[Federal Register Volume 81, Number 206 (Tuesday, October 25, 2016)]
[Rules and Regulations]
[Pages 73478-74274]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2016-21203]
[[Page 73477]]
Vol. 81
Tuesday,
No. 206
October 25, 2016
Part II
Environmental Protection Agency
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40 CFR Parts 9, 22, 85, et al.
Department of Transportation
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National Highway Traffic Safety Administration
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49 CFR Parts 523, 534, 535, et al.
Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium- and
Heavy-Duty Engines and Vehicles--Phase 2; Final Rule
Federal Register / Vol. 81 , No. 206 / Tuesday, October 25, 2016 /
Rules and Regulations
[[Page 73478]]
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ENVIRONMENTAL PROTECTION AGENCY
40 CFR Parts 9, 22, 85, 86, 600, 1033, 1036, 1037, 1039, 1042,
1043, 1065, 1066, and 1068
DEPARTMENT OF TRANSPORTATION
National Highway Traffic Safety Administration
49 CFR Parts 523, 534, 535, and 538
[EPA-HQ-OAR-2014-0827; NHTSA-2014-0132; FRL-9950-25-OAR]
RIN 2060-AS16; RIN 2127-AL52
Greenhouse Gas Emissions and Fuel Efficiency Standards for
Medium- and Heavy-Duty Engines and Vehicles--Phase 2
AGENCY: Environmental Protection Agency (EPA) and National Highway
Traffic Safety Administration (NHTSA), Department of Transportation
(DOT).
ACTION: Final rule.
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SUMMARY: EPA and NHTSA, on behalf of the Department of Transportation,
are establishing rules for a comprehensive Phase 2 Heavy-Duty (HD)
National Program that will reduce greenhouse gas (GHG) emissions and
fuel consumption from new on-road medium- and heavy-duty vehicles and
engines. NHTSA's fuel consumption standards and EPA's carbon dioxide
(CO2) emission standards are tailored to each of four
regulatory categories of heavy-duty vehicles: Combination tractors;
trailers used in combination with those tractors; heavy-duty pickup
trucks and vans; and vocational vehicles. The rule also includes
separate standards for the engines that power combination tractors and
vocational vehicles. Certain requirements for control of GHG emissions
are exclusive to the EPA program. These include EPA's hydrofluorocarbon
standards to control leakage from air conditioning systems in
vocational vehicles and EPA's nitrous oxide (N2O) and
methane (CH4) standards for heavy-duty engines.
Additionally, NHTSA is addressing misalignment between the Phase 1 EPA
GHG standards and the NHTSA fuel efficiency standards to virtually
eliminate the differences. This action also includes certain EPA-
specific provisions relating to control of emissions of pollutants
other than GHGs. EPA is finalizing non-GHG emission standards relating
to the use of diesel auxiliary power units installed in new tractors.
In addition, EPA is clarifying the classification of natural gas
engines and other gaseous-fueled heavy-duty engines. EPA is also
finalizing technical amendments to EPA rules that apply to emissions of
non-GHG pollutants from light-duty motor vehicles, marine diesel
engines, and other nonroad engines and equipment. Finally, EPA is
requiring that engines from donor vehicles installed in new glider
vehicles meet the emission standards applicable in the year of assembly
of the new glider vehicle, including all applicable standards for
criteria pollutants, with limited exceptions for small businesses and
for other special circumstances.
DATES: This final rule is effective on December 27, 2016. The
incorporation by reference of certain publications listed in this
regulation is approved by the Director of the Federal Register as of
December 27, 2016.
ADDRESSES: EPA and NHTSA have established dockets for this action under
Docket ID No. EPA-HQ-OAR-2014-0827 (for EPA's docket) and NHTSA-2014-
0132 (for NHTSA's docket). All documents in the docket are listed on
the https://www.regulations.gov Web site. Although listed in the index,
some information is not publicly available, e.g., CBI 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 in
https://www.regulations.gov or in hard copy at the following locations:
EPA: Air and Radiation Docket and Information Center, EPA Docket
Center, EPA/DC, EPA WJC 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 telephone number for the
docket management facility is (202) 366-9324. 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:
EPA: Tad Wysor, Office of Transportation and Air Quality,
Assessment and Standards Division (ASD), Environmental Protection
Agency, 2000 Traverwood Drive, Ann Arbor, MI 48105; telephone number:
(734) 214-4332; email address: [email protected].
NHTSA: Ryan Hagen, Office of Chief Counsel, National Highway
Traffic Safety Administration, 1200 New Jersey Avenue SE., Washington,
DC 20590. Telephone: (202) 366-2992; [email protected].
SUPPLEMENTARY INFORMATION:
A. Does this action apply to me?
This action will affect companies that manufacture, sell, or import
into the United States new heavy-duty engines and new Class 2b through
8 trucks, including combination tractors, all types of buses,
vocational vehicles including municipal, commercial, recreational
vehicles, and commercial trailers 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 lbs. or greater,
and the engines that power them, except for medium-duty passenger
vehicles already covered by the greenhouse gas standards and corporate
average fuel economy standards issued for light-duty model year 2017-
2025 vehicles.\1\ Regulated categories and entities include the
following:
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\1\ As discussed in Section I.A, the term heavy-duty is
generally used in this rulemaking to refer to all vehicles with a
gross vehicle weight rating above 8,500 lbs, including vehicles that
are sometimes otherwise known as medium-duty vehicles.
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Examples of potentially
Category NAICS code \a\ affected entities
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Industry................... 336111 Motor Vehicle
Manufacturers, Engine
Manufacturers, Truck
Manufacturers, Truck
Trailer Manufacturers.
336112
333618
336120
336212
Industry................... 541514 Commercial Importers of
Vehicles and Vehicle
Components.
811112
[[Page 73479]]
811198
Industry................... 336111 Alternative Fuel Vehicle
Converters.
336112
422720
454312
541514
541690
811198
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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.
B. Did EPA conduct a peer review before issuing this document?
This regulatory action is supported by influential scientific
information. Therefore, EPA conducted a peer review consistent with
OMB's Final Information Quality Bulletin for Peer Review. As described
in Section II.C, a peer review of updates to the vehicle simulation
model (GEM) for the Phase 2 standards has been completed. This version
of GEM is based on the model used for the Phase 1 rule, which was peer
reviewed by a panel of four independent subject matter experts. The
peer review report and EPA's response to the peer review comments are
available in Docket ID No. EPA-HQ-OAR-2014-0827. We note that this
rulemaking is based on a vast body of existing peer-reviewed work,
i.e., work that was peer-reviewed outside of this action, as noted in
the references throughout this Preamble, the Regulatory Impacts
Analysis, and the rulemaking docket. EPA also notified the SAB of its
plans for this rulemaking and on June 11, 2014, the chartered SAB
discussed the recommendations of its work group on the planned action
and agreed that no further SAB consideration of the supporting science
was merited.
C. Executive Summary
(1) Commitment to Greenhouse Gas Emission Reductions and Vehicle Fuel
Efficiency
In June 2013, the President announced a comprehensive Climate
Action Plan for the United States to reduce carbon pollution, prepare
for the impacts of climate change, and lead international efforts to
address global climate change.\2\ In this plan, President Obama
reaffirmed his commitment to reduce U.S. greenhouse gas emissions in
the range of 17 percent below 2005 levels by 2020. More recently, in
December 2015, the U.S. was one of over 190 signatories to the Paris
Climate Agreement, widely regarded as the most ambitious climate change
agreement in history. The Paris agreement reaffirms the goal of
limiting global temperature increase to well below 2 degrees Celsius,
and for the first time urged efforts to limit the temperature increase
to 1.5 degrees Celsius. The U.S. submitted a non-binding intended
nationally determined contribution (NDC) target of reducing economy-
wide GHG emissions by 26-28 percent below its 2005 level in 2025 and to
make best efforts to reduce emissions by 28 percent.\3\ This pace would
keep the U.S. on a trajectory to achieve deep economy-wide reductions
on the order of 80 percent by 2050.
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\2\ The White House, The President's Climate Action Plan (June,
2013). http://www.whitehouse.gov/share/climate-action-plan.
\3\ United States of America, Intended Nationally Determined
Contribution, March 31, 2015, http://www4.unfccc.int/submissions/INDC/Published%20Documents/United%20States%20of%20America/1/U.S.%20Cover%20Note%20INDC%20and%20Accompanying%20Information.pdf.
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As part of his Climate Action plan, the President specifically
directed the Environmental Protection Agency (EPA) and the Department
of Transportation's (DOT) National Highway Traffic Safety
Administration (NHTSA) to set the next round of standards to reduce
greenhouse gas (GHG) emissions and improve fuel efficiency for heavy-
duty vehicles pursuant to and consistent with the agencies' existing
statutory authorities.\4\ More than 70 percent of the oil used in the
United States and 26 percent of GHG emissions come from the
transportation sector, and since 2009 EPA and NHTSA have worked with
industry, states, and other stakeholders to develop ambitious, flexible
standards for both the fuel economy and GHG emissions of light-duty
vehicles and the fuel efficiency and GHG emissions of heavy-duty
vehicles.5 6 The standards here (referred to as Phase 2)
will build on the light-duty vehicle standards spanning model years
2012 to 2025 and on the initial phase of standards (referred to as
Phase 1) for new medium and heavy-duty vehicles (MDVs and HDVs) and
engines in model years 2014 to 2018. Throughout every stage of
development for these programs, EPA and NHTSA (collectively, the
agencies, or ``we'') have worked in close partnership not only with one
another, but also with the vehicle manufacturing industry,
environmental community leaders, and the State of California among
other entities to create a single, effective set of national standards.
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\4\ EPA's HD Phase 2 GHG emission standards are authorized under
the Clean Air Act, and NHTSA's HD Phase 2 fuel consumption standards
are authorized under the Energy Independence and Security Act of
2007.
\5\ The White House, Improving the Fuel Efficiency of American
Trucks--Bolstering Energy Security, Cutting Carbon Pollution, Saving
Money and Supporting Manufacturing Innovation (Feb. 2014), 2.
\6\ U.S. Environmental Protection Agency. April 2016. Inventory
of U.S. Greenhouse Gas Emissions and Sinks: 1990-2012. EPA 430-R-16-
002. Mobile sources emitted 28 percent of all U.S. GHG emissions in
2012. Available at https://www3.epa.gov/climatechange/Downloads/ghgemissions/US-GHG-Inventory-2016-Main-Text.pdf.
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Through two previous rulemakings, EPA and NHTSA have worked with
the auto industry to develop new fuel economy and GHG emission
standards for light-duty vehicles. Taken together with NHTSA's 2011
CAFE standards, the light-duty vehicle standards span model years 2011
to 2025 and are the first significant improvement in fuel economy in
approximately two decades. Under the final program, average new car and
light truck fuel economy is expected to nearly double by 2025
[[Page 73480]]
compared to 2010 vehicles.\7\ In the 2012 rule, the agencies projected
the standards would save consumers $1.7 trillion at the pump--roughly
$8,200 per vehicle for a MY 2025 vehicle--reducing oil consumption by
2.2 million barrels a day in 2025 and slashing GHG emissions by 6
billion metric tons over the lifetime of the vehicles sold during this
period.\8\ These fuel economy standards are already delivering savings
for American drivers. Between model years 2008 and 2013, the unadjusted
average test fuel economy of new passenger cars and light trucks sold
in the United States has increased by about four miles per gallon.
Altogether, light-duty vehicle fuel economy standards finalized after
2008 have already saved nearly one billion gallons of fuel and avoided
more than 10 million tons of carbon dioxide emissions.\9\
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\7\ The White House, Improving the Fuel Efficiency of American
Trucks--Bolstering Energy Security, Cutting Carbon Pollution, Saving
Money and Supporting Manufacturing Innovation (Feb. 2014), 2.
\8\ Id.
\9\ Id. at 3.
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Similarly, EPA and NHTSA have previously developed joint GHG
emission and fuel efficiency standards for MDVs and HDVs. Prior to
these Phase 1 standards, heavy-duty trucks and buses--from delivery
vans to the largest tractor-trailers--were required to meet pollution
standards for soot and smog-causing air pollutants, but no requirements
existed for the fuel efficiency or carbon pollution from these
vehicles.\10\ By 2010, total fuel consumption and GHG emissions from
MDVs and HDVs had been growing, and these vehicles accounted for 23
percent of total U.S. transportation-related GHG emissions \11\ and
about 20 percent of U.S. transportation-related energy use. In August
2011, the agencies finalized the groundbreaking Phase 1 standards for
new MDVs and HDVs in model years 2014 through 2018. This program,
developed with support from the trucking and engine industries, the
State of California, Environment and Climate Change Canada, and leaders
from the environmental community, set standards based on the use of
off-the-shelf technologies. These standards are expected to save a
projected 530 million barrels of oil and reduce carbon emissions by
about 270 million metric tons, representing one of the most significant
programs available to reduce domestic fuel consumption and emissions of
GHGs.\12\ The Phase 1 program, as well as the many additional actions
called for in the President's 2013 Climate Action Plan \13\ including
this Phase 2 rulemaking, not only result in meaningful decreases in GHG
emissions and fuel consumption, but also support--indeed are critical
for--United States leadership to encourage other countries to also
achieve meaningful GHG reductions and fuel conservation.
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\10\ Id.
\11\ Id.
\12\ Id. at 4.
\13\ The President's Climate Action Plan calls for GHG-cutting
actions including, for example, reducing carbon emissions from power
plants and curbing hydrofluorocarbon and methane emissions.
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This rule builds on our commitment to robust collaboration with
stakeholders and the public. It follows an expansive and thorough
outreach effort in which the agencies gathered input, data and views
from many interested stakeholders, involving over 400 meetings with
heavy-duty vehicle and engine manufacturers, technology suppliers,
trucking fleets, truck drivers, dealerships, environmental
organizations, and state agencies.\14\ As with the previous light-duty
rules and the heavy-duty Phase 1 rule, the agencies have consulted
frequently with the California Air Resources Board (CARB) staff during
the development of this rule, given California's unique ability among
the states to adopt their own GHG standards for on-highway engines and
vehicles. Through this close coordination, the agencies are finalizing
a Phase 2 program that will be fully aligned between EPA and NHTSA,
while providing CARB with the opportunity to adopt a Phase 2 program
that will allow manufacturers to continue to build a single fleet of
vehicles and engines.
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\14\ ``Heavy-Duty Phase 2 Stakeholder Meeting Log'', August
2016.
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(2) Overview of Phase 1 Medium- and Heavy-Duty Vehicle Standards
The Phase 1 program covers new trucks and heavy vehicles in model
years 2014 and later. That program includes specific standards for
combination tractors, heavy-duty pickup trucks and vans, and vocational
vehicles and includes separate standards for both vehicles and engines.
The program offers extensive flexibility, allowing manufacturers to
reach standards through average fleet calculations, a mix of
technologies, and the use of various credit and banking programs.
The Phase 1 program was developed by the agencies through close
consultation with industry and other stakeholders, resulting in
standards tailored to the specifics of each different class of vehicles
and engines.
Heavy-duty combination tractors. Combination tractors--
semi trucks that typically pull trailers--are regulated under nine
subcategories based on weight class, cab type, and roof height. These
vehicles represent approximately 60 percent of the fuel consumption and
GHG emissions from MDVs and HDVs.
Heavy-duty pickup trucks and vans. Heavy-duty pickup and
van standards are based on a ``work factor'' attribute that combines a
vehicle's payload, towing capabilities, and the presence of 4-wheel
drive. These vehicles represent about 23 percent of the fuel
consumption and GHG emissions from MDVs and HDVs.
Vocational vehicles. Specialized vocational vehicles,
which consist of a very wide variety of truck and bus types (e.g.,
delivery, refuse, utility, dump, cement, transit bus, shuttle bus,
school bus, emergency vehicles, and recreational vehicles) are
regulated in three subcategories based on engine classification. These
vehicles represent approximately 17 percent of the fuel consumption and
GHG emissions from MDVs and HDVs. The Phase 1 program includes EPA GHG
standards for recreational vehicles, but not NHTSA fuel efficiency
standards.\15\
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\15\ The Phase 2 program will also include NHTSA recreational
vehicle fuel efficiency standards.
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Heavy-duty engines. The Phase 1 rule has independent
standards for heavy-duty engines to assure they contribute to reducing
GHG emissions and fuel consumption because the Phase 1 tractor and
vocational vehicle standards do not account for the contributions of
engine improvements to reducing fuel consumption and GHG emissions.
The Phase 1 standards were premised on utilization of technologies
that were already in production on some vehicles at the time of the
Phase 1 FRM and are adaptable to the broader fleet. The Phase 1 program
provides flexibilities that facilitate compliance. These flexibilities
help provide sufficient lead time for manufacturers to make necessary
technological improvements and reduce the overall cost of the program,
without compromising overall environmental and fuel consumption
objectives. The primary flexibility provisions are an engine averaging,
banking, and trading (ABT) program and a vehicle ABT program. These ABT
programs allow for emission and/or fuel consumption credits to be
averaged, banked, or traded within each of the averaging sets.
The Phase 1 program was projected to save 530 million barrels of
oil and avoid 270 million metric tons of GHG emissions.\16\ At the same
time, the
[[Page 73481]]
program was projected to produce $50 billion in fuel savings and $49
billion of net societal benefits. Today, the Phase 1 fuel efficiency
and GHG reduction standards are already reducing GHG emissions and U.S.
oil consumption, and producing fuel savings for America's trucking
industry. The market appears to be very accepting of the Phase 1
technologies.
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\16\ The White House, Improving the Fuel Efficiency of American
Trucks--Bolstering Energy Security, Cutting Carbon Pollution, Saving
Money and Supporting Manufacturing Innovation (Feb. 2014), 4.
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(3) Overview of Phase 2 Medium- and Heavy-Duty Vehicle Standards
The Phase 2 GHG and fuel efficiency standards for MDVs and HDVs are
a critical next step in improving fuel efficiency and reducing GHG
emissions. The Phase 2 national program carries forward our commitment
to meaningful collaboration with stakeholders and the public, as they
build on more than 400 meetings with manufacturers, suppliers, trucking
fleets, dealerships, state air quality agencies, non-governmental
organizations (NGOs), and other stakeholders; over 200,000 public
comments; and two public hearings to identify and understand the
opportunities and challenges involved with this next level of fuel-
saving technology. These meetings and public feedback, in addition to
close coordination with CARB, have been invaluable to the agencies,
enabling the development of a program that appropriately balances all
potential impacts, effectively minimizes the possibility of unintended
consequences, and allows manufacturers to continue to build a single
fleet of vehicles and engines.
Phase 2 will include technology-advancing standards that will phase
in over the long-term (through model year 2027) to result in an
ambitious, yet achievable program that will allow manufacturers to meet
standards through a mix of different technologies at reasonable cost.
The terminal requirements go into effect in 2027, and would apply to MY
2027 and subsequent model year vehicles, unless modified by future
rulemaking. The Phase 2 standards will maintain the underlying
regulatory structure developed in the Phase 1 program, such as the
general categorization of MDVs and HDVs and the separate standards for
vehicles and engines. However, the Phase 2 program will build on and
advance Phase 1 in a number of important ways including the following:
basing standards not only on currently available technologies but also
on utilization of technologies now under development or not yet widely
deployed while providing significant lead time to assure adequate time
to develop, test, and phase in these controls; developing first-time
GHG and fuel efficiency standards for trailers; further encouraging
innovation and providing flexibility; including vehicles produced by
small business manufacturers with appropriate flexibilities for these
companies; incorporating enhanced test procedures that (among other
things) allow individual drivetrain and powertrain performance to be
reflected in the vehicle certification process; and using an expanded
and improved compliance simulation model.
The Phase 2 program will provide significant GHG reductions and
save fuel by:
Strengthening standards to account for ongoing
technological advancements. Relative to the baseline as of the end of
Phase 1, these final standards are projected to achieve vehicle fuel
savings as high as 25 percent, depending on the vehicle category. While
costs are higher than for Phase 1, benefits greatly exceed costs, and
payback periods are short, meaning that consumers will see substantial
net savings over the vehicle lifetime. Payback is estimated at about
two years for tractors and trailers, about four years for vocational
vehicles, and about three years for heavy-duty pickups and vans. The
agencies are finalizing a program that phases in the MY 2027 standards
with interim standards for model years 2021 and 2024 (and for certain
types of trailers, EPA is finalizing model year 2018 phase-in standards
as well). The final program includes both significant strengthening of
certain standards from the NPRM as well as adjustments to better align
other standards with new data, analysis, and stakeholder and public
feedback received since the time of the proposal.
Setting standards for trailers for the first time. In
addition to retaining the vehicle and engine categories covered in the
Phase 1 program, the Phase 2 standards include fuel efficiency and GHG
emission standards for trailers used in combination with tractors.
Although the agencies are not finalizing standards for all trailer
types, the majority of new trailers will be covered.
Encouraging technological innovation while providing
flexibility and options for manufacturers. For each category of HDVs,
the standards will set performance targets that allow manufacturers to
achieve reductions through a mix of different technologies and
generally leave manufacturers free to choose any means of compliance.
For tractor standards, for example, different combinations of
improvements like advanced aerodynamics, engine improvements and waste-
heat recovery, automated transmission, lower rolling resistance tires,
and automatic tire inflation can be used to meet standards. For
tractors and vocational vehicles, enhanced test procedures and an
expanded and improved compliance simulation model enable the vehicle
standards to encompass more of the complete vehicle than the Phase 1
program and to account for engine, transmission and driveline
improvements. With the addition of the powertrain and driveline to the
compliance model, representative drive cycles and vehicle baseline
configurations become critically important to assure the standards
promote technologies that improve real world fuel efficiency and GHG
emissions. This rule updates drive cycles and vehicle configurations to
better reflect real world operation. The final program includes
adjustments to technical elements of the proposed compliance program,
e.g., test procedures, reflecting the significant amount of stakeholder
and public comment the agencies received on the program. Additionally,
the agencies' analyses indicate that this rule should have no adverse
impact on vehicle or engine safety.
Providing flexibilities to help minimize effect on small
businesses. All small businesses are exempt from the Phase 1 standards.
The agencies are regulating small business entities under Phase 2
(notably certain trailer manufacturers), but we have conducted
extensive proceedings pursuant to section 609 of the Regulatory
Flexibility Act, and engaged in extensive consultation with
stakeholders, and developed an approach to provide targeted
flexibilities geared toward helping small businesses comply with the
Phase 2 standards. Specifically, the agencies are delaying the initial
implementation of the Phase 2 standards by one year and simplifying
certification requirements for small businesses. We are also adopting
additional flexibilities and exemptions adapted to particular vehicle
categories.
The following tables summarize the impacts of the Heavy-Duty Phase
2 rule.
[[Page 73482]]
Summary of the Phase 2 Medium- and Heavy-Duty Vehicle Rule Impacts to
Fuel Consumption, GHG Emissions, Benefits and Costs Over the Lifetime of
Model Years 2018-2029 \a\ \b\
------------------------------------------------------------------------
3% 7%
------------------------------------------------------------------------
Fuel Reductions (billion gallons)....... 71-82
-------------------------------
GHG Reductions (MMT, CO[ihel2]eq)....... 959-1098
-------------------------------
Pre-Tax Fuel Savings ($billion)......... 149-169 80-87
Discounted Technology Costs ($billion).. 24-27 16-18
Value of reduced emissions ($billion)... 60-69 48-52
Total Costs ($billion).................. 29-31 19-20
Total Benefits ($billion)............... 225-260 136-151
Net Benefits ($billion)................. 197-229 117-131
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Notes:
\a\ Ranges reflect two analysis methods: Method A with the 1b baseline
and Method B with the la baseline. For an explanation of analytical
Methods A and B, please see Section I.D; for an explanation of the
``flat'' baseline, 1a, and the ``dynamic'' baseline, 1b, please see
Section X.A.1.
\b\ Benefits and net benefits (including those in the 7% discount rate
column) use the 3 percent average Social Cost of CO[ihel2], the Social
Cost of CH[ihel4], and the Social Cost of N[ihel2]O.
Summary of the Phase 2 Medium- and Heavy-Duty Vehicle Annual Fuel and
GHG Reductions, Program Costs, Benefits and Net Benefits in Calendar
Years 2040 and 2050 \a\
------------------------------------------------------------------------
2040 2050
------------------------------------------------------------------------
Fuel Reductions (Billion Gallons)....... 10.8 13.0
GHG Reduction (MMT, CO[ihel2]eq)........ 166.8 199.3
Vehicle Program Costs (including -$6.5 -$7.5
Maintenance; Billions of 2013$)........
Fuel Savings (Pre-Tax; Billions of $53.1 $63.4
2013$).................................
Benefits (Billions of 2013$)............ $24.8 $31.7
Net Benefits (Billions of 2013$)........ $71.4 $87.6
------------------------------------------------------------------------
Note:
\a\ Benefits and net benefits (including those in the 7% discount rate
column) use the 3 percent average Social Cost of CO[ihel2], the Social
Cost of CH[ihel4], and the Social Cost of N[ihel2]O. Values reflect
the final program using Method B relative to the flat baseline (a
reference case that projects very little improvement in new vehicle
fuel economy absent new standards).
Summary of the Phase 2 Medium- and Heavy-Duty Vehicle Program Expected Per-Vehicle Fuel Savings, GHG Emission
Reductions, and Cost for Key Vehicle Categories
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MY 2021 MY 2024 MY 2027
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Maximum Vehicle Fuel Savings and Tailpipe GHG Reduction
(%):
Tractors \b\....................................... 13 20 25
Trailers \a\....................................... 5 7 9
Vocational Vehicles \b\............................ 12 20 24
Pickups/Vans....................................... 2.5 10 16
Per Vehicle Cost ($)\c\ \d\ (% Increase in Typical
Vehicle Price):
Tractors........................................... $6,400-$6,480 $9,920-$10,100 $12,160-$12,440
(6%) (10%) (12%)
Trailers........................................... $850-$870 $1,000-$1,030 $1,070-$1,110
(3%) (4%) (4%)
Vocational Vehicles................................ $1,110-$1,160 $1,980-$2,020 $2,660-$2,700
(1%) (2%) (3%)
Pickups/Vans....................................... $520-$750 $760-$960 $1,340-$1,360
(1%) (2%) (3%)
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Notes:
\a\ Note that the EPA standards for trailers begin in model year 2018
\b\ All engine costs are included
\c\ Please refer to Preamble Chapters 6 and 10 for additional information on the reference fleet used to analyze
costs and benefits of the rule. Please also refer to these chapters for impacts of the rule under more dynamic
baseline assumptions for pickups and vans.
\d\ Ranges reflect two analysis methods: Method A with the 1b baseline and Method B with the la baseline. For an
explanation of analytical Methods A and B, please see Section I.D; for an explanation of the ``flat''
baseline, 1a, and the ``dynamic'' baseline, 1b, please see Section X.A.1.
\e\ For this table, we use an approximate minimum vehicle price today of $100,000 for tractors, $25,000 for
trailers, $100,000 for vocational vehicles and $40,000 for HD pickups/vans.
[[Page 73483]]
Payback Periods for MY 2027 Vehicles Under the Final Standards, Based on
both Analysis Methods A and B
[Payback occurs in the year shown; using 7% discounting]
------------------------------------------------------------------------
Final standards
------------------------------------------------------------------------
Tractors/Trailers.......................... 2nd.
Vocational Vehicles........................ 4th.
Pickups/Vans \a\........................... 3rd.
------------------------------------------------------------------------
Note:
\a\ Please refer to Preamble Chapters 6 and 10 for additional
information on the reference fleet used to analyze costs and benefits
of the rule. Please also refer to these chapters for impacts of the
rule under more dynamic baseline assumptions for pickups and vans.
(4) Issues Addressed in This Final Rule
This Preamble contains extensive discussion of the background,
elements, and implications of the Phase 2 program, as well as updates
made to the final program from the proposal based on new data,
analysis, stakeholder feedback and public comments. Section I includes
information on the MDV and HDV industry, related regulatory and non-
regulatory programs, summaries of Phase 1 and Phase 2 programs, costs
and benefits of the final standards, and relevant statutory authority
for EPA and NHTSA. Section II discusses vehicle simulation, engine
standards, and test procedures. Sections III, IV, V, and VI detail the
final standards for combination tractors, trailers, vocational
vehicles, and heavy-duty pickup trucks and vans. Sections VII and VIII
discuss aggregate GHG impacts, fuel consumption impacts, climate
impacts, and impacts on non-GHG emissions. Section IX evaluates the
economic impacts of the final program. Sections X and XI present the
alternatives analyses and consideration of natural gas vehicles.
Finally, Sections XII and XIII discuss the changes that the Phase 2
rules will have on Phase 1 standards and other regulatory provisions.
In addition to this Preamble, the Regulatory Impact Analysis (RIA),\17\
provides additional data, analysis and discussion of the standards, and
the Response to Comments Document for Joint Rulemaking (RTC) provides
responses to comments received on the Phase 2 rulemaking through the
public comment process.\18\
---------------------------------------------------------------------------
\17\ Available on EPA and NHTSA's Web sites and in the public
docket for this rulemaking.
\18\ Available on EPA's Web site and in the public docket for
this rulemaking.
---------------------------------------------------------------------------
Table of Contents
A. Does this action apply to me?
B. Did EPA conduct a peer review before issuing this document?
C. Executive Summary
I. Overview
A. Background
B. Summary of Phase 1 Program
C. Summary of the Phase 2 Standards and Requirements
D. Summary of the Costs and Benefits of the Final Rules
E. EPA and NHTSA Statutory Authorities
F. Other Issues
II. Vehicle Simulation and Separate Engine Standards for Tractors
and Vocational Chassis
A. Introduction
B. Phase 2 Regulatory Structure
C. Phase 2 GEM and Vehicle Component Test Procedures
D. Engine Test Procedures and Engine Standards
III. Class 7 and 8 Combination Tractors
A. Summary of the Phase 1 Tractor Program
B. Overview of the Phase 2 Tractor Program and Key Changes From
the Proposal
C. Phase 2 Tractor Standards
D. Feasibility of the Final Phase 2 Tractor Standards
E. Phase 2 Compliance Provisions for Tractors
F. Flexibility Provisions
IV. Trailers
A. The Trailer Industry
B. Overview of the Phase 2 Trailer Program and Key Changes From
the Proposal
C. Phase 2 Trailer Standards
D. Feasibility of the Trailer Standards
E. Trailer Standards: Compliance and Flexibilities
V. Class 2b-8 Vocational Vehicles
A. Summary of Phase 1 Vocational Vehicle Standards
B. Phase 2 Standards for Vocational Vehicles
C. Feasibility of the Vocational Vehicle Standards
D. Compliance Provisions for Vocational Vehicles
VI. Heavy-Duty Pickups and Vans
A. Summary of Phase 1 HD Pickup and Van Standards
B. HD Pickup and Van Final Phase 2 Standards
C. Use of the CAFE Model in Heavy-Duty Rulemaking
D. NHTSA CAFE Model Analysis of the Regulatory Alternatives for
HD Pickups and Vans: Method A
E. Analysis of the Regulatory Alternatives for HD Pickups and
Vans: Method B
F. Compliance and Flexibility for HD Pickup and Van Standards
VII. Aggregate GHG, Fuel Consumption, and Climate Impacts
A. What methodologies did the agencies use to project GHG
emissions and fuel consumption impacts?
B. Analysis of Fuel Consumption and GHG Emissions Impacts
Resulting From Final Standards
C. What are the projected reductions in fuel consumption and GHG
emissions?
D. Climate Impacts and Indicators
VIII. How will these rules impact non-GHG emissions and their
associated effects?
A. Health Effects of Non-GHG Pollutants
B. Environmental Effects of Non-GHG Pollutants
C. Emissions Inventory Impacts
D. Air Quality Impacts of Non-GHG Pollutants
IX. Economic and Other Impacts
A. Conceptual Framework
B. Vehicle-Related Costs Associated With the Program
C. Changes in Fuel Consumption and Expenditures
D. Maintenance Expenditures
E. Analysis of the Rebound Effect
F. Impact on Class Shifting, Fleet Turnover, and Sales
G. Monetized GHG Impacts
H. Monetized Non-GHG Health Impacts
I. Energy Security Impacts
J. Other Impacts
K. Summary of Benefits and Costs
L. Employment Impacts
M. Cost of Ownership and Payback Analysis
N. Safety Impacts
X. Analysis of the Alternatives
A. What are the alternatives that the agencies considered?
B. How do these alternatives compare in overall fuel consumption
and GHG emissions reductions?
XI. Natural Gas Vehicles and Engines
A. Natural Gas Engine and Vehicle Technology
B. GHG Lifecycle Analysis for Natural Gas Vehicles
C. Projected Use of LNG and CNG
D. Natural Gas Emission Control Measures
E. Dimethyl Ether
XII. Amendments to Phase 1 Standards
A. EPA Amendments
B. Other Compliance Provisions for NHTSA
XIII. Other Regulatory Provisions
A. Amendments Related to Heavy-Duty Highway Engines and Vehicles
B. Amendments Affecting Glider Vehicles and Glider Kits
C. Applying the General Compliance Provisions of 40 CFR Part
1068 to Light-Duty Vehicles, Light-Duty Trucks, Chassis-Certified
Class 2b and 3 Heavy-Duty Vehicles and Highway Motorcycles
D. Amendments to General Compliance Provisions in 40 CFR Part
1068
E. Amendments to Light-Duty Greenhouse Gas Program Requirements
F. Amendments to Highway and Nonroad Test Procedures and
Certification Requirements
G. Amendments Related to Locomotives in 40 CFR Part 1033
H. Amendments Related to Nonroad Diesel Engines in 40 CFR Part
1039
I. Amendments Related to Marine Diesel Engines in 40 CFR Parts
1042 and 1043
J. Miscellaneous EPA Amendments
K. Competition Vehicles
L. Amending 49 CFR Parts 512 and 537 To Allow Electronic
Submissions and Defining Data Formats for Light-Duty Vehicle
Corporate Average Fuel Economy (CAFE) Reports
XIV. Statutory and Executive Order Reviews
A. Executive Order 12866: Regulatory Planning and Review and
Executive
[[Page 73484]]
Order 13563: Improving Regulation and Regulatory Review
B. National Environmental Policy Act
C. Paperwork Reduction Act
D. Regulatory Flexibility Act
E. Unfunded Mandates Reform Act
F. Executive Order 13132: Federalism
G. Executive Order 13175: Consultation and Coordination With
Indian Tribal Governments
H. Executive Order 13045: Protection of Children From
Environmental Health Risks and Safety Risks
I. Executive Order 13211: Actions Concerning Regulations That
Significantly Affect Energy Supply, Distribution, or Use
J. National Technology Transfer and Advancement Act and 1 CFR
Part 51
K. Executive Order 12898: Federal Actions To Address
Environmental Justice in Minority Populations and Low-Income
Populations
L. Endangered Species Act (ESA)
M. Congressional Review Act (CRA)
XV. EPA and NHTSA Statutory Authorities
A. EPA
B. NHTSA
List of Subjects
I. Overview
The agencies issued a Notice of Proposed Rulemaking (NPRM) on July
13, 2015, that proposed Phase 2 GHG and fuel efficiency standards for
heavy-duty engines and vehicles.\19\ The agencies also issued a Notice
of Data Availability (NODA) on March 2, 2016, to solicit comment on new
material not available at the time of the NPRM.\20\ The agencies have
revised the proposed standards and related requirements to address
issues raised in public comments. Nevertheless, the final rules being
adopted today remain fundamentally similar to the proposed rules.
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\19\ 80 FR 40137.
\20\ 81 FR 10824.
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Although the agencies describe the final requirements in this
document, readers are encouraged to also read supporting materials that
have been place into the public dockets for these rules. In particular,
the agencies note:
The Final Regulatory Impact Analysis (RIA), provides
additional technical information and analysis
The Response to Comments Document for Joint Rulemaking (RTC),
provides a detailed summary and analysis of public comments, including
comments received in response to the NODA
The NHTSA Final Environmental Impact Statement (FEIS)
This overview of the final Phase 2 GHG emissions and fuel
efficiency standards includes a description of the heavy-duty truck
industry and related regulatory and non-regulatory programs, a summary
of the Phase 1 GHG emissions and fuel efficiency program, a summary of
the Phase 2 standards and requirements being finalized, a summary of
the costs and benefits of the Phase 2 standards, discussion of EPA and
NHTSA statutory authorities, and other issues.
A. Background
For purposes of this Preamble (and consistent with all terminology
used at proposal), the terms ``heavy-duty'' or ``HD'' are used to apply
to all highway vehicles and engines that are not within the range of
light-duty passenger cars, light-duty trucks, and medium-duty passenger
vehicles (MDPV) covered by separate GHG and Corporate Average Fuel
Economy (CAFE) standards.\21\ (The terms also do not include
motorcycles). Thus, in this rulemaking, unless specified otherwise, the
heavy-duty category incorporates all vehicles with a gross vehicle
weight rating above 8,500 lbs, and the engines that power them, except
for MDPVs.22 23 24 Note also that the terms heavy-duty truck
and heavy-duty vehicle are sometimes used interchangeably, even though
commercially the term heavy-duty truck can have a narrower meaning.
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\21\ 2017 and Later Model Year Light-Duty Vehicle Greenhouse Gas
Emissions and Corporate Average Fuel Economy Standards; Final Rule,
77 FR 62623, October 15, 2012.
\22\ The CAA defines heavy-duty as a truck, bus or other motor
vehicles with a gross vehicle weight rating exceeding 6,000 lbs (CAA
section 202(b)(3)). The term HD as used in this action refers to a
subset of these vehicles and engines.
\23\ The Energy Independence and Security Act of 2007 requires
NHTSA to set standards for commercial medium- and heavy-duty on-
highway vehicles, defined as on-highway vehicles with a GVWR of
10,000 lbs or more, and work trucks, defined as vehicles with a GVWR
between 8,500 and 10,000 lbs and excluding medium duty passenger
vehicles.
\24\ The term ``medium-duty'' is sometimes used to refer to the
lighter end of this range of vehicles. This is typically in the
context of statutes or reports that use the term ``medium-duty.''
For example, because the term medium-duty is used in EISA, the term
is also used in much of the discussion of NHTSA's statutory
authority.
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Consistent with the President's direction, over the past three
years as we have developed this rulemaking, the agencies have met on an
on-going basis with a very large number of diverse stakeholders. This
includes meetings, and in many cases site visits, with truck, trailer,
and engine manufacturers; technology supplier companies and their trade
associations (e.g., transmissions, drivelines, fuel systems,
turbochargers, tires, catalysts, and many others); line haul and
vocational trucking firms and trucking associations; the trucking
industries owner-operator association; truck dealerships and dealers
associations; trailer manufacturers and their trade association; non-
governmental organizations (NGOs, including environmental NGOs,
national security NGOs, and consumer advocacy NGOs); state air quality
agencies; manufacturing labor unions; and many other stakeholders. In
addition, EPA and NHTSA have consulted on an on-going basis with the
California Air Resources Board (CARB) over the past three years as we
developed the Phase 2 rule. CARB staff and managers have also
participated with EPA and NHTSA in meetings with many external
stakeholders, including those with vehicle OEMs and technology
suppliers.\25\
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\25\ Vehicle chassis manufacturers are known in this industry as
original equipment manufacturers or OEMs.
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EPA and NHTSA staff also participated in a large number of
technical and policy conferences over the past three years related to
the technological, economic, and environmental aspects of the heavy-
duty trucking industry. The agencies also met with regulatory
counterparts from several other nations who either have already or are
considering establishing fuel consumption or GHG requirements,
including outreach with representatives from the governments of Canada,
the European Commission, Japan, and China.
These comprehensive outreach actions by the agencies provided us
with information to assist in our identification of potential
technologies that can be used to reduce heavy-duty GHG emissions and
improve fuel efficiency. The outreach has also helped the agencies to
identify and understand the opportunities and challenges involved with
these standards for the heavy-duty trucks, trailers, and engines
detailed in this Preamble, including time needed for implementation of
various technologies and potential costs and fuel savings. The scope of
this outreach effort to gather input for the proposal and final
rulemaking included well over 400 meetings with stakeholders. These
meetings and conferences have been invaluable to the agencies. We
believe they enabled us to refine the proposal in such a way as to
appropriately consider all of the potential impacts and to minimize the
possibility of unintended consequences in the final rules.
[[Page 73485]]
(1) Brief Overview of the Heavy-Duty Truck Industry
The heavy-duty sector is diverse in several respects, including the
types of manufacturing companies involved, the range of sizes of trucks
and engines they produce, the types of work for which the trucks are
designed, and the regulatory history of different subcategories of
vehicles and engines. The current heavy-duty fleet encompasses vehicles
from the ``18-wheeler'' combination tractor-trailers one sees on the
highway to the largest pickup trucks and vans, as well as vocational
vehicles covering the range between these extremes. Together, the HD
sector spans a wide range of vehicles with often specialized form and
function. A primary indicator of the 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.\26\ Table I-1 below outlines
the vehicle weight classifications commonly used for many years for a
variety of purposes by businesses and by several Federal agencies,
including the Department of Transportation, the Environmental
Protection Agency, the Department of Commerce, and the Internal Revenue
Service.
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\26\ GVWR describes the maximum load that can be carried by a
vehicle, including the weight of the vehicle itself. Heavy-duty
vehicles (including those designed for primary purposes other than
towing) 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-1--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 >33,000
--------------------------------------------------------------------------------------------------------------------------------------------------------
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.\27\
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\27\ Class 2b vehicles manufactured as passenger vehicles
(Medium Duty Passenger Vehicles, MDPVs) are covered by the light-
duty GHG and fuel economy standards and therefore are not addressed
in this rulemaking.
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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 trucks 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 span Classes 2b through 8, vary widely
in size, including smaller and larger van trucks, utility ``bucket''
trucks, tank trucks, refuse trucks, urban and over-the-road buses, fire
trucks, flat-bed trucks, and dump trucks, among others. The annual
mileage of these vehicles 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.
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 operate with one or more
trailers that can carry up to 50,000 lbs or more of payload, consuming
significant quantities of fuel and producing significant amounts of GHG
emissions. Together, Class 7 and 8 tractors and trailers account for
approximately 60 percent of the heavy-duty sector's total
CO2 emissions and fuel consumption. Trailer designs vary
significantly, reflecting the wide variety of cargo types. However, the
most common types of trailers are box vans (dry and refrigerated),
which are a focus of this Phase 2 rulemaking. The tractor-trailers used
in combination applications can and frequently do travel more than
150,000 miles per year and can operate for 20-30 years.
Heavy-duty vehicles differ significantly from light-duty vehicles
in other ways. In particular, we note that heavy-duty engines are much
more likely to be rebuilt. In fact, it is common for Class 8 engines to
be rebuilt multiple times. Commercial heavy-duty vehicles are often
resold after a few years and may be repurposed by the second or third
owner. Thus issues of resale value and adaptability have historically
been key concerns for purchasers.
EPA and NHTSA have designed our respective standards in careful
consideration of the diversity and complexity of the heavy-duty truck
industry, as discussed in Section I.C.
(2) Related Regulatory and Non-Regulatory Programs
(a) History of EPA's Heavy-Duty Regulatory Program and Assessments of
the Impacts of Greenhouse Gases on Climate Change
To provide a context for EPA's program to reduce greenhouse gas
emissions from motor vehicles, this subsection provides an overview of
two important related areas. First, we summarize the history of EPA's
heavy-duty regulatory program, which provides a basis for the
compliance structure of this rulemaking. Next we summarize EPA prior
assessments of the impacts of greenhouse gases on climate change, which
provides a basis for much of the analysis of the environmental benefits
of this rulemaking.
(i) History of EPA's 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 two decades these programs have
primarily addressed emissions of particulate matter (PM) and the
primary ozone precursors, hydrocarbons (HC) and oxides of nitrogen
(NOX). These programs, which have successfully achieved
significant and cost-effective reductions in emissions and associated
health and welfare benefits to the nation, were an important basis of
the Phase 1 program. See e.g. 66 FR 5002, 5008, and 5011-5012 (January
18, 2001) (detailing substantial public health benefits of controls of
criteria pollutants from heavy-duty diesel engines, including bringing
areas into attainment with primary (public health) PM NAAQS, or
contributing substantially to such attainment); National Petrochemical
Refiners Association v. EPA, 287 F. 3d 1130, 1134 (D.C. Cir. 2002)
(referring to the ``dramatic reductions'' in criteria pollutant
emissions resulting from the EPA on-
[[Page 73486]]
highway heavy-duty engine standards, and upholding all of the
standards).
As required by the Clean Air Act (CAA), the emission standards
implemented by these programs include standards that apply at the time
that the vehicle or engine is sold and continue to apply in actual use.
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 by regulating heavy-duty engine emissions. A key part of
this success has been the development over many years of a well-
established, representative, and robust set of engine test procedures
that industry and EPA now use routinely 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.
(ii) EPA Assessment of the Impacts of Greenhouse Gases on Climate
Change
In 2009, the EPA Administrator issued the document known as the
Endangerment Finding under CAA section 202(a)(1).\28\ In the
Endangerment Finding, which focused on public health and public welfare
impacts within the United States, the Administrator found that elevated
concentrations of GHG emissions in the atmosphere may reasonably be
anticipated to endanger public health and welfare of current and future
generations. See also Coalition for Responsible Regulation v. EPA, 684
F. 3d 102, 117-123 (D.C. Cir. 2012) (upholding the endangerment finding
in all respects). The following sections summarize the key information
included in the Endangerment Finding.
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\28\ ``Endangerment and Cause or Contribute Findings for
Greenhouse Gases Under section 202(a) of the Clean Air Act,'' 74 FR
66496 (December 15, 2009) (``Endangerment Finding'').
---------------------------------------------------------------------------
Climate change caused by human emissions of GHGs threatens public
health in multiple ways. By raising average temperatures, climate
change increases the likelihood of heat waves, which are associated
with increased deaths and illnesses. While climate change also
decreases the likelihood of cold-related mortality, evidence indicates
that the increases in heat mortality will be larger than the decreases
in cold mortality in the United States. Compared to a future without
climate change, climate change is expected to increase ozone pollution
over broad areas of the U.S., including in the largest metropolitan
areas with the worst ozone problems, and thereby increase the risk of
morbidity and mortality. Other public health threats also stem from
projected increases in intensity or frequency of extreme weather
associated with climate change, such as increased hurricane intensity,
increased frequency of intense storms and heavy precipitation.
Increased coastal storms and storm surges due to rising sea levels are
expected to cause increased drownings and other adverse health impacts.
Children, the elderly, and the poor are among the most vulnerable to
these climate-related health effects. See also 79 FR 75242 (December
17, 2014) (climate change, and temperature increases in particular,
likely to increase O3 (ozone) pollution ``over broad areas
of the U.S., including the largest metropolitan areas with the worst
O3 problems, increas[ing] the risk of morbidity and
mortality'').
Climate change caused by human emissions of GHGs also threatens
public welfare in multiple ways. Climate changes are expected to place
large areas of the country at serious risk of reduced water supplies,
increased water pollution, and increased occurrence of extreme events
such as floods and droughts. Coastal areas are expected to face
increased risks from storm and flooding damage to property, as well as
adverse impacts from rising sea level, such as land loss due to
inundation, erosion, wetland submergence and habitat loss. Climate
change is expected to result in an increase in peak electricity demand,
and extreme weather from climate change threatens energy,
transportation, and water resource infrastructure. Climate change may
exacerbate ongoing environmental pressures in certain settlements,
particularly in Alaskan indigenous communities. Climate change also is
very likely to fundamentally rearrange U.S. ecosystems over the 21st
century. Though some benefits may balance adverse effects on
agriculture and forestry in the next few decades, the body of evidence
points towards increasing risks of net adverse impacts on U.S. food
production, agriculture and forest productivity as temperature
continues to rise. These impacts are global and may exacerbate problems
outside the U.S. that raise humanitarian, trade, and national security
issues for the U.S. See also 79 FR 75382 (December 17, 2014) (welfare
effects of O3 increases due to climate change, with emphasis
on increased wildfires).
As outlined in Section VIII.A of the 2009 Endangerment Finding,
EPA's approach to providing the technical and scientific information to
inform the Administrator's judgment regarding the question of whether
GHGs endanger public health and welfare was to rely primarily upon the
recent, major assessments by the U.S. Global Change Research Program
(USGCRP), the Intergovernmental Panel on Climate Change (IPCC), and the
National Research Council (NRC) of the National Academies. These
assessments addressed the scientific issues that EPA was required to
examine, were comprehensive in their coverage of the GHG and climate
change issues, and underwent rigorous and exacting peer review by the
expert community, as well as rigorous levels of U.S. government review.
Since the administrative record concerning the Endangerment Finding
closed following EPA's 2010 Reconsideration Denial, a number of new
major, peer-reviewed scientific assessments have been released. These
include the IPCC's 2012 ``Special Report on Managing the Risks of
Extreme Events and Disasters to Advance Climate Change Adaptation''
(SREX) and the 2013-2014 Fifth Assessment Report (AR5), the USGCRP's
2014 ``Climate Change Impacts in the United States'' (Climate Change
Impacts), and the NRC's 2010 ``Ocean Acidification: A National Strategy
to Meet the Challenges of a Changing Ocean'' (Ocean Acidification),
2011 ``Report on Climate Stabilization Targets: Emissions,
Concentrations, and Impacts over Decades to Millennia'' (Climate
Stabilization Targets), 2011 ``National Security Implications for U.S.
Naval Forces'' (National Security Implications), 2011 ``Understanding
Earth's Deep Past: Lessons for Our Climate Future'' (Understanding
Earth's Deep Past), 2012 ``Sea Level Rise for the Coasts of California,
Oregon, and Washington: Past, Present, and Future,'' 2012 ``Climate and
Social Stress: Implications for Security Analysis'' (Climate and Social
Stress), and 2013 ``Abrupt Impacts of Climate Change'' (Abrupt Impacts)
assessments.
EPA has reviewed these new assessments and finds that the improved
understanding of the climate system they present further strengthens
the case that GHG emissions endanger public health and welfare.
In addition, these assessments highlight the urgency of the
situation as the concentration of CO2 in the atmosphere
continues to rise. Absent a reduction in emissions, a recent
[[Page 73487]]
National Research Council assessment projected that concentrations by
the end of the century would increase to levels that the Earth has not
experienced for millions of years.\29\ In fact, that assessment stated
that ``the magnitude and rate of the present greenhouse gas increase
place the climate system in what could be one of the most severe
increases in radiative forcing of the global climate system in Earth
history.'' \30\ What this means, as stated in another NRC assessment,
is that:
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\29\ National Research Council, Understanding Earth's Deep Past,
p. 1.
\30\ Id., p.138.
Emissions of carbon dioxide from the burning of fossil fuels
have ushered in a new epoch where human activities will largely
determine the evolution of Earth's climate. Because carbon dioxide
in the atmosphere is long lived, it can effectively lock Earth and
future generations into a range of impacts, some of which could
become very severe. Therefore, emission reductions choices made
today matter in determining impacts experienced not just over the
next few decades, but in the coming centuries and millennia.\31\
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\31\ National Research Council, Climate Stabilization Targets,
p. 3.
Moreover, due to the time-lags inherent in the Earth's climate, the
Climate Stabilization Targets assessment notes that the full warming
from any given concentration of CO2 reached will not be
realized for several centuries.
The most recent USGCRP ``National Climate Assessment'' \32\
emphasizes that climate change is already happening now and is
happening in the United States. The assessment documents the increases
in some extreme weather and climate events in recent decades, as well
as the resulting damage and disruption to infrastructure and
agriculture, and projects continued increases in impacts across a wide
range of peoples, sectors, and ecosystems.
---------------------------------------------------------------------------
\32\ U.S. Global Change Research Program, Climate Change Impacts
in the United States: The Third National Climate Assessment, May
2014 Available at http://nca2014.globalchange.gov/.
---------------------------------------------------------------------------
These assessments underscore the urgency of reducing emissions now.
Today's emissions will otherwise lead to raised atmospheric
concentrations for thousands of years, and raised Earth system
temperatures for even longer. Emission reductions today will benefit
the public health and public welfare of current and future generations.
Finally, it should be noted that the concentration of carbon
dioxide in the atmosphere continues to rise dramatically. In 2009, the
year of the Endangerment Finding, the average concentration of carbon
dioxide as measured on top of Mauna Loa was 387 parts per million.\33\
The average concentration in 2015 was 401 parts per million, the first
time an annual average has exceeded 400 parts per million since record
keeping began at Mauna Loa in 1958, and for at least the past 800,000
years according to ice core records.\34\ Moreover, 2015 was the warmest
year globally in the modern global surface temperature record, going
back to 1880, breaking the record previously held by 2014; this now
means that the last 15 years have been 15 of the 16 warmest years on
record.\35\
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\33\ ftp://aftp.cmdl.noaa.gov/products/trends/co2/co2_annmean_mlo.txt.
\34\ http://www.esrl.noaa.gov/gmd/ccgg/trends/.
\35\ http://www.ncdc.noaa.gov/sotc/global/201513.
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(b) The EPA and NHTSA 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).
More recently, the agencies adopted even stricter standards for model
years 2017 and later (77 FR 62624, October 15, 2012). The agencies have
used the light-duty National Program as a model for the HD National
Program in several respects. This is most apparent in the case of
heavy-duty pickups and vans, which are 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, and several light-duty
manufacturers also manufacture HD pickups and vans).\36\ For HD pickups
and vans, there are close parallels to the light-duty program in how
the agencies have developed our respective heavy-duty standards and
compliance structures. However, HD pickups and vans are true work
vehicles that are designed for much higher towing and payload
capabilities than are light-duty pickups and vans. The technologies
applied to light-duty trucks are not all applicable to heavy-duty
pickups and vans at the same adoption rates, and the technologies often
produce a lower percent reduction in CO2 emissions and fuel
consumption when used in heavy-duty vehicles. Another difference
between the light-duty and the heavy-duty standards is that each agency
adopts heavy-duty standards based on attributes other than vehicle
footprint, as discussed below.
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\36\ This is more broadly true for heavy-duty pickup trucks than
vans because every manufacturer of heavy-duty pickup trucks also
makes light-duty pickup trucks, while only some heavy-duty van
manufacturers also make light-duty vans.
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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 throughout the
Phase 1 rulemaking and the continued efforts for Phase 2. Most notably,
as with the light-duty program, manufacturers will continue to be able
to design and build vehicles to meet a closely coordinated, harmonized
national program, and to avoid unnecessarily duplicative testing and
compliance burdens. In addition, the averaging, banking, and trading
provisions in the HD program, although structurally different from
those of the light-duty program, serve the same purpose, which is to
allow manufacturers to achieve large reductions in fuel consumption and
emissions while providing a broad mix of products to their customers.
The agencies have also worked closely with CARB to provide harmonized
national standards.
(c) EPA's SmartWay Program
EPA's voluntary SmartWay Transport Partnership program encourages
businesses to take actions that reduce fuel consumption and
CO2 emissions while cutting costs by working with the
shipping, logistics, and carrier communities to identify low carbon
strategies and technologies across their transportation supply chains.
SmartWay provides technical information, benchmarking and tracking
tools, market incentives, and partner recognition to facilitate and
accelerate the adoption of these strategies. Through the SmartWay
program and its related technology assessment center, EPA has worked
closely with truck and trailer manufacturers and truck fleets over the
past 12 years 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. SmartWay partners have demonstrated these
new and emerging technologies in their business operations, adding to
the body of technical data and information that EPA can disseminate to
industry, researchers and other stakeholders. Over the last several
years, EPA has developed hands-on experience testing the largest heavy-
duty trucks and trailers and evaluating improvements in tire and
vehicle aerodynamic performance. In developing the Phase 1
[[Page 73488]]
program, the agencies drew from this testing and from the SmartWay
experience. In the same way, the agencies benefitted from SmartWay in
developing the Phase 2 trailer program.
(d) DOE's SuperTruck Initiative
The U.S. Department of Energy launched its SuperTruck I initiative
in 2009. SuperTruck I was a DOE partnership with four industry teams,
who at this point have either met the SuperTruck I 50 percent fuel
efficiency improvement goal (relative to a 2009 best-in-class truck) or
have laid the groundwork to succeed. Teams from Cummins/Peterbilt,
Daimler, and Volvo exceeded the 50 percent efficiency improvement goal,
with Navistar on track to exceed this target later this year. Research
vehicles developed under SuperTruck I are Class 8 combination tractor-
trailers that have dramatically increased fuel and freight efficiency
through the use of advanced technologies. These technologies include
tractor and trailer aerodynamic devices, engine waste heat recovery
systems, hybrids, automated transmissions and lightweight materials. In
March 2016 DOE announced SuperTruck II, which is an $80M follow-on to
SuperTruck I, where DOE will continue to partner with industry teams to
collaboratively fund new projects to research, develop, and demonstrate
technologies to further improve heavy-truck freight efficiency--by more
than 100 percent, relative to a manufacturer's best-in-class 2009
truck. Achieving these kinds of Class 8 truck efficiency increases will
require an integrated systems approach to ensure that the various
components of the vehicle work well together. SuperTruck II projects
will utilize a wide variety of truck and trailer technology approaches
to achieve performance targets, such as further improvements in engine
efficiency, drivetrain efficiency, aerodynamic drag, tire rolling
resistance, and vehicle weight.
The agencies leveraged the outcomes of SuperTruck I by projecting
how these tractor and trailer technologies could continue to advance
from this early developmental stage toward the prototype and production
stages. For a number of the SuperTruck technologies, the agencies are
projecting advancement into production, given appropriate lead time.
For example, a number of the aerodynamic and transmission technologies
are projected to be in widespread production by 2021, and the agencies
are finalizing 2021 standards based in part on performance of these
SuperTruck technologies. For other more advanced SuperTruck
technologies, such as organic Rankine cycle waste heat recovery
systems, the agencies are projecting that additional lead time is
needed to ensure that these technologies will be effective and reliable
in production. For these technologies, the agencies are finalizing 2027
standards whose stringency reflects a significant market adoption rate
of advanced technologies, including waste heat recovery systems.
Furthermore, the agencies are encouraged by DOE's announcement of
SuperTruck II. We believe that the combination of HD Phase 2 and
SuperTruck II will provide both a strong motivation and a proven means
for manufacturers to fully develop these technologies within the lead
times we have projected.
(e) The State of California
California has established ambitious goals for reducing GHG
emissions from heavy-duty vehicles and engines as part of an overall
plan to reduce GHG emissions from the transportation sector in
California.\37\ Heavy-duty vehicles are responsible for one-fifth of
the total GHG emissions from transportation sources in California. In
the past several years, the California Air Resources Board (CARB) has
taken a number of actions to reduce GHG emissions from heavy-duty
vehicles and engines. For example, in 2008, CARB adopted regulations to
reduce GHG emissions from heavy-duty tractors that pull box-type
trailers through improvements in tractor and trailer aerodynamics and
the use of low rolling resistance tires.\38\ The tractor-trailer
operators subject to the CARB regulation are required to use SmartWay-
certified tractors and trailers, or retrofit their existing fleet with
SmartWay-verified technologies, consistent with California's state
authority to regulate both new and in-use vehicles. In December 2013,
CARB adopted regulations that establish its own parallel Phase 1
program with standards consistent with EPA Phase 1 standards. On
December 5, 2014, California's Office of Administrative Law approved
CARB's adoption of the Phase 1 standards, with an effective date of
December 5, 2014.\39\ Complementary to its regulatory efforts, CARB and
other California agencies are investing significant public capital
through various incentive programs to accelerate fleet turnover and
stimulate technology innovation within the heavy-duty vehicle market
(e.g., Air Quality Improvement, Carl Moyer, Loan Incentives, Lower-
Emission School Bus and Goods Movement Emission Reduction
Programs).\40\ Recently, California Governor Jerry Brown established a
target of up to 50 percent petroleum reduction by 2030.
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\37\ See http://www.arb.ca.gov/cc/cc.htm for details on the
California Air Resources Board climate change actions, including a
discussion of Assembly Bill 32, and the Climate Change Scoping Plan
developed by CARB, which includes details regarding CARB's future
goals for reducing GHG emissions from heavy-duty vehicles.
\38\ See http://www.arb.ca.gov/msprog/truckstop/trailers/trailers.htm for a summary of CARB's ``Tractor-Trailer Greenhouse
Gas Regulation.''
\39\ See http://www.arb.ca.gov/regact/2013/hdghg2013/hdghg2013.htm for details regarding CARB's adoption of the Phase 1
standards.
\40\ See http://www.arb.ca.gov/ba/fininfo.htm for detailed
descriptions of CARB's mobile source incentive programs. Note that
EPA works to support CARB's heavy-duty incentive programs through
the West Coast Collaborative (http://westcoastcollaborative.org/)
and the Clean Air Technology Initiative (https://www.epa.gov/cati).
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California has long had the unique ability among states to adopt
its own separate new motor vehicle standards per section 209 of the
Clean Air Act (CAA). Although section 209(a) of the CAA expressly
preempts states from adopting and enforcing standards relating to the
control of emissions from new motor vehicles or new motor vehicle
engines (such as state controls for new heavy-duty engines and
vehicles), CAA section 209(b) directs EPA to waive this preemption
under certain conditions. Under the waiver process set out in CAA
section 209(b), EPA has granted CARB a waiver for its initial heavy-
duty vehicle GHG regulation.\41\ Even with California's ability under
the CAA to establish its own emission standards, EPA and CARB have
worked closely together over the past several decades to largely
harmonize new vehicle criteria pollutant standard programs for heavy-
duty engines and heavy-duty vehicles. In the past several years EPA and
NHTSA also consulted with CARB in the development of the Federal light-
duty vehicle GHG and CAFE rulemakings for the 2012-2016 and 2017-2025
model years.
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\41\ See EPA's waiver of CARB's heavy-duty tractor-trailer
greenhouse gas regulation applicable to new 2011 through 2013 model
year Class 8 tractors equipped with integrated sleeper berths
(sleeper-cab tractors) and 2011 and subsequent model year dry-can
and refrigerated-van trailers that are pulled by such tractors on
California highways at 79 FR 46256 (August 7, 2014).
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As discussed above, California operates under state authority to
establish its own new heavy-duty vehicle and engine emission standards,
including standards for CO2, methane, N2O, and
hydrofluorocarbons. EPA recognizes this independent authority, and we
also recognize the potential benefits for the regulated industry if the
Federal Phase 2 standards could result
[[Page 73489]]
in a single, National Program that would meet the EPA and NHTSA's
statutory requirements to set appropriate and maximum feasible
standards, and also be equivalent to potential future new heavy-duty
vehicle and engine GHG standards established by CARB (addressing the
same model years as addressed by the final Federal Phase 2 program and
requiring the same technologies). In order to further the opportunity
for maintaining coordinated Federal and California standards in the
Phase 2 timeframe (as well as to benefit from different technical
expertise and perspective), EPA and NHTSA consulted frequently with
CARB while developing the Phase 2 rule. Prior to the proposal, the
agencies' technical staff shared information on technology cost,
technology effectiveness, and feasibility with the CARB staff. We also
received information from CARB on these same topics. In addition, CARB
staff and managers participated with EPA and NHTSA in meetings with
many external stakeholders, in particular with vehicle OEMs and
technology suppliers. The agencies continued significant consultation
during the development of the final rules.
EPA and NHTSA believe that through this information sharing and
dialog we have enhanced the potential for the Phase 2 program to result
in a National Program that can be adopted not only by the Federal
agencies, but also by the State of California, given the strong
interest from the regulated industry for a harmonized State and Federal
program. In its public comments, California reiterated its support for
a harmonized State and Federal program, although it identified several
areas in which it believed the proposed program needed to be
strengthened.
(f) Environment and Climate Change Canada
On March 13, 2013, Environment and Climate Change Canada (ECCC),
which is EPA's Canadian counterpart, published its own regulations to
control GHG emissions from heavy-duty vehicles and engines, beginning
with MY 2014. These regulations are closely aligned with EPA's Phase 1
program to achieve a common set of North American standards. ECCC has
expressed its intention to amend these regulations to further limit
emissions of greenhouse gases from new on-road heavy-duty vehicles and
their engines for post-2018 MYs. As with the development of the current
regulations, ECCC is committed to continuing to work closely with EPA
to maintain a common Canada-United States approach to regulating GHG
emissions for post-2018 MY vehicles and engines. This approach will
build on the long history of regulatory alignment between the two
countries on vehicle emissions pursuant to the Canada-United States Air
Quality Agreement.\42\ In furtherance of this coordination, EPA
participated in a workshop hosted by ECCC on March 3, 2016 to discuss
Canada's Phase 2 program.\43\
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\42\ http://www.ijc.org/en_/Air_Quality__Agreement.
\43\ ``Phase 2 of the Heavy-duty Vehicle and Engine Greenhouse
Gas Emission Regulations; Pre-Consultation Session,'' March 3, 2016.
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The Government of Canada, including ECCC and Transport Canada, has
also been of great assistance during the development of this Phase 2
rule. In particular, the Government of Canada supported aerodynamic
testing, and conducted chassis dynamometer emissions testing.
(g) Recommendations of the National Academy of Sciences
In April 2010, as mandated by Congress in the EISA, the National
Research Council (NRC) under the National Academy of Sciences (NAS)
issued a report to NHTSA and to Congress evaluating medium- and heavy-
duty truck fuel efficiency improvement opportunities, titled
``Technologies and Approaches to Reducing the Fuel Consumption of
Medium- and Heavy-duty Vehicles.'' That NAS report was far reaching in
its review of the technologies that were available and that might
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 included technologies that may not be
available until 2020 or even further into the future. The report
provided not only a valuable list of off-the-shelf technologies from
which the agencies drew in developing the Phase 1 program, but also
provided useful information the agencies have considered when
developing this second phase of regulations.
In April 2014, the NAS issued another report: ``Reducing the Fuel
Consumption and Greenhouse Gas Emissions of Medium- and Heavy-Duty
Vehicles, Phase Two, First Report.'' \44\ This study outlines a number
of recommendations to the U.S. Department of Transportation and NHTSA
on technical and policy matters to consider when addressing the fuel
efficiency of our nation's medium- and heavy-duty vehicles. In
particular, this report provided recommendations with respect to:
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\44\ National Research Council ``Reducing the Fuel Consumption
and Greenhouse Gas Emissions of Medium- and Heavy-Duty Vehicles,
Phase Two.'' Washington, DC, The National Academies Press.
Cooperative Agreement DTNH22-12-00389. Available electronically from
the National Academy Press Web site at http://www.nap.edu/catalog/18736/reducing-the-fuel-consumption-and-greenhouse-gas-emissions-of-medium-and-heavy-duty-vehicles-phase-two (last accessed May 18,
2016). On September 24, 2016, NAS will release an update report,
consistent with Congress' quinquennial update requirement.
The Greenhouse Gas Emission Model (GEM) simulation tool used
by the agencies to assess compliance with vehicle standards
Regulation of trailers
Natural gas-fueled engines and vehicles
Data collection on in-use operation
The agencies are adopting many of these recommendations into the
Phase 2 program, including recommendations relating to the GEM
simulation tool and to trailers.
B. Summary of Phase 1 Program
(1) EPA Phase 1 GHG Emission Standards and NHTSA Phase 1 Fuel
Consumption Standards
The EPA Phase 1 mandatory GHG emission standards commenced in MY
2014 and include increased stringency for standards applicable to MY
2017 and later MY vehicles and engines. NHTSA's fuel consumption
standards were voluntary for MYs 2014 and 2015, due to lead time
requirements in EISA, and apply on a mandatory basis thereafter. They
also increase in stringency for MY 2017. Both agencies allowed
voluntary early compliance starting in MY 2013 and encouraged
manufacturers' participation through credit incentives.
Given the complexity of the heavy-duty industry, the agencies
divided the industry into three discrete categories for purposes of
setting our respective Phase 1 standards--combination tractors, heavy-
duty pickups and vans, and vocational vehicles--based on the relative
degree of homogeneity among trucks within each category. The Phase 1
rules also include separate standards for the engines that power
combination tractors and vocational vehicles. For each regulatory
category, the agencies adopted related but distinct program approaches
reflecting the specific challenges in these segments. In the following
paragraphs, we briefly summarize EPA's Phase 1 GHG emission standards
and NHTSA's Phase 1 fuel consumption standards for the three regulatory
categories of heavy-duty vehicles and for the engines powering
vocational vehicles and
[[Page 73490]]
tractors. See Sections II, III, V, and VI for additional details on the
Phase 1 standards. To respect differences in design and typical uses
that drive different technology solutions, the agencies segmented each
regulatory class into subcategories. The category-specific structure
enabled the agencies to set standards that appropriately reflect the
technology available for each regulatory subcategory of vehicles and
the engines for use in each type of vehicle. The Phase 1 program also
provided several flexibilities, as summarized in Section I.B.(3).
The agencies proposed and are adopting Phase 2 standards based on
test procedures that differ from those used for Phase 1, including the
revised GEM simulation tool. Significant revisions to GEM are discussed
in Section II and in the RIA Chapter 4, and other test procedures are
discussed further in the RIA Chapter 3. The pre-proposal revisions from
Phase 1 GEM reflected input from both the NAS and from industry.\45\
Changes since the proposal generally reflect comments received from
industry and other key stakeholders. It is important to note that due
to these test procedure changes, the Phase 1 and Phase 2 standards are
not directly comparable in an absolute sense. In particular, the
revisions being made to the 55 mph and 65 mph highway cruise cycles for
tractors and vocational vehicles have the effect of making the cycles
more challenging (albeit more representative of actual driving
conditions). We are not applying these revisions to the Phase 1 program
because doing so would significantly change the stringency of the Phase
1 standards, for which manufacturers have already developed engineering
plans and are now producing products to meet. Moreover, the changes to
GEM address a broader range of technologies not part of the projected
compliance path for use in Phase 1.
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\45\ For further discussion of the input the agencies received
from NAS, see Section XII of the Phase 2 NPRM at 80 FR 40512, July
13, 2015.
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Because the numeric values of the Phase 2 tractor and vocational
standards are not directly comparable to their respective Phase 1
standards, the Phase 1 numeric standards were not appropriate baseline
values to use to determine Phase 2's improvements. To address this
situation, the agencies applied all of the new Phase 2 test procedures
and GEM software to tractors and vocational vehicles equipped with
Phase 1 compliant levels of technology. The agencies used the results
of this approach to establish appropriate Phase 1 baseline values,
which are directly comparable to the Phase 2 standards. For example, in
this rulemaking we present Phase 2 per vehicle percent reductions
versus Phase 1, and for tractors and vocational vehicles these percent
reductions were all calculated versus Phase 1 compliant vehicles, where
we applied the Phase 2 test procedures and GEM software to determine
these Phase 1 vehicles' results.
(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 60 percent, due to their large
payloads, their high annual miles traveled, and their major role in
national freight transport. These vehicles consist of a cab and engine
(tractor or combination tractor) and a detachable trailer. The primary
manufacturers of combination tractors in the United States are Daimler
Trucks North America, Navistar, Volvo/Mack, and PACCAR. Each of the
tractor manufacturers and Cummins (an independent engine manufacturer)
also produce heavy-duty engines used in tractors. The Phase 1 standards
require manufacturers to reduce GHG emissions and fuel consumption for
these tractors and engines, which we expect them to do through
improvements in aerodynamics and tires, reductions in tractor weight,
reduction in idle operation, as well as engine-based efficiency
improvements.\46\
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\46\ We note although the standards' stringency is predicated on
use of certain technologies, and the agencies' assessed the cost of
the rule based on the cost of use of those technologies, the
standards can be met by any means. Put another way, the rules create
a performance standard, and do not mandate any particular means of
achieving that level of performance.
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The Phase 1 tractor standards differ depending on gross vehicle
weight rating (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.'' The agencies created nine subcategories within the
Class 7 and 8 combination tractor category reflecting combinations of
these attributes. The agencies set Phase 1 standards for each of these
subcategories beginning in MY 2014, with more stringent standards
following in MY 2017. 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 MY 2010 tractor and engine.
For Phase 1, tractor manufacturers demonstrate compliance with the
tractor CO2 and fuel consumption standards using a vehicle
simulation tool described in Section II. The tractor inputs to the
simulation tool in Phase 1 are the aerodynamic performance, tire
rolling resistance, vehicle speed limiter, automatic engine shutdown,
and weight reduction.
In addition to the Phase 1 tractor-based standards for
CO2, EPA adopted a separate standard to reduce leakage of
hydrofluorocarbon (HFC) refrigerant from cabin air conditioning (A/C)
systems from combination tractors, to apply to the tractor
manufacturer. This HFC leakage standard is independent of the
CO2 tractor standard. Manufacturers can choose technologies
from a menu of leak-reducing technologies sufficient to comply with the
standard, as opposed to using a test to measure performance. Given that
HFC leakage does not relate to fuel efficiency, NHTSA did not adopt
corresponding HFC standards.
(b) Heavy-Duty Pickup Trucks and Vans (Class 2b and 3)
Heavy-duty vehicles with a GVWR between 8,501 and 10,000 lb. are
classified as Class 2b motor vehicles. Heavy-duty vehicles with a 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 23 percent of today's GHG
emissions from the heavy-duty vehicle sector.\47\
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\47\ EPA MOVES Model, http://www3.epa.gov/otaq/models/moves/index.htm.
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The majority of HD pickups and vans are \3/4\-ton and 1-ton pickup
trucks, 12- and 15-passenger vans,\48\ 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 vehicles can also be sold as cab-complete vehicles (i.e.,
incomplete vehicles that include complete or nearly complete cabs that
are sold to secondary manufacturers). The majority of heavy-duty
pickups and vans are produced by companies with major light-duty
markets in the United States. 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 and NHTSA
concluded
[[Page 73491]]
that it was appropriate to adopt GHG standards, expressed as grams per
mile, and fuel consumption standards, expressed as gallons per 100
miles, for HD pickups and vans based on the whole vehicle (including
the engine), consistent with the way these vehicles have been regulated
by EPA for criteria pollutants and also consistent with the way their
light-duty counterpart vehicles are regulated by EPA and NHTSA. This
complete vehicle approach adopted by both agencies for HD pickups and
vans was consistent with the recommendations of the NAS Committee in
its 2010 Report.
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\48\ Note that 12-passenger vans are subject to the light-duty
standards as medium-duty passenger vehicles (MDPVs) and are not
subject to this proposal.
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For the light-duty GHG and fuel economy standards, the agencies
based the emissions and fuel economy targets on vehicle footprint (the
wheelbase times the average track width). For those standards,
passenger cars and light trucks with larger footprints are assigned
higher GHG and lower fuel economy target levels reflecting 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 have found that a work-based
metric is a more appropriate attribute than the footprint attribute
utilized in the light-duty vehicle rulemaking, given that work-based
measures such as towing and payload capacities are critical elements of
these vehicles' functionality. EPA and NHTSA therefore adopted
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.
Each manufacturer's fleet average Phase 1 standard is based on
production volume-weighting of target standards for all vehicles, which
in turn are based on each vehicle's work factor. These target standards
are taken from a set of curves (mathematical functions), with separate
curves for gasoline and diesel vehicles.\49\ However, both gasoline and
diesel vehicles in this category are included in a single averaging
set. EPA phased in the CO2 standards gradually starting in
the 2014 MY, at 15-20-40-60-100 percent of the MY 2018 standards
stringency level in MYs 2014-2015-2016-2017-2018, respectively (i.e.,
the 2014 standards requires only 15 percent of the reduction required
in 2018, etc.). The phase-in takes the form of a set of target curves,
with increasing stringency in each MY.
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\49\ As explained in Section XI, as part of this rulemaking, EPA
moved the Phase 1 requirements for pickups and vans from 40 CFR
1037.104 into 40 CFR part 86, which is also the regulatory part that
applies for light-duty vehicles.
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NHTSA allowed manufacturers to select one of two fuel consumption
standard alternatives for MYs 2016 and later. The first alternative
defined individual gasoline vehicle and diesel vehicle fuel consumption
target curves that will not change for MYs 2016-2018, and are
equivalent to EPA's 67-67-67-100 percent target curves in MYs 2016-
2017-2018-2019, respectively. The second alternative defined target
curves that are equivalent to EPA's 40-60-100 percent target curves in
MYs 2016-2017-2018, respectively. NHTSA allowed manufacturers to opt
voluntarily into the NHTSA HD pickup and van program in MYs 2014 or
2015 at target curves equivalent to EPA's target curves. If a
manufacturer chose to opt in for one category, they would be required
to opt in for all categories. In other words, a manufacturer would be
unable to opt in for Class 2b vehicles, but opt out for Class 3
vehicles.
EPA also adopted an alternative phase-in schedule for manufacturers
wanting to have stable standards for model years 2016-2018. The
standards for heavy-duty pickups and vans, like those for light-duty
vehicles, are expressed as set of target standard curves, with
increasing stringency in each model year. The Phase 1 EPA standards for
2018 (including a separate standard to control air conditioning system
leakage) are estimated to represent an average per-vehicle reduction in
GHG emissions of 17 percent for diesel vehicles and 12 percent for
gasoline vehicles (relative to pre-control baseline vehicles). The
NHTSA standard will require these vehicles to achieve up to about 15
percent reduction in fuel consumption by MY 2018 (relative to pre-
control baseline vehicles). Manufacturers demonstrate compliance based
on entire vehicle chassis certification using the same duty cycles used
to demonstrate compliance with criteria pollutant standards.
(c) Class 2b-8 Vocational Vehicles
Class 2b-8 vocational vehicles include a wide variety of vehicle
types, and serve a vast range of functions. Some examples include
service for parcel delivery, refuse hauling, utility service, dump,
concrete mixing, transit service, shuttle service, school bus,
emergency, motor homes, and tow trucks. In Phase 1, we defined Class
2b-8 vocational vehicles as all heavy-duty vehicles that are not
included in either the heavy-duty pickup and van category or the Class
7 and 8 tractor category. EPA's and NHTSA's Phase 1 standards for this
vocational vehicle category generally apply at the chassis manufacturer
level. Class 2b-8 vocational vehicles and their engines emit
approximately 17 percent of the GHG emissions and burn approximately 17
percent of the fuel consumed by today's heavy-duty truck sector.\50\
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\50\ EPA MOVES model, http://www3.epa.gov/otaq/models/moves/index.htm.
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The Phase 1 program for vocational vehicles has vehicle standards
and separate engine standards, both of which differ based on the weight
class of the vehicle into which the engine will be installed. The
vehicle weight class groups mirror those used for the engine
standards--Classes 2b-5 (light heavy-duty or LHD in EPA regulations),
Classes 6 and 7 (medium heavy-duty or MHD in EPA regulations) and Class
8 (heavy heavy-duty or HHD in EPA regulations). Manufacturers
demonstrate compliance with the Phase 1 vocational vehicle
CO2 and fuel consumption standards using a vehicle
simulation tool described in Section II. The Phase 1 program for
vocational vehicles limited the simulation tool inputs to tire rolling
resistance. The model assumes the use of a typical representative,
compliant engine in the simulation, resulting in one overall value for
CO2 emissions and one for fuel consumption.
(d) Engine Standards
The agencies established separate Phase 1 performance standards for
the engines manufactured for use in vocational vehicles and Class 7 and
8 tractors.\51\ These engine standards vary depending on engine size
linked to intended vehicle service class. EPA's engine-based
CO2 standards and NHTSA's engine-based fuel consumption
standards are being implemented using EPA's existing test procedures
and regulatory structure for criteria pollutant emissions from heavy-
duty engines. EPA also established engine-based N2O and
CH4 emission standards in Phase 1.
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\51\ See 76 FR 57114 explaining why NHTSA's authority under the
Energy Independence and Safety Act includes authority to establish
separate engine standards.
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(e) Manufacturers Excluded From the Phase 1 Standards
Phase 1 deferred 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
[[Page 73492]]
defines a small business by the maximum number of employees; for
example, this is currently 1,500 for heavy-duty truck manufacturing and
1,000 for engine manufacturing.\52\ In order to utilize this exemption,
qualifying small businesses must submit a declaration to the agencies.
See Section I.F.(1)(b) for a summary of how Phase 2 applies for small
businesses.
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\52\ These thresholds were revised in early 2016. See http://www.regulations.gov/#!documentDetail;D=SBA-2014-0011-0031.
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The agencies stated that they would 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 that introduce new products into the
U.S.
(2) Costs and Benefits of the Phase 1 Program
Overall, EPA and NHTSA estimated that the Phase 1 HD National
Program will cost the affected industry about $8 billion, while saving
vehicle owners fuel costs of nearly $50 billion over the lifetimes of
MY 2014-2018 vehicles. The agencies also estimated that the combined
standards will reduce CO2 emissions by about 270 million
metric tons and save about 530 million barrels of oil over the life of
MY 2014 to 2018 vehicles. The agencies estimated additional monetized
benefits from CO2 reductions, improved energy security,
reduced time spent refueling, as well as possible dis-benefits from
increased driving crashes, traffic congestion, and noise. When
considering all these factors, we estimated that Phase 1 of the HD
National Program will yield $49 billion in net benefits to society over
the lifetimes of MY 2014-2018 vehicles.
EPA estimated the benefits of reduced ambient concentrations of
particulate matter and ozone resulting from the Phase 1 program to
range from $1.3 to $4.2 billion in 2030.\53\
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\53\ Note: These calendar year benefits do not represent the
same time frame as the model year lifetime benefits described above,
so they are not additive.
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In total, we estimated the combined Phase 1 standards will reduce
GHG emissions from the U.S. heavy-duty fleet by approximately 76
million metric tons of CO2-equivalent annually by 2030. In
its Environmental Impact Statement for the Phase 1 rule, NHTSA also
quantified and/or discussed other potential impacts of the program,
such as the health and environmental impacts associated with changes in
ambient exposures to toxic air pollutants and the benefits associated
with avoided non-CO2 GHGs (methane, nitrous oxide, and
HFCs).
(3) Phase 1 Program Flexibilities
As noted above, the agencies adopted numerous provisions designed
to give manufacturers a degree of flexibility in complying with the
Phase 1 standards. These provisions, which are essentially identical in
structure and function in EPA's and NHTSA's regulations, 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.\54\
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\54\ NHTSA explained 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).
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Phase 1 included 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 ABT provisions were patterned on
existing EPA and NHTSA ABT programs (including the light-duty GHG and
fuel economy standards) 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. As
also noted above, for HD pickups and vans, we adopted a fleet averaging
system very similar to the light-duty GHG and CAFE fleet averaging
system. In both programs, manufacturers are allowed to carry-forward
deficits for up to three years without penalty. The agencies provided
in the ABT programs flexibility for situations in which a manufacturer
is unable to avoid a negative credit balance at the end of the year. In
such cases, manufacturers are not considered to be out of compliance
unless they are unable to make up the difference in credits by the end
of the third subsequent model year.
In total, the Phase 1 program divides the heavy-duty sector into 14
subcategories of vehicles and 4 subcategories of engines. These
subcategories are grouped into 4 vehicle averaging sets and 4 engine
averaging sets in the ABT program. For tractors and vocational
vehicles, the fleet averaging sets are: Light heavy-duty (Classes 2b-
5); medium heavy-duty (Class 6-7); and heavy heavy-duty (Class 8).
Complete HD pickups and vans (both spark-ignition and compression-
ignition) are the final vehicle averaging set. For engines, the fleet
averaging sets are spark-ignition engines, compression-ignition light
heavy-duty engines, compression-ignition medium heavy-duty engines, and
compression-ignition heavy heavy-duty engines. ABT allows the exchange
of credits within an averaging set. This means that a Class 8 day cab
tractor can exchange credits with a Class 8 sleeper tractor but not
with a smaller Class 7 tractor. Also, a Class 8 vocational vehicle can
exchange credits with a Class 8 tractor. However, we did not allow
trading between engines and chassis (i.e. vehicles).
In addition to ABT, the other primary flexibility provisions in the
Phase 1 program involve opportunities to generate early credits,
advanced technology credits (including for use of hybrid powertrains),
and innovative technology credits.\55\ For the early credits and
advanced technology credits, the agencies adopted a 1.5x multiplier,
meaning that manufacturers would get 1.5 credits for each early credit
and each advanced technology credit. In addition, advanced technology
credits for Phase 1 can be used anywhere within the heavy-duty sector
(including both vehicles and engines). Put another way, as a means of
promoting these promising technologies, the Phase 1 rule does not
restrict averaging or trading by averaging set in this instance.
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\55\ Early credits are for engines and vehicles certified before
EPA standards became mandatory, advanced technology credits are for
hybrids and/or Rankine cycle engines, and innovative technology
credits are for other technologies not in the 2010 fleet whose
benefits are not reflected using the Phase 1 test procedures.
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For other vehicle or engine technologies that can reduce
CO2 and fuel consumption, but whose benefits are not
reflected if measured using the Phase 1 test procedures, the agencies
wanted to encourage the development of such innovative technologies,
and therefore adopted special ``innovative technology'' credits. These
innovative technology credits apply to technologies that are shown to
produce emission and fuel consumption reductions that are not
adequately recognized on the Phase 1 test procedures and that were not
yet in widespread use in the heavy-duty sector before MY 2010.
Manufacturers
[[Page 73493]]
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 Phase 1 test procedures. As with ABT, the use of
innovative technology credits is allowed only among vehicles and
engines of the same defined averaging set generating the credit, as
described above. The credit multiplier likewise does not apply for
innovative technology credits.
(4) Implementation of Phase 1
Manufacturers have already begun complying with the Phase 1
standards. In some cases manufacturers voluntarily chose to comply
early, before compliance was mandatory. The Phase 1 rule allowed
manufacturers to generate credits for such early compliance. The market
appears to be very accepting of the new technologies, and the agencies
have seen no evidence of ``pre-buy'' effects in response to the
standards. In fact sales have been higher in recent years than they
were before Phase 1. Moreover, manufacturers' compliance plans indicate
intention to utilize the Phase 1 flexibilities, and we have yet to see
significant non-compliance with the standards.
(5) Litigation on Phase 1 Rule
The D.C. Circuit rejected all challenges to the agencies' Phase 1
regulations. The court did not reach the merits of the challenges,
holding that none of the petitioners had standing to bring their
actions, and that a challenge to NHTSA's denial of a rulemaking
petition could only be brought in District Court. See Delta
Construction v. EPA, 783 F. 3d 1291 (D.C. Cir. 2015).
C. Summary of the Phase 2 Standards and Requirements
The agencies are adopting new standards that build on and enhance
existing Phase 1 standards, and are adopting as well the first-ever
standards for certain trailers used in combination with heavy-duty
tractors. Taken together, the Phase 2 program comprises a set of
largely technology-advancing standards that will achieve greater GHG
and fuel consumption savings than the Phase 1 program. As described in
more detail in the following sections, the agencies are adopting these
standards because, based on the information available at this time and
careful consideration of all comments, we believe they best fulfill our
respective statutory authorities when considered in the context of
available technology, feasible reductions of emissions and fuel
consumption, costs, lead time, safety, and other relevant factors.
The Phase 2 standards represent a more technology-forcing \56\
approach than the Phase 1 approach, predicated on use of both off-the-
shelf technologies and emerging technologies that are not yet in
widespread use. The agencies are adopting standards for MY 2027 that we
project will require manufacturers to make extensive use of these
technologies. The standards increase in stringency incrementally
beginning in MY 2018 for trailers and in MY 2021 for other segments,
ensuring steady improvement to the MY 2027 stringency levels. For
existing technologies and technologies in the final stages of
development, we project that manufacturers will likely apply them to
nearly all vehicles, excluding those specific vehicles with
applications or uses that prevent the technology from functioning
properly. We also project as one possible compliance pathway that
manufacturers could apply other more advanced technologies such as
hybrids and waste engine heat recovery systems, although at lower
application rates than the more conventional technologies. Comments on
the overall stringency of the proposed Phase 2 program were mixed. Many
commenters, including most non-governmental organizations, supported
more stringent standards with less lead time. Many technology and
component suppliers supported more stringent standards but with the
proposed lead time. Vehicle manufacturers did not support more
stringent standards and emphasized the importance of lead time. To the
extent these commenters provided technical information to support their
comments on stringency and lead time, it is discussed in Sections II
through VI.
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\56\ In this context, the term ``technology-forcing'' has a
specific legal meaning and is used to distinguish standards that
will effectively require manufacturers to develop new technologies
(or to significantly improve technologies) from standards that can
be met using off-the-shelf technology alone. See, e.g., NRDC v. EPA,
655 F. 2d 318, 328 (D.C. Cir. 1981). Technology-forcing standards do
not require manufacturers to use any specific technologies. See also
76 FR 57130 (explaing that section 202(a)(2) allows EPA to adopt
such technology-forcing standards, although it does not compell such
standards).
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The standards being adopted provide approximately ten years of lead
time for manufacturers to meet these 2027 standards, which the agencies
believe is appropriate to implement the technologies industry could use
to meet these standards. For some of the more advanced technologies
production prototype parts are not yet available, though they are in
the research stage with some demonstrations in actual vehicles.\57\ In
the respective sections of Chapter 2 of the RIA, the agencies explain
what further steps are needed to successfully and reliably
commercialize these prototypes in the lead time afforded by the Phase 2
standards. Additionally, even for the more developed technologies,
phasing in more stringent standards over a longer timeframe will help
manufacturers to ensure better reliability of the technology and to
develop packages to work in a wide range of applications.
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\57\ ``Prototype'' as it is used here refers to technologies
that have a potentially production-feasible design that is expected
to meet all performance, functional, reliability, safety,
manufacturing, cost and other requirements and objectives that is
being tested in laboratories and on highways under a full range of
operating conditions, but is not yet available in production
vehicles already for sale in the market.
---------------------------------------------------------------------------
As discussed later, the agencies are also adopting new standards in
MYs 2018 (trailers only), 2021, and 2024 to ensure that manufacturers
make steady progress toward the 2027 standards, thereby achieving
steady and feasible reductions in GHG emissions and fuel consumption in
the years leading up to the MY 2027 standards.
Providing additional lead time can often enable manufacturers to
resolve technological challenges or to find lower cost means of meeting
new regulatory standards, effectively making them more feasible in
either case. See generally NRDC v. EPA, 655 F. 2d 318, 329 (D.C. Cir.
1981). On the other hand, manufacturers and/or operators may incur
additional costs if regulations require them to make changes to their
products with less lead time than manufacturers would normally have
when bringing a new technology to the market or expanding the
application of existing technologies. After developing a new
technology, manufacturers typically conduct extensive field tests to
ensure its durability and reliability in actual use. Standards that
accelerate technology deployment can lead to manufacturers incurring
additional costs to accelerate this development work, or can lead to
manufacturers beginning production before such testing can be
completed. Some industry stakeholders have informed EPA that when
manufacturers introduced new emission control technologies (primarily
diesel particulate filters) in response to the 2007 heavy-duty engine
standards they did not perform sufficient product development
validation, which led to additional costs for operators when the
technologies required repairs or resulted in other operational issues
in use. Thus, the issues of costs, lead time, and reliability are
intertwined for the
[[Page 73494]]
agencies' determination of whether standards are reasonable and maximum
feasible, respectively.
Another important consideration was the possibility of disrupting
the market, which would be a risk if compliance required application of
new technologies too suddenly. Several of the heavy-duty vehicle
manufacturers, fleets, and commercial truck dealerships informed the
agencies that for fleet purchases that are planned more than a year in
advance, expectations of reduced reliability, increased operating
costs, reduced residual value, or of large increases in purchase prices
can lead the fleets to pull-ahead by several months planned future
vehicle purchases by pre-buying vehicles without the newer technology.
In the context of the Class 8 tractor market, where a relatively small
number of large fleets typically purchase very large volumes of
tractors, such actions by a small number of firms can result in large
swings in sales volumes. Such market impacts would be followed by some
period of reduced purchases that can lead to temporary layoffs at the
factories producing the engines and vehicles, as well as at supplier
factories, and disruptions at dealerships. Such market impacts also can
reduce the overall environmental and fuel consumption benefits of the
standards by delaying the rate at which the fleet turns over. See
International Harvester v. EPA, 478 F. 2d 615, 634 (D.C. Cir. 1973). A
number of commenters stated that the 2007 EPA heavy-duty engine
criteria pollutant standard precipitated pre-buy for the Class 8
tractor market.\58\ The agencies understand the potential impact that
fleets pulling ahead purchases can have on American manufacturing and
labor, dealerships, truck purchasers, and on the program's
environmental and fuel savings goals, and have taken steps in the
design of the program to avoid such disruption (see also our discussion
in RTC Section 11.7). These steps include the following:
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\58\ For example, see the public comments of The International
Union, Volvo Trucks North America, United Automobile, Aerospace and
Agricultural Implement Workers of America (UAW).
Providing considerable lead time
Adopting standards that will result in significantly lower
operating costs for vehicle owners (unlike the 2007 standard, which
increased operating costs)
Phasing in the standards
Structuring the program so the industry will have a
significant range of technology choices to be considered for
compliance, rather than the one or two new technologies the OEMs
pursued to comply with EPA's 2007 criteria pollutant standard
Allowing manufacturers to use emissions averaging, banking and
trading to phase in the technology even further
As discussed in the Phase 1 final rule, NHTSA has certain statutory
considerations to take into account when determining feasibility of the
preferred alternative.\59\ EISA states that NHTSA (in consultation with
EPA and the Secretary of Energy) will develop a commercial medium- and
heavy-duty fuel efficiency program designed ``to achieve the maximum
feasible improvement.'' \60\ Although there is no definition of maximum
feasible standards in EISA, NHTSA is directed to consider three factors
when determining what the maximum feasible standards are. Those factors
are, appropriateness, cost-effectiveness, and technological
feasibility,\61\ which modify ``feasible'' beyond its plain meaning.
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\59\ 75 FR 57198.
\60\ 49 U.S.C. 32902(k).
\61\ Id.
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NHTSA has the broad discretion to weigh and balance the
aforementioned factors in order to accomplish EISA's mandate of
determining maximum feasible standards. The fact that the factors may
often be at odds gives NHTSA significant discretion to decide what
weight to give each of the competing factors, policies and concerns and
then determine how to balance them--as long as NHTSA's balancing does
not undermine the fundamental purpose of the EISA: Energy conservation,
and as long as that balancing reasonably accommodates ``conflicting
policies that were committed to the agency's care by the statute.''
\62\
---------------------------------------------------------------------------
\62\ Center for Biological Diversity v. National Highway Traffic
Safety Admin., 538 F.3d 1172, 1195 (9th Cir. 2008).
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EPA also has significant discretion in assessing, weighing, and
balancing the relevant statutory criteria. Section 202(a)(2) of the
Clean Air Act (42 U.S.C. 7521(a)(2)) requires that the standards ``take
effect after 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.'' This language affords EPA considerable discretion in how to
weight the critical statutory factors of emission reductions, cost, and
lead time (76 FR 57129-57130). Section 202(a)(2) also allows (although
it does not compel) EPA to adopt technology-forcing standards. Id. at
57130.
Sections II through VI of this Preamble explain the consideration
that the agencies took into account based on careful assessment and
balancing of the statutory factors under Clean Air Act section
202(a)(1) and (2), and under 49 U.S.C. 32902(k).
(1) Carryover From Phase 1 Program and Compliance Changes
Phase 2 is carrying over many of the compliance approaches
developed for Phase 1, with certain changes as described below. Readers
are referred to the regulatory text for much more detail. Note that the
agencies have adapted some of these Phase 1 provisions in order to
address new features of the Phase 2 program, notably provisions related
to trailer compliance. The agencies have also reevaluated all of the
compliance provisions to ensure that they will be effective in
achieving the projected reductions without placing an undue burden on
manufacturers.
The agencies received significant comments from vehicle
manufacturers emphasizing the potential for the structure of the
compliance program to impact stringency. Although the agencies do not
agree with all of these comments (which are discussed in more detail in
later sections), we do agree that it is important to structure the
compliance program so that the effective stringency of standards is
consistent with levels established by regulation. The agencies have
made appropriate improvements to the compliance structure in response
to these comments.
(a) Certification
EPA and NHTSA are applying the same general certification
procedures for Phase 2 as are currently being used for certifying to
the Phase 1 standards. Tractors and vocational vehicles will continue
to be certified using the vehicle simulation tool (GEM). The agencies,
however, revised the Phase 1 GEM simulation tool to develop a new
version, Phase 2 GEM, that more specifically reflects improvements to
engines, transmissions, and drivetrains.\63\ Rather than the GEM
simulation tool using default values for engines, transmissions and
drivetrains, most manufacturers will enter measured or tested values as
inputs reflecting performance of the actual engine, transmission and
drivetrain technologies.
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\63\ As described in Section IV, although the trailer standards
were developed using the simulation tool, the agencies are adopting
a compliance structure that does not require trailer manufacturers
to use it.
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[[Page 73495]]
The Phase 1 certification process for engines used in tractors and
vocational vehicles was based on EPA's process for showing compliance
with the heavy-duty engine criteria pollutant standards using engine
dynamometer testing, and the agencies are continuing it for Phase 2. We
also will continue certifying HD pickups and vans using the Phase 1
chassis dynamometer testing results and vehicle certification process,
which is very similar to the light-duty vehicle certification process.
The Phase 2 trailer certification process will resemble the Phase 2
tractor certification approach, but with a simplified version of Phase
2 GEM. The trailer certification process allows trailer manufacturers
to use a simple equation to determine GEM-equivalent g/ton-mile
emission rates without actually running GEM.
EPA and NHTSA are also clarifying provisions related to confirming
a manufacturer's test data during certification (i.e., confirmatory
testing) and verifying a manufacturer's vehicles are being produced to
perform as described in the application for certification (i.e.,
selective enforcement audits or SEAs). The EPA confirmatory testing
provisions for engines, vehicles, and components are in 40 CFR 1036.235
and 1037.235. The SEA provisions are in 40 CFR 1036.301 and 1037.301-
1037.320. The NHTSA provisions are in 49 CFR 535.9(a). As we proposed,
these clarifications will also apply for Phase 1 engines and vehicles.
In response to comments, we are making several changes to the
proposed EPA confirmatory testing provisions. First, the regulations
being adopted specify that EPA will conduct triplicate tests for engine
fuel maps to minimize the impact of test-to-test variability. The final
regulations also state that we will consider entire fuel maps rather
than individual points. Engine manufacturers objected to EPA's proposal
that individual points could be replaced based on a single test,
arguing that it effectively made the vehicle standards more stringent
due to point-to-point and test-to-test variability. We believe that the
changes being adopted largely address these concerns. We are also
applying this approach for axle and transmission maps for similar
reasons.
As described in Sections III and IV, EPA has also modified the SEA
regulations for verifying aerodynamic performance. These revised
regulations differ somewhat from the standard SEA regulations to
address the unique challenges of measuring aerodynamic drag. In
particular EPA recognizes that for coastdown testing, test-to-test
variability is expected to be large relative to production variability.
This differs fundamentally from traditional compliance testing, in
which test-to-test variability is expected to be small relative to
production variability. To address this difference, the modified
regulations call for more repeat testing of the same vehicle, but fewer
test samples. These revisions were generally supported by commenters.
See Section III and IV for additional discussion.
Some commenters suggested that the agencies should apply a
compliance margin to confirmatory and SEA test results to account for
test variability. However, other commenters supported following EPA's
past practice, which has been to base the standards on technology
projections that assume manufacturers will apply compliance margins to
their test results for certification. In other words, they design their
products to have emissions below the standards by some small margin so
that test-to-test or lab-to-lab variability would not cause them to
exceed any applicable standards. Consequently, EPA has typically not
set standards precisely at the lowest levels achievable, but rather at
slightly higher levels--expecting manufacturers to target the lower
levels to provide compliance margins for themselves. As discussed in
Sections II through VI, the agencies have applied this approach to the
Phase 2 standards.
(b) Averaging, Banking and Trading (ABT)
The Phase 1 ABT provisions were patterned on established EPA ABT
programs that have proven to work well. In Phase 1, the agencies
determined this flexibility would 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. Commenters generally
supported this approach for engines, pickups/vans, tractors, and
vocational vehicles. Thus, we are generally continuing this Phase 1
approach with few revisions to the engine and vehicle segments.
However, as described in Section IV, in response to comments, we are
finalizing a much more limited averaging program for trailers that will
not go into effect until 2027. We are adopting some other provisions
for certain vocational vehicles, which are discussed in Section V.
The agencies see the overall ABT program as playing an important
role in making the technology-advancing standards feasible, by helping
to address many issues of technological challenges in the context of
lead time and costs. It provides 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. They can be, as in EPA's Title II programs generally, 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
later-commencing standards) and at the same time increase flexibility
for, and reduce costs to, the regulated industry and ultimately
consumers. 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 25412-25413. 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 and more cost-
effective pace.\64\
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\64\ See NRDC v. Thomas, 805 F. 2d 410, 425 (D.C. Cir. 1986)
(upholding averaging as a reasonable and permissible means of
implementing a statutory provision requiring technology-forcing
standards).
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(i) Carryover of Phase 1 Credits and Credit Life
The agencies proposed to continue the five-year credit life
provisions from Phase 1, and not to adopt any general restriction on
the use of banked Phase 1 credits in Phase 2. In other words, Phase 1
credits in MY 2019 could be used in Phase 1 or in Phase 2 in MYs 2021-
2024. CARB commented in support of a more restrictive approach for
Phase 1 credits, based on the potential for manufacturers to delay
implementation of technology in Phase 2 by using credits generated
under Phase 1. We also received comments asking the agencies to provide
a path for manufacturers to generate credits for applying technologies
not explicitly included in the Phase 1 program. In response to these
comments, the agencies have analyzed the potential impacts of Phase 1
credits on the Phase 2 program for each sector and made appropriate
adjustments in the program. For example, as described in Section
II.D.(5), the agencies are adopting some restrictions on the carryover
of windfall Phase 1 engine credits that result from the Phase 1
vocational engine standards.
[[Page 73496]]
Also, as described in Section III, the agencies are projecting that
Phase 1 credit balances for tractor manufacturers will enable them to
meet more stringent standards for MY 2021-2023, so the agencies have
increased the stringency of these standards accordingly.
In contrast to the Phase 1 tractor program, the Phase 1 vocational
chassis program currently offers fewer opportunities to generate
credits for potential carryover into Phase 2. To address comments
related to this particular situation and also to provide a new Phase 1
incentive to voluntarily apply certain Phase 2 technologies, which are
available today but currently not being adopted, the agencies are
finalizing a streamlined Phase 1 off-cycle credit approval process for
these Phase 2 technologies. For vocational chassis, these technologies
include workday idle reduction technologies such as engine stop-start
systems, automatic engine shutdown systems, shift-to-neutral at idle
automatic transmissions, automated manual transmissions, and dual-
clutch transmissions. The agencies are also finalizing a streamlined
Phase 1 off-cycle credit approval process for Phase 2 automatic tire
inflation systems (ATIS), for both tractors and vocational chassis. The
purpose for offering these streamlined off-cycle approval processes for
Phase 1 is to encourage more early adoption of these Phase 2
technologies during the remaining portion of the Phase 1 program (e.g.,
model years 2018, 2019, 2020). Earlier adoption of these technologies
would help demonstrate that these newer, but not advanced, technologies
are effective, reliable and well-accepted into the marketplace by the
time the agencies project that they would be needed for compliance with
the Phase 2 standards.
The agencies are also including a provision allowing exempt small
business manufacturers of vocational chassis to opt into the Phase 1
program for the purpose of generating credits which can be used
throughout the Phase 2 program, as just described.
In conjunction with this provision allowing manufacturers to
receive credit in Phase 1 for pulling ahead certain Phase 2
technologies, the agencies are providing an extended credit life for
the Light and Medium heavy-duty vocational vehicle averaging sets (see
next subsection) to provide additional Phase 2 transition flexibility
for these vehicles. Unlike the HD Phase 1 pickup/van and tractor
programs, where the averaging sets are broad; where manufacturers have
many technology choices from which to earn credits (e.g., tractor
aerodynamic and idle reduction technologies, pickup/van engine and
transmission technologies); and where we project manufacturers to have
sufficient pickup/van and tractor credits to manage the transition to
the Phase 2 standards, transitioning to the new Light and Medium
vocational vehicle standards may be more challenging. Manufacturers
selling lower volumes of these lighter vehicles may find themselves
with fewer overall credits to manage the transition to the new
standards, especially the 2027 standards. To facilitate this transition
and better assure adequate lead time, the agencies are extending the
credit life for the Light and Medium heavy-duty vehicle averaging sets
(typically vehicles in Classes 2b through 7) so that all credits
generated in 2018 and later will last at least until 2027. We are not
doing this for the Heavy heavy-duty vocational vehicle category
(typically Class 8) because tractor credits may be used within this
averaging set. Because we project that manufacturers will have
sufficient tractor credits, we believe that they will be able to manage
the Heavy vocational transition to each set of new standards, without
the extended credit life that we are finalizing for Light and Medium
vocational averaging sets. Nevertheless, we will continue to monitor
the manufacturers' progress in transitioning to the Phase 2 standards
for each category, and we may reconsider the need for additional
transitional flexibilities, such as extending other categories' credit
lives.
Although, as we have already noted, the numerical values of Phase 2
standards are not directly comparable in an absolute sense to the
existing Phase 1 standards (in other words, a given vehicle would have
a different g/ton-mile emission rate when evaluated using Phase 1 GEM
than it would when evaluated using Phase 2 GEM), we believe that the
Phase 1 and Phase 2 credits are largely equivalent. Because the
standards and emission levels are included in a relative sense (as a
difference), it is not necessary for the Phase 1 and Phase 2 standards
to be directly equivalent in an absolute sense in order for the credits
to be equivalent.
This is best understood by examining the way in which credits are
calculated. For example, the credit equations in 40 CFR 1037.705 and 49
CFR 535.7 calculate credits as the product of the difference between
the standard and the vehicle's emission level (g/ton-mile or gallon/
1,000 ton-mile), the regulatory payload (tons), production volume, and
regulatory useful life (miles). The Phase 2 payloads, production
volumes, and useful lives for tractors, medium and heavy heavy-duty
engines, or medium and heavy heavy-duty vocational vehicles are
equivalent to those of Phase 1. However, EPA is changing the regulatory
useful lives of HD pickups and vans, light heavy-duty vocational
vehicles, spark-ignited engines, and light heavy-duty compression-
ignition engines. Because useful life is a factor in determining the
value of a credit, the agencies proposed to apply interim adjustment
factors to ensure banked credits maintain their value in the transition
from Phase 1 to Phase 2.
For Phase 1, EPA aligned the useful life for GHG emissions with the
useful life already in place for criteria pollutants. After the Phase 1
rules were finalized, EPA updated the useful life for criteria
pollutants as part of the Tier 3 rulemaking.\65\ The new useful life
implemented for Tier 3 is 150,000 miles or 15 years, whichever occurs
first. This same useful life is being adopted in Phase 2 for HD pickups
and vans, light heavy-duty vocational vehicles, spark-ignited engines,
and light heavy-duty compression-ignition engines.\66\ The numeric
value of the adjustment factor for each of these regulatory categories
depends on the Phase 1 useful life. These are described in detail below
in this Preamble in Sections II, V, and VI. Without these adjustment
factors the changes in useful life would effectively result in a
discount of banked credits that are carried forward from Phase 1 to
Phase 2, which is not the intent of the changes in the useful life.
With the relatively flat deterioration generally associated with
CO2, EPA does not believe the changes in useful life will
significantly affect the feasibility of the Phase 2 standards.
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\65\ 79 FR 23492, April 28, 2014 and 40 CFR 86.1805-17.
\66\ NHTSA's useful life is based on mileage and years of
duration.
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We note that the primary purpose of allowing manufacturers to bank
credits is to provide flexibility in managing transitions to new
standards. The five-year credit life is substantial, and allows credits
generated in either Phase 1 or early in Phase 2 to be used for the
intended purpose. The agencies believe a credit life longer than five
years is unnecessary to accomplish this transition. Restrictions on
credit life serve to reduce the likelihood that any manufacturer will
be able to use banked credits to disrupt the heavy-duty vehicle market
in any given year by effectively limiting the amount of credits that
can be held. Without this limit, one manufacturer that saved enough
credits over many years could achieve a significant cost advantage by
using all the credits in a single year. The agencies
[[Page 73497]]
believe that allowing a five-year credit life for all credits, and as a
consequence allowing use of Phase 1 credits in Phase 2, creates
appropriate flexibility and appropriately facilitates a smooth
transition to each new level of standards.
(ii) Averaging Sets
EPA has historically restricted averaging to some extent for its HD
emission standards to avoid creating unfair competitive advantages or
environmental risks due to credits being inconsistent. It also helps to
ensure a robust and manageable compliance program. Under Phase 1,
averaging, banking and trading can only occur within and between
specified ``averaging sets'' (with the exception of credits generated
through use of specified advanced technologies). As proposed, we will
continue this regime in Phase 2, retaining the existing vehicle and
engine averaging sets, and creating new trailer averaging sets. We are
also continuing the averaging set restrictions from Phase 1 in Phase 2.
(See Section V for certain other provisions applicable to vehicles
certified to special standards.) These general averaging sets for
vehicles are:
Complete pickups and vans
Other light heavy-duty vehicles (Classes 2b-5)
Medium heavy-duty vehicles (Class 6-7)
Heavy heavy-duty vehicles (Class 8)
Long dry and refrigerated van trailers \67\
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\67\ Averaging for trailers does not begin until 2027.
---------------------------------------------------------------------------
Short dry and refrigerated van trailers
We are not allowing trading between engines and chassis, even within
the same vehicle class. Such trading would essentially result in double
counting of emission credits, because the same engine technology would
likely generate credits relative to both standards (and indeed, certain
engine improvements are reflected exclusively in the vehicle standards
the agencies are adopting). We similarly limit trading among engine
categories to trades within the designated averaging sets:
Spark-ignition engines
Compression-ignition light heavy-duty engines
Compression-ignition medium heavy-duty engines
Compression-ignition heavy heavy-duty engines
The agencies continue to believe that maintaining trading to be only
within the classes listed above will provide adequate opportunities for
manufacturers to make necessary technological improvements and to
reduce the overall cost of the program without compromising overall
environmental and fuel efficiency objectives, and it is therefore
appropriate and reasonable under EPA's authority and maximum feasible
under NHTSA's authority, respectively. 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 credit calculations will fairly ensure the expected
fuel consumption and GHG emission reductions.
These restrictions have generally worked well for Phase 1, and we
continue to believe that these averaging sets create flexibility
without creating an unfair advantage for manufacturers with integrated
portfolios, including engines and vehicles. See 76 FR 57240.
(iii) Credit Deficits
The Phase 1 regulations allow manufacturers to carry-forward
deficits for up to three years. This is an important flexibility
because the program is designed to address the diversity of the heavy-
duty industry by allowing manufacturers to sell a mix of engines or
vehicles that have very different emission levels and fuel
efficiencies. Under this construct, manufacturers can offset sales of
engines or vehicles not meeting the standards by selling others (within
the same averaging set) that perform better than the standards require.
However, in any given year it is possible that the actual sales mix
will not balance out, and the manufacturer may be short of credits for
that model year. The three-year provision allows for this possibility
and creates additional compliance flexibility to accommodate it.
(iv) Advanced Technology Credits
At the time of the proposal, the agencies believed it was no longer
appropriate to provide extra credit for any of the technologies
identified as advanced technologies for Phase 1, although we requested
comment on this issue. The Phase 1 advanced technology credits were
adopted to promote the implementation of advanced technologies that
were not included in our basis of the feasibility of the Phase 1
standards. Such technologies included hybrid powertrains, Rankine cycle
waste heat recovery systems on engines, all-electric vehicles, and fuel
cell vehicles (see 40 CFR 86.1819-14(k)(7), 1036.150(h), and
1037.150(p)). The Phase 2 heavy-duty engine and vehicle standards are
premised on the use of some of these technologies, making them
equivalent to other fuel-saving technologies in this context. We
believe the Phase 2 standards themselves will provide sufficient
incentive to develop those specific technologies.
Although the agencies proposed to eliminate all advanced technology
incentives, we remained open to targeted incentives that would address
truly advanced technology. We specifically requested comment on this
issue with respect to electric vehicle, plug-in hybrid, and fuel cell
technologies. Although the Phase 2 standards are premised on some use
of Rankine cycle waste heat recovery systems on engines and hybrid
powertrains, none of these standards are based on projected utilization
of these other even more-advanced technologies (e.g., all-electric
vehicles, fuel cell vehicles). 80 FR 40158. Commenters generally
supported providing credit multipliers for these advanced technologies.
However, Allison supported ending the incentives for hybrids, fuel
cells, and electric vehicles in Phase 2. ATA, on the other hand,
commented that the agencies should preserve the advanced technology
credits which provide a credit multiplier of 1.5 in order to promote
the use of hybrid and electric vehicles in larger vocational vehicles
and tractors. ARB supported the use of credit multipliers even more
strongly and provided suggestions for values larger than 1.5 that could
be used to incentivize plug-in hybrids, electric vehicles, and fuel
cell vehicles. Eaton recommended the continuation of advanced
technology credits for hybrid powertrains until a sufficient number are
in the market. Overall, the comments indicated that there is support
for such incentives among operators, suppliers, and states. Upon
further consideration, the agencies are adopting advanced technology
credits for these three types of advanced technologies, as shown in
Table I-2 below.
Table I-2--Advanced Technology Multipliers
------------------------------------------------------------------------
Technology Multiplier
------------------------------------------------------------------------
Plug-in hybrid electric vehicles........................... 3.5
All-electric vehicles...................................... 4.5
Fuel cell vehicles......................................... 5.5
------------------------------------------------------------------------
Our intention in adopting these multipliers is to create a
meaningful incentive to those considering adopting these qualifying
advanced technologies into their vehicles. The values being
[[Page 73498]]
adopted are consistent with values recommended by CARB in their
supplemental comments.\68\ CARB's values were based on a cost analysis
that compared the costs of these technologies to costs of other
conventional technologies. Their costs analysis showed that adopting
multipliers in this range would make these technologies much more
competitive with the conventional technologies and could allow
manufacturers to more easily generate a viable business case to develop
these technologies for heavy-duty and bring them to market at a
competitive price.
---------------------------------------------------------------------------
\68\ Letter from Michael Carter, ARB, to Gina McCarthy,
Administrator, EPA and Mark Rosekind, Administrator, NHTSA, June 16,
2016.
---------------------------------------------------------------------------
Another important consideration in the adoption of these larger
multipliers is the tendency of the heavy-duty sector to significantly
lag the light-duty sector in the adoption of advanced technologies.
There are many possible reasons for this, such as:
Heavy-duty vehicles are more expensive than light-duty
vehicles, which makes it a greater monetary risk for purchasers to
invest in unproven technologies.
These vehicles are work vehicles, which makes predictable
reliability even more important than for light-duty vehicles.
Sales volumes are much lower for heavy-duty vehicles,
especially for specialized vehicles.
As a result of factors such as these, adoption rates for these
advanced technologies in heavy-duty vehicles are essentially non-
existent today and seem unlikely to grow significantly within the next
decade without additional incentives.
The agencies believe it is appropriate to provide such large
multipliers for these very advanced technologies at least in the short
term, because they have the potential to provide very large reductions
in GHG emissions and fuel consumption and advance technology
development substantially in the long term. However, because they are
so large, we also believe that we should not necessarily allow them to
continue indefinitely. Therefore, the agencies are adopting them as an
interim program that will continue through MY 2027. If the agencies
determine that these credit multipliers should be continued beyond MY
2027, we could do so in a future rulemaking.
As discussed in Section I.C.(1)(d), the agencies are not
specifically accounting for upstream emissions that might occur from
production of electricity to power these advanced vehicles. This
approach is largely consistent with the incentives offered for electric
vehicles in the light-duty National Program. 77 FR 62810. For light-
duty vehicles, the agencies also did not require manufacturers to
account for upstream emissions during the initial years, as the
technologies are being developed. While we proactively sunset this
allowance for light-duty due to concerns about potential impacts from
very high sales volumes, we do not have similar concerns for heavy-
duty. Nevertheless, in this program we are only adopting these credit
multipliers through MY 2027, and should we not promulgate a future
rulemaking to extend them beyond MY 2027, these multipliers would
essentially sunset in MY 2027.
One feature of the Phase 1 advanced technology program that is not
being continued in Phase 2 is the allowance to use advanced technology
credits across averaging sets. We believe that combined with the very
large multipliers being adopted, there could be too large a risk of
market distortions if we allowed the use of these credits across
averaging sets.
(v) Transition Flexibility for Meeting the Engine Standards
Some manufacturers commented that the proposed engine regulations
did not offer sufficient flexibility. Although these commenters
acknowledge that the tractor and vocational vehicle standards will
separately drive engine improvements, they nonetheless maintain that
the MY 2024 engine standards may constrain potential compliance paths
too much. Some commented that advanced technologies (such as waste heat
recovery) may need to be deployed before the technologies are fully
reliable for every engine manufacturer, and may lead to the development
and implementation of additional engine technologies outside of
scheduled engine redesign cycles, which could cause manufacturers to
incur costs which were not accounted for in the agencies' analyses.
These costs could include both product development and equipment costs
for the engine manufacturer, and potential increased costs for vehicle
owners associated with potential reliability issues in-the-field.
The agencies have considered these comments carefully. See, e.g.,
RIA Section 2.3.9 and RTC Section 3.4. The agencies recognize the
importance of ensuring that there is adequate lead time to develop,
test, and otherwise assure reliability of the technologies projected to
be needed to meet the standards and for the advanced engine
technologies in particular. See Section I.C above; see also responses
regarding waste heat recovery technology in RTC Section 3.4, and
Response 3.4.1. The agencies are therefore adopting an alternative,
optional ABT flexibility for heavy-heavy and medium-heavy engines in
partial response to these comments. This optional provision would
affect only the MYs 2021 and 2024 standards for these engines, not the
final MY 2027 engine standards, and to the extent manufacturers elect
the provision would increase fuel consumption and GHG reduction
benefits, as explained below.
This optional provision has three aspects:
A pull ahead of the engine standards to MY 2020
Extended credit life for engine credits generated against MYs
2018-2019 Phase 1 standards, the MY 2020 pull-ahead Phase 2 engine
standards, and the MYs 2021-2024 Phase 2 engine standards
Slightly relaxed engine standards for MYs 2024-2026 tractor
engine standards \69\
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\69\ Credits can be generated against these standards as well,
but the life of credits generated for 2025 and 2026 would be five
years. The pull ahead of the MY 2021 standards should more than
balance out any slight decreases in benefits attributable to such
credits.
Thus, the final rule provides the option of an extended credit life
for the medium heavy-duty and heavy heavy-duty engines so that all
credits generated in MY 2018 and later will last at least until MY
2030.\70\ To be eligible for this allowance, manufacturers would need
to voluntarily certify all of their HHD and/or MHD MY 2020 engines
(tractor and vocational) to MY 2021 standards.\71\ Manufacturers could
elect to apply this provision separately to medium heavy-duty and heavy
heavy-duty engines, since these remain separate averaging sets. Credits
banked by the manufacturer in Phase 1 for model year 2018 and 2019
engines would be eligible for the extended credit life for
manufacturers satisfying the pull ahead requirement. Such credits could
be used in any model year 2021 through
[[Page 73499]]
2030. Manufacturers that voluntarily certify their engines to MY 2021
standards early would then also be eligible for slightly less stringent
engine tractor standards in MYs 2024-2026, as shown in the following
table.
---------------------------------------------------------------------------
\70\ The final rule (40 CFR 1036.150(p)) provides that for
engine manufacturers choosing this alternative option, credits
generated with MY 2018-2024 engines can be used until MY 2030.
Credits from later model years can be used for five years from
generation under 40 CFR 1037.740(c).
\71\ Compliance with this requirement would be evaluated at the
time of certification and when end of year ABT reports are
submitted. Manufacturers that show a net credit deficit for the
averaging set at the end of the year would not meet this
requirement.
Table I-3--Optional ABT Flexibility Standards for Heavy-Heavy and Medium-Heavy Engines
----------------------------------------------------------------------------------------------------------------
Medium heavy-duty--tractor Heavy heavy-duty--tractor
---------------------------------------------------------------
EPA NHTSA fuel EPA NHTSA fuel
Model years CO[ihel2] consumption CO[ihel2] consumption
standard (g/ standard (gal/ standard (g/ standard (gal/
bhp-hr) 100bhp-hr) bhp-hr) 100bhp-hr)
----------------------------------------------------------------------------------------------------------------
2020-2023....................................... 473 4.6464 447 4.3910
2024-2026....................................... 467 4.5874 442 4.3418
----------------------------------------------------------------------------------------------------------------
Once having opted into this alternative compliance path, engine
manufacturers would have to adhere to that path for the remainder of
the Phase 2 program. The choice would be made when certifying MY 2020
engines. Instead of certifying engines to the final year of the Phase 1
engine standards, manufacturers electing the alternative would indicate
that they are instead certifying to the MY 2021 Phase 2 engine
standard.
Because these engine manufacturers would be reducing emissions of
engines otherwise subject to the MY 2020 Phase 1 engine standards (and
because engine reductions were not reflected in the Phase 1 vehicle
program), there would be a net benefit to the environment. These
engines would not generate credits relative to the Phase 1 standards
(that is, MY 2020 engines would only use or generate credits relative
to the pulled ahead MY 2021 Phase 2 engines standards) which would
result in net reductions of CO2 and fuel consumption of
about 2 percent for each engine. Thus, if every engine manufacturer
chooses to use this flexibility, there could be resulting reductions of
an additional 12MMT of CO2 and saving of nearly one billion
gallons of diesel fuel.
This alternative also does not have adverse implications for the
vehicle standards. As just noted, the vehicle standards themselves are
unaffected. Thus, these voluntary standards would not reduce the GHG
reductions or fuel savings of the program. Vehicle manufacturers using
the alternative MYs 2024-2026 engines would need to adopt additional
vehicle technology (i.e. technology beyond that projected to be needed
to meet the standard) to meet the vehicle standards. This means the
vehicles would still achieve the same fuel efficiency in use.\72\
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\72\ The agencies view this alternative as of reasonable cost
with respect to the vehicle standards. First, where engine
manufacturers and vehicle manufacturers are vertically integrated,
that manufacturer would choose the alternative which is most cost
advantageous. Second, where engine manufacturers and vehicle
manufacturers are not vertically integrated, the agencies anticipate
that engines certified to the alternative and the main standards
will both be available for the vehicle manufacturer to purchase, so
that the vehicle manufacturer would not need to incur any costs
attributable to the alternative engine standard.
---------------------------------------------------------------------------
In sum, the agencies view this alternative as being positive from
the environmental and energy conservation perspectives, and believe it
will provide significant flexibility for manufacturers that may reduce
their compliance costs. It also provides a hedge against potential
premature introduction of advanced engine technologies, providing more
lead time to assure in-use reliability.
(c) Innovative Technology and Off-Cycle Credits
The agencies are continuing the Phase 1 innovative technology
program (reflecting certain streamlining features as just discussed),
but re-designating it as an off-cycle program for Phase 2. In other
words, beginning in MY 2021 technologies that are not accounted for in
the GEM simulation tool, or by compliance dynamometer testing (for
engines or chassis certified vehicles) will be considered ``off-
cycle,'' including those technologies that may no longer be considered
innovative technologies.
The final rules provide that in order for a manufacturer to receive
these credits for Phase 2, the off-cycle technology will still need to
meet the requirement that it was not in common use prior to MY 2010.
Although we have not identified specific off-cycle technologies at this
time that should be excluded, we believe it is prudent to continue this
requirement to avoid the potential for manufacturers to receive
windfall credits for technologies that they were already using before
MY 2010, and that are therefore reflected in the Phase 2 (and possibly
Phase 1) baselines. However, because the Phase 2 program will be
implemented in MY 2021 and extend at least through MY 2027, the
agencies and manufacturers may have difficulty in the future
determining whether an off-cycle technology was in common use prior to
MY 2010. In order to avoid this approach becoming an unnecessary
hindrance to the off-cycle program, the agencies will presume that off-
cycle technologies were not in common use in 2010 unless we have clear
evidence to the contrary. Neither the agencies nor manufacturers will
be required to demonstrate that the technology meets this 2010
criteria. Rather, the agencies will simply retain the authority to deny
a request for off-cycle credits if it is clear that the technology was
in common use in 2010 and thus part of the baseline.
Manufacturers will be able to carry over innovative technology
credits from Phase 1 into Phase 2, subject to the same restrictions as
other credits. Manufacturers will also be able to carry over the
improvement factor (not the credit value) of a technology, if certain
criteria are met. The agencies will require documentation for all off-
cycle requests similar to those required by EPA for its light-duty GHG
program.
Additionally, the agencies will not grant any off-cycle credits for
crash avoidance technologies. The agencies will also require
manufacturers to consider the safety of off-cycle technologies and will
request a safety assessment from the manufacturer for all off-cycle
technologies.
Similar principles apply to off-cycle credits in this heavy-duty
Phase 2 program as under the light-duty vehicle rules. Thus,
technologies which are part of the basis of a Phase 2 standard would
not be eligible for off-cycle credits. Their benefits have been
accounted for in developing the stringency of the Phase 2 standard, as
have their costs. See 77 FR 62835 (October 15, 2012). In addition,
technologies which are integral or inherent to the basic vehicle design
and are recognized in GEM or under the FTP (for pickups and vans),
including engine, transmission, mass reduction, passive aerodynamic
design, and base tires, will not be eligible for off-cycle credits. 77
FR 62836.
[[Page 73500]]
Technologies integral or inherent to basic vehicle design are fully
functioning and are thus recognized in GEM, or operate over the
entirety of the FTP/HFET and therefore are adequately captured by the
test procedure.
Just as some technologies that were considered off-cycle for Phase
1 are being adopted as primary technologies in Phase 2 on whose
performance standard stringency is calculated, the agencies may revise
the regulation in a future rulemaking to create a more direct path to
recognize technologies currently considered off-cycle. For example,
although we are including specific provisions to recognize certain
electrified accessories, recognizing others would require the
manufacturer to go through the off-cycle process. However, it is quite
possible that the agencies could gather sufficient data to allow us to
adopt specific provisions in a future rulemaking to recognize other
accessories in a simpler manner. Because such a change would merely
represent a simpler way to receive the same credit as could be obtained
under the regulations being adopted today (rather than a change in
stringency), it would not require us to reconsider the standards.
(d) Alternative Fuels and Electric Vehicles
The agencies will largely continue the Phase 1 approach for engines
and vehicles fueled by fuels other than gasoline and diesel.\73\ Phase
1 engine emission standards applied uniquely for gasoline-fueled and
diesel-fueled engines. The regulations in 40 CFR part 86 implement
these distinctions for alternative fuels by dividing engines into Otto-
cycle and Diesel-cycle technologies based on the combustion cycle of
the engine. However, as proposed, the agencies are making a small
change that is described in Section II. Under this change, we will
require manufacturers to divide their natural gas engines into primary
intended service classes, like the current requirement for compression-
ignition engines. Any alternative fuel-engine qualifying as a heavy
heavy-duty engine will be subject to all the emission standards and
other requirements that apply to compression-ignition engines. Note
that this small change in approach will also apply with respect to
EPA's criteria pollutant program.
---------------------------------------------------------------------------
\73\ See Section XI for additional discussion of natural gas
engines and vehicles.
---------------------------------------------------------------------------
We are also applying the Phase 2 standards at the vehicle tailpipe.
That is, compliance is based on vehicle fuel consumption and GHG
emission reductions, and does not reflect any so-called lifecycle
emission properties. The agencies have explained why it is reasonable
that the heavy-duty standards be fuel neutral in this manner and adhere
to this reasoning here. See 76 FR 57123; see also 77 FR 51705 (August
24, 2012) and 77 FR 51500 (August 27, 2012). In particular, EPA notes
that there is a separate, statutorily-mandated program under the Clean
Air Act which encourages use of renewable fuels in transportation
fuels, including renewable fuel used in heavy-duty diesel engines. This
program considers lifecycle greenhouse gas emissions compared to
petroleum fuel. NHTSA notes that the fuel efficiency standards are
necessarily tailpipe-based, and that a lifecycle approach would likely
render it impossible to harmonize the fuel efficiency and GHG emission
standards, to the great detriment of our goal of achieving a
coordinated program. 77 FR 51500-51501; see also 77 FR 51705 (similar
finding by EPA); see also Section I.F.(1)(a) below, Section 1.8 of the
RTC, and Section XI.B.
The agencies received mixed comments on this issue. Many commenters
supported the proposed approach, generally agreeing with the agencies'
arguments. However, some other commenters opposed this approach.
Opposing commenters generally fell into two categories:
Commenters concerned that upstream emissions of methane
occurring during the production and distribution of natural gas would
offset some or all of the GHG emission reductions observed at the
tailpipe.
Commenters concerned that tailpipe-only standards ignore
the GHG benefits of using renewable fuels.
The agencies are not issuing rules that effectively would turn
these rules into a fuel program, rather than an emissions reduction and
fuel efficiency program. Nor will the agencies disharmonize the program
by having GHG standards reflect upstream emissions having no relation
to fuel efficiency. See e.g. 77 FR 51500-51501; see also 77 FR 51705.
We thus will continue to measure compliance at the tailpipe. Issues
relating to whether to consider in the emission standards upstream
emissions related to natural gas exploration and production are
addressed in detail in Section XI below. It is sufficient to state here
that the agencies carefully investigated the potential use of natural
gas in the heavy-duty sector and the impacts of such use. We do not
believe that the use of natural gas is likely to become a major fuel
source for heavy-duty vehicles during the Phase 2 time frame. Thus,
since we project natural gas vehicles to have little impact on both
overall GHG emissions and fuel consumption during the Phase 2 time
frame, the agencies see no need to make fundamental changes to the
Phase 1 approach for natural gas engines and vehicles.
The agencies note further that a consequence of the tailpipe-based
approach is that the agencies will treat vehicles powered by
electricity the same as in Phase 1. In Phase 1, EPA treated all
electric vehicles as having zero tailpipe emissions of CO2,
CH4, and N2O (see 40 CFR 1037.150(f)). Similarly,
NHTSA adopted regulations in Phase 1 that set the fuel consumption
standards based on the fuel consumed by the vehicle. The agencies also
did not require emission testing for electric vehicles in Phase 1. The
agencies considered the potential unintended consequence of not
accounting for upstream emissions from the charging of heavy-duty
electric vehicles. In our reassessment for Phase 2, we have found only
one all-electric heavy-duty vehicle manufacturer that has certified
through 2016. As we look to the future, we project limited adoption of
all-electric vehicles into the market. Therefore, we believe that this
provision is still appropriate. Unlike the 2017-2025 light-duty rule,
which included a cap whereby upstream emissions would be counted after
a certain volume of sales (see 77 FR 62816-62822), we believe there is
no need to establish a cap for heavy-duty vehicles because of the small
likelihood of significant production of EV technologies in the Phase 2
timeframe. Commenters specifically addressing electric vehicles
generally supported the agencies' proposal. However, some commenters
did support accounting for emissions from the generation of electricity
in the broader context of supporting full life-cycle analysis. As noted
above, and in more detail in Section I.F.(2)(f) as well as Section 1.8
of the RTC, the agencies are not predicating the standards on a full
life-cycle approach.
(e) Phase 1 Interim Provisions
EPA adopted several flexibilities for the Phase 1 program (40 CFR
86.1819-14(k), 1036.150 and 1037.150) as interim provisions. Because
the existing regulations do not have an end date for Phase 1, most of
these provisions did not have an explicit end date. NHTSA adopted
similar provisions. With few exceptions, the agencies are not
continuing these provisions for Phase 2. These will generally remain in
effect for the Phase 1 program. In particular, the agencies note that
we are not continuing the blanket exemption for small
[[Page 73501]]
manufacturers. Instead, in Phase 2 the agencies are providing more
targeted relief for these entities.
(f) In-Use Standards and Recall
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 and for the engine. EPA finalized in-use standards for the
Phase 1 program, whereas NHTSA's rules do not include these standards.
For the Phase 2 program, EPA will carry-over its in-use provisions, and
NHTSA is adopting EPA's useful life requirements for its vehicle and
engine fuel consumption standards to ensure manufacturers consider in
the design process the need for fuel efficiency standards to apply for
the same duration and mileage as EPA standards. If EPA determines a
manufacturer fails to meet its in-use standards, civil penalties may be
assessed.
CAA section 207(c)(1) requires ``the manufacturer'' to remedy
certain in-use problems. The remedy process is to recall the
nonconforming vehicles and bring them into conformity with the
standards and the certificate. The regulations for this process are in
40 CFR part 1068, subpart F. EPA is also adopting regulatory text
addressing recall obligations for component manufacturers and other
non-certifying manufacturers. We note that the CAA does not limit this
responsibility to certificate holders, consistent with the definition
of a ``manufacturer'' as ``any person engaged in the manufacturing or
assembling of new motor vehicles, new motor vehicle engines, new
nonroad vehicles or new nonroad engines, or importing such vehicles or
engines for resale, or who acts for and is under the control of any
such person in connection with the distribution of new motor vehicles,
new motor vehicle engines, new nonroad vehicles or new nonroad engines,
but shall not include any dealer with respect to new motor vehicles,
new motor vehicle engines, new nonroad vehicles or new nonroad engines
received by him in commerce.''
As discussed in Section I.E.(1) below, this definition was not
intended to restrict the definition of ``manufacturer'' to a single
person per vehicle. Under EPA regulations, we can require any person
meeting the definition of manufacturer for a nonconforming vehicle to
participate in a recall. However, we would normally presume the
certificate holder to have the primary responsibility.
EPA requested comment on adding regulatory text that would
explicitly apply these provisions to tire manufacturers. Comments from
the tire industry generally opposed this noting that they are not the
manufacturer of the vehicle. These comments are correct that tires are
not incomplete vehicles and hence that the recall authority does not
apply for companies that only manufacture the tires. However, EPA
remains of the view that in the event that vehicles (e.g. trailers) do
not conform to the standards in-use due to nonconforming tires, tire
manufacturers would have a role to play in remedying the problem. In
this (hypothetical) situation, a tire manufacturer would not only have
produced the part in question, but in the case of a trailer
manufacturer or other small vehicle manufacturer, would have
significantly more resources and knowledge regarding how to address
(and redress) the problem. Accordingly, EPA would likely require that a
component manufacturer responsible for the nonconformity assist in the
recall to an extent and in a manner consistent with the provisions of
CAA section 208(a). This section specifies that component and part
manufacturers ``shall establish and maintain records, perform tests
where such testing is not otherwise reasonably available under this
part and part C of this subchapter (including fees for testing), make
reports and provide information the Administrator may reasonably
require to determine whether the manufacturer or other person has acted
or is acting in compliance with this part and part C of this subchapter
and regulations thereunder, or to otherwise carry out the provision of
this part and part C of this subchapter. . .''. Any such action would
be considered on a case-by-case basis, adapted to the particular
circumstances at the time.
(g) Vehicle Labeling
EPA proposed to largely continue the Phase 1 engine and vehicle
labeling requirements, but to eliminate the requirement for tractor and
vocational vehicle manufacturers to list emission control on the label.
The agencies consider it crucial that authorized compliance inspectors
are able to identify whether a vehicle is certified, and if so whether
it is in its certified condition. To facilitate this identification in
Phase 1, EPA adopted labeling provisions for tractors that included
several items. The Phase 1 tractor label must include the manufacturer,
vehicle identifier such as the Vehicle Identification Number (VIN),
vehicle family, regulatory subcategory, date of manufacture, compliance
statements, and emission control system identifiers (see 40 CFR
1037.135). EPA proposed to apply parallel requirements for trailers.
In Phase 1, the emission control system identifiers are limited to
vehicle speed limiters, idle reduction technology, tire rolling
resistance, some aerodynamic components, and other innovative and
advanced technologies. However, the number of emission control systems
for greenhouse gas emissions in Phase 2 has increased significantly for
tractors and vocational vehicles. For example, all aspects of the
engine transmission and drive axle; accessories; tire radius and
rolling resistance; wind averaged drag; predictive cruise control; idle
reduction technologies; and automatic tire inflation systems are
controls which can be evaluated on-cycle in Phase 2 (i.e. these
technologies' performance can now be input to GEM), but could not be in
Phase 1. Due to the complexity in determining greenhouse gas emissions
in Phase 2, the agencies do not believe that we can unambiguously
determine whether or not a vehicle is in a certified condition through
simply comparing information that could be made available on an
emission control label with the components installed on a vehicle.
Therefore, EPA proposed to remove the requirement to include the
emission control system identifiers required in 40 CFR 1037.135(c)(6)
and in Appendix III to 40 CFR part 1037 from the emission control
labels for vehicles certified to the Phase 2 standards. The agencies
received comments on the emission control labels from Navistar, which
supported the elimination of the emission control information from the
vehicle GHG label.
Although we are largely finalizing the proposed labeling
requirements, we remain interested in finding a better approach for
labeling. Under the agencies' existing authorities, manufacturers must
provide detailed build information for a specific vehicle upon our
request. Our expectation is that this information should be available
to us via email or other similar electronic communication on a same-day
basis, or within 24 hours of a request at the latest. The agencies have
started to explore ideas that would provide inspectors with an
electronic method to identify vehicles and access on-line databases
that would list all of the engine-specific and vehicle-specific
emissions control system information. We believe that electronic and
Internet technology exists today for using scan tools to read a bar
code or radio frequency identification tag affixed to a vehicle that
could then lead to secure on-line access to a database of
manufacturers' detailed vehicle and
[[Page 73502]]
engine build information. Our exploratory work on these ideas has
raised questions about the level of effort that would be required to
develop, implement and maintain an information technology system to
provide inspectors real-time access to this information. We have also
considered questions about privacy and data security. We requested
comment on the concept of electronic labels and database access,
including any available information on similar systems that exist today
and on burden estimates and approaches that could address concerns
about privacy and data security.
Although we are not finalizing such a program in this rulemaking,
we remain very interested in the use of electronic labels that could be
used by the agencies to access vehicle information and may pursue these
in a future rulemaking. Such a rulemaking would likely consider the
feasibility of accessing dynamic link libraries in real-time to view
each manufacturer's build records (and perhaps pending orders). The
agencies envision that this could be very useful for our inspectors by
providing them access to the build information by VIN to confirm that
each vehicle has the proper emission control features.
(h) Model Year Definition
The agencies proposed to continue the Phase definitions of ``model
year'' for compliance with GHG emissions and fuel efficiency standards.
However, in response to comments, the agencies are revising the
definition slightly for Phase 2 tractors and vocational vehicles to
match the model years of the engines installed in them. The revised
definition generally sets the vehicle model year to be the calendar
year of manufacture, but allows the vehicle manufacturer the option to
select the prior year if the vehicle uses an engine manufactured in the
prior model year.\74\ Because Phase 2 vehicle standards are based in
part on engine performance, some commenters stated that the engine
model year should dictate the vehicle's GHG and fuel efficiency
compliance model year, and that the emissions and fuel efficiency
compliance model year should be presented on the vehicle emissions
label. This would allow manufacturers to market a vehicle and certify
it to NHTSA's safety standards based on the standards applicable on the
date of manufacture, but certify the vehicle for GHG emissions and fuel
efficiency purposes based on the engine model compliance year. For
example, a 2023 model year tractor might have a 2022 model year engine
in it. The tractor would be marketed as a model year 2023 tractor,
certified as complying with NHTSA's safety standards applicable at the
time when certifying the vehicle, but would have an ``emissions and
fuel efficiency compliance model year'' of 2022 for purposes of
emissions and fuel efficiency standards. In today's action, NHTSA and
EPA are finalizing standards that allow for the use of an ``emissions
and fuel efficiency compliance model year.'' This is consistent with
past program practice, in which certain manufacturers have been able to
reclassify tractors to the previous model year for emissions purposes
when the tractors use engines from the previous model year.
---------------------------------------------------------------------------
\74\ Anti-stockpiling provisions will generally prevent vehicle
manufacturers from using new engines older than the prior model
year. See Section XIII.B for a discussion of EPA requirements for
installing older used engines into new vehicles.
---------------------------------------------------------------------------
(2) Phase 2 Standards
This section briefly summarizes the Phase 2 standards for each
category and identifies the technologies that the agencies project will
be needed to meet the standards. Given the large number of different
regulatory categories and model years for these standards, the actual
numerical standards are not listed. Readers are referred to Sections II
through IV for the tables of standards.
(a) Summary of the Engine Standards
The agencies are continuing the basic Phase 1 structure for the
Phase 2 engine standards. There will be separate standards and test
cycles for tractor engines, vocational diesel engines, and vocational
gasoline engines. However, as described in Section II, we are adopting
a revised test cycle for tractor engines to better reflect actual in-
use operation. After consideration of comments, including those
specifically addressing whether the agencies should adopt an
alternative with accelerated stringency targets, the agencies are
adopting engine standards that can generally be characterized as more
stringent than the proposed alternative.
