle approach being adopted 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 finalizing, as detailed in Section II.C. These
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 will 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).\29\
---------------------------------------------------------------------------
\29\ 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).\30\ 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 work-based metric serves as a better
attribute than the footprint attribute utilized in the light-duty
vehicle
[[Page 57119]]
rulemaking. Work-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 pickup or van. EPA and NHTSA are therefore
finalizing standards for HD pickups and vans based on a ``work factor''
attribute that combines their payload and towing capabilities, with an
added adjustment for 4-wheel drive vehicles. The agencies received a
number of comments supporting this approach arguing, as the agencies
had, that this approach was an effective way to encourage technology
development and to appropriately reflect the utility of work vehicles
while setting a consistent metric measure of vehicle performance.
---------------------------------------------------------------------------
\30\ EISA requires CAFE standards for passenger cars and light
trucks to be attribute-based; See 49 U.S.C. 32902(b)(3)(A).
---------------------------------------------------------------------------
As proposed, the agencies are adopting provisions such that each
manufacturer's fleet average standard will be based on production
volume-weighting of target standards for all vehicles that in turn are
based on each vehicle's work factor. These target standards are taken
from a set of curves (mathematical functions), presented in Section
II.C below and in Sec. 1037.104. EPA is also phasing in the
CO2 standards gradually starting in the 2014 model year, at
15-20-40-60-100 percent of the model year 2018 standards stringency
level in model years 2014-2015-2016-2017-2018, respectively. The phase-
in takes the form of a set of target standard curves, with increasing
stringency in each model year, as detailed in Section II.C. The final
EPA standards 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. The rule contains separate standards for
diesel and gasoline heavy duty pickups and vans for reasons described
in Section II.C below. EPA is also finalizing a compliance alternative
whereby manufacturers can phase in different percentages: 15-20-67-67-
67-100 percent of the model year 2019 standards stringency level in
model years 2014-2015-2016-2017-2018-2019, respectively. This
compliance alternative parallels and is equivalent to NHTSA's first
alternative described below.
NHTSA is allowing manufacturers to select one of two fuel
consumption standard alternatives for model years 2016 and later. The
first alternative defines individual gasoline vehicle and diesel
vehicle fuel consumption target curves that will not change for model
years 2016-2018, and are equivalent to EPA's 67-67-67-100 percent
target curves in model years 2016-2017-2018-2019, respectively. The
target curves for this alternative are presented in Section II.C. The
second alternative uses target curves that are equivalent to the EPA's
40-60-100 percent target curves in model years 2016-2017-2018,
respectively. 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 finalizing, to rely on
the same product plans to satisfy either of these two alternatives, and
also EPA requirements. If a manufacturer cannot meet an applicable
standard in a given model year, it may make up its shortfall by
overcomplying in a subsequent year, called reconciling a credit
deficit. NHTSA is also allowing manufacturers to 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 agencies received a number of comments including from the
Senate authors and supporters of the Ten-in-Ten Fuel Economy Act
suggesting that the standards for heavy-duty pickups and vans should be
made more stringent for gasoline vehicles and that the phase-in timing
of the standards should be accelerated to the 2016 model year (from
2018). We also received comments arguing that the proposed standards
were aggressive and could only be met given the phase-in schedules
proposed by the agencies. In response to these comments, we reviewed
again the technology assessments from the 2010 NAS report, our own
joint light-duty 2012-2016 rulemaking, and information provided by the
commenters relevant to the stringency of these standards. After
reviewing all of the information, we continue to conclude that the
proposed standards and associated phase-in schedules represent
technically stringent but reasonable standards considering the
available lead time and costs to bring the necessary technologies to
market and our own assessments of the efficacy of the technologies when
applied to heavy-duty pickup trucks and vans. Further detail on the
feasibility of the standards and the agencies' choices among
alternative standards is found in Section III.C below.
The Senate authors and supporters of the Ten-in-Ten Fuel Economy
Act sent a letter to the agencies encouraging the agencies to finalize
a fuel economy labeling requirement for heavy-duty pickups and
vans.\31\ The agencies recognize that consumer information in the form
of a fuel efficiency label can be a valuable tool to help achieve our
goals, and we note that the agencies have just recently finalized a new
fuel economy label for passenger cars and light trucks. See 76 FR at
39478. That rulemaking effort focused solely on modifying an existing
label and was a multi-year process with significant public input. As we
did not propose a consumer label for heavy-duty pickups and vans in
this action and have not appropriately engaged the public in developing
such a label, we are not prepared to finalize a consumer-based label in
this action. However, we do intend to consider this issue as we begin
work on the next phase of regulations, as we recognize that a consumer
label can play an important role in reducing fuel consumption and GHG
emissions.
---------------------------------------------------------------------------
\31\ See Docket EPA-HQ-OAR-2010-0162.
---------------------------------------------------------------------------
The form and stringency of the EPA and NHTSA standards 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 are likely to 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.
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
[[Page 57120]]
device or container attached. We are generally regulating these
vehicles as Class 2b through 8 vocational vehicles but are also
allowing manufacturers the option to choose to comply with heavy-duty
pickup or van standards, as described in Section I.C.(2)(c). Although,
as with vocational vehicles generally, we have little information on
baseline aerodynamic performance and opportunities for improvement, 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 including provisions that will allow manufacturers to include these
vehicles, as well as some Class 4 and 5 vehicles, to be regulated under
the chassis-based HD pickup and van program (i.e. subject to the
standards for HD pickups and vans), rather than the vocational vehicle
program. These provisions are described in Section V.B(1)(e).
In addition to the EPA CO2 emission standards and the
NHTSA fuel consumption standards for HD pickups and vans, EPA is also
finalizing 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 finalizing standards that will apply to HD
pickups and vans in use. All of the standards for these HD pickups and
vans, as well as details about the 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,\32\ tow
trucks, among others. These vehicles and their engines contribute
approximately 20 percent of today's heavy-duty truck sector GHG
emissions.
---------------------------------------------------------------------------
\32\ NHTSA's final fuel consumption standards will not apply to
recreational vehicles, as discussed in earlier in this preamble
section.
---------------------------------------------------------------------------
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 proposed that in this vocational vehicle category the
proposed GHG and fuel consumption standards apply to chassis
manufacturers. Chassis manufacturers play a central role in the
manufacturing process. The product they produce--the chassis with
engine and transmission--includes the primary technologies that affect
GHG emissions and fuel consumption. They also constitute a much more
limited group of manufacturers for purposes of developing and
implementing a regulatory program. The agencies believe that a focus on
the body manufacturers would be much less practical, since they
represent a much more diverse set of manufacturers, many of whom are
small businesses. Further, the part of the vehicle that they add
affords very few opportunities to reduce GHG emissions and fuel
consumption (given the limited role that aerodynamics plays in many
types of lower speed and stop-and-go operation typically found with
vocational vehicles.) Therefore, the agencies proposed that the
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 requested comment on the
proposed focus on chassis manufacturers.
Volvo and Daimler commented that the EISA does not speak to the
regulation of subsystems, such as engines or incomplete vehicles, and
argued that on the other hand, Section 32902(k)(2) prescribes the
regulation of vehicles. Volvo further stated that precedent for the
regulation of complete vehicles exists in the light-duty fuel economy
rule. As noted above, NHTSA does not believe that EISA mandates a
particular regulatory approach, but rather gives the agency wide
latitude and explicitly leaves that determination to the agency. NHTSA
also notes that its heavy-duty rule creates a new fuel efficiency
program for which the light-duty program does not necessarily serve as
a useful precedent for considerations of its structure. Unlike the
light-duty fuel economy program, MD/HD vehicles are produced in widely
diverse stages. Further, given the MD/HD market structure, where the
complete vehicle manufacturers are numerous, diverse, and often small
businesses, the regulation of complete vehicles would create unique
difficulties for the application of appropriate and feasible
technologies. These same considerations justify EPA's determination,
pursuant to CAA section 202 (a), to regulate only chassis manufacturers
in this first stage of GHG rules for the heavy-duty sector. NHTSA also
notes that this rule does not represent the first time that the agency
has regulated incomplete vehicles. Rather, incomplete vehicles have a
history of regulation under the Federal Motor Vehicle Safety
Standards.\33\ For this first phase of the HD National Program, NHTSA
and EPA believe that given the complexity of the manufacturing process
for vocational vehicles, and given the wide range of entities that
participate in that process, vehicle fuel consumption standards would
be most appropriately applied to chassis manufacturers and not to body
builders.
---------------------------------------------------------------------------
\33\ See 49 U.S.C. 567.5 and 568.4.
---------------------------------------------------------------------------
The agencies continue to believe that regulation of the chassis
manufacturers for this vocational vehicle category will achieve the
maximum feasible improvement in fuel efficiency for purposes of EISA
and appropriate emissions reductions for purposes of the CAA.
Therefore, consistent with our proposal the final standards in this
vocational vehicle category 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. 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 finalizing two sets of
standards for Class 2b-8 vocational vehicles. For vehicle-related
emissions and fuel consumption, the agencies are adopting standards for
chassis manufacturers: EPA CO2 (g/ton-mile) standards and
NHTSA fuel consumption (gal/1,000 ton-mile) standards). While the
agencies believe that a freight-based metric is broadly appropriate for
vocational vehicles
[[Page 57121]]
because the vocational vehicle population is dominated by freight
trucks and maintain that it is appropriate for the first phase of the
program, the agencies may consider other metrics for future phases of a
HD program. Manufacturers will use GEM, the same customized vehicle
simulation model used for Class 7 and 8 tractors, to determine
compliance with the vocational vehicle standards finalized in this
action. The primary manufacturer-generated input into the GEM for this
category of trucks will 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 for vocational
vehicles. The model also assumes the use of a typical representative,
compliant engine in the simulation, resulting in an overall value for
CO2 emissions and one for fuel consumption. This is done for
the same reason as for combination tractors. As is the case for
combination tractors, the manufacturers of the engines intended for
vocational vehicles will be subject to separate engine-based standards.
(i) Final Standards for Class 2b-8 Vocational Vehicles and Their
Engines
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, EPA and NHTSA are
adopting separate standards for the manufacturers of engines used in
Class 2b-8 vocational vehicles (the same approach as for combination
tractors and engines intended for use in those tractors). EPA's final
engine-based CO2 standards and NHTSA's final engine-based
fuel consumption standards vary based on the expected weight class and
usage of the truck into which the engine will be installed. Tire
rolling resistance is closely related to the weight of the vehicle.
Therefore, we are adopting vehicle-based standards for these trucks
which vary according to one key attribute, GVWR. For this initial HD
rulemaking, we are adopting standards 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 final vehicle-based standards because they parallel
the general divisions among key engine characteristics, as discussed in
Section II.
The agencies are also finalizing an interim alternative compression
ignition (diesel) engine standard for model years 2014-2016, again
analogous to the alternative standards for compression ignition engines
use in combination tractors. The need for this provision and our
considerations in adopting it are the same for the engines used in
vocational vehicles as for the engines used in combination tractors. As
we proposed, these alternative standards will only be available through
model year 2016. In addition, manufacturers that use the interim
alternative diesel engine standards for model years 2014-2016 under the
EPA program must use equivalent fuel consumption standards under the
NHTSA program.
For the 2014 to 2016 model years, manufacturers may also choose to
meet alternative engine standards that are phased-in over the model
years to coincide with new EPA On-Board Diagnostic (OBD) requirements
applicable for these same model years. See Sections II.B and II.D
below.
The agencies received a significant number of comments including
from the Senate authors and supporters of the Ten-in-Ten Fuel Economy
Act arguing that our proposed standards for vocational vehicles did not
reflect all of the technologies identified in the 2010 NAS report. The
commenters encouraged the agencies to expand the program to bring in
additional reductions through the use of new transmission technologies,
vehicle weight reductions and hybrid drivetrains. In general, the
agencies agree with the commenters' central contention that there are
additional technologies to improve the fuel efficiency of vocational
vehicles. As discussed later, we are finalizing provisions to allow new
technologies to be brought into the program through the innovative
technology credit program. More specifically, 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. (See Sections I.E and IV
below.) However, we are not finalizing standards that are premised on
the use of these additional technologies because we have not been able
to develop the test procedures, regulatory mechanisms and baseline
performance data necessary to adopt a more comprehensive approach to
controlling fuel efficiency and GHG emissions from vocational vehicles.
In concept, the agencies would need to know the baseline weight,
aerodynamic performance, and transmission configuration for the wide
range of vocational vehicles produced today. We do not have this
information even for relatively small portions of this market (e.g.
concrete mixers) nor are we well informed regarding the potential
tradeoffs to changes to vehicle utility that might exist for changes to
concrete mixer designs in response to a regulation. Nor did the
commenters provide any such information. Absent this information and
the necessary regulatory tools, we believe the standards we are
finalizing for vocational vehicles represent the most appropriate
standards for this segment during the model years of the first phase of
the program. We intend to address fuel consumption and GHG emissions
from these vehicles in a more comprehensive manner through future
regulation and look forward to working with all stakeholders on this
important segment in the future.
The agencies are setting standards beginning in the 2014 model year
and establishing more stringent standards in the 2017 model year. Table
I-4 presents EPA's final CO2 standards and NHTSA's final
fuel consumption standards for chassis manufacturers of Class 2b
through Class 8 vocational vehicles for the 2017 model year. The 2017
model year standards represent a 6 to 9 percent reduction in
CO2 emissions and fuel consumption over a 2010 model year
vehicle.
Table I-4--Final 2017 Class 2b-8 Vocational Vehicle EPA CO2 Standards and NHTSA Fuel Consumption Standards
----------------------------------------------------------------------------------------------------------------
Light heavy-duty Medium heavy-duty Heavy heavy-duty
Class 2b-5 Class 6-7 Class 8
----------------------------------------------------------------------------------------------------------------
EPA CO2 (gram/ton-mile) Standard Effective 2017 Model Year
----------------------------------------------------------------------------------------------------------------
CO2 Emissions.......................................... 373 225 222
----------------------------------------------------------------------------------------------------------------
[[Page 57122]]
NHTSA Fuel Consumption (gallon per 1,000 ton-mile) Standard Effective 2017 Model Year
----------------------------------------------------------------------------------------------------------------
Fuel Consumption....................................... 36.7 22.1 21.8
----------------------------------------------------------------------------------------------------------------
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's final N2O and CH4
standards cover manufacturers of the engines to be used in vocational
vehicles. EPA did not propose, nor are we adopting separate vehicle-
based standards for these GHGs. As for the engines used in Class 7 and
8 tractors, we are finalizing a somewhat higher N2O and
CH4 emission standards reflecting new data submitted to the
agencies during the public comment period. EPA expects that
manufacturers of current engine technologies will be able to comply
with the final ``cap'' standards with little or no technological
improvements; the value of the standards is that they will prevent
significant increases in these emissions as alternative technologies
are developed and introduced in the future. Compliance with the final
EPA engine-based CO2 standards and the final NHTSA fuel
consumption standards, as well as the final EPA N2O and
CH4 standards, will 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 adopting standards that apply to Class 2b-8 vocational
vehicles at the time of production, and EPA is adopting standards for a
specified period of time in use. All of the standards for these trucks,
as well as details about the final provisions for certification and
implementation of these standards, are discussed in more detail later
in this notice and in the RIA.
EPA did not propose, nor is it adopting A/C refrigerant leakage
standards for Class 2b-8 vocational vehicles, 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.
(d) What manufacturers are not covered by the final standards?
The NPRM proposed to defer temporarily 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 (SBA). 13 CFR 121.201 defines a
small business by the maximum number of employees; for example, this is
currently 1,000 for heavy-duty vehicle manufacturing and 750 for engine
manufacturing.\34\ The agencies stated that they would 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 manufacturers. To ensure that the
agencies are aware of which companies would be exempt, the agencies
proposed to require that such entities submit a declaration describing
how it qualifies as a small entity under the provisions of 13 CFR
121.201 to EPA and NHTSA as prescribed in Section V below.
---------------------------------------------------------------------------
\34\ See Sec. 1036.150 and Sec. 1037.150
---------------------------------------------------------------------------
EPA and NHTSA were not aware of any manufacturers of HD pickups and
vans that meet these criteria. For each of the other categories and for
engines, the agencies identified a small number of manufacturers that
would appear to qualify as small businesses under the SBA size
criterion, which were estimated to comprise a negligible percentage of
the U.S. market.\35\ Therefore, the agencies believed 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. The agencies proposed to
consider appropriate GHG emissions and fuel consumption standards for
these entities as part of a future regulatory action.
---------------------------------------------------------------------------
\35\ Two heavy-duty combination tractor and ten chassis
manufacturers each comprising less than 0.5 percent of the total
tractor and vocational market based on Polk Registration Data from
2003 through 2007, and three engine manufacturing entities based on
company information included in Hoover's, comprising less than 0.1
percent of the total heavy-duty engine sales in the United States
based on 2009 and 2010 EPA certification information.
---------------------------------------------------------------------------
The Institute for Policy Integrity (IPI) commented that the small
business exemption proposed in the NPRM was based on the improper
framework of whether the exemption would have a negligible impact, and
did not adequately explain why the regulation of small businesses would
face special compliance and administrative burdens. IPI argued that the
only proper basis for this exemption would be if the agencies could
explain how these burdens create costs that exceeded the benefits of
regulation.
NHTSA believes that developing standards that are ``appropriate,
cost-effective, and technologically feasible'' under 49 U.S.C.
32902(k)(2) includes the authority to exclude certain manufacturers if
their inclusion would work against these statutory factors. Similarly,
under section 202(a) of the CAA, EPA may reasonably choose to defer
regulation of industry segments based on considerations of cost, cost-
effectiveness and available lead time for standards. As noted above,
small businesses make up a very small percentage of the market and are
estimated to have a negligible impact on the emissions and fuel
consumption goals of this program. The short lead time before the
CO2 standards take effect, the extremely small fuel savings
and emissions contribution of these entities, and the potential need to
develop a program that would be structured differently for them (which
would require more time to determine and adopt), all led to the
decision that the inclusion of small businesses would not be
appropriate at this time. Therefore, the final rule exempts small
businesses as proposed.
Volvo and EMA stated that by exempting small businesses based on
the definition from SBA, the rules would create a competitive advantage
for small businesses over larger entities. EMA commented that the
exemption should not apply to market segments where a small business
has a significant share of a particular HD market. Volvo argued that
the exempted businesses could expand their product offerings or
[[Page 57123]]
sell vehicles on behalf of larger entities, thereby inappropriately
increasing the scope of the exclusion. The agencies anticipate that the
gain a manufacturer might achieve by restructuring its practices and
products to circumvent the standard (which for vocational vehicles
simply means installing low rolling resistance tires) in the first few
years of this program will be outweighed by the costs, particularly as
small businesses anticipate their potential inclusion in the next
rulemaking.
Volvo also commented that the agencies should elaborate on the
requirements for the exemption in greater detail. The agencies agree
that this may help to clarify the process. As suggested by Volvo, the
agencies will consider affiliations to other companies and evidence of
spin-offs for the purpose of circumventing the standards in determining
whether a business qualifies as a small entity for this exclusion. Each
declaration must be submitted in writing to EPA and NHTSA as prescribed
in Section V below. As the agencies gain more experience with this
exemption, these clarifications may be codified in the regulatory text
of a future rulemaking.
Volvo further commented that the agencies were adopting an
exemption of ``small businesses'' in order to avoid doing a Small
Business Regulatory Enforcement Fairness Act (SBREFA) and Regulatory
Flexibility Act (RFA) analysis. The agencies would like to reiterate
that they have decided not to include small businesses at this time due
to the factors described above. The discussion on an RFA analysis is
laid out in Section XII(4).
The agencies continue to believe that deferring the standards for
these companies at this time will have a negligible impact on the GHG
emission reductions and fuel consumption reductions that the program
would otherwise achieve. Therefore, the final rules include the small
business exemption as proposed. The specific deferral provisions are
discussed 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.
(e) Light-Duty Vehicle CH4 and N2O Standards
Flexibility
After finalization of the N2O and CH4
standards for light-duty vehicles as part of the 2012-2016 MY program,
some manufacturers raised concerns that they may have difficulty
meeting those standards across their light-duty vehicle fleets. In
response to these concerns, as part of the same Federal Register notice
as the heavy-duty proposal, EPA requested comments on additional
options for manufacturers to comply with light-duty vehicle
N2O and CH4 standards to provide additional near-
term flexibility. Commenters providing comment on this issue supported
additional flexibility for manufacturers. EPA is finalizing provisions
allowing manufacturers to use CO2 credits, on a
CO2-equivalent basis, to meet the N2O and
CH4 standards, which is consistent with many commenters'
preferred approach. Manufacturers will have the option of using
CO2 credits to meet N2O and CH4
standards on a test group basis as needed for MYs 2012-2016.
(f) Alternative Fuel Engines and Vehicles
The agencies believe that it is also appropriate to take steps to
recognize the benefits of flexible-fueled vehicles (FFVs) and dedicated
alternative-fueled vehicles. In the NPRM, EPA proposed to determine the
emissions performance of dedicated alternative fuel engines and pickup
trucks and vans by measuring tailpipe CO2 emissions. NHTSA
proposed to determine fuel consumption performance of non-electric
dedicated alternative fuel engines and pickup trucks and vans by
measuring fuel consumption with the alternative fuel and then
calculating a petroleum equivalent fuel consumption using a Petroleum
Equivalency Factor (PEF) that is determined by the Department of
Energy. NHTSA proposed to treat electric vehicles as having zero fuel
consumption, comparable to the EPA proposal. Both agencies proposed to
determine FFV performance in the same way as for GHG emissions for
light-duty vehicles, with a 50-50 weighting of alternative and
conventional fuel test results through MY 2015, and a weighting based
on demonstrated fuel use in the real world after MY 2015 (defaulting to
an assumption of 100 percent conventional fuel use). This approach was
considered to be a reasonable and logical way to properly credit
alternative fuel use in FFVs in the real world without imposing a
difficult burden of proof on manufacturers. However, unlike in the
light-duty rule, the agencies do not believe it is appropriate to
create a provision for additional incentives similar to the 2012-2015
light-duty incentive program (See 49 U.S.C. 32904) because the HD
sector does not have the incentives mandated in EISA for light-duty
FFVs, and so has not relied on the existence of such credits in
devising compliance strategies for the early model years of this
program. See 74 FR at 49531. In fact, manufacturers have not in the
past produced FFV heavy-duty vehicles. On the other hand, the agencies
sought 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.\36\ See 75 FR at 74198.
---------------------------------------------------------------------------
\36\ E85 is a blended fuel consisting of nominally 15 percent
gasoline and 85 percent ethanol.
---------------------------------------------------------------------------
The agencies received several comments from natural gas vehicle
(NGV) interests arguing for greater crediting of NGVs than the proposed
approach would have provided. Clean Energy, Hayday Farms, Border
Valley, AGA, Ryder, Encana, and a group of NGV interests commented that
the NPRM ignored Congress' intent to incentivize the use of NGVs by not
including the conversion factor that exists in the light-duty statutory
language. The commenters argued that Congress' intent to incentivize
NGVs is evident in the formula contained in 49 U.S.C. 32905, which
deems a gallon equivalent of gaseous fuel to have a fuel content of
0.15 gallon of fuel. The commenters also argued that Congress
implicitly intended NGVs to be incentivized in this rulemaking, as
evidenced by the incentives in the light-duty statutory text. AGA and
Hayday suggested that the agencies were not including the NGV incentive
from light-duty because Congress did not explicitly include it in 49
U.S.C. 32902(k), and argued that this would contradict the agencies'
inclusion of other incentives similar to the light-duty rule.
The American Trucking Association expressed support for estimating
natural gas fuel efficiency by using carbon emissions from natural gas
rather than energy content to estimate fuel consumption. ATA explained
that two vehicles can achieve the same fuel efficiency, yet one
operated on natural gas would have a lower carbon dioxide emissions
rate. A natural gas conversion factor that uses carbon content versus
energy content is a more appropriate method for calculating fuel
consumption, in the commenter's view. A number of other groups
commented on the appropriate method to use in establishing fuel
consumption from alternative fueled vehicles. A group of NGV interests,
Ryder, Border Valley Trading, Waste Management, Robert Bosch and the
Blue Green Alliance encouraged the agencies to adopt the 0.15
conversion factor in estimating fuel consumption for FFVs and
alternative fuel vehicles finalized in the light-duty
[[Page 57124]]
2012-2016 MY vehicle standards. The suggested incentive would
effectively reduce the calculated fuel consumption for FFVs and
alternative fuel vehicles by a factor of 85 percent. The commenters
argued that the incentive is needed for heavy-duty vehicles to
encourage the use of natural gas and to reduce the nation's dependence
on petroleum.
The agencies reassessed the options for evaluating the
CO2 and fuel consumption performance of alternative fuel
vehicles in response to comments and because the agencies recognized
that the treatment of alternate fuel vehicles was one of the few
provisions in the proposal where the EPA and NHTSA programs were not
aligned. The agencies conducted an analysis comparing fuel consumption
calculated based on CO2 emissions \37\ to fuel consumption
calculated based on gasoline or diesel energy equivalency to evaluate
impacts of a consistent consumption measurement for all vehicle classes
covered by this program and to further understand how alternative fuels
would be impacted by this measurement methodology. In particular the
agencies evaluated how measuring consumption via CO2
emissions would hinder or benefit the application of alternative fuels
versus following similar alternative fuel incentivizing programs
provided via statute for the Agency's light-duty programs. The analysis
showed measuring a vehicle's CO2 output converted to fuel
consumption provided a fuel consumption measurement benefit to those
vehicles operating on fuels other than gasoline or diesel. For CNG, LNG
and LPG the benefit is approximately 19 percent to 24 percent, for
biodiesel and ethanol blends the benefit is approximately 1 percent to
3 percent, and for electricity and hydrogen fuels the benefit is 100
percent benefit, as fuel consumption is zero. The agencies also
considered that the EPA Renewable Fuel Standard,\38\ a separate
program, requires an increase in the volume of renewable fuels used in
the U.S. transportation sector. For the fuels covered by the Renewable
Fuels Standard additional incentives are not needed in this regulation
given the large volume increases required under the Renewable Fuel
Standard.
---------------------------------------------------------------------------
\37\ Fuel consumption calculated from measured CO2
using conversion factors of 8,887 g CO2/gallon for
gasoline (for alternative fuel engines that are derived from
gasoline engines), and 10,180 g CO2/gallon for diesel
fuel (for alternative fuel engines that are derived from diesel
engines).
\38\ EPA is responsible for developing and implementing
regulations to ensure that transportation fuel sold in the United
States contains a minimum volume of renewable fuel. The RFS program
was created under the Energy Policy Act (EPAct) of 2005, and
expanded under the Energy Independence and Security Act (EISA) of
2007.
---------------------------------------------------------------------------
The agencies continue to believe that alternative-fueled vehicles,
including NGVs, provide fuel consumption benefits that should be, and
are, accounted for in this program. However, the agencies do not agree
with the commenters' claim that the NGV incentive contained in EISA,
and reflected in the light-duty program, is an explicit Congressional
directive that must also be applied to the heavy-duty program, nor that
the light-duty incentive for NGVs should be interpreted as an implicit
Congressional directive for NGVs to be comparably incentivized in the
heavy-duty program. Further, the agencies believe that the fuel
consumption benefits that alternative fuel vehicles would obtain
through measuring CO2 emissions for the EPA program and
converting CO2 emissions to fuel consumption for the NHTSA
program accurately reflects their energy benefits. This accurate
accounting, in conjunction with the volumetric increases required by
the Renewable Fuels Standard, provides sufficient incentives for these
vehicles. The agencies continue to believe that the light-duty
conversion factor is not appropriate for this program. Instead, the
agencies are finalizing measuring the performance of alternative fueled
vehicles by measuring CO2 emissions for the EPA program and
converting CO2 emissions to fuel consumption for the NHTSA
program. The agencies are also finalizing measuring FFV performance
with a 50-50 weighting of alternative and conventional fuel test
results through MY 2015, and an agency- or 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).
The agencies believe this structure accurately reflects the fuel
consumption of the vehicles while at the same time providing an
incentive for the alternative fuel use. (For example, natural gas heavy
duty engines perform 20 to 30 percent better than their diesel and
gasoline counterparts from a CO2 perspective, and so meet
the standards adopted in these rules without cost, and indeed will be
credit generators without cost.) We believe this is a substantial
enough advantage to spur the market for these vehicles. The calculation
at the same time does not overestimate the benefit from these
technologies, which could reduce the effectiveness of the regulation.
Therefore, the final rules do not include the light-duty 0.15
conversion factor for NGVs. The agencies would like to clarify that the
decision not to include an NGV incentive was based on this policy
determination, not on a belief that incentives present in the light-
duty rule could not be developed for the heavy-duty sector because they
were not explicitly included in Section 32902(k).
NHTSA recognizes that EPCA/EISA promotes incentives for alternative
fueled vehicles for different purposes than does the CAA, and that
there may be additional energy and national security benefits that
could be achieved through increasing fleet percentages of natural gas
and other alternative-fueled vehicles. More alternative-fueled vehicles
on road would arguably displace petroleum-fueled vehicles, and thereby
increase both U.S. energy and national security by reducing the
nation's dependence on foreign oil.
However, a rule that adopts identical incentive provisions reduces
industry reporting burdens and NHTSA's monitoring burden. In addition,
the agencies are concerned that providing greater incentives under
EPCA/EISA might lead to little increased production of alternative
fueled vehicles. If this were the case, then the benefits of
harmonization could outweigh any potential gains from providing greater
incentives. It is also consistent with Executive Order 13563.\39\
---------------------------------------------------------------------------
\39\ EO 13563 states that an agency shall ``tailor its
regulations to impose the least burden on society, consistent with
obtaining regulatory objectives, taking into account, among other
things, and to the extent practicable, the costs of cumulative
regulations,'' and ``promote such coordination, simplification, and
harmonization'' as will reduce redundancy, inconsistency, and costs
of multiple regulatory requirements.
---------------------------------------------------------------------------
Adopting the same incentive provisions could also have benefits for
the public, the regulated industries, and the agencies. This approach
allows manufacturers to project clear benefits for the application of
GHG-reduction and fuel efficiency technologies, thus spurring their
adoption.
This combined rulemaking by EPA and NHTSA is designed to regulate
two separate characteristics of heavy duty vehicles: Greenhouse gas
emissions (GHG) and fuel consumption. In the case of diesel or gasoline
powered vehicles, there is a one-to-one relationship between these two
characteristics. Each gallon of gasoline combusted by a truck engine
generates approximately 8,887 grams of CO2; and each gallon
of diesel fuel burned generates about 10,180 grams of CO2.
Because no available technologies reduce tailpipe CO2
emissions per gallon of fuel combusted, any rule that limits tailpipe
CO2 emissions is
[[Page 57125]]
effectively identical to a rule that limits fuel consumption.
Compliance by a truck manufacturer with the NHTSA fuel economy rule
assures compliance with the EPA rule, and vice versa.
For alternatively fueled vehicles, which use no petroleum, the
situation is different. For example, a natural gas vehicle that
achieves approximately the same fuel economy as a diesel powered
vehicle would emit 20 percent less CO2; and a natural gas
vehicle with the same fuel economy as a gasoline vehicle would emit 30
percent less CO2. Yet natural gas vehicles consume no
petroleum. To the extent that the goal of the NHTSA fuel economy
portion of this rulemaking is to curb petroleum use, crediting natural
gas vehicles with zero fuel consumption per mile could contribute to
achieving that goal. Similar differences between oil consumption and
greenhouse gas emissions would apply to electric vehicles, hybrid
electric vehicles, and biofuel-powered vehicles.
NHTSA notes that the purpose of EPCA/EISA is not merely to curb
petroleum use--it is more generally to secure energy independence,
which can be achieved by reducing petroleum use. The value of
incentivizing natural gas, electric vehicles, biofuels, hydrogen, or
other alt fuel vehicles for energy independence is limited to the
extent that the alternative fuels may be imported.
In the recent rulemaking for light-duty vehicles, EPA and NHTSA
have followed the light duty specific statutory provision that treats
one gallon of alternative fuel as equivalent to 0.15 gallons of
gasoline until MY 2016, when performance on the EPA CO2
standards is measured based on actual emissions. 75 FR at 25433.
Following that MY 2012-2015 approach in this heavy duty program would
mean that, for example, a natural gas powered truck would have
attributed to it 20 percent less CO2 emissions than a
comparable diesel powered truck, but 85 percent less fuel consumption.
Engine manufacturers with a relatively large share of alternative-fuel
products would likely have an easier time complying with NHTSA's
average fuel economy standard than with EPA's GHG standard. Similarly,
engine manufacturers with a relatively small share of alternative-fuel
products would have a relatively easier time complying with EPA's
CO2 standard than with NHTSA's fuel economy standard. In
that way, the rule would not differ from the light duty vehicle rules.
Instead, in this program, EPA and NHTSA are establishing identical
rules. Fuel consumption for alternatively-powered vehicles will be
calculated according to their tailpipe CO2 emissions. In
that way, there will be a one-to-one relationship between fuel economy
and tailpipe CO2 emissions for all vehicles. However, this
might not result in a one-to-one relationship between petroleum
consumption and GHG emissions for all vehicles. On the other hand, it
could have the disadvantage of not doing more to encourage some cost-
effective means of reducing petroleum consumption by trucks, and the
accompanying energy security costs. By attributing to natural gas
engines only 20 percent less fuel consumption than comparable diesel
engines, because they emit 20 percent less CO2, rather than
attributing to them a much larger percentage reduction in fuel
consumption, because they use no petroleum, this uniform approach to
rulemaking provides less of an incentive for technologies that reduce
consumption of petroleum-based fuels.
In the future, the Agencies will consider the possibility of
proposing standards in a way that more fully reflects differences in
fuel consumption and greenhouse gas emissions. Under such standards,
any given vehicle might ``over-comply'' with the fuel economy standard,
but might ``under-comply'' with the greenhouse gas standard. Therefore,
in meeting the fleet-wide requirements, a manufacturer would need to
meet both standards using all available options, such as credit trading
and technology mix. Allowing for two distinct standards might enable
manufacturers to achieve the twin goals of reducing greenhouse gas
emissions and decreasing consumption of petroleum-based fuels in a more
cost-effective manner.
D. Summary of Costs and Benefits of the HD National Program
This section summarizes the projected costs and benefits of the
final NHTSA fuel consumption and EPA GHG emissions standards. These
projections helped to inform the agencies' choices among the
alternatives considered and provide further confirmation that the final
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, fuel
savings, and benefits of the final GHG and fuel consumption standards.
Table I-5 shows estimated lifetime discounted program costs (including
technological outlays), fuel savings, and benefits for all heavy-duty
vehicles projected to be sold in model years 2014-2018 over these
vehicles' lives. The benefits include impacts such as climate-related
economic benefits from reducing emissions of CO2 (but not
other GHGs) and reductions in energy security externalities caused by
U.S. petroleum consumption and imports. The analysis also includes
economic impacts stemming from additional heavy-duty vehicle use
attributable to fuel savings, such as the economic damages caused by
accidents, congestion and noise. Note that benefits reflect on
estimated values for the social cost of carbon (SCC), as described in
Section VIII.G.
The costs, fuel savings, and benefits summarized here are slightly
higher than at proposal, reflecting the use of 2009 (versus 2008)
dollars, some minor changes to our cost estimates in response to
comments, and a change to the 2011 Annual Energy Outlook (AEO) estimate
of economic growth and future fuel prices. In aggregate, these changes
lead to an increased estimate of the net benefits of the final action
compared to the proposal.
Table I-5--Estimated Lifetime Discounted Costs, Fuel Savings, Benefits,
and Net Benefits for 2014-2018 Model Year Heavy-Duty Vehiclesa b
[Billions, 2009$]
------------------------------------------------------------------------
------------------------------------------------------------------------
Lifetime Present Value\c\--3% Discount Rate
------------------------------------------------------------------------
Program Costs........................................... $8.1
Fuel Savings............................................ $50
Benefits................................................ $7.3
Net Benefits\d\......................................... $49
------------------------------------------------------------------------
Annualized Value\e\--3% Discount Rate
------------------------------------------------------------------------
Annualized Costs........................................ $0.4
Fuel Savings............................................ $2.2
Annualized Benefits..................................... $0.4
Net Benefits\d\......................................... $2.2
------------------------------------------------------------------------
Lifetime Present Value\c\--7% Discount Rate
------------------------------------------------------------------------
Program Costs........................................... $8.1
Fuel Savings............................................ $34
Benefits................................................ $6.7
Net Benefits\d\......................................... $33
------------------------------------------------------------------------
Annualized Value\e\--7% Discount Rate
------------------------------------------------------------------------
Annualized Costs........................................ $0.6
Fuel Savings............................................ $2.6
Annualized Benefits..................................... $0.5
Net Benefits\d\......................................... $2.5
------------------------------------------------------------------------
Notes:
[[Page 57126]]
\a\ The agencies estimated the benefits associated with four different
values of a one ton CO2 reduction (model average at 2.5% discount
rate, 3%, and 5%; 95th percentile at 3%), which each increase over
time. For the purposes of this overview presentation of estimated
costs and benefits, however, we are showing the benefits associated
with the marginal value deemed to be central by the interagency
working group on this topic: the model average at 3% discount rate, in
2009 dollars. Section VIII.F provides a complete list of values for
the 4 estimates.
\b\ Note that net present value of reduced GHG emissions is calculated
differently than other benefits. The same discount rate used to
discount the value of damages from future emissions (SCC at 5, 3, and
2.5 percent) is used to calculate net present value of SCC for
internal consistency. Refer to Section VIII.F for more detail.
\c\ Present value is the total, aggregated amount that a series of
monetized costs or benefits that occur over time is worth now (in year
2009 dollar terms), discounting future values to the present.
\d\ Net benefits reflect the fuel savings plus benefits minus costs.
\e\ The annualized value is the constant annual value through a given
time period (2012 through 2050 in this analysis) whose summed present
value equals the present value from which it was derived.
Table I-6 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-6 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-6--Estimated Lifetime Reductions in Fuel Consumption and CO2 Emissions for 2014-2018 Model Year HD Vehicles
--------------------------------------------------------------------------------------------------------------------------------------------------------
All heavy-duty vehicles 2014 MY 2015 MY 2016 MY 2017 MY 2018 MY Total
--------------------------------------------------------------------------------------------------------------------------------------------------------
Fuel (billion gallons).................................. 4.0 3.6 3.6 5.1 5.8 22.1
Fuel (billion barrels).................................. 0.10 0.09 0.08 0.12 0.14 0.53
CO2 (MMT)a.............................................. 50.2 44.8 44.0 62.8 71.7 273
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note:
\a\ Includes upstream and downstream CO2 reductions.
Table I-7 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 2009 dollars and 2010
emissions. Table I-7 presents benefits based on the $22 per ton of
CO2 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 energy
security, and other externalities such as impacts on accidents,
congestion and noise. However, the model year lifetime analysis
supporting the program omits other impacts such as benefits related to
non-GHG emission reductions.\40\ The lifetime discounted benefits are
shown for one of four different SCC values considered by EPA and NHTSA.
The values in Table I-7 do not include costs associated with new
technology required to meet the GHG and fuel consumption standards.
---------------------------------------------------------------------------
\40\ Non-GHG emissions and health-related impacts were estimated
for the calendar year analysis. See Section VII for more information
about non-GHG emission impacts and Section VIII for more information
about non-GHG-related health impacts.
Table I-7--Estimated Lifetime Discounted Benefits for 2014-2018 Model Year HD Vehicles Assuming the Model Average, 3% Discount Rate SCC Valuea b c
[billions of 2009 dollars]
--------------------------------------------------------------------------------------------------------------------------------------------------------
Model year
Discount rate (percent) -----------------------------------------------------------------------------------------------
2014 2015 2016 2017 2018 Total
--------------------------------------------------------------------------------------------------------------------------------------------------------
3....................................................... $10.7 $9.4 $9.2 $13.2 $14.9 $57
7....................................................... 8.3 6.9 6.6 9.2 10.1 41
--------------------------------------------------------------------------------------------------------------------------------------------------------
Notes:
\a\ The analysis includes impacts such as the economic value of reduced fuel consumption and accompanying climate-related economic benefits from
reducing emissions of CO2 (but not other GHGs), and reductions in energy security externalities caused by U.S. petroleum consumption and imports. The
analysis also includes economic impacts stemming from additional heavy-duty vehicle use, such as the economic damages caused by accidents, congestion
and noise.
\b\ Note that net present value of reduced CO2 emissions is calculated differently than other benefits. The same discount rate used to discount the
value of damages from future emissions (SCC at 5, 3, and 2.5 percent) is used to calculate net present value of SCC for internal consistency. Refer to
Section VIII.F for more detail, including a list of all four SCC values, which increase over time.
\c\ Benefits in this table include fuel savings.
Table I-8 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
[[Page 57127]]
estimated fuel savings in billions of barrels and the GHG reductions in
million metric tons of CO2 shown in Table I-8 are totals for
the five model years throughout their projected lifetime and are not
discounted. The monetized values shown in Table I-8 are the summed
values of the discounted monetized-fuel consumption and monetized-
CO2 reductions for the five model years 2014-2018 throughout
their lifetimes. The monetized values in Table I-8 reflect both a 3
percent and a 7 percent discount rate as noted.
Table I-8--Estimated Lifetime Reductions and Associated Discounted
Monetized Benefits for 2014-2018 Model Year HD Vehicles
[Monetized values in 2009 dollars]
------------------------------------------------------------------------
Amount $ Value (billions)
------------------------------------------------------------------------
Fuel Consumption Reductions..... 0.53 billion $50.1, 3% discount
barrels. rate $34.4, 7%
discount rate.
CO2 Emission Reductions \a\ 273 MMT CO2....... $5.8 \b\.
Valued assuming $22/ton CO2 in
2010.
------------------------------------------------------------------------
Notes:
\a\ Includes both upstream and downstream CO2 emission reductions.
\b\ Note that net present value of reduced CO2 emissions is calculated
differently than other benefits. The same discount rate used to
discount the value of damages from future emissions (SCC at 5, 3, and
2.5 percent) is used to calculate net present value of SCC for
internal consistency. Refer to Section VIII.F for more detail.
Table I-9 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-9 are for the industry as
a whole and do not account for fuel savings associated with the
program.
Table I-9--Estimated Incremental Technology Outlays for 2014-2018 Model Year HD Vehicles
[Billions of 2009 dollars]
----------------------------------------------------------------------------------------------------------------
2014 MY 2015 MY 2016 MY 2017 MY 2018 MY Total
----------------------------------------------------------------------------------------------------------------
All Heavy-Duty Vehicles................................... $1.6 $1.4 $1.5 $1.6 $2.0 $8.1
----------------------------------------------------------------------------------------------------------------
Table I-10 shows the agencies' estimated incremental cost increase
of the average new heavy-duty vehicle for each model year 2014-2018.
The values shown are incremental to a baseline vehicle and are not
cumulative.
Table I-10--Estimated Incremental Increase in Average Cost for 2014-2018 Model Year HD Vehicles
[2009 Dollars per unit]
----------------------------------------------------------------------------------------------------------------
2014 MY 2015 MY 2016 MY 2017 MY 2018 MY
----------------------------------------------------------------------------------------------------------------
Combination Tractors..................................... $6,019 $5,871 $5,677 $6,413 $6,215
HD Pickups & Vans........................................ 165 215 422 631 1,048
Vocational Vehicles...................................... 329 320 397 387 378
----------------------------------------------------------------------------------------------------------------
Both costs and benefits presented in this section are in comparison
to a reference case with no improvements in fuel consumption or
greenhouse gas emissions in model years 2014 to 2018.
E. Program Flexibilities
For each of the heavy-duty vehicle and heavy-duty engine categories
for which we are adopting respective standards, EPA and NHTSA are also
finalizing provisions designed to give manufacturers a degree of
flexibility in complying with the standards. These final provisions
have enabled the agencies to consider overall standards that are more
stringent and that will 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.\41\ 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.
---------------------------------------------------------------------------
\41\ 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 flexibility provisions are essentially identical
in structure and function. Within combination tractor and vocational
vehicle categories and within heavy-duty engines, we are finalizing
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
final ABT provisions are patterned on existing EPA and NHTSA ABT
programs and will allow a vehicle manufacturer to reduce CO2
emission and fuel consumption levels further than the level of the
standard for one or more vehicles to generate ABT credits. The
manufacturer can use those credits to offset higher emission or fuel
consumption levels in the same averaging set, ``bank'' the credits for
later use, or ``trade'' the credits to another manufacturer. For HD
pickups and vans, we are finalizing a fleet
[[Page 57128]]
averaging system very similar to the light-duty GHG and CAFE fleet
averaging system.
At proposal, we restricted the use of the ABT provisions of the
program to vehicles or engines within the same regulatory subcategory.
This meant that credit exchanges could only happen between similar
vehicles meeting the same standards. We proposed this approach for two
reasons. First, we were concerned about a level playing field between
different manufacturers who may not participate equally in the various
truck and engine markets covered in the regulation. Second, we were
concerned about the uncertainties inherent in credit calculations that
are based on projections of lifetime emissions for different vehicles
in wholly different vehicle markets. In response to comments, we have
revised our ABT provisions to provide greater flexibility while
continuing to provide assurance that the projected reductions in fuel
consumption and GHG emissions will be achieved. We are relaxing the
restriction on averaging, banking, and trading of credits between the
various regulatory subcategories, by defining three HD vehicle
averaging sets: Light Heavy-Duty (Classes 2b-5); Medium Heavy-Duty
(Class 6-7); and Heavy Heavy-Duty (Class 8). This allows the use of
credits between vehicles within the same weight class. This means that
a Class 8 day cab tractor can exchange credits with a Class 8 high roof
sleeper tractor but not with a smaller Class 7 tractor. Also, a Class 8
vocational vehicle can exchange credits with a Class 8 tractor. We are
adopting these revisions based on comments from the regulated industry
that convinced us these changes would allow the broadest trading
possible while maintaining a level playing field among the various
market segments. However, we are restricting trading between engines
and chassis, even within the same vehicle class.
The agencies believe that restricting trading to within the same
eight classes as EPA's existing criteria pollutant program (i.e. Heavy-
Heavy Duty, Light Heavy-Duty, Medium Heavy-Duty), but not restricting
trading between vehicle or engine type (such as combination tractors),
and restricting between engines and chassis for the same vehicle type,
is appropriate and reasonable. We do not expect emissions from engines
and vehicles--when restricted by weight class--to be dissimilar. We
therefore expect that the lifetime vehicle performance and emissions
levels will be very similar across these defined categories, and the
estimated credit calculations will fairly ensure the expected fuel
consumption and GHG reductions.
The agencies considered even broader averaging, banking, and
trading provisions but decided that in this first phase of regulation,
it would be prudent to start with the program described here, which
will regulate greenhouse gas emissions and fuel consumption from this
sector for the first time and provide considerable early reductions as
well as opportunities to learn about technical and other issues that
can inform future rulemakings. In the future we intend to consider
whether additional cost savings could be realized through broader
trading provisions and whether such provisions could be designed so as
to address any other relevant concerns.
Reducing the cost of regulation through broader use of market tools
is a high priority for the Administration. See Executive Order 13563
and in particular section 1(b)(5) and section 4. Consistent with this
principle, we intend to seek public comment through a Notice of Data
Availability after credit trading begins in 2013, the first year we
expect manufacturers to begin certifying 2014 model year vehicles, on
whether broader credit trading is more appropriate in developing the
next phase of heavy-duty regulations. We believe that input will be
better informed by the work the agencies and the regulated industry
will have put into implementing this first phase of heavy-duty
regulations.
Through this public process, emphasizing the Administration's
strong preference for flexible approaches and maximizing the use of
market tools, the agencies intend to fully consider whether broader
credit trading is more appropriate in developing the next phase of
heavy-duty regulations.
This program thus does not allow credits to be exchanged between
heavy-duty vehicles and light-duty vehicles, nor can credits be traded
from heavy-duty vehicle fleets to light-duty vehicle fleets and vice
versa.
The engine ABT provisions are also changed from the proposal and
now are the same as in EPA's existing criteria pollutant emission
rules. The agencies have broadened the averaging sets to include both
FTP-certified and SET-certified engines in the same averaging set. For
example, a SET-certified engine intended for a Class 8 tractor can
exchange credits with a FTP-certified engine intended for a Class 8
vocational vehicle.
The agencies are finalizing three year deficit carry-forward
provisions for heavy-duty engines and vehicles within a limited time
frame. This flexibility is expected to provide an opportunity for
manufacturers to make necessary technological improvements and reduce
the overall cost of the program without compromising overall
environmental and fuel economy objectives. This flexibility, similar to
the flexibility the agencies have offered under the light-duty vehicle
program, is intended to assist the broad goal of harmonizing the two
agencies' standards while preserving the flexibility of manufacturers
of vehicles and engines in meeting the standards, to the extent
appropriate and required by law. During the MYs 2014-2018 manufacturers
are expected to go through the normal business cycle of redesigning and
upgrading their heavy-duty engine and vehicle products, and in some
cases introducing entirely new vehicles and engines not on the market
today. As explained in the following paragraph, the carry-forward
provision will allow manufacturers the time needed to incorporate
technology to achieve GHG reductions and improve fuel economy during
the vehicle redesign process.
We received comments from Center for Biological Diversity against
the need to offer the deficit carry-forward flexibility. CBD has stated
that allowing manufacturers to carry-forward deficits for up to three
years would incentivize delays in investment and technological
innovation and allow for the generation of additional tons of GHG
emissions that may be prevented today. However, the deficit carry-
forward flexibility (as well as ABT generally) has enabled the agencies
to consider overall standards that are more stringent and that will
become effective at an earlier period than we could consider with a
more rigid program. The agencies also believe this flexibility is an
important aspect of the program, as it avoids the much higher costs
that would occur if manufacturers needed to add or change technology at
times other than their scheduled redesigns, i.e. the cost of adopting a
new engine or vehicle platform mid-production or mid-design. This time
period would also provide manufacturers the opportunity to plan for
compliance using a multi-year time frame, again consistent with normal
business practice. Over these four model years, there would be an
opportunity for manufacturers to evaluate practically all of their
vehicle and engine model platforms and add technology in a cost
effective way to control GHG emissions and improve fuel economy.
As noted above, in addition to ABT, the other primary flexibility
provisions in this program involve opportunities to generate early
credits, advanced technology credits (including for use of
[[Page 57129]]
hybrid powertrains), and innovative technology credits. For the early
credits and advanced technology credits, the agencies sought comment on
the appropriateness of providing a 1.5x multiplier as an incentive for
their use. We received a number of comments supporting the idea of a
credit multiplier, arguing it was an appropriate means to incentivize
the early compliance and advanced technologies the agencies sought. We
received other comments suggesting a multiplier was unnecessary. After
considering the comments, the agencies have decided to finalize a 1.5x
multiplier consistent with our request for comments. We believe that
given the very short lead time of the program and the nascent nature of
the advanced technologies identified in the proposal, that a 1.5x
multiplier is an effective means to bring technology forward into the
heavy-duty sector sooner than would otherwise occur. In addition,
advanced technology credits could be used anywhere within the heavy
duty sector (including both vehicles and engines), but early credits
would be restricted to use within the same defined averaging set
generating the credit.
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 wish to encourage the
development of such innovative technologies, and are therefore adopting
special ``innovative technology'' credits. These innovative technology
credits will 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 in
the heavy-duty sector. Manufacturers will need to quantify the
reductions in fuel consumption and CO2 emissions that the
technology is expected to achieve, above and beyond those achieved on
the existing test procedures. As with ABT, the use of innovative
technology credits will only be allowed for use among vehicles and
engines of the same defined averaging set generating the credit, as
described above. The credit multiplier will not be used for innovative
technology credits.
CBD argued that including any opportunities for manufacturers to
earn credits in the final rule would violate NHTSA's statutory mandate
to implement a program designed to achieve the maximum feasible
improvement.
NHTSA strongly believes that creating credit flexibilities for
manufacturers for this first phase of the HD National Program is fully
consistent with the agency's obligation to develop a fuel efficiency
improvement program designed to achieve the maximum feasible
improvement. EISA gives NHTSA broad authority to develop ``compliance
and enforcement protocols'' that are ``appropriate, cost-effective, and
technologically feasible,'' and the agency believes that compliance
flexibilities such as the opportunity to earn and use credits to meet
the standards are a reasonable and appropriate interpretation of that
authority, along with the other compliance and enforcement provisions
developed for this final rule. Unlike in NHTSA's light-duty program,
where the agency is restricted from considering the availability of
credits in determining the maximum feasible level of stringency for the
fuel economy standards,\42\ in this HD National Program, NHTSA and EPA
have based the levels of stringency in part on our assumptions of the
use of available flexibilities that have been built into the program to
incentivize over-compliance in some respects, to balance out potential
under-compliance in others.
---------------------------------------------------------------------------
\42\ See 49 U.S.C. 32902(h).
---------------------------------------------------------------------------
By assuming the use of credits for compliance, the agencies were
able to set the fuel consumption/GHG standards at more stringent levels
than would otherwise have been feasible. Greater improvements in fuel
efficiency will occur under more stringent standards; manufacturers
will simply have greater flexibility to determine where and how to make
those improvements than they would have without credit options.
Further, this is consistent with EOs 12866 and 13563, which encourage
agencies to design regulations that promote innovation and flexibility
where possible.\43\
---------------------------------------------------------------------------
\43\ EO 12866 states that an agency must ``design its
regulations in the most cost-effective manner to achieve the
regulatory objective * * * consider[ing] incentives for innovation *
* * [and] flexibility,'' among other factors; EO 13563 directs
agencies to ``seek to identify, as appropriate, means to achieve
regulatory goals that are designed to promote innovation,'' and
``identify and consider regulatory approaches that * * * maintain
flexibility.''
---------------------------------------------------------------------------
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 final action implements a specific provision from Title II,
section 202(a).\44\ 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 that certain greenhouse gases may reasonably be
anticipated to endanger public health and welfare and that emissions of
GHGs from section 202 (a) sources cause or contribute to that
endangerment, section 202(a) requires EPA to issue standards applicable
to emissions of those pollutants from new motor vehicles.
---------------------------------------------------------------------------
\44\ See 42 U.S.C. 7521 (a). A number of commenters believed
that the GHG program was being adopted pursuant to section 202
(a)(3)(A) and that the lead time requirements of section 202
(a)(3)(C) therefore apply. This is mistaken. Section 202 (a)(3)(A)
applies to standards for emissions of hydrocarbons, carbon monoxide,
oxides of nitrogen, and particulate matter from heavy-duty vehicles
and engines. This does not include the GHGs regulated under the
standards in today's action. This comment is addressed further in
the Response to Comment document.
---------------------------------------------------------------------------
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);
[[Page 57130]]
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 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 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)).\45\ EPA has interpreted a similar statutory provision, CAA
section 231, as follows:
---------------------------------------------------------------------------
\45\ One commenter mistakenly stated that section 202 (a)
standards must be technology-forcing, but the provision plainly does
not require EPA to adopt technology-forcing standards. See further
discussion in Section III.A below.
---------------------------------------------------------------------------
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' ''). See also
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)).
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
In 1975, Congress enacted the Energy Policy and Conservation Act
(EPCA), mandating a regulatory program for motor vehicle fuel economy
to meet the various facets of the need to conserve energy. In December
2007, Congress
[[Page 57131]]
enacted the Energy Independence and Securities Act (EISA), amending
EPCA to require, among other things, the creation of a medium- and
heavy-duty fuel efficiency program for the first time. This mandate in
EISA represents a major step forward in promoting EPCA's goals of
energy independence and security, and environmental and national
security.
NHTSA has primary responsibility for fuel economy and consumption
standards, and assures compliance with EISA through rulemaking,
including standard-setting; technical reviews, audits and studies;
investigations; and enforcement of implementing regulations including
penalty actions. This final action implements Section 32902(k)(2) of
EISA, which instructs NHTSA to create a fuel efficiency improvement
program for ``commercial medium- and heavy-duty on-highway vehicles and
work trucks'' \46\ 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.
---------------------------------------------------------------------------
\46\ ``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).
---------------------------------------------------------------------------
NHTSA has clear authority to design and implement a fuel efficiency
program for vehicles and work trucks under EISA, and was given broad
discretion to balance the statutory factors in Section 32902(k)(2) in
developing fuel consumption standards to achieve the maximum feasible
improvement. Since this is the first rulemaking that NHTSA has
conducted under 49 U.S.C. 32902(k)(2), the agency interpreted these
elements and factors in the context of setting standards, choosing
metrics, and determining test methods and compliance/enforcement
mechanisms. Discussion of the application of these factors can be found
in Section III below. 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. 32902(k). See
49 U.S.C. Section 32902(b)(1). 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. 32902(b)(3)(B). For purposes of the fuel efficiency standards
that the agency proposed for HD vehicles and engines, the NPRM stated
an interpretation of the statute that the 5-year maximum limit did not
apply to standards promulgated in accordance with 49 U.S.C. 32902(k),
given the language in Section 32902(b)(1). Based on this
interpretation, NHTSA proposed 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 sought comment on its interpretation of EISA.
Robert Bosch LLC (Bosch) commented that the absence of an
expiration date for the standards proposed in the NPRM could violate 49
U.S.C. 32902, which it interpreted as requiring the MD/HD program to
have standards that expire in five years. Section 32902(k)(3), which
lays out the requirements for the MD/HD program, specifies the minimum
regulatory lead and stability times, as described above, but does not
specify a maximum duration period. In contrast, Section 32902(b)(3)(B)
lays out the minimum and maximum durations of standards to be
established in a rulemaking for the light-duty program, but prescribes
no minimum lead or stability time. Bosch argued that as 49 U.S.C.
Section 32902(k)(3) does not require a maximum duration period,
Congress intended that NHTSA take the maximum duration period specified
for the light-duty program in Section 32902(b)(3)(B), five years, and
apply it to Section 32902(k)(3). Bosch also argued, however, that the
minimum duration period should not be carried over from the light-duty
to the heavy-duty section, as a minimum duration period for HD was
specified in Section 32902(k)(3).
NHTSA has revisited this issue and continues to believe that it is
reasonable to assume that if Congress intended for the HD/MD regulatory
program to be limited by the timeline prescribed in Subsection
(b)(3)(B), it would have either mentioned HD/MD vehicles in that
subsection or included the same timeline in Subsection (k).\47\ In
addition, in order for Subsection (b)(3)(B) to be interpreted to apply
to Subsection (k), the agency would need to give less than full weight
to the earlier phrase in the statute directing the Secretary to
prescribe standards for ``work trucks and commercial medium-duty or
heavy-duty on-highway vehicles in accordance with Subsection (k).'' 49
U.S.C. 32902(b)(1)(C). Instead, this direction would need to be read to
mean ``in accordance with Subsection (k) and the remainder of
Subsection (b).'' NHTSA believes this interpretation would be
inappropriate. Interpreting ``in accordance with Subsection (k)'' to
mean something indistinct from ``in accordance with this Subsection''
goes against the canon that statutes should not be interpreted in a way
that ``render[s] language superfluous.'' Dobrova v. Holder, 607 F.3d
297, 302 (2d Cir. 2010), quoting Mendez v. Holder, 566 F. 3d 316, 321-
22 (2d Cir. 2009). Based on this reasoning, NHTSA believes the more
reasonable and appropriate approach is reflected in the proposal, and
the final rules therefore follow this approach.
---------------------------------------------------------------------------
\47\ ``[W]here Congress includes particular language in one
section of a statute but omits it in another section of the same
Act, it is generally presumed that Congress acts intentionally and
purposely in the disparate inclusion or exclusion.'' Russello v.
United States, 464 U.S. 16, 23 (1983), quoting U.S. v. Wong Kim Bo,
472 F.2d 720, 722 (5th Cir 1972)., See also Mayo v. Questech, Inc.,
727 F.Supp. 1007, 1014 (E.D.Va. 1989) (conspicuous absence of
provision from section where inclusion would be most logical signals
Congress did not intend for it to be implied).
---------------------------------------------------------------------------
Another commenter, CBD, expressed concern that lack of an
expiration date meant that the standards would remain indefinitely,
thus forgoing the possibility of increased stringency in the future.
CBD argued that this violated NHTSA's statutory duty to set maximum
feasible standards. NHTSA disagrees that the indefinite duration of the
standards in this rule would prevent the agency from setting future
standards at the maximum feasible level in future rulemakings. The
absence of an expiration date for these standards should not be
interpreted to mean that there will be no future rulemakings to
establish new MD/HD fuel efficiency standards for MYs 2019 and beyond--
the agencies have already previewed the possibility of such a
rulemaking in other parts of this final rule preamble. Therefore, NHTSA
believes this concern is unnecessary.
[[Page 57132]]
(a) NHTSA Testing Authority
49 U.S.C. Section 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. For this program, manufacturers will test and
conduct modeling to determine GHG emissions and fuel consumption
performance, and EPA and NHTSA will perform validation testing. The
results of the validation tests will be used by EPA to create a
finalized reporting that confirms the manufacturer's final model year
GHG emissions and fuel consumption results, which each agency will use
to enforce compliance with its standards.
(v) NHTSA Enforcement Authority
(i) Overview
The NPRM proposed a compliance and enforcement program that
included civil penalties for violations of the fuel efficiency
standards. 49 U.S.C. 32902(k)(2) states that NHTSA must adopt and
implement appropriate, cost-effective, and technologically feasible
compliance and enforcement protocols for the fuel efficiency
improvement program. Congress gave DOT broad discretion to fashion its
fuel efficiency improvement program and thus necessarily did not speak
directly or specifically as to the nature of the compliance and
enforcement protocols that would be best suited for effectively
supporting the yet-to-be-designed-and-established program. Instead, it
left the matter generally to the Secretary. Congress' approach is
unlike CAFE enforcement for passenger cars and light trucks, where
Congress specified the precise details of a program and provided that a
manufacturer either complies with standards or pays civil penalties.
The statute is silent with respect to how ``protocol'' should be
interpreted. The term ``protocol'' is imprecise and thus Congress'
choice of that term affords the agency substantial breadth of
discretion. 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).\48\ 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.
---------------------------------------------------------------------------
\48\ 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 interpreted ``protocol'' in the context of EISA as authorizing
the agency to determine both whether manufacturers have complied with
the standards, and to establish suitable and reasonable enforcement
mechanisms and decision criteria for non-compliance. Therefore, NHTSA
interpreted its authority to develop an enforcement program to include
the authority to determine and assess civil penalties for non-
compliance.
Several commenters disagreed with this interpretation. Volvo and
EMA commented that the penalties proposed by NHTSA exceeded the
authority granted to the agency by Congress, and Volvo commented that
the fact that Congress did not adopt an entirely new statute for the HD
program should be interpreted to mean that provisions adopted for the
light-duty program should apply to the HD program as well. Daimler
argued that it was likely that EISA did not give NHTSA the authority to
assess civil penalties, and Navistar and EMA argued that NHTSA could
not have the authority as Congress did not expressly grant it.
NHTSA continues to believe that it is reasonable to interpret
``compliance and enforcement protocols'' to include authority to impose
civil penalties. Where a statute does not specify an approach, the
discretion to do so is left to the agency. When Congress has
``explicitly left a gap for an agency to fill, there is an express
delegation of authority to the agency to elucidate a specific provision
of the statute by regulation.'' United States. v. Mead, 533 U.S. 218,
227 (2001), quoting Chevron v. NRDC, 467 U.S. 837, 843-44 (1984). The
delegation of authority may be implicit rather than express. Id. at
229. NHTSA believes it would be unreasonable to assume that Congress
intended to create a hollow regulatory program without a mechanism for
effective enforcement. Further, interpreting ``enforcement protocols''
to mean not more than ``compliance protocols'' would go against the
canon noted above that statutes should not be interpreted in a way that
``render[s] language superfluous.'' Dobrova v. Holder, 607 F.3d 297,
302 (2d Cir. 2010), quoting Mendez v. Holder 566 F. 3d 316, 321-22 (2d
Cir. 2009). The interpretation urged by the commenters would render an
entire program superfluous.
Further, NHTSA believes that Congress would have anticipated that
compliance and enforcement protocols would include civil penalties for
the HD sector, given that penalties are an integral part of a product
standards program and given the long precedent of civil penalties for
the light-duty sector. The agency disagrees with the argument that the
HD program would have appeared in a wholly separate statute if Congress
had not intended the penalty program for light-duty to apply to it. The
inclusion of the MD/HD program in Title 329 does not mean that Congress
intended for the boundaries and differences between the separate
sections to be ignored. Rather, this argument leads to the opposite
conclusion that the fact that Congress created a new section for the HD
program, instead of simply amending the existing light-duty program to
include ``work trucks and other vehicles'' in addition to automobiles,
means the agency should assume that Congress acted intentionally when
it created two wholly separate programs and respect their distinctions.
Therefore, consistent with the statutory interpretation proposed in the
NPRM, the final rule includes penalties for non-compliance with the
fuel efficiency standards.
(ii) Penalty Levels
NHTSA proposed to adopt penalty levels equal to those in EPA's
existing heavy-duty program, in order to provide adequate deterrence as
well as consistency with the GHG regulation. The proposed maximum
penalty levels were $37,500.00 per vehicle or engine.
Several manufacturers commented that the penalty levels should be
limited to those mandated in the light-duty program. Volvo and Daimler
argued that Congress intended lower penalties for the HD program than
were proposed in the NPRM, because they believed that Congress had
expressly or implicitly intended for the HD program to be included in
the penalty calculation of Section 32912(b). That section prescribes
penalty levels for violators under Section 32902 of ``$5 multiplied
[[Page 57133]]
by each tenth (0.1) of a mile a gallon by which the applicable average
fuel economy standard under that section exceeds the average fuel
economy,'' \49\ calculated and applied to automobiles. Volvo further
argued that NHTSA was relying upon the CAA as the statutory basis for
the penalty levels.
---------------------------------------------------------------------------
\49\ This fine was increased by 49 CFR 578.6, which provides
that ``Except as provided in 49 U.S.C. 32912(c), a manufacturer that
violates a standard prescribed for a model year under 49 U.S.C.
32902 is liable to the United States Government for a civil penalty
of $5.50 multiplied by each 0.1 of a mile a gallon by which the
applicable average fuel economy standard under that section exceeds
the average fuel economy.''
---------------------------------------------------------------------------
NHTSA recognizes that Section 329 contains a detailed penalty
scheme, for light-duty vehicle CAFE standards. However, Section
32902(k)(2) explicitly directs NHTSA to ``adopt and implement
appropriate test methods, measurement metrics, fuel economy standards,
and compliance and enforcement protocols,'' in the creation of the new
HD program. NHTSA continues to believe that this broad Congressional
mandate should be interpreted based on a plain text reading, which
includes the authority to determine compliance and enforcement
protocols that will be effective and appropriate for this new sector of
regulation. NHTSA also believes that reading Section 32912 to apply to
the new HD program would contradict Congress' broad mandate for the
agency to establish new measurement metrics and a compliance and
enforcement program. Further, interpreting the requirement to create
``enforcement protocols'' for HD vehicles to mean that NHTSA should
rely on the enforcement provisions for light-duty vehicles would go
against the canon noted above that statutes should not be interpreted
in a way that ``render[s] language superfluous.'' Dobrova v. Holder,
607 F.3d 297, 302 (2d Cir. 2010), quoting Mendez v. Holder 566 F. 3d
316, 321-22 (2d Cir. 2009).
NHTSA believes that Section 32912 does not apply to the new HD
program for several other reasons. First, this section uses a fuel
economy metric, miles/gallon, while the HD program is built around a
fuel consumption metric, per the requirement to develop a ``fuel
efficiency improvement program'' and the agencies' conclusion,
supported by NAS, that a fuel consumption metric is a much more
reasonable choice than a fuel economy metric for HD vehicles given
their usage as work vehicles. Second, this section specifies a
calculation for automobiles, a vehicle class which is confined to the
light-duty rule. In addition, the HD program prescribes fuel
consumption standards, not average fuel economy standards.
Finally, NHTSA believes that if Congress had intended for a pre-
determined penalty scheme to apply to the new HD program, it would have
been specific. Instead, Congress explicitly directed the agency to
develop a new measurement, compliance, and enforcement scheme.
Consistent with the statutory interpretation of the duration of the
standards, NHTSA believes that if Congress intended for particular
penalty levels to be used in Section 32902(k)(3), it would have either
included a reference to those levels or included a reference in 32912
to the vehicles and metrics regulated by 32902(k)(3). See Russello v.
United States, 464 U.S. 16, 23 (1983), quoting United States v. Wong
Kim Bo, 472 F.2d 720, 722 (5th Cir 1972) (``[W]here Congress includes
particular language in one section of a statute but omits it in another
section of the same Act, it is generally presumed that Congress acts
intentionally and purposely in the disparate inclusion or exclusion.'')
Instead, the absence of such language could mean either that Congress
did not contemplate the specific penalty levels to be used, or that
Congress left the choice of specific penalty levels to the agency. See
Alliance for Community Media v. F.C.C. 529 F. 3d 763, 779 (6th Cir.
2008) (absence of a statutory deadline in one section but not others
meant that Congress authorized but did not require it in that section).
NHTSA believes that, based on EPA's experience regulating this
sector for criteria pollutants, the proposed maximum penalty is at an
appropriate level to create deterrence for non-compliance, while at the
same time, not so high as to create undue hardship for manufacturers.
Therefore, the final rule retains the maximum penalty level proposed in
the NPRM.
G. Future HD GHG and Fuel Consumption Rulemakings
This final action 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 adopt 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 time frame, our program is
very aggressive--with limited lead time compared to historic heavy-duty
regulations--but pragmatic in the context of technologies that are
available and that can be reasonably implemented during the regulatory
time frame.
While we are now only finalizing this first step, it is worthwhile
to consider how the next regulatory step may be designed. 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 will not be necessary to meet the final standards. Today's
standards are premised on the use of existing technologies given the
short lead time, as discussed in Section III, below. When we begin 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 adopting today 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
[[Page 57134]]
criteria pollutant and GHG emissions. However, we believe the important
issues and technical work related to setting new criteria pollutant
emissions standards appropriate for the World Harmonized Duty Cycle are
significant and beyond the scope of this rulemaking. Therefore, the
agencies are not adopting these test procedures in this action, but we
are ready to work with interested stakeholders to adopt these
procedures in a future action.
As noted above, the agencies also intend to further investigate
possibilities of expanded credit trading across the heavy-duty sector.
As part of this effort, the agencies will investigate the degree to
which the issue of credit trading is connected with complete vehicle
testing procedures.
As with this program, 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.
II. Final GHG and Fuel Consumption Standards for Heavy-Duty Engines and
Vehicles
This section describes the standards and implementation dates that
the agencies are finalizing for the three categories of heavy-duty
vehicles and engines. The agencies have performed a technology analysis
to determine the level of standards that we believe will be cost-
effective, feasible, and appropriate in the lead time provided. This
analysis, described in Section III and in more detail in the RIA
Chapter 2, considered for each of the regulatory categories:
The level of technology that is incorporated in current
new engines and trucks,
Forecasts of manufacturers' product redesign schedules,
The available data on corresponding CO2
emissions and fuel consumption for these engines and vehicles,
Technologies that would reduce CO2 emissions
and fuel consumption and that are judged to be feasible and appropriate
for these vehicles and engines through the 2018 model year,
The effectiveness and cost of these technologies, and
Projections of future U.S. sales for trucks and engines.
A. What vehicles will be affected?
EPA and NHTSA are finalizing standards for heavy-duty engines and
also for what we refer to generally as ``heavy-duty vehicles.'' In
general, these standards will apply for the model year 2014 and later
engines and vehicles, although some standards do not apply until 2016
or 2017. The EPA standards will apply throughout the useful life of the
engine or vehicle, just as existing criteria emission standards apply
throughout the useful life. As noted in Section I, for purposes of this
preamble and rules, the term ``heavy-duty or ``HD'' applies 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 final 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.\50\ 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.\51\ Therefore, the term ``heavy-duty vehicles'' in this
rulemaking refers to both work trucks and commercial medium- and heavy-
duty on-highway vehicles as defined by EISA. Heavy-duty engines
affected by the standards are those that are installed in commercial
medium- and heavy-duty vehicles, 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. The standards that EPA is finalizing today cover recreational
on-highway vehicles, while NHTSA limited its scope in the proposal to
not include these vehicles. See Section I.A above.
---------------------------------------------------------------------------
\50\ Codified at 49 U.S.C. 32901(a)(7).
\51\ 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., pickup
box or bed) of six feet or more in interior length. (See the Tier 2
final rulemaking, 65 FR 6698, February 10, 2000.)
---------------------------------------------------------------------------
The NPRM did not include an export exclusion in NHTSA's fuel
consumption standards. Oshkosh Corporation commented that NHTSA should
add an export exclusion in order to accommodate the testing and
delivery needs of manufacturers of vehicles intended for export. NHTSA
agrees with this comment and Section 535.3 of the final rule specifies
such an exclusion.
EPA and NHTSA are finalizing standards for each of the following
categories, which together comprise all heavy-duty vehicles and all
engines used in such vehicles. In order to most appropriately regulate
the broad range of heavy-duty vehicles and engines, the agencies are
setting separate engine and vehicle standards for the combination
tractors and Class 2b through 8 vocational vehicles. The engine
standards and test procedures for engines installed in the tractors and
vocational vehicles are discussed within the preamble sections for
combination tractors and vocational vehicles, respectively. The
agencies are establishing standards for heavy-duty pickups and vans
that apply to the entire vehicle;--there are no separate engine
standards.
As discussed in Section IX, the agencies are not adopting GHG
emission and fuel consumption standards for trailers at this time. In
addition, the agencies are not adopting standards at this time for
engine, chassis, and vehicle manufacturers which are small businesses
(as defined by the Small Business Administration). More detailed
discussion of each regulatory category is included in the subsequent
sections below.
B. Class 7 and 8 Combination Tractors
EPA is finalizing CO2 standards and NHTSA is finalizing
fuel consumption standards for new Class 7 and 8 combination tractors.
The standards are for the tractor cab, with a separate standard for the
engine that is installed in the tractor. Together these standards would
achieve reductions of up to 23 percent compared to the model 2010
baseline level. As discussed below, EPA is finalizing its proposal to
adopt the existing useful life definitions for Class 7 and 8 tractors
and the heavy-duty engines installed in them. NHTSA and EPA are
finalizing revised fuel consumption and GHG emissions standards for
tractors, and finalizing as proposed engine standards for heavy-duty
engines in Class 7 and 8 tractors. The agencies' analyses, as discussed
[[Page 57135]]
briefly below and in more detail later in this preamble and in the RIA
Chapter 2, show that these standards are feasible and appropriate under
each agency's respective statutory authorities.
EPA is also finalizing standards to control N2O,
CH4, and HFC emissions from Class 7 and 8 combination
tractors. The final heavy-duty engine standards for both N2O
and CH4 and details of the standard are included in the
discussion in Section II.E.1.b and II.E.2.b, respectively. The final
air conditioning leakage standards applying to tractor manufacturers to
address HFC emissions are discussed in Section II.E.5.
The agencies are finalizing CO2 emissions and fuel
consumption standards for the combination tractors that reflect
reductions that can be achieved through improvements in the tractor
(such as aerodynamics), tires, and other vehicle systems. The agencies
are also finalizing heavy-duty engine standards for CO2
emissions and fuel consumption that reflect technological improvements
in combustion and overall engine efficiency.
The agencies have analyzed the feasibility of achieving the
CO2 and fuel consumption standards, and have identified
means of achieving the standards that are technically feasible in the
lead time afforded, economically practicable and cost-effective. EPA
and NHTSA present the estimated costs and benefits of the standards in
Section III. In developing the final 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 national
CO2 and fuel savings that may be achieved.
The agencies received comments from multiple stakeholders regarding
the definition and classification of ``combination tractors.'' The
commenters raised three key issues. First, EMA/TMA, Navistar and DTNA
requested that both agencies use the same definition for ``tractor'' or
``truck tractor'' in the final rules. EPA proposed a definition for
``tractor'' in Sec. 1037.801 (see the proposed rule published November
30, 2010, 75 FR 74402) which stated that ``tractor'' means 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. For purposes of this
definition, the term ''cargo'' includes permanently attached equipment
such as fire-fighting equipment. The following vehicles are tractors:
any vehicle sold to an ultimate purchaser with a fifth wheel coupling
installed; any vehicle sold to an ultimate purchaser with the rear
portion of the frame exposed where the length of the exposed portion is
5.0 meters or less. See Sec. 1037.620 for special provisions related
to vehicles sold to secondary vehicle manufacturers in this condition.
The following vehicles are not tractors: Any vehicle sold to an
ultimate purchaser with an installed cargo carrying feature (for
example, this would include dump trucks and cement trucks); any vehicle
lacking a fifth wheel coupling sold to an ultimate purchaser with the
rear portion of the frame exposed where the length of the exposed
portion is more than 5.0 meters.
NHTSA proposed to use the 49 CFR 571.3 definition of ``truck
tractor'' in 49 CFR 535.4 (see the proposed rule published November 30,
2010, 75 FR 74440) which stated that ``truck tractor'' means a truck
designed primarily for drawing other motor vehicles and not so
constructed as to carry a load other than a part of the weight of the
vehicle and the load so drawn.
Second, EMA/TMA, NTEA and Navistar expressed concerns over, and
requested the removal of, the proposed language that all vehicles with
sleeper cabs would be classified as tractors. The commenters argued
that because there are vocational vehicles manufactured with sleeper
cabs that operate as vocational vehicles and not as tractors, those
vehicles should be treated the same as all other vocational vehicles.
Third, eleven different commenters requested that the agencies
subdivide tractors into line-haul tractors and vocational tractors and
treat each based upon their operational characteristics: vocational
tractors, which operate at lower speeds offroad or in stop-and-go city
driving as vocational vehicles; and line-haul tractors, which operate
at highway speeds on interstate roadways over long distances, as line-
haul tractors.
In response to the first comment, the agencies have decided to
standardize the definition of tractor by using the long-standing NHTSA
definition of ``truck tractor'' established in 49 CFR 571.3. 49 CFR
571.3(b) states that a ``truck tractor means a truck designed primarily
for drawing other motor vehicles and not so constructed as to carry a
load other than a part of the weight of the vehicle and the load so
drawn.'' EPA's proposed definition for ``tractor'' in the NPRM was
similar to the NHTSA definition, but included some additional language
to require a fifth wheel coupling and an exposed frame in the rear of
the vehicle where the length of the exposed portion is 5.0 meters or
less. EMA and Navistar argued that these two different definitions
could lead to confusion if the agencies applied their requirements for
truck tractors differently from each other. The commenters suggested
that the EPA definition was more complicated than necessary, and that
the simpler NHTSA definition should be used by both agencies as the
base definition of truck tractor.
The agencies agree that the definitions should be standardized and
that the NHTSA definition is sufficient and includes the essential
requirement that a truck tractor is a truck designed ``primarily for
drawing other motor vehicles and not so constructed as to carry a load
other than a part of the weight of the vehicle and the load so drawn.''
EPA's proposed tractor definition was intended to be functionally
equivalent to NHTSA's definition based on design, but to be more
objective by including the criteria related to ``fifth wheels'' and
exposed rear frame. However, EPA no longer believes that such
additional criteria are needed for implementation. NHTSA established
the definition for truck tractor in 49 CFR 571.3(b) years ago,\52\ and
has not encountered any notable problems with its application.
Nevertheless, because the NHTSA definition relies more on design intent
than EPA's proposed definition, we recognize that there may be some
questions regarding how the agencies would apply the NHTSA definition
being finalized to certain unique vehicles. For example, many of the
common automobile and boat transport trucks may look similar to
tractors, but the agencies would not consider them to meet the
definition, because they have the capability to carry one or several
vehicles as cargo with or without a trailer attached, and therefore are
not ``constructed as to carry a load other than a part of the weight of
the vehicle and the load so drawn.'' Similarly, a ``dromedary'' style
truck that has the capability to carry a large load of cargo with or
without drawing a trailer would also not qualify as a tractor.\53\ Even
though these particular vehicles identified could potentially draw
other motor vehicles like a trailer, they have also been designed to
carry cargo with or without the trailer attached. NHTSA has previously
interpreted its definition for ``truck tractor'' as excluding these
specific vehicles like the dromedary and
[[Page 57136]]
automobile/boat transport vehicles. Tow trucks have also been excluded
from the category of truck tractor. On the other hand, it is worth
clarifying that designs that allow cargo to be carried in the passenger
compartment, the sleeper compartment, or external toolboxes would not
exclude a vehicle from the tractor category. The agencies plan to
continue with this approach for the HD fuel efficiency and GHG
standards, which means that these particular vehicles will be subject
to the vocational vehicle standards and not the tractor standards, but
vehicles that did meet the definition above for ``tractor'' will be
subject to the combination tractor standards.
---------------------------------------------------------------------------
\52\ 33 FR 19703, December 25, 1968.
\53\ A dromedary is a box, deck or plate mounted behind the cab
to carry freight or cargo.
---------------------------------------------------------------------------
In response to the second comment, the agencies have decided not to
classify vocational vehicles with sleeper cabs as tractors. In the
NPRM, the agencies proposed that vocational vehicles with sleeper cabs
be classified as tractors out of concern that a vehicle could initially
be manufactured as a straight truck vocational vehicle with a sleeper
cab and, soon after introduction into commerce, be converted to a
combination tractor as a means to circumvent the Class 8 sleeper cab
regulations. Commenters who addressed this issue generally disagreed
with the agencies' concern. EMA/TMA, for example, argued that it is
expensive and difficult for a manufacturer to change a vehicle from a
straight truck to a tractor, because of modifications required to the
vehicle, such as to the vehicle's air brake system, and also because of
the manufacturers ultimate responsibility for recertification to
NHTSA's safety standards. EMA/TMA also argued that straight trucks are
often built with sleeper cabs to perform the functions of a vocational
type vehicle and not the functions of a line-haul tractor. NTEA also
provided an example of a straight truck (Expediter Cab) that can be
built with a sleeper cab and a cargo-carrying body, which it argued
should be classified as a vocational vehicle and not a tractor.
Upon further consideration, the agencies agree that vocational
vehicles with sleeper cabs are more appropriately classified as
vocational vehicles than as tractors. The comments discussed above help
to illustrate the reasons for building a vocational vehicle with a
sleeper cab and the difficulties of converting a straight truck to a
tractor. Moreover, 49 U.S.C. Chapter 301 requires any service
organization making such modifications to be responsible for
recertification to all applicable Federal motor vehicle safety
standards, which should act as a further deterrent to anyone
contemplating making such a conversion. Together these two items
address the agencies' primary reason for proposing the requirement that
all vehicles with sleeper cabs be treated as tractors--the concern of
circumvention of the tractor standards. However, the agencies will
continue to monitor whether it appears that the definitions are
creating unintended consequences, and may consider revising the
definitions in a future rulemaking to address such issues should any
arise. NHTSA and EPA have concluded that the engine and tire
improvements required in the vocational category are appropriate for
this set of vehicles based on the typical operation of these vehicles.
The agencies did not intend to include vocational vehicles with sleeper
cabs, such as an Expediter vehicle, into the tractor category in either
the NPRM or in this final action, and the agencies' analyses at
proposal reflected this intention. Therefore the agencies did not make
any adjustments to the program costs and benefits due to this
classification change.
In response to the third comment, the agencies have decided to
allow manufacturers to exclude certain vocational-type of tractors from
the combination tractor standards and instead be subject to the
vocational vehicle standards. We discuss below the reasoning underlying
this decision, the criteria manufacturers would use in asserting a
claim that a vocational tractor should be reclassified as a vocational
vehicle, and the procedures the agencies will use to accept or reject
manufacturers' claims.
Multiple commenters (Allison Transmission, ATA, CALSTART, Eaton,
EMA/TMA, National Solid Waste Management Association, MEMA, Navistar,
NADA, RMA, and Volvo) argued that the agencies' proposed classification
failed to recognize genuine differences between vocational tractors,
which typically operate at lower speeds in stop-and-go city driving,
and line-haul tractors, which typically operate at highway speeds on
interstate roadways over long distances. Commenters argued that the
proposed tractor standards and associated tractor GEM test cycles were
derived based primarily upon the operational characteristics of the
line-haul tractors, and that technologies that apply to these line-haul
tractors, such as improved aerodynamics, vehicle speed limiters and
automatic engine shutdown, as well as engine performance for improving
emissions and fuel consumption, do not have the same positive impact on
fuel consumption when used on tractors. In today's market, as mentioned
by Volvo and ATA, we understand that approximately 15 percent, or
approximately 15,000 to 20,000, of the Class 7 and 8 tractors could be
classified as vocational tractors based upon the work they perform.
The agencies agree that the overall operation of these vocational-
types of tractors resembles other vocational vehicles' operation: lower
average speed and more stop and go activity than line-haul tractors.
Due to their operation style, a FTP certified engine is a better match
for these tractors than a SET certified engine, because the FTP cycle
uses a lower average speed and more stop and go activity than the SET
cycle. In addition, the limited high speed operation leads to minimal
opportunities for fuel consumption and CO2 emissions
reductions due to aerodynamic improvements. Conversely, the additional
weight of the aerodynamic components could cause an unintended
consequence of increasing gram per ton-mile emissions by reducing the
amount of payload the vehicle can carry in those applications which are
weight-limited. Similarly, the vocational tractors typically do not
hotel overnight and therefore will have little to no benefit through
the installation of an idle reduction technology.
The agencies received several other comments that described
criteria that could be used to distinguish between vocational and non-
vocational tractors. Volvo suggested that a tractor could be a
vocational tractor if it meets three of five specified features:
(1) A frame Resisting Bending Moment (RBM) greater than or equal to
2,000,000 in-lbs per rail, or rail and liner combination;
(2) An approach angle greater than or equal to 20 degrees nominal
design specification, to exclude extended front rails/bumpers for
additional equipment (e.g.--pumps, winch, front engine PTO);
(3) Ground clearance greater than or equal to 14 inches as measured
unladen from the lowest point of any frame rail or body mounted
components, excluding axles and suspension (for HHD and MHD vehicles
this is usually considered as the lowest point of the fuel tank/
mounting or chassis aerodynamic devices);
(4) A total reduction in high gear greater than or equal to 3.00:1;
and
(5) A total reduction in low gear greater than or equal to 57:1.
The approach proposed by Volvo is somewhat similar to the approach
NHTSA has for determining if a vehicle is a light truck under the light
vehicle CAFE program, in which a vehicle must either have a GVWR
greater than 6,000 pounds or have 4-wheel drive, and meet
[[Page 57137]]
four of the five specified suspension characteristics (approach angle,
break-over angle, axle clearance, etc.) to be classified as a light
truck. Although we do not believe that the criteria suggested by Volvo
are workable for all manufacturers and all applications, we agree that
these criteria would reflect a reasonable basis for allowing
manufacturers to reclassify their vehicles as vocational tractors.
Two other commenters, EMA/TMA and Navistar, suggested simply that
the manufacturer should have the burden of establishing that a tractor
is a vocational tractor to the agencies' reasonable satisfaction. The
commenters also suggested some factors that could be used to establish
that a tractor is actually a ``vocational tractor'', including:
(1) A vehicle speed limiter set at 55 mph or less;
(2) Power take-off (PTO) controls;
(3) Extended front frame;
(4) Ground clearance greater than 14 in.;
(5) An approach angle greater than 20 degrees;
(6) Frame RBM greater than 2,000,000 in-lbs.; and
(7) A total gear reduction in low gear greater than 57 and a total
gear reduction in top gear greater than 3.
The agencies believe that both suggested approaches have some
merit. A rule based on specific criteria as suggested by Volvo could
help to minimize the burden on both the manufacturers and the agencies,
as manufacturer-written requests for approval and agency approvals of
those requests would not be required for each vocational tractor
determination whereas the EMA/TMA and Navistar approach requires the
opposite namely that each manufacturer would have to justify the
determination of each vocational tractor based upon its related design
features in a separate petition to the agencies. Neither of the two
approaches, which are based on specific criteria, could be used to
identify all the tractors that should be classified as vocational
tractors. An urban beverage delivery tractor, for example, may not be
designed with any of the features mentioned but is used in a vocational
vehicle manner. Also, the agencies were concerned about the possibility
of manufacturers circumventing the system by incorporating design
changes to their line-haul tractors in order to classify them as
vocational tractors required to meet less stringent emission and fuel
consumption standards. However, at this time the agencies do not
believe that circumventing the system is likely, as most of these
vocational tractors are built to order and will incorporate the design
features required by the customer. Manufacturer vehicle offerings are
designed or tailored to suit the particular task of the consumer. The
vehicle transport mission including vehicle type, gross vehicle weight,
gross combination weight, body style and load handling characteristics,
must be considered in the design process. Further, how the vehicle will
be utilized, including operating cycles, operating environment and road
conditions, is another important consideration in designing a vehicle
to accomplish a particular task. The agencies agree that these criteria
could also be used as part of a basis for classification. We also note
that many of these vehicles have front axle weight ratings greater than
14,600 pounds.
Although the agencies agree that these vocational tractors are
operated differently than line-haul tractors and therefore fit more
appropriately into the vocational vehicle category, we need to ensure
that only tractors that are truly vocational tractors are classified as
such. Upon further consideration of the comments received the agencies
have decided to allow manufacturers to exclude certain vocational-type
tractors from the combination tractor standards, and instead be subject
to the standards for vocational vehicles. A vehicle determined by the
manufacturer to be a HHD vocational tractor would fall into the HHD
vocational vehicle subcategory and be regulated as a vocational
vehicle. Similarly, MHD which the manufacturer chooses to reclassify as
vocational tractors will be regulated as a MHD vocational vehicle.
Specifically, under the provision being finalized at 40 CFR 1037.630
and NHTSA's regulation at 49 CFR 523.2 of today's rules only the
following three types of vocational tractors are eligible for
reclassification by the manufacturer:
(1) Low-roof tractors intended for intra-city pickup and delivery,
such as those that deliver bottled beverages to retail stores.
(2) Tractors intended for off-road operation (including mixed
service operation), such as those with reinforced frames and increased
ground clearance.
(3) Tractors with a GCWR over 120,000 pounds.
As adopted in 40 CFR 1037.230(a)(1)(xiii), manufacturers will be
required to group vocational tractors into a unique family, separate
from other combination tractors and vocational vehicles. The provision
being adopted in 40 CFR 1037.630 and 49 CFR 535.8 requires the
manufacturers to summarize in their applications their basis for
believing that the vehicles are eligible for manufacturer
reclassification as vocational tractors. EPA and NHTSA could ask for a
more detailed description of the basis and EPA would deny an
application for certification where it determines the manufacturer
lacks an adequate basis for reclassification. The manufacturer would
then have to resubmit a modified application to certify the vehicles in
question to the tractor standards. Where we determine that a
manufacturer is not applying this allowance in good faith, we may
require that manufacturer to obtain preliminary approval before using
this allowance. This would mean that a manufacturer would need to
submit its detailed records to EPA and receive formal approval before
submitting its application for certification. The agencies plan to
monitor how manufacturers classify their tractor fleets and would
reconsider the issue of vocational tractor classification in a future
rulemaking if necessary.
Because the difference between some vocational tractors and line-
haul tractors is potentially somewhat subjective, we are also including
an annual sales limit of 7,000 vocational tractors per manufacturer
(based on a three year rolling average) consistent with past production
volumes of such vehicles. It is important to note, however, that we do
not expect it to be common for manufacturers to be able to justify
classifying 7,000 vehicles as vocational tractors in a given model
year.
Under the regulations being promulgated in 40 CFR 1037.630 and 49
CFR 523.2, manufacturers will be required to keep records of how they
determined that such vehicles qualify as vocational. These records
would be more detailed than the description submitted in the
applications. Typically, this would be a combination of records of the
design features and/or purchasers of the vehicles. The agencies have
analyzed the design features that reflect the special needs of these
vocational tractors in the three areas noted above--mixed service,
heavy haul, and urban delivery. Mixed service applications, such as
construction trucks, typically require higher ground clearance and
approach angle to accommodate non-paved roads. In addition, they often
require frame rails with greater resisting bending moment (RBM) because
of the terrain where they operate.\54\ The mixed service
[[Page 57138]]
applications also sometimes require higher front axle weight ratings to
accommodate extra loads and/or power take off systems for additional
capability. Heavy haul tractors are typically designed with frame rails
with extra strength (greater RBM) and higher front axle weight ratings
to accommodate the heavy payloads. Often the heavy haul tractors will
also have higher ground clearance and greater approach angle for
similar reasons as the mixed service applications. Lastly, heavy haul
vehicles require a total gear reduction of 57:1 or greater to provide
the torque necessary to start the vehicle moving. Urban delivery
tractors, such as beverage haulers, have less defined design features
that reflect their operational needs. These vehicles offer options
which include high RBM rails and front axle weight ratings, but not all
beverage trucks are specified with these options. The primary
differentiation of these urban delivery tractors is their operation.
For this final rulemaking, the agencies projected the costs and
benefits of the program considering this provision. As detailed in RIA
Section 5.3.2.2.1, the agencies assumed that approximately 20 percent
of short-haul tractors sold in 2014 model year and beyond will be
vocational tractors. As such, these vehicles will experience benefits
reflective of a FTP-certified engine and tire rolling resistance
improvement at the technology costs projected in the rules for
vocational vehicles.
---------------------------------------------------------------------------
\54\ 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. An example line haul truck is the
Mack Pinnacle which has a RBM of 1,390,000 lb-in, as shown at http://www.macktrucks.com/assets/MackMarketing/Specifications/CXU6124x2PinAxleBack.pdf.
---------------------------------------------------------------------------
(1) What is the form of the Class 7 and 8 tractor CO2
emissions and fuel consumption standards?
As proposed, EPA and NHTSA are finalizing 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 light-duty 2012-16 MY vehicle rule, in
which the standards are based on the attribute of vehicle
``footprint,'' the existing heavy-duty highway engine standards for
criteria pollutants have for many years been based on a vehicle weight
attribute (Light Heavy, Medium Heavy, Heavy Heavy) with different
useful life periods, which is a similar approach finalized for the
engine GHG and fuel consumption standards discussed below.
Heavy-duty combination tractors are built to move freight. The
ability of a vehicle 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 combination 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 GCWR of
greater than 80,000 pounds, the effective weight limit on the federal
highway system except in states with preexisting higher weight limits.
Consistent with the recommendation in the National Academy of Sciences
2010 Report to NHTSA,\55\ the agencies are finalizing 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 vehicles have better specific fuel consumption and GHG
emissions than lower payload capacity vehicles. Therefore, since the
amount of payload that a Class 7 vehicle can carry is less than the
Class 8 vehicle'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 finalizing separate standards for
Class 7 and Class 8 tractors.
---------------------------------------------------------------------------
\55\ See 2010 NAS Report, Note 21, Recommendation 2-1.
---------------------------------------------------------------------------
The agencies are not finalizing 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 are 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 vehicles 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
[[Page 57139]]
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 using the roof height of the tractor to determine the
trailer type required to be used to demonstrate compliance of a vehicle
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 determined by
market foces linked 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.\56\ Therefore, 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 finalizing separate standards for sleeper cabs and day cabs.\57\
---------------------------------------------------------------------------
\56\ 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).
\57\ The agencies note, as discussed in the previous section,
that some day cabs and sleeper cabs will be reclassified as
vocational tractors and if so will not be subject to the combination
tractor standards.
---------------------------------------------------------------------------
The agencies received comments from industry stakeholders (EMA,
Allison Transmission, Bosch, and the Heavy-Duty Fuel Efficiency
Leadership Group) and ICCT supporting the nine tractor regulatory
subcategories proposed and did not receive any comments which supported
an alternate classification. Thus, to account for the relevant
combinations of these attributes, the agencies are adopting the
classification scheme proposed, segmenting 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
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. As proposed, the agencies are treating
tractors with adjustable roof fairings as low roof tractors that will
tested with the fairing in its lowest position.
(2) What are the Final Class 7 and 8 Tractor and Engine CO2
Emissions and Fuel Consumption Standards and Their Timing?
In developing the final standards for Class 7 and 8 tractors and
for the engines used in these tractors, 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 associated
engines, the necessary 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
on whose performance the final tractor standards are predicated are
improvements in aerodynamic design, lower rolling resistance tires,
extended idle reduction technologies, and lightweighting of the
tractor. The technologies on whose performance the final tractor
standards are predicated are engine friction reduction, aftertreatment
optimization, and turbocompounding, among others, as described in RIA
Chapter 2.4. The agencies' evaluation showed that these technologies
are available today, but have very low application rates on current
vehicles and engines. 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 RIA Chapter 2, explaining as well the
basis for the agencies' conclusion not to adopt standards which are
less stringent or more stringent.
(a) Tractor Standards
The agencies are finalizing the following standards for Class 7 and
8 combination tractors in Table 0-1, using the subcategorization
approach that was proposed. 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 finalizing standards starting for that model year
predicated on performance of those technologies. EPA is finalizing more
stringent tractor standards for the 2017 model year which reflect the
CO2 emissions reductions required for 2017 model year
engines. (As explained in Section II.B(3)(h)(v) 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 tractor manufacturers
installing additional vehicle technologies. EPA's final standards apply
throughout the useful life period as described in Section V. As
proposed, and as discussed further in Section IV below, manufacturers
may generate and use credits from Class 7 and 8 combination tractors to
show compliance with the standards.
NHTSA is finalizing 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 within EISA. The 2014 and 2015 model year standards are
voluntary in that manufacturers are not subject to them unless they
opt-in to the standards.\58\ Manufacturers that opt in become subject
to NHTSA standards for all regulatory categories. NHTSA is also
adopting new tractor standards for the 2017 model year which reflect
additional improvements in only the heavy-duty engines. As proposed,
NHTSA is not implementing an in-use compliance program for fuel
consumption because it does not anticipate that there will be notable
deterioration of fuel consumption over the useful life of the vehicle.
---------------------------------------------------------------------------
\58\ Once a manufacturer opts into the NHTSA program it must
stay in the program for all the optional MYs.
---------------------------------------------------------------------------
As explained more fully in Section III and Chapter 2 of the RIA,
EPA and NHTSA are not adopting more stringent tractor standards for
2014-2017 MY. The final tractor standards are based on
[[Page 57140]]
the maximum application rates of available technologies considering the
available lead time, and we explain in Section III and Chapter 2 of the
RIA that use of additional technologies, or further application of the
technologies already mentioned would be either infeasible in the lead
time afforded, or uneconomic.
Table II-1--Heavy-Duty Combination Tractor Emissions and Fuel Consumption Standards
----------------------------------------------------------------------------------------------------------------
Day cab Sleeper cab
-----------------------------------------------------------
Class 7 Class 8 Class 8
----------------------------------------------------------------------------------------------------------------
2014 Model Year CO2 Grams per Ton-Mile
----------------------------------------------------------------------------------------------------------------
Low Roof............................................ 107 81 68
Mid Roof............................................ 119 88 76
High Roof........................................... 124 92 75
----------------------------------------------------------------------------------------------------------------
2014-2016 Model Year Gallons of Fuel per 1,000 Ton-Mile \59\
----------------------------------------------------------------------------------------------------------------
Low Roof............................................ 10.5 8.0 6.7
Mid Roof............................................ 11.7 8.7 7.4
High Roof........................................... 12.2 9.0 7.3
----------------------------------------------------------------------------------------------------------------
2017 Model Year CO2 Grams per Ton-Mile
----------------------------------------------------------------------------------------------------------------
Low Roof............................................ 104 80 66
Mid Roof............................................ 115 86 73
High Roof........................................... 120 89 72
----------------------------------------------------------------------------------------------------------------
2017 Model Year and Later Gallons of Fuel per 1,000 Ton-Mile
----------------------------------------------------------------------------------------------------------------
Low Roof............................................ 10.2 7.8 6.5
Mid Roof............................................ 11.3 8.4 7.2
High Roof........................................... 11.8 8.7 7.1
----------------------------------------------------------------------------------------------------------------
The standard values shown above differ somewhat from the proposal,
reflecting refinements made to the GEM in response to comments. For
example, the agencies received comments from stakeholders concerned
that the 2017 MY tractor standards appeared to be backsliding because
the reductions were not in line with the reductions expected from the
2017 MY engine standards. The agencies reviewed the issue and found
that the engine maps we created in the GEM for the 2017 model year for
the proposal did not appropriately reflect the engine improvements.
Therefore, the agencies developed new fuel maps for the GEM v2.0 which
fully reflect the engine improvements due to the 2017 MY standards.\60\
These changes to the GEM did not impact our estimates of the relative
effectiveness of the greenhouse gas emissions and fuel consumption
improving technologies modeled in this final action nor the overall
cost or benefits estimated for these final vehicle standards.
---------------------------------------------------------------------------
\59\ As noted above, manufacturers may voluntarily opt-in to the
NHTSA fuel consumption program in 2014 or 2015. Once a manufacturer
opts into the NHTSA program it must stay in the program for all the
optional MYs.
\60\ See RIA Chapter 4 for the engine fuel maps used in GEM
v2.0.
---------------------------------------------------------------------------
Based on our analysis, the 2017 model year standards for
combination tractors and engines represent up to a 23 percent reduction
in CO2 emissions and fuel consumption over a 2010 model year
baseline tractor (the baseline sleeper cab does not include idle
shutdown technology), as detailed in Section III.A.2. In considering
the feasibility of vehicles to comply with the standards, EPA also
considered the potential for CO2 emissions to increase
during the regulatory useful life of the product. As we discuss
separately in the context of deterioration factor (DF) testing, we have
concluded that CO2 emissions are likely to stay the same or
actually decrease in-use compared to new certified configurations. In
general, engine and vehicle friction decreases as products wear in
leading to reduced parasitic losses and lower CO2 emissions.
Similarly, tire rolling resistance falls as tires wear due to the
reduction in tread height. In the case of aerodynamic components, we
project no change in performance through the regulatory life of the
vehicle since there is essentially no change in their physical form as
vehicles age. Similarly, weight reduction elements such as aluminum
wheels are not projected to increase in mass through time, and hence,
we can conclude will not deteriorate with regard to CO2
performance in-use. Given all of these considerations, EPA is confident
in projecting that the standards finalized today will be technical
feasible throughout the regulatory useful life of the program.
(b) Standards for Engines Installed in Combination Tractors
EPA is adopting GHG standards and NHTSA is adopting fuel
consumption standards for new heavy-duty engines. This section
discusses the standards for engines used in Class 7 and 8 combination
tractors and also provides some overall background information. We also
note that the agencies are adopting standards for heavy-duty engines
used in vocational vehicles. However, as explained further below,
compliance with the standards would be measured using different test
procedures, corresponding with actual vehicle use, depending on whether
the vehicle in which the engine is installed is a Class 7 and 8
combination tractor or a vocational vehicle.
The heavy-duty engine standards vary depending on the type of
vehicle in which they are installed, as well as whether the engines are
compression ignition or spark ignition. The agencies are adopting
separate engine fuel consumption and GHG emissions standards for
engines installed in combination tractors versus engines installed in
vocational vehicles. Also, for the purposes of the GHG engine emissions
and engine fuel consumption standards, the agencies are adopting engine
subcategories that match EPA's
[[Page 57141]]
existing criteria pollutant emissions regulations for heavy-duty
highway engines which established four regulatory service classes that
represent the engine's intended and primary vehicle application.\61\
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 service class. The engines in these four
regulatory service classes range in size between approximately five
liters and sixteen liters. This subcategory structure enables the
agencies to set standards that appropriately reflect the technology
available for engines installed in each type of vehicle, and that are
therefore technologically feasible for these engines. This is the same
engine classification scheme the agencies proposed, and there were no
adverse comments in response to the proposal.
---------------------------------------------------------------------------
\61\ See 40 CFR 86.90-2.
---------------------------------------------------------------------------
Heavy heavy-duty diesel and medium heavy-duty diesel engines are
used today in combination tractors. The following section refers to the
engine standards for these types of engines. This section does not
cover gasoline or light heavy-duty diesel engines because they are not
used in combination tractors.
In the NPRM, the agencies proposed CO2 and fuel
consumption standards for HD diesel engines to be installed in Class 7
and 8 combination tractors as shown in Table II-2.\62\
---------------------------------------------------------------------------
\62\ The agencies note that the CO2 and fuel
consumption standards for Class 7 and 8 combination tractors do not
cover gasoline or LHDD engines, as those are not used in Class 7 and
8 combination tractors.
Table II-2--Proposed Heavy-duty Diesel Engine Standards for Engines Installed in Tractors
----------------------------------------------------------------------------------------------------------------
Effective 2014 model year Effective 2017 Model Year
---------------------------------------------------------------
Voluntary fuel Fuel
CO2 standard consumption CO2 standard consumption
(g/bhp-hr) standard (gal/ (g/bhp-hr) standard (gal/
100 bhp-hr) 100 bhp-hr)
----------------------------------------------------------------------------------------------------------------
MHD diesel engine............................... 502 4.93 487 4.78
HHD diesel engine............................... 475 4.67 460 4.52
----------------------------------------------------------------------------------------------------------------
The agencies proposed to require diesel engine manufacturers to
achieve, on average, a three percent reduction in fuel consumption and
CO2 emissions for the 2014 standards over the baseline MY
2010 performance for the engines.\63\ The agencies' preliminary
assessment of the findings of the 2010 NAS Report and other literature
sources indicated that there are technologies available to reduce fuel
consumption by this amount in the time frame in the lead time provided
by the rules. These technologies include improved turbochargers,
aftertreatment optimization, and low temperature exhaust gas
recirculation.
---------------------------------------------------------------------------
\63\ The baseline HHD diesel engine performance in MY 2010 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. The
baseline MHD diesel engine performance on the SET cycle is 518 g
CO2/bhp-hr (5.09 gallon/100-bhp-hr) in MY 2010. Further
discussion of the derivation of the baseline can be found in Section
III.
---------------------------------------------------------------------------
The agencies also proposed to require diesel engine manufacturers
to achieve, on average, a six percent reduction in fuel consumption and
CO2 emissions for the 2017 MY standards over the baseline MY
2010 performance for MHD and HHD diesel engines required to use the
SET-based standard. The agencies stated that additional reductions
could likely be achieved through the increased refinement of the
technologies projected to be implemented for 2014, plus the addition of
turbocompounding, which the agencies' analysis showed would require a
longer development time and would not be available in MY 2014. The
agencies therefore proposed to provide additional lead time to allow
for the introduction of this additional technology, and to wait until
2017 to increase stringency to levels reflecting application of this
technology.
The agencies proposed that the MHD and HHD diesel engine
CO2 standards for Class 7 and 8 combination tractors would
become effective in MY 2014 for EPA, with more stringent CO2
standards becoming effective in MY 2017, while NHTSA's fuel consumption
standards would become effective in MY 2017, which would be both
consistent with the EISA four-year minimum lead-time requirements and
harmonized with EPA's timing. The agencies explained that the three-
year timing, besides being required by EISA, made sense because EPA's
heavy-duty highway engine program for criteria pollutants had begun to
provide new emissions standards for the industry in three year
increments, which had caused the heavy-duty engine product plans to
fall largely into three year cycles reflecting this regulatory
environment. To further harmonize with EPA, NHTSA proposed voluntary
fuel consumption standards for MHD and HHD diesel engines that are
equivalent to EPA CO2 standards for MYs 2014-2016, allowing
manufacturers to opt into the voluntary standards in any of those model
years.\64\ NHTSA proposed that manufacturers could opt into the program
by declaring their intent to opt in to the program at the same time
they submit the Pre-Certification Compliance Report, and that a
manufacturer opting into the program would begin tracking credits and
debits beginning in the model year in which they opt into the program.
Both agencies proposed to allow manufacturers to generate and use
credits to achieve compliance with the HD diesel engine standards,
including averaging, banking, and trading (ABT) and deficit carry-
forward. The agencies sought comment on the proposed MHD and HHD engine
standards and timing.
---------------------------------------------------------------------------
\64\ Once a manufacturer opts into the NHTSA program it must
stay in the program for all the optional MYs and remain standardized
with the implementation approach being used to meet the EPA emission
program.
---------------------------------------------------------------------------
The agencies received comments from EMA, Navistar, Cummins, ACEEE,
Center for Biological Diversity, Detroit Diesel Corporation, American
Lung Association, and the Union of
[[Page 57142]]
Concerned Scientists. Comments were divided with respect to the
proposed levels of stringency. While Cummins and DDC expressed support
for the CO2 and fuel consumption standards for diesel
engines, and EMA and Navistar stated the standards could be met if the
flexibilities outlined in the NPRM are finalized as proposed, Navistar
also stated that the model year 2017 standard may not be feasible since
what the agencies characterized as existing technologies are not in
production for all manufacturers. In contrast, environmental groups and
NGOs stated that the standards did not reflect the potential reductions
outlined in the 2010 NAS study and should be more stringent. CBD argued
that the standards were not set at the maximum feasible level by
definition, because the agencies had said that they were based on the
use of existing technologies. In addition, the Center for Neighborhood
Technology encouraged the agencies to implement the rules as soon as
possible, beginning in the 2012 model year.
In light of the above comments, the agencies re-evaluated the
technical basis for the heavy-duty engine standards. The baseline HHD
diesel engine performance in 2010 model year on the SET is estimated at
490 g CO2/bhp-hr (4.81 gal/100 bhp-hr), based on our
analysis of 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
estimated to be 518 g CO2/bhp-hr (5.09 gallon/100-bhp-hr)
for the 2010 model year. Further discussion of the derivation of the
baseline can be found in Section III. The agencies believe that the MY
2014 standards can be achieved by most manufacturers through the use of
technologies time frame such as improved aftertreatment systems,
friction reduction, improved auxiliaries, turbochargers, pistons, and
other components. These standards will require diesel engine
manufacturers to achieve on average a three percent reduction in fuel
consumption and CO2 emissions over the baseline 2010 model
year levels.
However, in recognizing that some manufacturers have engines that
would not meet the standard even after applying technologies that
improve GHG emissions and fuel consumption by three percent, the
agencies are finalizing both the proposed ABT provisions for these
engines and also an optional alternate engine standard for 2014 model
year, described in more detail below. We believe that concerns
expressed by Navistar regarding the 2014 MY standards will be addressed
by this alternative standard. The agencies also continue to believe
that the 2017 MY standards are achievable using the above approaches
and, in the case of SET certified engines, turbocompounding. While
Navistar commented that the 2017 MY standard may be challenging because
not all manufacturers are presently producing the technologies that may
be required to meet the standards, the agencies believe that since
manufacturers that may require turbocompounding to meet the standards
will not have to do so until 2017 MY, there will be sufficient lead
time for all manufacturers to introduce this technology. As noted
above, by MY 2017 all MHD and HHD engines installed in combination
tractors should have gone through a redesign during which all needed
technology can be applied. We note that we are finalizing these
standards as proposed based on the assessment that most manufacturers
(not just Navistar) will need to make improvements to existing engine
systems in order to meet the standards. EPA's HD diesel engine
CO2 emission standards and NHTSA's HD diesel engine fuel
consumption standards for engines installed in tractors are presented
in Table II-3. As explained above, the first set of standards take
effect with MY 2014 (mandatory standards for EPA, voluntary standards
for NHTSA), and the second set take effect with MY 2017 (mandatory for
both agencies).
Table II-3--Final Heavy-duty Diesel Engine Standards for Engines Installed in Tractors
----------------------------------------------------------------------------------------------------------------
Effective 2014 model year Effective 2017 model year
---------------------------------------------------------------
Voluntary fuel Fuel
CO2 standard consumption CO2 standard consumption
(g/bhp-hr) standard (gal/ (g/bhp-hr) standard (gal/
100 bhp-hr) 100 bhp-hr)
----------------------------------------------------------------------------------------------------------------
MHD diesel engine............................... 502 4.93 487 4.78
HHD diesel engine............................... 475 4.67 460 4.52
----------------------------------------------------------------------------------------------------------------
The agencies have also decided to remove NHTSA's proposed Pre-
Certification Compliance Report requirement. Instead, manufacturers
must submit their decision to opt into NHTSA's voluntary standards for
the 2014 through 2016 model years as part of its certification process
with EPA. Once a manufacturer opts into the NHTSA program it must stay
in the program for all the subsequent optional model years.
Manufacturers that opt in become subject to NHTSA standards for all
regulatory categories. The declaration statement must be entered prior
to or at the same time the manufacturer submits its first application
for a certificate of conformity. NHTSA will begin tracking credits and
debits beginning in the model year in which a manufacturer opts into
its program.
Compliance with the CO2 emissions and fuel consumption
standards will be evaluated based on the SET engine test cycle. In the
NPRM, the agencies proposed standards based on the SET cycle for MHD
and HHD engines used in tractors due to these engines' primary use in
steady state operating conditions (typified by highway cruising).
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 will be required to meet the standard based on the SET, which
is a steady state test cycle.
The agencies gave full consideration to the need for engine
manufacturers to redesign and upgrade their engines during the MYs
2014-2017 to meet standards, and fully considered the cost-
effectiveness of the standards and the available lead time. The final
two-step CO2 emission and fuel consumption standards
recognize the opportunity for technology improvements over the
rulemaking time frame, while reflecting the typical engine
manufacturers' product plan cycles. Over these four model years there
will be an opportunity for manufacturers to evaluate almost every one
of their
[[Page 57143]]
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 and flexibilities needed to incorporate technology that will
achieve the final GHG and fuel consumption standards within the normal
engine redesign process. This is an important aspect of the final
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.\65\ This time period will also provide
manufacturers the opportunity to plan for compliance using a multi-year
time frame, again in alignment with their normal business practice.
Further details on lead time, redesigns and technical feasibility can
be found in Section III.
---------------------------------------------------------------------------
\65\ See 75 FR at 25467-68 for further discussion of the
negative cost implications of establishing requirements outside of
the redesign cycle.
---------------------------------------------------------------------------
The agencies continue to believe the standards for MHD and HHD
diesel engines installed in combination tractors are the most stringent
technically feasible in the time frame established in this regulation.
The standards will require a 3 percent reduction in engine fuel
consumption and GHG emissions in 2014 MY based on improvements to
engine components and aftertreatment systems. The 2017 MY standards
will require a 6 percent reduction in fuel consumption and GHG
emissions over a 2010 model year baseline and assumes the introduction,
for some engines, of technologies such as turbocompounding. The
standards, however, are not premised on the introduction of
technologies that are still in development--such as Rankine bottoming
cycle--since these approaches cannot be introduced without further
technical development or engine re-design.\66\
---------------------------------------------------------------------------
\66\ See RIA Chapter 2.4.2.7.
---------------------------------------------------------------------------
Additional discussion on technical feasibility is included in
Section III below and in Chapter 2 of the RIA.
The agencies recognize, however, that the schedule of changes for
the final standards may not be the most cost-effective one for all
manufacturers. The agencies also sought comment as to whether an
alternate phase-in schedule for the HD diesel engine standards for
combination tractors should be considered. In developing the proposal,
heavy-duty engine manufacturers stated that the phase-in of the GHG and
fuel consumption standards should be aligned with the On Board
Diagnostic (OBD)\67\ phase-in schedule, which includes new requirements
for heavy-duty vehicles in the 2013 and 2016 model years. The agencies
did not adopt this suggestion in the proposal, explaining that the
credit averaging, banking and trading provisions would provide
manufacturers with considerable flexibility to manage their GHG and
fuel efficiency standard compliance plans--including the phase-in of
the new heavy-duty OBD requirements--but requested comment on whether
EPA and NHTSA should provide an alternate phase-in schedules that would
more explicitly accommodate this request in the event that
manufacturers did not agree that the ABT provisions mitigated their
concern about the GHG/fuel consumption standard phase-in. See 75 FR at
74178.
---------------------------------------------------------------------------
\67\ On-board diagnostics (OBD) is a computer-based emissions
monitoring system that was first required in 2007 for vehicles under
14,000 pounds (65 FR 59896, Oct. 6, 2000) and in 2010 for vehicles
over 14,000 pounds (74 FR 8310, Feb. 24, 2009).
---------------------------------------------------------------------------
In response, Cummins, Engine Manufacturers Association, and DTNA
commented that their first choice was a delay in the OBD effective date
for one year to the 2014 model year. The industry's second choice was
to provide manufacturers with an optional GHG and fuel consumption
phase-in that aligns their product development plans with their current
plans to meet the OBD regulations for EPA and California in the 2013
and 2016 model years. These commenters argued that meeting the OBD
regulation in the 2013 model year already poses a significant
challenge, and that having to meet GHG and fuel consumption standards
beginning in 2014 could require them to redesign and recertify their
products just one year later. They argued that bundling design changes
where possible can reduce the burden on industry for complying with
regulations, so aligning the introduction of the OBD, GHG, and fuel
consumption standards could help reduce manufacturers' burden for
product development, validation and certification.
In order to provide additional flexibility for manufacturers
looking to align their technology changes with multiple regulatory
requirements, the agencies are finalizing an alternate ``OBD phase-in''
option for meeting the standards for MHD and HHD diesel engines
installed in tractors (in addition to engines installed in vocational
vehicles as noted below in Section II.D), which delivers equivalent
CO2 emissions and fuel consumption reductions as the primary
standards for the engines built in the 2013 through 2017 model years,
as shown in Table II-4. The optional OBD phase-in schedule requires
that engines built in the 2013 and 2016 model years to achieve greater
reductions than the engines built in those model years under the
primary program, but requires fewer reductions for the engines built in
the 2014 and 2015 model years.
Table II-4--Comparison of CO2 reductions for the HHD and MHD Tractor Standards Under the Alternative OBD Phase-
In and Primary Phase-In
----------------------------------------------------------------------------------------------------------------
HHD Tractor engines MHD Tractor engines
-----------------------------------------------------------------------------
Difference Difference
Primary Optional in lifetime Primary Optional in lifetime
phase-in phase-in CO2 engine phase-in phase-in CO2 engine
standard standard emissions standard standard emissions
(g/bhp-hr) (g/bhp-hr) (MMT) (g/bhp-hr) (g/bhp-hr) (MMT)
----------------------------------------------------------------------------------------------------------------
Baseline.......................... 490 490 -- 518 518 --
2013 MY Engine.................... 490 485 14 518 512 17
2014 MY Engine.................... 475 485 -28 502 512 -28
2015 MY Engine.................... 475 485 -28 502 512 -28
2016 MY Engine.................... 475 460 42 502 487 42
2017 MY Engine.................... 460 460 0 487 487 0
Net Reductions (MMT).............. ........... ........... 0 ........... ........... 3
----------------------------------------------------------------------------------------------------------------
[[Page 57144]]
The technologies for the 2013 model year optional standard include
a subset of technologies that could be used to meet the primary 2014
model year standard. The agencies believe this approach is appropriate
because the shorter lead time provided for manufacturers selecting this
option limits the technologies which can be applied. However, in order
to maintain equivalent CO2 emissions and fuel consumption
reduction over the 2013 through 2017 model year period, it is necessary
for the 2016 model year standard to be equal to the 2017 model year
standard, using the same technology paths described for the primary
engine program. If a manufacturer selects this optional phase-in, then
the engines must be certified starting in the 2013 model year and
continue using this phase-in through 2016 model year. That is, once
electing this compliance path, manufacturers must adhere to it.\68\
Manufacturers may opt into the optional OBD phase-in through the
voluntary NHTSA program, but must opt in in the 2013 model year and
continue using this phase-in through the 2016 model year. Manufacturers
that opt in to the voluntary NHTSA program in 2014 and 2015 will be
required to meet the primary phase-in schedule and may not adopt the
OBD phase-in option. Table II-5 below presents the final HD diesel
engine CO2 emission standards under the ``OBD phase-in''
option.