Specifically, for diesel tractor engines, the agencies are adopting
standards for MY 2027 that are more stringent than the preferred
alternative from the proposal, and require reductions in CO2
emissions and fuel consumption that are 5.1 percent better than the
2017 baseline for tractor engines.\75\ We are also adopting standards
for MY 2021 and MY 2024, requiring reductions in CO2
emissions and fuel consumption of 1.8 to 4.2 percent better than the
2017 baseline tractor engines. For vocational diesel engines, the new
standards will require reductions of 2.3, 3.6, and 4.2 percent in MYs
2021, 2024, and 2027, respectively. These levels are more stringent
than the proposed standards for these same MYs, and approximately as
stringent in MY 2021 and MY 2024 as the Alternative 4 standards
discussed at proposal.\76\
---------------------------------------------------------------------------
\75\ For the flat baseline referenec case, the agencies project
that tractors engines will meet the Phase 1 engine standards with a
small compliancee margin. The Phase 1 standards for diesel engines
will be fully phased-in by MY 2017, so we use MY 2017 as the
baseline engine for tractors. Note that we project that vocational
engines will achieve additioanl overcompliance with the Phase 1
vocational engine standards.
\76\ As noted in Section II, the numerical levels of the
vocational engine standards also reflect an updated baseline in
which Phase 1 vocational engines are more efficient than assumed for
the proposal. In addition, the numerical levels of the tractor
engine standards reflect an updated baseline to reflect the changes
to the test cycle.
---------------------------------------------------------------------------
The agencies project that these reductions will be maximum feasible
and reasonable for diesel engines based on technological changes that
will improve combustion and reduce energy losses. For most of these
improvements, the agencies project (i.e., the agencies have set out a
potential, but by no means mandatory, compliance path) that
manufacturers will begin applying improvements to about 45 percent of
their heavy-duty engines by 2021, and ultimately apply them to about 95
percent of their heavy-duty engines by 2024. However, for some of these
improvements we project more limited application rates. In particular,
we project a more limited use of waste exhaust heat recovery systems in
2027, projecting that about 10 percent of tractor engines will have
turbo-compounding systems, and an additional 25 percent of tractor
engines will employ Rankine-cycle waste heat recovery. We do not
project that turbo-compounding or Rankine-cycle waste heat recovery
technology will be utilized in vocational engines due to vocational
vehicle drive cycles under which these technologies would not show
significant benefit, and also due to low sales volumes, limiting the
ability to invest in newer technologies for these vehicles.
As described in Section III.D.(1)(b)(i), the agencies project that
some engine manufacturers will be able to achieve larger reductions for
at least some of their tractor engines. So in developing the tractor
vehicle standards, we projected slightly better fuel efficiency for the
average tractor engine than is required by the engine standards. We are
projecting that similar over-compliance will occur for heavy heavy-duty
vocational engines.
For gasoline vocational engines, we are not adopting more stringent
engine standards. Gasoline engines used in
[[Page 73503]]
vocational vehicles are generally the same engines as are used in the
complete HD pickups and vans in the Class 2b and 3 weight categories,
although the operational demands of vocational vehicles often require
use of the largest, most powerful SI engines, so that some engines
fitted in complete pickups and vans are not appropriate for use in
vocational vehicles. Given the relatively small sales volumes for
gasoline-fueled vocational vehicles, manufacturers typically cannot
afford to invest significantly in developing separate technology for
these vocational vehicle engines. Thus, we project that in general,
vocational gasoline engines will incorporate much of the technology
that will be used to meet the pickup and van chassis standards, and
this will result in some real world reductions in CO2
emissions and fuel consumption. The agencies received many comments
suggesting that technologies be applied to increase the stringency of
the SI engine standard, which technologies in fact are already presumed
to be adopted at 100 percent to meet the MY 2016 engine standard. The
commenters did not identify any additional engine technologies that are
not already fully considered by the agencies in setting the MY 2016
engine standard, that could be recognized over the HD SI Engine FTP
test cycle. We did, however, consider some additional technologies
recommended by commenters, which can be recognized over the GEM vehicle
cycles. As a result, the Phase 2 vehicle standards for gasoline-fueled
vocational vehicles are predicated on adoption of engine technologies
beyond what is required to meet the separate engine standard, those
additional technologies being advanced engine friction reduction and
cylinder deactivation. As described in Section V, we are projecting
these technologies to improve fuel consumption over the GEM cycles by
nearly one percent in MY 2021, MY 2024, and MY 2027. In other words,
this improvement is reflected in the vehicle standards rather than in
the engine standards. To the extent any SI engines do not incorporate
the projected engine technologies, manufacturers of gasoline-fueled
vocational vehicles would need to achieve equivalent reductions from
some other technology to meet the GEM-based vehicle standards. The
engine standards are summarized in Table I-4.
Table I-4--Summary of Phase 1 and Phase 2 Requirements for Engines in
Combination Tractors and Vocational Vehicles
------------------------------------------------------------------------
Phase 1 program Final 2027 standards
------------------------------------------------------------------------
Covered in this category.... Engines installed in tractors and
vocational chassis.
------------------------------------------------------------------------
Share of HDV fuel Combination tractors and vocational
consumption and GHG vehicles account for approximately 85
emissions. percent of fuel use and GHG emissions in
the heavy duty truck sector.
------------------------------------------------------------------------
Per vehicle fuel consumption 5%-9% improvement 4%-5% improvement
and CO[ihel2] improvement. over MY 2010 over MY 2017 for
baseline, depending diesel engines.
vehicle Note that
application. improvements are
Improvements are in captured in
addition to complete vehicle
improvements from tractor and
tractor and vocational vehicle
vocational vehicle standards, so that
standards. engine improvements
and the vehicle
improvement shown
below are not
additive.
------------------------------------------------------------------------
Form of the standard........ EPA: CO[ihel2] grams/horsepower-hour and
NHTSA: Gallons of fuel/horsepower-hour.
------------------------------------------------------------------------
Example technology options Combustion, air Further technology
available to help handling, friction improvements and
manufacturers meet and emissions after- increased use of
standards. treatment all Phase 1
technology technologies, plus
improvements. waste heat recovery
systems for tractor
engines (e.g.,
turbo-compound and
Rankine-cycle).
------------------------------------------------------------------------
Flexibilities............... ABT program which Same ABT and off-
allows emissions cycle program as
and fuel Phase 1.
consumption credits Adjustment factor of
to be averaged, 1.36 for credits
banked, or traded carried forward
(five year credit from Phase 1 to
life). Phase 2 for SI and
Manufacturers LHD CI engines due
allowed to carry- to change in useful
forward credit life.
deficits for up to Revised multipliers
three model years. for Phase 2
Interim incentives advanced
for advanced technologies.
technologies, No Phase 2 early
recognition of credit multipliers.
innovative (off-
cycle) technologies
not accounted for
by the HD Phase 1
test procedures,
and credits for
certifying early.
------------------------------------------------------------------------
(b) Summary of the Tractor Standards
As explained in Section III, the agencies will largely continue the
structure of the Phase 1 tractor program, but adopt new standards and
update test procedures, as summarized in Table I-6. The tractor
standards for MY 2027 will achieve up to 25 percent lower
CO2 emissions and fuel consumption than a 2017 model year
Phase 1 tractor. The agencies project that the 2027 tractor standards
could be met through improvements in the:
Engine \77\ (including some use of waste heat recovery
systems)
---------------------------------------------------------------------------
\77\ Although the agencies are adopting new engine standards
with separate engine certification, engine improvements will also be
reflected in the vehicle certification process. Thus, it is
appropriate to also consider engine improvements in the context of
the vehicle standards.
---------------------------------------------------------------------------
Transmission
Driveline
Aerodynamic design
Tire rolling resistance
Idle performance
Other accessories of the tractor.
The agencies have enhanced the Phase 2 GEM vehicle simulation tool
to recognize these technologies, as described in Section II.C. The
agencies' evaluation shows that some of these technologies are
available today, but have very low adoption rates on current vehicles,
while others will require some lead time for development and
deployment. In addition to the proposed alternative for tractors, the
agencies solicited comment on an alternative that reached similar
ultimate stringencies, but at an accelerated pace.
We have also determined that there is sufficient lead time to
introduce many of these tractor and engine technologies into the fleet
at a reasonable cost starting in the 2021 model year. The
[[Page 73504]]
2021 model year standards for combination tractors and engines will
achieve up to 14 percent lower CO2 emissions and fuel
consumption than a 2017 model year Phase 1 tractor, the 2024 model year
standards will achieve up to 20 percent lower CO2 emissions
and fuel consumption, and as already noted, the 2027 model year
standards will achieve up to 25 percent lower CO2 emissions
and fuel consumption.
In addition to the CO2 emission standards for tractors,
EPA is adopting new particulate matter (PM) standards which effectively
limit which diesel fueled auxiliary power units (APUs) can be used as
emission control devices to reduce main engine idling in tractors, as
shown in Table I-5. Additional details are discussed in Section
III.C.3.
Table I-5--PM Standards Related to Diesel APUs
------------------------------------------------------------------------
PM emission
Tractor MY standard (g/kW- Expected control
hr) technology
------------------------------------------------------------------------
2018-2023........................ 0.15 In-cylinder PM
control.
2024............................. 0.02 DPF.
------------------------------------------------------------------------
Table I-6--Summary of Phase 1 and Phase 2 Requirements for Class 7 and
Class 8 Combination Tractors
------------------------------------------------------------------------
Phase 1 program Final 2027 standards
------------------------------------------------------------------------
Covered in this category.... Tractors that are designed to pull
trailers and move freight.
------------------------------------------------------------------------
Share of HDV fuel Combination tractors and their engines
consumption and GHG account for approximately sixty percent
emissions. of fuel use and GHG emissions in the
heavy duty vehicle sector.
------------------------------------------------------------------------
Per vehicle fuel consumption 10%-23% improvement 19%-25% improvement
and CO[ihel2] improvement. over MY 2010 over tractors
baseline, depending meeting the MY 2017
on tractor standards.
category.
Improvements are in
addition to
improvements from
engine standards.
------------------------------------------------------------------------
Form of the standard........ EPA: CO[ihel2] grams/ton payload mile and
NHTSA: Gallons of fuel/1,000 ton payload
mile.
------------------------------------------------------------------------
Example technology options Aerodynamic drag Further technology
available to help improvements; low improvements and
manufacturers meet rolling resistance increased use of
standards. tires; high all Phase 1
strength steel and technologies, plus
aluminum weight engine
reduction; extended improvements,
idle reduction; and improved
speed limiters. transmissions and
axles, tire
pressure systems,
and predictive
cruise control
(depending on
tractor type).
------------------------------------------------------------------------
Flexibilities............... ABT program which Same ABT and off-
allows emissions cycle program as
and fuel Phase 1.
consumption credits Revised multipliers
to be averaged, for Phase 2
banked, or traded advanced
(five year credit technologies.
life).
Manufacturers
allowed to carry-
forward credit
deficits for up to
three model years.
Interim incentives
for advanced
technologies,
recognition of
innovative (off-
cycle) technologies
not accounted for
by the HD Phase 1
test procedures,
and credits for
certifying early.
------------------------------------------------------------------------
(c) Summary of the Trailer Standards
The final rules contain a set of GHG emission and fuel consumption
standards for manufacturers of new trailers that are used in
combination with tractors. These standards will significantly reduce
CO2 and fuel consumption from combination tractor-trailers
nationwide over a period of several years. As described in Section IV,
there are numerous aerodynamic and tire technologies available to
manufacturers to achieve these standards. Many of these technologies
have already been introduced into the market through EPA's voluntary
SmartWay program and California's tractor-trailer greenhouse gas
requirements.
The agencies are adopting Phase 2 standards that will phase-in
beginning in MY 2018 and be fully phased-in by 2027. These standards
are predicated on use of aerodynamic and tire improvements, with
trailer OEMs making incrementally greater improvements in MYs 2021 and
2024 as standard stringency increases in each of those model years.
EPA's GHG emission standards will be mandatory beginning in MY 2018,
while NHTSA's fuel consumption standards will be voluntary beginning in
MY 2018, and be mandatory beginning in MY 2021. In general, the trailer
standards being finalized apply only for box vans, flatbeds, tankers,
and container chassis.
As described in Section XIV.D and Chapter 12 of the RIA, the
agencies are adopting special provisions to minimize the impacts on
small business trailer manufacturers. These provisions have been
informed by and are largely consistent with recommendations from the
SBAR Panel that EPA conducted pursuant to section 609(b) of the
Regulatory Flexibility Act (RFA). Broadly, these provisions provide
additional lead time for small business manufacturers, as well as
simplified testing and compliance requirements. The agencies also are
not finalizing standards for various trailer types, including most
specialty types of non-box trailers. Excluding these specialty trailers
also reduces the impacts on small businesses.
[[Page 73505]]
Table I-7--Summary of Phase 2 Requirements for Trailers
------------------------------------------------------------------------
Phase 1 program Final 2027 standards
------------------------------------------------------------------------
Covered in this category...... All lengths of dry vans, refrigerated
vans, tanks, flatbeds, and container
chassis hauled by low, mid, and high
roof day and sleeper cab tractors.
------------------------------------------------------------------------
Share of HDV fuel consumption Trailers are modeled together with
and GHG emissions. combination tractors and their engines.
Together, they account for
approximately sixty percent of fuel use
and GHG emissions in the heavy duty
truck sector.
------------------------------------------------------------------------
Per vehicle fuel consumption N/A.............. Between 3% and 9%
and CO[ihel2] improvement. improvement over MY
2018 baseline,
depending on the
trailer type.
------------------------------------------------------------------------
Form of the standard.......... N/A.............. EPA: CO[ihel2] grams/
ton payload mile and
NHTSA: Gallons/1,000
ton payload mile.
------------------------------------------------------------------------
Example technology options N/A.............. Low rolling
available to help resistance tires and
manufacturers meet standards. tire pressure
systems for most
trailers, plus
weight reduction and
aerodynamic
improvements such as
side and rear
fairings, gap
closing devices, and
undercarriage
treatment for box
vans (e.g., dry and
refrigerated).
------------------------------------------------------------------------
Flexibilities................. N/A.............. One year delay in
implementation for
small businesses,
trailer
manufacturers may
use pre-approved
aerodynamic data in
lieu of additional
testing, averaging
program available in
MY 2027 for
manufacturers of dry
and refrigerated box
vans.
------------------------------------------------------------------------
(d) Summary of the Vocational Vehicle Standards
As explained in Section V, the agencies are adopting new vocational
vehicle standards that expand upon the Phase 1 Program. These new
standards reflect further subcategorization from Phase 1, with separate
standards based on mode of operation: Urban, regional, and multi-
purpose. The agencies are also adopting optional separate standards for
emergency vehicles and other custom chassis vehicles.
The agencies project that the vocational vehicle standards could be
met through improvements in the engine, transmission, driveline, lower
rolling resistance tires, workday idle reduction technologies, weight
reduction, and some application of hybrid technology. These are
described in Section V of this Preamble and in Chapter 2.9 of the RIA.
These MY 2027 standards will achieve up to 24 percent lower
CO2 emissions and fuel consumption than MY 2017 Phase 1
standards. The agencies are also making revisions to the compliance
program for vocational vehicles. These include: The addition of two
idle cycles that will be weighted along with the other drive cycles for
each vocational vehicle; and revisions to Phase 2 GEM to recognize
improvements to the engine, transmission, and driveline.
Similar to the tractor program, we have determined that there is
sufficient lead time to introduce many of these new technologies into
the fleet starting in MY 2021. Therefore, we are adopting new standards
for MY 2021 and 2024. Based on our analysis, the MY 2021 standards for
vocational vehicles will achieve up to 12 percent lower CO2
emissions and fuel consumption than a MY 2017 Phase 1 vehicle, on
average, and the MY 2024 standards will achieve up to 20 percent lower
CO2 emissions and fuel consumption.
In Phase 1, EPA adopted air conditioning (A/C) refrigerant leakage
standards for tractors, as well as for heavy-duty pickups and vans, but
not for vocational vehicles. For Phase 2, EPA believes that it will be
feasible to apply similar A/C refrigerant leakage standards for
vocational vehicles, beginning with the 2021 model year. The
certification process for vocational vehicles to certify low-leakage A/
C components is identical to that already required for tractors.
Table I-8--Summary of Phase 1 and Phase 2 Requirements for Vocational
Vehicle Chassis
------------------------------------------------------------------------
Phase 1 program Final 2027 standard
------------------------------------------------------------------------
Covered in this category.... Class 2b--8 chassis that are intended for
vocational services such as delivery
vehicles, emergency vehicles, dump truck,
tow trucks, cement mixer, refuse trucks,
etc., except those qualified as off-
highway vehicles.
Because of sector diversity, vocational
vehicle chassis are segmented into Light,
Medium and Heavy Heavy-Duty vehicle
categories and for Phase 2 each of these
segments are further subdivided using
three duty cycles: Regional, Multi-
purpose, and Urban.
------------------------------------------------------------------------
Share of HDV fuel Vocational vehicles account for
consumption and GHG approximately 17 percent of fuel use and
emissions. GHG emissions in the heavy duty truck
sector categories.
------------------------------------------------------------------------
Per vehicle fuel consumption 2% improvement over Up to 24%
and CO[ihel2] improvement. MY 2010 baseline. improvement over MY
Improvements are in 2017 standards.
addition to
improvements from
engine standards.
------------------------------------------------------------------------
Form of the standard........ EPA: CO[ihel2] grams/ton payload mile and
NHTSA: Gallons of fuel/1,000 ton payload
mile.
------------------------------------------------------------------------
Example technology options Low rolling Further technology
available to help resistance tires. improvements and
manufacturers meet increased use of
standards. Phase 1
technologies, plus
improved engines,
transmissions and
axles, weight
reduction, hybrids,
and workday idle
reduction systems.
------------------------------------------------------------------------
[[Page 73506]]
Flexibilities............... ABT program which Same ABT and off-
allows emissions cycle program as
and fuel Phase 1. Adjustment
consumption credits factor of 1.36 for
to be averaged, credits carried
banked, or traded forward from Phase
(five year credit 1 to Phase 2 due to
life). change in useful
Manufacturers life.
allowed to carry- Revised multipliers
forward credit for Phase 2
deficits for up to advanced
three model years. technologies.
Interim incentives No Phase 2 early
for advanced credit multipliers.
technologies, Chassis intended for
recognition of emergency vehicles,
innovative (off- cement mixers,
cycle) technologies coach buses, school
not accounted for buses, transit
by the HD Phase 1 buses, refuse
test procedures, trucks, and motor
and credits for homes may
certifying early. optionally use
application-
specific Phase 2
standards using a
simplified version
of GEM.
------------------------------------------------------------------------
(e) Summary of the Heavy-Duty Pickup and Van Standards
The agencies are adopting new Phase 2 GHG emission and fuel
consumption standards for heavy-duty pickups and vans that will be
applied in largely the same manner as the Phase 1 standards. These
standards are based on the extensive use of most known and proven
technologies, and could result in some use of mild or strong hybrid
powertrain technology. These standards will commence in MY 2021. By
2027, these standards are projected to be 16 percent more stringent
than the 2018-2019 standards.
Table I-9--Summary of Phase 1 and Phase 2 Requirements for HD Pickups
and Vans
------------------------------------------------------------------------
Phase 1 program Final 2027 standard
------------------------------------------------------------------------
Covered in this category.... Class 2b and 3 complete pickup trucks and
vans, including all work vans and 15-
passenger vans but excluding 12-passenger
vans which are subject to light-duty
standards.
------------------------------------------------------------------------
Share of HDV fuel HD pickups and vans account for
consumption and GHG approximately 23% of fuel use and GHG
emissions. emissions in the heavy duty truck sector.
------------------------------------------------------------------------
Per vehicle fuel consumption 15% improvement over 16% improvement over
and CO[ihel2] improvement. MY 2010 baseline MY 2018-2019
for diesel standards.
vehicles, and 10%
improvement for
gasoline vehicles.
------------------------------------------------------------------------
Form of the standard........ Phase 1 standards are based upon a ``work
factor'' attribute that combines truck
payload and towing capabilities, with an
added adjustment for 4-wheel drive
vehicles. There are separate target
curves for diesel-powered and gasoline-
powered vehicles. The Phase 2 standards
are based on the same approach.
------------------------------------------------------------------------
Example technology options Engine improvements, Further technology
available to help transmission improvements and
manufacturers meet improvements, increased use of
standards. aerodynamic drag all Phase 1
improvements, low technologies, plus
rolling resistance engine stop-start,
tires, weight and powertrain
reduction, and hybridization (mild
improved and strong).
accessories.
------------------------------------------------------------------------
Flexibilities............... Two optional phase- Same as Phase 1,
in schedules; ABT with phase-in
program which schedule based on
allows emissions year-over-year
and fuel increase in
consumption credits stringency. Same
to be averaged, ABT and off-cycle
banked, or traded program as Phase 1.
(five year credit Adjustment factor
life). of 1.25 for credits
Manufacturers carried forward
allowed to carry- from Phase 1 to
forward credit Phase 2 due to
deficits for up to change in useful
three model years. life.
Interim incentives Revised multipliers
for advanced for Phase 2
technologies, advanced
recognition of technologies.
innovative (off- No Phase 2 early
cycle) technologies credit multipliers.
not accounted for
by the HD Phase 1
test procedures,
and credits for
certifying early.
------------------------------------------------------------------------
Similar to Phase 1, the agencies are adopting for Phase 2 a set of
continuous equation-based standards for HD pickups and vans. Please
refer to Section VI for a description of these standards, including
associated tables and figures.
D. Summary of the Costs and Benefits of the Final Rules
This section summarizes the projected costs and benefits of the
NHTSA fuel consumption and EPA GHG emission standards. See Sections VII
through IX and the RIA for additional details about these projections.
For these rules, the agencies used two analytical methods for the
heavy-duty pickup and van segment by employing both DOT's CAFE model
and EPA's MOVES model. The agencies used EPA's MOVES model to estimate
fuel consumption and emissions impacts for tractor-trailers (including
the engine that powers the tractor), and vocational vehicles (including
the engine that powers the vehicle). Additional calculations were
performed to determine corresponding monetized program costs and
benefits. For heavy-duty pickups and vans, the agencies performed
separate analyses, which we refer to as ``Method A'' and ``Method B.''
In Method A, a new version of the CAFE model was used to project a
pathway the industry could use to comply with each regulatory
alternative and the estimated effects on fuel consumption, emissions,
benefits and costs. In Method B, the CAFE model from the NPRM was used
to project a pathway the industry could use to comply with each
regulatory alternative, along with resultant impacts on per-vehicle
costs. However, the MOVES model was used to calculate corresponding
changes in total fuel consumption and annual emissions for pickups and
vans in Method B. Additional calculations were performed to determine
corresponding
[[Page 73507]]
monetized program costs and benefits. NHTSA considered Method A as its
central analysis and Method B as a supplemental analysis. EPA
considered the results of Method B. The agencies concluded that these
methods led the agencies to the same conclusions and the same selection
of these standards. See Section VII for additional discussion of these
two methods.
(1) Reference Case Against Which Costs and Benefits Are Calculated
The No Action Alternatives for today's analysis, alternatively
referred to as the ``baselines'' or ``reference cases,'' assume that
the agencies did not issue new rules regarding MD/HD fuel efficiency
and GHG emissions. These are the baselines against which costs and
benefits for these standards are calculated. The reference cases assume
that model year 2018 engine, tractor, vocational vehicle, and HD pickup
and van standards will be extended indefinitely and without change.
They also assume that no new standards would be adopted for trailers.
The agencies recognize that if these Phase 2 standards had not been
adopted, manufacturers would nevertheless continue to introduce new
heavy-duty vehicles in a competitive market that responds to a range of
factors, and manufacturers might have continued to improve technologies
to reduce heavy-duty vehicle fuel consumption. Thus, as described in
Section VII, both agencies fully analyzed these standards and the
regulatory alternatives against two reference cases. The first case
uses a baseline that projects no improvement in new vehicles in the
absence of new Phase 2 standards, and the second uses a more dynamic
baseline that projects some significant improvements in vehicle fuel
efficiency. NHTSA considered its primary analysis to be based on the
dynamic baseline, where certain cost-effective technologies are assumed
to be applied by manufacturers to improve fuel efficiency beyond the
Phase 1 requirements in the absence of new Phase 2 standards. EPA
considered both reference cases. The results for all of the regulatory
alternatives relative to both reference cases, derived via the same
methodologies discussed in this section, are presented in Section X of
the Preamble.
The agencies received limited comments on these reference cases.
Some commenters expressed support for a flat baseline in the context of
the need for the regulations, arguing that little improvement would
occur without the regulations. Others supported the less dynamic
baseline because they believe it more fully captures the costs. A
number of commenters expressed that purchasers are willing to and do
pay for fuel efficiency improving technologies, provided the cost for
the technology is paid back through fuel savings within a certain
period of time; this is the premise for a dynamic baseline. Some
commenters thought it reasonable that the agencies consider both
baselines given the uncertainty in this area. No commenters opposed the
consideration of both baselines.
The agencies have continued to analyze two different baselines for
the final rules because we recognize that there are a number of factors
that create uncertainty in projecting a baseline against which to
compare the future effects of this action and the remaining
alternatives. The composition of the future fleet--such as the relative
position of individual manufacturers and the mix of products they each
offer--cannot be predicted with certainty at this time. Additionally,
the heavy-duty vehicle market is diverse, as is the range of vehicle
purchasers. Heavy-duty vehicle manufacturers have reported that their
customers' purchasing decisions are influenced by their customers' own
determinations of minimum total cost of ownership, which can be unique
to a particular customer's circumstances. For example, some customers
(e.g., less-than-truckload or package delivery operators) operate their
vehicles within a limited geographic region and typically own their own
vehicle maintenance and repair centers within that region. These
operators tend to own their vehicles for long time periods, sometimes
for the entire service life of the vehicle. Their total cost of
ownership is influenced by their ability to better control their own
maintenance costs, and thus they can afford to consider fuel efficiency
technologies that have longer payback periods, outside of the vehicle
manufacturer's warranty period. Other customers (e.g., truckload or
long-haul operators) tend to operate cross-country, and thus must
depend upon truck dealer service centers for repair and maintenance.
Some of these customers tend to own their vehicles for about four to
seven years, so that they typically do not have to pay for repair and
maintenance costs outside of either the manufacturer's warranty period
or some other extended warranty period. Many of these customers tend to
require seeing evidence of fuel efficiency technology payback periods
on the order of 18 to 24 months before seriously considering evaluating
a new technology for potential adoption within their fleet (NAS 2010,
Roeth et al. 2013, and Klemick et al. 2014). Purchasers of HD pickups
and vans wanting better fuel efficiency tend to demand that fuel
consumption improvements pay back within approximately one to three
years, but some HD pickup and van owners accrue relatively few vehicle
miles traveled per year, such that they may be less likely to adopt new
fuel efficiency technologies, while other owners who use their
vehicle(s) with greater intensity may be even more willing to pay for
fuel efficiency improvements. Regardless of the type of customer, their
determination of minimum total cost of ownership involves the customer
balancing their own unique circumstances with a heavy-duty vehicle's
initial purchase price, availability of credit and lease options,
expectations of vehicle reliability, resale value and fuel efficiency
technology payback periods. The degree of the incentive to adopt
additional fuel efficiency technologies also depends on customer
expectations of future fuel prices, which directly impacts customer
payback periods. Purchasing decisions are not based exclusively on
payback period, but also include the considerations discussed above and
in Section X.A.1. For the baseline analysis, the agencies use payback
period as a proxy for all of these considerations, and therefore the
payback period for the baseline analysis is shorter than the payback
period industry uses as a threshold for the further consideration of a
technology. See Section X.A.1 of this Preamble and Chapter 11 of the
RIA for a more detailed discussion of baselines. As part of a
sensitivity analysis, additional baseline scenarios were also evaluated
for HD pickups and vans, including baseline payback periods of 12, 18
and 24 months. See Section VI of this Preamble and Chapter 10 of the
RIA for a detailed discussion of these additional scenarios.
(2) Costs and Benefits Projected for the Phase 2 Standards
The tables below summarize the benefits and costs for the program
in two ways: First, from the perspective of a program designed to
improve the Nation's energy security and to conserve energy by
improving fuel efficiency and then from the perspective of a program
designed to reduce GHG emissions. The individual categories of benefits
and costs presented in the tables below are defined more fully and
presented in more detail in Chapter 8 of the RIA.
Lifetime fuel savings, GHG reductions, benefits, costs and net
benefits for model years 2018 through
[[Page 73508]]
2029 vehicles as presented below. This is consistent with the NPRM
analysis and allows readers to compare the costs and benefits of the
final program with those projected for the NPRM. It also includes for
modeling purposes at least three model years for each standard.
Table I-10 shows benefits and costs for these standards from the
perspective of a program designed to improve the Nation's energy
security and conserve energy by improving fuel efficiency. From this
viewpoint, technology costs occur when the vehicle is purchased. Fuel
savings are counted as benefits that occur over the lifetimes of the
vehicles produced during the model years subject to the Phase 2
standards as they consume less fuel.
Table I-10--Lifetime Fuel Savings, GHG Reductions, Benefits, Costs, and
Net Benefits for Model Years 2018-2029 Vehicles Using Analysis Method A
[Billions of 2013$] \a\ \b\
------------------------------------------------------------------------
Category 3% discount rate 7% discount rate
------------------------------------------------------------------------
Fuel Reductions (Billion
Gallons)....................... 71.1-77.7
---------------------------------------
GHG reductions (MMT CO[ihel2]
eq)............................ 959-1049
---------------------------------------
Vehicle Program: Technology and 23.7 to 24.4 16.1 to 16.6
Indirect Costs, Normal Profit
on Additional Investments......
Additional Routine Maintenance.. 1.7 to 1.7 0.9 to 0.9
Congestion, Crashes, Fatalities 3.1 to 3.2 1.8 to 1.9
and Noise from Increased
Vehicle Use \d\................
---------------------------------------
Total Costs................. 28.5 to 29.3 18.8 to 19.4
---------------------------------------
Fuel Savings (valued at pre-tax 149.1 to 163.0 79.7 to 87.0
prices)........................
Savings from Less Frequent 3.0 to 3.2 1.6 to 1.7
Refueling......................
Economic Benefits from 5.4 to 5.5 3.4 to 3.5
Additional Vehicle Use.........
---------------------------------------
Reduced Climate Damages from GHG
Emissions \c\.................. 33.0 to 36.0
---------------------------------------
Reduced Health Damages from Non- 27.1 to 30.0 14.6 to 16.1
GHG Emissions..................
Increased U.S. Energy Security.. 7.3 to 7.9 3.9 to 4.2
---------------------------------------
Total Benefits.............. 225 to 246 136 to 149
---------------------------------------
Net Benefits................ 197 to 216 117 to 129
------------------------------------------------------------------------
Notes:
\a\ For an explanation of analytical Methods A and B, please see Section
I.D; for an explanation of the flat baseline, 1a, and dynamic
baseline, 1b, please see Section X.A.1.
\b\ Range reflects two reference case assumptions 1a and 1b.
\c\ Benefits and net benefits use the 3 percent global average SCC value
applied only to CO[ihel2] emissions; GHG reductions include CO[ihel2],
CH4, N[ihel2]O and HFC reductions, and include benefits to other
nations as well as the U.S. See Draft RIA Chapter 8.5 and Preamble
Section IX.G for further discussion.
\d\ ``Congestion, Crashes, Fatalities and Noise from Increased Vehicle
Use'' includes NHTSA's monetized value of estimated reductions in the
incidence of highway fatalities associated with mass reduction in HD
pickup and vans, but this does not include these reductions from
tractor-trailers or vocational vehicles. This likely results in a
conservative overestimate of these costs.
Table I-11 shows benefits and cost from the perspective of reducing
GHG. As shown below in terms of MY lifetime GHG reductions, and in RIA
Chapter 5 in terms of year-by-year GHG reductions, the final program is
expected to reduce more GHGs over the long run than the proposed
program. In general, the greater reductions can be attributed to
increased market penetration and effectiveness of key technologies,
based on new data and comments, leading to increases in stringency such
as with the diesel engine standards (Section I.C.(2)(a) above).
Table I-11--Lifetime Fuel Savings, GHG Reductions, Benefits, Costs and
Net Benefits for Model Years 2018-2029 Vehicles Using Analysis Method B
[Billions of 2012$] \a\ \b\
------------------------------------------------------------------------
Category 3% discount rate 7% discount rate
------------------------------------------------------------------------
Fuel Reductions (Billion
Gallons)....................... 73-82
---------------------------------------
GHG reductions (MMT CO[ihel2]eq) 976-1,098
---------------------------------------
Vehicle Program (e.g., -$26.5 to -$26.2 -$17.6 to -$17.4
technology and indirect costs,
normal profit on additional
investments)...................
Additional Routine Maintenance.. -$1.9 to -$1.9 -$1.0 to -$1.0
Fuel Savings (valued at pre-tax $149.3 to $169.1 $76.8 to $87.2
prices)........................
Energy Security................. $6.9 to $7.8 $3.5 to $4.0
Congestion, Crashes, and Noise -$3.2 to -$3.2 -$1.8 to -$1.8
from Increased Vehicle Use.....
Savings from Less Frequent $3.4 to $4.0 $1.8 to $2.1
Refueling......................
Economic Benefits from $10.4 to $10.5 $5.7 to $5.7
Additional Vehicle Use.........
Benefits from Reduced Non-GHG $28.3 to $31.9 $13.4 to $15.0
Emissions \c\..................
------------------------------------------------------------------------
[[Page 73509]]
Reduced Climate Damages from GHG
Emissions \d\.................. $33.0 to $37.2
---------------------------------------
Net Benefits................ $200 to $229 $114 to $131
------------------------------------------------------------------------
Notes:
\a\ For an explanation of analytical Methods A and B, please see Section
I.D; for an explanation of the flat baseline, 1a, and dynamic
baseline, 1b, please see Section X.A.1.
\b\ Range reflects two baseline assumptions 1a and 1b.
\c\ Range reflects both the two baseline assumptions 1a and 1b using the
mid-point of the low and high $/ton estimates for calculating
benefits.
\d\ Benefits and net benefits use the 3 percent average directly modeled
SC-GHG values applied to direct reductions of CO[ihel2], CH[ihel4] and
N[ihel2]O emissions; GHG reductions include CO[ihel2], CH[ihel4] and
N[ihel2]O reductions.
Table I-12 breaks down by vehicle category the benefits and costs
for these standards using the Method A analytical approach. For
additional detail on per-vehicle break-downs of costs and benefits,
please see RIA Chapter 10.
Table I-12--Per Vehicle Category Lifetime Fuel Savings, GHG Reductions,
Benefits, Costs and Net Benefits for Model Years 2018-2029 Vehicles
Using Analysis Method A (Billions of 2013$), Relative to Baseline 1b \a\
------------------------------------------------------------------------
Key costs and benefits by
vehicle category 3% discount rate 7% discount rate
------------------------------------------------------------------------
Tractors, Including Engines, and Trailers
------------------------------------------------------------------------
Fuel Reductions (Billion
Gallons)....................... 50
---------------------------------------
GHG Reductions (MMT CO[ihel2]
eq)............................ 685
---------------------------------------
Total Costs..................... 13.8 9.0
Total Benefits.................. 161.0 96.8
Net Benefits.................... 147.2 85.5
------------------------------------------------------------------------
Vocational Vehicles, Including Engines
------------------------------------------------------------------------
Fuel Reductions (Billion
Gallons)....................... 12
---------------------------------------
GHG Reductions (MMT CO[ihel2]
eq)............................ 162
---------------------------------------
Total Costs..................... 7.3 4.8
Total Benefits.................. 37.8 22.7
Net Benefits.................... 30.5 15.3
------------------------------------------------------------------------
HD Pickups and Vans
------------------------------------------------------------------------
Fuel Reductions (Billion
Gallons)....................... 10
---------------------------------------
GHG Reductions (MMT CO[ihel2]
eq)............................ 111
---------------------------------------
Total Costs..................... 7.4 5.1
Total Benefits.................. 26.0 16.7
Net Benefits.................... 18.6 11.6
------------------------------------------------------------------------
Notes:
\a\ For an explanation of analytical Methods A and B, please see Section
I.D; for an explanation of the flat baseline, 1a, and dynamic
baseline, 1b, please see Section X.A.1.
Table I-13--Per Vehicle Costs, Using Method A (2013$), Relative to Baseline 1b
----------------------------------------------------------------------------------------------------------------
MY 2021 MY 2024 MY 2027
----------------------------------------------------------------------------------------------------------------
Per Vehicle Cost ($): \a\
Tractors.................................................... $6,400 $9,920 $12,160
Trailers.................................................... 850 1,000 1,070
Vocational Vehicles......................................... 1,110 2,020 2,660
Pickups/Vans................................................ 750 760 1,340
----------------------------------------------------------------------------------------------------------------
Note:
\a\ Per vehicle costs include new engine and vehicle technology only; costs associated with increased insurance,
taxes and maintenance are included in the payback period values.
[[Page 73510]]
Table I-14--Per Vehicle Costs Using Method B Relative to Baseline 1a
----------------------------------------------------------------------------------------------------------------
MY 2021 MY 2024 MY 2027
----------------------------------------------------------------------------------------------------------------
Per Vehicle Cost ($): \a\
Tractors.................................................... $6,484 $10,101 $12,442
Trailers.................................................... 868 1,033 1,108
Vocational Vehicles......................................... 1,110 2,022 2,662
Pickups/Vans................................................ 524 963 1,364
----------------------------------------------------------------------------------------------------------------
Note:
\a\ Per vehicle costs include new engine and vehicle technology only; costs associated with increased insurance,
taxes and maintenance are included in the payback period values.
An important metric to vehicle purchasers is the payback period
that can be expected on any new purchase. In other words, there is
greater willingness to pay for new technology if that new technology
``pays back'' within an acceptable period of time. The agencies make no
effort to define the acceptable period of time, but seek to estimate
the payback period for others to make the decision themselves. The
payback period is the point at which reduced fuel expenditures outpace
increased vehicle costs, including increased maintenance, insurance
premiums and taxes. The payback periods for vehicles meeting the
standards considered for the final year of implementation are shown in
Table I-15, and are similar for both Method A and Method B.
Table I-15--Payback Periods for MY 2027 Vehicles Relative to Baseline 1a
[Payback cccurs in the year shown; using 7% discounting]
------------------------------------------------------------------------
------------------------------------------------------------------------
Tractors/Trailers......................... 2nd.
Vocational Vehicles....................... 4th.
Pickups/Vans.............................. 3rd.
------------------------------------------------------------------------
Table I-16--Payback Periods for MY 2027 Vehicles Relative to Baseline 1b
[Payback occurs in the year shown; using 7% discounting]
------------------------------------------------------------------------
------------------------------------------------------------------------
Tractors/Trailers......................... 2nd.
Vocational Vehicles....................... 4th.
Pickups/Vans.............................. 3rd.
------------------------------------------------------------------------
(3) Cost Effectiveness
These regulations implement section 32902(k) of EISA and section
202(a)(1) and (2) of the Clean Air Act. Through the 2007 EISA, Congress
directed NHTSA to create a medium- and heavy-duty vehicle fuel
efficiency program designed to achieve the maximum feasible improvement
by considering appropriateness, cost effectiveness, and technological
feasibility to determine maximum feasible standards.\78\ The Clean Air
Act requires that any air pollutant emission standards for heavy-duty
vehicles and engines take into account the costs of any requisite
technology and the lead time necessary to implement such technology.
Both agencies considered overall costs, overall benefits and cost
effectiveness in developing the Phase 2 standards. Although there are
different ways to evaluate cost effectiveness, the essence is to
consider some measure of costs relative to some measure of impacts.
---------------------------------------------------------------------------
\78\ This EISA requirement applies to regulation of medium- and
heavy-duty vehicles. For many years, and as reaffirmed by Congress
in 2007, ``economic practicability'' has been among the factors EPCA
requires NHTSA to consider when setting light-duty fuel economy
standards at the (required) maximum feasible levels. NHTSA
interprets ``economic practicability'' as a factor involving
considerations broader than those likely to be involved in ``cost
effectiveness.''
---------------------------------------------------------------------------
Considering that Congress enacted EPCA and EISA to, among other
things, address the need to conserve energy, the agencies have
evaluated these standards in terms of costs per gallon of fuel
conserved. We also considered the similar metric of cost of technology
per ton of CO2e removed, consistent with the objective of
CAA section 202(a)(1) and (2) to reduce emissions of air pollutants
which contribute to air pollution which endangers public health and
welfare. As described in the RIA, the agencies also evaluated these
standards using the same approaches employed in HD Phase 1. Together,
the agencies have considered the following three ratios of cost
effectiveness:
1. Total social costs per gallon of fuel conserved
2. Technology costs per ton of GHG emissions reduced (CO2eq)
3. Technology costs minus fuel savings per ton of GHG emissions reduced
By all three of these measures, the total heavy-duty program will be
highly cost effective.
As discussed below, the agencies estimate that over the lifetime of
heavy-duty vehicles produced for sale in the U.S. during model years
2018-2029, these standards will cost about $30 billion and conserve
about 75 billion gallons of fuel, such that the first measure of cost
effectiveness will be about 40 cents per gallon. Relative to fuel
prices underlying the agencies' analysis, the agencies have concluded
that today's standards will be cost effective.
With respect to the second measure, which is useful for comparisons
to other GHG rules, these standards will have overall $/ton costs
similar to the HD Phase 1 rule. As Chapter 7 of the RIA shows, social
costs will amount to about $30 per metric ton of GHG (CO2eq)
for the entire HD Phase 2 program. This compares well to both the HD
Phase 1 rule, which was also estimated to cost about $30 per metric ton
of GHG (without fuel savings), and to the agencies' estimates of the
social cost of carbon.\79\ Thus, even without accounting for fuel
savings, these standards will be cost-effective.
---------------------------------------------------------------------------
\79\ As described in Section IX.G, the social cost of carbon is
a metric that estimates the monetary value of impacts associated
with marginal changes in CO2 emissions in a given year.
---------------------------------------------------------------------------
The following table include the overall per-unit costs of both
gallons of fuel conserved and metric tons of GHG emissions abated using
both a 3 percent and a 7 percent discount rate. Table I-16 gives these
values under the Method A analysis.
[[Page 73511]]
Table I-17--Method A Cost Per-Unit of Fuel Savings and GHG Emission
Reductions by Vehicle Class
[Relative to the dynamic baseline]
------------------------------------------------------------------------
Per-unit costs (2013$/Unit) by
vehicle category 3% Discount rate 7% Discount rate
------------------------------------------------------------------------
Tractors, Including Engines, and Trailers
------------------------------------------------------------------------
Cost per Gallon of Fuel Saved... $0.28 $0.18
Cost per Ton of GHG Emissions 20 13
Saved..........................
------------------------------------------------------------------------
Vocational Vehicles, Including Engines
------------------------------------------------------------------------
Cost per Gallon of Fuel Saved... 0.61 0.40
Cost per Ton of GHG Emissions 45 30
Saved..........................
------------------------------------------------------------------------
HD Pickups and Vans
------------------------------------------------------------------------
Cost per Gallon of Fuel Saved... 0.76 0.52
Cost per Ton of GHG Emissions 67 46
Saved..........................
------------------------------------------------------------------------
Total Program
------------------------------------------------------------------------
Cost per Gallon of Fuel Saved... 0.40 0.26
Cost per Ton of GHG Emissions 30 20
Saved..........................
------------------------------------------------------------------------
When considering these values, it is important to emphasize two
points:
1. As is shown throughout this rulemaking, the Phase 2 standards
represent the most stringent standards that are technologically
feasible and reliably implementable within the lead time provided.
2. These are not the marginal cost-effectiveness values.
Without understanding these two points, some readers might assume
that because the tractor-trailer standards are more cost-effective
overall than the other standards that manufacturers would choose to
over-comply with the more cost-effective tractor or trailer standards
and do less for other vehicles. However, the agencies believe this is
not a technologically feasible option. Because the tractor and trailer
standards represent maximum feasible standards, they will effectively
require manufacturers to deploy all available technology to meet the
standards. The agencies do not project that manufacturers would be able
to over-comply with the 2027 standards by a significant margin.
The third measure deducts fuel savings from costs, which also is
useful for comparisons to other GHG rules. As shown in Table I-18, the
agencies have also calculated the cost per metric ton of
CO2e emission reductions including the savings associated
with reduced fuel consumption. The calculations presented here include
all engine-related costs but do not include benefits associated with
the final program such as those associated with criteria pollutant
reductions or energy security benefits (discussed in Chapter 8 of this
RIA). On this basis, net costs per ton of GHG emissions reduced will be
negative under these standards. This means that the value of the fuel
savings will be greater than the technology costs, and there will be a
net cost saving for vehicle owners. In other words, the technologies
will pay for themselves (indeed, more than pay for themselves) in fuel
savings.
Table I-18--Annual Net Cost per Metric Ton of CO2eq Emissions Reduced in the Final Program Vs. the Flat Baseline
and Using Method B for Calendar Year 2030
[Dollar values are 2013$] \a\
----------------------------------------------------------------------------------------------------------------
Vehicle &
maintenance Fuel savings GHG reduced Net cost ($/
Calendar year costs ($billions) (MMT) metric ton)
($billions) \b\
----------------------------------------------------------------------------------------------------------------
HDE Pickups and Vans............................ 1.6 3.9 15 0
Vocational Vehicles............................. 1.5 3.5 14 0
Tractor-Trailers................................ 2.3 16 64 0
All Vehicles.................................... 5.5 23 94 0
----------------------------------------------------------------------------------------------------------------
Notes:
\a\ For an explanation of analytical Methods A and B, please see the beginning of this Section I.D; for an
explanation of the flat baseline, 1a, and dynamic baseline, 1b, please see Section X.A.1. GHG reductions
include CO[ihel2] and CO[ihel2] equivalents of CH4, and N[ihel2]O.
\b\ For each category, fuel savings exceed cost so there is no net cost per ton of GHG reduced.
In addition, while the net economic benefits (i.e., total benefits
minus total costs) of these standards is not a traditional measure of
their cost effectiveness, the agencies have concluded that the total
costs of these standards are justified in part by their significant
economic benefits. As discussed in the previous subsection and in
Section IX, this rule will provide benefits beyond the fuel conserved
and GHG emissions avoided. The rule's net benefits is a measure that
quantifies each of its various benefits in economic terms, including
the economic value of the fuel it saves and the climate-related damages
it avoids, and compares their sum to the rule's estimated costs. The
agencies estimate that these standards will result in net economic
benefits exceeding $100 billion, making this a highly beneficial
program.
EPA and NHTSA received many comments suggesting that more
[[Page 73512]]
stringent standards were feasible because many cost effective
technologies exist for future vehicle designs. While the agencies agree
that many cost effective technologies exist, and indeed, we reflect the
potential for many of those technologies to be applied in our analysis
for today's final rule, commenters who focused on the cost-
effectiveness of technologies did not consistently recognize certain
real-world constraints on technology implementation. Manufacturers and
suppliers have limited research and development capacities, and
although they have some ability to expand (by adding staff or building
new facilities), the process of developing and applying new
technologies is inherently constrained by time. Adequate lead time is
also necessary to complete durability, reliability, and safety testing
and ramp up production to levels that might be necessary to meet future
standards. If the agencies fail to account for lead time needs in
determining the stringency of the standards, we could create unintended
consequences, such as technologies that are applied before they are
ready and lead to maintenance and repair problems. In addition to cost-
effectiveness, then, lead time constraints can also be highly relevant
to feasibility of more stringent standards.
E. EPA and NHTSA Statutory Authorities
This section briefly summarizes the respective statutory authority
for EPA and NHTSA to promulgate the Phase 1 and Phase 2 programs. For
additional details of the agencies' authority, see Section XV of this
document as well as the Phase 1 rule.\80\
---------------------------------------------------------------------------
\80\ 76 FR 57106-57129, September 15, 2011.
---------------------------------------------------------------------------
(1) EPA Authority
Statutory authority for the emission standards in this rule is
found in CAA section 202(a)(1) and (2) (which requires EPA to establish
standards for emissions of pollutants from new motor vehicles and
engines which emissions cause or contribute to air pollution which may
reasonably be anticipated to endanger public health or welfare), and in
CAA sections 202(a)(3), 202(d), 203-209, 216, and 301 (42 U.S.C. 7521
(a)(1) and (2), 7521(d), 7522-7543, 7550, and 7601).
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-GHG
emissions; 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 action implements a specific provision from Title II, section
202(a). 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. See Coalition
for Responsible Regulation v. EPA, 684 F. 3d at 116-125, 126-27 cert.
granted by, in part Util. Air Regulatory Group v. EPA, 134 S. Ct. 418
(2013), affirmed in part and reversed in part on unrelated grounds by
Util. Air Regulatory Group v. EPA, 134 S. Ct. 2427 (2014) (upholding
EPA's endangerment and cause and contribute findings, and further
affirming EPA's conclusion that it is legally compelled to issue
standards under section 202(a) to address emission of the pollutant
which endangers after making the endangerment and cause or contribute
findings); see also id. at 127-29 (upholding EPA's light-duty GHG
emission standards for MYs 2012-2016 in their entirety).
Other aspects of EPA's legal authority, including its authority
under section 202(a), its testing authority under section 203 of the
Act, and its enforcement authorities under sections 205 and 207 of the
Act are discussed fully in the Phase 1 rule, and need not be repeated
here. See 76 FR 57129-57130.
In this final rule, EPA is establishing first-time CO2
emission standards for trailers hauled by tractors. 80 FR 40170.
Certain commenters, notably the Truck Trailer Manufacturers Association
(TTMA), maintained that EPA lacks authority to adopt requirements for
trailer manufacturers, and that emission standards for trailers could
be implemented, if at all, by requirements applicable to the entity
assembling a tractor-trailer combination. The argument is that trailers
by themselves are not ``motor vehicles'' as defined in section 216(2)
of the Act, that trailer manufacturers therefore do not manufacture
motor vehicles, and that standards for trailers can be imposed, if at
all, only on ``the party that joined the trailer to the tractor.''
Comments of TTMA, p. 4; Comments of TTMA (March 31, 2016) p. 2.
EPA also proposed a number of changes and clarifications for rules
respecting glider kits and glider vehicles. 80 FR 40527-40530. As shown
in Figure I.1, a glider kit is a tractor chassis with frame, front
axle, interior and exterior cab, and brakes.
[[Page 73513]]
[GRAPHIC] [TIFF OMITTED] TR25OC16.000
It is intended for self-propelled highway use, and becomes a glider
vehicle when an engine, transmission, and rear axle are added. Engines
are often salvaged from earlier model year vehicles, remanufactured,
and installed in the glider kit. The final manufacturer of the glider
vehicle, i.e. the entity that installs an engine, is typically a
different manufacturer than the original manufacturer of the glider
kit. The final rule contains emission standards for glider vehicles,
but does not contain separate standards for glider kits.\81\
---------------------------------------------------------------------------
\81\ As discussed in sections (c) and (d) below, however,
manufacturers of glider kits can, and typically are, responsible for
obtaining a certificate of conformity before shipping a glider kit.
This is because they are manufacturers of motor vehicles, in this
case, an incomplete vehicle.
---------------------------------------------------------------------------
Many commenters to both the proposed rule and the NODA supported
EPA's interpretation. However, a number of commenters, including
Daimler, argued that glider kits are not motor vehicles and so EPA
lacks the authority to impose any rules respecting their sale or
configuration. Comments of Daimler, pp. 122-23; Comments of Daimler
Trucks (April 1, 2016) pp. 2-3. We respond to these comments below,
with a more detailed response appearing in RTC Section 1.3.1 and 14.2.
Under the Act, ``motor vehicle'' is defined as ``any self-propelled
vehicle designed for transporting persons or property on a street or
highway.'' CAA section 216(2). At proposal, EPA maintained that
tractor-trailers are motor vehicles and that EPA therefore has the
authority to promulgate emission standards for complete and incomplete
vehicles--both the tractor and the trailer. 80 FR 40170. The same
proposition holds for glider kits and glider vehicles. Id. at 80 FR
40528. The argument that a trailer, or a glider kit, standing alone, is
not self-propelled, and therefore is not a motor vehicle, misses the
key issues of authority under the Clean Air Act to promulgate emission
standards for motor vehicles produced in discrete segments, and the
further issue of the entities--namely ``manufacturers''--to which
standards and certification requirements apply. Simply put, EPA is
authorized to set emission standards for complete and incomplete motor
vehicles, manufacturers of complete and incomplete motor vehicles can
be required to certify to those emission standards, and there can be
multiple manufacturers of a motor vehicle, each of which can be
required to certify.
(a) Standards for Complete Vehicles--Tractor-Trailers and Glider
Vehicles
Section 202(a)(1) authorizes EPA to set standards ``applicable to
the emission of any air pollutant from any . . . new motor vehicles.''
There is no question that EPA is authorized to establish emission
standards under this provision for complete new motor vehicles, and
thus can promulgate emission standards for air pollutants emitted by
tractor-trailers and by glider vehicles.
Daimler maintained in its comments that although a glider vehicle
is a motor vehicle, it is not a ``new'' motor vehicle because ``glider
vehicles, when constructed retain the identity of the donor vehicle,
such that the title has already been exchanged, making the vehicles not
`new' under the CAA.'' Daimler Comments p. 121; see also the similar
argument in Daimler Truck Comments (April 1, 2016), p. 4. Daimler
maintains that because title to the powertrain from the donor vehicle
has already been transferred, the glider vehicle to which the
powertrain is added cannot be ``new.'' Comments of April 1, 2016 p. 4.
Daimler also notes that NHTSA considers a truck to be ``newly
manufactured'' and subject to Federal Motor Vehicle Safety Standards
when a new cab is used in its assembly, ``unless the engine,
transmission, and drive axle(s) (as a minimum) of the assembled vehicle
are not new, and at least two of these components were taken from the
same vehicle.'' 49 CFR 571.7(e). Daimler urges EPA to adopt a parallel
provision here.
First, this argument appears to be untimely. In Phase 1, EPA
already indicated that glider vehicles are new motor vehicles, at least
implicitly, by
[[Page 73514]]
adopting an interim exemption for them. See 76 FR 57407 (adopting 40
CFR 1037.150(j) indicating that the general prohibition against
introducing a vehicle not subject to current model year standards does
not apply to MY 2013 or earlier engines). Assuming the argument that
glider vehicles are not new can be raised in this rulemaking, EPA notes
that the Clean Air Act defines ``new motor vehicle'' as ``a motor
vehicle the equitable or legal title to which has never been
transferred to an ultimate purchaser'' (section 216(3)). Glider
vehicles are typically marketed and sold as ``brand new'' trucks.
Indeed, one prominent assembler of glider kits and glider vehicles
advertises that ``Fitzgerald Glider Kits offers customers the option to
purchase a brand new 2016 tractor, in any configuration offered by the
manufacturer . . . Fitzgerald Glider Kits has mastered the process of
taking the `Glider Kit' and installing the components to work
seamlessly with the new truck.'' \82\ The purchaser of a ``new truck''
necessarily takes initial title to that truck.\83\ Daimler would have
it that this `new truck' terminology is a mere marketing ploy, but it
obviously reflects reality. As shown in Figure I.1 above, the glider
kit constitutes the major parts of the vehicle, lacking only the
engine, transmission, and rear axle. The EPA sees nothing in the Act
that compels the result that adding a used component to an otherwise
new motor vehicle necessarily vitiates classification of the motor
vehicle as ``new.'' See 80 FR 40528. Rather, reasonable judgments must
be made, and in this case, the agency believes it reasonable that the
tail need not wag the dog: Adding the engine and transmission to the
otherwise-complete vehicle does not prevent the glider vehicle from
being ``new''--as marketed. The fact that this approach is reasonable,
if not mandated, is confirmed by the language of the Act's definition
of ``new motor vehicle engine,'' which includes any ``engine in a new
motor vehicle'' without regard to whether or not the engine was
previously used. EPA has also previously addressed the issue of used
components in new engines and vehicles explicitly in regulations in the
context of locomotives and locomotive engines in 40 CFR part 1033.
There we defined remanufactured locomotives and locomotive engines to
be ``new'' locomotives and locomotive engines. See 63 FR 18980; see
also Summary and Analysis of Comments on Notice of Proposed Rulemaking
for Emission Standards for Locomotives and Locomotive Engines (EPA-420-
R-97-101 (December 1997)) at pp. 10-14. This is a further reason that
the model year of the engine is not determinative of whether a glider
vehicle is ``new.'' As to the suggestion to adopt a provision parallel
to the NHTSA definition, EPA notes that the NHTSA definition was
developed for different purposes using statutory authority which
differs from the Clean Air Act in language and intent. There
consequently is no basis for requiring EPA to adopt such a definition,
and doing so would impede meaningful control of both GHG emissions and
criteria pollutant emissions from glider vehicles.
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\82\ Advertisement for Fitzgerald Glider kits in Overdrive
magazine (December 2015) (emphasis added).
\83\ Fitzgerald states ``All Fitzgerald glider kits will be
titled in the state of Tennessee and you will receive a title to
transfer to your state.'' https://www.fitzgeraldgliderkits.com/frequently-asked-questions. Last accessed July 9, 2016.
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(b) Standards for Incomplete Vehicles
Section 202(a)(1) not only authorizes EPA to set standards
``applicable to the emission of any air pollutant from any . . . new
motor vehicles,'' but states further that these standards are
applicable ``whether such vehicles . . . are designed as complete
systems or incorporate devices to prevent or control such pollution.''
The Act in fact thus not only contemplates, but in some instances,
directly commands that EPA establish standards for incomplete vehicles
and vehicle components. See CAA section 202(a)(6) (standards for
onboard vapor recovery systems on ``new light-duty vehicles,'' and
requiring installation of such systems); section 202(a)(5)(A)
(standards to control emissions from refueling motor vehicles, and
requiring consideration of, and possible design standards for, fueling
system components); 202(k) (standards to control evaporative emissions
from gasoline-fueled motor vehicles). Both TTMA and Daimler argued, in
effect, that these provisions are the exceptions that prove the rule
and that without this type of enumerated exception, only entire,
complete vehicles can be considered to be ``motor vehicles.'' This
argument is not persuasive. Congress did not indicate that these
incomplete vehicle provisions were exceptions to the definition of
motor vehicle. Just the opposite. Without amending the new motor
vehicle definition, or otherwise indicating that these provisions were
not already encompassed within Title II authority over ``new motor
vehicles'', Congress required EPA to set standards for evaporative
emissions from a portion of a motor vehicle. Congress thus indicated in
these provisions: (1) That standards should apply to ``vehicles''
whether or not the ``vehicles'' were designed as complete systems; (2)
that some standards should explicitly apply only to certain components
of a vehicle that are plainly not self-propelled. Congress thus
necessarily was of the view that incomplete vehicles can be motor
vehicles.
Emission standards EPA sets pursuant to this authority thus can be,
and often are focused on emissions from the new motor vehicle, and from
portions, systems, parts, or components of the vehicle. Standards thus
apply not just to exhaust emissions, but to emissions from non-exhaust
portions of a vehicle, or from specific vehicle components or parts.
See the various evaporative emission standards for light duty vehicles
in 40 CFR part 86, subpart B (e.g., 40 CFR 86.146-96 and 86.150-98
(refueling spitback and refueling test procedures); 40 CFR 1060.101-103
and 73 FR 59114-59115 (various evaporative emission standards for small
spark ignition equipment); 40 CFR 86.1813-17(a)(2)(iii) (canister bleed
evaporative emission test procedure, where testing is solely of fuel
tank and evaporative canister); see also 79 FR 23507 (April 28, 2014)
(incomplete heavy duty gasoline vehicles could be subject to, and
required to certify compliance with, evaporative emission standards)).
These standards are implemented by testing the particular vehicle
component, not by whole vehicle testing, notwithstanding that the
component may not be self-propelled until it is installed in the
vehicle or (in the case of non-road equipment), propelled by an
engine.\84\
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\84\ ``Non-road vehicles'' are defined differently than ``motor
vehicles'' under the Act, but the difference does not appear
relevant here. Non-road vehicles, like motor vehicles, must be
propelled by an engine. See CAA section 216(11) (`` `nonroad
vehicle' means a vehicle that is powered by a nonroad engine'').
Pursuant to this authority, EPA has promulgated many emission
standards applicable to components of engineless non-road equipment,
for which the equipment manufacturer must certify.
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EPA thus can set standards for all or just a portion of the motor
vehicle notwithstanding that an incomplete motor vehicle may not yet be
self-propelled. This is not to say that the Act authorizes emission
standards for any part of a motor vehicle, however insignificant. Under
the Act it is reasonable to consider both the significance of the
components in comparison to the entire vehicle and the significance of
the components for achieving emissions reductions. A vehicle that is
complete except for an ignition switch can be subject to standards even
though it is not self-
[[Page 73515]]
propelled. Likewise, as just noted, vehicle components that are
significant for controlling evaporative emissions can be subject to
standards even though in isolation the components are not self-
propelled. However, not every individual component of a complete
vehicle can be subjected to standards as an incomplete vehicle. To
reflect these considerations, EPA is adopting provisions stating that a
trailer is a vehicle ``when it has a frame with one or more axles
attached,'' and a glider kit becomes a vehicle when ``it includes a
passenger compartment attached to a frame with one or more axles.''
Section 1037.801 definition of ``vehicle,'' paragraphs (1)(ii) and
(iii); see also Section XIII.B below.
TTMA and Daimler each maintained that this claim of authority is
open-ended, and can be extended to the least significant vehicle part.
As noted above, EPA acknowledges that lines need to be drawn, but
whether looking at the relation between the incomplete vehicle and the
complete vehicle, or looking at the relation between the incomplete
vehicle and the emissions control requirements, it is evident that
trailers and glider kits should properly be treated as vehicles, albeit
incomplete ones.\85\ They properly fall on the vehicle side of the
line. When one finishes assembling a whole aggregation of parts to make
a finished section of the vehicle (e.g. the trailer), that is
sufficient. You have an entire, complete section made up of assembled
parts. Everything needed to be a trailer is complete. This is not an
engine block, a wheel, or a headlight. Similarly, glider kits comprise
the largely assembled tractor chassis with front axles, frame, interior
and exterior cab, and brakes. This is not a few assembled components;
rather, it is an assembled truck with a few components missing. See CAA
section 216(9) of the Act, which defines ``motor vehicle or engine part
manufacturer'' as ``any person engaged in the manufacturing, assembling
or rebuilding of any device, system, part, component or element of
design which is installed in or on motor vehicles or motor vehicle
engines.'' Trailers and glider kits are not ``installed in or on'' a
motor vehicle. A trailer is half of the tractor-trailer, not some
component installed on the tractor. And one would more naturally refer
to the donor drivetrain being installed on the glider kit than vice
versa. See Figure I.1 above. Furthermore, as discussed below, the
trailer and the glider kit are significant for purposes of controlling
emissions from the completed vehicle.
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\85\ Cf. Marine Shale Processors v. EPA, 81 F. 3d 1371, 1383
(5th Cir. 1996) (``[w]e make no comment on this argument: This is
simply not a thimbleful case'').
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Incomplete vehicle standards must, of course, be reasonably
designed to control emissions caused by that particular vehicle
segment. The standards for trailers would do so and account for the
tractor-trailer combination by using a reference tractor in the trailer
test procedure (and, conversely, by use of a reference trailer in the
tractor test procedure). The Phase 2 rule contains no emission
standards for glider kits in isolation, but the standards for glider
vehicles necessarily reflect the contribution of the glider kit.
(c) Application of Emission Standards to Manufacturers
In some ways, the critical issue is to whom these emission
standards apply. As explained in this section, the emission standards
apply to manufacturers of motor vehicles, and manufacturers thus are
required to test and to certify compliance to those standards.
Moreover, the Act contemplates that a motor vehicle can have multiple
manufacturers. With respect to the further question of which
manufacturer certifies and tests in multiple manufacturer situations,
EPA rules have long contained provisions establishing responsibilities
where a vehicle has multiple manufacturers. We are applying those
principles in the Phase 2 rules. The overarching principle is that the
entity with most control over the particular vehicle segment due to
producing it is usually the most appropriate entity to test and
certify.\86\ EPA is implementing the trailer and glider vehicle
emission standards in accord with this principle, so that the entities
required to test and certify are the trailer manufacturer and, for
glider kits and glider vehicles, either the manufacturer of the glider
kit or glider vehicle, depending on which is more appropriate in
individual circumstances.
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\86\ See discussion of standards applicable to small SI
equipment fuel systems, implemented by standards for the
manufacturers of that equipment at 73 FR 59115 (``In most cases,
nonroad standards apply to the manufacturer of the engine or the
manufacturer of the nonroad equipment. Here, the products subject to
the standards (fuel lines and fuel tanks) are typically manufactured
by a different manufacturer. In most cases the engine manufacturers
do not produce complete fuel systems and therefore are not in a
position to do all the testing and certification work necessary to
cover the whole range of products that will be used. We are
therefore providing an arrangement in which manufacturers of fuel-
system components are in most cases subject to the standards and are
subject to certification and other compliance requirements
associated with the applicable standards'').
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(i) Definition of Manufacturer
Emission standards are implemented through regulation of the
manufacturer of the new motor vehicle. See, e.g. section 206(a)(1)
(certification testing of motor vehicle submitted by ``a
manufacturer''); 203(a)(1) (manufacturer of new motor vehicle
prohibited from introducing uncertified motor vehicles into commerce);
207(a)(1) (manufacturer of motor vehicle to provide warranty to
ultimate purchaser of compliance with applicable emission standards);
207(c) (recall authority); 208(a) (recordkeeping and testing can be
required of every manufacturer of new motor vehicle).
The Act further distinguishes between manufacturers of motor
vehicles and manufacturers of motor vehicle parts. See, e.g. section
206(a)(2) (voluntary emission control system verification testing);
203(a)(3)(B) (prohibition on parts manufacturers and other persons
relating to defeat devices); 207(a)(2) (parts manufacturer may provide
warranty certification regarding use of parts); 208(a) (recordkeeping
and testing requirements for manufacturers of vehicle and engine
``parts or components'').
Thus, the question here is whether a trailer manufacturer or glider
kit manufacturer can be a manufacturer of a new motor vehicle and
thereby become subject to the certification and related requirements
for manufacturers, or must necessarily be classified as a manufacturer
of a motor vehicle part or component. EPA may reasonably classify
trailer manufacturers and glider kit manufacturers as motor vehicle
manufacturers.
Section 216(1) defines a ``manufacturer'' as ``any person engaged
in the manufacturing or assembling of new motor vehicles, new motor
vehicle engines, new nonroad vehicles or new nonroad engines, or
importing such vehicles or engines for resale, or who acts for and is
under the control of any such person in connection with the
distribution of new motor vehicles, new motor vehicle engines, new
nonroad vehicles or new nonroad engines, but shall not include any
dealer with respect to new motor vehicles, new motor vehicle engines,
new nonroad vehicles or new nonroad engines received by him in
commerce.''
It appears plain that this definition was not intended to restrict
the definition of ``manufacturer'' to a single person per vehicle. The
use of the conjunctive, specifying that a manufacturer is ``any person
engaged in the manufacturing or assembling of new motor vehicles . . .
or who acts for and is under the control of any such person
[[Page 73516]]
. . .'' (emphasis added) indicates that Congress anticipated that motor
vehicles could have more than one manufacturer, since in at least some
cases those will plainly be different people. The capacious reference
to ``any person engaged in the manufacturing of motor vehicles''
likewise allows the natural inference that it could apply to multiple
entities engaged in manufacturing.\87\
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\87\ See United States v. Gonzales, 520 U.S. 1, 5, (1997)
(``Read naturally the word `any' has an expansive meaning, that is,
`one or some indiscriminately of whatever kind'); New York v. EPA,
443 F.3d 880, 884-87 (D.C. Cir. 2006).
---------------------------------------------------------------------------
The provision also applies both to entities that manufacture and
entities that assemble, and does so in such a way as to encompass
multiple parties: Manufacturers ``or'' (rather than `and') assemblers
are included. Nor is there any obvious reason that only one person can
be engaged in vehicle manufacture or vehicle assembling.
Reading the Act to provide for multiple motor vehicle manufacturers
reasonably reflects industry realities, and achieves important goals of
the CAA. Since title II requirements are generally imposed on
``manufacturers'' it is important that the appropriate parties be
included within the definition of manufacturer--``any person engaged in
the manufacturing or assembling of new motor vehicles.'' Indeed, as set
out in Chapter 1 of the RIA, most heavy duty vehicles are manufactured
or assembled by multiple entities; see also Comments of Daimler
(October 1, 2015) p. 103.\88\ One entity produces a chassis; a
different entity manufactures the engine; specialized components (e.g.
garbage compactors, cement mixers) are produced by still different
entities. For tractor-trailers, one person manufactures the tractor,
another the trailer, a third the engine, and another typically
assembles the trailer to the tractor. Installation of various vehicle
components occurs at different and varied points and by different
entities, depending on ultimate desired configurations. See, e.g.
Comments of Navistar (October 1, 2015), pp. 12-13. The heavy duty
sector thus differs markedly from the light duty sector (and from
manufacturing of light duty pickups and vans), where a single company
designs the vehicle and engine (and many of the parts), and does all
assembling of components into the finished motor vehicle.
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\88\ ``The EPA should understand that vehicle manufacturing is a
multi-stage process (regardless of the technologies on the vehicles)
and that each stage of manufacturer has the incentive to properly
complete manufacturing . . . [T]he EPA should continue the
longstanding industry practice of allowing primary manufacturers to
pass incomplete vehicles with incomplete vehicle documents to
secondary manufacturers who complete the installation.''
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(ii) Controls on Manufacturers of Trailers
It is reasonable to view the trailer manufacturer as ``engaged in''
(section 216(1)) the manufacturing or assembling of the tractor-
trailer. The trailer manufacturer designs, builds, and assembles a
complete and finished portion of the tractor-trailer. All components of
the trailer--the tires, axles, flat bed, outsider cover, aerodynamics--
are within its control and are part of its assembling process. The
trailer manufacturer sets the design specifications that affect the GHG
emissions attributable to pulling the trailer. It commences all work on
the trailer, and when that work is complete, nothing more is to be
done. The trailer is a finished product. With respect to the trailer,
the trailer manufacturer is analogous to the manufacturer of the light
duty vehicle, specifying, controlling, and assembling all aspects of
the product from inception to completion. GHG emissions attributable to
the trailer are a substantial portion of the total GHG emissions from
the tractor-trailer.\89\ Moreover, the trailer manufacturer is not
analogous to the manufacturer of a vehicle part or component, like a
tire manufacturer, or to the manufacturer of a side skirt. The trailer
is a significant, integral part of the finished motor vehicle, and is
essential for the tractor-trailer to carry out its commercial purpose.
See 80 FR 40170. Although it is true that another person may ultimately
hitch the trailer to a tractor (which might be viewed as completing
assembly of the tractor-trailer), as noted above, EPA does not believe
that the fact that one person might qualify as a manufacturer, due to
``assembling'' the motor vehicle, precludes another person from
qualifying as a manufacturer, due to ``manufacturing'' the motor
vehicle. Given that section 216(1) does not restrict motor vehicle
manufacturers to a single entity, it appears to be consistent with the
facts and the Act to consider trailer manufacturers as persons engaged
in the manufacture of a motor vehicle.
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\89\ The relative contribution of trailer controls depends on
the types of tractors and trailers, as well as the tier of standards
applicable; however, it can be approximately one-third of the total
reduction achievable for the tractor-trailer.
---------------------------------------------------------------------------
This interpretation of section 216(1) is also reasonable in light
of the various provisions noted above relating to implementation of the
emissions standards--certification under section 206, prohibitions on
entry into commerce under section 203, warranty and recall under
section 207, and recordkeeping/reporting under section 208. All of
these provisions are naturally applied to the entity responsible for
manufacturing the trailer, which manufacturer is likewise responsible
for its GHG emissions.
TTMA maintains that if a tractor-trailer is a motor vehicle, then
only the entity connecting the trailer to the tractor could be subject
to regulation.\90\ This is not a necessary interpretation of section
216(1), as explained above. TTMA does not discuss that provision, but
notes that other provisions refer to ``a'' manufacturer (or, in one
instance, ``the'' manufacturer), and maintains that this shows that
only a single entity can be a manufacturer. See TTMA Comment pp. 4-5,
citing to sections 206(a)(1), 206(b), 207, and 203(a). This reading is
not compelled by the statutory text. First, the term ``manufacturer''
in all of these provisions necessarily reflects the underlying
definition in section 216(1), and therefore is not limited to a single
entity, as just discussed. Second, the interpretation makes no
practical sense. An end assembler of a tractor-trailer is not in a
position to certify and warrant performance of the trailer, given that
the end-assembler has no control over how trailers are designed,
constructed, or even which trailers are attached to the tractor. It
makes little sense for the entity least able to control the outcome to
be responsible for that outcome. The EPA doubts that Congress compelled
such an ungainly implementation mechanism, especially given that it is
well known that vehicle manufacture responsibility in the heavy duty
vehicle sector is divided, and given further that title II includes
requirements for EPA to promulgate emission standards for portions of
vehicles.
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\90\ Consequently, the essential issue here is not whether EPA
can issue and implement emission standards for trailers, but at what
point in the implementation process those standards apply.
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(iii) Controls on Manufacturers of Glider Kits
Application of these same principles indicate that a glider kit
manufacturer is a manufacturer of a motor vehicle and, as an entity
responsible for assuring that glider vehicles meet the Phase 2 vehicle
emission standards, can be a party in the certification process as
either the certificate holder or the entity which provides essential
test information to the glider vehicle manufacturer. As noted above,
glider kits include the entire tractor chassis, cab, tires, body, and
brakes. Glider kit manufacturers thus control critical elements of the
[[Page 73517]]
ultimate vehicle's greenhouse gas emissions, in particular, all
aerodynamic features and all emissions related to steer tire type.
Glider kit manufacturers would therefore be the entity generating
critical GEM inputs--at the least, those for aerodynamics and tires.
Glider kit manufacturers also often know the final configuration of the
glider vehicle, i.e. the type of engine and transmission which the
final assembler will add to the glider kit.\91\ This is because the
typical glider kit contains all necessary wiring, and it is necessary,
in turn, for the glider kit manufacturer to know the end configuration
in order to wire the kit properly. Thus, a manufacturer of a glider kit
can reasonably be viewed as a manufacturer of a motor vehicle under the
same logic as above: There can be multiple manufacturers of a motor
vehicle; the glider kit manufacturer designs, builds, and assembles a
substantial, complete and finished portion of the motor vehicle; and
that portion contributes substantially to the GHG emissions from the
ultimate glider vehicle. A glider kit is not a vehicle part; rather, it
is an assembled truck with a few components missing.
---------------------------------------------------------------------------
\91\ PACCAR indicated in its comments that manufacturers of
glider kits may not know all details of final assembly. Provisions
on delegated assembly, shipment of incomplete vehicles to secondary
manufacturers, and assembly instructions for secondary vehicle
manufacturers allow manufacturers of glider kits and glider vehicles
to apportion responsibilities, as appropriate, including
responsibility as to which entity shall be the certificate holder.
See 40 CFR 1037.130, 1037.621, and 1037.622. Our point here is that
both of these entities are manufacturers of the glider motor vehicle
and therefore that both are within the Act's requirements for
certification and testing.
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EPA rules have long provided provisions establishing
responsibilities where there are multiple manufacturers of motor
vehicles. See 40 CFR 1037.620 (responsibilities for multiple
manufacturers), 40 CFR 1037.621 (delegated assembly), and 40 CFR
1037.622 (shipment of incomplete vehicles to secondary vehicle
manufacturers). These provisions, in essence, allow manufacturers to
determine among themselves as to which should be the certificate
holder, and then assign respective responsibilities depending on that
decision. The end result is that incomplete vehicles cannot be
introduced into commerce without one of the manufacturers being the
certificate holder.
Under the Phase 1 rules, glider kits are considered to be
incomplete vehicles which may be introduced into commerce to a
secondary manufacturer for final assembly. See 40 CFR 1037.622(b)(1)(i)
and 1037.801 (definition of ``vehicle'' and ``incomplete vehicle'') of
the Phase 1 regulations (76 FR 57421). Note that 40 CFR
1037.622(b)(1)(i) was originally codified as 40 CFR 1037.620(b)(1)(i).
EPA is expanding somewhat on these provisions, but in essence, as under
Phase 1, glider kit and glider vehicle manufacturers could operate
under delegated assembly provisions whereby the glider kit manufacturer
would be the certificate holder. See 40 CFR 1037.621 of the final
regulations. Glider kit manufacturers would also continue to be able to
ship uncertified kits to secondary manufacturers, and the secondary
manufacturer must assemble the vehicle into certifiable condition. 40
CFR 1037.622.\92\
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\92\ Under this provision in the Phase 2 regulations, the glider
kit manufacturer would still have some responsibility to ensure that
products they introduce into U.S. commerce will conform with the
regulations when delivered to the ultimate purchasers.
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(d) Additional Authorities Supporting EPA's Actions
Even if, against our view, trailers and glider kits are not
considered to be ``motor vehicles,'' and the entities engaged in
assembling trailers and glider kits are not considered to be
manufacturers of motor vehicles, the Clean Air Act still provides
authority for the testing requirements adopted here. Section 208 (a) of
the Act authorizes EPA to require ``every manufacturer of new motor
vehicle or engine parts or components'' to ``perform tests where such
testing is not otherwise reasonably available.'' This testing can be
required to ``provide information the Administrator may reasonably
require to determine whether the manufacturer . . . has acted or is
acting in compliance with this part,'' which includes showing whether
or not the parts manufacturer is engaged in conduct which can cause a
prohibited act. Testing would be required to show that the trailer will
conform to the vehicle emission standards. In addition, testing for
trailer manufacturers would be necessary here to show that the trailer
manufacturer is not causing a violation of the combined tractor-trailer
GHG emission standard either by manufacturing a trailer which fails to
comply with the trailer emission standards, or by furnishing a trailer
to the entity assembling tractor-trailers inconsistent with tractor-
trailer certified condition. Testing for glider kit manufacturers is
necessary to prevent a glider kit manufacturer furnishing a glider kit
inconsistent with the tractor's certified condition. In this regard, we
note that section 203 (a)(1) of the Act not only prohibits certain
acts, but also prohibits ``the causing'' of those acts. Furnishing a
trailer not meeting the trailer standard would cause a violation of
that standard, and the trailer manufacturer would be liable under
section 203 (a)(1) for causing the prohibited act to occur. Similarly,
a glider kit supplied in a condition inconsistent with the tractor
standard would cause the manufacturer of the glider vehicle to violate
the GHG emission standard, so the glider kit manufacturer would be
similarly liable under section 203 (a)(1) for causing that prohibited
act to occur.
In addition, section 203 (a)(3)(B) prohibits use of `defeat
devices'--which include ``any part or component intended for use with,
or as part of, any motor vehicle . . . where a principal effect of the
part or component is to . . . defeat . . . any . . . element of design
installed . . . in a motor vehicle'' otherwise in compliance with
emission standards. Manufacturing or installing a trailer not meeting
the trailer emission standard could thus be a defeat device causing a
violation of the emission standard. Similarly, a glider kit
manufacturer furnishing a glider kit in a configuration that would not
meet the tractor standard when the specified engine, transmission, and
axle are installed would likewise cause a violation of the tractor
emission standard. For example, providing a tractor with a coefficient
of drag or tire rolling resistance level inconsistent with tractor
certified condition would be a violation of the Act because it would
cause the glider vehicle assembler to introduce into commerce a new
tractor that is not covered by a valid certificate of conformity.
Daimler argued in its comments that a glider kit would not be a defeat
device because glider vehicles use older engines which are more fuel
efficient since they are not meeting the more rigorous standards for
criteria pollutant emissions. (Daimler Truck Comment, April 1, 2016, p.
5). However, the glider kit would be a defeat device with respect to
the tractor vehicle standard, not the separate engine standard. A non-
conforming glider kit would adversely affect compliance with the
vehicle standard, as just explained. Furthermore, as explained in RTC
Section 14.2, Daimler is incorrect that glider vehicles are more fuel
efficient than Phase 1 2017 and later vehicles, much less Phase 2
vehicles.
In the memorandum accompanying the Notice of Data Availability, EPA
solicited comment on adopting additional regulations based on these
principles. EPA has decided not to adopt those provisions, but again
notes
[[Page 73518]]
that the authorities in CAA sections 208 and 203 support the actions
EPA is taking here with respect to trailer and glider kit testing.
(e) Standards for Glider Vehicles and Lead Time for Those Standards
At proposal, EPA indicated that engines used in glider vehicles are
to be certified to standards for the model year in which these vehicles
are assembled. 80 FR 40528. This action is well within the agency's
legal authority. As noted above, the Act's definition of ``new motor
vehicle engine,'' includes any ``engine in a new motor vehicle''
without regard to whether or not the engine was previously used. Given
the Act's purpose of controlling emissions of air pollutants from motor
vehicle engines, with special concern for pollutant emissions from
heavy-duty engines (see, e.g., section 202(a)(3)(A) and (B)), it is
reasonable to require engines placed in newly-assembled vehicles to
meet the same standards as all other engines in new motor vehicles. Put
another way, it is both consistent with the plain language of the Act
and reasonable and equitable for the engines in ``new trucks'' (see
Section I.E.(1)(a) above) to meet the emission standards for all other
engines installed in new trucks.
Daimler challenged this aspect of EPA's proposal, maintaining that
it amounted to regulation of vehicle rebuilding, which (according to
the commenter) is beyond EPA's authority. Comments of Daimler, p. 123;
Comments of Daimler Trucks (April 1, 2016) p. 3. This comment is
misplaced. The EPA has authority to regulate emissions of pollutants
from engines installed in new motor vehicles. As explained in
subsection (a) above, glider vehicles are new motor vehicles. As also
explained above, the Act's definition of ``new motor vehicle engine''
includes any ``engine in a new motor vehicle'' without regard to
whether or not the engine was previously used. CAA section 216(3).
Consequently, a previously used engine installed in a glider vehicle is
within EPA's multiple authorities. See CAA sections 202(a)(1) (GHGs),
202(a)(3)(A) and (B)(ii) (hydrocarbon, CO, PM and NOX from
heavy-duty vehicles or engines), and 202(a)(3)(D) (pollutants from
rebuilt heavy duty engines).\93\
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\93\ Comments from, e.g. Mondial and MEMA made clear that all of
the donor engines installed in glider vehicles are rebuilt. See also
http://www.truckinginfo.com/article/story/2013/04/the-return-of-the-glider.aspx (``1999 to 2002-model diesels were known for
reliability, longevity and good fuel mileage. Fitzgerald favors
Detroit's 12.7-liter Series 60 from that era, but also installs pre-
EGR 14-liter Cummins and 15-liter Caterpillar diesels. All are
rebuilt. . . .'').
---------------------------------------------------------------------------
As explained in more detail in Section XIII.B, the final rule
requires that as of January 1, 2017, glider kit and glider vehicle
production involving engines not meeting criteria pollutant standards
corresponding to the year of glider vehicle assembly be allowed at the
highest annual production for any year from 2010 to 2014. See section
1037.150(t)(3). (Certain exceptions to this are explained in Section
XIII.B.) The rule further requires that as of January 1, 2018, engines
in glider vehicles meet criteria pollutant standards and GHG standards
corresponding to the year of the glider vehicle assembly, but allowing
certain small businesses to introduce into commerce vehicles with
engines meeting criteria pollutant standards corresponding to the year
of the engine for up to 300 vehicles per year, or up to the highest
annual production volume for calendar years 2010 to 2014, whichever is
less. Section 1037.150(t)(1)(ii) (again subject to various exceptions
explained in Section XIII.B). Glider vehicles using these exempted
engines will not be subject to the Phase 1 GHG vehicle standards, but
will be subject to the Phase 2 vehicle standards beginning with MY
2021. As explained in Section XIII.B, there are compelling
environmental reasons for taking these actions in this time frame.
With regard to the issue of lead time, EPA indicated at proposal
that the agency has long since justified the criteria pollutant
standards for engines installed in glider kits. 80 FR 40528. EPA
further proposed that engines installed in glider vehicles meet the
emission standard for the year of glider vehicle assembly, as of
January 1, 2018 and solicited comment on an earlier effective date. Id.
at 40529. The agency noted that CAA section 202(a)(3)(D) \94\ requires
that standards for rebuilt heavy-duty engines take effect ``after a
period . . . necessary to permit the development and application of the
requisite control measures.'' Here, no time is needed to develop and
apply requisite control measures for criteria pollutants because
compliant engines are immediately available. In fact, manufacturers of
compliant engines, and dealers of trucks containing those compliant
engines, commented that they are disadvantaged by manufacturing more
costly compliant engines while glider vehicles avoid using those
engines. Not only are compliant engines immediately available, but (as
commenters warned) there can be risk of massive pre-buys. Moreover, EPA
does not envision that glider manufacturers will actually modify the
older engines to meet the applicable standards. Rather, they will
either choose from the many compliant engines available today, or they
will seek to qualify under other flexibilities provided in the final
rule. See Section XIII.B. Given that compliant engines are immediately
available, the flexibilities provided in the final rule for continued
use of donor engines for traditional glider vehicle functions and by
small businesses, and the need to expeditiously prevent further
perpetuation of use of heavily polluting engines, EPA sees a need to
begin constraining this practice on January 1, 2017. However, the final
rule is merely capping glider production using higher-polluting engines
in 2017 at 2010-2014 production levels, which would allow for the
production of thousands of glider vehicles using these higher polluting
engines, and unlimited production of glider vehicles using less
polluting engines.
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\94\ The engine rebuilding authority of section 202(a)(3)(D)
includes removal of an engine from the donor vehicle. See 40 CFR
86.004-40 and 62 FR 54702 (Oct. 21, 1997). EPA interprets this
language as including installation of the removed engine into a
glider kit, thereby assembling a glider vehicle.
---------------------------------------------------------------------------
Various commenters, however, argued that the EPA must provide four
years lead-time and three-year stability pursuant to section
202(a)(3)(C) of the Act, which applies to regulations for criteria
pollutant emissions from heavy duty vehicles or engines. For criteria
pollutant standards, CAA section 202(a)(3)(C) establishes lead time and
stability requirements for ``[a]ny standard promulgated or revised
under this paragraph and applicable to classes or categories of heavy
duty vehicles or engines.'' In this rule, EPA is generally requiring
large manufacturers of glider vehicles to use engines that meet the
standards for the model year in which a vehicle is manufactured. EPA is
not promulgating new criteria pollutant standards. The NOX
and PM standards that apply to heavy duty engines were promulgated in
2001.
We are not amending these provisions or promulgating new criteria
pollutant standards for heavy duty engines here. EPA interprets the
phrase ``classes or categories of heavy duty vehicles or engines'' in
CAA section 202(a)(3)(C) to refer to categories of vehicles established
according to features such as their weight, functional type, (e.g.
tractor, vocational vehicle, or pickup truck) or engine cycle (spark-
ignition or compression-ignition), or weight class of the vehicle into
which an engine is installed (LHD, MHD, or HHD). EPA has established
several different categories
[[Page 73519]]
of heavy duty vehicles (distinguished by gross vehicle weight, engine-
cycle, and other criteria related to the vehicles' intended purpose)
and is establishing in this rule GHG standards applicable to each
category.\95\ By contrast, a ``glider vehicle'' is defined not by its
weight or function but by its method of manufacture. A Class 8 tractor
glider vehicle serves exactly the same function and market as a Class 8
tractor manufactured by another manufacturer. Similarly, rebuilt
engines installed in glider vehicles (i.e. donor engines) are not
distinguished by engine cycle, but rather serve the same function and
market as any other HHD or MHD engine. Thus, EPA considers ``glider
vehicles'' to be a description of a method of manufacturing new motor
vehicles, not a description of a separate ``class or category'' of
heavy duty vehicles or engines. Consequently, EPA is not adopting new
standards for a class or category of heavy duty engines within the
meaning of section 202(a)(3)(C) of the Act.
---------------------------------------------------------------------------
\95\ Note, however, the Phase 2 GHG standards for tractors and
vocational vehicles do not apply until MY 2021.
---------------------------------------------------------------------------
EPA believes this approach is most consistent with the statutory
language and the goals of the Clean Air Act. The date of promulgation
of the criteria pollutant standards was 2001. There has been plenty of
lead time for the criteria pollutant standards and as a result,
manufacturers of glider vehicles have many options for compliant
engines that are available on the market today--just as manufacturers
of other new heavy-duty vehicles do. We are even providing additional
compliance flexibilities to glider manufacturers in recognition of the
historic practice of salvaging a small number of engines from vehicles
involved in crashes. See Section XIII.B. We do not believe that
Congress intended to allow changes in how motor vehicles are
manufactured to be a means of avoiding existing, applicable engine
standards. Obviously, any industry attempts to avoid or circumvent
standards will not become apparent until the standards begin to apply.
The commenters' interpretation would effectively preclude EPA from
curbing many types of avoidance, however dangerous, until at least four
years from detection.
As to Daimler's further argument that the lead time provisions in
section 202(3)(C) not only apply but also must trump those specifically
applicable to heavy duty engine rebuilding, the usual rule of
construction is that the more specific provision controls. See, e.g.
HCSC-Laundry v. U.S., 450 U.S.1, 6 (1981). Daimler's further argument
that section 202(a)(3)(C) lead time provisions also apply to engine
rebuilding because those provisions fall within the same paragraph
would render the separate lead time provisions for engine rebuilding a
virtual nullity. The sense of the provision is that Congress intended
there to be independent lead time consideration for the distinct
practice of engine rebuilding. In any case, as just explained, it is
EPA's view that section 202(a)(3)(C) does not apply here.
(2) NHTSA Authority
The Energy Policy and Conservation Act (EPCA) of 1975 mandates a
regulatory program for motor vehicle fuel economy to meet the various
facets of the need to conserve energy. In December 2007, Congress
enacted the Energy Independence and Security Act (EISA), amending EPCA
to require, among other things, the creation of a medium- and heavy-
duty fuel efficiency program for the first time.
Statutory authority for the fuel consumption standards in this
final rule is found in EISA section 103, 49 U.S.C. 32902(k). This
section authorizes a fuel efficiency improvement program, designed to
achieve the maximum feasible improvement to be created for commercial
medium- and heavy-duty on-highway vehicles and work trucks, to include
appropriate test methods, measurement metrics, standards, and
compliance and enforcement protocols that are appropriate, cost-
effective and technologically feasible.
NHTSA has 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 rule continues to fulfill the requirements of
section 103 of EISA, which instructs NHTSA to create a fuel efficiency
improvement program for ``commercial medium- and heavy-duty on-highway
vehicles and work trucks'' 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. NHTSA has broad discretion to balance the statutory factors
in section 103 in developing fuel consumption standards to achieve the
maximum feasible improvement.
As discussed in the Phase 1 final rule, NHTSA has determined that
the five year statutory limit on average fuel economy standards that
applies to passengers and light trucks is not applicable to the HD
vehicle and engine standards. As a result, the Phase 1 HD engine and
vehicle standards remain in effect indefinitely at their 2018 or 2019
MY levels until amended by a future rulemaking action. As was
contemplated in that rule, NHTSA is finalizing a Phase 2 rulemaking
action. Therefore, the Phase 1 standards will not remain in effect at
their 2018 or 2019 MY levels indefinitely; they will remain in effect
until the MY Phase 2 standards begin. In accordance with section 103 of
EISA, NHTSA will ensure that not less than four full MYs of regulatory
lead-time and three full MYs of regulatory stability are provided for
in the Phase 2 standards.
With respect to the proposal, many stakeholders opined in their
comments as to NHTSA's legal authority to issue the Phase 2 medium- and
heavy-duty standards (Phase 2 standards), in whole or in part. NHTSA
addresses these comments in the following discussion.
Allison Transmission, Inc. (Allison) questioned NHTSA's authority
to issue the Phase 2 Standards. Allison stated that the Energy
Independence and Security Act of 2007 (EISA) \96\ directs NHTSA to
undertake ``a rulemaking proceeding,'' (emphasis added) predicated on a
study by the National Academy of Sciences (NAS). Allison and the Truck
Trailer Manufacturers Association (TTMA) asserted that because NAS has
published a study on medium- and heavy duty vehicles and NHTSA
promulgated the Phase 1 medium- and heavy-duty vehicle standards (Phase
1 standards), NAS and NHTSA have fulfilled their statutory duties under
EISA. Thus, Allison stated, NHTSA has no authority to issue standards
beyond the Phase 1 standards.
---------------------------------------------------------------------------
\96\ Public Law 110-140, 121 Stat. 1492. (December 19, 2007).
---------------------------------------------------------------------------
NHTSA maintains that EISA allows the agency to promulgate medium-
and heavy duty fuel efficiency standards beyond the Phase 1 standards.
EISA states that NHTSA: \97\
---------------------------------------------------------------------------
\97\ By delegation at 49 CFR 1.95(a). For purposes of this NPRM,
grants of authority from EISA to the Secretary of Transportation
regarding fuel efficiency will be referred to as grants of authority
to NHTSA, as NHTSA has been delegated the authority to implement
these programs.
by regulation, shall determine in a rulemaking proceeding how to
implement a commercial medium- and heavy-duty on-highway vehicle and
work truck fuel
[[Page 73520]]
efficiency program designed to achieve the maximum feasible
improvement, and shall adopt and implement appropriate test methods,
measurement metrics, fuel economy standards, and compliance and
enforcement protocols . . . for commercial medium- and heavy-duty
on-highway vehicles and work trucks.\98\
---------------------------------------------------------------------------
\98\ Public Law 110-140, 121 Stat. 1492, Section 108. Codified
at 49 U.S.C. 32902(k)(2).
Allison equates the process by which Congress specified NHTSA
promulgate standards--a rulemaking proceeding--to mean a limitation or
constraint on NHTSA's ability to create, amend, or update the medium-
and heavy duty fuel efficiency program. NHTSA believes the charge in 49
U.S.C. 32902(k)(2) discusses ``a rulemaking proceeding'' only insofar
as the statute specifies the process by which NHTSA would create a
medium- and heavy-duty on-highway vehicle and work truck fuel
efficiency improvement program and its associated standards.
Allison and TTMA commented that EISA only refers to an initial NAS
study, meaning EISA only specified that NHTSA issue one set of
standards based on that study. As NHTSA stated in the NPRM, EISA
requires NAS to issue updates to the initial report every five years
through 2025.\99\ With that in mind, NAS issued an interim version of
its first update to inform the Phase 2 NPRM. EISA's requirement that
NAS update its initial report, which examines existing and potential
fuel efficiency technologies that can practically be integrated into
medium- and heavy-duty vehicles, is consistent with the conclusion that
EISA intended the medium- and heavy-duty standards to function as part
of an ongoing program \100\ and not a single rulemaking.
---------------------------------------------------------------------------
\99\ 80 FR 40512 (July 13, 2015).
\100\ ``. . . 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 program
designed to achieve the maximum feasible improvement . . .'' 49
U.S.C. 42902(k)(2).
---------------------------------------------------------------------------
Allison also noted that the language in EISA discussing lead time
and stability refers to a single medium- and heavy-duty on-highway
vehicle and work truck fuel economy standard.\101\ NHTSA believes the
language highlighted by Allison serves the purpose of noting that each
medium- and heavy-duty segment standard included in its program shall
have the requisite amount of lead-time and stability. As discussed in
49 U.S.C. 32902(k)(2), ``[t]he Secretary may prescribe separate
standards for different classes of vehicles . . .'' Since NHTSA has
elected to set standards for particular classes of vehicles, this
language ensures each particular standard shall have the appropriate
lead-time and stability required by EISA.
---------------------------------------------------------------------------
\101\ 49 U.S.C. 32902(k)(3) states that, ``The commercial
medium- and heavy-duty on-highway vehicle and work truck fuel
economy standard adopted pursuant to this subsection shall provide
not less than--(A) 4 full model years of regulatory lead-time; and
(B) 3 full model years of regulatory stability.''
---------------------------------------------------------------------------
TTMA asserted that NHTSA has no more than 24 months from the
completion of the NAS study to issue regulations related to the medium-
and heavy-duty program and therefore regulations issued after 2013
``lack congressional authorization.'' This argument significantly
misinterprets the Congressional purpose of this provision. Section
32902(k)(2) requires that, 24 months after the completion of the NAS
study, NHTSA begin implementing through a rulemaking proceeding a
commercial medium- and heavy-duty on-highway vehicle and work truck
fuel efficiency improvement program. Congress therefore authorized
NHTSA to implement through rulemaking a ``program,'' which the
dictionary defines as ``a plan of things that are done in order to
achieve a specific result.'' \102\ Contrary to TTMA's assertion,
Congress did not limit NHTSA to the establishment of one set of
regulations, nor did it in any way limit NHTSA's ability to update and
revise this program. The purpose of the 24 month period was simply to
ensure that NHTSA exercised this authority expeditiously after the NAS
study, which NHTSA accomplished by implementing the first phase of its
fuel efficiency program in 2011.\103\ Today's rulemaking merely
continues this program and clearly comports with the statutory language
in 49 U.S.C. 32902(k). Further, the specific result sought by Congress
in establishing the medium- and heavy-duty fuel efficiency program was
a program focused on continuing fuel efficiency improvements.
Specifically, Congress emphasized that the fuel efficiency program
created by NHTSA be ``designed to achieve the maximum feasible
improvement,'' allowing NHTSA to ensure the regulations implemented
throughout the program encourage regulated entities to achieve the
maximum feasible improvements. Congress did not limit, restrict, or
otherwise suggest that the phrase ``designed to achieve the maximum
feasible improvement'' be confined to the issuance of one set of
standards. NHTSA actions are, therefore, clearly consistent with the
authority conferred upon it in 49 U.S.C. 32902(k).
---------------------------------------------------------------------------
\102\ ``Program.'' Merriam-Webster (2016 http://www.merriam-webster.com/dictionary/program (last accessed July 19, 2016).
\103\ 76 FR 57016 (September 15, 2011).
---------------------------------------------------------------------------
POP Diesel stated that the word ``fuel'' has not been defined by
Congress, and therefore NHTSA should use its authority to define the
term ``fuel'' as ``fossil fuel,'' allowing the agencies to assess fuel
efficiency based on the carbon content of the fuels used in an engine
or vehicle. Congress has already defined the term ``fuel'' in 49 U.S.C.
32901(a)(10) as gasoline, diesel oil, or other liquid or gaseous fuel
that the Secretary decides to include. As Congress has already spoken
to the definition of fuel, it would be inappropriate for the agency to
redefine ``fuel'' as ``fossil fuel.''
Additionally, POP Diesel asserted that NHTSA's metric for measuring
fuel efficiency is contrary to the mandate in EISA. Specifically, POP
Diesel stated that many dictionaries define ``efficiency'' as a ratio
of work performed to the amount of energy used, and NHTSA's load
specific fuel consumption metric runs afoul of the plain meaning of
statute the Phase 2 program implements. POP Diesel noted that
Congressional debate surrounding what is now codified at 49 U.S.C.
32902(k)(2) included a discussion that envisioned NHTSA and EPA having
separate regulations, despite having overlapping jurisdiction.
NHTSA continues to believe its use of load specific fuel
consumption is an appropriate metric for assessing fuel efficiency as
mandated by Congress. 49 U.S.C. 32902(k)(2) states, as POP Diesel
noted, that NHTSA shall develop a medium- and heavy-duty fuel
efficiency program. The section further states that NHTSA ``. . . shall
adopt and implement appropriate test methods [and] measurement metrics
. . . for commercial medium- and heavy-duty on-highway vehicles and
work trucks.'' In the Phase 1 rulemaking, NHTSA, aided by the National
Academies of Sciences (NAS) report, assessed potential metrics for
evaluating fuel efficiency. NHTSA found that fuel economy would not be
an appropriate metric for medium- and heavy-duty vehicles. Instead,
NHTSA chose a metric that considers the amount of fuel consumed when
moving a ton of freight (i.e., performing work).\104\ This metric,
delegated by Congress to NHTSA to formulate, is not precluded by the
text of the statute. It is a reasonable way by which to measure fuel
efficiency for a program designed to reduce fuel consumption.
---------------------------------------------------------------------------
\104\ See: 75 FR 74180 (November 30, 2010).
---------------------------------------------------------------------------
[[Page 73521]]
(a) NHTSA's Authority To Regulate Trailers
As contemplated in the Phase 1 proposed and final rules, the
agencies proposed standards for trailers in the Phase 2 rulemaking.
Because Phase 1 did not include standards for trailers, NHTSA did not
discuss its authority for regulating them in the proposed or final
rules; that authority is described here.
NHTSA is finalizing fuel efficiency standards applicable to heavy-
duty trailers as part of the Phase 2 program. NHTSA received several
comments on the proposal relating to the agency's statutory authority
to issue standards for trailers as part of the Phase 2 program. In
particular, TTMA commented that NHTSA does not have the authority to
regulate trailers as part of the medium- and heavy-duty standards. TTMA
took issue with NHTSA's use of the National Traffic and Motor Vehicle
Safety Act as an aid in defining an undefined term in EISA.
Additionally, TTMA stated that EISA's use of GVWR instead of gross
combination weight rating (GCWR) to define the vehicles subject to
these regulations was intended to exclude trailers from the regulation.
As stated in the proposal, EISA 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 . . . .''
\105\ EISA defines a commercial medium- and heavy-duty on-highway
vehicle to mean ``an on-highway vehicle with a GVWR of 10,000 lbs or
more.'' A ``work truck'' is defined as a vehicle between 8,500 and
10,000 lbs GVWR that is not an MDPV. These definitions do not
explicitly exclude trailers, in contrast to MDPVs. Because Congress did
not act to exclude trailers when defining these terms by GVWRs, despite
demonstrating the ability to exclude MDPVs, it is reasonable to
interpret the provision to include them.
---------------------------------------------------------------------------
\105\ 49 U.S.C. 42902(k)(2).
---------------------------------------------------------------------------
Both the tractor and the trailer are vehicles subject to regulation
by NHTSA in the Phase 2 program. Although EISA does not define the term
``vehicle,'' NHTSA's authority to regulate motor vehicles under its
organic statute, the Motor Vehicle Safety Act (``Safety Act''), does.
The Safety Act defines a motor vehicle as ``a vehicle driven or drawn
by mechanical power and manufactured primarily for use on public
streets, roads, and highways. . . .'' \106\ NHTSA clearly has authority
to regulate trailers under this Act as they are vehicles that are drawn
by mechanical power--in this instance, a tractor engine--and NHTSA has
exercised that authority numerous times.\107\ Given the absence of any
apparent contrary intent on the part of Congress in EISA, NHTSA
believes it is reasonable to interpret the term ``vehicle'' as used in
the EISA definitions to have a similar meaning that includes trailers.
---------------------------------------------------------------------------
\106\ 49 U.S.C. 30102(a)(6).
\107\ See, e.g., 49 CFR 571.106 (Standard No. 106; Brake hoses);
49 CFR 571.108 (Standard No. 108; Lamps, reflective devices, and
associated equipment); 49 CFR 571.121 (Standard No. 121; Air brake
systems); 49 CFR 571.223 (Standard No. 223; Rear impact guards).
---------------------------------------------------------------------------
Additionally, it is worth noting that the dictionary definition of
``vehicle'' is ``a machine used to transport goods or persons from one
location to another.'' \108\ A trailer is a machine designed for the
purpose of transporting goods. With these foregoing considerations in
mind, NHTSA interprets its authority to regulate commercial medium- and
heavy-duty on-highway vehicles, including trailers.
---------------------------------------------------------------------------
\108\ ``Vehicle.'' Merriam-Webster (2016). http://www.merriam-webster.com/dictionary/vehicle (last accessed May 20, 2016).
---------------------------------------------------------------------------
TTMA pointed to language in the Phase 1 NPRM where the agencies
stated that GCWR included the weight of a loaded trailer and the
vehicle itself. TTMA interprets this language to mean that standards
applicable to vehicles defined by GVWR must inherently exclude
trailers. The language TTMA cited is a clarification from a footnote in
an introductory section describing the heavy-duty trucking industry.
This statement was not a statement of NHTSA's legal authority over
medium- and heavy-duty vehicles. NHTSA continues to believe a trailer
is a vehicle under EISA if its GVWR fits within the definitions in 49
U.S.C. 32901(a), and is therefore subject to NHTSA's applicable fuel
efficiency regulations.
Finally, in a comment on the Notice of Data Availability, TTMA
stated that because NHTSA's statutory authority instructs the agency to
develop a fuel efficiency program for medium- and heavy-duty on-highway
vehicles, and trailers themselves do not consume fuel, trailers cannot
be regulated for fuel efficiency. The agency disagrees with this
assertion. A tractor-trailer is designed for the purpose of holding and
transporting goods. While heavy-duty trailers themselves do not consume
fuel, they are immobile and inoperative without a tractor providing
motive power. Inherently, trailers are designed to be pulled by a
tractor, which in turn affects the fuel efficiency of the tractor-
trailer as a whole. As previously discussed, both a tractor and trailer
are motor vehicles under NHTSA's authority. Therefore it is reasonable
to consider all of a tractor-trailer's parts--the engine, the cab-
chassis, and the trailer--as parts of a whole. As such they are all
parts of a vehicle, and are captured within the scope of NHTSA's
statutory authority. As EPA describes above, the tractor and trailer
are both incomplete without the other. Neither can fulfill the function
of the vehicle without the other. For this reason, and the other
reasons stated above, NHTSA interprets its authority to regulate
commercial medium- and heavy-duty on-highway vehicles, including
tractor-trailers, as encompassing both tractors and trailers.
(b) NHTSA's Authority To Regulate Recreational Vehicles
NHTSA did not regulate recreational vehicles as part of the Phase 1
medium- and heavy-duty fuel efficiency standards, although EPA did
regulate them as vocational vehicles for GHG emissions. In the Phase 1
NPRM, NHTSA interpreted ``commercial medium- and heavy duty on-road
vehicle'' to mean that recreational vehicles, such as motor homes, were
not to be included within the program because recreational vehicles are
not commercial. Following comments to the Phase 1 proposal, NHTSA
reevaluated its statutory authority and proposed that recreational
vehicles be included in the Phase 2 standards, and that early
compliance be allowed for manufacturers who want to certify during the
Phase 1 period.
The Recreational Vehicle Industry Association (RVIA) and Newell
Coach Corporation (Newell) asserted that NHTSA does not have the
authority to regulate recreational vehicles (RVs). RVIA and Newell
stated that NHTSA's authority under EISA is limited to commercial
medium- and heavy-duty vehicles and that RVs are not commercial. RVIA
pointed to the fact that EISA gives NHTSA fuel efficiency authority
over ``commercial medium- and heavy-duty vehicles'' and ``work
trucks,'' the latter of which is not prefaced with the word
``commercial.'' Because of this difference, RVIA argued that NHTSA is
ignoring a limitation on its authority--that is, that NHTSA only has
authority over medium- and heavy-duty vehicles that are commercial in
nature. RVIA stated that RVs are not used for commercial purposes, and
are therefore not subject to Phase 2.
NHTSA's authority to regulate medium- and heavy-duty vehicles under
EISA extends to ``commercial medium- and heavy-duty on-highway
vehicles''
[[Page 73522]]
and ``work truck[s].'' \109\ If terms in the statute are defined, NHTSA
must apply those definitions. Both terms highlighted by RVIA have been
defined in EISA, therefore, NHTSA will use their defined meanings.
``Work truck'' means a vehicle that is rated between 8,500 and 10,000
pounds GVWR and is not an MDPV.\110\ ``Commercial medium- and heavy-
duty on-road highway vehicle'' means an on-highway vehicle with a gross
vehicle weight rating (GVWR) of 10,000 pounds or more.\111\ Based on
the definitions in EISA, recreational vehicles would be regulated as
class 2b-8 vocational vehicles. Neither statutory definition requires
that those vehicles encompassed be commercial in nature, instead
dividing the medium- and heavy-duty segments based on weight. The
definitions of ``work truck'' and ``commercial medium- and heavy-duty
on-highway vehicles'' collectively encompass the on-highway motor
vehicles not covered in the light duty CAFE standards.
---------------------------------------------------------------------------
\109\ 49 U.S.C. 42902(k)(2).
\110\ 49 U.S.C. 42901(a)(19).
\111\ 49 U.S.C. 42901(a)(7).
---------------------------------------------------------------------------
RVIA further stated that NHTSA's current fuel efficiency
regulations are not consistent with EISA and do not purport to grant
NHTSA authority to regulate vehicles simply based on weight. NHTSA's
regulations at 49 CFR 523.6 define, by cross-reference the language in
49 U.S.C. 32901(a)(7) and (19), and consistent with the discussion
above, include recreational vehicles.
Finally, NHTSA notes that excluding recreational vehicles in Phase
2 could create illogical results, including treating similar vehicles
differently, as determinations over whether a given vehicle would be
covered by the program would be based upon either its intended or
actual use, rather than the actual characteristics of the vehicle.
Moreover, including recreational vehicles under NHTSA regulations
furthers the agencies' goal of one national program, as EPA regulations
will continue to regulate recreational vehicles. NHTSA will allow early
compliance for manufacturers that want to certify during the Phase 1
period.
F. Other Issues
In addition to establishing new Phase 2 standards, this document
addresses several other issues related to those standards. The agencies
are adopting some regulatory provisions related to the Phase 1 program,
as well as amendments related to other EPA and NHTSA regulations. These
other issues are summarized briefly here and discussed in greater
detail in later sections.
(1) Opportunities for Further Oxides of Nitrogen (NOX)
Reductions From Heavy-Duty On-Highway Engines and Vehicles
The EPA has the authority under section 202 of the Clean Air Act to
establish, and from time to time revise, emission standards for certain
air pollutants emitted from heavy-duty on-highway engines and vehicles.
The emission standards that EPA has developed for heavy-duty on-highway
engines have become progressively more stringent over the past 40
years, with the most recent NOX standards for new heavy-duty
on-highway engines fully phased in with the 2010 model year.
NOX emissions standards for heavy-duty on-highway engines
have contributed significantly to the overall reduction in the national
NOX emissions inventory. Nevertheless, a need for additional
NOX reductions remains, particularly in areas of the country
with elevated levels of air pollution. As discussed further below, in
response to EPA's responsibilities under the Clean Air Act, the
significant comments we received on this topic during the public
comment period, the recent publication by the California Air Resources
Board (CARB) of its May 2016 Mobile Source Strategy report and Proposed
2016 Strategy for the State implementation Plan \112\ and a recent
Petition for Rulemaking,\113\ EPA plans to further engage with
stakeholders after the publication of this Final Rule to discuss the
opportunities for developing more stringent federal standards to
further reduce the level of NOX emissions from heavy-duty
on-highway engines through a coordinated effort with CARB.
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\112\ See ``Mobile Source Strategy,'' May 16, 2016 from CARB.
Available at: http://www.arb.ca.gov/planning/sip/2016sip/2016mobsrc.htm and ``Proposed 2016 State Strategy for the State
Implementation Plan,'' May 17, 2016 from CARB. Available at http://www.arb.ca.gov/planning/sip/2016sip/2016sip.htm.
\113\ EPA received a Petition for Rulemaking to adopt new
NOX emission standards for on-road heavy-duty trucks and
engines on June 3, 2016 from the South Coast Air Quality Management
District, the Arizona Pima County Department of Environmental
Quality, the Bay Area Air Quality Management District, the
Connecticut Department of Energy and Environmental Protection
Agency, the Delaware Department of Energy and Environmental
Protection, the Nevada Washoe County Health District, the New
Hampshire Department of Environmental Services, the New York City
Department of Environmental Protection, the Akron Regional Air
Quality Management District of Akron, Ohio, the Washington State
Department of Ecology, and the Puget Sound Clean Air Agency.
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NOX is one of the major precursors of tropospheric ozone
(ozone), exposure to which is associated with a number of adverse
respiratory and cardiovascular effects, as described in Section
VIII.A.2 below. These effects are particularly pronounced among
children, the elderly, and among people with lung disease such as
asthma. NOX is also a major contributor to secondary
PM2.5 formation, and exposure to PM2.5 itself has
been linked to a number of adverse health effects (see Section
VIII.A.1), such as heart attacks and premature mortality. In addition,
NO2 exposure is linked to asthma exacerbation and possibly
to asthma development in children (see Section VIII.A.3). EPA has
already adopted many emission control programs that are expected to
reduce ambient ozone levels. However, the U.S. Energy Information
Administration's AEO 2015 predicts that vehicles miles travelled (VMT)
for heavy-duty trucks will increase in the coming years,\114\ and even
with the implementation of all current state and federal regulations,
some of the most populous counties in the United States are expected to
have ozone air quality that exceeds the National Ambient Air Quality
Standards (NAAQS) into the future. As of April 22, 2016, there were 44
ozone nonattainment areas for the 2008 ozone NAAQS composed of 216 full
or partial counties, with a population of more than 120 million. These
nonattainment areas are dispersed across the country, with counties in
the west, northeastern United States, Texas, and several Great Lakes
states. The geographic diversity of this problem necessitates action at
the national level. In California, the San Joaquin Valley and the South
Coast Air Basin are highly-populated areas classified as ``extreme
nonattainment'' for the 2008 8-hour ozone standard, with an attainment
demonstration deadline of 2031 (one year in advance of the actual 2032
attainment date). In addition, EPA lowered the level of the primary and
secondary NAAQS for the 8-hour standards from 75 ppb to 70 ppb in 2015
(2015 ozone NAAQS),\115\ with plans to finalize nonattainment
designations for the 2015 ozone NAAQS in October 2017. Further
NOX reductions would provide reductions in ambient ozone
levels, helping to prevent adverse health impacts associated with ozone
exposure and assisting states and local areas in attaining and
maintaining the applicable ozone NAAQS. Reductions in NOX
emissions would also improve air quality and provide
[[Page 73523]]
public health and welfare benefits throughout the country by (1)
reducing PM formed by reactions of NOX in the atmosphere;
(2) reducing concentrations of the criteria pollutant NO2;
(3) reducing nitrogen deposition to sensitive environments; and (4)
improving visibility.
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\114\ US Energy Information Administration. Annual Energy
Outlook 2015. April 2015. Page E-8. http://www.eia.gov/forecasts/aeo/pdf/0383(2015).pdf.
\115\ 80 FR 65292 (Oct. 26, 2015).
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In the past year, EPA has received requests from several state and
local air quality districts and other organizations asking that EPA
establish more stringent NOX standards for heavy-duty on-
highway engines to help reduce the public's exposure to air pollution.
In its comments, CARB estimated that heavy-duty on-highway vehicles
currently contribute about one-third of all NOX emissions in
California. In order to achieve the 2008 ozone NAAQS, California has
estimated that the state's South Coast Air Basin will need an 80
percent reduction in NOX emissions by 2031. California has
the unique ability among states to adopt its own separate new motor
engine and vehicle emission standards under section 209 of the CAA;
however, CARB commented that EPA action to establish a new federal low-
NOX standard for heavy-duty trucks is critical, since
California standards alone are not sufficient to demonstrate compliance
with either the 2008 ozone NAAQS or the 2015, even more stringent ozone
NAAQS. CARB has developed a comprehensive mobile source strategy which
for heavy-duty on-highway vehicles includes: Lowering the emissions
from the in-use fleet; establishing more stringent NOX
standards for new engines; and accelerating the deployment of zero and
near-zero emissions technology.\116\ In September of 2015, CARB
published a draft of this strategy, Mobile Source Strategy Discussion
Draft, after which CARB held a public workshop and provided opportunity
for public comment. On May 16, 2016, CARB issued a final Mobile Source
Strategy report.\117\ In this report, CARB provides a comprehensive
strategy plan for the future of mobile sources and goods movement in
the State of California for how mobile sources in California can meet
air quality and climate goals over the next fifteen years. Among the
many programs discussed are plans for a future on-highway heavy-duty
engine and vehicle NOX control regulatory program for new
products with implementation beginning in 2024. CARB states ``The need
for timely action by U.S. EPA to establish more stringent engine
performance standards in collaboration with California efforts is
essential. About 60 percent of total heavy-duty truck VMT in the South
Coast on any given day is accrued by trucks purchased outside of
California, and are exempt from California standards. U.S. EPA action
to establish a federal low-NOX standard for trucks is critical.'' CARB
lays out a time line for a California specific action for new highway
heavy-duty NOX standards with CARB action in 2017-2019 that
would lead to new standards that could begin with the model year 2023.
CARB also requests that the U.S. EPA work on a Federal rulemaking
action in the 2017-2019 time frame which could result in standards that
could begin with the model year 2024. The CARB Mobile Source Strategy
document also states ``Due to the preponderance of interstate
trucking's contribution to in-state VMT, federal action would be far
more effective at reducing in-state emissions than a California-only
standard. However, California is prepared to develop a California-only
standard, if needed, to meet federal attainment targets.'' CARB goes on
to state ``[C]ARB will begin development of new heavy-duty low
NOX emission standard in 2017 with Board action expected in
2019. ARB may also petition U.S. EPA in 2016 to establish new federal
heavy-duty engine emission standards . . . . If U.S. EPA begins the
regulatory development process for a new federal heavy-duty emission
standard by 2017, ARB will coordinate its regulatory development
efforts with the federal regulation.'' On May 17, 2016, CARB published
its ``Proposed 2016 State Strategy for the State Implementation Plan.''
\118\ This document contains CARB staff's proposed strategy to attain
the health-based federal air quality standards over the next fifteen
years. With respect to future on-highway heavy-duty NOX
standards, the proposed State Implementation Plan is fully consistent
with the information published by CARB in the Mobile Source Strategy
report. EPA intends to work with CARB to consider the development of a
new harmonized Federal and California program that would apply lower
NOX emissions standards at the national level to heavy-duty
on-highway engines and vehicles.
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\116\ To foster the development of the next generation of lower
NOX engines, in 2013, CARB adopted optional low-
NOX heavy-duty engine standards ranging from 0.10 down to
0.02 grams per brake horsepower-hour (g/bhp-hr). CARB also funded
over $1 million to a low-NOX engine research and
demonstration project at Southwest Research Institute (SwRI).
\117\ See ``Mobile Source Strategy,'' May 16, 2016 from CARB.
Available at: http://www.arb.ca.gov/planning/sip/2016sip/2016mobsrc.htm.
\118\ See ``Proposed 2016 State Strategy for the State
Implementation Plan,'' May 17, 2016 from CARB. Available at http://www.arb.ca.gov/planning/sip/2016sip/2016sip.htm.
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In addition to CARB, EPA received compelling letters and comments
from the National Association of Clean Air Agencies, the Northeast
States for Coordinated Air Use Management, the Ozone Transport
Commission, and the South Coast Air Quality Management District
explaining the critical and urgent need to reduce NOX
emissions that significantly contribute to ozone and fine particulate
air quality problems in their represented areas. The comments describe
the challenges many areas face in meeting both the 2008 and recently
strengthened 2015 ozone NAAQS. These organizations point to the
significant contribution of heavy-duty vehicles to NOX
emissions in their areas, and call upon EPA to begin a rulemaking to
require further NOX controls for the heavy-duty sector as
soon as possible. Commenters such as the American Lung Association,
Environmental Defense Fund, Union of Concerned Scientists, the
California Interfaith Power and Light, Coalition for Clean Air/
California Cleaner Freight Coalition, and the Moving Forward Network
similarly describe the air quality and public health need for
NOX reductions and request EPA to lower NOX
emissions standards for heavy-duty vehicles. Taken as a whole, the
numerous comments, the expected increase in heavy-duty truck VMT, and
the fact that ozone challenges will remain across the country
demonstrate the critical need for more stringent nationwide
NOX emissions standards. Such standards are vital to
improving air quality nationwide and reducing public health effects
associated with exposure to ozone and secondary PM2.5,
especially for vulnerable populations and in highly impacted regions.
On June 3, 2016, the EPA received a Petition for Rulemaking from
the South Coast Air Quality Management District (California), the Pima
County Department of Environmental Quality (Arizona), the Bay Area Air
Quality Management District (California), the Connecticut Department of
Energy and Environmental Protection Agency, the Delaware Department of
Energy and Environmental Protection, the Washoe County Health District
(Nevada), the New Hampshire Department of Environmental Services, the
New York City Department of Environmental Protection, the Akron
Regional Air Quality Management District (Ohio), the Washington State
Department of Ecology, and the Puget Sound Clean Air
[[Page 73524]]
Agency (Washington).119 120 In a June 15, 2016 letter to
EPA, the Commonwealth of Massachusetts also joined this petition. On
June 22, 2016, the San Joaquin Valley Air Pollution Control District
(California) also submitted a petition for rulemaking to EPA.\121\ In
these Petitions, the Petitioners request that EPA establish a new,
lower NOX emission standard for on-road heavy-duty engines.
The Petitioners request that EPA implement a new standard by January 1,
2022, and that EPA establish this new standard through a Final
Rulemaking issued by December 31, 2017. EPA is not formally responding
to this Petition in this Final Rule, but we will do so in a future
action. In the petitions, the Petitioners include a detailed discussion
of their views and underlying data regarding the need for large scale
reduction in NOX emissions from heavy-duty engines, why they
believe new standards can be achieved, and their legal views on EPA's
responsibilities under the Clean Air Act.
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\119\ http://4cleanair.org/sites/default/files/resources/HD_Ultra-Low-NOX_Petition_to_EPA-060316.pdf.
\120\ http://4cleanair.org/sites/default/files/resources/Petition_Attachments-Ultra-Low-NOX_Petition_to_EPA-060316_0.pdf.
\121\ http://www.valleyair.org/recent_news/Media_releases/2016/PR-District-Petitions-Federal-Government-06-22-16.pdf.
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Since the establishment of the current heavy-duty on-highway
standards in January of 2001,\122\ there has been continued progress in
emissions control technology. EPA and CARB are currently investing in
research to evaluate opportunities for further NOX
reductions from heavy-duty on-highway vehicles and engines. Programs
and research underway at CARB, as well as a significant body of work in
the technical literature, indicate that reducing NOX
emissions significantly below the current on-highway standard of 0.20
grams per brake horsepower-hour (g/bhp-hr) is potentially
feasible.123 124 Opportunities for additional NOX
reductions include reducing emissions over cold start operation as well
as low-speed, low-load off-cycle operation. Reductions are being
accomplished through the use of improved engine management, advanced
aftertreatment technologies (improvements in SCR catalyst design/
formulation), catalyst positioning, aftertreatment thermal management,
and heated diesel exhaust fluid dosing. At the same time, the effect of
these new technologies on cost and GHG emissions is being carefully
evaluated,\124\ since it is important that any future NOX
control technologies be considered in the context of the final Phase 2
GHG standards. During the Phase 2 program public comment period, EPA
received some comments stressing the need for careful evaluation of
emerging NOX control technologies and urging EPA to consider
the relationship between CO2 and NOX before
setting lower NOX standards (commenters include American
Trucking Association, Caterpillar, Daimler Trucks North America,
Navistar Inc., PACCAR Inc., Volvo Group, Truck and Engine Manufacturers
Association, Diesel Technology Forum, National Association of
Manufacturers, and National Automobile Dealers Association). EPA also
received comments pointing to advances in NOX emission
control technologies that would lower NOX without reducing
engine efficiency (commenters include Advanced Engine Systems
Institute, Clean Energy, Manufacturers of Emission Controls
Association, and Union of Concerned Scientists). EPA will continue to
evaluate both opportunities and challenges associated with lowering
NOX emissions from the current standards, and over the
coming months we intend to engage with many stakeholders as we develop
our response to the June 2016 Petitions for Rulemaking discussed above.
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\122\ 66 FR 5002 (January 18, 2001).
\123\ See CARB's September 2015 Draft Technology Assessment:
Lower NOX Heavy-Duty Diesel Engines, and Draft Technology
Assessment: Low Emission Natural Gas and Other Alternative Fuel
Heavy-Duty Engines.
\124\ http://www.arb.ca.gov/research/veh-emissions/low-nox/low-nox.htm, 4/26/16. This low NOX study is in the process of
selecting the emission reduction systems for final testing and it is
expected that this demonstration program will be complete by the end
of 2016.
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EPA believes the opportunity exists to develop, in close
coordination with CARB and other stakeholders, a new, harmonized
national NOX reduction strategy for heavy-duty on-highway
engines which could include the following:
Substantially lower NOX emission standards;
Improvements to emissions warranties;
Consideration of longer useful life, reflecting actual in-
use activity;
Consideration of rebuilding/remanufacturing practices;
Updated certification and in-use testing protocols;
Incentives to encourage the transition to next-generation
cleaner technologies as soon as possible;
Improvements to test procedures and test cycles to ensure
emission reductions occur in the real-world, not only over the
applicable certification test cycles.
Based on the air quality need, the requests described above, the
continued progress in emissions control technology, and the June 2016
petitions for rulemaking, EPA plans to engage with a range of
stakeholders to discuss the opportunities for developing more stringent
federal standards to further reduce the level of NOX
emissions from heavy-duty on-highway engines, after the publication of
this Final Rule. Recognizing the benefits of a nationally harmonized
program and given California's unique ability under CAA section 209 to
be allowed to regulate new motor vehicle and engine emission standards
if certain criteria are met, EPA intends to work closely with CARB on
this effort. EPA also intends to engage with truck and engine
manufacturers, suppliers, state air quality agencies, NGOs, labor, the
trucking industry, and the Petitioners over the next several months as
we develop our formal response to the June 2016 Petitions for
Rulemaking.
(2) Issues Related to Phase 2
(a) Natural Gas Engines and Vehicles
This combined rulemaking by EPA and NHTSA is designed to regulate
two separate characteristics of heavy duty vehicles and engines: GHGs
and fuel consumption. In the case of diesel or gasoline powered
vehicles, there is a one-to-one relationship between these two
characteristics. For alternatively fueled vehicles, which use no
petroleum, the situation is different. For example, a natural gas
vehicle that achieves approximately the same fuel efficiency as a
diesel powered vehicle will emit 20 percent less CO2; and a
natural gas vehicle with the same fuel efficiency as a gasoline vehicle
will emit 30 percent less CO2. Yet natural gas vehicles
consume no petroleum. The agencies are continuing Phase 1 approach,
which the agencies have previously concluded balances these facts by
applying the gasoline and diesel CO2 standards to natural
gas engines based on the engine type of the natural gas engine. Fuel
consumption for these vehicles is then calculated according to their
tailpipe CO2 emissions. In essence, this applies a one-to-
one relationship between fuel efficiency and tailpipe CO2
emissions for all vehicles, including natural gas vehicles. The
agencies determined that this approach will likely create a small
balanced incentive for natural gas use. In other words, it created a
small incentive for the use of natural gas engines that appropriately
balanced concerns about the climate impact methane emissions against
other factors such as the energy security
[[Page 73525]]
benefits of using domestic natural gas. See 76 FR 57123.
(b) Alternative Refrigerants
In addition to use of low-leak components in air conditioning
system design, manufacturers can also decrease the global warming
impact of any refrigerant leakage emissions by adopting systems that
use alternative, lower global warming potential (GWP) refrigerants, to
replace the refrigerant most commonly used today, HFC-134a (R-134a).
HFC-134a is a potent greenhouse gas with a GWP 1,430 times greater than
that of CO2.
Under EPA's Significant New Alternatives Policy (SNAP)
Program,\125\ EPA has found acceptable, subject to use conditions,
three alternative refrigerants that have significantly lower GWPs than
HFC-134a for use in A/C systems in newly manufactured light-duty
vehicles: HFC-152a, CO2 (R-744), and HFO-1234yf.\126\ HFC-
152a has a GWP of 124, HFO-1234yf has a GWP of 4, and CO2
(by definition) has a GWP of 1, as compared to HFC-134a which has a GWP
of 1,430.\127\ CO2 is nonflammable, while HFO-1234yf and
HFC-152a are flammable. All three are subject to use conditions
requiring labeling and the use of unique fittings, and where
appropriate, mitigating flammability and toxicity. Currently, the SNAP
listing for HFO-1234yf is limited to newly manufactured A/C systems in
light-duty vehicles, whereas HFC-152a and CO2 have been
found acceptable for all motor vehicle air conditioning applications,
including heavy-duty vehicles.
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\125\ Section 612(c) of the Clean Air Act requires EPA to review
substitutes for class I and class II ozone-depleting substances and
to determine whether such substitutes pose lower risk than other
available alternatives. EPA is also required to publish lists of
substitutes that it determines are acceptable and those it
determines are unacceptable. See http://www3.epa.gov/ozone/snap/refrigerants/lists/index.html, last accessed on March 5, 2015.
\126\ Listed at 40 CFR part 82, subpart G.
\127\ GWP values cited in this final action are from the IPCC
Fourth Assessment Report (AR4) unless stated otherwise. Where no GWP
is listed in AR4, GWP values are determined consistent with the
calculations and analysis presented in AR4 and referenced materials.
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None of these alternative refrigerants can simply be ``dropped''
into existing HFC-134a air conditioning systems. In order to account
for the unique properties of each refrigerant and address use
conditions required under SNAP, changes to the systems will be
necessary. Typically these changes will need to occur during a vehicle
redesign cycle but can also occur during a refresh. For example,
because CO2, when used as a refrigerant, is physically and
thermodynamically very different from HFC-134a and operates at much
higher pressures, a transition to this refrigerant would require
significant hardware changes. A transition to A/C systems designed for
HFO-1234yf, which is more thermodynamically similar to HFC-134a than is
CO2, requires less significant hardware changes that
typically include installation of a thermal expansion valve and can
potentially require resized condensers and evaporators, as well as
changes in other components. In addition, vehicle assembly plants
require re-tooling in order to handle new refrigerants safely. Thus a
change in A/C refrigerants requires significant engineering, planning,
and manufacturing investments.
EPA is not aware of any significant development of A/C systems
designed to use alternative refrigerants in heavy-duty vehicles.\128\
However, all three lower GWP alternatives are in use or under various
stages of development for use in LD vehicles. Of these three
refrigerants, most manufacturers of LD vehicles have identified HFO-
1234yf as the most likely refrigerant to be used in that application.
For that reason, EPA anticipates that HFO-1234yf will be a primary
candidate for refrigerant substitution in the HD market in the future
if it is listed as an acceptable substitute under SNAP for HD A/C
applications.
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\128\ To the extent that some manufacturers produce HD pickups
and vans on the same production lines or in the same facilities as
LD vehicles, some A/C system technology commonality between the two
vehicle classes may be developing.
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As mentioned above, EPA has listed as acceptable, subject to use
conditions, two lower-GWP refrigerants, R-744 (CO2) and HFC-
152a, for use in HD vehicles. On April 18, 2016, EPA also proposed to
list HFO-1234yf as acceptable, subject to use conditions, in A/C
systems for newly manufactured MDPVs, HD pickup trucks, and complete HD
vans (81 FR 22810). In that action, EPA proposed to list HFO-1234yf as
acceptable, subject to use conditions, for those vehicle types for
which human health and environmental risk could be assessed using the
currently available risk assessments and analysis on LD vehicles. Also
in that action, EPA requested ``information on development of HFO-
1234yf MVAC systems for other HD vehicle types or off-road vehicles, or
plans to develop these systems in the future.'' EPA also stated ``This
information may be used to inform a future listing'' (81 FR 22868).
In another rulemaking action under the SNAP program, on July 20,
2015, EPA published a final rule (80 FR 42870) that will change the
listing status of HFC-134a to unacceptable for use in newly
manufactured LD motor vehicles beginning in MY 2021 (except as allowed
under a narrowed use limit for use in newly manufactured LD vehicles
destined for use in countries that do not have infrastructure in place
for servicing with other acceptable refrigerants through MY 2025). In
that same rule, EPA listed the refrigerant blends SP34E, R-426A, R-
416A, R-406A, R-414A, R-414B, HCFC Blend Delta, Freeze 12, GHG-X5, and
HCFC Blend Lambda as unacceptable for use in newly manufactured light-
duty vehicles beginning in MY 2017. EPA's decisions were based on the
availability of other substitutes that pose less overall risk to human
health and the environment, when used in accordance with required use
conditions. Neither the April 2016 proposed rule nor the July 2015
final rule consider a change of listing status for HFC-134a in HD
vehicles.
LD vehicle manufacturers are currently making investments in
systems designed for lower-GWP refrigerants, both domestically and on a
global basis. In support of the LD GHG rule, EPA projected a full
transition of LD vehicles to lower-GWP alternatives in the United
States by MY 2021. We expect the costs of transitioning to decrease
over time as alternative refrigerants are adopted across all LD
vehicles and trucks, in part due to increased availability of
components and the continuing increases in refrigerant production
capacity, as well as knowledge gained through experience. As lower-GWP
alternatives become widely used in LD vehicles, some HD vehicle
manufacturers may wish to also transition their vehicles. Transitioning
could be advantageous for a variety of reasons, including platform
standardization and company environmental stewardship policies.
In the proposal for this Phase 2 HD rule, EPA proposed another
action related to alternative refrigerants. EPA proposed to allow a
manufacturer to be ``deemed to comply'' with the leakage standard if
its A/C system used a refrigerant other than HFC-134a that was both
listed as an acceptable substitute refrigerant for heavy-duty A/C
systems under SNAP, and was identified in the LD GHG regulations at 40
CFR 86.1867-12(e). 80 FR 40172. By slightly reducing the regulatory
burden of compliance with the leakage standard for a manufacturer that
used an alternative refrigerant, the ``deemed to comply'' provision was
intended to provide a modest incentive for the use of such
refrigerants. There were comments in support of this approach,
[[Page 73526]]
including from Honeywell and Chemours, both of which manufacture HFO-
1234yf.
For several reasons, EPA has reconsidered the proposed ``deemed to
comply'' provision for this rule, and instead, the Phase 2 program
retains the Phase 1 requirement that manufacturers attest that they are
using low-leak components, regardless of the refrigerant they use. CARB
and several NGO commenters expressed concerns about the proposed
``deemed to comply'' provision, primarily citing the potential for
manufacturers to revert to less leak-tight components if they were no
longer required to attest to the use of low-leak A/C system components
because they used a lower-GWP refrigerant. In general, we expect that
the progress LD vehicle manufacturers are making toward more leak-tight
A/C systems will continue and that this progress will transfer to HD A/
C systems. Still, we agree that continued improvements in low-leak
performance HD vehicles is an important goal, and that continuing the
Phase 1 leakage requirements in the Phase 2 program should discourage
manufacturers from reverting to higher-leak and potentially less
expensive components. It is also important to note that there is no
``deemed to comply'' option in the parallel LD-GHG program--
manufacturers must attest to meeting the leakage standard. There is no
compelling reason to have a different regime for heavy duty
applications.
Although leakage of lower-GWP refrigerants is of less concern from
a climate perspective than leakage of higher GWP refrigerants, we also
agree with several commenters that expressed a concern related to the
servicing of lower-GWP systems with higher-GWP refrigerants in the
aftermarket. We agree that this could result due to factors such as
price differentials between aftermarket refrigerants. However, as is
the case for Phase 1, as a part of certification, HD manufacturers will
attest both to the use of low-leak components as well as to the
specific refrigerant used. Thus, in the future, a manufacturer wishing
to certify a vehicle with an A/C system designed for an alternative
refrigerant will attest to the use of that specific refrigerant. In
that situation, any end-user servicing and recharging that A/C system
with any other refrigerant would be considered tampering with an
emission-related component under Title II of the CAA. For example,
recharging an A/C system certified to use a lower-GWP refrigerant, such
as HFO-1234yf, with any other refrigerant, including but not limited to
HFC-134a, would be considered a violation of Title II tampering
provisions.
At the same time, EPA does not believe that finalizing the ``deemed
to comply'' provision would have had an impact on any future transition
of the HD industry to alternative refrigerants. As discussed above, two
lower-GWP refrigerants are already acceptable for use in HD vehicles,
and EPA has proposed to list HFO-1234yf as acceptable, subject to use
conditions, for limited HD vehicle types. As also discussed above, and
especially in light of the rapid expansion of alternative refrigerants
that has been occurring in the LD vehicle market, similar trends may
develop in the HD vehicle market, regardless of EPA's action regarding
leakage of alternative refrigerants in this final rule.
(c) Small Business Issues
The Regulatory Flexibility Act (RFA) generally requires an agency
to prepare a regulatory flexibility analysis of any rule subject to
notice and comment rulemaking requirements under the Administrative
Procedure Act or any other statute unless the agency certifies that the
rule will not have a significant economic impact on a substantial
number of small entities. See generally 5 U.S.C. 601-612. The RFA
analysis is discussed in Section XIV.
Pursuant to section 609(b) of the RFA, as amended by the Small
Business Regulatory Enforcement Fairness Act (SBREFA), EPA also
conducted outreach to small entities and convened a Small Business
Advocacy Review Panel to obtain advice and recommendations of
representatives of the small entities that potentially will be subject
to the rule's requirements. Consistent with the RFA/SBREFA
requirements, the Panel evaluated the assembled materials and small-
entity comments on issues related to elements of the Initial Regulatory
Flexibility Analysis (IRFA). A copy of the Panel Report was included in
the docket for this rule.
The agencies previously determined that the Phase 2 regulations
could potentially have a significant economic impact on small entities.
Specifically, the agencies identified four categories of directly
regulated small businesses that could be impacted:
Trailer Manufacturers
Alternative Fuel Converters
Vocational Chassis Manufacturers
Glider Vehicle \129\ Assemblers
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\129\ Vehicles produced by installing a used engine into a new
chassis are commonly referred to as ``gliders,'' ``glider kits,'' or
``glider vehicles.'' See Section I.E.i and XIII.B.
To minimize these impacts the agencies are adopting certain
regulatory flexibilities--both general and category-specific. In
general, we are delaying new requirements for EPA GHG emission
standards by one initial year and simplifying certification
requirements for small businesses. Even with this one year delay, small
businesses will be required to comply with EPA's standards before
NHTSA's fuel efficiency standards are mandatory. Because of this
timing, compliance with NHTSA's regulations will not be delayed, as
small business manufacturers will be accommodated through EPA's initial
one year delay. The agencies are also providing the following specific
relief:
Trailers: Adopting simpler requirements for non-box
trailers, which are more likely to be manufactured by small businesses;
reduced reliance on emission averaging; and making third-party testing
easier for certification.
Alternative Fuel Converters: Omitting recertification of a
converted vehicle when the engine is converted and certified; reduced
N2O testing; and simplified onboard diagnostics and delaying
required compliance with each new standard by one model year.
Vocational Chassis: Less stringent standards for certain
vehicle categories; opportunity to generate credits under the Phase 1
program.
Glider Vehicle Assemblers: \130\ Exempting existing small
businesses, but limiting the small business exemption to a capped level
of annual production (production in excess of the capped amount will be
allowed, but subject to all otherwise applicable requirements including
the Phase 2 standards). Providing additional flexibility for newer
engines.
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\130\ EPA is amending its rules applicable to engines installed
in glider kits, which will affect emission standards not only for
GHGs but for criteria pollutants as well. EPA is also clarifying its
requirements for certification and revising its definitions for
glider kit and glider vehicle manufacturers. NHTSA is not including
glider vehicles under its Phase 2 fuel consumption standards. See
Section XIII.B.
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These flexibilities are described in more detail in Section XIV, in
RIA Section 12 and in the Panel Report. Flexibilities specific to
glider vehicle assemblers are described in Section XIII.
(d) Confidentiality of Test Results and GEM Inputs
The agencies received mixed comments regarding the question of
whether GEM inputs should be made available to public. Some commenters
supported making this information available, while others thought it
should
[[Page 73527]]
be protected as confidential business information (CBI). In accordance
with Federal statutes, EPA does not release information from
certification applications (or other compliance reports) that we
determine to be CBI under 40 CFR part 2. Consistent with section 114(c)
of the CAA, EPA does not consider emission test results to be CBI after
introduction into commerce of the certified engine or vehicle.
(However, we have generally treated test results as protected before
the introduction into commerce date). EPA has not yet made a final
determination for Phase 1 or Phase 2 certification test results.
Nevertheless, at this time we expect to continue this policy and
consider it likely that we would not treat any test results or other
GEM inputs as CBI after the introduction into commerce date as
identified by the manufacturer.
With regard to NHTSA's treatment of confidential business
information, manufacturers must submit a request for confidentiality
with each electronic submission specifying any part of the information
or data in a report that it believes should be withheld from public
disclosure as trade secret or other confidential business information.
A form is available through the NHTSA Web site to request
confidentiality. NHTSA does not consider manufacturers to continue to
have a business case for protecting pre-model report data after the
vehicles contained within that report have been introduced into
commerce.