---------------------------------------------------------------------------
\68\ See Sec. 1036.150(e).
Table II-5--Optional Heavy-Duty Engine Standard Phase-in Schedule for
Tractor Engines
------------------------------------------------------------------------
MHD Diesel engine HHD Diesel engine
------------------------------------------------------------------------
Effective 2013 Through 2015 Model Year
------------------------------------------------------------------------
CO2 Standard (g/bhp-hr)......... 512 485
Voluntary Fuel Consumption 5.03 4.76
Standard (gallon/100 bhp-hr)...
------------------------------------------------------------------------
Effective 2016 Model Year and Later
------------------------------------------------------------------------
CO2 Standard (g/bhp-hr)......... 487 460
Fuel Consumption (gallon/100 bhp- 4.78 4.52
hr)............................
------------------------------------------------------------------------
Although the agencies believe that the standards for the HD diesel
engines installed in combination tractors are generally appropriate,
cost-effective, and technologically feasible in the rulemaking time
frame, we also recognize that when regulating a category of engines for
the first time, there will be individual products that may deviate
significantly from the baseline level of performance, whether because
of a specific approach to criteria pollution control, or due to engine
calibration for specific applications or duty cycles. In the current
fleet of 2010 and 2011 model year engines used in combination tractors,
NHTSA and EPA understand that there is a relatively small group of
legacy engines that are up to approximately 25 percent worse than the
average baseline for other engines. For this group of legacy MHD and
HHD diesel engines installed in tractors, when compared to the typical
performance levels of the majority of the engines in the fleet and the
fuel consumption/GHG emissions reductions that the majority of engines
would achieve through increased application of technology, the same
reduction from the industry baseline may not be possible at reasonably
comparable cost given the same amount of lead-time, because these
products may require a total redesign in order to meet the standards.
Manufacturers of the MHD and HHD diesel engines installed in tractors
with atypically high baseline CO2 and fuel consumption
levels may also, in some instances, have a limited line of engines
across which to average performance to meet the generally-applicable
standards.
To account for this possibility, the agencies requested comment in
the NPRM on the establishment of an optional alternative MHD and HHD
engine standard for those engines installed in combination tractors
which would be set at 3 percent below a manufacturer's 2011 engine
baseline emissions and fuel consumption, or alternatively, at 2 percent
below a manufacturer's 2011 baseline. The agencies also requested
comment on extending this optional standard one year (to the 2017 MY)
for a single engine family at a 6 percent level below the 2011
baseline.\69\ This option would not be available unless and until a
manufacturer had exhausted all available credits and credit
opportunities, and engines under the optional standard could not
generate credits.
---------------------------------------------------------------------------
\69\ See 75 FR at 74178-74179.
---------------------------------------------------------------------------
In comments to the NPRM, Navistar supported the alternative engine
standard, but recommended that it be set at 2 percent below the
manufacturer's 2011 baseline. They also supported the extension to 2017
MY at 6 percent. Navistar provided CBI in support of its comments.
Volvo, DTNA, environmental groups, NGOs, and the New York State
Department of Environmental Conservation opposed the optional engine
standard, arguing that existing flexibilities are sufficient to allow
compliance with the standards and that all manufacturers should be held
to the same standards.
Based on the CBI submitted by Navistar, the agencies found that a
large majority of the HD diesel engines used in Class 7 and 8
combination tractors were relatively close to the average baseline,
with some above and some below, but also that some legacy MHD and HDD
diesel engines were far enough away from the baseline that they could
not meet the generally-applicable standards with application of
technology that would be available for those specific engines by 2014.
The agencies continue to believe that an interim alternative standard
is needed for these products, and that an interim standard reflects a
legitimate difference between products starting from different fuel
consumption/GHG emitting baselines. As explained in the proposal, it is
legally permissible to accommodate short term lead time constraints
with alternative standards. Commenters did not dispute that there are
legacy engine families with significantly higher CO2
emissions and fuel consumption baselines, and that these engines
require longer lead time to meet the principal standards in the early
model years of the program. Although the agencies acknowledge the view
that all manufacturers should be subject to the same burden for meeting
the primary standards, the agencies believe that, in the initial years
of a new program,
[[Page 57145]]
additional flexibilities should be provided. The GHG standards and fuel
consumption standards are first-time standards for these engines, so
the possibility of significantly different baselines is not
unexpected.\70\ Moreover, the agencies do not believe that the
alternative standard affords a relative competitive advantage to the
higher emitting legacy engines: the same level of improvement at the
same cost will be required of those tractor engines, and in addition,
by 2017 MY, those tractor engines will be required to make the
additional improvements to meet the same standards as other engines. We
believe that the concern expressed by Navistar regarding the 2014 MY
standards will be addressed by this alternative. The agencies also
continue to believe the 2017 MY standards are achievable using the
above approaches and, in the case of MHD and HHD engines installed in
tractors, turbocompounding. While Navistar commented that the 2017 MY
standard may be challenging, the agencies believe that since
manufacturers which may need to use turbocompounding to meet the
standards will not have to do so until 2017 MY, there will be
sufficient lead time for all engine manufacturers to introduce this
technology. Thus, the agencies are finalizing a regulatory alternative
whereby a manufacturer, for an interim period of the 2014-2016 model
years, 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. 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. This is similar to EPA's approach in the
light-duty rule for handling a certain subset of vehicles that were
deemed unable to meet the generally-applicable GHG standards during the
2012-2015 time frame due to higher initial baseline conditions, and
which therefore needed alternate standards in those model years.\71\
---------------------------------------------------------------------------
\70\ See 75 FR at 74178.
\71\ See 75 FR 25414-25419.
---------------------------------------------------------------------------
The agencies stress that this is a temporary and limited option
being implemented to address diverse manufacturer needs associated with
complying with this first phase of the regulations. As codified in 40
CFR 1036.620 and 49 CFR 535.5(d), this optional standard will be
available only for the 2014 through 2016 model years, because we
believe that manufacturers will have had ample opportunity to make
appropriate changes to bring their product performance into line with
the rest of the industry after that time. As proposed, the final rules
require that manufacturers making use of these provisions for the
optional standard would need to exhaust all credits available to this
averaging set prior to using this flexibility and would not be able to
generate emissions credits from other engines in the same regulatory
averaging set as the engines complying using this alternate approach.
The agencies note again that manufacturers choosing to utilize this
option in MYs 2014-2016 will have to make a greater relative
improvement in MY 2017 than the rest of the industry, since they will
be starting from a worse level--for compliance purposes, emissions from
engines certified and sold at the three percent level will be averaged
with emissions from engines certified and sold at more stringent levels
to arrive at a weighted average emissions for all engines in the
subcategory. Again, this option can only be taken if all other credit
opportunities have been exhausted and the manufacturer still cannot
meet the primary standards. If a manufacturer chooses this option to
meet the EPA emission standards in the MY 2014-2016, and wants to opt
into the NHTSA fuel consumption program in these same MYs it must
follow the exact path followed under the EPA program utilizing
equivalent fuel consumption standards. Since the NHTSA standards are
optional in 2014, manufacturers may choose not to adopt either the
alternative engine standard or the regular voluntary standard by not
participating in the NHTSA program in 2014 and 2015.
Some commenters argued that manufacturers could game the standard
by establishing an artificially high 2011 baseline emission level. This
could be done, for example, by certifying an engine with high fuel
consumption and GHG emissions that is either: (1) Not sold in
significant quantities; or (2) later altered to emit fewer GHGs and
consume less fuel through service changes. In order to mitigate this
possibility, the agencies are requiring that the 2011 model year
baseline must be developed by averaging emissions over all engines in
an engine family certified and sold for that model year so as to
prevent a manufacturer from developing a single high GHG output engine
solely for the purpose of establishing a high baseline. As an
alternative, if a manufacturer does not certify all engine families in
an averaging set to the alternate standards, then the tested
configuration of the engine certified to the alternate standard must
have the same engine displacement and its rated power within 5 percent
of the highest rated power of the baseline tested configuration. In
addition, the tested configuration of the engine certified to the
alternate standard must be a configuration sold to customers. These
three requirements will prevent a manufacturer from producing an engine
with an artificially high power rating and therefore produce
artificially low grams of CO2 emissions and fuel consumption
per brake horsepower. In addition, the tested configurations must have
a BSFC equivalent to or better than all other configurations within the
engine family which will prevent a manufacturer from creating a
baseline configuration with artificially high CO2 emissions
and fuel consumption.
(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 finalizing would apply to
individual vehicles and engines. NHTSA is adopting an approach which
does not include in-use standards.
EPA proposed 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 to address measurement variability
inherent in comparing results among different laboratories and
different engines. The agency proposed a two percent adjustment factor
and requested comments and additional data during the proposal to
assist in developing an appropriate factor level. The agency received
additional data during the comment period which identified production
variability which was not accounted for at proposal. Details on the
development of the final adjustment factor are included in RIA Chapter
3. Based on the data received, EPA determined that the adjustment
factor in the final rules should be higher than the proposed level of
two percent. EPA is finalizing a three 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.
We are finalizing regulatory text (in Sec. 1036.150) to allow
engine manufacturers to used assigned
[[Page 57146]]
deterioration factors (DFs) without performing their own durability
emission tests or engineering analysis. However, the engines would
still be required to meet the standards in actual use without regard to
whether the manufacturer used the assigned DFs. This allowance is being
adopted as an interim provision applicable only for this initial phase
of standards.
Manufacturers will be allowed to use an assigned additive DF of 0.0
g/bhp-hr for CO2 emissions from any conventional engine
(i.e., an engine not including advance or innovative technologies).
Upon request, we could allow the assigned DF for CO2
emissions from engines including advance or innovative technologies,
but only if we determine that it would be consistent with good
engineering judgment. We believe that we have enough information about
in-use CO2 emissions from conventional engines to conclude
that they will not increase as the engines age. However, we lack such
information about the more advanced technologies.
EPA is also finalizing the proposed provisions requiring 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 is adopting provisions where the existing engine useful
life periods, as included in Table II-6, be broadened to include
CO2 emissions for both engines (See 40 CFR 1036.108(d)) and
tractors (See 40 CFR 1037.105).
Table II-6--Tractor and Engine Useful Life Periods
------------------------------------------------------------------------
Years Miles
------------------------------------------------------------------------
Medium Heavy-Duty Diesel Engines.................. 10 185,000
Heavy Heavy-Duty Diesel Engines................... 10 435,000
Class 7 Tractors.................................. 10 185,000
Class 8 Tractors.................................. 10 435,000
------------------------------------------------------------------------
(3) Test Procedures and Related Issues
The agencies are finalizing 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. Consistent with the
proposal, the test procedures related to the tractors are all new,
while the engine test procedures already established were built
substantially on EPA's current non-GHG emissions test procedures,
except as noted. This section discusses the final simulation model
developed for demonstrating compliance with the tractor standard and
the final engine test procedures.
(a) Vehicle Simulation Model
We are finalizing as proposed separate engine and vehicle-based
emission standards to achieve the goal of reducing emissions and fuel
consumption for both combination tractors and engines. Engine
manufacturers are subject to the engine standards while the Class 7 and
8 tractor manufacturers are required to install certified engines in
their tractors. The tractor manufacturer is also subject to a separate
vehicle-based standard which utilizes a vehicle simulation model to
evaluate the 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.
Consistent with the proposal, NHTSA and EPA are finalizing a
procedure 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.\72\ The EPA developed the Greenhouse gas Emissions
Model (GEM) for the specific purpose of this rulemaking 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 EPA and finalized 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 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
sought comments regarding other software packages which would better
serve the compliance purposes of the rules than the GEM, but did not
receive any recommendations.
---------------------------------------------------------------------------
\72\ See 2010 NAS Report. Note 21, Recommendation 8-4. Page 190.
---------------------------------------------------------------------------
The 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 the GEM based on the chassis test results from
two combination tractors tested at Southwest Research Institute. The
validation work conducted on this vehicle was 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 2 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 utilizing in compliance testing. Since the time of the
proposal, the EPA also conducted a validation of the GEM relative to a
commonly used vehicle simulation software, GT-Power. The results of
this validation found that the two software programs predicted the fuel
efficiency of each subcategory of tractor to be within 2 percent. Test
to test variation for heavy-duty vehicle chassis testing can be higher
than 4 percent due to driver variation alone. The final simulation
model is described in greater detail in Chapter 4 of the RIA and is
available for download by at (http://www.epa.gov/otaq/climate/regulations.htm).
After proposal, the agencies conducted a peer review of GEM version
1.0 which was proposed. In addition, we requested comment on all
aspects of
[[Page 57147]]
this approach to compliance determination in general and to the use of
the GEM in particular. The agencies received comments from stakeholders
and made changes for the release of GEM v2.0 to address concerns raised
in the comments, along with the comments received during the peer
review process. The most noticeable changes to the GEM include
improvements to the graphical user interface (GUI). In response to
comments, the agencies have reduced the amount of information required
in the Identification section; linked the inputs to the selected
subcategory while graying-out the items that are not applicable to the
subcategory; and added batch modeling capability to reduce the
compliance burden to manufacturers. In addition, substantial work went
into model validations and benchmarking against vehicle test data and
other commonly used vehicle simulation models.
The model also includes a new driver model, a simplified electric
system model, and revised engine fuel maps to better reflect the 2017
model year engine standards. The model in the final rulemaking uses the
targeted vehicle driving speed to estimate vehicle torque demand at any
given time, and then the power required to drive the vehicle is derived
to estimate the required accelerator and braking pedal positions. If
the driver misses the vehicle speed target, a speed correction logic
controlled by a PID controller is applied to adjust necessary
accelerator and braking pedal positions in order to match targeted
vehicle speed at every simulation time step. The enhanced driver model
used in the final rulemaking with its feed-forward driver controls more
realistically models driving behavior. The GEM v1.0, the proposed
version of the model, had four individual components to model the
electric system--starter, electrical energy system, alternator, and
electrical accessory. For the final rulemaking, the GEM v2.0 has a
single electric system model with a constant power consumption level.
Based on comments received, the agencies revisited the 2017 model year
proposed fuel maps, specifically the low load area, which was
extrapolated during the proposal and (incorrectly) generated negative
improvements. The agencies redeveloped the fuel maps for the final
rulemaking to better predict the fuel consumption of engines in this
area of the fuel consumption map. Details of the changes are included
in RIA Chapter 4.
To demonstrate compliance, a Class 7 and 8 tractor manufacturer
will measure the performance of specified tractor systems (such as
aerodynamics and tire rolling resistance), input the values into the
GEM, and compare the model's output to the standard. The rules require
that a tractor manufacturer provide the inputs for each of following
factors for each of the tractors it wishes 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-1.
[GRAPHIC] [TIFF OMITTED] TR15SE11.001
For the aerodynamic assessment, tire rolling resistance, and
tractor weight reduction, the input values for the simulation model
will be determined by the manufacturer through conducting tests using
the test procedures finalized
[[Page 57148]]
by the agencies in this action and described below. The agencies are
allowing several testing alternatives for aerodynamic assessment
referenced back to a coastdown test procedure, a single procedure for
determination of the coefficient of rolling resistance (CRR) for tires,
and a prescribed method to determine tractor weight reduction. The
agencies have finalized 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 finalizing standards for Class 7 and 8
combination tractors that would be expressed in terms of moving a ton
(2,000 pounds) of freight over one mile. Thus, NHTSA's final 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 final CO2 vehicle standards would be represented
as grams of CO2 per ton-mile. The model converts
CO2 emissions to fuel consumption using the CO2
grams per ton mile estimated by GEM and an assumed 10,180 grams of
CO2 per gallon of diesel fuel.
This approach tracks the recommendations of the NAS report. 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 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 adopting, 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
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 vehicle can go up. Based on this general approach, it can
be estimated that for every 1,200 pounds in mass reduction across all
Class 7 and 8 tractors on the road, that total 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
vehicle. There was strong consensus in the public comments for adopting
the proposed metrics for tractors.
(c) Vehicle Aerodynamic Assessment
The aerodynamic drag of a vehicle is determined by the vehicle's
coefficient of drag (Cd), frontal area, air density and speed. As noted
in the NPRM, quantifying truck aerodynamics as an input to the GEM
presents technical challenges because of the proliferation of vehicle
configurations, the lack of a clearly preferable standardized test
method, and subtle variations in measured aerodynamic values among
various test procedures. Class 7 and 8 tractor aerodynamics are
currently developed by manufacturers using a range of techniques,
including wind tunnel testing, computational fluid dynamics, and
constant speed tests.
Consistent with our discussion at proposal, we believe a broad
approach allowing manufacturers to use these multiple different test
procedures to demonstrate aerodynamic performance of its tractor fleet
is appropriate given that no single test procedure is superior in all
aspects to other approaches. 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)). However, we also
recognize the need for consistency and a level playing field in
evaluating aerodynamic performance.
The agencies are retaining an aerodynamic bin structure for the
final rulemaking, but are adjusting the method used to determine the
bins. To address the consistency and level playing field concerns,
NHTSA and EPA proposed that manufacturers use a two-part screening
approach for determining the aerodynamic inputs to the GEM. The first
part would have required the manufacturers to assign each vehicle
aerodynamic configuration based on descriptions of vehicle
characteristics to one of five aerodynamics bins created by EPA and
NHTSA. The proposed assignment by bin would have fixed (by rule) the
aerodynamic characteristics of the vehicle. However, the agencies,
while working with industry, concluded for the final rulemaking that an
approach which identified a reference aerodynamic test method and a
procedure to align results from other aerodynamic test procedures with
the reference method is a simpler, more accurate approach than
deciphering and interpreting written descriptions of aerodynamic
components.
Therefore, we are finalizing an approach, as described in Section
V.B.3.d and Sec. 1037.501, which uses an
[[Page 57149]]
enhanced coastdown procedure as a reference method and defines a
process for manufacturers to align drag results from each of their own
test methods to the reference method results. Manufacturers will be
able to use any aerodynamic evaluation method in demonstrating a
vehicle's aerodynamic performance as long as the method is aligned to
the reference method. The results from the aerodynamic testing will be
the single determining factor for aerodynamic bin assignments.
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,\73\ the wind average drag coefficient is
about 15 percent higher than the zero degree coefficient of drag. In
addition, the agencies received comments that supported the use of wind
averaged drag results for the aerodynamic determination. The agencies
considered finalizing the use of a wind averaged drag coefficient in
this regulatory program, but ultimately decided to finalize 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 the reference method is coastdown testing
which is not capable of determining wind averaged yaw. Wind tunnels are
currently the only tool which can accurately assess the influence of
wind speed and direction on a vehicle'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 overall technology effectiveness or change the
kinds of technology decisions made by the tractor manufacturers in
developing equipment to meet our final standards. However, the agencies
are adopting provisions which allow manufacturers to generate credits
reflecting performance of technologies which improve the aerodynamic
performance in crosswind conditions, similar to those experienced by
vehicles in use through innovative technologies, as described in
Section IV.
---------------------------------------------------------------------------
\73\ See 2010 NAS Report, Note 21, Finding 2-4 on page 39.
---------------------------------------------------------------------------
As just noted, the agencies are adopting an approach for this final
action where the manufacturer would determine a tractor's aerodynamic
drag force using their own aerodynamic assessment tools and correlating
the results back to the reference aerodynamic test method of enhanced
coastdown testing. The manufacturer determines the appropriate
predefined aerodynamic bin based on the correlated test results and
then inputs the predefined Cd value for that aerodynamic bin into the
GEM. Coefficient of drag and frontal area of the tractor-trailer
combination go hand-in-hand to determine the force required to overcome
aerodynamic drag. The agencies proposed that the Cd value would be a
GEM input derived by the manufacturer and that the agencies would
specify the vehicle's frontal area for each regulatory subcategory. The
agencies sought and received comment recommending an alternate approach
where the aerodynamic input tables (as shown in Table 0-7 and Table 0-
8) represent the drag force as defined as Cd multiplied by the frontal
area. Because both approaches are essentially equivalent and the use of
CdA more directly relates back to the aerodynamic testing, the agencies
are finalizing the use of CdA as recommended by manufacturers.
The agencies are finalizing aerodynamic technology bins which
divide the wide spectrum of tractor aerodynamics into five bins (i.e.,
categories) for high roof tractors. The first high roof category, Bin
I, is designed to represent tractor bodies which prioritize appearance
or special duty capabilities over aerodynamics. These Bin I 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 high
roof aerodynamics category is Bin II which roughly represents the
aerodynamic performance of the average new tractor sold today. The
agencies developed this bin to incorporate conventional tractors which
capitalize on a generally aerodynamic shape and avoid classic features
which increase drag. High roof tractors within Bin III build on the
basic aerodynamics of Bin II tractors with added components to reduce
drag in the most significant areas on the tractor, such as integral
roof fairings, side extending gap reducers, fuel tank fairings, and
streamlined grill/hood/mirrors/bumpers, similar to SmartWay trucks
today. The Bin IV aerodynamic category for high roof tractors builds
upon the Bin III tractor body with additional aerodynamic treatments
such as underbody airflow treatment, down exhaust, and lowered ride
height, among other technologies. And finally, Bin V 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 had proposed five aerodynamic bins for each tractor
regulatory subcategory. The agencies received comments from ATA, EMA/
TMA, and Volvo indicating that this approach was not consistent with
the aerodynamics of low and mid roof tractors. High roof tractors are
consistently paired with box trailer designs, and therefore
manufacturers can design the tractor aerodynamics as a tractor-trailer
unit and target specific areas like the gap between the tractor and
trailer. In addition, the high roof tractors tend to spend more time at
high speed operation which increases the impact of aerodynamics on fuel
consumption and GHG emissions. On the other hand, low and mid roof
tractors are designed to pull variable trailer loads and shapes. They
may pull trailers such as flat bed, low boy, tankers, or bulk carriers.
The loads on flat bed trailers can range from rectangular cartons with
tarps, to a single roll of steel, to a front loader. Due to these
variables, manufacturers do not design unique low and mid roof tractor
aerodynamics but instead use derivatives from their high roof tractor
designs. The aerodynamic improvements to the bumper, hood, windshield,
mirrors, and doors are developed for the high roof tractor application
and then carried over into the low and mid roof applications. As
mentioned above, the types of designs that would move high roof
tractors from a Bin III to Bins IV and V include features such as gap
reducers and integral roof fairings which would not be appropriate on
low and mid roof tractors. The agencies considered and largely agree
with these comments and are therefore finalizing only two aerodynamic
bins for low and mid roof tractors. The agencies are reducing the
number of bins to reflect the actual range of aerodynamic technologies
effective in low and mid roof tractor applications. Thus, the agencies
are differentiating the aerodynamic performance for low and mid roof
applications into two bins--conventional and aerodynamic.\74\
---------------------------------------------------------------------------
\74\ As explained in Section IV, there are no ABT implications
to this change from proposal, since all Class 8 combination tractors
are considered to be a single averaging set for ABT purposes.
Similarly, all Class 7 tractors are considered to be a single
averaging set for ABT purposes.
---------------------------------------------------------------------------
[[Page 57150]]
For high roof combination tractor compliance determination, a
manufacturer would use the aerodynamic results determined through
testing to establish the appropriate bin. The manufacturer would then
input into GEM the Cd value specified for each bin as defined in Table
II-7 and Table II-8. For example, if a manufacturer tests a Class 8
sleeper cab high roof tractor and the test produces a CdA value between
5.8 and 6.6, the manufacturer would assign this tractor to the Class 8
Sleeper Cab High Roof Bin III. The manufacturer would then use the Cd
value identified for Bin III of 0.60 as the input to GEM.
The Cd values in Table II-7 and Table II-8 differ from proposal
based on a change in the reference method (enhanced coastdown
procedure) and additional testing conducted by EPA. Details of the test
program and results are included in RIA Chapter 2.5.1.4.
Table II-7--Aerodynamic Input Definitions to GEM for High Roof Tractors
------------------------------------------------------------------------
Class 7 Class 8
--------------------------------------
Day cab Day cab Sleeper cab
--------------------------------------
High roof High roof High roof >
------------------------------------------------------------------------
Aerodynamic Test Results (CdA in m\2\)
------------------------------------------------------------------------
Bin I............................ >= 8.0 >= 8.0 >= 7.6
Bin II........................... 7.1-7.9 7.1-7.9 6.7-7.5
Bin III.......................... 6.2-7.0 6.2-7.0 5.8-6.6
Bin IV........................... 5.6-6.1 5.6-6.1 5.2-5.7
Bin V............................ <= 5.5 <= 5.5 <= 5.1
------------------------------------------------------------------------
Aerodynamic Input to GEM (Cd)
------------------------------------------------------------------------
Bin I............................ 0.79 0.79 0.75
Bin II........................... 0.72 0.72 0.68
Bin III.......................... 0.63 0.63 0.60
Bin IV........................... 0.56 0.56 0.52
Bin V............................ 0.51 0.51 0.47
------------------------------------------------------------------------
The CdA values in Table II-8 are based on testing using the
enhanced coastdown test procedures adopted for the final rulemaking,
which includes aerodynamic assessment of the low and mid roof tractors
without a trailer. The removal of the trailer significantly reduces the
CdA value of mid roof tractors with tanker trailers because of the poor
aerodynamic performance of the tanker trailer. The agencies developed
the Cd input for each of the low and mid roof tractor bins to represent
the Cd of the tractor, its frontal area, and the impact of the Cd value
due to the trailer such that the GEM value is representative of a
tractor-trailer combination, as it is for the high roof tractors.
Table II-8--Aerodynamic Input Definitions to GEM for Low and Mid Roof Tractors
--------------------------------------------------------------------------------------------------------------------------------------------------------
Class 7 Class 8
------------------------------------------------------------------------------------------
Day Cab Day Cab Sleeper
---------------------------------------------------------------- Cab
------------
Low Roof Mid Roof Low Roof Mid Roof Low
Roof
------------------------------------------------------------------------------------------------------------------------------------------------ ------------
Aerodynamic Test Results (CdA in m\2\)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Bin I............................................................. >= 5.1 >= 5.6 >= 5.1 >= 5.6 >= 5.1 >= 5.6
Bin II............................................................ <= 5.0 <= 5.5 <= 5.0 <= 5.5 <= 5.0 <= 5.5
--------------------------------------------------------------------------------------------------------------------------------------------------------
Aerodynamic Input to GEM (Cd)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Bin I............................................................. 0.77 0.87 0.77 0.87 0.77 0.87
Bin II............................................................ 0.71 0.82 0.71 0.82 0.71 0.82
--------------------------------------------------------------------------------------------------------------------------------------------------------
(d) Tire Rolling Resistance Assessment
NHTSA and EPA are finalizing as proposed 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.\75\
The agencies believe the ISO test procedure is appropriate for this
program because the procedure is the same one used by NHTSA in its fuel
efficiency tire labeling program \76\ and is consistent with the
testing direction being taken by
[[Page 57151]]
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 tractor. The
results would be expressed as a rolling resistance coefficient (CRR)
and measured as kilogram per metric ton (kg/metric ton). The agencies
are finalizing as proposed 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 will use the steer and
drive tire rolling resistance inputs and distribute 15 percent of the
gross weight of the tractor and trailer to the steer axle, 42.5 percent
to the drive axles, and 42.5 percent to the trailer axles.\77\ The
trailer tires' rolling resistance is 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.\78\
---------------------------------------------------------------------------
\75\ 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
\76\ 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).
\77\ 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).
\78\ 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.
---------------------------------------------------------------------------
EPA and NHTSA conducted additional evaluation testing on HD trucks
tires used for tractors, and also for vocational vehicles. The agencies
also received several comments on the suitability of low rolling
resistance tires for various HD vehicle applications. The summary of
the agencies' findings and a response to issues raised by commenters is
presented in Section II.D(1)(a).
(e) Weight Reduction Assessment
The agencies proposed that the tractor standards reflect improved
CO2 emissions and fuel consumption performance of a 400
pound weight reduction in Class 7 and 8 tractors through the
substitution of single wide tires and light-weight wheels for dual
tires and steel wheels. This approach was taken since there is a large
variation in the baseline weight among trucks that perform roughly
similar functions with roughly similar configurations. Because of this,
the only effective way to quantify the exact CO2 and fuel
consumption benefit of mass reduction using GEM is to estimate baseline
weights for specific components that can be replaced with light weight
components. If the weight reduction is specified for light weight
versions of specific components, then both the baseline and weight
differentials for these are readily quantifiable and well-understood.
Lightweight wheels are commercially available as are single wide tires
and thus data on the weight reductions attributable to these two
approaches are readily available.
The agencies received comments on this approach from Volvo, ATA,
MEMA, Navistar, American Chemistry Council, the Auto Policy Center,
Iron and Steel Institute, Arvin Meritor, Aluminum Association, and
environmental groups and NGOs. Volvo and ATA stated that not all fleets
can use single wide tires and if this is the case the 400 pound weight
reduction target cannot be met. Volvo stated that without the use of
single wide drive tires, a 6x4 tractor will have a maximum weight
reduction of 300 pounds if the customer selects all ten wheels to be
outfitted with light weight aluminum wheels. A number of additional
commenters--including American Chemistry Council, The Auto Policy
Center, Iron and Steel Institute, Aluminum Association, Arvin Meritor,
MEMA, Navistar, Volvo, and environmental and nonprofit groups--stated
that manufacturers should be allowed to use additional light weight
components in order to meet the tractor fuel consumption and
CO2 emissions standards. These groups stated that weight
reductions should not be limited to wheels and tires. They asked that
cab doors, cab sides and backs, cab underbodies, frame rails, cross
members, clutch housings, transmission cases, axle differential carrier
cases, brake drums, and other components be allowed to be replaced with
light-weight versions. Materials suggested for substitution included
aluminum, light-weight aluminum, high strength steel, and plastic
composites. The American Iron and Steel Institute stated there are
opportunities to reduce mass by replacing mild steel--which currently
dominates the heavy-duty industry--with high strength steel.
In addition, The American Auto Policy Center asked that
manufacturers be allowed to use materials other than aluminum and high
strength steel to comply with the regulations. DTNA asked that weight
reduction due to engine downsizing be allowed to receive credit. Volvo
requested that weight reductions due to changes in axle configuration
be credited. They used the example of a customer selecting a 4 X 2 over
a 6 X 4 axle tractor. In this case, they assert there would be a 1,000
pound weight savings from removing an axle.
As proposed, many of the material substitutions could have been
considered as innovative technologies for tractors and hence eligible
for off cycle credits (so that the commenters overstated that these
technologies were `disallowed'). Nonetheless in response to the above
summarized comments, the agencies evaluated whether additional
materials and components could be used directly for compliance with the
tractor weight reduction through the primary program (i.e. be available
as direct inputs to the GEM). The agencies reviewed comments and data
received in response to the NPRM and additional studies cited by
commenters. A summary of this review is provided in the following
paragraphs.
TIAX, in their report to the NAS, cited information from Alcoa
identifying several mass reduction opportunities from material
substitution in the tractor cab components which were similar to the
ones identified by the Aluminum Association in their comments to this
rulemaking.\79\ TIAX included studies submitted by Alcoa showing the
potential to reduce the weight of a tractor-trailer combination by
3,500 to 4,500 pounds.\80\ In addition, the U.S. Department of Energy
has several projects underway to improve the freight efficiency of
Class 8 trucks which provide relevant data: \81\ DOE reviewed
prospective lightweighting alternative materials and found that
aluminum has a potential to reduce mass by 40 to 60 percent, which is
in line with the estimates of mass reductions of various components
provided by Alcoa, and by the Aluminum Association in their comments
and as cited in the TIAX report. These combined studies, comments, and
additional data provided information on specific components that could
be replaced with aluminum components.
---------------------------------------------------------------------------
\79\ TIAX, LLC. ``Assessment of Fuel Economy Technologies for
Medium- and Heavy-Duty Vehicles,'' Final Report to National Academy
of Sciences, November 19, 2009. Pages 4-62 through 4-64.
\80\ Alcoa. ``Improving Sustainability of Transport: Aluminum is
Part of the Solution.'' 2009.
\81\ Schutte, Carol. U.S. Department of Energy, Vehicle
Technologies Program. ``Losing Weight--an enabler for a Systems
Level Technology Development, Integration, and Demonstration for
Efficient Class 8 Trucks (SuperTruck) and Advanced Technology
Powertrains for Light-Duty Vehicles.''
---------------------------------------------------------------------------
With regard to high strength steel, the Iron and Steel Institute
found that the use of high strength steel and redesign can reduce the
weight of light-duty trucks by 25 percent.\82\ Approximately
[[Page 57152]]
10 percent of this reduction results from material substitution and 15
percent from vehicle re-design. While this study evaluated light-duty
trucks, the agencies believe that a similar reduction could be achieved
in heavy-duty trucks since the reductions from material substitution
would likely be similar in heavy-trucks as in light-trucks. U.S. DOE,
in the report noted above, identified opportunities to reduce mass by
10 percent through high strength steel.\83\ This study was also for
light-duty vehicles.
---------------------------------------------------------------------------
\82\ American Iron and Steel Institute. ``A Cost Benefit
Analysis Report to the North American Steel Industry on Improved
Materials and Powertrain Architectures for 21st Century Trucks.''
\83\ Schutte, Carol. U.S. Department of Energy, Vehicle
Technologies Program. ``Losing Weight--an enabler for a Systems
Level Technology Development, Integration, and Demonstration for
Efficient Class 8 Trucks (SuperTruck) and Advanced Technology
Powertrains for Light-Duty Vehicles''.
---------------------------------------------------------------------------
The agencies considered other materials such as plastic composites
and magnesium substitutes but were not able to obtain weights for
specific components made from these materials. We have therefore not
included components made from these materials as possible substitutes
in the primary program, but they may be considered through the
innovative technology/off-cycle credits provision. We may consider
including these materials as part of the primary compliance option in a
subsequent regulation if data become available.
Based on this analysis, the agencies developed an expanded list of
weight reduction opportunities for the final rulemaking that may be
reflected in the GEM, as listed in Table II-9. The list includes
additional components, but not materials, from those proposed. For high
strength steel, the weight reduction value is equal to 10 percent of
the presumed baseline component weight, as the agencies used a
conservative value based on the DOE report. We recognize that there may
be additional potential for weight reduction in new high strength steel
components which combine the reduction due to the material substitution
along with improvements in redesign, as evidenced by the studies done
for light-duty vehicles. In the development of the high strength steel
component weights, we are only assuming a reduction from material
substitution and no weight reduction from redesign, since we do not
have any data specific to redesign of heavy-duty components nor do we
have a regulatory mechanism to differentiate between material
substitution and improved design. We are finalizing for wheels that
both aluminum and light weight aluminum are eligible to be used as
light-weight materials. Aluminum, but not light-weight aluminum, can be
used as a light-weight material for other components. The reason for
this is that data were available for light weight aluminum for wheels
but were not available for other components.
The agencies received comments on the proposal from the American
Chemistry Council highlighting the role of plastics and composites in
heavy-duty vehicles. As they stated, composites can be low density
while having high strength and are currently used in applications such
as oil pans and buses. The DOE mass reduction program demonstrated for
heavy vehicles proof of concept designs for hybrid composite doors with
an overall mass savings of 40 percent; 30 percent mass reduction of a
hood system with carbon fiber sheet molding compound; 50 percent mass
reduction from composite tie rods, trailing arms, and axles; and
superplastically formed aluminum body panels.\84\ While the agencies
recognize these opportunities, we do not believe the technologies have
advanced far enough to quantify the benefits of these materials because
they are very dependent on the actual composite material. The agencies
may consider such lightweighting opportunities in future actions, but
are not including them as part of this primary program. Manufacturers
which opt to pursue composite and plastic material substitutions may
seek credits through the innovative technology provisions.
---------------------------------------------------------------------------
\84\ Schutte, Carol. U.S. Department of Energy, Vehicle
Technologies Program. ``Losing Weight--an enabler for a Systems
Level Technology Development, Integration, and Demonstration for
Efficient Class 8 Trucks (SuperTruck) and Advanced Technology
Powertrains for Light-Duty Vehicles''.
---------------------------------------------------------------------------
With regard to Volvo's request that manufacturers be allowed to
receive credit for trucks with fewer axles, the agencies recognize that
vehicle options exist today which have less mass than other options.
However, we believe the decisions to add or subtract such components
will be made based on the intended use of the vehicle and not based on
a crediting for the mass difference in our compliance program. It is
not our intention to create a tradeoff between the right vehicle to
serve a need (e.g. one with more or fewer axles) and compliance with
our final standards. Therefore, we are not including provisions to
credit (or penalize) vehicle performance based on the subtraction (or
addition) of specific vehicle components. Table II-9 provides weight
reduction values for different components and materials.
Table II-9--Weight Reduction Values
------------------------------------------------------------------------
------------------------------------------------------------------------
Weight reduction technology Weight reduction (lb per tire/
wheel)
------------------------------------------------------------------------
Single Wide Drive Tire with:
Steel Wheel......................... 84
Aluminum Wheel...................... 139
Light Weight Aluminum Wheel......... 147
Steer Tire or Dual Wide Drive Tire with:
High Strength Steel Wheel........... 8
Aluminum Wheel...................... 21
Light Weight Aluminum Wheel......... 30
------------------------------------------------------------------------
Weight reduction technologies Aluminum High strength
weight steel weight
reduction reduction
(lb.) (lb.)
------------------------------------------------------------------------
Door.................................... 20 6
Roof.................................... 60 18
Cab rear wall........................... 49 16
Cab floor............................... 56 18
Hood Support Structure.................. 15 3
[[Page 57153]]
Fairing Support Structure............... 35 6
Instrument Panel Support Structure...... 5 1
Brake Drums--Drive (4).................. 140 11
Brake Drums--Non Drive (2).............. 60 8
Frame Rails............................. 440 87
Crossmember--Cab........................ 15 5
Crossmember--Suspension................. 25 6
Crossmember--Non Suspension (3)......... 15 5
Fifth Wheel............................. 100 25
Radiator Support........................ 20 6
Fuel Tank Support Structure............. 40 12
Steps................................... 35 6
Bumper.................................. 33 10
Shackles................................ 10 3
Front Axle.............................. 60 15
Suspension Brackets, Hangers............ 100 30
Transmission Case....................... 50 12
Clutch Housing.......................... 40 10
Drive Axle Hubs (8)..................... 160 4
Non Drive Front Hubs (2)................ 40 5
Driveshaft.............................. 20 5
Transmission/Clutch Shift Levers........ 20 4
------------------------------------------------------------------------
EPA and NHTSA are specifying the baseline vehicle weight for each
regulatory vehicle subcategory (including the tires, wheels, frame, and
cab components) in the GEM in aggregate based on weight of vehicles
used in EPA's aerodynamic test program, but allow manufacturers to
specify the use of light-weight components. The GEM then quantifies the
weight reductions based on the pre-determined weight of the baseline
component minus the pre-determined weight of the component made from
light-weight material. Manufacturers cannot specify the weight of the
light-weight component themselves, only the material used in the
substitute component. The agencies assume the baseline wheel and tire
configuration contains dual tires with steel wheels, along with steel
frame and cab components, because these represent the vast majority of
new vehicle configurations today. The weight reduction due to
replacement of components with light weight versions will be reflected
partially in the payload tons and partially in reducing the overall
weight of the vehicle run in the GEM. The specified payload in the GEM
will be set to the prescribed payload plus one third of the weight
reduction amount to recognize that approximately one third of the truck
miles are travelled at maximum payload, as discussed below in the
payload discussion. The other two thirds of the weight reduction will
be subtracted from the overall vehicle weight prescribed in the GEM.
The agencies continue to believe that the 400 pound weight target
is appropriate to use as a basis for setting the final combination
tractor CO2 emissions and fuel consumption standards. The
agencies agree with the commenter that 400 pounds of weight reduction
without the use of single wide tires may not be achievable for all
tractor configurations. As noted, the agencies have extended the list
of weight reduction components in order to provide the manufacturers
with additional means to comply with the combination tractors and to
further encourage reductions in vehicle weight. The agencies considered
increasing the target value beyond 400 pounds given the additional
reduction potential identified in the expanded technology list;
however, lacking information on the capacity for the industry to change
to these lightweight components across the board by the 2014 model
year, we have decided to maintain the 400 pound target. The agencies
intend to continue to study the potential for additional weight
reductions in our future work considering a second phase of vehicle
fuel efficiency and GHG regulations. In the context of the current
rulemaking for HD fuel consumption and GHG standards, one would expect
that reducing the weight of medium-duty trucks similarly would, if
anything, have a positive impact on safety. However, given the large
difference in weight between light-duty and medium-duty vehicles, and
even larger difference between light-duty vehicles and heavy-duty
vehicles with loads, the agencies believe that the impact of weight
reductions of medium- and heavy-duty vehicles would not have a
noticeable impact on safety for any of these classes of vehicles.\85\
---------------------------------------------------------------------------
\85\ For more information on the estimated safety effects of
this rule, see Chapter 9 of the RIA.
---------------------------------------------------------------------------
(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.\86\ 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 tractor cab itself than to pull off the road and find
accommodations.\87\ During this rest period a driver will idle the
tractor engine in order to provide heating or cooling, or to run on-
board appliances. In some cases the engine can idle in excess of 10
hours. During this period, the engine will consume approximately 0.8
gallons of fuel and emit over 8,000 grams of CO2 per hour.
An average tractor engine can consume 8 gallons of fuel and emit over
80,000 grams of CO2 during overnight idling in such a case.
---------------------------------------------------------------------------
\86\ 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/.
\87\ The agencies note that some sleeper cabs may be classified
as vocational tractors and therefore are expected to primarily
travel locally and would not benefit from an idle reduction
technology.
---------------------------------------------------------------------------
Idling reduction technologies (IRT) 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
[[Page 57154]]
available today. The agencies are adopting a provision for use of
extended idle reduction technology as an input to the GEM for Class 8
sleeper cabs. As discussed further in Section III, if a manufacturer
wishes to receive credit for using IRT to meet the standard, then an
automatic main engine shutoff must be programmed and enabled, such that
engine shutdown occurs after 5 minutes of idling, to help ensure the
reductions are realized in-use. A discussion of the provisions the
agencies are adopting for allowing an override of this automatic
shutdown can be found in RIA Chapter 2. 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 final standards and using these
technologies as the inputs to the GEM. The default value (5 g
CO2/ton-mile or 0.5 gal/1,000 ton-mile) for the use of
automatic engine shutdown (AES) with idle reduction technologies was
determined as the difference between a baseline main engine with idle
fuel consumption of 0.8 gallons per hour that idles 1,800 hours and
travels 125,000 miles per year, and a diesel auxiliary power unit
operating in lieu of main engine during those same idling hours. The
agencies received various comments from ACEEE and MEMA regarding the
assumptions used to derive the idle reduction value. ACEEE argued that
the agencies should use a fuel consumption rate of 0.47 gallon/hour for
main engine idling based on a paper written by Kahn. MEMA argued that
the agencies should use a main engine idling fuel consumption rate of
0.87 gal/hr, which is the midpoint of a DOE calculator reporting fuel
consumption rates from 0.64 to 1.15 gal/hr at idling conditions, and
between 800 and 1200 rpm with the air conditioning on and off,
respectively. The agencies respectfully disagree with the 0.47 gal/hr
recommendation because the same paper by Kahn shows that while idling
fuel consumption is 0.47 gal/hr on average at 600 rpm, CO2
emissions increase by 25 percent with A/C on at 600 rpm, and increase
by 165 percent between 600 rpm and 1,100 rpm with A/C on.\88\ MEMA
recommended using 2,500 hours per year for APU operation. They cited
the SmartWay Web site which uses 2,400 hours per year (8 hours per day
and 300 days per year). Also, they cited an Argonne study which assumed
7 hours per day and 303 days per year, which equals 2,121 hours per
year. Lastly, they referred to the FMCSA 2010 driver guidelines which
reduce the number of hours driven per day by one to two hours, which
would lead to 2,650 to 2,900 hours per year. The agencies reviewed
other studies to quantify idling operations, as discussed in greater
detail in RIA Section 2.5.4.2, and believe that the entirety of the
research does not support a change from the proposed calculation.
Therefore, the agencies are finalizing the calculation as proposed.
Additional details regarding the comments, calculations, and agency
decisions are included in RIA Section 2.5.4.2.
---------------------------------------------------------------------------
\88\ See Gaines, L., A. Vyas, J. Anderson. ``Estimation of Fuel
Used by Idling Commercial Trucks,'' Page 9 (2006).
---------------------------------------------------------------------------
The agencies are adopting a provision to allow manufacturers to
provide an AES system which is active for only a portion of a vehicle's
life. In this case, a discounted idle reduction value would be entered
into GEM. A discussion of the calculation of a discounted IRT credit
can be found in Section III. Additional details on the emission and
fuel consumption reduction values are included in RIA Section 2.5.4.2.
(g) Vehicle Speed Limiters
The NPRM proposed to allow combination tractors that use vehicle
speed limiters (VSL) to include the maximum governed speed value as an
input to the GEM for purposes of determining compliance with the
vehicle standards. The agencies also proposed not to assume the use of
a mandatory vehicle speed limiter because of concerns about how to set
a realistic application rate that avoids unintended consequences. See
75 FR at 74223. Governing the top speed of a vehicle can reduce fuel
consumption and GHG emissions, because fuel consumption and
CO2 emissions increase proportionally to the square of
vehicle speed.\89\ Limiting the speed of a vehicle reduces the fuel
consumed, which in turn reduces the amount of CO2 emitted.
The specific input to the GEM would be the maximum governed speed limit
of the VSL that is programmed into the powertrain control module (PCM).
The agencies stressed in the NPRM that in order to obtain a benefit in
the GEM, a 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.'' If the top speed could be easily overridden, the fuel
consumption/CO2 benefits of the VSL might not be realized,
and the agencies did not want to allow the technology to be used for
compliance if the technology could be disabled easily and the real
world benefits not achieved.
---------------------------------------------------------------------------
\89\ See 2010 NAS Report, Note 21, Page 28. Road Load Force
Equation defines the aerodynamic portion of the road load as
[frac12] * Coefficient of Drag * Frontal Area * air density *
vehicle speed squared.
---------------------------------------------------------------------------
Both the Center for Biological Diversity (CBD) and New York State
Department of Transportation and Environmental Conservation commented
that the application of speed limiters should be used to set the
tractor standards.\90\ CBD urged the agencies to reconsider the
position and adopt a speed limitation technology. NY State commented
that the technologies are cost effective, reduce emissions, and appear
to be generally acceptable to the trucking industry. They continued to
say that the vehicle speed limit could be set without compromising
operational logistics.
---------------------------------------------------------------------------
\90\ One commenter mistakenly thought that the agencies were
rejecting consideration of VSLs due to perceived jurisdictional
obstacles. In fact, both the CAA and EISA allow consideration of VSL
technology and the agencies considered the appropriateness of basing
standards on performance of the technology.
---------------------------------------------------------------------------
Many commenters (Cummins, Daimler, EMA/TMA, ATA, AAPC, NADA)
supported the use of VSLs as an input to the GEM, but requested
clarification of what the specific requirements would be to ensure the
VSL setting would not be capable of being easily overridden. Cummins
and Daimler requested that the final rules explicitly allow vehicle
manufacturers to access and adjust the VSL control feature for setting
the maximum governed speed, arguing that the diverse needs of the
commercial vehicle industry warrant flexibility in electronic control
features, and that otherwise supply chain issues \91\ may result from
the use of VSLs. NADA and EMA/TMA also requested that VSLs have
override features and be adjustable, citing various needs for
flexibility by the fleets. EMA/TMA and ATA requested that VSLs be
adjustable downward by fleets in order to obtain greater benefit in
GEM, if company policies change or if a subsequent vehicle owner needs
a different VSL setting. EMA/TMA stated that the agencies should
prohibit tampering with VSLs, and both EMA and TRALA requested more
information on how the agencies intended to address tampering with
VSLs.
---------------------------------------------------------------------------
\91\ Commenters stated that OEMs need access for setting
appropriate trims for managing the VSL, otherwise significant supply
chain issues could result such as parts shortages caused by the need
for unique speed governed PCMs.
---------------------------------------------------------------------------
In addition to features governing the maximum vehicle speed,
commenters requested adding other programmable flexibilities to
mitigate potential drawbacks to VSLs. Cummins, DTNA,
[[Page 57155]]
and EMA/TMA requested that a programmable ``soft top'' speed be added
to PCMs which would allow a vehicle to exceed the speed limit setting
governed by a VSL for a short period of time. A ``soft top'' feature
could be used for a limited duration in order to maneuver and pass
other on-road vehicles at speeds greater than that governed by the VSL.
The commenters argued this was important for vehicle passing and
safety-related situations where, without a soft top feature, it could
be possible for speed limited trucks to obstruct other vehicles on the
road and cause severe road congestion.
ATA and EMA/TMA also requested that manufacturers be allowed to
program a mileage based expiration into the VSL control feature, in
order to preserve the value of vehicles for second owners who may
require operation at higher speeds. ATA further commented that
manufacturers should be allowed to account for additional GEM input
benefits if the speed governor is reprogrammed to a lower speed within
the useful life of the vehicle.
After carefully considering the comments, the agencies have
decided, for these final rules, to retain most of the elements in the
proposal. Manufacturers will be allowed to implement a fixed maximum
governed vehicle speed through a VSL feature and to use the maximum
governed vehicle speed as an input to the GEM for certification. Also
consistent with the proposal, the agencies are not premising the final
standards on the use of VSLs. The comments received from stakeholders
did not address the agencies' concerns discussed in the proposal,
specifically the risk of requiring VSL in situations that are not
appropriate from an efficiency perspective because it may lead to
additional vehicle trips to deliver the same amount of freight.\92\ The
agencies continue to believe that we are not in a position to determine
how many additional vehicles would benefit from the use of a VSL with a
setting of less than 65 mph (a VSL with a speed set at or above 65 mph
will show no CO2 emissions or fuel consumption benefit on
the drive cycles included in this program). The agencies further
believe that manufacturers will not utilize VSLs unless it is in their
interest to do so, so that these unintended consequences should not
occur when manufacturers use VSLs as a compliance strategy. We will
monitor the industry's use of VSL in this program and may consider
using this technology in standard setting in the future.
---------------------------------------------------------------------------
\92\ See 75 FR at page 74223.
---------------------------------------------------------------------------
The agencies have decided to adopt commenters' suggestions to allow
adjustable lower limits that can be set and governed by VSLs
independent of the one governing the maximum certified speed limit to
provide the desired flexibility requested by the trucking industry. We
believe that this flexibility would not decrease the anticipated fuel
consumption or CO2 benefits of VSLs because the adjustable
limits would be lower values. Issues identified by the commenters
including the ability to change delivery routes requiring lower
governed speeds or when a fleet's business practices change resulting
in a desire for greater fuel consumption savings are not in conflict
with the purpose and benefit of VSLs. As such, the agencies have
decided to allow a manufacturer to install features for its fleet
customers to set their own lower adjustable limits below the maximum
VSL specified by the agencies. However, the agencies have decided to
not allow any additional benefit in the GEM to a manufacturer for
allowing a lower governed speed in-use than the certified maximum limit
for this first phase of the HD National Program because we can only be
certain that the VSL will be at the maximum setting.
Both agencies also agree that manufacturers can provide a ``soft
top'' and expiration features to be programmed into PCMs to provide
additional flexibility for fleet owners and so that fleets who purchase
used vehicles have the ability to have different VSL policies than the
original owner of the vehicle. Although the agencies considered
limiting the soft top maximum level due to safety and fuel consumption/
GHG benefit concerns, we have decided to allow the soft top maximum
level to be set to any level higher than the maximum speed governed by
the VSL. This approach will provide drivers with the ability to better
navigate through traffic. However, the agencies are requiring that
manufacturers providing a soft top feature must design the system so it
cannot be modified by the fleets and will not decrement the vehicle
speed limit causing the vehicle to decelerate while the driver is
operating a vehicle above the normal governed vehicle speed limit. For
example, if a manufacturer designs a vehicle speed limiter that has a
normal governed speed limiter setting of 62 mph, and a ``soft top''
speed limiter value of 65 mph, the algorithm shall not cause the
vehicle speed to decrement causing the vehicle to decelerate while the
driver is operating the vehicle at a speed greater that 62 mph (between
62 and 65 mph). The agencies are concerned that a forced deceleration
when a driver is attempting to pass or maneuver could have an adverse
impact on safety.
In using a soft top feature, a manufacturer will be required to
provide to the agencies a functional description of the ``soft top''
control strategy including calibration values, the speed setting for
both the hard limit and the soft top and the maximum time per day the
control strategy could allow the vehicle to operate at the ``soft top''
speed limit at the time of certification. This information will be used
to derive a factor to discount the VSL input used in the GEM to
determine the fuel consumption and GHG emissions performance of the
vehicle. The agencies also agree with comments that VSLs should be
adjustable so as not to potentially limit a vehicle's resale value.
However, manufacturers choosing the option to override the VSL after a
specified number of miles would be required to discount the benefit of
the VSL relative to the tractor's full lifetime miles. The VSL discount
benefits for using soft-top and expiration features must be calculated
using Equation II-1.\93\ Additional details regarding the derivation of
the discounted equation are included in RIA Chapter 2. The agencies are
also requiring that any vehicle that has a ``soft top'' VSL to identify
the use of the ``soft top'' VSL on the vehicle emissions label.
---------------------------------------------------------------------------
\93\ See Sec. 1037.640.
---------------------------------------------------------------------------
Equation II-1: Discounted Vehicle Speed Limiter Equation
VSL input for GEM = Expiration Factor * [Soft Top Factor* Soft Top VSL
+ (1-Soft Top Factor) * VSL] + (1-Expiration Factor)*65 mph
The agencies will require that the VSL algorithm be designed to
assure that over the useful life of the vehicle that the vehicle will
not operate in the soft top mode for more miles than would be expected
based on the values used in Equation 0-1, as specified by the
expiration factor and the soft top factor. In addition, any time the
cumulative percentage of operation in the soft top mode (based on
miles) exceeds the maximum ratio that could occur at the full lifetime
mileage, or at the expiration mileage if used, the algorithm must not
allow the vehicle to exceed the VSL value. In this case, the soft top
feature remain disabled until the vehicle mileage reaches a point where
the ratio no longer meets this condition.
In response to the comments about how the agencies will evaluate
[[Page 57156]]
tampering, NHTSA and EPA have added a number of requirements in these
final rules relating to the VSL control feature. VSL control features
should be designed so they cannot be easily overridden. Manufacturers
must ensure that the governed speed limit programmed into the VSL must
also be verifiable through on-board diagnostic scanning tools, and must
provide a description of the coding to identify the governed maximum
speed limit and the expiration mileage both at the time of the initial
vehicle certification and in-use. The agencies believe both
manufacturers and fleets should work toward maintaining the integrity
of VSLs, and the agencies may conduct new-vehicle and in-use random
audits to verify that inputs into GEM are accurate.
The agencies are aware that some fleets/owners make changes to
vehicles, such as installing different diameter tires, changing the
axle (final drive) ratio and transmission gearing, such that a vehicle
could travel at speeds higher than the speed limited by its VSL.
Vehicles subject to FMCSA requirements must be in compliance with 49
CFR 393.82. The requirements apply to speedometers and states as
follows:
Each bus, truck, and truck-tractor must be equipped with a
speedometer indicating vehicle speed in miles per hour and/or
kilometers per hour. The speedometer must be accurate to within plus
or minus 8 km/hr (5 mph) at a speed of 80 km/hr (50 mph).
To facilitate adjustments for component changes affecting vehicle
speed, manufacturers should provide a fleet/owner with the means to do
so unless the adjustments would affect the VSL setting or operation.
DTNA and ATA additionally requested that the agencies ensure that
any VSL provisions adopted under the GHG emissions and fuel efficiency
rules align with existing NHTSA standards. The agencies agree and note
that there are no existing standards for a VSL outside of this current
rulemaking activity. However, NHTSA has announced its intent to publish
a proposal in 2012 for a VSL.\94\ While both agencies have taken steps
to avoid potential conflicts between the rulemaking being finalized
today for fuel consumption and GHG emissions and the anticipated safety
rulemaking, different conclusions may be reached in a safety-based
rulemaking on VSLs, particularly in the approach to specifying soft top
parameters and VSL expiration.
---------------------------------------------------------------------------
\94\ 76 FR 78.
---------------------------------------------------------------------------
(h) Defined Vehicle Configurations in the GEM
As discussed above, the agencies are adopting methodologies that
manufacturers will use to quantify the values input into the GEM for
these factors affecting vehicle efficiency: Coefficient of Drag, Tire
Rolling Resistance Coefficient, Weight Reduction, Vehicle Speed
Limiter, and Extended Idle Reduction Technology. The other aspects of
the vehicle configuration are fixed within the model and are not varied
for the purpose of compliance. The defined inputs include the tractor-
trailer combination curb weight, payload, engine characteristics, and
drivetrain for each vehicle type, and others.
(i) Vehicle Drive Cycles
The GEM simulation model uses various inputs to characterize a
vehicle's configuration (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). As noted by the
2010 NAS Report,\95\ 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. An ill-suited drive cycle for a
regulatory category could 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 delivery may spend little time on the highway, reducing the
benefits 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.\96\ 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 vehicle has a different drive cycle in-use.
---------------------------------------------------------------------------
\95\ See 2010 NAS Report, Note 21, Chapters 4 and 8.
\96\ This situation does not typically occur for heavy-duty
emission control technology designed to control criteria pollutants
such as PM and NOX.
---------------------------------------------------------------------------
The agencies proposed a modified version of the California ARB
Heavy Heavy-duty Truck 5 Mode Cycle \97\, 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.\98\ 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 vehicle application usage patterns. For the proposal, EPA
analyzed the five cycles and found that some modifications to the
cycles were required to allow sufficient flexibility in weightings. The
agencies proposed the use of the Transient mode, as defined by
California ARB, because it broadly covers urban driving. The agencies
also proposed altered versions of the High Speed Cruise and Low Speed
Cruise modes which reflected only constant speed cycles at 65 mph and
55 mph respectively. In the NPRM, the agencies proposed to use three
cycles which were the ARB transient cycle, a 55 mph steady state
cruise, and a 65 mph steady state cruise.
---------------------------------------------------------------------------
\97\ 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.
\98\ EPA's MOVES (Motor Vehicle Emission Simulator). See http://www.epa.gov/otaq/models/moves/index.htm for additional information.
---------------------------------------------------------------------------
The agencies received comment from NACAA recommending an increase
in the high speed cruise cycle speed from the proposed value of 65 mph
to 75 mph because trucks travel at higher speeds. The agencies analyzed
the urban and rural interstate truck speed limits in each state to
determine the national average truck speed limit. State interstate
speed limits for trucks vary between 55 and 75 mph, depending on the
state.\99\ Based on this information, the national median truck speed
limit is
[[Page 57157]]
65 mph. The agencies also analyzed the national average truck speed
limit weighted by VMT for each state based on VMT data by state from
the Federal Highway Administration as described in RIA Section 3.4.2.
Based on this information, the national average VMT-weighted truck
speed limit is 63 mph. The agencies continue to believe that the
appropriate high speed cruise speed should be set at the national
average truck speed limit to appropriately balance the evaluation of
technologies such as aerodynamics, but not overstate the benefits of
these technologies. Therefore, the agencies are adopting as proposed a
speed of 65 mph for the high speed cruise cycle.
---------------------------------------------------------------------------
\99\ Governors Highway Safety Association. Speed Limit Laws May
2011. Last viewed on May 9, 2011 at http://www.ghsa.org/html/stateinfo/laws/speedlimit_laws.html.
---------------------------------------------------------------------------
The agencies also received comments from Allison which disagreed
with proposed drive cycles for combination tractors because the cycles
did not account for external factors such as grades, wind, traffic
condition, etc. Allison also believes that the acceleration rates are
too low. The agencies recognize that the proposed drive cycles do not
incorporate the external factors described by Allison. Parallel to the
approach used to evaluate light-duty vehicles, the drive cycles do not
incorporate either grade or wind which can be difficult to simulate in
chassis dynamometer cells. In the final rules, the agencies are
defining an approach that manufacturers may take to evaluate their
aerodynamic packages in a wind-averaged condition and use a modified Cd
value in GEM.\100\ The agencies are also adopting provisions for the
innovative technology demonstration that allows for the use of on-road
testing which includes grades for technologies whose benefits are
reflected with grade. Lastly, the agencies' final drive cycles for
highway operation contain a constant speed, as proposed. The
acceleration and deceleration rates are only used to bring the vehicle
to the cruising speed and the CO2 emissions and fuel
consumption from these portions of the drive cycle are not included in
the composite emissions and fuel consumption results. The agencies did
not include the speed dithering, which is representative of actual
driving and traffic conditions, in the proposed constant speed portion
of the cycles because the dithering does not provide any additional
distinction between technologies but only added complexity to the
cycle. The agencies believe this approach is still appropriate for the
final action.
---------------------------------------------------------------------------
\100\ See Section IV.B.3.b below.
---------------------------------------------------------------------------
Allison referred the agencies to the Oak Ridge National Laboratory
and SmartWay program to review the amount of time long-haul vehicles
spend on the highway. They believe the steady state highway speeds are
overestimated. Data provided by Allison indicates that day cabs spend
only 14 percent of miles traveling at speeds greater than 60 mph. NHTSA
and EPA recognize that there is a variation in the amount of miles day
cabs travel under different operations. As described above, the
agencies are adopting an approach where tractors which operate like
vocational vehicles may be regulated as such in the HD program. Thus,
these day cabs will have a drive cycle weighting representative of
vocational vehicles with more weighting on the transient operation and
less on the highway speed operation.
For proposal, EPA and NHTSA relied on the EPA MOVES analysis of
Federal Highway Administration data to develop the mode weightings to
characterize typical operations of heavy-duty trucks, per Table II-10
below.\101\ A detailed discussion of drive cycles is included in RIA
Chapter 3.\102\ The agencies are adopting the proposed drive cycle
weightings for combination tractors.
---------------------------------------------------------------------------
\101\ 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.
\102\ 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''.
Table II-10--Drive Cycle Mode Weightings
------------------------------------------------------------------------
55 mph 65 mph
Transient cruise cruise
------------------------------------------------------------------------
Day Cabs......................... 19% 17% 64%
Sleeper Cabs..................... 5% 9% 86%
------------------------------------------------------------------------
(ii) Standardized Trailers
As proposed, NHTSA and EPA are adopting provisions so that the
tractor performance in the GEM is judged assuming the tractor is
pulling a standardized trailer. The agencies did not receive any
adverse comments related to this approach. The agencies believe that an
assessment of the tractor fuel consumption and CO2 emissions
should be conducted using a tractor-trailer combination. We believe
this approach best reflects the impact of the overall weight of the
tractor-trailer and the aerodynamic technologies in actual use, where
tractors are designed and used with a trailer. The GEM will continue to
use a predefined typical trailer in assessing overall performance. The
high roof sleeper cabs are paired with a standard box trailer; the mid
roof tractors are paired with a tanker trailer; and the low roof
tractors are paired with a flat bed trailer.
(iii) 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 vehicle is important because it in part determines
the impact of technologies, such as rolling resistance, on GHG
emissions and fuel consumption. In this final action, the agencies are
specifying each of these aspects of the vehicle, as proposed.
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
[[Page 57158]]
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).\103\
---------------------------------------------------------------------------
\103\ 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 and GCWR) of the vehicle. For example,
a typical Class 7 tractor can carry less payload than a Class 8
tractor. For proposal, the agencies used the Federal Highway
Administration Truck Payload Equivalent Factors using Vehicle Inventory
and Use Survey (VIUS) and Vehicle Travel Information System data to
determine the proposed payloads. FHWA's results found that the average
payload of a Class 8 vehicle ranged from 36,247 to 40,089 pounds,
depending on the average distance travelled per day.\104\ The same
results found that Class 7 vehicles carried between 18,674 and 34,210
pounds of payload also depending on average distance travelled per day.
Based on this data, the agencies proposed 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 proposed a
common payload for Class 8 day cabs and sleeper cabs as predefined GEM
input because the data available do 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.''
---------------------------------------------------------------------------
\104\ 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.
---------------------------------------------------------------------------
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.\105\
---------------------------------------------------------------------------
\105\ 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.
---------------------------------------------------------------------------
The agencies received comments from UMTRI and ATA regarding the
values assumed for the combination tractor weights. UMTRI recommended
using 80,000 pounds for the total weight for tractor-trailer
combinations. ATA based on their analysis of the Federal Highway
Administration's Long Term Pavement Database, recommended 5,000 to
10,000 pound payload for Class 7 tractors and 25,000 to 30,000 pounds
for Class 8 tractors. ATA also determined from the same database that
20 percent of tractor miles are empty, 67 percent cube-out, and 13
percent weigh-out. The agencies are adopting the proposed tractor-
trailer weights because we do not have strong evidence to select other
values and because changing the assumed values would not change the
impact on GHG emissions or fuel consumption of the technologies
included in this phase of the HD program (the relative stringency of
the standards and the projected emission reductions do not change with
assumed payload). NHTSA and EPA intend to continue evaluating
additional sources of weight information in future phases of the
program.
Details of the final individual weight inputs by regulatory
category, as shown in Table II-11, are included in RIA Chapter 3.
Table II-11--Final Combination Tractor Weights
----------------------------------------------------------------------------------------------------------------
Tractor Trailer Total
Model type Regulatory subcategory tare weight weight Payload weight
(lbs) (lbs) (lbs) (lbs)
----------------------------------------------------------------------------------------------------------------
Class 8............................. Sleeper Cab High Roof. 19,000 13,500 38,000 70,500
Class 8............................. Sleeper Cab Mid Roof.. 18,750 10,000 38,000 66,750
Class 8............................. Sleeper Cab Low Roof.. 18,500 10,500 38,000 67,000
Class 8............................. Day Cab High Roof..... 17,500 13,500 38,000 69,000
Class 8............................. Day Cab Mid Roof...... 17,100 10,000 38,000 65,100
Class 8............................. Day Cab Low Roof...... 17,000 10,500 38,000 65,500
Class 7............................. Day Cab High Roof..... 11,500 13,500 25,000 50,000
Class 7............................. Day Cab Mid Roof...... 11,100 10,000 25,000 46,100
Class 7............................. Day Cab Low Roof...... 11,000 10,500 25,000 46,500
----------------------------------------------------------------------------------------------------------------
(iv) Standardized Drivetrain
The agencies' assessment at proposal of the current vehicle
configuration process at the truck dealer's level was 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 each individual 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 received comments from ArvinMeritor and ICCT which suggested
that the agencies incorporate the actual drivetrain configuration (axle
configuration, driveline efficiency, and transmission) into the GEM.
The agencies continue to believe, and therefore are adopting as
proposed, that it is appropriate 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 the GEM for Tractors
As proposed, the agencies are defining the engine characteristics
used in the 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 reflected in the final standards. The agencies are
finalizing two distinct fuel consumption maps for use in the GEM. The
first fuel
[[Page 57159]]
consumption map would be used in the GEM for the 2014 through 2016
model years and represents an average engine which meets EPA's final
2014 model year engine CO2 emissions standards. The same
fuel map would be used for NHTSA's 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 will be used beginning in the 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 final MY 2017 standard. The
agencies have modified the 2017 MY fuel map used in the GEM for the
final rulemaking to address comments received. Details regarding this
change can be found in RIA Chapter 4.4.4. Effectively there is no
change in stringency of the tractor vehicle (not including the engine
standards over the full rulemaking period).\106\ These inputs are
appropriate given the separate regulatory requirement that Class 7 and
8 combination tractor manufacturers use only certified engines.
---------------------------------------------------------------------------
\106\ As noted earlier, use of the 2017 model year fuel
consumption map as a GEM input results in numerically more stringent
final vehicle standards for MY 2017.
---------------------------------------------------------------------------
(i) Heavy-Duty Engine Test Procedure for Engines Installed in
Combination Tractors
The HD engine test procedure consists of two primary aspects--a
duty cycle and a metric to evaluate the emissions and fuel consumption.
EPA proposed that the GHG emission standards for heavy-duty engines
under the CAA would be expressed as g/bhp-hr while NHTSA's proposed
fuel consumption standards under EISA, in turn, be represented as gal/
100 bhp-hr. 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.\107\ An analogous
metric for engines is the amount of fuel consumed per unit of work. The
g/bhp-hr metric is also consistent with EPA's current standards for
non-GHG emissions for these engines. The agencies did not receive any
adverse comments related to the metrics for HD engines; therefore, we
are adopting the metrics as proposed.
---------------------------------------------------------------------------
\107\ See NAS Report, Note 21, at page 39.
---------------------------------------------------------------------------
The agencies believe it is 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. This approach differs from
EPA's criteria pollutant standards for engines which 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.
We are not concerned if manufacturers further calibrate engines off-
cycle 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 GHG and fuel consumption standards based on both
transient and steady-state operating conditions for all engines could
lead to undesirable outcomes.
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 and fuel consumption benefits. 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. 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. (It is for
this reason that turbocompounding is not part of the technology basis
for MHD or HHD engines installed in vocational vehicles.)
The agencies proposed that engines installed in tractors
demonstrate compliance with the CO2 emissions and fuel
consumption standards over the SET cycle. Commenters such as Cummins,
Bosch, Daimler, and Honeywell supported the proposed approach. ACEEE
recommended adopting a new test cycle, such as the World Harmonized
Duty Cycle which was developed using newer data, to evaluate HD
engines. Daimler also supported the WHDC for future phases of the
program. The agencies continue to believe the important issues and
technical work related to setting new criteria pollutant emissions
standards appropriate for the World Harmonized Duty Cycle are
significant and beyond the scope of this rulemaking. The SET cycle
remains representative of typical driving cycles for combination
tractors (and engines installed in them). Therefore, the agencies are
adopting the SET cycle to evaluate CO2 emissions and fuel
consumption of HD engines installed in tractors, as proposed.
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 proposed not to include these emissions from
the calculation of the compliance levels over the defined test
procedures. Cummins and Daimler supported this approach and stated that
sufficient incentives already exist for manufacturers to limit
regeneration frequency. Conversely, Volvo opposed the omission of IRAF
requirements for CO2 emissions because emissions from
regeneration can be a significant portion of the expected improvement
and a significant variable between manufacturers
At proposal, we considered including regeneration in the estimate
of fuel consumption and GHG emissions and decided not to do so for two
reasons. See 75 FR at 74188. 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
[[Page 57160]]
frequency and duration of future engine designs in the time frame of
this program. 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. Therefore, the agencies are finalizing an
approach as proposed which does not include the regenerative emissions.
(j) Chassis-Based Test Procedure
In the proposal, the agencies 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.\108\
---------------------------------------------------------------------------
\108\ 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 vehicle 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 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 were adopted based on a chassis test procedure.
The agencies received comments from ACEEE and UCS supporting a full
vehicle testing approach, but these commenters recognized the
difficulties in doing this in the first phase of the HD program. The
agencies maintain that the full vehicle testing on chassis dynamometers
is not feasible in the timeframe of this rulemaking, although we
believe such an approach may 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.
(4) Summary of Flexibility and Credit Provisions for Tractors and
Engine Used in These Tractors
EPA and NHTSA are finalizing 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.
With the exception of the advanced technology credits, credits
generated under these provisions can only be used within the same
averaging set which generated the credit (for example, credits
generated by HD engines installed in tractors can only be used by HD
engines). EPA is also adopting a N2O emission credit
program, as described in Section IV below.
(5) Deferral of Standards for Tractor and Engine Manufacturing
Companies That Are Small Businesses
EPA and NHTSA are not adopting 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.\109\ 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 and engine
manufacturers.
---------------------------------------------------------------------------
\109\ See Sec. 1036.150 and Sec. 1037.150.
---------------------------------------------------------------------------
The agencies have identified two entities that fit the SBA size
criterion of a small business.\110\ 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,\111\ and therefore that the exemption will
have a negligible impact on the GHG emissions and fuel consumption
improvements from the final standards.
---------------------------------------------------------------------------
\110\ The agencies have identified Ottawa Truck, Inc. and Kalmar
Industries USA as two potential small tractor manufacturers.
\111\ M.J. Bradley. Heavy-duty Vehicle Market Analysis. May
2009.
---------------------------------------------------------------------------
To ensure that the agencies are aware of which companies would be
exempt, we are requiring 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 for complete HD
pickups and vans are presented in this section. These provisions also
cover optional chassis certification of incomplete HD vehicles and of
Class 4 and 5 vehicles, as discussed in detail in Section V.B(1)(e).
Section II.C(1) explains the form of the CO2 and fuel
consumption standards, the numerical levels for those standards, and
the approach to phasing in the standards over time. The measurement
procedure for determining compliance is discussed in Section II.C(2),
and the EPA and NHTSA compliance programs are discussed in Section
II.C(3). Section II.C(4) discusses implementation flexibility
provisions. Section II.E discusses additional standards and provisions
for N2O and CH4 emissions, for vehicle air
conditioning leakage, and for ethanol-fueled and electric vehicles. HD
pickup and van air conditioning efficiency is not being regulated, for
reasons discussed in Section II.E.
(1) What are the 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 original equipment
manufacturers as complete vehicles, ready for use on the road. In
addition, most of these
[[Page 57161]]
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. As a result, Class 2b and
3 complete vehicles share much more in common with light-duty trucks
than with other heavy-duty 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 accessories), 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 being done
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.'' There was
consensus in the public comments supporting this approach.
(b) Work-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 rulemaking, 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. Work-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 work-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.\112\
---------------------------------------------------------------------------
\112\ Section II.C(2) discusses our decision 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 combination
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,
[[Page 57162]]
2009). The agencies believe that using payload and towing capacities as
the work-based attributes avoids 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
proposed to set standards for HD pickups and vans based on the proposed
``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 accounts for the
fact that 4wd, critical to enabling the many off-road heavy-duty work
applications, adds roughly 500 lb to the vehicle weight. There was
consensus in the public comments supporting this attribute, and the
agencies are adopting it as proposed. Target GHG and fuel consumption
standards will be determined for each vehicle with a unique work factor
(analogous to a target for each discrete vehicle footprint in the
light-duty vehicle rules). These targets will then be production
weighted and summed to derive a manufacturer's annual fleet average
standard for its heavy-duty pickups and vans. Widespread support for
the proposed work factor-based approach to standards and fleet average
approach to compliance was expressed in the comments we received.
To ensure consistency and help preclude gaming, we are finalizing
the proposed provision that payload capacity be defined as GVWR minus
curb weight, and towing capacity as GCWR minus GVWR. For purposes of
determining the work factor, GCWR is defined according to the Society
of Automotive Engineers (SAE) Recommended Practice J2807 APR2008, GVWR
is defined consistent with EPA's criteria pollutants program, and curb
weight is defined as in 40 CFR 86.1803-01. 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.\113\ This approach was supported by
commenters.
---------------------------------------------------------------------------
\113\ 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 finalized 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 vehicle 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 setting 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. Again, commenters agreed with this approach to setting HD
pickup and van 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 will be affected by
the standard. With this 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) Standards
The agencies are finalizing standards based on a technology
analysis performed by EPA to determine the appropriate HD pickup and
van standards. This analysis, described in detail in 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 finalizing the proposed
CO2 attribute-based target standards shown in Figure 0-2 and
II-3, and NHTSA is finalizing the equivalent attribute-based fuel
consumption target standards, also shown in Figure 0-2 and II-3,
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
respective statutory obligations. Also, for reasons discussed below,
the agencies proposed and are establishing separate targets for
gasoline-fueled (and any other Otto-cycle) vehicles and diesel-fueled
(and any other Diesel-cycle) vehicles. The targets will be used to
determine the production-weighted fleet average standards that apply to
the combined diesel and gasoline fleet of HD pickups and vans produced
by a manufacturer in each model year.
[[Page 57163]]
[GRAPHIC] [TIFF OMITTED] TR15SE11.002
\114\ The NHTSA program 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 57164]]
[GRAPHIC] [TIFF OMITTED] TR15SE11.003
Described mathematically, EPA's and NHTSA's target standards are
defined by the following formulae:
---------------------------------------------------------------------------
\115\ The NHTSA program 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-12 or Table II-
13.
---------------------------------------------------------------------------
\116\ The NHTSA program 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).
Table II-12--Coefficients for HD Pickup and Van Target Standards \116\
------------------------------------------------------------------------
Model year a b c d
------------------------------------------------------------------------
Diesel Vehicles
------------------------------------------------------------------------
2014............................ 0.0478 368 0.000470 3.61
2015............................ 0.0474 366 0.000466 3.60
2016............................ 0.0460 354 0.000452 3.48
2017............................ 0.0445 343 0.000437 3.37
2018 and later.................. 0.0416 320 0.000409 3.14
------------------------------------------------------------------------
Gasoline Vehicles
------------------------------------------------------------------------
2014............................ 0.0482 371 0.000542 4.17
2015............................ 0.0479 369 0.000539 4.15
2016............................ 0.0469 362 0.000528 4.07
2017............................ 0.0460 354 0.000518 3.98
2018 and later.................. 0.0440 339 0.000495 3.81
------------------------------------------------------------------------
[[Page 57165]]
Table II-13--Coefficients for NHTSA's First Alternative and EPA's
Alternative HD Pickup and Van Target Standards
------------------------------------------------------------------------
Model year a b c d
------------------------------------------------------------------------
Diesel Vehicles
------------------------------------------------------------------------
2014 a.......................... 0.0478 368 0.000470 3.61
2015 a.......................... 0.0474 366 0.000466 3.60
2016-2018....................... 0.0440 339 0.000432 3.33
2019 and later.................. 0.0416 320 0.000409 3.14
------------------------------------------------------------------------
Gasoline Vehicles
------------------------------------------------------------------------
2014 a.......................... 0.0482 371 0.000542 4.17
2015 a.......................... 0.0479 369 0.000539 4.15
2016-2018....................... 0.0456 352 0.000513 3.96
2019 and later.................. 0.0440 339 0.000495 3.81
------------------------------------------------------------------------
Notes:
a NHTSA standards will be voluntary in 2014 and 2015.
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. 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 requiring 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) HD pickup trucks and vans. An additional two percent reduction in
GHGs will be achieved by the direct air conditioning leakage standard
in the EPA standards. 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 levels for gasoline and diesel
vehicles, which is important in ensuring our program maintains product
choices available to vehicle buyers.
In written comments on the proposal, Cummins objected to setting
separate diesel and gasoline vehicle standards, on the basis that it
increases the burden for diesel engine manufacturers more than for
gasoline engine manufacturers, and thereby could shift market share
away from diesels. EMA argued for fuel-neutrality based on historical
precedent and the fact that GHGs emitted by one type of engine are no
different than those emitted by another type of engine. We believe that
both engine types have roughly equivalent redesign burdens as evidenced
by the feasibility and cost analysis in RIA Chapter 2. Also, even
though the emissions and fuel consumption reductions are expressed from
a common diesel/gasoline baseline in these final rules, the actual
starting base for diesels is at a lower level than for gasoline
vehicles. Other industry commenters, including those with sizeable
diesel sales, expressed general support for the standards. The agencies
agree that standards that do not distinguish between fuel types are
generally preferable where technological or market-based reasons do not
strongly argue otherwise. These technological differences exist
presently between gasoline and diesel engines for GHGs, as described
above. The agencies emphasize, however, that they are not committed to
perpetuating separate GHG standards for gasoline and diesel heavy-duty
vehicles and engines, and expect to reexamine the need for separate
gasoline/diesel standards in the next rulemaking.
Environmental groups and others commented that the proposed
standards were not stringent enough, citing the heavy-duty vehicle NAS
study finding that technologies such as hybridization are feasible.
However, in the ambitious timeframe we are focusing on for these rules,
targeting as it does technologies implementable in the HD pickup and
van fleet starting in 2014 and phasing in with normal product redesign
cycles through 2018, our assessment shows that the standards we are
establishing are appropriate. More advanced technologies considered in
the NAS report would be appropriate for consideration in future
rulemaking activity. Additional conventional technologies identified by
commenters as promising in light-duty applications and potentially
useful for HD applications are discussed in RIA chapter 2.
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
will generally be equivalent to fuel consumption. However, as explained
below in Section 0, EPA is finalizing a provision for manufacturers to
use CO2 credits to help demonstrate compliance with
N2O and CH4 emissions standards, by expressing
any N2O and CH4 undercompliance in terms of their
CO2-equivalent and applying the needed CO2
credits. For test families that do not use this compliance alternative,
the measured performance values for CO2 and fuel consumption
will be equivalent because the same test runs and measurement data will
be used to determine both values, and calculated fuel consumption will
be based on the same conversion factors that are used to establish the
relationship between the CO2 and fuel consumption target
curves (8,887 g CO2/gallon for gasoline and 10,180 g
CO2/gallon for diesel fuel). For manufacturers that choose
to use the EPA provision for CO2 credit use in demonstrating
N2O and CH4 compliance, compliance with the
CO2 standard will not be directly equivalent to compliance
with the NHTSA fuel consumption standard.
[[Page 57166]]
(d) Implementation Plan
(i) EPA Program Phase-In MY 2014-2018
EPA is finalizing the proposed provision 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 will need to meet a fleet-average
standard that will become increasingly more stringent each year of the
phase-in period. For both gasoline and diesel vehicles, this phase-in
will be 15-20-40-60-100 percent of the model year 2018 stringency 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 will be 15 percent of the fully-phased-in reductions. Figures
II-2 and II-3, and Table 0-12, reflect this phase-in approach.
EPA is also providing manufacturers with an optional alternative
implementation schedule in model years 2016 through 2018, equivalent to
NHTSA's first alternative for standards that do not change over these
model years, described below. Under this option the phase-in will be
15-20-67-67-67-100 percent of the model year 2019 stringency in model
years 2014-2015-2016-2017-2018-2019, respectively. Table 0-13, above,
provides the coefficients ``a'' and ``b'' for this manufacturer's
alternative. As explained below, this alternative will provide roughly
equivalent overall CO2 reductions and fuel consumption
improvements as the 15-20-40-60-100 percent phase-in. In addition, 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 will 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 with its MY 2014 fleet of HD pickups and vans. No comments
were received in support of an alternative approach that EPA requested
comment on, involving phasing in an annually increasing percentage of
each manufacturer's sales volume.
(ii) NHTSA Program Phase-In 2016 and Later
NHTSA is finalizing the proposed provision to allow manufacturers
to select one of two fuel consumption standard alternatives for model
years 2016 and later. Each manufacturer will select an alternative in
its joint pre-model year report, discussed below, that is now required
to be electronically submitted to the agencies; and, once selected, the
alternative will apply for model years 2016 and later, and cannot be
reversed. The first alternative will define a fuel consumption target
line function for gasoline vehicles and a target line function for
diesel vehicles that will not change for model years 2016 to 2018. The
target line function coefficients are provided in Table II-13.
The second alternative will be equivalent to the EPA target line
functions in each model year starting in 2016 and continuing
afterwards. Stringency of fuel consumption standards will increase
gradually for the 2016 and later model years. Relative to a model year
2010 unregulated baseline for both gasoline and diesel vehicles,
stringency will 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 2019 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 either alternative
and have a similar credit balance at the end of model year 2018 under
the EPA and NHTSA programs.
(iii) NHTSA Voluntary Standards Period
NHTSA is finalizing the proposed provision 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 in to the program, it
must stay in the program for all the optional model years.
Manufacturers that opt in become subject to NHTSA standards for all
regulatory categories. To opt into the program, a manufacturer must
declare its intent to opt in to the program in its Pre-Model Year
Report. The agencies have finalized new requirements for manufacturers
to provide all early model declarations as a part of the pre-model year
reports. See regulatory text for 49 CFR 535.8 for information related
to the Pre-Model Year Report. 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 2019 target line function stringency
(under the NHTSA first alternative) and 15-20 percent of the model year
2018 target line function stringency (under the NHTSA second
alternative) in model years 2014-2015, respectively. The corresponding
absolute standards target levels are provided in Figure II-2 and II-3,
and the accompanying equations.
(2) What are the HD pickup and van test cycles and procedures?
EPA and NHTSA are finalizing the proposed provision 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 is identical to that of the light-duty test,
other test parameters for running the HFET, such as test vehicle loaded
weight, are 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 will 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
work factor-based CO2 and fuel consumption standards, since
the data on the baseline and technology efficiency was also
[[Page 57167]]
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, nor did
any commenters provide such data. 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 [frac12] 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
[frac12] payload better fits their usage in the real world and will
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, nor did any commenters provide such information. We are
therefore using ALVW for test vehicle loading in GHG and fuel
consumption testing.
Additional provisions for our final testing and compliance program
are provided in Section V.B.
(3) How are the HD pickup and van standards structured?
EPA and NHTSA are finalizing the proposed fleet average standards
for new HD pickups and vans, based on a manufacturer's new vehicle
fleet makeup. In addition, EPA is finalizing proposed in-use standards
that apply to the individual vehicles in this fleet over their useful
lives. The compliance provisions for these 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 in
detail in the proposal.
(a) Fleet Average Standards
In the programs we are finalizing, each manufacturer will 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 have
individual targets at numerically higher CO2 and fuel
consumption levels than lower payload/towing vehicles, as discussed in
Section II.C(1). The fleet average standard for a manufacturer is 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
is based on its final production figures for the model year, and thus a
final assessment of compliance will occur after production for the
model year ends. Because compliance with the fleet average standards
depends on 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 will 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 will issue a certificate for the vehicles
covered by the test group based on this demonstration, and will 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 will 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 will 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 requiring 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 will be used. EPA and NHTSA
anticipate that the deterioration factor may 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 finalizing apply to individual vehicles.
NHTSA is not adopting in-use standards because they are not required
under EISA, and because it is not currently anticipated that there will
be any notable deterioration of fuel consumption. For the EPA program,
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 finalizing the proposed provision 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 finalizing the proposed
provision 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 finalizing the proposed provision 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 finalizing the proposed
adjustment factor for the in-use standard to provide some margin for
production and test-to-
[[Page 57168]]
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 finalizing
the proposed provision that each model's in-use CO2 standard
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). No adverse
comments were received on this proposed provision.
As it does now for heavy-duty vehicle criteria pollutants, EPA will
use a variety of mechanisms to conduct assessments of compliance with
the in-use standards, including pre-production certification and in-use
monitoring once vehicles enter customer service. The full useful life
in-use standards apply to vehicles that have entered customer service.
The same standards apply to vehicles used in pre-production and
production line testing, except that deterioration factors are not
applied.
(4) What HD pickup and van flexibility provisions are being
established?
This program 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
which encompasses averaging, banking and trading 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 finalizing the proposed
provision 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
approach, a manufacturer's HD pickup and van fleet that achieves a
fleet average CO2 or fuel consumption level better than its
standard will 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
will 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 light-duty 2012-2016 MY vehicle rule, 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 will 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 model years, consistent with the
light-duty program. We are finalizing the proposed provision that,
after satisfying any need to offset pre-existing deficits, a
manufacturer may bank remaining credits for use in future years, with a
limitation on the carry-forward of credits to five model years. We are
also finalizing the proposed provision 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 finalizing any credit transferability to or from other credit
programs or averaging sets.
Consistent with the President's May 21, 2010, directive to promote
advanced technology vehicles and with the agencies' respective
statutory authorities, we are adopting flexibility provisions that
parallel similar provisions adopted in the light-duty program. These
include credits for advance technology vehicles such as electric
vehicles, and credits for 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.
D. Class 2b-8 Vocational Vehicles
Heavy-duty vehicles serve a vast range of functions including
service for urban delivery, refuse hauling, utility service, dump,
concrete mixing, transit service, shuttle service, school bus,
emergency, motor homes,\117\ and tow trucks to name only a small subset
of the full range of vehicles. The vehicles designed to serve these
functions are as unique as the jobs they do. They are vastly
different--one from the other--in size, shape and function. The
agencies were unable to develop a specific vehicle definition based on
the characteristics of these vehicles. Instead at proposal, we proposed
to define that Class 2b-8 vocational vehicles as all heavy-duty
vehicles which are not included in the Heavy-duty Pickup Truck and Van
or the Class 7 and 8 Tractor categories. In effect, we said everything
that is not a combination tractor or a pickup truck or van is a
vocational vehicle. We are finalizing that definition as proposed
reflecting the same challenges we faced at proposal regarding defining
the full range of heavy-duty vehicles. As at proposal, recreational
vehicles are included under EPA's standards but are not included under
NHTSA's final standards. The agencies note that we are adding
vocational tractors to the vocational vehicle category in the final
rulemaking, as described above in Section II.B.
---------------------------------------------------------------------------
\117\ See above for discussion of applicability of NHTSA's
standards to non-commercial vehicles.
---------------------------------------------------------------------------
The agencies proposed that Class 4 pickup trucks although similar
to Class 2b and 3 vehicles be included in the vocational vehicle
category. Comments from EMA, Cummins, NTEA and Navistar supported the
premise that Class 4 vehicles belong as part of the vocational vehicle
program because they are specifically designed and engineered to meet
vocational requirements. They stated that components such as
transmissions, axles, frames, and tires differ from the similar pickup
trucks and vans in the Class 2b and 3 market. We agree with commenters'
arguments that there are a number of important differences between the
Class 4 and Class 3 trucks it unreasonable to regulate Class 4 vehicles
under the standards for heavy duty pickups and vans. As a result, we
are keeping Class 4 vehicles in the vocational vehicle category, but
are allowing the optional chassis certification of Class 4 and 5
vehicles. (See Section V.B(1)(e)).
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 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
[[Page 57169]]
tires) will be the same between these two types of complete vehicles.
The agencies face difficulties in establishing the baseline
CO2 and fuel consumption performance for the wide variety of
complete vocational vehicles because of the very large number of
vehicle types and the need to conduct testing on each of the vehicle
types to establish the baseline. To establish standards for a complete
vocational vehicle, it would be necessary to assess the potential for
fuel consumption and GHG emissions improvement for each of these
vehicle types and to establish standards for each vehicle type. Because
of the size and complexity of this task, the agencies judged it was not
practical to regulate complete vocational vehicles for this first fuel
consumption and GHG emissions program. To overcome the lack of baseline
information from the different vehicle types and to still achieve
improvements to fuel consumption and GHG emissions, the agencies
proposed to set standards for the chassis manufacturers of vocational
vehicles (but not the body builders) and the engine manufacturers.
Chassis manufacturers represent a limited number of companies as
compared to body builders, which are made up of a diverse set of
companies that are typically small businesses. These companies would
need to be regulated if whole vehicle standards were established.
Similar to combination tractors, the agencies proposed to set
separate vehicle and engine standards for vocational vehicles. A number
of comments were received on the proposal to regulate chassis and
engine manufacturers. The agencies received comments from DTNA
supporting the proposal to regulate the chassis manufacturer but not
body manufacturers. While organizations like Cummins and ICCT expressed
support for separate engine and vehicle standards, Navistar, Pew, and
Volvo, in contrast, opposed separate engine and chassis standards,
stating that separate engine standards disadvantages integrated truck/
engine manufacturers and full vehicle standards should be required.
Volvo asked that the standards include an alternative integrated
standard as well as complete vehicle modeling and testing beginning in
2017. ACEEE and Sierra Club stated that the proposed standards and test
procedures should move the agencies closer to full vehicle testing.
Although the agencies understand that full vehicle standards would
allow integrated truck/engine manufacturers--such as electrified
accessories and weight reduction--the agencies are finalizing separate
standards for vocational vehicles that apply to chassis manufacturers
and engine standards for engines installed in these vehicles that apply
to engine manufacturers. The agencies continue to believe that it is
not practical to regulate complete vocational vehicles for this first
fuel consumption and GHG emissions program because of the size and
complexity of the task associated with assessing the potential for fuel
consumption and GHG emissions improvement for each of the myriad types
of vocational vehicles. This issue is discussed further in comment
responses found in sections 5 and 6.1.4 of the Response to Comment
Document, as well as in the following section of the preamble. Thus,
the agencies are finalizing a set of standards for the chassis
manufacturers of vocational vehicles (but not the body builders) and
for the manufacturers of HD engines used in vocational vehicles.
(1) What are the vocational vehicle and engine CO2 and fuel
consumption standards and their timing?
In the NPRM, the agencies proposed vehicle standards based on the
agencies' assessment of the availability of low rolling resistance
tires that could be applied generally to vocational vehicles across the
entire category. The agencies considered the possibility of including
other technologies in determining the proposed stringency of the
vocational vehicle standards, such as aerodynamic improvements, but as
discussed in the NPRM, tentatively concluded that such improvements
would not be appropriate for basing vehicle standard stringency in this
phase of the rulemaking.\118\ For example, the aerodynamics of a
recovery vehicle are impacted significantly by the equipment such as
the arm located on the exterior of the truck.\119\ 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 minimal
fuel consumption reduction opportunity through aerodynamic technologies
for bucket trucks, transit buses, and refuse trucks \120\ 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 vehicles that operate at higher
speeds.\121\
---------------------------------------------------------------------------
\118\ See 75 FR at 74241.
\119\ A recovery vehicle removes or recovers vehicles that are
disabled (broken down).
\120\ See 2010 NAS Report, Note 21, page 133.
\121\ See 2010 NAS Report, Note 21, page 110.
---------------------------------------------------------------------------
The agencies received comments from the Motor Equipment
Manufacturers Association, Eaton, NRDC, NESCAUM, NACAA, ACEEE, ICCT,
Navistar, Arvin Meritor, the Union of Concerned Scientists and others
that technologies such as idle reduction, advanced transmissions,
advanced drivetrains, weight reduction, hybrid powertrains, and
improved auxiliaries provide opportunities to reduce fuel consumption
from vocational vehicles. Commenters asked that the agencies establish
regulations that would reflect performance of these technologies and
essentially force their utilization.
The agencies assessed these technologies and have concluded that
they may have the potential to reduce fuel consumption and GHG
emissions from at least certain vocational vehicles, but the agencies
have not been able to estimate baseline fuel consumption and GHG
emissions levels for each type of vocational vehicle and for each type
of technology, given the wide variety of models and uses of vocational
vehicles. For example, idle reduction technologies such as APUs and
cabin heaters can reduce workday idling associated with vocational
vehicles. However, characterizing idling activity for the vocational
segment in order to quantify the benefits of idle reduction technology
is complicated by the variety of duty cycles found in the sector.
Idling in school buses, fire trucks, pickup trucks, delivery trucks,
and other types of vocational vehicles varies significantly. Given the
great variety of duty cycles and operating conditions of vocational
vehicles and the timing of these rules, it is not feasible at this time
to establish an accurate baseline for quantifying the expected
improvements which could result from use of idle reduction
technologies. Similarly, for advanced drivetrains and advanced
transmissions determining a baseline configuration, or a set of
baseline configurations, is extremely difficult given the variety of
trucks in this segment. The agencies do not believe that we can
legitimately base standard stringency on the use of technologies for
which we cannot identify baseline configurations, because absent
baseline emissions and baseline fuel consumption, the emissions
reductions achieved from introduction of the technology cannot be
quantified. For some technologies, such as weight
[[Page 57170]]
reduction and improved auxiliaries--such as electrically driven power
steering pumps and the vehicle's air conditioning system--the need to
limit technologies to those under the control of the chassis
manufacturer further restricted the agencies' options for predicating
standard stringency on use of these technologies. For example,
lightweight components that are under the control of chassis
manufacturers are limited to a very few components such as frame rails.
Considering the fuel efficiency and GHG emissions reduction benefits
that will be achieved by finalizing these rules in the time frame
proposed, rather than delaying in order to gain enough information to
include additional technologies, the agencies have decided to finalize
standards that do not assume the use of these technologies and will
consider incorporating them in a later action applicable to later model
years. Cf. Sierra Club v. EPA, 325 F. 3d 374, 380 (DC Cir. 2003) (in
implementing a technology-forcing provision of the CAA, EPA reasonably
adopted modest initial controls on an industry sector in order to
better assess rules' effects in preparation for follow-up rulemaking).
As the program progresses and the agencies gather more information,
we expect to reconsider whether vocational vehicle standards for MYs
2019 and beyond should be based on the use of additional technologies
besides low rolling resistance tires.
EPA is adopting CO2 standards and NHTSA is finalizing
fuel consumption standards for manufacturers of chassis for new
vocational vehicles and for manufacturers of heavy-duty engines
installed in these vehicles. The final heavy-duty engine standards for
CO2 emissions and fuel consumption focus on potential
technological improvements in fuel combustion and overall engine
efficiency and those controls would achieve most of the emission
reductions. Further reductions from the Class 2b-8 vocational vehicle
itself are possible within the time frame of these final regulations.
Therefore, the agencies are also finalizing 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 RIA Chapter 2, show that these final standards
appear appropriate under each agency's respective statutory
authorities. Together these standards are estimated to achieve
reductions of up to 10 percent from most vocational vehicles.
EPA is also adopting standards to control N2O and
CH4 emissions from Class 2b-8 vocational vehicles through
controlling these GHG emissions from the HD engines. The final heavy-
duty engine standards for both N2O and CH4 and
details of the standard are included in the discussion in Section
II.E.1.b and II.E.2.b. EPA neither proposed nor is adopting air
conditioning leakage standards applying to vocational vehicle chassis
manufacturers.
As discussed further below, the agencies are setting CO2
and fuel consumption standards for the 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 proposed to aggregate several vehicle weight categories under
a single category for setting the standards. The agencies proposed to
divide the vocational vehicle segment into three broad regulatory
subcategories--Light 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 received comments supporting the division of vocational
vehicles into three regulatory categories from DTNA. The agencies also
received comments from Bosch, Clean Air Task Force, and National Solid
Waste Management Association supporting a finer resolution of
vocational vehicle subcategories. Their concerns include that the
agencies' vehicle configuration in GEM is not representative of a
particular vocational application, such as refuse trucks. Another
recommendation was to divide the category by both GVWR and by
operational characteristics. Upon further consideration, the agencies
are finalizing as proposed three vocational vehicle subcategories
because we believe this adequately balances simplicity while still
obtaining reductions in this diverse segment. (As noted in section IV.A
below, these three subcategories also denominate separate averaging
sets for purposes of ABT.) Finer distinctions in regulatory
subcategories would not change the technology basis for the standards
or the reductions expected from the vocational vehicle category. 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.
The agencies received comments supporting the exclusion of
recreational vehicles, emergency vehicles, school buses from the
vocational vehicle standards. The commenters argued that these
individual vehicle types were small contributors to overall GHG
emissions and that tires meeting their particular performance needs
might not be available by 2014. The agencies considered these comments
and the agencies have met with a number of tire manufacturers to better
understand their expectations for product availability for the 2014
model year. Based on our review of the information shared, we are
convinced that tires with rolling resistance consistent with our final
vehicle standards and meeting the full range of other performance
characteristics desired in the vehicle market, including for RVs,
emergency vehicles, and school buses, will be broadly available by the
2014 model year.\122\ Absent regulations for the vast majority of
vehicles in this segment, feasible cost-effective reductions available
at reasonable cost in the 2014-2018 model years will be needlessly
foregone. Therefore, the agencies have decided to finalize the
vocational vehicle standards as proposed with recreational vehicles,
emergency vehicles and school buses included in the vocational vehicle
category. As RVs were not included by NHTSA for proposed regulation,
they are not within the scope of the NPRM and are therefore excluded in
NHTSA's portion of the final program. NHTSA will revisit this issue in
the next rulemaking. In developing the final 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. After examining the possibility of vehicle improvements based
on use of the technologies underlying the standards for Class 7 and 8
tractors, including improved aerodynamics, vehicle speed limiters, idle
reduction technologies, tire rolling resistance, and weight reduction,
as well as use of hybrid technologies, the agencies ultimately
[[Page 57171]]
determined to base the final vehicle standards on performance of tires
with superior rolling resistance. For standards for diesel engines
installed in vocational vehicles, the agencies examined performance of
engine friction reduction, aftertreatment optimization, air handling
improvements, combustion optimization, turbocompounding, and waste heat
recovery, ultimately deciding to base the final standards on the
performance of all of the technologies except turbocompounding and
waste heat recovery systems. The standards for gasoline engine
installed in vocational vehicles are based on performance of
technologies such as gasoline direct injection, friction reduction, and
variable valve timing. The agencies' evaluation indicates that these
technologies, as described in Section III.C, are available today in the
heavy-duty tractor and light-duty vehicle markets, but have very low
application rates in the vocational vehicle market. The agencies have
analyzed the technical feasibility of achieving the 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 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 vocational vehicle standards in Section III.
---------------------------------------------------------------------------
\122\ Bachman, Joseph. Memorandum to the Docket. Heavy-Duty Tire
Evaluation. See Docket EPA-HQ-OAR-2010-0162. Pages 2-3 and
Appendix B.
---------------------------------------------------------------------------
(a) Vocational Vehicle Chassis Standards
In the NPRM, the agencies defined tire rolling resistance as a
frictional loss of energy, associated mainly with the energy dissipated
in the deformation of tires under load that influences fuel efficiency
and CO2 emissions. Tires with higher rolling resistance lose
more energy in response to this deformation, thus using more fuel and
producing more CO2 emissions in operation, while tires with
lower rolling resistance lose less energy, and save more fuel and
CO2 emissions in operation. Tire design characteristics
(e.g., materials, construction, and tread design) influence durability,
traction (both wet and dry grip), vehicle handling, ride comfort, and
noise in addition to rolling resistance.
The agencies explained that a typical Low Rolling Resistance (LRR)
tire's attributes, compared to a non-LRR tire, would include increased
tire inflation pressure; material changes; and tire construction with
less hysteresis, geometry changes (e.g., reduced height to width aspect
ratios), and reduction in sidewall and tread deflection. When a
manufacturer applies LRR tires to a vehicle, the manufacturer generally
also makes changes to the vehicle's suspension tuning and/or suspension
design in order to maintain vehicle handling and ride comfort.
The agencies also explained that while LRR tires can be applied to
vehicles in all MD/HD classes, they may have special potential for
improving fuel efficiency and reducing CO2 emissions for
vocational vehicles. According to an energy audit conducted by Argonne
National Lab, tires are the second largest contributor to energy losses
of vocational vehicles, after engines.\123\ Given this finding, the
agencies considered the availability of LRR tires for vocational
applications by examining the population of tires available, and
concluded that there appeared to be few LRR tires for vocational
applications. The agencies suggested in the NPRM that this low number
of LRR tires for vocational vehicles could be due in part to the fact
that the competitive pressure to improve rolling resistance of
vocational vehicle tires has been less than in the line haul tire
market, given that line haul vehicles generally drive significantly
more miles and therefore have significantly higher operating costs for
fuel than vocational vehicles, and much greater incentive to improve
fuel consumption. The small number of LRR tires for vocational vehicles
may perhaps also be due in part to the fact that vocational vehicles
generally operate more frequently on secondary roads, gravel roads and
roads that have less frequent winter maintenance, which leads
vocational vehicle buyers to value tire traction and durability more
than rolling resistance. The agencies recognized that this provided an
opportunity to improve fuel consumption and GHG emissions by creating a
regulatory program that encourages improvements in tire rolling
resistance for both line haul and vocational vehicles. The agencies
proposed to base standards for all segments of HD vehicles on the use
of LRR tires. The agencies estimated that a 10 percent reduction in
average tire rolling resistance would be attainable between model years
2010 and 2014 based on the tire development achievements over the last
several years in the line haul truck market. This reduction in tire
rolling resistance would correlate to a two percent reduction in fuel
consumption as modeled by the GEM.\124\
---------------------------------------------------------------------------
\123\ A Class 6 pick up and delivery truck at 50% load has tires
as the second largest contributor at speeds up to 35 mph, a typical
average speed of urban delivery vehicles. See Argonne National
Laboratory. ``Evaluation of Fuel Consumption Potential of Medium and
Heavy Duty Vehicles through Modeling and Simulation.'' October 2009.
Page 91.
\124\ See 75 FR at 74241.
---------------------------------------------------------------------------
(i) Summary of Comments
The agencies received many comments on the subject of tire rolling
resistance as applied to vocational vehicles. Comments included
suggestions for alternative test procedures; whether LRR tires should
be applied to certain types of vocational vehicles and whether certain
vehicles should be exempted from the vocational vehicle standards if
the standards are based on the ability to use LRR tires; the
appropriateness of the proposed standards; and compliance issues
(discussed below in Section II.D.2.b.
Regarding whether LRR tires should be applied to certain types of
vocational vehicles, the agencies received many comments from
stakeholders, such as Daimler Trucks North America, Fire Apparatus
Manufacturers Association (FAMA), International Association of Fire
Chiefs, National Ready Mix, National Solid Wastes Management
Association (NSWMA), Spartan Motors, National Automobile Dealers
Association, among others. There were comments regarding applicability
of low rolling resistance tires to vocational vehicles based on LRR
tire availability, suitability of the tires for the applications, fuel
consumption and GHG emissions benefits and the appropriateness of
standards. Many of these commenters focused particularly on the whether
LRR tires would compromise the capability of emergency vehicles.
Regarding whether LRR tires are available in the market for certain
vocational vehicles and whether the vocational vehicle standards were
therefore appropriate and feasible, both Ford and AAPC stated that the
proposed model-based requirement for Class 2b-8 vocational chassis
appeared to require tires with rolling resistance values of
approximately 8.0-8.1 kg/metric ton or better, and that limited data
available for smaller diameter tires, such as light-truck (LT) tires
used on many light heavy-duty trucks and vans, suggested that there
exist few if any choices for tires that would comply. Given this
concern about the availability of compliant tires, particularly in the
case of tires smaller than 22.5'', during the proposed regulatory time
frame, AAPC and Ford requested revisions to the requirement, or the
modeling method, to establish different standards for vehicles
[[Page 57172]]
that use different tire classes, with separate requirements for LT
tires, 19.5'' tires, and 22.5'' tires. AAPC argued that standards
should be set based on data collected on high volume in-use tires, and
that they should be set at a level that ensures the availability of
multiple compliant tires. CRR
(ii) Summary of Research Done Since the Notice of Proposed Rulemaking
Since the NPRM, the agencies have conducted additional research on
tire rolling resistance for medium- and heavy-duty applications. This
research involved direct discussions with tire suppliers,\125\
assessment of the comments received, additional review of tire products
available, and a more thorough review of tire use in the field. In
addition, EPA has conducted tire rolling resistance testing to help
inform the final rulemaking.\126\
---------------------------------------------------------------------------
\125\ Records of these communications, and additional
information submitted by the supplier companies and not CBI, are
available at Docket No. EPA-HQ-OAR-2010-0162.
\126\ Bachman, Joseph. Memorandum to the Docket. Heavy-Duty Tire
Evaluation. July 2011. Docket EPA-HQ-OAR-2010-0162, Pages 3-6.
---------------------------------------------------------------------------
The agencies discussed many aspects of low rolling resistance tire
technologies and their application to vocational vehicles with tire
suppliers since publication of the NPRM. Several tire suppliers
indicated to the agencies that low rolling resistance tires are
currently available for vocational applications that would enable
compliance with the proposed vocational vehicle standards, such as
delivery vehicles, refuse vehicles, and other vocations. However, these
conversations also made the agencies aware that availability of low
rolling resistance tires varies by supplier. Some suppliers stated they
focused their company resources on areas of the medium- and heavy-duty
vehicle spectrum where fleet operators would see the most fuel
efficiency benefits for the application of low rolling resistance
technologies; specifically the long-haul, on-highway applications that
drive many miles and use large amounts of fuel. These suppliers stated
that this choice was driven by the significant capital investment that
would be needed to improve tire rolling resistance across the
relatively large number of product offerings in the vocational vehicle
segment, based on the wide range of tire sizes, load ratings, and speed
ratings, compared to the much narrower range of offerings for long-haul
applications.\127\ Other suppliers stated that they have made conscious
efforts to reduce the rolling resistance of all of their medium- and
heavy-duty vehicle tire offerings, including vocational applications,
in an effort to become leaders in this technology.
---------------------------------------------------------------------------
\127\ More tire types and sizes have been developed for
vocational vehicle applications than for long-haul applications. In
some cases, suppliers offer up to 17 different vocational tire
designs, and for each design there may be 8-10 different tire sizes.
In contrast, a line-haul application may have only 2-3 tire designs
with a fewer range of sizes.
---------------------------------------------------------------------------
The agencies also discussed with tire suppliers the potential tire
attribute tradeoffs that may be associated with incorporating designs
that improve tire rolling resistance, given the driving patterns,
environmental conditions, and on-road and off-road surface conditions
that vocational vehicles are subjected to. Some vehicle manufacturer
commenters had suggested that changes in tire tread block design that
improve rolling resistance may adversely affect tire performance
characteristics such as traction, resistance to tearing, and resistance
to wear and damage from scrubbing on curbs and frequent tight radius
turns that are important to customers for vocational vehicle
performance. The suppliers agreed that providing tires unable to
withstand these conditions or meet the vehicle application needs would
adversely affect customer satisfaction and warranty expenses, and would
have detrimental financial effects to their businesses. One supplier
indicated that theoretically, tread-wear (tire life) could be
compromised if suppliers choose to reduce the initial tire tread depth
without any offsetting tire compound or design enhancements as the
means to achieve rolling resistance reductions. That supplier argued
that taking this approach could lead to more frequent tire replacements
or re-treading of existing tire carcasses, and that the agencies should
therefore take a total lifecycle view when evaluating the effects of
driving rolling resistance reductions. That supplier also indicated
that a correlation of a 20 percent reduction in rolling resistance
achieved through tread depth reduction could lead to a 30 percent
decrease in tread-life and 15 percent reduction in wet traction. The
agencies note that when they inquired about potential `safety' related
tradeoffs, such as traction (braking and handling) and tread wear when
applying low rolling resistance technologies, tire suppliers which
remain subject to safety standards regardless of this program,
consistently responded that they would not produce a tire that
compromises safety when fitted in its proper application.
In addition to the supplier discussions and evaluation of comments
to the Notice of Proposed Rulemaking, EPA conducted a series of tire
rolling resistance tests on medium- and heavy-duty vocational vehicle
tires. The testing measured the CRR of tires representing 16 different
vehicle applications for Class 4-8 vocational vehicles. The testing
included approximately 5 samples each of both steer and drive tires for
each application. The tests were conducted by two independent tire test
labs, Standards Testing Lab (STL) and Smithers-Rapra (Smithers).
Overall, a total of 156 medium- and heavy-duty tires\128\ were
included in this testing, which was comprised of 88 tires covering
various commercial vocational vehicle types, such as bucket trucks,
school buses, city delivery vehicles, city transit buses and refuse
haulers among others; 47 tires intended for application to tractors;
and 21 tires classified as light-truck (LT) tires intended for Class 4
vocational vehicles such as delivery vans. In addition, approximately
20 of the tires tested were exchanged between the labs to assess inter-
laboratory variability.
---------------------------------------------------------------------------
\128\ After the agencies completed their analysis of these data,
the agencies received raw data on 43 additional tires. See Powell,
Greg. Memorandum to the Docket. Additional Tire Testing Results.
July 2011. Docket NHTSA-2010-0079. The agencies have not analyzed
these additional data, nor included them in the final report, and
the data therefore played no role in the agencies' determination of
an appropriate standard for vocational vehicles. The agencies will
analyze and consider these data, along with any future data received
through continued testing, as appropriate, in the next rulemaking
for the heavy duty sector.
---------------------------------------------------------------------------
The test results for 88 commercial vocational vehicle tires (19.5''
and 22.5'' sizes) showed a test average CRR of 7.4 kg/metric ton, with
results ranging from 5.1 to 9.8. To comply with the proposed vocational
vehicle fuel consumption and GHG emissions standards using improved
tire rolling resistance as the compliance strategy, a manufacturer
would need to achieve an average tire CRR value of 8.1 kg/metric
ton.\129\ The measured average CRR of 7.4kg/metric ton is thus better
than the average value that would be needed to meet vocational vehicle
standards. Of those 173 tires tested, twenty tires had CRR values
exceeding 8.1 kg/metric ton, two were at 8.1 kg/metric ton, and sixty-
six tires were better than 8.1 kg/metric ton. Additional data analyses
examining the tire data by tire size to determine the range and
distribution of CRR values within each tire size showed each tire size
generally had tires ranging from approximately 6.0 to 8.5 kg/metric
ton, with a small number of tires in the 5.3-5.7 kg/metric ton range
and a small
[[Page 57173]]
number of tires in a range as high as 9.3-9.8 kg/ton. Review of the
data showed that for each tire size and vehicle type, the majority of
tires tested would enable compliance with vocational vehicle fuel
consumption and GHG emission standards.
---------------------------------------------------------------------------
\129\ See 75 FR at 74244.
---------------------------------------------------------------------------
The test results for the 47 tires intended for tractor application
showed an overall average of 6.9 kg/ton, the lowest overall average
rolling resistance of the different tire applications tested.\130\ This
is consistent with what the agencies heard through comments and
meetings with tire suppliers whose efforts have focused on tractor
applications, particularly for long-haul applications, which yield the
highest fuel efficiency benefits from LRR tire technology.
---------------------------------------------------------------------------
\130\ The CRR values for these applications ranged from 5.4 to
9.2 kg/metric ton.
---------------------------------------------------------------------------
Finally, the 21 LT tires intended for Class 4 vocational vehicles
were comprised of two sizes; LT225/75R16 and LT245/75R16 with 11 and 10
samples tested, respectively. Some auto manufacturers have indicated
that CRR values for tires fitted to these Class 4 vehicles typically
have a higher CRR values than tires found on commercial vocational
vehicles because of the smaller diameter wheel size and the ISO testing
protocol.\131\ The test data showed the average CRR for LT225/75R16
tires was 9.1 kg/metric ton and the average for LT245/75R16 tires was
8.6 kg/metric ton. The range for the LT225/75R16 tires spanned 7.4 to
11.0 \132\ and the range for the LT245/75R16 tires ranged from 6.6 to
9.8 kg/metric ton. Overall, the average for the tested LT tires was 8.9
kg/metric ton.
---------------------------------------------------------------------------
\131\ See comments to docket EPA-HQ-OAR-2010-0162-1761; Ford
Motor Company
\132\ The agency notes the highest CRR values recorded for LT
tires, of 11.0 and 10.9, were for two tires of the same size and
brand. The nearest recorded values to these two tires were 9.8;
substantially beyond the differences between other tires tested.
---------------------------------------------------------------------------
Analysis of the EPA test data for all vocational vehicles,
including LT tires, shows the test average CRR is 7.7 kg/metric ton
with a standard deviation of 1.2 kg/metric ton. Review of the data thus
shows that for each tire size and vehicle type, there are many tires
available that would enable compliance with the proposed standards for
vocational vehicles and tractors except for LT tires for Class 4
vocational vehicles where test results show the majority of these tires
have CRR worse than 8.1 kg/metric ton.
The agencies also reviewed the CRR data from the tires that were
tested at both the STL and Smithers laboratories to assess inter-
laboratory and test machine variability. The agencies conducted
statistical analysis of the data to gain better understanding of lab-
to-lab correlation and developed an adjustment factor for data measured
at each of the test labs. When applied, this correction factor showed
that for 77 of the 80 tires tested, the difference between the original
CRR and a value corrected CRR was 0.01 kg/metric ton. The values for
the remaining three tires were 0.03 kg/metric ton, 0.05 kg/metric ton
and 0.07 kg/metric ton. Based on these results, the agencies believe
the lab-to-lab variation for the STL and Smithers laboratories would
have very small effect on measured CRR values. Further, in analyzing
the data, the agencies considered both measurement variability and the
value of the measurements relative to proposed standards. The agencies
concluded that although laboratory-to-laboratory and test machine-to-
test machine measurement variability exists, the level observed is not
excessive relative to the distribution of absolute measured CRR
performance values and relative to the proposed standards. Based on
this, the agencies concluded that the test protocol is reasonable for
this program, but are making some revisions to the vehicle standards.
The agencies also conducted a winter traction test of 28 tires to
evaluate the impact of low rolling resistance designs on winter
traction. The results of the study indicate that there was no
statistical relationship between rolling resistance and snow
traction.\133\
---------------------------------------------------------------------------
\133\ Bachman, Joseph. Memorandum to Docket. Heavy-Duty Tire
Evaluation. Docket EPA-HQ-OAR-2010-0162. Pages 3-6.
---------------------------------------------------------------------------
(iii) Summary of Final Rules
For vocational vehicles, the agencies intend to keep rolling
resistance as an input to the GEM but with modifications to the
proposed targets as a result of the testing completed by EPA since the
NPRM and information from tire suppliers. The agencies continue to
believe that LRR tires, which are an available, cost-effective, and
appropriate technology with demonstrated fuel efficiency and GHG
reduction benefits, are reasonable for all on-highway vehicles.
The agencies acknowledge there can be tradeoffs when designing a
tire for reduced rolling resistance. These tradeoffs can include
characteristics such as wear resistance, cost and scuff resistance.
However, the agencies have continued to review this issue and do not
believe that LRR tires as specified in the rules present safety issues.
The agencies continue to believe that LRR tires, which are an
available, cost-effective, and appropriate technology with demonstrated
fuel efficiency and GHG reduction benefits, are reasonable for all on-
highway vehicles. The final program also provides exemptions for
vehicles meeting ``low-speed'' or ``off-road'' criteria, including
application of speed restricted tires. Vocational vehicles that have
speed restricted tires in order to accommodate particular applications
may be exempted from the program under the off-road or low-speed
exemption, described in greater detail below in Section
II.D.(1)(a)(iv).
As just noted, the agencies conducted independent testing of
current tires available to assist confirming the finalized rolling
resistance standards. The tire test samples were selected from those
currently available on the market and therefore have no known safety
issues and meet all current requirements to allow availability in
commerce; including wear, scuff resistance, braking, traction under wet
or icy conditions, and other requirements. These tires included a wide
array of sizes and designs intended for most all vocational
applications, including those used for school buses, refuse haulers,
emergency vehicles, concrete mixers, and recreational vehicles. As the
test results revealed, there are a significant number of tires
available that meet or do better than the rolling resistance targets
for vocational vehicles; both light-truck (with an adjustment factor
described later in this preamble section) and non-LT tire types, while
meeting all applicable safety standards.