(e) Delegated Assembly and Secondary Manufacturers
In EPA's existing regulations (40 CFR 1068.261), we allow engine
manufacturers to sell or ship engines that are missing certain
emission-related components if those components will be installed by
the vehicle manufacturer. These provisions already apply to Phase 1
vehicles as well, providing a similar allowance for vehicle
manufacturers to sell or ship vehicles that are missing certain
emission-related components if those components will be installed by a
secondary vehicle manufacturer. See section 1037.620. EPA has found
this provision to work well and is finalizing certain amendments in
this rule. See 40 CFR 1037.621. Under the amended rule, as conditions
of this allowance, manufacturers will be required to:
Have a contractual obligation with the secondary manufacturer
to complete the assembly properly and provide instructions about how to
do so
Keep records to demonstrate compliance
Apply a temporary label to the incomplete vehicles
Take other reasonable steps to ensure the assembly is
completed properly
Describe in its application for certification how it will use
this allowance
Under delegated assembly, it is the upstream manufacturer that
holds the certificate and assumes primary responsibility for all
compliance requirements. Our experience applying this approach has
shown that holding the upstream manufacturer responsible ensures that
they will exercise due diligence throughout the process.
EPA proposed to apply this new section broadly. However, commenters
raised valid questions about whether it is necessary to apply this
formal process as broadly as proposed. In response, we have
reconsidered the proposed approach and have determined that it would be
appropriate to allow a less formal process with components for which
market forces will make it unlikely that a secondary manufacturer would
not complete assembly properly. In those cases, the certifying
manufacturers will be required to provide sufficiently detailed
installation instructions to the secondary manufacturers, who would
then be obligated to complete assembly properly before the vehicles are
delivered to the ultimate purchasers.
One example of a case for which market forces could ensure that
assembly is completed properly would be air conditioning leakage
requirements. Purchasers will have the expectation that the systems
will not leak, and a secondary manufacturer should have no incentive to
not follow the certifying manufacturer's instructions.
As revised, Sec. 1037.621 will require the formal delegated
assembly process for the following technologies if they are part of the
OEM's certified configuration but not shipped with the vehicle:
Auxiliary power units
Aerodynamic devices
Hybrid components
Natural gas fuel tanks
Certificate holders will remain responsible for other certified
components, but will not automatically be required to comply with the
formal delegated assembly requirements. That determination will be made
case-by-case as part of the certification process. We are also
explicitly making the flexibility in 40 CFR 1037.621 available for HD
pickups and vans certified to the standards in 40 CFR part 86. As is
currently specified in 40 CFR 1068.261, EPA will retain the authority
to apply additional necessary conditions (at the time of certification)
to the allowance to delegate assembly of emission to secondary
manufacturers (when emission control equipment is not shipped with the
vehicle to the secondary manufacturer, as just noted). In particular,
we would likely apply such additional conditions for manufacturers that
we determine to have previously not completed assembly properly. Issues
of delegated assembly are addressed in more detail in Section 1.4.4 of
the RTC.
(f) Engine/Vehicle Useful Life
We received comment on what policies we should adopt to address the
situation where the engine and the vehicle are subject to emission
standards over different useful-life periods. For example, a medium
heavy-duty engine may power vehicles in weight classes ranging from 2b
to 8, with correspondingly different regulatory useful lives for those
vehicles. As provided in 40 CFR 1037.140 of the final regulations, we
have structured the vehicle regulations to generally apply the same
useful life for the vehicle that applies for the engines. However,
these regulations also allow vehicle manufacturers to certify their
vehicles to longer useful lives. The agencies see no problem with
allowing vehicles to have longer useful lives than the engines.
(g) Compliance Reports
The agencies received comment on the NPRM from two environmental
organizations requesting that the agencies make available to the public
data and information that would enable the public to track trends in
technology sales over time, as well as track company-specific
compliance data. The commenters suggested that this should include an
agency publication of an annual compliance report for the Heavy-duty
Phase 2 program. The commenters requested this information to allow all
stakeholders to see how individual companies, as well as the industry
overall, were performing relative to their compliance obligations (see
comments from ACEEE and NRDC).
The agencies agree with this comment. In the context of the light-
duty vehicle GHG standards, EPA has already published four annual
compliance reports which has made available to the public detailed
information regarding both how individual light-duty vehicle companies
have been meeting their compliance obligations, as well as summary
information at the light-duty fleet level. NHTSA makes the up-to-date
information on the light-duty fuel economy program available through
its
[[Page 73528]]
CAFE Public Information Center (http://www.nhtsa.gov/CAFE_PIC/CAFE_PIC_Home.htm). Information includes manufacturer and overall fleet
standards and CAFE performance, credit status, and civil penalty
status. This information has been helpful to increase transparency to
all stakeholders and to allow the public to see how companies are
progressing from one year to the next with respect to their compliance
requirements. It is EPA's intention to publish a similar annual
compliance report for the heavy duty GHG program, covering both the
existing Phase 1 program, as well as the Phase 2 standards contained in
this final rule. It is NHTSA's intention to expand the Public
Information Center to include the medium- and heavy-duty fuel
efficiency program and to make up-to-date information collected in the
heavy-duty fuel efficiency compliance process available publicly. Both
the EPA and NHTSA compliance reports will provide available information
at the vehicle subclass level for each of the four vehicle categories
(i.e. Tractors, Trailers, Vocational, and Heavy-Duty Pickups and Vans),
and EPA will provide available information for the other GHG standards,
such as N2O and refrigerant leak detection standards. Prior
to issuing the compliance reports, EPA and NHTSA will work with
regulated manufacturers to reconcile concerns over the release of
claimed confidential business information, consistent with 40 CFR part
2 and 49 CFR 512.
(3) Life Cycle Emissions
The agencies received many comments expressing concerns about
establishing the GHG and fuel consumption standards as tailpipe
standards that do not account for upstream emissions or other life
cycle impacts. However, many other commenters supported this approach.
Comments specifically related to alternative fuels or electric vehicles
are addressed in Section I.C.(1)(d) and in Section XI.B. This section
addresses the issue more broadly.
As discussed below, the agencies do not see how we could accurately
account for life cycle emissions in our vehicle standards, nor have
commenters shown that such an accounting is needed. In addition, NHTSA
has already noted that the fuel efficiency standards are necessarily
tailpipe-based, and that a lifecycle approach would likely render it
impossible to harmonize the fuel efficiency and GHG emission standards,
to the great detriment of our goal of achieving a national, harmonized
program. See 76 FR 57125.
It is also worth noting that EPA's engine and vehicle emission
standards and NHTSA's vehicle fuel consumption standards (including
those for light-duty vehicles) have been in place for decades as
tailpipe standards. The agencies find no reasonable basis in the
comments or elsewhere to change fundamentally from this longstanding
approach.
Although the final standards do not account for life cycle
emissions, the agencies have estimated the upstream emission impact of
reducing fuel consumption for heavy-duty vehicles. As shown in Section
VII and VIII, these upstream emission reductions are significant and
worth estimating, even with some uncertainty. However, this analysis
would not be a sufficient basis for inclusion in the standards
themselves.
(a) Challenges for Addressing Life Cycle Emissions With Vehicle
Standards
Commenters supporting accounting for life cycle emissions generally
did so in the context of one or more specific technologies. However,
the agencies cannot accurately address life-cycle emissions on a
technology specific basis at this time for two reasons:
We lack data to address each technology, and see no path
to selectively apply a life cycle analysis to some technologies, but
not to others.
Actual life cycle emissions are dependent on factors
outside the scope of the rulemaking that may change in the future.
With respect to the first reason, even if we were able to
accurately and fully account for life cycle impacts of one technology
(such as weight reduction), this would not allow us to address life
cycle emissions for other technologies. For example, how would the
agencies address potential differences in life cycle emissions for
shifting from a manual transmission to and AMT, or the life cycle
emissions of aerodynamic fairings? If we cannot factor in life cycle
impacts for all technologies, how would we do it for weight reductions?
Given the complexity of these rules and the number of different
technologies involved, we see no way to treat the technologies
equitably. Commenters do not provide the information necessary to
address this challenge, nor are the agencies aware of such information.
The second reason is just as problematic. This rulemaking is
setting standards for vehicles under specific statutory provisions. It
is not regulating manufacturing processes, distribution practices, or
the locations of manufacturing facilities. And yet each of these
factors could impact life cycle emissions. So while we could take a
snapshot of life cycle emissions at this point in time for specific
manufacturers, it may or may not have any relation to life cycle
emissions in 2027, or for other manufacturers. Consider, for example,
two component manufacturers: One that produces its components near the
vehicle assembly plant, and relies on natural gas to power its factory;
and a second that is located overseas and relies on coal-fired power.
How would the agencies equitably (or even non-arbitrarily) factor in
these differences without regulating these processes? To the extent
commenters provided any information on life cycle impacts, they did not
address this challenge.
(b) Need for Life Cycle Consideration in the Standards
The agencies acknowledge that a full and accurate accounting of
life cycle emissions (if it were possible) could potentially make the
Phase 2 program marginally better. However, we do not agree that this
is an issue of fundamental importance. While some commenters submitted
estimates of the importance of life cycle emissions for light-duty
vehicles, life cycle emissions are less important for heavy-duty
vehicles. Consider, for example, the difference between a passenger car
and a heavy-duty tractor. If the passenger car achieves 40 mile per
gallon and travels 150,000 miles in its life, it would consume less
than 4,000 gallons of fuel in its life. On the other hand, a tractor
that achieves 8 miles per gallon and travels 1,000,000 miles would
consume 125,000 gallons of fuel in its life, or more than 30 times the
fuel of the passenger car. Commenters provide no basis to assume the
energy consumption associated with tractor production would be 30 times
that of the production of a passenger car.
(4) Amendments to the Phase 1 Program
The agencies are revising some test procedures and compliance
provisions used for Phase 1. These changes are described in Section
XII. This includes both amendments specific to Phase 1, as well as
amendments that apply more broadly than Phase 1, such as the revisions
to the delegated assembly provisions. As a drafting matter, EPA notes
that we are moving the GHG standards for Class 2b and 3 pickups and
vans from 40 CFR 1037.104 to 40 CFR 86.1819-14.
NHTSA is also amending 49 CFR part 535 to make technical
corrections to its Phase 1 program to better align with EPA's
compliance approach, standards and CO2 performance results.
In general, these changes are intended to improve the regulatory
experience for regulated
[[Page 73529]]
parties and also reduce agency administrative burden. More
specifically, NHTSA is changing the rounding of its standards and
performance values to have more significant digits. Increasing the
number of significant digits for values used for compliance with NHTSA
standards reduces differences in credits generated and overall credit
balances for the EPA and NHTSA programs. NHTSA is also removing the
petitioning process for off-road vehicles, clarifying requirements for
the documentation needed for submitting innovative technology requests
in accordance with 40 CFR 1037.610 and 49 CFR 535.7, and adding further
detail to requirements for submitting credit allocation plans as
specified in 49 CFR 535.9. Finally, NHTSA is adding the same
recordkeeping requirements that EPA currently requires to facilitate
in-use compliance inspections. These changes are intended to improve
the regulatory experience for regulated parties and also reduce agency
administrative burden.
The agencies received few comments on these changes, with most
supporting the proposed changes or suggesting improvements. These
comments as well as the few comments opposing any of these changes are
discussed in Section XII and in the RTC.
(5) Other Amendments to EPA Regulations
EPA is finalizing certain other changes to regulations that we
proposed, which are not directly related to the HD Phase 1 or Phase 2
programs, as detailed in Section XIII. For these amendments, there are
no corresponding changes in NHTSA regulations. Some of these amendments
relate directly to heavy-duty highway engines, but not to the GHG
programs. Others relate to nonroad engines. This latter category
reflects the regulatory structure EPA uses for its mobile source
regulations, in which regulatory provisions applying broadly to
different types of mobile sources are codified in common regulatory
parts such as 40 CFR part 1068. This approach creates a broad
regulatory structure that regulates highway and nonroad engines,
vehicles, and equipment collectively in a common program. Thus, it is
appropriate to include some amendments to nonroad regulations in
addition to the changes applicable only for highway engines and
vehicles.
Except as noted below, the agencies received relatively few
significant comments on these issues. All comments are discussed in
more detail in Section XIII and in the RTC. One area, for which we did
receive significant comment was the issue of competition vehicles. As
described in Section XIII, EPA is not finalizing the proposed
clarification related to highway vehicles used for competition.
(a) Standards for Engines Installed In Glider Kits
EPA regulations currently allow used pre-2013 engines to be
installed into new glider kits without meeting currently applicable
standards. As described in Section XIII.B, EPA is amending its
regulations to allow only engines that have been certified to meet
standards for the model year in which the glider vehicle is assembled
(i.e. current model year engine standards) to be installed in new
glider kits, with certain exceptions. First, engines certified to
earlier MY standards that are identical to the current model year
standards may be used. Second, engines still within their useful life
(and certain similar engines) may be used. Note that this would not
allow use of the pre-2002 engines that are currently being used in most
glider vehicles because they all would be outside of the 10-year useful
life period. Finally, the interim small manufacturer allowance for
glider vehicles will also apply for the engines used in the exempted
glider kits. Comments on this issue are summarized and addressed in
Section XIII.B and in RTC Section 14.2.
(b) Nonconformance Penalty Process Changes
Nonconformance penalties (NCPs) are monetary penalties established
by regulation that allow a vehicle or engine manufacturer to sell
engines that do not meet the emission standards. Manufacturers unable
to comply with the applicable standard pay penalties, which are
assessed on a per-engine basis.
On September 5, 2012, EPA adopted final NCPs for heavy heavy-duty
diesel engines that could be used by manufacturers of heavy-duty diesel
engines unable to meet the current oxides of nitrogen (NOX)
emission standard. On December 11, 2013 the U.S. Court of Appeals for
the District of Columbia Circuit issued an opinion vacating that Final
Rule. It issued its mandate for this decision on April 16, 2014, ending
the availability of the NCPs for the current NOX standard,
as well as vacating certain amendments to the NCP regulations due to
concerns about inadequate notice. In particular, the amendments revise
the text explaining how EPA determines when NCP should be made
available. In the Phase 2 NPRM, EPA re-proposed most of these
amendments to provide fuller notice and additional opportunity for
public comment. As discussed in Section XIII, although EPA received one
comment opposing these amendments, they are being finalized as
proposed.
(c) Updates to Heavy-Duty Engine Manufacturer In-Use Testing
Requirements
EPA and manufacturers have gained substantial experience with in-
use testing over the last four or five years. This has led to important
insights in ways that the test protocol can be adjusted to be more
effective. We are accordingly making changes to the regulations in 40
CFR part 86, subparts N and T.
(d) Extension of Certain 40 CFR Part 1068 Provisions to Highway
Vehicles and Engines
As part of the Phase 1 GHG standards, we applied the exemption and
importation provisions from 40 CFR part 1068, subparts C and D, to
heavy-duty highway engines and vehicles. We also specified that the
defect reporting provisions of 40 CFR 1068.501 were optional. In an
earlier rulemaking, we applied the selective enforcement auditing under
40 CFR part 1068, subpart E (75 FR 22896, April 30, 2010). We are
adopting the rest of 40 CFR part 1068 for heavy-duty highway engines
and vehicles, with certain exceptions and special provisions.
As described above, we are applying all the general compliance
provisions of 40 CFR part 1068 to heavy-duty engines and vehicles
subject to 40 CFR parts 1036 and 1037. We are also applying the recall
provisions and the hearing procedures from 40 CFR part 1068 for highway
motorcycles and for all vehicles subject to standards under 40 CFR part
86, subpart S.
EPA is updating and consolidating the regulations related to formal
and informal hearings in 40 CFR part 1068, subpart G. This will allow
us to rely on a single set of regulations for all the different
categories of vehicles, engines, and equipment that are subject to
emission standards. We also made an effort to write these regulations
for improved readability.
We are also making a number of changes to part 1068 to correct
errors, to add clarification, and to make adjustments based on lessons
learned from implementing these regulatory provisions.
(e) Amendments to Engine and Vehicle Test Procedures in 40 CFR Parts
1065 and 1066
EPA is making several changes to our engine testing procedures
specified in
[[Page 73530]]
40 CFR part 1065. None of these changes will significantly impact the
stringency of any standards.
(f) Amendments Related to Marine Diesel Engines in 40 CFR Parts 1042
and 1043
EPA's emission standards and certification requirements for marine
diesel engines under the Clean Air Act and the act to Prevent Pollution
from Ships are identified in 40 CFR parts 1042 and 1043, respectively.
EPA is amending these regulations with respect to continuous
NOX monitoring and auxiliary engines, as well as making
several other minor revisions.
(g) Amendments Related to Locomotives in 40 CFR Part 1033
EPA's emission standards and certification requirements for
locomotives under the Clean Air Act are identified in 40 CFR part 1033.
EPA is making several minor revisions to these regulations.
(6) Other Amendments to NHTSA Regulations
NHTSA proposed to amend 49 CFR parts 512 and 537 to allow
manufacturers to submit required compliance data for the Corporate
Average Fuel Economy (CAFE) program electronically, rather than
submitting some reports to NHTSA via paper and CDs and some reports to
EPA through its VERIFY database system. NHTSA is not finalizing this
proposal in this rulemaking and will consider electronic submission for
CAFE reports in a future action.
II. Vehicle Simulation and Separate Engine Standards for Tractors and
Vocational Chassis
A. Introduction
This Section II. describes two regulatory program elements that are
common among tractors and vocational chassis. In contrast, Sections III
and V respectively describe the regulatory program elements that are
unique to tractors and to vocational chassis. The common elements
described here are the vehicle simulation approach to vehicle
certification and the separate standards for engines. Section II.B
discusses the reasons for this Phase 2 regulatory approach; namely,
requiring vehicle simulation for tractor and vocational chassis
certification, maintaining separate engine standards, and expanding and
updating their related mandatory and optional test procedures. Section
II.C discusses in detail the evolution and final version of the vehicle
simulation computer program, which is called the Greenhouse gas
Emissions Model or ``GEM.'' Section II.C also discusses the evolution
and final versions of the test procedures for determining the GEM
inputs that are common for tractors and vocational chassis. Section
II.D discusses in detail the separate engine standards for GHGs and
fuel efficiency and their requisite test procedures.
In this final action, the agencies have built on the success of the
Phase 1 GEM-based approach for the certification of tractors and
vocational chassis. To better recognize the real-world impact of
vehicle technologies, we have expanded the number of required and
optional vehicle inputs into GEM. Inputting these additional details
into GEM results in more accurate representations of vehicle
performance and greater opportunities to demonstrate reductions in
CO2 emissions and fuel consumption. We are also finalizing
revisions to the vehicle driving patterns that are programmed into GEM
to better reflect real-world vehicle operation and the emissions
reductions that result from applying GHG and fuel efficiency
technologies to vehicles. As a result of these revisions, the final
GEM-based vehicle certification approach necessitates new testing of
engines and testing of some other vehicle components to generate the
additional GEM inputs for Phase 2. More detail is provided in Section
II.C.
Based on our assessments of the technological feasibility; cost
effectiveness; requisite lead times for implementing new and additional
tractor and vocational vehicle technologies; and based on comments we
received in response to our notice of proposed rulemaking and in
response to our more recent notice of additional data availability, the
agencies are finalizing steadily increasing stringencies of the
CO2 and fuel consumption standards for tractors and
vocational chassis for vehicle model years 2021, 2024 and 2027. See
Section I or Sections III and V respectively for these numerical
standards for tractors and vocational chassis. As part of our
analytical process for determining the numerical values of these
standards, the agencies utilized GEM. Using GEM as an integral part of
our own standard-setting process helps ensure consistency between our
technology assessments and the GEM-based certification process that we
require for compliance with the Phase 2 standards. Our utilization of
GEM in our standard-setting process is described further in Section
II.C.
For Phase 2 we are finalizing, as proposed, the same Phase 1
certification approach for all of the GHG and fuel efficiency separate
engine standards for those engines installed in tractors and vocational
chassis. For the separate engine standards, we will continue to require
the Phase 1 engine dynamometer certification test procedures, which
were adopted substantially from EPA's existing heavy-duty engine
emissions test procedures. In this action we are finalizing, as
proposed, revisions to the weighting factors of the tractor engine 13-
mode steady-state test cycle (i.e., the Supplemental Engine Test cycle
or ``SET''). The SET is required for determining tractor engine
CO2 emissions and fuel consumption. Consistent with the
rationale we presented in our proposal and consistent with comments we
received, these revised SET weighting factors better reflect the lower
engine speed operation of modern engines, which frequently occurs at
tractor cruise speeds. We used these revised weighting factors as part
of our engine technology assessments of both current engine technology
(i.e., our ``baseline engine'' technology) and future engine
technology.
Based on our assessments of the technological feasibility; cost
effectiveness; requisite lead times for implementing new and additional
engine technologies; and based on comments we received in response to
our notice of proposed rulemaking and in response to our more recent
notice of additional data availability, the agencies are finalizing
steadily increasing stringencies of the CO2 and fuel
consumption separate engine standards for engine model years 2021, 2024
and 2027. In addition, for each of these model years, EPA is
maintaining the Phase 1 separate engine standards for CH4
and N2O emissions--both at their Phase 1 numeric values.
While EPA is not finalizing at this time more stringent N2O
emissions standards, as originally proposed, EPA may soon revisit these
separate engine N2O standards in a future rulemaking. All of
the final Phase 2 separate engine standards are presented in Section
II.D, along with our related assessments.
B. Phase 2 Regulatory Structure
As proposed, in this final action the agencies have built on the
success of the Phase 1 GEM-based approach for the certification of
tractors and vocational chassis, while also maintaining the Phase 1
separate engine standards approach to engine certification. While the
regulatory structures of both Phase 1 and Phase 2 are quite similar,
there are a number of new elements for Phase 2. Note that we are not
applying these new
[[Page 73531]]
Phase 2 elements for compliance with the Phase 1 standards.
These modifications for Phase 2 are consistent with the agencies'
Phase 1 commitments to consider a range of regulatory approaches during
the development of future regulatory efforts (76 FR 57133), especially
for vehicles not already subject to full vehicle chassis dynamometer
testing. For example, we committed to consider a more sophisticated
approach to vehicle testing to more completely capture the complex
interactions within the total vehicle, including the engine and
powertrain performance. We also committed to consider the potential for
full vehicle certification of complete tractors and vocational chassis
using a chassis dynamometer test procedure. We also considered chassis
dynamometer testing of complete tractors and vocational chassis as a
complementary approach for validating a more complex vehicle simulation
approach. We committed to consider the potential for a regulatory
program for some of the trailers hauled by tractors. After considering
these various approaches, the agencies proposed a structure in which
regulated tractor and vocational chassis manufacturers would
additionally enter engine and powertrain-related inputs into GEM, which
was not part of in Phase 1.
The basic structure in the proposal was widely supported by
commenters, although some commenters supported changing certain
aspects. Some commenters suggested revising GEM to recognize additional
technologies, such as tire pressure monitoring systems and electronic
controls that decrease fuel consumption while a vehicle is coasting. To
the extent that the agencies were able to collect and receive
sufficient data to support such revisions in GEM, these changes were
made. See Section II.C. for details. For determining certain GEM
inputs, some commenters suggested more cost-effective test procedures
for separate engine and transmission testing, compared to the engine-
plus-transmission powertrain test procedure that the agencies proposed.
In collaboration with researchers at engine manufacturer test
laboratories, at Oak Ridge National Laboratory and at Southwest
Research Institute, the agencies completed a number of laboratory
evaluations of these suggested test procedures.\131\ Based on these
results, which were made available to the public for a 30-day comment
period in the NODA, the agencies are finalizing these more cost-
effective test procedures as options, in addition to the powertrain
test procedure we proposed. We note that we are also finalizing some of
these more cost-effective test procedures, the cycle average approach
for all vehicle cycles, as optional for the testing of ``pre-
transmission'' hybrids. In response to our request for comment, some
commenters expressed support for a so-called, ``cycle-average''
approach for generating engine map data for input into GEM. This
approach facilitates an accurate recognition of an engine's transient
performance. The agencies further refined this approach, and we made
detailed information on this approach available in the NODA.\132\ Based
on comments, we are finalizing this approach as mandatory for mapping
engines over GEM's transient cycle, and we are allowing this approach
as optional for GEM's 55 mph and 65 mph cycles.
---------------------------------------------------------------------------
\131\ Oak Ridge National Laboratory results docketed for the
NODA: EPA-HQ-OAR-2014-0827-1622 and NHTSA-2014-0132-0183. Southwest
Research Institute results docketed for the NODA: EPA-HQ-OAR-2014-
0827-1619 and NHTSA-2014-0132-0184.
\132\ Ibid.
---------------------------------------------------------------------------
Some commenters expressed concern about GEM and our proposed
tractor standards appropriately accounting for the performance of
powertrain technologies installed in some of the largest specialty
tractors. We have addressed this concern by finalizing a new ``heavy-
haul'' tractor sub-category, with a unique payload and vehicle masses
in GEM, which result in a unique set of numeric standards for these
vehicles. This is explained in detail in Section III.D. Other
commenters expressed concern about the greater complexity of GEM's
additional inputs and the appropriateness of our proposed vocational
chassis standards, as applied to certain custom-built vocational
chassis. We have addressed these concerns by finalizing a limited
number of optional custom chassis standards, tailored according to a
vocational chassis' final application (e.g., school bus, refuse truck,
cement mixer, etc.). To address the concerns about GEM's complexity for
these specialty vehicles, these optional custom chassis standards
require a smaller number of GEM inputs. This is explained in detail in
Section V.D.
Some vehicle manufacturers did not support the agencies finalizing
separate engine standards. However, as described below, the agencies
continue to believe that separate engine standards are necessary and
appropriate. Thus, the agencies are finalizing the basic rule structure
that was proposed, but with a number of refinements.
For trailer manufacturers, which will be subject to first-time
standards under Phase 2, we will apply the standards using a GEM-based
certification, but to do so without actually running GEM. More
specifically, based on the agencies' analysis of the results of running
GEM many times and varying GEM's trailer configurations, the agencies
have developed a simple equation that replicates GEM results, based on
inputting certain trailer values into the equation. Use of the
equation, rather than full GEM, should significantly facilitate trailer
certification. As described in Chapter 2.10.5 of the RIA, the equation
has a nearly perfect correlation with GEM, so that they can be used
instead of GEM, without impacting stringency. This is a result of the
relative simplicity of the trailer inputs as compared to the tractor
and vocational vehicle inputs.
(1) Other Structures Considered
To follow-up on the commitment to consider other approaches, the
agencies spent significant time and resources before the proposal in
evaluating six different options for demonstrating compliance with the
proposed Phase 2 standards as shown in Figure II.1
[[Page 73532]]
[GRAPHIC] [TIFF OMITTED] TR25OC16.001
As shown in Figure II.1 these six options include:
1. Full vehicle simulation, where vehicle inputs are entered into
simulation software.
2. Vehicle simulation, supplemented with separate engine standards.
3. Controllers-in-the-loop simulation, where an actual electronic
transmission controller module (TCM) and an actual engine controller
module (ECM) are tested in hardware.
4. Engine-in-the-loop simulation, with or without a TCM, where at
least the engine is tested in hardware.
5. Vehicle simulation with powertrain-in-the-loop, where the engine
and transmission are tested in hardware. One variation involves an
engine standard.
6. Full vehicle chassis dynamometer testing.
The agencies evaluated these options in terms of the capital
investment required of regulated manufacturers to conduct the testing
and/or simulation, the cost per test, the accuracy of the simulation,
and the challenges of validating the results. Other considerations
included the representativeness compared to the real world behavior,
maintaining existing Phase 1 certification approaches that are known to
work well, enhancing the Phase 1 approaches that could use
improvements, the alignment of test procedures for determining GHG and
non-GHG emissions compliance, and the potential to circumvent the
intent of the test procedures. The agencies presented our evaluations
in the proposal, and we received comments on some of these approaches,
and these comments were considered carefully in our evaluations for
this final action. Notably, in this final action we are adopting a
combination of these options, where some are mandatory and others are
optional for certification via GEM. We have concluded that this
combination of these options strikes an optimal balance between their
costs, accuracy with respect to real-world performance, and robustness
for ensuring compliance. In this section we present our evaluation and
rationale for finalizing these Phase 2 certification approaches.
Chassis dynamometer testing (Option 6) is used extensively in the
development and certification of light-duty vehicles. It also is used
in Phase 1 to certify complete Class 2b/3 pickups and vans, as well as
to certify certain incomplete vehicles (at the manufacturer's option).
The agencies considered chassis dynamometer testing more broadly as a
heavy-duty fuel efficiency and GHG certification option because chassis
dynamometer testing has the ability to evaluate a vehicle's performance
in a manner that most closely resembles the vehicle's in-use
performance. Nearly all of the fuel efficiency technologies can be
evaluated simultaneously on a chassis dynamometer, including the
vehicle systems' interactions that depend on the behavior of the
engine, transmission, and other vehicle electronic controllers. One
challenge associated with the application of wide-spread heavy-duty
chassis testing is the small number of heavy-duty chassis test sites
that are available in North America. As discussed in RIA Chapter 3, the
agencies were only able to locate 11 heavy-duty chassis test sites.
However, more recently we have seen an increased interest in building
new sites since issuing the Phase 1 Final Rule. For example, EPA is
currently building a heavy-duty chassis dynamometer with the ability to
test up to 80,000 pound vehicles at the National Vehicle and Fuel
Emissions Laboratory in Ann Arbor, Michigan.
Nevertheless, the agencies continue to be concerned about requiring
a chassis test procedure for certifying tractors or vocational chassis
due to the initial cost of a new test facility and the large number of
heavy duty tractor and vocational chassis variants that could require
testing. We have also concluded that for heavy-duty tractors and
vocational chassis, there can be increased test-to-test variability
under chassis dynamometer test conditions, versus other approaches.
First, the agencies recognize that such testing
[[Page 73533]]
requires expensive, specialized equipment that is not widely available.
The agencies estimate that it would vary from about $1.3 to $4.0
million per new test site depending on existing facilities.\133\ In
addition, the large number of heavy-duty vehicle configurations would
require significant amounts of testing to cover the sector. For
example, for Phase 1 tractor manufacturers typically certified several
thousand variants of one single tractor model. Finally, EPA's
evaluation of heavy-duty chassis dynamometer testing has shown that the
variation of chassis test results is greater than light-duty testing,
up to 3 percent worse, based on our sponsored testing at Southwest
Research Institute.\134\ The agencies' research identified a number of
unique sources of test-to-test variability in HD chassis dynamometer
testing versus other types of testing (described next). These unique
sources include variations in HD tire performance and tire temperature
and pressure stability; variations in human driver performance; and
variations in the test facilities' heating, ventilation and air
conditioning system affecting emissions after-treatment performance
(e.g., increased fuel consumption to maintain after-treatment
temperature) and engine accessory power (e.g., engine fan clutching).
Although the agencies are not requiring chassis dynamometer
certification of tractors and vocational chassis, we believe such an
approach could potentially be appropriate in the future for some heavy
duty vehicles if more test facilities become available and if the
agencies are able to address the large number of vehicle variants that
might require testing and the unique sources of test-to-test
variability. Note, as discussed in Section II.C.(4) we are finalizing a
manufacturer-run complete tractor heavy-duty chassis dynamometer test
program for monitoring relative trends fuel efficiency and for
comparing those trends to the trends indicated via GEM simulation.
While the agencies did not receive significant comment on the
appropriateness of full vehicle heavy-duty chassis dynamometer testing
for certification, the agencies did receive significant, mostly
negative, comment on the costs versus benefits of a manufacturer-run
complete tractor heavy-duty chassis dynamometer test program for data
collection. These comments and our responses are detailed in Section
II.C.(4).
---------------------------------------------------------------------------
\133\ 03-19034 TASK 2 Report-Paper 03-Class8_hil_DRAFT,
September 30, 2013.
\134\ GEM Validation, Technical Research Workshop, San Antonio,
December 10-11, 2014.
---------------------------------------------------------------------------
Another option considered for certification involves testing a
vehicle's powertrain in a modified engine dynamometer test facility,
which is part of option 5 shown in Figure II.1. In this case the engine
and transmission are installed together in a laboratory test facility,
and a dynamometer is connected to the output shaft of the transmission.
GEM or an equivalent vehicle simulation computer program is then used
to control the dynamometer to simulate vehicle speeds and loads. The
step-by-step test procedure considered for this option was initially
developed as an option for hybrid powertrain testing for Phase 1. We
are not finalizing this approach as mandatory, but we are allowing this
as an option for manufacturers to generate powertrain inputs for use in
GEM. For Phase 2 we generally require this test procedure for
evaluating hybrid powertrains for inputs into GEM, but there are
certain exceptions where engine-only test procedures may be used to
certify hybrids via GEM (e.g., pre-transmission hybrids).
A key advantage of the powertrain test approach is that it directly
measures the effectiveness of the engine, the transmission, and the
integration of these two components. Engines and transmissions are
particularly challenging to simulate within a computer program like GEM
because the engines and transmissions installed in vehicles today are
actively and interactively controlled by their own sophisticated
electronic controls; namely the ECM and TCM.
We believe that the capital investment impact on manufacturers for
powertrain testing is reasonable; especially for those who already have
heavy-duty engine dynamometer test facilities. We have found that, in
general, medium-duty powertrains can be tested in heavy-duty engine
test cells. EPA has successfully completed such a test facility
conversion at the National Vehicle and Fuel Emissions Laboratory in Ann
Arbor, Michigan. Southwest Research Institute (SwRI) in San Antonio,
Texas has completed a similar test cell conversion. Oak Ridge National
Laboratory in Oak Ridge, Tennessee has been operating a recently
constructed heavy heavy-duty powertrain dynamometer facility, and EPA
currently has an interagency agreement with DOE to fund EPA powertrain
testing at ORNL. The results from this testing were published for a 30-
day comment period, as part of the NODA.\135\ Eaton Corporation has
been operating a heavy-duty powertrain test cell and has provided the
agencies with valuable test results and other comments.\136\ PACCAR
recently constructed and began operation of a powertrain test cell that
includes engine, transmission and axle test capabilities.\137\ EPA also
contracted SwRI to evaluate North America's capabilities (as of 2014)
for powertrain testing in the heavy-duty sector and the cost of
installing a new powertrain cell that meets agency requirements.\138\
Results from this 2014 survey indicated that one supplier (Eaton)
already had this capability. We estimate that the upgrade costs to an
existing engine test facility are on the order of $1.2 million, and a
new test facility in an existing building are on the order of $1.9
million. We also estimate that current powertrain test cells that could
be upgraded to measure CO2 emissions would cost
approximately $600,000. For manufacturers or suppliers wishing to
contract out such testing, SwRI estimated that a cost of $150,000 would
provide about one month of powertrain testing services. Once a
powertrain test cell is fully operational, we estimate that for a
nominal powertrain family (i.e. one engine family tested with one
transmission family), the cost for powertrain installation, testing,
and data analysis would be about $70,000 in calendar year 2016, in 2016
dollars. Since the NPRM in July 2015, the agencies and other
stakeholders have completed significant new work toward refining the
powertrain test procedure itself, and these results confirm the
robustness of this approach. The agencies regulations provide details
of the final powertrain test procedure. See 40 CFR 1037.550.
---------------------------------------------------------------------------
\135\ Oak Ridge National Laboratory results docketed for the
NODA: EPA-HQ-OAR-2014-0827-1622 and NHTSA-2014-0132-0183. Southwest
Research Institute results docketed for the NODA: EPA-HQ-OAR-2014-
0827-1619 and NHTSA-2014-0132-0184.
\136\ Eaton, Greenhouse gas emissions and fuel efficiency
standards for medium- and heavy-duty engines and vehicles--Phase 2,
80 FED. REG. 40,137--Docket ID NOS. EPA-HQ-OAR-2014-0827, October 1,
2015.
\137\ https://engines.paccar.com/technology/research-development/.
\138\ 03-19034 TASK 2 Report-Paper 03-Class8_hil_DRAFT,
September 30, 2013.
---------------------------------------------------------------------------
Furthermore, the agencies have worked with key transmission
suppliers to develop an approach to define transmission families.
Coupled with the agencies' existing definitions of engine families (40
CFR 1036.230 and 1037.230), we are finalizing powertrain family
definitions in 40 CFR 1037.231 and axle and transmission families in 40
CFR 1037.232.
Even though there is conclusive evidence that powertrain testing is
a
[[Page 73534]]
technically robust and cost-effective approach to evaluating the
CO2 and fuel consumption performance of powertrains, and
even though there has been a clear trend toward manufacturers and other
test laboratories recognizing the benefits and investing in new
powertrain testing facilities, the agencies also received significant
negative comment regarding the sheer amount of powertrain testing that
could be required to certify the large number of unique configurations
(i.e., unique combinations of engines and transmissions). While the
agencies proposed to allow manufacturers to group powertrains in
powertrain families, as defined by the EPA in 40 CFR 1037.231,
requiring powertrain testing broadly would still likely require a large
number of tests. To address these concerns, while at the same time
achieving most of the advantages of powertrain testing, the agencies
are also finalizing some mandatory and optional test procedures to
separately evaluate engine transient performance (via the mandatory
``cycle-average'' approach for the transient cycle) and transmission
efficiency performance. While neither of these test procedures capture
the optimized shift logic and other benefits of deep integration of the
engine and transmission controllers, which only powertrain testing can
capture, these separate test procedures do capture the remaining
benefits of powertrain testing. The advantage of these separate tests
is that their results can be mixed and matched within GEM to represent
many more combinations of engines and transmissions than a comparable
number of powertrain tests. For example, separately testing three
parent engines that each have two child ratings and separately
efficiency testing three transmissions that each have three major
calibrations requires the equivalent test time of testing 6
powertrains, but without requiring the use of a powertrain test
facility. More importantly, the results of these 6 tests can be
combined within GEM to certify at least 27 different powertrain
families, which would otherwise have required 27 powertrain tests--more
than a four-fold increase in costs. This example clearly shows how
cost-effective a vehicle simulation approach to vehicle certification
can be.
Another regulatory structure option considered by the agencies was
engine-only testing over the GEM duty cycles over a range of simulated
vehicle configurations, which is part of Option 4 in Figure II.1. This
is essentially a ``cycle-average approach,'' which would use GEM to
generate engine duty cycles by simulating a range of transmissions and
other vehicle variations. These engine-level duty cycles would then be
programmed into a separate controller of a dynamometer connected to an
engine's output shaft. The agencies requested comment on this approach,
and based on continued research that has been conducted since the
proposal, and based on comments we received in response to the NODA, we
are finalizing this approach as mandatory for determining the GEM
inputs that characterize an engine's transient engine performance
within GEM over the ARB Transient duty cycle. We are also finalizing
this approach as optional for characterizing the more steady-state
engine operation in GEM over the 55 mph and 65 mph duty cycles with
road grade, in lieu of steady-state engine mapping for these two
cycles. We are also finalizing this approach as an option for
certifying pre-transmission hybrids, in lieu of powertrain testing. We
are calling this approach the ``cycle-average'' approach, which
generates a cycle-average engine fuel map that is input into GEM. This
map simulates an engine family's performance over a given vehicle drive
cycle, for the full range of vehicles into which that engine could be
installed. Unlike the chassis dynamometer or powertrain dynamometer
approaches, which could have significant test facility construction or
modification costs, this engine-only approach necessitates little
capital investment because engine manufacturers already have engine
test facilities to both develop engines and to certify engines to meet
both EPA's non-GHG standards and the agencies' Phase 1 fuel efficiency
and GHG separate engine standards. This option has received significant
attention since our notice of proposed rulemaking. EPA and others have
published peer reviewed journal articles demonstrating the efficacy of
this approach,139 140 and the agencies have received
significant comments on both the information we presented in the
proposal and in the NODA. Comments have been predominantly supportive,
and the comments we received tended to focus on ideas for further minor
refinements of this test procedure.136 141 142 143 144 145
At this time the agencies believe that the wealth of experimental data
supporting the robustness and cost-effectiveness of the cycle-average
approach, supports the agencies' decision to finalize this test
procedure as mandatory for the determination of the transient
performance of engines for use in GEM (i.e., over the ARB Transient
Cycle).
---------------------------------------------------------------------------
\139\ H. Zhang, J, Sanchez, M, Spears, ``Alternative Heavy-duty
Engine Test Procedure for Full Vehicle Certification,'' SAE Int. J.
Commer. Veh. 8(2): 2015, doi:10.4271/2015-01-2768.
\140\ G. Salemme, E.D., D. Kieffer, M. Howenstein, M. Hunkler,
and M. Narula, An Engine and Powertrain Mapping Approach for
Simulation of Vehicle CO2 Emissions. SAE Int. J. Commer. Veh,
October 2015. 8: p. 440-450.
\141\ Cummins, Inc., Comments in Response to Greenhouse Gas
Emissions and Fuel Efficiency Standards for Medium- and Heavy-Duty
Engines and Vehicles--Phase 2 (Docket ID No. EPA-HQ-OAR-2014-0827
and Docket ID No. NHTSA-2014-0132).
\142\ Paccar, Inc., Greenhouse Gas Emissions and Fuel Efficiency
Standards for Medium- and Heavy-Duty Engines and Vehicles; Phase 2;
Proposed Rule, 80 FR 40138 (July 13, 2015); Docket I.D. No.: EPA-HQ-
OAR-2014-0827 and NHTSA-2014-0132.
\143\ Daimler Trucks North America LLC, Detroit Diesel
Corporation, And Mercedes-Benz USA, Greenhouse Gas Emissions and
Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and
Vehicles, Phase 2, Proposed Rule, Docket ID No: EPA-HQ-OAR-2014-0827
and NHTSA-2014-0132; 80 FR 40137 (July 13, 2015).
\144\ Volvo Group, Greenhouse Gas Emissions and Fuel Efficiency
Standards for Medium- and Heavy-Duty Engines and Vehicles, Phase 2,
Proposed Rule, Dockets ID No: EPA-HQ-OAR-2014-0827 and NHTSA-2014-
0132;80 FR 40137 (July 13, 2015).
\145\ Navistar, Greenhouse Gas Emissions and Fuel Efficiency
Standards for Medium- and Heavy-Duty Engines and Vehicles, Phase 2,
Proposed Rule, Dockets ID No: EPA-HQ-OAR-2014-0827 and NHTSA-2014-
0132;80 FR 40137 (July 13, 2015).
---------------------------------------------------------------------------
The agencies also considered simulating the engine, transmission,
and vehicle using a computer program; while having the actual
transmission electronic controller connected to the computer running
the vehicle simulation program, which is part of Option 3 in Figure
II.1. The output of the simulation would be an engine cycle that would
be used to test the engine in an engine test facility. Just as in the
cycle-average approach, this procedure would not require significant
capital investment in new test facilities. An additional benefit of
this approach would be that the actual transmission controller would be
determining the transmission gear shift points during the test, without
a transmission manufacturer having to reveal their proprietary
transmission control logic. This approach comes with some significant
technical challenges, however. The computer model would have to become
more complex and tailored to each new transmission and controller to
make sure that the controller would operate properly when it is
connected to a computer instead of an actual transmission. Some
examples of the transmission specific requirements would be simulating
all the Controller Area Network (CAN) communication to and from the
transmission controller and the specific sensor responses both through
simulation and hardware. Each vehicle manufacturer would have to be
[[Page 73535]]
responsible for connecting the transmission controller to the computer,
which would require a detailed verification process to ensure it is
operating properly while it is in fact disconnected from a real
transmission. Determining full compliance with this test procedure
would be a significant challenge for the regulatory agencies because
the agencies would have to be able to replicate each of the
manufacturer's unique interfaces between the transmission controller
and computer running GEM. The agencies did not receive any significant
comments on this approach, presumably because commenters focused on the
more viable options of powertrain testing and the cycle-average engine
mapping approach. And because of the significant challenges noted
above, the agencies did not pursue this option further between the time
of proposal and this final action. However, should this approach
receive more research attention in the future, such that the concerns
noted above are sufficiently addressed, the agencies could consider
allowing this certification approach as an option, within the context
of a separate future rulemaking.
Finally, the agencies considered full vehicle simulation plus
separate engine standards (Option 2 in Figure II.1), which is the
required approach being finalized for Phase 2. This approach is
discussed in more detail in the following sections. It should be noted
before concluding this subsection that the agencies do provide a
regulatory path for manufacturers to apply for approval of alternative
test methods that are different than those the agencies specify. See 40
CFR part 1065, subpart A. Therefore, even though we have not finalized
some of the certification approaches and test procedures that we
investigated, our conclusions about these procedures do not prevent a
manufacturer from seeking agency approval of any of these procedures or
any other alternative procedures.
(2) Final Phase 2 Regulatory Structure
Under the final Phase 2 structure, tractor and vocational chassis
manufacturers will be required to provide engine, transmission, drive
axle(s) and tire inputs into GEM (as well as the inputs already
required under Phase 1). For Phase 1, GEM used fixed default values for
all of these, which limited the types of technologies that could be
recognized by GEM to show compliance with the standards. We are
expanding GEM to account for a wider range of technological
improvements that would otherwise need to be recognized through the
more cumbersome off-cycle crediting approach in Phase 1. Additional
technologies that will now be recognized in GEM also include
lightweight thermoplastic materials, automatic tire inflation systems,
tire pressure monitoring systems, advanced cruise control systems,
electronic vehicle coasting controls, engine stop-start idle reduction
systems, automatic engine shutdown systems, hybrids, and axle
configurations that decrease the number of drive axles. The agencies
are also continuing separate engine standards. As described below, we
see advantages to having both engine-based and vehicle-based standards.
Moreover, the advantages described here for full vehicle simulation do
not necessarily correspond to disadvantages for engine testing or vice
versa.
(a) Advantages of Vehicle Simulation
The agencies' primary purpose in developing fuel efficiency and GHG
emissions standards is to increase the use of vehicle technologies that
improve fuel efficiency and decrease GHG emissions. Under the Phase 1
tractor and vocational chassis standards, there is no regulatory
incentive for vehicle manufacturers to consider adopting new engine,
transmission or axle technologies because GEM was not configured to
recognize these technologies uniquely, leaving off-cycle credits as the
only regulatory mechanism to recognize these technologies' benefits. By
recognizing such technologies in GEM under Phase 2, the agencies will
be creating a direct regulatory incentive to improve engine,
transmission, and axle technologies to improve fuel efficiency and
decrease GHG emissions. In its 2014 report, NAS also recognized the
benefits of full vehicle simulation and recommended that the Phase 2
rules incorporate such an approach.\160\
The new Phase 2 approach will create three new specific regulatory
incentives. First, vehicle manufacturers will have an incentive to use
the most efficient engines. Since GEM will no longer use the agency
default engine in simulation, manufacturers will have their own engines
recognized in GEM. Under Phase 1, engine manufacturers have a
regulatory incentive to design efficient engines, but vehicle
manufacturers do not have a similar regulatory incentive to use the
most efficient engines in their vehicles. Second, the new Phase 2
approach will create incentives for both engine and vehicle
manufacturers to design engines and vehicles to work together to ensure
that engines actually operate as much as possible near their most
efficient points. This is because Phase 2 GEM will require the vehicle
manufacturers to input specific transmission, axle, and tire
characteristics, thus recognizing powertrain optimization, such as
engine down-speeding, and different transmission architectures and
technologies, such as automated manual transmissions, automatic
transmissions, and different numbers of transmission gears,
transmission gear ratios, axle ratios and tire revolutions per mile. No
matter how well designed, all engines have speed and load operation
points with differing fuel efficiency and GHG emissions. The speed and
load point with the best fuel efficiency (i.e., peak thermal
efficiency) is commonly known as the engine's ``sweet spot.'' The more
frequently an engine operates near its sweet spot, the better the
vehicle's fuel efficiency will be. In Phase 1, a vehicle manufacturer
receives no regulatory credit under GEM for designing its vehicle to
operate closer to its engine's sweet spot because Phase 1 GEM does not
model the specific engine, transmission, axle, or tire revolutions per
mile of the vehicle. Third, this approach will recognize improvements
to the overall efficiency of the drivetrain, including the axle. The
new version of GEM will recognize the benefits of different integrated
axle technologies including axle lubricants (via an optional axle
efficiency test), and technologies that reduce axle losses such as by
enabling three-axle vehicles to deliver power to only one rear axle.
This is accomplished through the simulation of axle disconnect
technology (see Chapter 4.5 of the RIA). The new version of GEM also
will be able to recognize the benefits of reducing energy losses within
a transmission, via an optional transmission efficiency test.
In addition to providing regulatory incentives to use more fuel
efficient technologies, expanding GEM to recognize engine and other
powertrain component improvements will provide important flexibility to
vehicle manufacturers. Providing flexibility to effectively trade
engine and other powertrain component improvements against the other
vehicle improvements that are recognized in GEM will allow vehicle
manufacturers to better optimize their vehicles to achieve the lowest
cost for specific customers. Because of the improvements in GEM, GEM
will recognize this deeper level of vehicle optimization. Vehicle
manufacturers could use this flexibility to reduce overall compliance
costs and/or address special applications where certain vehicle
technologies are not preferred or
[[Page 73536]]
practical. The agencies considered in Phase 1 allowing the exchange of
emission certification credits generated relative to the separate
brake-specific engine standards and credits generated relative to the
vehicle standards. However, we did not allow this in Phase 1 due in
part to concerns about the equivalency of credits generated relative to
different standards, with different units of measure and different test
procedures. The Phase 2 approach eliminates these concerns because
engine and other vehicle component improvements will be evaluated
relative to the same vehicle standard in GEM. This also means that
under the Phase 2 approach there is no need to consider allowing
emissions credit trading between engine-generated and vehicle-generated
credits because vehicle manufacturers are directly credited by the
combination of engine and vehicle technologies they choose to install
in each vehicle. Therefore, this approach eliminates one of the
concerns about continuing separate engine standards, which was that a
separate engine standard and a full vehicle standard were somehow
mutually exclusive. That is not the case. In fact, in the next section
we describe how we are continuing the separate engine standard along
with recognizing engine performance at the vehicle level. The agencies
acknowledge that maintaining a separate engine standard will limit
flexibility in cases where a vehicle manufacturer wanted to use less
efficient engines and make up for them using more efficient vehicle
technologies. However, as described below, we see important advantages
to maintaining a separate engine standard, and we believe they more
than justify the reduced flexibility. Furthermore, in response to
comments about some specialized vocational custom chassis, the agencies
are finalizing a limited number of optional standards that would be met
using a somewhat simplified version of GEM. Specifically, in this
simplified version of GEM, which is only applicable as an option for
certain custom chassis applications, the GEM inputs for the engine,
transmission gears, gear ratios, gear efficiency; axle ratio, axle
efficiency; and tire revolutions per mile are all fixed to default
values. This simplification allows the option of certifying these
custom chassis without penalty for utilizing less efficient engines,
transmissions, or axles. This flexibility also addresses a comment the
agencies received from Cummins that the inclusion of the specific
engine in GEM limits the flexibility provided by the separate engine
standards' emissions averaging, banking and trading program. Cummins
explained that certain applications like emergency vehicles, cement
mixers and recreational vehicles oftentimes require higher-performance,
less-efficient, engines, which are credit using engines under the ABT
program of the separate engine standards. Because these particular
vehicle applications have few other cost-effective and practical
vehicle-level technologies with which to offset their use of less
efficient engines, the main Phase 2 vocational chassis standards that
require engine and other powertrain inputs into GEM (i.e., the
standards for other than custom chassis vocational vehicles) could be
particularly challenging for these applications. However, the optional
custom chassis standards solves this issue for custom chassis
applications. This approach solves two issues. First, it provides a
means toward certification for these custom chassis applications,
without penalty for using the engines they need. Second, this approach
maintains the flexibility intended by the separate engine standards'
averaging, banking and trading program since these custom chassis
applications would still be using certified engines.
One disadvantage of recognizing engines and transmission in GEM is
that it will increase complexity for the vehicle standards. For
example, vehicle manufacturers will be required to conduct additional
engine tests and to generate additional GEM inputs for compliance
purposes. However, we believe that most of the burden associated with
this increased complexity will be an infrequent burden of engine
testing and updating information systems to track these inputs.
Furthermore, the agencies are requiring that engine manufacturers
certify their respective GEM inputs; namely, their own engine maps.
Because there are a relatively small number of heavy-duty engine
manufacturers who will be responsible for generating and complying with
their declared engine maps for GEM, the overall engine testing burden
to the heavy-duty vehicle industry is small. With this approach, the
large number of vocational chassis manufacturers will not have to
conduct any engine testing.
Another potential disadvantage to GEM-based vehicle certification
is that because GEM measures performance over specific duty cycles
intended to represent average operation of vehicles in-use, this
approach might also create an incentive to optimize powertrains and
drivetrains for the best GEM performance rather than the best in-use
performance for a particular application. This is always a concern when
selecting duty cycles for certification, and so is not an issue unique
to GEM. There will always be instances, however infrequent, where
specific vehicle applications will operate differently than the duty
cycles used for certification. The question is would these differences
force manufacturers to optimize vehicles to the certification duty
cycles in a way that decreases fuel efficiency and increases GHG
emissions in-use? We believe that the certification duty cycles will
not create a disincentive for manufacturers to properly optimize
vehicles for customer fuel efficiency. First, the impact of the
certification duty cycles versus any other real-world cycle will be
relatively small because they affect only a small fraction of all
vehicle technologies. Second, the emission averaging and fleet average
provisions mean that the regulations will not require all vehicles to
meet the standards. Vehicles exceeding a standard over the duty cycles
because they are optimized for different in-use operation can be offset
by other vehicles that perform better over the certification duty
cycles. Third, vehicle manufacturers also have the ability to lower
such a vehicle's measured GHG emissions by adding technology that would
improve fuel efficiency both over the certification duty cycles and in-
use (and to be potentially eligible to generate off-cycle credits in
doing so). These standards are not intended to be at a stringency where
manufacturers will be expected to apply all technologies to all
vehicles. Thus, there should be technologies available to add to
vehicle configurations that initially fail to meet the Phase 2
standards. Fourth, we are further sub-categorizing the vocational
vehicle segment compared to Phase 1, tripling the number of
subcategories within this segment from three to nine. These nine
subcategories will divide each of the three Phase 1 weight categories
into three additional vehicle speed categories. Each of the three speed
categories will have unique duty cycle weighting factors to recognize
that different vocational chassis are configured for different vehicle
speed applications. This further subdivision better recognizes
technologies' performance under the conditions for which the vocational
chassis was configured to operate. This also decreases the potential of
the certification duty cycles to encourage manufacturers to configure
vocational chassis differently than the optimum configuration for
specific customers' applications. Similarly, for the tractor
[[Page 73537]]
category we are finalizing a new ``heavy-haul'' category to recognize
the greater payload and vehicle mass of these tractors, as well as
their limitations to effectively utilize some technologies like
aerodynamic technologies. These new categories help minimize
differences between GEM simulation and real-world operation. Finally,
we are also recognizing seven specific vocational vehicle applications
under the optional custom chassis vocational vehicle standards.
Another disadvantage of our full vehicle simulation approach is the
potential requirement for engine manufacturers to disclose information
to vehicle manufacturers who install their engines that engine
manufacturers might consider to be proprietary. Under this approach,
vehicle manufacturers may need to know some additional details about
engine performance long before production, both for compliance planning
purposes, as well as for the actual submission of applications for
certification. Moreover, vehicle manufacturers will need to know
details about the engine's performance that are generally not publicly
available--specifically the detailed steady-state fuel consumption map
of an engine. Some commenters expressed significant concern about the
Phase 2 program forcing the disclosure of proprietary steady-state
engine performance information to business competitors; especially
prior to an engine being introduced into commerce. It can be argued
that a sufficiently detailed steady-state engine map, such as the one
required for input into GEM, can reveal proprietary engine design
elements such as intake air, turbo-charger, and exhaust system design;
exhaust gas recirculation strategies; fuel injection strategies; and
exhaust after-treatment thermal management strategies. Conversely, the
agencies also received comments requesting that all GEM inputs be made
public, as a matter of transparency and public interest.
It is unclear at this point whether such information is truly
proprietary. In accordance with Federal statutes, EPA does not release
information from certification applications (or other compliance
reports) that we determine to be Confidential Business Information
(CBI) under 40 CFR part 2. Consistent with section 114(c) of the CAA,
EPA does not consider emission test results to be CBI after
introduction into commerce of the certified engine or vehicle. However,
we have generally treated test results as protected before a product's
introduction into commerce date. EPA has not yet made a final CBI
determination for Phase 1 or Phase 2 GEM inputs. Nevertheless, at this
time we expect to continue our current policy of non-disclosure prior
to introduction into commerce, but we consider it likely that we would
ultimately not treat any test results or other GEM inputs as CBI after
the introduction into commerce date, as identified by the manufacturer.
To further address the specific concern about the Phase 2 program
forcing the disclosure of proprietary steady-state engine maps to
business competitors, especially prior to an engine being introduced
into commerce, the agencies are finalizing an option for engine
manufacturers to certify only ``cycle average'' engine maps over the
55-mph and 65-mph GEM cycles and separately mandating the cycle average
approach for use over the ARB Transient cycle. See Section II.B. above.
The advantage to this approach is that each data point of a cycle
average map represents the average emissions over an entire cycle.
Therefore, the cycle average engine map approach does not reveal any
potentially proprietary information about an engine's performance at a
particular steady-state point of operation.
(b) Advantages of Separate Engine Standards
For engines installed in tractors and vocational vehicle chassis,
we are maintaining separate engine standards for fuel consumption and
GHG emissions in Phase 2 for both spark-ignition (SI, generally but not
exclusively gasoline-fueled) and compression-ignition (CI, generally
but not exclusively diesel-fueled) engines. Moreover, we are adopting a
sequence of new more stringent engine standards for CI engines for
engine model years 2021, 2024 and 2027. While the vehicle standards
alone are intended to provide sufficient incentive for improvements in
engine efficiency, we continue to see important advantages to
maintaining separate engine standards for both SI and CI engines. The
agencies believe the advantages described below are critical to fully
achieve the goals of the EPA and NHTSA standards.
First, EPA has a robust compliance program based on separate engine
testing. For the Phase 1 standards, we applied the existing criteria
pollutant compliance program to ensure that engine efficiency in actual
use reflected the improvements manufacturers claimed during
certification. With engine-based standards, it is straightforward to
hold engine manufacturers accountable by testing in-use engines in an
engine dynamometer laboratory. If the engines exceed the standards,
manufacturers can be required to correct the problem or perform other
remedial actions. Without separate engine standards in Phase 2,
addressing in-use compliance would be more subjective. Having clearly
defined compliance responsibilities is important to both the agencies
and to the manufacturers.
Second, engine standards for CO2 and fuel efficiency
force engine manufacturers to optimize engines for both fuel efficiency
and control of non-CO2 emissions at the same engine
operating points. This is of special concern for NOX
emissions, given the strong counter-dependency between engine-out
NOX emissions and fuel consumption. By requiring engine
manufacturers to comply with both NOX and CO2
standards using the same test procedures, the agencies ensure that
manufacturers include technologies that can be optimized for both,
rather than alternate, calibrations that would trade NOX
emissions against fuel consumption, depending how the engine or vehicle
is tested. In the past, when there was no CO2 engine
standard and no steady-state NOX standard, some
manufacturers chose this dual calibration approach instead of investing
in technology that would allow them to simultaneously reduce both
CO2 and NOX.
It is worth noting that these first two advantages foster fair
competition within the marketplace. In this respect, the separate
engine standards help assure manufacturers that their competitors are
not taking advantage of regulatory ambiguity. The agencies believe that
the absence of separate engine standards would leave open the
opportunity for a manufacturer to choose a high-risk compliance
strategy by gaming the NOX-CO2 tradeoff.
Manufacturer concerns that competitors might take advantage of this can
create a dilemma for those who wish to fully comply, but also perceive
shareholder pressure to choose a high-risk compliance strategy to
maintain market share.
Finally, the existence of meaningful separate engine standards
allows the agencies to exempt certain vehicles from some or all of the
vehicle standards and requirements without forgoing the engine
improvements. A good example of this is the off-road vehicle exemption
in 40 CFR 1037.631 and 49 CFR 535.3, which exempts vehicles ``intended
to be used extensively in off-road environments'' from the vehicle
requirements. The engines used in such vehicles must still meet the
engine standards of 40 CFR 1036.108 and 49 CFR 535.5(d). The agencies
see no
[[Page 73538]]
reason why efficient engines cannot be used in such vehicles. However,
without separate engine standards, there would be no way to require the
engines to be efficient. The engine standards provide a similar benefit
with respect to the custom chassis program discussed in Section V.
In the past there has been some confusion about the Phase 1
separate engine standards somehow preventing the recognition of engine-
vehicle optimization that vehicle manufacturers perform to minimize a
vehicle's overall fuel consumption. It was not the existence of
separate engine standards that prevented recognition of this
optimization. Rather it was that the agencies did not allow
manufacturers to enter inputs into GEM that characterized unique engine
performance. For Phase 2 we are requiring that manufacturers input such
data because we intend for GEM to recognize this engine-vehicle
optimization. The continuation of separate engine standards in Phase 2
does not undermine in any way the recognition of this optimization in
GEM.
C. Phase 2 GEM and Vehicle Component Test Procedures \146\
---------------------------------------------------------------------------
\146\ The specific version of GEM used to develop these
standards, and which we propose to use for compliance purposes is
also known as GEM 3.0.
---------------------------------------------------------------------------
GEM was originally created for the certification of tractors and
vocational vehicle chassis to the agencies' Phase 1 CO2 and
fuel efficiency standards. See 76 FR 57116, 57146, and 57156-57157. For
Phase 2 the agencies proposed a number of modifications to GEM, and
based on public comments in response to the agencies' proposed
modifications, the agencies have further refined these modifications
for this final action.
In Phase 1 the agencies adopted a regulatory structure where
regulated entities are required to use GEM to simulate and certify
tractors and vocational vehicle chassis. This computer program is
provided free of charge for unlimited use, and the program may be
downloaded by anyone from EPA's Web site: http://www3.epa.gov/otaq/climate/gem.htm. GEM mathematically combines the results of a number of
performance tests of certain vehicle components, along with other pre-
determined vehicle attributes and driving patterns to determine a
vehicle's characteristic levels of fuel consumption and CO2
emissions, for certification purposes. For Phase 1, the required inputs
to GEM for tractors include vehicle aerodynamics information, tire
rolling resistance, and whether or not a vehicle is equipped with
certain lightweight high-strength steel or aluminum components, a
tamper-proof speed limiter, or tamper-proof idle reduction
technologies. For Phase 1, the sole input for vocational vehicles is
tire rolling resistance. For Phase 1, the computer program's inputs did
not include engine test results or attributes related to a vehicle's
powertrain; namely, its transmission, drive axle(s), or tire
revolutions per mile. Instead, for Phase 1 the agencies specified
generic engine and powertrain attributes within GEM. For Phase 1 these
are fixed and cannot be changed in GEM.\147\
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\147\ These attributes are recognized in Phase 1 innovative
technology provisions at 40 CFR 1037.610.
---------------------------------------------------------------------------
Similar to other vehicle simulation computer programs, GEM combines
various vehicle inputs with known physical laws and justified
assumptions to predict vehicle performance for a given period of
vehicle operation. GEM represents this information numerically, and
this information is integrated as a function of time to calculate
CO2 emissions and fuel consumption. Some of the justified
assumptions in GEM include average energy losses due to friction
between moving parts of a vehicle's powertrain; the logical behavior of
an average driver shifting from one transmission gear to the next; and
speed limit assumptions such as 55 miles per hour for urban highway
driving and 65 miles per hour for rural interstate highway driving. The
sequence of the GEM vehicle simulation can be visualized by imagining a
human driver initially sitting in a parked running tractor or
vocational vehicle. The driver then proceeds to drive the vehicle over
a prescribed route that includes three distinct patterns of driving:
Stop-and-go city driving, urban highway driving, and rural interstate
highway driving. The driver then exits the highway and brings the
vehicle to a stop, with the engine still running at idle. This
concludes the vehicle simulation sequence.
Over each of the three driving patterns or ``duty cycles,'' GEM
simulates the driver's behavior of pressing the accelerator, coasting,
or applying the brakes. GEM also simulates how the engine operates as
the gears in the vehicle's transmission are shifted and how the
vehicle's weight, aerodynamics, and tires resist the forward motion of
the vehicle. GEM combines the driver behavior over the duty cycles with
the various vehicle inputs and other assumptions to determine how much
fuel must be consumed to move the vehicle forward at each point during
the simulation. For Phase 2 the agencies added the effect of road
grade. In GEM the effect of road grade on fuel consumption is simulated
by increasing fuel consumption uphill, by the amount of fuel consumed
by the engine to provide the power needed to raise the mass of the
vehicle and its payload against the force of Earth's gravity--while at
the same time maintaining the duty cycle's vehicle speed. Downhill road
grades are simulated by decreasing the engine's fuel consumption, by
the amount of power returned to the vehicle by it moving in the same
direction as Earth's gravity. To maintain vehicle speed downhill,
simulated brakes are sometimes applied, and the energy lost due to
braking results in a certain amount of fuel consumption as well. For
each of the three duty cycles, GEM totals the amount of fuel consumed
and then divides that amount by the product of the miles travelled and
tons of payload carried. The tons of payload carried are specified by
the agencies for each vehicle type and weight class, and these cannot
be changed in GEM.
In addition to determining fuel consumption over these duty cycles,
for Phase 2, GEM calculates a vehicle's fuel consumption rate when it
is stopped in traffic with the driver still operating the vehicle
(i.e., ``drive idle'') and when the vehicle is stopped and parked with
the engine still running (i.e., ``parked idle''). For each regulatory
subcategory of tractor and vocational vehicle (e.g., sleeper cab
tractor, day cab tractor, light heavy-duty urban vocational vehicle,
heavy heavy-duty regional vocational vehicle, etc.), GEM applies the
agencies' prescribed weighting factors to each of the three duty cycles
and to each of the two idle fuel consumption rates to represent the
fraction of city driving, urban highway driving, rural highway driving,
drive idle, and parked idle that is typical of each subcategory. After
combining the weighted results of all the cycles and idle fuel rates,
GEM then outputs a single composite result for the vehicle, expressed
as both fuel consumed in gallon per 1,000 ton-miles (for NHTSA
standards) and an equivalent amount of CO2 emitted in grams
per ton-mile (for EPA standards). These are the vehicle's GEM results
that are used along with other information to demonstrate that a
vehicle certificate holder (e.g., a vehicle manufacturer) complies with
the applicable standards. This other information includes the annual
sales volume of the vehicle family, plus information on emissions
credits that may be generated or used as
[[Page 73539]]
part of that vehicle family's certification.
For Phase 1 GEM's tractor inputs include vehicle aerodynamics
information, tire rolling resistance, and whether or not a vehicle is
equipped with lightweight materials, a tamper-proof speed limiter, or
tamper-proof idle reduction technologies. Other vehicle and engine
characteristics in GEM were fixed as defaults that cannot be altered by
the user. These defaults included tabulated data of engine fuel rate as
a function of engine speed and torque (i.e., ``engine fuel maps''),
transmissions, axle ratios, and vehicle payloads. For tractors, Phase 1
GEM simulates a tractor pulling a standard trailer. For vocational
vehicles, Phase 1 GEM includes a fixed aerodynamic drag coefficient and
vehicle frontal area.
For Phase 2 new inputs are required and other new inputs are
allowed as options. These include the outputs of new test procedures to
``map'' an engine to generate steady-state and transient, cycle-
average, engine fuel rate inputs to represent the actual engine in a
vehicle. As described in detail in RIA Chapter 4, certification to the
Phase 2 standards will require entering new inputs into GEM to describe
the vehicle's transmission type and its number of gears and gear
ratios. Manufacturers must also enter attributes that describe the
vehicle's drive axle(s) type, axle ratio and tire revolutions per mile.
We are also finalizing a number of options to conduct additional
component testing for the purpose of replacing some of the agencies'
``default values'' in GEM with inputs that are based on component
testing. These include optional axle and transmission power loss test
procedures. We are also finalizing an optional powertrain test
procedure that would replace both the required engine mapping and the
agencies' default values for a transmission and its automated shift
strategy. We are also finalizing an option to generate cycle-average
maps for the 55 mph and 65 mph cycles in GEM. In addition, we have made
a number of improvements to the aerodynamic coast-down test procedures
and associated aerodynamic data analysis techniques. While these
aerodynamic test and data analysis improvements are primarily intended
for tractors, for Phase 2 we are providing a streamlined off-cycle
credit pathway for vocational vehicle aerodynamic performance to be
recognized in GEM.
As proposed, we are finalizing a significantly expanded number of
technologies that are recognized in GEM. These include recognizing
lightweight thermoplastic materials, automatic tire inflation systems,
advanced cruise control systems, workday idle reduction systems, and
axle configurations that decrease the number of drive axles. In
response to comments and data submitted to the agencies on the Phase 2
proposal we are also finalizing inputs related to tire pressure
monitoring systems and advanced electronically controlled vehicle coast
systems.
Although GEM is similar in concept to a number of other
commercially available vehicle simulation computer programs, the
applicability of GEM is unique. First, GEM was designed exclusively for
manufacturers and regulated entities to certify tractor and vocational
vehicle chassis to the agencies' fuel consumption and CO2
emissions standards. For GEM to be effective for this purpose, the
inputs to GEM include only information related to certain vehicle
components and attributes that significantly impact vehicle fuel
efficiency and CO2 emissions. For example, these include
vehicle aerodynamics, tire rolling resistance, and powertrain component
information. On the other hand, other attributes such as those related
to a vehicle's suspension, frame strength, or interior features are not
included, where these otherwise might be included in other commercially
available vehicle simulation programs that are used for other purposes.
Furthermore, the simulated payload, driver behavior and duty cycles in
GEM cannot be changed. Keeping these values constant helps to ensure
that all vehicles are simulated and certified in the same way. However,
these fixed attributes in GEM largely preclude GEM from being of much
use as a research tool for exploring the effects of payload, driver
behavior and different duty cycles.
Similar to Phase 1, GEM for Phase 2 is available free of charge for
unlimited use, and the GEM source code is open source. That is, the
programming source code of GEM is freely available upon request for
anyone to examine, manipulate, and generally use without restriction.
In contrast, commercially available vehicle simulation programs are
generally not free and open source. Additional details of GEM are
included in Chapter 4 of the RIA.
GEM is a computer software program, and like all other software
development processes the agencies periodically released a number of
developmental versions of the GEM software for others to review and
test during the Phase 2 rulemaking process. This type of user testing
significantly helps the agencies detect and fix any problems or
``bugs'' in the GEM software.
As part of Phase 1, the agencies conducted a peer review of GEM
version 1.0, which was the version released for the Phase 1
proposal.148 149 In response to this peer review and to
comments from stakeholders, EPA made changes to the version of GEM
released with the Phase 1 final rule. Updates to the Phase 1 GEM were
also made via Technical Amendments.\150\ The current version of Phase 1
GEM is v2.0.1, which is the version applicable for the Phase 1
standards.\150\ As part of the development of GEM for Phase 2, both a
formal peer review \149\ and a series of expert reviews were
conducted.151 152 153 154
---------------------------------------------------------------------------
\148\ See 76 FR 57146-57147.
\149\ U.S. Environmental Protection Agency. ``Peer Review of the
Greenhouse Gas Emissions Model (GEM) and EPA's Response to
Comments.'' EPA-420-R-11-007. Last access on November 24, 2014 at
http://www3.epa.gov/otaq/climate/documents/420r11007.pdf.
\150\ See EPA's Web site at http://www3.epa.gov/otaq/climate/gem.htm for the Phase 1 GEM revision dated May 2013, made to
accommodate a revision to 49 CFR 535.6(b)(3).
\151\ U.S. Environmental Protection Agency, GEM new release (GEM
P2v1.1) and known issues and workarounds for GEM P2v1.0), Greenhouse
Gas Emissions Standards and Fuel Efficiency Standards for Medium-
and Heavy-Duty Engines and Vehicles--Phase 2--EPA-HQ-OAR-2014-0827,
August 19, 2015.
\152\ U.S. Environmental Protection Agency, GEM Power User
Release for Debugging, Greenhouse Gas Emissions Standards and Fuel
Efficiency Standards for Medium- and Heavy-Duty Engines and
Vehicles--Phase 2--EPA-HQ-OAR-2014-0827, January 27, 2016.
\153\ U.S. Environmental Protection Agency, GEM NODA Release,
Greenhouse Gas Emissions Standards and Fuel Efficiency Standards for
Medium- and Heavy-Duty Engines and Vehicles--Phase 2--EPA-HQ-OAR-
2014-0827, February 16, 2016.
\154\ U.S. Environmental Protection Agency, GEM Power User
Release for Debugging, Greenhouse Gas Emissions Standards and Fuel
Efficiency Standards for Medium- and Heavy-Duty Engines and
Vehicles--Phase 2--EPA-HQ-OAR-2014-0827, May 19, 2016.
---------------------------------------------------------------------------
The agencies have provided numerous opportunities for comment on
GEM, and its iterative development. Shortly after the Phase 2
proposal's publication in July 2015 (and before the end of the public
comment period), the agencies received comments on GEM. Based on these
early comments, the agencies made minor revisions to fix a few bugs in
GEM and in August 2015 released an updated version of GEM to the public
for additional comment, which also included new information on GEM road
grade profiles. The agencies also extended the public comment period on
the proposal, which provided at least 30 days for public comment on
this slightly updated version of GEM.\153\ Then, in response to
comments submitted at the close of the comment period, in early January
2016
[[Page 73540]]
the agencies released a ``debugging'' version of GEM to a wide range of
expert reviewers.\152\ The agencies provided one month for expert
reviewers to provide informal feedback for debugging purposes.\152\
Because the changes for this debugging version mostly added new
features to make GEM easier to use for certifying via optional test
procedures, like the powertrain test, there were only minor changes to
the way that GEM performed. In the March 2016 NODA, the agencies
included another developmental version of GEM \153\ for public comment
and provided 30 days for public comment. Based on the NREL report,
which was also released as part of the NODA for public comment, the
NODA version of GEM contained updated weighting factors of the duty
cycles and idle cycles.\155\ Therefore, the outputs of GEM for a given
vehicle configuration changed because these duty cycle weighting
factors changed, but there were only minor updates to how the
individual technologies were simulated in GEM. Based on comments
received on the NODA, the agencies made minor changes to GEM and
released another debugging version in May 2016 to manufacturers, NGOs,
suppliers, and CARB staff.\154\ The most significant change to GEM for
the May 2016 version was that 0.5 miles of flat road was added to the
beginning and end of the 55 mph and 65 mph drive cycles in response to
concerns raised by manufacturers.\156\ This change did not change the
way that GEM worked, but it did change GEM results because of the
change in the duty cycles. This change was made to better align GEM
simulation with real-world engine operation. The agencies provided the
expert reviewers with at least a 3-week period in which to review GEM
and provide feedback. Details on the history of the comments the
agencies received and the history of the agencies responses leading to
these multiple releases of GEM can be found in Section II.C.(1). The
following list summarizes the changes in GEM in response to those
comments and data submitted to the agencies in response to the Phase 2
proposal, NODA and other GEM releases:
---------------------------------------------------------------------------
\155\ EPA-HQ-OAR-2014-0827-1621 and NHTSA-2014-0132-0187.
\156\ Memo to Docket, ``Summary of Meetings and Conference Calls
with the Truck and Engine Manufacturers Association to Discuss the
Phase 2 Heavy-Duty GHG Rulemaking'', August 2016.
---------------------------------------------------------------------------
Revised road grade profiles for 55- and 65-mph cruise
cycles, only minor changes since August 2015.
Revised idle cycles for vocational vehicles with new
vocational cycle weightings, weightings released for public comment in
NODA.
Made changes to the input file structures. Examples
includes additions of columns for axle configuration (``6x2,'' ``6x4,''
``6x4D,'' ``4x2''), and additions of a few more technology improvement
inputs, such as ``Neutral Idle,'' ``Start/Stop,'' and ``Automatic
Engine Shutdown.'' These were minor changes, all were in NODA version
of GEM.
Made changes to the output file structures. Examples
include an option to allow the user to select an output of detailed
results on average speed, average work at the input and output of the
transmission, and the numbers of shifts for each cycle (e.g., 55 mph
cycle, 65 mph cycle and the ARB Transient cycle). These were minor
changes, all were in NODA version of GEM.
Added an input file for optional axle power losses
(function of axle output speed and torque) and replaced a single axle
efficiency value with lookup table of power loss. These were minor
changes to streamline the use of GEM, all were in NODA version of GEM.
Modified engine torque response to be more realistic, with
a fast response region scaled by engine displacement, and a slower
torque response in the turbo-charger's highly boosted region. These
were minor changes, all were in NODA version of GEM.
Added least-squares regression models to interpret cycle-
average fuel maps for all cycles. These were minor changes to
streamline the use of GEM, all were in NODA version of GEM.
Added different fuel properties according to 40 CFR
1036.530. This was a fix to align GEM with regulations.
Improved shift strategy based on testing data and comments
received. These were minor changes, all were in NODA version of GEM.
Added scaling factors for transmission loss and inertia,
per regulatory subcategory. These were minor changes, all were in NODA
version of GEM.
Added optional input table for transmission power loss
data. These were minor changes to streamline the use of GEM, all were
in NODA version of GEM.
Added minimum torque converter lock-up gear user input for
automatic transmissions. This was a minor change to streamline the use
of GEM, this change was in the NODA version of GEM.
Revised the default transmission power loss tables, based
on test data. This was a minor change to streamline the use of GEM,
this change was in the NODA version of GEM.
Added neutral idle and start/stop effects idle portions of
the ARB Transient cycle. These were minor changes, all were in NODA
version of GEM
Adjusted shift and torque converter lockup strategy. This
was a minor change to streamline the use of GEM, this change was in the
NODA version of GEM.
Notwithstanding these numerous opportunities for public comment (as
well as many informal opportunities via individual meetings), some
commenters maintained that they still had not received sufficient
notice to provide informed comment because each proposal represented
too much of a ``moving target.'' 157 158 159 The agencies
disagree. Even at proposal, Phase 2 GEM provided nearly all of the
essential features of the version we are promulgating in final form.
These include: (1) The reconfiguration of the engine, transmission, and
axle sub-models to reflect additional designs and to receive
manufacturer inputs; and (2) the addition of road grade and idle cycles
for vocational vehicles, along with revised weighting factors.
Moreover, the changes the agencies have made to GEM in response to
public comment indicates that those comments were highly informed by
the proposal. The agencies thus do not accept the contention that
commenters were not afforded sufficient information to provide
meaningful comment on GEM.
---------------------------------------------------------------------------
\157\ Memo to Docket, ``Summary of Meetings and Conference Calls
with the Truck and Engine Manufacturers Association to Discuss the
Phase 2 Heavy-Duty GHG Rulemaking'', August 2016.
\158\ Memo to Docket, ``Summary of Meetings and Conference Calls
with Allison Transmission to Discuss the Phase 2 Heavy-Duty GHG
Rulemaking'', August 2016.
\159\ ``Heavy-Duty Phase 2 Stakeholder Meeting Log'', August
2016.
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(1) Description of Modifications to GEM From Phase 1 to Phase 2
As explained above, GEM is a computer program that was originally
developed by EPA specifically for manufacturers to use to certify to
the Phase 1 tractor and vocational chassis standards. GEM
mathematically combines the results of vehicle component test
procedures with other vehicle attributes to determine a vehicle's
certified levels of fuel consumption and CO2 emissions.
Again as explained above, for Phase 1 the required inputs to GEM
include vehicle aerodynamics information, tire rolling resistance, and
whether or not a vehicle is equipped with certain lightweight
[[Page 73541]]
high-strength steel or aluminum components, a tamper-proof speed
limiter, or tamper-proof idle reduction technologies for tractors. The
vocational vehicle inputs to GEM for Phase 1 only included tire rolling
resistance. For Phase 1 GEM's inputs did not include engine test
results or attributes related to a vehicle's powertrain; namely, its
transmission, drive axle(s), or loaded tire radius. Instead, for Phase
1 the agencies specified a generic engine and powertrain within GEM,
and for Phase 1 these cannot be changed in GEM.
For this rulemaking, GEM has been modified as proposed and
validated against a set of experimental data that represent over 130
unique vehicle variants conducted at powertrain and chassis
dynamometers with the manufacturers' provided transmission shifting
tables. In addition, GEM has been validated against different types of
tests when the EPA transmission default auto-shift strategy is used,
which includes powertrain dynamometer tests and two truck tests running
in a real-world driving route. Detailed comparisons can be seen in
Chapter 4 of the RIA. As noted above, the agencies believe that this
new version of GEM is an accurate and cost-effective alternative to
measuring fuel consumption and CO2 over a chassis
dynamometer test procedure. Again as noted earlier, some of the key
modifications will require additional vehicle component test procedures
(both mandatory and optional) to generate additional GEM inputs. The
results of which will provide additional inputs into GEM. These include
a new required engine test procedure to provide engine fuel consumption
inputs into GEM. We proposed to measure fuel consumption as a matrix of
steady-state points, but also sought comment on a newly developed
engine test procedure that captures transient engine performance for
use in GEM. We are specifying a combination of these procedures for the
final rule--steady-state fuel maps for the highway cruise simulations,
and cycle-average maps for transient simulations. As an option, cycle
average maps could be also used for the highway cruise simulation as
well. See Chapter 3 of the RIA for additional discussion of the fuel
mapping procedures. We are also requiring inputs that describe the
vehicle's transmission type, and its number of gears and gear ratios.
We are allowing an optional powertrain test procedure that would
provide inputs to override the agencies' simulated engine and
transmission in GEM. In addition, in response to comments, we will also
allow manufacturers to measure transmission efficiency in the form of
the power loss tables to replace the default values in GEM. We are
finalizing the proposed requirement to input a description of the
vehicle's drive axle(s), including its type (e.g., 6x4 or 6x2) and axle
ratio. We are also finalizing the optional axle efficiency test
procedure for which we sought comment. This would allow manufacturers
to override the agencies' simulated axle in GEM. Chapter 4 of the RIA
details all of these GEM related input changes.
As noted above, we are significantly expanding the number of
technologies that are recognized in GEM. These include recognizing
lightweight thermoplastic materials, automatic tire inflation systems,
advanced cruise control systems, engine stop-start idle reduction
systems, and axle configurations that decrease the number of drive
axles. To better reflect real-world operation, we are also revising the
vehicle simulation computer program's urban and rural highway duty
cycles to include changes in road grade, and including a new duty cycle
to capture the performance of technologies that reduce the amount of
time a vehicle's engine is at idle during a workday. Finally, to better
recognize that vocational vehicle powertrains are configured for
particular applications, we are further subdividing the vocational
chassis category into three different vehicle speed categories, where
GEM weights the individual duty cycles' results of each of the speed
categories differently. Section 4.2 of the RIA details all these
modifications. The following sub-sections provide further details on
some of these key modifications to GEM.
(a) Simulating Engines for Vehicle Certification
Before describing the Phase 2 approach, this section first reviews
how engines are simulated for vehicle certification in Phase 1. As
noted earlier, GEM for Phase 1 simulates the same generic engine for
any vehicle in a given regulatory subcategory with a data table of
steady-state engine fuel consumption mass rates (g/s) versus a series
of steady-state engine output shaft speeds (revolutions per minute,
rpm) and loads (torque, N[middot]m). This data table is also sometimes
called a ``fuel map'' or an ``engine map,'' although the term ``engine
map'' can mean other kinds of data in different contexts. The engine
speeds in this map range from idle to maximum governed speed and the
loads range from engine motoring (negative load) to the maximum load of
an engine. When GEM executes a simulation over a vehicle duty cycle,
this data table is linearly interpolated to find a corresponding fuel
consumption mass rate at each engine speed and load that is demanded by
the simulated vehicle operating over the duty cycle. The fuel
consumption mass rate of the engine is then integrated over each duty
cycle in GEM to arrive at the total mass of fuel consumed for the
specific vehicle and duty cycle. Under Phase 1, manufacturers were not
allowed to input their own engine fuel maps to represent their specific
engines in the vehicle being simulated in GEM. Because GEM was
programmed with fixed engine fuel maps for Phase 1 that all
manufacturers had to use, the tables themselves did not have to exactly
represent how an actual engine might operate over these three different
duty cycles.
In contrast, for Phase 2 we are requiring manufacturers to generate
their own engine fuel maps to represent each of their engine families
in GEM. This Phase 2 approach is consistent with the 2014 NAS Phase 2
First Report recommendation.\160\ To investigate this approach, before
proposal we examined the results from 28 individual engine dynamometer
tests. Three different engines were used to generate this data, and
these engines were produced by two different engine manufacturers. One
engine was tested at three different power ratings (13 liters at 410,
450 & 475 bhp) and one engine was tested at two ratings (6.7 liters at
240 and 300 bhp), and other engine with one rating (15 liters 455 bhp)
service classes. For each engine and rating the steady-state engine
dynamometer test procedure was conducted to generate an engine fuel map
to represent that particular engine in GEM. Next, with GEM, we
simulated various vehicles in which the engine could be installed. For
each of the GEM duty cycles we are using, namely the urban local (ARB
Transient), urban highway with road grade (55 mph), and rural highway
with road grade (65 mph) duty cycles, we determined the GEM result for
each vehicle configuration, and we saved the engine output shaft speed
and torque information that GEM created to interpolate the steady-state
engine map for each vehicle configuration We then had this same engine
output shaft speed and torque information programmed into an engine
dynamometer controller, and we had each engine perform the same duty
cycles that GEM demanded of the
[[Page 73542]]
simulated version of the engine. We then compared the GEM results based
on GEM's linear interpolation of the engine maps to the measured engine
dynamometer results. We concluded that for the 55 mph and 65 mph duty
cycles, GEM's interpolation of the steady-state data tables was
sufficiently accurate versus the measured results. This is an outcome
one would reasonably expect because even with changes in road grade,
the 55 mph and 65 mph duty cycles do not demand rapid changes in engine
speed or load. The 55 mph and 65 mph duty cycles are nearly steady-
state, as far as engine operation is concerned, just like the engine
maps themselves. However, for the ARB Transient cycle, we observed a
consistent bias when using the steady-state maps, where GEM
consistently under-predicted fuel consumption and CO2
emissions. This low bias over the 28 engine tests ranged from 4.2
percent low to 7.8 percent low. The mean was 5.9 percent low and the
90th percentile value was 7.1 percent low. These observations are
consistent with the fact that engines generally operate less
efficiently under transient conditions than under steady-state
conditions.
---------------------------------------------------------------------------
\160\ National Academy of Science. ``Reducing the Fuel
Consumption and GHG Emissions of Medium- and Heavy-Duty Vehicles,
Phase Two, First Report.'' 2014. Recommendation 3.8.
---------------------------------------------------------------------------
A number of reasons explain this consistent trend. For example,
under rapidly changing (i.e. transient) engine conditions, it is
generally more challenging to program an engine electronic controller
to respond with optimum fuel injection rate and timing, exhaust gas
recirculation valve position, variable nozzle turbocharger vane
position and other set points than under steady-state conditions.
Transient heat and mass transfer within the intake, exhaust, and
combustion chambers also tend to increase turbulence and enhance energy
loss to engine coolant during transient operation. In many cases during
cold transient operation, the thermal management is triggered in order
to maintain optimal performance of selective catalytic reduction
devices for a diesel engine. Furthermore, because exhaust emissions
control is more challenging under transient engine operation,
engineering tradeoffs sometimes need to be made between fuel efficiency
and transient criteria pollutant emissions control. Special
calibrations are typically also required to control smoke and manage
exhaust temperatures during transient operation for a transient cycle.
To account for these effects in GEM, the agencies have developed
and are finalizing a test procedure called ``cycle average'' mapping to
account for this transient behavior (40 CFR 1036.540). Detailed
analyses and presentation of the test procedure was published in two
peer-reviewed journal articles.\139,140\ A number of commenters
likewise suggested this approach. Additionally, progress has been made
on further improving this test procedure since publication, based on a
large number of engine dynamometer tests conducted by a variety of
laboratory test facilities.\161\ Since the proposal, further refinement
of the numerical schemes used for interpreting cycle average engine
fuel map was also completed. The engine dynamometer tests include a
Cummins medium duty ISB engine, a Navistar heavy duty N13 engine, a
Volvo heavy duty D13 engine, and a Cummins heavy duty ISX engine. All
testing results indicated that the new test procedure works well for
the transient ARB cycle.\162\ In addition, Cummins in their NODA
comments (see the following paragraph) provided additional data
supporting this approach with their ISL 450 bhp rating engine. This
data corroborated earlier data showing good agreement between engine
dynamometer tests and the cycle average engine mapping approach.\163\
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\161\ Memos to Docket, ``Test Procedure Review with Cummins,
Volvo, Navistar, Paccar, Daimler Eaton and Allison.''
\162\ Michael Ross, Validation Testing for Phase 2 Greenhouse
Gas Test Procedures and the Greenhouse Gas Emission Model (GEM) for
Medium and Heavy-Duty Engines and Powertrains, Final Report to EPA,
Southwest Research Institute, June 2016, found in docket of this
rulemaking, EPA-HQ-QAR-2014-0827.
\163\ Cummins NODA Comments, found in Phase 2 Docket: ID No.
EPA-HQ-OAR-2014-0817, April 1, 2016.
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EPA solicited comment on the cycle average approach at proposal. 80
FR 40193. EPA also specifically provided notice and a 30-day
opportunity for public comment on the possibility of requiring use of
the cycle average mapping approach for the ARB Transient cycle. This
was included in the version of GEM that was made available for public
comment as part of the NODA \153\. In response, many comments were
received on the cycle average approach. These include comments from
Cummins \163\ and Volvo.\164\ Cummins was very supportive of the cycle
average approach and also supported applying this approach to the 55
mph and 65 mph cruise cycles in GEM. Volvo expressed some concern over
having enough time to fully evaluate this approach. The agencies
believe that one of the reasons that Volvo expressed concern over
having enough time to evaluate this approach is because Volvo initially
declined working with the agencies to collaboratively refine this
approach. At the same time, a number of Volvo's competitors chose to
actively coordinate laboratory testing and technical analysis to
contribute to the development of this approach. We believe these other
manufacturers gained a deeper understanding of the approach earlier
than Volvo because they invested time and resources to make technical
contributions at earlier point in time. Nevertheless, the agencies
fully welcome and appreciate Volvo's more recent active involvement in
reviewing the cycle average approach and for making a number of
productive suggestions for further refinement.
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\164\ Volvo Group NODA Comments, found in Phase 2 Docket: ID No.
EPA-HQ-OAR-2014-0817, April 1, 2016.
---------------------------------------------------------------------------
While the agencies are finalizing the cycle average engine mapping
test procedure as mandatory for the ARB Transient cycle, for the 55 mph
and 65 mph GEM drive cycles, the agencies are finalizing the same
steady-state mapping procedure that the agencies originally proposed.
The only difference is that we are finalizing about 85 unique steady-
state map points, versus the about 143 points that were proposed. See
40 CFR 1036.535 for details. We are adopting a lower number of points
because many of the originally proposed points were specified for use
with the ARB Transient cycle.\139\ Again, as an option, the cycle
average mapping test procedure also may be used for these two cruise
speed cycles, in lieu of the steady-state mapping procedure.
(b) Simulating Human Driver Behavior and Transmissions for Vehicle
Certification
GEM for Phase 1 simulates the same generic human driver behavior
and manual transmission shifting patterns for all vehicles. The
simulated driver responds to changes in the target vehicle speed of the
duty cycles by changing the simulated positions of the vehicle's
accelerator pedal, brake pedal, clutch pedal, and gear shift lever. For
simplicity, in Phase 1 the GEM driver shifted at pre-specified vehicle
speeds and the manual transmission was simulated as an ideal
transmission that did not have any delay time (i.e., torque
interruption) between gear shifts and did not have any energy losses
associated with clutch slip during gear shifts.
In GEM for Phase 2 we are allowing manufacturers to select one of
four types of transmissions to represent the transmission in the
vehicle they are certifying: Manual transmission (MT), automated manual
transmission (AMT), automatic transmission (AT) and dual clutch
transmission (DCT). For Phase 2 the agencies proposed unique
transmission shifting patters to
[[Page 73543]]
represent the different types of automated transmissions. These
shifting patterns over the steady state cruise cycles has been further
modified from the proposed version to be more realistic with respect to
slight variations in vehicle speed due to road grade. In particular,
when going downhill, the simulated vehicle is now allowed to exceed the
speed target by 3 mph before the brakes are applied. In the proposed
version, the driver model applied the brakes much sooner to prevent the
vehicle from exceeding the speed target. This change allows the vehicle
to carry additional momentum into the next hill, much the same as real
drivers would.
In the final version of GEM, the driver behavior and the different
transmission types are simulated in the same basic manner as in Phase
1, but each transmission type features unique transmission responses
that match the transmission responses we measured during vehicle
testing of these three transmission types. In general the transmission
gear shifting strategy for all of the transmissions is designed to
shift the transmission so that it is in the most efficient gear for the
current vehicle demand, while staying within certain limits to prevent
unrealistically high frequency shifting (i.e., to prevent ``short-
shifting''). Some examples of these limits are torque reserve limits
(which vary as function of engine speed), minimum time-in-gear and
minimum fuel efficiency benefit to shift to the next gear. Some of the
differences between the transmission types include a driver ``double-
clutching'' during gear shifts of the manual transmission only, and
``power shifts'' and torque converter torque multiplication, slip, and
lock-up in automatic transmissions only. Refer to Chapter 4 of the RIA
for a more detailed description of these different simulated driver
behaviors and transmission types.
Prior to the proposal, we considered an alternative approach where
transmission manufacturers would provide vehicle manufacturers with
detailed information about their automated transmissions' proprietary
shift strategies for representation in GEM. NAS also recommended this
approach.\165\ The advantages of this approach would include a more
realistic representation of a transmission in GEM and potentially the
recognition of additional fuel efficiency improving strategies to
achieve additional fuel consumption and CO2 emissions
reductions. However, there are a number of technical and compliance
disadvantages of this approach. One disadvantage is that it would
require the disclosure of proprietary information because some vehicle
manufacturers produce their own transmissions and also use other
suppliers' transmissions. There are technical challenges too. For
example, some transmission manufacturers have upwards of 40 different
shift strategies programmed into their transmission controllers.
Depending on in-use driving conditions, some of which are not simulated
in GEM (e.g., changing payloads, changing tire traction) a transmission
controller can change its shift strategy. Representing dynamic
switching between multiple proprietary shift strategies would be
extremely complex to simulate in GEM. Furthermore, if the agencies were
to require transmission manufacturers to provide shift strategy inputs
for use in GEM, then the agencies would have to devise a compliance
strategy to monitor in-use shift strategies, including a driver
behavior model that could be implemented as part of an in-use shift
strategy confirmatory test. This too would be very complex. If
manufacturers were subject to in-use compliance requirements of their
transmission shift strategies, this could lead to restricting the use
of certain shift strategies in the heavy-duty sector, which would in
turn potentially lead to sub-optimal vehicle configurations that do not
improve fuel efficiency or adequately serve the wide range of customer
needs; especially in the vocational vehicle segment. For example, if
the agencies were to restrict the use of more aggressive and less fuel
efficient in-use shift strategies that are used only under heavy loads
and steep grades, then certain vehicle applications would need to
compensate for this loss of capability through the installation of
over-sized and over-powered engines that are subsequently poorly
matched and less efficient under lighter load conditions. Therefore, as
a policy consideration to preserve vehicle configuration choice and to
preserve the full capability of heavy-duty vehicles today, the agencies
are intentionally not allowing transmission manufacturers to submit
detailed proprietary shift strategy information to vehicle
manufacturers to input into GEM. The agencies are finalizing as
proposed that vehicle manufacturers can choose from among several
transmission types that the agencies have already developed, validated,
and programmed into GEM. The vehicle manufacturers will then enter into
GEM their particular transmission's number of gears and gear ratios,
optionally together with power loss tables representing their
transmission's gear friction, pumping and spin losses. If a
manufacturer chooses to use the optional powertrain test procedure,
however, then the agencies' transmission types in GEM would be
overridden by the actual data collected during the powertrain test,
which would recognize the transmission's unique shift strategy.
(Presumably, vehicle manufacturers will choose to use the optional
powertrain test procedure only if their actual transmission shift
strategy is more efficient compared to its respective default shift
strategy simulated by GEM.)
---------------------------------------------------------------------------
\165\ Transportation Research Board 2014. ``Reducing the Fuel
Consumption and Greenhouse Gas Emissions of Medium- and Heavy-Duty
Vehicles, Phase Two.'' (``Phase 2 First Report'') Washington, DC,
The National Academies Press. Cooperative Agreement DTNH22-12-00389.
Available electronically from the National Academy Press Web site at
http://www.nap.edu/catalog.php?record_id=12845 (last accessed
December 2, 2014). Recommendation 3.7.
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(c) Simulating Axles for Vehicle Certification
In GEM for Phase 1 the axle ratio of the primary drive axle and the
energy losses assumed in the simulated axle itself were the same for
all vehicles. For Phase 2 the vehicle manufacturer will be required to
input into GEM the axle ratio of the primary drive axle. This input
will recognize the design to operate the engine at a particular engine
speed when the transmission is operating in its highest transmission
gear; especially for the 55 mph and 65 mph duty cycles in GEM. This
input facilitates GEM's recognition of vehicle designs that take
advantage of operating the engine at the lowest possible engine speeds.
This is commonly known as ``engine down-speeding,'' and the general
rule-of-thumb for heavy-duty engines is that for every 100 rpm decrease
in engine speed, there can be about a 1 percent decrease in fuel
consumption and CO2 emissions. Therefore, it is important
that GEM allow this value to be input by the vehicle manufacturer. Axle
ratio is also straightforward to verify during any in-use compliance
audit. UCS and ACEEE commented that engine down-speeding should be
recognized in the agencies' separate engine standards, rather than in
the vehicle standard. The agencies disagree with this because
recognizing down-speeding at the vehicle level ensures that the
powertrain configuration in-use, in the real world, will lead to the
engine operating at lower speeds. In contrast, the engine speeds
specified in the separate engine standards' test procedures are based
on the engine's maximum torque versus speed curve (i.e., lug curve) and
not on the configuration of the powertrain to
[[Page 73544]]
which the engine is attached in a vehicle. This means that even if a
manufacturer manipulated the engine's lug curve such that the separate
engine standards' test procedure led to the engine operating at lower
speeds during certification, that same engine could be installed in a
vehicle with a powertrain configured for the engine to operate at
higher engine speeds. Therefore, recognizing down-speeding within GEM,
at the vehicle level, best ensures that the agencies' test procedures
and standards lead to real-world engine down-speeding in-use.
We proposed to use a fixed axle ratio energy efficiency of 95.5
percent at all speeds and loads, but requested comment on whether this
pre-specified efficiency is reasonable. 80 FR 40185. In general,
commenters stated that the efficiency of the axle actually varies as a
function of axle ratio, axle speed, and axle input torque. Therefore,
we have modified GEM to accept an input data table of power loss as a
function of axle speed and axle torque. The modified version of GEM
subsequently interpolates this table over each of the duty cycles to
represent a more realistic axle efficiency at each point of each duty
cycle. The agencies specify a default axle efficiency table in GEM for
any manufacturer to use. We are also finalizing an optional axle power
loss test procedure that requires the use of a dynamometer test
facility (40 CFR 1037.560). With this optional test procedure, a
manufacturer can create an axle efficiency table for use in lieu of the
EPA default table. We requested comment on this test procedure in the
proposal, and we received supportive comments. Refer to 40 CFR 1037.560
of the Phase 2 regulations, which contain this test procedure.
Moreover, the final regulations allow the manufacturers to develop
analytical methods to derive axle efficiency tables for untested axle
configurations, based on testing of similar axles. This would be
similar to the analytically derived CO2 emission
calculations allowed for pickups and vans. However, manufacturers would
be required to obtain prior approval from the agencies before using
analytically derived values. In addition, the agencies could conduct
confirmatory testing or require a selective enforcement audit for any
axle configuration. See 40 CFR 1037.235.
In addition to requiring the primary drive axle ratio input into
GEM (and an option to input an actual axle power loss data table), we
are requiring that the vehicle manufacturer input into GEM whether one
or two drive axles are driven by the engine. When a heavy-duty vehicle
is equipped with two rear axles where both are driven by the engine,
this is called a ``6x4'' configuration. ``6'' refers to the total
number of wheel hubs on the vehicle. In the 6x4 configuration there are
two front wheel hubs for the two steer wheels and tires plus four rear
wheel hubs for the four rear wheels and tires (or more commonly four
sets of rear dual wheels and tires). ``4'' refers to the number of
wheel hubs driven by the engine. These are the two rear axles that have
two wheel hubs each. Compared to a 6x4 configuration, a 6x2
configuration decreases axle energy loss due to friction and oil
churning in two driven axles, by driving only one axle. The decrease in
fuel consumption and CO2 emissions associated with a 6x2
versus 6x4 axle configuration can be in the range of 2.5 percent
depending on specific axles, which is modeled by the power loss
table.\166\ Therefore, in the Phase 2 version of GEM, if a manufacturer
simulates a 6x2 axle configuration using the default axle efficiencies,
GEM decreases the overall GEM result roughly by 2.5 percent on average
through the power loss table. Note that GEM will similarly decrease the
overall GEM result by 2.5 percent for a 4x2 tractor or Class 8
vocational chassis configuration if it has only two wheel hubs driven.
If a manufacturer does not use the default efficiencies, the benefit of
6x2 and 4x2 configurations will be reflected directly in its input
tables. Note that the Phase 2 version of GEM does not have an option to
simulate more than two drive axles or configurations where the front
axle(s) are driven or where there are more than two rear axles. The
regulations specify that such vehicles are to be simulated as 6x4
vehicles in GEM. This is consistent with how the standards were
developed and the agencies believe this approach will provide the
appropriate incentive for manufacturers to apply the same fuel saving
technologies to these vehicles, as they would to their conventional 6x4
vehicles. Moreover, because these configurations are manufactured for
specialized vehicles that require extra traction for off-road
applications, they have very low sales volume and any increased fuel
consumption and CO2 emissions from them are not significant
in comparison to the overall reductions of the Phase 2 program. Note
that 40 CFR 1037.631 (for off-road vocational vehicles), which is being
continued from the Phase 1 program, exempts many of these vehicles from
the vehicle standards because they are limited mechanically to low-
speed operation.
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\166\ NACFE. Executive Report--6x2 (Dead Axle) Tractors.
November 2010. See Docket EPA-HQ-OAR-2014-0827.
---------------------------------------------------------------------------
(d) Simulating Accessories for Vehicle Certification
The agencies proposed to continue the approach from Phase 1 whereby
GEM uses a fixed power consumption value to simulate the fuel consumed
for powering accessories such as steering pumps and alternators. 80 FR
40186. The final rule continues the Phase 1 approach, as proposed.
However, Phase 2 GEM provides an option to provide a GEM input
reflecting technology improvement inputs for the accessory loads. This
allows the manufacturers to receive credit for those technologies that
are not modeled in GEM. Manufacturers seeking credit for those
technologies that are not modeled in GEM would generally follow the
off-cycle credit program procedures in 40 CFR 1037.610.
(e) Aerodynamics in GEM for Tractor, Vocational Vehicle, and Trailer
Certification
Phase 2 GEM simulates aerodynamic drag in using CdA (the
product of the drag coefficient and frontal area of the vehicle) rather
than a drag coefficient (Cd). For tractors and trailers we
will continue to use an aerodynamic bin approach similar to the one
that exists in Phase 1 today, although the actual Phase 2 bins are
being revised to reflect new test procedures and our projections for
more aerodynamic tractors and trailers in the future. This approach
allows manufacturers to determine CdA (or delta-
CdA in the case of trailers) from coastdown testing, scale
wind tunnel testing and/or computational fluid dynamics modeling. It
requires tractor manufacturers (but not trailer manufacturers) to
conduct a certain minimum amount of coast-down vehicle testing to
validate their methods. The regulations also provide an alternate path
for trailer manufacturers to rely on testing performed by component
suppliers. See 40 CFR 1037.
The results of these tests determine into which bin a tractor or
trailer is assigned. GEM uses the aerodynamic drag coefficient
applicable to the bin, which is the same for all tractors (or trailers)
within a given bin. This approach helps to account for limits in the
repeatability of aerodynamic testing and it creates a compliance margin
since any test result which keeps the vehicle in the same aerodynamic
bin is considered compliant. For Phase 2 we are establishing new
boundary values for the bins themselves and we are adding two
additional tractor bins in order to recognize further advances in
[[Page 73545]]
aerodynamic drag reduction beyond what was recognized in Phase 1.
Furthermore, while Phase 1 GEM used predefined frontal areas for
tractors where the manufacturers input only a Cd value,
manufacturers will use a measured drag area (CdA) value for
each tractor configuration for Phase 2. See 40 CFR 1037.525. The
agencies do not project that vocational vehicles will need to improve
their aerodynamic performance to comply with the Phase 2 vocational
chassis standards. However, the agencies are providing features in GEM
for vocational vehicles to receive credit for improving the
aerodynamics of vocational vehicles (see 40 CFR 1037.520(m)).
In addition to these changes, we are making a number of aerodynamic
drag test procedure improvements. One improvement is to update the
``standard trailer'' that is prescribed for use during aerodynamic drag
testing of a tractor. Using the CdA from such testing means
the standard trailer would also be the hypothetical trailer modeled in
GEM to represent a trailer paired with the tractor in actual use.\167\
In Phase 1, a non-aerodynamic 53-foot long box-shaped dry van trailer
was specified as the standard trailer for tractor aerodynamic testing
(see 40 CFR 1037.501(g)). For Phase 2 we are modifying this standard
trailer for tractor testing to make it more similar to the trailers we
expect to be produced during the Phase 2 timeframe. More specifically,
we are prescribing the installation of aerodynamic trailer skirts (and
low rolling resistance tires as applied in Phase 1) on the standard
trailer, as discussed in further in Section III.E.2. As explained more
fully in Sections III and IV, the agencies believe that tractor-trailer
pairings will be optimized aerodynamically to a significant extent in-
use (such as using high-roof cabs when pulling box trailers), and that
this real-world optimization should be reflected in the certification
testing. We are also revising the test procedures to better account for
average wind yaw angle to reflect the true impact of aerodynamic
features on the in-use fuel consumption and CO2 emissions of
tractors, again as discussed in more detail in Section III below. Refer
to the test procedures in 40 CFR 1037.525 through 1037.527 for further
details of these aerodynamic test procedures.
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\167\ See Section III. for a discussion of how GEM will model a
more advanced trailer beginning with the 2027 model year.
---------------------------------------------------------------------------
For trailer certification, the agencies use GEM in a different way
than it is used for tractor certification. As described in Section IV,
the agencies developed a simple equation to replicate GEM performance.
The trailer standards are based on this equation, and trailer
manufacturers use this GEM-based equation for certification. The only
technologies recognized by this GEM-based equation for trailer
certification are aerodynamic technologies, tire technologies
(including tire rolling resistance and tire pressure systems), and
weight reduction. Note that since the purpose of this equation is to
replicate GEM performance, it can be considered as simply another form
of the model using a different input interface. Thus, for simplicity,
the remainder of this Section II.C. sometimes discusses GEM as being
used for trailers, without regard to how manufacturers will actually
input GEM variables. As with all of the standards in Phase 2,
compliance is measured consistent with the same test methods used by
the agencies to establish the standard.
Similar to tractor certification, trailer manufacturers will use
data from aerodynamic testing (e.g., coastdown testing, scale wind
tunnel testing, computational fluid dynamics modeling, or possibly
aerodynamic component testing) with the equation.\168\ As part of the
protocol for generating these inputs, the agencies are specifying the
configuration of a reference tractor for conducting trailer testing.
Refer to Section IV of this Preamble and to 40 CFR 1037.501 of the
regulations for details on the reference tractor configuration for
trailer test procedures.
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\168\ The agencies project that more than enough aerodynamic
component vendors will take advantage of proposed optional pre-
approval process to make testing optional for trailer manufacturer.
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Finally, GEM has been modified to accept an optional delta
CdA value for vocational chassis, to simulate aerodynamic
improvements relative to pre-specified baseline defined in Chapter 4 of
RIA. For example, a manufacturer that demonstrates that adding side
skirts to a box truck reduces its CdA by 0.2 m\2\ could
input that value into GEM for box trucks that include those skirts. See
40 CFR 1037.520(m).
(f) Tires and Tire Inflation Systems for Truck and Trailer
Certification
For GEM in Phase 1 tractor and vocational chassis manufacturers
input the tire rolling resistance of steer and drive tires directly
into GEM. The agencies prescribed an internationally recognized tire
rolling resistance test procedure, ISO 28580, for determining the tire
rolling resistance value that is input into GEM, as described in 40 CFR
1037.520(c). For Phase 2 we will continue this same approach and the
use of ISO 28580, and we are expanding these requirements to trailer
tires as well.
In addition to tire rolling resistance, Phase 2 vehicle
manufacturers will enter into GEM the tire manufacturer's specified
revolutions per distance directly (revs/mile) for the vehicle's drive
tires. This value is commonly reported by tire manufacturers already so
that vehicle speedometers can be adjusted appropriately. This input
value is needed so that GEM can accurately convert simulated vehicle
speed into axle speed, transmission speed, and ultimately engine speed.
For tractors and trailers, we proposed to allow manufacturers to
specify whether or not an automatic tire inflation system (ATIS) is
installed. 80 FR 40187. Based on comments and as discussed further in
Sections III, IV, and V, in the Phase 2 final rule we are adopting
provisions that allow manufacturers of tractors, trailers, and
vocational vehicle chassis to input a percent decrease in overall fuel
consumption and CO2 emissions into GEM if the vehicle
includes either an ATIS or a tire pressure monitoring system (TPMS).
The value that can be input depends on whether a TPMS or ATIS is
deployed. See 40 CFR 1037.520.
(g) Weight Reduction for Tractor, Vocational Chassis and Trailer
Certification
Phase 2 GEM continues the weight reduction recognition approach in
Phase 1, where the agencies prescribe fixed weight reductions, or
``deltas,'' for using certain lightweight materials for certain vehicle
components. In Phase 1 the agencies published a list of weight
reductions for using high-strength steel and aluminum materials on a
part by part basis. For Phase 2 we use updated values for high-strength
steel and aluminum parts for tractors and for trailers and we have
scaled these values for use in certifying the different weight classes
of vocational chassis. In addition we use a similar part by part weight
reduction list for tractor parts made from thermoplastic material. We
proposed to assign a fixed weight increase to natural gas fueled
vehicles to reflect the weight increase of natural gas fuel tanks
versus gasoline or diesel tanks, but we are not finalizing that
provision based on comments. 80 FR 40187. Commenters opposing this
provision generally noted that the proposed provision was not
consistent with how the agencies were treating other technologies. We
agree that
[[Page 73546]]
natural gas vehicles should be treated consistently with other
technologies and so are not adopting the proposed provision.
For tractors, we will continue the same mathematical approach in
GEM to assign \1/3\ of a total weight decrease to a payload increase
and \2/3\ of the total weight decrease to a vehicle mass decrease. For
Phase 1, these ratios were based on the average frequency that a
tractor operates at its gross combined weight rating. We will also use
these ratios for trailers in Phase 2. For vocational chassis, for which
Phase 1 did not address weight reduction, we will assign \1/2\ of a
total weight decrease to a payload increase and \1/2\ of the total
weight decrease to a vehicle mass decrease.
(h) GEM Duty Cycles for Tractor, Vocational Chassis and Trailer
Certification
In Phase 1, there are three GEM vehicle duty cycles that represent
stop-and-go city driving (ARB Transient), urban highway driving (55
mph), and rural interstate highway driving (65 mph). In Phase 1 these
cycles were time-based. That is, they were specified as a function of
simulated time and the duty cycles ended once the specified time
elapsed in simulation. The agencies proposed to continue to use these
three drive cycles in Phase 2, but with some revisions. 80 FR 40187. We
are finalizing revisions similar but not identical to those that were
proposed. First, GEM will simulate these cycles on a distance-based
specification, rather than on a time-based specification. A distance-
based specification ensures that even if a vehicle in simulation does
not always achieve the target vehicle speed, the vehicle will have to
continue in simulation for a longer period to complete the duty cycle.
This ensures that vehicles are evaluated over the complete distance of
the duty cycle and not just the portion of the duty cycle that a
vehicle completes in a given time period. A distance-based duty cycle
specification also facilitates a straightforward specification of road
grade as a function of distance along the duty cycle. As noted in
above, for Phase 2, the agencies have enhanced the 55 mph and 65 mph
duty cycles by adding representative road grade to exercise the
simulated vehicle's engine, transmission, axle, and tires in a more
realistic way. A flat road grade profile over a constant speed test
does not properly simulate a transmission with respect to shifting
gears, and may have the unintended consequence of enabling underpowered
vehicles or excessively down-sped drivetrains to generate credits, when
in actuality the engine does not remain down-sped in-use when the
vehicle encounters road grades. The road grade profile being finalized
is the same hill and valley profile for both the 55 mph and 65 mph duty
cycles, and is based on statistical analysis of the United States'
national distribution of road grades. Although the final profile is
different than that proposed, the agencies provided notice of the
analysis that was used to generate the final profile.\169\ In written
comments, we received in-use engine data from some manufacturers, and
based on this information we made minor adjustments to the road grade
to ensure that engines simulated in GEM operated similarly to that
reported in the in-use engine data submitted to us. See Section
III.E.(2)(b) of this document and Chapter 3.4.2.1 of the RIA for more
details on development of the road grade profile. We believe that the
enhancement of the 55 mph and 65 mph duty cycles with road grade is
consistent with the NAS recommendation regarding road grade.\170\
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\169\ See National Renewable Energy Laboratory report ``EPA GHG
Certification of Medium- and Heavy-Duty Vehicles: Development of
Road Grade Profiles Representative of US Controlled Access
Highways'' dated May 2015 and EPA memorandum ``Development of an
Alternative, Nationally Representative, Activity Weighted Road Grade
Profile for Use in EPA GHG Certification of Medium- and Heavy-Duty
Vehicles'' dated May 13, 2015, both available in Docket EPA-HQ-OAR-
2014-0827. This docket also includes file
NREL_SyntheticAndLocalGradeProfiles.xlsx which contains numerical
representations of all road grade profiles described in the NREL
report.
\170\ NAS 2010 Report. Page 189. ``A fundamental concern raised
by the committee and those who testified during our public sessions
was the tension between the need to set a uniform test cycle for
regulatory purposes, and existing industry practices of seeking to
minimize the fuel consumption of medium and heavy-duty vehicles
designed for specific routes that may include grades, loads, work
tasks or speeds inconsistent with the regulatory test cycle. This
highlights the critical importance of achieving fidelity between
certification values and real-world results to avoid decisions that
hurt rather than help real-world fuel consumption.''
---------------------------------------------------------------------------
(i) Workday Idle Operation for Vocational Chassis Certification
In the Phase 1 program, reduction in idle emissions was recognized
only for sleeper cab tractors, and only with respect to hoteling idle,
where a driver needs power to operate heating, ventilation, air
conditioning and other electrical equipment in order to use the sleeper
cab to eat, rest, or conduct other business. As described in Section V,
GEM for Phase 2 will recognize technologies that reduce workday idle
emissions, such as automatic stop-start systems, daytime parked idle
automatic engine shutdown systems, and transmissions that either
automatically or inherently shift to neutral at idle while in drive.
Many vocational vehicle applications operate on patterns implicating
workday idle cycles, and the agencies use test procedures in GEM to
account specifically for these cycles and potential idle controls. GEM
will recognize these idle controls in two ways. For technologies like
neutral-idle transmissions and stop-start systems that address idle
that occurs during vehicle operation when the vehicle is stopped at a
stop light, GEM will interpolate lower fuel rates from the engine map
during the idle portions of the ARB Transient and during a separate GEM
``drive idle cycle.'' For technologies like start-stop and auto-
shutdown that eliminate some of the idle that occurs when a vehicle is
stopped or parked, GEM will assign a value of zero fuel rate during a
separate GEM ``parked idle cycle.'' The idle cycles will be weighted
along with the 65 mph, 55 mph, and ARB Transient duty cycles, according
to the new vocational chassis duty cycle weighting factors. These
weighting factors are different for each of the three vocational
chassis speed categories for Phase 2. For tractors, only neutral idle
and hotel idle will be addressed in GEM.
(2) Experimental Validation of GEM
The core simulation algorithms in GEM have not changed
significantly since the proposal. Most of the changes since proposal
focused on streamlining how manufacturers input data into GEM; revising
to the drive cycles in GEM; and updating how GEM weights these
different drive cycles to determine a composite fuel consumption value.
These changes did not alter the fundamental way that GEM simulates
varying vehicle ``road load'' and how GEM converts vehicle speed to
engine speed and then interpolates engine maps to determine vehicle
fuel consumption and CO2 emissions.
Refinements to GEM since the time of proposal that did alter GEM's
simulation performance include modifying the default transmissions'
shift strategies and their power losses. Another key refinement was
cycle average mapping engines for simulation of the ARB Transient
cycle. Each time the agencies made such modifications to GEM, GEM's
correlation to the agencies collection of laboratory-generated engine
and vehicle data was checked. Potential refinements to GEM were
accepted if GEM's correlation was improved versus this set of
experimental data. If potential refinements resulted in GEM's
correlation to the experimental data
[[Page 73547]]
becoming worse, those potential changes were rejected. Chapter 4.3.2 of
the RIA details the GEM validation that was performed to determine if
potential changes to GEM should be accepted or rejected. The first step
of the validation process involves simulating vehicles in GEM using
engine fuel maps and transmission shifting strategies obtained from
manufacturers and comparing GEM results to experiments conducted with
the same engines and transmissions. This first step re-validates all of
the non-powertrain elements of GEM, which were already validated in
Phase 1. The second step is to use GEM's default transmissions' shift
strategies in simulation \171\ and then compare GEM results to
powertrain tests of several transmissions. The only difference between
the first and second step is the shifting strategy and powertrain
energy loss assumptions. This step facilitates tuning of GEM's default
transmission models so that they correlate well to a variety of real
transmissions. The third step is to compare GEM simulations to real-
world in-use recorded data from actual vehicles. This is the most
challenging step because the experimental data includes real-world
effects of wind, road grade, and driver behavior in traffic. The most
important element of this third step is not absolute correlation, but
rather, relative correlation, which demonstrates that when a technology
is added to a real vehicle, the relative improvement in the real world
is simulated in GEM with a high degree of correlation.
---------------------------------------------------------------------------
\171\ K. Newman, J. Kargul, and D. Barba, ``Development and
Testing of an Automatic Transmission Shift Schedule Algorithm for
Vehicle Simulation, ``SAE Int. J. Engines 8(3):2015, doi:10.4271/
2015-01-1142.
---------------------------------------------------------------------------
In the first validation step, the agencies compared GEM to over 130
vehicle variants, consistent with the recommendation made by the NAS in
their Phase 2-First Report.\172\ As described in Chapter 4 of the RIA,
good agreement was observed between GEM simulations and test data over
a wide range of vehicles. In general, the model simulations agreed with
experimental test results within 5 percent on an absolute
basis. As pointed out in Chapter 4.3.2 of the RIA, relative accuracy is
more relevant to the intent of this rulemaking, which is to accelerate
the adoption of additional fuel efficiency improving technologies.
Consistent with the intent of this rulemaking, all of the numeric
standards for tractors, trailers and vocational chassis are derived
from running GEM first with Phase 1 ``baseline'' technology packages
and then with various Phase 2 technology packages. The differences
between these GEM results are examined to determine final stringencies.
In other words, the agencies used the same final version of GEM to
establish the numeric standards as will be used by manufacturers to
demonstrate compliance. Therefore, it is most important that GEM
accurately reflects relative changes in emissions for each added
technology. In other words, for vehicle certification purposes it is
less important that GEM's absolute value of the fuel consumption or
CO2 emissions be accurate compared to laboratory testing of
the same vehicle. The ultimate purpose of GEM is to evaluate changes or
additions in technology, and compliance is demonstrated on a relative
basis to the numeric standards that were also derived from GEM.
Nevertheless, the agencies concluded that the absolute accuracy of GEM
is generally within 5 percent, as shown in Figure II.2 2.
Chapter 4.3.2 of the RIA shows that relative accuracy is even better,
2-3 percent.
---------------------------------------------------------------------------
\172\ National Academy of Science. ``Reducing the Fuel
Consumption and GHG Emissions of Medium- and Heavy-Duty Vehicles,
Phase Two, First Report.'' 2014. Recommendation1.2.
[GRAPHIC] [TIFF OMITTED] TR25OC16.002
[[Page 73548]]
In addition to this successful validation against experimental
results, the agencies have also conducted a peer review of the GEM
source code. This peer review has been submitted to Docket number EPA-
HQ-OAR-2014-0827.
The second validation step was to repeat the first step's GEM
simulations with the agencies' default transmission shift
strategies.\171\ It was expected that GEM's absolute accuracy would
decrease because these shift strategies were tuned for best average
performance and for a particular transmission. Nevertheless, it was
shown that relative accuracy did not suffer; therefore, the agencies
deemed the GEM default shift strategies acceptable for GEM
certification purposes. Further details of this validation step are
presented in Chapter 4.3.2.3 of the RIA and in a SwRI final
report.\162\
As explained above and in Chapter 4.3.2.3 of the RIA, it is
challenging to achieve absolute correlation between any computer
simulation and real-world vehicle operation. Therefore, the agencies
focused on relative comparisons. Following the SAE standard procedure
SAE J1321 ``Type II,'' two trucks have been tested and these real-world
results were compared to GEM simulations. In summary, the relative
comparisons between GEM simulations and the real-world testing of
trucks showed a 2.4 percent difference. The details of this testing and
correlation analysis is presented in Chapter 4.3.2.3 of the RIA.
In conclusion, the agencies completed a number of validation steps
to ensure that GEM demonstrates a reasonable degree of absolute
accuracy, but more importantly a high degree of relative accuracy,
versus both laboratory and real-world experimental data.
(3) Supplements to GEM Simulation
As in Phase 1, for most tractors and vocational vehicles,
compliance with the Phase 2 g/ton-mile vehicle standards could be
evaluated by directly comparing the GEM result to the standard.
However, in Phase 1, manufacturers incorporating innovative or advanced
technologies could apply improvement factors to lower the GEM result
before comparing to the standard.\173\ For example, a manufacturer
incorporating a launch-assist mild hybrid that was pre-approved for a 5
percent benefit would apply a 0.95 improvement factor to its GEM
results for such vehicles. In this example, a GEM result of 300 g/ton-
mile will be reduced to 285 g/ton-mile.
---------------------------------------------------------------------------
\173\ 40 CFR 1036.610, 1036.615, 1037.610, and 1037.615.
---------------------------------------------------------------------------
For Phase 2, the agencies largely continue the existing Phase 1
innovative technology approach, but we name it ``off-cycle'' to better
reflect its purpose.
(a) Off-Cycle Technology Procedures
In Phase 1 the agencies adopted an emissions credit generating
opportunity that applied to new and innovative technologies that reduce
fuel consumption and CO2 emissions, which were not in common
use with heavy-duty vehicles before model year 2010 and are not
reflected over the test procedures or GEM (i.e., the benefits are
``off-cycle''). See 76 FR 57253. As was the case in the development of
Phase 1, the agencies continue this approach for technologies and
concepts with CO2 emissions and fuel consumption reduction
potential that might not be adequately captured over the Phase 2 duty
cycles or are not inputs to GEM. Note, however, that the agencies now
refer to these technologies as off-cycle rather than innovative.
Comments were generally supportive of continuing this provision. See
Section I.C(1)(c) of this document and Section 1 of the RTC for more
discussion of innovative and off-cycle technologies.
We recognize that the Phase 1 testing burden associated with the
innovative technology credit provisions discouraged some manufacturers
from applying. To streamline recognition of many technologies, default
values have been integrated directly into GEM. For example, automatic
tire inflation systems have fixed default values, and such technologies
are now recognized through a post-simulation adjustment approach,
discussed in Chapter 4 of the RIA. This is similar to the technology
``pick list'' from our light-duty programs. See 77 FR 62833-62835
(October 15, 2012). If manufacturers wish to receive additional credit
beyond these fixed values, then the off-cycle technology credit
provisions provide a regulatory path toward that additional
recognition.
Beyond the additional technologies that the agencies have added to
GEM, the agencies also believe there are several emerging technologies
that are being developed today, but will not be accounted for in GEM
because we do not have enough information about these technologies to
assign fixed values to them in GEM. Any credits for these technologies
will need to be based on the off-cycle technology credit generation
provisions. These require the assessment of real-world fuel consumption
and GHG reductions that can be measured with verifiable test methods
using representative operating conditions typical of the engine or
vehicle application.
As in Phase 1, the agencies continue to provide two paths for
approval of the test procedure to measure the CO2 emissions
and fuel consumption reductions of an off-cycle technology used in the
HD tractor. See 40 CFR 1037.610 and 49 CFR 535.7. The first path does
not require a public approval process of the test method. A
manufacturer can use ``pre-approved'' test methods for HD vehicles
including the A-to-B chassis testing, powertrain testing or on-road
testing. A manufacturer may also use any developed test procedure which
has known quantifiable benefits. A test plan detailing the testing
methodology is required to be approved by the agencies prior to
collecting any test data. The agencies will also continue the second
path which includes a public approval process of any testing method
which could have uncertain benefits (i.e., an unknown usage rate for a
technology). Furthermore, the agencies are modifying our provisions to
better clarify the documentation required to be submitted for approval
aligning them with provisions in 40 CFR 86.1869-12, and NHTSA
separately prohibits credits from technologies addressed by any of its
crash avoidance safety rulemakings (i.e., congestion management
systems).
Sections III and V separately describe tractor and vocational
vehicle technologies, respectively, that the agencies anticipate may
qualify for these off-cycle credit provisions.
(4) Production Vehicle Testing for Comparison to GEM
As described in Section III.E.(2)(j), The agencies are requiring
tractor manufacturers to annually chassis test five production vehicles
over the GEM cycles to verify that relative reductions simulated in GEM
are being achieved in production. See 40 CFR 1037.665. We do not expect
absolute correlation between GEM results and chassis testing. GEM makes
many simplifying assumptions that do not compromise its usefulness for
certification, but do cause it to produce emission rates different from
what would be measured during a chassis dynamometer test. Given the
limits of correlation possible between GEM and chassis testing, we
would not expect such testing to accurately reflect whether a vehicle
was compliant with the GEM standards. Therefore, we are not applying
GHG compliance liability to such testing. Rather, this testing will be
for data collection and informational purposes only. The agencies will
continue to evaluate in-use compliance
[[Page 73549]]
by verifying GEM inputs and testing in-use engines. (Note that NTE
standards for criteria pollutants may apply for some portion of the
test cycles.)
(5) Use of GEM in Establishing the Phase 2 Numerical Standards
As in Phase 1, the agencies are setting specific numerical
standards against which tractors and vocational vehicles will be
certified using GEM (box trailers will use a GEM-based equation, and
some trailers and custom chassis vocational vehicles may optionally use
a non-GEM certification path). Although these standards are
performance-based standards, which do not specifically require the use
of any particular technologies,\174\ the agencies established these
standards by evaluating specific vehicle technology packages using the
final version of Phase 2 GEM. We note that that this means the final
numerical standards are not directly comparable to the proposed
standards, which were based on an intermediate version of GEM, rather
than on the final version.
---------------------------------------------------------------------------
\174\ The sole exception being the design-based standards for
non-aero and partial aero trailers.
---------------------------------------------------------------------------
(a) Relation to In-Use Emissions
The purpose of this rulemaking is to achieve in-use emission and
fuel consumption reductions by requiring manufacturers to demonstrate
that they meet the promulgated emission standards. Thus, it is
important that GEM simulations be reasonably representative of in-use
operation. Testing that is unrepresentative of actual in-use operation
does not necessarily tell us anything about whether any emission
reductions occur. However, we recognize that certain simplifications
are necessary for practical simulations. In the past, EPA has addressed
this issue by including in our testing regulations a process by which
EPA can work with manufacturers to adjust test procedures to make them
more representative of in-use operation. For engine testing, this
provision is in 40 CFR 1065.10(c)(1), where EPA requires manufacturers
to notify us in cases in which they determine that the specified test
procedures would result in measurements that do not represent in-use
operation.
Although we are not adopting an equivalent provision for GEM at
this time, we expect similar principles to apply. To the extent that
GEM fails to represent in-use emission, we would expect to work with
manufacturers to address the issue--under the existing regulations
where possible, or by promulgating a new rulemaking.
We recognize that many compromises must be made between the
practicality of testing/simulation and the matching of in-use
operation. We have considered many aspects of the test procedures in
this respect for the engines, vehicles, and emission controls of which
we are currently aware. We have concluded that the procedures will
generally result in emission simulations that are sufficiently
representative of in-use emissions, even though not all in-use
operation will occur during simulation. Nevertheless, we have
identified several areas that deserve some additional discussion.
GEM is structured to simulate a single vehicle weight (curb weight
plus payload) per regulatory subcategory. However, we know that actual
in-use weights will rarely be exactly the same as the simulated
weights. Nevertheless, since the representativeness of the simulated
weights (or lack thereof) is being fully considered in the setting of
the standards, there would be no need to modify the procedures to
account for different curb weights or payloads.
GEM simulates vehicle emissions over three drive cycles plus two
idle cycles, and weights the cycle results based on the type of vehicle
being certified. These cycles and weightings reflect fleet average
driving patterns and the agencies do not expect them to fully match
driving patterns for individual vehicles. Thus, we would generally not
consider GEM's cycles as unrepresentative for vehicles with different
in-use driving patterns. However, if new information became available
that demonstrated that GEM's cycles somehow did not reflect fleet
average driving patterns, the agencies would consider such information
in the context of the principles of representative testing, described
above.
Finally, GEM includes default values for axle and transmission
efficiency derived from baseline technologies. However, we generally
expect manufacturers to use more efficient axles and transmissions for
Phase 2 vehicles. As noted above, based on comments, the agencies are
allowing manufacturers to optionally input measured efficiencies to
better represent these more efficient technologies. We would not
consider GEM unrepresentative if manufacturers chose to use the default
values rather than measure these efficiencies directly.
(b) Relation to Powertrain Testing
As already noted, GEM correlates very well with powertrain testing.
To the extent they differ, it would be expected to be primarily related
to how transmission performance is modeled in GEM. Although GEM
includes a sophisticated model of transmissions, it cannot represent a
transmission better than a powertrain test of the same transmission.
Thus, the agencies consider powertrain testing to be as good as or
better than GEM run using engine-only fuel maps; hence the provision in
the final rules allowing results from powertrain testing to be used as
a GEM input.
In some respects, powertrain testing can be considered to be a
reference method for this rulemaking. Because manufacturers have the
option to perform powertrain testing instead of engine-only fuel
mapping, the stringency of the final standards can be traced to
powertrain testing. In other words, methods that can be shown to be
equivalent to powertrain testing can be considered to be consistent
with the testing that was used as the basis of the final Phase 2
standards.
In a related context, it may be useful in the future to consider
equivalency to powertrain testing as an appropriate criterion for
evaluating changes to GEM to address new technologies. Consider, for
example, a new technology that is not represented in GEM, but that is
reflected in powertrain testing. The agencies could determine that it
would be appropriate to modify GEM to reflect the technology rather
than to require manufacturers to perform powertrain testing. In such a
case, the agencies would not consider the modification to GEM to impact
the effective stringency of the Phase 2 standards because the new
version of GEM would be equivalent to performing powertrain testing.
D. Engine Test Procedures and Engine Standards
In addition to the Phase 1 GEM-based vehicle certification of
tractors and vocational chassis, the agencies also set Phase 1 separate
CO2 and fuel efficiency standards for the engines installed
in tractors and vocational chassis. EPA also set Phase 1 separate
engine standards for capping methane (CH4) and nitrous oxide
(N2O) emissions (essentially capping emissions at current
emission levels). Compliance with all of these Phase 1 separate engine
standards is demonstrated by measuring these emissions during an engine
dynamometer test procedure. For Phase 1 the agencies use the same test
procedure specified for EPA's existing heavy-duty engine emissions
standards (e.g., NOX and PM standards). These Phase 1 engine
standards are specified in terms of brake-specific (g/bhp-hr) fuel,
CO2, CH4 and N2O emissions limits.
Since the test procedure already
[[Page 73550]]
specified how to measure fuel consumption, CO2 and
CH4, few changes were needed to utilize the test procedure
for Phase 1, the most notable change being a modification specifying
how to measure N2O.
There are some differences in how these non-GHG test procedures are
applied in Phase 1 and Phase 2. In EPA's non-GHG engine emissions
standards, heavy-duty engines must meet brake-specific standards for
emissions of total oxides of nitrogen (NOX), particulate
mass (PM), non-methane hydrocarbon (NMHC), and carbon monoxide (CO).
These standards must be met by all engines both over a 13-mode steady-
state duty cycle called the ``Supplemental Emissions Test'' (SET) \175\
and over a composite of a cold-start and a hot-start transient duty
cycle called the ``Federal Test Procedure'' (FTP). In contrast, for
Phase 1 the agencies require that engines specifically installed in
tractors meet fuel efficiency and CO2 standards over only
the SET but not the composite FTP. This requirement was intended to
reflect that tractor engines typically operate near steady-state
conditions versus transient conditions. See 76 FR 57159. For Phase 2
the agencies are finalizing, as proposed, slight changes to the 13-
modes' weighting factors to better reflect in-use engine operation.
These weighting factors apply only for determining SET fuel consumption
and CO2 emissions. No changes are being made to the
weighting factors for EPA's non-GHG emission standards. The agencies
adopted the converse for engines installed in vocational vehicles. That
is, these engines must meet fuel efficiency and CO2
standards over the composite FTP but not the SET. This requirement was
intended to reflect that vocational vehicle engines typically operate
under transient conditions versus steady-state conditions (76 FR
57178). For both tractor and vocational vehicle engines in Phase 1, EPA
set CH4 and N2O emissions cap standards over the
composite FTP only and not over the SET duty cycle. See Section II.D.
for details on this final action's engine test procedures for Phase 2.
---------------------------------------------------------------------------
\175\ The SET cycle is also referred to as the ``ramped-modal
cycle'' because, for criteria pollutants, it is performed as a
continuous cycle with ramped transitions between the individual
modes of the SET.
---------------------------------------------------------------------------
In response to the agencies' proposed engine standards, we received
a number of public comments. The agencies considered those comments,
and the following list summarizes key changes we've made in response,
and more detailed descriptions of these changes are presented in
Chapter 2.7 of the RIA:
Recalculated the SET baseline using the new Phase 2 SET
weighting factors.
Recalculated the FTP baseline, based on MY 2016 FTP
certification data from Cummins, DTNA, Volvo, Navistar, Hino, Isuzu,
Ford, GM and FCA. These included HHD, MHD, and LHD engines.
Projected how manufacturers would modify maximum fuel
rates as a function of speed to strategically relocate SET mode points
to achieve lowest SET results.
Projected a higher market penetration of WHR in 2027,
versus what we proposed.
Decreased our projected impact of engine technology dis-
synergies by increasing the magnitude of our so-called ``dis-synergy
factors;'' accounting for these changes by increasing the research and
development costs needed for this additional optimization.
The following section first describes the engine test procedures
used to certify engines to the Phase 2 separate engine standards.
Sections that follow describe the Phase 2 CO2,
N2O and CH4 separate engine standards and their
feasibility.
(1) Engine Test Procedures
(a) SET Cycle Weighting
The SET cycle was adopted by EPA in 2000 and modified in 2005 from
a discrete-mode test to a ramped-modal cycle to broadly cover the most
significant part of the speed and torque map for heavy-duty engines,
defined by three non-idle speeds and three relative torques. The low
speed is called the ``A speed,'' the intermediate speed is called the
``B speed,'' and the high speed is called the ``C speed.'' As is shown
in Table II-1, the SET cumulatively weights these three speeds at 23
percent, 39 percent, and 23 percent.
Table II-1--SET Modes Weighting Factor in Phase 1
------------------------------------------------------------------------
Weighting
Speed, % Load factor in
Phase 1 (%)
------------------------------------------------------------------------
Idle....................................................... 15
A, 100..................................................... 8
B, 50...................................................... 10
B, 75...................................................... 10
A, 50...................................................... 5
A, 75...................................................... 5
A, 25...................................................... 5
B, 100..................................................... 9
B, 25...................................................... 10
C, 100..................................................... 8
C, 25...................................................... 5
C, 75...................................................... 5
C, 50...................................................... 5
------------
Total.................................................... 100
Cumulative A Speed......................................... 23
Cumulative B Speed......................................... 39
Cumulative C Speed......................................... 23
------------------------------------------------------------------------
The C speed is typically in the range of 1800 rpm for current heavy
heavy-duty engine designs. However, it is becoming much less common for
engines to operate at such a high speeds in real-world driving
conditions, and especially not during cruise vehicle speeds in the 55
to 65 mph vehicle speed range. This trend has been corroborated by
engine manufacturers' in-use data that has been submitted to the
agencies in comments and presented at technical conferences.\176\ Thus,
although the current SET represents highway operation better than the
FTP cycle, it could be improved by adjusting its weighting factors to
better reflect modern trends in in-use engine operation. Furthermore,
the most recent trends indicate that manufacturers are configuring
drivetrains to operate engines at speeds down to a range of 1050-1200
rpm at a vehicle speed of 65 mph.
---------------------------------------------------------------------------
\176\ ``OEM perspective--Meeting EPA/NHTSA GHG/Efficiency
Standards'', 7th Integer Emissions Summit USA 2014, Volvo Group
North America.
---------------------------------------------------------------------------
To address this trend toward in-use engine down-speeding, the
agencies are finalizing as proposed refined SET weighting factors for
the Phase 2 CO2 emission and fuel consumption standards. The
new SET mode weightings move most of the C weighting to ``A'' speed, as
shown in Table II-2. To better align with in-use data, these changes
also include a reduction of the idle speed weighting factor. These new
mode weightings do not apply to criteria pollutants or to the Phase 1
CO2 emission and fuel consumption standards.
Table II-2--New SET Modes Weighting Factor in Phase 2
------------------------------------------------------------------------
Weighting
Speed/% load factor in
Phase 2 (%)
------------------------------------------------------------------------
Idle....................................................... 12
A, 100..................................................... 9
B, 50...................................................... 10
B, 75...................................................... 10
A, 50...................................................... 12
A, 75...................................................... 12
A, 25...................................................... 12
B, 100..................................................... 9
[[Page 73551]]
B, 25...................................................... 9
C, 100..................................................... 2
C, 25...................................................... 1
C, 75...................................................... 1
C, 50...................................................... 1
------------
Total.................................................... 100
Total A Speed.............................................. 45
Total B Speed.............................................. 38
Total C Speed.............................................. 5
------------------------------------------------------------------------
(b) Engine Test Provisions for SET, FTP, and Engine Mapping for GEM
Inputs
Although GEM does not apply directly to engine certification, Phase
2 will require engine manufacturers to generate and certify full load
and motoring torque curves and engine fuel rate maps for input into GEM
for tractor and vocational chassis manufacturers to demonstrate
compliance to their respective standards. The full load and motoring
torque curve procedures were previously defined in 40 CFR part 1065,
and these are already required for non-GHG emissions certification. The
Phase 2 final default test procedure for generating an engine map for
GEM's 55 mph and 65 mph drive cycles is the ``steady-state'' mapping
procedure. However, the agencies are finalizing an option for
manufacturers to use the ``cycle average'' mapping procedure for GEM's
55 mph and 65 mph drive cycles. The test procedure for generating an
engine map for GEM's ARB Transient drive cycle is the ``cycle-average''
mapping procedure, and the agencies are not finalizing any other
mapping options for the ARB Transient drive cycle. Note that if an
engine manufacturer elects to conduct powertrain testing to generate
inputs for GEM, then steady-state and cycle-average engine maps would
not be required for those GEM vehicle configurations to which the
powertrain test inputs would apply. The steady-state and cycle-average
test procedures are specified in 40 CFR parts 1036 and 1065. The
technical and confidential business information motivations for
finalizing these test procedures are explained in II. B. (2), along
with a summary of comments we received.
One important consideration is the need to correct measured fuel
consumption rates for the carbon and energy content of the test fuel.
As proposed, we will continue the Phase 1 approach, which is specified
in 40 CFR 1036.530. We are specifying a similar approach to GEM fuel
maps in Phase 2.