The agencies also recognize the extreme conditions fire apparatus
equipment must navigate to enable firefighters to perform their duties.
As described below, the final rules contain provisions to allow for
exemption of specific off-road capable vocational vehicles from the
fuel efficiency and greenhouse gas standards. Included in the exemption
criteria are provisions for vehicles equipped with specific tire types
that would be fit to a vehicle to meet extreme demands, including those
vehicles designed for off-road capability.
As follow-up to the final rules and in support for development of a
separate FMVSS rule, NHTSA plans to conduct additional performance-
focused testing (beyond rolling resistance) for medium- and heavy-duty
trucks. This testing is targeted for completion toward the end of this
year. The agencies will review these performance data when available,
in concert with any subsequent proposed rulemakings regarding fuel
consumption and GHG emissions
[[Page 57174]]
standards for medium- and heavy-duty vehicles.
For vocational vehicles, the rolling resistance of each tire will
be measured using the ISO 28850 test method for drive tires and steer
tires planned for fitment to the vehicle being certified. Once the test
CRR values are obtained, a manufacturer will input the CRR values for
the drive and steer tires separately into the GEM where, for vocational
vehicles, the vehicle load is distributed equally over the steer and
drive tires. Once entered, the amount of GHG reduction attributed to
tire rolling resistance will be incorporated into the overall vehicle
compliance value. The following table provides the revised target CRR
values for vocational vehicles for 2014 and 2017 model years that are
used to determine the vehicle standards.
Table II-14--Vocational Vehicle--Target CRR Values for GEM Input
------------------------------------------------------------------------
2014 MY 2017 MY
------------------------------------------------------------------------
Tire Rolling Resistance (kg/ 7.7 kg/metric ton. 7.7 kg/metric ton
metric ton).
------------------------------------------------------------------------
These target values are being revised based on the significant
availability of tires for vocational vehicles applications which have
performance better than the originally proposed 8.1 kg/metric ton
target. As just discussed, 63 of the 88 tires tested for vocational
applications had CRR values better than the proposed target. The tires
tested covered fitment to a wide range of vocational vehicle types and
classes; thus agencies believe the original target value of 8.1 kg/
metric ton was possibly too lenient after reviewing the testing data.
Therefore, the agencies believe it is appropriate to reduce the
proposed vehicle standard based on performance of a CRR target value of
7.7 kg/metric ton for non-LT tire type. As discussed previously, this
value is the test average of all vocational tires tested (including LT)
which takes a conservative approach over setting a target based on the
average of only the non-LT vocational tires tested. For LT tires, based
on both the test data and the comments from AAPC and Ford Motor
Company, the agencies recognize the need to provide an adjustment. In
lieu of having two sets of Light Heavy-Duty vocational vehicle
standards, the agencies are finalizing an adjustment factor which
applies to the CRR test results for LT tires. The agencies developed an
adjustment factor dividing the overall vocational test average CRR of
7.7 by the LT vocational average of 8.9. This yields an adjustment
factor of 0.87. For LT vocational vehicle tires, the measured CRR
values will be multiplied by the 0.87 adjustment factor before entering
the values in the GEM for compliance.
Based on the tire rolling resistance inputs noted above, EPA is
finalizing the following CO2 standards for the 2014 model
year for the Class 2b through Class 8 vocational vehicle chassis, as
shown in Table II-15. Similarly, NHTSA is finalizing 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 standard
applies throughout the useful life of the vehicle. The agencies note
that both the baseline performance and standards derived for the final
rules slightly differ from the values derived for the NPRM. The first
difference is due to the change in the target rolling resistance from
8.1 to 7.7 kg/metric ton based on the agencies' test results. Second,
there are minor differences in the fuel consumption and CO2
emissions due to the small modifications made to the GEM, as noted in
RIA Chapter 4. Lastly, the final HHD vocational vehicle standard uses a
revised payload assumption of 15,000 pounds instead of the 38,000
pounds used in the NPRM, as described in Section II.D.3.c.iii. As a
result, the emission standards shown in Table II-15 for vocational
vehicles have changed from the standards published in the NPRM. The
changes for light heavy and medium heavy-duty vehicles are modest. The
change for heavy heavy-duty vocational vehicles is larger, due to the
difference in assumed payload.
As with the 2017 MY standards for Class 7 and 8 tractors, EPA and
NHTSA are adopting more stringent vocational vehicle standards for the
2017 model year which reflect the CO2 emissions reductions
required through the 2017 model year engine standards. See also Section
II.B.2 explaining the same approach for the standards for combination
tractors. As explained in Section 0 below, engine performance is one of
the inputs into the GEM compliance model that has a pre-defined (i.e.
fixed) value established by the agencies, and that input will change in
the 2017 MY to reflect the 2017 MY engine standards. The 2017 MY
vocational vehicle standards are not premised on manufacturers
installing additional vehicle technologies, and a vocational vehicle
that complies with the standards in MY 2016 will also comply in MY 2017
with no vehicle (tire) changes. Thus, although chassis manufacturers
will not be required to make further improvements in the 2017 MY to
meet the standards, the standards will be more stringent to reflect the
engine improvements required in that year. This is because in 2017 MY
GEM vehicle modeling outputs (in grams per ton mile and gallons per
1,000 ton mile) will automatically decrease since engine efficiency
will improve in that year.
Table II-15--Final Class 2b-8 Vocational Vehicle CO2 and Fuel Consumption Standards
----------------------------------------------------------------------------------------------------------------
----------------------------------------------------------------------------------------------------------------
EPA CO2 (gram/ton-mile) Standard Effective 2014 Model Year
----------------------------------------------------------------------------------------------------------------
Light Heavy-Duty Class Medium Heavy-Duty Class Heavy Heavy-Duty Class
2b-5. 6-7. 8
----------------------------------------------------------------------------------------------------------------
CO2 Emissions........................ 388.................... 234.................... 226
----------------------------------------------------------------------------------------------------------------
NHTSA Fuel Consumption (gallon per 1,000 ton-mile) Standard Effective 2016 Model Year \134\
----------------------------------------------------------------------------------------------------------------
Light Heavy-DutyClass Medium Heavy-Duty Class Heavy Heavy-Duty Class
2b-5. 6-7. 8
----------------------------------------------------------------------------------------------------------------
Fuel Consumption..................... 38.1................... 23.0................... 22.2
----------------------------------------------------------------------------------------------------------------
EPA CO2 (gram/ton-mile) Standard Effective 2017 Model Year
----------------------------------------------------------------------------------------------------------------
Light Heavy-Duty Class Medium Heavy-Duty Class Heavy Heavy-Duty Class
2b-5. 6-7. 8
----------------------------------------------------------------------------------------------------------------
CO2 Emissions........................ 373.................... 225.................... 222
----------------------------------------------------------------------------------------------------------------
[[Page 57175]]
NHTSA Fuel Consumption (gallon per ton-mile) Standard Effective 2017 Model Year
----------------------------------------------------------------------------------------------------------------
Light Heavy-Duty Class Medium Heavy-Duty Class Heavy Heavy-Duty Class
2b-5. 6-7. 8
----------------------------------------------------------------------------------------------------------------
Fuel Consumption..................... 36.7................... 22.1................... 21.8
----------------------------------------------------------------------------------------------------------------
(iv) Off-Road and Low-Speed Vocational Vehicle Standards
Some vocational vehicles, because they are primarily designed for
off-road use, may not be good candidates for low rolling resistance
tires. These vehicles may travel on-road for very limited periods of
time, such as in traveling on an urban road, or if they are off-loaded
from another vehicle onto a road and then are driven off-road. The
infrequent and limited exposure to on-road environments makes these
vehicles suitable candidates for providing an exemption from the
CO2 emissions and fuel consumption standards for vocational
vehicles (although the standards for HD engines used in vocational
vehicles would still apply).\135\ The agencies are also targeting other
vehicles that travel at low speeds and that are meant to be used both
on- and off-road. The application of certain technologies to these
vehicles may not provide the same level of benefits as it would for
pure on-road vehicles, and moreover, could even reduce the
functionality of the vehicle. In this case, the agencies want to ensure
that vehicle functionality is maintained to the maximum extent
possible, while avoiding the possibility that achievable benefits are
not realized because of the structure of the regulations. The sections
below explain this issue in more detail as it applies to tractors and
vocational vehicles.
---------------------------------------------------------------------------
\134\ Manufacturers may voluntarily opt-in to the NHTSA fuel
consumption program in 2014 or 2015. Once a manufacturer opts into
the NHTSA program it must stay in the program for all the optional
MYs.
\135\ See 75 FR at 74199.
---------------------------------------------------------------------------
The agencies explained in the NPRM that certain vocational vehicles
have very limited on-road usage, and that although they would be
defined as ``motor vehicles'' per 40 CFR 85.1703, the fact that they
spend the most of their operations off-road might be reason for
excluding them from the vocational vehicle standards. Vocational
vehicles, such as those used on oil fields and construction sites,\136\
experience very little benefit from LRR tires or from any other
technologies to reduce GHG emissions and fuel consumption. The agencies
proposed to allow a narrow range of these de facto off-road vehicles to
be excluded from the proposed vocational vehicle standards if equipped
with special off-road tires having lug type treads. The agencies stated
in the NPRM that on/off road traction is the only tire performance
parameter which trades off with TRR so significantly that tire
manufacturers could be unable to develop tires meeting both a TRR
standard while maintaining or improving the characteristic allowing
them to perform off-road. See generally 75 FR at 74199-200. Therefore,
the agencies proposed to exempt these vehicles from the standards while
requiring them to use certified engines, which would provide fuel
consumption and CO2 emission reductions in all vocational
applications. To ensure that these vehicles were in fact used chiefly
off-road, the agencies proposed requirements that would allow exemption
of a vehicle provided the vehicle and the tires were speed restricted.
As mentioned, the agencies were aware that the majority of off road
trucks primarily use off-road tires and are low speed vehicles as well.
Based upon this understanding, the agencies specifically proposed that
a vehicle must meet the following requirements to qualify for an
exemption from vocational vehicle standards:
---------------------------------------------------------------------------
\136\ Vehicles such as concrete mixers, off-road dump trucks,
backhoes and wheel loaders.
---------------------------------------------------------------------------
Tires which are lug tires or contain a speed rating of
less than or equal to 60 mph; and
A vehicle speed limiter governed to 55 mph.
In response to the NPRM, EMA/TMA, Navistar and Volvo agreed with
the proposal to exclude off-road vocational vehicles from the standards
because these vehicles primarily operate off-road, but requested
broadening the exclusion to cover other types of vocational vehicles.
Several manufacturers (IAFC, FAMA, NTEA, NSWMA, AAPC, RMA, Navistar and
DTNA) requested the exemption of specific vehicle types, such as on/
off-road emergency vehicles, refuse vehicles, low speed transit buses
or school buses, because their usage was viewed as being incompatible
with LRR tires. Navistar opposed the application of the proposed
regulations to school buses, arguing that LRR tires may impact the ride
quality for children in school buses. However, Navistar also
acknowledged that a significant portion of the national fleet of school
buses already utilizes off-road tires designed with lug type tread
patterns (e.g., Kentucky). IAFC, FAMA and NTEA commented that fire
trucks and ambulances should also be exempted due to their part-time
off-road use such as in responding to a wildland fire or hazardous
materials incidents which would require operations on dirt and gravel
roads, fields or other off-road environments. Commenters also contended
that by requiring a 55-mph limitation, the proposed exemption would be
impractical for emergency vehicles due to the need to respond quickly
to life-threatening events. The refuse truck manufacturers and trade
associations, NSWMA and AAPC, commented that the solid waste industry
operates a variety of vocational vehicles that perform solely off-road
at landfills. These comments also requested an exemption for certain
refuse trucks (i.e., roll-off container trucks) that frequently go off-
road at construction sites. Other commenters (FAMA, IAFC and Oshkosh)
opposed compliance with the LRR standard for vocational vehicles for
on/off road mixed service tires with aggressive or lug treads, stating
that up to this point the industry has had very little interest in
improving the LRR aspects of these tires or even to conducting testing
to determine values for the coefficient of rolling resistance.
For the final rules, the agencies have considered the issues raised
by commenters and have decided to adopt different criteria than
proposed for exempting vocational vehicles and vocational tractors that
primarily travel off-road. The agencies believe that the reasons for
proposing the exemption are equally applicable to a wider class of
vocational vehicles operating mostly off-road so that the proposals
were either unsuitable for the industry or too restrictive to capture
all the vehicles intended for the exemption. For example, the NPRM
proposal, by using tire tread patterns and VSLs as the basis for
qualifying vehicles for the exemption, was too restrictive because
other non-lug type tread patterns exist in the market as well as other
technologies which are equally capable of limiting the speed of the
vehicle, as mentioned by Volvo. Therefore, the
[[Page 57176]]
proposed exemption for off-road vocational vehicles will be replaced
with new criteria based on the vehicle application, whether it operates
at low speed and whether the vehicle has speed restricted tires. The
exemption is in part based on existing industry standards established
by NHTSA.\137\ As such, any vocational vehicle including vocational
tractors primarily used off-road or at low speeds must meet the
following criteria to be exempt from GHG and fuel consumption vehicle
standards:
---------------------------------------------------------------------------
\137\ The heavy-duty off-road exemption is based in part on
requirements existing in NHTSA's Federal Motor Vehicle Safety
Standards (FMVSS) Nos. 119 and 121. In FMVSS No. 119, titled ``New
pneumatic tires for motor vehicles with a GVWR of more than 4,538
kilograms (10,000 pounds) and motorcycles,'' speed restricted tires
rated at a speed of 55 mph or less are subjected to lower test drum
speeds in the endurance test to account for their low design speeds
(e.g., off-road tires). The off-road vehicle exemptions adopted for
this heavy-duty program were based on the requirements used in FMVSS
No. 121, ``Air brake systems,'' to identify and exclude vocational
vehicles based upon their inability to meet on-highway stopping
distance requirements.
---------------------------------------------------------------------------
Any vehicle primarily designed to perform work off-road
such as in oil fields, forests, or construction sites and having
permanently or temporarily affixed components designed to work in an
off-road environment (i.e., hazardous material equipment or off-road
drill equipment) or vehicles operating at low speeds making them
unsuitable for normal highway operation; and meeting one or more of the
following criteria:
Any vehicle equipped with an axle that has a gross axle
weight rating (GAWR) of 29,000 pounds; or
Any truck or bus that has a speed attainable in 2 miles of
not more than 33 mph; or
Any truck that has a speed attainable in 2 miles of not
more than 45 mph, an unloaded vehicle weight that is not less than 95
percent of its gross vehicle weight rating (GVWR), and no capacity to
carry occupants other than the driver and operating crew.
The agencies are also adopting in the final rules provisions to
exempt any vocational vehicle that can operate in both on and off-road
environments and has speed restricted tires rated at 55 mph or
below.\138\ The agencies' reasoning in adopting a speed restricted
exemption for tires is that the majority of mixed service tires used
for off-road use was identified as being restricted at 55 mph or
less.\139\ Also, as identified by FMVSS No. 119, speed restricted tires
at a rating of 55 mph or less are incapable of meeting the same on-road
performance standards as conventional tires. The agencies acknowledge
that using a speed restriction criteria could allow certain vehicles to
be exempted inappropriately (i.e., low speed city delivery tractors)
but the agencies believe this is preferable to creating a situation
where a segment of vehicles are precluded from performing their
intended applications. Therefore, the final rules include an exemption
for any mixed service (on and off-road) vocational vehicle equipped
with off-road tires that are speed restricted at 55 mph or less.
---------------------------------------------------------------------------
\138\ See 40 CFR 1037.631.
\139\ Particular tire use was identified during the FMVSS 119
rulemaking and confirmed through subsequent market research. See
``2010 Year Book the Tire and RIM Association Inc.''
---------------------------------------------------------------------------
Manufacturers choosing to exempt vehicles based on the above
criteria will be required to provide a description of how they meet the
qualifications for each vehicle family group in their end-of-the year
and final year reports (see Section V).
A manufacturer having an off-road vehicle failing to meet the
criteria under the agencies' off-road exemptions will be allowed to
submit a petition describing how and why their vehicles should qualify
for exclusion. The process of petitioning for an exemption is explained
in Sec. 1037.631 and Sec. 535.8. For each request, the manufacturer
will be required to describe why it believes an exemption is warranted
and address the following factors which the agencies will consider in
granting its petition:
The agencies provide an exemption based on off-road
capability of the vehicle or if the vehicle is fitted with speed
restricted tires. Which exemption does your vehicle qualify under; and
Are there any comparable tires that exist in the market to
carry out the desired application both on and off road for the subject
vehicle(s) of the petition which have LLR values that would enable
compliance with the standard?
(b) Heavy-Duty Engine Standards for Engines Installed in Vocational
Vehicles
EPA is finalizing GHG standards \140\ and NHTSA is finalizing 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 since emissions and fuel
consumption profiles differ significantly depending on whether the
engine is gasoline or diesel powered. The agencies' analyses, as
discussed briefly below and in more detail later in this preamble and
in the RIA Chapter 2, show that these standards are appropriate and
feasible under each agency's respective statutory authorities.
---------------------------------------------------------------------------
\140\ Specifically, EPA is finalizing CO2,
N2O, and CH4 emissions standards for new
heavy-duty engines over an EPA specified useful life period (See
Section 0 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 below. In
developing the final 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.
EPA's existing criteria pollutant emissions regulations for heavy-
duty highway engines establish four service classes (three for
compression-ignition or diesel engines and one for spark ignition or
gasoline engines) that represent the engine's intended and primary
vehicle application, as shown in Table II-16 (40 CFR 1036.140 and
NHTSA's 49 CFR 535.4). The agencies proposed to use the existing
service classes to define the engine subcategories in this HD GHG
emissions and fuel consumption program. The agencies did not receive
any adverse comments to using this approach. Thus, the agencies are
adopting the four engine subcategories for this final action.
Table II-16--Engine Regulatory Subcategories
------------------------------------------------------------------------
Engine category Intended application
------------------------------------------------------------------------
Light Heavy-duty (LHD) Diesel.......... Class 2b through Class 5 trucks
(8,501 through 19,500 pounds
GVWR).
Medium Heavy-duty (MHD) Diesel......... Class 6 and Class 7 trucks
(19,501 through 33,000 pounds
GVWR).
Heavy Heavy-duty (HHD) Diesel.......... Class 8 trucks (33,001 pounds
and greater GVWR.
Gasoline............................... Incomplete vehicles less than
14,000 pounds GVWR and all
vehicles (complete or
incomplete) greater than
14,000 pounds GVWR.
------------------------------------------------------------------------
(i) Diesel Engine Standards for Engines Installed in Vocational
Vehicles
In the NPRM, the agencies proposed the following CO2 and
fuel consumption standards for HD diesel engines to be
[[Page 57177]]
installed in vocational vehicles, as shown in Table II-17.
Table II-17--Vocational Diesel Engine Standards Over the Heavy-Duty FTP Cycle
----------------------------------------------------------------------------------------------------------------
Light heavy- Medium heavy- Heavy heavy-
Model year Standard duty diesel duty diesel duty diesel
----------------------------------------------------------------------------------------------------------------
2014-2016............................. CO2 Standard (g/bhp-hr). 600 600 567
Voluntary Fuel 5.89 5.89 5.57
Consumption Standard
(gallon/100 bhp-hr).
2017 and Later........................ CO2 Standard (g/bhp-hr). 576 576 555
Fuel Consumption (gallon/ 5.66 5.66 5.45
100 bhp-hr).
----------------------------------------------------------------------------------------------------------------
The agencies explained in the NPRM that the standards were based on
our assessment of the findings of the 2010 NAS report and other
literature sources that there are technologies available to reduce fuel
consumption in all these engines by this level in the final time frame
in a cost-effective manner. Similar to the technology basis for HD
engines used in combination tractors, these technologies include
improved turbochargers, aftertreatment optimization, low temperature
exhaust gas recirculation, and engine friction reductions.
The agencies proposed that the HD diesel engine CO2
standards for vocational vehicles would become effective in MY 2014 for
EPA, with more stringent CO2 standards becoming effective in
MY 2017, while NHTSA's fuel consumption standards would become
effective in MY 2017, which would be both consistent with the EISA
four-year minimum lead-time requirements and harmonized with EPA's
timing for stringency increases. The agencies explained that the three-
year timing, besides being required by EISA, made sense because EPA's
heavy-duty highway engine program for criteria pollutants had begun to
provide new emissions standards for the industry in three year
increments, which had caused the heavy-duty engine and vehicle
manufacturer product plans to fall largely into three year cycles
reflecting this regulatory environment.\141\ To further harmonize with
EPA, NHTSA proposed voluntary fuel consumption standards for HD diesel
engines for vocational vehicles in MYs 2014-2016, allowing
manufacturers to opt into the voluntary standards in any of those model
years.\142\ Manufacturers opting into the program must declare by
statement their intent to comply prior to or at the same time they
submit their first application for a certificate of conformity. A
manufacturer opting into the program would begin tracking credits and
debits beginning in the model year in which they opt in. Both agencies
proposed to allow manufacturers to generate and use credits to achieve
compliance with the HD diesel engine standards for vocational vehicles,
including averaging, banking, and trading (ABT), and deficit carry-
forward.
---------------------------------------------------------------------------
\141\ See generally 75 FR at 74200-201.
\142\ Once a manufacturer opts into the NHTSA program it must
stay in the program for all the optional MYs and remain standardized
with the implementation approach being used to meet the EPA emission
program.
---------------------------------------------------------------------------
The agencies proposed to require HD diesel engine manufacturers to
achieve, on average, a three percent reduction in fuel consumption and
CO2 emissions for the 2014 standards over the baseline MY
2010 performance for the HHD diesel engines, and a five percent
reduction for the LHD and MHD diesel engines. The standards for the LHD
and MHD engine categories were proposed to be set at the same level
because 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 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 in the 2010 model
year, which overall averaged 630 g CO2/bhp-hr (6.19 gal/100
bhp-hr).\143\ Furthermore, the technologies available to reduce fuel
consumption and CO2 emissions from these two categories of
engines are similar. The agencies considered combining these engine
categories into a single category, but decided to maintain these two
separate engine categories with the same standard level to respect the
different useful life periods associated with each category.
---------------------------------------------------------------------------
\143\ Calculated using the conversion 10,180 g CO2/
gallon for diesel fuel.
---------------------------------------------------------------------------
For vocational engines certified on the FTP cycle, the agencies
proposed to require a five percent reduction for HHD engines and nine
percent for LHD and MHD engines. For LHD and MHD engines in 2017 MY,
the nine percent reduction is based on the assumption that valvetrain
friction reduction can be achieved in LHD and MHD engines in addition
to turbo efficiency and accessory (water, oil, and fuel pump)
improvements, improved EGR cooler, and other approaches being used for
HHD engines.
Commenters who discussed the HD diesel engine standards generally
did not differentiate between the standards for engines used in
combination tractors and the engines used in vocational vehicles. As
explained above in Section II.B.2.b, some commenters, such as EMA/TMA,
Cummins, DTNA, and other manufacturers, supported the proposed
standards, as long as the flexibilities proposed in the NPRM were
finalized as proposed. Volvo argued that the standards are being phased
in too quickly. Environmental groups and NGOs commented that the
standards should be more stringent and reflect the potential for
greater fuel consumption and CO2 emissions reductions
through the use of additional technologies outlined in the 2010 NAS
study.
In response to those comments, the agencies refer back to our
discussion in Section II.B.2.b. The agencies believe that the
additional reductions may be achieved through the increased development
of the technologies evaluated for the 2014 model year standard, but the
agencies' analysis indicates that this type of advanced engine
development will require a longer development time than MY 2014. The
agencies are therefore providing additional lead time to allow for the
introduction of this additional technology, and waiting until 2017 to
increase stringency to levels reflecting application of
turbocompounding. See Chapter 2 of the RIA for more details.
While it made sense to set standards at the same level for LHD and
MHD diesel engines for vocational vehicles, the agencies found that it
did not make sense to set HHD standards at the same level. Based on
manufacturer-submitted
[[Page 57178]]
CO2 data for the non-GHG emissions certification process,
the agencies found that the baseline for HHD diesel engines was much
lower than for LHD/MHD diesel engines--584 g CO2/bhp-hr
(5.74 gal/100 bhp-hr) on average for HHD, compared to 630 g
CO2/bhp-hr (6.19 gal/100 bhp-hr) on average for LHD/
MHD.\144\ In addition to the differences in the baseline performance,
the agencies believe that there may be some technologies available to
reduce fuel consumption and CO2 emissions that may be
appropriate for the HHD diesel engines but not for the LHD/MHD diesel
engines, such as turbocompounding. Therefore, the agencies are setting
a different standard level for HHD diesel engines to be used in
vocational vehicles. Additional discussion on technical feasibility is
included in Section III below and in Chapter 2 of the RIA.
---------------------------------------------------------------------------
\144\ Calculated using the conversion 10,180 g CO2/
gallon for diesel fuel.
---------------------------------------------------------------------------
After consideration of the comments, EPA and NHTSA are adopting as
proposed the CO2 emission standards and fuel consumption
standards for heavy-duty diesel engines installed in vocational
vehicles are presented in Table II-17. Consistent with proposal, the
first set of standards take effect with MY 2014 (mandatory standards
for EPA, voluntary standards for NHTSA), and the second set take effect
with MY 2017 (mandatory for both agencies).
Compliance with the standards for engines installed in vocational
vehicles will be evaluated based on the composite HD FTP cycle. In the
NPRM, the agencies proposed 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 in some steady cruise conditions as
represented on the Heavy-duty FTP. The primary reason the agencies
proposed two separate certification cycles for HD diesel engines--one
for HD diesel engines used in combination tractors and the other for HD
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.\145\
---------------------------------------------------------------------------
\145\ See generally 75 FR at 74201.
---------------------------------------------------------------------------
DTNA, Cummins, EMA/TMA, and Honeywell commented that certain
vocational vehicle applications would achieve greater fuel consumption
and CO2 emissions reductions in-use by using an engine
designed to meet the SET-based standard. They stated that some
vocational vehicles operate at steady-state more frequently than in
transient operation, such as motor coaches, and thus should be able to
have an engine certified on a steady-state cycle to better reflect the
vehicle's real use.
In response, while the agencies recognize the value to
manufacturers of having additional flexibility that allows them to meet
the standards in a way most consistent with how their vehicles and
engines will ultimately be used, we remain concerned about increasing
flexibility in ways that might impair fuel consumption and
CO2 emissions reductions. The agencies are therefore
providing the option in these final rules for some vocational vehicles,
but not others, to have SET certified engines. Heavy heavy-duty
vocational engines will be allowed to be SET certified for vocational
vehicles, since SET certified HHD engines must meet more stringent GHG
and fuel consumption standards than FTP certified engines. We believe
this will provide manufacturers additional flexibility while still
achieving the expected fuel consumption and CO2 emissions
reductions. However, medium heavy-duty vocational engines will not be
allowed to be SET-certified, because medium heavy-duty engines
certified on the FTP must meet a more stringent standard than engines
certified on the SET, and the agencies are not confident that fuel
consumption and CO2 emissions reduction levels would
necessarily be maintained.
As discussed above in Section II.B.2.b, the agencies place
important weight in making our decisions about the cost-effectiveness
of the standards and the availability of lead time on the fact that
engine manufacturers are expected to redesign and upgrade their
products during MYs 2014-2017. The final two-step CO2
emission and fuel consumption standards recognize the opportunity for
technology improvements over the rulemaking time frame, while
reflecting the typical diesel truck manufacturers' and diesel engine
manufacturers' product plan cycles. 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 final GHG and fuel consumption reductions, and to do this
as part of the normal engine redesign process. This is an important
aspect of the final 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.\146\ 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.
---------------------------------------------------------------------------
\146\ See 75 FR at 25467-68.
---------------------------------------------------------------------------
The agencies recognize, however, that the schedule of changes for
the final standards may not be the most cost-effective one for all
manufacturers. For HD diesel engines for use in tractors, the agencies
discussed above in Section II.B.2.b our decision in this final program
to allow an ``OBD phase-in'' option for meeting the standards, based on
comments received from several industry organizations indicating that
aligning technology changes for multiple regulatory requirements would
provide them with greater flexibility. In the context of HD diesel
engines for use in vocational vehicles, Volvo, EMA/TMA, and DDC
specifically requested an ``OBD phase-in'' option in its comments to
the NPRM. DDC argued that bundling design changes where possible can
reduce the burden on industry for complying with regulations, so
aligning the introduction of the OBD, GHG, and fuel consumption
standards could help reduce the resources devoted to validation of new
product designs and certification.
The agencies have the same interest in providing this flexibility
for manufacturers of HD diesel engines for use in vocational vehicles
as in providing it for manufacturers of HD diesel engines for use in
combination tractors, as long as equivalent emissions and fuel savings
are maintained. Thus, in order to provide additional flexibility for
manufacturers looking to align their technology changes with multiple
regulatory requirements, the agencies are finalizing an alternate ``OBD
phase-in'' option for meeting the HD diesel engine standards which
delivers equivalent CO2 emissions and fuel consumption
reductions as the primary standards for the engines built in the 2013
through 2017 model years, as shown in Table II-18.
[[Page 57179]]
Table II-18--Comparison of CO2 reductions for the Engine Standards Under the Alternative OBD Phase-in and
Primary Phase-In
----------------------------------------------------------------------------------------------------------------
HHD FTP LHD/MHD FTP
----------------------------------------------------------------------------------------------------------------
Difference Difference
Primary Optional in lifetime Primary Optional in lifetime
phase-in phase-in CO2 engine phase-in phase-in CO2 engine
standard (g/ standard (g/ emissions standard (g/ standard (g/ emissions
bhp-hr) bhp-hr) (MMT) bhp-hr) bhp-hr) (MMT)
----------------------------------------------------------------------------------------------------------------
Baseline.......................... 584 584 ........... 630 630
2013 MY Engine.................... 584 577 20 630 618 14
2014 MY Engine.................... 567 577 -28 600 618 -22
2015 MY Engine.................... 567 577 -28 600 618 -22
2016 MY Engine.................... 567 555 34 600 576 29
2017 MY Engine.................... 555 555 0 576 576 0
Net Reductions (MMT).............. ........... ........... -3 ........... ........... 0
----------------------------------------------------------------------------------------------------------------
Table II-19 presents the final HD diesel engine CO2
emission and fuel consumption standards under the optional ``OBD phase-
in'' option.
Table II-19--Optional Heavy-Duty Engine Standard Phase-in
----------------------------------------------------------------------------------------------------------------
Light heavy- Medium heavy- Heavy heavy-
Model year Standard duty diesel duty diesel duty diesel
----------------------------------------------------------------------------------------------------------------
2013.................................. CO2 Standard (g/bhp-hr). 618 618 577
Voluntary Fuel 6.07 6.07 5.67
Consumption Standard
(gallon/100 bhp-hr).
2016 and Later........................ CO2 Standard (g/bhp-hr). 576 576 555
Fuel Consumption (gallon/ 5.66 5.66 5.45
100 bhp-hr).
----------------------------------------------------------------------------------------------------------------
In order to ensure equivalent CO2 and fuel consumption
reductions and orderly compliance, and to avoid gaming, the agencies
are requiring that if a manufacturer selects the OBD phase-in option,
it must certify its engines starting in the 2013 model year and
continue using this phase-in through the 2016 model year. Manufacturers
may opt into the OBD phase-in option through the voluntary NHTSA
program, but must opt in in the 2013 model year and continue using this
phase-in through the 2016 model year. Manufacturers that opt in to the
voluntary NHTSA program in 2014 and 2015 will be required to meet the
primary phase-in schedule and may not adopt the OBD phase-in option.
As discussed above in Section II.B.2.b, while the agencies believe
that the HD diesel engine standards are appropriate, cost-effective,
and technologically feasible in the rulemaking time frame, we also
recognize that when regulating a category of engines for the first
time, there will be individual products that may deviate significantly
from the baseline level of performance, whether because of a specific
approach to criteria pollution control, or due to engine calibration
for specific applications or duty cycles. That earlier discussion
described HD diesel engines for use in combination tractors, but the
same supporting information is relevant to the agencies' consideration
of an alternate standard for HD diesel engines installed in vocational
vehicles. In the NPRM, the agencies proposed an optional engine
standard for HD diesel engines installed in vocational vehicles based
on a five percent reduction from the engine's own 2011 model year
baseline level, but requested comment on whether a two percent
reduction would be more appropriate.\147\ The comments received in
response did not directly address engines for vocational vehicles, but
the agencies believe that the information provided by Navistar and
others is equally applicable to HD diesel engines for combination
tractors and for vocational vehicles. Our assessment for the final
standards is that a 2.5 percent reduction is appropriate for LHD and
MHD engines installed in vocational vehicles and 3 percent is
appropriate for HHD engines installed in vocational vehicles given the
technologies available for application to legacy products by model year
2014.\148\ Unlike the majority of engine products in this segment,
engine manufacturers have devoted few resources to developing
technologies for these legacy products reasoning that the investment
would have little value if the engines are to be substantially
redesigned or replaced in the next five years. Hence, although the
technologies we have identified to achieve the proposed five percent
reduction would theoretically work for these legacy products, there is
inadequate lead time for manufacturers to complete the pre-application
development needed to add the technology to these engines by 2014. The
mix of technologies available off the shelf for legacy engines varies
between engine lines within OEMs and varies among OEMs as well. On
average, based on our review of manufacturer development history and
current plans, we project that for the legacy products approximately
half of the defined technologies appropriate for the 2014 standard will
be available and ready for application by 2014 for older legacy engine
designs. Hence, we have concluded that if we limit the reductions to
those improvements which reflect further enhancements of already
installed systems rather than the addition or replacement of
technologies with fully developed new on the shelf components, the
potential improvement for the 2014 model year will be 2.5 percent for
LHD and MHD engines and 3 percent HHD engines.
---------------------------------------------------------------------------
\147\ See 75 FR at 74202.
\148\ To be codified at 40 CFR 1036.620.
---------------------------------------------------------------------------
Just as for HD diesel engines used in combination tractors, the
agencies stress that this option for HD engines used in vocational
vehicles is temporary and
[[Page 57180]]
limited and is being adopted to address diverse manufacturer needs
associated with complying with this first phase of the regulations.
This optional, alternative standard will be available only for the 2014
through 2016 model years, because we believe that manufacturers will
have had ample opportunity to make appropriate changes to bring their
product performance into line with the rest of the industry after that
time. This optional standard will not be available unless and until a
manufacturer has exhausted all available credits and credit
opportunities, and engines under the alternative standard could not
generate credits.
The agencies note that manufacturers choosing to utilize this
option in MYs 2014-2016 will have to make a greater relative
improvement in MY 2017 than the rest of the industry, since they will
be starting from a worse level. For compliance purposes, in MYs 2014-
2016 emissions from engines certified and sold at the alternate level
will be averaged with emissions from engines certified and sold at more
stringent levels to arrive at a weighted average emissions level for
all engines in the subcategory. Again, this option can only be taken if
all other credit opportunities have been exhausted and the manufacturer
still cannot meet the primary standards. If a manufacturer chooses this
option to meet the EPA emission standards in MY 2014-2016, and wants to
opt into the NHTSA fuel consumption program in these same MYs it must
follow the exact path followed under the EPA program utilizing
equivalent fuel consumption standards.
As discussed above in Section II.B.2.b, Volvo argued that
manufacturers could game the standard by establishing an artificially
high 2011 baseline emission level. This could be done, for example, by
certifying an engine with high fuel consumption and GHG emissions that
is either: (1) Not sold in significant quantities; or (2) later altered
to emit fewer GHGs and consume less fuel through service changes. In
order to mitigate this possibility, the agencies are requiring either
that the 2011 model year baseline must be developed by averaging
emissions over all engines in an engine averaging set certified and
sold for that model year so as to prevent a manufacturer from
developing a single high GHG output engine solely for the purpose of
establishing a high baseline or meet additional criteria. The agencies
are allowing manufacturers to combine light heavy-duty and medium
heavy-duty diesel engines into a single averaging set for this
provision because the engines have the same GHG emissions and fuel
consumption standards. If a manufacturer does not certify all engine
families in an averaging set to the alternate standards, then the
tested configuration of the engine certified to the alternate standard
must have the same engine displacement and its rated power within 5
percent of the highest rated power as the baseline engine. In addition,
the tested configurations must have a BSFC equivalent to or better than
all other configurations within the engine family and represent a
configuration that is sold to customers.
(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.\149\ Unlike the heavy-duty diesel engines typical
of this segment which are built for vocational vehicles, these gasoline
engines are developed for heavy-duty pickup trucks and vans primarily,
but are also sold as loose engines to vocational vehicle manufacturers,
for use in vocational vehicles such as some delivery trucks. Some
fleets still prefer gasoline engines over diesel engines. In the past,
this was the case since gasoline stations were more prevalent than
stations that sold diesel fuel. Because they are developed for HD
pickups and vans, the agencies evaluated these engines in parallel with
the heavy-duty pickup truck and van standard development. As in the
pickup truck and van segment, the agencies anticipated that the
manufacturers will have only one engine re-design within the 2014-2018
model years under consideration within the proposal. The agencies
therefore proposed fuel consumption and CO2 emissions
standards for gasoline engines for use in vocational vehicles, which
represent a five percent reduction in CO2 emissions and fuel
consumption 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.
---------------------------------------------------------------------------
\149\ EPA's heavy-duty engine certification database at http://www.epa.gov/otaq/certdata.htm#largeng.
---------------------------------------------------------------------------
In our meetings with all three of the major manufacturers in the HD
pickup and van 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
had concluded for proposal 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 finalizing 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 final fuel
consumption standard and EPA's final 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 (7.43 gal/100 bhp-hr) in 2010 based on non-GHG
certification data provided to EPA by the manufacturers. The agencies
are finalizing 2016 model year standards that require manufacturers to
achieve a five percent reduction in CO2 compared to 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 RIA Chapter 2. As shown in Table II-20, NHTSA is
finalizing as proposed a 7.06 gallon/100 bhp-hr standard for fuel
consumption while EPA is adopting as proposed 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 averaging set to show
compliance with both agencies' standards.
Table II-20--Heavy-Duty Gasoline Engine Standards
------------------------------------------------------------------------
Gasoline
Model year engine
standard
------------------------------------------------------------------------
2016 and Later.................... CO2 Standard (g/bhp- 627
hr).
Fuel Consumption 7.06
(gallon/100 bhp-hr).
------------------------------------------------------------------------
(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
[[Page 57181]]
is finalizing apply to individual vehicles and engines. NHTSA is not
finalizing in-use standards that would apply to the vehicles and
engines in a similar fashion.
EPA proposed 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 results projected in the EPA
certification process to account for measurement variability inherent
in testing done at different laboratories with different engines. The
agency proposed a two percent adjustment factor and requested comments
and additional data during the proposal to assist in developing an
appropriate factor level. The agency received additional data during
the comment period which identified production variability which was
not accounted for at proposal. Details on the development of the final
adjustment factor are included in RIA Chapter 3. Based on the data
received, EPA determined that the adjustment factor in the final rules
should be higher than the proposed level of two percent. EPA is
finalizing a three 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.
We are finalizing regulatory text (in Sec. 1036.150) to allow
engine manufacturers to used assigned deterioration factors (DFs)
without performing their own durability emission tests or engineering
analysis. However, the engines would still be required to meet the
standards in actual use without regard to whether the manufacturer used
the assigned DFs. This allowance is being adopted as an interim
provision applicable only for this initial phase of standards.
Manufacturers will be allowed to use an assigned additive DF of 0.0
g/bhp-hr for CO2 emissions from any conventional engine
(i.e., an engine not including advance or innovative technologies).
Upon request, we could allow the assigned DF for CO2
emissions from engines including advance or innovative technologies,
but only if we determine that it would be consistent with good
engineering judgment. We believe that we have enough information about
in-use CO2 emissions from conventional engines to conclude
that they will not increase as the engines age. However, we lack such
information about the more advanced technologies.
EPA proposed that the useful life for these engines and vehicles
with respect to GHG emissions be set equal to the respective useful
life periods for criteria pollutants. EPA proposed that the existing
engine useful life periods, as included in Table II-21, be broadened to
include CO2 emissions and fuel consumption for both engines
and vocational vehicles. The agency did not receive any adverse
comments with this approach and is finalizing the useful life periods
as proposed (see 40 CFR 1036.108(d) and 1037.105). While NHTSA will 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.
Table II-21--Useful Life Periods
------------------------------------------------------------------------
Years Miles
------------------------------------------------------------------------
Class 2b-5 Vocational Vehicles, Spark 10 110,000
Ignited, and Light Heavy-Duty Diesel
Engines................................
Class 6-7 Vocational Vehicles and Medium 10 185,000
Heavy-Duty Diesel Engines..............
Class 8 Vocational Vehicles and Heavy 10 435,000
Heavy-Duty Diesel Engines..............
------------------------------------------------------------------------
(2) Test Procedures and Related Issues
The agencies are finalizing 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 the 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 package on which the final standard for vocational
vehicles 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 finalizing
separate engine and vehicle-based emission and fuel consumption
standards for vocational vehicles and engines used in those vehicles.
For the vocational vehicles, engine manufacturers are subject to the
engine standards, and chassis manufacturers are required to install
certified engines in their chassis. The chassis manufacturer is subject
to a separate vehicle-based standard that uses the final vehicle
simulation model, the GEM, to evaluate the impact of the tire design to
determine compliance with the vehicle 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 finalizing an approach consistent with the
proposal 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 EPA developed the GEM for the specific purpose
of this rulemaking to evaluate vehicle 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 EPA and
finalized here was designed for the express purpose of vehicle
compliance demonstration and is therefore simpler and less configurable
than similar
[[Page 57182]]
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, including changes made to the
model to address concerns of the peer reviewers and commenters are
included in Chapter 4 of the RIA. An example of the GEM input screen is
shown in Figure II-4.
[GRAPHIC] [TIFF OMITTED] TR15SE11.004
EPA and NHTSA have validated the GEM simulation of vocational
vehicles against a commonly used simulation tool used in industry, GT-
Drive, for each vocational vehicle subcategory. Prior to using GT-Drive
as a comparison tool, the agencies first benchmarked a GT-Drive
simulation of the combination tractor tested at Southwest Research
against the experimental test results from the chassis dynamometer in
the same manner as done for GEM. Then the EPA developed three
vocational vehicle models (LHD, MHD, and HHD) and simulated them using
both GEM and GT-Drive. Overall, the GEM and GT-Drive predicted the fuel
consumption and CO2 emissions for all three vocational
vehicle subcategories with differences of less than 2 percent for the
three test cycles--the California ARB Transient cycle, 55 mph cruise,
and 65 mph cruise cycle.\150\ The final simulation model is described
in greater detail in RIA Chapter 4 and is available for download by
interested parties at (http://www.epa.gov/otaq/).
---------------------------------------------------------------------------
\150\ See RIA Chapter 4, Table 4-8.
---------------------------------------------------------------------------
The agencies are requiring 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. As
explained earlier, low rolling resistance tires are the only technology
on which the agencies' own feasibility analysis for these vehicles is
predicated. The input values for the simulation model will be derived
by the manufacturer from the final tire test procedure described in
this action. The remaining model inputs will be fixed values pre-
defined by the agencies. These are detailed in the RIA Chapter 4,
including the engine fuel consumption map to be used in the simulation.
(b) Tire Rolling Resistance Assessment
In terms of how tire rolling resistance would be measured, the
agencies proposed to require that the tire rolling resistance input to
the GEM be determined using ISO 28580:2009(E), Passenger car, truck and
bus tyres--Methods of measuring rolling resistance--Single point test
and correlation of measurement results.\151\ The agencies stated that
they believed the ISO test method was the most appropriate for this
program because the method is the same one used by the NHTSA tire fuel
efficiency consumer information program,\152\ by European
regulations,\153\ and by the EPA SmartWay program.
---------------------------------------------------------------------------
\151\ See http://www.iso.org/iso/iso_catalogue/catalogue_tc/catalogue_detail.htm?csnumber=44770.
\152\ 75 FR 15893, March 30,2010.
\153\ See http://www.energy.ca.gov/2009publications/CEC-600-2009-010/CEC-600-2009-010-SD-REV.PDF (last accessed May 9, 2011).
---------------------------------------------------------------------------
The NPRM also discussed the potential for tire-to-tire variability
to confound rolling resistance measurement results for LRR tires--that
is, different tires of the same tire model could turn out to have
different rolling resistance measurements when run on
[[Page 57183]]
the same test. NHTSA's research during the development of the light-
duty vehicle tire fuel efficiency consumer information program
identified several sources of variability including test procedures,
test equipment and the tires themselves, but found that all of the
existing test methods had similar levels of and sources of
variability.\154\ The agencies proposed to address production tire-to-
tire variability by specifying that three tire samples within each tire
model be tested three times each, and that the average of the nine
tests would be used as the Rolling Resistance Coefficient (CRR) for the
tire, which would be the basis for the rolling resistance value for
that tire that the manufacturer would enter into the GEM. The agencies
requested comment on this proposed method.\155\
---------------------------------------------------------------------------
\154\ 75 FR 15893, March 30, 2010.
\155\ See generally 75 FR at 74204.
---------------------------------------------------------------------------
The agencies received many comments on the subject of tire rolling
resistance, including suggestions for alternative test procedures and
compliance issues. Regarding whether the agencies should base tire CRR
inputs for the GEM on the use of the ISO 28580 test procedure, the
American Automotive Policy Council (AAPC) argued that the agencies
should instead require the SAE J2452 Coastdown test method for
calculating tire rolling resistance, which the commenter stated was
preferred by OEMs because it simulates the use of tires on actual
vehicles rather than the ISO procedure which tests the tire by itself.
The Rubber Manufacturers Association (RMA) argued, in contrast, that
the agencies should use the SAE J1269 multi-point test, which is
currently the basis for the EPA SmartWay\TM\ CRR baseline values. RMA
also argued that the SAE J1269 multi-point test can be used to
accurately predict truck/bus tire CRR at various loads and inflations,
including at the ISO 28580 load and inflation conditions, and that
therefore the agencies should use the SAE test, or if the agencies want
to use ISO, they should accept results from the SAE test and just
correlate them. Regarding compliance obligations, RMA further argued
that it was not clear how or in what format testing information would
need to be provided in order to be in compliance with the proposed
requirement at Sec. 1037.125(i).
The agencies analyzed many comments on the subject of tire rolling
resistance. One of the primary concerns raised in comments was that the
proposed test protocol and measurement methodology would not adequately
address production tire variability and measurement variability.
Commenters stated that machine-to-machine differences are a significant
source of variation, and this variation would make it difficult for
manufacturers to be confident that the agency would assign the same CRR
to a tire was tested for compliance purposes. Commenters argued that
the ISO 28580 test method is unique in that it specifies a procedure to
correlate results between different test equipment (i.e., different
rolling resistance test machines), but not all aspects of the ISO
procedure have been completely defined. Commenters stated that under
ISO 28580, the lab alignment procedure depends on the specification of
a reference test machine to which all other labs will align their
measurement results. RMA particularly emphasized the need for
establishing a tire testing reference lab for use with ISO 28580,
referencing the European Tyre and Rim Technical Organization (ETRTO)
estimate that CRR values could vary as much as 20 percent absent an
inter-laboratory alignment procedure. RMA stated the agencies should
specify a reference laboratory with the designation proposed in a
supplemental notice that provides public comment. In addition, RMA
commented that the extra burden proposed by the agencies for testing
three tires, three times each is nine times more burdensome than what
is required through the ISO procedure.
Based on the additional tire rolling resistance research conducted
by the agencies, we have decided to use the ISO 28580 test procedure,
as proposed, to measure tire performance for these final rules.
The agencies believe this test procedure provides two advantages
over other test methods. First, the ISO 28580 test method is unique in
that it specifies a procedure to correlate results between different
test equipment (i.e., different tire rolling resistance test machines).
This is important because NHTSA's research conducted for the light-duty
tire fuel efficiency program indicated that machine-to-machine
differences are a source of variation.\156\ In addition, the ISO 28580
test procedure is either used, or proposed to be used, by several
groups including the European Union through Regulation (EC) No 661/2009
\157\and the California Air Resources Board (CARB) through a staff
recommendation for a California regulation,\158\ and the EPA SmartWay
program. Using the ISO 28580 may help reduce burden on manufacturers by
allowing a single test protocol to be used for multiple regulations and
programs. While we recognize that commenters recommended the use of
other test procedures, like SAE J1269, the agencies have determined
there is no established data conversion method from the SAE J1269
vehicle condition for vocational vehicle tires to the ISO 28580 single
point condition at this time, and that given our reasonable preference
for the ISO procedure, it would not be practical to attempt to include
the use of the SAE J1269 procedure as an optional way of determining
CRR values for the GEM inputs.
---------------------------------------------------------------------------
\156\ 75 FR 15893, March 30, 2010.
\157\ See http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:200:0001:0024:EN:PDF (last accessed May
8, 2011).
\158\ See http://www.energy.ca.gov/2009publications/CEC-600-2009-010/CEC-600-2009-010-SD-REV.PDF (last accessed May 9, 2011).
---------------------------------------------------------------------------
The agencies received comments from the Rubber Manufacturers
Association, Michelin, and Bridgestone which identified the need to
develop a reference lab and alignment tires. Because the ISO has not
yet specified a reference lab and machine for the ISO 28580 test
procedure, NHTSA announced in its March 2010 final rule concerning the
light-duty tire fuel efficiency consumer information program that NHTSA
would specify this laboratory for the purposes of implementing that
rule so that tire manufacturers would know the identity of the machine
against which they may correlate their test results. NHTSA has not yet
announced the reference test machine(s) for the tire fuel efficiency
consumer information program. Therefore, for the light-duty tire fuel
efficiency rule, the agencies are postponing the specification of a
procedure for machine-to-machine alignment until a tire reference lab
is established. The agencies anticipate establishing this lab in the
future with intentions for the lab to accommodate the light-duty tire
fuel efficiency program.
Under the ISO 28580 lab alignment procedure, machine alignment is
conducted using batches of alignment tires of two models with defined
differences in rolling resistance that are certified on a reference
test machine. ISO 28580 specifies requirements for these alignment
tires (``Lab Alignment Tires'' or LATs), but exact tire sizes or models
of LATs are not specifically identified in ISO 28580. Because the test
procedure has not been finalized and heavy-duty LATs are not currently
defined, the agencies are postponing the use of these elements of ISO
28580 to
[[Page 57184]]
a future rulemaking. The agencies also note the lab-to-lab comparison
conducted in the most recent EPA tire test program mentioned
previously. The agencies reviewed the CRR data from the tires that were
tested at both the STL and Smithers laboratories to assess inter-
laboratory and machine variability. The agencies conducted statistical
analysis of the data to gain better understanding of lab-to-lab
correlation and developed an adjustment factor for data measured at
each of the test labs. Based on these results, the agencies believe the
lab-to-lab variation for the STL and Smithers laboratories would have
very small effect on measured CRR values. Based on the test data, the
agencies judge that it is reasonable to implement the HD program with
current levels of variability, and to allow the use of either Smithers
or STL laboratories for determining the CRR value in the HD program, or
demonstrate that the test facilities will not bias results low relative
to Smithers or STL laboratories.
RMA also commented that the extra burden proposed by the agencies
for testing three tires, three times each is nine times more burdensome
than what is required through the ISO procedure. Since the proposal,
EPA obtained replicate test data for a number of Class 8 combination
tractor tires from various manufacturers. Some of these were tires
submitted to SmartWay for verification, while some were tires tested by
manufacturers for other purposes. Three tire model samples for 11 tire
models were tested using the ISO 28580 test.\159\ A mean and a standard
deviation were calculated for each set of three replicate measurements
performed on each tire of the 3-tire sample. The coefficient of
variability (COV) of the CRR was calculated by dividing the standard
deviation by the mean. The values of COV ranged from 0 percent (no
measurable variability) to six percent. In addition, during the period
September 2010 and June 2011, EPA contracted with Smithers-Rapra to
select and test for rolling resistance using ISO 28580 for a
representative sample of Class 4-8 vocational vehicle tires. As part of
the test, 10 tires were selected for replicate testing.\160\ Three
replicate tests were conducted for each of the tires, to evaluate test
variability only. The COV of the RRC results ranged from
nearly 0 to 2 percent, with a mean of less than 1 percent. Based on the
results of these two testing programs, the agencies determined that the
impact of production variability is greater than the impact of
measurement variability. Thus, the agencies concluded that the extra
burden of testing a single tire three times was not necessary to obtain
accurate results, but the variability of RRC results due to
manufacturing of the tires is significant to continue to require
testing of three tire samples for each tire model. In summary, we are
allowing manufacturers to determine the rolling resistance coefficient
of the heavy-duty tires by testing three tire samples one time each.
---------------------------------------------------------------------------
\159\ Bachman, Joseph. EPA Memorandum to the Docket. Heavy-Duty
Tire Evaluation. Docket EPA-HQ-OAR-2010-0162. July 2011.
\160\ Bachman, Joseph. EPA Memorandum to the Docket. Heavy-Duty
Tire Evaluation. Docket EPA-HQ-OAR-2010-0162. July 2011.
---------------------------------------------------------------------------
For the final rules, the agencies are also including a warm up
cycle as part of the procedure for bias ply tires to allow these tires
to reach a steady temperature and volume state before ISO 28580
testing. This procedure is similar to a procedure that was developed
for the light-duty tire fuel efficiency consumer information program,
and was adopted from a procedure defined in Federal motor vehicle
safety standard No. 109 (FMVSS No. 109).\161\
---------------------------------------------------------------------------
\161\ See 49 CFR 571.109.
---------------------------------------------------------------------------
Finally, the agencies are including testing and reporting for
`single-wide' or `super-single' type tires. These tires replace the
traditional `dual' wheel tire combination with a single wheel and tire
that is nearly as wide as the dual combination with similar load
capabilities. These tire types were developed as a fuel saving
technology. The tires provide lower rolling resistance along with a
reduction in weight when compared to a typical set of dual wheel tire
combinations; and are one of the technologies included in the EPA
SmartWay\TM\ program. The agencies have learned that there is limited
testing equipment available that is capable of testing single wide
tires; single wide tires require a wider test machine drum than
required for conventional tires. Although the number of machines
available is limited, the agencies believe the equipment is adequate
for the testing and reporting of CRR for this program.
As discussed above, the agencies are taking the approach of using
CRR for the HD fuel efficiency and greenhouse gas program to align with
the measurement methodology already employed or proposed by the EPA
SmartWay program, the European Union Regulation (EC) No 661/2009 \162\
and the California Air Resources Board (CARB) through a staff
recommendation for a California regulation.\163\ In the NPRM, the
agencies proposed to use CRR, but for purposes of developing these
final rules, the agencies also evaluated whether to use CRR or Rolling
Resistance Force (RRF) as the measurement for tire rolling
resistance for the GEM input. The agencies considered RRF
largely because in the NPRM for Passenger Car Tire Fuel Efficiency
(TFE) program, NHTSA had proposed to use RRF. A key
distinction between these two programs, and their associated metrics,
are the differences in how the measurement data are used and who uses
the data. In particular, the HD fuel efficiency and GHG emissions
program is a compliance program using information developed by and for
technical personnel at manufacturers and agencies to determine a
vehicle's compliance with regulations. The TFE program, in contrast, is
a consumer education program intended to inform consumers making
purchase decisions regarding the fuel saving benefits of replacement
passenger car tires. The target audiences are much different for the
two programs which in turn affect how the information will be used. The
agencies believe that RRF may be more intuitive for non-
technical people because tires that are larger and/or that carry higher
loads will generally have numerically higher RRF values than
smaller tires and/or tires that carry lower loads. CRR values generally
follow an opposite trend, where tires that are larger and/or carry
higher loads will generally have numerically lower CRR values than
smaller tires and/or tires that carry lower loads. The agencies believe
this key distinction helps define the type of metrics to be used and
communicated in accordance with their respective purposes.
---------------------------------------------------------------------------
\162\ See Note 157, above.
\163\ See Note 158, above.
---------------------------------------------------------------------------
Additionally, the CRR metric for use in the MD/HD program is not
susceptible to the skew associated with tire diameter. Medium- and
heavy-duty vehicle tires are available in a small fraction of the tire
sizes of the passenger market and, for the most part, are larger tires
than those found on passenger cars. When viewing CRR over a larger
range of sizes, small diameter tires tend to appear as having a lower
performance, which is not necessarily accurate, with the converse
occurring as the diameter increases.
Using the CRR value for determining the rolling resistance also
takes into account the load carrying capability for the tire being
tested, which, intuitively, can lead to some potentially confusing
results. Several vocational vehicle manufacturers argued in their
comments that LRR tires were not available for, e.g., vehicles like
refuse trucks, which tend to use large diameter tires to carry very
heavy loads. Based on the agencies'
[[Page 57185]]
testing, in fact, the measured CRR (as opposed to the RRF)
for refuse trucks were found to be among the best tested. This finding
can be explained by considering that CRR is calculated by dividing the
measured rolling resistance force by the tire's load capacity rating.
Although the tire may have a relatively high rolling resistance force,
the tire load capacity rating is also very high, resulting in an
overall lower (better) CRR value than many other types of tires. The
amount of load tire can carry (test load) contributes to a very low
reported CRR, thus confirming low rolling resistance tires meeting the
standards, as measured by CRR, are available to the industry regardless
of segment or application.
Based on these considerations, the agencies have decided to use the
CRR metric for the HD fuel efficiency and GHG emissions program.
(c) Defined Vehicle Configurations in the GEM
As discussed above, the agencies are finalizing a methodology that
chassis manufacturers will use to quantify the tire rolling resistance
values to be input into the GEM. Moreover, the agencies are defining
the remaining GEM inputs (i.e., specifying them by rule), which differ
by the regulatory subcategory (for reasons described in the RIA Chapter
4). The defined inputs, among others, include the drive cycle,
aerodynamics, vehicle curb weight, payload, engine characteristics, and
drivetrain for each vehicle type.
(i) Metric
Based on NAS's recommendation and feedback from the heavy-duty
truck industry, NHTSA and EPA proposed 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 vehicles 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. The agencies received comments that a
payload-based metric is not appropriate for all types of vocational
vehicles, specifically buses. The agencies recognize that a payload-
based approach may not be the most representative of an individual
vocational application; however, it best represents the broad
vocational category. The metric which we proposed treats all vocational
applications equally and requires the same technologies be applied to
meet the standard. Thus, the agencies are adopting the proposed metric,
but will revisit the issue of metrics in any future action, if
required, depending on the breadth of each standard.
(ii) Drive cycle
The drive cycles proposed for the vocational vehicles consisted of
the same three modes used for the Class 7 and 8 combination tractors.
The proposed cycle included 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. The agencies proposed different
weightings for each mode for vocational vehicles than those proposed
for Class 7 and 8 combination tractors, given the known difference in
driving patterns between these two categories of vehicles. The same
reasoning underlies the agencies' use of 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 for proposal two sources
for mode weightings, as detailed in RIA Chapter 3. The agencies
proposed 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.\164\ The proposed weighted CO2 and
fuel consumption value consisted of 37 percent of 65 mph Cruise, 21
percent of 55 mph Cruise, and 42 percent of Transient performance.
---------------------------------------------------------------------------
\164\ 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.
---------------------------------------------------------------------------
The agencies received comments stating that the proposed drive
cycles and weightings are not representative of individual vocational
applications, such as buses and refuse haulers. A number of groups
commented that the vocational vehicle cycle is not representative of
real world driving and recommended changes to address that concern.
Several organizations proposed the addition of new drive cycles to make
the test more representative.
Bendix suggested using the Composite International Truck Local and
Commuter Cycle (CILCC) as the general purpose mixed urban/freeway
cycles and to use four representative cycles: mixed urban, freeway,
city bus, refuse, and utility. Bendix suggested using the Standardized
On-Road Test (SORT) cycles for vocational vehicles operating in the
urban environment in addition to SORT cycles for 3 different
vocations--with separate weightings. They stated that SORT with an
average speed of 11.2 mph, lines up most closely with the average of
transit bus duty cycles at 9.9 mph as well as the overall U.S. National
average of 12.6 mph. As alternative approaches they suggested adopting
the Orange County duty cycle for the urban transit bus vocation, or
creating an Urban Transit Bus cycle with several possible weighting
factors--all with very high percentage transient (90% to 100%), very
low 55 mph (0% to 7%), very low 65 mph (0% to 3%), and an average speed
of 15 to 17 mph. Bendix supported their assertions about urban bus
vehicle speed with data from the 2010 American Public Transportation
Association (APTA) `Fact Book' and other sources. In contrast, Bendix
stated, the GEM cycle average speed is currently 32.6 mph. Such high
speeds at steady state will penalize technologies such as
hybridization.
Clean Air Task Force said the agencies have not adequately
addressed the diversity of the vocational vehicle fleet since they are
not distinguished by different duty cycles. They urged the agencies to
sub-divide vocational vehicles by expected use, with separate test
cycles for each sub-group in order to capture the full potential
benefits of hybridization and other advanced technologies in a
meaningful and accurate way in future rulemakings for MY2019 and later
trucks.
Two groups cautioned that unintended consequences could result from
the lack of diversity in duty cycles. DTNA said that the single drive
cycle proposed for all vehicles by the agencies would likely lead to
unintended consequences--such as customers being driven for regulatory
reasons to purchase a transmission that does not suit their actual
operation. Similarly, Volvo said medium- and heavy-duty vehicles are
uniquely built for specific applications but it will not be feasible to
develop regulatory protocols that can accurately predict efficiency in
each application duty cycle. This trade-off could result in unintended
or negative consequences in parts of the market.
Several commenters suggested changing the weightings of the cycle
to more accurately reflect real world driving. Allison stated that the
vocational vehicle cycle includes too much steady state driving time.
They suggested (with supporting data from
[[Page 57186]]
the Oakridge National Laboratory analysis) reducing steady state
driving at 60 mph to minimal or no time on the cycle to address this
problem. Allison commented that GEM contains lengthy accelerations to
reach 55 and 65 miles per hour--much longer than is required in real
world driving. They supported this statement with data from a testing
program conducted at Oakridge National Laboratory showing medium- and
heavy-duty vehicles accelerate more rapidly than in the GEM drive
cycle. According to Allison, this long acceleration time in the GEM,
coupled with too much steady state operation with very little
variation, is not representative of vocational vehicle operation. In
addition, Allison said that the GEM does not adequately account for
shift time, clutch profile, turbo lag, and other impacts on both steady
state and transient operation. The impact, they state, is that the
cycle will hinder proper deployment of technologies to reduce fuel
consumption and GHG emissions.
BAE focused their comments on urban transit bus operation. They
stated the weighting factors for steady state operation are
inconsistent with urban transit bus cycles.
Other commenters suggested the agencies develop chassis dynamometer
tests based on the engine (FTP) test. Cummins said that chassis
dynamometer testing should allow the use of average vehicle
characteristics to determine road load and make use of the vehicle FTP
and SET cycles. Others commented that the correlation between the FTP
and the UDDS is poor.
After careful consideration of the comments, the agencies are
adopting the proposed drive cycles. The final drive cycles and
weightings represent the straight truck operations which dominate the
vehicle miles travelled by vocational vehicles. The agencies do not
believe that application-specific drive cycles are required for this
final action because the program is based on the generally-applicable
use of low rolling resistance tires. The drive cycles that we are
adopting treat all vocational applications equally predicate standard
stringency on use of the same technology (LRR tires) to meet the
standard. The drive cycles in the final rule accurately reflect the
performance of this technology. The agencies are also finalizing, as
proposed, 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.\165\ Similar to the issue of
metrics discussed above, the agencies may revisit drive cycles and
weightings in any future regulatory action to develop standards
specific to applications.
---------------------------------------------------------------------------
\165\ 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 proposed to specify each of
these aspects of the vehicle. The agencies developed the proposed
vehicle curb weight inputs based on industry information developed by
ICF.\166\ The proposed curb weights were 10,300 pounds for the LHD
trucks, 13,950 pounds for the MHD trucks, and 29,000 pounds for the HHD
trucks.
---------------------------------------------------------------------------
\166\ 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 proposed payload requirements for each regulatory
category developed from Federal Highway statistics based on averaging
the payloads for the weight categories represented within each vehicle
subcategory.\167\ The proposed payloads were 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.
---------------------------------------------------------------------------
\167\ 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.
---------------------------------------------------------------------------
The agencies received comments from several stakeholders regarding
the proposed curb weights and payloads for vocational vehicles. BAE
said a Class 8 transit bus has a typical curb weight of 27,000 pounds
and maximum payload of 15,000 pounds. Daimler commented that Class 8
buses have a GVWR of 42,000 pounds. Autocar said that Class 8 refuse
trucks typically have a curb weight of 31,000 to 33,000 pounds, typical
average payload of 10,000 pounds, and typical maximum payload of 20,000
pounds.
Upon further consideration, the agencies are reducing the assigned
weight of heavy heavy-duty vocational vehicles. While we still believe
the proposed values are appropriate for some vocational vehicles, we
reduced the total weight to bring it closer to some of the lighter
vocational vehicles. The agencies are adopting final curb weights of
10,300 pounds for the LHD trucks, 13,950 pounds for the MHD trucks, and
27,000 pounds for the HHD trucks. The agencies are also adopting
payloads of 5,700 pounds for the Light Heavy-Duty trucks, 11,200 pounds
for Medium Heavy-Duty trucks, and 15,000 pounds for Heavy Heavy-Duty
trucks. Additional information is available in RIA Chapter 3.
(iv) Engine
As the agencies are finalizing separate engine and vehicle
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 adopting the proposed approach of using fixed values that
are predefined 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 vehicle that uses an
engine with emissions and fuel consumption better than the standards
would require fewer vehicle reductions than those being finalized. As
proposed, the agencies are using diesel engine characteristics in the
GEM, as most representative of the largest fraction of engines in this
market. The agencies did not receive any adverse comments to using this
approach.
The agencies are finalizing 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 final MY 2017 standard).
The agencies have modified the 2017 MY heavy heavy-duty diesel fuel map
used in the GEM for the final rulemaking to address comments received.
Details regarding this change can be found in RIA Chapter 4.4.4.
Effectively there is no change in stringency of the vocational vehicle
standard (not including the engine) between the 2014 MY and 2017 MY
standards for the full rulemaking period. These inputs are reasonable
(indeed, seemingly necessitated) given the separate final regulatory
requirement that vocational vehicle chassis manufacturers use only
certified engines.
[[Page 57187]]
(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 specifying the
engine's fuel consumption map, drive cycle, and payload; therefore, it
makes sense to specify the drivetrain that matches.
(d) Engine Metrics and Test Procedures
EPA proposed that the GHG emission standards for heavy-duty engines
under the CAA would be expressed as g/bhp-hr while NHTSA's proposed
fuel consumption standards under EISA, in turn, be represented as gal/
100 bhp-hr. 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.\168\ An analogous
metric for engines is the amount of fuel consumed per unit of work. The
g/bhp-hr metric is also consistent with EPA's current standards for
non-GHG emissions for these engines. The agencies did not receive any
adverse comments related to the metrics for HD engines; therefore, we
are adopting the metrics as proposed.
---------------------------------------------------------------------------
\168\ See NAS Report, Note 21, at page 39.
---------------------------------------------------------------------------
With regard to GHG and fuel consumption control, the agencies
believe it is 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. EPA's criteria pollutant standards for
engines currently require that manufacturers demonstrate compliance
over the transient Heavy-duty 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. We are not concerned if
manufacturers further calibrate these engines off cycle 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.
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 and fuel consumption benefits. We are finalizing
standards based on the composite Heavy-duty FTP cycle for engines used
in vocational vehicles reflecting these vehicles' primary use in
transient operating conditions typified by frequent accelerations and
decelerations as well as some steady cruise conditions as represented
on the Heavy-duty FTP. The primary reason the agencies are finalizing
two separate diesel engine standards--one for diesel engines used in
tractors and the other for diesel engines used in vocational vehicles--
is to encourage engine manufacturers to install engine technologies
appropriate to the intended use of the engine with the vehicle. 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 proposed not to include these emissions from
the calculation of the compliance levels over the defined test
procedures. Cummins and Daimler supported and stated sufficient
incentives already exist for manufacturers to limit regeneration
frequency. Conversely, Volvo opposed the omission of IRAF requirements
for CO2 emissions because emissions from regeneration can be
a significant portion of the expected improvement and a significant
variable between manufacturers
For the proposal, we considered including regeneration in the
estimate of fuel consumption and GHG emissions and 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 time frame of this program. 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. Therefore, the
agencies are finalizing an approach as proposed which does not include
the regenerative emissions.
(e) Hybrid Powertrain Technology
Although the final 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 finalizing to provide credits for the use of hybrid
powertrain technology as described in Section IV. Under the advanced
technology credit provisions, credits generated by use of hybrid
powertrains could be used to meet any of the heavy-duty standards, and
are not restricted to the averaging set generating the credit, unlike
the other credit provisions in the final rules. The agencies are
finalizing that any credits generated using such advanced technologies
could be applied to any heavy-duty vehicle or engine, and not be
limited to the averaging set generating the credit. Section IV below
also details the final approach to account for the use of a hybrid
powertrain when evaluating compliance with the vehicle standard. In
general, manufacturers can derive the fuel consumption and
CO2 emissions
[[Page 57188]]
reductions based on comparative test results using the final chassis
testing procedures.
(3) Summary of Final Flexibility and Credit Provisions
EPA and NHTSA are finalizing four flexibility provisions
specifically for heavy-duty vocational vehicle 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 FTP test cycle. With the exception of the
advanced technology credits, credits generated under these provisions
can only be used within the same averaging set which generated the
credit (for example, credits generated by HHD vocational vehicles can
only be used by HHD vehicles). EPA is also adopting a temporary
provision whereby N2O emission credits can be used to comply
with the CO2 emissions standard, as described in Section IV
below.
(3) Deferral of Standards for Small Chassis Manufacturing Business and
Small Business Engine Companies
EPA and NHTSA are finalizing an approach 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.\169\ 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,\170\ and
therefore that the exemption will have a negligible impact on the GHG
emissions and fuel consumption improvements from the final standards.
---------------------------------------------------------------------------
\169\ 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.
\170\ 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.\171\ 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 final exemption from the standards
established under this rulemaking would have a negligible impact on the
GHG emissions and fuel consumption reductions otherwise due to the
standards.
---------------------------------------------------------------------------
\171\ 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 are finalizing as proposed 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, as described in Section V below.
E. Other Standards
In addition to finalizing CO2 emission standards for
heavy-duty vehicles and engines, EPA is also finalizing separate
standards for N2O and CH4 emissions.\172\ NHTSA
is not finalizing 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).\173\ EPA is finalizing N2O and CH4
standards which apply to HD pickup trucks and vans as well as to all
heavy-duty engines. EPA is not finalizing 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.
---------------------------------------------------------------------------
\172\ NHTSA's statutory responsibilities relating to reducing
fuel consumption are directly related to reducing CO2
emissions, but not to the control of other GHGs.
\173\ The global warming potentials (GWP) used in this rule are
consistent with the 2007 Intergovernmental Panel on Climate Change
(IPCC) Fourth Assessment Report (AR4). At this time, the 1996 IPCC
Second Assessment Report (SAR) GWP values are used in the official
U.S. greenhouse gas inventory submission to the United Nations
Framework Convention on Climate Change (per the reporting
requirements under that international convention). N2O
has a GWP of 298 and CH4 has a GWP of 25 according to the
2007 IPCC AR4.
---------------------------------------------------------------------------
EPA requested comment on possible alternative CO2
equivalent approaches to provide near-term flexibility for 2012-14 MY
light-duty vehicles. As described below, EPA is finalizing alternative
provisions allowing manufacturers to use CO2 credits, on a
CO2-equivalent (CO2eq) basis, to meet the
N2O and CH4 standards, which is consistent with
many commenters' preferred approach.
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 non-methane 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 final ``cap'' standards. The final standards would primarily
function 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
[[Page 57189]]
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
finalizing the same standards for all of the model years to which the
rules apply.
EPA believes that the final N2O and CH4 cap
standards will 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 finalizing that such an alternative compliance
approach be available to manufacturers to provide certain flexibilities
for different technologies.
EPA requested comments in the NPRM on the approach to regulating
N2O and CH4 emissions including the
appropriateness of ``cap'' standards, the technical bases for the
levels of the final N2O and CH4 standards, the
final test procedures, and the final timing for the standards. In
addition, EPA requested any additional emissions data on N2O
and CH4 from current technology engines. We solicited
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
finalizing 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 finalizing
assigned factors corresponding to no deterioration, as we are
finalizing for CO2, or for that matter to any predetermined
level. In addition to N2O and CH4 standards, this
section also discusses air conditioning-related provisions and EPA
provisions to extend certification requirements to all-electric HD
vehicles and vehicles and engines designed to run on ethanol fuel.
(1) What is EPA's Approach to Controlling N2O?
N2O is a global warming gas with a GWP of 298. It
accounts for about 0.3 percent of the current greenhouse gas emissions
from heavy-duty trucks.\174\
---------------------------------------------------------------------------
\174\ 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 \175\ 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 CO2eq option
discussed in Section II.E.3.
---------------------------------------------------------------------------
\175\ Memorandum ``N2O Data from EPA Heavy-Duty
Testing''.
---------------------------------------------------------------------------
EPA is finalizing an N2O emission standard that we
believe would be met by most current-technology gasoline and diesel
vehicles at essentially no cost to the vehicle, though the agency is
accounting for additional N2O measurement equipment costs.
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 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
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
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.
[[Page 57190]]
(a) Heavy-Duty Pickup Truck and Van N2O Exhaust Emission
Standard
EPA is finalizing the proposed 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
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 N2O standard 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.\176\ Manufacturers typically use design targets for
NOX emission levels at approximately 50 percent 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 adopting a more stringent 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.
---------------------------------------------------------------------------
\176\ 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
final 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 rulemaking.
Overall, we believe that manufacturers of HD pickups and vans (both
gasoline and diesel) would meet the 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 proposed a per engine N2O emissions standard of 0.05
g/bhp-hr for heavy-duty engines, but is finalizing a standard of 0.10
g/bhp-hr based on additional data submitted to the agency which better
represents the full range of current diesel and gasoline engine
performance. The final N2O standard becomes effective in
2014 model year for diesel engines, as proposed. However, EPA is
finalizing N2O standards for gasoline engines that become
effective in 2016 model year to align with the first year of the
CO2 gasoline engine standards. Without this alignment,
manufacturers would not have any flexibility, such as CO2eq
credits, in meeting the N20 cap and therefore would not have
any recourse to comply if an engine's N2O emissions were
above the standard. The standard remains the same over the useful life
of the engine. The N2O emissions would be measured over the
composite 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. The agencies received comments
from industry suggesting that the N2O and CH4
emissions be evaluated over the same test cycle required for
CO2 emissions compliance. In other words, the commenters
wanted to have the N2O emissions measured over the SET for
engines installed in tractors. The agencies are not adopting this
approach for the final action because we do not have sufficient data to
set the appropriate N2O level using the SET. The agencies
are not requiring any additional burden by requiring the measurement to
be conducted over the Heavy-Duty FTP cycle because it is already
required for criteria emissions. Averaging of N2O emissions
between HD engines will 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 was twice the average
N2O level of primarily pre-2010 model year diesel engines as
demonstrated in the ACES Study and in EPA's testing of two additional
engines with selective catalytic reduction aftertreatement
systems.\177\ Manufacturers typically use design targets for
NOX emission levels of about 50 percent 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.
---------------------------------------------------------------------------
\177\ 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).
---------------------------------------------------------------------------
EPA sought comment about deterioration factors for N2O
emissions. See 75 FR 74208. Industry stakeholders recommended that the
agency define a DF of zero. While we believe it is also possible that
N2O emissions will not deteriorate in use, very little data
exist for aged engines and vehicles. Therefore, the value we are
assigning is conservative, specifically additive DF of 0.02 g/bhp-hr.
While the value is conservative, it is small enough to allow compliance
for all engines except those very close to the standards. For engines
too close to the standard to use the assigned DFs, the manufacturers
would need to demonstrate via engineering analysis that deterioration
is less than assigned DF.
EPA sought additional data on the level of the proposed
N2O level of 0.05 g/bhp-hr. See 75 FR 74208. The agency
received additional data of 2010 model year engines from the Engine
Manufacturers Association.\178\ The agencies reanalyzed a new data set,
as shown in Table II-22, to derive the final N2O standard of
0.10 g/bhp-hr with a defined deterioration factor of 0.02 g/bhp-hr.
---------------------------------------------------------------------------
\178\ Engine Manufacturers Association. EMA N2O Email
03--22--2011. See Docket EPA-HQ-OAR-2010-0162.
[[Page 57191]]
Table II-22--N2O Data Analysis
------------------------------------------------------------------------
Composite FTP
Rated power cycle N2O
Engine family (HP) result (g/bhp-
hr)
------------------------------------------------------------------------
EPA Data of 2007 Engine with SCR........ .............. 0.042
EPA Data of 2010 Production Intent .............. 0.037
Engine.................................
A....................................... 450 0.0181
A....................................... 600 0.0151
B....................................... 360 0.0326
C....................................... 380 0.0353
D....................................... 560 0.0433
D....................................... 455 0.0524
E....................................... 600 0.0437
F....................................... 500 0.0782
G....................................... 483 0.1127
H....................................... 385 0.0444
H....................................... 385 0.0301
H....................................... 385 0.0283
J....................................... 380 0.0317
========================================================================
Mean 0.043
2 * Mean 0.09
------------------------------------------------------------------------
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 finalizing a consistent approach for heavy-duty engine
manufacturers which allows them to delay direct measurement of
N2O until the 2015 model year.
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 final program. EPA has
established four separate N2O measurement methods, all of
which are commercially available today. EPA expects that most
manufacturers would use either photo-acoustic measurement equipment for
stand-alone, existing FTIR instrumentation at a cost of $50,000 per
unit or upgrade existing emission measurement systems with NDIR
analyzers for $25,000 per test cell.
Overall, EPA believes that manufacturers of heavy-duty engines,
both gasoline and diesel, would meet the final standard without
implementing any new technologies, and beyond relatively small
facilities costs for any company that still needs to acquire and
install N2O measurement equipment, EPA does not project that
manufacturers would incur significant costs associated with this final
N2O standard.
EPA is not adopting any vehicle-level N2O standards for
heavy-duty vocational vehicles and combination tractors. The
N2O emissions would be controlled through the heavy-duty
engine portion of the program. The only requirement of those vehicle
manufacturers to comply with the N2O requirements is to
install a certified engine.
(2) What is EPA's approach to controlling CH4?
CH4 is greenhouse gas with a GWP of 25. It accounts for
about 0.03 percent of the greenhouse gases from heavy-duty trucks.\179\
---------------------------------------------------------------------------
\179\ Value adapted from ``Inventory of U.S. Greenhouse Gas
Emissions and Sinks: 1990-2007. April 2009.
---------------------------------------------------------------------------
EPA is finalizing 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 final action. 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 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.\180\ However,
CH4 emissions levels in the gasoline and diesel heavy-duty
truck fleet have nevertheless
[[Page 57192]]
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.
---------------------------------------------------------------------------
\180\ 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 on gasoline or diesel equivalent vehicles, natural gas-fueled
vehicles have historically generated 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 final 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 finalizing 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 final standard
will not result in additional testing costs.
(a) Heavy-Duty Pickup Truck and Van CH4 Standard
EPA is finalizing the proposed 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 CO2 standards. Similar to the CO2 standard
approach, the CH4 emission level of a vehicle will be a
composite of the Light-duty FTP and HFET cycles, with the same 55
percent city weighting and 45 percent highway weighting.
The level of the standard is approximately two times the average
heavy-duty gasoline and diesel truck and van levels.\181\ As with
N2O, this standard level recognizes that manufacturers
typically set emissions design targets with a compliance margin of
approximately 50 percent of the standard. Thus, we believe that the
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 will also meet the standard
with a larger compliance margin resulting in no change in today's
CH4 levels.
---------------------------------------------------------------------------
\181\ Memorandum ``CH4 Data from 2010 and 2011 Heavy-
Duty Vehicle Certification Tests''.
---------------------------------------------------------------------------
(b) Heavy-Duty Engine CH4 Exhaust Emission Standard
EPA is adopting a heavy-duty engine CH4 emission
standard of 0.10 g/hp-hr with a defined deterioration factor of 0.02 g/
bhp-hr as measured on the composite Heavy-duty FTP, to apply beginning
in model year 2014 for diesel engines and in 2016 model year for
gasoline engines. EPA is adopting a different CH4 standard
than proposed based on additional data submitted to the agency which
better represents the full range of current diesel and gasoline engine
performance. EPA is adopting CH4 standards for gasoline
engines that become effective in 2016 model year to align with the
first year of the gasoline engine CO2 standards. Without
this alignment, manufacturers would not have any flexibility, such as
CO2eq credits, in meeting the CH4 cap and
therefore would not be able to sell any engine with a CH4
level above the standard. The final 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 program (see 40 CFR 86.007-11).
The level of the final CH4 standard is twice the average
CH4 emissions from gasoline engines from General Motors in
addition to the four diesel engines in the ACES study.\182\ As with
N2O, this final level recognizes that manufacturers
typically set emission design targets at about 50 percent of the
standard. Thus, EPA believes the final 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.
---------------------------------------------------------------------------
\182\ Coordinating Research 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 final standard would not result in additional testing costs.
EPA is not adopting any vehicle-level CH4 standards for
heavy-duty combination tractors or vocational vehicles in this final
action. The CH4 emissions will 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) Use of CO2 Credits
As proposed, if a manufacturer is unable to meet the N2O
or CH4 cap standards, the EPA program will allow the
manufacturer to comply using CO2 credits. In other words, a
manufacturer could offset any N2O or CH4
emissions above the standard by taking steps to further reduce
CO2. A manufacturer choosing this option would convert its
measured N2O and CH4 test results that are 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.\183\ By using the Global Warming Potential of
N2O and CH4, the approach recognizes the inter-
correlation of these compounds in impacting global warming and is
environmentally neutral for demonstrating compliance with the
individual emissions caps. Because fuel conversion manufacturers
certifying under 40 CFR part 85, subpart F do not participate in ABT
programs, EPA is finalizing a compliance option for fuel conversion
manufacturers to comply with the N2O and CH4
standards that is similar to the credit program just described above.
The compliance option will allow conversion manufacturers, on an
individual engine family basis, to convert CO2
overcompliance into CO2 equivalents of N20 and/or
CH4 that can be subtracted from the CH4 and
N20 measured values to demonstrate compliance with
CH4 and/or N20 standards. Other than in the
limited
[[Page 57193]]
case of N2O for model years 2014-16, we have not finalized
similar provisions allowing overcompliance with the N2O or
CH4 standards to serve as a means to generate CO2
credits because the CH4 and N2O standards are cap
standards representing levels that all but the worst vehicles should
already be well below. Allowing credit generation against such cap
standard would provide a windfall credit without any true GHG
reduction.
---------------------------------------------------------------------------
\183\ N2O has a GWP of 298 and CH4 has a
GWP of 25 according to the IPCC AR4.
---------------------------------------------------------------------------
The final 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 with the NHTSA fuel
consumption standard.
(4) Amendment to Light-Duty Vehicle N2O and CH4
Standards
EPA also requested comment on revising a portion of the light-duty
vehicle standards for N2O and CH4. 75 FR at
74211. Specifically, EPA requested comments on two additional options
for manufacturers to comply with N2O and CH4
standards to provide additional near-term flexibility. EPA is
finalizing one of those options, as discussed below.
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 to prevent future emissions increases, and were generally
not expected to result in the application of new technologies or
significant costs for the manufacturers for current vehicle designs.
EPA also finalized an alternative CO2 equivalent standard
option, which manufacturers may choose to use in lieu of complying with
the N2O and CH4 cap standards. The CO2
equivalent standard option allows manufacturers to fold all
N2O and CH4 emissions, on a CO2eq
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).
After the light-duty standards were finalized, manufacturers raised
concerns that for a few of the vehicle models in their existing fleet
they were having difficulty meeting the N2O and/or
CH4 standards, especially in the early years of the program
for a few of the vehicle models in their existing fleet. These
standards could be 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 CO2eq 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.\184\ See 75 FR at 74211. 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. As stated at proposal, EPA believed this posed 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 would not result in significant costs for
existing vehicles. Id. However, EPA expected 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.
---------------------------------------------------------------------------
\184\ 0.030 g/mile CH4 multiplied by a GWP of 25 plus
0.010 g/mile N2O multiplied by a GWP of 298 results in a
combined 3.7 g/mile CO2-equivalent value. Manufacturers
using the default N2O value of 0.10 g/mile prior to MY
2015 in lieu of measuring N2O would fold in the entire
0.010 g/mile on a CO2-equivalent basis, or about 3 g/mile
under the CO2-equivalent option.
---------------------------------------------------------------------------
Because EPA intended for these standards to be caps with little
anticipated near-term impact on manufacturer's current product lines,
EPA requested comment in the heavy-duty vehicle and engine proposal on
two approaches to provide additional flexibilities in the light-duty
vehicle program for meeting the N2O and CH4
standards. 75 FR at 74211. EPA requested 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 CO2 equivalent option including CH4, but
choose to comply separately with the applicable N2O cap
standard.
EPA also requested comments on an alternative approach of allowing
manufacturers to use CO2 credits, on a CO2
equivalent basis, to offset N2O and CH4 emissions
above the applicable standard. This is similar to the approach proposed
and being finalized for heavy-duty vehicles as discussed above in
Section II.E. EPA requested comments on allowing the additional
flexibility in the light-duty program for MYs 2012-2014 to help
manufacturers address any near-term issues that they may have with the
N2O and CH4 standards.
Commenters providing comment on this issue supported additional
flexibility for manufacturers, and manufacturers specifically supported
the heavy-duty vehicle approach of allowing CO2 credits on a
CO2 equivalent basis to be used to meet the CH4
and N2O standards. The Alliance of Automobile Manufacturers
and the American Automotive Policy Council commented that the proposed
heavy-duty approach represented a significant improvement over the
approach adopted for light-duty vehicles. Manufacturers support de-
linking N2O and CH4, and commented that the
formation of the pollutants do not necessarily trend together.
Manufacturers also commented that a deficit against the N2O
or CH4 cap would be required to be covered with
CO2 credits for that model, but the approach does not
``punish'' manufacturers for using a specific technology (which could
provide CO2 benefits, e.g., diesel, CNG, etc.) by requiring
manufacturers to use the CO2-equivalent approach for their
entire fleet. The Natural Gas Vehicle Interests also supported allowing
the use of CO2 credits on a CO2-equivalent basis
for compliance with CH4 standards and urged providing this
type of flexibility on a permanent basis. The Institute for Policy
Integrity also submitted comments supportive of providing additional
flexibility to manufacturers as long as it does not undermine standard
stringency. This commenter was supportive of either approach discussed
at proposal.\185\
---------------------------------------------------------------------------
\185\ The Institute for Policy Integrity questioned whether EPA
had provided adequate notice of the proposal, given that it appeared
in the proposed GHG rules for heavy duty vehicles. EPA provided
notice not only in the preamble, but in the summary of action
appearing on the first page of the Federal Register notice (``EPA is
also requesting comment on possible alternative CO2-
equivalent approaches for model year 2012-14 light-duty vehicles'').
75 FR at 74152. This is ample notice (demonstrated as well by the
comments received on the issue, including from the Institute).
---------------------------------------------------------------------------
Manufacturers supported not only adopting the aspects of the heavy-
duty approach noted above, but the entire
[[Page 57194]]
heavy-duty vehicle approach, including two aspects of the program not
contemplated in EPA's request for comments. First, manufacturers
commented that EPA incorrectly characterizes the light-duty vehicle
issues with CH4 and N2O as short-term or early
lead time issues. For the reasons discussed above, manufacturers
believe the changes should be made permanent, for the entire 2012-2016
light-duty rulemaking period and, indeed, in any subsequent rules for
the light-duty vehicle sector. Second, manufacturers commented that
N2O and CH4 should be measured on the combined
55/45 weighting of the FTP and highway cycles, respectively, as these
cycles are the yardstick for fuel economy and CO2
measurement. Manufacturers commented that there should not be a
disconnect between the light-duty and heavy-duty vehicle programs.
EPA continues to believe that it is appropriate to provide
additional flexibility to manufacturers to meet the N2O and
CH4 standards. EPA is thus finalizing provisions allowing
manufacturers to use CO2 credits, on a CO2-
equivalent basis, to meet the N2O and CH4
standards, which is consistent with many commenters' preferred
approach. Manufacturers will have the option of using CO2
credits to meet N2O and CH4 standards on a test
group basis as needed for MYs 2012-2016. Because fuel conversion
manufacturers certifying under 40 CFR part 85, subpart F do not
participate in ABT programs, EPA is finalizing a compliance option for
fuel conversion manufacturers to comply with the N2O and
CH4 standards similar to the credit option just described
above. The compliance option will allow conversion manufacturers, on an
individual test group basis, to convert CO2 overcompliance
into CO2 equivalents of N2O and/or CH4
that can be subtracted from the CH4 and N2O
measured values to demonstrate compliance with CH4 and/or
N2O standards.
In EPA's request for comments, EPA discussed the new flexibility as
being needed to address lead time issues for MYs 2012-2014. EPA
understands that manufacturers are now making technology decisions for
beyond MY 2014 and that some technologies such as FFVs may have
difficulty meeting the CH4 and N2O standards,
presenting manufacturers with difficult decisions of absorbing the 3-4
g/mile CO2-equivalent emissions fleet wide, making
significant investments in existing vehicle technologies, or curtailing
the use of certain technologies.\186\ The CH4 standard, in
particular, could prove challenging for FFVs because exhaust
temperatures are lower on E-85 and CH4 is more difficult to
convert over the catalyst. EPA's initial estimate that these issues
could be resolved without disrupting product plans by MY 2015 appears
to be overly optimistic, and therefore EPA is extending the flexibility
through model year 2016. This change helps ensure that the
CH4 and N2O standards will not be an obstacle for
the use of FFVs or other technologies in this timeframe, and at the
same time, assure that overall fleet average GHG emissions will remain
at the same level as under the main standards.
---------------------------------------------------------------------------
\186\ ``Discussions with Vehicle Manufacturers Regarding the
Light-duty Vehicle CH4 and N2O Standards,''
Memorandum from Christopher Lieske to Docket EPA-HQ-OAR-2010-0162.
---------------------------------------------------------------------------
In response to comments from manufacturers and from the Natural Gas
Vehicle Interests that the changes to the program make sense and should
be made on a permanent basis (i.e. for model years after 2016), EPA is
extending this flexibility through MY 2016 as discussed above, but we
believe it is premature to decide here whether or not these changes
should be permanent. EPA may consider this issue further in the context
of new standards for MYs 2017-2025 in the planned future light-duty
vehicle rulemaking. With regard to comments on changing the test
procedures over which N2O and CH4 emissions are
measured to determine compliance with the standards, the level of the
standards and the test procedures go hand-in-hand and must be
considered together. Weighting the highway test result with the city
test result in the emissions measurement would in most cases reduce the
overall emissions levels for determining compliance with the standards,
and would thereby, in effect make the standards less stringent. This
appears to be inappropriate. In addition, EPA did not request comments
on changing the level of the N2O and CH4
standards or the test procedures and it is inappropriate to amend the
standards for that reason as well.
(5) EPA's Final 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.\187\ This
includes the direct leakage of refrigerant as well as the subsequent
leakage associated with maintenance and servicing, and with disposal at
the end of the vehicle's life.\188\ The most commonly used refrigerant
in automotive applications--R134a, has a high GWP of 1430.\189\ 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.
---------------------------------------------------------------------------
\187\ The United States has submitted a proposal to the Montreal
Protocol which, if adopted, would phasedown production and
consumption of HFCs.
\188\ The U.S. EPA has reclamation requirements for refrigerants
in place under Title VI of the Clean Air Act.
\189\ The global warming potentials used in this rule are
consistent with the 2007 Intergovernmental Panel on Climate Change
(IPCC) Fourth Assessment Report. At this time, the global warming
potential values from the 1996 IPCC Second Assessment Report are
used in the official U.S. greenhouse gas inventory submission to the
United Nations Framework Convention on Climate Change (per the
reporting requirements under that international convention, which
were last updated in 2006).
---------------------------------------------------------------------------
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 vehicle 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 finalizing the proposed requirement that vehicle
manufacturers 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 finalizing 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
[[Page 57195]]
consequent difficulties in developing a regulatory system.
For air conditioning systems with a refrigerant capacity greater
than 733 grams, EPA is finalizing a leakage standard which is a
``percent refrigerant leakage 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
finalizing a standard of 1.50 percent leakage per year for heavy-duty
pickup trucks and vans and Class 7 and 8 tractors. The final standard
was derived from the vehicles with the largest system refrigerant
capacity based on the Minnesota GHG Reporting database.\190\ The
average percent leakage per year of the 2010 model year vehicles is 2.7
percent. This final 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 recognizes that a single ``percent refrigerant
leakage per year'' is not feasible for systems with a refrigerant
capacity of 733 grams or lower, as the minimum feasible leakage rate
does not continue to drop as the capacity or size of the air
conditioning system is reduced. The fixed leakage from the compressor
seal and other system devices results in a minimum feasible yearly
leakage rate, and further reductions in refrigerant capacity (the
`denominator' in the percent refrigerant leakage calculation) will
result in a system which cannot meet the 1.50 percent leakage per year
standard. EPA does not believe that leakage reducing technologies are
available at this time which would allow lower capacity systems to meet
the percent per year standard, so we are finalizing a maximum gram per
year leakage standard of 11.0 grams per year for air conditioning
systems with a refrigerant capacity of 733 grams or lower. EPA defined
the standard, as well as the refrigerant capacity threshold, by
examining the State of Minnesota GHG Reporting Database for the yearly
leakage rate from 2010 and 2011 model year pickup trucks. In the
Minnesota data, the average leak rate for the pickup truck category (16
unique model and refrigerant capacity combinations) was 13.3 grams per
year, with an average capacity of 654 grams, resulting in an average
percent refrigerant leakage per year of 2.0 percent. 4 of the 16 model/
capacity combinations in the reporting data achieved a leak rate 11.0
grams per year or lower, and this was chosen as the maximum yearly leak
rate, as several manufacturers have demonstrated that this level of
yearly leakage is feasible. To avoid a discontinuity between the
``percent leakage'' and ``leak rate'' standards--where one approach
would be more or less stringent, depending on the refrigerant
capacity--a refrigerant capacity of 733 grams was chosen as a threshold
capacity, below which, the leak rate approach can be used. EPA believes
this approach of having a leak rate standard for lower capacity systems
and a percent leakage per year standard for higher capacity systems
will result in reduced refrigerant emissions from all air conditioning
systems, while still allowing manufacturers the ability to produce low-
leak, lower capacity systems in vehicles which require them.
---------------------------------------------------------------------------
\190\ The Minnesota refrigerant leakage data can be found at
http://www.pca.state.mn.us/climatechange/mobileair.html#leakdata.
---------------------------------------------------------------------------
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-
Global Warming Potential (GWP) refrigerant. One alternative
refrigerant, HFO-1234yf, with a GWP of 4, has been approved for use in
light-duty passenger vehicles under EPA's Significant New Alternatives
Program (SNAP). While the scope of this SNAP approval does not include
heavy-duty highway vehicles, we expect that those interested in using
this refrigerant in other sectors will petition EPA for broader
approval of its use in all mobile air conditioning systems. In
addition, the EPA is currently acting on a petition to de-list R-134a
as an acceptable refrigerant for new, light-duty passenger vehicles.
The time frame and scale of R-134a de-listing is yet to be determined,
but any phase-down of R-134a use will likely take place after this
rulemaking is in effect. Given that HFO-1234yf is yet to be approved
for heavy-duty vehicles, and that the time frame for the de-listing of
R-134a is not known, EPA believes that a leakage standard for heavy-
duty vehicles is still appropriate. If future heavy-duty vehicles adopt
refrigerants other than R-134a, the calculated refrigerant leak rate
can be adjusted by multiplying the leak rate by the ratio of the GWP of
the new refrigerant divided by the GWP of the old refrigerant (e.g. for
HFO-1234yf replacing R-134a, the calculated leak rate would be
multiplied by 0.0028, or 4 divided by 1430).
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.\191\ 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 has recognized some manufacturers
utilize an improved manufacturing process for air conditioning systems,
where a helium leak test is performed on 100 percent of all o-ring
fittings and connections after final assembly. By leak testing each
fitting, the manufacturer or supplier is verifying the o-ring is not
damaged during assembly (which is the primary source of leakage from o-
ring fittings), and when calculating the yearly leak rate for a system,
EPA will allow a relative emission value equivalent to a `seal washer'
can be used in place of the value normally used for an o-ring fitting,
when 100 percent helium leak testing is performed on those fittings.
While further updates to the SAE J2727 standard may be forthcoming (to
address new materials and measurement methods for permeation through
hoses), EPA believes it is appropriate to include the helium leak test
update to the leakage calculation method at this time.
---------------------------------------------------------------------------
\191\ Team 1-Refrigerant Leakage Reduction: Final Report to
Sponsors, SAE, 2007.
---------------------------------------------------------------------------
Consistent with the light-duty 2012-2016 MY vehicle 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. A/C control technology is considered to be on the flat portion of
the learning curve, so costs in the 2017 model year will 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 final rules.
[[Page 57196]]
EPA is requiring that manufacturers demonstrate improvements in
their A/C system designs and components through a design-based method.
The 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 final approach, manufacturers will choose from a menu of A/C
equipment and components used in their vehicles in order to establish
leakage scores, which will 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 rule, EPA is finalizing a
requirement that a manufacturer will 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 final approach will 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 vehicle program, the total A/C leakage score will 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 will result in estimates of likely leakage emissions
reductions that will be comparable to those that would eventually
result from performance-based testing.
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 rule, where we require that manufacturers attest to
the durability of 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
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.
These indirect CO2 emissions are associated with air
conditioner efficiency, since air conditioners create load on the
engine. See 74 FR 49529. However, the agencies are not setting air
conditioning efficiency standards for vocational vehicles, combination
tractors, or heavy-duty pickup trucks and vans. The CO2
emissions due to air conditioning systems in these heavy-duty vehicles
are minimal compared to their overall emissions of CO2. For
example, EPA conducted modeling of a Class 8 sleeper cab using the 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 percent 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.
(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. As we proposed, we are
revising 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
will 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 will remain
optional for all criteria pollutants through the 2015 model year.
Commenters did not oppose this change in EPA regulations.
This change primarily affects 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 will also be
impacted, as they will need to comply with requirements for operation
both on gasoline and ethanol.
The regulatory requirements we are finalizing today for
certification on ethanol follow those already established for methanol,
such as certification to NMHC equivalent standards and waiver of
certain requirements. We 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 will also follow light-duty precedents, primarily
calling on manufacturers to exercise good engineering judgment in
applying the regulatory requirements, but will not be allowed to
generate NOX or PM credits.
This 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 set in connection with this provision. We expect that there will
be strong incentives for any manufacturer seeking to market these
vehicles to also want them to be certified: (1) Uncertified vehicles
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 are not 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 will not be needed; in fact the highly integrated nature of
modern automotive products make the emission control systems essential
to reliable vehicle performance.
[[Page 57197]]
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.
(8) Correction to 40 CFR 1033.625
In a 2008 final rule that set new locomotive and marine engine
standards, EPA adopted a provision allowing manufacturers to use a
limited number of nonroad engines to power switch locomotives provided,
among other things, that ``the engines were certified to standards that
are numerically lower than the applicable locomotive standards of this
part (1033).'' (40 CFR 1033.625(a)). The goal of this provision is to
encourage the replacement of aging, high-emitting switch locomotives
with new switch locomotives having very low emissions of PM,
NOX, and hydrocarbons. However, this provision neglected to
consider the fact that preexisting nonroad engine emission standards
for CO were set at levels that were slightly numerically higher than
those for locomotives. The applicable switch locomotive CO standard of
part 1033 is 3.2 g/kW-hr (2.4 g/hp-hr), while the applicable nonroad
engine CO standard is 3.5 g/kW-hr (2.6 g/hp-hr). This is the case even
for the cleanest final Tier 4 nonroad engines that will phase in
starting in 2014. Thus, nonroad engines cannot be certified to CO
standards that are numerically lower than the applicable locomotive
standards, and the nonroad engine provision is rendered practically
unusable. This matter was brought to EPA's attention by affected engine
manufacturers.\192\
---------------------------------------------------------------------------
\192\ See e-mail correspondence from Timothy A. French, EMA, to
Donald Kopinski and Charles Moulis, U.S. EPA dated 12/8/10,
``Switcher Locomotive Flexibility'', docket EPA-HQ-OAR-
2010-0162.
---------------------------------------------------------------------------
As indicated above, EPA believes that allowing certification of new
switch locomotive engines to nonroad engine standards will greatly
reduce emissions from switch locomotives, and EPA does not believe the
slight difference in CO standards should prevent this environmentally
beneficial program. EPA is therefore adopting a corrective technical
amendment in part 1033. The regulation is being amended at Sec.
1033.625(a)(2) to add the following italicized text: ``The engines were
certified to PM, NOX, and hydrocarbon standards that are
numerically lower than the applicable locomotive standards of this
part.'' This change is a straightforward correction to restore the
intended usability of the provision and is not expected to have adverse
environmental impacts, as nonroad engines have CO emissions that are
typically well below both the nonroad and locomotive emissions
standards.
(9) Corrections to 40 CFR Part 600
EPA adopted changes to fuel economy labeling requirements on July
6, 2011 (76 FR 39478). We are making the following corrections to these
regulations in 40 CFR part 600:
We adopted a requirement to use the specifications of SAE
J1711 for fuel economy testing related to hybrid-electric vehicles. In
this final rule, we are extending that requirement to the calculation
provisions in Sec. 600.114-12. This change was inadvertently omitted
from the earlier final rule.
We are correcting an equation in Sec. 600.116-12.
We are removing text describing label content that differs
from the sample labels that were published with the final rule. The
sample labels properly characterize the intended label content.
(10) Definition of Urban Bus
EPA is adding a new section 86.012-2 to revise the definition of
``urban bus.'' The new definition will treat engines used in urban
buses the same as engines used in any other HD vehicle application,
relying on the definitions of primary intended service class for
defining which standards and useful life apply for bus engines. This
change is necessary to allow for installation of engines other than
HHDDE for hybrid bus applications.
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 final 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 final
standards based on application of technology in light of the attribute
based distinctions and related compliance measurement procedures. We
also discuss the agencies' consideration of standards that are either
more or less stringent than those adopted.
This program 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 in the model years of this program.
The decision on what standard to set is guided by each agency's
statutory 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 final
rulemaking.
CBD submitted several comments on whether NHTSA had met EISA's
mandate to set standards ``designed to achieve the maximum feasible
improvement'' and, to that end, appropriately considered feasible
technologies in setting the stringency level. CBD stated that the
proposed rule had been improperly limited to currently available
technology, and that none of the alternatives contained all of the
available technology, which it argued violated EISA and the CAA. CBD
also stated that the phase-in schedule violated the technology-forcing
intention of EISA, and that the agencies misperceived their statutory
mandates, arguing that the agencies are required to force technological
innovation through aggressive standards.
As demonstrated in the standard-specific discussions later in this
section of the preamble, the standards adopted in the final program are
consistent with section 202(a) of the CAA and section 32902(k)(2) of
EISA. With respect to the EPA rules, we note at the outset, that CBD's
premise that EPA must adopt ``technology-forcing'' standards for heavy-
duty vehicles and engines is wrong. A technology-forcing standard is
one that is to be based on standards which will be available, rather
than technology which is presently available. NRDC v. Thomas, 805 F. 2d
410, 429 (DC Cir. 1986). Clean Air Act provisions requiring ``the
greatest degree of emission reduction achievable through the
application of technology which the Administrator determines will be
available'' are technology-forcing. See e.g., CAA sections
202(a)(3)(1);\193\
[[Page 57198]]
213(a)(3). Section 202(a)(1) standards are technology-based, but not
technology-forcing, requiring EPA to issue standards for a vehicle's
useful life ``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.'' See NACAA v. EPA, 489 F. 3d 1221, 1230 (DC Cir.
2007) upholding EPA's interpretation of similar language in CAA section
231(a) as providing even greater leeway to weigh the statutory factors
than if the provision were technology-forcing. See generally 74 FR at
49464-465 (Sept. 28. 2009); 75 FR at 74171.
---------------------------------------------------------------------------
\193\ CBD cites the District Court's opinion in Cent. Valley
Chrysler-Jeep Inc. v. Goldstene, 529 F. Supp. 2d 1151, 1178 (E.D.
Cal. 2007) for the proposition that standard-setting provisions of
Title II of the CAA are technology forcing, but the court was citing
to the technology-forcing provision section 202(a)(3)(A)(i), which
is not the applicable authority here.
---------------------------------------------------------------------------
Section 202(a)(1) of course allows EPA to consider application of
technologies which will be available as well as those presently
available, id., and EPA exercised that discretion here. For example, as
shown below, the agencies carefully considered application of hybrid
technologies and bottoming cycle technologies for a number of the
standards. Thus, the critical issue is whether EPA's choice of
technology penetration on which the standards are premised is
reasonable considering the statutory factors, the key ones being
technology feasibility, technology availability in the 2014-2018 model
years (i.e., adequacy of lead time), and technology cost and cost-
effectiveness. EPA has considerable discretion to weigh these factors
in a reasonable manner (even for provisions which are explicitly
technology-forcing, see Sierra Club v. EPA, 325 F. 3d 374, 378 (DC Cir.
2003)), and has done so here.
With respect to EISA, 49 U.S.C. section 32902(k)(2) directs NHTSA
to ``determine in a rulemaking proceeding how to implement a commercial
medium- and heavy-duty on-highway vehicle and work truck fuel
efficiency improvement program designed to achieve the maximum feasible
improvement,'' and ``adopt and implement appropriate test methods,
measurement metrics, fuel economy standards, and compliance and
enforcement protocols that are appropriate, cost-effective, and
technologically feasible for commercial medium- and heavy-duty on-
highway vehicles and work trucks'' NHTSA recognizes that Congress
intended EPCA (and by extension, EISA, which amended it) to be
technology-forcing. See Center for Auto Safety v. National Highway
Traffic Safety Admin., 793 F.2d 1322, 1339 (DC Cir. 1986). However,
NHTSA believes it is important to distinguish between setting ``maximum
feasible'' standards, as EPCA/EISA requires, and ``maximum
technologically feasible'' standards, as CBD would have NHTSA do. The
agency must weigh all of the statutory factors in setting fuel
efficiency standards, and therefore may not weigh one statutory factor
in isolation of others.
Neither EPCA nor EISA define ``maximum feasible'' in the context of
setting fuel efficiency or fuel economy standards. Instead, NHTSA is
directed to consider and meet three factors when determining what the
maximum feasible standards are--``appropriateness, cost-effectiveness,
and technological feasibility.'' 32902(k)(2). These factors modify
``feasible'' in the context of the MD/HD rules beyond a plain meaning
of ``capable of being done.'' See Center for Biological Diversity v.
National Highway Traffic Safety Admin., 538 F.3d 1172, 1194 (9th Cir.
2008). With respect to the setting of standards for light-duty
vehicles, EPCA/EISA ``gives NHTSA discretion to decide how to balance
the statutory factors--as long as NHTSA's balancing does not undermine
the fundamental purpose of EPCA: energy conservation.'' Id. at 1195.
Where Congress has not directly spoken to a potential issue related to
such a balancing, NHTSA's interpretation must be a ``reasonable
accommodation of conflicting policies * * * committed to the agency's
care by the statute.'' Id. (discussing consideration of consumer
demand) (internal citations omitted). In the context of the agency's
light-duty vehicle authority, it was determined that Congress delegated
the process for setting the maximum feasible standard to NHTSA with
broad guidelines concerning the factors that the agency must consider.
Id. (internal citations omitted) (emphasis in original). We believe
that the same conclusion should be drawn about the statutory provisions
governing the agency's setting of standards for heavy-duty vehicles.
Those provisions prescribe statutory factors commensurate to, and
equally broad as, those prescribed for light-duty. Thus, NHTSA believes
that it is firmly within our discretion to weigh and balance the
factors laid out in 32902(k) in a way that is technology-forcing, as
evidenced by these standards promulgated in this final action, but not
in a way that requires the application of technology which will not be
available in the lead time provided by the rules, or which is not cost-
effective, or is cost-prohibitive, as CBD evidently deems mandated.
As detailed below for each regulatory category, NHTSA has
considered the appropriateness, cost-effectiveness, and technological
feasibility of the standards in designing a program to achieve the
maximum feasible fuel efficiency improvement. It believes that each of
those criteria is met.
As described in Section I. F. (2) above, the final standards will
remain in effect indefinitely at their 2018 or 2019 levels, unless and
until the standards are revised. CBD maintained that this is a per se
violation of EISA, arguing that, by definition, standards which are not
updated continually and regularly cannot be considered maximum
feasible. NHTSA would like to clarify that the NPRM specified that the
standards would remain indefinitely ``until amended by a future
rulemaking action.'' NPRM at 74172. Further, as noted above, NHTSA has
broad discretion to determine the maximum feasible standards. Unlike
Sec. 32902(b)(3)(B), which applies to automobiles regulated under
light-duty CAFE, Sec. 32902(k) does not specify a maximum number of
years that fuel economy standards for heavy-duty vehicles will be in
place. Consistent with its broad authority to define maximum feasible
standards, NHTSA interprets its authority as including the discretion
to define expiration periods where Congress has not otherwise
specified. This is particularly appropriate for the heavy-duty sector,
where fuel efficiency regulation is unprecedented. NHTSA believes that
it would be unwise to set an expiration period for this first
rulemaking absent both Congressional direction and a known compelling
reason for setting a specific date.
NHTSA believes that the phase-in schedules provide an appropriate
balance between the technology-forcing purpose of the statute and EISA-
mandated considerations of economic practicability. NHTSA recognizes,
as noted in the case above, that balancing each statutory factor in
order to set the maximum feasible standards means that the agency must
engage in a ``reasonable accommodation of conflicting policies.'' See
538 F.3d at 1195, supra. Here, the agency has determined that the
phase-in schedules are one such reasonable accommodation.
Navistar commented generally that the proposed rule was not
technologically feasible, stating that the proposed standards assume
technologies which are not in production for all manufacturers. This is
[[Page 57199]]
not the test for technical feasibility. Under the Clean Air Act, EPA
needs only to outline a technical path toward compliance with a
standard, giving plausible reasons for its belief that technology will
either be developed or applied in the requisite period. NRDC v. EPA,
655 F. 2d 318, 333-34 (DC Cir. 1981). EPA has done so here with respect
to the alternative engine standards of particular concern to
Navistar.\194\ Similarly, NHTSA has previously interpreted
``technological feasibility'' to mean ``whether a particular method of
improving fuel economy can be available for commercial application in
the model year for which a standard is being established.'' 74 FR
14196, 14216. NHTSA has further clarified that the consideration of
technological feasibility ``does not mean that the technology must be
available or in use when a standard is proposed or issued.'' Center for
Auto Safety v. National Highway Traffic Safety Admin., 793 F.2d 1322,
1325 n12 (DC Cir. 1986), quoting 42 FR 63, 184, 63, 188 (1977).
---------------------------------------------------------------------------
\194\ See 40 CFR 1036.620.
---------------------------------------------------------------------------
Consistent with these previous interpretations, NHTSA believes that
a technology does not necessarily need to be currently available or in
use for all regulated parties to be ``technologically feasible'' for
this program, as long as it is reasonable to expect, based on the
evidence before the agency, that the technology will be available in
the model year in which the relevant standard takes effect. The
agencies provide multiple technology pathways for compliance with a
standard, allowing each manufacturer to develop technologies which fit
their current production and research, and the standards are based on
fleet penetration rates of those technologies. As discussed below, it
is reasonable to assume that all the technologies on whose performance
the standards are premised will be available over the period the
standards are in effect.
The Institute for Policy Integrity (IPI) commented that the
agencies should increase the scope and stringency of the final rule to
the point at which net benefits would be maximized, citing Executive
Orders 12866 and 13563. EOs 12866 and 13563 instruct agencies, to the
extent permitted by law, to select, among other things, the regulatory
approaches which maximize net benefits. NHTSA agrees with IPI about the
applicability of these EOs and has made every effort to incorporate
their guidance in drafting this rule.
Though IPI agreed that the proposed rule was cost-benefit
justified, IPI further stated that the agencies must implement an
alternative that provides the maximum net benefits. The agencies
believe that standards that maximized net benefits would be beyond the
point of technological feasibility for this first phase of the HD
National Program. The standards already require the maximum feasible
fuel efficiency improvements for the HD fleet in the 2014-2018 time
frame. Thus, even though, the final standards are highly cost-
effective, and standards that maximized net benefits would likely be
more stringent than those being promulgated in this final action, NHTSA
believes that standards that maximized net benefits would not be
appropriate or technologically feasible in the rulemaking time frame.
The Executive Orders cited by IPI cannot and do not require an agency
to select a regulatory alternative that is inconsistent with its
statutory obligations. Thus, the standards adopted in the final rules
are consistent with the agencies' respective statutory authorities, and
are not established at levels which are infeasible or cost-ineffective.
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 final 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 (a key consideration in the choice of the
five model year duration during which the vehicle standards are phased
in). 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
[[Page 57200]]
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 needed
the lead time required.
As described below, the vast majority of technology on whose
performance the final standards are predicated is commercially
available and already being utilized to a limited extent across the
heavy-duty fleet. Therefore the majority of the emission and fuel
consumption reductions which would result from these final rules would
result from the increased use of these technologies. EPA and NHTSA also
believe that these final rules will 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
consideration of standards which could result in fundamental changes in
the engine or vehicle's performance. Put another way, none of the
technology pathways underlying the final 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 vehicle cost to
technologies which maintain freight utility. Similarly, the agencies'
choice of attributes on which to base the standards, and the metrics
used to measure them, are consciously adopted to preserve the utility
of heavy-duty vehicles and engines.
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 2012-16 MY vehicle 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
light-duty 2012-2016 MY vehicle 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 2009 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 RIA, rather than using the traditional Retail Price
Equivalent (RPE) multiplier approach. For the heavy-duty pickup truck
and van cost projections in this final action, 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 final rulemaking, 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.\195\ 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. The agencies did not receive any adverse comments related
to this methodology.
---------------------------------------------------------------------------
\195\ 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 RIA. In addition, for details on the
ICMs, please refer to the RTI report (See Docket ID EPA-HQ-OAR-2010-
0162-0283). Importantly, the agencies have revised the ICM factors and
the way that indirect costs are calculated using the ICMs. As a result,
the ICM factors are now higher, the indirect costs are higher and,
therefore, technology costs are
[[Page 57201]]
higher. The changes made to the ICMs and the indirect cost calculations
are discussed in Section VIII of this preamble and are detailed in
Chapter 2 of the RIA.
EPA and NHTSA believe that the emissions reductions called for by
the final standards are technologically feasible at reasonable costs
within the lead time provided by the final 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 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 RIA Chapter 2.
A. Class 7-8 Combination Tractor
Class 7 and 8 tractors are used in combination with trailers to
transport freight.\196\ The variation in the design of these tractors
and their typical uses drive different technology solutions for each
regulatory subcategory. The agencies are adopting provisions to treat
vocational tractors as vocational vehicles instead of as combination
tractors, as noted in Section II.B. The focus of this section is on the
feasibility of the standards for combination tractors, not the
vocational tractors.
---------------------------------------------------------------------------
\196\ ``Tractor'' is defined in 49 CFR 571.3 to mean ``a truck
designed primarily for drawing other motor vehicles and not so
constructed as to carry a load other than a part of the weight of
the vehicle and the load so drawn.''
---------------------------------------------------------------------------
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 2010
National Academy of Sciences report of Technologies and Approaches to
Reducing the Fuel Consumption of Medium- and Heavy-Duty Vehicles,\197\
TIAX's assessment of technologies to support the NAS panel report,\198\
EPA's Heavy-duty Lumped Parameter Model,\199\ the analysis conducted by
the Northeast States Center for a Clean Air Future, International
Council on Clean Transportation, Southwest Research Institute and TIAX
for reducing fuel consumption of heavy-duty long haul combination
tractors (the NESCCAF/ICCT study),\200\ and the technology cost
analysis conducted by ICF for EPA.\201\ 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 identified the potential cost of such
technologies. The NAS panel contracted with TIAX to perform an
assessment of technologies which provide potential fuel consumption
reductions in heavy-duty trucks and engines and the technologies'
associated capital costs. 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 of that model to specifically address the
effectiveness and interactions of the final pickup truck and light
heavy-duty engine technologies. The NESCAFF/ICCT study assessed
technologies available in 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.
---------------------------------------------------------------------------
\197\ 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.php?record_id=12845.
\198\ TIAX, LLC. ``Assessment of Fuel Economy Technologies for
Medium- and Heavy-Duty Vehicles,'' Final Report to National Academy
of Sciences, November 19, 2009.
\199\ U.S. EPA. Heavy-duty Lumped Parameter Model.
\200\ NESCCAF, ICCT, Southwest Research Institute, and TIAX.
Reducing Heavy-Duty Long Haul Combination Truck Fuel Consumption and
CO2 Emissions. October 2009.
\201\ 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-2010-0162-0283.
---------------------------------------------------------------------------
(1) What technologies did the agencies consider to reduce the
CO2 emissions and fuel consumption of combination 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 in the final rules are premised on use of
these technologies. The agencies note that SmartWay trucks are
available today which incorporate the technologies on whose performance
the final standards are based. We will also discuss other technologies
that could potentially be used, such as vehicle speed limiters,
although we are not basing the final standards on their use for the
model years covered by this rulemaking, 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 types of
technologies that the agencies considered to improve performance
relative to this baseline, while Section III.A.2 discusses the
technology packages the agencies used to determine the final standard
levels.
(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 so-called classic styling (as described in Section II.B.3.c),
or may be sold with aerodynamic packages. Based on our review of
current truck model configurations and Polk data provided through MJ
Bradley,\202\ we believe the aerodynamic configuration of the baseline
new truck fleet is approximately 25 percent Bin I, 70 percent Bin II,
and 5 percent Bin III (as these bin 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 Bin I
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,\203\ 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. The
agencies received a comment from the ICCT stating that the 0.69 Cd
baseline for high roof sleepers published in the NPRM is higher than
existing studies show. ICCT cited three studies
[[Page 57202]]
including a Society of Automotive Engineering paper showing a lower Cd
for tractor trailers. The agencies based the average Cd for high roof
sleepers on available in use fleet composition data, combined with an
assessment of drag coefficient for different truck configurations. The
agencies are finalizing the 0.69 baseline Cd for high roof sleeper
based on our assessment for the NPRM. However, we will continue to
gather information on the composition of the in-use fleet and may alter
the baseline in a future action, should more data become available that
demonstrates our estimate is incorrect.