As proposed, the agencies are requiring that engine manufacturers
certify fuel maps for GEM, as part of their certification to the engine
standards. However, there were a number of manufacturer comments
strongly questioning the particular proposed requirement that engine
manufacturers provide these maps to vehicle manufacturers starting in
MY 2020 for the certification of vehicles commercially marketed as MY
2021 vehicles in calendar year 2020. This is a normal engine and
vehicle manufacturing process, where many vehicles may be produced with
engines having an earlier model year than the commercial model year of
the vehicle. For example, we expect that some MY 2021 vehicles will be
produced with MY 2020 engines. Thus, we proposed to require engine
manufacturers to begin providing GEM fuel maps for MY 2020 engines so
that vehicle manufacturers could run GEM to certify MY 2021 vehicles
with MY 2020 engines. EMA and some of its members commented that MY
2020 engines should not be subject to Phase 2 requirements, based on
NHTSA's statutory 4-year lead-time requirement and because the
potential higher fuel consumption of MY 2020 (i.e., Phase 1) engine
maps could force vehicle manufacturers to install additional
technologies that were not projected by the agencies for compliance.
The agencies considered these comments along with the potential cost
savings for manufacturers to align the timing of both their engines'
and vehicle's Phase 2 product plans and certification paths. The
agencies also considered how this situation would repeat in MY 2024 and
MY 2027 and possibly with future standards as well. Based on these
considerations, we have decided that it would be more appropriate to
harmonize the engine and vehicle standards, starting in MY 2021 so that
vehicle manufacturers will not need fuel maps for 2020 engines. Thus,
we are not finalizing the requirement to provide fuel maps for MY 2020
engines. However, we are requiring fuel maps for all MY 2021 engines,
even those (e.g., small businesses) for which the Phase 2 engine and
vehicle standards have been delayed. See 40 CFR 1036.150.
The current engine test procedures also require the development of
regeneration emission rate and frequency factors to determine
infrequent regeneration adjustment factors (IRAFs) that account for the
emission changes for criteria pollutants during an exhaust emissions
control system regeneration event. In Phase 1 the agencies adopted
provisions to exclude CO2 emissions and fuel consumption due
to regeneration. However, for Phase 2, we are requiring the inclusion
of CO2 emissions and fuel consumption due to regeneration
over the FTP and SET (RMC) cycles, as determined using the IRAF
provisions in 40 CFR 1065.680. While some commenters opposed this
because of its potential impact on stringency, we do not believe this
will significantly impact the stringency of these standards because
manufacturers have already made great progress in reducing the
frequency and impact of regeneration emissions since 2007. Rather, the
agencies are including IRAF CO2 emissions for Phase 2 to
prevent these emissions from increasing in the future to the point
where they would otherwise become significant. Manufacturers
qualitatively acknowledged the likely already small and decreasing
magnitude of IRAF CO2 emissions in their comments. For
example, EMA stated, ``the rates of infrequent regenerations have been
going down since the adoption of the Phase 1 standards'' and that IRAF
``contributions are minor.'' Nevertheless, we believe it is prudent to
begin accounting for regeneration emissions to discourage manufacturers
from adopting criteria emissions compliance strategies that could
reverse this trend. Manufacturers expressed concern about the
additional test burden, but the only additional requirement would be to
measure and report CO2 emissions for the same tests they are
already performing to determine IRAFs for other pollutants.
At the time of the proposal, we did not specifically adjust
baseline levels to include additional IRAF emissions because we
believed them to be negligible and decreasing. Commenters opposing this
proposed provision provided no data to dispute this belief. We continue
to believe that regeneration strategies can be engineered to maintain
these negligible rates. Thus, we do not believe they are of fundamental
significance for our baselines in the FRM. Highway operation includes
enough high temperature operation to make active regenerations
unnecessary. Furthermore, recent improvements in exhaust after-
treatment catalyst formulations and exhaust temperature thermal
management strategies, such as intake air throttling, minimize
CO2 IRAF impacts during non-highway operation, where active
regeneration might be required. Finally, as is discussed in Section
II.D.(2), recent significant
[[Page 73552]]
efficiency improvements over the FTP cycle suggest that FTP emissions
may actually be even lower than we have estimated in our updated FTP
baselines, which would provide additional margin for manufacturers to
manage any minor CO2 IRAF impacts that may occur.
We are not including fuel consumption due to after-treatment
regeneration in the creation of fuel maps used in GEM for vehicle
compliance. We believe that the IRAF requirements for the separate SET
and FTP engine standards, along with market forces that already exist
to minimize regeneration events, will create sufficient incentives to
reduce fuel consumption during regeneration over the entire fuel map.
(c) Powertrain Testing
The agencies are finalizing a powertrain test option to afford a
robust mechanism to quantify the benefits of CO2 reducing
technologies that are a part of the powertrain (conventional or
hybrid), that are not captured in the GEM simulation. Among these
technologies are integrated engine and transmission control and hybrid
systems. We are finalizing a number of improvements to the test
procedure in 40 CFR 1037.550. As proposed we are finalizing the
requirement for Phase 2 hybrid powertrains to mapped using this
powertrain test method. The agencies are also finalizing modifications
to 40 CFR 1037.550 to separate out the hybrid specific testing
protocols.
To limit the amount of testing under this rule, powertrains can be
divided into families and are tested in a limited number of simulated
vehicles that will cover the range of vehicles in which the powertrain
will be used. A matrix of 8 to 9 tests will be needed per vehicle
cycle, to enable the use of the powertrain results broadly across all
the vehicles in which the powertrain will be installed. The individual
tests differ by the vehicle that is being simulated during the test.
These are discussed in detail in Chapter 3.6 of the RIA.
(i) Powertrain Test Procedure
The agencies are expanding upon the test procedures defined 40 CFR
1037.550 for Phase 1 hybrid vehicles. The Phase 2 expansion will
migrate the current Phase 1 test procedure to a new 40 CFR 1037.555 and
will modify the current test procedure in 40 CFR 1037.550, allowing its
use for Phase 2 only. The Phase 2 modifications relative to 40 CFR
1037.550 include the addition of the rotating inertia of the driveline
and tires, and the axle efficiency. This revised procedure also
requires that each of the powertrain components be cooled so that the
temperature of each of the components is kept in the normal operation
range. We are extending the powertrain procedure to PHEV powertrains.
Powertrain testing contains many of the same requirements as engine
dynamometer testing. The main differences are where the test article
connects to the dynamometer and the software that is used to command
the dynamometer and operator demand setpoints. The powertrain procedure
finalized in Phase 2 allows for the dynamometer(s) to be connected to
the powertrain either upstream of the drive axle or at the wheel hubs.
The output of the transmission is upstream of the drive axle for
conventional powertrains. In addition to the transmission, a hydraulic
pump or an electric motor in the case of a series hybrid may be located
upstream of the drive axle for hybrid powertrains. If optional testing
with the wheel hub is used, two dynamometers will be needed, one at
each hub. Beyond these points, the only other difference between
powertrain testing and engine testing is that for powertrains, the
dynamometer and throttle setpoints are not set by fixed speed and
torque targets prescribed by the cycle, but are calculated in real time
by the vehicle model. The powertrain test procedure requires a forward
calculating vehicle model, thus the output of the model is the
dynamometer speed setpoints. The vehicle model calculates the speed
target using the measured torque at the previous time step, the
simulated brake force from the driver model, and the vehicle parameters
(tire rolling resistance, drag area, vehicle mass, rotating mass, and
axle efficiency). The operator demand that is used to change the torque
from the engine is controlled such that the powertrain follows the
vehicle speed target for the cycle instead of being controlled to match
the torque or speed setpoints of the cycle. The emission measurement
procedures and calculations are identical to engine testing.
(ii) Engine Test Procedures for Replicating Powertrain Tests
As described in Section II.B.(2)(b), the agencies are finalizing
the proposed powertrain test option to quantify the benefits of
CO2-reducing powertrain technologies. This option is very
similar to the cycle average mapping approach, although these
powertrain test results would be used to override both the engine and
transmission (and possibly axle) simulation portions of GEM, not just
the engine fuel map. The agencies are requiring that any manufacturer
choosing to use this option also measure engine speed and engine torque
during the powertrain test so that the engine's performance during the
powertrain test could be replicated in a non-powertrain engine test
cell. Manufacturers would be required to measure or calculate, using
good engineering judgment, the engine shaft output torque, which would
be close-coupled to the transmission input shaft during a powertrain
test. Subsequent engine testing then could be conducted using the
normal part 1065 engine test procedures as specified in 40 CFR
1037.551, and g/bhp-hr CO2 results could be compared to the
levels the manufacturer reported during certification. Such testing
could apply for both confirmatory and selective enforcement audit (SEA)
testing. This would simplify both the certification and SEA testing.
As proposed, engine manufacturers certifying powertrain performance
(instead of or in addition to the multi-point fuel maps) will be held
responsible for powertrain test results. If the engine manufacturer
does not certify powertrain performance and instead certifies only the
steady-state and/or cycle-average fuel maps, it will held responsible
for fuel map performance rather than the powertrain test results.
Engine manufacturers certifying both will be responsible for both.
Some commenters objected to the potential liability for such
engine-only tests. However, it appears they do not understand our
intent. This provision states clearly that this approach could be used
only where ``the test engine's operation represents the engine
operation observed in the powertrain test.'' Also, since the
manufacturers perform all SEA testing themselves, this would be an
option for the manufacturer rather than something imposed by EPA. Thus,
this concern should be limited to the narrow circumstance in which EPA
performs confirmatory engine testing of an engine that was certified
using powertrain testing, follows the manufacturer's specified engine
test cycle, and ensures that the test accurately represents the
engine's performance during the powertrain test. However, it is not
clear why this would be problematic. It is entirely reasonable to
assume that testing the engine in this way would result in equivalent
emission results. To the extent manufacturer concerns remain, each
manufacturer would be free to certify their engines based on engine-
only fuel maps rather than powertrain testing.
(d) CO2 From Urea SCR Systems
For diesel engines utilizing urea SCR emission control systems for
NOX
[[Page 73553]]
reduction, the agencies will allow, but not require, correction of the
final engine (and powertrain) fuel maps to account for the contribution
of CO2 from the urea injected into the exhaust. This urea
typically contributes 0.2 to 0.5 percent of the total CO2
emissions measured from the engine, and up to 1 percent at certain map
points. Since current urea production methods use gaseous
CO2 captured from the atmosphere (along with
NH3), CO2 emissions from urea consumption does
not represent a net carbon emission. This adjustment is necessary so
that fuel maps developed from CO2 measurements will be
consistent with fuel maps from direct measurements of fuel flow rates.
This adjustment is also necessary to fully align EPA's CO2
standards with NHTSA's fuel consumption standards. Failing to account
for urea CO2 tailpipe emissions would result in reporting
higher fuel consumption than what was actually consumed. Thus, we are
only allowing this correction for emission tests where CO2
emissions are determined from direct measurement of CO2 and
not from fuel flow measurement, which would not be impacted by
CO2 from urea.
We note that this correction will be voluntary for manufacturers,
and we expect that some manufacturers may determine that the correction
is too small to be of concern. The agencies will use this correction
for CO2 measurements with any engines for which the engine
manufacturer applied the correction for its fuel maps during
certification.
We are not allowing this correction for engine test results with
respect to the engine CO2 standards. Both the Phase 1
standards and the new standards for CO2 from diesel engines
are based on test results that included CO2 from urea. In
other words, these standards are consistent with using a test procedure
that does not correct for CO2 from urea.
(2) Engine Standards for CO2 and Fuel Consumption
We are largely maintaining the existing Phase 1 regulatory
structure for engine standards, which had separate standards for spark-
ignition engines (such as gasoline engines) and compression-ignition
engines (such as diesel engines), and for HHD, MHD and LHD engines, but
we are changing how these standards will apply to alternative fuel
engines as described in Section XII.A.2.
Phase 1 applied different test cycles depending on whether the
engine is used for tractors, vocational vehicles, or both, and we are
continuing this approach. Tractor engines are subject to standards over
the SET, while vocational engines are subject to standards over the
FTP. Table II-3 shows the Phase 1 standards for diesel engines.
Table II-3--Phase 1 MY 2017 Diesel Engine CO2 and Fuel Consumption Standards
--------------------------------------------------------------------------------------------------------------------------------------------------------
Units HHD SET MHD SET HHD FTP MHD FTP LHD FTP
--------------------------------------------------------------------------------------------------------------------------------------------------------
g/bhp-hr................................................. 460 487 555 576 576
gal/100 bhp-hr........................................... 4.5187 4.7839 5.4519 5.6582 5.6582
--------------------------------------------------------------------------------------------------------------------------------------------------------
In the Phase 2 proposal we assumed that these numeric values of the
Phase 1 standards were the baselines for Phase 2. We applied our
technology assessments to these baselines to arrive at the Phase 2
standards for MY 2021, MY 2024 and MY 2027. In other words, for the
Phase 2 proposal we projected that starting in MY 2017 engines would,
on average, just meet the Phase 1 standards and not over-comply.
However, based on comments we received on how to consistently apply our
new SET weighting factors in our analysis and based on recent MY 2016
engine certification data, we are updating our Phase 2 baseline
assumptions for both the SET and FTP.
First, with respect to the SET, in the proposal we compared our
proposed Phase 2 standards, which are based on these new Phase 2
weighting factors, to the Phase 1 numeric standards, which are based on
the current Phase 1 weighting factors. Because we continue to use the
same 13-mode brake specific CO2 and fuel consumption numeric
values we used for the proposal to represent the performance of a MY
2017 baseline engine, we are not projecting a different technology
level in the baseline. Rather, this is simply correcting an ``apples-
to-oranges'' comparison from the proposal by applying the Phase 2
weighting factors to the MY 2017 baseline engine. This was pointed out
to us by UCS, ICCT and EDF in their public comments. While this did not
impact our technology effectiveness or cost analyses, it did impact the
numeric value of our baseline to which we reference the effectiveness
of applying technologies to the 13 individual modes of the SET. Because
the revised SET weighting factors result in somewhat lower brake
specific CO2 and fuel consumption numeric results for the
composite baseline SET value, this correction, in turn, lowers the
numerical values of the final Phase 2 SET standards. Making this
particular update did not result in a change to the relative stringency
of the final Phase 2 numeric engine standards (relative to MY 2017
baseline performance), but our updated feasibility analysis did; see
Section II.D.(2)(a) below).
Second, the agencies made adjustments to the FTP baselines, but
these adjustments were not made because of a calculation error. Rather,
MY 2016 FTP certification data showed an unexpected step-change
improvement in engine fuel consumption and CO2 emissions.
These data were not available at the time of proposal, so the agencies
relied upon the MY 2017 Phase 1 standard as a baseline. EDF publicly
commented in response to the NODA that the more recent certification
data revealed this new step-change. MY 2016 certification data
submitted to the agencies \177\ as well as to ARB \178\ show that many
engines from many manufacturers already not only achieve the Phase 1
FTP standards, but some were also below the MY 2027 standards proposed
for Phase 2. This was not the case for the SET, where most
manufacturers are still not yet complying with the MY 2017 Phase 1 SET
standards. In view of this situation for the FTP, the agencies are
adjusting the Phase 2 FTP baseline to reflect this shift. The
underlying reasons for this shift are mostly related to manufacturers
optimizing their SCR thermal management strategy over the FTP in ways
that we (mistakenly) thought they already had in MY 2010 (i.e., the
Phase 1 baseline). As background, the FTP includes a cold-start, a hot-
start and significant time spent at engine idle. During these portions
of the FTP, the NOX SCR system can cool down and lose
NOX reducing efficiency. One simplistic strategy to maintain
SCR temperature is to inefficiently consume additional fuel, such that
the fuel energy is lost to the
[[Page 73554]]
exhaust system in the form of heat. There are more sophisticated
strategies to maintain SCR temperature, however, but these apparently
required additional time from MY 2010 for research, development and
refinement. In updating these baseline values, the agencies did
consider the concerns raised by manufacturers about the potential
impact of IRAFs on baseline emissions.
---------------------------------------------------------------------------
\177\ https://www3.epa.gov/otaq/certdata.htm#oh.
\178\ http://www.arb.ca.gov/msprog/onroad/cert/mdehdehdv/2016/2016.php.
---------------------------------------------------------------------------
As just noted, at the time of Phase 1 we had not realized that
these improvements were not already in the Phase 1 baseline. These
include optimizing the use of an intake throttle to decrease excess
intake air at idle and SCR catalyst reformulation to maintain SCR
efficiency at lower temperatures. Based on this information, which was
provided to the agencies by engine manufacturers, but only after we
specifically requested this information, the agencies concluded that in
Phase 1 we did not account for how much further these kinds of
improvements could still impact FTP fuel consumption. Conversely, only
by reviewing the new MY 2016 certification data did we realize how
little SCR thermal management optimization actually occurred for the
engine model years that we used to establish the Phase 1 baseline--
namely MY 2009 and MY 2010 engines. Because we never accounted for this
kind of improvement in our Phase 2 proposal's stringency analysis for
meeting the Phase 2 proposed FTP standards, this baseline shift does
not alter our projected effectiveness and market adoption rates from
the proposal. Therefore, we continue to apply the same improvements
that we proposed, but we apply them to the updated FTP baseline. See
Section II.D.(5) for a discussion on how this impacts carry-over of
Phase 1 emission credits.
Table II-4 shows the Phase 2 diesel engine final CO2
baseline emissions. Note that the gasoline engine CO2
baseline for Phase 2 is the same as the Phase 1 HD gasoline FTP
standard, 627 g/bhp-hr. More detailed analyses on these Phase 2
baseline values of tractor and vocational vehicles can be found in
Chapter 2.7.4 of RIA.
Table II-4--Phase 2 Diesel Engine Final CO2 and Fuel Consumption Baseline Emissions
--------------------------------------------------------------------------------------------------------------------------------------------------------
Units HHD SET MHD SET HHD FTP MHD FTP LHD FTP
--------------------------------------------------------------------------------------------------------------------------------------------------------
g/bhp-hr................................................. 455 481 525 558 576
gal/100 bhp-hr........................................... 4.4695 4.7250 5.1572 5.4813 5.6582
--------------------------------------------------------------------------------------------------------------------------------------------------------
As described below, the agencies are adopting standards for new
compression-ignition engines for Phase 2, commencing in MY 2021, that
will require additional reductions in CO2 emissions and fuel
consumption beyond the Phase 2 baselines. The agencies are not adopting
new CO2 or fuel consumption engine standards for new heavy-
duty gasoline engines. Note, however, that we are projecting some small
improvement in gasoline engine performance that will be recognized over
the vehicle cycles (that is, reflected in the stringency of certain of
the vocational vehicle standards). See Section V.B.2.a below.
For diesel engines to be installed in Class 7 and 8 combination
tractors, the agencies are adopting the SET standards shown in Table
II-5.\179\ The MY 2027 SET standards for engines installed in tractors
will require engine manufacturers to achieve, on average, a 5.1 percent
reduction in fuel consumption and CO2 emissions beyond the
Phase 2 baselines. We are also adopting SET standards in MY 2021 and MY
2024 that will require tractor engine manufacturers to achieve, on
average, 1.8 percent and 4.2 percent reductions in fuel consumption and
CO2 emissions, respectively, beyond the Phase 2 baselines.
---------------------------------------------------------------------------
\179\ 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.
\180\ Tractor engine standards apply to all tractor engines,
without regard to the actual fuel (e.g., diesel or natural gas) or
engine-cycle classification (e.g., compression-ignition or spark-
ignition).
Table II-5--Phase 2 Heavy-Duty Tractor Engine Standards for Engines 180 Over the SET Cycle
----------------------------------------------------------------------------------------------------------------
Heavy heavy- Medium heavy-
Model year Standard duty duty
----------------------------------------------------------------------------------------------------------------
2021-2023..................................... CO2 (g/bhp-hr).................. 447 473
Fuel Consumption (gallon/100 bhp- 4.3910 4.6464
hr).
2024-2026..................................... CO2 (g/bhp-hr).................. 436 461
Fuel Consumption (gallon/100 bhp- 4.2829 4.5285
hr).
2027 and Later................................ CO2 (g/bhp-hr).................. 432 457
Fuel Consumption (gallon/100 bhp- 4.2436 4.4892
hr).
----------------------------------------------------------------------------------------------------------------
For diesel engines to be installed in vocational chassis, the
agencies are adopting the FTP standards shown in Table II-6. The MY
2027 FTP standards for engines installed in vocational chassis will
require engine manufacturers to achieve, on average, a 4.2 percent
reduction in fuel consumption and CO2 emissions beyond the
Phase 2 baselines. We are also adopting FTP standards in MY 2021 and MY
2024 that will require vocational chassis engine manufacturers to
achieve, on average, 2.3 percent and 3.6 percent reductions in fuel
consumption and CO2 emissions, respectively, beyond the
Phase 2 baselines.
[[Page 73555]]
Table II-6--Vocational Diesel (CI) Engine Standards Over the Heavy-Duty FTP Cycle
----------------------------------------------------------------------------------------------------------------
Medium heavy- Light heavy-
Model year Standard Heavy heavy- duty diesel duty diesel
duty \181\ \181\ \182\
----------------------------------------------------------------------------------------------------------------
2021-2023............................. CO2 (g/bhp-hr).......... 513 545 563
Fuel Consumption (gallon/ 5.0393 5.3536 5.5305
100 bhp-hr).
2024-2026............................. CO2 (g/bhp-hr).......... 506 538 555
Fuel Consumption (gallon/ 4.9705 5.2849 5.4519
100 bhp-hr).
2027 and Later........................ CO2 (g/bhp-hr).......... 503 535 552
Fuel Consumption (gallon/ 4.9411 5.2554 5.4224
100 bhp-hr).
----------------------------------------------------------------------------------------------------------------
(a) Feasibility of the Diesel (Compression-Ignition) Engine Standards
---------------------------------------------------------------------------
\181\ Heavy heavy-duty engine standards apply to all heavy
heavy-duty engines, without regard to the actual fuel (e.g., diesel
or natural gas) or engine-cycle classification (e.g., compression-
ignition or spark-ignition).
\182\ The agencies are not adopting new CO2 or fuel
consumption engine standards for new heavy-duty gasoline engines.
Therefore, the Phase 2 HD gasoline FTP standard is the same as the
Phase 1 HD gasoline FTP standard, 627 g/bhp-hr, 7.0552 gallon/100
bhp-hr.
---------------------------------------------------------------------------
In this section, the agencies discuss our assessment of the
feasibility of the engine standards and the extent to which they
conform to our respective statutory authorities and responsibilities.
More details on the technologies discussed here can be found in RIA
Chapter 2.3. The feasibility of these standards is further discussed in
RIA Chapter 2.7 for tractor and vocational vehicle engines. While the
projected technologies are discussed here separately, as is discussed
at the beginning of this Section II.D, the agencies also accounted for
dis-synergies between technologies. Note that Section II.D.(2)(e)
discusses the potential for some manufacturers to achieve greater
emission reductions by introducing new engine platforms, and how and
why these reductions are reflected in the tractor and vocational
vehicle standards.
Based on the technology analysis described below, the agencies
project that a technology path exists that will allow engine
manufacturers to meet the final Phase 2 standards by 2027, and to meet
the MY 2021 and 2024 standards. The agencies also project that these
manufacturers will be able to meet these standards at a reasonable cost
and without adverse impacts on in-use reliability.
In general, engine performance for CO2 emissions and
fuel consumption can be improved by improving the internal combustion
process and by reducing energy losses. More specifically, the agencies
have identified the following key means by which fuel efficiency can be
improved:
Combustion optimization
Turbocharger design and optimization
Engine friction and other parasitic loss reduction
Exhaust after-treatment pressure drop reduction
Intake air and exhaust system pressure drop reduction
(including EGR system)
Engine down-sizing to improve core engine efficiency
Engine down-speeding over the SET, and in-use, by lug
curve shape optimization
Waste heat recovery system installation and optimization
Physics model based electronic controls for transient
performance optimization
The agencies are gradually phasing in the separate engine standards
from 2021 through 2027 so that manufacturers can gradually introduce
these technology improvements. For most of these, the agencies project
manufacturers could begin applying these technologies to about 45-50
percent of their heavy-duty engines by 2021, 90-95 percent by 2024, and
ultimately apply them to 100 percent of their heavy-duty engines by
2027. However, for some of these improvements (such as waste heat
recovery and engine downsizing) we project lower application rates in
the Phase 2 time frame. This phase-in structure is consistent with the
normal manner in which manufacturers introduce new technology to manage
limited R&D budgets as well as to allow them to work with fleets to
fully evaluate in-use reliability before a technology is applied fleet-
wide. The agencies believe the phase-in schedule will allow
manufacturers to complete these normal processes. See RIA 2.3.9.
Based on our technology assessment described below, the engine
standards appear to be consistent with the agencies' respective
statutory authorities. All of the technologies with high penetration
rates above 50 percent have already been demonstrated to some extent in
the field or in research laboratories, although some development work
remains to be completed. We note that our feasibility analysis for
these engine standards is not based on projecting 100 percent
application for any technology until 2027. We believe that projecting
less than 100 percent application is appropriate and gives us
additional confidence that the 2021 and 2024 MY standards are feasible.
Because this analysis considers reductions from engines meeting the
Phase 1 standards, it assumes manufacturers will continue to include
the same compliance margins as in Phase 1. In other words, a
manufacturer currently declaring FCLs 10 g/bhp-hr above its measured
emission rates (in order to account for production and test-to-test
variability) will continue to do the same in Phase 2. Both the costs
and benefits are determined relative to these baselines, and so are
reflective of these compliance margins.
The agencies have carefully considered the costs of applying these
technologies, which are summarized in Section II.D.(2)(d). These costs
appear to be reasonable on both a per engine basis, and when
considering payback periods.\183\ The engine technologies are discussed
in more detail below. Readers are encouraged to see the RIA Chapter 2.7
for additional details (and underlying references) about our
feasibility analysis.
---------------------------------------------------------------------------
\183\ See Section IX.M for additional information about payback
periods.
---------------------------------------------------------------------------
(i) Combustion Optimization
Although manufacturers are making significant improvements in
combustion to meet the Phase 1 engine standards, the agencies project
that even more improvement is possible after 2018. For example,
improvements to fuel injection systems will allow more flexible fuel
injection capability with higher injection pressure, which can provide
more opportunities to improve engine fuel efficiency. Further
optimization of piston bowls and injector tips will also improve engine
performance and fuel efficiency. We project that a reduction of up to
1.0 percent is feasible in the 2024 model year through the use of
[[Page 73556]]
these technologies, although it will likely apply to only 95 percent of
engines until 2027.
Another important area of potential improvement is advanced engine
control incorporating model based calibration to reduce losses of
control during transient operation. Improvements in computing power and
speed will make it possible to use much more sophisticated algorithms
that are more predictive than today's controls. Because such controls
are only beneficial during transient operation, they will reduce
emissions over the FTP cycle, over the ARB Transient cycle's cycle-
average mapping procedure, and during in-use operation, but this
technology will not reduce emissions over the SET cycle or over the
steady-state engine mapping procedure. Thus, the agencies are
projecting model based control reductions only for vocational engines'
FTP standards and for projecting improvements captured by the cycle-
average mapping over the ARB Transient cycle. Although this control
concept is not currently available and is still under development, we
project model based controls achieving a 2 percent improvement in
transient emissions. Based on model based controls already in
widespread use in engine laboratories for the calibration of simpler
controllers and based on recent model based control development under
the DOE SuperTruck partnership (e.g., DTNA's SuperTruck engine's model
based controls), we project that such controls could be in limited
production for some engine models by 2021. We believe that some
vocational chassis applications would particularly benefit from these
controls in-use (e.g., urban applications with significant in-use
transient operation). Therefore, we project that a modest amount of
engine models will have these controls by MY 2021. We also project that
manufacturers will learn more from the in-use operation of these
technology leading engines, and manufacturers will be able to improve
these controls even further, such that they would additionally benefit
other vocational applications, such as multi-purpose and regional
applications. By 2027, we project that 40 percent of all vocational
diesel engines will incorporate model-based controls at a 2 percent
level of effectiveness.
(ii) Turbocharging System
Many advanced turbocharger technologies can be brought into
production in the time frame between 2021 and 2027, and some of them
are already in production, such as mechanical or electric turbo-
compounding, more efficient variable geometry turbines, and Detroit
Diesel's patented asymmetric turbocharger. A turbo-compound system,
like those installed on some of Volvo's EURO VI compliant diesels and
on some of DTNA's current U.S. offerings (supplied to DTNA by a
division of Cummins), extracts energy from the exhaust to provide
additional power. Mechanical turbo-compounding includes a power turbine
located downstream of the turbine which in turn is connected to the
crankshaft to supply additional power. On-highway demonstrations of
this technology began in the early 1980s. It was used first in heavy
duty production in the U.S. by Detroit Diesel for their DD15 and DD16
engines and reportedly provided a 3 to 5 percent fuel consumption
reduction. Results are duty cycle dependent, and require significant
time at high load to realize an in-use fuel efficiency improvement.
Lightly loaded vehicles on flat roads or at low vehicle speeds can
expect little or no benefit. Volvo reports two to four percent fuel
consumption improvement in line haul applications.\184\ Because of
turbo-compound technology's drive cycle dependent effectiveness, the
agencies are only projecting a market penetration of 10 percent for all
tractor engines, at slightly less than 2 percent effectiveness over the
SET. The agencies are considering turbo-compound to be mutually
exclusive with WHR because both technologies seek to extract additional
usable work from the same waste heat and are unlikely to be used
together.
---------------------------------------------------------------------------
\184\ http://www.volvotrucks.us/powertrain/d13/.
---------------------------------------------------------------------------
(iii) Engine Friction and Parasitic Losses
The friction associated with each moving part in an engine results
in a small loss of engine power. For example, frictional losses occur
at bearings, in the valve train, and at the piston ring-cylinder
interface. Taken together such losses represent a measurable fraction
of all energy lost in an engine. For Phase 1, the agencies projected a
1-2 percent reduction in fuel consumption due to friction reduction.
However, new information leads us to project that an additional 1.4
percent reduction is possible for some engines by 2021 and all engines
by 2027. These reductions are possible due to improvements in bearing
materials, lubricants, and new accessory designs such as variable-speed
pumps.
(iv) After-Treatment Optimization
All heavy duty diesel engine manufacturers are already using diesel
particulate filters (DPFs) to reduce particulate matter (PM) and
selective catalytic reduction (SCR) to reduce NOX emissions.
The agencies see two areas in which improved after-treatment systems
can also result in lower fuel consumption. First, increased SCR
efficiency could allow re-optimization of combustion for better fuel
consumption because the SCR would be capable of reducing higher engine-
out NOX emissions. We don't expect this to be significant,
however. Manufacturers already optimize the DEF (urea) consumption and
fuel consumption to achieve the lowest cost of operation; taking into
account fuel consumption, DEF consumption and the prices of fuel and
DEF. Therefore, if manufacturers re-optimized significantly for fuel
consumption, it is possible that this would lead to higher net
operating costs. This scenario is highly dependent upon fuel and DEF
prices, so projecting this technology path is uncertain. Second,
improved designs could reduce backpressure on the engine to lower
pumping losses. If manufacturers have opportunities to lower
backpressure within the size constraints of the vehicle, the agencies
project that manufacturers will opt to lower after-treatment back
pressure. The agencies project the combined impact of these
improvements would be 0.6 percent over the SET.
Note that this improvement is independent of cold-start
improvements made recently by some manufacturers with respect to
vocational engines. Thus, the changes being made to the FTP baseline
engines do not reduce the likelihood of the benefits of re-optimizing
after-treatment projected here.
(v) Engine Intake and Exhaust Systems
Various high efficiency air handling for both intake air and
exhaust systems could be produced in the 2020 and 2024 time frame. 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 will likely include higher efficiency EGR systems and
intercoolers that reduce frictional pressure losses while maximizing
the ability to thermally control induction air and EGR. EGR systems
that often rely upon an adverse pressure gradient (exhaust manifold
pressures greater than intake manifold pressures) must be reconsidered
and their adverse pressure gradients
[[Page 73557]]
minimized. Other components that offer opportunities for improved flow
efficiency include cylinder heads, ports and exhaust manifolds to
further reduce pumping losses by about 1 percent over the SET.
(vi) Engine Downsizing and Down Speeding
Proper sizing of an engine is an important component of optimizing
a vehicle for best fuel consumption. This Phase 2 rule will require
reductions in road load due to aerodynamic resistance, tire rolling
resistance and weight, which will result in a drop in the vehicle power
demand for most operation. This drop moves the engine operating points
down to a lower load zone, which can move the engine away from
operating near its peak thermal efficiency (a.k.a. the ``sweet spot'').
Engine downsizing combined with engine down speeding can allow the
engine to move back to higher loads and a lower speed zone, thus
achieving better fuel efficiency in the real world. However, because of
the way engines are tested, little of the benefit of engine downsizing
would be detected during engine testing (if power density remains the
same) because the engine test cycles are de-normalized based on the
full torque curve. Thus, the separate engine standards are not the
appropriate standards for recognizing the benefits of engine
downsizing. Nevertheless, we project that some small benefit can be
measured over the engine test cycles depending on the characteristics
of the engine fuel map and how the SET points are determined as a
function of the engine's lug curve.
After the proposal we received comments recommending that we should
recognize some level of engine down speeding within the separate engine
standards. Based on this comment and some additional confidential
business information that we received, we believe that engine lug curve
reshaping to optimize the locations of the 13-mode points is a way that
manufacturers can demonstrate some degree of engine down-speeding over
the engine test. As pointed out in Chapter 2.3.8 and 2.7.5 of the RIA,
down speeding via lug curve reshaping alone can provide SET reductions
in the range of 0.4 percent depending on the engine map
characteristics.
(vii) Waste Heat Recovery
More than 40 percent of all energy loss in an engine is lost as
heat to the exhaust and engine coolant. For many years, manufacturers
have been using turbochargers to convert some of this waste heat in the
exhaust into usable mechanical power that is then used to compress the
intake air. Manufacturers have also been developing a Rankine cycle-
based system to extract additional heat energy from the engine. Such
systems are often called waste heat recovery (WHR) systems. The
possible sources of waste heat energy include the exhaust, recirculated
exhaust gases, compressed charge air, and engine coolant. The basic
approach with WHR is to use waste heat from one or more of these
sources to evaporate a working fluid, which is passed through a turbine
or equivalent expander to create mechanical or electrical power, then
re-condensed.
For the proposal, the agencies projected that by 2027, 15 percent
of tractor engines would employ WHR systems with an effectiveness of
better than three percent. We received many comments on this
projection, which are discussed briefly below and in more detail in the
RTC. In particular, we note that some of the comments included
confidential data related to systems not yet on the market. After
carefully considering all of these comments, we have revised our
projections to increase the effectiveness, decrease costs, and project
higher adoption rates than we proposed.
Prior to the Phase 1 Final Rule, the NAS estimated the potential
for WHR to reduce fuel consumption by up to 10 percent.\185\ However,
the agencies do not believe such levels will be achievable within the
Phase 2 time frame. There currently are no commercially available WHR
systems for diesel engines, although research prototype systems are
being tested by some manufacturers. American Trucking Association,
Navistar, DTNA, OOIDA, Volvo, and UPS commented that because WHR is
still in the prototype stage, it should not be assumed for setting the
stringency of the tractor engine standards. Many of these commenters
pointed to the additional design and development efforts that will be
needed to reduce cost, improve packaging, reduce weight, develop
controls, select an appropriate working fluid, implement expected OBD
diagnostics, and achieve the necessary reliability and durability. Some
stated that the technology has not been thoroughly tested or asked that
more real-world data be collected before setting standards based on
WHR. Some of these commenters provided confidential business
information pertaining to their analysis of WHR system component costs,
failure modes, and projected warranty cost information.
---------------------------------------------------------------------------
\185\ See 2010 NAS Report, page 57.
---------------------------------------------------------------------------
Alternatively, a number of commenters including Cummins, ICCT,
CARB, ACEEE, EDF, Honeywell, ARB and others stated that the agencies
should increase the assumed application rate of WHR in the final rule
and the overall stringency of the engine standards. They argued the
agencies' WHR technology assessment was outdated and too conservative,
the fuel savings and GHG reduction estimation for WHR were too low, and
the agencies' cost estimates were based on older WHR systems where
costs were confounded with hybrid component costs and that these have
since been improved upon. In addition, the agencies received CBI
information supporting the arguments of some of these commenters.
Cummins stated the agencies underestimated the commercial viability
of WHR and that we overstated the development challenges and timing in
the NPRM. They said WHR can provide a 4 to 5 percent improvement in
fuel consumption on tractor drive cycles and that WHR would be
commercially viable and available in production as early as 2020 and
will exceed the agencies' estimates for market penetration over the
period of the rule. According to Cummins, the reliability of their WHR
system has improved with each generation of the technology and they
have developed a smaller system footprint, improved integration with
the engine and vehicle and a low-GWP working fluid, resulting in a much
more compact and integrated system. They added that their system would
be evaluated in extended customer testing by the end of 2015, and that
results of that experience will inform further technology development
and product engineering leading to expected commercial product
availability in the 2020 timeframe. Furthermore, they said multiple
product development cycles over the implementation timeframe of the
rule would provide opportunities for further development for reduced
cost and improved performance and reliability.
Some commenters, including EDF, said the agencies' assumed design
had little in common with the latest designs planned for production.
They cited several publications, including the NAS 21st Century Truck
Program report #3 and stated WHR effectiveness is much higher than the
agencies estimated. Gentham cited an ICCT study saying that up to a 12
percent fuel consumption reduction from a 2010 baseline engine is
possible with the application of advanced engine technologies and WHR.
[[Page 73558]]
The agencies recognize that much work remains to be done, but we
are providing significant lead time to bring WHR to market. Based on
our assessment of each manufacturer's work to date, we are confident
that a commercially-viable WHR capable of reducing fuel consumption by
over three percent will be available in the 2021 to 2024 time frame.
Concerns about the system's cost and complexity may remain high enough
to limit the use of such systems in this time frame. Moreover,
packaging constraints and lower effectiveness under transient
conditions will likely limit the application of WHR systems to line-
haul tractors. Refer to RIA Chapter 2.3.9 for a detailed description of
these systems and their applicability. For our analysis of the engine
standards, the agencies project that WHR with the Rankine technology
could be used on 1 percent of tractor engines by 2021, on 5 percent by
2024, and 25 percent by 2027, with nearly all being used on sleeper
cabs. We project this sharper increase in market adoption in the 2027
timeframe because we have noted that most technology adoption rate
curves follow an S-shape: Slow initial adoption, then more rapid
adoption, and then a leveling off as the market saturates (not always
at 100 percent).\186\ We assumed an S-shape curve for WHR adoption,
where we project a steeper rise in market adoption in and around the
2027 timeframe. Given our averaging, banking and trading program
flexibilities and that manufacturers may choose from a range of other
technologies, we believe that manufacturers will be able to meet the
2027 standards, which we based on a 25 percent WHR adoption in tractor
engines. Although we project these as steps, it is more likely that
manufacturers will try to gradually increase the WHR adoption in MY
2025 and MY 2026 from the 5 percent in 2024 to generate emission
credits to smooth the transition to the 2027 standards.
---------------------------------------------------------------------------
\186\ NACFE 2015 Annual Fleet Fuel Study.
---------------------------------------------------------------------------
Commenters opposing the agencies' WHR projections argued that the
real-world GHG and fuel consumption savings will be less than in
prototype systems. DTNA said a heat rejection increase of 30 percent to
40 percent with WHR systems will require larger radiators, resulting in
more aerodynamic drag and lower fuel savings from WHR systems. DTNA
cited a Volvo study showing a 2 percent loss of efficiency with the
larger frontal areas needed to accommodate heat rejection from WHR
systems. Daimler stated effectiveness may be lower than expected since
there is large drop off in fuel savings when the tractor is not
operating on a steady state cycle and the real world performance of WHR
systems will be hurt by transient response issues. Daimler and ACEEE
said the energy available from exhaust and other waste heat sources
could diminish as tractor aerodynamics improve, thus lowering the
expected fuel savings from WHR. Daimler said because of this, WHR
estimated fuel savings was overestimated by the agencies. Navistar said
WHR working fluids will have a significant GHG impact based on their
high global warming potential. They commented that fuel and GHG
reductions will be lower in the real world with the re-weighting of the
RMC which results in lower engine load, and thus lower available waste
heat. However, none of these commenters have access to the full range
of data available to the agencies, which includes CBI.
It is important to note that the net cost and effectiveness of
future WHR systems depends on the sources of waste heat. Systems that
extract heat from EGR gases may provide the side benefit of reducing
the size of EGR coolers or eliminating them altogether. To the extent
that WHR systems use exhaust heat, they increase the overall cooling
system heat rejection requirement and likely require larger radiators.
This could have negative impacts on cooling fan power needs and vehicle
aerodynamics. Limited engine compartment space under the hood could
leave insufficient room for additional radiator size increasing. Many
of these issues disappear if exhaust waste heat is not recovered from
the tailpipe and brought under the hood for conversion to mechanical
work. In fact, it is projected that if a WHR system only utilizes heat
that was originally within the engine compartment (e.g., EGR cooler
heat, coolant heat, oil heat, etc.), then any conversion of that heat
to mechanical heat actually reduces the heat rejection demand under the
hood; potentially leading to smaller radiators and lower frontal area,
which would actually lead toward improved aerodynamic performance.
Refer to RIA Chapter 2.3.9 for more discussion.
Several commenters stated that costs are highly uncertain for WHR
technology, but argued that the agencies' assumption of a $10,523 cost
in 2027 are likely significantly lower than reality. Volvo estimated a
cost of $21,700 for WHR systems. Volvo said that in addition to
hardware cost being underestimated, the agencies had not properly
accounted for other costs such as the R&D needed to bring the
technology into production within a vehicle. Volvo said they would lose
$17,920 per unit R&D alone, excluding other costs such as materials and
administrative expenses. Daimler said that costs almost always inflate
as the complexity of real world requirements drive up need for more
robust designs, sensors, controls, control hardware, and complete
vehicle integration. They added that development costs will be large
and must be amortized over limited volumes. Furthermore, OOIDA said the
industry experience with such complex systems is that maintenance,
repair, and down-time cost can be much greater than the initial
purchase cost. ATA and OOIDA said that potential downtime associated
with an unproven technology is a significant concern for the industry.
On the other hand, some commenters argued that the agencies had
actually overestimated WHR costs in the proposal. These commenters
generally argued that engineering improvements to the WHR systems that
will go into production in the Phase 2 time frame would lower costs, in
particular by reducing components. The agencies largely agree with
these commenters and we have revised our analysis to reflect these cost
savings. See RIA 2.11.2.15 for additional discussion.
(viii) Technology Packages for Diesel Engines Installed in Tractors
This Section (a)(viii) describes technology packages that the
agencies project could be applied to Phase 1 tractor engines to meet
the Phase 2 SET separate engine standards. Section II.D.(2)(e) also
describes additional improvements that the agencies project some engine
manufacturers will be able to apply to their engines.
We received comments on the tractor engine standards in response to
the proposal and in response to the NODA. These comments can be grouped
into two general themes. One theme expressed by ARB, non-governmental
environmentally focused organizations, Cummins and some technology
suppliers like Honeywell, recommended higher engine stringencies, up to
10-15 percent in some comments. Another theme, generally expressed by
vertically integrated engine and vehicle manufacturers supported either
no Phase 2 engine standards at all, or they supported the proposal's
standards, but none of these commenters supported standards that were
more stringent than what we proposed. An example of the contrast
between these two themes can be shown in one report submitted to the
docket and another submission rebutting the statements made in the
[[Page 73559]]
report. The report was submitted to the agencies by the Environmental
Defense Fund (EDF).\187\ On the other hand, four vertically integrated
engine and vehicle manufacturers, DTNA, Navistar, Paccar, and Volvo,
submitted a rebuttal to EDF's findings.\188\ Some of these individual
vehicle manufacturers also provided their own comments on EDF's
report.189 190 Cummins also provided comments and
recommended stringencies somewhere between EDF's recommendations and
the integrated manufacturers' rebuttal. Cummins recommended achieving
reductions by 2030 in the range of 9-15 percent. CARB's recommendation
from their comments \191\ is 7.1 percent in 2024.
---------------------------------------------------------------------------
\187\ Environmental Defense Fund, Greenhouse Gas Emission and
Fuel Efficiency Standards for Medium-Duty and Heavy-Duty Engines and
Vehicles--Phase 2--Notice of Data Availability,'' Docket: ID No.
EPA-HQ-OAR-2014-0817, October 1, 2015.
\188\ Daimler Trucks North America, Navistar, Inc, Paccar Inc,
and Volvo Group,'' Greenhouse Gas Emission and Fuel Efficiency
Standards for Medium-Duty and Heavy-Duty Engines and Vehicles--Phase
2--Notice of Data Availability,'' Docket: ID No. EPA-HQ-OAR-2014-
0817, April 1, 2016.
\189\ Navistar, Inc., Greenhouse Gas Emission and Fuel
Efficiency Standards for Medium-Duty and Heavy-Duty Engines and
Vehicles--Phase 2--Notice of Data Availability,'' Docket: ID No.
EPA-HQ-OAR-2014-0817, April 1, 2016.
\190\ Daimler Trucks North America LLC, Detroit Diesel
Corporation, Greenhouse Gas Emission and Fuel Efficiency Standards
for Medium-Duty and Heavy-Duty Engines and Vehicles--Phase 2--Notice
of Data Availability,'' Docket: ID No. EPA-HQ-OAR-2014-0817, April
1, 2016.
\191\ California Air Resources Board (CARB), Greenhouse Gas
Emissions and Fuel Efficiency Standards for Medium- and Heavy-Duty
Engines and Vehicles--Phase 2 (Docket ID No. EPA-HQ-OAR-2014-0827
and Docket ID No. NHTSA-2014-0132).
---------------------------------------------------------------------------
The agencies carefully considered this wide range of views, and
based on the best data available, the agencies modified some of our
technology projections between the proposal and the final rule.
Table II-5 lists our projected technologies together with our
projected effectiveness and market adoption rates for tractor engines.
The reduction values shown as ''SET reduction'' are relative to our
Phase 2 baseline values, as shown in Table II-7. It should be pointed
out that the reductions in Table II-7 are based on the Phase 2 final
SET weighting factors, shown in Table II-2. RIA Chapter 2.7.5 details
the reasoning supporting our projection of improvements attributable to
this fleet average technology package.
Table II-7--Projected Tractor Engine Technologies and Reduction
----------------------------------------------------------------------------------------------------------------
SET weighted Market Market Market
SET mode reduction (%) penetration penetration penetration
2020-2027 (2021) (%) (2024) (%) (2027) (%)
----------------------------------------------------------------------------------------------------------------
Turbo compound with clutch...................... 1.9 5 10 10
WHR (Rankine cycle)............................. 3.6 1 5 25
Parasitic/Friction (Cyl Kits, pumps, FIE), 1.5 45 95 100
lubrication....................................
After-treatment (lower dP)...................... 0.6 30 95 100
EGR/Intake & exhaust manifolds/Turbo/VVT/Ports.. 1.1 45 95 100
Combustion/FI/Control........................... 1.1 45 95 100
Downsizing...................................... 0.3 10 20 30
-----------------------------------------------
Overall reductions (%)
-----------------------------------------------
Weighted reduction (%).......................... .............. 1.7 4.0 4.8
Down speeding optimization on SET............... .............. 0.1 0.2 0.3
---------------------------------------------------------------
Total % reduction........................... .............. 1.8 4.2 5.1
----------------------------------------------------------------------------------------------------------------
The weighted reductions shown in this table have been combined
using the ``[Pi]-formula,'' which has been augmented to account for
technology dis-synergies that occur when combining multiple
technologies. A 0.85 dis-synergy factor was used for 2021, and a 0.90
dis-synergy factor was used for 2024 and 2027.\192\ RIA Chapter 2.7.4
provides details on the ``[Pi]-formula'' and an explanation for how the
dis-synergy factors were determined. Some commenters argued that use of
a single dis-synergy factor for all technologies is inappropriate.
While we agree that it would be preferable to have a more detailed
analysis of the dis-synergy between each pair or group of technologies,
we do not have the information necessary to conduct such an analysis.
In the absence of such information, the simple single value approach is
a reasonable approximation. Moreover, we note that the degree of dis-
synergy is sufficiently small to make the impact of any errors on the
resulting standards negligible.
---------------------------------------------------------------------------
\192\ As used in the agencies' analyses, dis-synergy factors
less than one reflect dis-synergy between technologies that reduce
the overall effectiveness, while dis-synergy factors greater than
one would indicate synergy that improves the overall effectiveness.
---------------------------------------------------------------------------
Figure II.3 2018 HHD Figure II.4 are the samples of the HHD engine
fuel maps used for the agencies' MY 2018 baseline engine and MY 2027
sleeper cab engine for tractors. As can be seen from these two figures,
the torque curve shapes are different. This is because engine down
speeding optimization for the SET is taken into consideration, where
the engine peak torque is increased and the engine speed is shifted to
lower speed. All maps used by GEM for all vehicles are shown in Chapter
2.7 of the RIA.
[[Page 73560]]
[GRAPHIC] [TIFF OMITTED] TR25OC16.003
(ix) Technology Packages for Diesel Engines Installed in Vocational
Vehicles
For diesel engines (and other compression-ignition engines) used in
vocational vehicles, the MY 2021 standards will require engine
manufacturers to achieve, on average, a 2.3 percent reduction in fuel
consumption and CO2 emissions beyond the Phase 2 FTP
baselines. Beginning in MY 2024, the agencies are requiring a 3.6
percent reduction in fuel consumption and CO2 emissions
beyond the Phase 2 FTP baselines for all diesel engines including LHD,
MHD, and HHD, and beginning in MY 2027 this increases to 4.2 percent,
on average. The agencies have based these FTP standards on the
performance of reduced parasitic and friction losses, improved after-
treatment, combustion optimization, superchargers and variable geometry
turbochargers, physics model-based controls, improved EGR pressure
drop, and variable valve timing (only in LHD and MHD engines).
[[Page 73561]]
The percent reduction for the MY 2021, MY 2024, and MY 2027 standards
is based on the combination of technology effectiveness and the
respective market adoption rates projected.
Most of the potential engine technologies discussed previously for
tractor engines can also be applied to vocational engines. However,
neither of the waste heat technologies, Rankine cycle nor turbo-
compound, are likely to be applied to vocational engines because they
are less effective under transient operation, which is weighted more
heavily for all of the vocational sub-categories. Given the projected
cost and complexity of such systems, we believe that for the Phase 2
time frame manufacturers will focus their WHR development work on
tractor applications (which will have better payback for operators),
rather than on vocational applications. In addition, the benefits due
to engine downsizing, which can be realized in some tractor engines,
may not be realized at all in in the vocational sector, again because
this control technology produces few benefits under transient
operation.
One of the most effective technologies for vocational engines is
the optimization of transient controls with physics model based
control, which would replace current look-up table based controls.
These are described more in detail in Chapter 2.3 of the RIA. We
project that more advanced transient controls, including different
levels of model based control, discussed in Chapter 2.3 of the RIA,
would continue to progress and become more broadly applicable
throughout the Phase 2 timeframe.
Other effective technologies include parasitic load/friction
reduction, as well as improvements to combustion, air handling systems,
turbochargers, and after-treatment systems. Table II-8 below lists
those potential technologies together with the agencies' projected
market penetration rates for vocational engines. Again, similar to
tractor engines, the technology reduction and market penetration rates
are estimated by combining manufacturer-submitted confidential business
information, together with estimates reflecting the agencies' judgment,
which is informed by historical trends in the market adoption of other
fuel efficiency improving technologies. The reduction values shown as
``percent reduction'' are relative to the Phase 2 FTP baselines, which
are shown in Table II-3. The overall reductions combine the technology
reduction values with their market adoption rates. The same set of the
dis-synergy factors as the tractor are used for MY 2021, 2024, and
2027.
Table II-8--Projected Vocational Engine Technologies and Reduction
----------------------------------------------------------------------------------------------------------------
Percent Market Market Market
Technology reduction penetration penetration penetration
2020-2027 2021 (%) 2024 (%) 2027 (%)
----------------------------------------------------------------------------------------------------------------
Model based control............................. 2.0 25 30 40
Parasitic/Friction.............................. 1.5 60 90 100
EGR/Air/VVT/Turbo............................... 1.0 60 90 100
Improved AT..................................... 0.5 30 60 100
Combustion Optimization......................... 1.0 60 90 100
Weighted reduction (%)-L/M/HHD.................. .............. 2.3 3.6 4.2
----------------------------------------------------------------------------------------------------------------
Figure II.5 is a sample of a 2018 baseline engine fuel map for a
MHD vocational engine.
[GRAPHIC] [TIFF OMITTED] TR25OC16.004
[[Page 73562]]
(x) Summary of the Agencies' Analysis of the Feasibility of the Diesel
Engine Standards
The HD Phase 2 standards are based on projected adoption rates for
technologies that the agencies regard as the maximum feasible for
purposes of EISA section 32902 (k) and appropriate under CAA section
202(a) based on the technologies discussed above and in RIA Chapter 2.
The agencies believe these technologies can be adopted at the estimated
rates for these standards within the lead time provided, as discussed
in RIA Chapter 2.7. The 2021 and 2024 MY standards are phase-in
standards on the path to the 2027 MY standards, and these earlier
standards were developed using less aggressive application rates and
therefore have lower technology package costs than the 2027 MY
standards.
As described in Section II.D.(2)(d) below, the costs to comply with
these standards are estimated to range from $275 to $1,579 per engine.
This is slightly higher than the costs for Phase 1, which were
estimated to be $234 to $1,091 per engine. Although the agencies did
not separately determine fuel savings or emission reductions due to the
engine standards apart from the vehicle program, it is expected that
the fuel savings will be significantly larger than these costs, and the
emission reductions will be roughly proportional to the technology
costs when compared to the corresponding vehicle program reductions and
costs. Thus, we regard these standards as cost-effective. This is true
even without considering payback period. The phase-in 2021 and 2024 MY
standards are less stringent and less costly than the 2027 MY
standards. Given that the agencies believe these standards are
technologically feasible, are highly cost effective, and highly cost
effective when 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), they appear to 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).
(b) Basis for Continuing the Phase 1 Spark-Ignited Engine Standard
For gasoline vocational engines, we are not adopting more stringent
engine standards. Today most SI-powered vocational vehicles are sold as
incomplete vehicles by a vertically integrated chassis manufacturer,
where the incomplete chassis shares most of the same technology as
equivalent complete pickups or vans, including the powertrain. Another,
even less common way that SI-powered vocational vehicles are built is
by a non-integrated chassis manufacturer purchasing an engine from a
company that also produces complete and/or incomplete HD pickup trucks
and vans. Gasoline engines used in vocational vehicles are generally
the same engines as are used in the complete HD pickups and vans in the
Class 2b and 3 weight categories, although the operational demands of
vocational vehicles often require use of the largest, most powerful SI
engines, so that some engines fitted in complete pickups and vans are
not appropriate for use in vocational vehicles. Given the relatively
small sales volumes for gasoline-fueled vocational vehicles,
manufacturers typically cannot afford to invest significantly in
developing separate technology for these engines.
The agencies received many comments suggesting that technologies be
applied to increase the stringency of the SI engine standard. These
comments were essentially misplaced, since the agencies already had
premised the Phase 1 SI MY 2016 FTP engine standards on 100 percent
adoption of these technologies. The commenters thus did not identify
any additional engine technologies that the agencies did not already
consider and account for in setting the MY 2016 FTP engine standard.
Therefore, the Phase 1 SI engine FTP standard for these engines will
remain in place. However, as noted above, projected engine improvements
are being reflected in the stringency of the vehicle standard for the
vehicle in which the engine will be installed. In part this is because
the GEM cycles result in very different engine operation than what
occurs when an engine is run over the engine FTP cycle. We believe that
certain technologies will show a fuel consumption and CO2
emissions reduction during GEM cycles that do not occur over the engine
FTP. We received comments on engine technologies that can be recognized
over the GEM vehicle cycles. As a result, the Phase 2 gasoline-fueled
vocational vehicle standards are predicated on adoption of advanced
engine friction reduction and cylinder deactivation. To the extent any
SI engines do not incorporate the projected engine technologies,
manufacturers of SI-powered vocational vehicles would need to achieve
equivalent reductions from some other vehicle technology to meet the
vehicle standards. See Section V.C of this Preamble for a description
of how we applied these technologies to develop the vocational vehicle
standards. See Section VI.C of this Preamble for a description of the
SI engine technologies that have been considered in developing the HD
pickup truck and van standards.
(c) Engine Improvements Projected for Vehicles Over the GEM Duty Cycles
As part of the certification process for the Phase 2 vehicle
standards, tractor and vocational vehicle manufacturers will need to
represent their vehicles' actual engines in GEM. Although the vehicle
standards recognize the same engine technologies as the separate engine
standards, each have different test procedures for demonstrating
compliance. As explained earlier in Section II.D.(1), compliance with
the tractor separate engine standards is determined from a composite of
the Supplemental Engine Test (SET) procedure's 13 steady-state
operating points. Compliance with the vocational vehicle separate
engine standards is determined over the Federal Test Procedure's (FTP)
transient engine duty cycle. In contrast, compliance with the vehicle
standards is determined using GEM, which calculates composite results
over a combination of 55 mph, 65 mph, ARB Transient and idle vehicle
cycles. Each of these duty cycles emphasize different engine operating
points; therefore, they can each recognize certain technologies
differently. Hence, these engine improvements can be readily recognized
in GEM and appropriately reflected in the stringency of the vehicle
standards. It is important to note, however, that the tractor vehicle
standards presented in Section III project that some (but not all)
tractor engines will achieve greater reductions than required by the
engine standards. This was reflected in the agencies' feasibility
analysis using projected engine fuel maps that represent engines having
fuel efficiency better than what is required by the engine standards.
Similarly, the vocational vehicle standards in presented in Section V
project that the average vocational engine will achieve greater
reductions than required by the engine standards. These additional
reductions are recognized by GEM and are reflected in the stringency of
the respective vehicle standards.
Our first step in aligning our engine technology assessment at both
the engine and vehicle levels was to separately identify how each
technology impacts performance at each of the 13 individual test points
of the SET steady-state engine duty cycle. For example, engine friction
reduction technology is expected to have the greatest impact at the
highest engine speeds, where frictional energy losses are the greatest.
[[Page 73563]]
As another example, turbocharger technology is generally optimized for
best efficiency at steady-state cruise vehicle speed. For an engine,
this is near its lower peak-torque speed and at a moderately high load
that still offers sufficient torque reserve to climb modest road grades
without frequent transmission gear shifting. The agencies also
considered the combination of certain technologies causing dis-
synergies with respect to engine efficiency at each of these test
points. See RIA Chapter 2.3 and 2.7 for further details. Chapter 2.8
and 2.9 of the RIA details how the engine fuel maps are created for
both tractor and vocational vehicles used for GEM as the default engine
fuel maps.
(d) Engine Technology Package Costs for Tractor and Vocational Engines
(and Vehicles)
As described in Chapters 2 and 7 of the RIA, the agencies estimated
costs for each of the engine technologies discussed here. All costs are
presented relative to engines projected to at least comply with the
model year 2017 standards--i.e., relative to our Phase 2 baseline
engines. Note that we are not presenting any costs for gasoline engines
(SI engines) in this section because we are not changing the SI engine
standards. However, we are including a cost for additional engine
technology as part of the vocational vehicle analysis in Section
V.C.2.(e) (and appropriately so, since those engine improvements are
reflected in the stringency of the vocational vehicle standard).
Our engine cost estimates include a separate analysis of the
incremental part costs, research and development activities, and
additional equipment. 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 the 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.
Consequently, the indirect costs incurred by the original equipment
manufacturer need not reflect significant cost to cover research and
development since the bulk of that effort is already completed. For the
MHD and HHD diesel engine segment, however, the agencies believe that
OEMs will incur costs not associated with 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 have directly
estimated additional indirect costs to account for these development
costs. The agencies used the same approach in the Phase 1 HD rule. 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 would 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 2.7. To reiterate, we have used this different
approach because the MHD and HHD diesel engines are expected to comply
in part via technology changes that are not reflected in new hardware
but rather reflect 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. Note that these engines are also expected to
incur new hardware costs as shown in Table II-9 through Table II-12.
EPA also developed the incremental piece cost for the components to
meet each of the 2021 and 2024 standards. The costs shown in Table II-
13 include a low complexity ICM of 1.15 and assume the flat-portion of
the learning curve is applicable to each technology.
(i) Tractor Engine Package Costs
Table II-9--MY 2021 Tractor Diesel Engine Component Costs Inclusive of
Indirect Cost Markups and Adoption Rates
[2013$]
------------------------------------------------------------------------
Medium HD Heavy HD
------------------------------------------------------------------------
After-treatment system (improved $7 $7
effectiveness SCR, dosing, DPF)........
Valve Actuation......................... 84 84
Cylinder Head (flow optimized, increased 3 3
firing pressure, improved thermal
management)............................
Turbocharger (improved efficiency)...... 9 9
Turbo Compounding....................... 51 51
EGR Cooler (improved efficiency)........ 2 2
Water Pump (optimized, variable vane, 44 44
variable speed)........................
Oil Pump (optimized).................... 2 2
Fuel Pump (higher working pressure, 2 2
increased efficiency, improved pressure
regulation)............................
Fuel Rail (higher working pressure)..... 5 5
Fuel Injector (optimized, improved 5 5
multiple event control, higher working
pressure)..............................
Piston (reduced friction skirt, ring and 1 1
pin)...................................
Valve train (reduced friction, roller 39 39
tappet)................................
Waste Heat Recovery..................... 71 71
``Right sized'' engine.................. -41 -41
-------------------------------
Total............................... 284 284
------------------------------------------------------------------------
Note: ``Right sized'' diesel engine is a smaller, less costly engine
than the engine it replaces.
[[Page 73564]]
Table II-10--MY 2024 Tractor Diesel Engine Component Costs Inclusive of
Indirect Cost Markups and Adoption Rates
[2013$]
------------------------------------------------------------------------
Medium HD Heavy HD
------------------------------------------------------------------------
After-treatment system (improved $14 $14
effectiveness SCR, dosing, DPF)........
Valve Actuation......................... 169 169
Cylinder Head (flow optimized, increased 6 6
firing pressure, improved thermal
management)............................
Turbocharger (improved efficiency)...... 17 17
Turbo Compounding....................... 93 93
EGR Cooler (improved efficiency)........ 3 3
Water Pump (optimized, variable vane, 85 85
variable speed)........................
Oil Pump (optimized).................... 4 4
Fuel Pump (higher working pressure, 4 4
increased efficiency, improved pressure
regulation)............................
Fuel Rail (higher working pressure)..... 9 9
Fuel Injector (optimized, improved 10 10
multiple event control, higher working
pressure)..............................
Piston (reduced friction skirt, ring and 3 3
pin)...................................
Valve train (reduced friction, roller 77 77
tappet)................................
Waste Heat Recovery..................... 298 298
``Right sized'' engine.................. -82 -82
-------------------------------
Total............................... 712 712
------------------------------------------------------------------------
Note: ``Right sized'' diesel engine is a smaller, less costly engine
than the engine it replaces.
Table II-11--MY 2027 Tractor Diesel Engine Component Costs Inclusive of
Indirect Cost Markups and Adoption Rates
[2013$]
------------------------------------------------------------------------
Medium HD Heavy HD
------------------------------------------------------------------------
After-treatment system (improved $15 $15
effectiveness SCR, dosing, DPF)........
Valve Actuation......................... 172 172
Cylinder Head (flow optimized, increased 6 6
firing pressure, improved thermal
management)............................
Turbocharger (improved efficiency)...... 17 17
Turbo Compounding....................... 89 89
EGR Cooler (improved efficiency)........ 3 3
Water Pump (optimized, variable vane, 85 85
variable speed)........................
Oil Pump (optimized).................... 4 4
Fuel Pump (higher working pressure, 4 4
increased efficiency, improved pressure
regulation)............................
Fuel Rail (higher working pressure)..... 9 9
Fuel Injector (optimized, improved 10 10
multiple event control, higher working
pressure)..............................
Piston (reduced friction skirt, ring and 3 3
pin)...................................
Valve train (reduced friction, roller 77 77
tappet)................................
Waste Heat Recovery..................... 1,208 1,208
``Right sized'' engine.................. -123 -123
-------------------------------
Total............................... 1,579 1,579
------------------------------------------------------------------------
Note: ``Right sized'' diesel engine is a smaller, less costly engine
than the engine it replaces.
(ii) Vocational Diesel Engine Package Costs
Table II-12--MY 2021 Vocational Diesel Engine Component Costs Inclusive of Indirect Cost Markups and Adoption
Rates
[2013$]
----------------------------------------------------------------------------------------------------------------
Light HD Medium HD Heavy HD
----------------------------------------------------------------------------------------------------------------
After-treatment system (improved effectiveness SCR, dosing, DPF) $8 $8 $8
Valve Actuation................................................. 93 93 93
Cylinder Head (flow optimized, increased firing pressure, 6 3 3
improved thermal management)...................................
Turbocharger (improved efficiency).............................. 10 10 10
EGR Cooler (improved efficiency)................................ 2 2 2
Water Pump (optimized, variable vane, variable speed)........... 58 58 58
Oil Pump (optimized)............................................ 3 3 3
Fuel Pump (higher working pressure, increased efficiency, 3 3 3
improved pressure regulation)..................................
Fuel Rail (higher working pressure)............................. 8 6 6
Fuel Injector (optimized, improved multiple event control, 8 6 6
higher working pressure).......................................
Piston (reduced friction skirt, ring and pin)................... 1 1 1
Valve train (reduced friction, roller tappet)................... 70 52 52
Model Based Controls............................................ 29 29 29
-----------------------------------------------
Total....................................................... 298 275 275
----------------------------------------------------------------------------------------------------------------
[[Page 73565]]
Table II-13--MY 2024 Vocational Diesel Engine Component Costs Inclusive of Indirect Cost Markups and Adoption
Rates
[2013$]
----------------------------------------------------------------------------------------------------------------
Light HD Medium HD Heavy HD
----------------------------------------------------------------------------------------------------------------
After-treatment system (improved effectiveness SCR, dosing, DPF) $14 $14 $14
Valve Actuation................................................. 160 160 160
Cylinder Head (flow optimized, increased firing pressure, 10 6 6
improved thermal management)...................................
Turbocharger (improved efficiency).............................. 16 16 16
EGR Cooler (improved efficiency)................................ 3 3 3
Water Pump (optimized, variable vane, variable speed)........... 81 81 81
Oil Pump (optimized)............................................ 4 4 4
Fuel Pump (higher working pressure, increased efficiency, 4 4 4
improved pressure regulation)..................................
Fuel Rail (higher working pressure)............................. 11 9 9
Fuel Injector (optimized, improved multiple event control, 13 10 10
higher working pressure).......................................
Piston (reduced friction skirt, ring and pin)................... 2 2 2
Valve train (reduced friction, roller tappet)................... 97 73 73
Model Based Controls............................................ 32 32 32
-----------------------------------------------
Total....................................................... 446 413 413
----------------------------------------------------------------------------------------------------------------
Table II-14--MY 2027 Vocational Diesel Engine Component Costs Inclusive of Indirect Cost Markups and Adoption
Rates
[2013$]
----------------------------------------------------------------------------------------------------------------
Light HD Medium HD Heavy HD
----------------------------------------------------------------------------------------------------------------
After-treatment system (improved effectiveness SCR, dosing, DPF) $15 $15 $15
Valve Actuation................................................. 172 172 172
Cylinder Head (flow optimized, increased firing pressure, 10 6 6
improved thermal management)...................................
Turbocharger (improved efficiency).............................. 17 17 17
EGR Cooler (improved efficiency)................................ 3 3 3
Water Pump (optimized, variable vane, variable speed)........... 85 85 85
Oil Pump (optimized)............................................ 4 4 4
Fuel Pump (higher working pressure, increased efficiency, 4 4 4
improved pressure regulation)..................................
Fuel Rail (higher working pressure)............................. 11 9 9
Fuel Injector (optimized, improved multiple event control, 14 10 10
higher working pressure).......................................
Piston (reduced friction skirt, ring and pin)................... 3 3 3
Valve train (reduced friction, roller tappet)................... 102 77 77
Model Based Controls............................................ 41 41 41
-----------------------------------------------
Total....................................................... 481 446 446
----------------------------------------------------------------------------------------------------------------
(e) Feasibility of Additional Engine Improvements
While the agencies' technological feasibility analysis for the
engine standards focuses on what is achievable for existing engine
platforms, we recognize that it could be possible to achieve greater
reductions by designing entirely new engine platforms. Unlike existing
platforms, which are limited with respect to peak cylinder pressures
(precluding certain efficiency improvements), new platforms can be
designed to have higher cylinder pressure than today's engines. New
designs are also better able to incorporate recent improvements in
materials and manufacturing, as well as other technological
developments. Considered together, it is likely that a new engine
platform could be about 2 percent better than engines using older
platforms. Moreover, the agencies have seen CBI data that suggests
improvement of more than 3 percent are possible. However, because
designing and producing a new engine platform requires hundreds of
millions of dollars in capital investment and significant lead time for
research and development, it would not be appropriate to project that
each engine manufacturer could complete a complete redesign of all of
its engines within the Phase 2 time frame. Unlike light-duty, heavy-
duty sales volumes are not large enough to support short redesign
cycles. As a result, it can take 20 years for a manufacturer to
generate the necessary return on the investment associated with an
engine redesign. Forcing a manufacturer to redesign its engines
prematurely could easily result in significant financial strain on a
company.
On the other hand, how far the various manufacturers are into their
design cycles suggests that one or more manufacturers will probably
introduce a new engine platform during the Phase 2 time frame. This
would not enable other engine manufacturers to meet more stringent
standards, and thus it would not be an appropriate basis to justify
more stringent engine standards (and certainly not engine standards
reflecting 100 percent use of technologies premised on existence of new
platforms). However, the availability of some more efficient engines on
the market will provide the opportunity for vehicle manufacturers to
lower their average fuel consumption as measured by GEM. Vehicle
manufacturers can use a mix of newer and older engine designs to
achieve an average engine performance significantly better than what is
required by the engine standards. Thus, the vehicle standards can
reflect engine platform improvements (which are amenable to measurement
in GEM), without necessarily forcing each manufacturer to achieve these
additional reductions,
[[Page 73566]]
which may be achievable only for new engine platforms.
As discussed in Section III.D.(1)(b)(i), the agencies project that
at least one engine manufacturer (and possibly more) will have
completed a redesign for tractor engines by 2027. Accordingly, we
project that 50 percent of tractor engines in 2027 will be redesigned
engines and be 1.6 percent more efficient than required by the engine
standards, so the average engine would be 0.8 percent better. However,
we could have projected the same overall improvement by projecting 25
percent of engine getting 3.2 percent better. Based on the CBI
information available to us, we believe projecting a 0.8 percent
improvement is reasonable, but may be somewhat conservative.
Adding this 0.8 percent improvement to the 5.1 percent reduction
required by the standards means we project the average 2027 tractor
engine would be 5.9 percent better than Phase 1. Because engine
improvements for tractors are applied separately for day cabs and
sleeper cabs in the vehicle program, we estimated separate improvements
for them here. Specifically, we project a 5.4 percent reduction for day
cabs and a 6.4 percent reduction in fuel consumption in sleeper cabs
beyond Phase 1. It is important to also note that manufacturers that do
not achieve this level would be able to make up for the difference by
applying one of the many other tractor vehicle technologies to a
greater extent than we project, or to achieve greater reductions by
optimizing technology efficiency further. We are not including the cost
of developing these new engines in our cost analysis because we believe
these engines are going to be developed due to market forces (i.e., the
new platform, already contemplated) rather than due to this rulemaking.
We are making a similar new engine platform projection for
vocational vehicles. This is because many of tractor and vocational
engines, such as HHD, would likely share the same engine hardware with
the exception of WHR. In addition, the model based control discussed in
Chapter 2.3 of the RIA could integrate engines better with
transmissions on the vehicle side. We believe manufacturers will first
focus their efforts on improving tractor engines but still believe that
the 2027 vocational engine will be significantly better than required
by the engine standards.
(3) EPA Engine Standards for N2O
EPA will continue to apply the Phase 1 N2O engine
standard of 0.10 g/bhp-hr and a 0.02 g/bhp-hr default deterioration
factor to the Phase 2 program. EPA adopted the cap standard for
N2O as an engine-based standard because the agency believes
that emissions of this GHG are technologically related solely to the
engine, fuel, and emissions after-treatment systems, and the agency is
not aware of any influence of vehicle-based technologies on these
emissions. Note that NHTSA did not adopt standards for N2O
because these emissions do not impact fuel consumption in a significant
way.
In the proposal we considered reducing both the standard and
deterioration factor to 0.05 and 0.01 g/bhp-hr respectively because
engines certified in model year 2014 were generally meeting the
proposed standard. We also explained the process behind N2O
formation in urea SCR after-treatment systems and how that process
could be optimized to elicit additional N2O reductions. 80
FR 40203. While we have seen some reductions and a few increases in
engine family certified N2O levels across the 2014, 2015,
and 2016 model years, the majority have remained unchanged.
While we still believe that further optimization of SCR systems is
possible to reduce N2O emissions, as demonstrated for some
engine families, we do not know to what extent further optimization can
be achieved given the tradeoffs required to meet the Phase 2
CO2 standards. These tradeoffs potentially include advancing
fuel injection timing to reduce CO2 emissions resulting in
an increase in NOX emissions at the engine outlet before the
after-treatment, increasing the needed NOX reduction
efficiency of the SCR system. We will continue to assess N2O
emissions as SCR technology evolves and CO2 emission
reductions phase in, and we will revisit the standard at a later date
to further control N2O emission. This will likely be
included in the upcoming rule to consider more stringent NOX
standards.
[[Page 73567]]
[GRAPHIC] [TIFF OMITTED] TR25OC16.005
[[Page 73568]]
[GRAPHIC] [TIFF OMITTED] TR25OC16.006
(4) EPA Engine Standards for Methane
EPA will continue to apply the Phase 1 methane engine standards to
the Phase 2 program. EPA adopted the cap standards for CH4
(along with N2O standards) as engine-based standards because
the agency believes that emissions of this GHG are technologically
related solely to the engine, fuel, and emissions after-treatment
systems, and the agency is not aware of any influence of vehicle-based
technologies on these emissions. We are applying these cap standards
against the FTP duty-cycle because the FTP cycle is the most stringent
with respect to emissions of these pollutants and we do not believe
that a reduction is stringency from the current Phase 1 standards is
warranted. Note that NHTSA did not adopt standards for CH4
(or N2O) because these emissions do not impact fuel
consumption in a significant way.
EPA continues to believe that manufacturers of most engine
technologies will be able to comply with the Phase 1 CH4
standard with no technological improvements. We note that we are not
aware of any new technologies that would have allowed us to adopt more
stringent standards at this time.
(5) Compliance Provisions and Flexibilities for Engine Standards
The agencies are continuing most of the Phase 1 compliance
provisions and flexibilities for the Phase 2 engine standards.
(a) Averaging, Banking, and Trading
The agencies' general approach to averaging is discussed in Section
I. We did not propose to offer any new or special credits to engine
manufacturers to comply with any of the separate engine standards.
Except for early credits, the agencies are retaining all Phase 1 credit
flexibilities and limitations to continue for use in the Phase 2 engine
program.
As discussed below and as proposed, EPA is changing the useful life
for LHD engines for GHG emissions from the current 10 years/110,000
miles to 15 years/150,000 miles to be consistent with the useful life
of criteria pollutants recently updated in EPA's Tier 3 rule. In order
to ensure that banked credits maintain their value in the transition
from Phase 1 to Phase 2, EPA and NHTSA are adopting the proposed
adjustment factor of 1.36 (i.e., 150,000 mile / 110,000 miles) for
credits that are carried forward from Phase 1 to the MY 2021 and later
Phase 2 standards. Without this adjustment factor the change in useful
life would have effectively resulted in a discount of banked credits
that are carried forward from Phase 1 to Phase 2, which is not the
intent of the change in the useful life. See Sections V and VI for
additional discussion of similar adjustments of vehicle-based credits.
Finally, the agencies are limiting the carryover of certain Phase 1
engine credits into the Phase 2 program. As described in Section
II.D.(2) the agencies made adjustments to the FTP baselines, to address
the unexpected step-change improvement in engine fuel consumption and
CO2 emissions. The underlying reasons for this shift are
mostly related to manufacturers optimizing their SCR thermal management
strategy over the FTP in ways that we (mistakenly) thought they already
had in MY 2010 (i.e., the Phase 1 baseline). At the time of Phase 1 we
had not realized that these improvements were not already in the Phase
1 baseline. This issue does not apply for SET emissions, and thus only
significantly impacts engines certified
[[Page 73569]]
exclusively to the FTP standards (rather than both FTP and SET
standards). To prevent manufacturers from diluting the Phase 2 engine
program with credits generated relative to this incorrect baseline, we
are not allowing engine credits generated against the Phase 1 FTP
standards to be carried over into the Phase 2 program.
(b) Changing Global Warming Potential (GWP) Values in the Credit
Program for CH4 and N2O
The Phase 1 rule included a compliance flexibility that allowed
heavy-duty manufacturers and conversion companies to comply with the
respective methane or nitrous oxide standards by means of over-
complying with CO2 standards (40 CFR 1036.705(d)). The
heavy-duty rules allow averaging only between vehicles or engines of
the same designated type (referred to as an ``averaging set'' in the
rules). Specifically, the Phase 1 heavy-duty rulemaking added a
CO2 credits program which allowed heavy-duty engine
manufacturers to average and bank emission credits to comply with the
methane and nitrous oxide requirements after adjusting the
CO2 emission credits based on the relative GWP equivalents.
To establish the GWP equivalents used by the CO2 credits
program, the Phase 1 rule incorporated the IPCC Fourth Assessment
Report GWP values of 25 for CH4 and 298 for N2O,
which are assessed over a 100 year lifetime.
EPA will continue this provision for Phase 2. However, since the
Phase 1 rule was finalized, a new IPCC report has been released (the
Fifth Assessment Report), with new GWP estimates. This caused us to
look again at the relative GWP equivalency of methane and nitrous oxide
and to seek comment on whether the methane and nitrous oxide GWPs used
to establish the equivalency value for the CO2 Credit
program should be updated to those established by IPCC in its Fifth
Assessment Report. 80 FR 40206. The Fifth Assessment Report provides
four 100 year GWP values for methane ranging from 28 to 36 and two 100
year GWP values for nitrous oxide, either 265 or 298.
EPA is updating the GWP value to convert CO2 credits for
use against the methane standard. We are using a GWP of 34 for the
value of methane reductions relative to CO2 reductions. (The
GWP remains 298 for N2O). The use of this new methane GWP
will not begin until MY 2021, when the Phase 2 engine standards begin.
This provides sufficient lead time for both the agencies and
manufacturers to update systems, and also ensures that manufacturers
would be able make any necessary design changes. The choice of when to
commence use of this GWP value for our engines standards does not
prejudice the choice of other GWP values for use in regulations and
other purposes in the near term. Further discussion is found in Section
XI.D.2.a.
(c) In-Use Compliance and Useful Life
Consistent with section 202(a)(1) and 202(d) of the CAA, for Phase
1, EPA established in-use standards for heavy-duty engines. Based on
our assessment of testing variability and other relevant factors, we
established in-use standards by adding a 3 percent adjustment factor to
the full useful life CO2 emissions and fuel consumption
results measured in the EPA certification process to address
measurement variability inherent in comparing results among different
laboratories and different engines. See 40 CFR part 1036. The agencies
are not changing this for Phase 2 SET and FTP engine standard
compliance.
In Phase 1, EPA set the useful life for engines and vehicles with
respect to GHG emissions equal to the respective useful life periods
for criteria pollutants. In April 2014, as part of the Tier 3 light-
duty vehicle final rule, EPA extended the regulatory useful life period
for criteria pollutants to 150,000 miles or 15 years, whichever comes
first, for Class 2b and 3 pickup trucks and vans and some light-duty
trucks (79 FR 23414, April 28, 2014). As proposed, EPA is applying the
same useful life of 150,000 miles or 15 years for the Phase 2 GHG
standards for engines primarily intended for use in vocational vehicles
with a GVWR at or below 19,500 lbs. NHTSA will use the same useful life
values as EPA for all heavy-duty vehicles.
As proposed, we will continue the regulatory allowance in 40 CFR
1036.150(g) that allows engine manufacturers to use assigned
deterioration factors (DFs) for most engines without performing their
own durability emission tests or engineering analysis. However, the
engines will still be required to meet the standards in actual use
without regard to whether the manufacturer used the assigned DFs. This
allowance is being continued as an interim provision and may be
discontinued for later phases of standards as more information becomes
known. Manufacturers are 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 advanced or off-cycle technologies).
Upon request, we could allow the assigned DF for CO2
emissions from engines including advanced or off-cycle 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. For technologies such
as WHR that are considered advanced in the context of Phase 1, but
would be treated as a more ordinary technology by the end of Phase 2,
we plan to work with manufacturers to determine if using the assigned
zero DF would be appropriate.
(d) Alternate CO2 Standards
In the Phase 1 rulemaking, the agencies allowed certification to
alternate CO2 engine standards in model years 2014 through
2016. This flexibility was intended to address the special case of
needed lead time to implement new standards for a previously
unregulated pollutant. Since that special case does not apply for Phase
2, we are not adopting a similar flexibility in this rulemaking.
(e) Approach to Standards and Compliance Provisions for Natural Gas
Engines
EPA is also making certain clarifying changes to its rules
regarding classification of natural gas engines. This relates to
standards for all emissions, both greenhouse gases and criteria
pollutants. These clarifying changes are intended to reflect the status
quo, and therefore should not have any associated costs.
EPA emission standards have always applied differently for
gasoline-fueled and diesel-fueled engines. The regulations in 40 CFR
part 86 implement these distinctions by dividing engines into Otto-
cycle and Diesel-cycle technologies. This approach led EPA to
categorize natural gas engines according to their design history. A
diesel engine converted to run on natural gas was classified as a
diesel-cycle engine; a gasoline engine converted to run on natural gas
was classified as an Otto-cycle engine.
The Phase 1 rule described our plan to transition to a different
approach, consistent with EPA's non-road programs, in which we divide
engines into compression-ignition and spark-ignition technologies based
only on the thermodynamic operating characteristics of the
engines.\193\ However, the Phase 1 rule included a provision allowing
us to continue with
[[Page 73570]]
the historic approach on an interim basis.
---------------------------------------------------------------------------
\193\ See 40 CFR 1036.108.
---------------------------------------------------------------------------
Under the existing EPA regulatory definitions of ``compression-
ignition'' and ``spark-ignition,'' a natural gas engine would generally
be considered compression-ignition if it operates with lean air-fuel
mixtures and uses a pilot injection of diesel fuel to initiate
combustion, and would generally be considered spark-ignition if it
operates with stoichiometric air-fuel mixtures and uses a spark plug to
initiate combustion.
EPA's basic premise here is that natural gas engines performing
similar in-use functions as diesel engines should be subject to similar
regulatory requirements. The compression-ignition emission standards
and testing requirements reflect the operating characteristics for the
full range of heavy-duty vehicles, including substantial operation in
long-haul service characteristic of tractors. The spark-ignition
emission standards and testing requirements do not include some of
those provisions related to use in long-haul service or other
applications where diesel engines predominate, such as steady-state
testing, Not-to-Exceed standards, and extended useful life. We believe
it would be inappropriate to apply the spark-ignition standards and
requirements to natural gas engines that are being used in applications
mostly served by diesel engines today. We therefore proposed to replace
the interim provision described above with a differentiated approach to
certification of natural gas engines across all of the EPA standards--
for both GHGs and criteria pollutants. 80 FR 40207. Under the proposed
amendment, we would require manufacturers to divide all their natural
gas engines into primary intended service classes, as we already
require for compression-ignition engines, whether or not the engine has
features that otherwise could (in theory) result in classification as
SI under the current rules. We proposed that any natural gas engine
qualifying as a medium heavy-duty engine (19,500 to 33,000 lbs. GVWR)
or a heavy heavy-duty engine (over 33,000 lbs. GVWR) would be subject
to all the emission standards and other requirements that apply to
compression-ignition engines. However, based on comments, we are
finalizing this change only for heavy heavy-duty engines. Commenters
identified medium heavy-duty applications in which SI alternative fuel
engines compete significantly with gasoline engines, which is not
consistent with the premise of the proposal. Thus, we are not
finalizing the proposed change for medium heavy-duty engines.
Table II-15 describes the provisions that apply differently for
compression-ignition and spark-ignition engines:
Table II-15--Regulatory Provisions That Are Different for Compression-
Ignition and Spark-Ignition Engines
------------------------------------------------------------------------
Provision Compression-ignition Spark-ignition
------------------------------------------------------------------------
Transient duty cycle........... 40 CFR part 86, 40 CFR part 86,
Appendix I, Appendix I,
paragraph (f)(2) paragraph (f)(1)
cycle; divide by cycle.
1.12 to de-
normalize.
Ramped-modal test (SET)........ yes................. no.
NTE standards.................. yes................. no.
Smoke standard................. yes................. no.
Manufacturer-run in-use testing yes................. no.
ABT--pollutants................ NOX, PM............. NOX, NMHC.
ABT--transient conversion 6.5................. 6.3.
factor.
ABT--averaging set............. Separate averaging One averaging set
sets for light, for all SI
medium, and heavy engines.
HDDE.
Useful life.................... 110,000 miles for 110,000 miles.
light HDDE, \a\ \a\
185,000 miles for
medium HDDE,
435,000 miles for
heavy HDDE.
Warranty....................... 50,000 miles for 50,000 miles.
light HDDE, 100,000
miles for medium
HDDE, 100,000 miles
for heavy HDDE.
Detailed AECD description...... yes................. no.
Test engine selection.......... highest injected most likely to
fuel volume. exceed emission
standards.
------------------------------------------------------------------------
Note:
\a\ As proposed, useful life for light heavy-duty diesel and spark
ignition engines is being increased to 150,000 miles for GHG
emissions, but remains at 110,000 for criteria pollutant emissions.
The onboard diagnostic requirements already differentiate
requirements by fuel type, so there is no need for those provisions to
change based on the considerations of this section.
We are not aware of any currently certified engines that will
change from compression-ignition to spark-ignition under this approach.
Nonetheless, because these proposed changes could result in a change in
standards for engines currently under development, we believe it is
appropriate to provide additional lead time. We will therefore continue
to apply the existing interim provision through model year 2020.\194\
Starting in model year 2021, all the provisions will apply as described
above for heavy heavy-duty engines. Manufacturers will not be permitted
to certify any engine families using carryover emission data if a
particular engine model switched from compression-ignition to spark-
ignition, or vice versa. However, as noted above, in practice these
vehicles are already being certified as CI engines, so we view these
changes as clarifications ratifying the current status quo.
---------------------------------------------------------------------------
\194\ Section 202(a)(2), applicable to emissions of greenhouse
gases, does not mandate a specific period of lead time, but EPA sees
no reason for a different compliance date here for GHGs and criteria
pollutants. This is also true with respect to the closed crankcase
emissions discussed in the following subsection. Also, as explained
in section I.E.i.e, EPA interprets the phrase ``classes or
categories of heavy duty vehicles or engines'' in CAA section
202(a)(3)(C) to refer to categories of vehicles established
according to features such as their engine cycle (spark-ignition or
compression-ignition).l.
---------------------------------------------------------------------------
These provisions will apply equally to engines fueled by any fuel
other than gasoline or ethanol, should such engines be produced in the
future. Given the current and historic market for vehicles above 33,000
lbs. GVWR, the agencies believe any alternative-fueled vehicles in this
weight range will be competing primarily with diesel vehicles and
should be subject to the same requirements as them. See Sections XI and
XII for additional discussion of natural gas fueled engines.
[[Page 73571]]
(f) Crankcase Emissions From Natural Gas Engines
EPA proposed to require that all natural gas-fueled engines have
closed crankcases, rather than continuing the provision that allows
venting to the atmosphere all crankcase emissions from all compression-
ignition engines. 80 FR 40208. However, EPA is not finalizing the
proposed requirement at this time.
Open crankcases have been allowed as long as these vented crankcase
emissions are measured and accounted for as part of an engine's
tailpipe emissions. This allowance has historically been in place to
address the technical limitations related to recirculating diesel-
fueled engines' crankcase emissions, which have high PM emissions, back
into the engine's air intake. High PM emissions vented into the intake
of an engine can foul turbocharger compressors and after cooler heat
exchangers. In contrast, historically EPA has mandated closed crankcase
technology on all gasoline fueled engines and all natural gas spark-
ignition engines.\195\ The inherently low PM emissions from these
engines posed no technical barrier to a closed crankcase mandate.
However, after considering the comments on this issue, we now believe
that there are practical reasons why we should not close natural gas
crankcases without also requiring closed crankcases for other
compression-ignition engines. Because current natural gas engines are
generally produced from diesel engine designs that are not designed to
operate with closed crankcases, we have concerns that sealing the
crankcase on the natural gas versions will require substantial
development effort, and the seals may not function properly. Thus, we
expect to update our regulations for crankcase emissions from all
compression ignition engines at the same time in a future rulemaking.
---------------------------------------------------------------------------
\195\ See 40 CFR 86.008-10(c).
---------------------------------------------------------------------------
(g) Compliance Margins
Some commenters suggested that the agencies should apply a
compliance margin to confirmatory and SEA test results to account for
variability of engine maps and emission tests. However, EPA's past
practice has been to base the standards on technology projections that
assume manufacturers will apply compliance margins to their test
results for certification. In other words, they design their products
to have emissions below the standards by some small margin so that
test-to-test or lab-to-lab variability would not cause them to exceed
any applicable standards. Consequently, EPA has typically not set
standards precisely at the lowest levels achievable, but rather at
slightly higher levels--expecting manufacturers to target the lower
levels to provide compliance margins for themselves. The agencies have
applied this approach to the Phase 2 standards. Thus, the feasibility
and cost analyses reflect the expectation that manufacturers will
target lower values to provide compliance margins.
The agencies have also improved the engine test procedures and
compliance provisions to reduce the agencies' and the manufacturers'
uncertainty of engine test results. For example, in the agencies'
confirmatory test procedures we are requiring that the agencies use the
average of at least three tests (i.e., the arithmetic mean of a sample
size of at least three test results) for determining the values of
confirmatory test results for any GEM engine fuel maps. We are only
doing this for GEM engine fuel maps because these are relatively new
tests, compared to Phase 1 testing or EPA's other emissions standards.
Therefore, this provision does not apply to any other emissions
testing. For all other emissions testing besides GEM engine fuel maps
the agencies' maintain our usual convention of utilizing a sample size
of one for confirmatory testing. For GEM engine fuel mapping this at
least triples the test burden for the agencies to conduct confirmatory
testing, but it also decreases confirmatory test result uncertainty by
at least 42 percent.\196\ Based on improvements like this one, and
others described in Section 1.4 of the RTC, we believe that SET, FTP
and GEM's steady-state, cycle-average and powertrain test results will
have an overall uncertainty of +/-1.0 percent. To further protect
against falsely high emissions results or false failures due to this
remaining level of test procedure uncertainty, we have included a +1
percent compliance margin into our stringency analyses of the engine
standards and the GEM fuel map inputs used to determine the tractor and
vocational vehicle standards. In other words we set Phase 2 engine and
vehicle standards 1 percent less stringent than if we had not
considered this test procedure uncertainty.
---------------------------------------------------------------------------
\196\ The statistical formula for standard error, which is a
well-accepted measure of uncertainty, is the standard deviation
times the reciprocal of the square root of the sample size. For a
sample size of three, the reciprocal of the square root of three is
approximately 0.58, which results in a 42% reduction in uncertainty,
versus a sample size of one.
---------------------------------------------------------------------------
In addition to the test procedure improvements and the +1 percent
margin we incorporated into our standards, the agencies are also
committed to a process of continuous improvement of test procedures to
further reduce test result uncertainty. To contribute to this effort,
in mid-2016 EPA committed $250,000 to fund research to further evaluate
individual sources of engine mapping test procedure uncertainty. This
work will occur at SwRI. Should the results of this work or other
similar future work indicate test procedure improvements that would
further reduce test result uncertainty, the agencies will incorporate
these improvements through appropriate guidance or through technical
amendments to the regulations via a notice and comment rulemaking. If
we determine in the future through the SwRI work or other work that
such improvements eliminate the need to require the agencies to conduct
triplicate confirmatory testing of GEM engine fuel maps, we will
promulgate technical amendments to the regulations to remove this
requirement. If we determine in the future through the SwRI work or
other work that the +1.0 percent we factored into our stringency
analysis was inappropriately low or high, we will promulgate technical
amendments to the regulations to address any inappropriate impact this
+1.0 percent had on the stringency of the engine and vehicle
standards.\197\ In addition, whenever the agencies determine whether or
not confirmatory test results are statistically significantly different
from manufacturers' declared values, the agencies will use good
engineering judgment to appropriately factor into such determinations
the results of this SwRI work and/or any other future work that
quantifies our test procedures' uncertainty.
---------------------------------------------------------------------------
\197\ Note that this +1.0 percent compliance margin built into
the standards, or any other future determination of test procedure
uncertainty, does not impact the agencies' technology feasibility or
cost-benefit analyses for this rulemaking.
---------------------------------------------------------------------------
III. Class 7 and 8 Combination Tractors
Class 7 and 8 combination tractors-trailers contribute the largest
portion of the total GHG emissions and fuel consumption of the heavy-
duty sector, approximately 60 percent, due to their large payloads,
their high annual miles traveled, and their major role in national
freight transport.\198\ These vehicles
[[Page 73572]]
consist of a cab and engine (tractor or combination tractor) and a
trailer.\199\ In general, reducing GHG emissions and fuel consumption
for these vehicles will involve improvements to all aspects of the
vehicle.
---------------------------------------------------------------------------
\198\ The on-highway Class 7 and 8 combination tractor-trailers
constitute the vast majority of this regulatory category. A small
fraction of combination tractors are used in off-road applications
and are regulated differently, as described in Section III.C.
\199\ ``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.''
---------------------------------------------------------------------------
As we found during the development in Phase 1 and as continues to
be true in the industry today, the heavy-duty combination tractor-
trailer industry consists of separate tractor manufacturers and trailer
manufacturers. 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. 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. Thus,
although tractor-trailers operate essentially as a unit from both a
commercial standpoint and for purposes of fuel efficiency and
CO2 emissions, the agencies have developed separate
standards for each.
Based on these industry characteristics, EPA and NHTSA believe that
the most appropriate regulatory approach for combination tractors and
trailers is to establish standards for tractors separately from
trailers. As discussed below in Section IV, the agencies are also
adopting standards for certain types of trailers.
A. Summary of the Phase 1 Tractor Program
The design of each tractor's cab and drivetrain determines the
amount of power that the engine must produce in moving the truck and
its payload down the road. As illustrated in Figure III-1, the loads
that require additional power from the engine include air resistance
(aerodynamics), tire rolling resistance, and parasitic losses
(including accessory loads and friction in the drivetrain). The
importance of the engine design is that it determines the basic GHG
emissions and fuel consumption performance for the variety of demands
placed on the vehicle, regardless of the characteristics of the cab in
which it is installed.
[GRAPHIC] [TIFF OMITTED] TR25OC16.007
Accordingly, for Class 7 and 8 combination tractors, the agencies
adopted two sets of Phase 1 tractor standards for fuel consumption and
CO2 emissions. The CO2 emission and fuel
consumption reductions related to engine technologies are recognized in
the engine standards. For vehicle-related emissions and fuel
consumption, tractor manufacturers are required to meet vehicle-based
standards. Compliance with the vehicle standard must be determined
using the GEM vehicle simulation tool.
---------------------------------------------------------------------------
\200\ 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.
---------------------------------------------------------------------------
The Phase 1 tractor standards were based on several key attributes
related to GHG emissions and fuel consumption that reasonably represent
the many differences in utility and performance among these vehicles.
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 the customer's demand. The Phase 1 tractor
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
[[Page 73573]]
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. Based on these attributes,
the agencies created nine subcategories within the Class 7 and 8
combination tractor category. The Phase 1 rules set standards for each
of them. Phase 1 standards began with the 2014 model year and were
followed with more stringent standards following in model year
2017.\201\ 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.
Although the EPA and NHTSA standards are expressed differently (grams
of CO2 per ton-mile and gallons per 1,000 ton-mile
respectively), the standards are equivalent.
---------------------------------------------------------------------------
\201\ Manufacturers may have voluntarily opted-in to the NHTSA
fuel consumption standards in model years 2014 or 2015. Once a
manufacturer opts into the NHTSA program it must stay in the program
for all optional MYs.
---------------------------------------------------------------------------
In Phase 1, the agencies allowed manufacturers to certify certain
types of combination tractors as vocational vehicles. These are
tractors that do not typically operate at highway speeds, or would
otherwise not benefit from efficiency improvements designed for line-
haul tractors (although standards still apply to the engines installed
in these vehicles). The agencies created a subcategory of ``vocational
tractors,'' or referred to as ``special purpose tractors'' in 40 CFR
part 1037, because real world operation of these tractors is better
represented by our Phase 1 vocational vehicle duty cycle than the
tractor duty cycles. Vocational tractors are subject to the standards
for vocational vehicles rather than the combination tractor standards.
In addition, specific vocational tractors and heavy-duty vocational
vehicles primarily designed to perform work off-road or having tires
installed with a maximum speed rating at or below 55 mph are exempted
from the Phase 1 standards.
In Phase 1, the agencies also established separate performance
standards for the engines manufactured for use in these tractors. EPA's
engine-based CO2 standards and NHTSA's engine-based fuel
consumption standards are being implemented using EPA's existing test
procedures and regulatory structure for criteria pollutant emissions
from medium- and heavy-duty engines. These engine standards vary
depending on engine size linked to intended vehicle service class
(which are the same service classes used for many years for EPA's
criteria pollutant standards).
Manufacturers demonstrate compliance with the Phase 1 tractor
standards using the GEM simulation tool. As explained in Section II
above, GEM is a customized vehicle simulation model which is the
preferred approach to demonstrating compliance testing for combination
tractors rather than chassis dynamometer testing used in light-duty
vehicle compliance. As discussed in the development of HD Phase 1 and
recommended by the NAS 2010 study, a simulation tool is the preferred
approach for HD tractor compliance because of the extremely large
number of vehicle configurations.\202\ The GEM compliance tool was
developed by EPA and 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. For HD Phase 1, these characteristics
relate to key technologies appropriate for this category 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 in compliance with the separate, applicable Phase 1 engine
standard. Using these inputs, the model is used to quantify the overall
performance of the vehicle in terms of CO2 emissions and
fuel consumption. CO2 emission reduction and fuel
consumption technologies not measured by the model must be evaluated
separately, and the HD Phase 1 rules establish mechanisms allowing
credit for such ``off-cycle'' technologies.
---------------------------------------------------------------------------
\202\ National Academy of Science. ``Technologies and Approaches
to Reducing the Fuel Consumption of Medium- and Heavy-Duty
Vehicles.'' 2010. Recommendation 8-4 stated ``Simulation modeling
should be used with component test data and additional tested inputs
from powertrain tests, which could lower the cost and administrative
burden yet achieve the needed accuracy of results.''
---------------------------------------------------------------------------
In addition to the final Phase 1 tractor-based standards for
CO2, EPA adopted a separate standard to reduce leakage of
HFC refrigerant from cabin air conditioning (A/C) systems from
combination tractors that apply to the tractor manufacturer. This HFC
leakage standard is independent of the CO2 tractor standard.
Manufacturers can choose technologies from a menu of leak-reducing
technologies sufficient to comply with the standard, as opposed to
using a test to measure performance.
The Phase 1 program also provided several flexibilities to advance
the goals of the overall program while providing alternative pathways
to achieve compliance. The primary flexibility is the averaging,
banking, and trading program which allows emissions and fuel
consumption credits to be averaged within an averaging set, banked for
up to five years, or traded among manufacturers. Manufacturers with
credit deficits were allowed to carry-forward credit deficits for up to
three model years, similar to the LD GHG and CAFE carry-back credits.
Phase 1 also included several interim provisions, such as incentives
for advanced technologies and provisions to obtain credits for
innovative technologies (called off-cycle in the Phase 2 program) not
accounted for by the HD Phase 1 version of GEM or for certifying early.
B. Overview of the Phase 2 Tractor Program and Key Changes From the
Proposal
The HD Phase 2 program is similar in many respects to the Phase 1
approach. The agencies are keeping the Phase 1 attribute-based
regulatory structure in terms of dividing the tractor category into the
same nine subcategories based on the tractor's GVWR, cab configuration,
and roof height. This structure is working well in the implementation
of Phase 1. EMA and Daimler supported this approach again in their
comments to the Phase 2 NPRM. The one area where the agencies are
changing the regulatory structure is related to heavy-haul tractors. As
noted above, the Phase 1 regulations include a set of provisions that
allow vocational tractors to be treated as vocational vehicles.
However, because the agencies are including the powertrain as part of
the technology basis for the tractor and vocational vehicle standards
in Phase 2, we are classifying a certain set of these vocational
tractors as heavy-haul tractors and subjecting them to a separate
tractor standard that reflects their unique powertrain requirements and
limitations in application of technologies to reduce fuel consumption
and CO2 emissions.\203\ The agencies are adopting some
revisions to the proposed Phase 2 criteria used to define heavy-haul
tractors in response
[[Page 73574]]
to comments, as discussed below in Section III.C.4.
---------------------------------------------------------------------------
\203\ See 76 FR 57138 for Phase 1 discussion. See 40 CFR
1037.801 for Phase 2 heavy-haul tractor regulatory definition.
---------------------------------------------------------------------------
The agencies will retain much of the certification and compliance
structure developed in Phase 1. The Phase 2 tractor CO2
emissions and fuel consumption standards, as in Phase 1, will be
aligned.\204\ The agencies will also continue to have separate engine
and vehicle standards to drive technology improvements in both areas.
The reasoning behind maintaining separate standards is discussed above
in Section II.B.2. As in Phase 1, the manufacturers will certify
tractors using the GEM simulation tool and evaluate the performance of
subsystems through testing (the results of this testing to be used as
inputs to the GEM simulation tool). Other aspects of the HD Phase 2
certification and compliance program also mirror the Phase 1 program,
such as maintaining a single reporting structure to satisfy both
agencies, requiring limited data at the beginning of the model year for
certification, and determining compliance based on end of year reports.
In the Phase 1 program, manufacturers participating in the ABT program
provided 90 day and 270 day reports after the end of the model year.
For the Phase 2 program, the agencies proposed that manufacturers would
only be required to submit one end of the year report, which would have
simplified reporting. Manufacturers provided comments opposing this
approach. After further consideration, the agencies are adopting an
approach in Phase 2 that mirrors the Phase 1 approach with a 90 day
preliminary report and a 270 day final report, with the manufacturer
having the option to request a waiver of the 90 day report based on
positive credit balances.
---------------------------------------------------------------------------
\204\ Fuel consumption is calculated from CO2 using
the conversion factor of 10,180 grams of CO2 per gallon
for diesel fuel.
---------------------------------------------------------------------------
Even though many aspects of the HD Phase 2 program are similar to
Phase 1, there are some key differences. While Phase 1 focused on
reducing CO2 emissions and fuel consumption in tractors
through the application of existing (``off-the-shelf'') technologies,
the HD Phase 2 standards seek additional reductions through increased
use of existing technologies and the development and deployment of more
advanced technologies. The agencies received numerous comments on the
proposed Phase 2 technology assessments in terms of the baseline, the
technology effectiveness, the market adoption rate projections, and the
technology costs. The agencies have made changes reflecting our
assessment of these comments, as described in Section III.D.
To evaluate the effectiveness of a more comprehensive set of
technologies in Phase 2, the agencies are including several additional
inputs to the Phase 2 GEM. The set of inputs includes the Phase 1
inputs plus parameters to assess the performance of the engine,
transmission, and driveline. Specific inputs for, among others,
predictive cruise control, automatic tire inflation systems, and 6x2
axles will now be required. The final Phase 2 program includes some
changes to the proposed Phase 2 technology inputs to GEM. These changes
from proposal include the use of cycle-averaged fuel maps for use when
evaluating a vehicle over the transient cycle, optional transmission
efficiency inputs, optional axle efficiency inputs, an increase in the
types of idle reduction technologies recognized in GEM, and the ability
to recognize the effectiveness of tire pressure monitoring systems,
neutral coast, and neutral idle. As in Phase 1, in Phase 2
manufacturers will conduct component testing to obtain the values for
these technologies (should they choose to use them), then the testing
values will be input into the GEM simulation tool. See Section III.D.1
below. To effectively assess performance of the technologies, the
agencies are adopting a revised version of the road grade profiles
proposed for Phase 2. Finally, the agencies are adopting Phase 2
regulations with clarified selective enforcement and confirmatory
testing requirements for the GEM inputs that differ from the Phase 2
NPRM based on the comments received.
The key aerodynamic assessment areas that the agencies proposed to
change in Phase 2 relative to Phase 1 were the use of a more
aerodynamic reference trailer, the inclusion of the impact of wind on
the tractor, and changes to the aerodynamic test procedures. We are
adopting these changes in Phase 2 with some further revisions from
those proposed for Phase 2 based on comments. To reflect the evolving
trailer market, the agencies are adopting as proposed the addition of
trailer skirts (an aerodynamic improving device) to the reference
trailer (i.e. the trailer used during testing to determine the relative
aerodynamic performance of the tractor). The agencies are also adopting
the proposed aerodynamic certification test procedure that captures the
impact of wind average drag on tractor aerodynamic performance.
However, the agencies are specifying in the final rule the use of a
single surrogate yaw angle instead of a full yaw sweep to reduce the
aerodynamic testing burden based on further assessment of the EPA
aerodynamic data and comments received on the NPRM. Finally, the
agencies are adopting aerodynamic test procedure and data analysis
changes from the Phase 2 proposal to further reduce the variability of
aerodynamic test results. Detailed discussion of the aerodynamic test
procedures is included in Section III.E.2.
Another key change to the final rule is the adoption of more
stringent particulate matter (PM) standards for auxiliary power units
(APU) installed in new tractors.\205\ In the Phase 2 NPRM, EPA sought
comment on the need for and feasibility of new PM standards for these
engines because APUs can be used in lieu of operating the main engine
during extended idle operations to provide climate control and power to
the driver. See 80 FR 40213. APUs can reduce fuel consumption,
NOX, HC, CH4, and CO2 emissions when
compared to main engine idling.\206\ However, a potential unintended
consequence of reducing CO2 emissions from combination
tractors through the use of APUs during extended idle operation is an
increase in PM emissions. EPA is adopting requirements for APUs
installed in new tractors to meet lower PM standards starting in 2018,
with a more stringent PM standard starting in 2024. Please see Section
III.C.3 for more details.
---------------------------------------------------------------------------
\205\ This is necessarily an EPA-only provision since it relates
to control of criteria pollutant emissions from a type of non-road
engine, not to fuel efficiency.
\206\ U.S. EPA. Development of Emission Rates for Heavy-Duty
Vehicles in the Motor Vehicle Emissions Simulator MOVES 2010. EPA-
420-B-12-049. August 2012.
---------------------------------------------------------------------------
The agencies are also ending some of the interim provisions
developed in Phase 1 to reflect the maturity of the program and the
reduced need and justification for some of the Phase 1 flexibilities.
Further discussions on all of these matters are covered in the
following sections.
C. Phase 2 Tractor Standards
EPA is adopting CO2 standards and NHTSA is adopting fuel
consumption standards for new Class 7 and 8 combination tractors in
Phase 2 that are more stringent than Phase 1. In addition, EPA is
continuing the HFC standards for the air conditioning systems that were
adopted in Phase 1. EPA is also adopting new standards to further
control emissions of particulate matter (PM) from auxiliary power units
(APU) installed in new tractors that will prevent an unintended
consequence of
[[Page 73575]]
increasing PM emissions during long duration idling.
This section describes these standards in detail.
(1) Final Fuel Consumption and CO2 Standards
The Phase 2 fuel consumption and CO2 standards for the
tractor cab are shown below in Table III-1. These standards will
achieve reductions of up to 25 percent compared to the 2017 model year
baseline level when fully phased in for the 2027 MY.\207\ The standards
for Class 7 are described as ``Day Cabs'' because we are not aware of
any Class 7 sleeper cabs in the market today; however, the agencies
require any Class 7 tractor, regardless of cab configuration, meet the
standards described as ``Class 7 Day Cab.''
---------------------------------------------------------------------------
\207\ Since the HD Phase 1 tractor standards fully phase-in by
the MY 2017, this is the logical baseline year.
---------------------------------------------------------------------------
The agencies' analyses, as discussed briefly below and in more
detail later in this Preamble and in the RIA Chapter 2.4 and 2.8,
indicate that these standards are the maximum feasible (within the
meaning of 49 U.S.C. 32902(k)) and are appropriate under each agency's
respective statutory authorities.
Table III-1--Phase 2 Heavy-Duty Combination Tractor EPA Emissions Standards (g CO[ihel2]/ton-mile) and NHTSA
Fuel Consumption Standards (gal/1,000 ton-mile)
----------------------------------------------------------------------------------------------------------------
Day cab Sleeper cab Heavy-haul
---------------------------------------------------------------
Class 7 Class 8 Class 8 Class 8
----------------------------------------------------------------------------------------------------------------
2021 Model Year CO2 Grams per Ton-Mile
----------------------------------------------------------------------------------------------------------------
Low Roof........................................ 105.5 80.5 72.3 52.4
Mid Roof........................................ 113.2 85.4 78.0 ..............
High Roof....................................... 113.5 85.6 75.7 ..............
----------------------------------------------------------------------------------------------------------------
2021 Model Year Gallons of Fuel per 1,000 Ton-Mile
----------------------------------------------------------------------------------------------------------------
Low Roof........................................ 10.36346 7.90766 7.10216 5.14735
Mid Roof........................................ 11.11984 8.38900 7.66208 ..............
High Roof....................................... 11.14931 8.40864 7.43615 ..............
----------------------------------------------------------------------------------------------------------------
2024 Model Year CO2 Grams per Ton-Mile
----------------------------------------------------------------------------------------------------------------
Low Roof........................................ 99.8 76.2 68.0 50.2
Mid Roof........................................ 107.1 80.9 73.5 ..............
High Roof....................................... 106.6 80.4 70.7 ..............
----------------------------------------------------------------------------------------------------------------
2024 Model Year and Later Gallons of Fuel per 1,000 Ton-Mile
----------------------------------------------------------------------------------------------------------------
Low Roof........................................ 9.80354 7.48527 6.67976 4.93124
Mid Roof........................................ 10.52063 7.94695 7.22004 ..............
High Roof....................................... 10.47151 7.89784 6.94499 ..............
----------------------------------------------------------------------------------------------------------------
2027 Model Year CO2 Grams per Ton-Mile a
----------------------------------------------------------------------------------------------------------------
Low Roof........................................ 96.2 73.4 64.1 48.3
Mid Roof........................................ 103.4 78.0 69.6 ..............
High Roof....................................... 100.0 75.7 64.3 ..............
----------------------------------------------------------------------------------------------------------------
2027 Model Year and Later Gallons of Fuel per 1,000 Ton-Mile
----------------------------------------------------------------------------------------------------------------
Low Roof........................................ 9.44990 7.21022 6.29666 4.74460
Mid Roof........................................ 10.15717 7.66208 6.83694 ..............
High Roof....................................... 9.82318 7.43615 6.31631 ..............
----------------------------------------------------------------------------------------------------------------
Note:
\a\ The 2027 MY high roof tractor standards include a 0.3 m\2\ reduction in CdA as described in Section
III.E.2.a.vii.
As the agencies noted in the Preamble to the proposed standards,
the HD Phase 2 CO2 and fuel consumption standards are not
directly comparable to the Phase 1 standards. 80 FR 40212. This is
because the agencies are adopting several test procedure changes to
more accurately reflect real world operation. With respect to tractors,
these changes will result in the following differences. First, the same
vehicle evaluated using the HD Phase 2 version of GEM will obtain
higher (i.e. less favorable) CO2 and fuel consumption values
because the Phase 2 drive cycles include road grade. Road grade, which
(of course) exists in the real-world, requires the engine to operate at
higher horsepower levels to maintain speed while climbing a hill. Even
though the engine saves fuel on a downhill section, the overall impact
increases CO2 emissions and fuel consumption. The second of
the key differences between the CO2 and fuel consumption
values in Phase 1 and Phase 2 is due to changes in the evaluation of
aerodynamics. Vehicles are exposed to wind when in use which increases
the drag of the vehicle and in turn increases the power required to
move the vehicle down the road. To more appropriately reflect the in-
use aerodynamic performance of tractor-
[[Page 73576]]
trailers, the agencies are adopting a wind averaged coefficient of drag
instead of the no-wind (zero yaw) value used in Phase 1. The final key
difference between Phase 1 and the Phase 2 program includes a more
realistic and improved simulation of the transmission in GEM, which
could increase CO2 and fuel consumption relative to Phase 1.
The agencies are adopting Phase 2 CO2 emissions and fuel
consumption standards for the combination tractors that reflect
reductions that can be achieved through improvements in the tractor's
powertrain, aerodynamics, tires, and other vehicle systems. The
agencies have analyzed the feasibility of achieving the CO2
and fuel consumption standards, and have identified means of achieving
these 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 these standards in Section
III.D.1. In developing these standards for Class 7 and 8 tractors, the
agencies have evaluated the following:
The current levels of emissions and fuel consumption
the types of technologies that could be utilized by tractor
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
the magnitude of the CO2 and fuel savings that may
be achieved
The technologies on whose performance the final tractor standards
are predicated include: improvements in the engine, transmission,
driveline, aerodynamic design, tire rolling resistance, other
accessories of the tractor, and extended idle reduction technologies.
These technologies, and other accessories of the tractor, are described
in RIA Chapter 2.4 and 2.8. The agencies' evaluation shows that some of
these technologies are available today, but have very low adoption
rates on current vehicles, while others will require some lead time for
development. EPA and NHTSA also present the estimated costs and
benefits of the Class 7 and 8 combination tractor standards in RIA
Chapter 2.8 and 2.12, explaining as well the basis for the agencies'
stringency level.
As explained below in Section III.D, EPA and NHTSA have determined
that there will be sufficient lead time to introduce various tractor
and engine technologies into the fleet starting in the 2021 model year
and fully phasing in by the 2027 model year. This is consistent with
NHTSA's statutory requirement to provide four full model years of
regulatory lead time for standards. As was adopted in Phase 1, the
agencies are adopting provisions for Phase 2 that allow manufacturers
to generate and use credits from Class 7 and 8 combination tractors to
show compliance with the standards. This is discussed further in
Section III.F.
Based on our analysis, the 2027 model year standards for
combination tractors and engines represent up to a 25 percent reduction
in CO2 emissions and fuel consumption over a 2017 model year
baseline tractor, as detailed in Section III.D.1. In considering the
feasibility of vehicles to comply with these standards over their
useful lives, EPA also considered the potential for CO2
emissions to increase during the regulatory useful life of the product.
As we discuss in Phase 1 and 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 for the projected technologies. In general,
engine and vehicle friction decreases as products wear, leading to
reduced parasitic losses and consequent lower CO2 emissions.
Similarly, tire rolling resistance falls as tires wear due to the
reduction in tread depth. 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
emissions performance in-use. Given all of these considerations, the
agencies are confident in projecting that the tractor standards today
will be technically feasible throughout the regulatory useful life of
the program.
(2) Non-CO2 GHG Emission Standards for Tractors
EPA is also continuing the Phase 1 standards to control non-
CO2 GHG emissions from Class 7 and 8 combination tractors.
(a) N2O and CH4 Emissions
The final Phase 2 heavy-duty engine standards for both
N2O and CH4 as well as details of these standards
are included in the discussion in Section II.D.3 and II.D.4. EPA
requested comment, but did not receive any comments (or otherwise
obtain any new information) indicating that there were appropriate
controls for these non-CO2 GHG emissions for the tractors
manufacturers. Nor does EPA believe there are any technologies
available to set vehicle standards. Therefore, EPA is not adopting any
additional controls for N2O or CH4 emissions
beyond those in the HD Phase 2 engine standards for the tractor
category.
(b) HFC Emissions
Manufacturers can reduce hydrofluorocarbon (HFC) emissions from air
conditioning (A/C) leakage emissions in two ways. First, they can
utilize leak-tight A/C system 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, to replace the commonly used R-134a refrigerant. EPA
is maintaining the A/C leakage standards adopted in HD Phase 1 (see 40
CFR 1037.115). EPA believes the Phase 1 use of leak-tight components is
at an appropriate level of stringency while maintaining the flexibility
to produce the wide variety of A/C system configurations required in
the tractor category. Please see Section I.F.(1)(b) for a discussion
related to alternative refrigerants.
(3) EPA's PM Emission Standards for APUs Installed in New Tractors
Auxiliary power units (APUs) can be used in lieu of operating the
main engine during extended idle operations to provide climate control
and additional hotel power for the driver. As noted above, APUs can
reduce fuel consumption, NOX, HC, CH4, and
CO2 emissions by a meaningful amount when compared to main
engine idling.\208\ However, a potential unintended consequence of
reducing CO2 emissions from combination tractors through the
use of APUs during extended idle operation is an increase in diesel PM
emissions. Engines currently being used to power APUs have been subject
to the Nonroad Tier 4 p.m. standards (40 CFR 1039.101), which are less
stringent in this power category than the heavy-duty on-highway
standards (40 CFR 86.007-11) on a brake-specific basis. In the NPRM,
EPA sought comment on the need for and appropriateness of further
reducing PM emissions from APUs used as part of a compliance strategy
for Phase 2, and suggested the basis for possible new PM
[[Page 73577]]
standards to avoid these unintended consequence. 80 FR 40213.
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\208\ U.S. EPA. Development of Emission Rates for Heavy-Duty
Vehicles in the Motor Vehicle Emissions Simulator MOVES 2010. EPA-
420-B-12-049. August 2012.
---------------------------------------------------------------------------
After considering the numerous comments submitted on this issue and
our consideration of feasibility of PM controls, EPA is adopting a new
PM standard of 0.02 g/kW-hr that applies exclusively to APUs installed
in MY 2024 and later new tractors. EPA is also amending the Phase 1 GHG
standards to provide that as of January 1, 2018 and through MY 2020, a
tractor can receive credit for use of an AESS with an APU installed at
the factory only if the APU engine is certified under 40 CFR part 1039
with a deteriorated emission level for PM that is at or below 0.15 g/
kW-hr. For MY 2021 through 2023, this same emission level applies as a
standard for all new tractors with an APU installed. Starting in MY
2024, any APU installed in a new tractor must be certified to a PM
emission standard of 0.02 g/kW-hr over the full useful life as
specified in 40 CFR 1039.699. Engine manufacturers may alternatively
meet the APU standard by certifying their engines under 40 CFR part
1039 with a Family Emission Limit for PM at or below 0.02 g/kW-hr. APUs
installed on MY 2024 and later tractors must have a label stating that
the APU meets the PM requirements of 40 CFR 1039.699. Tractor
manufacturers will be subject to a prohibition against selling new MY
2024 and later tractors with APUs that are not certified to the
specified standards, and manufacturers will similarly be subject to a
prohibition against selling new MY 2021 through 2023 tractors with APUs
that do not meet the specified emission levels. This applies for both
new and used APUs installed in such new tractors. Manufacturers of new
nonroad engines and new APUs may continue to produce and sell their
products for uses other than installation in new tractors without
violating these prohibitions. However, nonroad engine manufacturers and
APU manufacturers would be liable if they are found to have caused a
tractor manufacturer to violate this prohibition, such as by
mislabeling an APU as compliant with this standard. Note also that the
PM standard for APUs applies for new tractors, whether or not the
engine and APU are new; conversely, the PM standard does not apply for
APU retrofits on tractors that are no longer new, even if the engine
and APU are new.
Table III-2--PM Standards for Tractors Using APUs
------------------------------------------------------------------------
PM emission
Tractor MY standard (g/kW- Expected control
hr) technology
------------------------------------------------------------------------
MY 2021-2023 \a\.................. 0.15 In-cylinder PM
control.
MY 2024 and later................. 0.02 Diesel Particulate
Filter.
------------------------------------------------------------------------
Note:
\a\ APUs installed on new tractors built January 1, 2018 and later,
through model year 2020, must have engines that meet the same 0.15 g/
kW-hr emission level if they rely on AESS for demonstrating compliance
with emission standards.
We discuss below the principal comments we received on whether to
adopt a standard to control PM emissions from APUs used for tractor
idle emission control, the basis for the amended standards, and how EPA
envisions the standards operating in practice.
Among the comments we received were those from the American Lung
Association, National Association of Clean Air Agencies, Northeast
States for Coordinated Air Use Management, Environmental Defense Fund,
Natural Resources Defense Council, Environmental Law and Policy Center,
Coalition for Clean Air/California Cleaner Freight Coalition, Moving
Forward Network, Ozone Transport Commission, and the Center for
Biological Diversity that urged EPA to amend the standards for PM
emissions from these engines in order to reduce PM emission increases
resulting from increased APU use. Bendix commented that EPA should
consider the full vehicle emissions and fuel consumption, including the
APU, to create a more accurate comparison when considering alternatives
to diesel powered APUs. California's ARB supported the development of a
federal rule that requires DPFs on APUs, similar to the requirements
already in place in California because diesel PM poses a large public
health risk.
In contrast, EMA commented that EPA should not impose any new
emission requirements on APU engines because they already meet the Tier
4 nonroad standards and argued further that this rulemaking is not the
proper forum for amending nonroad engine emission standards. Ingersoll
Rand commented that they have significant concerns with regard to a
nationwide requirement for use of DPFs in diesel-powered APUs, and
strongly urged EPA not to impose such a perceived burden on the
trucking industry. Ingersoll Rand's concerns are that the additional
cost would push owners away from diesel-powered APUs to battery-powered
APUs that, according to Ingersoll Rand, are not yet mature enough to
serve as a replacement for diesel-powered APUs. Ingersoll Rand believes
that high-capacity battery-powered APUs will eventually become a
commercially available and cost-effective alternative to diesel-powered
APUs. Ingersoll Rand stated that, although Thermo King has been
dedicating resources to research and development in this area for some
time, mandating this technology today would significantly decrease
consumer choice, competitiveness in the APU marketplace, and driver
comfort and safety. ATA is concerned that efforts to place additional
emissions controls, and therefore additional costs, on APUs by making
PM standards more stringent will discourage the use of this fuel
efficient technology. EPA considered Ingersoll Rand's comments in
developing a phased-in approach to the new PM standards for new
tractors using APUs to, having the principal standard apply commencing
with MY 2024 tractors in order to provide sufficient lead time.
Following is discussion of our analysis of this issue in light of
the information we received and of our decision to establish a new PM
standard for these units.
(a) PM Emissions Impact Without Additional Controls
EPA conducted an analysis using MOVES, which evaluates the
potential impact on PM emissions due to an increase in APU adoption
rates. In this analysis, EPA assumed that PM emission rates from
current technology APUs would be unchanged in the future. We estimated
an average in-use APU emission rate of 0.96 grams PM per hour from
three in-use APUs (model years 2006 and 2011), measured in
[[Page 73578]]
different load conditions.\209\ We determined that a typical 2010 model
year or newer tractor that uses its main engine to idle emits 0.32
grams PM per hour, based on a similar analysis of in-use idling of
emissions from 2010 model year and newer tractors.\12\ Thus, the use of
an APU would lead to a potential increase in PM of as much as 0.64
grams per hour.
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\209\ U.S. EPA. Updates to MOVES for Emissions Analysis of
Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium-
and Heavy-Duty Engines and Vehicles--Phase 2 FRM. Docket Number EPA-
HQ-OAR-2014-0827. July 2016.
---------------------------------------------------------------------------
The results from these MOVES runs are shown below in Table III-3.
These results show that an increase in use of APUs could lead to an
overall increase in PM emissions if no additional PM emission standards
were put in place. Column three labeled ``Final Phase 2 GHG Program
PM2.5 Emission Impact without Further PM Control (tons)''
shows the incremental increase in PM2.5 without further
regulation of APU PM2.5 emissions, assuming the rate of APU
use on which the final CO2 standard is premised. These PM
emission impacts represent an increase of approximately three percent
of the HD sector PM emissions. We note further that the pollutant at
issue is diesel PM, which is associated with myriad serious health
effects, including premature mortality. See Section VIII.A.6 below.
Table III-3--Projected Impact of Increased Adoption of APUs in Phase 2
------------------------------------------------------------------------
Final phase 2
GHG program
Baseline HD PM2.5 \a\
CY vehicle PM2.5 emission impact
emissions (tons) without further
PM control
(tons) \b\
------------------------------------------------------------------------
2040.............................. 20,939 464
2050.............................. 22,995 534
------------------------------------------------------------------------
Note:
\a\ Positive numbers mean emissions would increase from baseline to
control case.
\b\ The impacts shown include all PM2.5 impacts from the rule including
impacts from increased tire wear and brake wear that results from the
slight increase in VMT projected as a result of this rule.
(b) Feasibility of PM Emission Reductions
As EPA discussed in the NPRM, there are DPFs in the marketplace
today that can reduce PM emissions from APUs. 80 FR 40213. Since
January 1, 2008, California ARB has restricted the idling of sleeper
cab tractors during periods of sleep and rest.\210\ The regulations
apply additional requirements to diesel-fueled APUs on tractors
equipped with 2007 model year or newer main engines. Truck owners in
California must either: (1) Fit the APU with an ARB verified Level 3
particulate control device that achieves 85 percent reduction in
particulate matter; or (2) have the APU exhaust plumbed into the
vehicle's exhaust system upstream of the particulate matter
aftertreatment device.\211\ Currently ARB has identified four control
devices that have been verified to meet the Level 3 p.m. requirements.
These devices include HUSS Umwelttechnik GmbH's FS-MK Series Diesel
Particulate filters, Impco Ecotrans Technologies' ClearSky Diesel
Particulate Filter, Thermo King's Electric Regenerative Diesel
Particulate Filter, and Proventia's Electronically Heated Diesel
Particulate Filter. In addition, ARB has approved a Cummins integrated
diesel-fueled APU and several fuel-fired heaters produced by Espar and
Webasto.
---------------------------------------------------------------------------
\210\ California Air Resources Board. Idle Reduction
Technologies for Sleeper Berth Trucks. Last viewed on September 19,
2014 at http://www.arb.ca.gov/msprog/cabcomfort/cabcomfort.htm.
\211\ California Air Resources Board. Sec. 2485(c)(3)(A)(1).
---------------------------------------------------------------------------
EPA received comments from Daimler, Idle Smart, MECA, and Proventia
addressing the feasibility of PM reductions from APU engines. Daimler
stated that they supply APUs that currently meet ARB's PM emission
requirements and encouraged EPA to simply adopt ARB's regulations.
Proventia commented that they have produced an ARB-approved actively
regenerating DPF to fit the Thermo King Tripac APU since 2012 and that
it is proven, reliable, and commercially available. Idle Smart
commented that their start-stop idle reduction solution emits less PM
emissions than a diesel APU without a DPF. MECA commented that a
particulate filter in this application would be a wall flow device and,
due to the relatively cold exhaust temperature of these small engines,
the filters would need to use either all active or a combination of
passive and active regeneration to periodically clean the soot from the
filter. MECA stated that active regeneration could be achieved through
the use of a fuel burner or electric heather upstream of the filter.
MECA also stated that ARB's regulations demonstrate that it is feasible
to control PM from small APU engines and that the technology has been
available since 2008.
California's Clean Idle program requires that diesel-powered APUs
be fitted with a verified DPF. In some cases, limits are put on the PM
emission level at the engine outlet (upstream of the DPF). For example,
the ThermoKing APU approval utilizing a Yanmar engine requires that
engine is certified to a PM level of 0.2 g/kW-hr or less (upstream of
the DPF).\212\ Implementation of the California program and the
subsequent approval of Level 3 verified devices has led to the
certification of engines utilized in APUs whose PM emissions at the
engine outlet are well below the 0.4 g/kW-hr nonroad Tier 4 final
standard for this size engine in 40 CFR part 1039. For example, the
Yanmar TK270M engine that is used in combination with ThermoKing's
electronic regenerative diesel particulate filter, which is certified
under the EPA designated engine family GYDXL0.57NUA, is certified with
a PM level of 0.09 g/kW-hr. The addition of a DPF affords at least an
additional 85 percent reduction from the engine outlet certified value,
or less than 0.014 g/kW-hr.
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\212\ California Air Resources Board. Executive Order DE-12-006.
Last viewed on June 21, 2016 at http://www.arb.ca.gov/diesel/verdev/pdf/executive_orders/de-12-006.pdf.
---------------------------------------------------------------------------
EPA believes that these comments confirm our discussion at proposal
that PM standards reflecting performance of a diesel particulate filter
are technically feasible.
[[Page 73579]]
(c) Benefits of Further PM Controls
Using MOVES, EPA evaluated the impact of requiring further PM
control from APUs nationwide. As shown in Table III-3 and Table III-4,
EPA projects that the HD Phase 2 program without additional PM controls
would increase PM2.5 emissions by 464 tons in 2040 and 534
tons in 2050. The annual impact of the final program to further control
PM is projected to lead to a reduction of PM2.5 emissions
nationwide by 927 tons in 2040 and by 1,114 tons in 2050, as shown in
Table III-4 the column labeled ``Net Impact on National
PM2.5 Emission with Further PM Control of APUs (tons).''
Note that these requirements will reduce PM emissions from APUs assumed
in the baseline for MY 2018 and later, as well as the additional APUs
that are projected to be used as a result of the Phase 2 standards.
This results in projected reductions that exceed the projected increase
in PM emissions that would have occurred with the new Phase 2 GHG
standards but without these newly promulgated APU standards.
Table III-4--Projected Impact of Further Control on PM2.5 Emissions \a\
----------------------------------------------------------------------------------------------------------------
Net impact on
Baseline national HD Phase 2 HD Phase 2 national PM2.5
heavy-duty program national program national emission with
CY vehicle PM2.5 PM2.5 emissions PM2.5 emissions further PM
emissions (tons) without further with further PM control of APUs
PM control (tons) control (tons) (tons)
----------------------------------------------------------------------------------------------------------------
2040................................ 20,939 21,403 20,476 -927
2050................................ 22,995 23,529 22,416 -1,114
----------------------------------------------------------------------------------------------------------------
Note:
\a\ The impacts shown include all PM2.5 impacts from the rule including impacts from increased tire wear and
brake wear that results from the slight increase in VMT projected as a result of this rule.
(d) PM Emission Reduction Technology Costs
EPA does not project any cost for meeting the requirement,
commencing on January 1, 2018, that tractor manufacturers using APUs as
part of a compliance path to meeting the Phase 1 GHG standards only
receive credit in GEM for use of the APU if they use an APU with an
engine with deteriorated PM emissions at or below 0.15 g/kW-hr. The
same conclusion applies for MY 2021, when we adopt the PM emission
level of 0.15 g/kW-hr as an emission standard, not only as a qualifying
condition for using AESS for demonstrating compliance with the
CO2 standard. First, EPA projects that the 2018-2023
requirements can be achieved at zero cost because several engines are
already meeting them today with in-cylinder controls. Second, this is
only one of many potential compliance pathways for tractors meeting the
Phase 1 standards. We nonetheless are providing extra lead time by
tying this provision to calendar year 2018, rather than model year
2018, to allow manufacturers time for confirming emission levels and
otherwise complying with administrative requirements.
PM emission reductions from APU engines beginning in MY 2024 would
most likely be achieved through installation of a diesel particulate
filter (DPF).\213\ In the NPRM, EPA discussed several sources for DPF
cost estimates. The three sources included the federal Nonroad Diesel
Tier 4 rule, ARB, and Proventia. EPA developed long-term cost
projections for catalyzed diesel particulate filters (DPF) as part of
the Nonroad Diesel Tier 4 rulemaking. In that rulemaking, EPA estimated
the DPF costs would add $580 to the cost of 150 horsepower engines (69
FR 39126, June 29, 2004). On the other hand, ARB estimated the cost of
retrofitting a diesel powered APU with a PM trap to be $2,000 in
2005.\214\ Proventia is charging customers $2,240 for electronically
heated DPF for retrofitting existing APUs.\215\
---------------------------------------------------------------------------
\213\ As discussed below, a DPF could be installed by the APU
manufacturer, the engine manufacturer, the tractor manufacturer, or
a fourth entity, with certification and labelling responsibilities
differing depending on which entity does the installation.
\214\ California Air Resources Board. Staff Report: Initial
Statement of Reasons; Notice of Public Hearing to Consider
Requirements to Reduce Idling Emissions From New and In-Use Trucks,
Beginning in 2008. September 1, 2005. Page 38. Last viewed on
October 20, 2014 at http://www.arb.ca.gov/regact/hdvidle/isor.pdf.
\215\ Proventia. Tripac Filter Kits. Last accessed on October
21, 2014 at http://www.proventiafilters.com/purchase.html.
---------------------------------------------------------------------------
EPA requested comment on DPF costs in the NPRM and received
comments from MECA, Proventia, and Ingersoll Rand. MECA agreed with
EPA's range of DPF costs discussed in the NPRM. Proventia stated that
the $2,240 end user price cited in the NPRM is for an aftermarket
retrofit device. Proventia estimated that the direct manufacturing cost
of materials and manufacturing (which is less than the retail price
equivalent) for quantities exceeding 10,000 annually would be $975 for
an actively regenerating device. The basis for this estimate is
Proventia's current production cost in the quantity of 50 units of
$1069. Proventia stated that EPA's estimate of $580 for a 150hp engine
is likely to be for a catalyzed passively regenerating DPF because
those engines have higher exhaust temperatures. Proventia also stated
that a cost of an actively regenerating DPF is significantly higher
than for passively regenerating devices. Ingersoll Rand commented that
Thermo King currently offers a DPF option on its line of diesel-powered
APUs and the incremental price of the DPF option can be as high as
$3,500. ATA commented that adding a DPF to an APU increases the cost of
the device by up to 20 percent. Daimler provided DPF costs as CBI.
EPA considered the comments and more closely evaluated NHTSA's
contracted TetraTech cost report which found the total retail price of
a diesel-powered APU that includes a DPF to be $10,000.\216\ Based on
all of this information, EPA is projecting the retail price increment
of an actively regenerating DPF installed in an APU to be $2,000. This
cost is incremental to the diesel-powered APU technology costs
beginning in 2024 MY.
---------------------------------------------------------------------------
\216\ U.S. DOT/NHTSA. Commercial Medium- and Heavy-Duty Truck
Fuel Efficiency Technology Cost Study. May 2015. Page 71.
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EPA regards these costs as reasonable. First, the PM standard is
necessary to avoid an unintended consequence of GHG idle control. The
standard adopted is also appropriate for APUs used in on-highway
applications, since it is comparable to the heavy-duty on-highway
standard after considering rounding conventions (the PM standard for a
tractor's main engine is 0.01 g/hp-hr as specified in 40 CFR 86.007-
11(a)(1)(iv))). The standard is also voluntary in the sense that
tractor
[[Page 73580]]
manufacturers can use other types of idle reducing technologies, or
choose a Phase 2 compliance path not involving idle control. The
agencies have developed technology packages for determining the final
Phase 2 tractor GHG and fuel consumption standards that are predicated
on lower penetration rates of diesel APUs than in the NPRM and have
included several additional idle reducing technologies, making it more
likely that alternative compliance paths are readily available. APU
manufacturers (and manufacturers of APU engines) also can market their
product to any entities other than MY 2024 and later new tractors
without meeting the DPF-based PM standard. Our review of the costs of
these standards thus indicates that they will be reasonable.
It is also worth noting that the reductions also have monetized
benefits far greater than the costs of the standard. Section IX.H.1 of
this Preamble discusses the economic value of reductions in criteria
pollutants. In this analysis, EPA estimates the economic value of the
human health benefits associated with the resulting reductions in
PM2.5 exposure using what are known as ``benefit per ton''
values. The benefit per ton values estimate the benefits of reducing
incidence of specific PM2.5-related health impacts,
including reduction in both premature mortality and premature morbidity
from on-road mobile sources. The estimate of benefits from reducing one
ton of direct PM2.5 from on-road mobile sources in 2030
using a three percent discount rate range is between $490,000 and
$1,100,000 (2013$) and is between $440,000 and $990,000 (2013$) using a
seven percent discount rate.\217\ The estimated cost per ton for the
new APU standards in 2040 is $101,717.
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\217\ This valuation is undoubtedly conservative because it
reflects exposure to PM2.5 generally, rather than to the
form of PM here: Diesel exhaust particulate, a likely human
carcinogen. See section VIII.A.6.b. Due to underlying analytical
limitations, PM2.5-related benefit per ton values are
only estimated out to the year 2030. For the criteria pollutant
benefits analysis in this rulemaking, we make a conservative
assumption that 2030 values apply to all emission reductions in
years that extend beyond 2030. We assume benefit-per-ton values grow
larger in the future due to income growth and a larger future
population.
---------------------------------------------------------------------------
(e) Other Considerations
EPA considered the lead time of the new PM standards for APUs
installed in new tractors. The 2018 provision restricting GEM credit
for use of APUs is not a new standard, but rather a compliance
constraint. There should be ample time for tractor manufacturers to
consider how to obtain APUs certified to the designated deteriorated PM
emissions level should they wish to receive GEM credit for use of APUs.
As noted in (d) above, we concluded that the reasonable feasible lead
time is to implement these provisions on January 1, 2018 because the
manufacturer's contemplating use of APUs in conjunction with a Phase 1
compliance strategy using AESS would need time to adapt their
certification systems, which we believe requires lead time of at least
several months.
In MY 2021, tractor manufacturers will be subject to a prohibition
against selling new MY 2021 through 2023 tractors with APUs that do not
meet those specified PM emission levels. For the reasons just given,
there is ample time to meet this requirement.
The diesel particulate filter-based standard for APUs installed in
new tractors begins in MY 2024. This allows several years for the
development and application of diesel particulate filters to these
APUs. We have concluded that, given the timing of the PM emission
standards finalized in this document and the availability of the
technologies, APUs can be designed to meet the new standards with the
lead time provided (and, again, noting that tractor manufacturers have
available compliance pathways available not involving APUs).
In terms of safety, EPA considered the fact that diesel particulate
filters are a known technology. DPFs have been installed on a subset of
diesel powered APUs since the beginning of the California requirements
and have been used with on-highway diesel engines since the sale of MY
2007 engines. We are unaware of any safety issues with this technology.
We are adopting these APU requirements because they allow for reduced
fuel consumption; this also leads to a positive impact with respect to
energy.
(f) Implementation of the Standard
EPA has a choice as to whether to adopt these provisions as a
tractor vehicle standard or as a standard for the non-road engine in
the APU. Under either approach, EPA is required to consider issues of
technical feasibility, cost, safety, energy, and lead time. EPA has
addressed all of these factors above, and finds the 2018, 2021, and
2024 provisions, and associated lead time, to be justified.\218\
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\218\ As noted above, the 2018 provision is a compliance
constraint, not a standard.
---------------------------------------------------------------------------
The final rule applies most directly to tractor manufacturers.
However, other entities potentially affected are the manufacturer of
the APU, the manufacturer of the engine installed in the APU, and a
different entity (if any) separately installing a DPF on the APU
engine. At present, all engines used in APUs must certify to the PM
standard in 40 CFR 1039.101, and must label the engine accordingly (see
40 CFR 1039.135). The provisions we are adopting for MY 2024 require
that any APU engine being certified to the 0.02 g/kW-hr PM standard
have a label indicating that the APU or engine is so certified. This
puts any entity receiving that engine on notice that the APU (and its
engine) can be used in a new tractor. Conversely, the absence of such a
label indicates that the engine cannot be so used. Consequently, if a
tractor manufacturer receives an APU without the supplemental label, it
can only use the APU in a new tractor if it installs a DPF or otherwise
retrofits the APU engine to meet the PM standard.
The APU certification provisions in 40 CFR 1039.699 are simplified
to account for the fact that the APU manufacturer would generally be
adding emission control hardware without modifying the engine from its
certified configuration. Note that engine manufacturers, tractor
manufacturers or others installing the emission control hardware may
also certify to the 0.02 g/kW-hr standard. Since the prohibition
applies to the tractor manufacturer, we would not expect the delegated
assembly provisions of 40 CFR 1037.621 or the secondary vehicle
manufacturer provisions of 40 CFR 1037.622 to apply for APU
manufacturers.
As described above, we are aware that the PM standards as adopted
would not prevent a situation in which tractors are retrofitted with
diesel APUs after they are no longer new, without meeting the PM
standards described above. We believe that vehicle manufacturers will
strongly desire to apply the benefit of AESS with low-PM diesel APUs to
help them meet CO2 standards for any installations where a
diesel APU is a viable or likely option for in-use tractors. We will
consider addressing this possible gap in the program with a standard
for new APUs installed on new or used tractors. Such a standard would
be issued exclusively under our authority to regulate nonroad engines
as described in Clean Air Act section 213 (a)(4). If we adopt such a
standard, we will also consider whether to adopt that same requirement
for new APUs installed in other motor vehicles, and for other nonroad
installations generally.