---------------------------------------------------------------------------
\202\ MJ Bradley. Heavy-duty Market Analysis. May 2009. Page 10.
\203\ 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.
---------------------------------------------------------------------------
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.\204\ The GEM demonstrates that an aerodynamic improvement of a
Class 8 high roof sleeper cab with a Cd value of 0.60 (which represents
a Bin III tractor) provides a 5 percent reduction in fuel consumption
and CO2 emissions over a truck with a Cd of 0.68.
---------------------------------------------------------------------------
\204\ See TIAX, Note 198, 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 percent 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.\205\ 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.\206\ Low
rolling resistance (LRR) drive tires are currently offered in both dual
assembly and single wide-base configurations. Single wide tires can
offer rolling resistance reduction along with improved aerodynamics and
weight reduction. The GEM demonstrates that replacing baseline tractor
tires with tires which meet the Bin I level provides approximately a 4
percent reduction in fuel consumption and CO2 emissions over
the prescribed test cycle, as shown in RIA Chapter 2, Figure 2-2.
---------------------------------------------------------------------------
\205\ See SmartWay, Note 203, above.
\206\ 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 for proposal,
the agencies considered evaluating vehicle mass reductions on a total
vehicle basis for combination tractors.\207\ The agencies considered
defining a baseline vehicle curb weight and the GEM 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 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 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.
---------------------------------------------------------------------------
\207\ 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 proposed. In the proposal,
we reflected mass reductions for specific technology substitutions
(e.g., installing aluminum wheels instead of steel wheels) where we
could 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 accounted for mass reductions where we
can accurately account for its benefits.
For the final rules, based on evaluation of the comments, the
agencies developed an expanded list of weight reduction opportunities,
from which the sum of the weight reduction from the technologies
installed on a specific tractor can be input into the GEM as listed in
Table II-9 in Section II. The list includes additional components, but
not materials, from those proposed in the NPRM. For high strength
steel, the weight reduction value is equal to 10 percent of the
presumed baseline component weight, as the agencies used a conservative
value based on the DOE report. We recognize that there may be
additional potential for weight reduction in new high strength steel
components which combine the reduction due to the material substitution
along with improvements in redesign, as evidenced by the studies done
for light-duty vehicles. In the development of the high strength steel
component weights, we are only assuming a reduction from material
substitution and no weight reduction from redesign, since we do not
have any data specific to redesign of heavy-duty components nor do we
have a regulatory mechanism to differentiate between material
substitution and improved design. We are finalizing for wheels that
both aluminum and light weight aluminum are eligible to be used as
light-weight materials. Only aluminum and not light weight aluminum can
be used as a light-weight material for other components. The reason for
this is data was available for light weight aluminum for wheels but was
not available for other components.
As explained in Section II.B above, the agencies continue to
believe that the 400 pound weight target is appropriate for setting the
final combination tractor CO2 emissions and fuel consumption
standards. The agencies agree with the commenter that 400 pounds of
weight reduction without the use of single wide tires may not be
achievable for all tractor configurations. The agencies have expanded
the list of weight reduction components which can be input into the GEM
in order to provide the manufacturers with additional means to comply
with the combination tractors and to further encourage reductions in
vehicle weight. The agencies considered increasing the
[[Page 57203]]
target value beyond 400 pounds given the additional reduction potential
identified in the expanded technology list; however, lacking
information on the capacity for the industry to change to these light
weight components across the board by the 2014 model year, we have
decided to maintain the 400 pound target. The agencies intend to
continue to study the potential for additional weight reductions in our
future work considering a second phase of truck fuel efficiency and GHG
regulations.
A weight reduction of 400 pounds 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 in 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, as shown in Figure 2-3 of RIA Chapter 2.
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.\208\ EPA and NHTSA agree
with the TIAX assessment of a 6 percent reduction in overall fuel
consumption reduction.\209\
---------------------------------------------------------------------------
\208\ See the RIA Chapter 2 for details.
\209\ See the 2010 NAS Report, Note 197, 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 (VSL), 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
on a sleeper cab tractor 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.\210\
---------------------------------------------------------------------------
\210\ The Center for Biological Diversity thought that the
agencies; were limiting their consideration of vehicle speed
limiters as a potential control technology due to perceived legal
constraints. As noted above, vehicle speed limiters are a potential
control technology for heavy duty vehicles and there is no statutory
bar on either agency considering the performance of VSLs in
developing the standards.
---------------------------------------------------------------------------
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.\211\ 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. Although
we believe there may be real benefits in reduced fuel consumption and
GHG emissions through the application of dual clutch, automatic or
automated manual transmission technology, we are not reflecting this
potential improvement in our standard setting or in our compliance
model. We have taken this approach because we cannot say with
confidence what level of performance improvement to expect.
---------------------------------------------------------------------------
\211\ See TIAX, Note 198, 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.\212\ The light-duty 2012-16 MY vehicle 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.
---------------------------------------------------------------------------
\212\ See the 2010 NAS Report, Note 197, 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, but the
standard is already premised on use of extended idle reduction so use
of hybrid technology would duplicate many of the same emission
reductions attributable to extended idle reduction. NAS estimated that
hybrid systems would cost approximately $25,000 per tractor in the 2015
through the 2020 time frame and provide a potential fuel consumption
reduction of 10 percent, of which 6 percent is idle reduction which can
be achieved (less expensively) through the use of other idle reduction
technologies.\213\ 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 action (as well
as issues regarding sufficiency of lead time (see Section III.2 (a)
below), 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.
---------------------------------------------------------------------------
\213\ See the 2010 NAS Report, Note 197, 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 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
[[Page 57204]]
developed the baseline diesel engine as a 2010 model year engine with
an aftertreatment system which meets EPA's 0.20 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.
With respect to stringency level, the agencies received comments
from Cummins and Daimler stating that the proposed stringency levels
were appropriate for the lead-times. Conversely, the agencies received
comments from several environmental groups (UCS, CATF, ACEEE)
supporting a greater reduction in engine CO2 emissions and
fuel consumption based on the NAS report. Navistar also stated that the
agencies' baseline engine is inappropriate since there is not currently
a 0.20 NOX compliant engine in production. A discussion of
how the baseline engine configuration can be found below in Section
(2)(b)(i).
Navistar also stated that the baseline engines proposed in the
NPRM, MY 2010 selective catalytic reduction (SCR)-equipped, could not
meet the agencies' statutory obligation to set feasible standards, and
requested instead that MY 2010 engines currently in-use be used to meet
the feasibility factor. The agencies thus disagree with the statement
that SCR is infeasible and therefore, the agencies reaffirm that the
engine used as the baseline engine in the agencies' analysis does
indeed exist. In fact, several engine families have been certified by
EPA using SCR technology over the past two years, all of which have met
the 0.20 g/bhp-hr NOX standard.\214\ EPA disagrees with
Navistar that SCR engines currently certified do not meet this
standard. Compliance with the 0.20 g/bhp-hr FTP NOX standard
is measured based on an engine's performance when tested over a
specific duty cycle (see 40 CFR 86.007-11(a)(2)). This is also true
regarding the SET standard (see 40 CFR 86.007-11(a)(3)). Further, the
FTP and SET tests are average tests, so emissions could go over 0.20
even for some portion of the test itself. Manufacturers are also
required to ensure that their engines meet the NTE standard under all
conditions specified in the regulations (see 40 CFR 86.007-11(a)(4)).
---------------------------------------------------------------------------
\214\ See 2010 Model Year Engine Certification Data and 2011
Model Year Engine Certification Data files located in the Docket
EPA-HQ-OAR-2010-0162.
---------------------------------------------------------------------------
Several manufacturers have been able to show compliance with these
standards in applications for certification provided to EPA for several
engine families. Navistar has provided no information indicating that
these tests were false or improper. Indeed, Navistar does not appear to
suggest, or provide any evidence, that engines with working SCR systems
do not meet the NOX standard. Thus, it is demonstrably false
to conclude that the NOX standard cannot be met with SCR-
equipped engines.
A more detailed response to these comments appears in Section 6.2
of the Response to Comment document for this rule.
Engine performance for CO2 emissions and fuel
consumption can be improved by use of the following technologies:
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.\215\
---------------------------------------------------------------------------
\215\ See TIAX. Note 198, Page 4-13.
---------------------------------------------------------------------------
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.\216\ 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.
---------------------------------------------------------------------------
\216\ See TIAX Note 198, Page 4-2.
---------------------------------------------------------------------------
Higher efficiency air handling processes: To maximize the
efficiency of such processes, induction systems may be improved by
manufacturing more efficiently designed flow paths (including those
associated with air cleaners, chambers, conduit, mass air flow sensors
and intake manifolds) and by designing such systems for improved
thermal control. Improved turbocharging and air handling systems must
include higher efficiency EGR systems and intercoolers that reduce
frictional pressure loss while maximizing the ability to thermally
control induction air and EGR. The agencies received comments from
Honeywell confirming that turbochargers provide a role in reducing the
CO2 emissions from engines. Other components that offer
opportunities for improved flow efficiency include cylinder heads,
ports and exhaust manifolds to further reduce pumping losses. Variable
air breathing systems such as variable valve actuation may provide
additional gains at different loads and speeds. The NESCCAF/ICCT study
indicated up to 1.2 percent reduction could be achieved solely through
improved EGR systems.
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.\217\ 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.
---------------------------------------------------------------------------
\217\ See TIAX, Note 198, 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 to 2 percent.\218\
---------------------------------------------------------------------------
\218\ TIAX, Note 198, pg 4-15
---------------------------------------------------------------------------
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
[[Page 57205]]
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.\219\ Bendix, in their comments to the agencies, confirmed
that there are engine accessories available that can improve an
engine's fuel efficiency.
---------------------------------------------------------------------------
\219\ See TIAX. Note 198, Page 3-5.
---------------------------------------------------------------------------
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 have included 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.\220\ 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.\221\ The
agencies estimate an additional 1 to 2 percent reduction may be
feasible in the 2017 model year through additional refinement.
---------------------------------------------------------------------------
\220\ 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.
\221\ See TIAX, Note 198, pg. 4-9.
---------------------------------------------------------------------------
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.\222\ 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.
---------------------------------------------------------------------------
\222\ 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.\223\
---------------------------------------------------------------------------
\223\ 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.\224\ However, none
of the bottoming cycle or Rankine systems has been demonstrated
commercially and are currently in only the research stage. See Section
2.4.2.7 of the RIA and Section II.B above.
---------------------------------------------------------------------------
\224\ See 2010 NAS Report, Note 197, 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' time frames through the increased application of
aerodynamic technologies, LRR tires, weight reduction, extended idle
reduction technologies, vehicle speed limiters, and engine
improvements. The agencies believe that hybrid powertrains systems for
tractors will not be sufficiently developed and the necessary
manufacturing capacity put in place to base a standard on any
significant volume of hybrid tractors. The agencies are not aware of
any full hybrid systems currently developed for long haul tractor
applications. To date, hybrid systems for tractors have been primarily
focused on idle shutdown technologies and not the broader energy
storage and recovery systems necessary to achieve reductions over
typical vehicle drive cycles. The final standards reflect the potential
for idle shutdown technologies through the GEM model. Further as
highlighted by the 2010 NAS report, the agencies do believe that full
hybrid powertrains have the potential in the longer term to provide
significant improvements in fuel efficiency and to reduce greenhouse
gas emissions. However lacking any existing systems or manufacturing
base, we cannot conclude such technology will be available in the 2014-
2018 timeframe. Developing a full hybrid system itself would be a three
to five project followed by several more years to put in place
manufacturing capacity. The agencies are including incentives for the
use of hybrid technologies to help encourage their development and to
reward manufacturers that can produce hybrids through prototype and low
volume production methods. The agencies also are not including
drivetrain technologies in the standard setting process, as discussed
in Section II.B.3.h.iv.
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 final 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 the GEM, as shown in Table III-1. 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 an exhaust stacks at
the B-pillar, which increases drag. As noted earlier, our assessment of
the baseline new high roof tractor fleet aerodynamics consists of
approximately 25 percent Bin I, 70 percent Bin II, and 5 percent Bin
III tractors. 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
[[Page 57206]]
manufacturers based on market share.\225\ The agencies assumed no
application of vehicle speed limiters, weight reduction technologies,
or idle reduction technologies in the baseline tractor. The agencies
use the inputs in the GEM to derive the baseline CO2
emissions and fuel consumption of Class 7 and 8 tractors. The results
are included in Table III-1.
---------------------------------------------------------------------------
\225\ 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.
Table III-1--Baseline Tractor Definitions
--------------------------------------------------------------------------------------------------------------------------------------------------------
Class 7 Class 8
--------------------------------------------------------------------------------------------------------------------
Day cab Day cab Sleeper cab
--------------------------------------------------------------------------------------------------------------------
Low roof Mid roof High roof Low roof Mid roof High roof Low roof Mid roof High roof
--------------------------------------------------------------------------------------------------------------------------------------------------------
Aerodynamics (Cd)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Baseline........................... 0.77 0.87 0.73 0.77 0.87 0.73 0.77 0.87 0.70
--------------------------------------------------------------------------------------------------------------------------------------------------------
Steer Tires (CRR kg/metric ton)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Baseline........................... 7.8 7.8 7.8 7.8 7.8 7.8 7.8 7.8 7.8
--------------------------------------------------------------------------------------------------------------------------------------------------------
Drive Tires (CRR kg/metric ton)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Baseline........................... 8.2 8.2 8.2 8.2 8.2 8.2 8.2 8.2 8.2
--------------------------------------------------------------------------------------------------------------------------------------------------------
Weight Reduction (lb)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Baseline........................... 0 0 0 0 0 0 0 0 0
--------------------------------------------------------------------------------------------------------------------------------------------------------
Extended Idle Reduction (gram CO2/ton-mile reduction)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Baseline........................... N/A N/A N/A N/A N/A N/A 0 0 0
--------------------------------------------------------------------------------------------------------------------------------------------------------
Vehicle Speed Limiter
--------------------------------------------------------------------------------------------------------------------------------------------------------
Baseline........................... ........... ........... ........... ........... ........... ........... ........... ........... ...........
--------------------------------------------------------------------------------------------------------------------------------------------------------
Engine
--------------------------------------------------------------------------------------------------------------------------------------------------------
Baseline........................... 2010 MY 11L 2010 MY 11L 2010 MY 11L 2010 MY 15L 2010 MY 15L 2010 MY 15L 2010 MY 15L 2010 MY 15L 2010 MY 15L
Engine Engine Engine Engine Engine Engine Engine Engine Engine
--------------------------------------------------------------------------------------------------------------------------------------------------------
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table III-2--Class 7 and 8 Tractor Baseline CO2 Emissions and Fuel Consumption
--------------------------------------------------------------------------------------------------------------------------------------------------------
Class 7 Class 8
--------------------------------------------------------------------------------------------------------------------
Day cab Day cab Sleeper cab
--------------------------------------------------------------------------------------------------------------------
Low roof Mid roof High roof Low roof Mid roof High roof Low roof Mid roof High roof
--------------------------------------------------------------------------------------------------------------------------------------------------------
CO2 (grams CO2/ton-mile)........... 116 128 138 88 95 103 80 89 94
--------------------------------------------------------------------------------------------------------------------------------------------------------
Fuel Consumption (gal/1,000 ton- 11.4 12.6 13.6 8.7 9.4 10.1 7.8 8.7 9.3
mile).............................
--------------------------------------------------------------------------------------------------------------------------------------------------------
(ii) Tractor Technology Package Definitions
The agencies' assessment of the final 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 the standards through a three-step process. First, the
agencies developed technology performance characteristics for each
technology, described below. Each technology is associated with an
input parameter which is in turn modeled in the GEM. The performance
levels for the range of Class 7 and 8 tractor aerodynamic packages and
vehicle technologies are described in Table III-3. Second, the agencies
combined the technology performance levels with a projected technology
application rate to determine the GEM inputs used to set the stringency
of the final standards. Third, the agencies input the parameters
[[Page 57207]]
into GEM and used the output to determine the final CO2
emissions and fuel consumption levels.
Aerodynamics
The aerodynamic packages are categorized as Bin I, Bin II, Bin III,
Bin IV, or Bin V based on the aerodynamic performance determined
through testing conducted by the manufacturer. A more complete
description of these aerodynamic packages is included in Chapter 2 of
the RIA. In general, the CdA values for each package and tractor
subcategory were developed through EPA's coastdown testing of tractor-
trailer combinations, the 2010 NAS report, and SAE papers.
Tire Rolling Resistance
The rolling resistance coefficient for the tires was developed from
SmartWay's tire testing to develop the SmartWay certification, in
addition to testing a selection of tractor tires as part of this
program. The tire performance was evaluated in three levels--the
baseline (average), 15 percent better than the average, and an
additional 15 percent improvement. The first 15 percent improvement
represents the threshold used to develop SmartWay certified tires for
long haul tractors. The second 15 percent threshold represents an
incremental step for improvements beyond today's SmartWay level and
represents the best in class rolling resistance of the tires we tested.
Weight Reduction
The weight reductions were developed from tire manufacturer
information, the Aluminum Association, the Department of Energy, and
TIAX, as discussed above in Section II.B.3.e.
Idle Reduction
The benefits for the extended idle reductions were developed from
literature, SmartWay work, and the 2010 NAS report. The agencies
received comments from multiple stakeholders regarding idle reduction
technologies (IRT). Two commenters asked us to revise the default value
associated with the IRT technology, and two commenters want to use IRT
in GEM even without automatic engine shut down (AES). The agencies
proposed AES after 5 minutes with no exceptions to help ensure that the
idle reductions are realized in-use. Use of an AES ensures the main
engine will be shut down, whereas idle reduction technologies alone do
not provide that level of certainty. Without an automatic shutdown of
the main engine, actual savings would depend on operator behavior and
thus be essentially unverifiable. The agencies are finalizing the
calculation as proposed, along with the automotive engine shutdown
requirement. Additional details regarding the comments and calculations
are included in RIA Section 2.5.4.2.
Several commenters requested that the level of emissions reductions
vary in GEM by different idle reduction technologies, and one commenter
requested that the application of battery powered APUs be incentivized.
The agencies recognize that the level of emission reductions provided
by different IRT varies, but are adopting a conservative level to
recognize that some vehicles may be sold with only an AES but may then
install an IRT in-use. Or some vehicles may be sold with one IRT but
then choose to install alternative ones in-use. The agencies cannot
verify the savings which depend on operator behavior.
One commenter requested that we provide manufacturers with an
option to allow the AES feature to be reprogammable after a specified
number of miles or time in service. The agencies recognize that AES may
impact the resale value of tractors and, in response to comments, are
adopting provisions for the optional expiration of an AES. Thus, the
initial buyer could select AES only for the number of miles based on
the expected time before resale. Similar to vehicle speed limiters, we
would discount the impact based on the full life of the truck (e.g.
1,259,000 miles). Additional detail can be found in RIA Section
2.5.4.2.
Vehicle Speed Limiter
The agencies are not including vehicle speed limiters in the
technology package for Class 7 and 8 tractors.
Summary of Technology Performance
Table III-3 describes the performance levels for the range of Class
7 and 8 tractor aerodynamic packages and vehicle technologies.
Table III-3--Class 7 and 8 Tractor Technology Values
--------------------------------------------------------------------------------------------------------------------------------------------------------
Class 7 Class 8
------------------------------------------------------------------------------------------
Day cab Day cab Sleeper cab
------------------------------------------------------------------------------------------
Low/mid Low/mid
roof High roof roof High roof Low roof Mid roof High roof
--------------------------------------------------------------------------------------------------------------------------------------------------------
Aerodynamics (Cd)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Bin I........................................................ 0.77/0.87 0.79 0.77/0.87 0.79 0.77 0.87 0.75
Bin II....................................................... 0.71/0.82 0.72 0.71/0.82 0.72 0.71 0.82 0.68
Bin III...................................................... ........... 0.63 ........... 0.63 ........... ........... 0.60
Bin IV....................................................... ........... 0.56 ........... 0.56 ........... ........... 0.52
Bin V........................................................ ........... 0.51 ........... 0.51 ........... ........... 0.47
--------------------------------------------------------------------------------------------------------------------------------------------------------
Steer Tires (CRR kg/metric ton)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Baseline..................................................... 7.8 7.8 7.8 7.8 7.8 7.8 7.8
Level I...................................................... 6.6 6.6 6.6 6.6 6.6 6.6 6.6
Level II..................................................... 5.7 5.7 5.7 5.7 5.7 5.7 5.7
--------------------------------------------------------------------------------------------------------------------------------------------------------
Drive Tires (CRR kg/metric ton)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Baseline..................................................... 8.2 8.2 8.2 8.2 8.2 8.2 8.2
Level I...................................................... 7.0 7.0 7.0 7.0 7.0 7.0 7.0
Level II..................................................... 6.0 6.0 6.0 6.0 6.0 6.0 6.0
--------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 57208]]
Weight Reduction (lb)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Control...................................................... 400 400 400 400 400 400 400
--------------------------------------------------------------------------------------------------------------------------------------------------------
Extended Idle Reduction (gram CO2/ton-mile reduction) \a\
--------------------------------------------------------------------------------------------------------------------------------------------------------
Control...................................................... N/A N/A N/A N/A 5 5 5
--------------------------------------------------------------------------------------------------------------------------------------------------------
Vehicle Speed Limiter \b\
--------------------------------------------------------------------------------------------------------------------------------------------------------
Control...................................................... N/A N/A N/A N/A N/A N/A N/A
--------------------------------------------------------------------------------------------------------------------------------------------------------
Notes:
\a\ While the standards are set based on this value, users would enter another value if AES is not applied or applied for less than the full useful life
of the engine.
\b\ Vehicle speed limiters are an applicable technology for all Class 7 and 8 tractors, however the standards are not premised on the use of this
technology.
(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.
With respect to the levels of technology application used to
develop the final 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
final standards. The agencies received a significant number of comments
related to this second basis. In particular, commenters questioned the
reasons for not requiring the maximum reduction technology in every
case. The agencies have not done so because we have concluded that
within each of these individual vehicle categories there are particular
applications where the use of the identified technologies would be
either ineffective or not technically feasible. The addition of
ineffective technologies provides no environmental or fuel efficiency
benefit, increases costs and is not a basis upon which to set a maximum
feasible improvement. For example, the agencies have not required the
use of full aerodynamic vehicle treatments on 100 percent of tractors
because we know that in many applications (for example gravel truck
engaged in local aggregate delivery) the added weight of the
aerodynamic technologies will increase fuel consumption and hence
CO2 emissions to a greater degree than the reduction that
would be accomplished from the more aerodynamic nature of the tractor.
To simply set the standard based on the largest reduction possible
estimated narrowly over a single test procedure while ignoring the in-
use effects of the technology would in this case result in a perverse
outcome that is not in keeping with the agencies' goals or the
requirements of the CAA and EISA.
Aerodynamics Application Rate
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 adopting
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.\226\ 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 final standard is premised)
consists of 20 percent of Bin IV, 70 percent Bin III, and 10 percent
Bin II reflecting our assessment of the fraction of tractors in this
segment that can successfully apply these aerodynamic packages.
---------------------------------------------------------------------------
\226\ See TIAX, Note 198, Page 4-40.
---------------------------------------------------------------------------
The 90 percent of tractors that we project can either be Bin II or
Bin III equipped reflects the bulk of Class 8 high roof sleeper cab
applications. We are not projecting a higher fraction of Bin III
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.
Aerodynamic improvements through new tractor designs and the
[[Page 57209]]
development of new aerodynamic components is an inherently slow and
iterative process. Aerodynamic impacts are highly nonlinear and often
reflect unexpected interactions between multiple components. Given the
nature of aerodynamic improvements it is inherently difficult to
estimate the degree to which improvements can be made beyond previously
demonstrated levels. The changes required for Bins III and IV reflect
the kinds of improvements projected in the Department of Energy's
Supertruck program. That program assumes that such systems can be
demonstrated on vehicles by 2017. In this case, the agencies are
projecting that truck OEMs will be able to begin implementing these
aerodynamic technologies prior to 2017 on a limited scale. Importantly,
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.
The final 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.\227\ 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.
---------------------------------------------------------------------------
\227\ U.S. Department of Energy. Transportation Energy Data
Book, Edition 28-2009. Table 5.7.
---------------------------------------------------------------------------
As discussed in Section II.B.2.c, in response to comments received
from manufacturers making some of these same points, the agencies are
finalizing only two aerodynamic bins for low and mid roof tractors. The
agencies are reducing the number of bins for these tractors from the
proposal to reflect the actual range of aerodynamic technologies
effective in low and mid roof tractor applications. The aerodynamic
improvements to the bumper, hood, windshield, mirrors, and doors are
developed for the high roof tractor application and then carried over
into the low and mid roof applications. As mentioned in Section
II.B.2.c, the types of designs that would move high roof tractors from
a Bin III to Bins IV and V include features such as gap reducers and
integral roof fairings which would not be appropriate on low and mid
roof tractors. Thus, the agencies are differentiating the aerodynamic
performance for low- and mid-roof tractors into two bins--Bin I and Bin
II. The application rates in the low and mid roof categories are the
same as proposed, but aggregated into just two bins. Bin I for these
tractors corresponds to the proposed ``Classic'' and ``Conventional''
bins and Bin II corresponds to the proposed ``SmartWay,'' ``Advanced
SmartWay,'' and ``Advanced SmartWay II'' bins.
Low Rolling Resistance Tire Application Rate
At proposal, the agencies stated that at least one LRR tire model
is available today that meets the rolling resistance requirements of
the Level I and Level II tire packages so the 2014 MY should afford
manufacturers sufficient lead time to install these packages. EPA and
NHTSA conducted additional evaluation testing on HD tires used for
tractors. The agencies also received several comments on the
suitability of low rolling resistance tires for various HD truck
applications. The summary of the agencies findings and a response to
issues raised by commenters is presented in Section II.D(1)(a).
The agencies note that baseline rolling resistance level for tires
installed on tractors is approximately equivalent to what the agencies
consider to be low rolling resistance tires for vocational vehicles
because of the tire manufacturer's focus on improving the rolling
resistance of tractor tires. For the tire manufacturers to further
reduce tire rolling resistance, the manufacturers must consider 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 final
standards should not be premised on 100 percent application of Level II
tires in all tractor segments given the interference with vehicle
utility that would result. The agencies are basing their analyses on
application rates that vary by subcategory recognizing that some
subcategories require a different balancing of performance versus
rolling resistance.
Weight Reduction Technology Application Rate
The agencies proposed setting the 2014 model year tractor standards
using 100 percent application of a 400 pound weight reduction package.
Volvo and ATA stated in their comments that not all fleets can use
single wide tires and if this is the case the 400 pound weight
reduction cannot be met. The agencies also received comments from MEMA,
Navistar, American Chemistry Council, the Auto Policy Center, Iron and
Steel Institute, Arvin Meritor, Aluminum Association, and environmental
groups and NGOs identifying other potential weight reduction
opportunities for tractors. As described in Section II.B.3.e above, the
agencies are adopting an expanded list of weight reduction options
which can be input into the GEM for the final rulemaking.
As also explained in that earlier discussion, the agencies, upon
further analysis, continue to believe that a 400 pound weight reduction
package is appropriate for tractors in the time frame. As stated in
Section II.B.2.e above, for tractors where single wide tires are not
appropriate, the manufacturers have additional options available to
achieve weight reduction, such as body panels and chassis components as
documented in the earlier discussion. The agencies have extended the
list of weight reduction components in order to provide the
manufacturers with additional means to comply with the combination
tractors and to further encourage reductions in vehicle weight. The
agencies considered increasing the target value beyond 400 pounds given
the additional reduction potential components identified in the
expanded list; however, lacking information on the capacity for the
industry to change to these light weight components across the board by
the 2014 model year, we have decided to maintain the 400 pound target.
The agencies intend to continue to study the potential for additional
weight reductions in our future work considering a second phase of
truck fuel efficiency and GHG regulations.
[[Page 57210]]
Idle Reduction Technology Application Rate
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 and to do
so in a manner that the emission reductions associated with idle
reduction technology occur in use. Therefore, as proposed, we are
allowing only idle emission reduction technologies with include an
automatic engine shutoff (AES). We are also adopting some override
provisions in response to comments we received (as explained below). As
proposed, we are adopting a 100 percent application rate for this
technology for Class 8 sleeper cabs, even though the current fleet is
estimated to have a 30 percent application rate. The agencies are
unaware of reasons why AES with extended idle reduction technologies
could not be applied to all tractors with a sleeper cab, except those
deemed a vocational tractor, in the available lead time.
One commenter stated the application rate of AES should be less
than 100 percent, but did not recommend an alternative application rate
or provide justification for a change. The agencies re-evaluated the
proposed 100 percent application rate and determined that a 100 percent
application rate for this technology for Class 8 sleeper cabs remains
appropriate. The agencies have also considered the many comments which
raised concerns about the proposed mandatory 5 minute automatic engine
shut down without override capability (in terms of safety, extreme
temperatures and low battery conditions). To avoid unintended adverse
impacts, we are adopting limited override provisions. Three of the five
exceptions are similar to those currently in effect under a California
Air Resources Board (CARB) regulation. CARB provides AES exceptions (or
overrides) within its existing heavy-duty vehicle anti-idling laws,
which were developed to address these same types of concerns. The
exceptions we are adopting include override capability during exhaust
emissions control device regeneration, during engine servicing and
maintenance, when battery state of charge is too low, in extreme
ambient temperatures, when engine coolant temperature is too low, and
during PTO operation. The RIA provides more detail about these final
override provisions in Section 2.5.4.3.
The agencies received comment that we should extend the idle
reduction benefits beyond Class 8 sleepers, including Class 7 tractors
and vocational vehicles. The agencies reviewed literature to quantify
the amount of idling which is conducted outside of hoteling operations.
One study, conducted by Argonne National Laboratory, identified several
different types of trucks which might idle for extended amounts of time
during the work day.\228\ Idling may occur during the delivery process,
queuing at loading docks or border crossings, during power take off
operations, or to provide comfort during the work day. However, the
study provided only ``rough estimates'' of the idle time and energy use
for these vehicles. The agencies are not able to appropriately develop
a baseline of workday idling for the other types of vehicles and
identify the percent of this idling which could be reduced through the
use of AES. Absent such information, the agencies cannot justify adding
substantial cost for AES systems with such uncertain benefits.
---------------------------------------------------------------------------
\228\ Gaines, L., A. Vyas, J. Anderson. Estimation of Fuel Use
by Idling Commercial Trucks. January 2006.
---------------------------------------------------------------------------
Vehicle Speed Limiter Application Rate
Vehicle speed limiters may be used as a technology to meet the
standard, but in setting the standard we assumed a zero percent
application rate of vehicle speed limiters. Although we believe vehicle
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 a 55 mph for this customer. The resulting truck
modeled in GEM could meet our final 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.\229\
---------------------------------------------------------------------------
\229\ Ibid.
The agencies note that because a VSL value can be input into
GEM, its benefits can be directly assessed with the model and off
cycle credit applications therefore are not necessary even though
the standard is not based on performance of VSLs (i.e. VSL is an on-
cycle technology).
---------------------------------------------------------------------------
As discussed in Section II.B.2.g above, we have chosen not to base
the standards on performance of VSLs 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. Therefore, the
agencies are not premising the final standards on use of VSL, and
instead will rely on the industry to select VSL when circumstances are
appropriate for its use. The agencies have not included either the cost
or benefit due to VSLs in analysis of the program's costs and benefits.
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. The Center for Biological
Diversity (CBD) argued the agencies should reflect the use of VSLs in
setting the standard for tractors rather than assuming no VSL use in
determining the appropriate standard. The agencies have chosen not to
do so because, as explained, we are not able at this time to quantify
to potential loss in utility due to the use of VSLs. Absent this
information, we cannot make a determination regarding the
reasonableness of setting a standard based on a particular VSL level.
In
[[Page 57211]]
confirmation, a number of commenters most notably the Owner Operator
Independent Drivers Association (OOIDA) suggest that VSLs could
significantly impact the ability of a vehicle to deliver goods against
a fixed schedule and hence would significantly impact its utility. ATA
commented that limited flexibility must be built into speed limiters as
not to interfere with NHTSA planned rulemaking in response to 2006 ATA
petition and its 2008 Sustainability Plan. Similar comments were
received from DTNA requesting that the agencies consider any NHTSA
safety regulations that may also be regulating VSLs. NHTSA plans to
issue a rule in 2012 addressing the safety performance features of
VSLs.
Table III-4 provides the final application rates of each technology
broken down by weight class, cab configuration, and roof height.
Table III-4--Final Technology Application Rates for Class 7 and 8 Tractors
[In percent]
--------------------------------------------------------------------------------------------------------------------------------------------------------
Class 7 Class 8
------------------------------------------------------------------------------------------
Day cab Day cab Sleeper cab
------------------------------------------------------------------------------------------
Low/mid Low/mid
roof High roof roof High roof Low roof Mid roof High roof
--------------------------------------------------------------------------------------------------------------------------------------------------------
Aerodynamics (Cd)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Bin I........................................................ 40 0 40 0 30 30 0
Bin II....................................................... 60 30 60 30 70 70 10
Bin III...................................................... ........... 60 ........... 60 ........... ........... 70
Bin IV....................................................... ........... 10 ........... 10 ........... ........... 20
Bin V........................................................ ........... 0 ........... 0 ........... ........... 0
--------------------------------------------------------------------------------------------------------------------------------------------------------
Steer Tires (CRR kg/metric ton)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Baseline..................................................... 40 30 40 30 30 30 10
Bin I........................................................ 50 60 50 60 60 60 70
Bin II....................................................... 10 10 10 10 10 10 20
--------------------------------------------------------------------------------------------------------------------------------------------------------
Drive Tires (CRR kg/metric ton)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Baseline..................................................... 40 30 40 30 30 30 10
Bin I........................................................ 50 60 50 60 60 60 70
Bin II....................................................... 10 10 10 10 10 10 20
--------------------------------------------------------------------------------------------------------------------------------------------------------
Weight Reduction (lb)
--------------------------------------------------------------------------------------------------------------------------------------------------------
400 lb. Weight Reduction..................................... 100 100 100 100 100 100 100
--------------------------------------------------------------------------------------------------------------------------------------------------------
Extended Idle Reduction (gram CO2/ton-mile reduction)
--------------------------------------------------------------------------------------------------------------------------------------------------------
AES.......................................................... N/A N/A N/A N/A 100 100 100
--------------------------------------------------------------------------------------------------------------------------------------------------------
Vehicle Speed Limiter
--------------------------------------------------------------------------------------------------------------------------------------------------------
VSL.......................................................... 0 0 0 0 0 0 0
--------------------------------------------------------------------------------------------------------------------------------------------------------
(iv) Derivation of the Final Tractor Standards
The agencies used the technology inputs and final technology
application rates in GEM to develop the final fuel consumption and
CO2 emissions standards for each subcategory of Class 7 and
8 combination tractors. The agencies derived a scenario tractor for
each subcategory by weighting the individual GEM input parameters
included in Table III-3 with 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
final engine standards, the agencies assumed a compliant engine in
GEM.\230\ In other words, EPA is finalizing 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.\231\ The agencies then ran GEM with a
single set of vehicle inputs, as shown in Table III-5, to derive the
final standards for each subcategory. Additional detail is provided in
the RIA Chapter 2.
---------------------------------------------------------------------------
\230\ See Section III.A.2.b below explaining the derivation of
the engine standards.
\231\ 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 57212]]
Table III-5--GEM Inputs for the Class 7 and 8 Tractor Standard Setting
--------------------------------------------------------------------------------------------------------------------------------------------------------
Class 7 Class 8
--------------------------------------------------------------------------------------------------------------------------------------------------------
Day cab Day cab Sleeper cab
--------------------------------------------------------------------------------------------------------------------------------------------------------
Low roof Mid roof High roof Low roof Mid roof High roof Low roof Mid roof High roof
--------------------------------------------------------------------------------------------------------------------------------------------------------
Aerodynamics (Cd)
--------------------------------------------------------------------------------------------------------------------------------------------------------
0.73............................................ 0.84 0.65 0.73 0.84 0.65 0.73 0.84 0.59
--------------------------------------------------------------------------------------------------------------------------------------------------------
Steer Tires (CRR kg/metric ton)
--------------------------------------------------------------------------------------------------------------------------------------------------------
6.99............................................ 6.99 6.87 6.99 6.99 6.87 6.87 6.87 6.54
--------------------------------------------------------------------------------------------------------------------------------------------------------
Drive Tires (CRR kg/metric ton)
--------------------------------------------------------------------------------------------------------------------------------------------------------
7.38............................................ 7.38 7.26 7.38 7.38 7.26 7.26 7.26 6.92
--------------------------------------------------------------------------------------------------------------------------------------------------------
Weight Reduction (lb)
--------------------------------------------------------------------------------------------------------------------------------------------------------
400............................................. 400 400 400 400 400 400 400 400
--------------------------------------------------------------------------------------------------------------------------------------------------------
Extended Idle Reduction (gram CO2/ton-mile reduction)
--------------------------------------------------------------------------------------------------------------------------------------------------------
N/A............................................. N/A N/A N/A N/A N/A 5 5 5
--------------------------------------------------------------------------------------------------------------------------------------------------------
Vehicle Speed Limiter
--------------------------------------------------------------------------------------------------------------------------------------------------------
--.............................................. ........... ........... ........... ........... ........... ........... ........... ...........
--------------------------------------------------------------------------------------------------------------------------------------------------------
Engine
--------------------------------------------------------------------------------------------------------------------------------------------------------
2014/17 MY 11L Engine........................... 2014/17 MY 2014/17 MY 2014/17 MY 2014/17 MY 2014/17 MY 2014/17 MY 2014/17 MY 2014/17 MY
11L Engine 11L Engine 15L Engine 15L Engine 15L Engine 15L Engine 15L Engine 15L Engine
--------------------------------------------------------------------------------------------------------------------------------------------------------
The level of the 2014 and 2017 model year final standards and
percent reduction from the baseline for each subcategory are included
in Table III-6.
Table III-6--Final 2014 and 2017 Model Year Tractor Reductions
----------------------------------------------------------------------------------------------------------------
----------------------------------------------------------------------------------------------------------------
2014 Model Year CO2 Grams per Ton-Mile
----------------------------------------------------------------------------------------------------------------
Day cab Sleeper cab
-----------------------------------------------
Class 7 Class 8 Class
-----------------------------------------------
Low Roof........................................................ 107 81 68
Mid Roof........................................................ 119 88 76
High Roof....................................................... 124 92 75
----------------------------------------------------------------------------------------------------------------
2014-2016 Model Year Gallons of Fuel per 1,000 Ton-Mile \232\
----------------------------------------------------------------------------------------------------------------
Day cab Sleeper cab
-----------------------------------------------
Class 7 Class 8 Class
-----------------------------------------------
Low Roof........................................................ 10.5 8.0 6.7
Mid Roof........................................................ 11.7 8.7 7.4
High Roof....................................................... 12.2 9.0 7.3
----------------------------------------------------------------------------------------------------------------
2017 Model Year CO2 Grams per Ton-Mile
----------------------------------------------------------------------------------------------------------------
Day cab Sleeper cab
-----------------------------------------------
Class 7 Class 8 Class
-----------------------------------------------
Low Roof........................................................ 104 80 66
Mid Roof........................................................ 115 86 73
High Roof....................................................... 120 89 72
----------------------------------------------------------------------------------------------------------------
2017 Model Year and Later Gallons of Fuel per 1,000 Ton-Mile
----------------------------------------------------------------------------------------------------------------
[[Page 57213]]
Day cab Sleeper cab
-----------------------------------------------
Class 7 Class 8 Class
-----------------------------------------------
Low Roof........................................................ 10.2 7.8 6.5
Mid Roof........................................................ 11.3 8.4 7.2
High Roof....................................................... 11.8 8.7 7.1
----------------------------------------------------------------------------------------------------------------
A summary of the final technology package costs is included in
Table III-7 with additional details available in the RIA Chapter 2.
---------------------------------------------------------------------------
\232\ Manufacturers may voluntarily opt-in to the NHTSA fuel
consumption program in 2014 or 2015. If a manufacturer opts-in, the
program becomes mandatory.
Table III-7--Class 7 and 8 Tractor Technology Costs Inclusive of Indirect Cost Markups in the 2014 Model Year a (2009$)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Class 7 Class 8
------------------------------------------------------------------------------------------
Day cab Day cab Sleeper cab
------------------------------------------------------------------------------------------
Low/mid Low/mid
roof High roof roof High roof Low roof Mid roof High roof
--------------------------------------------------------------------------------------------------------------------------------------------------------
Aerodynamics................................................. $675 $924 $675 $924 $962 $983 $1,627
Steer Tires.................................................. 68 68 68 68 68 68 68
Drive Tires.................................................. 63 63 126 126 126 126 126
Weight Reduction............................................. 1,536 1,536 1,980 1,980 3,275 3,275 1,980
Idle Reduction with Auxiliary Power Unit..................... ........... ........... ........... ........... 3,819 3,819 3,819
Air Conditioning\c\.......................................... 22 22 22 22 22 22 22
------------------------------------------------------------------------------------------
Total.................................................... 2,364 2,612 2,871 3,119 8,271 8,291 7,641
--------------------------------------------------------------------------------------------------------------------------------------------------------
Notes:
\a\ Costs shown are for the 2014 model year so do not reflect learning impacts which would result in lower costs for later model years. For a
description of the learning impacts considered in this analysis and how it impacts technology costs for other years, refer to Chapter 2 of the RIA
(see RIA 2.2.2).
\b\ Note that values in this table include penetration rates. Therefore, the technology costs shown reflect the average cost expected for each of the
indicated classes. To see the actual estimated technology costs exclusive of penetration rates, refer to Chapter 2 of the RIA (see RIA 2.9 in
particular).
\c\ EPA's air conditioning standards are presented in Section II.E.5 above.
(v) Reasonableness of the Final Standards
The final standards are based on aggressive application rates for
control technologies which the agencies regard as the maximum feasible
for purposes of EISA section 32902 (k) and appropriate under CAA
section 202 (a) for the reasons given in Section (iii) above; see also
RIA Chapter 2.5.8.2. These technologies, at the estimated application
rates, are available within the lead time provided, as discussed in 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 $20 per ton of CO2eq per vehicle in
2030 without consideration of the substantial fuel savings.\233\ 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.\234\ Moreover, the cost of controls is
rapidly recovered due to the associated fuel savings, as shown in the
payback analysis included in Table VIII-11 located in Section VIII
below. Thus, overall cost per ton of the program, considering fuel
savings, is negative--fuel savings associated with the rules more than
offset projected costs by a wide margin. See Table VIII-6 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 final
standards represent a reasonable choice under section 202(a) of the CAA
and the maximum feasible under NHTSA's EISA authority at 49 U.S.C.
32902(k)(2).
---------------------------------------------------------------------------
\233\ See Section VIII.D below.
\234\ 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 adopting 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.
The agencies considered adopting 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 finalizing 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 off-
[[Page 57214]]
road conditions. We have not adopted 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, for example, that
hybrid systems are being researched to capture and return energy for
tractors that operate in gently rolling hills. However, as discussed
above, it is not clear to us today that these systems will be generally
applicable to tractors in the time frame of this regulation. In
addition, even if hybrid technologies were generally available for
these tractors during the MY 2014-2017 period, their costs would be
extremely high and benefits would be limited given that idle reduction
controls already capture many of the same emissions. According to the
2010 NAS Report, hybrid powertrains in tractors have the potential to
improve fuel consumption by 10 percent, but it displaces the 6 percent
reduction for idle reduction technologies, for a net improvement of 4
percent at a cost of $25,000 per vehicle.\235\
---------------------------------------------------------------------------
\235\ See 2010 NAS Report, Note 197, Page 146.
---------------------------------------------------------------------------
(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 0.20 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 0.20 g/bhp-hr NOX level, then the
individual engine's CO2 result was adjusted to accommodate
aftertreatment strategies that would result in a 0.20 g/bhp-hr
NOX emission level as described in RIA Chapter 2.4.2.1. The
engine CO2 results were then sales weighted within each
regulatory subcategory (i.e., medium heavy-duty diesel or heavy heavy-
duty diesel) to develop an industry average 2010 model year reference
engine. Although, 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.
Table III-8--2010 Model Year Baseline Diesel Engine Performance
------------------------------------------------------------------------
Fuel
CO2 Emissions consumption
(g/bhp-hr) (gallon/100
bhp-hr)
------------------------------------------------------------------------
Medium Heavy-Duty Diesel--SET........... 518 5.09
Heavy Heavy-Duty Diesel--SET............ 490 4.81
------------------------------------------------------------------------
(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 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 adopted a standard that
therefore reflects a 100 percent application rate of this technology
package. The agencies gave consideration to finalizing a more stringent
standard based on the application of mechanical turbocompounding by
model year 2014, 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. Implementing turbocompounding
into an engine design must be done through a significant redesign of
the engine architecture a process that typically takes 4 to 5 years.
Hence, we believe that turbocompounding is a more appropriate
technology for the agencies to consider in the 2017 timeframe.
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 finalizing fuel
consumption and CO2 emission standards recognizing the
opportunity for technology improvements over this time frame
(specifically, the addition of turbocompounding to the engine
technology package) while reflecting the typical heavy-duty engine
manufacturer product plan redesign and refresh cycles. Thus, the
agencies are finalizing 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
[[Page 57215]]
in RIA Chapter 2.4.2.12. The agencies' final standards are premised on
a 100 percent application rate of this technology package.
Commenters noted that the National Academy of Sciences (NAS) study
indicates that additional technology improvements can be made to heavy-
duty engines in MY 2014 and 2017. For diesel engine standards, the
agencies evaluated the following technologies: Combustion system
optimization, turbocharging and air handling systems, engine parasitic
and friction reduction, integrated aftertreatment systems,
electrification, and waste heat recovery.
The agencies carefully evaluated the research supporting the NAS
report and its recommendations and incorporated them to the extent
practicable in the development of the HD program. While the NAS report
suggests that greater engine improvements could be achieved by the use
of technologies such as improved emission control systems and
turbocompounding than do the agencies in this final action, we believe
the standards being finalized represent the most stringent technically
feasible for diesel engines used in tractors and vocational vehicles in
the 2014 to 2017 model year time frame. The NAS study concluded that
tractor engine fuel consumption can be reduced by approximately 15
percent in the 2015 to 2020 time frame and vocational engine fuel
consumption can be reduced by approximately 10 to 17 percent in the
same time frame compared to a 2008 engine baseline.\236\ Throughout
this presentation, the agencies' projections of performance
improvements are measured relative to a 2010 engine performance
baseline that itself reflects a four to five percent improvement over
the 2008 engine baseline used by NAS. Based on a review of existing
studies, NAS study authors found a range of reduction potential exists
for improvements in combustion efficiency, electrification of
accessories; improved emission control systems; and turbocompounding.
The study found that improvements in combustion efficiency can provide
reductions of 1 percent to 4 percent; electrification of accessories
can provide reductions of 2 percent to 5 percent in a hybridized
vehicle; improved emission control systems can provide a 1 percent to 4
percent improvement (depending on whether the improvement is to the EGR
or SCR system); and a 2.5 percent to 10 percent reduction is possible
with mechanical or electrical turbocompounding. While the reductions
being finalized in this regulation are lower than those published in
the NAS study, the agencies believe that the percent reductions being
finalized in these rules are consistent with the findings of the NAS
study. The reasons for this are as follows.
---------------------------------------------------------------------------
\236\ National Research Council, ``Technologies and Approaches
to Reducing the Fuel Consumption of Medium- and Heavy-Duty
Vehicles'' Figure S-1, page 4, National Acedemies Press, 2011.
---------------------------------------------------------------------------
First, some technologies cannot be used by all manufacturers. For
example, improved SCR conversion efficiency was projected by NAS to
provide a 3 percent to 4 percent improvement in fuel consumption.
Conversely, low temperature EGR was found to provide only a one percent
improvement. While the majority of manufacturers do use SCR systems and
will be able to realize the 3 percent to 4 percent improvement, not all
manufacturers use SCR for NOX aftertreatment. Manufacturers
that do not use SCR aftertreatment systems would only be able to
realize the 1 percent improvement from low temperature EGR. The
agencies need to take into consideration the entire market in setting
the stringency of the standards and, in assessing feasibility and cost,
cannot assume that all manufacturers will be able to use all
technologies.
Second, significant technical advances may be needed in order to
realize the upper end of estimates for some technologies. For example,
studies evaluated by NAS on turbocompounding found that a 2.5 percent
to 10 percent reduction is feasible. However, only one system is
available commercially and this system provides reductions on the low
end of this range.\237\ Little technical information is available on
the systems that achieve reductions in the upper range for
turbocompounding. These systems are based on proprietary designs the
improvement results for which have not yet been replicated by other
companies or organizations. The agencies are assuming that all tractor
engine manufacturers will use turbocompounding by 2017 model year. This
will require a significant change in the design of heavy-duty tractor
engines, one that represents the maximum technically feasible standard
even at the low end of the assumed improvement spectrum.
---------------------------------------------------------------------------
\237\ NAS 2010, page 53 cites Detroit Diesel Corporation, DD15
Brochure, DDC-EMC-BRO-0003-0408, April 2008.
---------------------------------------------------------------------------
Finally, different duty cycles used in the evaluation of medium-
and heavy-duty engine technologies can affect reported fuel consumption
improvements. For example, some technologies are dependent on high load
conditions to provide the greatest reductions. The duty cycles used to
evaluate some of the technologies considered by NAS differed
significantly from that used by the agencies in the modeling for this
rulemaking. Maximum and average speed was higher in some of the cycles
used in the studies, for example, and one result was demonstrated on a
nonroad engine cycle. In another example, the effectiveness of
turbocompounding when evaluated on a duty cycle with higher engine load
can show a greater reduction potential than when evaluated with a lower
engine load. In addition, technologies such as improvements to cooling
fans, air compressors, and air conditioning systems will not be
demonstrated using the engine dynamometer test procedures being adopted
in this final action because those components are not installed on the
engine during the testing. The agencies selected the duty cycles for
analysis, and for the final standards, that we believed best suited
tractor engines.
The agencies selected engine technologies and the estimated fuel
reduction percentages for setting the standards. For the reasons stated
above, the agencies believe the technologies and required improvements
in fuel consumption represent the maximum feasible improvement, and are
appropriate, cost-effective, and technologically feasible.
We gave consideration to finalizing an even more stringent standard
based on the use of waste heat recovery via a Rankine cycle (also
called bottoming cycle) 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. 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.\238\ The Department of Energy is working with
industry to develop waste heat recovery systems for heavy-duty engines.
At the Diesel Engine-Efficiency and Emissions Research (DEER)
conference in 2010, Caterpillar presented details regarding their waste
heat recovery systems development effort. In their presentation,
Caterpillar clearly noted that the work is a research project and
therefore does not imply
[[Page 57216]]
commercial viability.\239\ At the same conference, Concepts NREC
presented a status of exhaust energy recovery in heavy-duty engines.
The scope of Concepts NREC included the design and development of
prototype parts.\240\ Cummins, also in coordination with DOE, is also
active in developing exhaust energy recovery systems. Cummins made a
presentation to the DEER conference in 2009 providing an update on
their progress which highlighted opportunities to achieve a 10 percent
engine efficiency improvement during their research, but indicated the
need to focus their future development on areas with the highest
recovery opportunities (such as EGR, exhaust, and charge air).\241\
Cummins also indicated that future development would focus on reducing
the high additional costs and system complexity. Based upon the
assessment of this information, the agencies did not include these
technologies in determining the stringency of the final 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 finalizing provisions for
advanced technology credits described in Section IV to create
incentives for manufacturers to continue to invest to develop this
technology.
---------------------------------------------------------------------------
\238\ See TIAX, Note 198, Page 4-29.
\239\ Kruiswyk, R. ``An Engine System Approach to Exhaust Waste
Heat Recovery.'' Presented at DOE DEER Conference on September 29,
2010. Last viewed on May 11, 2011 at http://www1.eere.energy.gov/vehiclesandfuels/pdfs/deer_2010/wednesday/presentations/deer10_kruiswyk.pdf.
\240\ Cooper, D, N. Baines, N. Sharp. ``Organic Rankine Cycle
Turbine for Exhaust Energy Recovery in a Heavy Truck Engine.''
Presented at the 2010 DEER Conference. Last viewed on May 11, 2011
at http://www1.eere.energy.gov/vehiclesandfuels/pdfs/deer_2010/wednesday/presentations/deer10_baines.pdf.
\241\ Nelson, C. ``Exhaust Energy Recovery.'' Presented at the
DOE DEER Conference on August 5, 2009. Last viewed on May 11, 2011
at http://www1.eere.energy.gov/vehiclesandfuels/pdfs/deer_2009/session5/deer09_nelson_1.pdf.
---------------------------------------------------------------------------
(iii) Derivation of Engine Standards
EPA developed the final 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 final standards
are included in Table III-9.
Table III-9--Final Diesel Engine Standards Over the SET Cycle
----------------------------------------------------------------------------------------------------------------
MHD diesel HHD diesel
Model year engine engine
----------------------------------------------------------------------------------------------------------------
2014-2016..................................... CO2 Standard (g/bhp-hr)......... 502 475
Voluntary Fuel Consumption 4.93 4.67
Standard (gallon/100 bhp-hr).
2017 and later................................ CO2 Standard (g/bhp-hr)......... 487 460
Fuel Consumption (gallon/100 bhp- 4.78 4.52
hr).
----------------------------------------------------------------------------------------------------------------
(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 action (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 RIA
Chapter 2. The agencies did not receive any comments regarding the cost
approach used in the proposal.
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,
[[Page 57217]]
dynamometer cell time, and fabrication of prototype parts are estimated
at $6.8 million (2009 dollars) per manufacturer per year over the five
years covering 2012 through 2016. In aggregate, this averages out to
$284 per engine during 2012 through 2016 using an annual sales volume
of 600,000 light-, medium- and heavy-HD engines. The agencies received
comments from Horriba regarding the assumption the agencies used in the
proposal that said manufacturers would need to purchase new equipment
for measuring N2O and the associated costs. Horriba provided
information regarding the cost of stand-alone FTIR instrumentation
(estimated at $50,000 per unit) and cost of upgrading existing emission
measurement systems with NDIR analyzers (estimated at $25,000 per
unit). The agencies further analyzed our assumptions along with
Horriba's comments. Thus, we have revised the equipment costs estimates
and assumed that 75 percent of manufacturers would update existing
equipment while the other 25 percent would require new equipment. The
agencies are estimating costs of $63,087 (2009 dollars) per engine
manufacturer per engine subcategory (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 less than $1 per
engine in 2013 using an annual sales volume of 600,000 light-, medium-
and heavy-HD engines.
Where we projected that additional new hardware was needed to the
meet the final standards, we developed the incremental costs for those
technologies and marked them up using the ICM approach. Table III-10
below summarizes those estimates of cost on a per item basis. All costs
shown in Table III-18, below, include a low complexity ICM of 1.15 and
flat-portion of the curve learning is considered applicable to each
technology.
Table III-10--Heavy-Duty Diesel Engine Component Costs for Combination
Tractors\a\ (2009$)
------------------------------------------------------------------------
Technology 2014 2017
------------------------------------------------------------------------
Cylinder Head........................... $6 $6
Turbo efficiency........................ 18 17
EGR cooler.............................. 4 3
Water pump.............................. 91 84
Oil pump................................ 5 4
Fuel pump............................... 5 4
Fuel rail............................... 10 9
Fuel injector........................... 11 10
Piston.................................. 3 3
Engine Friction Reduction of Valvetrain. 82 76
Turbo-compounding (engines placed in 0 875
combination tractors only).............
MHHD and HHDD Total (combination 234 1,091
tractors)..............................
------------------------------------------------------------------------
Note:
\a\ Costs for aftertreatment improvements for MH and HH diesel engines
are covered via the engineering costs (see text). For LH diesel
engines, we have included the cost of aftertreatment improvements as a
technology cost.
The overall diesel engine technology package cost for an engine
being placed in a combination tractor is $234 in the 2014 model year
and $1,091 in the 2017 model year.
(v) Reasonableness of the Final Standards
The final 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 final
standards reflect 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,\242\ and the associated reductions are highly cost effective,
an estimated $20 per ton of CO2eq per vehicle.\243\ 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.\244\ Even the more expensive 2017 MY final 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).
---------------------------------------------------------------------------
\242\ 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.
\243\ See Tractor CO2 savings and technology costs in
Table 7-5 in RIA chapter 7.
\244\ 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(2)(b), notwithstanding the
general reasonableness of the final 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 final 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 final standards are based. Those
technologies can be utilized by all diesel engines installed in
tractors 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
[[Page 57218]]
today. Manufacturers have been gradually replacing these legacy
products with new engines. Engine manufacturers have indicated to the
agencies they will have to align their planned replacement of these
products with our final standards and at the same time add additional
technologies beyond those identified by the agencies as the basis for
the final 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 finalizing a
similar approach here. As explained above in Section II.B.(2)(b), the
agencies are finalizing 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 finalizing an optional standard whereby
manufacturers would elect to have designated engine families meet a
standard of 3 percent reduction from their 2011 baseline emission and
fuel consumption levels for that engine family or engine subcategory.
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. In the NPRM, we solicited comment on
extending this alternative (See 75 FR at 74202). As explained earlier,
we have decided not to allow the alternative standard to continue 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 final 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, as proposed, 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 also 75 FR 25417-25419 (similar approach for
vehicles which are part of Temporary Lead Time Allowance under the
light-duty vehicle rule). We are finalizing that manufacturers can
select engine families for this alternative standard without agency
approval, but are requiring that manufacturers notify the agency of
their choice and also requiring manufacturers 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) ther Engine Standards Considered
The agencies are not finalizing engine standards less stringent
than the final standards because the agencies believe these final
standards are appropriate, highly cost effective, and technologically
feasible, as just described.
The agencies considered finalizing engine standards which are more
stringent. Since the final standards reflect 100 percent utilization of
the various technology packages, some additional technology would have
to be added. The agencies are finalizing 2017 model year standards
based on the use of turbocompounding. As discussed above in Section
III.A.2.b.iii, 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 finalizing
this level of stringency because our assessment is that these
technologies would not be available for production by the 2017 model
year.
B. Heavy-Duty Pickup Trucks and Vans
This section describes the process the agencies used to develop the
standards the agencies are finalizing 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
\245\ 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.\246\
---------------------------------------------------------------------------
\245\ http://www.epa.gov/otaq/certdata.htm.
\246\ 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 be used to model
emissions and fuel consumption from a truck of the same basic body
design, but with four-wheel drive, a 4.10:1 axle ratio, and 8,500 lb
test weight. The adjustment factors are
[[Page 57219]]
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.\247\
---------------------------------------------------------------------------
\247\ 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 final 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,\248\ 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).
---------------------------------------------------------------------------
\248\ See Section III.B(2)(a) for our response to comments
arguing for inclusion of this technology in the list of technologies
needed to meet the standards.
---------------------------------------------------------------------------
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 final 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
final standards.
Since the manufacturers of HD pickups and vans generally only have
one basic pickup 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
final standards would be feasible and appropriate by the 2018 model
year.
Although we did not determine a technological need for less than
full implementation of any technology, 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 finalizing, 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.