[[Page 73581]]
(4) Special Purpose Tractors and Heavy-Haul Tractors
The agencies proposed and are adopting provisions in Phase 2 to set
standards for a new subcategory of heavy-haul tractors. In addition and
as noted above, in Phase 1 the agencies adopted provisions to allow
tractor manufacturers to reclassify certain tractors as vocational
vehicles, also called Special Purpose Tractors.\219\ The agencies
proposed and are adopting provisions in Phase 2 to continue to allow
manufacturers to exclude certain vocational-types of tractors (Special
Purpose Tractors) from the combination tractor standards and instead be
subject to the vocational vehicle standards. However, the agencies are
making changes to the proposed Phase 2 Special Purpose Tractors and
heavy-haul tractors in response to comments, as discussed below.
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\219\ See 40 CFR 1037.630.
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(a) Heavy-Haul Tractors
For Phase 2, the agencies proposed and are adopting an additional
subcategory to the tractor category for heavy-haul tractors that are
designed to haul much heavier loads than conventional tractors. The
agencies recognize the need for manufacturers to build these types of
vehicles for specific applications and also recognize that such heavy-
haul tractors are not fully represented by the way GEM simulates
conventional tractors. We believe the appropriate way to prevent
effectively penalizing these vehicles is to set separate standards
recognizing a heavy-haul vehicle's unique needs, which include the need
for a higher horsepower engine and different transmissions. In addition
drivetrain technologies such as 6x2 axles, may not be capable of
handling the heavier loads. The agencies are adopting this change in
Phase 2 because, unlike in Phase 1, the engine, transmission, and
drivetrain technologies are included in the technology packages used to
determine the stringency of the tractor standards and are included as
manufacturer inputs in GEM. The agencies also recognize that certain
technologies used to determine the stringency of the Phase 2 tractor
standards are less applicable to the heavy-haul tractors designed for
the U.S. market. For example, heavy-haul tractors in the U.S. are not
typically used in the same manner as long-haul tractors with extended
highway driving, and therefore will experience less benefit from
aerodynamics. This means that the agencies are adopting a standard that
reflects individualized performance of these technologies in particular
applications, in this case, heavy-haul tractors, and further, have a
means of reliably assessing individualized performance of these
technologies at certification.
The typical tractor is designed in the U.S. with a Gross Combined
Weight Rating (GCWR) of approximately 80,000 pounds due to the
effective weight limit on the federal highway system, except in states
with preexisting higher weight limits. The agencies proposed in Phase 2
to consider tractors with a GCWR over 120,000 pounds as heavy-haul
tractors. Based on comments received during the development of HD Phase
1 (76 FR 57136-57138) and because we did not propose in Phase 2 a sales
limit for heavy-haul as we have for the vocational tractors in Phase 1,
the agencies also believed it would be appropriate to further define
the heavy-haul vehicle characteristics to differentiate these vehicles
from the vehicles in the other nine tractor subcategories. The two
additional requirements in the Phase 2 proposal included a total gear
reduction greater than or equal to 57:1 and a frame Resisting Bending
Moment (RBM) greater than or equal to 2,000,000 in-lbs per rail or rail
and liner combination. Heavy-haul tractors typically require the large
gear reduction to provide the torque necessary to start the vehicle
moving. These vehicles also typically require frame rails with extra
strength to ensure the ability to haul heavy loads. We requested
comment on the proposed heavy-haul tractor specifications, including
whether Gross Vehicle Weight Rating (GVWR) or Gross Axle Weight Rating
(GAWR) would be a more appropriate metric to differentiate between a
heavy-haul tractor and a typical tractor.
We received comments from several manufacturers about the proposed
heavy-haul subcategory. None of the commenters were averse to creating
such a subcategory, and many manufacturers directly supported such an
action. Navistar supported creating a new heavy-haul subcategory
maintaining that this type of vehicle is specified uniquely and is not
designed for standard trailers. Volvo supported this addition since
heavy-haul tractors require large engines and increased cooling
capacity and most heavy-haul rigs have some requirement for off-road
access to pick up machinery, bulk goods, and unusual loads.
We received comments from several manufacturers about the criteria
proposed to define the heavy-haul tractor subcategory. Allison
commented that for heavy-haul tractors equipped with an automatic
transmission, the gear reduction ratio should be greater than or equal
to 24.9:1 because an automatic transmission with a torque converter
provides a torque multiplying effect and better launch capability. EMA
and other manufacturers commented that the proposed specifications for
heavy-haul tractors do not allow the relevant vehicles to meet the
proposed total gear reduction ratio of 57:1 or greater. EMA commented
that the Allison 7-speed 4700 transmission and the Eaton 9LL products
both are specifically designed for heavy-haul operations, could meet a
53:1 specification, but not a 57:1 ratio. PACCAR also commented that an
automatic transmission torque converter ratio should be included in the
Total Reduction ratio calculation to properly incorporate the slip and
first gear ratio combination that is inherent in an automatic
transmission. EMA, PACCAR, and Volvo recommended that the agencies
should change the rear axle ratio for the baseline vehicle to attain
the 53:1 total reduction ratio because the proposed baseline heavy-haul
vehicle did not meet the proposed total reduction ratio. Daimler
commented that the agencies should remove both the frame resistance
bending moment requirement and the gear reduction requirement.
EMA and some of the manufacturers commented that the agencies
should revise the definition of heavy-haul tractor to be ``equal to or
greater than 120,000 pounds GCWR'' rather than ``greater than 120,000
pounds GCWR.'' They stated that the specifications for the heavy-haul
market start with and include 120,000 pounds GCWR. Daimler suggested
that the minimum GCWR be set at 105,000 pounds to better catch the
large number of Canadian vehicles that are heavy-haul. Daimler stated
that this broader weight definition catches a very small number of US
vehicles (0.1 to 0.9 percent of the vehicles, depending on other
factors) but catches the large number of Canadian vehicles that Daimler
considers to be heavy-haul.
Volvo commented that there are multiple types of heavy-haul
tractors, each with their own specific characteristics based on
operational considerations: High-roof highway sleeper tractors pulling
box vans at or above 120,000 pounds GCWR (e.g. long combination
vehicles) that run regional and long-haul operations and can benefit
from the same technologies as high-roof sleepers with 80,000 pound GCWR
and should be credited for the higher payload; low- and mid-roof
sleepers that primarily run long-haul routes (e.g. pulling low-boy
trailers and
[[Page 73582]]
heavy equipment); low-roof day cab tractors running regional and
shorter routes (e.g. bulk haul); and then what the industry typically
refers to as heavy-haul that are extremely high GCWR and can haul above
300 metric tons and sometimes run in multiple tractor configurations
that provide for one or more tractor(s) pulling and one or more
tractor(s) pushing.
In part to follow up on the comments made by manufacturers, EPA
held discussions with Environment and Climate Change Canada (ECCC)
after the NPRM was released regarding the Special Purpose tractors and
heavy-haul tractors.\220\ In our discussions, ECCC emphasized that the
highway weight limitations in Canada are much greater than those in the
U.S. Where the U.S. federal highways have limits of 80,000 pounds GCW,
Canadian provinces have weight limits up to 140,000 pounds. This
difference could potentially limit emission reductions that could be
achieved if ECCC were to fully harmonize with the U.S.'s HD Phase 2
standards because a significant portion of the tractors sold in Canada
have GCWR greater than 120,000 pounds, the proposed limit for heavy-
haul tractors.
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\220\ Memo to Docket. Heavy Class 8 Discussion with Environment
and Climate Change Canada. July 2016. Docket EPA-HQ-OAR-2014-0827.
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For the FRM, EPA and NHTSA are revising the heavy-haul tractor
provisions to balance the certainty that vehicles are regulated in an
appropriate subcategory along with the potential to better harmonize
the U.S. and Canadian regulations. Based on our assessment, the
tractors with GCWR greater than or equal to 120,000 pounds truly
represent heavy-haul applications in the U.S. Therefore, we are
adopting criteria only based on GCWR, not the proposed RBM or total
gear reduction ratios. The agencies are adopting Phase 2 heavy-haul
standards for this subset of vehicles, similar to the standards
proposed for Phase 2 and detailed below in Section III.D.1.
In Canada, due to their differences in weight and dimension
requirements, it is primarily tractors with a GCWR of equal to or
greater than 140,000 pounds that are truly heavy-haul vehicles. This
leaves a set of tractors sold in Canada with a GCWR between 120,000 and
140,000 pounds that are used in ways that are similar to the way
tractors with a GCWR less than 120,000 pounds (the typical Class 8
tractor) are used in the U.S. These tractors sold in Canada could
benefit from the deployment of additional GHG-reducing technologies
beyond what is being required for heavy-haul tractors in the U.S., such
as aerodynamic and idle reduction improvements. Most manufacturers tend
to rely on U.S. certificates as their evidence of conformity for
products sold into Canada to reduce compliance burden. Therefore, in
Phase 2 the agencies are adopting provisions that allow the
manufacturers the option to meet standards that reflect the appropriate
technology improvements, along with the powertrain requirements that go
along with higher GCWR. While these heavy Class 8 tractor standards
will be optional for tractors sold into the U.S. market, we expect that
Canada will consider adopting these as mandatory requirements as part
of their regulatory development and consultation process. Given the
unique circumstances in the Canadian fleet, we believe that there is a
reasonable basis for considering such an approach for Canadian
tractors. As such, the agencies have coordinated these requirements
with ECCC. The agencies are only adopting optional heavy Class 8
standards for MY 2021 at this time. The expectation is that ECCC will
develop their own heavy-duty GHG regulations to harmonize with this
Phase 2 rulemaking through its own domestic regulatory process. We
expect that ECCC will include a mandate that heavy Class 8 tractors be
certified to the MY 2021 heavy Class 8 tractor standards, but could
also specify more stringent standards for later years for these
vehicles. We plan to coordinate with ECCC to incorporate any needed
future changes in a timely manner. Details of these optional standards
are included in Section III.D.1.
(b) Special Purpose Tractors
During the development of Phase 1, the agencies received comments
from several stakeholders supporting an approach for an alternative
treatment of a subset of tractors because they were designed to operate
at lower speeds, in stop and go traffic, and sometimes operate off-road
or at higher weights than the typical line-haul tractor. These types of
applications have limited potential for improvements in aerodynamic
performance to reduce CO2 emissions and fuel consumption.
Therefore, we adopted provisions to allow these special purpose
tractors to certify as vocational vehicles (or vocational tractors).
Consistent with our approach in Phase 1, the agencies still believe
that these vocational tractors are operated differently than line-haul
tractors and therefore fit more appropriately into the vocational
vehicle category. However, we need to continue to ensure that only
tractors that are truly vocational tractors are classified as
such.\221\ As adopted in Phase 1, a Phase 2 vehicle determined by the
manufacturer to be a HHD vocational tractor will fall into one of the
HHD vocational vehicle subcategories and be regulated as a vocational
vehicle. Similarly, MHD tractors which the manufacturer chooses to
reclassify as vocational tractors will be regulated as MHD vocational
vehicles. Specifically, the agencies adopted in Phase 1 provisions in
EPA's 40 CFR 1037.630 and NHTSA's regulation at 49 CFR 523.2 to only
allow the following three types of vocational tractors to be eligible
for reclassification by the manufacturer: Low-roof tractors intended
for intra-city pickup and delivery, such as those that deliver bottled
beverages to retail stores; tractors intended for off-road operation
(including mixed service operation), such as those with reinforced
frames and increased ground clearance; and tractors with a GCWR over
120,000 pounds.\222\
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\221\ As a part of the end of the year compliance process, EPA
and NHTSA verify manufacturer's production reports to avoid any
abuse of the vocational tractor allowance.
\222\ See existing 40 CFR 1037.630 (a)(1)(i) through (iii).
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In the Phase 2 proposal, the agencies proposed to remove the third
type of vocational tractors, heavy-haul tractors with a GCWR over
120,000 pounds, from the Phase 2 Special Purpose Tractor category and
set unique standard for heavy-haul tractors. 80 FR 40214. The agencies
requested comment on the Special Purpose Tractor criteria and received
comments from the manufacturers. EMA and PACCAR commented there is a
group of special purpose tractors with a gross combination weight
rating over 120,000 pounds that fall in between the proposed regulatory
categories for heavy-haul tractors and Class 8 tractors that need to be
accounted for in a separate and distinct manner. They stated that such
vehicles are still appropriately categorized as Special Purpose
Tractors and should be included at the manufacturer's option in the
vocational tractor family, even though they may not meet the proposed
total gear reduction requirement or the frame rail requirements. PACCAR
and Volvo also requested a modification to the definition to include
``equal to 120,000 GCWR.''
Volvo provided a list of recommended Special Purpose Tractor
criteria. Volvo stated that these characteristics differentiate these
vehicles from line haul operation, especially in terms of fuel economy
as well as the significant added costs for these features. Volvo's
[[Page 73583]]
recommended criteria included GCWR greater than 120,000 pounds or any
three of the following vehicles specifications: Configuration other
than 4x2, 6x2, or 6x4; greater than 14,600 pounds front axle load
rating; greater than 46,000 pounds rear axle load rating; greater than
or equal to 3.00:1 overall axle reduction in transmission high range;
greater than 57.00:1 overall axle reduction in transmission low range;
frame rails with a resistance bending moment greater than or equal to
2,000,000 in-lbs., greater than or equal to 20 degree approach angle;
or greater than or equal to 14 inch ground clearance.
The heavy-haul tractor standards that the agencies are adopting in
Phase 2 apply to tractors with a GCWR greater than or equal to 120,000
pounds. As stated above, the agencies are adopting heavy-haul tractor
criteria based only on GCWR, and are not adopting the proposed criteria
of RBM or total gear reduction. With these Phase 2 changes to the
proposed heavy-haul tractor definition, all tractors that would have
been considered as Special Purpose Tractors in Phase 1 due to the GCWR
criteria listed in EPA's 40 CFR 1037.630 and NHTSA's regulation at 49
CFR 523.2 will now qualify as heavy-haul tractors in Phase 2.
Therefore, we no longer believe that it is necessary for heavy-haul
tractors to be treated as Special Purpose Tractors. The agencies also
reviewed Volvo's suggested criteria and concluded that the Phase 1
approach and Special Purpose Tractor criteria are working well;
therefore, we do not see the need to adopt more restrictive criteria.
Consequently, the agencies are adopting in Phase 2 provisions in EPA's
40 CFR 1037.630 and NHTSA's regulation at 49 CFR 523.2 to only allow
the following two types of vocational tractors to be eligible for
reclassification to Special Purpose Tractors 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.
These provisions apply only for purposes of Phase 2. The agencies
are not amending the Phase 1 provisions for special purposes tractors.
Volvo also requested that the agencies add a Vocational Heavy-Haul
Tractor subcategory that allows for a heavy-haul tractor which benefits
from the utilization of a powertrain optimized to meet the vocational
operational requirements of this segment, a technology package
corresponding to those operational characteristics, and with a
corresponding duty cycle and, most importantly, a payload
representative of heavy-haul operation. The agencies considered this
request and analyzed the expected technology package differences
between the vocational and tractor program. As described in Section
III.D.1, the agencies are only adopting technologies in the heavy-haul
tractor category that would be applicable to the operation of these
vehicles. For example, we are not adopting standards that are premised
on any improvements to aerodynamics or extended idle reduction.
Therefore, we concluded that there is no need to develop another
vocational subcategory to account for heavy-haul tractors.
Because the difference between some vocational tractors and line-
haul tractors is potentially somewhat subjective, and because of
concerns about relative stringency, we also adopted in Phase 1 and
proposed to continue in Phase 2 a rolling three year sales limit of
21,000 vocational tractors per manufacturer consistent with past
production volumes of such vehicles to limit the use of this provision.
We proposed in Phase 2 to carry-over the existing three year sales
limit with the recognition that heavy-haul tractors would no longer be
permitted to be treated as vocational vehicles (suggesting a lower
volume cap could be appropriate) but that the heavy-duty market has
improved since the development of the HD Phase 1 rule (suggesting the
need for a higher sales cap). The agencies requested comment on whether
the proposed sales volume limit is set at an appropriate level looking
into the future. 80 FR 40214.
Several of the manufacturers commented that it would be reasonable
to remove the sales cap limit. Allison stated that this limitation may
have been reasonable in the initial years of the program as a
precaution against unreasonably assigning too many tractors to the
vocational vehicle category. However in Phase 2, Allison recommended
that the agencies should remove the cap for three reasons: (1) Vehicle
configurations change over time; (2) the Phase 2 vocational program
drives technology improvements of powertrains; and (3) Phase 2 better
represents the diversity of vocational vehicle uses that would allow
for better alignment of vehicles with duty cycles that most represent
their real world operation. Daimler stated that they think that with
the addition of heavy-haul tractor standards, there will be less need
for a sales volume limit on special purpose tractors. In Volvo Group's
opinion, the proposed volume limit is overly constraining and
burdensome and should be removed. Volvo stated that given the recent
product lineup overhauls across the industry they do not believe that
there are many models still on the market that are sold in large
numbers into both highway tractor and vocational tractor segments, nor
is there sufficient reason that any OEM cannot identify specific
vehicle attributes in order to classify a tractor as suitable solely
for highway use, or for on/off-road use. Volvo Group suggested that the
agencies remove the vocational tractor volume restrictions and employ a
guideline based on specific vehicle characteristics.
The agencies evaluated the sales cap limit proposed for special
purpose tractors and the comments addressing the issue of a sales cap.
EPA calculated the number of vocational tractors certified in MY 2014
and MY 2015. The number of tractors ranged between approximately 2,600
and 6,200 per year per manufacturer that certified special purpose
tractors, but one manufacturer did not use this provision at all.\223\
It is apparent that none of the manufacturers are utilizing this
provision near the maximum allowable level in Phase 1 (a rolling three
year sales limit of 21,000). We also believe that there is more
incentive for manufacturers to use the special purpose tractor
provisions in Phase 1 because the relative difference in stringency
between the tractor and vocational programs is much greater in Phase 1
than it will be in Phase 2. Upon further consideration, we concluded
that there is significantly less incentive for the manufacturers to
reclassify tractors that are not truly special purpose tractors as
vocational vehicles as a pathway to a less stringent standard in Phase
2 primarily since the Phase 2 vocational vehicle program stringency is
similar to the stringency of the tractor program. In addition, the
Phase 2 vocational vehicle compliance program and standards better
represent the duty cycles expected of these vehicles and are predicated
on performance of similar sets of vehicle technologies, except for
aerodynamic technologies, as the primary tractor program. Therefore, we
are adopting Phase 2 special purpose tractor provisions without a sales
cap, but will continue to monitor during the Phase 2 implementation.
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\223\ U.S. EPA. Memo to Docket: Special Purpose Tractor
Production Volumes. Docket EPA-HQ-OAR-2014-0827.
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[[Page 73584]]
(5) Small Tractor Manufacturer Provisions
In Phase 1, EPA determined that manufacturers that met the small
business criteria specified in 13 CFR 121.201 for ``Heavy Duty Truck
Manufacturing'' should not be subject to the initial phase of
greenhouse gas emissions standards in 40 CFR 1037.106.\224\ The
regulations required that qualifying manufacturers notify the
Designated Compliance Officer each model year before introducing the
exempted vehicles into commerce. The manufacturers are also required to
label the vehicles to identify them as excluded vehicles. EPA and NHTSA
proposed to eliminate this small business provision for tractor
manufacturers in the Phase 2 program. As stated in the NPRM, the
agencies are aware of two second stage manufacturers building custom
sleeper cab tractors. In the proposal we stated that we could treat
these vehicles in one of two ways. First, the vehicles may be
considered as dromedary vehicles and therefore treated as vocational
vehicles.\225\ Or the agencies could provide provisions that stated if
a manufacturer changed the cab, but not the frontal area of the
vehicle, then it could retain the aerodynamic bin of the original
tractor. 80 FR 40214.
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\224\ See 40 CFR 1037.150(c).
\225\ A dromedary is a box, deck, or plate mounted behind the
tractor cab and forward of the fifth wheel on the frame of the power
unit of a tractor-trailer combination to carry freight.
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The agencies received comments on the second stage manufacturer
options for small manufacturers discussed in the proposal. American
Reliance Industries (ARI) raised concerns related to the proposed
alternative methods for excluding or exempting second stage
manufacturers performing cab sleeper modifications. ARI is concerned
that treating these vehicles as vocational vehicles may mean that other
regulations related to vocational vehicles would become applicable and
have unanticipated adverse results and that the vehicles would not be
certified as vocational vehicles when originally certified by an OEM.
ARI commented that if EPA and NHTSA adopt a frontal area approach for
second stage manufacturers making cab sleeper modifications, that the
section be revised to ensure greater clarity as to the intention and
effect of this section. In building a custom sleeper cab, ARI stated
that they may use wind fairings, fuel tank fairings, roof fairings, and
side extenders that can modify the frontal area of the tractor in
height and width as compared to the frontal area of the vehicle used to
obtain the original certification. ARI also commented that depending on
the custom cab sleeper modification, ARI may replace an aerodynamic
fairing from the tractor in order to provide better aerodynamic results
in light of the cab sleeper modification. ARI does not want to be
precluded from continuing to provide these benefits to clients. ARI
encourages the agencies to take a similar approach to small business
exemption under the Phase 1 regulation in the Phase 2 regulation.
Daimler commented on the agencies' two proposed approaches for
second stage manufacturers that build custom sleepers. Daimler's main
concern is to clarify that where the primary manufacturer has certified
a vehicle as a day cab, the second stage manufacturer's actions do not
draw the primary manufacturer into noncompliance. Daimler stated that
in many cases, they do not know that a vehicle will be altered by a
second stage manufacturer. Daimler did not have a preference on the way
that the agencies proposed to regulate these secondary vehicle
manufacturers, as long as the primary vehicle manufacturers could
continue to sell vehicles with the expectation that anyone changing
them from the compliant state in which it was built would certify those
changes.
In response to these comments, EPA is clarifying in 40 CFR 1037.622
that small businesses may modify tractors as long as they do not modify
the front of the vehicle and so long as the sleeper compartment is no
more than 102 inches wide or 162 inches in height. As an interim
provision, to allow for a better transition to Phase 2, EPA is
finalizing a more flexible compliance path in 40 CFR 1037.150(r). This
option allows small manufacturers to convert a low or mid roof tractor
to a high roof configuration without recertification, provided it is
for the purpose of building a custom sleeper tractor or for conversion
to a natural gas tractor. Although this more flexible allowance to
convert low and mid roof tractors to high roof tractors is being
adopted as an interim provision, we have not established an end date at
this time. We expect to reevaluate as manufacturers begin to make use
of and may decide to revise it in the future, potentially deciding to
make it a permanent allowance. To be eligible for this option, the
secondary manufacturer must be a small manufacturer and the original
low or mid roof tractor must be covered by a valid certificate of
conformity. The modifications may not increase the frontal area of the
tractor beyond the frontal area of the equivalent high roof tractor
paired with a standard box van. With respect to Daimler's comment, 40
CFR 1037.130 only applies to vehicles sold in an uncertified condition
and does not apply to vehicles sold in a certified condition.
(6) Glider Vehicles
As described in Section XIII.B, EPA is adopting new provisions
related to glider vehicles, including glider tractors.\226\ NHTSA did
not propose such changes. Glider vehicles and glider kits were also
treated differently under NHTSA and EPA regulations prior to this
rulemaking. They are exempt from NHTSA's Phase 1 fuel consumption
standards. For EPA purposes, the CO2 provisions of Phase 1
exempted glider vehicles and glider kits produced by small businesses
but did not include such a blanket exemption for other glider kits.
Thus, some gliders and glider kits are already subject to the Phase 1
requirement to obtain a vehicle certificate prior to introduction into
commerce as a new vehicle. 80 FR 40528.
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\226\ See section I.E. 1 for descriptions of glider vehicles and
glider kits.
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In the NPRM, EPA proposed to revise the provisions applicable to
glider vehicles so that the engines used in these vehicles would need
to meet the standards for the year of the new glider vehicle. EPA's
resolution of issues relating to glider vehicles, including glider
tractors, and glider kits, is discussed fully in Section XIII.B and RTC
Section 14.2.
Similarly, NHTSA considered including glider vehicles under its
Phase 2 program. After assessing the impact glider vehicles have on the
tractor segment, NHTSA has elected not to include glider vehicles in
its Phase 2 program. NHTSA may reconsider fuel efficiency regulations
for glider vehicles in a future rulemaking.
As discussed in the NPRM, NHTSA would like to reiterate its safety
authority over gliders--notably, that it has become increasingly aware
of potential noncompliance with its regulations applicable to gliders.
While there are instances in which NHTSA regulations allow gliders to
use a ``donor VIN'' from a ``donor tractor,'' NHTSA has learned of
manufacturers that are creating glider vehicles that are new vehicles
under 49 CFR 571.7(e); however, the manufacturers are not certifying
them and obtaining a new VIN as required. NHTSA plans to pursue
enforcement actions as applicable against noncompliant manufacturers.
In addition to enforcement actions, NHTSA may
[[Page 73585]]
consider amending 49 CFR 571.7(e) and related regulations as necessary.
NHTSA believes manufacturers may not be using this regulation as
originally intended.
We believe that the agencies having different policies for glider
kits and glider vehicles under the Phase 2 program will not result in
problematic disharmony between the NHTSA and EPA programs, because of
the small number of vehicles that will be involved. EPA believes that
its changes will result in the glider market returning to the pre-2007
levels, in which fewer than 1,000 glider vehicles will be produced in
most years. Only non-exempt glider vehicles will be subject to
different requirements under the NHTSA and EPA regulations. However, we
believe that this is unlikely to exceed a few hundred vehicles in any
year, which will be few enough not to result in any meaningful
disharmony between the two agencies.
(7) Useful Life and Deterioration Factors
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 Phase 2 standards that EPA is adopting will apply
to individual vehicles and engines, just as EPA adopted for Phase 1.
NHTSA is also adopting the same useful life mileage and years as EPA
for Phase 2.
EPA is also not adopting any changes to the existing provisions
that require that the useful life for tractors with respect to
CO2 emissions be equal to the respective useful life periods
for criteria pollutants, as shown below in Table III-5. See 40 CFR
1037.106(e). EPA does not expect degradation of the technologies
evaluated for Phase 2 in terms of CO2 emissions, therefore
we did not adopt any changes to the regulations describing compliance
with GHG pollutants with regards to deterioration. See 40 CFR 1037.241.
Table III-5--Tractor Useful Life Periods
------------------------------------------------------------------------
Years Miles
------------------------------------------------------------------------
Class 7 Tractors.................................... 10 185,000
Class 8 Tractors.................................... 10 435,000
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D. Feasibility of the Final Phase 2 Tractor Standards
This section describes the agencies' technical feasibility and cost
analysis. Further detail on all of these technologies can be found in
the RIA Chapter 2.
Class 7 and 8 tractors are used in combination with trailers to
transport freight. The variation in the design of these tractors and
their typical uses drive different technology solutions for each
regulatory subcategory. As noted above, the agencies are continuing the
Phase 1 provisions that treat vocational tractors as vocational
vehicles instead of as combination tractors, as noted in Section
III.C.4. The focus of this section is on the feasibility of final
standards for combination tractors including the heavy-haul tractors,
but not the vocational tractors.
EPA and NHTSA collected information on the cost and effectiveness
of fuel consumption and CO2 emission reducing technologies
from several sources, including new information collected since the
NPRM was promulgated. The primary sources of pre-proposal information
were the Southwest Research Institute evaluation of heavy-duty vehicle
fuel efficiency and costs for NHTSA,\227\ the Department of Energy's
SuperTruck Program,\228\ 2010 National Academy of Sciences report of
Technologies and Approaches to Reducing the Fuel Consumption of Medium-
and Heavy-Duty Vehicles,\229\ TIAX's assessment of technologies to
support the NAS panel report,\230\ 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),\231\ and the technology cost analysis
conducted by ICF for EPA.\232\ Some additional information and data
were also provided in comments.
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\227\ Reinhart, T.E. (June 2015). Commercial Medium- and Heavy-
Duty Truck Fuel Efficiency Technology Study--Report #1. (Report No.
DOT HS 812 146). Washington, DC: National Highway Traffic Safety
Administration.
\228\ U.S. Department of Energy. SuperTruck Initiative.
Information available at http://energy.gov/eere/vehicles/vehicle-technologies-office.
\229\ 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 2010 NAS
Report'') Washington, DC, The National Academies Press.
\230\ TIAX, LLC. ``Assessment of Fuel Economy Technologies for
Medium- and Heavy-Duty Vehicles,'' Final Report to National Academy
of Sciences, November 19, 2009.
\231\ NESCCAF, ICCT, Southwest Research Institute, and TIAX.
Reducing Heavy-Duty Long Haul Combination Truck Fuel Consumption and
CO2 Emissions. October 2009.
\232\ 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.
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Commenters generally supported the agencies' projection that
manufacturers can reduce CO2 emissions and fuel consumption
of combination tractors through use of many technologies, including
engine, drivetrain, aerodynamic, tire, extended idle, and weight
reduction technologies. The agencies' determination of the feasibility
of the final HD Phase 2 standards is based on our updated projection of
the use of these technologies and an updated assessment of their
effectiveness. 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 rule, for various reasons discussed below.
(1) Projected Technology Effectiveness and Cost
EPA and NHTSA project that CO2 emissions and fuel
consumption reductions can be feasibly and cost-effectively met through
technological improvements in several areas. The agencies evaluated
each technology and estimated the most appropriate adoption rate of
technology into each tractor subcategory. The next sections describe
the baseline vehicle configuration, the effectiveness of the individual
technologies, the costs of the technologies, the projected adoption
rates of the technologies into the regulatory subcategories, and
finally the derivation of these standards.
Based on information available at the time of the NPRM, the
agencies proposed Phase 2 standards that projected by 2027, all high-
roof tractors would have aerodynamic performance equal to or better
today's SmartWay performance--which represents the best of today's
technology. This would equate to having 40 percent of new high roof
sleeper cabs in 2027 complying with the current best practices and 60
percent of the new high-roof sleeper cab tractors sold in 2027 having
better aerodynamic performance than the best tractors available today.
For tire rolling resistance, we premised the proposed standards on the
assumption that nearly all tires in 2027 would have rolling resistance
equal to or superior to tires meeting today's SmartWay designation. At
proposal, the agencies assumed the 2027 MY engines would achieve an
additional 4 percent improvement over Phase 1 engines and we projected
15 percent adoption of waste heat recovery (WHR) and many other
advanced engine technologies. In addition, we proposed standards that
projected improvements to nearly all of today's transmissions,
incorporation of extended idle reduction technologies on 90 percent of
sleeper cabs, and significant adoption of
[[Page 73586]]
other types of technologies such as predictive cruise control and
automatic tire inflation systems.
The agencies also discussed several other alternatives in the
proposal. When considering alternatives, it is necessary to evaluate
the impact of a regulation in terms of CO2 emission
reductions, fuel consumption reductions, and technology costs. However,
it is also necessary to consider other aspects, such as manufacturers'
research and development resources, the impact on purchase price, and
the impact on purchasers. Manufacturers are limited in their ability to
develop and implement new technologies due to their human resources and
budget constraints. This has a direct impact on the amount of lead time
that is required to meet any new standards. From the owner/operator
perspective, heavy-duty vehicles are a capital investment for firms and
individuals so large increases in the upfront cost could impact buying
patterns. Though the dollar value of the lifetime fuel savings will far
exceed the upfront technology costs, purchasers often discount future
fuel savings for a number of reasons, as discussed in more detail in
Section IX.A. Tractor purchasers are often uncertain regarding the
amount of fuel savings that can be expected for their specific
operation due to the diversity of the heavy-duty tractor market.
Although a nationwide perspective that averages out this uncertainty is
appropriate for rulemaking analysis, individual operators must consider
their potentially narrow operation. In addition, purchasers often put a
premium on reliability (because downtime is costly in terms of towing,
repair, late deliveries, and lost revenue) and may perceive any new
technology as a potential risk with respect to reliability. Another
factor that purchasers consider is the impact of a new technology on
the resale market, which can also be impacted by uncertainty.
The agencies solicited comment on all of these issues and again
noted the possibility of adopting, in a final action, standards that
are more accelerated than those in Alternative 3, notably what we
termed at proposal, Alternative 4 which would have involved a three
year pull ahead of the proposed 2027 standards. 80 FR 40211. The
agencies also assumed in the NPRM that both the proposed standards and
Alternative 4 could be accomplished with all changes being made during
manufacturers' normal product design cycles. However, we noted that
doing so would be more challenging for Alternative 4 and may require
accelerated research and development outside of design cycles with
attendant increased costs. Commenters were encouraged in the NPRM to
address all aspects of feasibility analysis, including costs, the
likelihood of developing the technology to achieve sufficient
relaibility within the lead time, and the extent to which the market
could utilize the technology.
The agencies received several general comments on the overall
stringency of the proposed Phase 2 standards. Several entities
encouraged the agencies to adopt more stringent tractor standards,
including adoption of Alternative 4. They pointed out that DOE's
SuperTruck program demonstrated over 40 percent improvement over 2010
levels, including 10.7 mpg by Cummins-Peterbuilt and 12.2 mpg by
Daimler. CBD stated that the technology forcing nature of Clean Air Act
section 202(a)(2) \233\ and EPCA/EISA requires more aggressive
assumptions regarding technology adoption. UCS commented that the
tractor standards could be strengthened by another six percent in 2024
and seven percent in 2027 to reflect the full range of improvements to
the powertrain and engine. ICCT stated that its analysis indicates that
the technology potential is higher and costs are lower than the
agencies' assessments in the NPRM. CARB stated that Alternative 4 is
technologically feasible and will result in more emission and fuel
consumption reductions. CARB continued to state that the increased cost
due to accelerated implementation is minimal, about $1,000 per vehicle
purportedly according to the NPRM.
---------------------------------------------------------------------------
\233\ CBD is mistaken that section 202(a)(2) mandates
technology-forcing standards, although it allows them. See generally
74 FR 49464-465 (Sept. 28, 2009).
---------------------------------------------------------------------------
In contrast to the commenters that called for more stringent
standards than those proposed, several other commenters cautioned the
agencies from adopting final standards that are more stringent than
those proposed. Diesel Technology Forum commented that the agencies
should proceed with caution on technologies that are not in wide use
that have not demonstrated reliability or commercial availability. The
International Foodservice Distributors Association is concerned about
Alternative 4 in terms of reliability, commenting that it would require
their members to purchase unproven and unreliable equipment in order
for OEMs to meet the requirements. OOIDA commented if owners fear a
reduction in reliability, increased operating costs, reduced residual
value, or large increases in purchase prices, they will adjust their
purchase plans.
PACCAR commented about the importance of lead time because their
customers need time to determine if a technology meets their specific
needs in their specific application and need assurance that a
technology will be reliable in use. PACCAR also stated that the timing
provided in the NPRM Alternative 3 provides the ``greatest likelihood
for a successful program.'' Volvo commented that SuperTruck
demonstration vehicles serve only the purpose of demonstration but are
not proven with respect to cost, reliability, and durability. Volvo
stated that the purpose of SuperTruck was narrow in applicability of
matched tractor-trailers and that it did not result in a cost effective
tractor because each project cost between $40 and $80 million to
produce a single vehicle. Volvo also commented that not all SuperTruck
technologies should be forced into all applications and duty cycles and
if they are a pre-buy (or no-buy) could result.
The agencies considered all of the general comments associated with
the proposed Alternative 3 and Alternative 4 tractor standards. We
believe there is merit in many of the detailed comments received
regarding technologies. These are discussed in detail in the following
sections. Instead of merely choosing from among the proposed
alternatives, the agencies have developed a set of final tractor
standards that reflect our reevaluation of the ability to pull ahead
certain technologies, the limitations in adoption rates and/or
effectiveness of other technologies, and consideration of additional
technologies. In general, the final Phase 2 tractor standards are
similar in overall stringency as the levels proposed in Alternative 3,
but have been determined using new technology packages that reflect
consideration of all of the technology comments, and in some respects
reflect greater stringency than the proposed Alternative 3.
As can be seen from the comments, there is uncertainty and a wide
range of opinions regarding the extent to which these technologies can
be applied to heavy-duty tractors. Vehicle manufacturers tended to take
the conservative position for each technology and argue that the
agencies should not project effectiveness or adoption rates beyond that
which is certain. Many other commenters took a more optimistic view and
argued for the agencies to assume that each potential technology will
be highly effective in most applications. However the agencies believe
the most likely outcome will be that some technologies
[[Page 73587]]
will work out better than expected while others will be slightly more
challenging than projected. Thus, the agencies have tended to make
balanced projections for the various technologies, although some may be
slightly optimistic while others are somewhat conservative. We believe
the overall effect of this approach will be standards that achieve
large reductions with minimal risks to the industry.
(a) Tractor Baselines for Costs and Effectiveness
The fuel efficiency and CO2 emissions of combination
tractors vary depending on the configuration of the tractor. Many
aspects of the tractor impact its performance, including the engine,
transmission, drive axle, aerodynamics, and rolling resistance. For
each subcategory, the agencies selected a theoretical tractor to
represent the average 2017 model year tractor that meets the Phase 1
standards (see 76 FR 57212, September 15, 2011). These tractors are
used as baselines from which to evaluate costs and effectiveness of
additional technologies and standards.
As noted earlier, the Phase 1 2017 model year tractor standards
(based on Phase 1 GEM and test procedures) and the baseline 2017 model
year tractor results (using Phase 2 GEM and test procedures) are not
directly comparable. The same set of aerodynamic and tire rolling
resistance technologies were used in both setting the Phase 1 standards
and determining the baseline of the Phase 2 tractors. However, there
are several aspects that differ. First, a new version of GEM was
developed and validated to provide additional capabilities, including
more refined modeling of transmissions and engines. Second, the
determination of the HD Phase 2 CdA value takes into account
a revised test procedure, a new standard reference trailer, and wind
averaged drag as discussed below in Section III.E. In addition, the HD
Phase 2 version of GEM includes road grade in the 55 mph and 65 mph
highway cycles, as discussed below in Section III.E.
The agencies used the same adoption rates of tire rolling
resistance for the Phase 2 baseline as we used to set the Phase 1 2017
MY standards. See 76 FR 57211. The tire rolling resistance level
assumed to meet the 2017 MY Phase 1 standard high roof sleeper cab is
considered to be a weighted average of 10 percent pre-Phase 1 baseline
rolling resistance, 70 percent Level 1, and 20 percent Level 2. The
tire rolling resistance to meet the 2017MY Phase 1 standards for the
high roof day cab, low roof sleeper cab, and mid roof sleeper cab
includes 30 percent pre-Phase 1 baseline level, 60 percent Level 1 and
10 percent Level 2. Finally, the low and mid roof day cab 2017 MY
standards were premised on a weighted average rolling resistance
consisting of 40 percent baseline, 50 percent Level 1, and 10 percent
Level 2. The agencies did not receive comments on the tire packages
used to develop the Phase 2 baseline in the NPRM.
The agencies sought comment on the baseline vehicle attributes
described in the NPRM. The agencies received comments related to the
baseline adoption rate of automatic engine shutdown systems (AESS) and
the baseline aerodynamics assessment. In the proposal, the agencies
noted that the manufacturers were not using tamper-proof AESS to comply
with the Phase 1 standards so the agencies reverted back to the
baseline APU adoption rate of 30 percent used in the Phase 1 baseline.
EMA and TRALA commented that the agencies confused the use of an APU
with the use of tamper-proof idle technologies in assessing the
baseline for the proposed Phase 2 standards. They stated that a 30
percent penetration rate of APUs is not the same as a 30 percent
penetration rate of tamper-proof idle systems. ATA and Volvo also
commented that the assumption that 30 percent of 2017 sleeper tractors
will utilize the tamper-proof automatic engine shutdown is too high.
EMA and PACCAR commented that virtually all tractors in the field have
an automatic shutdown programmed in their engine; however, less than
one percent of vehicles sold in recent years have tamper-proof AESS
that are triggered in less than five minutes and cannot be reprogrammed
for 1.259 million miles. In response to these comments, the agencies
reassessed the baseline idle reduction adoption rates. The latest NACFE
confidence report found that 9 percent of tractors had auxiliary power
units and 96 percent of vehicles are equipped with adjustable automatic
engine shutdown systems.\234\ Therefore, the agencies are projecting
that 9 percent of sleeper cabs will contain an adjustable AESS and APU,
while the other 87 percent will only have an adjustable AESS.
Additional discussion on adjustable AESS is included in Section
III.D.1.b.
---------------------------------------------------------------------------
\234\ North American Council for Freight Efficiency. Confidence
Report:Idle Reduction Solutions. 2014. Page 13.
---------------------------------------------------------------------------
The Phase 2 baseline in the NPRM was determined based on the
aerodynamic bin adoption rates used to determine the Phase 1 MY 2017
tractor standards. Volvo, EMA, and other manufacturers also commented
that the aerodynamic drag baseline for 2017 tractors included in the
NPRM was too aerodynamically efficient. EMA commented that some of the
best aerodynamic tractors available were tested by the agencies and
then declared to be the baseline. According to the manufacturers, the
average tractor--the true baseline--is a full bin worse than these best
tractors. While the agencies agree with the commenters that it is
important to develop an accurate baseline so that the appropriate
aerodynamic technology package effectiveness and costs can be evaluated
in determining the final Phase 2 standards, there appears to be some
confusion regarding the NPRM baseline aerodynamic assessment. The Phase
2 baseline in the NPRM was determined based on the aerodynamic bin
adoption rates used to determine the Phase 1 MY 2017 tractor standards
(see 76 FR 57211). The baseline was not determined by or declared to be
the average results of the vehicles tested, as some commenters
maintained. The vehicles that were tested prior to the NPRM were used
to develop the proposed aerodynamic bin structure for Phase 2. In both
the NPRM and this final rulemaking, we developed the Phase 2 bins such
that there is an alignment between the Phase 1 and Phase 2 aerodynamic
bins after taking into consideration the changes in aerodynamic test
procedures and reference trailers required in Phase 2. The Phase 2 bins
were developed so that tractors that performed as a Bin III in Phase 1
would also perform as Bin III tractors in Phase 2. Additional details
regarding how the agencies refined the aerodynamic bin values for Phase
2 for the final rule can be found in Section III.E.2.a. The baseline
aerodynamic value for the Phase 2 final rulemaking was determined in
the same manner as the NPRM, using the adoption rates of the bins used
to determine the Phase 1 standards, but reflect the final Phase 2 bin
CdA values.
In the NPRM, we used a transmission top gear ratio of 0.73 and
drive axle ratio of 3.70 in the baseline 2017 MY tractor. UCS commented
that the baseline axle ratio is too high. The agencies determined the
rear axle ratio and final drive ratio in the baseline tractor based on
axle market information shared by Meritor,\235\ one of the primary
suppliers of heavy-duty axles, and confidential business information
provided by Daimler. Our assessment of this information found that a
rear axle ratio
[[Page 73588]]
of 3.70 and a top gear ratio of 0.73 (equivalent to a final drive ratio
of 2.70) is a commonly spec'd tractor. Meritor's white paper on
downspeeding stated that final drive ratios of less than 2.64 are
considered to be ``downsped.'' \236\ The agencies recognize that there
is a significant range in final drive ratios that will be utilized by
tractors built in 2017 MY, we do not believe that the average (i.e.,
baseline) tractor in 2017 MY will downsped (i.e., have a final drive
ratio of less than 2.64). Therefore, the agencies are maintaining the
proposed top gear ratio and drive axle ratio for the assessment of the
baseline tractor performance.
---------------------------------------------------------------------------
\235\ NACFE. Confidence Report: Programmable Engine Parameters.
February 2015. Page 23.
\236\ Ostrander, Robert, et.al. (Meritor). Understanding the
Effects of Engine Downspeeding on Drivetrain Components. 2014. Page
2.
---------------------------------------------------------------------------
The agencies are using the specific attributes of each tractor
subcategory as are listed below in Table III-6 for the Phase 2
baselines. Using these values, the agencies assessed the CO2
emissions and fuel consumption performance of the baseline tractors
using the Phase 2 GEM. The results of these simulations are shown below
in Table III-7.
Table III-6--GEM Inputs for the Baseline Class 7 and 8 Tractor
--------------------------------------------------------------------------------------------------------------------------------------------------------
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
--------------------------------------------------------------------------------------------------------------------------------------------------------
Engine
--------------------------------------------------------------------------------------------------------------------------------------------------------
2017 MY 11L 2017 MY 11L 2017 MY 11L 2017 MY 15L 2017 MY 15L 2017 MY 15L 2017 MY 15L 2017 MY 15L 2017 MY 15L
Engine 350 Engine 350 HP Engine 350 Engine 455 Engine 455 Engine 455 Engine 455 Engine 455 Engine 455
HP HP HP HP HP HP HP HP
--------------------------------------------------------------------------------------------------------------------------------------------------------
Aerodynamics (CdA in m2)
--------------------------------------------------------------------------------------------------------------------------------------------------------
5.41 6.48 6.38 5.41 6.48 6.38 5.41 6.48 5.90
--------------------------------------------------------------------------------------------------------------------------------------------------------
Steer Tires (CRR in kg/metric ton)
--------------------------------------------------------------------------------------------------------------------------------------------------------
6.99 6.99 6.87 6.99 6.99 6.87 6.87 6.87 6.54
--------------------------------------------------------------------------------------------------------------------------------------------------------
Drive Tires (CRR in kg/metric ton)
--------------------------------------------------------------------------------------------------------------------------------------------------------
7.38 7.38 7.26 7.38 7.38 7.26 7.26 7.26 6.92
--------------------------------------------------------------------------------------------------------------------------------------------------------
Extended Idle Reduction--Adjustable AESS with no Idle Red Tech Adoption Rate @1% Effectiveness
--------------------------------------------------------------------------------------------------------------------------------------------------------
N/A N/A N/A N/A N/A N/A 87% 87% 87%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Extended Idle Reduction--Adjustable AESS with Diesel APU Adoption Rate @3% Effectiveness
--------------------------------------------------------------------------------------------------------------------------------------------------------
N/A N/A N/A N/A N/A N/A 9% 9% 9%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Transmission = 10 Speed Manual Transmission
Gear Ratios = 12.8, 9.25, 6.76, 4.90, 3.58, 2.61, 1.89, 1.38, 1.00, 0.73
--------------------------------------------------------------------------------------------------------------------------------------------------------
Drive Axle Configuration = 4 x 2 Drive Axle Configuration = 6 x 4
--------------------------------------------------------------------------------------------------------------------------------------------------------
Tire Revs/Mile = 512
--------------------------------------------------------------------------------------------------------------------------------------------------------
Drive Axle Ratio = 3.70
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table III-7--Class 7 and 8 Tractor Baseline CO[ihel2] 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
--------------------------------------------------------------------------------------------------------------------------------------------------------
CO[ihel2] (grams CO[ihel2]/ton-mile)................. 119.1 127.2 129.7 91.3 96.6 98.2 84.0 90.2 87.8
Fuel Consumption (gal/1,000 ton-mile)................ 11.69941 12.49509 12.74067 8.96857 9.48919 9.64637 8.25147 8.86051 8.62475
--------------------------------------------------------------------------------------------------------------------------------------------------------
The agencies also received comments related to the baseline heavy-
haul tractor parameters. Volvo did not agree that certain segments of
the heavy-haul population are appropriately represented by the baseline
in the NPRM. Volvo stated that these types of vehicles typically
utilize an 18-speed transmission, since they require the very close
gear ratios and nearly all heavy-haul tractors have deeper drive axle
ratios than the agencies have assumed
[[Page 73589]]
(3.55). PACCAR commented the 14.4 first gear of the 18-speed
transmission coupled with the 3.73 rear axle ratio is an example of a
significant sales volume combination that meets their recommended 53:1
Total Reduction ratio. Upon further consideration, the agencies find
the suggestion that the baseline heavy-haul tractor is better
represented by an 18-speed manual transmission to be persuasive. We
therefore revised the baseline heavy-haul tractor configuration, as
shown in Table III-8.
The baseline 2017 MY heavy-haul tractor will emit 56.9 grams of
CO2 per ton-mile and consume 5.59 gallons of fuel per 1,000
ton-mile.
Table III-8--Heavy-Haul Tractor Baseline Configuration
------------------------------------------------------------------------
Baseline heavy-haul tractor configuration
-------------------------------------------------------------------------
Engine = 2017 MY 15L Engine with 600 HP.
------------------------------------------------------------------------
Aerodynamics (CdA in m\2\) = 5.00.
------------------------------------------------------------------------
Steer Tires (CRR in kg/metric ton) = 7.0.
------------------------------------------------------------------------
Drive Tires (CRR in kg/metric ton) = 7.4.
------------------------------------------------------------------------
Transmission = 18 speed Manual Transmission
Gear ratio = 14.4, 12.29, 8.51, 7.26, 6.05, 5.16, 4.38, 3.74, 3.2, 2.73,
2.28, 1.94, 1.62, 1.38, 1.17, 1.00, 0.86, 0.73.
------------------------------------------------------------------------
Drive axle Ratio = 3.73.
------------------------------------------------------------------------
All Technology Improvement Factors = 0%.
------------------------------------------------------------------------
The fuel consumption and CO2 emissions in this ``flat''
baseline described above remains the same over time with no assumed
improvements after 2017, absent a Phase 2 regulation. An alternative
baseline was also evaluated by the agencies in which there is a
continuing uptake of technologies in the tractor market that reduce
fuel consumption and CO2 emissions absent a Phase 2
regulation. This alternative baseline, referred to as the ``dynamic''
baseline, was developed to estimate the potential effect of market
pressures and non-regulatory government initiatives to improve tractor
fuel consumption. The dynamic baseline assumes that the significant
level of research funded and conducted by the Federal government,
industry, academia and other organizations will, in the future, result
in the adoption of some technologies beyond the levels required to
comply with Phase 1 standards. One example of such research is the
Department of Energy Super Truck program \237\ which has a goal of
demonstrating cost-effective measures to improve the efficiency of
Class 8 long-haul freight trucks by 50 percent by 2015. The dynamic
baseline also assumes that manufacturers will not cease offering fuel
efficiency improving technologies that currently have significant
market penetration, such as automated manual transmissions. The
baselines (one for each of the nine tractor types) are characterized by
fuel consumption and CO2 emissions that gradually decrease
between 2019 and 2028. In 2028, the fuel consumption for the
alternative tractor baselines is approximately 4.0 percent lower than
those shown in Table III-7. This results from the assumed introduction
of aerodynamic technologies such as down exhaust, underbody airflow
treatment in addition to tires with lower rolling resistance. The
assumed introduction of these technologies reduces the CdA
of the baseline tractors and CRR of the tractor tires. To take one
example, the CdA for baseline high roof sleeper cabs in
Table III-6 is 5.90 m\2\ in 2017. In 2028, the CdA of a high
roof sleeper cab would be assumed to still be 5.90 m\2\ in the flat
baseline case outlined above. Alternatively, in the dynamic baseline,
the CdA for high roof sleeper cabs is 5.61 m\2\ in 2028 due
to assumed market penetration of technologies absent the Phase 2
regulation. The dynamic baseline analysis is discussed in more detail
in RIA Chapter 11.
---------------------------------------------------------------------------
\237\ U.S. Department of Energy. See SuperTruck Report to
Congress. http://energy.gov/eere/vehicles/downloads/vehicle-technologies-office-report-adoption-new-fuel-efficient-technologies.
---------------------------------------------------------------------------
(b) Tractor Technology Effectiveness
The agencies' assessment of the technology effectiveness was
developed through the use of the GEM in coordination with modeling
conducted by Southwest Research Institute. The agencies developed these
standards through a three-step process, similar to the approach used in
Phase 1. First, the agencies developed estimates of technology
performance characteristics and effectiveness in terms of reducing
CO2 emissions and fuel consumption for each technology, as
described below. Each technology is associated with an input parameter
which in turn is used as an input to the Phase 2 GEM simulation tool.
There are two types of GEM input parameters. The first type requires a
manufacturer to measure aspects of the technology. These aspects are
used as inputs to GEM which then models the technology's effectiveness
(i.e. the effectiveness for that technology is the GEM output).
Aerodynamics, tire rolling resistance, engine fuel maps, axle ratio,
the optional axle efficiency, and optional transmission efficiencies
are examples of this first type of GEM input. The second type of GEM
input only requires a manufacturer to install the technology onto the
vehicle and does not require any testing to determine the GEM input.
The agencies determined and specify in the regulations (see 40 CFR
1037.520) the effectiveness of this second type of GEM input. The
agencies also define the technologies that qualify to be eligible for
these GEM technology inputs in the regulations (see 40 CFR 1037.660 and
1037.801). Examples of these technology inputs include transmission
type, idle reduction technologies, tire pressure systems, vehicle speed
limiters, weight reduction, intelligent controls, and other
accessories. The performance levels for the range of Class 7 and 8
tractor aerodynamic packages and vehicle technologies are described
below in Table III-10.\238\ All percentage improvements noted below are
relative to the 2017 MY baseline tractor.
---------------------------------------------------------------------------
\238\ These GEM default values could be superseded on a case-by-
case basis based on an appropriate off-cycle credit demonstration.
---------------------------------------------------------------------------
As discussed in Section I.C.1.a, we assume manufacturers will
incorporate appropriate compliance margins for all measured GEM inputs.
In other words, they will declare values slightly higher than their
measured values. As discussed in Section II.D.5, compliance margins
associated with fuel maps are likely to be approximately one percent.
For aerodynamic inputs, we believe the bin structure will eliminate the
need for CdA compliance margins for most vehicles. However,
for vehicles with measured CdA values very near the upper
bin boundary, manufacturers will likely choose to certify some of them
to the next higher bin values (as a number of commenters noted). For
tire rolling resistance, our feasibility rests on the Phase 1
standards, consistent with our expectation that manufacturers will to
continue to incorporate the compliance margins they considered
necessary for Phase 1. With respect to optional axle and/or
transmission power loss maps, we believe manufacturers will need very
small compliance margins. These power loss procedures require high
precision so measurement uncertainty will likely be on the order of 0.1
percent of the transmitted power. All of these margins are reflected in
our projections of the emission levels that will be technologically
feasible.
The agencies then determined the adoption rates feasible for each
[[Page 73590]]
technology in each model year, as described in Section III.D.1.c. Then
as described in Section III.D.1.f, the agencies combined the technology
performance levels with a projected technology adoption rate to
determine the GEM inputs used to set the stringency of these standards.
The agencies input these parameters into Phase 2 GEM and used the
output to determine the final CO2 emissions and fuel
consumption levels.
(i) Engine Improvements
There are several technologies that could be used to improve the
efficiency of diesel engines used in tractors. These technologies
include friction reduction, combustion system optimization, and waste
heat recovery using the Rankine cycle. Details of the engine
technologies, adoption rates, and overall fuel consumption and
CO2 emission reductions are included in Section II.D. The
Phase 2 engine standards will lead each manufacturer to achieve
reductions of 1.8 percent in 2021 MY, 4.2 percent in 2024 MY, and 5.1
percent in 2027 MY. For the final Phase 2 rule, we recognize that it
could be possible to achieve greater reductions than those included in
the engine standard by designing entirely new engine platforms. See
Section II.D.2.e. Unlike existing platforms, which are limited with
respect to peak cylinder pressures (precluding certain efficiency
improvements), new platforms can be designed to have higher cylinder
pressure than today's engines. New designs are also better able to
incorporate recent improvements in materials and manufacturing, as well
as other technological developments. Considered together, it is likely
that a new engine platform could be about 2 percent better than engines
using older platforms. Moreover, the agencies have seen CBI data that
suggests improvement of more than 3 percent are possible. As discussed
in Section II.D.2.e above, how far the various manufacturers are into
their design cycles suggests that one or more manufacturers will
probably introduce a new engine platform during the Phase 2 time frame.
Thus, we project that 50 percent of tractor engines produced in 2027 MY
will be redesigned engines (i.e. engines reflecting redesigned engine
platforms, again based on existing engine platform redesign schedules
within the industry). This means the average 2027 MY tractor engine
would be 5.4 and 6.4 percent better than Phase 1 for day and sleeper
cabs respectively.\239\ This reflects an average 0.8 percent
improvement beyond what is required to meet the engine standards.
---------------------------------------------------------------------------
\239\ See RIA Chapter 2.8.4.1 for the analysis of the engine
technologies and the associated fuel maps.
---------------------------------------------------------------------------
As noted in Section II.D.2.e, it is import to note that these new
platforms will be developed based on normal market forces rather than
as a result of this rulemaking. Some engine manufacturers have
developed new platforms with the last ten years, and we do not expect
these engines to be replaced within the Phase 2 time frame. However,
other engines have not been fundamentally redesigned recently and will
be due for replacement by 2027. Because these new platforms will occur
because of market forces rather than this rulemaking, these reductions
are in some ways windfalls for vehicle manufacturers. Thus, we have not
included the cost of these new platforms as part of our rulemaking
analysis.
We have factored these levels into our analysis of the vehicle
efficiency levels that will be achievable in MY 2027. These additional
engine improvements will result in vehicles having lower GEM results.
Thus, they make more stringent vehicle standards feasible, and the
final standards are structured so that these improved engines are not
able to generate windfall credits against the engine standards, but
rather that their projected performance is reflected in the stringency
of the final tractor vehicle standard. It is important to also note
that manufacturers that do not achieve this level of engine reduction
would be able to make up the difference by applying one of the many
other available and cost-effective tractor technologies to a greater
extent or more effectively, so that there are multiple technology paths
for meeting the final standards. In other words, a manufacturer that
does not invest in updating engine platforms in the Phase 2 time frame
is likely to be able to invest in improving other vehicle technologies.
(Note that these same reductions cannot be assumed as part of the
engine standards because engine manufacturers will not have this same
flexibility). These reductions from the engine will show up in the fuel
maps used in GEM to set the Phase 2 tractor stringencies.
(ii) Aerodynamics
There are opportunities to reduce aerodynamic drag from the tractor
by further optimization of body components, but it is sometimes
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. DOE has partnered with
the heavy-duty industry to demonstrate high roof sleeper cab tractor
and box trailer combinations that achieve a 50 percent improvement in
freight efficiency evaluated as a 65,000 pound vehicle operating on the
highway under somewhat controlled circumstances. However, these
demonstration vehicles developed in SuperTruck are not necessarily
designed to handle the rigors of daily use over actual in-use roads.
For example, they generally have very limited ground clearance that
would likely preclude operation in snow, and would be very susceptible
to damage from potholes or other road hazards. Nevertheless, this
SuperTruck program has led to significant advancements in the
aerodynamics of combination tractor-trailers. While the agencies cannot
simply apply the SuperTruck program achievements directly into the
Phase 2 program because of the significant differences in the limited
purpose of SuperTruck and the plenary applicability of a regulation to
all operating conditions and duty cycles, it is helpful to assess the
achievements and evaluate how the technologies could be applied into
mass production into a variety of real world applications while
maintaining performance throughout the full useful life of the vehicle.
A manufacturer's SuperTruck demonstration vehicle achieved
approximately a seven percent freight efficiency improvement over a
2009 MY baseline vehicle due to improvements in tractor aerodynamics
and approximately 16 percent overall for the tractor-trailer
combination.\240\ The seven percent freight efficiency improvement due
to tractor aerodynamics equates to roughly a 14 percent reduction in
CdA from a 2010 MY baseline vehicle. The 2010 NAS Report on
heavy-duty trucks found that there are achievable aerodynamic
[[Page 73591]]
improvements which yield 3 to 4 percent fuel consumption reduction or
six to eight percent reduction in Cd values, beyond a baseline
reflecting performance of technologies used in today's SmartWay
trucks.\241\
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\240\ Daimler Truck North America. SuperTruck Program Vehicle
Project Review. June 19, 2014.
\241\ See TIAX, Note 230, Page 4-40.
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The Phase 2 aerodynamic packages are categorized as Bin I, Bin II,
Bin III, Bin IV, Bin V, Bin VI, or Bin VII based on the wind averaged
drag aerodynamic performance determined through testing conducted by
the manufacturer. Bin I represents the least aerodynamic tractors,
while Bins V-VII would be more aerodynamic than any tractor on the road
today. A more complete description of these aerodynamic packages is
included in Chapter 2.8.2.2 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.
The agencies received comments on our aerodynamic technology
assessment. A de F Limited commented that wheel covers improve the
aerodynamics of tractors and trailers, though the results may be lost
in the noise when evaluated on tractors and trailers separately.
Daimler commented that they found in their SuperTruck work that there
are diminishing opportunities for tractor aerodynamics improvements and
there may be impediments to some due to the need to access the back of
cab and reliability concerns. AIR CTI commented that they have built a
truck with aerodynamic technologies such as a front spoiler that
automatically deploys at vehicle speeds over 30 mph, aerodynamic
mirrors, and wheel covers over the rear wheels. ICCT found in their
workshop that opportunities exist for high roof line haul tractor
aerodynamic improvements that could lead to a three to nine percent
improvement in fuel consumption over a 2010 baseline.\242\ The HD
manufacturers and EMA raised significant concerns with regard to the
proposed aerodynamic assessment for Phase 2. They stated that even the
best anticipated future-technology SuperTruck tractor configurations
with a Phase 2 reference trailer likely would only qualify for the
proposed Phase 2 Bin IV or possibly Bin V, leaving Bins V, VI and VII
largely infeasible and unachievable.
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\242\ Delgado, Oscar. N. Lutsey. Advanced Tractor-Trailer
Efficiency Technology Potential in the 2020-2030 Timeframe. April
2015. Docket EPA-HQ-OAR-2014-0827.
---------------------------------------------------------------------------
The agencies' assessment is that the most aerodynamic tractor
tested by EPA in 2015 achieved Bin IV performance. See RIA Chapter
3.2.1.2. This vehicle did not include all of the possible aerodynamic
technologies, such as wheel covers or active aerodynamics like a grill
shutter or front air dam. Upon further analysis of simulation modeling
of a SuperTruck tractor with a Phase 2 reference trailer with skirts,
we agree with the manufacturers that a SuperTruck tractor technology
package would only achieve the Bin V level of CdA, as
discussed above and in RIA Chapter 2.8.2.2. Therefore, the agencies'
assessment is that Bin V is achievable with known aerodynamic
technologies, as discussed in RIA Chapter 2.4.2.1 and 2.8.2.2, but
agree with the manufacturers that Bins VI and VII have less known
technology paths. The agencies are including definitions of Bins VI and
VII performance in the Phase 2 regulations with the understanding that
aerodynamics will continue to improve over the next ten years until the
full phase-in of the Phase 2 program and to provide a value to be input
to GEM should they do so. However, we considered the comments and
discuss the adoption rates of the more aerodynamic bins in Section
III.D.1.c.i, which ultimately concludes that the standards should be
predicated only on performance of aerodynamic technologies reflecting
up to Bin V.
As discussed in Section III.E.2, the agencies are increasing the
number of aerodynamic bins for low and mid roof tractors from the two
levels adopted in Phase 1 to seven levels in Phase 2. The agencies
adopted an increase in the number of bins for these tractors 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.
(iii) Tire Rolling Resistance
A tire's rolling resistance is a function of 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. Since 2007, SmartWay designated tractors
have had steer tires with rolling resistance coefficients of less than
6.5 kg/metric ton for the steer tire and less than 6.6 kg/metric ton
for the drive tire.\243\ Low rolling resistance (LRR) drive tires are
currently offered in both dual assembly and wide-based single
configurations. Wide based single tires can offer rolling resistance
reduction along with improved aerodynamics and weight reduction. The
rolling resistance coefficient target for the Phase 2 NPRM was
developed from SmartWay's tire testing to develop the SmartWay
certification and testing a selection of tractor tires as part of the
Phase 1 and Phase 2 programs. Even though the coefficient of tire
rolling resistance comes in a range of values, to analyze this range,
the tire performance was evaluated at four levels for both steer and
drive tires, as determined by the agencies. The four levels in the
Phase 2 proposal included the baseline (average) from 2010, Level I and
Level 2 from Phase 1, and Level 3 that achieves an additional 25
percent improvement over Level 2. The Level 1 rolling resistance
performance represents the threshold used to develop SmartWay
designated tires for long haul tractors. The Level 2 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 for Phase 1. The Level 3 values in the NPRM represented the
long-term rolling resistance value that the agencies predicts could be
achieved in the 2025 timeframe. Given the multiple year phase-in of the
standards, the agencies expect that tire manufacturers will continue to
respond to demand for more efficient tires and will offer increasing
numbers of tire models with rolling resistance values significantly
better than today's typical low rolling resistance tires.
---------------------------------------------------------------------------
\243\ U.S. EPA. ``US EPA Low Rolling Resistance Tire Testing
Activities'' presentation to SAE Government-Industry Meeting.
January 22, 2016. Values represent the ISO 28580 2 meter drum
results because these align with the test method used to certify
tractors to the GHG and fuel consumption standards.
---------------------------------------------------------------------------
ICCT found in their workshop that opportunities exist for
improvements in rolling resistance for tractor tires that could lead to
a two to six percent improvement in fuel consumption when compared to a
2010 baseline tractor.\244\ A fuel consumption improvement in this
range would require a six to 18 percent improvement in the tractor tire
rolling resistance levels. Michelin commented that the proposed values
for the drive tires seem reasonable, though the 4.5 kg/ton level would
require significantly higher adoption rate of
[[Page 73592]]
new generation wide base single tires. Michelin also stated that the
value of 4.3 kg/ton target for steer tires is highly unlikely based on
current evolution and that research shows that 5.0 kg/ton would be more
likely.
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\244\ Delgado, Oscar. N. Lutsey. Advanced Tractor-Trailer
Efficiency Technology Potential in the 2020-2030 Timeframe. April
2015. Docket EPA-HQ-OAR-2014-0827.
---------------------------------------------------------------------------
The agencies have evaluated this comment and find it persuasive.
The agencies analyzed the 2014MY certification data for tractors
between the NPRM and final rulemaking. We found that the lowest rolling
resistance value submitted for 2014 MY GHG and fuel efficiency
certification for tractors was 4.9 and 5.1 kg/metric ton for the steer
and drive tires respectively, while the highest rolling resistance tire
had a CRR of 9.8 kg/metric ton.\245\ We have accordingly increased the
coefficient of rolling resistance for Level 3 tires in the final rule
based on the comments and the certification data.
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\245\ U.S. EPA. Memo to Docket. Coefficient of Rolling
Resistance and Coefficient of Drag Certification Data for Tractors.
See Docket EPA-HQ-OAR-2014-0827.
---------------------------------------------------------------------------
(iv) Tire Pressure Monitoring and Automatic Tire Inflation Systems
Proper tire inflation is critical to maintaining proper stress
distribution in the tire, which reduces heat loss and rolling
resistance. Tires with low inflation pressure exhibit a larger
footprint on the road, more sidewall flexing and tread shearing, and
therefore, have greater rolling resistance than a tire operating at its
optimal inflation pressure. Bridgestone tested the effect of inflation
pressure and found a 2 percent variation in fuel consumption over a 40
psi range.\246\ Generally, a 10 psi reduction in overall tire inflation
results in about a one percent reduction in fuel economy.\247\ To
achieve the intended fuel efficiency benefits of low rolling resistance
tires, it is critical that tires are maintained at the proper inflation
pressure.
---------------------------------------------------------------------------
\246\ Bridgestone Tires. Real Questions, Real Answers. http://www.bridgestonetrucktires.com/us_eng/real/magazines/ra_special-edit_4/ra_special4_fuel-tires.asp
\247\ ``Factors Affecting Truck Fuel Economy,'' Goodyear, Radial
Truck and Retread Service Manual. Accessed February 16, 2010 at
http://www.goodyear.com/truck/pdf/radialretserv/Retread_S9_V.pdf.
---------------------------------------------------------------------------
Proper tire inflation pressure can be maintained with a rigorous
tire inspection and maintenance program or with the use of tire
pressure and inflation systems. According to a study conducted by FMCSA
in 2003, about 1 in 5 tractors/trucks is operating with 1 or more tires
underinflated by at least 20 psi.\248\ A 2011 FMCSA study estimated
under inflation accounts for one service call per year and increases
tire procurement costs 10 to 13 percent. The study found that total
operating costs can increase by $600 to $800 per year due to under
inflation.\249\ A recent study by The North American Council on Freight
Efficiency, found that openness to the use of tire pressure monitoring
systems is increasing. It also found that reliability and durability of
commercially available tire pressure systems are good and early issues
with the systems have been addressed.\250\ These automatic tire
inflation systems (ATIS) monitor tire pressure and also automatically
keep tires inflated to a specific level. The agencies proposed to
provide a one percent CO2 and fuel consumption reduction
value for tractors with automatic tire inflation systems installed.
---------------------------------------------------------------------------
\248\ American Trucking Association. Tire Pressure Monitoring
and Inflation Maintenance. June 2010. Page 3. Last accessed on
December 15, 2014 at http://www.trucking.org/ATA%20Docs/About/Organization/TMC/Documents/Position%20Papers/Study%20Group%20Information%20Reports/Tire%20Pressure%20Monitoring%20and%20Inflation%20Maintenance%E2%80%94TMC%20I.R.%202010-2.pdf.
\249\ TMC Future Truck Committee Presentation ``FMCSA Tire
Pressure Monitoring Field Operational Test Results,'' February 8,
2011.
\250\ North American Council for Freight Efficiency, ``Tire
Pressure Systems,'' 2013.
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Tire pressure monitoring systems (TPMS) notify the operator of tire
pressure, but require the operator to manually inflate the tires to the
optimum pressure. Because of the dependence on the operator's action,
the agencies did not propose an emission reduction value for tire
pressure monitoring systems. Instead, we requested comment on this
approach and sought data from those that support a reduction value be
assigned to tire pressure monitoring systems. 80 FR 40218.
Many commenters including OOIDA, ATA, the truck manufacturers, RMA,
UPS, Bendix, Doran, First Industries, NADA, and others suggested that
the agencies should recognize TPMS as a technology in GEM, with the
effectiveness value set at an equal level as ATIS. On the other hand,
ARB generally supported the use of ATIS but not TPMS because it
requires action from the driver. Many stakeholders stated that TPMS
offers similar benefit, but at a lower cost, so is more acceptable in
the market. UPS commented that they prefer TPMS because TPMS gives the
truck owner an affirmative indication that there is a tire pressure
problem, so it can be fixed, whereas the ATIS does not and they are
concerned that ATIS simply keeps adding tire pressure automatically,
wasting energy, and the truck owner may never know it. Bendix believes
that both ATIS and TPMS should be available in the market in the Phase
2 timeframe for tractors. RMA cited a NHTSA study of LD vehicles of
model years 2004-2007 and found that the presence of a TPMS system led
to a 55.6 percent reduction in the likelihood that a vehicle would have
one tire that is significantly underinflated (25 percent or
greater).\251\ RMA also stated that NHTSA found TPMS to be effective in
reducing moderate under inflation (at least 10 percent, but under 25
percent), which was reduced by 35.3 percent.\252\ RMA's comments also
stated for light trucks and vans, the effectiveness rates were even
higher, with TPMS reducing severe under inflation by 61.2 percent and
moderate under inflation by 37.7 percent. RMA commented that NHTSA
found that in 2011, the TPMS systems save $511 million in fuel costs
across the vehicle fleet.\253\ Navistar said the driver alert with TPMS
is simpler and sufficient to ensure tire inflation in commercial
applications. Navistar also commented that in heavy duty, a
professional driver has both the incentive and the knowledge to keep
tires adequately inflated, neither of which may necessarily be the case
with light duty. Doran Manufacturing cited FMCSA studies on TPMS in
2006 that found TPMS were accurate at assessing tire pressure, in 2007
found acceptable durability of TPMS, and in 2011 found that TPMS or
ATIS in fleet studies showed a 1.4 percent improvement in fuel economy.
ARB's technology assessment found ATIS benefit at one percent.\254\
ICCT found in their workshop that opportunities exist for ATIS that
could lead to a 0.5 to two percent improvement in fuel
consumption.\255\ AIR CTI discussed the consequences of improper
inflation pressures on tire life, safety, stopping distance, vehicle
vibration, and damage to the roads. AIR CTI commented that their
Central Tire Inflation system controls tire pressure from controls on
the dash and is commonly used in logging and other off-road
transportation.
---------------------------------------------------------------------------
\251\ 80 FR at 40173.
\252\ 80 FR 40278.
\253\ 80 FR at 40258.
\254\ California Air Resources Board. Draft Technology
Assessment: Engine/Powerplant and Drivetrain Optimization and
Vehicle Efficiency. June 2015. Page III-3. Report is available at
www.arb.ca.gov.
\255\ Delgado, Oscar. N. Lutsey. Advanced Tractor-Trailer
Efficiency Technology Potential in the 2020-2030 Timeframe. April
2015. Docket EPA-HQ-OAR-2014-0827.
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After consideration of the comments, the agencies found them
persuasive and are adopting provisions in Phase 2 GEM that allow
manufacturers flexibility to
[[Page 73593]]
show compliance with the CO2 and fuel consumption standards
using various technologies, including the flexibility to adopt ATIS or
TPMS (see 40 CFR 1037.520). This reflects a change from the Phase 2
NPRM, where only ATIS (not TPMS) was a GEM input. The agencies believe
that sufficient incentive exists for truck operators to address low
tire pressure conditions if they are notified that they exist through a
TPMS.
The agencies also considered the comments to determine the
effectiveness of TPMS and ATIS. The agencies conducted a further review
of the FCMSA study cited by commenters and we interpret the results of
the study to indicate that overall a combination of TPMS and ATIS in
the field achieved 1.4 percent reduction. However, it did not separate
the results from each technology, and therefore did not indicate that
TPMS and ATIS achieved the same levels of reduction. Therefore, we set
the effectiveness of TPMS slightly lower than ATIS to reflect that
operators will be required to take some action to insure that the
proper inflation pressure is maintained. The input values to the Phase
2 GEM are set to 1.2 percent reduction in CO2 emissions and
fuel consumption for ATIS and 1.0 percent reduction for TPMS. In other
words, if a manufacturer installs an ATIS onto a vehicle, then they
will enter 1.2 percent into the Tire Pressure System value in their GEM
input file. If a manufacturer installs a TPMS, then they will input 1.0
percent into the Tire Pressure System value in GEM.
EPA proposed a definition of ATIS in 40 CFR 1037.801 to qualify it
as a technology input to GEM. The proposed definition stated that
``Automatic tire inflation system means a system installed on a vehicle
to keep each tire inflated to within 10 percent of the target value
with no operator input.'' The agencies received comment about this
definition. Meritor suggested adopting the historical industry
definition of ATIS as ``Automatic Tire Inflation Systems maintain tire
pressure at a single preset level and are pneumatically or
electronically activated. These systems eliminate the need to manually
inflate tires.'' Meritor is concerned with the proposed definition of
ATIS that required the system must ``keep each tire inflated to within
10 percent'' to qualify as a technology input to GEM. Meritor commented
that the proposed definition is not consistent with the manner in which
these systems are used in practice. Meritor stated that an ATIS assures
that tires will always be running at the recommended cold tire
inflation pressure. The agencies are adopting changes to reflect the
appropriate definition of ATIS in the final rule (see 40 CFR 1037.801).
(v) Idle Reduction
Auxiliary power units (APU), fuel operated heaters (FOH), battery
supplied air conditioning, and thermal storage systems are among the
technologies available today to reduce fuel consumption and
CO2 emissions from extended idling (or hoteling). Each of
these technologies reduces fuel consumption during idling relative to a
truck without this equipment. In Phase 1 and in the Phase 2 NPRM, the
agencies took an approach whereby tractor manufacturers could input an
idle reduction value into GEM only if a vehicle included a tamper-proof
automatic engine shutdown system (AESS) programmed to shut down the
engine after five minutes or less. This approach allows the
manufacturers to use AESS as one of the technologies (in combination
with other technologies such as aerodynamics or low rolling resistance
tires) to demonstrate compliance with the CO2 emission and
fuel consumption standards. The agencies also included several override
provisions for the AESS and a discounted GEM input value for an
expiring AESS or a system that allowed a specified number of hours of
idling per year (see 40 CFR 1037.660).
The agencies did not differentiate between the various idle
reduction technologies in terms of effectiveness because we adopted in
Phase 1 and proposed in Phase 2 a conservative effectiveness level to
recognize that some vehicles may be sold with only an AESS but may then
install an idle reduction technology after it leaves the factory (76 FR
57207). The effectiveness for AESS in Phase 1 and proposed in Phase 2
was determined by comparing the idle fuel consumption of the main
engine at approximately 0.8 gallons per hour to the fuel consumption of
a diesel powered APU that consumes approximately 0.2 gallons per hour.
This difference equates to a five percent reduction in overall
CO2 emissions and fuel consumption of a Class 8 sleeper cab.
A diesel powered APU was selected for determining the effectiveness and
cost because it was a conservative estimate. Diesel powered APUs have
the highest fuel consumption and cost of the idle reduction
technologies considered.\256\ The agencies proposed that a tamper-proof
AESS would receive a five percent CO2 emissions and fuel
consumption reduction in GEM for vehicles that included this
technology. This value is in line with the TIAX assessment which found
a five percent reduction in overall fuel consumption to be
achievable.\257\ The agencies requested comments on the proposed
approach.
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\256\ See the draft RIA Chapter 2.4.8 for details.
\257\ See the 2010 NAS Report at 128.
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The agencies received a number of comments regarding ``mandating
APU'' or ``mandating AESS.'' There is a misconception of the proposed
Phase 2 program where stakeholders thought that the agencies were
mandating use of APUs. This is incorrect. The tractor standards are
performance standards. The agencies merely projected an adoption rate
of up to 90 percent for tamper-proof AESS in our analysis for
determining the stringency level of the proposed standard. As stated
above, we did not propose to differentiate between the various idle
reduction technologies in terms of effectiveness and only used the
diesel powered APU in terms of determining the cost and effectiveness
of a potential standard. Also, because the standards are performance
standards, the agencies are not mandating any specific fuel consumption
or GHG emission reducing technology. For each standard, we developed
one potential technology pathway to demonstrate the feasibility of the
standards, but manufacturers will be free to choose other paths.\258\
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\258\ The one exception being the design standards for certain
non-aero trailers. See Section IV below.
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The agencies received a significant number of comments about idle
reduction for sleeper cabs, including recommendations to the agencies
to assess the emission reduction for a variety of idle reduction
technologies instead of just a tamper-proof AESS. ATA, NADA, and others
commented that fleets have a variety of choices available in providing
the driver power and comfort in-lieu of idling including use of APUs,
FOHs, stop-start (main engine turns on only to recharge the battery
after several hours), shore power, battery stand-by, stand-alone anti-
idling infrastructure establishments, slip-seat operations, and hotel
accommodations. Convoy Solutions stated that IdleAir's electrified
parking spaces are an important bridge technology to more electrified
solutions. IdleAir commented it may be possible to recognize off board
behavior at the OEM level as a buyer of a new truck could enter into a
contract with an EPS provider prior to accepting delivery. ATA and
First Industries support efficiency credits for idling reduction
options installed by fleets either at the OEM point-of-sale or
installed in the after-market.
[[Page 73594]]
The agencies also received comments regarding the level of
effectiveness of idle reduction technologies. ICCT found in their
workshop that opportunities exist for line haul tractor idle reduction
improvements that could lead to a four to seven percent improvement in
fuel consumption.\259\ MEMA recommended that the agencies modify the
projected effectiveness level based on the merit of the individual idle
control technology. MEMA's recommendation for effectiveness levels
based on the fuel consumption and GHG emissions of each technology
ranged from 7.7 g/ton-mile for fuel cell APU, 6 g/ton-mile for diesel
APU, and 9 g/ton-mile for batter air conditioning systems, fuel
operated heater, and combinations of technologies. MEMA supports the
agencies' proposal that, in order to qualify for the use of an idle
reduction technology in GEM, it is mandatory that the truck be equipped
with an AESS. MEMA also commented that in the Phase 1 RIA, the agencies
assumed a Class 8 sleeper cab spends 1,800 hours in extended idle per
year and travels about 250 days per year. MEMA recommends that the
agencies use 2,500 annual hours for APUs and 1,250 annual hours for
FOHs to better reflect real-world application and experiences.
Additionally, MEMA recommends that 0.87 gallon/hour fuel consumed by
the main engine during idle be used in the calculations for credit.
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\259\ Delgado, Oscar. N. Lutsey. Advanced Tractor-Trailer
Efficiency Technology Potential in the 2020-2030 Timeframe. April
2015. Docket EPA-HQ-OAR-2014-0827.
---------------------------------------------------------------------------
The agencies also received a significant number of comments about
idle reduction encouraging the agencies to consider recognizing
adjustable AESS instead of only a tamper-proof AESS. ATA commented that
most fleets already purchase ``programmable'' idle shutdown timers to
limit idling due to the national patchwork of anti-idling laws
currently in place. ATA continued to say that these timers are
typically set for a given period of time throughout the initial fleet's
ownership period. ATA also stated as witnessed under Phase I, fleets
are unwilling to purchase hard-programmed, tamper-proof AESS given
their need for flexibility regarding their resale of used equipment on
the secondary market. Caterpillar also noted that fleets do not
purchase tamper-resistant automatic engine shutdown systems; therefore,
AESS should not be part of the stringency setting, unless the agencies
also consider programmable versions of AESS. PACCAR, Volvo and EMA
request the agencies to consider partial credit for AESS that are
programmed to a 5-minute or sooner shutdown but are not tamper-
resistant to changes by an owner. Daimler and Navistar also commented
that the agencies should consider adjustable AESS as a technology input
to GEM. Daimler found that less than one percent of the adjustable AESS
systems set at or below 5 minutes that were installed in customer
tractors were deactivated or reprogrammed to a value longer than 5
minutes. PACCAR viewed the proposed tamper-proof AESS for 1.259 million
miles as unrealistic and not reflecting current market conditions.
While the agencies do not necessarily believe that customer
reluctance in the initial years of Phase 1 should be considered
insurmountable, we do agree with commenters that the agencies should
allow adjustable AESS to be a technology input to GEM and should
differentiate effectiveness based on the idle reduction technology
installed by the tractor manufacturer. We will still apply the Phase 1
requirement that the AESS be programmed to 5 minutes or less at the
factory to qualify as a technology input in GEM (see 40 CFR 1037.660),
but for Phase 2 will allow a variety of both tamper-proof and
adjustable systems to qualify for some reduction (i.e. to be recognized
by GEM). Any changes made subsequent to the factory but prior to
delivery to the purchaser, must be accounted for in the manufacturer's
end of year reports.
The agencies developed effectiveness levels for the extended idle
technologies from literature, SmartWay work, and the 2010 NAS report.
The agencies also reviewed the NACFE report on programmable engine
parameters which included a fleet survey on how often the fleets change
programmable parameters, such as automatic engine shutdown timers.\260\
The survey found that approximately 70 percent of these fleets never
changed the setting. The agencies developed the effectiveness levels to
reflect that there is some greater uncertainty of adjustable AESS
systems, therefore the effectiveness values are discounted from the
values determined for tamper-proof AESS. A detailed discussion
regarding the comments and the associated calculations to determine the
effectiveness of each of the idle reduction technologies are included
in RIA Chapter 2.4.8.1.1. In summary, the effectiveness for each type
of idle reduction technology is included in Table III-9.
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\260\ North American Council for Freight Efficiency. Confidence
Report: Programmable Engine Parameters. February 2015. Page 48.
Table III-9--Idle Reduction Technology Effectiveness
------------------------------------------------------------------------
Idle reduction
Idle Reduction Technology value in GEM
(%)
------------------------------------------------------------------------
Tamper-Proof AESS....................................... 4
Tamper-Proof AESS w/Diesel APU.......................... 4
Tamper-Proof AESS w/Battery APU......................... 6
Tamper-Proof AESS w/Automatic Stop-Start................ 3
Tamper-Proof AESS w/FOH Cold, Main Engine Warm.......... 3
Adjustable AESS w/Diesel APU............................ 3
Adjustable AESS w/Battery APU........................... 5
Adjustable AESS w/Automatic Stop-Start.................. 3
Adjustable AESS w/FOH Cold, Main Engine Warm............ 2
Adjustable AESS programmed to 5 minutes................. 1
------------------------------------------------------------------------
In addition to extended idling (or hoteling) by sleeper cabs, the
agencies discussed work day idle by day cabs in the Phase 2 NPRM. 80 FR
40217. Day cab tractors often idle while cargo is loaded or unloaded,
as well as during the frequent stops that are inherent with driving in
urban traffic conditions near cargo destinations. Prior to issuing the
Phase 2 NPRM, 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.\261\ 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. At the time of the Phase 2 NPRM, the agencies were
not able to appropriately develop a baseline of workday idling for day
cabs and identify the percent of this idling which could be reduced
through the use of AESS. We welcomed comment and data on quantifying
the effectiveness of AESS on day cabs. We further requested comment on
the possibility of adapting the idle-only duty cycle for vocational
vehicles to certain day cab tractors, and also considered the
possibility of neutral idle technology for tractors using torque-
converter automatic
[[Page 73595]]
transmissions and stop-start for any tractor. Id.
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\261\ Gaines, L., A. Vyas, J. Anderson. Estimation of Fuel Use
by Idling Commercial Trucks. January 2006.
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The agencies received a significant number of comments regarding
day cab idle reduction. CARB commented that the agencies should include
idle reduction technologies for day cabs, similar to the proposed
vocational vehicle approach. CARB stated that even if the first owners
do not see significant emission reductions, many of the day cab
tractors are used in port and drayage applications in their second life
where they would see significant reductions. CARB suggested that the
GEM composite weighting factor for idle should be between 5 and 10
percent. Bendix would like to see the vocational vehicle idle reduction
approach extended to day cab tractors based on their data which found
that there are many applications of day cab tractors that spend a
significant portion of their day's drive time at idle, especially pick-
up and delivery type applications and a growing number of fleets that
run hub and spoke type operations. MEMA supported extending neutral
idle and stop-start technologies to day cab tractors. MEMA recommends
that the agencies set the effectiveness of day cabs idle reduction
technologies at a value equal to 35 percent of the effectiveness
associated with a comparable technology in a Class 8 sleeper cab.
Allison stated that agencies should include automatic neutral in all
tractors. Allison stated that automatic neutral is standard with the
Allison TC10 and is available with the Allison 3000 and 4000 Series
transmissions.
Daimler commented that they have not validated that stop-start
strategies are viable for Class 7 and 8 applications and considers it
premature for the agencies to project that stop-start strategies are
viable for this class of engines. Daimler stated that lubrication of
critical bearing surfaces is lacking or severely compromised during
engine start up due to the lack of lubricating oil pressure and this
lack of lubrication leads to metal to metal contact, wear, and
ultimately failure. In addition, Daimler commented that firing
pressures inherent to compression ignition engines further exacerbate
wear as compared to, for example, spark ignition engines where stop-
start technology is being increasingly applied. Daimler also stated
that these known problems, coupled with the extremely long million mile
plus service life expectations for this heavier class of heavy-duty
engines, together pose a development challenge that is significantly
more challenging than that posed to spark ignition engines in passenger
cars. Daimler further stated that heat soak of temperature critical
parts and temporary disruption of their lubrication/cooling systems
will have to be understood and possible degradations handled through
modifications at either component or system basis, the extent of which
is not yet fully quantified. Daimler also stated that similarly, on the
turbocharger side, the larger speed swings will shorten turbocharger
wheel life, which is increasingly challenged in vocational applications
that are characteristically more transient as compared to the
relatively steady operation nature of line haul.
The agencies considered the comments, both supporting and raising
concerns over idle reduction in day cabs. The agencies determined that
neutral idle for automatic transmissions is an appropriate technology
for use in tractors. Therefore, the agencies are adopting provisions in
Phase 2 to recognize neutral-idle in automatic transmissions as an
input to GEM. Our analysis shows that neutral idle effectiveness is
approximately 0.8 to one percent over the composite day cab tractor
cycles, as shown in RIA Chapter 2.8.2.6.2. The agencies will also
include neutral idle as a GEM input for sleeper cabs, though the
effectiveness is very low. The agencies are predicating the standards
for day cabs based on a technology package that includes neutral idle.
In terms of stop-start technologies in tractors, the agencies are
not including it as a technology input to GEM because we believe the
technology, as applied to tractors, needs further development. If this
technology is developed in the future for tractors, then manufacturers
may consider applying for off-cycle technology credits. Since the
agencies are not predicating the Phase 2 standards on adoption of
start-stop technologies, the agencies are also not including this
technology as a GEM input.
(vi) Transmissions
As discussed in the 2010 NAS report, automatic (AT) and automated
manual transmissions (AMT) may offer the ability to improve vehicle
fuel consumption by optimizing gear selection compared to an average
driver.\262\ 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 zero to eight percent.\263\
Well-trained drivers would be expected to perform as well or even
better than an automated transmission since the driver can see the road
ahead and anticipate a changing stoplight or other road condition that
neither an automatic nor automated manual transmission can anticipate.
However, less well-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. As transmissions continue to evolve, dual clutch
transmissions (DCTs) are now being used in the European heavy-duty
vehicle market. DCTs operate similar to AMTs, but with two clutches so
that the transmission can maintain engine speed during a shift which
improves fuel efficiency.
---------------------------------------------------------------------------
\262\ Manual transmissions require the driver to shift the gears
and manually engage and disengage the clutch. Automatic
transmissions shift gears through computer controls and typically
include a torque converter. An AMT operates similar to a manual
transmission, except that an automated clutch actuator disengages
and engages the drivetrain instead of a human driver. An AMT does
not include a clutch pedal controllable by the driver or a torque
converter.
\263\ See TIAX, Note 230, above at 4-70.
---------------------------------------------------------------------------
The benefits for automated manual, automatic, and dual clutch
transmissions were developed from literature, from simulation modeling
conducted by Southwest Research Institute, and powertrain testing
conducted at Oak Ridge National Laboratory. The proposed Phase 2
benefit of these transmissions in GEM was set at a two percent
improvement over a manual transmission due to the automation of the
gear shifting. 80 FR 40217.
Allison Transmission commented that their real world studies
indicate that automatic transmissions perform as well or better than
AMTs or DCTs in terms of GHG and fuel efficiency impact. Allison
commented that their ATs can exceed the 2 percent level estimated at
proposal, but believe it is a reasonable level to apply this level of
effectiveness for ATs and AMTs. Allison stated that automatic
transmissions in tractors have neutral at stop capability, first gear
lockup operation, load-based and grade-based shift algorithms and
acceleration rate management that contribute to the overall fuel
efficiency of ATs in tractors. Allison also commented that although
DCTs should logically perform better than the MT baseline, there was no
record information to support that assumption. Volvo commented that
fuel consumption with their I-Shift DCT is the same as the I-Shift AMT.
PACCAR recommends that the agencies take a more detailed approach to
assessing transmission advances and revise the
[[Page 73596]]
agencies' estimate to reflect technologies that are already under true
consideration for use in production powertrains.
UCS commented that as much as 1.3 to 2.0 percent savings from
tractor-trailers could be added to the proposed stringency to reflect
the true potential from tractor-trailers from powertrain optimization,
particularly since every major manufacturer already offers at least one
``integrated powertrain'' option in its long-haul fleet. ICCT referred
to two studies related to tractor-trailer technologies in their
comments.264 265 In their stakeholder workshop, they found
that the effectiveness of automated manual transmissions ranged between
two and three percent. They also cited another finding that highlighted
opportunities to improve transmission efficiency, including direct
drive, which would provide about two percent fuel consumption
reduction.\266\
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\264\ Lutsey, Nic. T. Langer, S. Khan. Stakeholder Workshop on
Tractor-Trailer Efficiency Technology in the 2015-2030 Timeframe.
August 2014. Docket EPA-HQ-OAR-2014-0827.
\265\ Delgado, Oscar. N. Lutsey. Advanced Tractor-Trailer
Efficiency Technology Potential in the 2020-2030 Timeframe. April
2015. Docket EPA-HQ-OAR-2014-0827.
\266\ Stoltz, T. and Dorobantu, M. Transmission Potential to
Contribute to CO2 Reduction: 2020 and Beyond Line Haul
Perspective. ACEEE/ICCT Workshop on Emerging Technologies for Heavy-
Duty Fuel Efficiency. July 2014.
---------------------------------------------------------------------------
The agencies' assessment of the comments is that Allison, ICCT, and
Volvo support the proposed two percent effectiveness for AT and AMT
transmission types. In addition, the agencies reviewed the NACFE report
on electronically controlled transmissions (AT, AMT, and DCT).\267\
This report had similar findings as those noted above in the NAS 2010
report. Electronically controlled transmissions were found to be more
fuel efficient than manual transmissions, though the amount varied
significantly. The report also stated that fleets found that
electronically controlled transmissions also reduced the fuel
efficiency variability between drivers. Therefore after considering the
comments related to effectiveness and additional reports, the agencies
are adopting as proposed a two percent effectiveness for AMT. As
discussed in RIA 2.8.2.5, the agencies conducted powertrain testing at
Oak Ridge National Laboratory to compare the fuel efficiency of an AMT
to an AT. Based on the results, the agencies expect that automatic
transmissions designed for long haul operation and automated manual
transmissions will perform similarly and have similar effectiveness
when compared to a manual transmission.
---------------------------------------------------------------------------
\267\ North American Council for Freight Efficiency. Confidence
Report: Electronically Controlled Transmissions. December 2014.
---------------------------------------------------------------------------
The benefit of the AMT's automatic shifting compared to a manual
transmission is recognized in Phase 2 GEM by simulating the MT as an
AMT and increasing the emission results from the simulation by two
percent. For ATs, the agencies developed the default automatic
transmission inputs to GEM to represent a typical heavy-duty automatic
transmission, which is less efficient than the TC10 (the transmission
tested at Oak Ridge National Lab). The agencies selected more
conservative default transmission losses in GEM so that we would not
provide a false efficiency improvement for the less efficient automatic
transmissions that exist in the market today. Under the regulations in
this rulemaking, manufacturers that certify using the TC10 transmission
would need to either conduct the optional transmission gear efficiency
testing or powertrain testing to recognize the effectiveness of this
type of automatic transmission in GEM. In our technology packages
developed to set the Phase 2 standard stringencies, the agencies used a
two percent effectiveness for automatic transmissions with neutral idle
under the assumption that either powertrain or transmission gear
efficiency tests would be conducted. The compliance costs for this type
of testing (which crosses over both the vocational and tractor
programs) are included as noted in RIA Chapter 7.2.1.2.
The agencies agree with PACCAR that we should consider future
transmission advances. There are three certification pathways for
manufacturers to assess benefits of future transmissions; that is, to
generate a value reflecting greater improvement than the two percent
GEM input. The first is an optional powertrain test (40 CFR 1037.550),
the second is an optional transmission efficiency test (40 CFR
1037.565), and the third is off-cycle credits (40 CFR 1037.610).
The agencies acknowledge UCS's comment about increasing the
stringency of the tractor program due to the opportunity to further
improve powertrain optimization through powertrain testing. For the
Phase 2 final rule, we have made several changes that capture much of
the improvement potential highlighted by UCS. First, the required use
of a cycle average fuel map in lieu of a steady state fuel map for
evaluating the transient cycle in GEM will recognize improvements to
transient fuel control of the engine. The agencies are including the
impact of improved transient fuel control in the engine fuel maps used
to derive the final standards. Second, the optional transmission
efficiency test will recognize the benefits of improved gear
efficiencies. The agencies have built some improvements in transmission
gear efficiency into the technology package used to derive the final
standards. This leaves only the optimization of the transmission shift
strategy, which would need to be captured on a powertrain test. The
agencies believe that the opportunity of shift strategy optimization is
less for tractors than for other types of vocational vehicles because a
significant portion of the tractor drive cycles are at highway speeds
with limited transmission shifting. Therefore, we have not included the
powertrain optimization portion only recognized through powertrain
testing into the standard setting for the final rule.
The agencies also proposed standards that considered the efficiency
benefit of transmissions that operate with top gear direct drive
instead of overdrive. In the proposal, we estimated that direct drive
had two percent higher gear efficiency than an overdrive gear. 80 FR
40229. The benefit of direct drive was recognized through the
transmission gear ratio inputs to GEM. Direct drive leads to greater
reductions of CO2 emissions and fuel consumption during
highway operation, but virtually none in transient operation. The
agencies did not receive any negative comments regarding the efficiency
difference between direct drive and overdrive; therefore, we continued
to include the default transmission gear efficiency advantage of two
percent for a gear with a direct drive ratio in the version of GEM
adopted for the final Phase 2 rules.
The agencies are also adopting in Phase 2 an optional transmission
efficiency test (40 CFR 1037.565) for generating an input to GEM that
overrides the default efficiency of each gear based on the results of
the test. Although optional, the transmission efficiency test will
allow manufacturers to reduce the CO2 emissions and fuel
consumption by designing better transmissions with lower friction due
to better gear design and/or mandatory use of better lubricants. The
agencies project that transmission efficiency could improve one percent
over the 2017 baseline transmission in Phase 2. Our assessment was
based on comments received and discussions with transmission
manufacturers.\268\
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\268\ Memorandum to the Docket ``Effectiveness of Technology to
Increase Transmission Efficiency.'' July 2016.
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[[Page 73597]]
(vii) Drivetrain and Engine Downspeeding
Downspeeding: As tractor manufacturers continue to reduce the
losses due to vehicle loads, such as aerodynamic drag and rolling
resistance, the amount of power required to move the vehicle decreases.
In addition, engine manufacturers continue to improve the power density
of heavy-duty engines through means such as reducing the engine
friction due to smaller surface area. These two changes lead to the
ability for truck purchasers to select lower displacement engines while
maintaining the previous level of performance. Engine downsizing could
be more effective if it is combined with the downspeeding assuming
increased brake mean effective pressure does not affect durability. The
increased efficiency of the vehicle moves the operating points down to
a lower load zone on a fuel map, which often moves the engine away from
its sweet spot to a less efficient zone. In order to compensate for
this loss, downspeeding allows the engine to run at a lower engine
speed and move back to higher load zones, and thus can slightly improve
fuel efficiency. Reducing the engine size allows the vehicle operating
points to move back to the sweet spot, thus further improving fuel
efficiency. Engine downsizing can be accounted for as a vehicle
technology through the use of the engine's fuel map in GEM in
combination with the vehicle's transmission gear ratios, drive axle
ratio, and tire diameter. The agencies evaluated the impact of
downspeeding in setting the stringencies by modeling different rear
axle ratios in GEM. As shown in RIA Chapter 2.8.2.7, a decrease in
final drive ratio from 2.6 to 2.3 will lead to a 2.5 percent reduction
in tractor CO2 emissions and fuel consumption. The reshaping
of the torque curve of an engine to increase the low speed torque and
reduce the speed at which maximum torque occurs, will impact the
CO2 emissions and fuel consumption on the engine test
cycles, but will also have a small impact on the vehicle fuel
consumption. Higher torque at lower engine speeds will allow the
transmission to operate in top gear for a longer period of the time
which will reduce the number of downshifts over a cycle and in turn
means that the engine speed is lower on average. This benefit will show
up in GEM. Additional information on engine downspeeding can be found
in RIA Chapter 2.3.8.
Low Friction Axle and Wheel Bearing Lubricants: The 2010 NAS report
assessed low friction lubricants for the drivetrain as providing a one
percent improvement in fuel consumption based on fleet testing.\269\ A
field trial of European medium-duty trucks found an average fuel
consumption improvement of 1.8 percent using SAE 5W-30 engine oil, SAE
75W90 axle oil and SAE 75W80 transmission oil when compared to SAE
15W40 engine oil and SAE 90W axle oil, and SAE 80W transmission
oil.\270\ 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 zero and one percent compared to
traditional lubricants. In the Phase 2 proposal, the agencies proposed
the reduction in friction due to low viscosity axle lubricants of 0.5
percent. 80 FR 40217.
---------------------------------------------------------------------------
\269\ See the 2010 NAS Report, Note 229, page 67.
\270\ Green, D.A., et. al. ``The Effect of Engine, Axle, and
Transmission Lubricant, and Operating Conditions on Heavy Duty
Diesel Fuel Economy. Part 1: Measurements.'' SAE 2011-01-2129. SAE
International Journal of Fuels and Lubricants. January 2012.
---------------------------------------------------------------------------
Lubrizol commented that high performing lubricants should play a
role in Phase 2. Lubrizol also supports the axle test procedures to
further recognize axle efficiency improvements. PACCAR recommended
eliminating the rear axle efficiency test and provide credits based on
calculated values.
The agencies' assessment of axle improvements found that axles
built in the Phase 2 timeline could be 2 percent more efficient than a
2017 baseline axle.\271\ In lieu of a fixed value for low friction axle
lubricants (i.e. in lieu of a specified GEM input), the agencies are
adopting an axle efficiency test procedure (40 CFR 1037.560), as
discussed in the NPRM. 80 FR 40185. The axle efficiency test will be
optional, but will allow manufacturers to recognize in GEM reductions
in CO2 emissions and fuel consumption through improved axle
gear designs and/or mandatory use of low friction lubricants. The
agencies are not providing an alternate path to recognize better
lubricants without axle testing.
---------------------------------------------------------------------------
\271\ Memorandum to the Docket ``Effectiveness of Technology to
Increase Axle Efficiency.'' July 2016.
---------------------------------------------------------------------------
Axle Configuration: Most tractors today have three axles--a steer
axle and two rear drive axles, and are commonly referred to as 6x4
tractors. Manufacturers offer 6x2 tractors that include one rear drive
axle and one rear non-driving axle. The 6x2 tractors offer three
distinct benefits. First, the non-driving rear axle does not have
internal friction and therefore reduces the overall parasitic losses in
the drivetrain. In addition, the 6x2 configuration typically weighs
approximately 300 to 400 lbs less than a 6x4 configuration.\272\
Finally, the 6x2 typically costs less or is cost neutral when compared
to a 6x4 tractor. Sources cite the effectiveness of 6x2 axles at
between one and three percent.273 274 The NACFE report found
in OEM evaluations of 6x2 axles that the effectiveness ranged between
1.6 and 2.2 percent. NACFE also evaluated 6x2 axle tests conducted by
several fleets and found the effectiveness in the range of 2.2 to 4.6
percent. Similarly, with the increased use of double and triple
trailers, which reduce the weight on the tractor axles when compared to
a single trailer, manufacturers offer 4x2 axle configurations. The 4x2
axle configuration would have as good as or better fuel efficiency
performance than a 6x2. The agencies proposed to apply a 2.5 percent
improvement in vehicle efficiency to 6x4 and 4x2 axle configurations.
80 FR 40217-218.
---------------------------------------------------------------------------
\272\ North American Council for Freight Efficiency.
``Confidence Findings on the Potential of 6x2 Axles.'' 2014. Page
16.
\273\ Ibid.
\274\ Reinhart, T.E. (June 2015). Commercial Medium- and Heavy-
Duty Truck Fuel Efficiency Technology Study--Report #1. (Report No.
DOT HS 812 146). Washington, DC: National Highway Traffic Safety
Administration.
---------------------------------------------------------------------------
Meritor stated in their comments that their internal testing and
real world testing supported the 2.5 percent efficiency proposed by the
agencies for 6x2 axles. Meritor suggested the need to better define a
``disengageable tandem'' when the agencies discussed what we called
axle disconnect in the NPRM. Meritor recommends that a fuel efficiency
benefit of 2.0 percent be assigned to the disengageable tandem for the
55 mph and 65 mph drive cycles to account for the more limited use.
ICCT referred to two studies related to tractor-trailer
technologies in their comments.275 276 In their stakeholder
workshop, they found that the effectiveness of 6x2 axles ranged between
one and 2.5 percent.
---------------------------------------------------------------------------
\275\ Lutsey, Nic. T. Langer, S. Khan. Stakeholder Workshop on
Tractor-Trailer Efficiency Technology in the 2015-2030 Timeframe.
August 2014. Docket EPA-HQ-OAR-2014-0827.
\276\ Delgado, Oscar. N. Lutsey. Advanced Tractor-Trailer
Efficiency Technology Potential in the 2020-2030 Timeframe. April
2015. Docket EPA-HQ-OAR-2014-0827.
---------------------------------------------------------------------------
The agencies' assessments of these technologies show that the
reductions are in the range of two to three percent. For the final
rule, the agencies are simulating 6x2, 4x2, and disengageable axles
within GEM based on the manufacturer input of the axle configuration
instead of providing a fixed value for the reduction. This approach is
more technically sound because it will take into account future changes
in axle efficiency. See RIA
[[Page 73598]]
Chapter 4 for additional details regarding GEM.
(viii) Accessories and Other Technologies
Accessory Improvements: Parasitic losses from the engine come from
many systems, including the water pump, oil pump, and power steering
pump. Reductions in parasitic losses are one of the areas being
developed under the DOE SuperTruck program. As presented in the DOE
Merit reviews, Navistar stated that they demonstrated a 0.45 percent
reduction in fuel consumption through water pump improvements and 0.3
percent through oil pump improvements compared to a current engine. In
addition, Navistar showed a 0.9 percent benefit for a variable speed
water pump and variable displacement oil pump. Detroit Diesel reports a
0.5 percent benefit coming from improved water pump efficiency.\277\ It
should be noted that water pump improvements include both pump
efficiency improvement and variable speed or on/off controls. Lube pump
improvements are primarily achieved using variable displacement pumps
and may also include efficiency improvement. All of these results shown
in this paragraph are demonstrated through the DOE SuperTruck program
at a single operating point on the engine map, and therefore the
overall expected reduction of these technologies is less than the
single point result. The agencies proposed that compared to 2017 MY air
conditioners, air conditioners with improved efficiency compressors
will reduce CO2 emissions by 0.5 percent. Improvements in
accessories, such as power steering, can lead to an efficiency
improvement of one percent over the 2017 MY baseline. 80 FR 40218.
---------------------------------------------------------------------------
\277\ See the RIA Chapter 2.4 for details.
---------------------------------------------------------------------------
Navistar commented that the proposed ``electrically powered pumps
for engine cooling'' be revised to include ``electronically controlled
variable speed coolant pumps'' to align with the Preamble descriptions
and technology under development as part of the SuperTruck program.
Navistar commented that shifting to fully electronic pump creates
reliability concerns and adds additional complexity due to the size of
the necessary pumps (2+ horsepower) and that the increased power load
will require a larger alternator and upgraded wiring. Navistar
suggested that in addition to a fully electric pump, Dual Displacement
power steering should also be included as an accessory improvement
because this technology reduces parasitic loads by applying power
proportional to steering demand. ZF TRW Commercial Steering commented
that they are developing a power steering pump that uses a secondary
chamber deactivation during highway cruise operations that reduce the
pump drive torque by 30 to 40 percent. Navistar also commented that the
effectiveness for an electrified air conditioning compressor is
understated in the NPRM. Navistar's estimates are closer to 1.5 percent
when in use which will be during the use of air conditioning and during
defrost; therefore, the effective benefit should be one percent.
Daimler commented that the proposed high efficiency air conditioning
effectiveness should be refined and that other opportunities to reduce
losses, such as blend air systems, should be considered. In response to
the comments, the agencies evaluated a set of accessories that can be
designed to reduce accessory losses. Due to the complexity in
determining what qualifies as an efficient accessory, we are
maintaining the proposed language for accessories for tractors which
provides defined effectiveness values for only electric air
conditioning compressors and electric power steering pumps and coolant
pumps. Manufacturers have the option to apply for off-cycle credits for
the other types and designs of high efficiency accessories.
Intelligent Controls: Skilled drivers know how to control a vehicle
to obtain maximum fuel efficiency by, among other things, considering
road terrain. For example, the driver may allow the vehicle to slow
down below the target speed on an uphill and allow it to go over the
target speed when going downhill, to essentially smooth out the engine
demand. Electronic controls can be developed to essentially mimic this
activity. The agencies proposed to provide a two percent reduction in
fuel consumption and CO2 emissions for vehicles configured
with intelligent controls, such as predictive cruise control. 80 FR
40218. ICCT found in their workshop that opportunities exist for road
load optimization through predictive cruise, GPS, and driver feedback
that could lead to a zero to five percent improvement in fuel
consumption.\278\ Daimler commented that eCoast should also be
recognized as an intelligent control within GEM. Eaton offers similar
technology, known as Neutral Coast Mode. Neutral coast is an electronic
feature that places an automated transmission in neutral on downhill
grades which allows the engine speed to go idle speed. A fuel savings
is recognized due to the difference in engine operating conditions due
to the reduced load on the engine due to the transmission.
---------------------------------------------------------------------------
\278\ Delgado, Oscar. N. Lutsey. Advanced Tractor-Trailer
Efficiency Technology Potential in the 2020-2030 Timeframe. April
2015. Docket EPA-HQ-OAR-2014-0827.
---------------------------------------------------------------------------
Based on literature information, intelligent controls such as
predictive cruise control will reduce CO2 emissions by two
percent, and the agencies are assuming this level of improvement in
considering the level of the tractor standard. In addition, the
agencies' review of literature and confidential business information
provided based on the SuperTruck demonstration vehicles indicates that
neutral coasting will reduce fuel consumption and CO2
emissions by 1.5 percent.
Solar Load Management: The agencies received a letter from the
California Air Resources Board prior to the proposal requesting
consideration of including technologies that reduce solar heating of
the cab (to reduce air conditioning loads) in setting the Phase 2
tractor standards. Solar reflective paints and solar control glazing
technologies are discussed in RIA Chapter 2.4.9.3. The agencies
requested comment on the Air Resources Board's letter and
recommendations.\279\ The agencies received some clarifications from
ARB on our evaluation of solar technologies and some CBI from Daimler,
but not a sufficient amount of information to evaluate the baseline
level of solar control that exists in the heavy-duty market today,
determine the effectiveness of each of the solar technologies, or to
develop a definition of what qualifies as a solar control technology
that could be used in the regulations. Therefore, the agencies would
consider solar control to be a technology that manufacturers may
consider pursuing through the off-cycle credit program. As such, the
agencies did not include solar load management technologies in the
technology packages used in setting the final Phase 2 tractor standard
stringencies.
---------------------------------------------------------------------------
\279\ California Air Resources Board. Letter from Michael Carter
to Matthew Spears dated December 3, 2014. Solar Control: Heavy-Duty
Vehicles White Paper. Docket EPA-HA-OAR-2014-0827.
---------------------------------------------------------------------------
(ix) Weight Reduction
Reductions in vehicle mass lower fuel consumption and GHG emissions
by decreasing the overall vehicle mass that is moved down the road.
Weight reductions also increase vehicle payload capability which can
allow additional tons to be carried by fewer trucks consuming less fuel
and producing
[[Page 73599]]
lower emissions on a ton-mile basis. We treated such weight reduction
in two ways in Phase 1 to account for the fact that combination
tractor-trailers weigh-out approximately one-third of the time and
cube-out approximately two-thirds of the time. Therefore in Phase 1 and
also as finalized for Phase 2, one-third of the weight reduction will
be added payload in the denominator while two-thirds of the weight
reduction is subtracted from the overall weight of the vehicle in GEM.
See 76 FR 57153.
In Phase 1, we reflected mass reductions for specific technology
substitutions (e.g., installing aluminum wheels instead of steel
wheels). These substitutions were included where we could with
confidence verify the mass reduction information provided by the
manufacturer. The weight reductions were developed from tire
manufacturer information, the Aluminum Association, the Department of
Energy, SABIC and TIAX. The agencies proposed to expand the list of
weight reduction components which can be input into GEM in order to
provide the manufacturers with additional means to comply via GEM with
the combination tractor standards and to further encourage reductions
in vehicle weight. As in Phase 1, 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.\280\ The agencies however do not agree with
all of the recommendations in this report. See Section I.C.1 and RTC
Section 1 for a discussion on lifecycle emissions. 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. Additional weight
reduction would be evaluated as a potential off-cycle credit. As
described in Section III.E.2 below, the agencies discuss the weight
reduction component comments received and are adopting an expanded list
of weight reduction options which could be input into the GEM by the
manufacturers to reduce their certified CO2 emission and
fuel consumption levels.
---------------------------------------------------------------------------
\280\ American Iron and Steel Institute. ``A Cost Benefit
Analysis Report to the North American Steel Industry on Improved
Material and Powertrain Architectures for 21st Century ``Trucks.''
---------------------------------------------------------------------------
(x) Vehicle Speed Limiter
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
another technology option for compliance that is already utilized today
by some fleets (though the typical maximum speed setting is often
higher than 65 mph).
CARB recommended not giving any credit for VSLs because the
available data do not fully support whether VSLs result in real-world
fuel consumption and GHG reductions. CARB referenced Oakridge National
Laboratory's Transportation Energy Data Book, Table 5.11 that shows
CO2 emissions decrease with increased speed. CARB also
stated that the draft GEM model appears to offer up to 22 percent
credit for use of VSL set to 45 mph, which they consider to be
unreasonably high. Before including VSLs as a technology, CARB staff
suggests that EPA and NHTSA should thoroughly evaluate whether they
would result in real-world CO2 and fuel consumption
benefits.
The agencies conducted in-use tractor testing at different speeds
and in turn used this data to validate the GEM simulations of VSL, as
discussed in more detail in RIA Chapter 4. The agencies are confident
that GEM appropriately recognizes the impact of VSL on CO2
emissions and fuel consumption. The agencies have limited the range of
inputs to the VSL in Phase 2 GEM to a minimum of 55 mph to align with
the regulations in 40 CFR 1037.631 that provide exemptions for
vocational vehicles intended for off-road use. A 55 mph VSL installed
on a typical day cab tractor would reduce the composite grams of
CO2 emitted per ton-mile by seven percent. Similarly, a 55
mph VSL on a sleeper cab would reduce the composite grams of
CO2 per ton-mile emitted by 10 percent. Please see RIA
Chapter 2.8 for additional detail of technology impacts.
(xi) Hybrid Powertrains
In Phase 2, hybrid powertrains are generally considered a
conventional rather than innovative technology, especially for
vocational vehicles. However, 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 will 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 ten percent, of which six
percent is idle reduction that can be achieved (less expensively)
through the use of other idle reduction technologies.\281\ 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, the agencies did not include hybrids in
assessing stringency of the proposed tractor standard.
---------------------------------------------------------------------------
\281\ See the 2010 NAS Report, Note 229, page 128.
---------------------------------------------------------------------------
In addition to the high cost and limited utility of hybrids for
many tractor drive cycles noted above, the agencies believe that hybrid
powertrains systems for tractors may not be sufficiently developed and
the necessary manufacturing capacity put in place to base a standard on
any significant volume of hybrid tractors. Unlike hybrids for
vocational vehicles and light-duty vehicles, 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 extended idle shutdown technologies and not on the broader
energy storage and recovery systems necessary to achieve reductions
over typical tractor drive cycles. The Phase 2 sleeper cab tractor
standards instead reflect the potential for extended idle shutdown
technologies. Further, as highlighted by the 2010 NAS report, the
agencies do believe that full hybrid powertrains may have the potential
in the longer term to provide significant improvements in long haul
tractor fuel efficiency and to greenhouse gas emission reductions. With
respect to day cab tractors, the types of tractors that would receive
the benefit from hybrid powertrains would be those such as beverage
delivery tractors which could be treated as vocational vehicles through
the Special Purpose Tractor provisions (40 CFR 1037.630).
Several stakeholders commented on hybrid powertrain development for
tractor applications. Allison agreed with the agencies' overall
assessment of hybrids in tractors, as discussed in the
[[Page 73600]]
NPRM. Bendix agreed that hybrid systems for tractors have not been
focused on. Bendix believed that mild hybrid systems should be included
in GEM for credit, including stop-start and electrification of
accessories. Daimler commented that in SuperTruck, a tractor that was
tested on line haul-type highway routes, the hybrid system provided
little benefit beyond what eCoast achieved because it competes with
hybrids for energy that might be lost on hills. Overall, Daimler's view
was that hybrid systems proved too costly relative to their benefit.
Eaton stated that hybrids have not penetrated the commercial trucking
landscape, primarily due to the costs but that there may be potential
in the future for hybrids in tractor applications driven by improved
aerodynamics and lower rolling resistance tires because it would lead
to longer coasting times and higher braking loads, therefore greater
regeneration opportunities. PACCAR commented that their history with
hybrid technology was a niche market application appealing to ``green''
companies as long as incentives offset the cost of the technology.
PACCAR stated that the low sales volumes were not based on performance,
but rather on the combination of the payback of the high initial cost
based on the limited number of gallons saved in low mileage pick up-
and-delivery applications and on the concern over resale value, since
at some point in the vehicle's life the battery must be replaced at a
significant cost to the owner.
After considering the comments, the agencies are continuing the
Phase 1 approach of not including hybrid powertrains in our feasibility
analysis for Phase 2. Because the technology for tractor applications
is still under development we cannot confidently assess the
effectiveness of this technology at this point in time. In addition,
due to the high cost, limited benefit during highway driving, and
lacking any existing systems or manufacturing base, we cannot conclude
that such technology will be available for tractors in the 2021-2027
timeframe. However, manufacturers will be able to use powertrain
testing to capture the performance of a hybrid system in GEM if systems
are developed in the Phase 2 timeframe, so this technology remains a
potential compliance option (without requiring an off-cycle
demonstration).
(xii) Operational 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
Phase 2 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. In addition, the agencies have also declined to base
standard stringencies on technologies which are largely to chiefly
driver-dependent, and evaluate such potential improvements through the
off-cycle credit mechanism. See, e.g., 77 FR 62838/3 (Oct. 12, 2012).
(xiii) Consideration of Phase 1 Credits in Phase 2 Stringency Setting
The agencies requested comment regarding the treatment of Phase 1
credits, as discussed in Section I.C.1.b. See 80 FR 40251. As examples,
the agencies discussed limiting the use of Phase 1 credits in Phase 2
and factoring credit balances into the 2021 standards. Daimler
commented that allowing Phase 1 credits in Phase 2 is necessary to
smooth the transition into a new program that is very complex and that
HD manufacturers cannot change over an entire product portfolio at one
time. The agencies evaluated the status of Phase 1 credit balances in
2015 by sector. For tractors, we found that manufacturers are
generating significant credits, and that it appears that many of the
credits result from their use of an optional provision for calculating
aerodynamic drag. However, we also believe that manufacturers will
generate fewer credits in MY 2017 and later when the final Phase 1
standards begin. Still, the agencies believe that manufacturers will
have significant credit balances available to them for MYs 2021-2023,
and that much of these balances would be the result of the test
procedure provisions rather than pull ahead of any technology. Based on
confidential product plans for MYs 2017 and later, we expect this total
windfall amount to be three percent of the MY 2021 standards or more.
Therefore, the agencies are factoring in a total credit amount
equivalent to this three percent credit (i.e. three years times 1
percent per year). Thus, we are increasing the stringency of the
CO2 and fuel consumption tractor standards for MYs 2021-2023
by 1 percent to reflect these credits.
(xiv) Summary of Technology Performance
Table III-10 describes the performance levels for the range of
Class 7 and 8 tractor vehicle technologies.
Table III-10--Phase 2 Technology Inputs
--------------------------------------------------------------------------------------------------------------------------------------------------------
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
--------------------------------------------------------------------------------------------------------------------------------------------------------
Engine
--------------------------------------------------------------------------------------------------------------------------------------------------------
2021MY 2021MY 2021MY 2021MY 2021MY 2021MY 2021MY 2021MY 2021MY
11L Engine 11L Engine 11L Engine 15L Engine 15L Engine 15L Engine 15L Engine 15L Engine 15L Engine
350 HP 350 HP 350 HP 455 HP 455 HP 455 HP 455 HP 455 HP 455 HP
--------------------------------------------------------------------------------------------------------------------------------------------------------
Aerodynamics (CdA in m2)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Bin I.............................. 6.00 7.00 7.45 6.00 7.00 7.45 6.00 7.00 7.15
Bin II............................. 5.60 6.65 6.85 5.60 6.65 6.85 5.60 6.65 6.55
Bin III............................ 5.15 6.25 6.25 5.15 6.25 6.25 5.15 6.25 5.95
Bin IV............................. 4.75 5.85 5.70 4.75 5.85 5.70 4.75 5.85 5.40
Bin V.............................. 4.40 5.50 5.20 4.40 5.50 5.20 4.40 5.50 4.90
Bin VI............................. 4.10 5.20 4.70 4.10 5.20 4.70 4.10 5.20 4.40
Bin VII............................ 3.80 4.90 4.20 3.80 4.90 4.20 3.80 4.90 3.90
--------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 73601]]
Steer Tires (CRR in kg/metric ton)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Base............................... 7.8 7.8 7.8 7.8 7.8 7.8 7.8 7.8 7.8
Level 1............................ 6.6 6.6 6.6 6.6 6.6 6.6 6.6 6.6 6.6
Level 2............................ 5.7 5.7 5.7 5.7 5.7 5.7 5.7 5.7 5.7
Level 3............................ 4.9 4.9 4.9 4.9 4.9 4.9 4.9 4.9 4.9
--------------------------------------------------------------------------------------------------------------------------------------------------------
Drive Tires (CRR in kg/metric ton)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Base............................... 8.1 8.1 8.1 8.1 8.1 8.1 8.1 8.1 8.1
Level 1............................ 6.9 6.9 6.9 6.9 6.9 6.9 6.9 6.9 6.9
Level 2............................ 6.0 6.0 6.0 6.0 6.0 6.0 6.0 6.0 6.0
Level 3............................ 5.0 5.0 5.0 5.0 5.0 5.0 5.0 5.0 5.0
--------------------------------------------------------------------------------------------------------------------------------------------------------
Idle Reduction (% reduction)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Tamper Proof AESS.................. N/A N/A N/A N/A N/A N/A 4 4 4
Tamper Proof AESS with Diesel APU.. N/A N/A N/A N/A N/A N/A 4 4 4
Tamper Proof AESS with Battery APU. N/A N/A N/A N/A N/A N/A 6 6 6
Tamper Proof AESS with Automatic N/A N/A N/A N/A N/A N/A 3 3 3
Stop-Start........................
Tamper Proof AESS with FOH......... N/A N/A N/A N/A N/A N/A 3 3 3
Adjustable AESS.................... N/A N/A N/A N/A N/A N/A 1 1 1
Adjustable AESS with Diesel APU.... N/A N/A N/A N/A N/A N/A 3 3 3
Adjustable AESS with Battery APU... N/A N/A N/A N/A N/A N/A 5 5 5
Adjustable AESS with Automatic Stop- N/A N/A N/A N/A N/A N/A 5 5 5
Start.............................
Adjustable AESS with FOH........... N/A N/A N/A N/A N/A N/A 2 2 2
--------------------------------------------------------------------------------------------------------------------------------------------------------
Transmission (% reduction)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Manual............................. 0 0 0 0 0 0 0 0 0
AMT................................ 2 2 2 2 2 2 2 2 2
Auto............................... 2 2 2 2 2 2 2 2 2
Dual Clutch........................ 2 2 2 2 2 2 2 2 2
Top Gear Direct Drive.............. 2 2 2 2 2 2 2 2 2
Trans Efficiency................... 1 1 1 1 1 1 1 1 1
Neutral Idle....................... Modeled in Modeled in Modeled in Modeled in Modeled in Modeled in Modeled in Modeled in Modeled in
GEM GEM GEM GEM GEM GEM GEM GEM GEM
--------------------------------------------------------------------------------------------------------------------------------------------------------
Driveline (% reduction)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Axle Efficiency.................... 2 2 2 2 2 2 2 2 2
6x2, 6x4 Axle Disconnect or 4x2 N/A N/A N/A Modeled in Modeled in Modeled in Modeled in Modeled in Modeled in
Axle.............................. GEM GEM GEM GEM GEM GEM
Downspeed.......................... Modeled in Modeled in Modeled in Modeled in Modeled in Modeled in Modeled in Modeled in Modeled in
GEM GEM GEM GEM GEM GEM GEM GEM GEM
--------------------------------------------------------------------------------------------------------------------------------------------------------
Accessory Improvements (% reduction)
--------------------------------------------------------------------------------------------------------------------------------------------------------
A/C Efficiency..................... 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5
Electric Access.................... 1 1 1 1 1 1 1 1 1
--------------------------------------------------------------------------------------------------------------------------------------------------------
Other Technologies (% reduction)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Predictive Cruise Control.......... 2 2 2 2 2 2 2 2 2
Automated Tire Inflation System.... 1.2 1.2 1.2 1.2 1.2 1.2 1.2 1.2 1.2
Tire Pressure Monitoring System.... 1 1 1 1 1 1 1 1 1
Neutral Coast...................... 1.5 1.5 1.5 1.5 1.5 1.5 1.5 1.5 1.5
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note:
``Modeled in GEM'' means that a manufacturer will input information into GEM, such as ``Yes or No'' for neutral idle, and GEM will simulate that
condition. The values listed in the table above as percentages reflect a post-processing done within GEM after the simulation runs the drive cycles.
[[Page 73602]]
(c) Tractor Technology Adoption Rates
As explained above, tractor 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. Since Phase 1 began, this
approach also has allowed manufacturers to consolidate testing and
certification requirements. 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 adoption used to develop
the HD Phase 2 standards, NHTSA and EPA established technology adoption
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,
extended idle reduction technologies are limited to Class 8 sleeper
cabs using the reasonable assumption that day cabs are not used for
overnight hoteling. Day cabs typically idle for shorter durations
throughout the day.
A second type of constraint was applied to most other technologies
and limited their adoption based on factors reflecting the real world
operating conditions that some combination tractors encounter (so that
the standards are not based on use of technologies which do not provide
in-use benefit). This second type of constraint was applied to the
aerodynamic, tire, powertrain, vehicle speed limiter technologies, and
other technologies. NHTSA and EPA believe that within each of these
individual vehicle categories there are particular applications where
the use of the identified technologies will be either ineffective or
not technically feasible. For example, the agencies are not predicating
these standards on the use of full aerodynamic vehicle treatments on
100 percent of tractors because we know that in some applications (for
example, gravel trucks engaged in local delivery) the added weight of
the aerodynamic technologies will increase fuel consumption and hence
CO2 emissions to a greater degree than the reduction that
will be accomplished from the more aerodynamic nature of the tractor.
General considerations of needed lead time also play a significant role
in the agencies' determination of technology adoption rates.
In the development of the standards, we generally focused initially
on what technology could be adopted in 2027 MY after ten years of lead
time, consistent with the general principles discussed above. Based on
our detailed discussions with manufacturers and technology suppliers,
we can project that the vast majority of technologies will be fully
developed and in widespread use by 2027 MY. (One notable exception to
this is Rankine cycle waste heat recovery, which we project to be less
widespread in 2027). Having identified what could be achieved in 2027
MY, we projected technology steps for 2021 MY and 2024 MY to reflect
the gradual development and deployment of these technologies.
This is also consistent with how manufacturers will likely approach
complying with these standards. In general, we would expect a
manufacturer to first identify technology packages that would allow
them to meet the 2027 MY standards, then to structure a development
plan to make steady progress toward the 2027 MY standards. To some
extent, it was easier to project the technology for 2027 MY, because it
represents a maximum feasible adoption of most technologies. The
agencies' projections for MYs 2021 and 2024 are less certain because
they reflect choices manufacturers would likely make to reach the 2027
levels. As such, we have more confidence that the levels of our MYs
2021 and 2024 standards are appropriate than we do that each
manufacturer will follow our specific technology development path in
2021 MY or 2024 MY.
Table III-13, Table III-14, and Table III-15 specify the adoption
rates that EPA and NHTSA used to develop these standards.
(i) Aerodynamics Adoption Rate
The impact of aerodynamics on a tractor-trailer's efficiency
increases with vehicle speed. Therefore, the usage pattern of the
vehicle 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 proposed standards that reflect the most
aggressive aerodynamic technology application rates to this regulatory
subcategory, along with the high roof day cabs. 80 FR 40227. All of the
major manufacturers today offer at least one SmartWay sleeper cab
tractor model, which is represented as Bin III aerodynamic performance.
The agencies requested comment on the proposed aerodynamic assessment.
The agencies received significant comment from the manufacturers
regarding our assessment of aerodynamics in the most aerodynamic bins
for high roof sleeper cabs. EMA commented that the assumptions that
Class 7 and Class 8 high-roof vehicles will achieve a 35 percent
penetration rate into Bin V, a 20 percent penetration rate into Bin VI,
and a 5 percent penetration rate into Bin VII by 2027 are over-stated
and unreasonable. Volvo and EMA commented that it is impossible to
achieve the targeted aerodynamic drag reductions that ultimately are
predicated on 60 percent of tractors achieving aero bins V, VI, and
VII. According to their analysis, the manufacturers stated that it is
not possible to achieve these low drag levels with any tractor design
coupled to the non-aerodynamic test trailer prescribed in this
proposal. Caterpillar commented that given the proposed aerodynamic
testing procedures, the Phase 2 test trailer, and the lack of any audit
margin for these highly variable test processes, it is infeasible to
design tractors that can achieve bin V, and so would not be able to
achieve bins VI and VII. Caterpillar also stated that none of the
vehicles developed within the Department of Energy's SuperTruck program
are capable of meeting the proposed aerodynamic targets.
In Phase 1, the agencies determined the stringency of the tractor
standards through the use of a mix of aerodynamic bins in the
technology packages. For example, we included 10 percent Bin II, 70
percent Bin III, and 20 percent Bin IV in the high roof sleeper cab
tractor standard. The weighted average aerodynamic performance of this
technology package is equivalent to Bin III. 76 FR 57211. In
consideration of the comments, the agencies have adjusted the
aerodynamic adoption rate for Class 8 high roof sleeper cabs used to
set the final standards in 2021, 2024, and 2027 MYs (i.e., the degree
of technology adoption on which the stringency of the standard is
premised). Upon further analysis of simulation modeling of a SuperTruck
tractor with a Phase 2 reference trailer with skirts, we agree with the
manufacturers that a SuperTruck tractor technology package would only
achieve the Bin V level of CdA, as discussed above and in
RIA Chapter 2.8.2.2. Consequently, as noted above, the final standards
are not premised on any adoption of Bin VI and VII technologies.
Accordingly, we
[[Page 73603]]
determined the adoption rates in the technology packages developed for
the final rule using a similar approach as Phase 1--spanning three
aerodynamic bins and not setting adoption rates in the most aerodynamic
bin(s)--to reflect that there are some vehicles whose operation limits
the applicability of some aerodynamic technologies. We set the MY 2027
high roof sleeper cab tractor standards using a technology package that
included 20 percent of Bin III, 30 percent Bin IV, and 50 percent Bin V
reflecting our assessment of the fraction of high roof sleeper cab
tractors that we project could successfully apply these aerodynamic
packages with this amount of lead time. The weighted average of this
set of adoption rates is equivalent to a tractor aerodynamic
performance near the border between Bin IV and Bin V. We believe that
there is sufficient lead time to develop aerodynamic tractors that can
move the entire high roof sleeper cab aerodynamic performance to be as
good as or better than today's SmartWay designated tractors.
The agencies phased-in the aerodynamic technology adoption rates
within the technology packages used to determine the MY 2021 and 2024
standards so that manufacturers can gradually introduce these
technologies. The changes required for Bin V performance reflect the
kinds of improvements projected in the Department of Energy's
SuperTruck program. That program has demonstrated tractor-trailers in
2015 with significant aerodynamic technologies. For the final rule, the
agencies are projecting that truck manufacturers will be able to begin
implementing some of these aerodynamic technologies on high roof
tractors as early as 2021 MY on a limited scale. For example, in the
2021 MY technology package, the agencies have assumed that 10 percent
of high roof sleeper cabs will have aerodynamics better than today's
best tractors. This phase-in structure is consistent with the normal
manner in which manufacturers introduce new technology to manage
limited research and development budgets as well as to allow them to
work with fleets to fully evaluate in-use reliability before a
technology is applied fleet-wide. The agencies believe the phase-in
schedule will allow manufacturers to complete these normal processes.
Overall, while the agencies are now projecting slightly less benefit
from aerodynamic improvements than we did in the NPRM, the actual
aerodynamic technologies being projected are very similar to what was
projected at the time of NPRM (however, these vehicles fall into Bin V
in the final rule, instead of Bin VI and VII in the NPRM). Importantly,
our averaging, banking and trading provisions provide manufacturers
with the flexibility (and incentive) to implement these technologies
over time even though the standard changes in a single step.
The agencies also received comment regarding our aerodynamic
assessment of the other tractor subcategories. Daimler commented that
due to their shorter length, day cabs are more difficult to make
aerodynamic than sleeper cabs, and that the bin boundaries and adoption
rates should reflect this. EMA commented that the assumed aerodynamic
performance improvements to be achieved by day cab and mid and low-roof
vehicles are over-estimated by at least one bin. Daimler commented that
the agencies should adjust the average bin down in recognition of the
fact that mid/low-roof vehicles should have lower penetration rates of
aerodynamic vehicles to reflect market needs, reflecting these
vehicles' use in rough environments or in hauling non-aerodynamic
trailers.
Aerodynamic improvements through new tractor designs and the
development of new aerodynamic components is an inherently slow and
iterative process. The agencies recognize that there are tractor
applications that 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.\282\ 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 will
prevent 100 percent adoption of more advanced aerodynamic technologies
for all of the tractor regulatory subcategories and developed standards
with new penetration rates reflecting that these vehicles spend less
time at highway speeds. For the final rule, the agencies evaluated the
certification data to assess how the aerodynamic performance of high
roof day cabs compare to high roof sleeper cabs. In 2014, the high roof
day cabs on average are certified to one bin lower than the high roof
sleeper cabs.\283\ Consistent with the public comments, and the
certification data, the aerodynamic adoption rates used to develop the
final Phase 2 standards for the high roof day cab regulatory
subcategories are less aggressive than for the Class 8 sleeper cab high
roof tractors. In addition, the agencies are also accordingly reducing
the adoption rates in the highest bins for low and mid roof tractors to
follow the changes made to the high roof subcategories because we
neither proposed nor expect the aerodynamics of a low or mid roof
tractor to be better than a high roof tractor.
---------------------------------------------------------------------------
\282\ U.S. Department of Energy. Transportation Energy Data
Book, Edition 28-2009. Table 5.7.
\283\ U.S. EPA. Memo to Docket. Coefficient of Rolling
Resistance and Coefficient of Drag Certification Data for Tractors.
See Docket EPA-HQ-OAR-2014-0827.
---------------------------------------------------------------------------
(ii) Low Rolling Resistance Tire Adoption Rate
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 proposed standards should not be
premised on 100 percent application of Level 3 tires in all tractor
segments given the potential interference with vehicle utility that
could result. 80 FR 40223.
Several stakeholders commented about the level of rolling
resistance used in setting the proposed level of tractor stringencies
because the agencies used a single level for all tractor subcategories.
ATA, First Industries, National Association of Manufacturers, PACCAR,
Navistar and Daimler commented that the agencies erred by using the
same rolling resistance for all types of day and sleeper cab tractors.
They stated that the tire stringency levels should account for fleet
and class variations and different duty-cycle needs. Caterpillar stated
that tires need to meet demands of all conditions, including
[[Page 73604]]
unpaved roads, sloped loading docks which are frequently not treated in
winter conditions. Caterpillar also stated that tire casings must have
adequate durability to allow for as many as five retreads. NADA
commented current LRRT tractor adoption rates are low and are not
expected to increase significantly any time soon unless significant
improvements in design are forthcoming and that there is no realistic
means of ensuring that customers (or subsequent owners) will continue
to use LRR tires. OOIDA commented that the LRR tire may be beneficial
on flat terrain, but may pose a safety concern in many geographical
regions. OOIDA also stated that a LRR tire achieves much of its
potential fuel savings benefit by reducing the very component of
friction or resistance that a truck driver may rely upon. PACCAR
commented that customers with low- and mid-roof configurations
typically operate more in urban areas where tires must withstand the
abuse of curbs and other obstacles or in more on/off road conditions
that are typical for flatbed, tanker, and low-boy operations, which use
the low and mid-roof configuration vehicles. PACCAR stated that the
tires for low and mid roof tractors vehicles are designed with
additional side wall protection and generally have a higher coefficient
of rolling resistance. Volvo commented with respect to tractor
penetration and stringency setting the agencies show penetration of
Level 3 tires starting in MY 2021. Volvo stated that they continue to
hear customer feedback that low rolling resistance tires often lack
adequate traction under many of the demanding conditions that trucks
and tractors experience, such as snow and off-road. Schneider commented
that fleet uses low rolling resistance tires on dual wheels for the
majority of the standard fleet while using wide-based single tires for
weight sensitive portions of the fleet. Schneider commented that
regulations should not force the use of wide based single tires based
solely on rolling resistance advantages without considering the overall
performance because it may increase waste, the number of scrapped tire
casings and landfill requirements. The commenter's view is that LRR
dual tires are very comparable to wide based single tires (WBS) tires
in fuel efficiency while providing better overall operating and
economic efficiency.
For the final rulemaking, the agencies evaluated the tire rolling
resistance levels in the Phase 1 certification data.\284\ We found that
high roof sleeper cabs are certified today with steer tire rolling
resistance levels that ranged between 4.9 and 7.6 kg/ton and with drive
tires ranging between 5.1 and 9.8 kg/ton. In the same analysis, we
found that high roof day cabs are certified with rolling resistance
levels ranging between 4.9 and 9.0 kg/ton for steer tires and between
5.1 and 9.8 kg/ton for drive tires. This range spans the baseline
through Level 3 rolling resistance performance levels. Therefore, for
the final rule we took an approach similar to the one taken in Phase 1
and proposed in Phase 2 that considers adoption rates across a wide
range of tire rolling resistance levels to recognize that operators may
have different needs. 76 FR 57211 and 80 FR 40227. The adoption rates
for the technology packages used to determine the MY 2027 standards for
each high roof tractor subcategory are shown in Table III-15.
---------------------------------------------------------------------------
\284\ Memo to Docket. Coefficient of Rolling Resistance and
Coefficient of Drag Certification Data for Tractors. Docket EPA-HQ-
OAR-2014-0827.
---------------------------------------------------------------------------
In our analysis of the Phase 1 certification data, we found that
the drive tires on low and mid roof sleeper cab tractors on average had
10 to 17 percent higher rolling resistance than the high roof sleeper
cabs. But we found only a minor difference in rolling resistance of the
steer tires between the tractor subcategories. Based on comments
received and further consideration of our own analysis of the
difference in tire rolling resistance levels that exist today in the
certification data, the agencies are adopting Phase 2 standards using a
technology pathway that utilizes higher rolling resistance levels for
low and mid roof tractors than the levels used to set the high roof
tractor standards. This is also consistent with the approach that we
took in setting the Phase 1 tractor standards. 76 FR 57211. In
addition, the final rule reflects a reduction in Level 3 adoption rates
for low and mid roof tractors from 25 percent in MY 2027 used at
proposal (80 FR 40227) to zero percent adoption rate. The technology
packages developed for the low and mid roof tractors used to determine
the stringency of the MY 2027 standards in the final rule do not
include any adoption rate of Level 3 drive tires to recognize the
special needs of these applications, consistent with the comments noted
above raising concerns about applications that limit the use of low
rolling resistance tires.
The agencies phased-in the low rolling resistance tire adoption
rates within the technology packages used to determine the MY 2021 and
2024 standards so that manufacturers can gradually introduce these
technologies. In addition, the levels of rolling resistance used in all
of the technology packages are achievable with either dual or wide
based single tires, so the agencies are not forcing one technology over
another. The adoption rates for the technology packages used to
determine the MY 2021, 2024, and 2027 standards for each tractor
subcategory are shown in Table III-13, Table III-14, and Table III-15.
(iii) Tire Pressure Monitoring and Automatic Tire Inflation System
(ATIS) Adoption Rate
The agencies used a 20 percent adoption rate of ATIS in MY 2021 and
a 40 percent adoption rate in setting the proposed Phase 2 MY 2024 and
2027 tractor standards. 80 FR 40227.
ATA commented that as of 2012, roughly one percent of tractors used
ATIS. Caterpillar and First Industries stated that the agencies should
not force ATIS into the market by assuming any penetration rate. EMA
commented that the assumption that 40 percent of all Class 7 and 8
vehicles will utilize automated tire inflation systems lacked support
and failed to account for the prevalence of tire inflation monitoring
systems. NADA stated that they can support a 40 percent tractor
adoption rate for MY 2027 if TPMS are considered. Volvo commented that
given the poor reliability of past ATIS systems, they are skeptical of
supplier's claims of current or future reliability improvements to
these systems. Volvo stated that fleets are even more skeptical than
truck OEMs, as an ATIS air leak results in increased fuel consumption
due to a compressor cycling more frequently and also in potentially
significant downtime of the vehicle. Volvo also commented that to
incentivize truck operators to maintain tire pressure on vehicles
equipped with a TPMS system, fleets have the ability to monitor fuel
consumption remotely, including the ability to identify causes for
increased fuel consumption which would be expected to motivate drivers
to properly maintain tire pressure on TPMS equipped vehicles.
The agencies find the comments related to a greater acceptance of
TPMS in the tractor market to be persuasive. However, available
information indicates that it is feasible to utilize either TPMS or
ATIS to reduce the prevalence on underinflated tires in-use on all
tractors. As a result, we are finalizing tractor standards that are
predicated on the performance of a mix of TPMS and ATIS adoption rates
in all tractor subcategories. The agencies are
[[Page 73605]]
using adoption rates of 30 percent of ATIS and 70 percent of TPMS in
the technology packages used in setting the final Phase 2 MY 2027
tractor standards. This represents a lower adoption rate of ATIS than
used in the NPRM, but the agencies have added additional adoption rate
of TPMS because none of the comments or available information disputed
the ability to use it on all tractors. The agencies have developed
technology packages for setting the 2021 and 2024 MY standards which
reflect a phase in of adoption rates of each of these technologies. In
2021 MY, the adoption rates consist of 20 percent TPMS and 20 percent
ATIS. In 2024 MY, the adoption rates are 50 percent TPMS and 25 percent
ATIS.
(iv) Idle Reduction Technology Adoption 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. There are several different
technologies available to reduce idling. These include APUs, diesel
fired heaters, and battery powered units. Our discussions with
manufacturers prior to the Phase 2 NPRM indicated that idle
technologies are sometimes installed in the factory, but that it is
also a common practice to have the units installed after the sale of
the truck. We want 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. We proposed to continue the Phase 1
approach into Phase 2 where we recognize only idle emission reduction
technologies that include a tamper-proof automatic engine shutoff
system (AESS) with some override provisions.\285\ However, we welcomed
comment on other approaches that will appropriately quantify the
reductions that will be experienced in the real world. 80 FR 40224.
---------------------------------------------------------------------------
\285\ The agencies are retaining the HD Phase 1 AESS override
provisions included in 40 CFR 1037.660(b) for driver safety.
---------------------------------------------------------------------------
We used an overall 90 percent adoption rate of tamper-proof AESS
for Class 8 sleeper cabs in setting the proposed MY 2024 and 2027
standards. Id. The agencies stated in the Phase 2 NPRM that we were
unaware of reasons why AESS with extended idle reduction technologies
could not be applied to this high fraction of tractors with a sleeper
cab, except those deemed a vocational tractor, in the available lead
time.
EMA, Volvo, Daimler, and Navistar commented that the agencies
should consider that customers are not accepting the tamper-proof AESS
in Phase 1, therefore the adoption rates included in the proposal were
too high and that resale concerns remain a significant issue for
customers. PACCAR and EMA commented that the proposed 90 percent
penetration rate of tamper-proof AESS is unachievable. Many comments
also focused on the need for adjustable AESS. OOIDA commented that 90
percent APU adoption is unreasonable and that the 400 pound weight
exemption for APUs is not provided in California, Washington DC,
Hawaii, Kentucky, Massachusetts, North Carolina, and Rhode Island.
OOIDA also raised concerns about situations where an AESS could have
negative consequences--such as team drivers where the co-driver was
left asleep in the berth while the truck was shut off, or drivers with
certain medical conditions, or pets.
The agencies find the comments regarding the concerns for using 90
percent adoption rates of tamper-proof AESS to be persuasive. For the
final rule, the agencies developed a menu of idle reduction
technologies that include both tamper-proof and adjustable AESS (as
discussed in Section III.D.1.b) that are recognized at different levels
of effectiveness in GEM. As discussed in the discussion of tractor
baselines (Section III.D.1.a), the latest NACFE confidence report found
that 96 percent of HD vehicles are equipped with adjustable automatic
engine shutdown systems.\286\ Therefore, the agencies built this level
of idle reduction into the baseline for sleeper cab tractors. Due to
the high percentage acceptance of adjustable AESS today, the agencies
project that by 2027 MY it is feasible for 100 percent of sleeper cabs
to contain some type of AESS and idle reduction technology to meet the
hoteling needs of the driver. However, we recognize that there are a
variety of idle reduction technologies that meet the various needs of
specific customers and not all customers will select diesel powered
APUs due to the cost or weight concerns highlighted in the comments.
Therefore, we developed an idle reduction technology package for each
MY that reflects this variety. The idle reduction packages developed
for the final rule contain lower AESS adoption rates than used at
proposal. The AESS used during the NPRM assumed that it also included a
diesel powered APU in terms of determining the effectiveness and costs.
In the final rule, the idle reduction technology mix actually has an
overall lower cost (even after increasing the diesel APU technology
cost estimate for the final rule) than would have been developed for
the final rule. In addition, the stringency of the tractor standards
are not affected because the higher penetration rate of other idle
reduction technologies, which are not quite as effective, but will be
deployed more. We developed the technology package to set the 2027 MY
sleeper cab tractor standards that includes 15 percent adoption rate of
adjustable AESS only, 40 percent of adjustable AESS with a diesel
powered APU, 15 percent adjustable AESS with a battery APU, 15 percent
adjustable AESS with automatic stop/start, and 15 percent adjustable
AESS with a fuel operated heater. We continued the same approach of
phasing in different technology packages for the 2021 and 2024 MY
standards, though we included some type of idle reduction on 100
percent of the sleeper cab tractors. The 2021 MY technology package had
a higher adoption rate of adjustable AESS with no other idle reduction
technology and lower adoption rates of adjustable AESS with other idle
reduction technologies. Details on the idle reduction technology
adoption rates for the MY 2021 and 2024 standards are included in Table
III-13 and Table III-14.
---------------------------------------------------------------------------
\286\ North American Council for Freight Efficiency. Confidence
Report: Idle-Reduction Solutions. 2014. Page 13.
---------------------------------------------------------------------------
(v) Transmission Adoption Rates
The agencies' proposed standards included a 55, 80, and 90 percent
adoption rate of automatic, automated manual, and dual clutch
transmissions in MYs 2021, 2024, and 2027 respectively. 80 FR 40225-7.
The agencies did not receive any comments regarding these proposed
transmission adoption rates, and have not found any other information
suggesting a change in approach. Therefore, we are including the same
level of adoption rates in setting the final rule standards. The MY
2021 and 2024 standards are likewise premised on the same adoption
rates of these transmission technologies as at proposal.
The agencies have added neutral idle as a technology input to GEM
for Phase 2 in the final rulemaking. The TC10 that was tested by the
agencies for the final rule included this technology. Therefore, we
projected that neutral idle would be included in all of the automatic
transmissions and therefore the adoption rates of neutral idle match
the adoption rates of the automatic transmission in each of the MYs.
Transmissions with direct drive as the top gear and numerically
lower axles are
[[Page 73606]]
better suited for applications with primarily highway driving with flat
or low rolling hills. Therefore, this technology is not appropriate for
use in 100 percent of tractors. The agencies proposed standards
reflected the projection that 50 percent of the tractors would have
direct drive in top gear in MYs 2024 and 2027. 80 FR 40226-7. The
agencies did not receive any comments regarding the adoption rates of
transmissions with direct drive in those MYs. We therefore are
including the same level of adoption rates in setting the final rule
standards for MYs 2024 and 2027. Transmissions with direct drive top
gears exist in the market today, therefore, the agencies determined it
is feasible to also include this technology in the package for setting
the 2021 MY standards. For the final rule, the agencies included a 20
percent adoption rate of direct drive in the 2021 MY technology
package.
The agencies received comments supporting establishing a
transmission efficiency test that measures the efficiency of each
transmission gear and could be input into GEM. In the final rule, the
agencies are adopting Phase 2 standards that project that 20, 40, and
70 percent of the AMT and DCT transmissions will be tested and achieve
a fuel consumption and CO2 emissions reduction of one
percent in MYs 2021, 2024, and 2027, respectively.
The adoption rates for the technology packages used to determine
the MY 2021, 2024, and 2027 standards for each tractor subcategory are
shown in Table III-13, Table III-14, and Table III-15.
(vi) Engine Downspeeding Adoption Rates
The agencies proposed to include lower final drive ratios in
setting the Phase 2 standards to account for engine downspeeding. In
the NPRM, we used a transmission top gear ratio of 0.73 and baseline
drive axle ratio of 3.70 in 2017 going down to a rear axle ratio of
3.55 in 2021 MY, 3.36 in 2024 MY, and 3.20 in 2027 MY. 80 FR 40228-30.
UCS commented that downspeeding was only partially captured as
proposed. The agencies also received additional information from
vehicle manufacturers and axle manufacturers that we believe supports
using lower numerical drive axle ratios in setting the final Phase 2
standards for sleeper cabs that spend more time on the highway than day
cabs, directionally consistent with the UCS comment. For the final
rules, the agencies have used 3.70 in the baseline and 3.16 for sleeper
cabs and 3.21 for day cabs in MY 2027 to account for continued
downspeeding opportunities. The final drive ratios used for setting the
other model years are shown in Table III-11. These values represent the
``average'' tractor in each of the MYs, but there will be a range of
final drive ratios that contain more aggressive engine downspeeding on
some tractors and less aggressive on others.
Table III-11--Final Drive Ratio for Tractor Technology Packages
----------------------------------------------------------------------------------------------------------------
Transmission
Model year Rear axle top gear Final drive
ratio ratio ratio
----------------------------------------------------------------------------------------------------------------
Sleeper Cabs
----------------------------------------------------------------------------------------------------------------
2018............................................................ 3.70 0.73 2.70
2021............................................................ 3.31 0.73 2.42
2024............................................................ 3.26 0.73 2.38
2027............................................................ 3.16 0.73 2.31
----------------------------------------------------------------------------------------------------------------
Day Cabs
----------------------------------------------------------------------------------------------------------------
2018............................................................ 3.70 0.73 2.70
2021............................................................ 3.36 0.73 2.45
2024............................................................ 3.31 0.73 2.42
2027............................................................ 3.21 0.73 2.34
----------------------------------------------------------------------------------------------------------------
(vii) Drivetrain Adoption Rates
The agencies' proposed standards included 6x2 axle adoption rates
in high roof tractors of 20 percent in 2021 MY and 60 percent in MYs
2024 and 2027. Because 6x2 axle configurations could raise concerns of
traction, the agencies proposed standards that reflected lower adoption
rates of 6x2 axles in low and mid roof tractors recognizing that these
tractors may require some unique capabilities. The agencies proposed
standards for low and mid roof tractors that included 6x2 axle adoption
rates of 10 percent in MY 2021 and 20 percent in MYs 2024 and 2027. 80
FR 40225-7.
ATA and others commented that limitations to a high penetration
rate of 6x2 axles include curb cuts, other uneven terrain features that
could expose the truck to traction issues, lower residual values,
traction issues, driver dissatisfaction, tire wear, and the legality of
their use. The commenters stated that recent surveys indicate current
market penetration rates of new line-haul 6x2 tractor sales are only in
the range of two percent, according to a NACFE confidence report. The
commenters also stated that while recent improvements in traction
control systems can automatically shift weight for short periods of
time from the non-driving axle to the driving axle during low-traction
events, concerns remain over the impacts to highways caused by such
shifting of weight between axles. EMA, ATA, OOIDA, Volvo, Daimler,
PACCAR, First Industries, National Association of Manufacturers,
Caterpillar, and others discussed that 6x2 axles are not legal in all
U.S. states and Canadian provinces. Caterpillar and Daimler also stated
the agencies should not assume more than 5 percent penetration rates of
6x2 through 2027. EMA forecasts a 6x2 penetration rate of less than 5
percent.
Upon further consideration, the agencies have reduced the adoption
rate of 6x2 axles and projected a 30 percent adoption rate in the
technology package used to determine the Phase 2 2027 MY standards. The
2021 MY standards include an adoption rate of 15 percent and the 2024
MY standards include an adoption rate of 25 percent 6x2 axles. This
adoption rate represents a combination of liftable 6x2 axles (which as
noted in ATA's comments are allowed in all states but Utah, and Utah is
expected to revise their law) and 4x2 axles. In addition, it is worth
recognizing that state regulations related to 6x2 axles could change
significantly
[[Page 73607]]
over the next ten years. It is also worth noting that the issue related
to the legality of 6x2 axles was not mentioned as a barrier to adoption
by fleets in the NACFE Confidence Report on 6x2 axles.\287\
---------------------------------------------------------------------------
\287\ North American Council for Freight Efficiency.
``Confidence Findings on the Potential of 6x2 Axles.'' 2014. Page
16.
---------------------------------------------------------------------------
In the NPRM, the agencies projected that 20 percent of 2021 MY and
40 percent of the 2024 and 2027 MY axles would use low friction axle
lubricants. 80 FR 40225-7. In the final rule, we are requiring that
manufacturers conduct an axle efficiency test if they want to include
the benefit of low friction lubricant or other axle design improvements
when certifying in GEM. The axle efficiency test will be optional, but
will allow manufacturers to reduce CO2 emissions and fuel
consumption if the manufacturers have improved axle gear designs and/or
mandatory use of low friction lubricants. The agencies' assessment of
axle improvements found that 80 percent of the axles built in MY 2027
could be two percent more efficient than a 2017 baseline axle. Because
it will take time for axle manufacturers to make improvements across
the majority of their product offerings, the agencies phased in the
amount of axle efficiency improvements in the technology packages in
setting the 2021 and 2024 MY standards to include 30 and 65 percent
adoption rates, respectively.
(viii) Accessories and Other Technology Adoption Rates
In the NPRM, the agencies projected adoption rates as show in Table
III-12. 80 FR 40227. The agencies are adopting the same level of
adoption rates for setting the final Phase 2 standards because we did
not receive any comments or new data to support a change in the
adoption rates used in the proposal.
Table III-12--Adoption Rates Used in the Tractor Technology Packages in the NPRM
----------------------------------------------------------------------------------------------------------------
Higher efficiency
Model year Predictive cruise Electrified air conditioning
control (%) accessories (%) (%)
----------------------------------------------------------------------------------------------------------------
2021.......................................... 20 10 10
2024.......................................... 40 20 20
2027.......................................... 40 30 30
----------------------------------------------------------------------------------------------------------------
(ix) Weight Reduction Technology Adoption Rates
In the NPRM, the agencies proposed to allow manufacturers to use
tractor weight reduction to comply with the standards. 80 FR 40223. A
number of organizations commented generally in favor of the inclusion
of light weight components for compliance, including the Aluminum
Association, Meritor, American Die Casting Association, and the
American Chemistry Council saying light-weight materials are durable
and their use in heavy-duty vehicles can reduce weight and fuel
consumption.
Unlike in HD Phase 1, the agencies proposed the 2021 through 2027
model year tractor standards without using weight reduction as a
technology to demonstrate the feasibility of the standards. The ICCT
stated that the agencies should include light weight components in
setting the stringency of the standards, citing an ICCT tractor and
trailer study showing specific light weight benefits for tractor
components. Meritor argued that weight reduction should not be included
in setting stringency, given the high cost to benefit ratio for weight
reduction.
The agencies view weight reduction as a technology with a high cost
that offers a small benefit in the tractor sector. For example, our
estimate of a 400 pound weight reduction will cost $2,050 (2012$) in
2021 MY, but offers a 0.3 percent reduction in fuel consumption and
CO2 emissions. The agencies are excluding the use of weight
reduction components for the tractor stringency calculation due to the
high cost associated with this technology. As noted above, Meritor in
their comments expressed agreement with this approach.
(x) Vehicle Speed Limiter Adoption Rate
Consistent with Phase 1, we proposed to continue the approach where
vehicle speed limiters may be used as a technology to meet the Phase 2
standard. See 80 FR 40224. In setting the Phase 2 proposed standard,
however, we assumed a zero percent adoption rate of vehicle speed
limiters. 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. To date, the compliance data provided by
manufacturers indicate that none of the tractor configurations include
a tamper-proof VSL setting less than 65 mph.
At this point the agencies are not in a position to determine in
how many additional situations use of a VSL will result in similar
benefits to overall efficiency or how many customers will be willing to
accept a tamper-proof VSL setting. Although we believe vehicle speed
limiters are a simple, easy to implement, and inexpensive technology,
we want to leave the use of vehicle speed limiters to the truck
purchaser. In doing so, we are providing another means of meeting the
standard that can lower compliance costs and provide a more optimal
vehicle solution for some truck fleets or owners. For example, a local
beverage distributor may operate trucks in a distribution network of
primarily local roads. Under those conditions, aerodynamic fairings
used to reduce aerodynamic drag provide little benefit due to the low
vehicle speed while adding additional mass to the vehicle. A vehicle
manufacturer could choose to install a VSL set at an optimized speed
for its intended application and use this technology to assist in
complying with our program all at a lower cost to the ultimate tractor
purchaser.\288\
---------------------------------------------------------------------------
\288\ Ibid.
\288\ 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).
---------------------------------------------------------------------------
We welcomed comment on whether the use of a VSL would require a
fleet to deploy additional tractors, but did not receive responsive
comment. ARB stated that if EPA and NHTSA decide to give credit in
Phase 2 GEMs for VSLs, VSL benefit should also be reflected in the
standard's stringency. Daimler supported the approach of not including
VSLs in setting the stringency because of the resistance in the market
to accept tamperproof VSLs. OOIDA commented that the agencies must
consider the significant negative consequences of VSLs, such as safety
impact from
[[Page 73608]]
differential speeds between light duty vehicles and trucks.
After considering the comments, we still could not make a
determination regarding the reasonableness of setting a standard based
on a particular VSL adoption rate, for the same reasons articulated at
proposal. Therefore, the agencies are not premising these final Phase 2
standards on use of VSL, and instead will continue to rely on the
industry to select VSL when circumstances are appropriate for its use
(in which case there is an input in GEM reflecting VSL efficiency).
(d) Summary of the Adoption Rates Used To Determine the Final Phase 2
Tractor Standards
Table III-13 through Table III-16 provide the adoption rates of
each technology broken down by weight class, cab configuration, and
roof height.
Table III-13--Technology Adoption Rates for Class 7 and 8 Tractors for Determining the 2021 MY Standards
--------------------------------------------------------------------------------------------------------------------------------------------------------
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
--------------------------------------------------------------------------------------------------------------------------------------------------------
Engine
--------------------------------------------------------------------------------------------------------------------------------------------------------
2021 MY 11L 2021 MY 11L 2021 MY 11L 2021 MY 15L 2021 MY 15L 2021 MY 15L 2021 MY 15L 2021 MY 15L 2021 MY 15L
engine 350 engine 350 engine 350 engine 455 engine 455 engine 455 engine 455 engine 455 engine 455
HP HP HP HP HP HP HP HP HP
--------------------------------------------------------------------------------------------------------------------------------------------------------
Aerodynamics
--------------------------------------------------------------------------------------------------------------------------------------------------------
Bin I.............................. 10% 10% 0% 10% 10% 0% 0% 10% 0%
Bin II............................. 10% 10% 0% 10% 10% 0% 20% 10% 0%
Bin III............................ 70% 70% 60% 70% 70% 60% 60% 70% 60%
Bin IV............................. 10% 10% 35% 10% 10% 35% 20% 10% 30%
Bin V.............................. 0% 0% 5% 0% 0% 5% 0% 0% 10%
Bin VI............................. 0% 0% 0% 0% 0% 0% 0% 0% 0%
Bin VII............................ 0% 0% 0% 0% 0% 0% 0% 0% 0%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Steer Tires
--------------------------------------------------------------------------------------------------------------------------------------------------------
Base............................... 5% 5% 5% 5% 5% 5% 5% 5% 5%
Level 1............................ 35% 35% 35% 35% 35% 35% 35% 35% 35%
Level 2............................ 50% 50% 50% 50% 50% 50% 50% 50% 50%
Level 3............................ 10% 10% 10% 10% 10% 10% 10% 10% 10%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Drive Tires
--------------------------------------------------------------------------------------------------------------------------------------------------------
Base............................... 15% 15% 5% 15% 15% 5% 15% 15% 5%
Level 1............................ 35% 35% 35% 35% 35% 35% 35% 35% 35%
Level 2............................ 50% 50% 50% 50% 50% 50% 50% 50% 50%
Level 3............................ 0% 0% 10% 0% 0% 10% 0% 0% 10%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Idle Reduction
--------------------------------------------------------------------------------------------------------------------------------------------------------
Tamper Proof AESS.................. N/A N/A N/A N/A N/A N/A 0% 0% 0%
Tamper Proof AESS with Diesel APU.. N/A N/A N/A N/A N/A N/A 0% 0% 0%
Tamper Proof AESS with Battery APU. N/A N/A N/A N/A N/A N/A 0% 0% 0%
Tamper Proof AESS with Automatic N/A N/A N/A N/A N/A N/A 0% 0% 0%
Stop-Start........................
Tamper Proof AESS with FOH......... N/A N/A N/A N/A N/A N/A 0% 0% 0%
Adjustable AESS.................... N/A N/A N/A N/A N/A N/A 40% 40% 40%
Adjustable AESS with Diesel APU.... N/A N/A N/A N/A N/A N/A 30% 30% 30%
Adjustable AESS with Battery APU... N/A N/A N/A N/A N/A N/A 10% 10% 10%
Adjustable AESS with Automatic Stop- N/A N/A N/A N/A N/A N/A 10% 10% 10%
Start.............................
Adjustable AESS with FOH........... N/A N/A N/A N/A N/A N/A 10% 10% 10%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Transmission
--------------------------------------------------------------------------------------------------------------------------------------------------------
Manual............................. 0% 0% 0% 0% 0% 0% 0% 0% 0%
AMT................................ 40% 40% 40% 40% 40% 40% 40% 40% 40%
Auto............................... 10% 10% 10% 10% 10% 10% 10% 10% 10%
Dual Clutch........................ 5% 5% 5% 5% 5% 5% 5% 5% 5%
Top Gear Direct Drive.............. 20% 20% 20% 20% 20% 20% 20% 20% 20%
Trans. Efficiency.................. 20% 20% 20% 20% 20% 20% 20% 20% 20%
Neutral Idle....................... 10% 10% 10% 10% 10% 10% 10% 10% 10%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Driveline
--------------------------------------------------------------------------------------------------------------------------------------------------------
Axle Efficiency.................... 30% 30% 30% 30% 30% 30% 30% 30% 30%
6x2, 6x4 Axle Disconnect or 4x2 N/A N/A N/A 15% 15% 15% 15% 15% 15%
Axle..............................
Downspeed (Rear Axle Ratio)........ 3.36 3.36 3.36 3.36 3.36 3.36 3.31 3.31 3.31
--------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 73609]]
Accessory Improvements
--------------------------------------------------------------------------------------------------------------------------------------------------------
A/C Efficiency..................... 10% 10% 10% 10% 10% 10% 10% 10% 10%
Electric Access.................... 10% 10% 10% 10% 10% 10% 10% 10% 10%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Other Technologies
--------------------------------------------------------------------------------------------------------------------------------------------------------
Predictive Cruise Control.......... 20% 20% 20% 20% 20% 20% 20% 20% 20%
Automated Tire Inflation System.... 20% 20% 20% 20% 20% 20% 20% 20% 20%
Tire Pressure Monitoring System.... 20% 20% 20% 20% 20% 20% 20% 20% 20%
Neutral Coast...................... 0% 0% 0% 0% 0% 0% 0% 0% 0%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table III-14--Technology Adoption Rates for Class 7 and 8 Tractors for Determining the 2024 MY Standards
--------------------------------------------------------------------------------------------------------------------------------------------------------
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
--------------------------------------------------------------------------------------------------------------------------------------------------------
Engine
--------------------------------------------------------------------------------------------------------------------------------------------------------
2024 MY 11L 2024 MY 11L 2024 MY 11L 2024 MY 15L 2024 MY 15L 2024 MY 15L 2024 MY 15L 2024 MY 15L 2024 MY 15L
engine 350 engine 350 engine 350 engine 455 engine 455 engine 455 engine 455 engine 455 engine 455
HP HP HP HP HP HP HP HP HP
--------------------------------------------------------------------------------------------------------------------------------------------------------
Aerodynamics
--------------------------------------------------------------------------------------------------------------------------------------------------------
Bin I.............................. 0% 0% 0% 0% 0% 0% 0% 0% 0%
Bin II............................. 20% 20% 0% 20% 20% 0% 20% 20% 0%
Bin III............................ 60% 60% 40% 60% 60% 40% 60% 60% 40%
Bin IV............................. 20% 20% 40% 20% 20% 40% 20% 20% 40%
Bin V.............................. 0% 0% 20% 0% 0% 20% 0% 0% 20%
Bin VI............................. 0% 0% 0% 0% 0% 0% 0% 0% 0%
Bin VII............................ 0% 0% 0% 0% 0% 0% 0% 0% 0%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Steer Tires
--------------------------------------------------------------------------------------------------------------------------------------------------------
Base............................... 5% 5% 5% 5% 5% 5% 5% 5% 5%
Level 1............................ 25% 25% 15% 25% 25% 15% 25% 25% 15%
Level 2............................ 55% 55% 60% 55% 55% 60% 55% 55% 60%
Level 3............................ 15% 15% 20% 15% 15% 20% 15% 15% 20%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Drive Tires
--------------------------------------------------------------------------------------------------------------------------------------------------------
Base............................... 10% 10% 5% 10% 10% 5% 10% 10% 5%
Level 1............................ 25% 25% 15% 25% 25% 15% 25% 25% 15%
Level 2............................ 65% 65% 60% 65% 65% 60% 65% 65% 60%
Level 3............................ 0% 0% 20% 0% 0% 20% 0% 0% 20%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Idle Reduction
--------------------------------------------------------------------------------------------------------------------------------------------------------
Tamper Proof AESS.................. N/A N/A N/A N/A N/A N/A 0% 0% 0%
Tamper Proof AESS with Diesel APU.. N/A N/A N/A N/A N/A N/A 0% 0% 0%
Tamper Proof AESS with Battery APU. N/A N/A N/A N/A N/A N/A 0% 0% 0%
Tamper Proof AESS with Automatic N/A N/A N/A N/A N/A N/A 0% 0% 0%
Stop-Start........................
Tamper Proof AESS with FOH......... N/A N/A N/A N/A N/A N/A 0% 0% 0%
Adjustable AESS.................... N/A N/A N/A N/A N/A N/A 30% 30% 30%
Adjustable AESS with Diesel APU.... N/A N/A N/A N/A N/A N/A 40% 40% 40%
Adjustable AESS with Battery APU... N/A N/A N/A N/A N/A N/A 10% 10% 10%
Adjustable AESS with Automatic Stop- N/A N/A N/A N/A N/A N/A 10% 10% 10%
Start.............................
Adjustable AESS with FOH........... N/A N/A N/A N/A N/A N/A 10% 10% 10%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Transmission
--------------------------------------------------------------------------------------------------------------------------------------------------------
Manual............................. 0% 0% 0% 0% 0% 0% 0% 0% 0%
AMT................................ 50% 50% 50% 50% 50% 50% 50% 50% 50%
Auto............................... 20% 20% 20% 20% 20% 20% 20% 20% 20%
[[Page 73610]]
Dual Clutch........................ 10% 10% 10% 10% 10% 10% 10% 10% 10%
Top Gear Direct Drive.............. 50% 50% 50% 50% 50% 50% 50% 50% 50%
Trans. Efficiency.................. 40% 40% 40% 40% 40% 40% 40% 40% 40%
Neutral Idle....................... 20% 20% 20% 20% 20% 20% 20% 20% 20%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Driveline
--------------------------------------------------------------------------------------------------------------------------------------------------------
Axle Efficiency.................... 65% 65% 65% 65% 65% 65% 65% 65% 65%
6x2, 6x4 Axle Disconnect or 4x2 N/A N/A N/A 25% 25% 25% 25% 25% 25%
Axle..............................
Downspeed (Rear Axle Ratio)........ 3.31 3.31 3.31 3.31 3.31 3.31 3.26 3.26 3.26
--------------------------------------------------------------------------------------------------------------------------------------------------------
Accessory Improvements
--------------------------------------------------------------------------------------------------------------------------------------------------------
A/C Efficiency..................... 20% 20% 20% 20% 20% 20% 20% 20% 20%
Electric Access.................... 20% 20% 20% 20% 20% 20% 20% 20% 20%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Other Technologies
--------------------------------------------------------------------------------------------------------------------------------------------------------
Predictive Cruise Control.......... 40% 40% 40% 40% 40% 40% 40% 40% 40%
Automated Tire Inflation System.... 25% 25% 25% 25% 25% 25% 25% 25% 25%
Tire Pressure Monitoring System.... 50% 50% 50% 50% 50% 50% 50% 50% 50%
Neutral Coast...................... 0% 0% 0% 0% 0% 0% 0% 0% 0%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table III-15--Technology Adoption Rates for Class 7 and 8 Tractors for Determining the 2027 MY Standards
--------------------------------------------------------------------------------------------------------------------------------------------------------
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
--------------------------------------------------------------------------------------------------------------------------------------------------------
Engine
--------------------------------------------------------------------------------------------------------------------------------------------------------
2027 MY 11L 2027 MY 11L 2027 MY 11L 2027 MY 15L 2027 MY 15L 2027 MY 15L 2027 MY 15L 2027 MY 15L 2027 MY 15L
Engine 350 Engine 350 Engine 350 Engine 455 Engine 455 Engine 455 Engine 455 Engine 455 Engine 455
HP HP HP HP HP HP HP HP HP
--------------------------------------------------------------------------------------------------------------------------------------------------------
Aerodynamics
--------------------------------------------------------------------------------------------------------------------------------------------------------
Bin I.............................. 0% 0% 0% 0% 0% 0% 0% 0% 0%
Bin II............................. 20% 20% 0% 20% 20% 0% 20% 20% 0%
Bin III............................ 50% 50% 30% 50% 60% 30% 40% 50% 20%
Bin IV............................. 30% 30% 30% 30% 20% 30% 40% 30% 30%
Bin V.............................. 0% 0% 40% 0% 0% 40% 0% 0% 50%
Bin VI............................. 0% 0% 0% 0% 0% 0% 0% 0% 0%
Bin VII............................ 0% 0% 0% 0% 0% 0% 0% 0% 0%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Steer Tires
--------------------------------------------------------------------------------------------------------------------------------------------------------
Base............................... 5% 5% 5% 5% 5% 5% 5% 5% 5%
Level 1............................ 20% 20% 10% 20% 20% 10% 20% 20% 10%
Level 2............................ 50% 50% 50% 50% 50% 50% 50% 50% 50%
Level 3............................ 25% 25% 35% 25% 25% 35% 25% 25% 35%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Drive Tires
--------------------------------------------------------------------------------------------------------------------------------------------------------
Base............................... 5% 5% 5% 5% 5% 5% 5% 5% 5%
Level 1............................ 10% 10% 10% 10% 10% 10% 10% 10% 10%
Level 2............................ 85% 85% 50% 85% 85% 50% 85% 85% 50%
Level 3............................ 0% 0% 35% 0% 0% 35% 0% 0% 35%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Idle Reduction
--------------------------------------------------------------------------------------------------------------------------------------------------------
Tamper Proof AESS.................. N/A N/A N/A N/A N/A N/A 0% 0% 0%
Tamper Proof AESS with Diesel APU.. N/A N/A N/A N/A N/A N/A 0% 0% 0%
Tamper Proof AESS with Battery APU. N/A N/A N/A N/A N/A N/A 0% 0% 0%
Tamper Proof AESS with Automatic N/A N/A N/A N/A N/A N/A 0% 0% 0%
Stop-Start........................
Tamper Proof AESS with FOH......... N/A N/A N/A N/A N/A N/A 0% 0% 0%
Adjustable AESS.................... N/A N/A N/A N/A N/A N/A 15% 15% 15%
Adjustable AESS with Diesel APU.... N/A N/A N/A N/A N/A N/A 40% 40% 40%
[[Page 73611]]
Adjustable AESS with Battery APU... N/A N/A N/A N/A N/A N/A 15% 15% 15%
Adjustable AESS with Automatic Stop- N/A N/A N/A N/A N/A N/A 15% 15% 15%
Start.............................
Adjustable AESS with FOH........... N/A N/A N/A N/A N/A N/A 15% 15% 15%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Transmission
--------------------------------------------------------------------------------------------------------------------------------------------------------
Manual............................. 0% 0% 0% 0% 0% 0% 0% 0% 0%
AMT................................ 50% 50% 50% 50% 50% 50% 50% 50% 50%
Auto............................... 30% 30% 30% 30% 30% 30% 30% 30% 30%
Dual Clutch........................ 10% 10% 10% 10% 10% 10% 10% 10% 10%
Top Gear Direct Drive.............. 50% 50% 50% 50% 50% 50% 50% 50% 50%
Trans. Efficiency.................. 70% 70% 70% 70% 70% 70% 70% 70% 70%
Neutral Idle....................... 30% 30% 30% 30% 30% 30% 30% 30% 30%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Driveline
--------------------------------------------------------------------------------------------------------------------------------------------------------
Axle Efficiency.................... 80% 80% 80% 80% 80% 80% 80% 80% 80%
6x2, 6x4 Axle Disconnect or 4x2 N/A N/A N/A 30% 30% 30% 30% 30% 30%
Axle..............................
Downspeed (Rear Axle Ratio)........ 3.21 3.21 3.21 3.21 3.21 3.21 3.16 3.16 3.16
--------------------------------------------------------------------------------------------------------------------------------------------------------
Accessory Improvements
--------------------------------------------------------------------------------------------------------------------------------------------------------
A/C Efficiency..................... 30% 30% 30% 30% 30% 30% 30% 30% 30%
Electric Access.................... 30% 30% 30% 30% 30% 30% 30% 30% 30%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Other Technologies
--------------------------------------------------------------------------------------------------------------------------------------------------------
Predictive Cruise Control.......... 40% 40% 40% 40% 40% 40% 40% 40% 40%
Automated Tire Inflation System.... 30% 30% 30% 30% 30% 30% 30% 30% 30%
Tire Pressure Monitoring System.... 70% 70% 70% 70% 70% 70% 70% 70% 70%
Neutral Coast...................... 0% 0% 0% 0% 0% 0% 0% 0% 0%
--------------------------------------------------------------------------------------------------------------------------------------------------------
(e) Adoption Rates Used To Set the Heavy-Haul Tractor Standards
The agencies recognize that certain technologies used to determine
the stringency of the Phase 2 tractor standards are less applicable to
heavy-haul tractors. Heavy-haul tractors are not typically used in the
same manner as long-haul tractors with extended highway driving, and
therefore will experience less benefit from aerodynamics. Aerodynamic
technologies are very effective at reducing the fuel consumption and
GHG emissions of tractors, but only when traveling at highway speeds.
At lower speeds, the aerodynamic technologies may have a detrimental
impact due to the potential of added weight. The agencies therefore
proposed not considering the use of aerodynamic technologies in the
development of the Phase 2 heavy-haul tractor standards. Moreover,
because aerodynamics will not play a role in the heavy-haul standards,
the agencies proposed to combine all of the heavy-haul tractor cab
configurations (day and sleeper) and roof heights (low, mid, and high)
into a single heavy-haul tractor subcategory. We welcomed comment on
this approach. 80 FR 40233.
The agencies received comments regarding the applicability of
aerodynamic technologies on heavy-haul vehicles. Daimler commented that
heavy-haul vehicles are designed to meet high cooling needs, therefore
have large radiators and grilles, and are not designed primarily for
hauling standard trailers on the highway. Daimler also stated that
these vehicles are designed to operate off-road or on difficult
terrain, which also limits the application of aerodynamic fairings, and
that requiring aerodynamic improvements on these vehicles, may
compromise the vehicles' work. EMA supported the agencies' proposed
approach of not requiring the use of aerodynamic technologies as a
component of the proposed Phase 2 heavy-haul tractor standards. EMA
stated that those vehicles are already quite heavy (by virtue of need),
are designed to meet high-cooling needs (thus having, for example,
large grilles), and generally are not designed for hauling standard
trailers on highways. EMA also stated that those vehicles are often
designed to be capable of operation off-road or on difficult terrain.
Volvo supported the addition of a heavy-haul subcategory since heavy-
haul tractors require large engines and increased cooling capacity that
limits aerodynamic improvements. Volvo also stated the most heavy-haul
rigs have some requirement for off-road access to pick up machinery,
bulk goods, and unusual loads that also inhibit aerodynamic
improvements. These comments largely echo the agencies' own concerns
voiced at proposal. After considering these comments, the agencies are
using a technology package that does not use aerodynamic improvements
in setting the Phase 2 heavy-haul tractor standards, as we
proposed.\289\
---------------------------------------------------------------------------
\289\ Since aerodynamic improvements are not part of the
technology package, the agencies likewise are not adopting any aero
bin structure for the heavy-haul tractor subcategory.
---------------------------------------------------------------------------
Certain powertrain and drivetrain components are also impacted
during the design of a heavy-haul tractor,
[[Page 73612]]
including the transmission, axles, and the engine. Heavy-haul tractors
typically require transmissions with 13 or 18 speeds to provide the
ratio spread to ensure that the tractor is able to start pulling the
load from a stop. Downspeed powertrains are typically not an option for
heavy-haul operations because these vehicles require more torque to
move the vehicle because of the heavier load. Finally, due to the
loading requirements of the vehicle, it is not likely that a 6x2 axle
configuration can be used in heavy-haul applications. We requested
comments on all aspects of our heavy-haul tractor technology packages.
80 FR 40233.
We received comments from stakeholders about the application of
technologies other than aerodynamics for heavy-haul tractors. Daimler
commented that the low rolling resistance levels in the NPRM are overly
aggressive because heavy-haul tractors require unusually high traction
and stopping power. Daimler agreed with the agencies' assessment in the
NPRM that did not include weight reduction because these vehicles
require strong frames and axles to carry heavy loads. Volvo commented
that heavy-haul tractors would not likely be able to utilize current
SmartWay tires; would see no benefit from predictive cruise; sometimes
utilize an auxiliary transmission for further reduction or closer
ratios; and nearly all heavy-haul tractors have deeper drive axle
ratios than the agencies assumed in the NPRM. After considering these
comments and the information regarding the tire rolling resistance
improvement opportunities, discussed in Section III.D.1.b.iii, the
agencies have adjusted the adoption rate of low rolling resistance
tires. Consistent with the changes made in the final rule for the
adoption of low rolling resistance tires in low and mid roof tractors,
the agencies did not project any adoption of Level 3 tires for heavy-
haul tractors in the final rule.
Allison commented that AMTs in the NPRM receive a 1.8 percent
credit in GEM for heavy-haul tractors, yet there is no similar credit
for ATs. Allison commented that since ATs offer similar, if not
greater, benefits, they should also receive credit and that neutral-
idle recognition should be available. The final version of Phase 2 GEM
treats ATs and AMTs the same for heavy-haul tractors as for the other
tractors.
The agencies used the following heavy-haul tractor adoption rates
for developing the final Phase 2 2021, 2024, and 2027 MY standards, as
shown in Table III-16.
Table III-16--Application Rates for Heavy-Haul Tractor Standards
[Heavy-haul tractor application rates]
----------------------------------------------------------------------------------------------------------------
2021 MY 2024 MY 2027 MY
--------------------------------------------------------------------------
Engine 2021 MY 15L engine with 2024 MY 15L engine with 2027 MY 15L engine with
600 HP with 2% 600 HP with 4.2% 600 HP with 5.4%
reduction over 2018 MY reduction over 2018 MY reduction over 2018 MY
----------------------------------------------------------------------------------------------------------------
Aerodynamics--0%
----------------------------------------------------------------------------------------------------------------
Steer Tires
----------------------------------------------------------------------------------------------------------------
Phase 1 Baseline: 15% 10% 5%
Level I.......................... 35% 30% 10%
Level 2.......................... 50% 60% 85%
Level 3.......................... 0% 0% 0%
----------------------------------------------------------------------------------------------------------------
Drive Tires
----------------------------------------------------------------------------------------------------------------
Phase 1 Baseline: 15% 10% 5%
Level I.......................... 35% 30% 10%
Level 2.......................... 50% 60% 85%
Level 3.......................... 0% 0% 0%
----------------------------------------------------------------------------------------------------------------
Transmission
----------------------------------------------------------------------------------------------------------------
AMT.................................. 40% 50% 50%
Automatic with Neutral Idle.......... 10% 20% 20%
DCT.................................. 5% 10% 10%
----------------------------------------------------------------------------------------------------------------
Other Technologies
----------------------------------------------------------------------------------------------------------------
6x2 Axle............................. 0% 0% 0%
Transmission Efficiency.............. 20% 40% 70%
Axle Efficiency...................... 30% 65% 80%
Predictive Cruise Control............ 20% 40% 40%
Accessory Improvements............... 10% 20% 20%
Air Conditioner Efficiency 10% 20% 20%
Improvements........................
Automatic Tire Inflation Systems..... 20% 25% 30%
Tire Pressure Monitoring System...... 20% 50% 70%
----------------------------------------------------------------------------------------------------------------
The agencies are also adopting in Phase 2 provisions that allow the
manufacturers to meet an optional heavy Class 8 tractor standard that
reflects both aerodynamic improvements, along with the powertrain
requirements that go along with higher GCWR. Table III-17 reflects the
adoption rates for each of the technologies for each of the
subcategories in MY 2021. The technology packages closely reflect those
in the primary Class 8 tractor program. The exceptions include less
aggressive targets for low rolling
[[Page 73613]]
resistance tires, no 6x2 axle adoption rates, and no downspeeding due
to the heavier loads of these vehicles.
Table III-17--Adoption Rates Used To Develop the 2021 MY Optional Heavy Class 8 Tractor Standards
[Optional heavy class 8 tractor application rates--2021 MY]
----------------------------------------------------------------------------------------------------------------
Low/mid roof High roof day Low/mid roof High roof
day cab cab sleeper cab sleeper cab
---------------------------------------------------------------
Engine 2021 MY 15L 2021 MY 15L 2021 MY 15L 2021 MY 15L
Engine with Engine with Engine with Engine with
600 HP 600 HP 600 HP 600 HP
----------------------------------------------------------------------------------------------------------------
Aerodynamics
----------------------------------------------------------------------------------------------------------------
Bin I........................................... 10% 0% 10% 0%
Bin II.......................................... 10% 0% 10% 0%
Bin III......................................... 70% 60% 70% 60%
Bin IV.......................................... 10% 35% 10% 30%
Bin V........................................... 0% 5% 0% 10%
Bin VI.......................................... 0% 0% 0% 0%
Bin VII......................................... 0% 0% 0% 0%
----------------------------------------------------------------------------------------------------------------
Steer Tires
----------------------------------------------------------------------------------------------------------------
Phase 1 Baseline 10% 5% 10% 5%
Level I......................................... 25% 35% 25% 35%
Level 2......................................... 65% 60% 65% 60%
Level 3......................................... 0% 0% 0% 0%
----------------------------------------------------------------------------------------------------------------
Drive Tires
----------------------------------------------------------------------------------------------------------------
Phase 1 Baseline 20% 10% 20% 10%
Level I......................................... 40% 30% 40% 30%
Level 2......................................... 40% 60% 40% 60%
Level 3......................................... 0% 0% 0% 0%
----------------------------------------------------------------------------------------------------------------
Transmission
----------------------------------------------------------------------------------------------------------------
AMT............................................. 40% 40% 40% 40%
Automatic with Neutral Idle..................... 10% 10% 10% 10%
DCT............................................. 5% 5% 5% 5%
----------------------------------------------------------------------------------------------------------------
Other Technologies
----------------------------------------------------------------------------------------------------------------
Adjustable AESS w/Diesel APU.................... N/A N/A 30% 30%
Adjustable AESS w/Battery APU................... N/A N/A 10% 10%
Adjustable AESS w/Automatic Stop-Start.......... N/A N/A 10% 10%
Adjustable AESS w/FOH Cold, Main Engine Warm.... N/A N/A 10% 10%
Adjustable AESS programmed to 5 minutes......... N/A N/A 40% 40%
Transmission Efficiency......................... 20% 20% 20% 20%
Axle Efficiency................................. 30% 30% 30% 30%
Predictive Cruise Control....................... 20% 20% 20% 20%
Accessory Improvements.......................... 10% 10% 10% 10%
Air Conditioner Efficiency Improvements......... 10% 10% 10% 10%
Automatic Tire Inflation Systems................ 20% 20% 20% 20%
Tire Pressure Monitoring System................. 20% 20% 20% 20%
----------------------------------------------------------------------------------------------------------------
(f) Derivation of the Final Phase 2 Tractor Standards
The agencies used the technology effectiveness inputs and
technology adoption rates to develop GEM inputs to derive the HD Phase
2 fuel consumption and CO2 emissions standards for each
subcategory of Class 7 and 8 combination tractors. Note that we have
analyzed one technology pathway for each level of stringency, but
manufacturers will be free to use any combination of technology to meet
the standards, as well as the flexibility of averaging, banking and
trading, to meet the standard on average. The agencies derived a
scenario tractor for each subcategory by weighting the individual GEM
input parameters included in Table III-7 with the adoption rates in
Table III-8 through Table III-10. For example, the CdA value
for a 2021 MY Class 8 Sleeper Cab High Roof scenario case was derived
as 60 percent times 5.95 plus 30 percent times 5.40 plus 10 percent
times 4.90, which is equal to a CdA of 5.68 m\2\. Similar
calculations were made for tire rolling resistance, transmission types,
idle reduction, and other technologies. The agencies developed fuel
maps that achieved the CO2 emissions and fuel consumption
reductions described in Section III.D.1.b. The agencies then ran GEM
with a single set of vehicle inputs, as shown in Table III-18 through
Table III-21, to derive the final standards for each subcategory.
Additional detail is provided in the RIA Chapter 2.8.4.
[[Page 73614]]
Table III-18--GEM Inputs for the 2021 MY 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
--------------------------------------------------------------------------------------------------------------------------------------------------------
Engine
--------------------------------------------------------------------------------------------------------------------------------------------------------
2021 MY 11L 2021 MY 11L 2021 MY 11L 2021 MY 15L 2021 MY 15L 2021 MY 15L 2021 MY 15L 2021 MY 15L 2021 MY 15L
Engine 350 HP Engine 350 HP Engine 350 HP Engine 455 HP Engine 455 HP Engine 455 HP Engine 455 HP Engine 455 HP Engine 455 HP
--------------------------------------------------------------------------------------------------------------------------------------------------------
Aerodynamics (CdA in m\2\)
--------------------------------------------------------------------------------------------------------------------------------------------------------
5.24 6.33 6.01 5.24 6.33 6.01 5.24 6.33 5.68
--------------------------------------------------------------------------------------------------------------------------------------------------------
Steer Tires (CRR in kg/metric ton)
--------------------------------------------------------------------------------------------------------------------------------------------------------
6.0 6.0 6.0 6.0 6.0 6.0 6.0 6.0 6.0
--------------------------------------------------------------------------------------------------------------------------------------------------------
Drive Tires (CRR in kg/metric ton)
--------------------------------------------------------------------------------------------------------------------------------------------------------
6.6 6.6 6.3 6.6 6.6 6.3 6.6 6.6 6.3
--------------------------------------------------------------------------------------------------------------------------------------------------------
Extended Idle Reduction Weighted Effectiveness
--------------------------------------------------------------------------------------------------------------------------------------------------------
N/A N/A N/A N/A N/A N/A 2.3% 2.3% 2.3%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Transmission = 10 speed Manual Transmission
Gear Ratios = 12.8, 9.25, 6.76, 4.90, 3.58, 2.61, 1.89, 1.38, 1.00, 0.73
--------------------------------------------------------------------------------------------------------------------------------------------------------
Drive Axle Ratio = 3.36 for day cabs, 3.31 for sleeper cabs
--------------------------------------------------------------------------------------------------------------------------------------------------------
6x2 Axle Weighted Effectiveness
--------------------------------------------------------------------------------------------------------------------------------------------------------
N/A N/A N/A 0.3% 0.3% 0.3% 0.3% 0.3% 0.3%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Transmission Type Weighted Effectiveness = 1.1%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Neutral Idle Weighted Effectiveness
--------------------------------------------------------------------------------------------------------------------------------------------------------
0.1% 0.1% 0.1% 0.1% 0.1% 0.1% 0.02% 0.02% 0.02%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Direct Drive Weighted Effectiveness = 0.4%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Transmission Efficiency Weighted Effectiveness = 0.2%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Axle Efficiency Improvement = 0.6%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Air Conditioner Efficiency Improvements = 0.1%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Accessory Improvements = 0.1%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Predictive Cruise Control = 0.4%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Automatic Tire Inflation Systems = 0.3%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Tire Pressure Monitoring System = 0.2%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Phase 1 Credit Carry-over = 1%
--------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 73615]]
Table III-19--GEM Inputs for the 2024 MY 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
--------------------------------------------------------------------------------------------------------------------------------------------------------
Engine
--------------------------------------------------------------------------------------------------------------------------------------------------------
2024 MY 11L 2024 MY 11L 2024 MY 11L 2024 MY 15L 2024 MY 15L 2024 MY 15L 2024 MY 15L 2024 MY 15L 2024 MY 15L
Engine 350 HP Engine 350 HP Engine 350 HP Engine 455 HP Engine 455 HP Engine 455 HP Engine 455 HP Engine 455 HP Engine 455 HP
--------------------------------------------------------------------------------------------------------------------------------------------------------
Aerodynamics (CdA in m\2\)
--------------------------------------------------------------------------------------------------------------------------------------------------------
5.16 6.25 5.82 5.16 6.25 5.82 5.16 6.25 5.52
--------------------------------------------------------------------------------------------------------------------------------------------------------
Steer Tires (CRR in kg/metric ton)
--------------------------------------------------------------------------------------------------------------------------------------------------------
5.9 5.9 5.8 5.9 5.9 5.8 5.9 5.9 5.8
--------------------------------------------------------------------------------------------------------------------------------------------------------
Drive Tires (CRR in kg/metric ton)
--------------------------------------------------------------------------------------------------------------------------------------------------------
6.4 6.4 6.0 6.4 6.4 6.0 6.4 6.4 6.0
--------------------------------------------------------------------------------------------------------------------------------------------------------
Extended Idle Reduction Weighted Effectiveness
--------------------------------------------------------------------------------------------------------------------------------------------------------
N/A N/A N/A N/A N/A N/A 2.5% 2.5% 2.5%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Transmission = 10 speed Manual Transmission
Gear Ratios = 12.8, 9.25, 6.76, 4.90, 3.58, 2.61, 1.89, 1.38, 1.00, 0.73
--------------------------------------------------------------------------------------------------------------------------------------------------------
Drive Axle Ratio = 3.31 for day cabs, 3.26 for sleeper cabs
--------------------------------------------------------------------------------------------------------------------------------------------------------
6x2 Axle Weighted Effectiveness
--------------------------------------------------------------------------------------------------------------------------------------------------------
N/A N/A N/A 0.5% 0.5% 0.5% 0.5% 0.5% 0.5%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Transmission Type Weighted Effectiveness = 1.6%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Neutral Idle Weighted Effectiveness
--------------------------------------------------------------------------------------------------------------------------------------------------------
0.2% 0.2% 0.2% 0.2% 0.2% 0.2% 0.03% 0.03% 0.03%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Direct Drive Weighted Effectiveness = 1.0%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Transmission Efficiency Weighted Effectiveness = 0.4%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Axle Efficiency Improvement = 1.3%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Air Conditioner Efficiency Improvements = 0.1%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Accessory Improvements = 0.2%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Predictive Cruise Control = 0.8%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Automatic Tire Inflation
--------------------------------------------------------------------------------------------------------------------------------------------------------
Tire Pressure Monitoring System = 0.5%
--------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 73616]]
Table III-20--GEM Inputs for the 2027 MY 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
--------------------------------------------------------------------------------------------------------------------------------------------------------
Engine
--------------------------------------------------------------------------------------------------------------------------------------------------------
2027 MY 11L 2027 MY 11L 2027 MY 11L 2027 MY 15L 2027 MY 15L 2027 MY 15L 2027 MY 15L 2027 MY 15L 2027 MY 15L
Engine 350 HP Engine 350 HP Engine 350 HP Engine 455 HP Engine 455 HP Engine 455 HP Engine 455 HP Engine 455 HP Engine 455 HP
--------------------------------------------------------------------------------------------------------------------------------------------------------
Aerodynamics (CdA in m\2\)
--------------------------------------------------------------------------------------------------------------------------------------------------------
5.12 6.21 5.67 5.12 6.21 5.67 5.08 6.21 5.26
--------------------------------------------------------------------------------------------------------------------------------------------------------
Steer Tires (CRR in kg/metric ton)
--------------------------------------------------------------------------------------------------------------------------------------------------------
5.8 5.8 5.6 5.8 5.8 5.6 5.8 5.8 5.6
--------------------------------------------------------------------------------------------------------------------------------------------------------
Drive Tires (CRR in kg/metric ton)
--------------------------------------------------------------------------------------------------------------------------------------------------------
6.2 6.2 5.8 6.2 6.2 5.8 6.2 6.2 5.8
--------------------------------------------------------------------------------------------------------------------------------------------------------
Extended Idle Reduction Weighted Effectiveness
--------------------------------------------------------------------------------------------------------------------------------------------------------
N/A N/A N/A N/A N/A N/A 3% 3% 3%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Transmission = 10 speed Manual Transmission
--------------------------------------------------------------------------------------------------------------------------------------------------------
Gear Ratios = 12.8, 9.25, 6.76, 4.90, 3.58, 2.61, 1.89, 1.38, 1.00, 0.73
--------------------------------------------------------------------------------------------------------------------------------------------------------
Drive Axle Ratio = 3.21 for day cabs, 3.16 for sleeper cabs
--------------------------------------------------------------------------------------------------------------------------------------------------------
6x2 Axle Weighted Effectiveness
--------------------------------------------------------------------------------------------------------------------------------------------------------
N/A N/A N/A 0.6% 0.6% 0.6% 0.6% 0.6% 0.6%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Transmission Type Weighted Effectiveness = 1.6%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Neutral Idle Weighted Effectiveness
--------------------------------------------------------------------------------------------------------------------------------------------------------
0.2% 0.2% 0.2% 0.2% 0.2% 0.2% 0.03% 0.03% 0.03%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Direct Drive Weighted Effectiveness = 1.0%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Transmission Efficiency Weighted Effectiveness = 0.7%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Axle Efficiency Improvement = 1.6%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Air Conditioner Efficiency Improvements = 0.3%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Accessory Improvements = 0.2%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Predictive Cruise Control = 0.8%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Automatic Tire Inflation Systems = 0.4%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Tire Pressure Monitoring System = 0.7%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table III-21--GEM Inputs for 2021, 2024 and 2027 MY Heavy-Haul Tractor
Standards
------------------------------------------------------------------------
2021 MY 2024 MY 2027 MY
------------------------------------------------------------------------
Engine = 2021 MY 15L Engine Engine = 2024 MY 15L Engine = 2027 MY 15L
with 600 HP. Engine with 600 HP. Engine with 600 HP.
------------------------------------------------------------------------
Aerodynamics (CdA in m\2\) = 5.00
------------------------------------------------------------------------
Steer Tires (CRR in kg/ Steer Tires (CRR in Steer Tires (CRR in
metric ton) = 6.2. kg/metric ton) = kg/metric ton) =
6.0. 5.8.
Drive Tires (CRR in kg/ Drive Tires (CRR in Drive Tires (CRR in
metric ton) = 6.6. kg/metric ton) = kg/metric ton) =
6.4. 6.2.
Transmission = 18 speed Transmission = 18 Transmission = 18
Manual Transmission. speed Manual speed Manual
Transmission. Transmission.
Drive axle Ratio = 3.70..... Drive axle Ratio = Drive axle Ratio =
3.70. 3.70.
6x2 Axle Weighted 6x2 Axle Weighted 6x2 Axle Weighted
Effectiveness = 0%. Effectiveness = 0%. Effectiveness = 0%.
Transmission benefit = 1.1%. Transmission benefit Transmission benefit
= 1.8%. = 1.8%.
[[Page 73617]]
Transmission Efficiency = Transmission Transmission
0.2%. Efficiency = 0.4%. Efficiency = 0.7%.
Axle Efficiency = 0.3%...... Axle Efficiency = Axle Efficiency =
0.7%. 1.6%.
Predictive Cruise Control = Predictive Cruise Predictive Cruise
0.4%. Control = 0.8%. Control = 0.8%.
Accessory Improvements = Accessory Accessory
0.1%. Improvements = 0.2%. Improvements =
0.3%.
Air Conditioner Efficiency Air Conditioner Air Conditioner
Improvements = 0.1%. Efficiency Efficiency
Improvements = 0.1%. Improvements =
0.2%.
Automatic Tire Inflation Automatic Tire Automatic Tire
Systems = 0.3%. Inflation Systems = Inflation Systems =
0.3%. 0.4%.
Tire Pressure Monitoring Tire Pressure Tire Pressure
System = 0.2%. Monitoring System = Monitoring System =
0.5%. 0.7%.
------------------------------------------------------------------------
The agencies ran GEM with a single set of vehicle inputs, as shown
in Table III-22, to derive the optional standards for each subcategory
of the Heavy Class 8 tractors (see Section III.C.(4)(a)).
Table III-22--GEM Inputs for 2021 MY Optional Heavy Class 8 Tractor Standards
[Heavy Class 8 GEM inputs for 2021 MY]
----------------------------------------------------------------------------------------------------------------
Day cab Sleeper cab
----------------------------------------------------------------------------------------------------------------
Low roof Mid roof High roof Low roof Mid roof High roof
----------------------------------------------------------------------------------------------------------------
2021 MY 15L Engine 600 HP
----------------------------------------------------------------------------------------------------------------
Aerodynamics (CdA in m \2\)
----------------------------------------------------------------------------------------------------------------
5.2 6.3 6.0 5.2 6.3 5.7
----------------------------------------------------------------------------------------------------------------
Steer Tires (CRR in kg/metric ton)
----------------------------------------------------------------------------------------------------------------
6.1 6.1 6.1 6.1 6.1 6.1
----------------------------------------------------------------------------------------------------------------
Drive Tires (CRR in kg/metric ton)
----------------------------------------------------------------------------------------------------------------
6.8 6.8 6.5 6.8 6.8 6.5
----------------------------------------------------------------------------------------------------------------
Extended Idle Reduction Weighted Effectiveness
----------------------------------------------------------------------------------------------------------------
N/A N/A N/A 2.3% 2.3% 2.3%
----------------------------------------------------------------------------------------------------------------
Transmission = 18 speed Manual Transmission
----------------------------------------------------------------------------------------------------------------
Drive Axle Ratio = 3.73
----------------------------------------------------------------------------------------------------------------
Transmission Type Weighted Effectiveness = 1.1%
----------------------------------------------------------------------------------------------------------------
Neutral Idle Weighted Effectiveness
----------------------------------------------------------------------------------------------------------------
0.1% 0.1% 0.1% 0.1% 0.1% 0.1%
----------------------------------------------------------------------------------------------------------------
Direct Drive Weighted Effectiveness = 0.4%
----------------------------------------------------------------------------------------------------------------
Transmission Efficiency Weighted Effectiveness = 0.2%
----------------------------------------------------------------------------------------------------------------
Axle Efficiency Improvement = 0.6%
----------------------------------------------------------------------------------------------------------------
Air Conditioner Efficiency Improvements = 0.1%
----------------------------------------------------------------------------------------------------------------
Accessory Improvements = 0.1%
----------------------------------------------------------------------------------------------------------------
Predictive Cruise Control = 0.4%
----------------------------------------------------------------------------------------------------------------
Automatic Tire Inflation Systems = 0.3%
----------------------------------------------------------------------------------------------------------------
Tire Pressure Monitoring System = 0.2%
----------------------------------------------------------------------------------------------------------------
The level of the final Phase 2 2027 model year standards, and the
phase-in standards in model years 2021 and 2024 for each subcategory,
is shown in Table III-23.
[[Page 73618]]
Table III-23--Final Phase 2 2021, 2024, and 2027 Model Year Tractor Standards
----------------------------------------------------------------------------------------------------------------
Day cab Sleeper cab Heavy-haul
---------------------------------------------------------------
Class 7 Class 8 Class 8 Class 8
----------------------------------------------------------------------------------------------------------------
2021 Model Year CO[ihel2] Grams per Ton-Mile
----------------------------------------------------------------------------------------------------------------
Low Roof........................................ 105.5 80.5 72.3 52.4
Mid Roof........................................ 113.2 85.4 78.0
High Roof....................................... 113.5 85.6 75.7
----------------------------------------------------------------------------------------------------------------
2021 Model Year Gallons of Fuel per 1,000 Ton-Mile
----------------------------------------------------------------------------------------------------------------
Low Roof........................................ 10.36346 7.90766 7.10216 5.14735
Mid Roof........................................ 11.11984 8.38900 7.66208
High Roof....................................... 11.14931 8.40864 7.43615
----------------------------------------------------------------------------------------------------------------
2024 Model Year CO[ihel2] Grams per Ton-Mile
----------------------------------------------------------------------------------------------------------------
Low Roof........................................ 99.8 76.2 68.0 50.2
Mid Roof........................................ 107.1 80.9 73.5
High Roof....................................... 106.6 80.4 70.7
----------------------------------------------------------------------------------------------------------------
2024 Model Year and Later Gallons of Fuel per 1,000 Ton-Mile
----------------------------------------------------------------------------------------------------------------
Low Roof........................................ 9.80354 7.48527 6.67976 4.93124
Mid Roof........................................ 10.52063 7.94695 7.22004
High Roof....................................... 10.47151 7.89784 6.94499
----------------------------------------------------------------------------------------------------------------
2027 Model Year CO[ihel2] Grams per Ton-Mile \a\
----------------------------------------------------------------------------------------------------------------
Low Roof........................................ 96.2 73.4 64.1 48.3
Mid Roof........................................ 103.4 78.0 69.6
High Roof....................................... 100.0 75.7 64.3
----------------------------------------------------------------------------------------------------------------
2027 Model Year and Later Gallons of Fuel per 1,000 Ton-Mile
----------------------------------------------------------------------------------------------------------------
Low Roof........................................ 9.44990 7.21022 6.29666 4.74460
Mid Roof........................................ 10.15717 7.66208 6.83694
High Roof....................................... 9.82318 7.43615 6.31631
----------------------------------------------------------------------------------------------------------------
Note:
\a\ The 2027 MY high roof tractor standards include a 0.3 m\2\ reduction in CdA as described in Section
III.E.2.a.vii.
The level of the Phase 2 2027 model year optional Heavy Class 8
standards is shown in Table III-24.
Table III-24--Phase 2 Optional Heavy Class 8 Standards
[Optional heavy Class 8 tractor standards]
----------------------------------------------------------------------------------------------------------------
Low roof sleeper Mid roof sleeper High roof sleeper
Low roof day cab Mid roof day cab High roof day cab cab cab cab
----------------------------------------------------------------------------------------------------------------
2021 Model Year CO[ihel2] Standards (Grams per Ton-Mile)
----------------------------------------------------------------------------------------------------------------
51.8 54.1 54.1 45.3 47.9 46.9
----------------------------------------------------------------------------------------------------------------
2021 MY and Later Fuel Consumption (Gallons of Fuel per 1,000 Ton-Mile)
----------------------------------------------------------------------------------------------------------------
5.08841 5.31434 5.31434 4.44990 4.70530 4.60707
----------------------------------------------------------------------------------------------------------------
(g) Technology Costs of the Final Phase 2 Tractor Standards
A summary of the technology package costs is included in Table III-
15 through Table III-17 for MYs 2021, 2024, and 2027, respectively,
with additional details available in the RIA Chapter 2.12.
The agencies received several comments related to the APU, tire,
and aerodynamic technology costs used by the agencies at proposal. As
noted in Section III.C.3 above, ATA, First Industries, and Daimler
commented that APU costs are substantially higher than the figures in
the proposal. PACCAR commented that the cost of a diesel or battery-
based APU is $8,570 to $11,263. EMA commented that the direct per-
chassis cost of a diesel APU is approximately $8,500-$10,100 and
approximately $11,300 for battery/electric APUs. Volvo commented that
APU prices can vary between $9,500 and $11,000 depending on the type.
Schneider commented that an electronic APU will have an initial cost of
at least $5,000 and engine powered APUs are 2 to 3 times the electric
costs.
[[Page 73619]]
EPA considered the comments and more closely evaluated NHTSA's
contracted TetraTech cost report found the retail price of a diesel-
powered APU with a DPF to be $10,000.\290\ The agencies used a retail
price of a diesel-powered APU to be $8,000 without a DPF and $10,000
with a DPF in the cost analysis for this final rulemaking.
---------------------------------------------------------------------------
\290\ U.S. DOT/NHTSA. Commercial Medium- and Heavy-Duty Truck
Fuel Efficiency Technology Cost Study. May 2015. Page 71.
---------------------------------------------------------------------------
ATA and First Industries commented that the LRR tire costs
calculations appear to be based on calculations on 1999 data indexed
for inflation. Michelin's comments stated that they estimate the cost
of low rolling resistance tires to be about $25 per tire. ATA commented
that the industry commonly sees a 40 percent reduction in useful life
and a 20 percent reduction in casing life resulting from low rolling
resistance tires. ATA and First Industries commented that the LRR tire
costs do not account for reduced tire life resulting in fewer retreads.
Schneider commented that WBS tire costs must include additional service
costs, cost of reduced tire life, and increased replacement tire costs
due to recaps not available, and reduced resale value. Volvo also
commented that heavy-duty fleets expect to retread tires as many as
five times and have concerns that tire casing durability may be
compromised with low rolling resistance tires. Volvo stressed that
retreading saves cost and about two thirds of the oil required to
produce a new tire.
We have estimated the cost of lower rolling resistance tires based
on an estimate from TetraTech of $30 (retail, 2013$). We also have
applied a ``medium'' complexity markup value for the more advanced low
rolling resistance tires. We expect that, when replaced, the lower
rolling resistance tires would be replaced by equivalent performing
tires throughout the vehicle lifetime. As such, the incremental
increases in costs for lower rolling resistance tires would be incurred
throughout the vehicle lifetime at intervals consistent with current
tire replacement intervals. A recent study conducted by ATA's
Technology and Maintenance Council found through surveys of 51 fleets
that low rolling resistance tires and wide base single tires lasted
longer than standard tractor tires.\291\ Due to the uncertainty
regarding the life expectancy of the LRR tires, we maintained the
current tire replacement intervals in our cost analysis.
---------------------------------------------------------------------------
\291\ Truckinginfo. TMC Survey Reveals Misinformed View of Fuel-
Efficient Tires. March 2015.
---------------------------------------------------------------------------
ATA and First Industries commented that the estimated costs of
future aerodynamic devices appear low given the historical nature of
the proposed changes. ATA and First Industries also commented that the
agencies should describe in detail the component packages they expect
to satisfy each bin level, cost breakdowns of these individual
components, and how this technology will be modified over time to
maintain compliance with increasingly stringency levels. The agencies
included the technology cost of aerodynamic improvements, such as wheel
covers and active grill shutters, in RIA Chapter 2.11.
The agencies also received comments associated with other costs
that should be considered related to the technologies, specifically 6x2
axle configurations, tire pressure monitoring and inflation system, and
APUs. ATA and First Industries commented that the agencies should
include additional tire wear and negative residual values associated
with 6x2 axles. Schneider commented that 6x2 axle configurations cost
should include loss on resale value, increased tire wear, and cost for
electronic technology to improve traction. ATA and First Industries
commented that the cost estimates for tire inflation systems and TPMS
must include warranty limitations, useful life, maintenance and
replacement costs, as well as costs of false warnings and increased
operation of the air compressor. Doran cited a FMCSA study that found
TPMS and ATIS reduce road calls for damaged tires and reduced number of
tire replacements and did not introduce unscheduled maintenance.
Schneider commented that an electronic APU will have maintenance of
$500 per year and engine powered APUs must also include maintenance
costs. Caterpillar requested that the agencies take a total cost of
ownership approach when considering the technology feasibility and
adoption rates.
With respect to costs, all of the agencies' technology cost
analyses include both direct and indirect costs. Indirect costs include
items such as warranty. In terms of maintenance, the presence of tire
inflation management systems, should serve to improve tire maintenance
intervals and perhaps reduce vehicle downtime due to tire issues; they
may also carry with them some increased maintenance costs to ensure
that the tire inflation systems themselves remain in proper operation.
For the analysis, we have considered these two competing factors to
cancel each other out. The agencies also considered the maintenance
impact of 6x2 axles. As noted in the NACFE Confidence Report on 6x2
axles, the industry expects an overall reduction in maintenance costs
and labor for vehicles with a 6x2 configuration as compared to a 6x4
configuration.\292\ Among other savings, the reduction in number of
parts, such as the interaxle drive shaft, will reduce the number of
lubrication procedures needed and reduce the overall quantity of
differential fluid needed at change intervals. The agencies have taken
an approach to the maintenance costs for the 6x2 technology where we
believe that the overall impact will be zero. The agencies added
maintenance costs for diesel powered APUs, battery powered APUs, and
diesel fired heaters into the cost analysis for the final rulemaking,
as described in RIA Chapter 7.2.3. In response to Caterpillar's
comment, the agencies considered the total cost of ownership during the
payback calculations, included in RIA Chapter 7 of the final rule. The
payback calculations include the hardware costs of the new technologies
and their associated fixed costs, increased insurance, taxes, and
maintenance. The agencies found that for each category of vehicle--
tractor/trailers, vocational vehicles, and HD pickups and vans--
included in the Phase 2 rule that the fuel savings significantly exceed
the costs associated with the technologies over the lifetime of the
vehicles.
---------------------------------------------------------------------------
\292\ North American Council for Freight Efficiency. Confidence
Findings on the Potential of 6x2 Axles. 2014.
[[Page 73620]]
Table III-25--Class 7 and 8 Tractor Technology Incremental Costs in the 2021 Model Year \a\ \b\ Final Standard vs. the Flat Baseline
[2013$ per vehicle]
--------------------------------------------------------------------------------------------------------------------------------------------------------
Class 7 Class 8
---------------------------------------------------------------------------------------------------------------
Day cab Day cab Sleeper cab
---------------------------------------------------------------------------------------------------------------
Low/mid roof High roof Low/mid roof High roof Low roof Mid roof High roof
--------------------------------------------------------------------------------------------------------------------------------------------------------
Engine \c\.............................. $284 $284 $284 $284 $284 $284 $284
Aerodynamics............................ 164 299 164 299 119 119 349
Tires................................... 39 9 61 16 61 56 16
Tire inflation system................... 259 259 300 300 300 300 300
Transmission............................ 4,096 4,096 4,096 4,096 4,096 4,096 4,096
Axle Efficiency......................... 71 71 101 101 101 101 101
Idle reduction.......................... 0 0 0 0 1,998 1,998 1,909
Air conditioning........................ 17 17 17 17 17 17 17
Other vehicle technologies.............. 204 204 204 204 204 204 204
---------------------------------------------------------------------------------------------------------------
Total............................... 5,134 5,240 5,228 5,317 7,181 7,175 7,276
--------------------------------------------------------------------------------------------------------------------------------------------------------
Notes:
\a\ Costs shown are for the 2021 model year and are incremental to the costs of a baseline tractor meeting the Phase 1 standards. These costs include
indirect costs via markups along with learning impacts. For a description of the markups and learning impacts considered in this analysis and how it
impacts technology costs for other years, refer to Chapter 2 of the RIA (see RIA 2.12).
\b\ Note that values in this table include adoption rates. Therefore, the technology costs shown reflect the average cost expected for each of the
indicated tractor classes. To see the actual estimated technology costs exclusive of adoption rates, refer to Chapter 2 of the RIA (see RIA 2.12 in
particular).
\c\ Engine costs are for a heavy HD diesel engine meant for a combination tractor. The engine costs in this table are equal to the engine costs
associated with the separate engine standard because both include the same set of engine technologies (see Section II.D.2.d.i).
Table III-26--Class 7 and 8 Tractor Technology Incremental Costs in the 2024 Model Year \a\ \b\ Preferred Alternative vs. the Flat Baseline
[2013$ per vehicle]
--------------------------------------------------------------------------------------------------------------------------------------------------------
Class 7 Class 8
---------------------------------------------------------------------------------------------------------------
Day cab Day cab Sleeper cab
---------------------------------------------------------------------------------------------------------------
Low/mid roof High roof Low/mid roof High roof Low roof Mid roof High roof
--------------------------------------------------------------------------------------------------------------------------------------------------------
Engine \c\.............................. $712 $712 $712 $712 $712 $712 $712
Aerodynamics............................ 264 465 264 465 217 217 467
Tires................................... 40 12 65 20 65 65 20
Tire inflation system................... 383 383 477 477 477 477 477
Transmission............................ 6,092 6,092 6,092 6,092 6,092 6,092 6,092
Axle Efficiency......................... 139 139 185 185 185 185 185
Idle reduction.......................... 0 0 0 0 2,946 2,946 2,946
Air conditioning........................ 32 32 32 32 32 32 32
Other vehicle technologies.............. 374 374 374 374 374 374 374
---------------------------------------------------------------------------------------------------------------
Total............................... 8,037 8,210 8,201 8,358 11,100 11,100 11,306
--------------------------------------------------------------------------------------------------------------------------------------------------------
Notes:
\a\ Costs shown are for the 2024 model year and are incremental to the costs of a baseline tractor meeting the Phase 1 standards. These costs include
indirect costs via markups along with learning impacts. For a description of the markups and learning impacts considered in this analysis and how it
impacts technology costs for other years, refer to Chapter 2 of the RIA (see RIA 2.12).
\b\ Note that values in this table include adoption rates. Therefore, the technology costs shown reflect the average cost expected for each of the
indicated tractor classes. To see the actual estimated technology costs exclusive of adoption rates, refer to Chapter 2 of the RIA (see RIA 2.12).
\c\ Engine costs are for a heavy HD diesel engine meant for a combination tractor. The engine costs in this table are equal to the engine costs
associated with the separate engine standard because both include the same set of engine technologies (see Section II.D.2.d.i).
Table III-27--Class 7 and 8 Tractor Technology Incremental Costs in the 2027 Model Year \a\ \b\ Preferred Alternative vs. the Flat Baseline
[2013$ per vehicle]
--------------------------------------------------------------------------------------------------------------------------------------------------------
Class 7 Class 8
---------------------------------------------------------------------------------------------------------------
Day cab Day cab Sleeper cab
---------------------------------------------------------------------------------------------------------------
Low/mid roof High roof Low/mid roof High roof Low roof Mid roof High roof
--------------------------------------------------------------------------------------------------------------------------------------------------------
Engine \c\.............................. $1,579 $1,579 $1,579 $1,579 $1,579 $1,579 $1,579
Aerodynamics............................ 453 547 453 547 415 415 639
[[Page 73621]]
Tires................................... 43 12 70 20 70 70 20
Tire inflation system................... 469 469 594 594 594 594 594
Transmission............................ 7,098 7,098 7,098 7,098 7,098 7,098 7,098
Axle Efficiency......................... 168 168 220 220 220 220 220
Idle reduction.......................... 0 0 0 0 3,134 3,173 3,173
Air conditioning........................ 45 45 45 45 45 45 45
Other vehicle technologies.............. 380 380 380 380 380 380 380
---------------------------------------------------------------------------------------------------------------
Total............................... 10,235 10,298 10,439 10,483 13,535 13,574 13,749
--------------------------------------------------------------------------------------------------------------------------------------------------------
Notes:
\a\ Costs shown are for the 2027 model year and are incremental to the costs of a baseline tractor meeting the Phase 1 standards. These costs include
indirect costs via markups along with learning impacts. For a description of the markups and learning impacts considered in this analysis and how it
impacts technology costs for other years, refer to Chapter 2 of the RIA (see RIA 2.12).
\b\ Note that values in this table include adoption rates. Therefore, the technology costs shown reflect the average cost expected for each of the
indicated tractor classes. To see the actual estimated technology costs exclusive of adoption rates, refer to Chapter 2 of the RIA (see RIA 2.12 in
particular).
\c\ Engine costs are for a heavy HD diesel engine meant for a combination tractor. The engine costs in this table are equal to the engine costs
associated with the separate engine standard because both include the same set of engine technologies (see Section II.D.2.d.i).
The technology costs associated with the heavy-haul tractor
standards are shown below in Table III-28.
Table III-28--Heavy-Haul Tractor Technology Incremental Costs in the 2021, 2024, and 2027 Model Year \a\ \b\
Preferred Alternative vs. the Flat Baseline
[2013$ per vehicle]
----------------------------------------------------------------------------------------------------------------
2021 MY 2024 MY 2027 MY
----------------------------------------------------------------------------------------------------------------
Engine \c\...................................................... $284 $712 $1,579
Tires........................................................... 61 65 70
Tire inflation system........................................... 300 477 594
Transmission.................................................... 4,096 6,092 7,098
Axle Efficiency................................................. 101 185 220
Air conditioning................................................ 17 32 45
Other vehicle technologies...................................... 204 374 380
-----------------------------------------------
Total....................................................... 5,063 7,937 9,986
----------------------------------------------------------------------------------------------------------------
Notes:
\a\ Costs shown are for the specified model year and are incremental to the costs of a baseline tractor meeting
the Phase 1 standards. These costs include indirect costs via markups along with learning impacts. For a
description of the markups and learning impacts considered in this analysis and how it impacts technology
costs for other years, refer to Chapter 2 of the RIA (see RIA 2.12).
\b\ Note that values in this table include adoption rates. Therefore, the technology costs shown reflect the
average cost expected for each of the indicated tractor classes. To see the actual estimated technology costs
exclusive of adoption rates, refer to Chapter 2 of the RIA (see RIA 2.12 in particular).
\c\ Engine costs are for a heavy HD diesel engine meant for a combination tractor.
(2) Consistency of the Tractor Standards With the Agencies' Legal
Authority
The HD Phase 2 standards are based on adoption rates for
technologies that 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.D.1(b) through (d) above;
see also RIA Chapter 2.8. The agencies believe these technologies can
be adopted at the estimated rates for these standards within the lead
time provided, as discussed above and in RIA Chapter 2.8. The 2021 and
2024 MY standards are phase-in standards on the path to the 2027 MY
standards and were developed using less aggressive application rates
and therefore have lower technology package costs than the 2027 MY
standards. Moreover, we project the cost of these technologies will be
rapidly recovered by operators due to the associated fuel savings, as
shown in the payback analysis included in Section IX below. The cost
per tractor to meet the 2027 MY standards is projected to range between
$10,200 and $13,700 (which includes the cost of the engine standards).
See Table III-25 above. Much or all of this will be recovered in the
form of fuel savings during the first two years of ownership. The
agencies note that while the projected costs per vehicle are
significantly greater than the costs projected for Phase 1, we still
consider that cost to be reasonable, especially given the relatively
short payback
[[Page 73622]]
period. In this regard the agencies note that the estimated payback
period for tractors of less than two years,\293\ is itself shorter than
the estimated payback period for light duty trucks in the 2017-2025
light duty greenhouse gas standards. That period was slightly over
three years, see 77 FR 62926-62927, which EPA found to be a highly
reasonable given the usual period of ownership of light trucks is
typically five years.\294\ The same is true here. Ownership of new
tractors is customarily four to six years, meaning that the greenhouse
gas and fuel consumption technologies pay for themselves early on and
the purchaser sees overall savings in succeeding years--while still
owning the vehicle.\295\ The agencies note further that the costs for
each subcategory are relatively proportionate; that is, costs of any
single tractor subcategory are not disproportionately higher (or lower)
than any other. Although the rule is technology-forcing (especially
with respect to aerodynamic and drivetrain efficiency improvements),
the agencies believe that manufacturers retain leeway to develop
alternative compliance paths, increasing the likelihood of the
standards' successful implementation. The agencies also regard these
reductions as cost-effective, even without considering payback period.
The agencies estimate the cost per metric ton of CO2eq
reduction without considering fuel savings to be $36 for tractor-
trailers in 2030 which compares favorably with the levels of cost
effectiveness the agencies found to be reasonable for light duty
trucks.296 297 See 77 FR 62922. The phase-in 2021 and 2024
MY standards are less stringent and less costly than the 2027 MY
standards and hence likewise reasonable. For these reasons, and because
the agencies have carefully considered lead time and shown that lead
time is adequate, EPA believes they are also reasonable under Section
202(a) of the CAA. Given that the agencies believe these standards are
technically feasible, are highly cost effective, and even more highly
cost effective when 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, and EPA has taken steps
to avoid adverse collateral consequences from use of APUs without
filter-based particulate controls), these standards represent a
reasonable choice under Section 202(a)(2) of the CAA and the maximum
feasible under NHTSA's EISA authority at 49 U.S.C. 32902(k)(2).
---------------------------------------------------------------------------
\293\ See RIA Chapter 7.2.4.
\294\ Auto Remarketing. Length of Ownership Returning to More
Normal Levels; New Registrations Continue Slow Climb. April 1, 2013.
Last accessed on February 26, 2015 at http://www.autoremarketing.com/trends/length-ownership-returning-more-normal-levels-new-registrations-continue-slow-climb.
\295\ North American Council for Freight Efficiency. Barriers to
Increased Adoption of Fuel Efficiency Technologies in Freight
Trucking. July 2013. Page 24.
\296\ See RIA Chapter 7.2.5 and Memo to Docket ``Tractor-Trailer
Cost per Ton Values.'' July 2016. EPA-HQ-OAR-2014-0827.
\297\ If using a cost effectiveness metric that treats fuel
savings as a negative cost, net costs per ton of GHG emissions
reduced or per gallon of avoided fuel consumption will be negative
under these standards.
---------------------------------------------------------------------------
(3) Alternative Tractor Standards Considered
The agencies developed and considered other alternative levels of
stringency for the Phase 2 program. The results of the analysis of
these alternatives are discussed below in Section X of the Preamble.
For tractors, the agencies developed the following alternatives as
shown in Table III-29. The agencies are not adopting standards
reflecting Alternative 2, because as already described, technically
feasible standards are available that provide for greater emission
reductions and reduced fuel consumption than provided under Alternative
2. The agencies are not adopting standards reflecting Alternative 4 or
Alternative 5 in their entirety because we do not believe to be
feasible considering lead time and other relevant factors. However, we
note that the tractor standards are predicated on the adoption of
engine technology beyond what was projected in Alternative 4 of the
NPRM. In addition, the final rule stringency includes additional
technologies for tractors that were not considered in any of the
alternatives analyzed in the NPRM--axle efficiency, transmission
efficiency, adjustable automatic engine shutdown systems, and tire
pressure monitoring systems.
Table III-29--Summary of Alternatives Considered for the Final
Rulemaking
------------------------------------------------------------------------
Alternatives 1a and 1b No action alternatives
------------------------------------------------------------------------
Alternative 2..................... Less Stringent than the Preferred
Alternative applying off-the-shelf
technologies.
Preferred Alternative............. Final Phase 2 standards, fully
phased-in by 2027 MY.
Alternative 4..................... Alternative presented in the NPRM
that pulls ahead the proposed 2027
MY standards to 2024 MY.
Alternative 5..................... Alternative based on very high
market adoption of advanced
technologies.
------------------------------------------------------------------------
E. Phase 2 Compliance Provisions for Tractors
In HD Phase 1, the agencies developed an entirely new program to
assess the CO2 emissions and fuel consumption of tractors.
The agencies are carrying over many aspects of the Phase 1 compliance
approach, but we are also adopting changes to enhance several aspects
of the compliance program. The sections below highlight the key areas
that are the same and those that are different.
(1) HD Phase 2 Compliance Provisions That Remain the Same
The overall Phase 2 regulatory structure is discussed in more
detail above in Section II. This section discusses tractor-specific
compliance provisions.
(a) Application and Certification Process
For the Phase 2 final rule, the agencies are keeping many aspects
of the HD Phase 1 tractor compliance program. For example, the agencies
will continue to use GEM (as revised for Phase 2), in coordination with
additional component testing by manufacturers to determine the inputs,
to determine compliance with the fuel efficiency and CO2
standards. Another aspect that we are carrying over is the overall
compliance approach. EMA's and the HD manufacturers' comments supported
the continued use of GEM and did not support chassis-based
certification.
In Phase 1 and as finalized in Phase 2, the general compliance
process in terms of the pre-model year, during the model year, and post
model year activities remains unchanged. The manufacturers will be
required to apply
[[Page 73623]]
for certification through a single source, EPA, with limited sets of
data and GEM results (see 40 CFR 1037.205). EPA will issue certificates
upon approval based on information submitted through the VERIFY
database (see 40 CFR 1037.255). In Phase 1, EPA and NHTSA jointly
review and approve innovative technology requests, i.e. performance of
any technology whose performance is not measured by the GEM simulation
tool and is not in widespread use in the 2010 MY. For Phase 2, the
agencies are adopting a similar process for allowing credits for off-
cycle technologies that are not measured by the GEM simulation tool,
although the revised GEM now recognizes many more technologies than the
Phase 1 version of GEM, notably drivetrain and transmission
improvements, so fewer technologies would be candidates for off-cycle
credits (see Section I.B.v. for a more detailed discussion of off-cycle
requests). During the model year, the manufacturers will continue to
generate certification data and conduct GEM runs on each of the vehicle
configurations it builds. After the model year ends, the manufacturers
will submit end of year reports to EPA that include the GEM results for
all of the configurations it builds, along with credit/deficit balances
if applicable (see 40 CFR 1037.250 and 1037.730). EPA and NHTSA will
jointly coordinate on any enforcement action required.
(b) Compliance Requirements
As proposed in Phase 2, the agencies did not adopt any provisions
in the final Phase 2 rules that significantly change the following
Phase 1 provisions:
Useful life of tractors (40 CFR 1037.105(e) and 1037.106(e))
although added for NHTSA in Phase 2 (49 CFR 535.5)
Emission-related warranty requirements (40 CFR 1037.120)
Maintenance instructions, allowable maintenance, and amending
maintenance instructions (40 CFR 1037.125 and 137.220)
Deterioration factors (40 CFR 1037.205(l) and 1037.241(c))
Vehicle family, subfamily, and configurations (40 CFR
1037.230), except for the addition of a heavy-haul family in Phase 2
(c) Drive Cycle Speed Targets and Weightings
In Phase 1, the agencies adopted three drive cycles used in GEM to
evaluate the fuel consumption and CO2 emissions from various
vehicle configurations. One of the cycles is the Transient mode of the
California ARB Heavy Heavy-Duty Truck 5 Mode cycle. It is intended to
broadly cover urban driving. The other two cycles represent highway
driving at 55 mph and 65 mph.
The agencies proposed to maintain the existing Phase 1 drive cycle
speed traces and weightings in Phase 2. In the Phase 2 proposal sleeper
cab weightings would remain 5 percent of the Transient cycle, 9 percent
of the 55 mph cycle, and 86 percent of the 65 mph cycle. The day cabs
would be weighted based on 19 percent of the transient cycle, 17
percent of the 55 mph cycle, and 64 percent of the 65 mph cycle (see
proposed 40 CFR 1037.510(c) and 80 FR 40242). In response to the Phase
2 NPRM, the American Trucking Associations (ATA) submitted comments
based on spot speed records throughout the month of May 2015. This
study found that Class 8 trucks operated at speeds of 55 mph or less 57
percent of the time. United Parcel Service (UPS) stated that their
Class 8 tractor-trailers average 54 miles per hour in part because they
use vehicle speed limiters in their fleet. UPS also shared ATA's
comments on the spot speed records. Daimler stated that they did not
see a benefit of increasing the amount of low speed operation for
tractors, unless the EPA-NREL work supported the need for a change.
The agencies considered these comments along with the information
that was used to derive the drive cycle weightings in Phase 1. The
agencies did not receive any new drive cycle weighting data for
tractors from the EPA-NREL work. The agencies believe that the study
cited by ATA includes weightings of speed records, which represent the
fraction of time spent at a given speed. However, our drive cycle
weightings represent the fraction of vehicle miles traveled (VMT). The
agencies used the vehicle speed information provided in the ATA
comments and translated the weightings to VMT. Based on our assessment
shown in RIA Chapter 3.4.3, their findings produce weightings that are
approximately 74 percent of the vehicle miles traveled are at speeds
greater than 55 mph and 26 percent less than 55 mph. In addition, the
study cited by ATA represents ``Class 8 trucks'' which would include
day cab tractors, sleeper cab tractors, and heavy heavy-duty vocational
trucks. Based on this assessment, the agencies do not believe this new
information is significantly different than the drive cycle weightings
that were proposed. Therefore, we are adopting the drive cycle
weightings for tractors that we adopted for Phase 1 and proposed for
Phase 2.
Both in the Phase 1 program and as proposed in the Phase 2 program,
the 55 mph and 65 mph drive cycles used in GEM assume a constant target
speed with downshifting occurring if road incline causes a
predetermined drop in vehicle speed. In real-world vehicle operation,
traffic conditions and other factors may cause periodic operation at
lower (e.g. creep) or variable vehicle speeds. In the Phase 2 NPRM, the
agencies requested comment on the need to include segments of lower or
variable speed operation in the nominally 55 mph and 65 mph drive
cycles used in GEM and how this may or may not impact the strategies
manufacturers would develop. 80 FR 80242.
In response, ACEEE commented that NREL found that constant speeds
on positive and negative grades misrepresent the real world operation
of HD trucks because there is a strong correlation between road grade
and average speed. Daimler commented that for regulatory purposes using
a constant speed cycle with representative road grade is appropriate,
noting as well that some manufacturers use a constant speed cycle in
their internal development processes and have found it correlates well
to real world operation. They also highlight the concern that it would
be extremely difficult to develop traffic patterns that represent a
national average. However, Daimler also stated in their comments that
they do see a benefit of allowing increased variability in the vehicle
speeds in the 55 and 65 mph cycles, for evaluating the effectiveness of
technologies such as predictive cruise control.
After considering these comments and evaluating the final Phase 2
version of GEM, the agencies are adopting in the Phase 2 final rules
constant target speed for the 55 mph and 65 mph cycles, as adopted in
Phase 1. One key difference in Phase 2 is the addition of road grade in
these cruise cycles, as discussed below in Section III.E.2. The
addition of road grade to the cruise cycles brings the GEM simulation
of vehicles over the drive cycles closer to the real world operation
described by ACEEE and Daimler. Even though the cruise cycles will
continue to have constant target speeds (55 mph or 65 mph), the vehicle
may slow down from the target speed of the cycle on an uphill stretch
of road due to the addition of road grade in the Phase 2 cycles. If the
vehicle does slow down, the transmission shift logic built into GEM
will downshift the transmission to limit the amount of further vehicle
deceleration. Similarly, on the downhill portions of the cycles, the
driver control logic built into GEM will allow the vehicle to exceed
the
[[Page 73624]]
target speed by 3 mph prior to braking the vehicle.
(d) 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 Phase 2, we proposed to carry over
the total weight of the tractor-trailer combination used in GEM for
Phase 1. The agencies developed the tractor curb weight inputs for
Phase 2 from actual tractor weights measured in two of EPA's Phase 1
test programs. The trailer curb weight inputs were derived from actual
trailer weight measurements conducted by EPA and from weight data
provided to ICF International by the trailer manufacturers.\298\ We
welcomed comment on the tractor weights we proposed.
---------------------------------------------------------------------------
\298\ 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.
---------------------------------------------------------------------------
Daimler commented that there is a large spread of weights within a
subcategory given the variety of different features that a vehicle
might incorporate in order to perform its task. The agencies' proposed
curb weights for tractors may be higher than Daimler's vehicles but in
Daimler's opinion align with some of their competitors' vehicles, and
therefore are reasonable. Based on no negative comment or newer data,
the agencies are adopting the Phase 1 tractor curb weights, as
proposed.
There is a further issue of what payload weight to assign during
compliance testing. 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, this may not always be
practicable. Delivery logistics may dictate partial loading. Some
payloads, such as potato chips, may fill the trailer before it reaches
the vehicle's maximum weight limit. Or full loads simply may not be
available commercially. M.J. Bradley analyzed the Truck Inventory and
Use Survey and found that approximately 9 percent of combination
tractor miles travelled empty, 61 percent are ``cubed-out'' (the
trailer volume is full before the weight limit is reached), and 30
percent are ``weighed out'' (operating weight equals 80,000 lbs which
is the gross vehicle weight limit on the Federal Interstate Highway
System or greater than 80,000 lbs for vehicles traveling on roads
outside of the interstate system).\299\
---------------------------------------------------------------------------
\299\ 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.
---------------------------------------------------------------------------
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
Phase 1, 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
payloads. FHWA's results indicated that the average payload of a Class
8 vehicle ranged from 36,247 to 40,089 lbs, depending on the average
distance travelled per day.\300\ The same study shows that Class 7
vehicles carried between 18,674 and 34,210 lbs of payload also
depending on average distance travelled per day. Based on these data,
the agencies proposed to continue to prescribe a fixed payload of
25,000 lbs for Class 7 tractors and 38,000 lbs for Class 8 tractors for
certification testing for Phase 2. The agencies also proposed to
continue to use a common payload for Class 8 day cabs and sleeper cabs
as a predefined GEM input because the data available do not distinguish
among Class 8 tractor types. 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.''
---------------------------------------------------------------------------
\300\ 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.
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The agencies requested comments and data to support changes to our
proposed payloads for Phase 2. 80 FR 40242. Daimler commented that the
payload weight is even more difficult to determine because weights
change based on economic conditions, such as when carriers continue to
try to reduce their dead volume and increase their weight per load.
Daimler suggested that the agencies might consider increasing the
proposed payloads, but did not provide data. In the absence of newer
data or other compelling comments, the agencies continue to believe
that it is appropriate to continue using the Phase 1 tractor payloads
for all of the Class 7 and 8 tractors, as proposed, except for heavy-
haul.
Details of the predefined weights by regulatory subcategory, as
shown in Table III-30, are included in RIA Chapter 3.
Table III-30--Final Combination Tractor Weight Inputs
----------------------------------------------------------------------------------------------------------------
Regulatory Tractor tare Trailer Total weight
Model type subcategory weight (lbs) weight (lbs) Payload (lbs) (lbs)
----------------------------------------------------------------------------------------------------------------
Class 8....................... Sleeper Cab High 19,000 13,500 38,000 70,500
Roof.
Class 8....................... Sleeper Cab Mid 18,750 10,000 38,000 66,750
Roof.
Class 8....................... Sleeper Cab Low 18,500 10,500 38,000 67,000
Roof.
Class 8....................... Day Cab High 17,500 13,500 38,000 69,000
Roof.
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 11,500 13,500 25,000 50,000
Roof.
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
Class 8....................... Heavy-Haul...... 19,000 13,500 86,000 118,500
----------------------------------------------------------------------------------------------------------------
[[Page 73625]]
(e) Tire Testing
In Phase 1, manufacturers are required to input their tire rolling
resistance coefficient into GEM. Also in Phase 1, the agencies adopted
the provisions in ISO 28580 to determine the rolling resistance of
tires. As described in 40 CFR 1037.520(c), the agencies require that at
least three tires for each tire design are to be tested at least one
time. Our assessment of the Phase 1 program to date indicates that
these requirements reasonably balance the need for precision,
repeatability, and testing burden. Therefore we proposed to carry over
the Phase 1 testing provisions for tire rolling resistance into Phase
2. 80 FR 40243. We welcomed comments regarding the tire testing
provisions, but did not receive any. Therefore, based on the same
reasoning presented at proposal, we are adopting the Phase 1 tire
testing provisions in Phase 2.
In Phase 1, the agencies received comments from stakeholders
highlighting a need to develop a reference lab and alignment tires for
the HD sector. The agencies discussed the lab-to-lab comparison
conducted in the Phase 1 EPA tire test program (80 FR 40243, citing to
76 FR 57184). The agencies reviewed the rolling resistance 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. Based on these results, the agencies
believe the lab-to-lab variation for the STL and Smithers laboratories
will have very small effect on measured rolling resistance values.
Based on the test data, the agencies judge for the HD Phase 2 program
to continue to use the current levels of variability, and the agencies
therefore proposed to allow the use of either Smithers or STL
laboratories for determining the tire rolling resistance value. The
agencies requested comment on the need to establish a reference machine
for the HD sector and whether tire testing facilities are interested in
and willing to commit to developing a reference machine. The agencies
did not receive any comments on the issue. Therefore, again based on
the reasoning presented at proposal, we are adopting the Phase 1
testing approach for Phase 2.
(2) Key Differences in HD Phase 2 Compliance Provisions
The agencies are adopting certain provisions in Phase 2 that are
significantly different from Phase 1. Details regarding some of these
key changes such as aerodynamic assessments, road grade in the drive
cycles, weight reduction, GEM inputs, emission control labels, and
chassis dynamometer testing are provided in this subsection.
(a) Aerodynamic Assessment
In Phase 1, the manufacturers conduct aerodynamic testing to
establish the appropriate bin and GEM input for determining compliance
with the CO2 and fuel consumption standards. The agencies
proposed to continue this general approach in HD Phase 2, but to make
several enhancements to the aerodynamic assessment of tractors. As
discussed below, we proposed some modifications to the aerodynamic test
procedures--the addition of wind averaged drag in the aerodynamic
assessment, the addition of trailer skirts to the standard trailer used
to determine aerodynamic performance of tractors and revisions to the
aerodynamic bins. As discussed in more detail in the following
subsections, we are adopting many of the proposed Phase 2 aerodynamic
test procedures, but with some additional revisions to the test
procedures. These procedures are then appropriately reflected in the
final Phase 2 aerodynamic bins.
(i) Phase 1 Aerodynamic Test Procedures
The aerodynamic drag of a vehicle is determined by the vehicle's
coefficient of drag (Cd), frontal area, air density and speed.
Quantifying tractor aerodynamics as an input to the GEM presents
technical challenges because of the proliferation of tractor
configurations and subtle variations in measured aerodynamic values
among various test procedures. In Phase 1, Class 7 and 8 tractor
aerodynamic results are developed by manufacturers using a range of
techniques, including wind tunnel testing, computational fluid
dynamics, and constant speed tests.
We continue to believe a broad approach allowing manufacturers to
use these multiple 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. However,
we also recognize the need for consistency and a level playing field in
evaluating aerodynamic performance. To address the consistency and
level playing field concerns, NHTSA and EPA adopted in Phase 1, while
working with industry, an approach that identified a reference
aerodynamic test method (coastdown) and a procedure to align results
from other aerodynamic test procedures with the reference method by
applying a correction factor (Falt-aero) to results from
alternative methods. The Phase 1 regulations require manufacturers to
use good engineering judgment in developing their corrections and
specify some minimum testing requirements.
(ii) Reference Aerodynamic Method in Phase 2
Based on feedback received during the development of Phase 1, we
understood even before the Phase 2 NPRM was issued that there was
interest from some manufacturers to change the reference method in
Phase 2 from coastdown to constant speed testing. EPA conducted an
aerodynamic test program at Southwest Research Institute to evaluate
both methods in terms of cost of testing, testing time, testing
facility requirements, and repeatability of results. Details of the
analysis and results are included in RIA Chapter 3.2. The results
showed that the enhanced coastdown test procedures and analysis
produced results with acceptable repeatability and at a lower cost than
the constant speed testing. Based on the results of this testing, the
agencies proposed to continue to use the enhanced coastdown procedure
for the reference method in Phase 2.\301\ 80 FR 40244. However, we
welcomed comment on the need to change the reference method for the
Phase 2 final rule to constant speed testing, including comparisons of
aerodynamic test results using both the coastdown and constant speed
test procedures. In addition, we welcomed comments on and suggested
revisions to the constant speed test procedure specifications set forth
in the proposal in Chapter 3.2.2.2 of the draft RIA and 40 CFR 1037.533
in the proposed regulations (40 CFR 1037.534 in the final regulations).
---------------------------------------------------------------------------
\301\ Southwest Research Institute. ``Heavy Duty Class 8 Truck
Coastdown and Constant Speed Testing.'' April 2015.
---------------------------------------------------------------------------
Several stakeholders provided comments both in favor and against
the use of coastdown as the reference aero method for Phase 2 for
tractors. CARB does not support the constant speed test as the
reference method until it can be demonstrated to be superior to the
coastdown methods. Their concerns included the cost associated with
vehicle modifications required in test preparation (such as the torque
meters
[[Page 73626]]
on the wheel hubs). Daimler did not support a change to constant speed
testing for the reference method and stated that more time is needed to
determine if constant speed testing would be a better alternative.
Navistar supports the coastdown as the reference method and does not
believe constant speed testing should be adopted even as an
alternative, unless significant further work is conducted. EMA stated
that they could not support the adoption of constant speed testing as
the reference method in Phase 2 because there is insufficient time in
the process to properly study whether constant speed is equivalent to
or better than coastdown testing. Further, EMA recommended that
constant speed testing be included only as a potential alternative to
be phased in at a future date if appropriate. Volvo opposed a change in
the aerodynamic reference test method to constant speed at this time
due to insufficient time to fully evaluate the new test method.
Exa supported the use of constant speed testing as a reference
method because it is a real-world measurement with the ability to
evaluate wind-averaged drag. Exa also cited some concerns that
coastdown is limited to near zero wind yaw angle and does not
accurately represent the aerodynamics experienced on the road. MEMA
supported including the constant speed test based on research that has
demonstrated that it is reliable relative to coastdown tests and is
required in European aerodynamic test protocols. SABIC commented that
constant speed testing may help isolate the aerodynamic drag from
vibration, mechanical, and friction encountered at low speeds. SABIC
also cited research that suggested constant speed testing may provide
better repeatability than coastdown tests, and suggested that the U.S.
may be able to promote harmonization with the required European
constant speed testing.
After consideration of the comments, the agencies are continuing to
use the Phase 1 approach of setting coastdown testing as the reference
method for tractor aerodynamic assessment in Phase 2. After developing
revised coastdown test procedures and data analysis methods for the
final rule, we have concluded that coastdown testing continues to
produce acceptable repeatability and can be conducted at a lower cost
than constant speed testing. However, we are finalizing some revisions
to the Phase 2 coastdown test procedures in response to comments and
discussed below. The agencies are also continuing to allow alternative
test methods to be used to determine the aerodynamic performance of
tractors in Phase 2, as long as the results are correlated back to the
reference method using a correlation factor (Falt-aero). Additional
details are included in the Falt-aero discussion below.
(iii) Coastdown Test Procedure Changes for Phase 2
The agencies worked closely with the tractor manufacturers between
the Phase 2 NPRM and final rulemaking to develop robust coastdown test
procedures that are technically sound.\302\ EPA also continued to test
additional tractors after the proposal to better inform the test
procedure development. Based on this work, the agencies are adopting
aerodynamic test procedures that have been improved from those proposed
for Phase 2. The details of these procedures and their development are
included in RIA Chapter 3.2. Below is a summary of the changes to the
coastdown test procedures and data analysis method for the final rule.
---------------------------------------------------------------------------
\302\ Memo to Docket. Aerodynamic Subteam Meetings with EMA.
July 2016. Docket EPA-HQ-OAR-2014-0827.
---------------------------------------------------------------------------
The coastdown test procedure changes include the tested speed
range, the calibration of the equipment, and specification of yaw and
air speed measurements. The agencies proposed two test speed ranges for
coastdown testing--70 to 60 mph and 25 to 15 mph. EPA's evaluation of
the CdA values in relation to yaw angle showed that the 25
to 15 mph low-speed range specified in the NPRM test procedures
produced yaw curves that were flatter than expected and flatter than
demonstrated using other test methods, such as wind tunnels and CFD.
Upon further analysis, EPA found that by reducing the low-speed range
to even lower speeds, the yaw curve results were more representative.
The best speed range to alleviate this concern is a 15 to 5 mph low
speed range; however, requiring this would significantly reduce the
number of available days for testing in a given year because it would
lead to a wind speed limit of 3 mph. Therefore, the agencies are
adopting a low speed range of 20 to 10 mph to balance the yaw curve
representativeness with the real world testing implications. Along with
this test speed change, the component of the wind speed parallel to the
road or track will be limited to less than or equal to 6 mph. The
agencies are adopting Phase 2 coastdown test procedures that specify
the yaw measurement method resolution and accuracy requirements similar
to those proposed for constant speed testing. The calibration of the
yaw and air speed equipment will be conducted in a point-by-point
manner for each run.
The coastdown data analysis changes include the analysis of low
speed pairs and filtering methods, adjustments for rear axle losses and
rolling resistance, and determination of the final CdA value
for coastdown. EPA found that the method proposed to analyze the
coastdown results of paired runs leads to an unexpected yaw curve
asymmetry. Upon further evaluation, EPA found that the yaw curve
asymmetry is mitigated by averaging the road load force and air speed
from every two opposite direction low-speed segments and using the
average with each of the high speed segments in the data analysis.
Therefore, the agencies are adopting this method for the Phase 2 final
rules. The filtering of the air speed, yaw, vehicle speed, and track
wind speed is necessary to remove outliers and replace the data with
the moving median value to reduce the variability of coastdown test
results. The agencies are specifying this filtering method in the final
rules. Coastdown testing measures all of the losses associated with the
vehicle, including aerodynamics, rolling resistance, and axle spin
losses. To isolate the aerodynamic CdA, it is important to
remove the losses associated with drive axle and tire rolling
resistance. For the final Phase 2 rules, the agencies are adopting the
SAE J2452 test procedures that require manufacturers to measure the
speed dependence of the tire rolling resistance for each of the steer,
drive, and trailer tire models used on the article undergoing a
coastdown test. The agencies are also requiring that manufacturers
measure the speed dependence of the drive axle spin losses for the
drive axle model used in the article undergoing a coastdown test using
a subset of the rear axle efficiency test procedure being adopted in
Phase 2.
The agencies have also developed a process of identifying and
removing coastdown test result outliers for the final rules. First, the
median yaw angle of the data is determined. All results outside of a
range of plus or minus 1 yaw degree are removed. Then the mean
CdA value of the remaining data points is determined.
CdA values that lie outside of plus or minus two standard
deviations from the CdA mean are removed. At least 24 data
points are needed after removal of outliers for the results to be
valid. Finally, the mean CdA and mean effective yaw angle
are calculated from the remaining points. These values are then used to
adjust to reflect a 4.5 degree yaw angle result
[[Page 73627]]
based on an alternate method yaw curve results.
(iv) Improving Correlation of Coastdowns With Alternative Methods
(Falt-aero)
As already noted, the agencies adopted in Phase 1 a coastdown
procedure as the reference method (see 40 CFR 1066.310) and defined a
process for manufacturers to align drag results from each of their own
alternative test methods to the reference method results using
Falt-aero (see 40 CFR 1037.525).\303\ Manufacturers are able
to use any aerodynamic evaluation method in demonstrating a vehicle's
aerodynamic performance as long as they obtain our prior approval and
the method is aligned to the reference method. The agencies proposed to
continue to use this alignment method approach in Phase 2 to maintain
the testing flexibility that manufacturers have today. However, the
agencies proposed to increase the rigor in determining the
Falt-aero for Phase 2, including enhancing the minimum
testing requirements. Beginning in MY 2021, we proposed that the
manufacturers would be required to determine a new Falt-aero
for each of their tractor models for each aerodynamic test method. In
Phase 1, manufacturers are required to determine their
Falt-aero using only a high roof sleeper cab with a full
aerodynamics package (see 40 CFR 1037.521(a)(2) and proposed 40 CFR
1037.525(b)(2)). In Phase 2, we proposed that manufacturers would be
required to determine a unique Falt-aero value for each
major model of their high roof day cabs and high roof sleeper cabs. In
Phase 2, we proposed that manufacturers may carry over the
Falt-aero value until a model changeover or based on the
agencies' discretion to require up to six new Falt-aero
determinations each year. We requested comment on the amount of testing
required to accurately develop a Falt-aero value and the
burden associated with it. See 80 FR 40244.
---------------------------------------------------------------------------
\303\ Falt-aero is an experimentally determined
factor that represents the ratio of coastdown results to results
from the alternative method. The agencies allow other functional
forms of the relationship consistent with good engineering judgment.
---------------------------------------------------------------------------
The agencies received comments with regard to the need of
Falt-aero and the burden of determining it. Exa Corporation
(a supplier of CFD software) commented that it is not clear that the
Falt-aero factor would alleviate challenges associated with
their expectation that the absolute drag values will differ
substantially between different test methods and different facilities.
Exa suggested that the agencies require a certification procedure for
an alternate tool that includes a broad validation suite including
different types of vehicles from aerodynamic sleeper to less
aerodynamic day cabs. The HD vehicle manufacturers strongly recommended
that the agencies reduce the number of coastdown tests that must be
conducted each year. Navistar commented that only one
Falt-aero should be required for Phase 2. Navistar's testing
of their ProStar sleeper and day cabs found that the
Falt-aero only differed within less than one percent using
the same test facility. Navistar also commented that the data in the
Phase 2 NPRM draft RIA show that three different sleepers show
Falt-aero values within 0.4 percent. EMA commented that only
one Falt-aero value should be required, as supported by the
values shown in the Phase 2 Draft RIA where the Falt-aero
values were 1.09 +/-0.02 for three tested vehicles. EMA also commented
that the proposed requirements would be time-consuming, costly, and an
unreasonable burden. Daimler supported EMA's comments. The HD vehicle
manufacturers also submitted data to the agencies that show the
Falt-aero values were within a range of one percent. Volvo
shared data with the agencies that support that Falt-aero is
highly consistent for varying truck models when correcting the test
data under the conditions and methods that the industry has
recommended. Volvo therefore concluded that multiple
Falt-aero values are not necessary for Phase 2. PACCAR
provided results from three tractor models showing the spread of
Falt-aero is less than 0.3 percent.
The agencies determined the Falt-aero values for all of
the tractors tested using different aerodynamic methods for Phase 2
using the aerodynamic test procedures and data analysis finalized for
Phase 2. As shown in further detail in RIA Chapter 3.2.1, the
Falt-aero values ranged between 1.13 and 1.20 for a single
CFD software. Therefore, the agencies concluded that a single
Falt-aero value is not sufficient for determining the
correlation of test methods for all tractors. Furthermore, based on the
comments and further refinement of our selective enforcement audit
(SEA) provisions in the Phase 2 final rule, we are adopting provisions
that require manufacturers to determine Falt-aero for a
minimum of one day cab and one sleeper cab in MYs 2021, 2024, and
2027.\304\ While this significantly reduces the test burden from the
levels proposed, it also only represents a minimum requirement. The
agencies believe that the improvements to the SEA requirements for
aerodynamics will further encourage the manufacturers to ensure that
they are accurately reflecting the Falt-aero for their entire tractor
fleet and that they may do additional Falt-aero
determinations beyond the minimum requirement in Phase 2. Without
confidence in their Falt-aero values, manufacturers would
risk SEA failures that could halt vehicle production. Even without
failing the SEA overall, failing individual vehicles would lead to
increased SEA testing. Thus, the SEA requirements will create a
stronger incentive for manufacturers to use good engineering judgment
for Falt-aero values.
---------------------------------------------------------------------------
\304\ See Section III.E.(2)(a)(ix) for details on the SEA
requirements.
---------------------------------------------------------------------------
The agencies also received comments from HD manufacturers stressing
that coastdown testing does not produce CdA values at zero
yaw as assumed. Even at calm test conditions, the resulting yaw angle
is something greater than zero degrees. The agencies evaluated our
aerodynamic test data and agree with the manufacturers. Therefore, we
are adopting Phase 2 provisions that use the effective yaw angle from
coastdown testing to determine the Falt-aero value (see 40
CFR 1037.525). See RIA Chapter 3.2.2 for additional detail.
(v) Computational Fluid Dynamics
The agencies considered refinements to the computational fluid
dynamics (CFD) modeling method to determine the aerodynamic performance
of tractors in the NPRM. Specifically, we are considering whether the
conditions for performing the analysis require greater specificity
(e.g., wind speed and direction inclusion, turbulence intensity
criteria value) or if turbulence model and mesh deformation should be
required, rather than ``if applicable,'' for all CFD analysis.\305\ The
agencies welcomed comment on the proposed revisions.
---------------------------------------------------------------------------
\305\ 40 CFR 1037.532 ``Using computational fluid dynamics to
calculate drag area (CdA).''
---------------------------------------------------------------------------
Daimler and EMA recommended that the agencies should raise the test
speed for CFD from the proposed 55 mph to 65 mph to be consistent with
GEM and the sleeper cab tractor weighting of 86 percent. Daimler
supported the agencies' other proposed revisions to CFD test
procedures.
The agencies agree with the suggested comment to include
consistency between the test methods and are adopting CFD provisions
that include a test speed of 65 mph, along with the other proposed
revisions. The agencies finalized these changes through incorporation
of the SAE J2966 CFD guidelines with exceptions and clarifications to
keep other aspects of
[[Page 73628]]
the CFD simulations consistent with Phase 1.
(vi) Wind Averaged Drag Determination
In Phase 1, EPA and NHTSA recognized 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.\306\ As noted in the NAS report, the wind
average drag coefficient is about 15 percent higher than the zero
degree coefficient of drag.\307\ In addition, the agencies received
comments in Phase 1 that supported the use of wind averaged drag
results for the aerodynamic determination. The agencies considered
adopting the use of a wind averaged drag coefficient in the Phase 1
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 took this approach
recognizing that the reference method is coastdown testing and it is
not capable of determining wind averaged yaw.\308\ Wind tunnels and CFD
are currently the only tools to accurately assess the influence of wind
speed and direction on a truck's aerodynamic performance. The agencies
recognized, 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.
---------------------------------------------------------------------------
\306\ See 2010 NAS Report, page 95.
\307\ See 2010 NAS Report, Finding 2-4 on page 39. Also see 2014
NAS Report, Recommendation 3.5.
\308\ See 2010 NAS Report. Page 95.
---------------------------------------------------------------------------
As the tractor manufacturers continue to refine the aerodynamics of
tractors, we believe that continuing the zero yaw approach into Phase 2
would potentially impact the overall technology effectiveness or change
the kinds of technology decisions made by the tractor manufacturers in
developing equipment to meet our HD Phase 2 standards. Therefore, we
proposed and are adopting aerodynamic test procedures that take into
account the wind averaged drag performance of tractors. The agencies
proposed to account for this change in aerodynamic test procedure by
appropriately adjusting the aerodynamic bins to reflect a wind averaged
drag result instead of a zero yaw result.
The agencies proposed and are adopting provisions that require
manufacturers to adjust their CdA values to represent a zero
yaw value from coastdown and add the CdA impact of the wind
averaged drag. The impact of wind averaged drag relative to a zero yaw
condition can only be measured in a wind tunnel or with CFD. This
requirement commences in MY 2021.
All stakeholders that commented on wind averaged drag supported its
use over zero yaw. ACEEE supports the shift to the use of wind averaged
drag in Phase 2. Exa supported the use of wind averaged drag because it
is a better predictor of real world fuel economy. Michelin supported
wind average drag assessments for a realistic and complete assessment
of aerodynamic performance and would prevent the unintended consequence
of incentivizing improvements that are better at zero wind conditions
but sacrifice cross-wind performance. SABIC Innovative Plastics
commented that it is imperative that wind effects be part of the
standard due to the real-world impact of wind. Plastics Industry Trade
Association supported wind average drag to better simulate real life
conditions.
PACCAR and Daimler recommended the use of a surrogate angle of
4.5[deg] in lieu of the nine angles required for a full wind averaged
draft evaluation for CFD evaluated at 65 mph. PACCAR and Daimler
provided data to support the use of a single angle. PACCAR also stated
that there is significant CFD burden associated with the use of a nine
angle yaw sweep. According to PACCAR in a given year, this would add
approximately 4,000 additional simulations to their certification
burden. EMA and other tractor manufacturers supported the single
surrogate angle of 4.5[deg] as being equivalent to the full yaw sweep
result generated with SAE J1252.
As discussed in further detail in RIA Chapter 3.2.1.1.3, our data
support that 4.5[deg] results are a good surrogate for full wind
averaged drag results for wind tunnel and CFD assessments. Therefore,
we are adopting the 4.5[deg] surrogate angle in Phase 2.
The agencies require that manufacturers use the following equation
to make the necessary adjustments to a coastdown result to obtain the
CdAwa value:
CdAwa =
CdAeffective yaw angle, coastdown *
(CdA4.5[deg]/
CdAeffective yaw angle)
If the manufacturer has a CdA value from either a wind
tunnel or CFD, then they will use the following equation to obtain the
CdA wad value:
CdAwa = CdA4.5[deg] *
Falt-aero
Because the agencies are adopting a 4.5[deg] surrogate angle, the
agencies are not adopting the proposed provisions that manufacturers
have the option of determining the offset between zero yaw and wind
averaged yaw either through testing or by using the EPA-defined default
offset.
(vii) Standard Trailer Definition
Similar to the approach the agencies adopted in Phase 1, NHTSA and
EPA are adopting provisions such that the tractor performance in GEM is
judged assuming the tractor is pulling a standardized trailer.\309\ The
agencies believe that an assessment of the tractor fuel consumption and
CO2 emissions should be conducted using a tractor-trailer
combination, as tractors are invariably used in combination with
trailers and this is their essential commercial purpose. Trailers, of
course, also influence the extent of carbon emissions from the tractor
(and vice-versa). We believe that using a standardized trailer best
reflects the impact of the overall weight of the tractor-trailer and
the aerodynamic technologies in actual use, and consequent real-world
performance, where tractors are designed and used with a trailer. EPA
research confirms what one intuits: Tractor-trailer pairings are almost
always optimized, but this does not indicate that a tractor always uses
the same trailer. EPA conducted an evaluation of over 4,000 tractor-
trailer combinations using live traffic cameras in 2010.\310\ The
results showed that approximately 95 percent of the tractors were
matched with the standard trailer specified (high roof tractor with dry
van trailer, mid roof tractor with tanker trailer, and low roof with
flatbed trailer). Therefore, the agencies are continuing the Phase 1
approach into Phase 2 GEM to use a predefined typical trailer in
assessing overall performance for test purposes. As such, the high roof
tractors will be paired with a standard dry van trailer; the mid roof
tractors will be paired with a tanker trailer; and the low roof
tractors will be paired with a flatbed trailer.
---------------------------------------------------------------------------
\309\ See 40 CFR 1037.501(g).
\310\ See Memo to Docket, Amy Kopin. ``Truck and Trailer Roof
Match Analysis.'' August 2010.
---------------------------------------------------------------------------
However, the agencies proposed a change to the definition of the
standard dry van reference trailer used by tractor manufacturers to
determine the aerodynamic performance of high roof tractors in Phase 2.
We believe this is necessary to reflect the aerodynamic improvements
experienced by the trailer fleet over the last several years due to
influences from the California Air Resources Board mandate \311\ and
EPA's
[[Page 73629]]
SmartWay Transport Partnership. The standard dry van trailer used in
Phase 1 to assess the aerodynamic performance of high roof tractors is
a 53 foot box trailer without any aerodynamic devices. In the
development of Phase 2, the agencies evaluated the increase in adoption
rates of trailer side skirts and boat tails in the market over the last
several years and have seen a marked increase. We estimate that
approximately 50 percent of the new trailers sold in 2018 will have
trailer side skirts.312 313 As the agencies look towards
these tractor standards in the 2021 and beyond timeframe, we believe
that it is appropriate to update the standard box trailer definition.
In 2021-2027, we believe the trailer fleet will be a mix of trailers
with no aerodynamics, trailers with skirts, and trailers with advanced
aero; with the advanced aero being a very limited subset of the new
trailers sold each year. Consequently, overall, we believe a trailer
with a skirt will be the most representative of the trailer fleet for
the duration of the regulation timeframe, and plausibly beyond. EPA has
conducted extensive aerodynamic testing to quantify the impact on the
coefficient of drag of a high roof tractor due to the addition of a
trailer skirt. Details of the test program and the results can be found
in RIA Chapter 3.2. The results of the test program indicate that on
average, the impact of a trailer skirt matching the definition of the
skirt specified in 40 CFR 1037.501(g)(1) is approximately eight percent
reduction in drag area.
---------------------------------------------------------------------------
\311\ California Air Resources Board. Tractor-Trailer Greenhouse
Gas regulation. Last viewed on September 4, 2014 at http://www.arb.ca.gov/msprog/truckstop/trailers/trailers.htm.
\312\ Ben Sharpe (ICCT) and Mike Roeth (North American Council
for Freight Efficiency), ``Costs and Adoption Rates of Fuel-Saving
Technologies for Trailer in the North American On-Road Freight
Sector,'' Feb 2014.
\313\ Frost & Sullivan, ``Strategic Analysis of North American
Semi-trailer Advanced Technology Market,'' Feb 2013.
---------------------------------------------------------------------------
We proposed a definition of the standard dry van trailer in Phase
2--the trailer assumed during the certification process to be paired
with a high roof tractor--that includes a trailer skirt starting in
2021 model year. 80 FR 40245. Even though the agencies proposed that
new dry van trailer standards begin in 2018 MY, we did not propose to
update the standard trailer in the tractor certification process until
2021 MY, to align with the new tractor standards. If we were to revise
the standardized trailer definition for Phase 1, then we would have
needed to revise the Phase 1 tractor standards. The details of the
trailer skirt definition are included in 40 CFR 1037.501(g)(1). We
requested comment on our HD Phase 2 standard trailer configuration. We
also welcomed comments on suggestions for alternative ways to define
the standard trailer, such as developing a certified computer aided
drawing (CAD) model.
The agencies received support in comments for adopting a reference
trailer with skirts. Daimler supported the addition of side skirts to
the Phase 2 reference trailer and stated that it aligns with their
internal development process. Daimler also suggested that if the
agencies believe there will be significant adoption of trailers with
boat tails, then the agencies could update the CdA bin value
input to GEM and reduce it by 0.5 m\2\ to reflect the actual on-road
aerodynamics load without changing the standard trailer. The Plastics
Industry Trade Association stated that the proposed reference trailer
is representative of trailer aerodynamic improvements likely to emerge
during Phase 2. Navistar suggested that the standard trailer should be
more aerodynamic to reflect trailers that will be used during the life
of Phase 2 tractors. ACEEE supports the use of a more aerodynamic
reference trailer in Phase 2, however, they suggest an even more
aerodynamic reference trailer be required that is closer to the
aerodynamic packages projected to be installed on new trailers in 2027.
ACEEE and UCS suggested that Phase 2 should facilitate the transition
of promoting more tractor-trailer integration. ACEEE recommended
providing manufacturers the option to test tractors with advanced
trailers; correct the test result appropriately to account for the
benefit provided by the trailer alone to promote integration of
aerodynamically advanced tractors and trailers. UCS raised concerns
that because tractors and trailers are interchangeable and that there
is no guarantee that the Phase 2 tractors will pull the newest
trailers, therefore, the agencies should not revise the standard
trailer over the course of the rule.
The agencies re-evaluated the proposal to include trailer skirts on
the Phase 2 reference trailer with consideration of the comments. Based
on testing conducted to support the trailer portion of Phase 2, we
found that on average a boat tail added to a dry van trailer with
skirts reduces wind averaged CdA by 0.6 m\2\.\314\ We still
project that the bulk of trailers that will be in operation during the
life of tractors produced early in Phase 2 will be represented by the
aerodynamic performance of a trailer with skirts. Therefore, we are
adopting the reference trailer as proposed. However, we also want to
recognize that the trailer fleet will continue to evolve over the
lifetime of tractors built and certified to Phase 2, especially from MY
2027 and later. We recognize that if we do not account for reduced
aerodynamic loads in the real world, then we may not be appropriately
evaluating the tractor powertrain. We considered changing the standard
trailer in MY 2027; however, this would lead to significant testing
burden for the manufacturers because they would have to determine new
CdA values for their entire fleet of tractors. Instead, we
are adopting Phase 2 GEM that beginning in MY 2027 will take the
CdA input for each vehicle and reduce it by 0.3 m\2\ to
reflect the lower aerodynamic loads that are a mix of trailers with
skirts and trailers with skirts and boat tails. This change has been
accounted for in both the baseline and standard setting of the
CO2 emissions and fuel consumption values.
---------------------------------------------------------------------------
\314\ See RIA Chapter 2.10.2.1.3.
---------------------------------------------------------------------------
With respect to ACEEE's recommendation for the agencies to
facilitate the transition to more integrated tractor-trailers, such as
those demonstrated with SuperTruck, the agencies believe this would
require a significant change in tractor-trailer logistics to encourage
more matching of specific tractors to specific trailers in operation.
We believe that this would be most appropriately handled through the
Off-Cycle Credit program.
(viii) Aerodynamic Bins
The agencies proposed to continue the approach where the
manufacturer would determine a tractor's aerodynamic drag force through
testing, determine the appropriate predefined aerodynamic bin, and then
input the predefined CdA value for that bin into the GEM. 80
FR 40245. The agencies' Phase 2 aerodynamic bins reflect three changes
to the Phase 1 bins--the incorporation of wind averaged drag, the
addition of trailer skirts to the standard box trailer used to
determine the aerodynamic performance of high roof tractors (as just
explained above), and the addition of bins to reflect the continued
improvement of tractor aerodynamics in the future. Because of each of
these changes, the aerodynamic bins for Phase 2 are not directly
comparable to the Phase 1 bins.
HD Phase 1 included five aerodynamic bins to cover the spectrum of
aerodynamic performance of high roof tractors. Since the development of
the Phase 1 rules, the manufacturers have continued to invest in
aerodynamic improvements for tractors. This continued evolution of
aerodynamic performance, both in
[[Page 73630]]
production and in the research stage as part of the SuperTruck program,
has consequently led the agencies to propose two additional aerodynamic
technology bins (Bins VI and VII) for high roof tractors.
In both HD Phase 1 and Phase 2, aerodynamic Bin I through Bin V
represent tractors sharing similar levels of technology. The first high
roof aerodynamic category, Bin I, is designed to represent tractor
bodies which prioritize appearance or special duty capabilities over
aerodynamics. These Bin I tractors incorporate few, if any, aerodynamic
features and may have several features that 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 in 2010. The agencies developed this bin to incorporate
conventional tractors that capitalize on a generally aerodynamic shape
and avoid classic features that 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 2013 model year SmartWay tractors. 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. HD
Phase 1 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. For HD Phase 2, the agencies
proposed to segment the aerodynamic performance of these advanced
technologies into Bins V through VII.
In Phase 1, the agencies adopted only two aerodynamic bins for low
and mid roof tractors. The agencies limited the number of bins to
reflect the actual range of aerodynamic technologies effective in low
and mid roof tractor applications. 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 will move high roof tractors from a Bin III to Bins IV
through V include features such as gap reducers and integral roof
fairings which will not be appropriate on low and mid roof tractors.
As Phase 2 looks to further improve the aerodynamics for high roof
sleeper cabs, we believe it is also appropriate to expand the number of
bins for low and mid roof tractors too. For Phase 2, the agencies
proposed to differentiate the aerodynamic performance for low and mid
roof applications with four bins, instead of two, in response to
feedback received from manufacturers of low and mid roof tractors
related to the limited opportunity to incorporate certain aerodynamic
technologies in their compliance plan. However, upon further
discussions with EMA, it became evident to the agencies that the most
straightforward approach would be to include the same number of low and
mid roof aero bins as we have for high roof tractors.\315\ Therefore,
we are adopting seven aero bins for low and mid roof tractors in Phase
2. In addition, we proposed and are adopting provisions that allow low
and mid roof tractor aerodynamic bins to be determined based on the
aerodynamic bin of an equivalent high roof tractor, as shown below in
Table III-31.
---------------------------------------------------------------------------
\315\ Memo to Docket. Aerodynamic Subteam Meetings with EMA.
July 2016. Docket EPA-HQ-OAR-2014-0827.
Table III-31--Phase 2 Revisions to 40 CFR 1037.520(b)(3)
------------------------------------------------------------------------
High roof bin Low and mid roof bin
------------------------------------------------------------------------
Bin I..................................... Bin I.
Bin II.................................... Bin II.
Bin III................................... Bin III.
Bin IV.................................... Bin IV.
Bin V..................................... Bin V.
Bin VI.................................... Bin VI.
Bin VII................................... Bin VII.
------------------------------------------------------------------------
The agencies developed new high roof tractor aerodynamic bins for
Phase 2 that reflect the change from zero yaw to wind averaged drag,
the more aerodynamic reference trailer, and the addition of two bins.
Details regarding the derivation of the high roof bins are included in
RIA Chapter 3.2.1.2. The high roof bin values being adopted in the HD
Phase 2 final rulemaking differ from those proposed due to the
coastdown and other aerodynamic test procedures changes discussed above
in Section III.E.2.a. However, as explained above in Section III.D.1,
in both the NPRM and this final rulemaking, we developed the Phase 2
bins such that there is an alignment between the Phase 1 and Phase 2
aerodynamic bins after taking into consideration the changes in
aerodynamic test procedures and reference trailers required in Phase 2.
The Phase 2 bins were developed so that a tractor that performed as a
Bin III in Phase 1 would also perform as a Bin III tractor in Phase 2.
The high roof tractor bins are defined in Table III-32. The final
revisions to the low and mid roof tractor bins reflect the addition of
five new aerodynamic bins and are listed in Table III-33.
[[Page 73631]]
Table III-32--Phase 2 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 (CdAwad in m\2\)
----------------------------------------------------------------------------------------------------------------
Bin I........................................................... >=7.2 >=7.2 >=6.9
Bin II.......................................................... 6.6-7.1 6.6-7.1 6.3-6.8
Bin III......................................................... 6.0-6.5 6.0-6.5 5.7-6.2
Bin IV.......................................................... 5.5-5.9 5.5-5.9 5.2-5.6
Bin V........................................................... 5.0-5.4 5.0-5.4 4.7-5.1
Bin VI.......................................................... 4.5-4.9 4.5-4.9 4.2-4.6
Bin VII......................................................... <=4.4 <=4.4 <=4.1
----------------------------------------------------------------------------------------------------------------
Aerodynamic Input to GEM (CdAwad in m\2\)
----------------------------------------------------------------------------------------------------------------
Bin I........................................................... 7.45 7.45 7.15
Bin II.......................................................... 6.85 6.85 6.55
Bin III......................................................... 6.25 6.25 5.95
Bin IV.......................................................... 5.70 5.70 5.40
Bin V........................................................... 5.20 5.20 4.90
Bin VI.......................................................... 4.70 4.70 4.40
Bin VII......................................................... 4.20 4.20 3.90
----------------------------------------------------------------------------------------------------------------
Table III-33--Phase 2 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 Mid roof
--------------------------------------------------------------------------------------------------------------------------------------------------------
Aerodynamic Test Results (CdA in m\2\)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Bin I................................................... [gteqt]5.4 [gteqt]5.9 [gteqt]5.4 [gteqt]5.9 [gteqt]5.4 [gteqt]5.9
Bin II.................................................. 4.9-5.3 5.5-5.8 4.9-5.3 5.5-5.8 4.9-5.3 5.5-5.8
Bin III................................................. 4.5-4.8 5.1-5.4 4.5-4.8 5.1-5.4 4.5-4.8 5.1-5.4
Bin IV.................................................. 4.1-4.4 4.7-5.0 4.1-4.4 4.7-5.0 4.1-4.4 4.7-5.0
Bin V................................................... 3.8-4.0 4.4-4.6 3.8-4.0 4.4-4.6 3.8-4.0 4.4-4.6
Bin VI.................................................. 3.5-3.7 4.1-4.3 3.5-3.7 4.1-4.3 3.5-3.7 4.1-4.3
Bin VII................................................. <=3.4 <=4.0 <=3.4 <=4.0 <=3.4 <=4.0
--------------------------------------------------------------------------------------------------------------------------------------------------------
Aerodynamic Input to GEM (CdA in m\2\)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Bin I................................................... 6.00 7.00 6.00 7.00 6.00 7.00
Bin II.................................................. 5.60 6.65 5.60 6.65 5.60 6.65
Bin III................................................. 5.15 6.25 5.15 6.25 5.15 6.25
Bin IV.................................................. 4.75 5.85 4.75 5.85 4.75 5.85
Bin V................................................... 4.40 5.50 4.40 5.50 4.40 5.50
Bin VI.................................................. 4.10 5.20 4.10 5.20 4.10 5.20
Bin VII................................................. 3.80 4.90 3.80 4.90 3.80 4.90
--------------------------------------------------------------------------------------------------------------------------------------------------------
(ix) Selective Enforcement Audits (SEA) and Confirmatory Testing for
Aerodynamics
EPA has long required manufacturers to perform SEAs to verify that
actual production engines and vehicles conform to their certificates.
Before this rulemaking, the regulations in 40 CFR 1037.301 provided
generally for SEAs for Phase 1 vehicles, but did not provide specific
descriptions of how such testing would be conducted for coastdowns. In
Phase 1, we adopted interim provisions in 40 CFR 1037.150(k) that
accounted for coastdown measurement variability by allowing a
compliance demonstration based on in-use test results if the drag area
was at or below the maximum drag area allowed for the bin above the bin
to which the vehicle was certified. Since adoption of Phase 1, EPA has
conducted in-use aerodynamic testing and found that uncertainty
associated with coastdown testing is less than anticipated.\316\ In
addition, as noted earlier in this Section III.E.(2)(a), we proposed
and are adopting additional enhancements in the Phase 2 coastdown
procedures to continue to reduce the variability of coastdown results,
including the impact of environmental conditions. Therefore, we are
sunsetting the provision in 40 CFR 1037.150(k) at the end of the Phase
1 program (after the 2020 model year). In the NPRM, we proposed a
conventional approach to conducting SEAs with respect to aerodynamics.
See 80 FR at 40156 and proposed section 1037.301. We requested comment
on whether or not we should factor in a test variability compliance
margin into the aerodynamic test procedure, and
[[Page 73632]]
therefore requested data on aerodynamic test variability.
---------------------------------------------------------------------------
\316\ Southwest Research Institute. ``Heavy Duty Class 8 Truck
Coastdown and Constant Speed Testing.'' April 2015.
---------------------------------------------------------------------------
The agencies received comments from manufacturers arguing for the
agencies to establish compliance margins that would allow actual
production vehicles to exceed the standards by some fixed amount. These
comments included specific requests for an aerodynamic compliance
margin. We also received comments from UCS supporting the elimination
of the aerodynamic compliance margin. As explained in Section I.C.1,
although EPA sometimes provides interim compliance margins to
facilitate the initial implementation of new programs, we generally do
not consider such an approach to be an appropriate long-term policy.
Nevertheless, EPA recognizes that compliance testing relying on
coastdowns to evaluate aerodynamic parameters differs fundamentally
from traditional compliance testing, in which test-to-test variability
is normally expected to be small relative to production variability.
With coastdown testing, however, test-to-test variability is expected
to be larger relative to production variability. In response to
comments addressing this difference, EPA developed a different
structure for conducting SEAs to evaluate tractor CdA s and
solicited supplemental comments on it. See 81 FR 10825. This new
structure reflects an approach that would be consistent with the
following principles:
Test-to-test variability for individual coastdown runs can
be high, so compliance determinations should be based on average values
from multiple runs.
Coastdown testing of a single vehicle is expensive and
time consuming, so testing should focus more on repeat tests for the
same vehicle than on tests for multiple vehicles. However,
manufacturers should not be required to conduct more than 100 valid
coastdown runs on any single vehicle.
Compliance determinations should be based on whether or
not the true value for the CdA falls within the bin to which
the vehicle was certified, rather than on whether or not the true value
for the CdA exceeds the value measured for certification.
Given the limited ability to eliminate uncertainty,
compliance determinations should consider the statistical confidence
that a true value lies outside a bin.
Commenters were generally very supportive of these principles and
the proposed structure.
We believe the structure being finalized appropriately balances
EPA's need to provide strong incentives for manufacturers to act in
good faith with manufacturers' need to avoid compliance actions based
on inaccurate testing. Our current assessment is that, where a
manufacturer acts in good faith when certifying and uses good
engineering judgment throughout the process, false failures for
individual vehicles would be rare and false failures for a family would
not occur.
Under this approach, EPA would select a production vehicle for
coastdown testing, and the manufacturer would be required to perform up
to 100 valid coastdown runs to demonstrate whether or not the vehicle
was certified to the correct bin. The coastdown results must be
adjusted to a yaw angle of 4.5[deg] using an alternate aerodynamic
method. EPA will address uncertainty in the measurement using a
confidence interval around the mean CdA value, where the
confidence interval will be calculated from the standard deviation of
the CdA values ([sigma]) and the number of runs (n)
according to the following equation:
[GRAPHIC] [TIFF OMITTED] TR25OC16.008
For example, the result of the testing could be a CdA
value of 5.90 0.09, which would fall entirely within Bin
III for high roof sleeper cabs.\317\ If the vehicle had been certified
to Bin III or lower, this would be considered a passing test. If it had
been certified to Bin IV or higher, this would be considered a failing
test. For each vehicle that fails, the manufacturer would be required
to test two additional vehicles up to a maximum of 11 vehicles.
Manufacturers would have the option to select the same vehicle
configuration, or they could choose to have EPA select another
configuration within the family. It is appropriate to allow
manufacturers the opportunity to retest the same failed configurations
because they would only do so where there had reasonable confidence
that the failure did not accurately reflect the true value.
---------------------------------------------------------------------------
\317\ As specified in 40 CFR 1037.305, bin boundaries for this
determination are expressed to two decimal places and adjusted for
rounding effects.
---------------------------------------------------------------------------
The regulations require that manufacturers continue testing until
the results are clearly either above or below the applicable bin
boundary (i.e., the confidence interval does not cross the boundary),
or until 100 runs are completed. By making the confidence interval a
function of the number of runs, it will generally become smaller as
additional runs are completed, so that it would be increasingly likely
to have a clear result as additional runs are completed. Nevertheless,
there may be some cases where the results are close enough to the bin
boundary that the confidence interval still crosses the boundary after
100 runs, meaning the true CdA value could be slightly above
or slightly below the bin boundary. The regulations will treat these
results as passing.
It is important to note that, although SEAs are directed by EPA,
the actual testing is conducted by the manufacturer at their chosen
facilities. This minimizes many potential causes of test variability,
such as differences in test trailers, test tracks, or instrumentation.
Thus confidence intervals need only reflect true test-to-test
variability. Also, manufacturers generally rent facilities for
coastdown testing as needed, which means EPA will need to provide some
advance notice to allow the manufacturer to reserve the appropriate
facility.
In selecting the original configuration and subsequent selections,
EPA would likely consider vehicles with measured CdA values
near the top of the bin since they could be most the likely to be mis-
certified based on inaccurate results. However, EPA could select any
configuration. For subsequent testing if the first vehicle fails,
manufacturers would be allowed to retest the same configuration (but
not the same exact vehicle). EPA believes this would not decrease the
risk of failure for subsequent vehicles, but could allow a manufacturer
the opportunity to show its design was actually compliant.
With respect to confirmatory testing, which is testing EPA conducts
during certification rather than during production, EPA has generally
[[Page 73633]]
considered its test results to be the official test results. However,
we recognize that we need to treat confirmation of a manufacturer's
Falt-aero differently because small changes in its value
would be spread over an entire family. Therefore, EPA is adopting an
interim provision that would apply the SEA confidence interval approach
for confirmatory testing with respect to Falt-aero. EPA
would also attempt to use the same test trailers, test locations, and
instrumentation that the manufacturer. Nevertheless, we expect to
revisit this issue in the future.
(b) Road Grade in the Drive Cycles
Road grade can have a significant impact on the overall fuel
economy of a heavy-duty vehicle. Table III-34 shows the results from a
real world evaluation of heavy-duty tractor-trailers conducted by Oak
Ridge National Lab.\318\ The study found that the impact of a mild
upslope of one to four percent led to a decrease in average fuel
economy from 7.33 mpg to 4.35 mpg. These results are as expected
because vehicles consume more fuel while driving on an upslope than
driving on a flat road because the vehicle needs to exert additional
power to overcome the grade resistance force.\319\ The amount of extra
fuel increases with increases in road gradient. On downgrades, vehicles
consume less fuel than on a flat road. However, as shown in the fuel
consumption results in Table III-34, the amount of increase in fuel
consumption on an upslope is greater than the amount of decrease in
fuel consumption on a downslope which leads to a net increase in fuel
consumption. As an example, the data show that a vehicle would use 0.3
gallons per mile more fuel in a severe upslope than on flat terrain,
but only save 0.1 gallons of fuel per mile on a severe downslope. In
another study, Southwest Research Institute modeling found that the
addition of road grade to a drive cycle has an 8 to 10 percent negative
impact on fuel economy.\320\
---------------------------------------------------------------------------
\318\ Oakridge National Laboratory. Transportation Energy Book,
Edition 33. Table 5.10 Effect of Terrain on Class 8 Truck Fuel
Economy. 2014. Last accessed on September 19, 2014 at http://cta.ornl.gov/data/Chapter5.shtml.
\319\ Ibid.
\320\ Reinhart, T. (February 2016). Commercial Medium- and
Heavy-Duty (MD/HD) Truck Fuel Efficiency Technology Study--Report
#2. Washington, DC: National Highway Traffic Safety Administration.