The final 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.\249\ By expressing the final 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 program affords manufacturers
substantial flexibility to satisfy the phase-in through a variety of
pathways, among them, 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.
---------------------------------------------------------------------------
\249\ The NHTSA program provides voluntary standards for model
years 2014 and 2015. NHTSA and EPA are also providing 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 time frame, 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 consumption benefits, but we recognize that
there is uncertainty at this time over the cost-effectiveness of these
systems in heavy-duty applications, and legitimate concern with
customer
[[Page 57220]]
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 time
frame, 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 final standards are premised are clearly available at
reasonable cost in the 2014-2018 time frame, 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 final standards. Our basis for these estimates is
described in the following Section 0. 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.
(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. Several of the technologies have already
been introduced into the heavy-duty pickup and van market (i.e.,
variable valve timing, improved accessories, etc.) in a limited number
of applications. 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 final action.
The agencies received comments regarding applicability of certain
advanced technologies described in the TIAX 2009 report submitted to
NAS. Specifically mentioned were turbocharging and downsizing of
gasoline vehicles and hydraulic hybrid systems. While turbocharging and
downsizing of gasoline vehicles was a principal technology underlying
the standards in the light-duty rule, the agencies determined that in
the realm of heavy-duty vehicles, this approach provides much less
benefit to vehicles which are required to regularly operate at high and
sustained loads. In light-duty applications, downsizing of a typically
oversized engine largely results in benefits mainly under partial and
light load conditions. This approach is more applicable to light-duty
vehicles because they infrequently require high or full power. Further,
while turbo downsizing was already occurring in a portion of the light-
duty fleet, it has not been demonstrated in the heavy-duty fleet,
likely due to concerns with durability of this technology in the
sustained high-load duty cycles frequently encountered. Similarly,
other light-duty technologies (i.e., cylinder deactivation, engine
start stop) were also determined to not be compatible with the duty
cycle of heavy-duty vehicles for similar reasons. Due to the relatively
aggressive implementation of this program and the lack of
commercialization in the heavy-duty market, hydraulic hybrid systems
were not considered a technology that could be implemented in the time
frame of this program for the HD pickup and van sector. The fact that
no HD pickup or van hydraulic hybrids have been, or are the verge of
being marketed makes their widespread introduction before the MY 2018
final year of the phase-in very unlikely.
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 final
standards on a targeted switch in the mix of diesel and gasoline
vehicles. We believe our final standards require similar levels of
technology development and cost for both diesel and gasoline vehicles.
Hence the final 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 finalizing
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 lubricants 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.
[[Page 57221]]
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.
Six-, seven-, and eight-speed automatic transmissions--the
gear ratio spacing and transmission ratio are optimized for a broader
range of engine operating conditions specific to the mating engine.
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 program.
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.\250\
---------------------------------------------------------------------------
\250\ See RIA Chapter 2.3 for more detailed technology
descriptions.
---------------------------------------------------------------------------
(2) How did the agencies determine the costs and effectiveness of each
of these technologies?
Building on the technical analysis underlying the light-duty 2012-
2016 MY vehicle rule, the agencies took a fresh look at technology cost
and effectiveness values for purposes of this final action. 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.\251\
---------------------------------------------------------------------------
\251\ 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 2009 dollars using a ratio of gross domestic
product (GDP) values for the associated calendar years,\252\ and
indirect costs were accounted for using the new approach developed by
EPA and used in the light-duty 2012-2016 MY vehicle 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.
---------------------------------------------------------------------------
\252\ 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 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
[[Page 57222]]
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 (and individual
vehicles) might obtain from adding a fuel-saving technology.
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.
(a) Engine Technologies
NHTSA and EPA have reviewed the engine technology estimates used in
the 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 program.
(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 light-duty 2012-2016 MY 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 2009 dollars using the GDP price deflator and have used a
markup of 1.24 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.253 254
---------------------------------------------------------------------------
\253\ 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. The markups are also
higher than those used the in proposal for this action. That change
has to do with our decision to base the ICMs solely on EPA internal
work rather than averaging that work with earlier work done under
contract to EPA by RTI, International. That change is discussed in
Section VIII.C of this preamble and is detailed in Chapter 2 of the
RIA (See RIA 2.2.1)
\254\ 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.\255\ 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.
---------------------------------------------------------------------------
\255\ ``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 light-duty 2012-2106 MY vehicle 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 light-duty rule, the agencies estimate the cost
of this technology at $15 per cylinder compliance cost (2008$),
including the low complexity ICM markup value of 1.24. 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. 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. Based on the light-duty 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
[[Page 57223]]
and EPA reviewed this estimate for purposes of the NPRM, and continue
to find it accurate.
The agencies received comments questioning the exclusion of cam
phasing from the technology packages. During the rulemaking process,
manufacturers introduced many new or updated gasoline engines resulting
in the majority of the 2010 gasoline heavy-duty engines including cam
phasing, and so we now consider this technology to be in the baseline
fleet. Because of this, the baseline analysis of technology for the
2010 heavy-duty gasoline fleet already includes the benefits of cam
phasing and therefore it is not appropriate for the agencies to include
this as a technology that is available for most manufactures to add to
their current gasoline engines.
(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 a range in 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 light-duty 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. For heavy-
duty vehicles tested and operated at loaded conditions, the power to
weight ratio is considerably lower than the light-duty case greatly
reducing the opportunity for ``part-cylinder'' mode and therefore was
not considered in this rulemaking as an effective technology for heavy-
duty pickup truck and van applications.
(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 light-duty 2012-2016 MY vehicle 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 light-duty 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 $481 (2009$) in the 2014 model year. Flat-portion of the curve
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.\256\ 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.
---------------------------------------------------------------------------
\256\ 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 time frame. 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
light-duty rule. Based on confidential business information,
[[Page 57224]]
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 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 $119 (2009$) for a 2014
model year truck or van. This estimate includes a low complexity ICM of
1.24 and flat-portion of the curve 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 time
frame. These improvements include items such as improved combustion
management, optimal turbocharger design, and improved thermal
management. This technology was not considered in the light-duty 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 $148 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, $95. All values are in 2009 dollars and
are applicable in the 2014 MY. Applying a low complexity ICM of 1.24
results in a cost of $184 (2009$) applicable in the 2014 MY. We
consider flat-portion of the curve learning to be appropriate for these
technologies.
(c) Transmission Technologies
NHTSA and EPA have also reviewed the transmission technology
estimates used in the light-duty 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 the final standards.
(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 time frame.
(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 or busy 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 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.\257\
---------------------------------------------------------------------------
\257\ 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 percent and a conversion from a 6- to 8-speed transmission to be
1.7 percent. While 8-speed transmissions were not considered in the
light-duty 2012-2016 MY vehicle 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
time frame. We are estimating the cost of an 8-speed automatic
transmission at $281 (2009$) 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 1.24 and
flat-portion of the curve learning. This technology applies to both
gasoline and diesel pickup 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
[[Page 57225]]
hydraulic power steering because of reduced overall accessory loads.
This eliminates the parasitic losses 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 light-duty rule estimated a one to two 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 1.24, the estimated costs are $115 for a MY
2014 truck or van (2009$). As EPS systems are in widespread usage
today, flat-portion of the curve 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 the pumping accessories electrically, and only when needed
(``on-demand''). Alternator improvements include internal changes
resulting in lower mechanical and electrical losses combined with
control logic that charges the battery at more efficient voltage levels
and during conditions of available kinetic energy from the vehicle
which would normally be wasted energy such as braking during vehicle
decelerations.
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.\258\
---------------------------------------------------------------------------
\258\ In the CAFE model, improved accessories refer 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.
NHTSA and EPA jointly reviewed the estimates of 1 to 2 percent
effectiveness estimates used in the light-duty rule and found them to
be accurate for Improved Electrical Accessories. Consistent with the
light-duty rule, the agencies have estimated the cost of this
technology at $93 (2009$) including a low complexity ICM of 1.24. This
cost is applicable in the 2014 model year. Improved accessory systems
are in production currently and thus flat-portion of the curve learning
is applied. This technology was considered for diesel pickup 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.'' \259\ 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.\260\ 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
[[Page 57226]]
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.
---------------------------------------------------------------------------
\259\ ``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.
\260\ ``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.
---------------------------------------------------------------------------
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 light-duty vehicle
when all subsystems are redesigned to take into account the initial
primary weight savings.261 262
---------------------------------------------------------------------------
\261\ ``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.
\262\ ``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 final 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 percent by
2015.\263\ 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.\264\ Mazda plans to
reduce vehicle weight by 220 pounds per vehicle or more as models are
redesigned.265 266 Ducker International estimates that the
average curb weight of light-duty vehicle fleet will decrease
approximately 2.8 percent from 2009 to 2015 and approximately 6.5
percent 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.\263\ 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 and systems necessary for the work vehicle aspects.
---------------------------------------------------------------------------
\263\ ``Lighten Up!,'' Brooke, L., Evans, H. Automotive
Engineering International, Vol. 117, No. 3, March 2009.
\264\ ``2008/9 Blueprint for Sustainability,'' Ford Motor
Company. Available at: http://www.ford.com/go/sustainability (last
accessed February 8, 2010).
\265\ ``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).
\266\ ``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 and 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
percent of the light-duty rule values due to the elimination of engine
downsizing for this class of vehicle.
In the NPRM, EPA and NHTSA relied on three studies to estimate the
cost of vehicle mass reduction. The agencies used a value of $1.32 per
pound of mass reduction that was derived from a 2002 National Academy
of Sciences study, a 2008 Sierra Research report, and a 2008 MIT study.
The cost was estimated to be constant, independent of the level of mass
reduction.
The agencies along with the California Air Resources Board (CARB)
have recently completed work on an Interim Joint Technical Assessment
Report (TAR) that considers light-duty GHG and fuel economy standards
for model years 2017 through 2025 and have continued this work to
support the light-duty vehicle NPRM, which is expected to be issued
this fall. Based on new information from various industry and
literature sources, the TAR modified the mass reduction/cost
relationship used in the light-duty 2012-2016 MY vehicle rule to begin
at the origin (zero cost at zero percent mass reduction) and to have
increasing cost with increasing mass reduction.\267\ The resulting
analysis showed costs for 5 percent mass reduction on light-duty
vehicles to be near zero or cost parity.
---------------------------------------------------------------------------
\267\ ``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.
---------------------------------------------------------------------------
In the proposal for heavy-duty vehicles, we estimated mass
reduction costs based on the 2012-2016 light-duty analysis without
accounting for the new work completed in the Interim Joint Technical
Assessment and additional
[[Page 57227]]
work the agencies have considered for the upcoming light-duty vehicle
NPRM. Since the heavy-duty vehicle proposal, the agencies have been
able to consider updated cost estimates in the context of both light-
duty and heavy-duty vehicle bodies of work. While the agencies intend
to discuss the additional work for the light-duty NPRM in much more
detail in the documents for that rulemaking, we think it appropriate to
explain here that after having considered a number of additional and
highly-varying sources, the agencies believe that the cost estimates
used in the TAR may have been lower than would be reasonable for HD
pickups and vans, given their different and work-related uses and thus
different construction as compared to the light-duty vehicles evaluated
in the TAR. We do not believe that all of the weight reduction
opportunities for light-duty vehicles can be applied to heavy-duty
trucks. However, we do believe reductions in the following components
and systems can be found that do not affect the payload and towing
requirements of these heavy-duty vehicles: Body, closure panels,
glazing, seats and other interior components, engine cooling systems
and HVAC systems.
The agencies have reviewed and considered many different mass
reduction studies during the technical assessment for the heavy-duty
vehicle GHG and fuel efficiency rulemaking. The agencies found that
many of the studies on this topic vary considerably in their rigor,
transparency, and applicability to the regulatory assessment. Having
considered a variety of options, the agencies for this heavy-duty
analysis have been unable to come up with a way to quantitatively
evaluate the available studies. Therefore, the agencies have chosen a
value within the range of the available studies that the agencies
believe is reasonable. The studies and manufacturers' confidential
business information relied upon in determining the final mass
reduction costs are summarized in Figure 2.1, Section 2.3.6 of the RIA.
Each study relied upon by the agencies in this determination has also
been placed in the agencies' respective dockets. See NHTSA-2010-0079;
EPA-HQ-0AR-2010-0162.
The agencies note that the NAS 2010 study provided estimates of
mass reduction costs, but the agencies did not consider using the NAS
2010 study as the single source of mass reduction cost estimates
because the NAS 2010 estimates were not based on literature reports
that focused on trucks or were necessarily appropriate for MD/HD
vehicles, and also because a variety of newer and more rigorous studies
were available to the agencies than those relied upon by the NAS in
developing its estimates. We note, however, that for a 5 percent
reduction in mass, the NAS 2010 report estimates a per pound cost of
mass reduction of $1.65.
Thus, we are estimating the direct manufacturing costs for a 5
percent mass reduction of a 6,000 lb vehicle at a range of $75-$90 per
vehicle. With additional margin for uncertainty, we arrive at a direct
manufacturing cost of $85-$100, which is roughly in the upper middle of
the range of values that resulted from the additional and highly-
varying studies mentioned above that were considered in the agencies'
review. We have broken this down for application to HD pickup trucks
and vans as follows: Class 2b gasoline $85, Class 2b diesel $95, Class
3 gasoline $90, and Class 3 diesel trucks $100. Applying the low
complexity ICM of 1.24 results in estimated total costs for a 5 percent
mass reduction applicable in the 2016 model year as follows: Class 2b
gasoline $108, Class 2b diesel $121, Class 3 gasoline $115, and Class 3
diesel trucks $127. All mass reduction costs stated here are in 2009
dollars.
(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 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 light-duty rule.
Based on the light-duty rule and the 2010 NAS Report, the agencies
have estimated the cost for LRR tires to be $7 per Class 2b truck or
van, and $10 per Class 3 truck or van (both values in 2009$ and
inclusive of a 1.24 low complexity markup).\268\ 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 reductions due to learning are not applied.
This technology is considered applicable to both gasoline and diesel.
---------------------------------------------------------------------------
\268\ ``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 are 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 light-duty 2012-2016 MY vehicle 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 light-duty rule, the agencies have estimated
the cost for this technology at $58 (2009$) including a low complexity
ICM of 1.24. This cost is applicable in the 2014 model year to
[[Page 57228]]
both gasoline and diesel pickup trucks and vans.
(3) What are the projected technology packages' effectiveness and cost?
The assessment of the final 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 final 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 final 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.
Table III-11--Technology Costs for HD Pickup Trucks & Vans Inclusive of Indirect Cost Markups for the 2014MY
[2009$]
----------------------------------------------------------------------------------------------------------------
Class 2b Class 2b Class 3 Class 3
Technology gasoline diesel gasoline diesel
----------------------------------------------------------------------------------------------------------------
Low friction lubes.......................................... $4 $4 $4 $4
Engine friction reduction................................... 116 N/A 116 N/A
Stoichiometric gasoline direct injection.................... 481 N/A 481 N/A
Engine improvements......................................... N/A 184 N/A 184
8s automatic transmission (increment to 6s automatic 281 281 281 281
transmission)..............................................
Improved accessories........................................ N/A 93 N/A 93
Low rolling resistance tires................................ 7 7 10 10
Aerodynamic improvements.................................... 58 58 58 58
Electric (or electro/hydraulic) power steering.............. 115 115 115 115
Aftertreatment improvements................................. N/A 119 N/A 119
Mass reduction (5%)......................................... 108 121 115 127
Air conditioning............................................ 21 21 21 21
Total................................................... 1,190 1,003 1,209 1,013
---------------------------------------------------
At 15% phase-in in 2014..................................... 179 150 180 152
----------------------------------------------------------------------------------------------------------------
(4) Reasonableness of the Final Standards
The final 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 RIA Chapter
2.3. These controls are estimated to add costs of approximately $1,048
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
18 MMT of CO2eq emissions over the lifetimes of 2014 through
2018 MY vehicles.\269\ The reductions are cost effective, estimated at
$90 per ton of CO2eq removed in 2030.\270\ 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 -$230 per ton of CO2eq (i.e. a savings of $230
per ton) in 2030. The cost of controls is fully recovered due to the
associated fuel savings, with a payback period in the second year of
ownership, as shown in Table VIII-9 below in Section VIII. 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 final 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). Based on the discussion
above, NHTSA believes these standards are the maximum feasible under
EISA.
---------------------------------------------------------------------------
\269\ See Table VI-4 of this preamble.
\270\ See Table 0-3 of this preamble.
---------------------------------------------------------------------------
(5) Alternative HD Pickup Truck and Van Standards Considered
The agencies rejected consideration of any less stringent standards
given that the standards adopted are feasible at reasonable cost and
cost-effectiveness within the lead time of the program. Furthermore, as
explained above, because the standards are premised on 100 percent
application of available technologies during this period, the agencies
rejected adoption of more stringent standards. The agencies have also
explained above why the phase-in period for the standards is reasonable
and that attempting more aggressive phase-ins would start to force
changes outside normal redesign cycles at likely exorbitant cost.
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 entities such as
body builders. These factors create special sensitivity to
[[Page 57229]]
concerns of needed lead time, as well as developing standards that do
not interfere with vocational vehicles' utility. The agencies are
adopting a standard for vocational vehicles for the first phase of the
program that relies on less extensive addition of technology than do
the other regulatory categories as well as making the chassis
manufacturer the manufacturer subject to the standard. We intend that
future rulemakings will consider increased stringency and possibly more
application-specific standards. The agencies are also finalizing
standards for the diesel and gasoline engines installed in vocational
vehicles, similar to those discussed above for HD engines installed in
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 final 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 engines--while spark ignition (or
``gasoline'') engines are a single regulatory subcategory (an approach
for which there was consensus in the public comments). 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 combination 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 combination
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.\271\
---------------------------------------------------------------------------
\271\ 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 time frame.\272\ The agencies estimate that average
rolling resistance from tires in 2010 model year can be reduced by 10
percent for 50 percent of the vehicles by 2014 model year based on the
tire development achievements over the last several years in the line
haul truck market.
---------------------------------------------------------------------------
\272\ See 2010 NAS Report, Note 197, page 146.
---------------------------------------------------------------------------
Aerodynamics: The Argonne National lab work shows that aerodynamics
has 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
vehicle. The agencies are not regulating body builders in this phase of
regulations for the reasons discussed in Section II. Therefore, we are
not basing any of the final 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
final vocational vehicle standards on use of vehicle weight reduction.
Thus, vehicle mass reductions are not an input into GEM. The agencies
are taking this approach despite comments suggesting that the agencies
make use of weight reductions for this segment, because we are unable
to quantify the potential impact of weight reduction on vehicle utility
in this broad segment. Vocational vehicles serve an incredibly diverse
range of functions. Each of these unique vehicle functions is likely to
have its own unique tradeoff between vehicle utility and the potential
for vehicle mass reduction. The agencies have not been able at this
time to determine the degree to which such tradeoffs exist nor the
specific level of the tradeoff for each unique vehicle vocation. No
commenter provided data to inform this question. Absent this
information, the agencies cannot at this time project the potential for
worthwhile weight reductions from vocational vehicles.
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
time frame ranged between 2 and 8 percent.\273\ 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 manual and automatic
transmissions for tractors). We have however decided not to do so for
the following reasons.
---------------------------------------------------------------------------
\273\ See 2010 NAS Report, Note 197, 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
[[Page 57230]]
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 finalizing to reflect transmission and
gear ratio optimization in our GEM or in our standard setting.
Some commenters suggested that the agencies predicate the
vocational vehicle standard on the use of specific transmission
technologies for example automated manual transmissions believing that
these mechanically more efficient designs would inherently provide
better fuel efficiency and lower greenhouse gas emissions than
conventional torque convertor automatic transmission designs. However
as discussed above the agencies believe that the small mechanical
efficiency differences between these transmission designs are
relatively insignificant in the context of the dominant impact of
proper gear ratio selection in determining a vehicle's overall
performance. In many cases, the mechanically more efficient design may
prove less effective in use if other aspects of vehicle performance
(such a vehicle launch under load) compromise the selection of gear
ratios. This somewhat surprising outcome can be seen most readily by
looking at modern passenger cars where mechanically less efficient
torque converter automatic models often produce equal or better fuel
economy when compared to the more mechanically efficient manual
transmission versions of the same vehicles. Given this reality, we do
not believe it would be appropriate to base the vocational truck
standard on the use of a particular transmission technology. In the
future, if we develop a complete vehicle chassis test approach to
regulating this segment, we would then be able to incorporate
transmission performance as we already do for the heavy-duty pickup
truck and van segment.
Idle Reduction: Episodic idling by vocational vehicles occurs
during the workday, unlike the overnight idling of combination tractors
(see discussion in Section III.A.2.a). 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.\274\ 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.\275\ The use of
hybrid powertrains to reduce idling is discussed below.
---------------------------------------------------------------------------
\274\ Gaines, Linda, A. Vyas, J. Anderson (Argonne National
Laboratory). Estimation of Fuel Use by Idling Commercial Trucks.
January 2006.
\275\ Southwest Research Institute. Power Take Off Cycle
Development and Testing. 2010. Docket EPA-HQ-OAR-2010-0162-3335.
---------------------------------------------------------------------------
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 many
variations of hybrid powertrain systems. 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. 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 time frame--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 hopes for future advancements in hybrid
technologies to encourage their production through incentives. Thus, to
create an incentive for early introduction of hybrid powertrains into
the vocational vehicle fleet, the agencies are adopting the proposed
advanced technology credits if hybrid powertrains are used as a
technology to meet the vocational vehicle standard (or any other
vehicle standard), as described in Section IV.
(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 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 light-duty 2012-
2016 MY vehicle rule, the agencies took a fresh look at technology
effectiveness values for purposes of this analysis using as 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
[[Page 57231]]
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 final rulemaking, 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.
Baseline Engine: Similar to the gasoline engine used as the
baseline in the light-duty rule, the agencies assumed the baseline
engine in this segment to be a naturally aspirated, overhead valve V8
engine.\276\ The agencies did not receive any comments regarding the
baseline engine assumptions in the proposal. The following discussion
of effectiveness is generally in comparison to 2010 baseline engine
performance.
---------------------------------------------------------------------------
\276\ The agencies note that baseline did not include coupled
cam phasing for loose HD gasoline engines. The HD loose engines are
slightly different than the ones used in the HD pickup trucks. They
tend to be the older versions of the same engine.
---------------------------------------------------------------------------
For the final rulemaking, the agencies considered the same set of
technologies for loose gasoline engines at proposal. The agencies
received comments which suggested that the agencies consider
electrification of accessories to reduce the fuel consumption and
CO2 emissions from heavy-duty gasoline engines.
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. However, technologies
such as these improvements to accessories are not demonstrated using
the engine dynamometer test procedures being adopted in this final rule
because those systems are not installed on the engine during the
testing. Thus, 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 \277\ and
EEA \278\ 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.
---------------------------------------------------------------------------
\277\ Northeast States Center for a Clean Air Future. ``Reducing
Greenhouse Gas Emissions from Light-Duty Motor Vehicles.'' September
2004.
\278\ 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 light-duty 2012-2016
MY 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 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. Cylinder
deactivation is less effective on heavily-loaded vehicles because they
require more power and spend less time in areas of operation where only
partial power is required. The technology also requires proper
integration into the vehicles which is difficult in the vocational
vehicle segment where often the engine is sold to a chassis
manufacturer or body builder without knowing the type of transmission
or axle used in the vehicle or the precise duty cycle of the vehicle.
The cylinder deactivation requires fine tuning of the calibration as
the engine moves into and out of deactivation mode to achieve
acceptable NVH. Additionally, cylinder deactivation would be difficult
to apply to vehicles with a manual transmission because it requires
careful gear change control. NHTSA and EPA adjusted the 2012-16 MY
light-duty rule estimates using updated power to weight ratings of
heavy-duty trucks and confidential business information and downwardly
adjusted the effectiveness to 0 to 3 percent for these vehicles to
reflect the differences in drive cycle and operational opportunities
compared to light-duty vehicles. Because of the complexities associated
with integrating cylinder deactivation in a non-integrated vehicle
assembly process and the low effectiveness of the technology, the
agencies did not include cylinder deactivation in the final gasoline
engine technology package.
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 light-duty 2012-2016 MY vehicle rule estimated the
effectiveness
[[Page 57232]]
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 program. 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. As noted above in Section III.A.1.b, the agencies
received comments from Navistar stating that the agencies used an
artificially low baseline CO2 emissions level which was
tilted toward the use of SCR aftertreatment system. As discussed in
Section III.A.1.b, the agencies disagree with the statement that SCR is
infeasible. Additional responses from the agencies are available in the
Response to Comments document, Section 6.2.\279\ 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.
---------------------------------------------------------------------------
\279\ U.S. EPA. Greenhouse Gas Emissions Standards and Fuel
Efficiency Standards for Medium- and Heavy-Duty Engines and
Vehicles--EPA Response to Comments Document for Joint Rulemaking.
EPA-420-R-11-004. Docket EPA-HQ-OAR-2010-0162.
---------------------------------------------------------------------------
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
turbocompounding 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.\280\
---------------------------------------------------------------------------
\280\ See TIAX, Note 198, 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.\281\ 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.\282\ 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.
---------------------------------------------------------------------------
\281\ 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.
\282\ See TIAX, Note 198, pg. 4-9
---------------------------------------------------------------------------
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.\283\
---------------------------------------------------------------------------
\283\ See 2010 NAS Report, Note 197, 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.\284\
---------------------------------------------------------------------------
\284\ See TIAX. Note 198, Pages 3-5.
---------------------------------------------------------------------------
[[Page 57233]]
(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 the GEM, as
described in RIA Chapter 4.4.6. At proposal, the agencies used a
baseline rolling resistance coefficient for today's vocational vehicle
fleet of 9.0 kg/metric ton.\285\ As discussed in Section II.D.1, the
agencies conducted a tire rolling resistance evaluation of tires used
in vocational vehicles. The agencies found that the average rolling
resistance of the tires was lower than the agencies' assessment at
proposal. Based on this new information and our understanding of the
potential to improve tire rolling resistance by 2014, the agencies are
setting the vocational truck standard premised on the use of tires with
a rolling resistance coefficient of 7.7 kg/metric ton. This value is
consistent with the average performance of the subset of tires the
agencies tested. We are projecting this standard will drive a 5 percent
reduction in tire rolling resistance on average across the fleet. We
are projecting this 5 percent reduction based on our expectation that
manufacturers will desire to bring all of their tires below the
standard (not just comply on average) and knowing manufacturers will
need some degree of overcompliance to ensure despite manufacturing
variability and test to test variability their products are compliant
with the emission standards. In order to reflect both this tighter
standard (based on 7.7) and the 5 percent reduction in rolling
resistance we project it will accomplish, we are modeling the baseline
performance of vocational truck tires as 8.1 kg/metric ton.
---------------------------------------------------------------------------
\285\ 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. As noted above, further analysis has
resulted in an estimate of improved performance in the baseline
fleet, which is based entirely on use of LRR tires on vocational
vehicles (not cars). Additional details are available in the RIA
chapter 2.
---------------------------------------------------------------------------
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 RIA Chapter 4. Using these values, the
baseline performance of these vehicles is included in Table III-12.
The agencies note that the baseline performance derived for the
final rule slightly differs from the values derived for the NPRM. The
first difference is due to the change in rolling resistance from 9.0 to
8.1 kg/metric ton based on the agencies' post-proposal test results.
Second, there are minor differences in the fuel consumption and
CO2 emissions due to the small modifications made to the
GEM, as noted in RIA Chapter 4. In addition, the HHD vocational vehicle
baseline performance for the final rule uses a revised payload
assumption from 38,000 to 15,000 pounds, as described in Section
II.D.3.c.iii.
Table III-12--Baseline Vocational Vehicle Performance
------------------------------------------------------------------------
Vocational vehicle
------------------------------------------------------------------------
Medium heavy- Heavy heavy-
Heavy-duty duty duty
------------------------------------------------------------------------
Fuel Consumption Baseline 40.0 24.3 23.2
(gallon/1,000 ton-mile)......
CO2 Baseline (grams CO2/ton- 408 247 236
mile)........................
------------------------------------------------------------------------
(ii) Vocational Vehicle Technology Package
The final program for vocational vehicles for this phase of
regulatory standards is based on the 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) and Section II.D.
The assessment of the final technology effectiveness was developed
through the use of the GEM. To account for the two final engine
standards, EPA is finalizing the use of a 2014 model year fuel
consumption map in the 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 for HD diesel engines, not the alternative engine standards.)
The agencies estimate that the rolling resistance of 50 percent of the
tires can be reduced by 10 percent in the 2014 model year, for an
overall reduction in rolling resistance of 5 percent. The vocational
vehicle standards for all three regulatory categories were determined
using a tire rolling resistance coefficient of 7.7 kg/metric ton in the
2014 model year. The set of input parameters which are modeled in GEM
are shown in Table III-13.
Table III-13--GEM Inputs for Final Vocational Vehicle Standards
----------------------------------------------------------------------------------------------------------------
2014 MY 2017 MY
----------------------------------------------------------------------------------------------------------------
Engine...................................................... 2014 MY 7L for LHD/MHD 2017 MY 7L for LHD/MHD
and 15L for HHD Trucks and 15L for HHD Trucks.
Tire Rolling Resistance (kg/metric ton)..................... 7.7 7.7
----------------------------------------------------------------------------------------------------------------
The agencies developed the final 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.
[[Page 57234]]
Table III-14--Final Vocational Vehicle Standards and Percent Reductions
----------------------------------------------------------------------------------------------------------------
Vocational vehicle
-----------------------------------------------
Light heavy- Medium heavy- Heavy heavy-
duty duty duty
----------------------------------------------------------------------------------------------------------------
2016 MY Fuel Consumption Standard (gallon/1,000 ton-mile)....... 38.1 23.0 22.2
2017 MY Fuel Consumption Standard (gallon/1,000 ton-mile)....... 36.7 22.1 21.8
2014 MY CO2 Standard (grams CO2/ton-mile)....................... 388 234 226
2017 MY CO2 Standard (grams CO2/ton-mile)....................... 373 225 222
Percent Reduction from 2010 baseline in 2014 MY................. 5% 5% 4%
Percent Reduction from 2010 baseline in 2017 MY................. 8% 9% 6%
----------------------------------------------------------------------------------------------------------------
(iii) Technology Package Cost
The agencies did not receive any substantial comments on the engine
costs proposed. Thus the agencies are projecting the costs of the
technologies used to develop the final standards based on the costs
used in the proposal, but revised to reflect 2009$, new ICMs, and a 50
percent penetration rate of low rolling resistance tires (as explained
above). EPA and NHTSA developed the costs of LRR tires based on the ICF
report. The estimated cost per truck is $81 (2009$) for LHD and MHD
trucks and $97 (2009$) for HHD trucks. These costs include a low
complexity ICM of 1.18 and are applicable in the 2014 model year.
(iv) Reasonableness of the Final Vocational Vehicle Standards
The final 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.\286\ 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.\287\ 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
final 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. Based on the discussion above, NHTSA believes
these standards are the maximum feasible under EISA.
---------------------------------------------------------------------------
\286\ See Section VIII.D.
\287\ As noted above, 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 finalizing vehicle standards less stringent
than the final standards because the agencies believe these standards
are highly cost effective, as just explained.
The agencies considered finalizing 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 RIA at chapter 6.1.8. The emission
reductions associated with these very high costs appear to be modest.
See the RIA Table 6-14. In addition, the agencies are finalizing
flexibilities in the form of generally applicable credit opportunities
for advanced technologies, to encourage use of hybrid powertrains. See
Section IV.C. 2 below. Several commenters recommended that in addition
to hybrid powertrains, the agencies consider setting more stringent
standards based on the use of aerodynamic improvements, weight
reduction, idle shutdown technologies, vehicle speed limiters, and
specific transmission technologies. As described above, we are not
finalizing standards based on these technologies for reasons that
related to the unique nature of the very diverse vocational vehicle
segment. At this time, the agencies have no means to determine the
current baseline aerodynamic performance of all vocational vehicles
(ranging from concrete mixers to school buses), nor a means to project
to what degree the aerodynamic performance could be improved without
compromising the utility of the vehicle. Absent this information, the
agencies cannot set a standard based on improvements in aerodynamic
performance. The agencies face similar obstacles regarding our ability
to project the utility tradeoffs that may exist between limitations on
vehicle speed or reductions in vehicle mass and utility and safety of
vocational vehicles. We are confident the answer to those questions
will differ for a school bus compared to a concrete mixer compared to a
fire truck compared to an ambulance. Absent an approach to set distinct
standards for each of the vocational vehicle types and the information
necessary to determine the appropriate level of performance for those
vehicles, the agencies cannot set standards for vocational vehicles
based on the use of these technologies. For these reasons, the agencies
are not adopting more comprehensive standards for vocational vehicles.
The agencies do agree that at least some vocational vehicles can be
made more efficient through the use of technologies, including those
technologies mentioned in the comments, and the agencies fully intend
to take on the challenge of developing the data, test procedures and
regulatory structures necessary to set more comprehensive standards for
vocational trucks in the future.
(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 0.20 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
[[Page 57235]]
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 percent
application rate of 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 are adopting gasoline engine standards
that begin in the 2016 model year based on the agencies' projection of
the engine redesign schedules for the small number of engines in this
category.
(iii) Gasoline Engine Technology Package Cost
For the proposed 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 BOM
approach employed by NHTSA and EPA in the light-duty 2012-2016 MY
vehicle rule. In this final action, the agencies are using marked up
gasoline engine technology costs developed for the HD Pickup Truck and
Van segment because these engines are made by the same manufacturers
(primarily by Ford and GM) and are simply, sold as loose engines rather
than as complete vehicles. Hence the engine cost estimates are
fundamentally the same. The agencies did not receive any comments
recommending adjustments to the proposed gasoline engine technology
costs. The costs summarized in Table III-15 are consistent with the
proposed values, but updated to reflect 2009$ and new ICMs. The costs
shown in Table III-15 include a low complexity ICM of 1.24 and are
applicable in the 2016 model year. No learning effects are applied to
engine friction reduction costs, while flat-portion of the curve
learning is considered applicable to both coupled cam phasing and SGDI.
Table III-15--Heavy-Duty Gasoline Engine Technology Costs Inclusive of
Indirect Cost Markups
[2009$]
------------------------------------------------------------------------
2016 MY
------------------------------------------------------------------------
Engine Friction Reduction.................................... $95
Coupled Cam Phasing.......................................... 46
Stoichiometric Gas Direct Injection.......................... 452
----------
Total.................................................... 594
------------------------------------------------------------------------
(iv) Reasonableness of the Final Standard
The final engine standards are 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 final
standards reflect 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 0-15. Use of these
technologies would add only a small amount to the cost of the
vehicle,\288\ and the associated reductions are highly cost effective,
an estimated $20 per ton of CO2eq per vehicle.\289\ 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.\290\ 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). Based on the discussion above,
NHTSA believes these standards are the maximum feasible under EISA.
---------------------------------------------------------------------------
\288\ 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.
\289\ See Vocational Vehicle CO2 savings and
technology costs in Table 7-4 in RIA chapter 7.
\290\ 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.
---------------------------------------------------------------------------
Several commenters suggested that the lead time provided by the
agencies for heavy-duty pickups and vans and by extension the 2016
gasoline engine standards were unnecessarily long. The agencies do not
agree with this assessment. The technologies that we are considering
here cannot simply be bolted on to an existing engine but can only be
effectively applied through an integrated design and development
process. The four years lead time provided here is short in the context
of engine redesigns and is only possible in part because the standards
align with engine manufacturers' planned redesign processes that are
either just starting or will be starting within the year. These
standards set a clear metric of performance for those planned redesigns
and we project will lead manufacturers to include a number of
technologies that would not otherwise have been incorporated into those
engines.
(v) Alternative Gasoline Engine Standards Considered
The agencies are not finalizing gasoline standards less stringent
than the final standards because the agencies believe these standards
are feasible in the lead time provided, inexpensive, and highly cost
effective.
The final 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 finalizing gasoline engine standards which are more
stringent reflecting the inclusion of cylinder deactivation and other
advanced technologies. However, the agencies are not finalizing this
level of stringency because our assessment is that these technologies
cannot be adapted to the higher average engine loads of heavy-duty
vehicles for production by the 2017 model year. We intend to continue
to evaluate the potential for further gasoline engine improvements
building on the work done for light-duty passenger cars and trucks as
we begin work on the next phase of heavy-duty regulations.
(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 0.20 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
[[Page 57236]]
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 RIA Chapter 2.
Table III-16--2010 Model Year Reference Diesel Engine Performance Over
the Heavy-Duty FTP Cycle
------------------------------------------------------------------------
CO2 emissions (g/ Fuel consumption
bhp-hr) (gallon/100 bhp-hr)
------------------------------------------------------------------------
LHD Diesel.................. 630 6.19
MHD Diesel.................. 630 6.19
HHD Diesel.................. 584 5.74
------------------------------------------------------------------------
(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 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 final 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
finalizing CO2 emission standards recognizing the
opportunity for technology improvements over this time frame while
reflecting the typical heavy-duty engine manufacturer product plan
redesign cycles. Thus, the agencies are establishing initial standards
for the 2014 model year and a more stringent standard for these 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. 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 RIA Chapter 2.4.2.13. The agencies used a 100 percent
application rate of the technology package to determine the final 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.\291\ Therefore, these technologies were not
included in determining the stringency of the final standards. However,
we do believe the bottoming cycle approach represents a significant
opportunity to reduce fuel consumption and GHG emissions in the future
for vehicles that operate under primarily steady-state conditions like
line-haul tractors and some vocational vehicles. As discussed above, we
also considered setting standards based on the use of hybrid
powertrains that are a better match to many vocational vehicle duty
cycles but have decided for the reasons articulated above to not base
the vocational vehicle standard on the use of hybrid technologies in
this first regulation. However, EPA and NHTSA are both finalizing
provisions described in Section IV to create incentives for
manufacturers to continue to invest to develop these technologies in
the believe that with further development these technologies can form
the basis of future standards.
---------------------------------------------------------------------------
\291\ 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.
Table III-17--Percent Fuel Consumption and CO2 Emission Reductions Over
the Heavy-duty FTP Cycle
------------------------------------------------------------------------
2014 2017
------------------------------------------------------------------------
LHD Diesel............................................ 5% 9%
MHD Diesel............................................ 5 9
HHD Diesel............................................ 3 5
------------------------------------------------------------------------
(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 action (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 appropriate when compliance with
final 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
[[Page 57237]]
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 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 $6.8 million (2009$) per manufacturer per year
over the five years covering 2012 through 2016. In aggregate, this
averages out to $284 per engine during 2012 through 2016 using an
annual sales value of 600,000 light, medium, and heavy heavy-duty
engines. The agencies received comments from Horriba regarding the
assumption the agencies used in the proposal that said manufacturers
would need to purchase new equipment for measuring N2O and
the associated costs. Horriba provided information regarding the cost
of stand-alone FTIR instrumentation (estimated at $50,000 per unit) and
cost of upgrading existing emission measurement systems with NDIR
analyzers (estimated at $25,000 per unit). The agencies further
analyzed our assumptions along with Horriba's comments. Thus, we have
revised the equipment costs estimates and assumed that 75 percent of
manufacturers would update existing equipment while the other 25
percent would require new equipment. The agencies are estimating costs
of $63,087 (2009$) per engine manufacturer per engine subcategory
(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 less than $1 per engine in 2013 using an annual sales
value of 600,000 light, medium, and heavy HD engines.
EPA also developed the incremental piece cost for the components to
meet each the 2014 and 2017 standards. These costs shown in Table III-
18 which include a low complexity ICM of 1.15; flat-portion of the
curve learning is considered applicable to each technology.
Table III-18--Heavy-Duty Diesel Engine Component Costs Inclusive of
Indirect Cost Markups a
[2009$]
------------------------------------------------------------------------
2014 Model year 2017 Model year
------------------------------------------------------------------------
Cylinder Head (flow optimized, $6 (MHD & HH), $11 $6 (MHD & HHD),
increased firing pressure, (LHD). $10 (LHD).
improved thermal management).
Exhaust Manifold (flow $0................ $0.
optimized, improved thermal
management).
Turbocharger (improved $18............... $17.
efficiency).
EGR Cooler (improved efficiency) $4................ $3.
Water Pump (optimized, variable $91............... $84.
vane, variable speed).
Oil Pump (optimized)............ $5................ $4.
Fuel Pump (higher working $5................ $4.
pressure, increased efficiency,
improved pressure regulation).
Fuel Rail (higher working $10 (MHD & HHD), $9 (MHD & HHD),
pressure). $12 (LHD). $11 (LHD).
Fuel Injector (optimized, $11 (MHD & HHD), $10 (MHD & HHD),
improved multiple event $15 (LHD). $13 (LHD).
control, higher working
pressure).
Piston (reduced friction skirt, $3................ $3.
ring and pin).
Aftertreatment system (improved $0 (MHD & HHD), $0 (MHD & HHD),
effectiveness SCR, dosing, $111 (LHD). $101 (LHD).
dpf)a.
Valve Train (reduced friction, $82 (MHD), $109 $76 (MHD), $101
roller tappet). (LHD). (LHD).
------------------------------------------------------------------------
Note:
a Note that costs for aftertreatment improvements for MHD and HHD diesel
engines are covered via the engineering costs (see text). For LH
diesel engines, we have included the cost of aftertreatment
improvements as a technology cost.
The overall costs for each diesel engine regulatory subcategory are
included in Table III-19.
Table III-19--Diesel Engine Technology Costs per Engine
[2009$]
------------------------------------------------------------------------
2014 2017
------------------------------------------------------------------------
LHD Diesel............................................ $388 $358
MHD Diesel............................................ 234 216
HHD Diesel............................................ 234 216
------------------------------------------------------------------------
Reasonableness of the Final Standards
The final 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 are
based have already been demonstrated and their effectiveness is well
documented. The final standards reflect a 100 percent application rate
for these technologies.
[[Page 57238]]
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,\292\ and the
associated reductions are highly cost effective, an estimated $20 per
ton of CO2eq per vehicle.\293\ 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.\294\ 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). Based on the discussion above, NHTSA believes these
standards are the maximum feasible under EISA.
---------------------------------------------------------------------------
\292\ 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.
\293\ See RIA chapter 7, Table 7-4.
\294\ 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 option related to legacy engine products,
the agencies are not finalizing diesel engine standards less stringent
than the final standards because the agencies believe these standards
are highly cost effective.
The agencies have not considered finalizing diesel engine standards
which are more stringent because we have exhausted the list of engine
technologies that we believe are directly applicable to medium- and
heavy-duty diesel engines used in vocational applications. We are
continuing to evaluate the potential for bottoming cycle technologies
to be used in the future, however it is not clear today that this
technology, although promising for more steady-state operation will
provide any significant efficiency improvement under the more transient
operating cycles typical of vocational vehicles. Moreover, as stated at
II.D above, the agencies do not believe that this technology will be
available in the time frame of this rule in any case.
IV. Final Regulatory Flexibility Provisions
This section describes flexibility provisions intended to advance
the goals of the overall program while providing alternate pathways to
achieve those goals, consistent with the agencies' statutory authority,
as well as with Executive Order 13563.\295\ The primary flexibility
provisions for combination tractors and vocational vehicles and the
engines installed in these vehicles are incorporated in a program of
averaging, banking, and trading of credits. For HD pickups and vans,
the primary flexibility provision is also an ABT program expressed in
the fleet average form of the standards, along with provisions for
credit and deficit carry-forward and for trading, patterned after the
agencies' light-duty vehicle GHG and CAFE programs. Furthermore, EPA
will allow manufacturers to comply with the N2O and
CH4 standards using CO2 credits and is providing
an opportunity for engine manufacturers to earn N2O credits
that can be used to comply with the CO2 standards. However,
EPA is not adopting an emission credit program associated with the
CH4 or HFC standards. This section also describes other
flexibility provisions that apply, including advanced technology
credits, innovative technology credits and early compliance credits.
---------------------------------------------------------------------------
\295\ Section 4 of EO 13563 states that ``Where relevant,
feasible, and consistent with regulatory objectives, and to the
extent permitted by law, each agency shall identify and consider
regulatory approaches that reduce burdens and maintain flexibility
and freedom of choice for the public.'' 76 FR 3821 (Jan. 21, 2011).
---------------------------------------------------------------------------
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. NHTSA has also long
had an averaging and banking program for light-duty CAFE under EPCA,
and recently gained authority to add a trading program for light-duty
CAFE through EISA. ABT programs are useful because they can help to
address many issues of technological feasibility and lead-time, as well
as considerations of cost. They provide manufacturers flexibilities
that assist the efficient development and implementation of new
technologies and therefore enable new technologies to be implemented at
a more aggressive pace than without ABT. ABT programs are more than
just add-on provisions included to help reduce costs, and can be, as in
EPA's Title II programs an integral part of the standard setting
itself. A well-designed ABT program can also provide important
environmental and energy security benefits by increasing the speed at
which new technologies can be implemented (which means that more
benefits accrue over time than with slower-starting standards) and at
the same time increase flexibility for, and reduce costs to, the
regulated industry. American Council for an Energy-Efficient Economy
(ACEEE) has commented that ABT and related flexibilities should not be
offered for this program because the agencies are not promoting the use
of new technologies but rather the use of existing technologies.
However, without ABT provisions (and other related flexibilities),
standards would typically have to be numerically less stringent since
the numerical standard would have to be adjusted to accommodate issues
of feasibility and available lead time. See 75 FR at 25412-13. By
offering ABT credits and additional flexibilities the agencies can
offer progressively more stringent standards that help meet our fuel
consumption reduction and GHG emission goals at a faster pace.
Section II above describes EPA's GHG emission standards and NHTSA's
fuel consumption standards. For each of these respective sets of
standards, the agencies also offer ABT provisions, consistent with each
agency's statutory authority. The agencies worked closely to design
these 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 the GHG and fuel
consumption ABT program for HD engines was based closely on EPA's
earlier ABT programs for HD engines; the program for HD pickups and
vans was built on the existing light-duty GHG program flexibility
provisions; and the first-time ABT provisions for combination tractors
and vocational vehicles are as consistent as possible with EPA's other
HD vehicle regulations. The flexibility provisions associated with this
new regulatory category were intended to build systematically upon the
structure of the existing programs.
As an overview, ``averaging'' means the exchange of emission or
fuel consumption credits between engine families or truck families
within a given manufacturer's regulatory subcategories and averaging
sets. For example, specific ``engine families,'' which manufacturers
create by dividing their product lines into groups expected to have
similar emission characteristics throughout their useful life, would be
contained within an averaging set.
[[Page 57239]]
Averaging allows a manufacturer to certify one or more engine families
(or vehicle families, as appropriate) within the same averaging set at
levels worse than the applicable emission or fuel consumption standard.
The increased emissions or fuel consumption over the standard would
need to be offset by one or more engine (or vehicle) families within
that manufacturer's averaging set that are certified better than the
same emission or fuel consumption standard, such that the average
emissions or fuel consumption 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 or fuel
consumption standard \296\ Total credits for each averaging set within
each model year are determined by summing together the credits
calculated for every engine family within that specific averaging set.
---------------------------------------------------------------------------
\296\ The inclusion of engine power, useful life, and production
volume in the averaging calculations allows the emissions or fuel
consumption credits or debits to be expressed in total emissions or
consumption over the useful life of the credit-using or generating
engine sales.
---------------------------------------------------------------------------
``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 EPA's current HD engine program for criteria pollutants,
manufacturers are restricted to averaging, banking and trading only
credits generated by the engine families within a regulatory
subcategory, and EPA and NHTSA proposed to continue this restriction in
the GHG and fuel consumption program for engines and vehicles. However,
the agencies sought comment on potential alternative approaches in
which fewer restrictions are placed on the use of credits for
averaging, banking, and trading. Particularly, the agencies requested
comment on removing prohibitions on averaging and trading between some
or all regulatory categories in the 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).
The agencies received many comments on the restrictions proposed
for the ABT program, namely on the proposal that credits could only be
averaged within the specified vehicle and engine subcategories and not
averaged across subcategories or between vehicle and engine categories.
Many commenters, including Union of Concerned Scientist (UCS), NY Dept
of Transportation, Natural Resources Defense Council, Oshkosh, and
Autocar, requested that the agencies maintain the restrictions as
proposed in the NPRM. UCS argued that allowing credits to be used
across categories could undermine further technology advancements, and
that manufacturers that have broad portfolios would have advantages
over those manufacturers that do not. The Center for Biological
Diversity (CBD) argued that because of the various credit opportunities
in the ABT program and the potential that manufacturers will pay
penalties rather than comply with the standards, the program could
actually cause an increase in emissions and a decrease in fuel
efficiency. On the other hand, several commenters, including EMA/TMA,
Cummins, Volvo, and ATA, requested that the agencies maintain the
proposed restrictions of averaging credits between the engine and
vehicle categories, but reduce the restrictions on credit averaging
across vehicle subcategories or engine subcategories or averaging sets
within similar vehicle and engine weight classes (LHD, MHD and HHD).
Cummins requested that the agencies allow credit averaging between
engine subcategories within the same weight classes (LHD, MHD and HHD).
Cummins explained that tractor and vocational engines in the
corresponding weight classes not only share the same useful life but
also use the same emission and fuel consumption technologies and
therefore should be placed into the same engine averaging set. EMA/TMA
argued that the NPRM restrictions would inhibit a manufacturer's
ability to use credits to address market fluctuations, which would
reduce the flexibility that the ABT program was intended to provide. As
an example, EMA/TMA stated that if the line-haul market were depressed
for a period of time a manufacturer could make up any deficit selling
more low-roof tractors with regional hauling operations. The same
market shift could eliminate a manufacturer's ability to generate
credits using its aerodynamic high-roof sleeper cab tractors and could
create a credit deficit if there is a demand for more of the less
aerodynamic low-roof tractors. EMA/TMA argued that credit exchanges
across vehicle categories within the same weight classes within the
tractor subcategories and across vocational vehicle and tractor
subcategories would allow a manufacturer more flexibility to deal with
these types of market and customer demand situations. Finally, several
commenters, including Ford, DTNA NADA, NTEA and Navistar, requested
that the agencies reduce the proposed restrictions even further by
allowing credit averaging between vehicle categories and engine
categories. Navistar argued that more flexibility was necessary for
manufacturers like itself to increase innovation at a reasonable cost,
stating that more restrictions would increase costs within a shorter
time frame.
After considering these comments, the agencies continue to believe
that the ABT program developed by the agencies increases and
accelerates the technological feasibility of the GHG and fuel
consumption standards by providing manufacturers flexibility in
implementing new technologies in a way that may be more consistent with
their business practices and cost considerations. In response to the
comments submitted by CBD, the agencies disagree with CBD's statements
that the ABT program will adversely affect the fuel efficiency and GHG
emission goals of this regulation. This joint final action requires
vehicle and engine manufacturers to meet increasingly more stringent
emission and fuel consumption standards which will result in emission
reductions and fuel consumption savings. Manufacturers will not have
the option of not meeting the standards. The ABT program simply
provides each manufacturer the flexibility to meet these standards
based upon their individual products and implementation plans.
By assuming the use of credits for compliance, the agencies were
able to set the fuel consumption/GHG standards at more stringent levels
than would otherwise have been feasible. One reason is that use of ABT
allows each manufacturer maximum flexibility to develop compliance
strategies consistent with its redesign cycles and with its product
plans generally, allowing the agencies, in turn, to adopt standards
which are numerically more stringent in earlier model years than would
be possible with a more rigid program since those rigidities would be
associated with greater costs. Greater improvements in fuel efficiency
will occur under more stringent standards; manufacturers will simply
have greater flexibility to determine where and how to make those
improvements than they would have without credit options. Further, this
is consistent with the directive in EO 13563 to ``seek to identify, as
appropriate, means to
[[Page 57240]]
achieve regulatory goals that are designed to promote innovation.''
The agencies further agree that certain restrictions on use of ABT
which were proposed are unnecessary. The proposed ABT program for
engines was somewhat more restrictive, in its definition of averaging
sets, than EPA's parallel ABT program for criteria pollutant emissions
from the same engines. The final rules conform to the ABT provisions
for GHG heavy-duty engine emissions to be consistent with the parallel
ABT provisions for criteria pollutants with same weight engines treated
as a single averaging set regardless of the vehicles in which they are
installed. We have applied this same principle with respect to
combination tractors and vocational vehicles: Treating like weight
classes as an averaging set. The agencies have determined that these
additional flexibilities will help to reduce manufacturing costs
further and encourage technology implementation without creating an
unfair advantage for manufactures with vertically integrated portfolios
including engines and vehicles. EPA's experience in administering the
ABT program for heavy-duty diesel engine criteria pollutant emissions
supports this conclusion. Therefore, the agencies have decided to allow
credit averaging within and across vocational vehicle and tractor
subcategories within the same weight class groups, as well as credit
averaging across the same weight class vocational and tractor engine
groups. This added flexibility beyond what was proposed in the NPRM
will not be extended to the HD pickup truck and van category because
this group of vehicles is comprised of only one subcategory and is not
broken down like the other categories and corresponding subcategories
into different weight classes, and the standard applies to the entire
vehicle, so that there are no separate engine and vehicle standards.
Put another way, the HD pickup truck and van category is one large
averaging set that will remain as proposed.
However, the agencies are maintaining the restrictions against
averaging vehicle credits with engine credits or between vehicle weight
classes or engine subcategories for this first phase of regulation. We
believe averaging or trading credits between averaging sets would be
problematic because of the diversity of applications involved. This
diversity creates large differences in the real world conditions that
impact lifetime emissions--such as actual operating life, load cycles,
and maintenance practices. In lieu of conducting extensive and
burdensome real world tracking of these parameters, along with
corrective measures to provide some assurance of parity between credits
earned and credits redeemed, averaging sets provide a reasonable amount
of confidence that typical engines or vehicles within each set have
comparable enough real world experience to make such follow-up activity
unnecessary. The agencies believe this approach will ensure that
CO2 emissions are reduced and fuel consumption is improved
in each engine subcategory without interfering with the ability of
manufacturers to engage in free trade and competition. Again, EPA's
experience in administering its ABT program for criteria pollutant
emissions from heavy-duty diesel engines confirms these views. The
agencies also note that no commenter offered an explanation of why the
restrictions on this ABT program should differ from the parallel ABT
program respecting criteria pollutants. As explained earlier in this
preamble, the agencies intend to re-evaluate the appropriateness of the
ABT averaging sets and credit use restrictions we are adopting here for
the HD GHG and fuel consumption program in the future based on
information we gain implementing this first phase of regulation.
Under previous ABT programs for other rulemakings, EPA and NHTSA
have allowed manufacturers to carry forward credit deficits for a set
period of time--if a manufacturer cannot meet an applicable standard in
a given model year, it may make up its shortfall by overcomplying in a
subsequent year. In the NPRM the agencies proposed to allow
manufacturers of engines, tractors, HD pickups and vans, and vocational
vehicles to carry forward deficits for up to three years before
reconciling the shortfall--the same period allowed in numerous other
EPA rules--but sought comments on alternative approaches for
reconciling deficits. DTNA supported the three year period and stated
that it was sufficient for reconciling deficits. CBD did not support
the use of the carry forward of deficits because it would delay
investments and technological innovation. The agencies respectfully
disagree with CBD and believe this provision has enabled the agencies
to consider overall standards that are more stringent and that will
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. Therefore the agencies
included in the final rulemaking the proposed 3 year reconciliation
period. However, the agencies' respective credit programs require
manufacturers to use credits 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.
For the heavy-duty pickup and van category, the agencies proposed a
5-year credit life provision, as adopted in the light-duty vehicle GHG/
CAFE program. Navistar requested that the agencies drop the 5-year
credit expiration date proposed for the heavy-duty pickup and van
category and not specify an expiration date for earned credits.
Navistar stated that such credits are necessary to further improve the
flexibilities of this program in order to meet the new stringent
standards within the limited lead time provided. The agencies disagree.
The 5-year credit life is substantial, and allows credits earned early
in the phase-in to be held and used without discounting throughout the
phase-in period.
For engines, vocational vehicles and tractors, EPA also proposed
that CO2 credits generated during this first phase of the HD
National Program could not be used for later phases of standards, but
NHTSA did not expressly specify the potential expiration of fuel
consumption credits. DTNA and Cummins requested that the surplus
credits from the first phase of the program not expire. DTNA suggested
that the agencies drop any reference to credit expiration until the
next rulemaking, at which time the agencies would have a better
understanding of actual credit balances and what kind of lifespan for
credits might be necessary or appropriate. DTNA argued that in some of
EPA's past programs, EPA had delayed a final decision about credit
expiration until development of the subsequent rule when, EPA had a
better understanding of associated credit balances, along with the
stringency of the standards being proposed for future model years. EPA
had proposed to limit the lifespan of credits earned to the first phase
of standards in the interest of ensuring a level playing field before
the next phase begins. Upon further consideration, the agencies
recognize that this is a new program and it is unknown whether any
manufacturers will have credit surpluses by the end of the first phase
of standards, much less whether some manufacturers will have
significantly larger credit surpluses that might create an unlevel
playing field going into the next phase. The agencies
[[Page 57241]]
are adopting a 5-year credit life provision for all regulatory
categories, as adopted in the light-duty vehicle program and proposed
for the HD pickup trucks and vans.\297\
---------------------------------------------------------------------------
\297\ Note, however, that manufacturers have no property right
in these credits, so no issues of deprivation of property arise if
later rules choose not to recognize those credits. See 69 FR at
39001-002 (June 29, 2004).
---------------------------------------------------------------------------
The following sections provide further discussions of the
flexibilities provided in this action under the ABT program and the
agencies' rationale for providing them.
(1) Heavy-duty Engines
For the heavy-duty engine ABT program, EPA and NHTSA proposed to
use six averaging sets per 40 CFR 1036.740 for EPA and 49 CFR 535.7(d)
for NHTSA, which aligned with the proposed regulatory engine
subcategories. As described above, the agencies have decided that these
engine averaging sets should be the same as for criteria pollutants
under the EPA heavy-duty diesel engine rules, and agree with commenters
that increasing the size of averaging sets from within subcategories to
across subcategories within the same engine weight class would provide
important additional flexibilities for engine manufacturers without
negatively impacting fuel savings or emissions reductions. The agencies
are therefore adopting four engine averaging sets rather than the
proposed six. The four engine averaging sets are light heavy-duty (LHD)
diesel, medium heavy-duty (MHD) diesel, heavy heavy-duty (HHD) diesel,
and gasoline or spark ignited engines without distinction for the type
of vehicle in which the engine is installed. Thus, the final ABT
program will allow for averaging, banking, and trading of credits
between HHD diesel engines which are certified for use in vocational
vehicles and HHD diesel engines which are certified for installation in
tractors. Similarly, the MHD diesel engines certified for use in either
vocational vehicles or tractors will be treated as a single averaging
set. As noted in Section I.G above, the agencies intend to monitor this
program and consider possibilities of more widespread trading based on
experience in implementing the program as the first engines and
vehicles certified to the new standards are introduced. Credits
generated by engine manufacturers under this ABT program are restricted
for use only within their engine averaging set, based on performance
against the standard as defined in Section II.B and II.D. Thus, LHD
diesel engine manufacturers can only use their LHD diesel engine
credits for averaging, banking and trading with LHD diesel engines, not
with MHD diesel or HHD diesel engines. As noted, this limitation is
consistent with ABT provisions in EPA's existing criteria pollutant
program for engines and will help avoid problems created by the
diversity of applicat