EPA-HQ-OAR-2014-0827-1623.
Table III-34--Fuel Consumption Relative to Road Grade
------------------------------------------------------------------------
Average
fuel Average fuel
economy consumption
Type of terrain (miles (gallons per
per mile)
gallon)
------------------------------------------------------------------------
Severe upslope (>4%)........................... 2.90 0.34
Mild upslope (1% to 4%)........................ 4.35 0.23
Flat terrain (1% to 1%)........................ 7.33 0.14
Mild downslope (-4% to -1%).................... 15.11 0.07
Severe downslope (<=4%)........................ 23.50 0.04
------------------------------------------------------------------------
In Phase 1, the agencies did not include road grade. However, we
believe it is important to include road grade in Phase 2 to properly
assess the value of technologies, such as downspeeding and the
integration of the engine and transmission, which were not technologies
included in the technology basis for Phase 1 and are not directly
assessed by GEM in its Phase 1 iteration. The addition of road grade to
the drive cycles is consistent with the NAS recommendation in the 2014
Phase 2 First Report.\321\
---------------------------------------------------------------------------
\321\ National Academy of Science. ``Reducing the Fuel
Consumption and GHG Emissions of Medium- and Heavy-Duty Vehicles,
Phase Two, First Report.'' 2014. Recommendation S.3 (3.6).
---------------------------------------------------------------------------
The U.S. Department of Energy and EPA partnered to support a
project to develop the appropriate road grade profiles for the 55 mph
and 65 mph highway cruise duty cycles that will be used in the
certification of heavy-duty vehicles to the Phase 2 final GHG emission
and fuel efficiency standards. The National Renewable Energy Laboratory
(NREL) was contracted to do this work and has developed a database of
activity-weighted percent road grades representative of U.S. limited-
access highways. To this end, NREL used high-accuracy road grade data
and county-specific vehicle miles traveled data. A report documenting
this NREL work is in the public docket for these final rules.\322\
---------------------------------------------------------------------------
\322\ See NREL Report ``EPA Road Grade profiles'' for DOE-EPA
Interagency Agreement to Refine Drive Cycles for GHG Certification
of Medium- and Heavy-Duty Vehicles, IA Number DW-89-92402501.
---------------------------------------------------------------------------
In the Phase 2 proposal, the agencies developed an interim road
grade profile and provided information in the docket on two NREL-
derived road grade profiles. The agencies proposed the inclusion of an
interim road grade profile, in both the 55 mph and 65 mph cycles. The
grade profile was developed by Southwest Research Institute on a 12.5
mile stretch of restricted-access highway during on-road tests
conducted for EPA's validation of the Phase 2 version of GEM.\323\ The
agencies also included an additional road grade profile as part of the
Notice of Data Availability (81 FR at 10825). The agencies sought
comment on all of the road grade profiles.
---------------------------------------------------------------------------
\323\ Southwest Research Institute. ``GEM Validation,''
Technical Research Workshop supporting EPA and NHTSA Phase 2
Standards for MD/HD Greenhouse Gas and Fuel Efficiency--December 10
and 11, 2014. Can be accessed at http://www3.epa.gov/otaq/climate/regs-heavy-duty.htm.
---------------------------------------------------------------------------
Cummins supported the development of road grade and stated that the
proposed road grade with 2 percent did not reflect their
assessment of the distribution of North American roads with a
distribution of road grades of 6 percent. ACEEE supported
inclusion of road grade. Daimler, Navistar, EMA, Volvo, and Eaton
commented that the road grade profile presented in the NODA were too
steep and did not represent real world driving. Their primary concern
was related to the fraction of time the engine spent at full load for
various vehicle configurations. According to the manufacturers, the
road grade cycle presented in GEM in the NODA spent too high of a
fraction of time at full load.
After considering the road grade profile comments and using the
NREL database, the agencies have independently developed a road grade
profile for the final rules for use in the 55 mph and 65 mph highway
cruise duty cycles for the Phase 2 final rulemaking. While based on the
same road grade database generated by NREL for U.S. restricted-access
highways, its design is predicated on a different approach. The
development of this profile is documented in the RIA Chapter 3.4.2.1.
The road grade in the final rules includes a stretch with zero percent
grade and lower peak grades than the profile presented in the NODA. The
minimum grade in the final cycle is -5 percent and the maximum grade is
5 percent. The cycle spends 46 percent of the distance in grades of
0.5 percent. Overall, the cycle spends approximately 66
percent of the time in relatively flat terrain with road gradients of
1 percent. A detailed discussion of the road grade profile
is included in RIA Chapter 3.4.2.1.
(c) Heavy-Haul Provisions
The agencies proposed that heavy-haul tractors demonstrate
compliance with the standards using the day cab drive cycle weightings
of 19 percent transient cycle, 17 percent 55 mph cycle, and 64 percent
65 mph cycle. We also proposed that GEM simulates the heavy-haul
tractors with a payload of 43
[[Page 73634]]
tons and a total tractor, trailer, and payload weight of 118,500 lbs.
In addition, we proposed that the engines installed in heavy-haul
tractors meet the tractor engine standards included in 40 CFR 1036.108.
We welcomed comments on these specifications.
Volvo does not agree with the proposal that the engine installed in
a heavy-haul tractor must meet the tractor engine standard defined in
40 CFR 1036.108. As discussed below in Section III.E.2.i, we have
modified 40 CFR 1037.601(a)(1) in this final rulemaking to remove the
prohibition of using vocational engines in tractors.
(d) Weight Reduction
In Phase 1, the agencies adopted regulations that provided
manufacturers with the ability to use GEM to measure emission reduction
and reductions in fuel consumption resulting from use of high strength
steel and aluminum components for weight reduction, and to do so
without the burden of entering the curb weight of every tractor
produced. We treated such weight reduction in two ways in Phase 1 to
account for the fact that combination tractor-trailers weigh-out
approximately one-third of the time and cube-out approximately two-
thirds of the time. Therefore, one-third of the weight reduction is
added payload in the denominator while two-thirds of the weight
reduction is subtracted from the overall weight of the vehicle in GEM.
See 76 FR 57153. The agencies also allowed manufacturers to petition
for off-cycle credits for components not measured in GEM.
NHTSA and EPA proposed to carry the Phase 1 treatment of weight
reduction into Phase 2. That is, these types of weight reduction,
although not part of the agencies' technology packages for the final
standards, can still be recognized in GEM up to a point. In addition,
the agencies proposed to add additional thermoplastic components to the
weight reduction table. The thermoplastic component weight reduction
values were developed in coordination with SABIC, a thermoplastic
component supplier. Also, in Phase 2, we proposed to recognize the
potential weight reduction opportunities in the powertrain and
drivetrain systems as part of the vehicle inputs into GEM. Therefore,
we believe it is appropriate to also recognize the weight reduction
associated with both smaller engines and 6x2 axles.\324\ We welcomed
comments on all aspects of weight reduction. 80 FR 40249.
---------------------------------------------------------------------------
\324\ North American Council for Freight Efficiency.
``Confidence Findings on the Potential of 6x2 Axles.'' 2014. Page
16.
---------------------------------------------------------------------------
Several organizations suggested changes to specific weights
proposed in the NPRM. The Aluminum Association cited several additional
advancements in the aluminum industry and stated that the proposed
table is appropriate when these components are considered for
substitution on an individual basis. Aluminum Association also asked
the agencies to add a 500 pound weight reduction for switching from
steel to aluminum tractor cabs, among other components. Meritor
supported the inclusion and expansion of the weight reduction
technologies in the NPRM. Meritor suggested the aluminum carriers
illustrate consistent weight reductions of 60 pounds for the rear-
front-drive axle, 35 pounds for the rear-rear-drive axle and therefore
95 pounds for the tandem. Based on their data, Meritor recommends that
a 42 pound weight savings be credited per tractor for using High-
Strength steel drums on the steer (non-drive) axle and 74 pound per
vehicle for 6x4 drive axle applications. Meritor anticipates the
availability of an aluminum version of a brake bracket in the timeframe
of the regulation which will provide a calculated per vehicle weight
savings of 36 pounds for a 6x4 configuration. Meritor believes that
weight savings should be credited for the use of single-piece
drivelines in excess of 86 because today, most drivelines in
excess of 86 are two piece. American Iron and Steel
Institute commented that light weight values for high strength steel
should be adjusted upward in the FRM, citing light duty vehicle weight
reduction approaches using high strength steel and saying these
improvements should apply to the heavy-duty sector as well. Daimler
commented that increased credit should be given to hoods and fairings
for the difference between steel and thermoplastic, but no specific
values were provided. PACCAR recommends that the agencies broaden the
definition of ``composite'' to include materials other than
thermoplastics, including thermoplastics, thermosets, and fiber
reinforced plastics.
Some organizations commented against including some or all light-
weight components for compliance with the tractor standards. American
Iron and Steel Institute commented against the inclusion of any light-
weight components as a compliance mechanism for tractors unless
improved technical data to support the weight saving values are used.
Daimler commented that the weight reduction values for engines less
than 15 liters are arbitrary. Allison commented that the agencies
should establish weight penalties for components that increase weight,
and they used the example of MT/AMT with countershaft architectures.
We have expanded the list of weight reduction technologies for some
steel and aluminum components for the final rule based on information
provided in the comments. We did not adopt weight reduction values for
some components, such as an axle carrier, because we are not confident
that this is not double counting the weight reduction of the axles
already provided in the regulations. We also did not adopt weight
reduction values for technologies still in development, such as
aluminum brake brackets. The agencies are not finalizing a weight
penalty for any components since this would require detailed
information on conventional and light-weight tractor components to
establish a baseline and the weight reduction potential for each
component. In addition, we are not broadening the definition of
composite at this time to include materials other than thermoplastics
because the specific weight reduction values in the table are specific
to thermoplastics. We are adopting the values listed in Table III-35
and Table III-36 and making them available upon promulgation of the
final Phase 2 rules (i.e., available even under Phase 1). Additional
weight reduction would be evaluated as a potential off-cycle credit.
Table III-35--Phase 2 Weight Reduction Technologies for Tractors
------------------------------------------------------------------------
Weight reduction technology Weight reduction
------------------------------------------------------------------------
Wide-Based Single Drive Tire
with:
Steel Wheel.................. 84 lbs. per wheel/tire set.
Aluminum Wheel/Aluminum Alloy 147 lbs. per wheel/tire set.
Wheel.
[[Page 73635]]
Wide-Based Single Trailer Tire
with:
Steel Wheel.................. 84 lbs. per wheel/tire set.
Aluminum Wheel/Aluminum Alloy 131 lbs. per wheel/tire set.
Wheel.
Steer Tire or Dual Wide Drive
Tire with:
High Strength Steel Wheel.... 8 lbs. per wheel.
Aluminum Wheel/Aluminum Alloy 25 lbs. per wheel.
Wheel.
------------------------------------------------------------------------
----------------------------------------------------------------------------------------------------------------
Aluminum High strength Thermoplastic
weight steel weight weight
Weight reduction technologies Steel (lb.) reduction reduction reduction
(lb.) (lb.) (lb.)
----------------------------------------------------------------------------------------------------------------
Door (per door)................................. .............. 20 6 ..............
Roof (per vehicle).............................. .............. 60 18 ..............
Cab rear wall (per vehicle)..................... .............. 49 16 ..............
Cab floor (per vehicle)......................... .............. 56 18 ..............
Hood (per vehicle).............................. .............. 55 17 ..............
Hood Support Structure (per vehicle)............ .............. 15 3 ..............
Hood and Front Fender (per vehicle)............. .............. .............. .............. 65
Day Cab Roof Fairing (per vehicle).............. .............. .............. .............. 18
Sleeper Cab Roof Fairing (per vehicle).......... .............. 75 20 40
Aerodynamic Side Extender (per vehicle)......... .............. .............. .............. 10
Fairing Support Structure (per vehicle)......... .............. 35 6 ..............
Instrument Panel Support Structure (per vehicle) .............. 5 1 ..............
Brake Drums--Drive (per 4)...................... .............. 140 74 ..............
Brake Drums--Non Drive (per 2).................. .............. 60 42 ..............
Frame Rails (per vehicle)....................... .............. 440 87 ..............
Crossmember--Cab (per vehicle).................. .............. 15 5 ..............
Crossmember--Suspension (per vehicle)........... .............. 25 6 ..............
Crossmember--Non Suspension ( per 3)............ .............. 15 5 ..............
Fifth Wheel (per vehicle)....................... .............. 100 25 ..............
Radiator Support (per vehicle).................. .............. 20 6 ..............
Fuel Tank Support Structure (per vehicle)....... .............. 40 12 ..............
Steps (per vehicle)............................. .............. 35 6 ..............
Bumper (per vehicle)............................ .............. 33 10 ..............
Shackles (per vehicle).......................... .............. 10 3 ..............
Front Axle (per vehicle)........................ .............. 60 15 ..............
Suspension Brackets, Hangers (per vehicle)...... .............. 100 30 ..............
Transmission Case (per vehicle)................. .............. 50 12 ..............
Clutch Housing (per vehicle).................... .............. 40 10 ..............
Drive Axle Hubs (per 4)......................... .............. 80 20 ..............
Non Drive Front Hubs (per 2).................... .............. 40 5 ..............
Single Piece Driveline (for drivelines longer 43 63 43 ..............
than 86'').....................................
Driveshaft (per vehicle)........................ .............. 20 5 ..............
Transmission/Clutch Shift Levers (per vehicle).. .............. 20 4 ..............
----------------------------------------------------------------------------------------------------------------
Table III-36--Phase 2 Weight Reduction Values for Other Components
------------------------------------------------------------------------
Weight
Weight reduction technology reduction
(lb)
------------------------------------------------------------------------
6x2 axle configuration in tractors.......................... 300
4x2 axle configuration in Class 8 tractors.................. 300
Tractor engine with displacement less than 14.0L............ \325\ 300
------------------------------------------------------------------------
(e) GEM Inputs
---------------------------------------------------------------------------
\325\ Kenworth. ``Kenworth T680 with PACCAR MX-13 Engine Lowers
Costs for Oregon Open-Deck Carrier.'' Last viewed on December 16,
2014 at http://www.kenworth.com/news/news-releases/2013/december/t680-cotc.aspx.
---------------------------------------------------------------------------
The agencies proposed to continue to require the Phase 1 GEM inputs
for tractors in Phase 2. These inputs include the following:
Steer tire rolling resistance,
Drive tire rolling resistance,
Coefficient of Drag Area,
Idle reduction,
Weight reduction, and
Vehicle Speed Limiter.
As discussed above in Section II.C and III.D, there are several
additional inputs that we are adopting for Phase 2. The majority of
these new inputs are the same as proposed, with the addition of two new
optional inputs to account for transmission and axle efficiency
improvements in response to comments. The new GEM inputs for Phase 2
include the following:
Engine information including manufacturer, model,
combustion type, fuel type, family name, and calibration
identification,
Engine steady state and cycle average fuel maps,
Engine full-load torque curve,
Engine motoring curve,
Transmission information including manufacturer and model,
Transmission type,
Transmission gear ratios,
Transmission loss map (optional),
Drive axle(s) ratio,
Axle power loss map (optional),
Tire size (revolutions per mile) for drive tires, and
Other technology inputs.
(f) Vehicle Speed Limiter Provisions
The agencies received comments during the development of Phase 1
that the Clean Air Act provisions to prevent tampering (CAA section
203(a)(3)(A)) of vehicle speed limiters and extended idle reduction
technologies would prohibit
[[Page 73636]]
their use for demonstrating compliance with the Phase 1 standards. In
Phase 1, the agencies adopted provisions to allow for discounted
credits for idle reduction technologies that allowed for override
conditions and expiring engine shutdown systems (see 40 CFR 1037.660).
Similarly, the agencies adopted provisions to allow for ``soft top''
speeds and expiring vehicle speed limiters, and we did not propose to
change those provisions (see 40 CFR 1037.640). However, as we developed
Phase 2, we understood that the concerns still exist that the ability
for a tractor manufacturer to reflect the use of a VSL in its
compliance determination may be constrained by the demand for
flexibility in the use of VSLs by the customers. The agencies welcomed
suggestions on how to close the gap between the provisions that would
be acceptable to the industry while maintaining our need to ensure that
modifications do not violate section 203(a)(3)(A). We requested comment
on potential approaches which would enable a feedback mechanism between
the vehicle owner/fleet that would provide the agencies the assurance
that the benefits of the VSLs will be seen in use but would also
provide the vehicle owner/fleet the flexibility they may need during
in-use operation. More generally, in our discussions with several
trucking fleets and with the American Trucking Associations, an
interest was expressed by the fleets if there was a means by which they
could participate in the emissions credit transactions that are
currently limited to the directly regulated truck manufacturers. VSLs
were an example technology that fleets and individual owners can order
for a new build truck, and for which, from the fleets' perspective, the
truck manufacturers receive emission credits. The agencies did not have
a specific suggestion in the Phase 2 NPRM or a position on the request
from the American Trucking Association and its members, but we
requested comment on whether or not it is appropriate to allow owners
to participate in the overall compliance process for the directly
regulated parties, if such a thing is allowed under the two agencies'
respective statutes, and what regulatory provisions would be needed to
incorporate such an approach. 80 FR 40250.
The agencies received comments regarding VSLs. ATA commented that
the agencies should recognize in GEM VSLs set at speeds less than the
speed limit mandated if a rule is adopted by NHTSA and FMCSA. ATA also
suggested that the agencies should explore ways of incorporating the
in-use benefits being derived from VSLs, such as allowing manufacturers
to accept a purchaser's commitment to establish a maximum limited
speed, as opposed to the tamper-proof option, when acknowledged and
affirmed on a vehicle's purchase agreement. ATA also suggested that the
agencies allow manufacturers to adjust VSLs at the end of a vehicle's
lease or trade-in and allow the creation of deficits or credits if such
adjustments affect the initial VSL effectiveness that was generated and
allow trucking companies to adjust maximum speeds if company policies
change during the ownership cycle with corresponding adjustment to
manufacturer credits. CARB stated it is not clear what fleet owners
would do with Phase 2 credits and allowing fleet owners to garner such
credits would unnecessarily complicate implementation and enforcement
of the Phase 2 program. As a result, CARB staff recommends not
including owners in emission credit transactions for VSL installation.
Daimler suggested that they report in their 270 day end of year report
the number of VSLs that remain active. Daimler recommends that the
agencies provide in GEM reduced effectiveness for non-regulatory VSLs
in proportion to the fraction of non-regulatory ones that remained
unaltered, based upon their study of their database. Volvo commented
that approximately 15 percent of tractors built over 2013-2015 were
shipped with their programmable road speed limiters set at less than 65
mph from the factory and 47 percent were reported in use with the same
setting, even during a period of very low fuel prices. Volvo Group
requests that the agencies consider providing an effectiveness value in
GEM for reprogrammable speed limiters set at the factory at, or below
65 mph. UPS commented that instead of tamperproof VSLs, they would
support a regulatory approach in which the fleet owner can adjust speed
settings, but only if certified personnel make these changes and their
activities within the ECIVIs are trackable and fully accountable to
proper authorities.
The agencies considered the comments and the compliance burden
associated with the suggestions. The agencies also considered DOT's
upcoming actions with respect to mandatory vehicle speed limiters for
heavy-duty trucks. The existing Phase 1 VSL flexibilities provide
opportunities for manufacturers to use VSL as a technology in GEM while
still allowing the settings to change after an ``expiration'' time
determined by the manufacturer. At this time, we believe that the Phase
1 flexibilities sufficiently balance the desire to encourage
technologies that reduce GHG emissions and fuel consumption while
minimizing the compliance burden of trying to accommodate changes
throughout the useful life of the vehicle. Therefore, the agencies are
not adopting any new VSL provisions for Phase 2 and the Phase 1
provisions will continue (see 40 CFR 1037.640).
(g) Emission Control Labels
The agencies consider it crucial that authorized compliance
inspectors are able to identify whether a vehicle is certified, and if
so whether it is in its certified condition. To facilitate this
identification in Phase 1, EPA adopted labeling provisions for tractors
that included several items. The Phase 1 tractor label must include the
manufacturer, vehicle identifier such as the Vehicle Identification
Number (VIN), vehicle family, regulatory subcategory, date of
manufacture, compliance statements, and emission control system
identifiers (see 40 CFR 1037.135). In Phase 1, the emission control
system identifiers are limited to vehicle speed limiters, idle
reduction technology, tire rolling resistance, some aerodynamic
components, and other innovative and advanced technologies.
The number of emission control systems for greenhouse gas emissions
in Phase 2 has increased significantly. For example, all aspects of the
engine transmission and drive axle; accessories; tire radius and
rolling resistance; wind averaged drag; predictive cruise control; idle
reduction technologies; and automatic tire inflation systems are
controls that can be evaluated on-cycle in Phase 2 (i.e. these
technologies' performance can now be input to GEM), but could not be in
Phase 1. Due to the complexity in determining greenhouse gas emissions
as in Phase 2, the agencies do not believe that we can unambiguously
determine whether or not a vehicle is in a certified condition through
simply comparing information that could be made available on an
emission control label with the components installed on a vehicle.
Therefore, EPA proposed to remove the requirement to include the
emission control system identifiers required in 40 CFR 1037.135(c)(6)
and in Appendix III to 40 CFR part 1037 from the emission control
labels for vehicles certified to the Phase 2 standards. However, the
agencies requested comment on the appropriate content that would
properly balance the need to limit label content with the interest in
providing the most useful information for inspectors to
[[Page 73637]]
confirm that vehicles have been properly built. The agencies received
comments on the emission control labels. Navistar supported the
elimination of the emission control information from the vehicle GHG
label. After considering the comments, EPA is finalizing the proposed
tractor labeling requirements. Nevertheless, as described below we
remain interested in finding a better approach for labeling.
Under the agencies' existing authorities, manufacturers must
provide detailed build information for a specific vehicle upon our
request. Our expectation is that this information should be available
to us via email or other similar electronic communication on a same-day
basis, or within 24 hours of a request at most. The agencies have
started to explore ideas that would provide inspectors with an
electronic method to identify vehicles and access on-line databases
that would list all of the engine-specific and vehicle-specific
emissions control system information. We believe that electronic and
Internet technology exists today for using scan tools to read a bar
code or radio frequency identification tag affixed to a vehicle that
could then lead to secure on-line access to a database of
manufacturers' detailed vehicle and engine build information. Our
exploratory work on these ideas has raised questions about the level of
effort that would be required to develop, implement and maintain an
information technology system to provide inspectors real-time access to
this information. We have also considered questions about privacy and
data security. We requested comment on the concept of electronic labels
and database access, including any available information on similar
systems that exist today and on burden estimates and approaches that
could address concerns about privacy and data security. Based on new
information that we receive, we stated in the NPRM that we may consider
initiating a separate rulemaking effort to propose and request comment
on implementing such an approach.
(h) End of Year Reports
In the Phase 1 program, manufacturers participating in the ABT
program provided 90 day and 270 day reports to EPA and NHTSA after the
end of the model year. The agencies adopted two reports for the initial
program to help manufacturers become familiar with the reporting
process. For the HD Phase 2 program, the agencies proposed to simplify
reporting such that manufacturers would only be required to submit the
final report 90 days after the end of the model year with the potential
to obtain approval for a delay up to 30 days. We requested comments on
this approach. EMA, PACCAR, Navistar, Daimler, and Cummins recommended
keeping the 270 day report to allow sufficient time after the
production period is completed. We are accordingly keeping both the 90
day and 270 day reports, with the ability of the agencies to waive the
90 day report.
(i) Other Compliance Provisions
In Phase 2, the agencies are adopting provisions to evaluate the
performance of the engine, transmission, and drivetrain in determining
compliance with the Phase 2 tractor standards. With the inclusion of
the engine's performance in the vehicle compliance, EPA proposed to
modify the prohibition to introducing into U.S. commerce a tractor
containing an engine not certified for use in tractor (see proposed 40
CFR 1037.601(a)(1)). During development of the Phase 2 NPRM, we no
longer saw the need to prohibit the use of vocational engines in
tractors because the performance of the engine would be appropriately
reflected in GEM. We welcomed comments on removing this prohibition.
The agencies received comments supporting the proposed approach.
PACCAR supports removing the prohibition on the installation of
vocational engines into tractors where these engines are appropriate
for the customer's application. Daimler agreed with the proposal that
with the engine properly represented in GEM, there is less need for the
prohibition on vocational-only certified engines in tractors and that
the true in-vehicle emissions are represented by the full-vehicle
standard. Accordingly, we are modifying 40 CFR 1037.601(a)(1) in this
final rulemaking to remove the prohibition of using vocational engines
in tractors.
The agencies also proposed to change the compliance process for
manufacturers seeking to use the off-road exclusion. During the Phase 1
program, manufacturers realized that contacting the agencies in advance
of the model year was necessary to determine whether vehicles would
qualify for exemption and need approved certificates of conformity. The
agencies found that the petition process allowed at the end of the
model year was not necessary and that an informal approval during the
precertification period was more effective. Therefore, NHTSA proposed
to remove its off-road petitioning process in 49 CFR 535.8 and EPA
proposed to add requirements for informal approvals in 40 CFR 1037.610.
The agencies did not receive any comments regarding the petition
process. We are adopting the Phase 2 provisions as proposed.
In Phase 1 and as proposed in Phase 2, the agencies allow
manufacturers to certify vehicles into a higher service class. No
credits can be generated from vehicles certified to the higher service
class, but any deficit produced must be offset by credits generated
from other vehicles within the higher service class. Though the
agencies did not propose any changes, we received comments on the
treatment of 4x2 tractors. EMA and the manufacturers suggest that
tractors with a 4x2 axle configuration and a heavy heavy-duty engine
should be classified as a Class 8 tractor regardless of GVWR and be
included in the Class 8 averaging set. Navistar and EMA stated that
these vehicles are typically purchased to pull multiple trailers, even
though the GVWR is less than 33,000 pounds. In the agencies'
assessment, we agree with the manufacturers that these vehicles
resemble Class 8 work and due to the higher useful life requirements,
we are adopting provisions into the Phase 2 regulations that gives all
manufacturers the option to classify Class 7 tractors with 4x2 axle
configurations as Class 8 tractors.
(j) Chassis Dynamometer Testing Requirement
The agencies foresee the need to continue to track the progress of
the Phase 2 program throughout its implementation. As discussed in
Section II, the agencies expect to evaluate the overall performance of
tractors with the GEM results provided by manufacturers through the end
of year reports. However, we also need to continue to have confidence
in our simulation tool, GEM, as the vehicle technologies continue to
evolve. Therefore, EPA proposed that the manufacturers conduct annual
chassis dynamometer testing of three sleeper cab tractors and two day
cab tractors and provide the data and the GEM result from each of these
tractor configurations to EPA (see 40 CFR 1037.665). 80 FR 40251. We
requested comment on the costs and efficacy of this data submission
requirement.
In response, the agencies received mixed comments supporting and
raising concerns about the proposed chassis test requirements. ACEEE
and ICCT supported the proposal to conduct annual chassis testing to
verify the relative reductions simulated in GEM and suggested that the
results be provided to the public. UCS supported the proposal, similar
to ACEEE and ICCT, with the additional suggestion to conduct an over
the road testing of
[[Page 73638]]
select vehicles under real world conditions. EMA, Daimler, Volvo,
PACCAR, and Navistar commented that they support auditing, but the
proposed chassis testing is burdensome with few facilities available
and will not achieve the agencies' stated goal of validating GEM's
measure trends in the real world. Daimler and Navistar also stated that
chassis dyno testing cannot replicate the real-world conditions for
many technologies, such as tire pressure monitoring systems,
intelligent coasting on grades, predictively adjusting vehicle speed on
hills, adapting ride height at speed, using advanced cooling system
controls, etc. Volvo raised concerns about the chassis test results due
to driver variability, accessory loads, and the need to simulate road
loads that comprise around 90 percent of the vehicle load in tractor
cycles. Volvo and Daimler noted that without separate tests to quantify
the aerodynamics and rolling resistance, which accounts for a
significant majority of the vehicle losses, the chassis test
essentially only evaluates the powertrain and therefore recommended
powertrain testing for this purpose over a chassis test. The
manufacturer's suggested that EPA conduct the testing or work
collaboratively to develop an in-use research program. Navistar
commented that if the provision remains for the final rule, then it be
limited to one vehicle in 2021, 2024, and 2027 model year. Navistar
also suggested that the final requirements do not include the proposed
measurement of gaseous emissions due to the additional cost burden.
After consideration of the comments, the agencies are requiring
tractor manufacturers to annually chassis test five production vehicles
over the GEM cycles to verify that relative reductions simulated in GEM
are being achieved in actual production. See 40 CFR 1037.665. We do not
expect absolute correlation between GEM results and chassis testing.
GEM makes many simplifying assumptions that do not compromise its
usefulness for certification, but do cause it to produce emission rates
different from what would be measured during a chassis dynamometer
test. Given the limits of correlation possible between GEM and chassis
testing, we would not expect such testing to accurately reflect whether
a vehicle was compliant with the GEM standards. Therefore, we are not
applying compliance liability to such testing. Rather, this testing
will be for informational purposes only. However, we do expect there to
be correlation in a relative sense. Vehicle to vehicle differences
showing a 10 percent improvement in GEM should show a similar percent
improvement with chassis dynamometer testing. Nevertheless,
manufacturers will not be subject to recall or other compliance actions
if chassis testing did not agree with the GEM results on a relative
basis. Rather, the agencies will continue to evaluate in-use compliance
by verifying GEM inputs and testing in-use engines. (Note that NTE
standards for criteria pollutants may apply for some portion of the
test cycles.)
EPA believes this chassis test program is necessary because of our
experience implementing regulations for heavy-duty engines. In the
past, manufacturers have designed engines that have much lower
emissions on the duty cycles than occur during actual use. The recent
experience with Volkswagen is an unfortunate instance. By using this
simple test program, we hope to be able to identify such issues earlier
and to dissuade any attempts to design solely to the certification
test. We also expect the results of this testing to help inform the
need for any further changes to GEM.
As already noted in Section II.B.(1), it can be expensive to build
chassis test cells for certification. However, EPA has structured this
pilot-scale program to minimize the costs. First, this chassis testing
will not need to comply with the same requirements as will apply for
official certification testing. This will allow testing to be performed
in developmental test cells with simple portable analyzers. Second,
since the program will require only five tests per year, manufacturers
without their own chassis testing facility will be able to contract
with a third party to perform the testing. Finally, EPA is applying
this testing to only those manufacturers with annual production in
excess of 20,000 vehicles.
F. Flexibility Provisions
EPA and NHTSA are adopting two flexibility provisions specifically
for heavy-duty tractor manufacturers in Phase 2. These are an
averaging, banking and trading program for CO2 emissions and
fuel consumption credits, as well as provisions for credits for off-
cycle technologies which are not included as inputs to the GEM. Credits
generated under these provisions can only be used within the same
averaging set that generated the credit.
The agencies are also modifying several Phase 1 interim provisions,
as described below.
(1) Averaging, Banking, and Trading (ABT) Program
Averaging, banking, and trading of emission credits have been an
important part of many EPA mobile source programs under CAA Title II,
and the NHTSA light-duty CAFE program. The agencies also included this
flexibility in the HD Phase 1 program. ABT provisions are useful
because they can help to address many potential issues of technological
feasibility and lead-time, as well as considerations of cost. They
provide manufacturers flexibilities that assist in the efficient
development and implementation of new technologies and therefore enable
new technologies to be implemented at a more aggressive pace than
without ABT. 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. Between MYs 2013 and 2014
all four tractor manufacturers are taking advantage of the ABT
provisions in the Phase 1 program. NHTSA and EPA proposed to carry-over
the Phase 1 ABT provisions for tractors into Phase 2, and are adopting
these provisions.
The agencies proposed and are adopting for Phase 2 the five year
credit life and three year deficit carry-over provisions from Phase 1
(40 CFR 1037.740(c) and 1037.745). Please see additional discussion in
Section I.C.1.b.i. Although we did not propose any additional
restrictions on the use of Phase 1 credits, we requested comment on
this issue. In the NPRM, we stated that early indications suggest that
positive market reception to the Phase 1 technologies could lead to
manufacturers accumulating credits surpluses that could be quite large
at the beginning of the Phase 2 program. 80 FR 40251. For the final
rule, the agencies assessed the level of credits that the tractor
manufacturers are accruing. As discussed above in Section III.D, the
agencies adjusted the 2021 MY standards to reflect the accumulation of
credits.
(2) Off-Cycle Technology Credits
In Phase 1, the agencies adopted an emissions and fuel consumption
credit generating opportunity that applied to innovative technologies
that reduce fuel consumption and CO2 emissions. These
technologies were required to not be in common use with heavy-duty
vehicles before the 2010MY and not reflected in the GEM simulation tool
(i.e., the benefits are ``off-cycle''). See 76 FR 57253. The agencies
proposed to essentially continue this program in Phase 2. However, we
are calling the
[[Page 73639]]
program an off-cycle credit program rather than an innovative
technology program (although there is little, if any, difference in
practice). In other words, beginning in 2021 MY all technologies that
are not accounted for in the GEM test procedure (including powertrain
testing) could be considered off-cycle, including those technologies
that may have been considered innovative technologies in Phase 1 of the
program. The agencies proposed to maintain the requirement that, in
order for a manufacturer to receive credits for Phase 2, the off-cycle
technology would still need to meet the requirement that it was not in
common use prior to MY 2010. However, the final provisions will not
require manufacturers to make such a demonstration. Rather, the
agencies will merely retain the authority to deny a request if we
determine that a technology was in common use in 2010 and was thus part
of the Phase 1 baseline (and thus also the Phase 2 baseline). For
additional information on the treatment of off-cycle technologies see
Section I.C.1.c. as well as the discussion of off-cycle credits in each
of the Phase 2 standard chapters.
(3) Post Useful Life Modifications
Under 40 CFR part 1037, it is generally prohibited for any person
to remove or render inoperative any emission control device installed
to comply with the requirements of part 1037. However, in 40 CFR
1037.655 EPA clarifies that certain vehicle modifications are allowed
after a vehicle reaches the end of its regulatory useful life. This
section applies for all vehicles subject to 40 CFR part 1037 and will
thus apply for trailers regulated in Phase 2. EPA proposed to continue
this provision and requested comment on it. 80 FR 40252.
This section states (as examples) that it is generally allowable to
remove tractor roof fairings after the end of the vehicle's useful life
if the vehicle will no longer be used primarily to pull box trailers,
or to remove other fairings if the vehicle will no longer be used
significantly on highways with vehicle speed of 55 miles per hour or
higher. More generally, this section clarifies that owners may modify a
vehicle for the purpose of reducing emissions, provided they have a
reasonable technical basis for knowing that such modification will not
increase emissions of any other pollutant. This essentially requires
the owner to have information that will lead an engineer or other
person familiar with engine and vehicle design and function to
reasonably believe that the modifications will not increase emissions
of any regulated pollutant. Thus, this provision does not provide a
blanket allowance for modifications after the useful life.
This section also makes clear that no person may ever disable a
vehicle speed limiter prior to its expiration point, or remove
aerodynamic fairings from tractors that are used primarily to pull box
trailers on highways. It is also clear that this allowance does not
apply with respect to engine modifications or recalibrations.
This section does not apply with respect to modifications that
occur within the useful life period, other than to note that many such
modifications to the vehicle during the useful life and to the engine
at any time are presumed to violate section 202(a)(3)(A) of the Act.
EPA notes, however, that this is merely a presumption, and it does not
prohibit modifications during the useful life where the owner clearly
has a reasonable technical basis for knowing that the modifications
would not cause the vehicle to exceed any applicable standard.
The agencies did not receive comments opposing the proposed
regulation, and is adopting it as proposed.
(4) Other Interim Provisions
In HD Phase 1, EPA adopted provisions to delay the full onboard
diagnostics (OBD) requirements for heavy-duty hybrid powertrains until
the 2016 and 2017 model years (see 40 CFR 86.010-18(q)). In discussions
with manufacturers during the development of Phase 2, the agencies have
learned that meeting the on-board diagnostic requirements for criteria
pollutant engine certification continues to be a potential impediment
to adoption of hybrid systems. See Section XIII.A.1 for a discussion of
regulatory changes to reduce the non-GHG certification burden for
engines paired with hybrid powertrain systems.
The Phase 1 advanced technology credits were adopted to promote the
implementation of advanced technologies, such as hybrid powertrains,
Rankine cycle engines, all-electric vehicles, and fuel cell vehicles
(see 40 CFR 1037.150(p)). As the agencies stated in the Phase 1 final
rule, the Phase 1 standards were not premised on the use of advanced
technologies but we expected these advanced technologies to be an
important part of the Phase 2 rulemaking (76 FR 57133, September 15,
2011). The HD Phase 2 heavy-duty engine and tractor standards are
premised on the use of Rankine-cycle engines; therefore, the agencies
believe it is no longer appropriate to provide extra credit for this
technology. While the agencies have not premised the HD Phase 2 tractor
standards on hybrid powertrains, fuel cells, or electric vehicles, we
also foresee some limited use of these technologies in 2021 and beyond.
We proposed in Phase 2 to not provide advanced technology credits in
Phase 2 for any technology, but received many comments supporting the
need for such incentive. As described in Section I.C.1.b, the agencies
are finalizing credit multipliers for plug-in battery electric hybrids,
all-electric, and fuel cell vehicles.
(5) Phase 1 Flexibilities Not Adopted for Phase 2
In Phase 1, the agencies adopted an early credit mechanism to
create incentives for manufacturers to introduce more efficient engines
and vehicles earlier than they otherwise would have planned to do (see
40 CFR 1037.150(a)). The agencies did not propose to extend this
flexibility to Phase 2 because the ABT program from Phase 1 will be
available to manufacturers in 2020 model year and this will displace
the need for early credits. However, the agencies are adopting
provisions in the final Phase 2 rule that provide early credit
opportunities for a limited set of technologies (see 40 CFR
1037.150(y)(2); see also 40 CFR 1037.150(y)(1) and (3) providing early
credit flexibilities to certain vocational vehicles).
IV. Trailers
As mentioned in Section III, trailers pulled by Class 7 and 8
tractors (together considered ``tractor-trailers'') account for
approximately 60 percent of the heavy-duty sector's total
CO2 emissions and fuel consumption. Because neither trailers
nor the tractors that pull them are useful by themselves, it is the
combination of the tractor and the trailer that forms the useful
vehicle. Although trailers do not directly generate exhaust emissions
or consume fuels (except for the refrigeration units on refrigerated
trailers), their designs and operation nevertheless contribute
substantially to the CO2 emissions and diesel fuel
consumption of the tractors pulling them. See also Section I.E above.
The agencies are finalizing standards for trailers specifically
designed to be drawn by Class 7 and 8 tractors when coupled to the
tractor's fifth wheel. Although many other vehicles are known
commercially as trailers, this trailer program does not apply to those
that are pulled by vehicles other than tractors, and those that are
coupled to vehicles exclusively by pintle hooks or hitches instead of a
fifth wheel. These
[[Page 73640]]
standards are expressed in terms of CO2 emissions and fuel
consumption, and as described in more detail in Section IV.C.(2), apply
to specific trailer subcategories. In general, the final standards are
based on the same technology as the proposed standards--primarily
better tires (including tire pressure management) for all regulated
trailers and aerodynamic improvements for box vans (dry and
refrigerated). Most of the changes from the proposal are intended to
simplify and clarify the implementation of these standards. See Section
IV.B. for an overview of the final program, and the rest of this
Section IV for more detailed discussions.
This rulemaking establishes the first EPA regulations covering
trailer manufacturers for CO2 emissions (or any other
emissions), and the first fuel consumption regulations by NHTSA for
these manufacturers. The agencies have designed this program to be a
unified national program, so that when a trailer model complies with
EPA's standards it will also comply with NHTSA's standards, and vice
versa.
A. The Trailer Industry
(1) Industry Characterization
The trailer industry encompasses a wide variety of trailer
applications and designs. Among these are box vans (dry and
refrigerated vans of various sizes) and ``non-box'' trailers, including
platform (e.g., lowboys, flatbeds), tanks, container chassis, bulk,
dump, grain, and many specialized types of trailers, such as car
carriers, pole trailers, and logging trailers. Most trailers are
designed for predominant use on paved streets, roads, and highways. A
relatively small number of trailers are designed with unique
capabilities and features for dedicated use in off-road applications.
The trailer manufacturing industry is very competitive, and
manufacturers are highly responsive to their customers' diverse
demands. The wide range of trailer designs and features reflects the
broad variety of customer needs, chief among them typically being the
ability to maximize the amount of freight the trailer can transport.
Other design goals reflect the numerous, more specialized customer
needs.
Box vans (i.e., dry and refrigerated) are the most common type of
trailer and are made in many different lengths, generally ranging from
28 feet to 53 feet. While all have a rectangular shape, they can vary
widely in basic construction design (internal volume and weight),
materials (steel, fiberglass composites, aluminum, and wood) and the
number and configuration of axles (usually two axles closely spaced,
but number and spacing of axles can be greater). Box van designs may
also include additional features, such as one or more side doors, out-
swinging or roll-up rear doors, side or rear lift gates, and numerous
types of undercarriage accessories (such as access ramps, dolly
storage, spare tire storage, or mechanical lifts).
Non-box trailers are often uniquely designed to transport a
specific type of freight. Platform trailers carry cargo that may not be
easily contained within or loaded into/unloaded from a box van, such as
large, non-uniform equipment or machine components. Tank trailers are
often sealed or pressurized enclosures designed to carry liquids, gases
or bulk, dry solids and semi-solids. There are also a number of other
specialized trailers such as grain, dump, livestock trailers, or
logging.
Chapter 1 of the RIA includes a more thorough characterization of
the trailer industry. The agencies have considered the variety of
trailer designs and applications in developing the CO2
emissions and fuel consumption standards for trailers. As is described
later in this Section IV, the agencies have excluded most types of
specialized trailers from the Phase 2 regulations.
(2) Context for the Trailer Provisions
(a) Summary of Trailer Consideration in Phase 1
In the Phase 1 program, the agencies did not regulate trailers, but
discussed how we might do so in the future (see 76 FR 57362). In
proposing the Phase 1 program, the agencies solicited general comments
on controlling CO2 emissions and fuel consumption through
future trailer regulations (see 75 FR 74345-74351). The agencies
considered those comments in developing today's rules.
(b) SmartWay Program
For several years, EPA's voluntary SmartWay Transport Partnership
program has been encouraging businesses to take actions that reduce
fuel consumption and CO2 emissions while cutting costs. The
SmartWay program works with the shipping, logistics, and carrier
communities to identify cleaner strategies and technologies for moving
goods across their transportation supply chains. It is a voluntary,
market-based program that provides carbon footprint and other air
emissions performance information to partners who submit annual partner
reports. SmartWay Partners commit to assessing, tracking, and improving
environmental performance over time, by adopting fuel-saving practices
and technologies. SmartWay also provides technical assistance, provides
recognition incentives and encourages the use of best practices that
enable companies to readily incorporate fuel and emission reduction
strategies into their freight supply chains.
Annually, SmartWay trucking fleet partners report type and amount
of fuel consumption, tons of goods moved, type and model year of
equipment used, miles driven, speed profiles and other data. Using EPA
MOVES model emission factors and other EPA resources, SmartWay's
assessment and tracking tools convert this information to an objective
ranking of a company's environmental efficiency, enabling each
participating company to benchmark performance relative to its
competitors. Logistics companies, multimodal firms and shippers use
this information to calculate their corporate emissions from goods
movement, which can be included in annual carbon reporting protocols
and sustainability reports.
EPA's SmartWay program has accelerated the availability and market
penetration of advanced, fuel efficient technologies and operational
practices. In conjunction with the SmartWay Partnership Program, EPA
established a testing, verification, and designation program, the
SmartWay Technology Program, to help freight companies identify the
equipment, technologies, and strategies that save fuel and lower
emissions. SmartWay verifies the performance of aerodynamic equipment,
low rolling resistance tires and other technologies and maintains lists
of verified technologies on its Web site. Trailer aerodynamic
technologies are grouped in performance bins that represent one
percent, four percent, five percent or nine percent fuel savings
relative to a typical long-haul tractor-trailer at 65-mph cruise
conditions. As a shorthand description and to encourage saving fuel
with multiple available technologies, EPA established criteria to
describe tractors and trailers as SmartWay designated if they are
equipped with specific technologies. Historically, a 53-foot dry van
trailer equipped with verified aerodynamic devices totaling at least
five percent fuel savings, and SmartWay verified tires, qualifies as a
``SmartWay Designated Trailer.'' In 2014, EPA expanded the program to
include the aerodynamic bin for nine percent or more fuel savings and
these trailers when also equipped with verified tires qualify as
``SmartWay Designated Elite Trailer.'' The 2014 updates also expanded
the use of aerodynamic technologies and SmartWay-designated trailer
eligibility to include 53-foot refrigerated van
[[Page 73641]]
trailers in addition to 53-foot dry van trailers.
The SmartWay Technology Program continues to improve the industry
understanding of technologies, test methods and quality of data fleet
stakeholders need to achieve fuel savings and environmental goals. EPA
bases its SmartWay verification protocols on common industry test
methods with additional criteria to achieve performance objectives and
cost effective industry acceptance. Historically, SmartWay's
aerodynamic equipment verification protocol was based on the TMC type
II and SAE J1321 test procedures, which measures fuel consumption as
test vehicles drive laps around a test track. Under SmartWay's 2014
updates, EPA expanded the aerodynamic technology verification program
to allow additional testing options. The updates included a new, more
stringent 2014 track test protocol based on industry updates to the TMC
RP 1102 (2014) and SAE's 2012 update to its SAE J1321 test method \326\
as well as protocols for wind tunnel and coastdown methods. The
SmartWay program is also reviewing computational fluid dynamics (CFD)
approaches for verification. These new protocols are based on
stakeholder input, the latest industry standards (i.e., 2012 versions
of the SAE fuel consumption and wind tunnel test \327\ methods and 2013
CFD guidance \328\), EPA's own testing and research, and lessons
learned from years of communications with manufacturers, testing
organizations and trucking companies. Wind tunnel, coastdown, and CFD
testing produce values for aerodynamic drag improvements in terms of
coefficient of drag (CD), which is then related to projected
fuel savings using a mathematical curve.\329\
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\326\ SAE International, Fuel Consumption Test Procedure--Type
II. SAE Standard J1321. Revised 2012-02-06. Available at: http://standards.sae.org/j1321_201202/.
\327\ SAE International. Wind Tunnel Test Procedure for Trucks
and Buses. SAE Standard J1252. Revised 2012-07-16. Available at:
http://standards.sae.org/j1252_201207/.
\328\ SAE International, Guidelines for Aerodynamic Assessment
of Medium and Heavy Commercial Ground Vehicles Using Computational
Fluid Dynamics. SAE Standard J2966. Issued 2013-09-17. Available at:
http://standards.sae.org/j2966_201309/.
\329\ McCallen, R., et al. Progress in Reducing Aerodynamic Drag
for Higher Efficiency of Heavy Duty Trucks (Class 7-8). SAE
Technical Paper. 1999-01-2238.
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The SmartWay Technology Program verifies tires based on test data
submitted by tire manufacturers demonstrating the coefficient of
rolling resistance (CRR) of their tires using either the SAE
J1269 or ISO 28580 test methods. These verified tires have rolling
resistance targets for each axle position on the tractor and trailer.
SmartWay-verified trailer tires achieve a CRR of 5.1 kg/
metric ton or less on the ISO28580 test method. Compared to popular
tires used in 2007, an operator who replaces the trailer tires with
SmartWay-verified tires can expect fuel consumption savings of one
percent or more at a 65-mph cruise. Operators who apply SmartWay-
verified tires on both the trailer and tractor can achieve three
percent fuel consumption savings at 65-mph. As most van trailers and
many other trailer types are manufactured with SmartWay verified tires,
fleets have confidence in maintaining their fuel performance thru the
use of and flexibility to choose other SmartWay verified tires.
Over the last decade, the trucking industry has achieved
measureable fuel consumption benefits by adding aerodynamic features
and low rolling resistance tires to their trailers. To date, SmartWay
has verified over 70 aerodynamic technologies, including ten packages
from five manufacturers that have received the Elite performance level.
The SmartWay Transport Partnership program has worked with over 3,000
partners, the majority of which are trucking fleets, and broadly
throughout the supply-chain industry, since 2004. These relationships,
combined with the Technology Program's extensive involvement testing
and technology development has provided EPA with significant experience
in freight fuel efficiency. Furthermore, the more than 10-year duration
of the voluntary SmartWay Transport Partnership has resulted in
significant fleet and manufacturer experience with innovating and
deploying technologies that reduce CO2 emissions and fuel
consumption.
(c) California Tractor-Trailer Greenhouse Gas Regulation
The state of California passed the Global Warming Solutions Act of
2006 (Assembly Bill 32, or AB32), enacting the state's 2020 greenhouse
gas emissions reduction goal into law. Pursuant to this Act, the
California Air Resource Board (CARB) was required to begin developing
early actions to reduce GHG emissions. As a part of a larger effort to
comply with AB32, the California Air Resource Board issued a regulation
entitled ``Heavy-Duty Greenhouse Gas Emission Reduction Regulation'' in
December 2008.
This regulation reduces GHG emissions by requiring improvement in
the efficiency of heavy-duty tractors and 53 feet or longer dry and
refrigerated box trailers that operate in California.\330\ The program
is being phased in between 2010 and 2020. Small fleets have been
allowed special compliance opportunities to phase in the retrofits of
their existing trailer fleets through 2017. The regulation requires
affected trailer fleet owners to either use SmartWay-verified
aerodynamic technologies and SmartWay-verified tires or retread tires.
The efficiency improvements are achieved through the use of aerodynamic
equipment and low rolling resistance tires on both the tractor and
trailer. EPA has granted a waiver for this California program.\331\
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\330\ In December 2013, ARB adopted regulations that establish
its own parallel Phase 1 program with standards consistent with the
EPA Phase 1 tractor standards. On December 5, 2014 California's
Office of Administrative Law approved ARB's adoption of the Phase 1
standards, with an effective date of December 5, 2014.
\331\ See EPA's waiver of CARB's heavy-duty tractor-trailer
greenhouse gas regulation applicable to new 2011 through 2013 model
year Class 8 tractors equipped with integrated sleeper berths
(sleeper-cab tractors) and 2011 and subsequent model year dry-can
and refrigerated-van trailers that are pulled by such tractors on
California highways at 79 FR 46256 (August 7, 2014).
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(d) NHTSA Safety-Related Regulations for Trailers and Tires
NHTSA regulates new trailer safety through regulations. Table IV-1
lists the current regulations in place related to trailers. Trailer
manufacturers continue to be required to meet current safety
regulations for the trailers they produce. FMVSS Nos. 223 and 224 \332\
require installation of rear guard protection on trailers. The
definition of rear extremity of the trailer in 223 limits installation
of rear fairings to a specified zone behind the trailer.
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\332\ 49 CFR 571.223 and 571.224.
Table IV-1--Current NHTSA Statutes and Regulations Related to Trailers
------------------------------------------------------------------------
Reference Title
------------------------------------------------------------------------
49 CFR part 565........................... Vehicle Identification
Number (VIN) Requirements.
49 CFR part 566........................... Manufacturer Identification.
49 CFR part 567........................... Certification.
49 CFR part 568........................... Vehicles Manufactured in Two
or More Stages.
49 CFR part 569........................... Regrooved Tires.
49 CFR part 571........................... Federal Motor Vehicle Safety
Standards.
49 CFR part 573........................... Defect and Noncompliance
Responsibility and Reports.
49 CFR part 574........................... Tire Identification and
Recordkeeping.
49 CFR part 575........................... Consumer Information.
49 CFR part 576........................... Record Retention.
------------------------------------------------------------------------
[[Page 73642]]
NHTSA recognizes that regulatory and market factors that result in
changes in trailer weight can potentially have safety ramifications,
both positive and negative. NHTSA believes that the appropriate
perspective is to evaluate the regulation and market factors in their
entirety. One such factor is that incentives in the Phase 2 regulation
could result in an average decrease in trailer weight. Since removing
weight from trailers allows more cargo to be carried, fewer trips are
needed to move the same amount of cargo, and fewer crashes--including
fatal crashes--could occur. Fleets and other customers have a natural
incentive to request lighter-weight trailers. From the trailer owners'
perspective, reducing trailer weight not only allows them to increase
cargo when they are near capacity, but also reduces fuel consumption
whether the trailer is fully loaded or not. In pre-proposal meetings
with trailer manufacturers, companies said that customers are
requesting lighter-weight components when possible and manufacturers
are installing them.
To further incentivize a shift to lighter weight materials, the
Phase 2 program provides two compliance mechanisms, both of which are
discussed later in this Preamble (Section IV.D.(1)(d) and Section
IV.E.(5)(d), respectively). The first is a list of weight reductions
from which manufacturers can select. The list identifies specific
lighter-weight components, such as side posts, roof bows, and flooring.
Manufacturers using these lighter-weight components achieve fuel
consumption and GHG reductions that count toward their compliance
calculations. The NPRM identified twelve components, ranging from
lighter-weight landing gear (which receives credit for 50 pounds of
weight reduction) to aluminum upper coupler assemblies (which receive
credit for 430 pounds). See proposed section 1037.515 at 80 FR 40627.
In addition, for a lighter-weight component or technology that is not
on the list of specific components, the program provides for
manufacturers to use the ``off-cycle'' process to recognize the weight
reduction (Section IV.E.(5)(d)). Through these mechanisms, the program
provides significant flexibility and incentives for trailer light-
weighting.
NHTSA also recognizes that the aerodynamic devices that we expect
may be adopted to meet the Phase 2 trailer standards inherently add
weight to trailers. In comments on the NPRM, TTMA stated that they
believe that this weight increase will result in added trips and
increased numbers of fatal crashes. By its analysis, this additional
weight--which TTMA estimates to be 250 pounds per trailer, will cause
some trucks to exceed the trailer weight limits, necessitating
additional truck trips to transport freight that could not be moved by
the ``weighed-out'' trucks. By TTMA's analysis, these added trips would
cause an additional 184 million truck miles per year and would result
in 246 crashes and 7 extra fatal crashes, using an assumed crash rate
of 134 collisions per 100 million VMT and a 3 percent fatality rate per
crash. The agencies evaluated TTMA's estimate of additional fatalities
and disagree with some of the assumptions made in the analysis. For
example, the fatality rate used was developed in a study conducted for
Idaho and is higher than the national average. According to FMCSA's
2014 annual report for ``Large Truck and Bus Crash Facts'' indicates
there are less than 1.67 fatalities per 100 million vehicle miles
traveled (VMT) by combination trucks in the U.S. for 2014. When
multiplied by an estimated 184 million additional truck miles due to
weighed-out trucks, the result is an increase of about 3 fatalities, or
2.7 fatal crashes.
Overall, the potential positive safety implications of weight
reduction efforts could partially or fully offset safety concerns from
added weight of aerodynamic devices. In fact, for this reason, we
believe that the Phase 2 trailer program could produce a net safety
benefit in the long run due to the potentially greater amount of cargo
that could be carried on each truck as a result of trailer weight
reduction.
(e) Additional DOT Regulations Related to Trailers
In addition to NHTSA's regulations, DOT's Federal Highway
Administration (FHWA) regulates the weight and dimensions of motor
vehicles on the National Network.\333\ FHWA's regulations limit states
from setting truck size and weight limits beyond certain ranges for
vehicles used on the National Network. Specifically, vehicle weight and
truck tractor-semitrailer length and width are limited by FHWA.\334\
EPA and NHTSA do not anticipate any conflicts between FHWA's
regulations and those established in this rulemaking.
---------------------------------------------------------------------------
\333\ 23 CFR 658.9.
\334\ 23 CFR part 658.
---------------------------------------------------------------------------
Utility Trailer Manufacturing Co. (Utility) commented that reducing
existing restrictions on trailer size and weight could help encourage
the transition to new technologies and trailer designs. However, these
size and weight restrictions are under the jurisdiction of FHWA, and
are largely controlled by the weight limits established by Congress in
1956 and 1974, the size limits established in the Surface
Transportation Assistance Act of 1982, and the size and weight limits
established in the Intermodal Surface Transportation Efficiency Act of
1991. Changes to these restrictions would require a broader process
involving Congress and federal and state agencies, and is beyond the
scope of the Phase 2 trailer program.
Wabash National Corporation (Wabash) stated that the agencies
should seek to ensure that today's action harmonizes with safety
regulations applicable to trailers. Specifically, Wabash highlighted
NHTSA's work on rear impact guard standards and ongoing examination of
side impact guards. Wabash stated new or revised requirements for
impact guards could increase trailer weight. The agencies have analyzed
the issues in the present rulemaking while fully considering NHTSA's
safety regulations and rulemakings pertaining to trailers. The subject
of a possible side guard requirement is in a research stage. As
discussed in a July 2015 document, NHTSA is in the process of
evaluating issues relating to side guards and will issue a decision on
them at a later date.\335\ In December 2015, NHTSA issued a notice of
proposed rulemaking proposing to adopt requirements of Transport
Canada's standard for underride guards.\336\ NHTSA is currently
assessing next steps on that proposal, and includes as part of its
analysis consideration of impacts of any decisions on the fuel
efficiency of the vehicles. With respect to Wabash's comment regarding
the additional weight from aerodynamic devices, as discussed in the
previous subsection, the agencies believe potential compliance paths
incorporating lightweighting could offset the additional weight of
aerodynamic devices in whole or in part.
---------------------------------------------------------------------------
\335\ 80 FR 43663 (footnote 3) (July 23, 2015).
\336\ 80 FR 78417 (December 16, 2015).
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B. Overview of the Phase 2 Trailer Program and Key Changes From the
Proposal
The HD Phase 2 program represents the first time CO2
emission and fuel consumption standards have been established for
manufacturers of new trailers. As was proposed (80 FR 40257), the final
standards will phase in gradually, beginning in MY 2018. New regulated
trailers built on or after January 1, 2018 need to be certified to
[[Page 73643]]
the new CO2 emissions standards.\337\ NHTSA fuel consumption
standards are voluntary until MY 2021.
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\337\ For an explanation of how EPA defines ``model year'' for
purposes of the trailer program, see Section IV.E.(1)(a).
---------------------------------------------------------------------------
EPA and NHTSA proposed a trailer program, using appropriate aspects
of the Phase 1 tractor program as a guide, including optional averaging
provisions (i.e. optional averaging across a manufacturer's trailer
fleet) as a flexibility for trailer manufacturers to meet the proposed
standards. The comments from the trailer industry were nearly unanimous
in opposing averaging. Commenters cited the highly competitive nature
of the industry, combined with a wide range of product diversity among
companies. Commenters believe that these two factors could result in a
program that unfairly benefits the few larger companies with diverse
offerings and would be impossible to implement for the many companies
with limited product diversity. Additionally, compared to other
industry sectors, trailer manufacturers noted that they often have
little control over what kinds of trailer models their customers demand
and thus limited ability to manage the mix and volume of different
products. Specifically, Wabash and Utility stated that the dynamic and
customer-driven nature of the industry, with many customer-specific
requirements for each trailer order, makes it impossible for a
manufacturer to predict what products they will produce in a given
year. Utility stated that an averaging program will put manufacturers
in the position of having to decide which customers receive trailers
with aerodynamic devices and which receive trailers without devices.
Utility added that averaging may force manufacturers to absorb the cost
of aerodynamic devices, or it could cause customers to go to another
manufacturer with sufficient credits to fill an order without using
aerodynamic devices. Truck Trailer Manufacturers Association (TTMA)
also submitted comments asking the agencies not to adopt averaging
provisions. In contrast, Great Dane stated that averaging is an option
manufacturers may need and recommended its inclusion in the final rule.
The International Council on Clean Transportation (ICCT) said that they
generally favor averaging since it gives manufacturers maximum
flexibility in meeting standards while allowing for the technology
deployment path that best matches a company's business strategy.
In order to balance the advantage of an averaging program in
allowing for introduction of the most reasonably stringent standards
for trailers with the concerns articulated by manufacturers, the final
program accordingly limits the option for trailer manufacturers to
apply averaging exclusively to MYs 2027 and later for full-aero box
vans only. We believe this delay provides box van manufacturers
sufficient time to develop, evaluate and market new technologies and to
become familiar with the compliance process and possible benefits of
averaging. This will also allow customers to become more familiar with
the technologies and to recognize their benefits. See Section
IV.E.(5)(b) for more details on the trailer averaging program. In the
earlier years of the program, when the program does not provide for
averaging, the program does provide each manufacturer with a limited
``allowance'' of trailers that do not need to meet the standards. See
Section IV.E.(5)(a) below.
The agencies proposed standards for dry and refrigerated box vans
that were performance-based, and that were predicated on a high
adoption of aerodynamic technologies, lower rolling resistance (LRR)
tires and automatic tire inflation systems (ATIS). We designed the
compliance approach for these performance-based standards so that
manufacturers would have a degree of choice among aerodynamic, tire,
tire pressure, and weight-reduction technologies and could combine them
as they wished to achieve the standards. See 80 FR 40257. This final
program maintains this flexible approach, adding provisions that
include options for using tire pressure monitoring systems (TPMS) and
innovative weight-reduction technologies as part of manufacturer
compliance strategies. Section IV.E.(2) below discusses the trailer
compliance provisions.
We proposed ``partial-aero'' criteria for box vans with work-
performing equipment that impeded use of aerodynamic technologies and
we proposed that those ``partial-aero'' box vans would not have to
adopt the most stringent standards in MY 2027; instead, they would
maintain the MY 2024 standards. We also proposed design-based tire
standards for non-box trailers that required adoption of LRR tires and
ATIS. Finally, in recognition that some specialized box van designs are
not very compatible with the aerodynamic technologies, the agencies
established ``non-aero'' criteria for box vans. Box vans meeting the
``non-aero'' criteria will be subject to the same requirements as the
non-box trailers. 80 FR 40259.
The proposed program was designed to include nearly all trailer
types, with a limited number of exemptions or exclusions that we
believed indicated off-road, heavy-haul or non-freight transporting
operation. TTMA and the American Trucking Associations (ATA) provided
comments suggesting that additional trailer types should be excluded
from the program based on these trailers' typical operational
characteristics. The agencies considered the suggestions of these
commenters and of several individual trailer manufacturers, and we
recognize that many trailers in the proposed non-box subcategory have
unique physical characteristics for specialized operations that may
make use of lower rolling resistance (LRR) tires and/or tire pressure
systems difficult or infeasible. Instead of focusing on trailer
characteristics that indicated off-highway or specialty use, the
agencies have identified three specific types of non-box trailers that
represent the majority of non-box trailers that are designed for and
mostly used in on-road applications: Tank trailers, flatbed trailers,
and container chassis. Because of their predominant on-road usage, the
tire technologies adopted in this trailer program will be consistently
effective for these non-box trailer types. Consequently, the final
program as it applies to non-box trailers is limited to tanks,
flatbeds, and container chassis. All other non-box trailers, about half
of the non-box trailers produced, are excluded from the Phase 2 trailer
program, with no regulatory requirements. See Section IV.C.(1) for the
regulatory definitions of the trailers included in this program.
Wabash commented that partial-aero vans should be exempt in MY 2021
rather than MY 2027 as proposed, citing the need for multiple devices
to meet the later standards. The agencies reconsidered the proposed
partial-aero standards in light of this comment and recognize that it
would likely be difficult for most manufacturers to meet the proposed
MY 2024 standards without the use of multiple devices, and yet partial-
aero trailers, by definition, are restricted from using multiple
devices. For these reasons, the agencies redesigned the partial-aero
standards such that trailers with qualifying work-performing equipment
can meet standards that would be achievable with the use of a single
aerodynamic device throughout the program, similar to the MY 2018
standards. The partial-aero standards do, however, increase in
stringency slightly in MY 2021 to reflect
[[Page 73644]]
the broader use of improved lower rolling resistance tires.
The agencies also considered comments from manufacturers that were
concerned about the cost and, availability of ATIS for the trailer
industry. Wabash, Owner Operator Independent Drivers Association
(OOIDA), the Rubber Manufacturers Association (RMA), American Trucking
Associations (ATA), and Bendix asked that TPMS be allowed for trailer
tire compliance in addition to ATIS. OOIDA said that operators prefer
less expensive and easier to operate TPMS to ATIS. Wabash expressed
concern that ATIS suppliers would not be able to meet demand should
ATIS be required as a compliance mechanism for all trailers, especially
in the early years of the program. Great Dane stated that their
customers are not seeing consistent benefit of ATIS. ATA commented that
trailer manufacturers should be allowed to use TPMS for compliance
because they are increasingly effective, and some trailers used in
heavy-haul applications would need an additional ATIS air compressor,
which adds cost and weight that can be avoided by the use of TPMS. The
California Air Resources Board supported the agencies' proposal to
allow only ATIS for compliance since TPMS require action on the part of
the driver to re-inflate affected tires and thus the benefit of the
systems is dependent on driver behavior.
The agencies agree that TPMS generally promote proper tire
inflation and that including these lower-cost systems as a compliance
option will increase acceptance of the technologies. The final trailer
program provides for manufacturers to install either TPMS or ATIS as a
part of compliance. For full- and partial-aero trailers, the standards
are performance standards, and the GEM-based compliance equation
(described below) provides ATIS a slightly greater credit than it does
for TPMS, to account for the greater uncertainty about TPM system
effectiveness due to the inherent user-interaction required with
systems that simply monitor tire pressure. These performance standards
are based on the use of ATIS and the numerical values of these
standards reflect the 0.2 percent increase in stringency. See Section
IV.D.(1)(c) for additional information.
For non-aero box vans and non-box trailers, the standards are
design standards, met directly by installation of specified
technologies, not by using the compliance equation. As long as a
manufacturer of these trailers installs either a TPMS or an ATIS (as
well as lower rolling resistance tires meeting the specified
threshold), the trailer will comply, and either technology applies
equally. We project that most design-based tire standards will be met
with the less expensive TPMS, but trailers with ATIS will also comply.
The effectiveness values adopted for ATI and TPMS in the trailer
program are consistent with those in the tractor and vocational vehicle
programs.
The agencies generated the proposed standards with use of EPA's
Greenhouse gas Emissions Model (GEM) vehicle simulation tool, but for
compliance we created a GEM-based equation that trailer manufacturers
would use for compliance. See Section IV.E.(2)(a). We made several
improvements to GEM based on public comment, and these improvements
impacted the results of the model. We have re-created a compliance
equation for trailers based on the updated model and are adopting the
new equation as the means for trailer manufacturers to certify their
trailers in Phase 2.
The agencies also proposed an aerodynamic device testing compliance
path that would allow device manufacturers to submit performance test
data directly to EPA for pre-approval. 80 FR 40280. We designed this
alternative to reduce the test burden of trailer manufacturers by
allowing them to install devices with pre-approved data and to
eliminate the need to perform their own testing of the devices. Based
on public comment, the agencies are adopting the aerodynamic device
testing alternative in the final trailer program and are updating
several of the provisions related to submission and verification of
test data on those devices. See Section IV.E.(3)(b)(v).
The agencies considered five alternative programs in the proposal
and extensively evaluated what were termed Alternative 3 and
Alternative 4 in our feasibility analysis. 80 FR 40273. The final
stringency of both alternatives was identical and each included three-
year stages of increasing stringency. However, Alternative 4
represented an accelerated timeline that reached its final stringency
in MY 2024. Alternative 3 included an additional three years to meet
its final stringency in MY 2027. Alternative 5 was proposed in four
stages, but would have a required much greater application rate of the
most advanced aerodynamic devices, including aerodynamic technologies
on non-box trailers. The agencies believed this alternative was
infeasible for this newly-regulated industry and did not extensively
evaluate it.
Public comment from the trailer industry unanimously opposed the
accelerated timeline of the proposed Alternative 4. TTMA recommended
that the agencies adopt no mandatory requirements, and instead rely on
a voluntary program for trailers. OOIDA supported standards less
stringent than either Alternatives 3 or 4. Great Dane said that
adoption of standards more stringent than Alternative 3 would
considerably increase the probability of negative effects on
stakeholders. Wabash questioned whether, under the accelerated timeline
of Alternative 4, current technologies could be produced for all
applications for which they would be needed, and with sufficient
reliability. The International Food Service Delivery Association, the
Truck Trade Association, and Schneider also opposed Alternative 4 for
similar reasons. STEMCO, California Air Resources Board (CARB), ICCT,
and American Council for an Energy-Efficient Economy (ACEEE) supported
Alternative 4. The Environmental Defense Fund (EDF) supported
Alterative 5, but with an accelerated schedule, saying technologies
will be available to meet the Alternative 5 standards by 2024.
The final standards adopted for the Phase 2 trailer program have
the same four-stage implementation schedule as the proposed Alternative
3, with standards phasing in for MYs 2018, 2021, 2024, and 2027 (NHTSA
standards apply beginning in MY 2021). We received comments regarding
adjustments to technology adoption rates in our baseline reference
cases which the agencies found to be persuasive, and the resulting
adjustments are described in Section IV.D.(2)(c). Additionally, the
technology effectiveness values and projected adoption rates for each
of the four stages of the program were updated in response to comments,
to reflect new test data, and to account for a program without
averaging.
C. Phase 2 Trailer Standards
These final rules establish, for the first time, a set of
CO2 emission and fuel consumption standards for
manufacturers of new trailers that phase in over a period of nine years
and continue to reduce CO2 emissions and fuel consumption in
the years to follow. These standards are expressed as overall
CO2 emissions and fuel consumption performance standards,
considering the trailer as an integral part of the tractor-trailer
vehicle.
The agencies believe that the trailer standards finalized here will
implement our respective statutory obligations. That is, we believe
that this set of standards represents the maximum feasible alternative
within the meaning of section 32902(k) of EISA, and are
[[Page 73645]]
appropriate under EPA's CAA authority (sections 202(a)(1) and (2)).
These standards have the same implementation schedule as the
proposed Alternative 3, with standards phasing in for MYs 2018, 2021,
2024, and 2027. In our consideration of the full range of comments, the
agencies have adjusted elements of the proposed Alternative 3 in ways
that address some of these comments, as discussed in Section 0 below.
As discussed in Section IV.E.(5)(b), the option to apply averaging to
meet these standards will be available starting with MY 2027, but will
not be available in earlier model years.
The agencies did not propose and are not establishing standards for
CO2 emissions and fuel consumption from the transport
refrigeration units (TRUs) used on refrigerated box trailers. Also, EPA
is not establishing standards for hydrofluorocarbon (HFC) emissions
from TRUs. See Section IV.C.(3) below.
(1) Trailer Designs Covered by the Trailer Program
As described previously, the trailer industry produces many
different trailer designs for many different applications. The agencies
are introducing standards for a majority of these trailers that phase
in from MY 2018 through MY 2027; the NHTSA fuel consumption standards
are voluntary until MY 2021. The regulatory definitions of the trailers
covered by this program are summarized below and are found in 40 CFR
1037.801 and 49 CFR 571.3.
(a) Box Vans
Box vans are trailers with enclosed cargo space that is permanently
attached to the chassis, with fixed sides, nose and roof. Trailers with
sides or roofs consisting of curtains or other removable panels are not
considered box vans in this program. Box vans with self-contained HVAC
systems are considered ``refrigerated vans.'' This definition includes
systems that provide cooling, heating or both. Box vans without HVAC
systems are considered ``dry vans.''
This rulemaking establishes separate standards for box vans based
on length. Box vans of length greater than 50 feet are considered
``long box vans.'' \338\ All vans 50 feet and shorter are considered
``short box vans.'' The agencies requested comment on the proposed 50-
foot demarcation between ``long'' and ``short'' box vans (80 FR 40258).
CARB and the Union of Concerned Scientists (UCS) commented on this
issue, requesting that the demarcation be changed to 47 feet, such that
48-foot vans would be covered under the long box subcategory. CARB
suggested that the performance of aerodynamic technologies such as
skirts and boat tails on a 48-foot van would be more similar to the
performance of the same technologies on a 53-foot van than on the 28-
foot van used to evaluate short box performance. CARB also stated that
48-foot trailers are not pulled in tandem and thus have the potential
to adopt rear devices for additional reductions.
---------------------------------------------------------------------------
\338\ Most long trailers are 53 feet in length; we are adopting
a cut-point of 50 feet to avoid an unintended incentive for an OEM
to slightly shorten a trailer design in order to avoid the new
regulatory requirements.
---------------------------------------------------------------------------
The agencies agree that 48-foot vans are aerodynamically similar to
longer vans and that 28-foot trailers are often used in tandem,
reducing the opportunity for rear aerodynamic features. However, the
agencies believe that the use of 48-foot vans is more similar to that
of shorter trailers than to that of the long-haul vans that make up
most the long box subcategory. Trailer manufacturers have indicated
that 48-foot vans are mostly used in short-haul operations (e.g., local
food service delivery) and consequently they travel less frequently at
speeds at which aerodynamic technologies can be most beneficial. Also,
48-foot vans make up a relatively small fraction of long box vans.\339\
The agencies thus do not believe that standards predicated on the use
of more effective aerodynamic technologies on 48-foot vans will provide
a substantial enough additional reduction in CO2 emissions
and fuel consumption to justify more stringent standards for those
trailers. For these reasons, the agencies are maintaining the proposed
50-foot demarcation between long and short box vans and are basing the
standards for each van size category accordingly.
---------------------------------------------------------------------------
\339\ Memorandum to Docket EPA-HQ-OAR-2014-0827: Evaluation of
50-Foot Trailer Length Demarcation to Distinguish between Long and
Short Box Vans. July 18, 2016.
---------------------------------------------------------------------------
The trailer program identifies certain types of work-performing
equipment manufacturers may install on box vans that may inhibit the
use of aerodynamic technologies and thus impede the trailers' ability
to meet standards predicated on adoption of aerodynamic technologies.
For this program, we consider such trailer equipment to consist of a
rear lift gate or rear hinged ramp and any of the following side
features: A side lift gate, a side-mounted pull-out platform, steps for
side-door access, a drop-deck design, or a belly box or boxes that
occupy at least half the length of both sides of the trailer between
the centerline of the landing gear and the leading edge of the front
wheels. See 40 CFR 1037.107(a)(1) and 49 CFR 571.3.
The agencies have also considered how ``roll-up'' or ``overhead''
rear trailer doors might inhibit the use of rear aerodynamic devices.
TTMA, ATA, Great Dane, and Utility stated that roll-up doors are work-
performing devices that can inhibit rear aerodynamic technologies.
However, the agencies are aware of several existing aerodynamic devices
designed to be installed near the rear of a trailer that can function
regardless of the type of rear door. Also, in their comments, STEMCO
indicated that additional rear aerodynamic technologies would be less
likely to enter the market if the trailer program were to include roll-
up doors on the list of work-performing devices above and the industry
didn't demand an aerodynamic product to work with roll-up doors. The
agencies recognize there may currently be limited availability of rear
aerodynamic technologies for roll-up door trailers, yet we also
understand that innovations and improvements continue for all trailer
aerodynamic technologies. For this reason, the final trailer program
includes an interim provision--through MY 2023--for box vans with roll-
up doors to qualify for non-aero and partial-aero standards (as defined
immediately below), by treating such doors as work-performing devices
equivalent to rear lift gates. For MY 2024 and later, roll-up doors
will not qualify as a work-performing device in this way; however, we
expect that manufacturers of trailers with roll-up doors will comply
using combinations of new rear aerodynamic technologies, in conjunction
with improved trailer side and gap-reducing technologies as
appropriate. See 40 CFR 1037.150.
As presented in Section IV.C.(2) below, the agencies are adopting
separate standards for each of the same nine box van subcategories
introduced in the proposal (80 FR 40256) and for the non-box category
discussed below. Full-aero long box dry vans and full-aero long box
refrigerated vans are those that are over 50 feet in length and that do
not have any of the work-performing equipment discussed immediately
above. Similarly, full-aero short box dry vans and full-aero short box
refrigerated vans are 50 feet and shorter without any work-performing
equipment. We expect these trailers to be capable of meeting the most
stringent standards in the trailer program.
Long box dry vans and long box refrigerated vans that have work-
performing equipment either on the underside or on the rear of the
trailer that would limit a manufacturer's ability
[[Page 73646]]
to install aerodynamic technologies may be designated as partial-aero
vans for their given subcategory. The partial-aero standards are based
on adoption of tire technologies and a single aerodynamic device
throughout the program. Long box dry and refrigerated vans that have
work-performing equipment on the underside and rear of the trailer may
be designated non-aero box vans. Non-aero box vans are a single
subcategory that have design-based tire standards.
For short vans, the standards are never predicated on the use of
rear devices, since many 28-foot trailers are often pulled in tandem.
However, we are not aware of any current legislative or regulatory
initiatives that would allow tandem trailers longer than 33 feet in
length, and therefore we believe that short vans of length 35 feet and
longer are unlikely to be pulled in tandem in the timeframe of these
rules. We are adopting separate criteria for partial- and non-aero
designation for short vans based on a length threshold of 35 feet. If
vans 35 feet or longer have work-performing equipment on the underside
of the trailer, we expect manufacturers can install rear devices to
meet the full-aero standards, but they have the option to designate
these trailers as partial-aero dry or refrigerated short vans with
reduced standards that can be met with tire technologies and a single
aerodynamic device. If vans 35 feet and longer have work performing
equipment on the underside and rear, manufacturers may designate them
as non-aero box vans.
Short vans that are less than 35 feet in length are more likely to
be pulled in tandem, making most rear aerodynamic devices infeasible.
Since gap reducers alone are not sufficiently effective to replace a
skirt and the shortest trailers are not expected to install rear
devices, both dry and refrigerated vans that are shorter than 35 feet
with work-performing equipment on the underside of the trailer may be
designated non-aero box vans that can comply with tire technologies
only. In addition, refrigerated vans that are shorter than 35 feet
cannot install gap reducers because of the TRU. Consequently, all
refrigerated vans shorter than 35 feet, irrespective of work-performing
equipment, can be designated partial-aero short refrigerated vans whose
standards can be met with skirts and tire technologies. See 40 CFR
1037.107(a)(1) and 49 CFR 571.3. Because the types of work-performing
equipment identified here generally add significant cost and weight to
a trailer, we believe that the reduced standards available for trailers
using this equipment are unlikely to provide an incentive for
manufacturers to install them simply as a way to avoid the full aero
standards.
(b) Non-Box Trailers
All trailers that do not meet the definition of box vans are
considered non-box trailers in the trailer program. Several commenters
requested a clearer distinction of the trailers that are included in
the program. In response, the agencies are limiting the non-box trailer
standards to three trailer types that have distinct physical
characteristics and are most often driven on-highway: Tank trailers,
flatbed trailers, and container chassis. Non-box trailers that do not
meet the definitions below are excluded from the trailer program, as
discussed in the following section.
Tank trailers are defined for the trailer program as enclosed
trailers designed to transport liquids or gases. For example, DOT 406,
DOT 407, and DOT 412 tanks would fit this definition. These non-box
trailers can be pressurized or designed for atmospheric pressure. Tanks
that are infrequently used in transport and primarily function as
storage vessels for liquids or gases (e.g., frac tanks) are not
included in our definition of tank trailers and are excluded from the
program.
Flatbed trailers for purposes of the trailer program are platform
trailers with a single, continuous load-bearing surface that runs from
the rear of the trailer to at least the trailer's kingpin. Flatbed
trailers are designed to accommodate side-loading cargo, and this
definition includes trailers that use bulkheads, one or more walls,
curtains, straps or other devices to restrain or protect cargo while
underway. Note that drop deck and lowboy platform trailers are not
considered continuous load-bearing surfaces.
Finally, in the trailer program, container chassis are trailers
designed to transport temporary containers. The standards apply to all
lengths of container chassis, including expandable versions. The
regulations do not apply to the containers being transported, unless
they are permanently mounted on the chassis.
(c) Excluded Trailers
As in the proposal (80 FR 40259), the final trailer program
completely excludes certain trailer types. However, in response to
comments and an improved understanding of the industry, the agencies
have changed our approach to excluding some trailer types.
In the proposal, we focused on excluding trailers based on
characteristics that tended to indicate predominant operation in off-
highway applications. The American Trucking Associations (ATA) and the
Truck Trailer Manufacturers Association (TTMA) provided comments
suggesting that additional trailer types should be excluded from the
program based on the trailers' typical operational characteristics,
generally because of these trailers' limited on-highway operation.
Also, Wabash requested that the program specify clearer criteria for
excluding or exempting trailers.
The agencies considered all of the suggestions of the commenters,
and we now believe that a different approach to excluding some trailer
types is more appropriate. We recognize that many trailer types in the
proposed non-box subcategory have many unique physical characteristics
and are designed for specialized operations and it would be difficult
to create a comprehensive list of traits that indicated off-road use.
This wide array of trailer types would have made the proposed approach
difficult to implement for both trailer manufacturers and for the
agencies, since the usage patterns of many specialty trailer types can
vary greatly. Some of these uses, especially off-highway applications,
may make use of the proposed tire technologies for compliance difficult
or infeasible and may limit their effectiveness. Additionally, the
agencies are aware that many manufacturers that build these specialty
non-box trailers are small businesses (fewer than 1000 employees), and
they would incur a disproportionately large financial burden compared
to larger manufacturers if they were subject to the standards.
For these reasons, instead of focusing our approach to excluding
trailer types on trailer characteristics that indicated predominant
off-highway use, the final program excludes all non-box trailer types
except for three specific types that we believe are designed for and
mostly used in on-road applications. These types are tanks, flatbeds,
and container chassis, as defined in the previous sub-section. We now
consider this approach to be much clearer and more straightforward to
implement than the proposed approach. Manufacturers of these types of
trailers can easily obtain and install LRR tires and tire pressure
systems, and achieve the most consistent benefit from use of these
technologies. The trailer program excludes all trailers that do not
meet the criteria outlined in Section IV.C.(1)(b) above, and specified
in 40 CFR 1037.5 and in 49 CFR 535.3(e).
The final rule also excludes certain types of trailers based on
design
[[Page 73647]]
characteristics, consistent with the proposed rule. More precisely,
these excluded trailer types are sub-types of otherwise regulated
trailer types, such as certain types of box vans. First, the rule
excludes trailers intended to haul very heavy loads, as indicated by
the number of axles. Specifically, the rules exclude all trailers with
four or more axles, and trailers less than 35 feet long with three
axles. For example, a 53-foot box van with four axles would be
excluded. Also, we agree with Utility that spread-axle trailers may be
more susceptible to tire scrubbing, and the program accordingly
excludes trailers with an axle spread of at least 120 inches between
adjacent axle centerlines. The axle spread exclusion does not apply to
trailers with adjustable axles that have the ability to be spaced less
than 120 inches apart. Finally, the rules exclude trailers intended for
temporary or permanent residence, office space, or other work space,
such as campers, mobile homes, and carnival trailers.\340\
---------------------------------------------------------------------------
\340\ Secondary manufacturers who purchase incomplete trailers
and complete their construction to serve as trailers are subject to
the requirements of 40 CFR 1037.620 and 49 CFR 535.5(e).
---------------------------------------------------------------------------
Manufacturers of excluded trailers have no reporting or other
regulatory requirements under the trailer program. See 40 CFR 1037.5
and 49 CFR 535.3 for complete definitions of the trailer types that the
program excludes. However, where the criteria for exclusion identified
above may be unclear for specific trailer models, manufacturers are
encouraged to ask the agencies to make a determination before
production begins.
(2) Fuel Consumption and CO2 Standards
As described previously in Section I, it is the combination of the
tractor and the trailer that form the useful vehicle, and trailer
designs substantially affect the CO2 emissions and fuel
consumption of the tractors pulling them. Note that although the
agencies are adopting new CO2 and fuel consumption standards
for trailers separately from tractors, we set the numerical level of
the trailer standards (see Section IV.D. below) based on operation with
``standard'' reference tractors in recognition of their
interrelatedness. In other words, the regulatory standards refer to the
simulated emissions and fuel consumption of a standard tractor pulling
the trailer being certified.
Unlike the other sectors covered by this Phase 2 rulemaking,
trailer manufacturers do not have experience certifying under the Phase
1 program (or under EPA's criteria pollutant program). Moreover, a
large fraction of the trailer industry is composed of small businesses
and even the largest trailer manufacturers do not have the same
resources available to them as do manufacturers in some of the other
heavy-duty sectors. The standards and compliance regime for trailers
have been developed with this in mind, and we are confident these
standards can be achieved and demonstrated by manufacturers who lack
prior experience implementing such standards.
The agencies designed this trailer program to ensure a gradual
progression of both stringency and compliance requirements in order to
limit the impact on this newly-regulated industry. The agencies are
adopting progressively more stringent standards in three-year stages
leading up to the MY 2027,\341\ and are including several options to
reduce compliance burden in the early years as the industry gains
experience with the program (see Section IV.E.). EPA will initiate its
program in MY 2018 with standards for long box dry and refrigerated
vans, which standards can be met with common tire technologies and
SmartWay-verified aerodynamic devices and standards for the other
regulated trailers based on tire technologies only. In this early
stage, we expect that manufacturers of trailers in the other trailer
subcategories will meet their standards by using tire technologies
only. NHTSA's regulations will be voluntary until MY 2021 as described
in Section IV.C.(2).
---------------------------------------------------------------------------
\341\ These stages are consistent with NHTSA's stability
requirements under EISA.
---------------------------------------------------------------------------
Standards for the next stages, which begin in MY 2021, gradually
increase in stringency for each subcategory, including the introduction
of standards for short box vans that we expect will be met by applying
both aerodynamic and tire technologies. The standards for partial-aero
box vans are less stringent than those for full-aero box vans,
reflecting that the standards for partial-aero vans are based on
adoption of a single aerodynamic device throughout the program. This is
in contrast to the proposed standards for partial-aero vans that were
identical to the standards for full-aero vans through MY 2026.
Table IV-2 and Table IV-3 below present the CO2 and fuel
consumption standards, beginning in MY 2018 that the agencies are
adopting for full- and partial-aero box vans, respectively. The
standards are expressed in grams of CO2 per ton-mile and
gallons of fuel per 1,000 ton-miles to reflect the load-carrying
capacity of the trailers.
Table IV-2--Trailer CO[ihel2] and Fuel Consumption Standards for Full-Aero Box Vans
----------------------------------------------------------------------------------------------------------------
Subcategory Dry van Refrigerated van
Model year ---------------------------------------------------------------------------------
Length Long Short Long Short
----------------------------------------------------------------------------------------------------------------
2018-2020..................... EPA Standard.... 81.3 125.4 83.0 129.1
(CO[ihel2] Grams
per Ton-Mile)
Voluntary NHTSA 7.98625 12.31827 8.15324 12.68173
Standard.
(Gallons per
1,000 Ton-Mile)
2021-2023..................... EPA Standard.... 78.9 123.7 80.6 127.5
(CO[ihel2] Grams
per Ton-Mile)
NHTSA Standard.. 7.75049 12.15128 7.91749 12.52456
(Gallons per
1,000 Ton-Mile)
2024-2026..................... EPA Standard.... 77.2 120.9 78.9 124.7
(CO[ihel2] Grams
per Ton-Mile)
NHTSA Standard.. 7.58350 11.87623 7.75049 12.24951
(Gallons per
1,000 Ton-Mile)
2027+......................... EPA Standard.... 75.7 119.4 77.4 123.2
(CO[ihel2] Grams
per Ton-Mile)
NHTSA Standard.. 7.43615 11.72888 7.60314 12.10216
(Gallons per
1,000 Ton-Mile)
----------------------------------------------------------------------------------------------------------------
[[Page 73648]]
Table IV-3--Trailer CO[ihel2] and Fuel Consumption Standards for Partial-Aero Box Vans
----------------------------------------------------------------------------------------------------------------
Subcategory Dry van Refrigerated van
Model year ---------------------------------------------------------------------------------
Length Long Short Long Short
----------------------------------------------------------------------------------------------------------------
2018-2020..................... EPA Standard.... 81.3 125.4 83.0 129.1
(CO[ihel2] Grams
per Ton-Mile)
Voluntary NHTSA 7.98625 12.31827 8.15324 12.68173
Standard.
(Gallons per
1,000 Ton-Mile)
2021+......................... EPA Standard.... 80.6 123.7 82.3 127.5
(CO[ihel2] Grams
per Ton-Mile)
NHTSA Standard.. 7.91749 12.15128 8.08448 12.52456
(Gallons per
1,000 Ton-Mile)
----------------------------------------------------------------------------------------------------------------
The agencies are not adopting CO2 or fuel consumption
standards predicated on aerodynamic improvements for non-box trailers
or non-aero box vans at any stage of this program. Instead, we are
adopting design standards that require manufacturers of these trailers
to adopt specific tire technologies and thus to comply without
aerodynamic devices. This approach significantly limits the compliance
burden for these manufacturers, especially if they do not also
manufacture box vans subject to the aerodynamic requirements. The
agencies are adopting these design standards in two stages. In MY 2018,
the non-box trailer standards require manufacturers to use tires
meeting a rolling resistance of 6.0 kg/ton or better and to install
tire pressure systems. In MY 2021, non-box trailers will also need tire
pressure systems and LRR tires at 5.1 kg/ton (the current SmartWay-
verification threshold) or better. The standards require non-aero box
vans, which we believe are largely at a baseline rolling resistance 6.0
kg/ton today, to install tire pressure monitoring systems and tires at
a rolling resistance of 5.1 kg/ton in MY 2018 and 4.7 kg/ton in MY 2021
and later (there are no further increases in standard stringency for
these trailers after MY 2021). For non-box trailers and non-aero box
vans, manufacturers may install either TPMS or ATIS for compliance.
Table IV-4 summarizes the two stages of these design standards.
Table IV-4--Design-Based Tire Standards for Non-Box Trailers and Non-Aero Box Vans
----------------------------------------------------------------------------------------------------------------
Model year Tire technology Non-box trailers Non-aero box vans
----------------------------------------------------------------------------------------------------------------
2018-2020............................... Tire Rolling Resistance Level 6.0 5.1
(kg/ton).
Tire Pressure System............ TPMS or ATIS TPMS or ATIS
2021+................................... Tire Rolling Resistance Level 5.1 4.7
(kg/ton).
Tire Pressure System............ TPMS or ATIS TPMS or ATIS
----------------------------------------------------------------------------------------------------------------
The agencies project that the standards for the entire class of
regulated trailers, when fully implemented in MY 2027, will achieve
fuel consumption and CO2 emissions reductions of two to nine
percent relative to mostly market-driven adoption absent a national
regulatory program (see Section IV.D.(2)). Because of the rapid pace of
technological improvement in recent years and the lead time of nearly a
decade, the agencies expect that both trailer designs and bolt-on
CO2- and fuel consumption-reducing technologies will advance
well beyond the performance of their present-day counterparts.
Regardless, we expect that the MY 2027 standards for full-aero box vans
could be met with high-performing aerodynamic and tire technologies
largely available in the marketplace today. A description of
technologies that the agencies considered in developing these rules is
provided in Section IV.D., with additional details in RIA Chapter 2.10.
(3) Non-CO2 GHG Emissions From Trailers
In addition to the impact of trailer design on the CO2
emissions of tractor-trailer vehicles, EPA recognizes that refrigerated
trailers can also be a source of emissions of HFCs. Specifically, HFC
refrigerants that are used in transport refrigeration units (TRUs) have
the potential to leak into the atmosphere.
In their comments, CARB said they believed that EPA underestimated
the potential for TRU refrigerant leakage, and requested that EPA (1)
initiate a TRU refrigerant ``usage monitoring program'' to support
future evaluations of leakage; (2) create incentives for low- and zero-
emission (e.g., cryogenic) TRUs; and (3) for EPA's SNAP program to
phase out the main TRU refrigerant (R404a) when viable alternatives are
available. EPA did not propose any action related to TRUs in this rule,
and CARB did not provide sufficient information for EPA to introduce
new regulatory requirements for TRUs at this time. In general, however,
EPA will continue to monitor the state of TRU technology and operation,
and may pursue appropriate action if warranted in the future.
We also note that EPA has separately proposed a regulation under
Title VI of the CAA, specifically section 608. See 80 FR 69457
(November 9, 2015). This proposal would extend existing regulations on
ozone depleting refrigerants to many alternative refrigerants, such as
HFCs, which are the most common refrigerants used in TRUs.\342\ If
finalized as proposed, EPA would require that appliances like TRUs be
subject to the applicable requirements of 40 CFR subpart F, including
requirements for servicing by a certified technician using certified
recovery equipment and for recordkeeping by technicians disposing of
such appliances with a charge size between five and fifty pounds, which
[[Page 73649]]
would include TRUs, to help ensure that the refrigerant is not
vented.\343\
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\342\ Under the proposal, the regulations would not be extended
to equipment using a substitute refrigerant when that use of the
refrigerant has been exempted from the venting prohibition, as
listed in 40 CFR 82.154(a).
\343\ The Clean Air Act (42 U.S.C. 7671) uses the term
``appliance'' to refer to TRUs and other similar equipment.
---------------------------------------------------------------------------
(4) Lead-Time Considerations
As mentioned earlier, although the agencies did not include
standards for trailers in Phase 1, box van manufacturers have been
gaining experience with CO2- and fuel consumption-reducing
technologies over the past several years, and the agencies expect that
trend to continue, due in part to EPA's SmartWay program and
California's Tractor-Trailer Greenhouse Gas Regulation. Most
manufacturers of 53-foot box vans have some experience installing these
aerodynamic and tire technologies for customers. Manufacturers of
trailers other than 53-foot box vans do not have the benefit of
programs such as SmartWay to provide a reliable evaluation and
promotion of aerodynamic technologies for those trailers and therefore
have less experience with those technologies. However, all trailer
manufacturers have experience installing tires and the installation
process does not change with the use of lower rolling resistance tires.
Some manufacturers may not have direct experience with tire pressure
systems, but we observe that they are mechanically fairly simple and
can be incorporated into trailer production lines without significant
process changes.
EPA is adopting CO2 emission standards for long box vans
for MY 2018 that represent stringency levels similar to the current
performance level needed for SmartWay's verification and those required
for the current California regulation. These standards can be met by
adopting off-the-shelf aerodynamic and tire technologies available
today. The agencies are adopting less stringent requirements for
manufacturers of other highway trailer subcategories beginning in MY
2018 that can be met without use of aerodynamic technologies. Given
that these technologies are readily available and are already familiar
to the industry, the agencies believe, for both cases, that
manufacturers have sufficient lead time to adopt these technologies and
to implement the simplified compliance provisions introduced below and
described fully in Section IV.E.
NHTSA's direction under EISA is to allow four model years of lead-
time for new fuel consumption standards, regardless of the stringency
level or availability of flexibilities. Therefore, NHTSA's fuel
consumption requirements are not mandatory until MY 2021. Prior to MY
2021, trailer manufacturers could voluntarily participate in NHTSA's
program, noting that once they made such a choice, they will need to
stay in the program for all succeeding model years.\344\
---------------------------------------------------------------------------
\344\ NHTSA adopted a similar voluntary approach in the first
years of Phase 1 (see 76 FR 57106).
---------------------------------------------------------------------------
We believe there are technology pathways available today that
manufacturers could use to comply with the standards when they are
fully implemented in MY 2027. The agencies designed each three-year
stage of the program as a gradual progression of stringency that
provides sufficient lead-time for all affected trailer manufacturers to
evaluate and adopt CO2- and fuel consumption-reducing
technologies or design trailers to meet these standards while meeting
their customers' needs. The agencies believe that the burdens of
installing and marketing these CO2- and fuel consumption-
reducing technologies at the stringency levels of this program are not
limiting factors in determining necessary lead-time for manufacturers
of these trailers. Instead, we expect that the first-time compliance
and, in some cases, performance testing, will be more challenging
obstacles for this newly regulated industry. For these reasons, the
standards phase in over a period of nine years, with flexibilities to
minimize the compliance and testing burdens especially in the early
years of the program (see Section IV.E.). We are adopting provisions
for manufacturers to use a GEM-based compliance equation in lieu of the
GEM vehicle simulation tool, which will reduce the number of resources
required to learn and implement the model. We are also finalizing
compliance provisions that allow trailer manufacturers to use pre-
approved aerodynamic test data from aerodynamic device manufacturers,
which could eliminate a trailer manufacturer's test burden for
compliance. As explained above, non-aero box vans and non-box trailers,
which make up almost 20 percent of the regulated trailers, are subject
to straightforward design-based tire standards throughout the program
that require that they install qualified LRR tires and tire pressure
systems with simplified compliance requirements. See Section IV.E. for
a full description of the trailer compliance program.
The Rubber Manufacturers Association (RMA) expressed concern that
the proposed program would not provide sufficient lead time for the
development and production of LRR tire designs for some off-road
applications. As discussed above, the final program now excludes all
trailer types that would generally be used in off-road applications,
including all non-box trailers except tanks, flatbeds, and container
chassis. Therefore, trailer types designed for off-road use do not have
LRR tire requirements, and the final program should significantly
reduce RMA's concerns about available lead time for special tire
development. Additionally, we have adjusted the tire performance
requirements for the LRR tires of the non-box trailer design standards.
D. Feasibility of the Trailer Standards
As discussed below, the agencies' determination is that the
standards presented in Section IV.C.(2), are the maximum feasible and
appropriate under the agencies' respective authorities, considering
lead time, cost, and other factors. We summarize our analyses in this
section, and describe them in more detail in RIA Chapter 2.10.
Our analysis of the feasibility of the CO2 and fuel
consumption standards is based on technology cost and effectiveness
values collected from several sources. Our assessment of the trailer
program is based on information from:
--Southwest Research Institute evaluation of heavy-duty vehicle fuel
efficiency and costs for NHTSA,\345\
---------------------------------------------------------------------------
\345\ Reinhart, T.E. (June 2015). Commercial Medium- and Heavy-
Duty Truck Fuel Efficiency Technology Study--Report #1. (Report No.
DOT HS 812 146). Washington, DC: National Highway Traffic Safety
Administration.
---------------------------------------------------------------------------
--2010 National Academy of Sciences report of Technologies and
Approaches to Reducing the Fuel Consumption of Medium- and Heavy-Duty
Vehicles,\346\
---------------------------------------------------------------------------
\346\ 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.
---------------------------------------------------------------------------
--TIAX's assessment of technologies to support the NAS panel
report,\347\
---------------------------------------------------------------------------
\347\ TIAX, LLC. ``Assessment of Fuel Economy Technologies for
Medium- and Heavy-Duty Vehicles,'' Final Report to National Academy
of Sciences, November 19, 2009.
---------------------------------------------------------------------------
--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-
[[Page 73650]]
duty long haul combination tractors (the NESCCAF/ICCT study),\348\
---------------------------------------------------------------------------
\348\ NESCCAF, ICCT, Southwest Research Institute, and TIAX.
Reducing Heavy-Duty Long Haul Combination Truck Fuel Consumption and
CO2 Emissions. October 2009.
---------------------------------------------------------------------------
--The technology cost analysis conducted by ICF for EPA,\349\ and
---------------------------------------------------------------------------
\349\ 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.
---------------------------------------------------------------------------
--Testing conducted by EPA.
As an initial step in our analysis, we identified the extent to
which fuel consumption- and CO2-reducing technologies are in
use today. The technologies include those that reduce aerodynamic drag
at the front, back, and underside of trailers, tires with lower rolling
resistance, tire pressure technologies, and weight reduction through
component substitution. For our feasibility analysis, we identified a
set of technologies to represent the range of those likely to be used
in the time frame of the rule. The agencies developed the
CO2 and fuel consumption standards for each stage of the
program by combining the projected effectiveness of trailer
technologies and the projected adoption rates for each trailer type. It
should be noted that the agencies need not and did not attempt to
predict the exact future pathway of the industry's response to the new
performance standards for box vans. Rather, we demonstrated one example
compliance pathway that could reasonably occur, taking into account
cost of the standards (including costs of compliance testing and
certification), and needed lead time. More details regarding our
analysis can be found in Chapter 2.10 of the RIA.
(1) Technological Basis of the Standards
Trailer manufacturers can design a trailer to reduce fuel
consumption and CO2 emissions by addressing the trailer's
aerodynamic drag, tire rolling resistance, and weight. Accordingly, the
agencies investigated aerodynamic technologies (e.g., skirts and
tails), low rolling resistance tires, tire pressure systems, and
materials that could be used to reduce trailer weight. A description of
these technologies, including their expected performance, can be found
in Chapter 2.10.2 of the RIA. For box vans, the analysis below presents
one possible set of technology designs by which trailer manufacturers
could reasonably achieve the standards. However, in practice, trailer
manufacturers could choose different technologies, versions of
technologies, and combinations of technologies that meet the business
needs of their customers while complying with this program.
To minimize complexity, a single van is used to represent each box
van trailer subcategory in compliance and in our feasibility analysis.
Within the short box dry and refrigerated van subcategories (50-foot
and shorter), the largest fraction of those trailers are 28 feet in
length. Similarly, 53-foot vans make up the majority of the long box
dry and refrigerated vans. Consequently, a 28-foot dry van is used to
represent all lengths of short dry vans and a 53-foot dry van
represents all lengths of long dry vans in this analysis and for
compliance. Similar lengths represent the short and long refrigerated
van subcategories. This means that manufacturers do not need to analyze
the performance of devices for each trailer length in each subcategory.
This approach provides a conservative estimate of CO2
emissions and fuel consumption reductions for the longer vans within a
given length subcategory,\350\ but the agencies believe that the need
to avoid an overly complex compliance program, reinforced by most of
the industry comments, justifies this approach.
---------------------------------------------------------------------------
\350\ For example, aerodynamic devices on a 48 foot box van will
perform somewhat better than on a 28 foot box van, so our analysis
likely underestimates the benefits of these technologies. See
Chapter 2.10.2.1.2.6 of the RIA and Memorandum to Docket EPA-HQ-OAR-
2014-0827. ''
---------------------------------------------------------------------------
(a) Aerodynamic Technologies
For box vans under these rules, aerodynamic performance of tractor-
trailers is evaluated using a vehicle's aerodynamic drag area,
CdA. However, unlike the tractor program, the performance of
trailer technologies is quantified using changes in CdA (or
``delta CdA'') rather than absolute values. This delta
CdA classification methodology, which measures improvement
in performance relative to a baseline, is similar to the SmartWay
technology verification program with which most long box van
manufacturers are already familiar. The one difference is that,
although EPA's SmartWay aerodynamic verification program uses a
relative improvement, the metric is a percent fuel savings, whereas the
compliance program for Phase 2 uses change in drag area, delta
CdA. Chapter 2.10.2.1.1 of the RIA provides a comparison of
the SmartWay and Phase 2 metrics.
The agencies proposed to use a delta CdA measured at
zero-yaw (head-on wind) in the trailer aerodynamic test procedures (80
FR 40277). However, comments from several stakeholders including ACEEE,
CARB, ICCT, RMA, STEMCO, and Utility suggested that measurements that
account for cross-wind provide a more appropriate measure of the
benefits these technologies would experience in the real world,
especially for technologies that are effective when the wind is at an
angle. The agencies evaluated our own aerodynamic test data, including
data collected to justify use of wind-average results in the proposed
tractor program, and we recognize that the drag coefficient increases
under cross-wind conditions likely seen in real-world operation. Since
wind-averaging will account for this, and more appropriately capture
aerodynamic benefits from many devices, including several small-scale
devices, we are adopting a wind-averaged approach for aerodynamic
testing in the trailer program. See Section IV.E.(3)(b)(ii) below and
Chapter 2.10.2.1.2 of the RIA for a summary of yaw-angle effect as
observed in our aerodynamic testing. The feasibility analysis that
follows was performed using wind-averaged delta CdA values.
(i) Aerodynamic Technologies for Non-Box Trailers
The agencies are aware that some side skirts have been adapted for
the non-box trailers considered in this rule (e.g., tank trailers,
flatbeds, and container chassis). CARB submitted comments noting that
some of these technologies have shown potential for large reductions in
drag. At this time, however, we are unable to sufficiently assess the
degree of CO2 and fuel consumption improvement that could
generally be achieved across this segment of the industry and the
associated costs of these technologies. In the case of each of the
general non-box trailer types included in the trailer program, the
range of physical trailer designs, including the areas where
aerodynamic devices would be installed, is great, and technologies to
date tend to be designed for narrow applications. This lack of basic
information about the applicability of future technologies for these
trailer types also inhibits our ability to estimate costs, either of
the specific future designs themselves or of the size of the market for
any particular product. As a result, we expect that standards
predicated on aerodynamic technologies for these trailer types could
result in relatively little emission and fuel consumption improvement
at relatively high costs. We will continue to monitor this segment of
the trailer industry in this regard and may consider further action in
the future.
The agencies proposed to adopt design-based tire standards (i.e.
[[Page 73651]]
standards not predicated on any aerodynamic technology, and for which
neither GEM nor the GEM-based equation is required) for these trailers
to eliminate the need for performance testing and to reduce the overall
compliance burden for these manufacturers. 80 FR 40257. The data
submitted and adoption rates suggested by CARB would not provide a
large enough reduction in CO2 and fuel consumption from non-
box trailer aerodynamics to justify the increased burden on these
manufacturers. In addition, we believe that there is not currently
sufficient information to develop aerodynamic performance standards on
these relatively new and untried technologies. Consequently, we are
adopting design-based tire technology standards for non-box trailers,
as proposed. Non-box trailer manufacturers may include aerodynamic
improvements in their future trailer designs, but non-box trailer
aerodynamic devices cannot be used for compliance at any point in the
Phase 2 program.
(ii) Aerodynamic Technologies for Box Vans
EPA collected aerodynamic test data for several tractor-trailer
configurations equipped with technologies similar to common SmartWay-
verified technologies. As mentioned previously, SmartWay-verified
technologies are evaluated on 53-foot dry vans. However, the
CO2- and fuel consumption-reducing potential of some
aerodynamic technologies demonstrated on 53-foot dry vans can be
translated to refrigerated vans and box trailers of other lengths. Some
fleets have opted to add trailer skirts to their refrigerated vans and
28-foot trailers and our testing included dry vans of length 53-foot,
48-foot, 33-foot, and 28-foot.\351\
---------------------------------------------------------------------------
\351\ Although, as noted above, compliance testing (where
required) uses either a 28 foot van or 53 foot van to simplify the
compliance process.
---------------------------------------------------------------------------
In order to evaluate performance and cost of the aerodynamic
technologies, the agencies identified ``packages'' of individual or
combined technologies that are being sold today on box trailers. The
agencies also identified distinct performance levels (i.e., bins) for
these technology packages based on EPA's aerodynamic testing. All
technology packages that produce similar improvements in drag would be
categorized as meeting the same bin level of performance. The agencies
recognize that there are other technology options that have similar
performance to those that we analyzed. We chose the technologies
presented here based on their current adoption rates and availability
of test data.
The agencies are adopting a regulatory structure for box trailers
with seven bins to evaluate aerodynamic performance. Note that these
bins are slightly different than those proposed. We adjusted the
aerodynamic bins to reflect additional data and the use of wind-
averaged results. The most notable difference is that we expanded the
width of the lower bins. The NPRM Bins III, IV and V were reduced to
two bins. Bins V, VI, and VII are identical to the highest bins from
the NPRM (NPRM bins VI, VII, and VIII). See Chapter 2.10.2.1.3 of the
RIA for a complete description of the development of these bins.
In the final trailer program, Bin I represents a base trailer with
no aerodynamic technologies added and a delta CdA of zero.
Bin II is intended to capture aerodynamic devices that achieve small
reductions in CO2 and fuel consumption. Some gap reducers
may achieve Bin II on long dry vans, and most individual devices (e.g.,
skirts or tails) will achieve this bin for short box vans. We expect a
majority of single aerodynamic devices to perform in the range of Bins
III through IV for long box vans. Combinations of devices are expected
to meet Bin III for short vans and Bin V or Bin VI levels of
performance for long vans. Bin VI represents the more optimized
combinations of technologies on long vans. The agencies observed one
device combination that met Bin VI in our aerodynamic testing and did
not observe any combinations that meet Bin VII. This final level is
designed to represent aerodynamic improvements that may become
available in the future, including aerodynamic devices yet to be
designed or approaches that incorporate changes to the design of
trailer bodies. The agencies believe there is ample lead time to
optimize additional existing Bin V combinations such that they can also
meet Bin VI by MY 2027. However, none of the standards are predicated
on the performance of Bin VII aerodynamic improvements. See Table IV-14
and accompanying text.
Table IV-5 illustrates the bin structure that the agencies are
adopting as the basis for box vans to demonstrate compliance. The
agencies believe these bins apply to all box vans (dry and refrigerated
vans of various lengths). Although the underlying test data from EPA's
aerodynamic testing program reflect some variation due to differences
in test methods, as well as differences in trailer and aerodynamic
device models, the agencies believe that each of these bins covers a
wide enough range of delta CdAs to account for the
uncertainty. See RIA Chapter 2.10 for more information.
When manufacturers obtain test results, they would check the range
shown in Table IV-5 for the measured CdA value and use the
corresponding input value for compliance. Note that these are wind-
averaged results, as described in Chapter 2.10 of the RIA and below in
Section IV.E.(3)(b)(ii). Also, the input is a threshold and not an
average of the bin range. Consequently, the compliance results will be
a conservative estimate of the performance of most technologies that
achieve a given bin.\352\
---------------------------------------------------------------------------
\352\ This is in contrast to the tractor program where
manufacturers obtain absolute CdA values in tractor
aerodynamic testing. The tractor results are corrected to coastdown
values before applying them to bins and obtaining a bin-average
value as a compliance input. Trailers measure a delta CdA
and do not have a correction to a reference method (see Section
IV.E.(3)(b)). The lower threshold approach adopted for the trailer
compliance inputs limits the chance of over-predicting performance
when a reference method correction is not applied.
Table IV-5--Technology Bins Used To Evaluate Trailer Benefits and Costs
------------------------------------------------------------------------
Delta CdA
---------------------------------------
Bin Input value
Measured value for compliance
------------------------------------------------------------------------
Bin I........................... <0.10................. 0.0
Bin II.......................... 0.10-0.39............. 0.1
Bin III......................... 0.40-0.69............. 0.4
Bin IV.......................... 0.70-0.99............. 0.7
Bin V........................... 1.00-1.39............. 1.0
Bin VI.......................... 1.4-1.79.............. 1.4
Bin VII......................... >=1.80................ 1.8
------------------------------------------------------------------------
To develop the standards for box trailers, the agencies assessed
the CO2 emissions and fuel consumption impacts of the
aerodynamic bins using an equation based on the GEM vehicle simulation
tool. See Section II and Section IV.E. (1) for more information about
GEM and Chapter 2.10.5 of the RIA for our development of the GEM-based
equation. Within GEM, and reflected in the results of the equation, the
aerodynamic performance of each box van subcategory is evaluated by
subtracting the delta CdA shown in Table IV-5 from the
CdA value representing a specific standard tractor pulling a
trailer with no CO2- or fuel consumption-reducing
technologies (i.e., a ``no-control'' trailer). In other words, the
tractor-trailer is simulated with improvements to the baseline trailer.
The agencies chose to model the no-control long box dry van using a
CdA value of 6.0 m\2\ (the mean wind-averaged CdA
from EPA's wind tunnel
[[Page 73652]]
testing). The single, short box dry vans showed lower CdA
values compared to its 53-foot counterpart in EPA's wind tunnel testing
with an average of 5.6 m\2\. The agencies did not test any refrigerated
vans, but we assumed a refrigerated van's TRU would behave similar to a
gap reducer. Our test results in Chapter 2.10.2.1.3 did not show gap
reducer technologies to have a significant effect on CdA and
the agencies accordingly assigned the same default CdA to
refrigerated and dry box vans in GEM. Note that the trailer
subcategories that have design standards (i.e., non-box and non-aero
box trailers) do not have numerical standards to meet, and do not have
defaults in GEM. Table IV-6 illustrates the no-control drag areas
(CdA) associated with each trailer subcategory.
Table IV-6--Default Aerodynamic Drag Area (CdA) Values Associated With
Each (No-Control) Trailer Modeled in GEM
------------------------------------------------------------------------
Trailer subcategory CdA (M\2\)
------------------------------------------------------------------------
Long Dry Van............................................ 6.0
Short Dry Van........................................... 5.6
Long Ref. Van........................................... 6.0
Short Ref. Van.......................................... 5.6
------------------------------------------------------------------------
Current ``boat tail'' devices, applied to the rear of a trailer
with rear swing doors, are typically designed to collapse flat as the
trailer rear doors are opened. If the tail structure can remain in the
collapsed configuration when the doors are closed, the benefit of the
device is lost. We requested comment on whether we should require that
trailer manufacturers using such devices for compliance with these
standards only use designs that automatically deploy when the vehicle
is in motion. STEMCO commented that automatic deployment should not be
required, since those systems are more expensive, and in their view,
not necessary for the Phase 2 program. STEMCO believes that, since
there is a strong economic incentive for operators to ensure that the
devices are correctly deployed in order to achieve the greatest fuel
cost payback, a regulatory requirement related to deployment is not
needed. We generally agree, and have not included such a requirement in
the final trailer program. For this analysis, we consider all boat
tails to be properly deployed.
The agencies are aware that physical characteristics of some box
trailers influence the technologies that can be applied. For instance,
the TRUs on refrigerated vans are located at the front of the trailer,
which prevents the use of current gap-reducers, either by occupying the
space that a front-end fairing would use, or by blocking air flow that
the TRU needs for cooling purposes. Similarly, drop deck dry vans have
lowered floors between the landing gear and the trailer axles that
limit the ability to use side skirts. We discuss another example, roll-
up rear doors, in Section IV.C.(1)(a) above. The agencies considered
the availability and limitations of aerodynamic technologies for each
trailer type evaluated in our feasibility analysis of the standards.
(b) Tire Rolling Resistance
Similar to the Phase 2 tractor and vocational vehicle programs, the
agencies are adopting standards based on adoption of lower rolling
resistance tires. While some box vans continue to be sold with tires of
higher rolling resistances, the agencies believe most box van tires
currently achieve a tire CRR of 6.0 kg/ton or better.
Feedback from several box trailer manufacturers indicates that the
standard tires offered on their new trailers are SmartWay-verified
tires (i.e., CRR of 5.1 kg/ton or better). An informal
survey of members from the Truck Trailer Manufacturers Association
(TTMA) in 2014 indicates about 85 percent of box vans sold at that time
had SmartWay tires.\353\
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\353\ Letter, Truck Trailer Manufacturers Association to EPA.
Received on October 16, 2014. Docket EPA-HQ-OAR-2014-0827-0146.
---------------------------------------------------------------------------
The agencies evaluated two levels of tire performance for box vans
beyond the baseline trailer tire rolling resistance level (TRRL) of 6.0
kg/ton. The first performance level was set at the criteria for
SmartWay-verification for trailer tires, 5.1 kg/ton, which is a 15
percent reduction in CRR from the baseline. As mentioned
previously, several tire models available today achieve rolling
resistance values well below the present SmartWay threshold. Given the
multiple year phase-in of the standards, the agencies expect that tire
manufacturers will continue to respond to demand for more efficient
tires and will offer increasing numbers of tire models with rolling
resistance values significantly better than today's typical LRR tires.
In this context, we believe it is reasonable to expect a large fraction
of the trailer industry could adopt tires with rolling resistances at a
second performance level that will achieve an additional reduction in
rolling resistance, especially in the later stages of the program. The
agencies project the CRR for this second level of
performance to be a value of 4.7 kg/ton (a 22 percent reduction from
the baseline tire).
The vast majority of box van miles occur on-road, and current LRR
tire designs are appropriate and effective for those applications. We
note that current designs of LRR tires may not be appropriate for some
non-box trailer types, including those that operate significantly in
off-road conditions. We expect that the tire manufacturing industry
will continue to expand their offerings of tire designs to additional
applications. Regardless, by limiting the non-box trailer types covered
by the final trailer program to those generally used in on-highway
applications (tanks, flatbeds, and container chassis), the program
avoids most of these potential situations.
We received comment from Michelin supporting the use of 6.0 kg/ton
as the box trailer tire rolling resistance baseline, but they expressed
concern that the SmartWay threshold of 5.1 kg/ton does not apply for
non-box trailers, and could compromise their operation. Similarly, the
Rubber Manufacturers Association indicated that a baseline of 6.0 kg/
ton does not apply to non-box trailers. The agencies agree that the
baseline tires for non-box trailers should have a higher rolling
resistance, but we did not receive any comments that included
CRR data. For the analysis for the final rules, the agencies
revised the baseline CRR to a value of 6.5 kg/ton for non-
box trailer manufacturers. The updated non-box trailer designs
standards require LRR tires of 6.0 kg/ton in the first stage of the
program and 5.1 kg/ton in the later years. Nowhere in the final program
do we require Level 4 tires for non-box trailers.
The agencies evaluated four tire rolling resistance levels,
summarized in Table IV-7, in the feasibility analysis of the following
sections. It should be noted that these levels are targets for setting
the stringency of the box van performance standards and rolling
resistance thresholds for the non-box design standards. For compliance,
box van manufacturers have the option to use tires with any rolling
resistance and are not be limited to these TRRLs.
Table IV-7--Summary of Trailer Tire Rolling Resistance Levels Evaluated
------------------------------------------------------------------------
CRR (kg/ton)
Tire rolling resistance level
------------------------------------------------------------------------
Level 1 (Non-Box Baseline).............................. 6.5
Level 2 (Box Van Baseline )............................. 6.0
Level 3................................................. 5.1
Level 4................................................. 4.7
------------------------------------------------------------------------
(c) Tire Pressure Systems
Tire pressure monitoring systems (TPMS) and automatic tire
inflation systems (ATIS) are designed to address under-inflated tires.
Both systems alert
[[Page 73653]]
drivers if a tire's pressure drops below its set point. TPMS are
simpler and merely monitor tire pressure. Thus, they require user-
interaction to reinflate to the appropriate pressure. Today's ATIS, on
the other hand, typically take advantage of trailers' air brake systems
to supply air back into the tires (continuously or on demand) until a
selected pressure is achieved. In the event of a slow leak, ATIS have
the added benefit of maintaining enough pressure to allow the driver to
get to a safe stopping area. See Chapter 2.10.2.3 of the RIA for more
on tire pressure systems.
The agencies proposed that ATIS be the only tire pressure system
allowed to be used to meet the standards, since TPMS require action on
the part of the operator. Our position at the time of the proposal was
that TPMS could not sufficiently guarantee proper inflation. 80 FR
40262. However, some commenters stated that TPMS are effective in
encouraging proper tire pressure maintenance, and should also be
eligible as a compliance option. Commenters did not provide specific
data about the overall effectiveness of TPMS. However, we are aware of
the emergence of TPMS that use telematics to automatically report tire
pressure data to a central contact. It is also our understanding that
there is a growing recognition among fleet and individual operators of
the potential value that these systems can provide to operators, so
long as the operator and/or a central fleet contact take action to
address cases of low tire pressures indicated by the systems. These
factors have led the agencies to reconsider our approach to TPMS. As
described in Section IV.B. above, we now believe that TPMS provides
overall fuel consumption and CO2 reductions, and the final
program recognizes the option of TPMS as part of the compliance path
for all covered trailers.
NHTSA and EPA recognize the role of proper tire inflation in
maintaining optimum tire rolling resistance during normal trailer
operation. Rather than require performance testing of tire pressure
systems, the agencies recognize the benefits of these systems, and the
program applies default reduction values for manufacturers that
incorporate ATIS or TPMS into their trailer designs. Based on
information available today, we believe that most tire pressure
technologies and systems in typical use perform similarly.
We proposed to assign a 1.5 percent reduction in CO2 and
fuel consumption for all trailers that implement ATIS, based on
information available at that time.\354\ We did not receive any
comments directly addressing the proposed reduction value. However, the
agencies believed it was appropriate to align the effectiveness of tire
pressure systems for tractors, trailers and vocational vehicles, and
the agencies are adopting a 1.2 percent reduction for ATIS for each of
these vehicle categories. As just noted, we are also adopting
provisions that recognize a CO2 and fuel consumption
reduction for TPMS. The agencies believe that sufficient incentive
exists for truck operators to address low tire pressure conditions if
they are notified that they exist through a TPMS (for example, for
reasons of personal safety as well as fuel savings). However, we
recognize the dependence on operator action for TPMS, and we are
adopting a reduction of 1.0 percent for these systems. We have
concluded that the use of these systems can consistently ensure that
tire pressure and tire rolling resistance are maintained. Sections
III.D.(1)(b) and V.C.(1)(a) also discuss the overall Phase 2 program's
treatment of both types of tire pressure systems for tractors and
vocational vehicles, respectively.
---------------------------------------------------------------------------
\354\ See Chapter 2.10.2.3 of the RIA.
---------------------------------------------------------------------------
We selected the standards for most box vans with the expectation
that a high rate of adoption of ATIS will occur during all years of the
phase-in of the program, and that manufacturers of non-aero vans, and
non-box trailers will install either TPMS or ATIS, as well as LRR
tires, to comply with the design-based tire standards.
In the performance-based compliance approach to full- and partial-
aero box vans, the program incorporates a small discount in the value
of TPMS in the compliance equation as compared to ATIS, to reflect the
inherent user interaction required for TPMS to be effective. In the
design-based compliance approach for non-aero vans and non-box
trailers, manufacturers may comply by using either TPMS or ATIS, which
in that case are valued equally. See Section IV.D.(2)(d) below for
discussion of our estimates of the degree of adoption of tire pressure
systems prior to and at various points in the phase-in of the proposed
program.
(d) Weight Reduction
As proposed, the trailer program provides manufacturers the option
of complying through the substitution of specified lighter-weight
components that can be clearly isolated from the trailer as a whole. In
the proposal, the agencies identified several conventional components
with lighter-weight substitutes that are currently available (e.g.,
substituting conventional dual tires mounted on steel wheels with wide-
based single tires mounted on aluminum wheels). 80 FR 40262. Several
commenters provided additional component suggestions, with information
about their typical associated weight reductions. The component
substitutions we have included in the final program, and the weight
savings that we are associating with each component, are presented in
the RIA Chapter 2.10.2.4 and 40 CFR 1037.515. The agencies have
identified 12 common trailer components for which lighter weight
options are currently available (see 40 CFR
1037.515).355 356 357 358 Manufacturers that adopt these
technologies and choose to use them as part of their compliance
strategy sum the associated weight reductions and apply those values in
the GEM-based compliance equation (see Section IV.E.(2)(a)). We believe
that the initial cost of these component substitutions is currently
substantial enough that only a relatively small segment of the industry
has adopted these technologies today.
---------------------------------------------------------------------------
\355\ Scarcelli, Jamie. ``Fuel Efficiency for Trailers''
Presented at ACEEE/ICCT Workshop: Emerging Technologies for Heavy-
Duty Vehicle Fuel Efficiency, Wabash National Corporation. July 22,
2014.
\356\ ``Weight Reduction: A Glance at Clean Freight
Strategies,'' EPA SmartWay. EPA420F09-043. Available at: http://permanent.access.gpo.gov/gpo38937/EPA420F09-043.pdf.
\357\ Memorandum dated June 2015 regarding confidential weight
reduction information obtained during SBREFA Panel. Docket EPA-HQ-
OAR-2014-0827.
\358\ Randall Scheps, Aluminum Association, ``The Aluminum
Advantage: Exploring Commercial Vehicles Applications,'' presented
in Ann Arbor, Michigan, June 18, 2009.
---------------------------------------------------------------------------
There is no clear ``baseline'' for current trailer weight against
which lower-weight designs could be compared for regulatory purposes.
For this reason, the agencies do not believe it is appropriate or fair
across the industry to apply overall weight reductions toward
compliance using a universal baseline trailer. However, the agencies do
believe it is appropriate to give a manufacturer credit for overall
weight reduction achieved in their own product line. In the final
program, we are clarifying that manufacturers of box trailers with
significant weight reductions have the option of using our off-cycle
credit process to compare overall weight reduction of future trailers
using an appropriate baseline from their own production. This process
allows manufacturers to do a comparison of their new trailer to a
previous model to quantify the weight reduction improvements.
Manufacturers wishing to go this route should contact
[[Page 73654]]
EPA in advance to discuss appropriate test procedures. More information
about the off-cycle process can be found in Section IV.E.(5)(d) and in
40 CFR 1037.610 or 49 CFR 535.7. Note that non-box trailers and non-
aero box vans have design standards that are limited to adoption of
lower rolling resistance tires and tire pressure systems, and do not
include weight reduction as part of their simplified compliance
demonstration.
The agencies recognize that when weight reduction is applied to a
trailer, some operators will replace that saved weight with additional
payload. To account for this in the average vehicle represented by
EPA's GEM vehicle simulation tool, it is assumed that one-third of any
weight reduction will be applied to the payload. Wabash suggested that
the agencies reconsider the distribution of weight between payload and
trailer weight when modeling weight reduction, expressing concern that
the reduction was not receiving appropriate credit in the program.
Although the simulated vehicle in GEM only receives \2/3\ of the weight
reduction applied, the model calculates CO2 emissions and
fuel consumption on a per-ton-mile basis by dividing by the payload,
which now includes the extra one-third from weight reduction. Dividing
by a larger payload results in lower CO2 and fuel
consumption values.\359\
---------------------------------------------------------------------------
\359\ Memorandum to Docket EPA-HQ-OAR-2014-0827, ``Evaluation of
Weight Reduction Distribution in Response to Public Comments from
Wabash National Corporation,'' June 18, 2016.
---------------------------------------------------------------------------
For 53-foot vans simulated in GEM (and thus, for the GEM-based
equation), it takes a weight reduction of nearly 1,000 pounds before a
one percent fuel savings is achieved. The impact of the same 1000
pounds is slightly greater for shorter vans, due to their lower overall
weight, but the effectiveness of weight reduction is still relatively
low compared to the effectiveness of many aerodynamic technologies. In
addition, large material substitutions can be costly. The agencies thus
believe that few trailer manufacturers will apply weight reduction
solely as a means of achieving reduced fuel consumption and
CO2 emissions. Therefore, we are adopting standards that
could be met without reducing weight--that is, the feasible compliance
path set out by the agencies for this program does not assume weight
reduction as a compliance avenue. However, as discussed here, the final
program includes the option for box trailer manufacturers to apply
weight reduction to some of their trailers as part of their compliance
strategy.
(2) Effectiveness, Adoption Rates, and Costs of Technologies for the
Trailer Standards
The agencies evaluated the technologies above as they apply to each
of the trailer subcategories. The next sections describe the
effectiveness, adoption rates and costs associated with these
technologies. The effectiveness and adoption rate projections were used
to derive these standards.
(a) No-Control Default Tractor-Trailer Vehicles in GEM (Box Van
Standards Only)
The regulatory purpose of EPA's heavy-duty vehicle compliance tool,
GEM, is to combine the effects of trailer technologies through
simulation so that they can be expressed as g/ton-mile and gal/1000
ton-mile and thus avoid the need for direct testing of each trailer
being certified. All of the standards for box vans (with the exception
of non-aero box vans, which have design standards) use an equation
derived from GEM to demonstrate compliance. The trailer program has
separate performance standards for each box van subcategory (again,
with the exception of non-aero box vans) and each of these
subcategories is modeled as a tractor-trailer combination that we
believe reflects the average physical characteristics and use pattern
of vans in that subcategory. Long vans are pulled by sleeper cab
tractors and use the long-haul drive cycle weightings. Short vans are
pulled by day cabs and have the short-haul drive cycle weightings.
Short vans also have a lighter payload and overall vehicle weight
compared to their longer counterparts.
Table IV-8 highlights the relevant vehicle characteristics for the
no-control default of each subcategory (i.e., zero CO2- or
fuel consumption reducing technologies installed). Baseline trailer
tires are used, and the drag area, which is a function of the
aerodynamic characteristics of both the tractor and trailer, is set to
the values shown previously in Table IV-6. Weight reduction and tire
pressure systems are not applied in these default vehicles. Chapter
2.10 of the RIA provides a detailed description of the development of
these default tractor-trailers. Note that the agencies proposed to use
Class 8 tractors for all default tractor-trailer vehicles. However, we
are adopting the final standards based on 4x2 Class 7 tractors for
short box vans.
Table IV-8--Characteristics of the No-Control Default Tractor-Trailer Vehicles in GEM
----------------------------------------------------------------------------------------------------------------
Dry van Refrigerated van
----------------------------------------------------------------------------------------------------------------
Trailer length Long Short Long Short
----------------------------------------------------------------------------------------------------------------
Standard Tractor:
Class....................... Class 8........... Class 7........... Class 8........... Class 7.
Cab Type.................... Sleeper........... Day............... Sleeper........... Day.
Roof Height................. High.............. High.............. High.............. High.
Axle Configuration.......... 6 x 4............. 4 x 2............. 6 x 4............. 4 x 2.
Engine...................... 2018 MY 15L, 455 2018 MY 11L, 350 2018 MY 15L, 455 2018 MY 11L, 350
HP. HP. HP. HP.
Steer Tire RR (kg/ton)...... 6.54.............. 6.54.............. 6.54.............. 6.54.
Drive Tire RR (kg/ton)...... 6.92.............. 6.92.............. 6.92.............. 6.92.
Drag Area, CdA (m\2\)....... 6.0............... 5.6............... 6.0............... 5.6.
Number of Trailer Axles..... 2................. 1................. 2................. 1.
Trailer Tire RR (kg/ton).... 6.00.............. 6.00.............. 6.00.............. 6.00.
Total Weight (kg)........... 31978............. 18306............. 33778............. 20106.
Payload (tons).............. 19................ 10................ 19................ 10.
Tire Pressure System Use.... 0................. 0................. 0................. 0.
Weight Reduction (lb)....... 0................. 0................. 0................. 0.
Drive Cycle Weightings:
65-MPH Cruise............... 86%............... 64%............... 86%............... 64%.
55-MPH Cruise............... 9%................ 17%............... 9%................ 17%.
[[Page 73655]]
Transient Driving........... 5%................ 19%............... 5%................ 19%.
----------------------------------------------------------------------------------------------------------------
(b) Effectiveness of Technologies
As already noted, the agencies recognize trailer improvements via
four performance parameters: Aerodynamic drag reduction, tire rolling
resistance reduction, the adoption of tire pressure systems, and
weight-reducing strategies. Table IV-9 summarizes the performance
levels the agencies evaluated for each of these parameters based on the
technology characteristics outlined in Section IV.D.(1).
Table IV-9--Performance Parameters for the Trailer Program
------------------------------------------------------------------------
------------------------------------------------------------------------
Aerodynamics (Delta CdA, m\2\):
Bin I.............................. 0.0.
Bin II............................. 0.1.
Bin III............................ 0.4.
Bin IV............................. 0.7.
Bin V.............................. 1.0.
Bin VI............................. 1.4.
Bin VII............................ 1.8.
Tire Rolling Resistance (CRR, kg/ton):
Tire Level 1....................... 6.5.
Tire Level 2....................... 6.0.
Tire Level 3....................... 5.1.
Tire Level 4....................... 4.7.
Tire Inflation System (% reduction):
ATIS............................... 1.2.
TPMS............................... 1.0.
Weight Reduction (lb):
Weight............................. 1/3 added to payload, remaining
reduces overall vehicle
weight.
------------------------------------------------------------------------
These performance parameters have different effects on each trailer
subcategory due to differences in the simulated trailer
characteristics. Table IV-10 shows the agencies' estimates of the
effectiveness of each parameter for the four box van types. Each
technology was evaluated using the baseline parameter values for the
other technology categories. For example, each aerodynamic bin was
evaluated using the baseline tire (6.0 kg/ton) and the baseline weight
reduction option (zero pounds). The table shows that aerodynamic
improvements offer the largest potential for CO2 emissions
and fuel consumption reductions, making them relatively effective
technologies.
Table IV-10--Effectiveness (Percent CO[ihel2] Emissions and Fuel Consumption) of Technologies for Box Vans in the Trailer Program
--------------------------------------------------------------------------------------------------------------------------------------------------------
Dry van Refrigerated van
Aerodynamics Delta CdA (m\2\) ---------------------------------------------------------------
Long (%) Short (%) Long (%) Short (%)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Bin I..................................................... 0.0 0 0 0 0
Bin II.................................................... 0.1 1 1 1 1
Bin III................................................... 0.4 3 3 3 3
Bin IV.................................................... 0.7 5 5 5 5
Bin V..................................................... 1.0 7 7 7 7
Bin VI.................................................... 1.4 9 10 9 10
Bin VII................................................... 1.8 12 13 12 13
--------------------------------------------------------------------------------------------------------------------------------------------------------
Tire Rolling Resistance CRR (kg/ton) Dry van
Refrigerated van
---------------------------------------------------------------
Long Short Long Short
--------------------------------------------------------------------------------------------------------------------------------------------------------
Level 1................................................... 6.5 .............. .............. .............. ..............
Level 2................................................... 6.0 0 0 0 0
Level 3................................................... 5.1 -2 -1 -2 -1
Level 4................................................... 4.7 -3 -2 -3 -2
--------------------------------------------------------------------------------------------------------------------------------------------------------
Weight Reduction Weight (lb) Dry van
Refrigerated van
---------------------------------------------------------------
Long Short Long Short
--------------------------------------------------------------------------------------------------------------------------------------------------------
Baseline.................................................. 0 0 0 0 0
[[Page 73656]]
Option 1.................................................. 100 0 0 0 0
Option 2.................................................. 500 1 1 1 1
Option 3.................................................. 1000 1 2 1 2
Option 4.................................................. 2000 2 4 2 4
--------------------------------------------------------------------------------------------------------------------------------------------------------
(c) Baseline Tractor-Trailer To Evaluate Benefits and Costs
In order to evaluate the benefits and costs of the final standards
for each of the ten subcategories, it is necessary to establish a
reference point for comparison. As mentioned previously, the
technologies described in Section IV.D.(1) exist in the market today,
and their adoption is driven by available fuel savings as well as by
the voluntary SmartWay Partnership and California's tractor-trailer
requirements. For these rules, the agencies identified baseline
tractor-trailers for each trailer subcategory based on the technology
adoption rates we project would exist in MY 2018 if this trailer
program was not implemented.
CARB's comments noted the informal survey of TTMA members provided
in letter from TTMA to EPA in 2014 regarding current adoption rates of
several technologies. CARB suggested that our proposed baseline
adoption rates did not reflect the data in that letter.\360\ We have
reassessed available data and we believe that higher baseline rates are
more appropriate, and have made corresponding changes in our analysis.
First, we created a separate baseline for box vans that qualify as
full-aero, box vans that qualify as partial-aero, and box vans that
qualify as non-aero. Because of the challenges of installing effective
aerodynamic devices, market forces are not likely to significantly
drive adoption of CO2- and fuel-consumption reducing
technologies for trailers with work performing equipment (e.g., lift
gates), and we are projecting zero adoption of the technologies in the
baselines for partial- and non-aero box vans before the start of this
program. Similarly, we assume that there will be zero adoption of these
technologies for non-box trailers in the baseline. We updated the
baseline tire rolling resistance level for non-box trailers to reflect
the lower 6.5 kg/ton value in response to RMA's comment that these
trailers have different operational characteristics and should not have
the same baseline tires as box vans (see Section IV.D.(1)(b) above).
---------------------------------------------------------------------------
\360\ Letter, Truck Trailer Manufacturers Association to EPA.
Received on October 16, 2014. Docket EPA-HQ-OAR-2014-0827-0146.
---------------------------------------------------------------------------
TTMA's survey indicated that 35 percent of long vans and less than
2 percent of vans under 53-foot in length include aerodynamic devices,
and over 80 percent have adopted lower rolling resistance tires. The
agencies believe the trailers for which manufacturers have adopted
these technologies are likely to be trailers that would qualify as
``full-aero'' vans, and we adjusted our baselines to reflect these
values. Our baseline assumes that aerodynamics would increase to 40
percent adoption for full-aero long vans (dry and refrigerated) and 5
percent for full-aero short vans by 2018 without the Phase 2 standards.
We also assume adoption of lower rolling resistance tires (Level 1)
will increase to 90 percent and ATIS to 45 percent in the baseline. We
held these adoption rates constant throughout the timeframe of the
rules. Table IV-11 summarizes the updated baseline trailers for each
trailer subcategory.
Table IV-11--Estimated Adoption Rates and Average Performance Parameters for the Flat Baseline Trailers for MY
2018 and Later
----------------------------------------------------------------------------------------------------------------
All partial-aero, All non-box
Technology Long vans Short vans non-aero vans trailers
----------------------------------------------------------------------------------------------------------------
Aerodynamics:
Bin I....................... 55% 95% 100% 100%
Bin II...................... .................. 5%
Bin III..................... 40%
Bin IV...................... 5%
Bin V.......................
Bin VI......................
Bin VII.....................
Average Delta CdA (m2) 0.2 0.0 0.0 0.0
\a\....................
Tire Rolling Resistance:
Level 1..................... .................. .................. .................. 100%
Level 2..................... 10% 10% 100%
Level 3..................... 90% 90%
Level 4.....................
Average CRR (kg/ton) \a\ 5.2 5.2 6.0 6.5
Tire Pressure Systems:
ATIS........................ 45% 30%
TPMS........................
Average Pressure System 0.5% 0.3% 0.0% 0.0%
Reduction (%) \a\......
Weight Reduction:
[[Page 73657]]
Weight (lb) \b\.........
----------------------------------------------------------------------------------------------------------------
Notes:
A blank cell indicates a zero value.
\a\ Combines adoption rates with performance levels shown in Table IV-9.
\b\ Weight reduction was not projected for the baseline trailers.
Also shown in Table IV-11 are average aerodynamic performance
(delta CdA), average tire rolling resistance
(CRR), and average reductions due to use of tire pressure
systems and weight reduction for each reference trailer. These values
indicate the performance of theoretical average tractor-trailers that
the agencies project would be in use in 2018 if no federal regulations
were in place for trailer CO2 and fuel consumption. The
average tractor-trailer vehicles serve as baselines for each trailer
subcategory.
Because the agencies cannot be certain about future trends, we also
considered a second baseline. This dynamic baseline reflects the
possibility that, absent a Phase 2 regulation, there would be
continuing adoption of aerodynamic technologies in the long box trailer
market after 2018 that reduce fuel consumption and CO2
emissions. This case assumes the research funded and conducted by the
federal government, industry, academia and other organizations would,
after 2018, result in the adoption of additional aerodynamic
technologies beyond the levels required to comply with existing
regulatory and voluntary programs. One example of such research is the
Department of Energy SuperTruck program which has a goal of
demonstrating cost-effective measures to improve the efficiency of
Class 8 long-haul freight trucks by 50 percent by 2015.\361\ This
baseline assumes that by 2040, 75 percent of new full-aero long vans
would be equipped with SmartWay-verified aerodynamic devices. The
agencies project that the lower rolling resistance tires and ATIS
adoption would remain constant. Table IV-12 shows the agencies'
projected adoption rates of technologies in the dynamic baseline.
---------------------------------------------------------------------------
\361\ Daimler Truck North America. SuperTruck Program Vehicle
Project Review. June 19, 2014. Docket EPA-HQ-OAR-2014-0827.
Table IV-12--Projected Adoption Rates and Average Performance Parameters for the Dynamic Baseline for Long Dry
and Refrigerated Vans
[All other trailers are the same as Table IV-11]
----------------------------------------------------------------------------------------------------------------
Technology Long dry and refrigerated
----------------------------------------------------------------------------------------------------------------
Model year 2018 2021 2024 2027 2040
----------------------------------------------------------------------------------------------------------------
Aerodynamics:
Bin I....................... 55% 50% 45% 40% 20%
Bin II......................
Bin III..................... 40% 45% 50% 55% 75%
Bin IV...................... 5% 5% 5% 5% 5%
Bin V.......................
Bin VI......................
Bin VII.....................
Average Delta CdA (m\2\) 0.2 0.3 0.3 0.3 0.4
\a\....................
Tire Rolling Resistance:
Level 1.....................
Level 2..................... 10% 10% 10% 10% 10%
Level 3..................... 90% 90% 90% 90% 90%
Level 4.....................
Average CRR (kg/ton) \a\ 5.2 5.2 5.2 5.2 5.2
Tire Pressure Systems:
ATIS........................ 45% 45% 45% 45% 45%
TPMS........................
Average Pressure System 0.5% 0.5% 0.5% 0.5% 0.5%
Reduction (%) \a\......
Weight Reduction (lbs):
Weight \b\..............
----------------------------------------------------------------------------------------------------------------
Notes:
A blank cell indicates a zero value.
\a\ Combines adoption rates with performance levels shown in Table IV-9.
\b\ Weight reduction was not projected for the baseline trailers.
The agencies applied the vehicle attributes from Table IV-8 and the
average performance values from Table IV-11 in the Phase 2 GEM vehicle
simulation to calculate the CO2 emissions and fuel
consumption performance of the baseline tractor-trailers. The results
of these simulations are shown in Table IV-13. We used
[[Page 73658]]
these CO2 and fuel consumption values to calculate the
relative improvements that will occur over time with a regulatory
program. Note that the large difference between the per ton-mile values
for long and short trailers is due primarily to the large difference in
assumed payload (19 tons compared to 10 tons) and the small difference
between dry and refrigerated vans of the same length are due to
differences in vehicle weight because of the 1800 pounds added to the
simulated refrigerated vans to account for the TRU (see the vehicle
characteristics of the simulated tractor-trailers Table IV-8). The
alternative baseline shown in Table IV-12 mainly impacts the long-term
projections of benefits beyond 2027, which are analyzed in Chapters 5-7
of the RIA.
Table IV-13--CO[ihel2] Emissions and Fuel Consumption Results for the Baseline Tractor-Trailers
--------------------------------------------------------------------------------------------------------------------------------------------------------
Full-aero dry van Full-aero Partial-aero dry Partial-aero
--------------------------------------------------------------------------------------- refrigerated van van refrigerated van
-----------------------------------------------------------------
Length Long Short Long Short Long Short Long Short
--------------------------------------------------------------------------------------------------------------------------------------------------------
CO[ihel2] Emissions (g/ton-mile)................................ 83.2 126.5 84.9 130.3 86.1 128.5 87.9 132.4
Fuel Consumption (gal/1000 ton-miles)........................... 8.17289 12.42633 8.33988 12.79961 8.45776 12.62279 8.63458 13.00589
--------------------------------------------------------------------------------------------------------------------------------------------------------
(d) Projected Technology Adoption Rates for the Trailer Standards
The agencies developed their performance and design standards based
on projected adoption rates of certain technologies. This section
describes how these adoption rates were applied for each of the trailer
subcategories.
(i) Aerodynamic and Tire Technologies for Full- and Partial-Aero Box
Vans
As described in Section 0, the agencies evaluated several
alternatives for the trailer program. Based on our analysis and
comments received, the agencies are adopting standards consistent with
the agencies' respective statutory authorities. The agencies proposed
alternatives that were based on the use of averaging and the technology
adoption rates for those alternatives at proposal reflected the use of
averaging. As noted in Section IV.B., we received nearly unanimous,
persuasive comments from the trailer industry opposing averaging and
the agencies reconsidered the use of averaging in the early years of
the program. The agencies designed the trailer program to have no
averaging in MY 2018 through MY 2026. In those years, all box vans sold
must meet the standards using any combination of available
technologies. In MY 2027, when the trailer manufacturers are more
comfortable with compliance and the industry is more familiar with the
technologies, trailer manufacturers will have the option to use
averaging to meet the standards. See Section IV.E.(5)(b) below for
additional information about averaging.
Table IV-14 and Table IV-15 present sets of assumed adoption rates
for aerodynamic, tire, and tire pressure technologies that a
manufacturer could apply to meet the box van standards. Since averaging
would not be allowed for MY 2018-MY 2026, the adoption rates consist of
the combination of a single aerodynamic bin (not reflecting any
averaging of aerodynamic controls), tire rolling resistance level, and
tire pressure system. As mentioned previously, manufacturers can choose
other combinations to meet the standards. Chapter 2.10 of the RIA shows
several examples of alternative compliance pathways.
The adoption rates in Table IV-14 begin with all full-aero long box
vans achieving current SmartWay-level aerodynamics (Bin III) in MY 2018
with a stepwise progression to achieving Bin V in 2024. The adoption
rates for full-aero short box vans in Table IV-15 assume no adoption of
aerodynamic devices in MY 2018, adoption of single aero devices in MY
2021, and combinations of devices by MY 2024. Although the shorter
lengths of these trailers can restrict the design of aerodynamic
technologies that fully match the SmartWay-like performance levels of
long boxes, we nevertheless expect that trailer and device
manufacturers will continue to innovate skirt, under-body, rear, and
gap-reducing devices and combinations to achieve improved aerodynamic
performance on these shorter trailers.
The adoption rates in MY 2018-MY 2026 are projected to be 100
percent for each technology, instead of an industry average seen in
other vehicle sectors in the Phase 2 program. Since we are not
considering averaging during those years, each set of adoption rates is
one example of how an individual trailer in each subcategory could
comply. Through MY 2026, the standards are based on technologies that
exist today. We evaluated one technology in our aerodynamic test
programs that met Bin VI levels of performance for long vans,
suggesting that this bin can be met with combinations of existing
aerodynamic technologies, but none of our tested technologies that met
Bin IV levels of performance for short vans. We could not justify
standards based on 100 percent adoption of those levels of performance
as a final step in our progression of stringency. However, the industry
has made great progress toward improving trailer aerodynamics in recent
years and are continuing to optimize these technologies. Although we
are not projecting fundamentally new technologies for trailers, we do
believe aerodynamic performance will evolve in the trailer industry as
a result of this rulemaking. Based on the recent rate of improvement,
the agencies believe that there is ample lead time to optimize
additional existing Bin V and Bin III combinations such that they can
also meet Bins VI and IV by MY 2027 and it is reasonable to project
that more than half of these full-aero capable trailers will have
aerodynamic improvements greater than what is possible with today's
technologies. Our projected aerodynamic improvements in MYs 2027 and
later reflect this performance potential.
The MY 2027 full-aero box van standards are based on an averaging
program.\362\ We cannot predict what technologies or trailer designs
may be adapted to meet this level of aerodynamic performance, but an
averaging program incentivizes manufacturers to develop advanced
designs with the benefit that not all trailers in their production have
to meet the same level of performance. The gradual increase in assumed
adoption of aerodynamic technologies throughout the phase-in to the MY
2027 standards recognizes that even though many of the technologies are
available today and technologically feasible throughout the phase-in
period, adoption of more advanced technologies will likely take time.
The adoption rates we are
[[Page 73659]]
projecting in the interim years and the standards that we developed
from these rates represent steady and reasonable improvement in
aerodynamic performance.
---------------------------------------------------------------------------
\362\ No averaging is allowed for partial-aero box van reduced
standards, or the design-based standards for non-aero box vans and
non-box trailers.
---------------------------------------------------------------------------
We expect manufacturers of all box vans will adopt tires such as
SmartWay-verified trailer tires (Level 3) to meet the standards in MY
2018 and will adopt tires with even lower rolling resistance tires
(represented as Level 4) as they become available by MY 2021 and later
years and as fleet experience with these tires develops.
In establishing standard stringency, the agencies are also assuming
that all box vans will adopt ATIS throughout the program, though
manufacturers have the option to install TPMS if they would prefer to
make up the difference in effectiveness using other technologies. As
mentioned previously, the agencies did not include weight reduction in
their technology adoption projections, but certain types of weight
reduction could be used as part of a compliance pathway, as discussed
in Section IV.D.(1)(d) IV.D.(1)(d) above.
Table IV-14--Projected Adoption Rates and Average Performance Parameters for Full-Aero Long Box Vans
----------------------------------------------------------------------------------------------------------------
Technology Long box dry & refrigerated vans
----------------------------------------------------------------------------------------------------------------
Model year 2018 2021 2024 2027
----------------------------------------------------------------------------------------------------------------
Aerodynamic Technologies:
Bin I.......................................
Bin II......................................
Bin III..................................... 100%
Bin IV...................................... .............. 100%
Bin V....................................... .............. .............. 100% 30%
Bin VI...................................... .............. .............. .............. 70%
Bin VII.....................................
Average Delta CdA (m\2\) \a\............ 0.5 0.7 1.0 1.3
Trailer Tire Rolling Resistance:
Level 1.....................................
Level 2..................................... .............. .............. .............. 5%
Level 3..................................... 100%
Level 4..................................... .............. 100% 100% 95%
Average CRR (kg/ton) \a\................ 5.1 4.7 4.7 4.8
Tire Pressure Systems:
ATIS........................................ 100% 100% 100% 100%
TPMS........................................
Average Pressure System Reduction (%) 1.2% 1.2% 1.2% 1.2%
\a\....................................
Weight Reduction:
Weight (lb) \b\.........................
----------------------------------------------------------------------------------------------------------------
Notes:
A blank cell indicates a zero value.
\a\ Combines projected adoption rates with performance levels shown in Table IV-9.
\b\ This set of adoption rates did not apply any assumed weight reduction to meet these standards for these
trailers.
Table IV-15--Projected Adoption Rates and Average Performance Parameters for Full-Aero Short Box Vans
----------------------------------------------------------------------------------------------------------------
Technology Short box dry & refrigerated vans
----------------------------------------------------------------------------------------------------------------
Model year 2018 2021 2024 2027
----------------------------------------------------------------------------------------------------------------
Aerodynamic Technologies:
Bin I.......................................
Bin II...................................... .............. 100%
Bin III..................................... .............. .............. 100% 40%
Bin IV...................................... .............. .............. .............. 60%
Bin V.......................................
Bin VI......................................
Bin VII.....................................
Average Delta CdA (m\2\) \b\............ 0.0 0.1 0.4 0.6
Trailer Tire Rolling Resistance:
Level 1.....................................
Level 2..................................... .............. .............. .............. 5%
Level 3..................................... 100%
Level 4..................................... .............. 100% 100% 95%
Average CRR (kg/ton) \b\................ 5.1 4.7 4.7 4.8
Tire Pressure Systems:
ATIS........................................ 100% 100% 100% 100%
TPMS........................................
Average Tire Pressure Reduction (%) \c\. 1.2% 1.2% 1.2% 1.2%
Weight Reduction:
Weight (lb) \b\.........................
----------------------------------------------------------------------------------------------------------------
Notes:
A blank cell indicates a zero value.
\a\ The majority of short box trailers are 28 feet in length. We recognize that they are often operated in
tandem, which limits the technologies that can be applied (for example, boat tails).
\b\ Combines projected adoption rates with performance levels shown in Table IV-9.
[[Page 73660]]
\c\ This set of adoption rates did not apply any assumed weight reduction to meet these standards for these
trailers.
The agencies proposed that the partial-aero box vans would track
with the full-aero van standards until MY 2024. 80 FR 40257. Wabash
commented that partial-aero box vans should be exempt starting in MY
2021 since partial-aero vans cannot use multiple devices. The agencies
reconsidered the proposed partial-aero standards and recognize that it
would likely be difficult to meet the proposed MY 2024 standards
without the use of multiple devices and yet partial-aero trailers, by
definition, are restricted from using multiple devices. For these
reasons, the agencies redesigned the partial-aero standards, such that
trailers with qualifying work-performing equipment can meet standards
that would be achievable with the use of a single aerodynamic device
throughout the program, similar to the MY 2018 standards. The partial-
aero standards do, however, increase in stringency slightly in MY 2021,
to reflect the broader use of improved lower rolling resistance tires.
Table IV-16--Projected Adoption Rates and Average Performance Parameters for Partial-Aero Box Vans
----------------------------------------------------------------------------------------------------------------
Technology Partial-aero long box vans Partial-aero short box vans
----------------------------------------------------------------------------------------------------------------
Model year 2018 2021+ 2018 2021+
----------------------------------------------------------------------------------------------------------------
Aerodynamic Technologies:
Bin I.......................................
Bin II...................................... .............. .............. .............. 100%
Bin III..................................... 100% 100%
Bin IV......................................
Bin V.......................................
Bin VI......................................
Bin VII.....................................
Average Delta CdA (m\2\) \b\............ 0.5 0.5 0.0 0.1
Trailer Tire Rolling Resistance:
Level 1.....................................
Level 2.....................................
Level 3..................................... 100% .............. 100%
Level 4..................................... .............. 100% .............. 100%
Average CRR (kg/ton) \b\................ 5.1 4.7 5.1 4.7
Tire Pressure Systems:
ATIS........................................ 100% 100% 100% 100%
TPMS........................................
Average Pressure System Reduction (%) 1.2% 1.2% 1.2% 1.2%
\a\....................................
Weight Reduction:
Weight (lb) \b\.........................
----------------------------------------------------------------------------------------------------------------
Notes:
A blank cell indicates a zero value.
\a\ Combines projected adoption rates with performance levels shown in Table IV-9.
\b\ This set of adoption rates did not apply weight reduction to meet these standards for these trailers.
The adoption rates shown in these tables are one set of many
possible combinations that box trailer manufacturers could apply to
achieve the same average stringency. If a manufacturer chose these
adoption rates, a variety of technology options exist within the
aerodynamic bins, and several models of LRR tires exist for the levels
shown. Alternatively, technologies from other aero bins and tire levels
could be used to comply. It should be noted that since the standards
for box vans are all performance-based, box van manufacturers are not
limited to specific aerodynamic and tire technologies in their
compliance choices. Certain types of weight reduction, for example, may
be used as part of a compliance pathway. See RIA Chapter 2.10.2.4.1 for
other example compliance pathways that include weight reduction.
Similar to our analyses of the baseline cases, the agencies derived
a single set of performance parameters for each subcategory by
weighting the performance levels included in Table IV-9 by the
corresponding adoption rates. These performance parameters represent a
compliant vehicle for each trailer subcategory and are presented as
average values in the Table IV-14 through Table IV-16.
(ii) Tire Technologies for Non-Aero Box Vans and Non-Box Trailers
Neither non-aero vans (i.e., those with two or more work-related
special components), nor non-box trailers are shown in the tables
above. This is because we are adopting design-based (i.e., technology-
based) standards for these trailers, not performance-based standards.
Manufacturers of these trailers do not need to use aerodynamic
technologies, but they need to install the lower rolling resistance
tires and tire pressure systems established by this program (see
Section IV.C.(2)). Compared to manufacturers that needed aerodynamic
technologies to comply, the approach for non-aero box trailers and non-
box trailers results in a significantly lower compliance burden for
manufacturers by reducing the amount of tracking and eliminating the
need to calculate a compliance value (see Section IV.E.). The agencies
are adopting these design standards, which can be assumed to be 100
percent adoption, in two stages. In MY 2018, the non-box trailer
standards require manufacturers to use tires meeting a rolling
resistance of Level 2 or better and to install tire pressure systems.
In MY 2021, non-box trailers standards require tire pressure systems
and LRR tires at Level 3 or better. Non-aero box vans, which we believe
are largely at a baseline rolling resistance Level 2 today, require
tire pressure monitoring systems with Level 3 tires in MY 2018 and
Level 4 tires in MY 2021 and later.
We received comment that manufacturers were concerned about the
cost and availability of ATIS for the trailer industry. Still, based on
comments about TPMS and further evaluations by the agencies, we are
including TPMS as an additional option for tire pressure systems in the
trailer program, as discussed in Section IV.D.(1)(c) above. Non-aero
vans and
[[Page 73661]]
non-box trailers are compliant if they have appropriate lower rolling
resistance tires and either TPMS or ATIS.
(e) Derivation of the Trailer Standards
The agencies applied the average performance parameters from Table
IV-14 and Table IV-15 as input values to the GEM vehicle simulation to
derive the HD Phase 2 fuel consumption and CO2 emissions
standards for each long and short full-aero box van subcategory. These
full-aero van standards are shown in Table IV-17. Similarly, the
average performance parameters from Table IV-16 were used to calculate
the partial-aero van standards shown in Table IV-18. The design
standards for non-box trailer and non-aero box van are summarized in
Table IV-19.
Over the four stages of the trailer program, the full-aero box vans
longer than 50 feet are projected to reduce their CO2
emissions and fuel consumption by two percent, five percent, seven
percent and nine percent compared to their average baseline cases in
Table IV-13. Full-aero box vans 50-feet and shorter will achieve
reductions of one percent, two percent, four percent and six percent
compared to their average baseline cases. The partial-aero long and
short box van standards will reduce CO2 and fuel consumption
by six percent and four percent, respectively, by MY 2021. The tire
technologies used on non-box and non-aero box trailers are projected to
provide reductions of two percent in the first stage and three percent
in MY 2021 and later.
Table IV-17--Standards for Full-Aero Box Vans
----------------------------------------------------------------------------------------------------------------
Subcategory Dry van Refrigerated van
Model year ---------------------------------------------------------------------------
Length Long Short Long Short
----------------------------------------------------------------------------------------------------------------
2018-2020........................... EPA Standard 81.3 125.4 83.0 129.1
(CO[ihel2] Grams per
Ton-Mile).
Voluntary NHTSA 7.98625 12.31827 8.15324 12.68173
Standard (Gallons per
1,000 Ton-Mile).
2021-2023........................... EPA Standard 78.9 123.7 80.6 127.5
(CO[ihel2] Grams per
Ton-Mile).
NHTSA Standard 7.75049 12.15128 7.91749 12.52456
(Gallons per 1,000
Ton-Mile).
2024-2026........................... EPA Standard 77.2 120.9 78.9 124.7
(CO[ihel2] Grams per
Ton-Mile).
NHTSA Standard 7.58350 11.87623 7.75049 12.24951
(Gallons per 1,000
Ton-Mile).
2027+............................... EPA Standard 75.7 119.4 77.4 123.2
(CO[ihel2] Grams per
Ton-Mile).
NHTSA Standard 7.43615 11.7288 7.60314 12.10216
(Gallons per 1,000
Ton-Mile).
----------------------------------------------------------------------------------------------------------------
Table IV-18--Standards for Partial-Aero Box Vans
----------------------------------------------------------------------------------------------------------------
Subcategory Dry van Refrigerated van
Model year ---------------------------------------------------------------------------
Length Long Short Long Short
----------------------------------------------------------------------------------------------------------------
2018-2020........................... EPA Standard 81.3 125.4 83.0 129.1
(CO[ihel2] Grams per
Ton-Mile).
Voluntary NHTSA 7.98625 12.31827 8.15324 12.68173
Standard (Gallons per
1,000 Ton-Mile).
2021+............................... EPA Standard 80.6 123.7 82.3 127.5
(CO[ihel2] Grams per
Ton-Mile).
NHTSA Standard 7.91749 12.15128 8.08448 12.52456
(Gallons per 1,000
Ton-Mile).
----------------------------------------------------------------------------------------------------------------
Table IV-19--Design-Based Tire Standards for Non-Box Trailers and Non-Aero Box Vans
----------------------------------------------------------------------------------------------------------------
Model year Tire technology Non-box trailers Non-aero box vans
----------------------------------------------------------------------------------------------------------------
2018-2020................................ Tire Rolling Resistance <=6.0 <=5.1
Level (kg/ton).
Tire Pressure System....... TPMS or ATIS TPMS or ATIS
2021+.................................... Tire Rolling Resistance <=5.1 <=4.7
Level (kg/ton).
Tire Pressure System....... TPMS or ATIS TPMS or ATIS
----------------------------------------------------------------------------------------------------------------
(f) Technology Costs for the Trailer Standards
The agencies evaluated the incremental technology costs for 53-foot
dry and refrigerated vans and 28-foot dry vans. (As explained above, we
believe these length trailers are representative of the majority of
trailers in the long and short box van subcategories, respectively.) We
identified costs for each technology package and projected the costs
for each year of the program. A summary of the technology costs is
included in Table IV-20 through Table IV-23 for MYs 2018 through 2027,
with additional details available in the RIA Chapter 2.12. Costs shown
in the following tables are for the specific model year indicated and
are incremental to the average baseline costs, which includes some
level of adoption of these technologies as shown in Table IV-13.
Therefore, the technology costs in the following tables reflect the
average cost expected for each of the indicated trailer classes across
the fleet. Note that these costs do not represent actual costs for the
individual components because they are relative to the costs of the MY
2018 baselines which are expected due to market-driven adoption of the
technologies. For more on the estimated technology costs exclusive of
adoption rates, refer to Chapter 2.12 of the RIA. These costs include
indirect costs via markups and reflect lower costs over time due to
learning impacts. For a description of the markups and learning impacts
considered in this analysis and how technology costs for other years
are thereby affected, refer to Chapter 7 of the RIA.
[[Page 73662]]
Table IV-20--Trailer Technology Incremental Costs in the 2018 Model Year
[2013$]
--------------------------------------------------------------------------------------------------------------------------------------------------------
Long vans, Short vans,
Long vans, partial Short vans, partial Long vans, Short vans, Non-box
full aero aero full aero aero no aero no aero
--------------------------------------------------------------------------------------------------------------------------------------------------------
Aerodynamics................................................. $367 $742 $0 $0 $0 $0 $0
Tires........................................................ 2 40 1 20 40 20 28
Tire inflation system........................................ 347 659 338 494 421 210 421
------------------------------------------------------------------------------------------
Total.................................................... 716 1,441 339 514 461 231 448
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table IV-21--Trailer Technology Incremental Costs in the 2021 Model Year
[2013$]
--------------------------------------------------------------------------------------------------------------------------------------------------------
Long vans, Short vans,
Long vans, partial Short vans, partial Long vans, Short vans, Non-box
full aero aero full aero aero no aero no aero
--------------------------------------------------------------------------------------------------------------------------------------------------------
Aerodynamics................................................. $743 $679 $450 $475 $0 $0 $0
Tires........................................................ 17 49 9 25 49 25 23
Tire inflation system........................................ 321 609 313 457 389 195 389
------------------------------------------------------------------------------------------
Total.................................................... 1,081 1,337 772 957 438 219 412
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table IV-22--Trailer Technology Incremental Costs in the 2024 Model Year
[2013$]
--------------------------------------------------------------------------------------------------------------------------------------------------------
Long vans, Short vans,
Long vans, partial Short vans, partial Long vans, Short vans, Non-box
full aero aero full aero aero no aero no aero
--------------------------------------------------------------------------------------------------------------------------------------------------------
Aerodynamics................................................. $899 $645 $879 $451 $0 $0 $0
Tires........................................................ 11 48 6 24 48 24 27
Tire inflation system........................................ 294 558 286 418 357 178 357
------------------------------------------------------------------------------------------
Total.................................................... 1,204 1,251 1,171 894 405 202 383
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table IV-23--Trailer Technology Incremental Costs in the 2027 Model Year
[2013$]
--------------------------------------------------------------------------------------------------------------------------------------------------------
Long vans, Short vans,
Long vans, partial Short vans, partial Long vans, Short vans, Non-box
full aero aero full aero aero no aero no aero
--------------------------------------------------------------------------------------------------------------------------------------------------------
Aerodynamics................................................. $1,069 $623 $921 $436 $0 $0 $0
Tires........................................................ 22 44 11 22 44 22 16
Tire inflation system........................................ 279 529 272 397 338 169 338
------------------------------------------------------------------------------------------
Total.................................................... 1,370 1,196 1,204 855 382 191 354
--------------------------------------------------------------------------------------------------------------------------------------------------------
(3) Consistency of the Trailer Standards With the Agencies' Statutory
Obligations
The agencies have determined that the standards presented in the
Section IV.C.(2), are the maximum feasible and appropriate under the
agencies' respective authorities, considering lead time, cost, and
other factors. The agencies' decisions on the stringency and timing of
the trailer standards focused on available technology and the
consequent emission reductions and fuel efficiency improvements
associated with use of the technology, while taking into account the
circumstances of the trailer manufacturing sector. Trailer
manufacturers are subject to first-time emission control and fuel
consumption regulation under the trailer standards. These manufacturers
are in many cases small businesses, with limited resources to master
the mechanics of regulatory compliance. Thus, the agencies are
providing ample and reasonable time for trailer manufacturers to become
familiar with the requirements and the new compliance regime.
The stringency of the standard is predicated on more widespread
deployment of tire technologies that are already in commercial use and
existing aerodynamic devices combinations that we believe will be
further optimized in the near-term. The availability, feasibility, and
level of effectiveness of these technologies are well-documented. In
developing the standards, we also took into account not just the
capabilities of the technologies, but also how the use of these
technologies is likely to expand under the trailer program, considering
factors like degree of market penetration over time and the effect of
different operational patterns for different trailer types (Section
IV.D.(2) above). For example, some commenters point out that trailers
operating at lower speeds will achieve smaller CO2 and fuel
consumption reductions than they will at highway speeds. The agencies
acknowledge this fact, and account for a fraction of trailer operation
at slower speeds. All long box vans are evaluated with 5 percent of
their miles at low speed operation and all short vans are evaluated
with 17 percent low speed miles. While we cannot predict individual
trailer use, we believe these
[[Page 73663]]
values are a reasonable estimate of an industry average.\363\ Our
analysis in RIA Chapter 2.10.2.1.1 shows that skirts will provide short
trailers with at least 1 percent improvement and long trailers with at
least 4 percent improvement at 55 mph. We expect most trailers spend at
least some of their miles at 55 mph or faster in use and will gain
similar benefits during those speeds. We also show that even trailers
operating under fully transient conditions (combining slower and faster
operation) will experience a small improvement from use of trailer
skirts.
---------------------------------------------------------------------------
\363\ Memorandum to Docket EPA-HQ-OAR-2014-0827, ``Comparison of
GEM Drive Cycle Weightings and Fleet Data Provided by Utility
Trailer Manufacturing Co. in Public Comments'', July 2016.
---------------------------------------------------------------------------
The agencies do not believe that there is any issue of
technological feasibility of the levels of the standards and the time
line for implementing them in the final trailer program. The agencies
considered cost and the sufficiency of lead-time, including lead-time
not only to deploy technological improvements, but, as just noted, also
for this industry sector to assimilate for the first time the
compliance mechanisms of the trailer program.
The highest cost shown in Table IV-23 is associated with the
standard for long dry vans. We project that the average cost per
trailer to meet the MY 2027 standards for these trailers will be about
$1,400, which is less than 10 percent of the cost of a new dry van
trailer (estimated to be about $20,000). Other trailer types have lower
projected technology costs, and many have higher purchase prices. As a
result, we project that the per-trailer costs for all trailers covered
in this regulation will be less than 10 percent of the cost of a new
trailer.
The agencies regard these costs as reasonable. We project that most
customers will rapidly recover the initial cost of these technologies
due to the associated fuel savings, usually in two years. As discussed
in Section IX.M and RIA Chapter 7.2.4, this payback is for tractors and
trailers together, and includes both long and short-haul. This payback
period is generally considered reasonable in the trailer industry for
investments that reduce fuel consumption.\364\ Although longer paybacks
will occur for some trailers, we do not project that any trailers will
achieve lifetime fuel savings less than the cost of the technologies.
In addition, the agencies estimate the cost per metric ton of
CO2eq reduction without considering fuel savings to be $36
for tractor-trailers in 2030 which compares favorably with the levels
of cost effectiveness the agencies found to be reasonable for light
duty trucks.\365\
---------------------------------------------------------------------------
\364\ Roeth, Mike, et al. ``Barriers to Increased Adoption of
Fuel Efficiency Technologies in Freight Trucking,'' July 2013.
International Council for Clean Transportation. Available here:
http://www.theicct.org/sites/default/files/publications/ICCT-NACFE-CSS_Barriers_Report_Final_20130722.pdf.
\365\ See RIA Chapter 7.2.5 and Memo to Docket ``Tractor-Trailer
Cost per Ton Values.'' July 2016. EPA-HQ-OAR-2014-0827.
---------------------------------------------------------------------------
The agencies believe these technologies can be adopted at the
projected rates within the lead time provided in the trailer program,
as discussed above in Section IV.C.(4) above.
(4) Alternative Standards and Feasibility That the Agencies Considered
As discussed in Section X of the NPRM, the agencies evaluated five
regulatory alternatives representing different levels of stringency for
the Phase 2 program. See 80 FR 40273. A wide range of stakeholders
commented on the proposed (Alternative 3) standards and the other
alternatives that we discussed, and our final standards reflect our
consideration of all of those comments.
Comments on our proposed standards (Alternative 3) and the
alternatives we presented generally fell into three categories: (1)
Commenters supporting Alternative 1; i.e., generally advocating no
mandatory standards and a continuation of today's voluntary SmartWay
regime and; (2) Commenters preferring the proposed Alternative 3
standards and timeline to the standards of Alternative 4; and (3)
Commenters supporting the more stringent standards and timeline of
Alternative 4, Alternative 5, or of other more stringent potential
programs.
Commenters including the TTMA, Utility, and Stoughton stated their
belief that no mandatory standards are necessary; however, they did not
provide information to show that market forces at work today will
achieve the clear potential for the industry to reduce CO2
and fuel consumption in the near- and longer-term future. The agencies
have concluded that a program involving no or minimal mandatory
requirements would not be appropriate or meet our statutory
requirements.
As discussed previously, the agencies believe that our final
trailer standards are appropriate under the Clean Air Act and are the
maximum feasible standards under the EISA. In developing the proposal
and the final rule, we considered standards that would be more
stringent or would become effective in an earlier model year than the
proposed Alternative 3 standards and timeline. Several commenters
stated that a still more stringent program should be finalized,
including information about current and potential future trailer
aerodynamic technologies. Commenters including CARB, NACAA, NRDC, ICCT,
UCS, and STEMCO supported the standards we presented for Alternative 4
in the proposal (essentially the pull ahead of the MY 2027 standards)
in the proposal. In addition, some of the commenters made the
additional suggestion that the agencies should anticipate that
manufacturers will incorporate a modest degree of Bin VIII
technologies--i.e., two bins higher than any performance demonstrated
in our aerodynamic testing--in the later stages of the program. EDF
supported a program of even greater stringency, supporting Alternative
5 standards (advanced aerodynamic technologies on all box vans,
aerodynamic technologies on some non-box trailers, and tire
technologies on all non-box trailers) on the Alternative 4 timeline.
The Center for Biological Diversity (CBD) did not specifically comment
on the alternatives presented in the proposal, but supported a program
that would result in significantly more stringent standards (based, for
example, on integrated tractor and trailer technologies, such as in the
SuperTruck demonstration program). Great Dane, Wabash, ATA, and the
International Foodservice Distributors Association expressed concerns
that a program of the stringency and timeline of Alternative 4 would
have negative consequences, including requiring trailer manufacturers
to adopt less-tested technology.
Where commenters provided relevant data and information, the
agencies made adjustments to the final program accordingly. For
example, as noted in Section IV.C.(1) and Section IV.D.(2) previously,
information from the industry was helpful in the decision to limit the
non-box trailer program to tanks, flatbeds, and container chassis.
Also, partially in response to information we received in comments, we
slightly reduced the proposed stringency for partial-aero vans to
better reflect their aerodynamic limitations. Also, while not a direct
change to the stringency of the standards, the program limits averaging
to the final stage of the program to allow van manufacturers more time
to become familiar with the compliance processes and the industry to
gain confidence in the technologies. Overall, the final standards are
slightly more stringent than proposed, based on
[[Page 73664]]
an expectation of earlier adoption of more efficient lower rolling
resistance tires for all subcategories, and a strengthened the full-
aero van program that includes greater adoption of advanced
aerodynamics in the final stage.
Based on this analysis and as informed by the comments, we believe
that the final standards in the program, slightly revised from the
proposed Alternative 3 standards, are appropriate and represent the
maximum feasible standards. In contrast, we believe that the
accelerated timeline of Alternative 4 may cause technologies to
prematurely enter the market, leading to unnecessary costs and
compliance burdens that would not be appropriate for this newly
regulated industry. Standards similar to or more stringent than those
we evaluated for Alternative 5 would require CO2 and fuel
consumption reductions that may well not be technologically achievable,
even with fundamental changes to the industry. Nor did the commenters
present any information as to how advanced aerodynamic technologies
(Bins VII and VIII) could be developed and reliably brought to market
at reasonable cost within the lead time of the Phase 2 program. On the
basis of what we know today, the agencies are unable to show a pathway
for the industry to achieve such additional improvements, at least
without the potential for major disruptions to the industry due to
requiring, for example, fundamental changes to trailer design and
construction, or impractical levels of tractor-trailer integration.
E. Trailer Standards: Compliance and Flexibilities
As with other EPA motor vehicle programs, trailer manufacturers
must annually obtain a certificate of conformity from EPA before
introducing into commerce new trailers subject to the new trailer
CO2 and fuel consumption standards. See CAA section 206(a).
The EPA certification provisions align with provisions that apply to
the NHTSA trailer program such that this single certification program
meets the requirements of both agencies.
The certification process for trailer manufacturers is very similar
in its basic structure to the process for the other Phase 2 vehicle
programs, although it has been simplified for trailers. This structure
involves pre-certification activities, the certification application
and its approval, and end-of-year reporting.
In this section, the agencies first describe the general
certification process and how we developed compliance equations based
on the GEM vehicle simulation tool, followed by a discussion of the
specified test procedures for measuring the performance of tires and
aerodynamic technologies and how manufacturers will apply test results
toward compliance and certification. The section closes with
discussions of several other certification and compliance provisions as
well as provisions to provide manufacturers with compliance
flexibility.
(1) General Certification Process
Under the process for certification, manufacturers of all covered
trailers are required to apply to EPA for certification.\366\ In
addition, manufacturers of box vans subject to the performance-based
standards are required to provide aerodynamic performance test data
(see 40 CFR 1037.205) in their applications. EPA expects to provide
additional guidance to the regulated industry as the program begins to
be implemented, including an overview of the regulations, how to
prepare for compliance, and instructions for registering with the EPA.
Once a trailer manufacturer is registered with EPA, EPA's Compliance
Division in the Office of Transportation and Air Quality will assign a
staff certification representative to the company to help them through
the compliance process. After this point, manufacturers can arrange to
meet with the agencies to discuss compliance plans and obtain any
preliminary approvals (e.g., appropriate test methods) before applying
for certification.
---------------------------------------------------------------------------
\366\ As with the other Phase 2 vehicle programs, manufacturers
submit their applications to EPA, which then shares them with NHTSA.
Obtaining an approved certificate of conformity from EPA is the
first step in complying with the NHTSA program.
---------------------------------------------------------------------------
Trailer manufacturers submit their applications through the EPA
``Verify'' electronic database, and EPA issues certificates based on
the information provided. At the end of the model year, trailer
manufacturers submit an end-of-year report to the agencies to complete
their annual obligations.
(a) Definition of Model Year
As mentioned previously, consistent with Clean Air Act
specifications, EPA's vehicle certification is an annual process. EPA
CO2 emissions standards start to apply for trailers built on
or after January 1, 2018, with later standards being introduced by
model year. Under the Clean Air Act, the term ``model year'' refers to
a manufacturer's annual production period. Manufacturers may use the
calendar year as the model year, or may choose a different period of
production that includes January 1 of that year. Thus, manufacturers
have the option to choose any year-long period of production that
begins on or before January 1 of the named model year, but no sooner
than January 2 of the previous calendar year. For example, at
certification, a manufacturer could specify the 2021 model year
production period to be July 1, 2020 through June 30, 2021.
(b) Preliminary Considerations for Compliance
Before submitting an application for a certificate, a manufacturer
chooses the technologies they plan to offer their customers, and
identifies any trailers in their production line that qualify for
exclusion from the program.\367\ Non-box trailers, which are subject to
design standards, the manufacturer will need to select which tires and
tire pressure systems to include and confirm that their tires meet the
LRR performance standards. For box vans subject to performance
standards, manufacturers also obtain performance information for these
technologies at this time, either from supplier data or their own
testing. Manufacturers that choose to perform aerodynamic or tire
testing themselves may also need to obtain approval of test methods and
perform preliminary testing. Trailer manufacturers relying on data from
a third-party aerodynamic device manufacturer would need to verify that
these data are approved.
---------------------------------------------------------------------------
\367\ Trailers that meet the qualifications for exclusion do not
require a certificate of conformity and manufacturers do not have to
submit an application to EPA for these trailers.
---------------------------------------------------------------------------
During this time, the manufacturers also decide the strategy they
intend to use for compliance by identifying ``families'' for the
trailers they produce. A family is a grouping of similar products that
are all subject to the same standard and covered by a single
certificate. All products in each trailer subcategory are generally
certified as the same family. That is, long box dry vans, short box dry
vans, long refrigerated vans, short refrigerated vans, non-box
trailers, partial-aero vans (long and short box, dry and refrigerated
vans), and non-aero box vans, are each certified as separate trailer
families. Manufacturers may combine dissimilar trailers into a single
vehicle family to reduce the compliance burden as described in 40 CFR
1037.230(d)(3) and 49 CFR 535.5(e). In general, manufacturers can
combine trailers that have less stringent standards with more stringent
standards as long as the combined set of trailers
[[Page 73665]]
meet the more stringent standards. Refrigerated and dry vans of the
same length can be combined to meet the dry van standards. Short vans
can combine with long vans, meeting the corresponding long van
standard. Additionally, non-box trailers can be combined with the non-
aero box vans if the manufacturer would like to meet the more stringent
non-aero box van design standards with higher-performing tires.
When no averaging is available (i.e., MY 2018 through MY 2026 for
full-aero box vans, and all years for remaining trailers), all products
within a family need to meet or exceed the standards for that trailer
subcategory (except for any trailers included in the manufacturer's
allowance for non-complying vehicles (See Section IV.E.(5)(a) below)).
This is not to say that, for example, every long box dry van model
needs to have identical technologies like skirts, tires, and tire
inflation systems, but that every model in that family need to meet the
standard for that family.
In MY 2027 and later, full-aero box van manufacturers will still
generally have one family per subcategory. However, if a full-aero box
van manufacturer subject to performance standards wishes to utilize the
averaging provisions, it would need to divide the trailer models in
each of the van subcategories/families into subfamilies.\368\ Each
subfamily can be a grouping of box vans that have similar performance
levels, even if they use different technologies. We refer to the
performance levels for each subfamily as ``Family Emission Limits''
(FELs). A long box dry van manufacturer could choose, for example, to
create two subfamilies in its long box dry van family. Trailers in one
of these subfamilies could be allowed to under-comply with the standard
(e.g., not apply a tire pressure system) as long as the performance of
the other subfamily over-complies with the standard (e.g., installs
additional aerodynamic technologies), such that the average of all of
the subfamilies' FELs met or exceeded the standard for that family on a
production-weighted basis. Section IV.E.(5)(b) below further discusses
how the averaging program would function for any such trailer
subfamilies.
---------------------------------------------------------------------------
\368\ The program essentially requires that manufacturers equip
100 percent of their non-box and special purpose box trailers with
tire pressure systems and tires meeting the specified rolling
resistance levels. Partial-aero box vans meet a reduced performance
standard. As a result, averaging provisions do not apply to these
trailer subcategories.
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(c) Submitting a Certification Application and Request for a
Certificate to EPA
Once the preliminary steps are completed, the manufacturer can
prepare and submit applications to EPA for certificate of conformity
for each of its trailer families. The contents of the application are
specified in 40 CFR 1037.205, though not all items listed in the
regulation are applicable to each trailer manufacturer.
For the early years of the program (i.e., MY 2018 through MY 2020),
the application must specify whether the trailer manufacturer is opting
into the NHTSA voluntary program to ensure the information is
transferred between the agencies. Throughout the program, the
application must include a description of the emission and fuel
consumption reduction technologies that a manufacturer intends to
offer. These technologies could include aerodynamic features, LRR tire
models, tire pressure systems, or components that qualify for weight
reduction. Basic information about labeling, warranty, and recommended
maintenance should also be included the application (see Section
IV.E.(4) for more information on these additional compliance
provisions).
The manufacturer also provides a summary of the plans to comply
with the standard. This information includes a description of the
trailer family and subfamilies (if applicable) covered by the
certificate, the technologies that are used for compliance, and
projected sales of its products. For trailers subject to performance-
based standards (and not those subject to the design-based standards),
in the earlier stages of the program when averaging is not available
(or for manufacturers of full-aero vans that do not participate in
averaging after MY 2026), additional provisions apply. These
manufacturers will include information on the configuration with the
worst performance level in terms of CO2 and fuel consumption
offered in the trailer family. Any of these manufacturers that choose
to average within their full-aero van families after MY 2026 will
include performance information for the projected highest production
trailer configuration, as well as the lowest and the highest performing
configurations within those families. For all covered trailers, once
the certification application is accepted, a certificate is issued and
manufacturers can begin selling their trailers.
(d) End-of-Year Obligations
After the end of each year, all manufacturers, including those with
design-based standards, need to submit a report to the agencies
presenting production-related data for that year (see 40 CFR 1037.250
and 49 CFR 535.8). In addition, the year's final compliance data (as
calculated using the compliance equation) for box van manufacturers
subject to performance-based standards will include both CO2
emissions and fuel consumption information and actual production
volumes in order to demonstrate that the trailers met the standards for
that year.
In MY 2027 and later, full-aero box van manufacturers that opt to
participate in the averaging program will submit a second report that
describes their subfamily FELs and a final calculation of their
production-weighted average CO2 and fuel consumption. See 40
CFR 1037.730, 40 CFR 1037.745, and 49 CFR 535.7. All certifying
manufacturers need to maintain records of all the data and information
that is required to be supplied to EPA and NHTSA for eight years.
(2) Evaluating Trailer Performance for Compliance
The agencies believe that this final compliance program for trailer
manufacturers is straightforward, technically robust, transparent, and
minimizes administrative burdens on the industry. As described earlier
in this section and in Chapter 4 of the RIA, GEM is a customized
vehicle simulation model that EPA developed for the Phase 1 program to
relate measured aerodynamic and tire performance values, as well as
other parameters, to CO2 and fuel consumption without
performing full-vehicle testing. As with the Phase 1 and Phase 2
tractor and vocational vehicle programs, the trailer program uses GEM
in evaluating emissions and fuel consumption in developing the trailer
standards. However, unlike the tractor and vocational vehicle programs,
trailer manufacturers will not use GEM directly to demonstrate
compliance with the trailer standards. Instead, we have developed an
equation based on GEM that calculates CO2 and fuel
consumption from performance inputs without running the model.
(a) Development of the GEM-Based Trailer Compliance Equation
For compliance with the performance-based standards in the trailer
program (i.e. the standards for full- and partial-aero long and short
box vans), the trailer characteristics that a manufacturer supplies to
the equation are aerodynamic improvements (i.e., the change in the
aerodynamic drag area,
[[Page 73666]]
delta CdA, from the appropriate bin in m\2\), tire rolling
resistance (i.e., coefficient of rolling resistance, CRR, in
kg/metric ton), the presence of a tire pressure system, and any weight
reduction applied in pounds. The use of the equation quantifies the
overall performance of the trailer in terms of CO2 emissions
on a grams per ton-mile basis, which can be converted to fuel
consumption on a gallons per 1000 ton-mile basis.
Chapter 2.10.5 of the RIA provides a full a description of the
development and evaluation of the equation for trailer compliance where
the standards are performance-based. Equation IV-1 is a single linear
regression curve that can be used for all box vans in these rules to
calculate CO2 emissions, eCO2. Unique constant
values, C1 through C4, are applied for each of
the van types as shown in Table IV-24. Constant C5 is equal
to 0.988 for any trailer that installs an ATIS (accounting for the 1.2
percent reduction given for use of ATI), 0.990 for any trailer that
installs a TPMS, or 1.0 for trailers without tire pressure systems. We
found that this equation accurately reproduces the results of GEM for
each of the box van subcategories, and the program requires these
trailer manufacturers use Equation IV-1 to calculate CO2 for
compliance. Manufacturers insert their tire rolling resistance level
(TRRL), wind-averaged change in drag area ([Delta]CdA),
weight reduction value (WR) (if applicable), and the appropriate
C5 value if a tire pressure system is installed into the
equation and submit the result to EPA. The program provides for
manufacturers to use a conversion of 10.180 grams of CO2 per
gallon of diesel to calculate the corresponding fuel consumption values
for compliance with NHTSA's regulations. See 40 CFR 1037.515 and 49 CFR
535.6.
[GRAPHIC] [TIFF OMITTED] TR25OC16.009
Table IV-24--Constants for GEM-Based Trailer Compliance Equation
--------------------------------------------------------------------------------------------------------------------------------------------------------
C[ihel5] (tire pressure)
Trailer subcategory C[ihel1] C[ihel2] C[ihel3] C[ihel4] -----------------------------------------
None TPMS ATIS
--------------------------------------------------------------------------------------------------------------------------------------------------------
Long Dry Van.................................. 76.1 1.67 -5.82 -0.00103 1.000 0.990 0.988
Long Refrigerated Van......................... 77.4 1.75 -5.78 -0.00103
Short Dry Van................................. 117.8 1.78 -9.48 -0.00258
Short Refrigerated Van........................ 121.1 1.88 -9.36 -0.00264
--------------------------------------------------------------------------------------------------------------------------------------------------------
These long and short van constants are based on GEM-simulated
tractors pulling 53-foot and solo 28-foot trailers, respectively. As a
result, aerodynamic testing to obtain a trailer's performance
parameters for Equation IV-1 must be performed using consistent trailer
sizes (i.e., aerodynamic performance for all lengths of short vans
would be tested as a solo 28-foot van, and performance for all lengths
of long vans would be tested as a 53-foot van). More information about
aerodynamic testing is provided in Section IV.E.(3)(b) below.
The constants for long vans apply for all dry or refrigerated vans
longer than 50-feet and the constants for short vans apply for all dry
or refrigerated vans 50-feet and shorter. The vans with work-performing
devices that may be designated as partial-aero vans would use the same
equation constants as their full-aero counterparts for compliance. The
partial-aero designation simply allows a van to input different values
(i.e., lower delta CdA) and meet a different standard. Note
that compliance with the design-based standards (non-box trailers and
non-aero vans) does not require use of the GEM-based equation.
Manufacturers supply the TRRL values for their trailer tires and attest
that they installed one of the tire pressure systems (TPMS or ATIS) to
EPA for compliance.
(b) Use of the Compliance Equation for Box Van Compliance
Box van manufacturers subject to the performance-based standards
meet the standards using the GEM-based compliance equation to combine
the effects of technologies and quantify the overall performance of the
vehicle to demonstrate compliance. Trailer manufacturers obtain delta
CdA and tire rolling resistance values from testing (either
from their own testing or from testing performed by another entity as
described in Section IV.E.(3)(b)) and attest that they installed a
qualifying tire pressure system and/or adopted weight reduction
strategies. Manufacturers adopting aerodynamic improvements will
compare their measured delta CdA value to the values shown
in Table 2 of 40 CFR 1037.515 (and Table IV-5 previously) and use the
appropriate aerodynamic bin value as the aerodynamic input into the
equation. The TRRL can be directly applied from measurements. Weight
reduction is obtained by summing applicable values in our list of light
weight components (Table 3 of 40 CFR 1037.515) or from measurements
using the off-cycle provisions. Manufacturers indicate use of TPMS or
ATIS with a specified percent reduction in CO2 and fuel
consumption.
Qualifying components for weight reduction can be found in 40 CFR
1037.515(d). Manufacturers that substitute one or more of these
components on their box vans sum the weight reductions assigned to each
component and enter that total into the equation. As noted in Section
IV.D.(1)(d), the equation accounts for weight reduction by assigning
one-third of that reduced weight to increase the payload and the
remaining weight reduction to reduce the overall weight of the assumed
vehicle.
Manufacturers of box vans subject to the performance standards
apply the compliance equation separately to each configuration to
ensure that all of the trailer configurations they offer need to meet
the standard for the given model year. The certification application
submitted to EPA includes equation results from the worst performing
trailer configuration for each subcategory and the manufacturer attests
that no regulated trailer will be sold in a lower performing
configuration. If the manufacturer offers a new technology package
during the model year, the performance can be evaluated using the
equation. If the performance of the new package is lower than the value
submitted in the application, the manufacturer would submit a ``running
change'' to EPA to reflect the change. Box van manufacturers will
submit a single end-of-year report that will include their production
volumes and
[[Page 73667]]
confirmation that all of their trailers applied the technology packages
outlined in their application.
Any full-aero box van manufacturers that wish to take advantage of
the agencies' averaging provision in MY 2027 and later will make
greater use of the compliance equation. Before submitting a certificate
application, these manufacturers would decide which technologies to
make available for their customers and use the equation to determine
the range of performance of the packages they planned to offer. The
manufacturers would supply these results from the equation in their
certificate application and those manufacturers that wish to perform
averaging would continue to calculate emissions (and fuel consumption)
with the equation throughout the model year and keep records of the
results for each trailer package produced. As described in Section
IV.E.(1)(d) above, at the end of the year, these manufacturers would
submit two reports. One report would include their production volumes
for each configuration. The second report would summarize the families
and subfamilies, and CO2 emissions and fuel consumption
results from the equation for all of the trailer configurations they
build in that model year, including a production-weighted average to
show compliance.
For non-box trailers and non-aero box vans, compliance is design-
based, not performance-based, and the compliance equation is not
needed. As described earlier, the standards for these trailers require
the use of tires with rolling resistance levels at or below a
threshold, and tire pressure systems (either TPMS or ATIS). Instead of
aerodynamic testing data in their certification applications,
manufacturers of these trailers submit their tire rolling resistance
levels and a description of their tire pressure system(s) to EPA.
(3) Trailer Certification Test Protocols
The Clean Air Act specifies that compliance with emission standards
for motor vehicles be demonstrated by the manufacturer using emission
test data (see CAA section 206(a) and (b)). As discussed earlier, for
the design-based standards (non-box trailers and non-aero vans), the
trailer program considers the use of specified LRR tires and tire
pressure systems an appropriate surrogate for emission testing, and
there are no testing requirements associated with these standards
beyond the testing required to show the tires qualify as LRR tires. We
expect that tire testing will be performed by the tire manufacturers.
All full- and partial-aero vans covered by the program are subject
to performance standards, and compliance is based on measured emission
performance. For these trailers, the program uses the GEM-based
compliance equation discussed in Section IV.E.(2)(a) above as the
official ``test procedure'' for quantifying CO2 and fuel
consumption performance for trailer compliance and certification (as
opposed to use of GEM, which serves this function in the tractor and
vocational vehicle programs). Manufacturers input performance
information from the applicable trailer technologies into the equation
in order to calculate their impact on overall trailer performance.
Manufacturers needing aerodynamic and tire rolling resistance
performance data obtain it either through their own testing or through
a device or tire manufacturer that performed the testing. The program
specifies pre-determined values for tire pressure systems and many
weight reduction components for manufacturers to apply.
The following subsections describe the approved performance tests
for tire rolling resistance and aerodynamic drag in this trailer
program. See 40 CFR part 1037, subpart F, for a full description of the
performance tests, in particular section 40 CFR 1037.515.
(a) Trailer Tire Performance Testing
Under Phase 1, tractor and vocational chassis manufacturers are
required to input the tire rolling resistance level (TRRL) into GEM,
and the agencies adopted the provisions in ISO 28580:2009(E) \369\ to
determine the rolling resistance of tires. The tire rolling resistance
level (TRRL) is a declared value that is based on a measured value. As
described in 40 CFR 1037.520(c), this measured value, expressed as
CRR, is required to be the result of measurements of three
different tires of a given design, giving a total of at least three
data points. Manufacturers specify a CRR value for GEM that
is less than or equal to the average of these three results. Tire
rolling resistance may be determined by either the vehicle or tire
manufacturer. In the latter case, the tire manufacturer provides a
signed statement confirming that it conducted testing in accordance
with this part.
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\369\ See http://www.iso.org/iso/iso_catalogue/catalogue_tc/catalogue_detail.htm?csnumber=44770.
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The Phase 1 tire testing provisions for rolling resistance apply to
all of the regulated trailers in the Phase 2 program. In the Phase 2
program, full- and partial-aero box van manufacturers, subject to the
trailer performance-based standards, apply their declared TRRL in the
compliance equation. Non-box trailer and non-aero box vans, subject to
the design-based standards, simply report the TRRL as part of their
certification application. Based on the current practice for Phase 1,
we expect the trailer manufacturers to obtain these data from tire
manufacturers, but trailer manufacturers have the option to perform
tire testing themselves.
The agencies requested comment on adopting a program for tire
manufacturers similar to the provision described in Section
IV.E.(3)(b)(v) for aerodynamic device manufacturers, through which tire
manufacturers would seek preliminary approval of the performance of
their trailer tires. 80 FR 40278. CARB supported this option and
further requested that EPA create a public database of the tire rolling
resistance data submitted to the agency in such preliminary approvals.
RMA's comments opposed making tire data available to the public without
first developing a rating system for medium and heavy truck tires. The
agencies have chosen not to pursue provisions for pre-approved trailer
tire rolling resistance data or a public database of this information
in this rulemaking, recognizing the overall unresolved issues relating
to standard HD truck and trailer testing within the tire industry (as
discussed in the Tractor section of this Preamble, Section
III.E(1)(e)). Instead, trailer tire manufacturers provide tire rolling
resistance values directly to the trailer manufacturers and that
information is shared with EPA and NHTSA for certification.
(b) Trailer Aerodynamic Performance Testing
As discussed earlier, manufacturers of trailers subject to
performance standards (i.e., most box vans), need to provide EPA with
aerodynamic performance data at the time of certification. The purpose
of our trailer aerodynamic test procedures is to establish an estimate
of the aerodynamic drag experienced by a tractor-trailer vehicle in
real-world operation. We based these procedures on the current tractor
aerodynamic procedures, including coastdown, wind tunnel, and
computational fluid dynamics (CFD) modeling. More specifically, the
tests are conducted according to the same test procedures for tractors
and trailers, but different provisions apply for the test articles and
the data analysis. In the tractor program, the resulting CdA
value represents the absolute aerodynamic drag of a tested tractor
assumed to be pulling a specified standard trailer. In the trailer
program,
[[Page 73668]]
the tests measure the difference in CdA value between the
tested trailer as pulled by a standard tractor and a reference trailer
pulled by the same standard tractor. In other words, the trailer test
procedure is intended to measure the aerodynamic improvements rather
than the absolute aerodynamic performance. The agencies chose to base
the standards on measurements of aerodynamic improvements in part to
reflect the market reality that many trailer manufacturers rely on
manufacturers of bolt-on aerodynamic devices for the improvements
rather than redesigning their trailer or developing their own
components.
To minimize the testing burden, the program specifies that all
aerodynamic devices for long box vans (i.e., those greater than 50-feet
in length) be evaluated based on 53-foot box vans, and that devices for
all trailers 50-feet and shorter be evaluated based on 28-foot box
vans. In other words, a manufacturer can use test data from a single
trailer to certify all trailers in the same subcategory. As noted
previously in Section IV.D.(1) and demonstrated in Chapter 2.10.2.1.2.6
of the RIA, the performance of aerodynamic devices on these two trailer
lengths is expected to provide a conservative estimate of the
performance on the longer trailers within the same length category. We
believe that this compliance approach effectively represents the
performance of such devices on the majority of box vans, yet limits the
number of such vans that a manufacturer needs to track and evaluate.
The program provides for manufacturers to have flexibility in the
devices (or packages of devices) they install on box vans with lengths
that differ from 53-feet or 28-feet. In such situations, a manufacturer
could use devices that they believe would be more appropriate for the
length of the trailer they are producing, consistent with good
engineering judgement. For example, they could test skirts on a 28-foot
trailer and use longer skirts on 40-foot trailers that they make. No
additional testing would be required in order to validate the
appropriateness of using the alternate devices on these trailers.
The agencies have structured the final regulations to make wind
tunnel testing the primary method for measuring trailer aerodynamic
performance. While coastdown testing measures performance of full-scale
vehicles, which is generally the agencies' preference for performance
testing, wind tunnel testing achieves similar results in terms of delta
CdA, with the added benefit of measuring wind-averaged
values in the same test. In addition, wind tunnel testing is
inexpensive relative to other aero test methods and does not require as
much time to complete. Thus, it has generally been the preferred method
for the trailer industry. Nevertheless, the program provides for
manufacturers to use coastdown or CFD methods as described below and
fully in 40 CFR 1037.526(b) and 1037.150(x).
The agencies considered making coastdown testing the primary test
method for trailers, as it is for the tractor program. However, the
delta CdA approach for the trailer aerodynamic program would
require multiple tests to evaluate most configurations. Coastdown
testing is a full-scale test method that requires the vehicle, which
includes the trailer and an appropriately aerodynamic tractor, be
driven on a road or track that meets specified conditions. An important
challenge with coastdown testing is that wind and weather restrictions
can limit the days in which testing can be performed. Additionally,
coastdown testing has higher natural variability due to environmental
variability in an uncontrolled system. We have placed an additional
restriction on the allowable difference in yaw angles for delta
CdA measurements to reduce this variability (see 40 CFR
1037.526(a)(2)). However, the combination of our test constraints
(e.g., restrictions on the wind, temperature, and road conditions), can
make it challenging to measure a drag difference from two valid
coastdown tests. These factors would make accurate coastdown testing
for the trailer program even more time-consuming and expensive relative
to the tractor program. Accordingly, we decided that wind tunnel
testing is more appropriate for this newly regulated industry.
Coastdown testing has two significant advantages over wind tunnel
testing. First, as a full-scale method, it can be directly applied to
actual products. Second, full-scale methods may be the only way to
reliably test small-scale devices that cannot be appropriately scaled
or recreated in wind tunnel or CFD. Although these advantages justify
allowing coastdown testing as an alternate method, they do not justify
the additional costs that would occur if it were specified as the
primary test method for trailers.
In making this determination, the agencies were cognizant of the
limited financial ability of trailer manufacturers (and device
manufacturers) to absorb testing costs. Unlike the tractor industry,
most of the manufacturers in the trailer industry are small- to medium-
sized companies. Even the largest trailer manufacturers are much
smaller than the companies that manufacture tractors. Had we
established coastdown as the primary method, trailer manufacturers
would have needed to not only perform extensive coastdown testing to
show equivalency with their preferred methods, but would have also
needed to maintain the ability to perform coastdowns on a regular basis
like tractor manufacturers are required to under Phase 1 and Phase 2,
including owning or maintaining access to an appropriate test tractor
or tractors. While this is a manageable burden for the large tractor
manufacturers, it would have been a substantial burden for trailer
manufacturers, especially the smaller ones. TTMA commented that any of
the larger manufacturers in its membership that may do testing would
prefer wind tunnel or CFD testing to ``contain costs.'' In conjunction
with the NODA, EPA laid out principles related to aerodynamic testing
that we intended to follow when applying our compliance oversight to
trailers.\370\ In particular, we indicated that we intended to rely
more on our own confirmatory testing, recognizing that both trailer
manufacturers and device manufacturers have less financial ability to
perform Selective Enforcement Audit (SEA) testing than do tractor
manufacturers (see Section IV.E.(4)(f) for more information on SEAs).
Under the final regulations, the agencies can perform wind tunnel
testing, but would also retain the right to perform coastdown testing,
provided we adjusted any coastdown results to account for yaw
differences. If we conducted confirmatory testing using coastdowns, we
would also need to perform enough runs to minimize variability between
the test conditions. Should we measure worse aerodynamic performance
(after fully adjusting for methodological differences and accounting
for test-to-test variability), we would require the manufacturer to use
our test results as the official test results. It is important to
emphasize that, because confirmatory testing generally occurs before we
have issued a certificate of conformity and before the manufacturer has
begun production, there are no penalties or other compliance actions
that would result from EPA confirmatory testing. Thus, we do not expect
manufacturers using wind tunnels to have any need to
[[Page 73669]]
separately verify their results using coastdown procedures.
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\370\ ``Additional Discussion of Selective Enforcement Audit and
Confirmatory Testing for Aerodynamic Parameters for Combination
Tractors and for Trailers,'' February 19, 2015. Docket EPA-HQ-OAR-
2014-0827-1625.
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Details of the test procedures can be found in 40 CFR 1037.526 and
a discussion of EPA's aerodynamic testing program as it relates to the
trailer program is provided in the RIA Chapter 3.2. The following
subsections outline the testing requirements for the long term trailer
program, as well as simpler testing provisions that apply in the nearer
term.
(i) A to B Testing for Trailer Aerodynamic Performance
The agencies expect a majority of the aerodynamic improvements for
trailers will be accomplished by adding bolt-on technologies. As just
explained above, a key difference between the tractor program and the
trailer program is that while the tractor test procedures provide a
direct measurement of an absolute CdA value for each tractor
model, aerodynamic improvements for trailers are evaluated by measuring
a change in CdA (delta CdA) relative to a
baseline without aerodynamic improvements. Specifically, trailer tests
are performed as ``A to B'' tests, comparing the aerodynamic
performance of a tractor-trailer without a trailer aerodynamic device
(or package of devices) to one with the device (or package) installed.
As noted below, this approach can be applied if changes are made to the
aerodynamic design of a trailer as well. See RIA Chapter 2.10.2.1.2 for
more justification for this A to B approach.
In essence, an A to B test is a pair of tests: one test of a
baseline tractor-trailer in a ``no-control'' configuration with zero
trailer aerodynamic improvements (A), and one test that includes the
aerodynamic improvements to be tested (B). However, because an A test
relates to a B test only with respect to the test method and the basic
tractor-trailer vehicle, one A test could be used for many different B
test configurations. This type of testing results in a delta
CdA value instead of an absolute CdA value. For
the trailer program, the vehicle configuration in the A test includes a
standard tractor that meets specified characteristics (40 CFR
1037.501(h)), and a baseline trailer with no aerodynamic improvements.
The entity conducting the testing (e.g., the trailer manufacturer, a
contractor, or an aerodynamic device manufacturer, as discussed below)
performs the test for this configuration according to the procedures in
40 CFR 1037.526 and repeats the test for the B configuration, which
includes the trailer aerodynamic package/device(s) being tested. The
delta CdA value for that trailer with that aerodynamic
improvement is the difference between the CdA values
obtained in the A and B tests.
The agencies note that it was relatively straightforward in Phase 1
to establish a standard trailer with enough specificity to ensure
consistent testing of tractors, since there are relatively small
differences in aerodynamic performance of base-model dry box vans.
However, as discussed in Chapter 2.10 of the RIA, small differences in
tractor design can have a significant impact on overall tractor-trailer
aerodynamic performance. An advantage of an A to B test approach for
trailers is that many of the effects due to differences in tractor
design are minimized, which allows different models of tractors to be
used as standard tractors in testing without compromising the
evaluation of the trailer aerodynamic technology. Thus, the relative
approach does not require the agencies to precisely specify a standard
tractor, nor does it require trailer manufacturers to purchase, modify
or retain a specific tractor model in order to evaluate their trailers.
In the event that a trailer manufacturer makes major changes to the
aerodynamic design of its trailer in lieu of installing add-on devices,
it could use the same baseline trailer for the A configuration as could
be used for bolt-on features. In both cases, the baseline trailer would
be a manufacturer's standard box van. Thus, the manufacturer of a
redesigned trailer would get full credit for any aerodynamic
improvements it made.
As discussed in Chapter 2.10 of the RIA, measured drag coefficients
and drag areas can vary slightly depending on the test method used. In
general, absolute wind-averaged CdA values measured using
wind tunnels and CFD tend to be higher than values measured using the
near-zero yaw coastdown method. The Phase 1 and Phase 2 tractor program
use coastdown testing as the reference test method, and the agencies
require tractor manufacturers to perform at least one test using that
method to establish a correction factor to apply to each of the
alternative test methods. The proposed trailer regulations referred to
coastdown as our reference method, although we noted that the size of
the bins and the use of delta CdA (as opposed to absolute
values) minimized the significance of variability between test methods.
80 FR 40280. CARB recommended that we require a reference method in our
aerodynamic testing, but provided no data to support their
recommendation.
As noted already, the agencies have established the wind tunnel
method as the primary method. Like the tractor program, the allowance
to use alternate aerodynamic test procedures provides for adjustments
to make the measurements equivalent to the primary method. This is done
to ensure that the manufacturer is neither advantaged nor disadvantaged
by using the alternate method, relative to results they would have
obtained using the primary method. However, because determining
equivalency between methods can be burdensome, the agencies are
adopting in 40 CFR 1037.150(x) an interim allowance to use certain
specific approximations based on data currently available to us.
Manufacturers would not be required to justify using these
approximations or to seek prior approval for them. Nevertheless, in the
unlikely event that we determine that these approximations overstate
actual aerodynamic performance for a particular trailer or device, we
would not allow the manufacturer to use the approximated values for
certification and they would be required to use other more reasonable
adjustments.
Our test results shown in Chapter 2.10 of the RIA, show that wind
tunnel and CFD produce wind-averaged delta CdA values within
the same bin for the devices tested. Thus, this interim provision
allows CFD results to be used without adjustment. Coastdown delta
CdA results, which are not wind-averaged, may be in the same
bin, but we note that the tails showed more yaw dependence and
coastdown tests under-predicted the performance of tails relative to
wind-averaged methods. We anticipate some additional current and future
devices may be sensitive to yaw angle, and our interim provision
accounts for this. Manufacturers that choose to use coastdown testing
can use their results without adjustment, or, if they suspect their
device is affected by yaw angle, they can use other testing or
analytical methods to demonstrate a means of adjusting their near-zero
yaw results to a wind-averaged equivalent 4.5-degree value. The bin
values in Section IV.E.(3)(b)(iv), which were updated based on
additional aerodynamic test data collected between the NPRM and final
rules, are based on our wind tunnel testing results, though our results
suggest that most CFD and coastdown results will fit into the same
bins. See RIA Chapter 2.10.2.1.3.
(ii) Standard Tractor for Aerodynamic Testing in the Trailer Program
The agencies are adopting a set of characteristics that qualify a
tractor to be use in trailer aerodynamic compliance testing. EPA's
trailer testing program investigated the impact of
[[Page 73670]]
tractor aerodynamics on the performance of trailer aerodynamic
technologies, as mentioned in Chapter 2.10.2.1.2.2 of the RIA. We found
the A to B test strategy reduces the degree of precision with which the
standard tractor needs to be specified. Instead of identifying a
specific make and model of a tractor to be used over the entire
duration of the program, the agencies identified an appropriate
aerodynamic performance threshold that maintains a relatively
consistent level of performance between trailers. Tractors used in
trailer aerodynamic tests must meet Phase 2 aerodynamic Bin III or
better tractor requirements. We believe the majority of tractors in the
U.S. trucking fleet will be Bin III or better in the timeframe of this
rulemaking, and trailer manufacturers have the option to choose higher-
performing tractors in later years as tractor technology improves. See
Section III.D.2.c.i. The standard tractor for long-box vans is a Class
8 high-roof sleeper cab. The standard tractor for short box vans is a
Class 7 or 8 high roof day cab with a single drive axle (i.e., 4x2 axle
configuration). Trailer or device manufacturers are free to choose any
standard tractor that meets these criteria in their aerodynamic
performance testing. See 40 CFR 1037.501.
The compliance equation used to determine compliance with the
trailer standards is based on GEM, so our discussion of the feasibility
of our standards (Section IV.D.(2)) includes a description of the
tractor-trailer vehicle used in GEM. The agencies proposed to require
use of a 6x4 Class 8 sleeper cab for long box van aerodynamic testing,
and a 6x4 Class 8 day cab for short box van testing. 80 FR 40279. We
believe Class 8 tractors are more widely available, which will make it
easier for the trailer industry to obtain a qualified tractor if they
choose to perform trailer testing. In order to align with the test
procedures, we also proposed to consistently model a Class 8 tractor
across all trailer subcategories in GEM. CARB supported the use of
Class 8 tractors in their comments. However, EPA encountered difficulty
in meeting the test procedure-specified tractor-trailer gap width when
using a dual drive axle day cab in one of our short box van wind tunnel
tests due to the location of the landing gear relative to the kingpin.
As a result, we are changing the standard tractor specifications for
aerodynamic testing to require the use of a 4x2 tractor for short
trailers. While we expect most manufacturers will use tractor-trailer
models in wind tunnel or CFD testing, we recognize that there are fewer
4x2 tractors available for full-scale testing, and we are adopting
provisions that testers can use either a Class 8 or Class 7 day cab
tractor to address availability concerns. We believe the external
aerodynamic characteristics of Class 7 and Class 8 day cabs are very
similar and the engine performance differences between the two tractor
classes would not impact the aerodynamic performance in terms of delta
CdA. Note that a Class 7 4x2 day cab tractor is used for all
short van default tractor-trailer vehicles within GEM and represented
in the GEM-based equation (see Table IV-8).
Daimler requested that we choose a single tractor for all trailer
testing to ensure consistency over time. As stated above, the agencies
agree that the tractor does have the potential to influence the
aerodynamic performance of trailers. As discussed above, however, we
believe that influence is reduced with use of a delta CdA.
Additionally, we believe it would be a significant burden on the
trailer industry to require manufacturers and suppliers to acquire a
specific tractor make and model over the timeframe of the rules. Thus,
the final trailer program does not require the use of a specific
tractor make for the Phase 2 trailer program.
(iii) Accounting for Wind Impacts When Measuring Aerodynamic
Performance
The agencies proposed to determine the delta CdA for
trailer aerodynamic performance using the zero-yaw (or head-on wind)
values from any of the approved test procedures. However, based on
comments received, we are revising the final program to be based on
wind-averaged results, similar to the tractor program. The agencies
recognize the value of wind-averaging to better reflect the performance
expected in real-world operation, but at the time of proposal, we
believed the use of a zero-yaw delta CdA would reduce the
number of tests compared to generating a wind-averaged value from a
sweep of yaw angles. Additionally, it is relatively straightforward to
generate wind-averaged CdA values from wind tunnel and CFD,
but there is a significant increase in test burden to obtain wind-
averaged results from coastdown tests. Our intent was to ensure parity
between test procedures, such that manufacturers would have the several
options to test aerodynamic performance.
The agencies received comment on this issue, in the context of the
proposed tractor standards, suggesting that the CdA measured
at a yaw angle of 4.5 degrees is very similar to the wind-averaged
CdA calculated at 7 degrees/65 MPH. The agencies evaluated
our own test data using an average of +4.5 degrees and -4.5 degrees to
minimize the effect of potential facility asymmetry, and found that the
results were within two percent of the corresponding wind-averaged
values (See Section III.E.2.a and Chapter 3.2 of the RIA). Adoption of
this surrogate angle approach reduces the cost of generating a wind-
averaged value from wind tunnel and CFD procedures.\371\ Consequently,
the tractor program uses an average CdA measured at +4.5 and
-4.5 degree yaw angles as a surrogate wind-averaged value (see RIA
Chapter 3.2 for more information). However, it does not address the
increased burden for conducting coastdown tests.
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\371\ CFD test contracts are often priced for individual yaw
angles. Wind tunnel test contracts are often priced for an entire
yaw sweep. Limiting our measurement requirement to one or two yaw
angles is expected to reduce the cost of generating a wind-averaged
value from CFD, but will only reduce the cost from wind tunnel tests
if the manufacturer choses to do individual yaw angles in lieu of
the customary sweep.
---------------------------------------------------------------------------
The agencies received comment from TTMA that ``repetitive''
coastdown testing would rarely be used by its trailer manufacturer
members. Instead, manufacturers that do choose to perform their own
testing will likely rely on CFD and wind tunnel tests. Because we are
establishing the wind tunnel method as the primary method, and because
we expect it to also be the most commonly used method, we no longer
have test burden concerns about requiring wind-averaging. Therefore,
the agencies believe we can adopt aerodynamic test procedures for
trailers that require wind-averaged delta CdA values, as
represented by an average of results from +4.5 and -4.5 degree yaw
angles, for compliance. We believe that coastdown testing will be
chosen by a small number of manufacturers and the burden of performing
this optional test on the overall industry will be relatively small.
EPA may rely on coastdown testing in its own confirmatory testing, and
the agency will accept the additional burden of correcting to a wind-
averaged value.
(iv) Bins for Aerodynamic Performance
As mentioned in Section IV.D., the trailer program uses aerodynamic
bins to account for testing variability and to provide consistency in
the performance values used for compliance. We developed these bins in
terms of delta CdA ranges, and we designed them to be broad
enough to cover the range of uncertainty seen in our aerodynamic
testing program in terms of test-to-test variability as well as
variability due to
[[Page 73671]]
differences in test method, tractor models, trailer models and device
models. The bins are somewhat different than in the proposal, as
discussed in Section IV.D.(1)(a)(ii) above RIA Chapter 2.10.2.1.3.
Table IV-25--Aerodynamic Bins Used To Determine Inputs for Trailer
Certification
------------------------------------------------------------------------
Delta CdA
Delta CdA measured in testing Bin input for
compliance
------------------------------------------------------------------------
<0.1............................... Bin I................. 0.0
0.10-0.39.......................... Bin II................ 0.1
0.40-0.69.......................... Bin III............... 0.4
0.70-0.99.......................... Bin IV................ 0.7
1.00-1.39.......................... Bin V................. 1.0
1.40-1.79.......................... Bin VI................ 1.4
>=1.8.............................. Bin VII............... 1.8
------------------------------------------------------------------------
A manufacturer that wishes to perform testing first identifies a
standard tractor according to 40 CFR 1037.501(h) and a representative
baseline trailer with no aerodynamic features (or models of these
vehicles), then performs the A to B tests with and without aerodynamic
improvements to obtain a delta CdA value. The manufacturer
uses Table IV-25 to determine the appropriate bin based on their
measured delta CdA. Each bin has a corresponding delta
CdA threshold value that is the value manufacturers insert
into the compliance equation.
(v) Aerodynamic Device Testing Compliance Path
The agencies recognize that much of the trailer manufacturing
industry may have little experience with aerodynamic performance
testing. For this reason, the program includes a compliance option that
we believe minimizes the testing burden for trailer manufacturers, and
at the same time meets the requirements of the Clean Air Act and of
EISA by providing reasonable assurance that the anticipated
CO2 and fuel consumption benefits of the program will be
realized in real-world operation. This approach provides an opportunity
for trailer manufacturers to choose technologies with pre-approved test
data for installation on their new trailers without performing their
own aerodynamic testing. We note that this testing option is consistent
with recommendations of the Small Business Advocacy Review (SBAR)
Panel, which is summarized in Section XIV.D and Chapter 12 of the RIA.
The trailer program provides for trailer aerodynamic device
manufacturers to seek preliminary approval of the performance of their
devices (or combinations of devices) based on the same performance
tests described previously. Trailer manufacturers could then choose to
use these devices and apply the approved performance levels in the
certification application for their trailer families. A device
manufacturer would need to perform the required A to B testing using a
tractor-trailer that meets the requirements specified in 40 CFR
1037.211 and 1037.526 and submit the performance results, in terms of
delta CdA, directly to EPA.\372\ EPA would require much of
the same information from the device manufacturers as it would normally
require during certification, including the technology name, a
description of its proper installation procedure, and its corresponding
delta CdA derived from the approved test procedures. See 40
CFR 1037.211.
---------------------------------------------------------------------------
\372\ Note that in the event a device manufacturer submits false
or inaccurate data to EPA, it could incur liability for causing a
regulated entity to commit a prohibited act. See 40 CFR 1068.101(c).
This same potential liability exists with respect to information
provided by a device manufacturer directly to a trailer
manufacturer.
---------------------------------------------------------------------------
Once a device manufacturer has obtained this preliminary approval,
it could supply the same information to any trailer manufacturers that
wish to install its devices. When the trailer manufacturer certifies,
the agencies would merely verify that the values in the trailer
manufacturer's certification application are those already approved for
the device manufacturer. To ease the transition for MYs 2018 through
2020, we proposed and are adopting a flexibility to allow pre-approval
of certain data accepted by the EPA SmartWay aerodynamic verification
program. Section IV.E.(5)(c) below describes how a device manufacturer
can use certain test data generated for SmartWay verification as a part
of its pre-approval in the early years of the program.
The program also allows trailer manufacturers to use multiple
devices with individually pre-approved test data on a single trailer
configuration, provided each device does not impair the effectiveness
of the other(s), consistent with good engineering judgment.\373\ 40 CFR
1037.211 outlines a process for combining the effects of multiple
devices to determine an appropriate delta CdA value for
compliance. More specifically, manufacturers would fully count the
technology with largest delta CdA value, discount the second
by 10 percent, and discount each of the remaining additional
technologies by 20 percent. This discounting acknowledges the complex
interactions that can occur among individual aerodynamic devices and
provides a conservative value for the impact of the combined devices
(see the analysis of device combinations in RIA Chapter 2.10). For
example, a manufacturer applying three separately tested devices with
delta CdA values of 0.40, 0.30, and 0.10 would calculate the
combined delta CdA as:
---------------------------------------------------------------------------
\373\ A trailer manufacturer needs to use good engineering
judgement (as defined in 40 CFR 1068.5) in combining devices for
compliance in order to avoid combinations that are not intended to
work together (e.g., both a side skirt and an under-body device).
---------------------------------------------------------------------------
Delta CdA = 0.40 + 0.90*0.30 + 0.80*0.10 = 0.75 m\2\
The agencies believe that discounting the delta CdA
values of individually-tested devices used as a combination provides a
modest incentive for trailer or device manufacturers to test and get
EPA pre-approval of the combination as an aerodynamic system for
compliance. To avoid this discounting, device manufacturers can test a
trailer incorporating a combination of devices and receive EPA pre-
approval for data from that combination. Trailer manufacturers could
then use the test results from that specific combination for
certification.
Note that the aerodynamic bins of Table IV-25 do not apply to
aerodynamic data that device manufacturers submit to EPA for pre-
approval. The pre-approved data will have greater precision than the
bin-averaged values shown in Table IV-25. Therefore, trailer
manufacturers calculating a delta CdA value based on
combinations of pre-approved data use the exact numbers submitted by
the device manufacturers to calculate the discounted delta
CdA, and thus select an appropriate bin value for compliance
based on that result. The process to obtain approval is outlined in 40
CFR 1037.211.
The agencies note that many of the largest van manufacturers are
already performing aerodynamic test procedures to some extent, and the
agencies expect other van manufacturers will increasingly be capable of
and interested in performing these tests as the program progresses. The
device testing approach is intended to allow trailer manufacturers to
focus on and become familiar with the certification process in the
early years of the program and, if they wish, begin to perform testing
in the later years, when it may be more appropriate for their
individual companies. This approach does not preclude trailer
manufacturers from performing their own testing at any time, even if
the technologies they wish to install are already pre-approved. For
[[Page 73672]]
example, a manufacturer that believed a specific trailer actually
performed in a more synergistic manner with a given device than the
device's pre-approved delta CdA value suggested could
perform its own testing and submit the results to EPA for
certification.
STEMCO, an aerodynamic device manufacturer, commented in support of
the proposed pre-approval option, but also supported the agencies
publishing information about the testing performed by device
manufacturers for their devices to be pre-approved. The agencies are
not committing to publish the pre-approved aerodynamic data at this
time. We do note that once data are submitted to EPA and the device is
introduced into commerce, the data are available to the public at their
request and the information gathered may be published by outside
stakeholders.
(4) Additional Certification and Compliance Provisions
(a) Trailer Useful Life
Section 202(a)(1) of the CAA specifies that EPA is to propose
emission standards that are applicable for the ``useful life'' of the
vehicle. NHTSA is adopting EPA's proposed useful life requirements for
trailers, to ensure that manufacturers consider in their design process
the need for fuel efficiency standards to apply for the same duration
as the EPA standards. Based on our own research and discussions with
trailer manufacturers, EPA and NHTSA are adopting a regulatory useful
life value for trailers of 10 years, as proposed. This useful life
value represents the average duration of the initial use of trailers,
before they are moved into less rigorous duty (e.g., limited use or
storage). We note that the useful life value is 10 years or a mileage
threshold for other heavy-duty vehicles. However, unlike for the other
vehicles, the program does not include a parallel mileage value for
trailers. This would require odometers on trailers, and we do not
believe that mandating odometers would be appropriate for this purpose.
With this useful life provision, trailer manufacturers are
responsible for designing and building their trailers so that they will
be able to meet the CO2 emissions and fuel consumption
standards for 10 years after the trailer is produced, provided that
they are properly maintained. For technologies at issue here, we
believe that this requirement is essentially the same as customers'
existing durability expectations. The useful life requirements do not
include liability for damage to or removal of devices by users.
Instead, trailer manufacturers must ensure at the time of sale that
devices are properly installed and able to maintain functionality
throughout the useful life. We believe that manufacturers will be able
to demonstrate at certification that their trailers, including all
bolt-on technologies used as emissions controls, will comply with the
CO2 and fuel consumption standards for the useful life of
the trailers without separate durability testing. The aerodynamic
technologies that we expect manufacturers to use to comply with the
trailer standards, including side skirts and boat tails, are designed
to continue to provide their full potential benefit indefinitely as
long as no serious damage occurs.
Regarding a useful life value for trailer tires, we recognize that
the original lower rolling resistance tires will wear over time and
will be replaced several times during the useful life of a trailer,
either with new or retreaded tires. As with the Phase 1 tractor
program, to help ensure that trailer owners have sufficient knowledge
of which replacement tires to purchase in order to retain the as-
certified emission and fuel consumption performance of their trailer
for its useful life, the trailer program requires that trailer
manufacturers supply adequate information in the owners manual to allow
the trailer owner to purchase replacement tires meeting or exceeding
the rolling resistance performance of the original equipment tires.
(Note that the ``owners manual'' need not be a physical document, but
could be made available on line). We believe that the favorable fuel
consumption benefit of continued use of LRR tires generally results in
proper replacements throughout the 10-year useful life. Finally, the
program requires that tire pressure systems remain effective for at
least the 10-year useful life, although some servicing may be necessary
by the customer. See also the related discussions below in Section
IV.E.(4)(c) (Emission-Related Warranty) and Section IV.E.(4)(d)
(Maintenance).
(b) Emission Control Labels
Historically, EPA-certified vehicles are required to have a
permanent emission control label affixed to the vehicle. The label
facilitates identification of the vehicle as a certified vehicle. For
the trailer program, EPA requires that the labels include the same
basic information as we require for tractor labels in Phase 1. For
trailers, this information includes the manufacturer, a trailer
identifier such as the Vehicle Identification Number, the trailer
family and regulatory subcategory, the date of manufacture, and
compliance statements. Although the Phase 2 label for tractors does not
include emission control system identifiers (as previously required for
tractors in the Phase 1 program in 40 CFR 1037.135(c)(6)), the trailer
program requires that these identifiers be included in the trailer
labels. See 40 CFR 1037.135 for a list of general requirements for
emissions labels, which includes a reference to Appendix III for
appropriate abbreviations for trailer technologies.
(c) Emission-Related Warranty
Section 207 (a) of the CAA requires manufacturers to warrant their
products to be free from defects that could otherwise cause non-
compliance with emission standards. For purposes of the trailer
program, EPA requires trailer manufacturers to warrant all components
that form the basis of the certification to the CO2 emission
standards. The emission-related warranty covers all aerodynamic
devices, lower rolling resistance tires, tire pressure systems, and
other components that may be included in the certification application.
Note that the emission-related warranty is completely separate from any
other warranties a manufacturer might offer.
The trailer manufacturer needs to warrant that these emission-
related components and systems are designed to remain functional for
the warranty period. We note that this emission-related warranty, and
the trailer manufacturer's financial responsibility for repairs, does
not apply to components that are damaged in collisions or through
abuse; nor does it cover components that experience wear with normal
use. This warranty is meant to apply to defects in the product or
improper installation by the manufacturer. Based on the historical
practice of requiring emissions warranties to apply for half of the
useful life, we are adopting a warranty period for trailers of five
years for everything except tires. For trailer tires, we apply a
warranty period of one year.
Utility and Great Dane noted in their comments that the warranty of
current ATIS that they are aware of is limited to three years. However,
we view this as a business decision by the ATIS manufacturers, rather
than as a reflection of the actual durability of the systems. With
proper maintenance, we are aware of no reason that these systems would
be unable to meet the durability requirements of the trailer program or
to be designed to last the full useful life of the trailer if properly
maintained. See the Maintenance
[[Page 73673]]
discussion at IV.E.(4)(d) below. We believe a five year emission-
related warranty is justified, but we note that trailer manufacturers
can specify that their warranty depends on the proper maintenance of
components. Manufacturers can offer a more generous warranty if they
choose; however, the emission-related warranty may not be shorter than
any other warranty they offer without charge for the trailer. NHTSA is
not adopting any warranty requirements relating to its trailer fuel
consumption program.
At the time of certification, manufacturers need to supply a copy
of the warranty statement that they supply to the end customer. This
document outlines what is covered under the GHG emissions related
warranty as well as the duration of coverage. Customers also need to
have clear access to the terms of the warranty, the repair network, and
the process for obtaining warranty service.
(d) Maintenance
In general, EPA requires that vehicle manufacturers specify
schedules for any maintenance needed to keep their product in
compliance with emission standards throughout the useful life of the
vehicle (CAA section 207(a)). For trailers, such maintenance could
include adjustments to fairings or service to tire pressure systems.
EPA believes that any such maintenance is likely to be performed by
operators to maintain the fuel savings of the components. If
manufacturers believe that the durability of their trailer's
performance is contingent on proper maintenance of these systems, they
must include a corresponding maintenance schedule in their
certification applications.
Since lower rolling resistance tires are key emission control
components under this program, and they will likely require replacement
at multiple points within the life of a vehicle, it is important to
clarify how tires fit into the emission-related maintenance
requirements. Although the agencies encourage the exclusive use of LRR
tires throughout the life of trailers vehicles, we do not hold trailer
manufacturers responsible for the actions of end users. We do not see
this as problematic because, as noted above, we believe that trailer
end users have a genuine financial motivation for ensuring their
vehicles are as fuel efficient as possible, which includes purchasing
LRR replacement tires and that they will continue to use them once they
are accustomed to their use. Therefore, as mentioned in Section
IV.E.(4) above, to help ensure that trailer owners have sufficient
knowledge of which replacement tires to purchase in order to retain the
as-certified emission and fuel consumption performance of their
trailer, the program requires that trailer manufacturers supply
adequate information in the owners manual to allow the trailer owner to
purchase tires meeting or exceeding the rolling resistance performance
of the original equipment tires. (As discussed above, note that the
``owners manual'' need not be a physical document, but could be made
available on line). Manufacturers submit these instructions to EPA as
part of the application for certification.
(e) Post-Useful Life Modifications
The Clean Air Act generally prohibits any person from removing or
rendering inoperative any emission control device installed for
compliance, such as those needed to comply with the requirements of 40
CFR part 1037. However, in 40 CFR 1037.655 EPA clarifies that certain
vehicle modifications are allowed after a vehicle reaches the end of
its regulatory useful life. This section applies to trailers, since it
applies to all vehicles subject to 40 CFR part 1037.
The provisions of 40 CFR 1037.655 clarify that owners may modify a
vehicle for the purpose of reducing emissions, provided they have a
reasonable technical basis for knowing that such modification will not
increase emissions of any other pollutant, but emphasizes that EPA
presumes such modifications to be more appropriate for second owners.
In the case of trailers, an owner would need to have information that
would lead an engineer or other person familiar with trailer design and
function to reasonably believe that the modifications will not increase
emissions of any regulated pollutant. In the absence of such
information, modifications during or after the trailer's useful life
would constitute tampering with an emission control system. Thus, this
provision does not provide a blanket allowance for modifications after
the useful life.
This section does not specifically apply with respect to
modifications that occur within the useful life period, other than to
note that many such modifications to the vehicle during the useful life
are presumed to violate CAA section 203(a)(3)(A). EPA notes, however,
that this is merely a presumption, and would not prohibit modifications
during the useful life where the owner clearly has a reasonable
technical basis for knowing the modifications will not cause the
vehicle to exceed any applicable standard.
(f) Confirmatory Testing and Selective Enforcement Audits (SEA) for GEM
Inputs
In Phase 2, vehicle performance for box vans (except non-aero box
vans) is measured using a GEM-based equation, which accepts input
parameters related to aerodynamics, tire rolling resistance, and
trailer weight. Trailer manufacturers are responsible for obtaining
performance measures for these parameters through valid testing
according to the specified test procedures. The Clean Air Act
authorizes EPA to perform its own testing to confirm the manufacturer's
data. This testing, which is called confirmatory testing, is conducted
prior to issuing a certificate. The Act also authorizes EPA to require
manufacturers to conduct Selective Enforcement Audits (SEA), which
would involve testing performed on production vehicles before they
enter into commerce.
The agencies are finalizing a list of lightweight trailer
components that can be installed by trailer manufacturers and used in
certification. Additionally, we are assigning a set percent reduction
value to qualifying tire pressure systems (i.e., ATIS and TPMS) that
manufacturers can apply if they install these systems. Thus, because
these are agency-default values rather than the manufacturers' measured
or declared values, we will not hold trailer manufacturers responsible
for the accuracy of these values. Additionally, we expect most trailer
manufacturers will obtain LRR tire information directly from the tire
manufacturers and many trailer manufacturers will install aerodynamic
devices with data that was pre-approved by EPA. Information provided by
a third party (such as a tire or device manufacturer) to a regulated
entity for compliance is treated as though it was submitted directly to
EPA. EPA has the authority to verify such data and hold the third party
responsible for any falsified data, since submission of such data could
incur liability for causing a regulated entity to commit a prohibited
act. See 40 CFR 1068.101(c).
Of all of the performance measures for trailers, we believe
aerodynamic testing has the greatest potential for variability and
these results are likely to receive the most scrutiny. In the NPRM, we
proposed to generally apply the same SEA and confirmatory testing
structures to tractors and trailer with respect to aerodynamics.
However, we also proposed to retain the authority to require component
manufacturers to perform SEAs where certification relies
[[Page 73674]]
on their test data. See, e.g. section 1037.301(d)(4) of the proposed
regulations.
We are revising the SEA and confirmatory testing structures for
trailers based on further consideration and comments received from the
trailer manufacturing industry (TTMA). In general, the final
regulations reflect the following principles:
Due to the smaller number of possible trailer
configurations (compared to tractor configurations), it would be more
possible for EPA to rely on confirmatory testing for trailer
aerodynamics.
Since test-to-test variability for individual coastdown
runs can be high, confirmatory test determinations should be based on
average values from multiple runs.
Trailer manufacturers and trailer component manufacturers
have less financial ability to perform SEAs than do tractor
manufacturers. Nevertheless, EPA should retain the authority to require
trailer and trailer component manufacturers to perform SEAs, especially
where EPA has reason to believe the trailers are non-compliant.
Given the limited ability to eliminate uncertainty,
compliance determinations should consider the statistical confidence
that a true value lies outside a bin.
EPA will generally try to duplicate a manufacturer's test setup in
any confirmatory testing (which would include the standard tractor)
unless we have reason to believe an inappropriate setup was used. While
our test results presented in Chapter 2.10 of the RIA show that the
trailer program's delta CdA approach reduces the tractor's
impact on trailer results, to the extent practical, EPA will use the
same standard tractors that manufacturers used in their testing.
We believe that, although the final compliance structure for
trailers is simpler than for tractors, it will still provide a strong
incentive for manufacturers to act in good faith. In particular, the
regulations emphasize the final value of EPA's auditing records and
inspecting production components, rather than requiring manufacturers
to perform expensive testing. Thus, EPA expects to require
manufacturers to perform SEA testing only when we have reasonable
evidence leading us to believe a manufacturer have not provided
accurate test data. See Section III.E.(2)(a)(ix) for a discussion of
how EPA would conduct an aerodynamic SEA.
(g) Importation of New Trailers
Manufacturers have raised concerns about enforcement of emission
standards for new trailers that are imported into the United States.
This poses unique challenges at the point of entry, because new
trailers may be carrying cargo and are therefore nearly
indistinguishable from trailers that have already been imported or
otherwise placed into service. We are not adopting any new or different
compliance provisions in this rulemaking to address this; however, we
intend to work cooperatively with Customs and Border Protection and
other agencies to ensure that first-time state registration of new
trailers includes verification that the trailer manufacturers have
certified them to meet U.S. emission and fuel consumption standards. We
expect this to be similar to the current system for ensuring that new,
imported trailers meet NHTSA safety standards.
A related concern applies for foreign-based trailers traveling in
the United States for importing or exporting cargo. Such trailers are
not subject to emission and fuel consumption standards unless they are
considered imported into the United States. U.S. cabotage law prohibits
foreign truck drivers from carrying product from one point to another
within the United States. Effective enforcement of this cabotage law
will help prevent manufacturers of noncompliant foreign-produced
trailers from gaining a competitive advantage over manufacturers of
compliant domestic trailers.
(5) Flexibilities
The trailer program that the agencies are adopting incorporates a
number of provisions that have the effect of providing flexibility and
easing the compliance burden on trailer manufacturers while maintaining
the expected CO2 and fuel consumption benefits of the
program. Among these is the basic approach we used in setting the
trailer standards, including the staged phase-in of the standards,
which gradually increase the CO2 and fuel consumption
reductions that manufacturers need to achieve over time as they also
increase their experience with the program. As described in Section
IV.E.(3)(b)(v), another of these is the process for device
manufacturers to submit test data directly to EPA for review by the
agencies in advance of formal certification, allowing a trailer
manufacturer to reduce the amount of testing needed to demonstrate
compliance or avoid it altogether.
In addition to these provisions inherent to the trailer program,
this section describes additional options the agencies are adopting
that we believe will be valuable to many trailer manufacturers.
(a) Limited Allowance of Non-Complying Trailers
As described in Section IV.B. above the agencies are not finalizing
the proposed provisions that would have allowed manufacturers to comply
with the trailer standards using averaging before MY 2027. As a result,
in the absence of mitigating provisions, manufacturers would need to
comply with the applicable standards for all of their trailers. The
agencies received comment, primarily from trailer manufacturers, that,
without the flexibility of averaging, trailer manufacturers should be
allowed to ``carve-out'' a set percentage of their sales that would not
be required to meet the standards. Stoughton Trailers suggested a 20
percent carve-out.
The agencies considered this concept and this final program
provides each manufacturer with a limited ``allowance'' of trailers
that do not need to meet the standards. In determining an appropriate
value for this allowance, the agencies sought to balance the need for
some degree of flexibility in the absence of averaging while minimizing
changes in the competitive relationships among larger and smaller
trailer manufacturers. An allowance of 20 percent, as suggested by
Stoughton, is problematic, since the annual production for individual
trailer manufacturers varies so widely. An allowance of 20 percent for
a very large manufacturer could very well represent the same volume of
trailers as an entire year's sales for a small manufacturer. This in
turn could result in a situation where a large number of non-complying
trailers would be on the market, potentially attracting customers away
from smaller manufacturers that needed to market complying trailers.
Because of this, the agencies estimated a representative volume of
trailers based on the 2015 Trailer Production Figures published by
Trailer-BodyBuilders.com.\374\ The smallest box van manufacturer in the
list produced 1800 dry freight vans in 2015. Twenty percent of that
production is 360 trailers. The agencies are adopting an interim
provision providing box van manufacturers an allowance of 20 percent of
their production (up to a maximum of 350 units) that are not
[[Page 73675]]
required to meet the standards for model years 2018 through 2026 when
we do not include averaging. All lengths of box vans, including both
dry and refrigerated, produced by a given manufacturer count toward the
allowance.
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\374\ 2015 Trailer Production Figures Table. Schenk, Paul. March
4, 2016. Accessed January 4, 2016. Available at: http://trailer-bodybuilders.com/trailer-output/2015-trailer-production-figures-table.
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While averaging does not apply for partial- and non-aero box
trailers at any point in the program, the agencies believe
manufacturers can also benefit from the ability to exempt some trailers
from these subcategories in the early years as they transition into the
full program. For MY 2018 through 2026, manufacturers can include
partial- and non-aero box trailers in their 350 box van allowance. In
MY 2027, we believe all partial- and non-aero box vans can meet the
reduced standards for their given subcategories.
Non-box trailers have design-based tire standards and averaging
thus does not apply for this subcategory. Similar to the partial- and
non-aero box vans, we also believe non-box manufacturers can benefit
from a transitional exemption allowance. The agencies are adopting a
separate allowance for non-box trailers, because their production
volumes differ and many non-box trailer manufacturers do not build box
vans. Using the same trailer production figures, we found that the
smallest non-box trailer manufacturer in the list produced 1325
trailers in 2015 and twenty percent of that production is 265 trailers.
From MY 2018 through 2026, non-box trailer manufacturers can exempt 20
percent or 250 trailers from the applicable tire standards. By MY 2027,
we believe all non-box trailers can incorporate the tire technologies
required by the design standards.
The agencies estimate that the box van and non-box trailer
allowances translate on average to less than two percent of production
across the trailer industry, and the agencies believe that this minor
degree of loss of emission and fuel consumption reduction benefits is
more than offset by the flexibility which, as pointed out earlier, may
be needed by this newly regulated industry segment. These allowances
are specified in 40 CFR 1037.150 and 49 CFR 535.3.
(b) Averaging Provisions for the Late Years of the Trailer Program
The agencies proposed to allow trailer manufacturers to use
averaging throughout the phase-in of the program as one option for
complying with the trailer standards. As noted, we received nearly
unanimous comments, in response to the pre-proposal SBREFA panel and to
the NPRM, from trailer manufacturers opposing averaging. Specifically,
the commenters cited their concern that the unique aspects of the
trailer market tend to mean that the value of averaging as a tool is
less than it has been for manufacturers in other industries, and the
potential for negative consequences to some manufacturers is
substantial. The trailer manufacturing industry is very competitive,
and manufacturers must be highly responsive to their customers' diverse
demands. Compared to other industry sectors, they can have little
control over what kinds of trailer models their customers demand and
thus limited ability to manage the mix and volume of different
products. Additionally, one of the larger, more diverse manufacturers
could potentially supply a customer with trailers that had few if any
aerodynamic features, while offsetting this part of their business with
over-complying trailers that they were able to sell to another
customer; many smaller companies with limited product offerings might
not be able to compete for those customers.
As a result of the many comments opposing averaging from trailer
manufacturers--the very stakeholders meant to benefit from an averaging
program--the agencies have reconsidered how averaging is incorporated
into the program. The final program does not allow averaging as a
compliance option in the early years of the program, in MY 2018 through
MY 2026. In those years, all box vans sold (beyond a manufacturer's
allowance of non-complying trailers) must meet the standards using any
combination of available technologies.
However, the agencies have concluded that by late in the program,
the value of an averaging option to many trailer manufacturers may well
outweigh the concerns they have expressed. In addition, the final stage
of the phase-in of the standards for MY 2027 represents the most
stringent standards in the program, and additional flexibility may be
welcome by trailer manufacturers. Therefore, the final program will
provide a limited optional averaging program for MY 2027 and later
full-aero box vans. By that time, we believe that the trailer
manufacturers will be experienced and comfortable with the program, and
the industry will be more familiar with the technologies.
The MY 2027 and later averaging provisions are identical in most
respects to those we proposed for the other Phase 2 vehicle programs.
One notable difference involves use of credits. As in the proposed
trailer program, the averaging provisions for trailers focus on each
individual model year's production. A manufacturer choosing to use the
averaging provisions could not ``bank'' compliance credits for a future
model year or ``trade'' (sell) credits to another manufacturer, since
these provisions would disproportionately benefit the few large trailer
manufacturers. Under these averaging provisions, a full-aero box van
manufacturer that produces some MY 2027 or later box vans that perform
better than required by the applicable standard could produce a number
of vans in the same family that do not meet the standards, provided
that the average compliance levels of the trailers it produces in any
given model year is at or below the applicable standards for that
family.
As in the proposed program, averaging is only available for full-
aero box vans. The program is already designed to offer reduced
standards for box vans designated as partial-aero, and the additional
flexibility of averaging is not available. Also, averaging is
inherently incompatible with design standards for non-aero box vans and
non-box trailers, since those manufacturers cannot choose among
compliance paths.
The agencies are adopting averaging sets for full-aero box vans
based on trailer length. Trailers in a family are certified to a single
standard, but individual trailers within the family may be grouped to
certify to a family emissions limit (FEL) that is higher or lower than
the standard, provided the production-weighted average of all FELs in a
family can be averaged to the standard or better. By allowing averaging
sets to include both refrigerated and dry vans similar length
categories, a manufacturer that over-complies, on average, in one
family, can use the credits generated toward compliance in the other
family. For example, if a manufacturer has two subfamilies in each of
its long dry and long refrigerated van families, and the over-
compliance of one dry van subfamily exceeds the under-compliance of the
other dry van subfamily, the additional over-compliance beyond the dry
van family's standard become credits that can be used to offset any
under-compliance in the refrigerated van family.
In order to avoid backsliding with the use of averaging, the
agencies are adopting a provision to require a minimum level of
technology adoption in MY 2027 and later. No FEL can exceed the MY 2018
standard for the given trailer subcategory. For example, a manufacturer
could not over-comply on some trailers and expect to produce a fraction
of their trailers with zero
[[Page 73676]]
technologies installed; every trailer must, at minimum, include enough
technologies to meet the corresponding MY 2018 standard. See 40 CFR
1037.107(a)(5) and 49 CFR 535.5(e).
As mentioned previously, manufacturers with a trailer family that
performed better than the standard at the end of the year would not be
allowed to bank credits for a future model year. However, the agencies
understand that it is possible for a manufacturer to misjudge
production and come up short at the end of the model year. In such a
case, the program provides for a manufacturer to generate a credit
deficit, if necessary, as a temporary recourse for unexpected
challenges in a given model year.\375\ The agencies would closely
monitor the certification applications for the following model year, to
ensure the manufacturer can make progress in reducing the deficit. Any
such credit deficits would need to be resolved within the following
three model years, and the manufacturer would need to generate credits
from over-compliance in subsequent years to address deficits from prior
model years. See 40 CFR 1037.745.
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\375\ Section IV.E.(1)(b) describes the process of identifying
trailer families and sub-families based on basic trailer
characteristics. 40 CFR 1037.710 describes the provisions for
establishing subfamilies within a trailer family and the Family
Emission Limits that are averaged among the subfamilies.
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The agencies believe that limiting the availability of averaging
provisions to the final stage of the program will ease a number of the
competitive concerns that trailer manufacturers have raised, since the
trailer program will be familiar and the value of averaging may be
greater as the most stringent standards phase in. Small business
manufacturers raised concerns in our pre-proposal small business
outreach that averaging would disproportionately benefit larger
manufacturers with larger production volumes and greater product
diversity. We are limiting our averaging program to single model year
averaging (i.e., no banking or trading) to help address this concern.
Similarly, we are adopting a maximum FEL based on the MY 2018 standard
to ensure that larger manufacturers will not be able to produce large
volumes of trailers with little or no technologies at the expense of
manufacturers that cannot accumulate sufficient over-compliance within
their annual production. To the extent that concerns about the MY 2027
and later averaging provisions remain as that model year approaches,
the agencies look forward to working with manufacturers as they
consider using averaging.
(c) Aerodynamic Device Testing Using SmartWay-Verified Data
The agencies expect some trailer manufacturers and aerodynamic
device manufacturers to continue to submit test data to the SmartWay
program for verification. Since many manufacturers have some experience
with EPA's SmartWay program, the agencies have designed the trailer
program and aerodynamic testing to recognize the significant synergy
with the SmartWay Technology Program. Section IV.E.(3)(b)(v) describes
the compliance path available to trailer manufacturers to use pre-
approved performance data for aerodynamic devices. As an additional
interim option, any device manufacturer that attains SmartWay
verification for a device prior to January 1, 2018 is eligible to
submit its previous SmartWay-verified data to EPA's Compliance Division
for pre-approval, provided their test results come from one of
SmartWay's 2014 test protocols that measure a delta CdA. The
protocols for coastdown, wind tunnel, and computational fluid dynamics
analyses result in a CdA value. Note that SmartWay's 2014
protocols allow SAE J1321 Type 2 track testing, which generates fuel
consumption results, not CdA values. Two commenters (a
device manufacturer and an NGO) requested that we allow SAE J1321 track
test results, but did not suggest a means of converting from the fuel
consumption results to an appropriate delta CdA value for
use in compliance. As a result, the agencies will not accept J1321 data
for pre-approval.
Beginning on January 1, 2018, EPA will require that device and
trailer manufacturers that seek approval of new aerodynamic
technologies for trailer certification use one of the approved test
methods for Phase 2 (i.e., coastdown, wind tunnel or CFD) and the test
procedures found in 40 CFR 1037.526. Aerodynamic technologies that were
pre-approved using performance data from SmartWay's 2014 Protocols will
maintain their approved status through December 31, 2020. Beginning
January 1, 2021, all pre-approval of device performance will need to be
based on testing using the Phase 2 test procedures.
(d) Off-Cycle Technologies
The Phase 1 and Phase 2 programs include provisions for
manufacturers to request the use of off-cycle technologies that are not
recognized in GEM and were not in common use before MY 2010. During the
development of the trailer proposal, the agencies were not aware of any
technologies that could improve CO2 and fuel consumption
performance that would not be captured in the trailer test protocols,
and we did not propose a process to evaluate off-cycle trailer
technologies. We continue to believe that effective trailer aerodynamic
technologies that would not be captured by the test protocols are
unlikely to emerge. However, Wabash provided comments requesting a
process for evaluating future trailer weight reduction options. They
suggested that these options could include lightweight components that
are not listed in our regulations as approved material substitution
components, or overall trailer weight reduction strategies that are not
limited to individual components.
In light of these comments and further consideration of the issue,
the agencies believe that the off-cycle technology process is an
appropriate way for certain box van manufacturers--that is, those using
the compliance equation and not subject to the design standards--to
receive credit for future lightweighting or other technologies that are
not recognized in the compliance equation. For this reason, we have
incorporated box vans into the existing off-cycle provisions. In the
case of lightweighting, a measured difference in trailer weight could
substitute for the weight component of the compliance equation. For
other such technologies (should any exist), the general off-cycle
provisions apply. See 40 CFR 1037.515(e).
(e) Small Business Regulatory Flexibility Provisions
As a part of our small business obligations under the Regulatory
Flexibility Act, EPA and NHTSA have considered additional flexibility
provisions aimed at this segment of the trailer manufacturing industry.
EPA convened a Small Business Advocacy Review (SBAR) Panel as required
by the Small Business Regulatory Enforcement Fairness Act (SBREFA), and
much of the information gained and recommendations provided by this
process form the basis of the proposed flexibilities.\376\ As in
previous rulemakings, our justification for including provisions
specific to small businesses is that these entities generally have a
greater degree of difficulty in complying with the
[[Page 73677]]
standards compared to other entities. Thus, as discussed below, we are
adopting several regulatory flexibility provisions for small trailer
manufacturers that we believe will reduce the burden on them while
achieving the goals of the program.
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\376\ Additional information regarding the findings and
recommendations of the Panel are available in Section XIV, Chapter
12 of the RIA, and in the Panel's final report titled ``Final Report
of the Small Business Advocacy Review Panel on EPA's Planned
Proposed Rule: Greenhouse Gas Emissions and Fuel Efficiency
Standards for Medium- and Heavy-Duty Engines and Vehicles: Phase 2''
(See Docket EPA-HQ-OAR-2014-0827).
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The agencies identified 178 trailer and tank manufacturers for our
analysis and we believe 147 qualify as small business (i.e., less than
1000 employees).\377\ The agencies designed many of the program
elements and flexibility provisions available to all trailer
manufacturers with the large fraction of small business trailer
manufacturers in mind. For the small van manufacturers, we believe the
option to choose pre-approved aerodynamic data will significantly
reduce the compliance burden and eliminate the requirement for all
manufacturers to perform testing. We are also limiting the final non-
box trailer program to tanks, flatbeds, and container chassis. All
other non-box trailers are exempt from the Phase 2 trailer program,
with no regulatory requirements. This exemption reduces the number of
small businesses in the trailer program from 147 to 74 companies at the
time of the development of this rulemaking. With no regulatory
requirements, these companies have zero burden under the trailer
program. We are also adopting the proposed design standards for the
remaining non-box trailers, such that they can certify by installing
tire technologies only, with no testing requirements. The agencies are
also adopting provisions that would increase the number of eligible
tire pressure systems that can be installed for compliance. In addition
to ATIS, TPMS is a recognized technology in the final rulemaking.
Furthermore, the non-box trailers, which have design-based tire
standards, comply if they have either a TPMS or an ATIS, and
appropriate lower rolling resistance tires. The inclusion of the less
expensive TPMS as a tire pressure system option will improve the
availability of technologies and reduce the technology cost for many
small businesses.
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\377\ In the period between the SBAR Panel and Initial
Regulatory Flexibility Analysis and issuing of the final rule, the
Small Business Administration (SBA) finalized new size standards for
small business classification. For trailers, the threshold to
qualify as small changed from 500 employees to 1000 employees. We
have updated our analysis to reflect the new size standards.
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As noted above, the small trailer manufacturers raised concerns
that their businesses could be harmed by provisions allowing averaging,
banking, and trading of emissions and fuel consumption performance,
since they will not be able to generate the same volume of credits as
large manufacturers. The agencies are not adopting banking and trading
provisions in any part of the program, and are limiting the option to
average to manufacturers of full-aero dry and refrigerated box trailers
and delaying the averaging until MY 2027. Similarly, we are adopting a
maximum FEL based on the MY 2018 standard to ensure that larger
manufacturers will not be able to produce large volumes of trailers
with little or no technologies at the expense of manufacturers that
cannot accumulate sufficient over-compliance within their annual
production. We expect that the familiarity of the industry, including
small business manufacturers, with the trailer program by this stage of
the program, and the requirement that all trailers meet at least the MY
2018 level of control, will reduce the concerns of small manufacturer
compared to an earlier or broader averaging program.
For all small business trailer manufacturers, the agencies are
adopting a one-year delay in the beginning of implementation of the
program, until MY 2019. We believe that this allows small businesses
additional needed lead time to make the necessary staffing adjustments
and process changes, and possibly add new infrastructure to meet the
requirements of the program. TTMA commented that all trailer
manufacturers are ``small businesses'' relative to other heavy-duty
industries and that the one-year delay would divert sales to small
businesses for that model year. Wabash argued that providing a
flexibility is not required by the RFA and not authorized by the Clean
Air Act. The agencies believe that small businesses do not have the
same resources available to become familiar with the regulations, make
process and staffing changings, or evaluate and market new technologies
as their larger counterparts. We believe a one-year delay provides
additional time for small businesses to address these issues, without a
large CO2 and fuel consumption impact or substantial
negative competitive effects. The cumulative annual production of all
of the small business box trailer manufacturers is estimated to be less
than 15 percent of the industry's total production, which is
significantly less than the annual production of the four largest
manufacturers.\378\ We expect any diverted sales for this one year will
be a small fraction of the large manufacturers' production and we are
finalizing the one-year delay for all small business trailer
manufacturers.
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\378\ See Figure 1-3 of Chapter 1 in the RIA comparing the 2015
trailer output from the top 28 trailer manufacturers.
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Chapter 12 of the RIA presents the agencies' Final Regulatory
Flexibility Analysis. In this chapter, we discuss the recommendations
of the Panel, what we proposed, and what we finalized for the small
businesses regulated in Phase 2. We also estimate the economic effect
of the rulemaking on these businesses based on their annual revenue.
Considering the flexibilities adopted in this rulemaking, our estimate
of compliance burden indicates that only 15 of the 147 small trailer
manufacturers (about 10 percent) will have an economic impact greater
than one percent of their annual revenue. Therefore, we believe the
trailer provisions in this rulemaking do not have a significant impact
on small businesses.
V. Class 2b-8 Vocational Vehicles
A. Summary of Phase 1 Vocational Vehicle Standards
Class 2b-8 vocational vehicles include a wide variety of vehicle
types, and serve a wide range of functions. Some examples include
service for urban delivery, refuse hauling, utility service, dump,
concrete mixing, transit service, shuttle service, school bus,
emergency, motor homes, and tow trucks. In the HD Phase 1 Program, the
agencies defined Class 2b-8 vocational vehicles as all heavy-duty
vehicles that are not included in the Heavy-duty Pickup Truck and Van
or the Class 7 and 8 Tractor categories. In effect, the rules classify
heavy-duty vehicles that are not a combination tractor or a pickup
truck or van as vocational vehicles. Class 2b-8 vocational vehicles and
their engines emit approximately 17 percent of the GHG emissions and
burn approximately 17 percent of the fuel consumed by today's heavy-
duty truck sector.\379\
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\379\ Memorandum to the Docket ``Runspecs, Model Inputs, MOVES
Code and Database for HD GHG Phase 2 FRM Emissions Modeling.''. July
2016. See also EPA's MOVES Web page at https://www3.epa.gov/otaq/models/moves/index.htm.
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Most vocational vehicles are produced in a two-stage build process,
though some are built from the ``ground up'' by a single entity. In the
two-stage process, the first stage sometimes is completed by a chassis
manufacturer that also builds its own proprietary components such as
engines or transmissions. This is known as a vertically integrated
manufacturer. The first stage can also be completed by a chassis
manufacturer who procures all
[[Page 73678]]
components, including the engine and transmission, from separate
suppliers. The product completed at the first stage is generally either
a stripped chassis, a cowled chassis, or a cab chassis. A stripped
chassis may include a steering column, a cowled chassis may include a
hood and dashboard, and a cab chassis may include an enclosed driver
compartment. Many of the same companies that build Class 7 and 8
tractors also sell vocational chassis in the medium heavy- and heavy
heavy-duty weight classes. Similarly, some of the companies that build
Class 2b and 3 pickups and vans also sell vocational chassis in the
light heavy-duty weight classes.
The second stage is typically completed by a final stage
manufacturer or body builder, which installs the primary load carrying
device or other work-related equipment, such as a dump bed, delivery
box, or utility boom. There are over 200 final stage manufacturers in
the U.S., most of which are small businesses. Even the large final
stage manufacturers are specialized, producing a narrow range of
vehicle body types. These businesses also tend to be small volume
producers. In 2011, the top four producers of truck bodies sold a total
of 64,000 units, which is about 31 percent of sales in that year.\380\
In that same year, 74 percent of final stage manufacturers produced
less than 500 units.
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\380\ Specialty Transportation.net, 2012. Truck Body
Manufacturing in North America.
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The businesses that act both as the chassis manufacturer and the
final stage manufacturer are those that build the vehicles from the
``ground up.'' These entities generally produce custom products that
are sold in lower volumes than those produced in large commercial
processes. Examples of vehicles produced with this build process
include fire apparatus and transit buses.
The diversity in the vocational vehicle segment can be primarily
attributed to the variety of customer needs for specialized vehicle
bodies and added equipment, 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 leads to
different in-use fuel consumption and GHG emissions. However, the
baseline fuel consumption and emissions due to the components included
in the common chassis (such as the engine, drivetrain, frame, and
tires) may be the same between these two types of vehicles.
Owners of vocational vehicles that are upfitted with high-priced
bodies that are purpose-built for particular applications tend to keep
them longer, on average, than owners of vehicles such as pickups, vans,
and tractors, which are traded in broad markets that include many
potential secondary markets. The fact that vocational vehicles also
generally accumulate far fewer annual miles than tractors further
contributes to lengthy trade cycles among owners of these vehicles. To
the extent vocational vehicle owners may be similar to owners of
tractors in terms of business profiles, they are more likely to
resemble private fleets or owner-operators than for-hire fleets. A 2013
survey conducted by NACFE found that the trade cycle of private tractor
fleets ranged from seven to 12 years.\381\
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\381\ See 2013 ICCT Barriers Report, Note 364 above.
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The Phase 1 standards for this vocational vehicle category
generally apply at the chassis manufacturer level. For the same reasons
given in Phase 1, the agencies are applying the Phase 2 vocational
vehicle standards at the chassis manufacturer level.\382\
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\382\ See 76 FR 57120.
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The Phase 1 regulations prohibit the introduction into commerce of
any heavy-duty vehicle without a valid certificate or exemption. 40 CFR
1037.622, originally codified as 40 CFR 1037.620, allows for a
temporary exemption for the chassis manufacturer if it produces the
chassis for a secondary manufacturer that holds a certificate. The
agencies received several comments on the requirements for secondary
manufacturers. A discussion of temporary exemptions and obligations of
secondary manufacturers can be found in Section V.D.(2).
In Phase 1, the agencies adopted two equivalent sets of standards
for Class 2b-8 vocational vehicles. For vehicle-level (chassis)
emissions, EPA adopted CO2 standards expressed in grams per
ton-mile. For fuel efficiency, NHTSA adopted fuel consumption standards
expressed in gallons per 1,000 ton-miles. The Phase 1 engine-based
standards vary based on the expected weight class and usage of the
vehicle into which the engine will be installed. We adopted Phase 1
vehicle-based standards that vary according to one key attribute, GVWR,
based on the same groupings of vehicle weight classes used for the
engine standards--light heavy-duty (LHD, Class 2b-5), medium heavy-duty
(MHD, Class 6-7), and heavy heavy-duty (HHD, Class 8).
In Phase 1, the agencies defined a special regulatory category
called vocational tractor, which generally operate more like vocational
vehicles than line haul tractors.\383\ As described above in Section
III.C.4, under the Phase 1 rules, a vocational tractor is certified
under standards for vocational vehicles, not those for tractors. In
Phase 2, the agencies are revising the vocational tractor definition to
remove heavy-haul tractors, as we are adopting tractor standards for
these. The agencies received many comments pertaining to vocational
tractors, which are described in Section III.C.4 and Section V.B.
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\383\ See EPA's regulation at 40 CFR 1037.630 and NHTSA's
regulation at 49 CFR 523.2.
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Manufacturers are required to use GEM to determine compliance with
the Phase 1 vocational vehicle standards, where the primary vocational
vehicle manufacturer-generated input is the measure of tire rolling
resistance. The GEM assumes the use of a typical representative,
compliant engine in the simulation, resulting in one overall value for
CO2 emissions and one for fuel consumption. The
manufacturers of engines intended for use in vocational vehicles are
subject to separate Phase 1 engine-based standards. Manufacturers also
may demonstrate compliance with the CO2 standards in whole
or in part using credits reflecting CO2 reductions resulting
from technologies not reflected in the GEM testing regime. See 40 CFR
1037.610.
In Phase 1, EPA and NHTSA also adopted provisions designed to give
manufacturers a degree of flexibility in complying with the standards.
Most significantly, we adopted an ABT program to allow manufacturers to
comply on average within a given averaging set. See 40 CFR part 1037,
subpart H. These provisions enabled the agencies to adopt overall
standards that are more stringent than we could have considered with a
less flexible program.\384\
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\384\ As noted earlier, 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 to
heavy-duty fuel efficiency under 49 U.S.C. 32902(k).
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B. Phase 2 Standards for Vocational Vehicles
Since proposal, in addition to considering substantive written
public comments, the agencies have held dozens of meetings with
manufacturers, suppliers, non-governmental organizations (NGOs), and
other stakeholders to better understand the opportunities and
challenges involved with regulating vocational vehicles. These meetings
have helped us to better
[[Page 73679]]
develop final Phase 2 standards. As an example, we have updated our
industry characterization to better describe the vocational vehicle
market, including the custom chassis manufacturers.\385\ We believe
these information exchanges have enabled us to develop these rules with
an appropriate balance of achievable reductions at reasonable cost with
a reasonably small risk of unintended consequences.
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\385\ See Chapter 1 of the RIA.
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(1) Final Subcategories and Test Cycles
The Phase 2 vocational vehicle standards are based on the
performance of a wider array of control technologies than the Phase 1
rules. In particular, as proposed, the Phase 2 vocational vehicle
standards recognize detailed characteristics of powertrains and
drivelines. As described below, driveline improvements present a
significant opportunity for reducing fuel consumption and
CO2 emissions from vocational vehicles. However, there is no
single package of driveline technologies that will be equally suitable
for the majority of vocational vehicles, because there is an extremely
broad range of driveline configurations available in the market. This
is due in part to the variety of build processes, ranging from a
purpose built custom chassis to a commercial chassis that may be
intended as a multi-purpose stock vehicle. Further, the wide range of
applications and driving patterns of these vehicles leads manufacturers
to offer a variety of drivelines, as each performs differently in use.
For example, depending on whether the transmission has an overdrive
gear, drive axle ratios for Class 7 and 8 tractors can generally be
found in the range of 2.5:1 to 4.1:1. By contrast, across all types of
vocational vehicles, drive axle ratios can range from 3.1:1 (delivery
vehicle) to 9.8:1 (transit bus).\386\ Other components of the driveline
also have a broader range of product in vocational vehicles than in
tractors, including transmission gears, tire sizes, and engine speeds.
Each of these design features affects the GHG emission rate and fuel
consumption of the vehicle. It therefore is reasonable to define more
than one baseline configuration of vocational vehicle, to encompass a
range of drivelines. A detailed list of the technologies the agencies
project could be adopted to meet the vocational vehicle standards is
described in Section V.C, and in the RIA Chapter 2.9, along with a
description of the differences in technology effectiveness that are
projected to be demonstrated through GEM under different test cycles.
The agencies have found that the ranges of effectiveness of a majority
of the technologies are significant enough to merit creation of
subcategories with different test cycles.
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\386\ See Dana Spicer Drive Axle Application Guidelines,
available at http://www.dana.com/wps/wcm/connect/133007004bd8422b9ea8be14e7b6dae0/DEXT-daag2012_0712_DriveAxlesAppGuide_LR.pdf?MOD=AJPERES&CONVERT_TO=url&CACHEID=133007004bd8422b9ea8be14e7b6dae0. See also ZF Driveline and
Chassis Technology brochure, available at http://www.zf.com/media/media/en/document/corporate_2/downloads_1/flyer_and_brochures/bus_driveline_technology_flyer/Busbroschuere_12_DE_final.pdf.
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(a) Basis for Duty Cycles and Subcategories
The agencies are relying on work conducted by the U.S. Department
of Energy at the National Renewable Energy Laboratory (NREL), as well
as duty cycle information provided in public comments, in establishing
the weighting factors for the test cycles to be used in the
certification of heavy-duty vocational vehicles to the final Phase 2
standards. NREL's methodology and findings are described in a report in
the docket for this rulemaking.\387\ The data from NREL have also
informed our segmentation process, and to some extent the technology
assessment. For example, without data regarding the amount of parked
idle observed by vocational vehicles in the NREL database, we would not
have been able to sufficiently identify and recognize technologies that
separately reduce either drive idle or parked idle emissions.\388\
Based on available fleet data, NREL identified three general clusters
of vehicle behavior: one cluster of vehicles most often driving with
slower speeds and frequent stops; one with higher average speeds and
fewer stops; and one multi-modal cluster with vehicles that may operate
similarly to either of the other clusters on any given day. In Chapter
2.2 of the NREL report, an alternate bi-modal clustering analysis is
also presented, where instead of having a distinct middle cluster,
vehicles with highly variable driving patterns are grouped as either
high speed or low speed. A preliminary update provided by NREL includes
cycle weightings that correspond with this two cluster depiction of
vehicle behavior.\389\ Based on the NREL report and other information,
the agencies believe it is appropriate to finalize a regulatory
subcategory structure that includes a drive cycle appropriate for mixed
use vehicles; especially considering that the ultimate application of
incomplete chassis is unknown at the time of certification. In other
words, we are adopting a program structure that follows NREL's three
cluster depiction of vehicle behavior. The final rules' primary
vocational standards thus have subcategories for Regional, Multi-
purpose, and Urban drive cycles in each of the three weight classes
(LHD, MHD and HHD), which results in nine unique subcategories.
---------------------------------------------------------------------------
\387\ National Renewable Energy Laboratory July 2016, ``The
Development of Vocational Vehicle Drive Cycles and Segmentation,''
NREL/TP-5400-65921.
\388\ While drive idle can generally be thought of as in-gear
and parked idle can generally be thought of as out-of-gear, NREL has
data on driving patterns for trucks with manual transmissions and
has considered the fact that these are always out of gear when the
vehicle has zero speed. See Section 5.5 of the final NREL report for
more details.
\389\ See memorandum dated July 2016 titled, ``NREL Bi-Modal
Vocational Vehicle Cluster Information.''
---------------------------------------------------------------------------
In the final weeks before promulgation, the agencies received
significant new comments from a number of vehicle manufacturers, along
with new data characterizing in detail the distribution of powertrain
configurations of their vehicles.\390\ These recent comments suggested
some uncertainty with respect to the three drive cycle structure, and
the manufacturers expressed related concerns regarding assumptions
about transmissions in our baseline vehicle configurations, which they
believe could result in some OEMs being put at competitive
disadvantage. The agencies appreciate these new comments and data;
however, we determined that it would not be appropriate to alter this
regulatory action so late in the rulemaking process based solely upon
this newly submitted information, which was not made available for
broader public comment. Instead, the agencies will continue to analyze
this new information and any other new information we receive. We will
also continue to actively engage with manufacturers and other
stakeholders to determine if future revisions to the vocational vehicle
program structure are warranted, based on this and any other new
information. For example, it is possible that further analysis of new
data could lead us to consider proposing amendments to adopt the two
cluster approach for one or more of the vehicle weight classes, or to
consider amending the regulatory constraints limiting the choice of
drive cycle subcategory that we are adopting to prevent potential
adverse impacts of vehicle misclassification. However, at this time the
final program structure, including these constraints, will remain in
place
[[Page 73680]]
unless and until the agencies determine that revisions to the
vocational vehicle program structure are warranted, in which case the
agencies would undertake a notice and comment rulemaking proposing to
amend the programmatic structure, consistent with such a determination.
In considering whether to undertake further action, the agencies will
necessarily be mindful of statutory lead time requirements and other
practical considerations.
---------------------------------------------------------------------------
\390\ See memorandum dated July 2016 titled, ``Summary of Late
Comments on Vocational Transmissions and N/V.''
---------------------------------------------------------------------------
NREL also synthesized a new transient test cycle using statistical
targets and the DRIVE tool. Eaton commented that the new transient
cycle developed by NREL is similar to cycles they use to calibrate
shift controls, and is more representative of how trucks are driven
than the current ARB Transient certification test cycle. Although there
is some reason to believe this new cycle may actually be more
representative of nationwide operation than the ARB transient cycle,
the agencies recognize that sufficient uncertainty remains that we are
not prepared to adopt this new NREL transient cycle for Phase 2
certification at this time. The agencies also note that, although GEM
has been extensively validated for the ARB transient cycle, we have not
conducted a similar validation for the NREL cycle. Nevertheless, we
will continue to evaluate this cycle and may reconsider it as part of a
future rulemaking. The most significant shortfall identified by NREL in
their comparison of real world vocational vehicle operation and the ARB
transient cycle is a gap in measurement points between speeds of 48 and
55 mph. We have remedied this shortfall by adjusting the composite
weighting factor of the 55 mph cruise cycle. Because vehicles tested in
GEM over our final road grade profile have been observed to decrease
speed well below 55 mph during this cycle, those measurement points
that are absent from the ARB transient cycle are captured in the
nominally 55 mph test cycle.
Other commenters questioned whether the vehicles from which NREL
collected data for the cycle were sufficiently representative, or
whether sufficient data existed to justify the NREL weightings, while
other commenters supported use of the data. Daimler supported making
changes to reflect the NREL-recommended weightings to align with real-
world data. ACEEE supported using the more realistic NREL cycle
weightings to revisit stringency where certain technologies may be more
effective over the new cycles. Both Volvo and Navistar expressed
concerns that the NREL study fleet doesn't appear to be representative.
Navistar believes that the NREL data has too few refuse trucks, and
Volvo believes that the NREL data has too few class 8 vehicles. In
fact, 35 percent of the vehicles in the NREL database that were
evaluated for the drive cycle analysis are class 8, which we believe is
(if anything) over-representative of the percent of new HHD vehicles
manufactured each year. Because the full NREL database also contains
over five percent refuse trucks and our MOVES model estimates that
refuse trucks comprise only three percent of newly manufactured
vocational vehicles each year, we directed NREL to remove excess refuse
trucks from their final analysis, to avoid skewing the data by over-
representing refuse trucks.\391\ A similar process was followed for
removing excess school buses and transit buses. More details are
available in the NREL report.\392\ While some discrepancies may remain
between the NREL vehicle distribution and the national fleet, we are
confident they are sufficiently small to allow us to use this report to
establish weighting factors for different types of operation. Moreover,
the agencies believe the more relevant question to be whether or not
the cycles exercise the technologies over enough of the range of in-use
operation to effect in-use reductions, and to reasonably estimate the
extent of those reductions. In this context, the weighting factors and
duty-cycles are fully adequate.
---------------------------------------------------------------------------
\391\ MOVES 2014. See Note 379 above.
\392\ National Renewable Energy Laboratory July 2016, ``The
Development of Vocational Vehicle Drive Cycles and Segmentation,''
NREL/TP-5400-65921.
---------------------------------------------------------------------------
After considering all the comments, the agencies are establishing
nine subcategories of vocational vehicles in Phase 2, based on the
three weight class groups of vocational vehicles described above that
are continuing from the Phase 1 program, plus Regional, Multipurpose
and Urban duty cycle groups, as shown in Table V-1 below. For reasons
described below in Section V.C.(2)(a) we are not establishing distinct
subcategories for SI-powered vocational vehicles in the HHD weight
class. Thus, with nine diesel subcategories and six gasoline
subcategories, we are essentially setting 15 separate numerical
performance standards. As described in Section V.B.2, we are also
adopting optional standards for seven subcategories of custom
vocational chassis.
This structure enables the technologies that perform best at
highway speeds and those that perform best in urban driving to each be
properly recognized over appropriate drive cycles, while avoiding
unintended results of forcing vocational vehicles that are designed to
serve in different applications to be measured against a single drive
cycle. The agencies intend for these three drive cycles to balance the
competing pressures to recognize the varying performance of
technologies, serve the wide range of customer needs, and maintain
reasonable regulatory simplicity. In light of the very recent comments
noted above, if the agencies were to determine in the future that
revisions to the vocational vehicle program structure are warranted, we
would intend to propose any revisions in a way that would be consistent
with the technology feasibility and cost-benefit analyses of this final
rulemaking. In other words, the agencies do not anticipate any changes
to the technology basis for, or the effective stringency of, the final
standards. Rather, potential changes in program structure would only be
to better assure that the projected reductions are achieved in use,
consistent with the projected technology packages on whose performance
the stringency of the final standards are based, and consistent with
the costs we projected for that compliance pathway.
Table V-1--Regulatory Subcategories for Vocational Vehicles
----------------------------------------------------------------------------------------------------------------
Light heavy-duty class Medium heavy-duty class Heavy heavy-duty class
Weight class 2b-5 6-7 8 (CI only)
----------------------------------------------------------------------------------------------------------------
Duty Cycle........................... Regional............... Regional............... Regional.
Multi-Purpose.......... Multi-Purpose.......... Multi-Purpose.
Urban.................. Urban.................. Urban.
----------------------------------------------------------------------------------------------------------------
[[Page 73681]]
In the NREL Fleet DNA clustering analysis, the medioid of each
cluster was characterized using eight drive cycle metrics, and distance
histograms were created for each statistically representative vehicle.
By summing the miles accumulated at different driving speeds (including
zero speed idle), NREL was able to recommend composite cycle
weightings. Commenters suggested that the proposed weightings of both
highway cruise and idle were too low for some vehicles. When the
agencies released additional data for comment in February 2016, an
early draft of NREL's duty cycle report was included. Most commenters
supported the draft NREL duty cycles. Volvo commented that NREL's cycle
weightings didn't match their extensive telematics database for their
class 8 vocational vehicles, and recommended specific changes to
increase the weighting of 65 mph for Urban and Multipurpose HHD
vehicles. A description of the drive cycle data submitted to the
agencies by Volvo in support of the final test cycles is found in the
RIA Chapter 3.4.3.1. In response, we have adjusted our composite test
weightings for Urban and Multipurpose HHD vehicles in consideration of
Volvo's data. Although Volvo also suggested specific cycle weightings
for coach buses, we have established optional coach bus standards (one
example of the custom chassis standards the agencies are adopting) with
the same weightings as for other Regional vehicles for reasons
described below in V.B.2.b. The final cycle weightings shown in Table
V-2 reflect NREL's recommendations along with consideration of public
comments. Although both NREL and Volvo data showed vehicles whose
behavior would logically be classified as Urban accumulating some miles
(from one to seven percent) in the 65 mph range, the agencies are
applying a zero weighting factor to the 65 mph cycle for all Urban
vehicles for certification purposes. Instead, those miles are assigned
to the 55 mph cycle. We believe it is important to have a test cycle
available in the primary program for vehicles that may regularly drive
on urban or local highways, but are not expected (or designed) to drive
on rural highways. Further, the final rules include the refinement of a
split idle cycle (parked idle and drive idle), since NREL's final
report includes analysis of data characterizing the percent of time in
a work day that vocational vehicles idle when parked as distinct from
idling time when stopped in traffic. More details on the
characterization of parked and drive idle are found in the RIA Chapter
2.9.3.4. More details of the NREL clustering analysis are found in the
RIA Chapter 2.9.2, and more details on the data behind the final
composite cycle weightings are found in the RIA Chapter 3.4.3.
Table V-2--Composite Test Cycle Weightings (in Percent) for Vocational Vehicles
----------------------------------------------------------------------------------------------------------------
55 mph Cruise 65 mph Cruise
ARB transient with road with road Parked idle Drive idle
grade \a\ grade \a\
----------------------------------------------------------------------------------------------------------------
Regional........................ 0.20 0.24 0.56 0.25 0.00
Multi-Purpose (2b-7)............ 0.54 0.29 0.17 0.25 0.17
Multi-Purpose (class 8)......... 0.54 0.23 0.23 0.25 0.17
Urban (2b-7).................... 0.92 0.08 0.00 0.25 0.15
Urban (class 8)................. 0.90 0.10 0.00 0.25 0.15
----------------------------------------------------------------------------------------------------------------
Note:
\a\ As described in Section II, the agencies have adopted highway cruise test cycles with revised road grade
profiles.
We recognize that by adopting a few meaningful duty cycles that
``bound'' how vocational vehicles are generally used, we cannot
perfectly match how every vocational vehicle is actually used. There
are a few vehicle applications we have identified, for which these
general cycles are likely to be poorly representative. We received
several comments that our proposed duty cycles are particularly
unrepresentative of real world behavior of transit buses and refuse
trucks, for example. These vehicles also generally have chassis
characteristics unlike those in the reference GEM vehicles used to
establish the subcategory baselines. The agencies have determined that
it is impractical, from a regulatory perspective, to establish
separate, unique test cycles for transit buses or refuse trucks. In
considering the challenges of such an undertaking, as well as the
market structure of manufacturers who produce such vehicles, the
agencies are instead adopting separate standards for transit buses and
refuse trucks as part of the final Phase 2 program for custom
vocational chassis, as described in Section V.B.(2)(b).
Vocational vehicles neither qualifying under the optional custom
chassis program nor meeting eligibility for exemption as low speed/off
road vehicles will need to be certified in one of the primary
subcategories established in this rulemaking. Below in Section V.C, the
agencies explain the technology basis supporting the standards for each
vehicle weight class.
The agencies received extensive comment on how to define attributes
of vehicles in each subcategory to provide regulatory certainty to
manufacturers. The proposed approach was to set criteria by which a
vehicle manufacturer would know in which vocational subcategory--
Regional, Urban, or Multipurpose--the vehicle should be certified, by
use of cut-points defined using calculations relating engine speed to
vehicle speed. Two commenters suggested we reinstate the Phase 1
approach with a one-size-fits-all drive cycle. Six commenters agreed
with the proposed approach on subcategorization, though some
recommended slight adjustments. The final rules allow manufacturers to
generally choose the subcategory of each vocational chassis, with a
revised set of constraints essentially reflecting types of equipment on
the vehicle (especially transmission type). In Section V.C.(2)(a) and
the RIA Chapter 2.9, we describe changes since proposal with respect to
the baseline vehicle configurations. In Section V.C.(2)(d), we describe
the changes since proposal reflecting use of fleet average sales mixes
in the standard-setting process. In Section V.D.(1)(e), we describe the
constraints we are adopting regarding selection of subcategories by
manufacturers. Taken together, these analyses demonstrate why we are
confident that even if (generally against its own interests) a
manufacturer chooses to certify a vehicle over a less appropriate test
cycle, that choice would not result in a loss of environmental benefit.
Continuing the averaging scheme from Phase 1, each manufacturer will
[[Page 73682]]
generally be able to average within each vehicle weight class (i.e.
averaging sets are not further limited by the Regional, Multi-purpose,
Urban subcategorization).
(b) Vocational Tractors
As discussed in Section V.A., the Phase 1 program includes a
special regulatory category called vocational tractors, which covers
vehicles that are technically tractors but generally operate more like
vocational vehicles than line haul tractors. Heavy-haul, off-road, and
certain intra-city delivery tractors are eligible for this category in
the Phase 1 program, but manufacturers may also choose to certify them
as conventional tractors. The agencies proposed to keep this program in
Phase 2, but to exclude heavy-haul tractors. With the removal of heavy-
haul tractors from the vocational tractor definition (see 40 CFR
1037.630 and 49 CFR 523.2), the agencies have re-assessed the vehicles
remaining in this group, and the most appropriate way for them to be
certified. One typically thinks of beverage tractors in this group,
though it may also include drayage tractors, vehicle carriers,
construction vehicles, and many vehicles with unusual axle
configurations. NREL observed drayage tractors with operational
patterns consistent with the Regional duty cycle.\393\ Volvo also
commented that their vocational tractors would logically fall in the
Regional duty cycle. The agencies have therefore concluded that these
vehicles may reasonably be represented by our final regulatory duty
cycles, and are requiring that vocational tractors not meeting other
exemption criteria must use one of the vocational vehicle duty cycles.
---------------------------------------------------------------------------
\393\ Comparing the vocational Regional duty cycle to the day
cab tractor duty cycle, vocational Regionals have one percent
greater weighting of the ARB Transient, 6 percent more weighting of
the 55 cycle, 8 percent less weighting of the 65 cycle, plus 25
percent parked idle.
---------------------------------------------------------------------------
There is a separate question of whether vocational tractors may
have their performance fairly measured against the agencies' defined
baseline vocational configurations. The agencies requested comment on
whether vocational tractors would be deficit-generating vehicles if
certified in the proposed vocational vehicle subcategories. When a
vehicle is designed with a higher power engine or higher number of
axles to carry a heavier payload than presumed in the GEM baseline for
that subcategory, GEM may return a value that poorly represents the
real world performance of that vehicle. We received comments from the
chassis manufacturers who certify vocational tractors, plus two other
comments. These comments consistently asked the agencies to allow some
tractors with GVWR over 120,000 lbs but not qualifying as heavy-haul
tractors to remain as vocational vehicles rather than be forced to
certify to the primary tractor standards. Volvo submitted written
comments stating that a separate regulatory subcategory with unique
performance standard is warranted for vocational tractors. However,
during a subsequent telephone conversation, Volvo stated that their
vocational tractors would be adequately represented by the other
defined subcategories, and a unique subcategory was not necessary.\394\
See Section III.C.(4). for a discussion of the attributes adopted by
the agencies as distinguishing vocational tractors from regular or
heavy-haul tractors.
---------------------------------------------------------------------------
\394\ See call log for L. Steele, conversation with M. Miller,
dated January 18, 2016.
---------------------------------------------------------------------------
Based on comments and our technical analysis, the agencies have
concluded that the technologies determined to be feasible for regular
vocational vehicles are also feasible for vocational tractors, with
similar adoption rates and package costs. Further, we are not aware of
any non-diversified chassis manufacturers producing vocational
tractors. One implication is that we believe that all manufacturers
certifying vocational tractors will be able to take advantage of our
ABT program flexibilities. According to MY 2014 certification data,
less than 14,000 vocational tractors were certified between the three
manufacturers, including an unidentifiable number that would likely
qualify as heavy-haul tractors, if that definition existed in Phase 1.
Thus, possible deficits (if any) generated by the small sales volume of
vocational tractors in Phase 2 could likely be accommodated within each
company's overall compliance plan.
(2) GHG and Fuel Consumption Standards for Vocational Vehicles
EPA is adopting CO2 standards and NHTSA is adopting fuel
consumption standards for manufacturers of chassis for new vocational
vehicles. As described in Sections II.C.(1) and II.D.(1) above, the
agencies are adopting test procedures so that engine performance will
be evaluated within the GEM simulation tool. These test procedures
include corrections for the test fuel, enabling vocational vehicles to
be certified with many different types of CI and SI engines. In
addition, EPA is establishing HFC leakage standards for air
conditioning systems in vocational vehicles, as described in Section
V.B.(2)(c), with more details available in the RIA Chapter 2.9.3.8 and
Chapter 5.3.4.
This section describes the standards and implementation dates that
the agencies are adopting for the 15 regulatory subcategories of
vocational vehicles, plus the optional standards for the seven custom
vocational chassis categories. The agencies have performed a technology
analysis to determine the level of standards that we believe will be
available at reasonable cost, cost-effective, technologically feasible,
and appropriate in the lead time provided. More details of this
analysis are described in the RIA Chapter 2.9. This analysis considered
the following for each of the regulatory subcategories:
The level of technology that is incorporated in current
new vehicles,
forecasts of manufacturers' product redesign schedules,
the available data on CO2 emissions and fuel
consumption for these vehicles,
technologies that will reduce CO2 emissions and
fuel consumption and that are judged to be feasible and appropriate for
these vehicles through the 2027 model year,
the effectiveness and cost of these technologies,
a projection of the technologically feasible application
rates of these technologies, in this time frame, and
projections of future U.S. sales for different types of
vehicles and engines.
The final Phase 2 program described here and throughout the
rulemaking documents is derived from the preferred alternative,
referred to as Alternative 3 in the NPRM.
(a) Primary Fuel Consumption and CO2 Standards
The agencies' final standards will phase in over a period of seven
years, beginning in the 2021 model year, consistent with the
requirement in EISA that NHTSA's standards provide four full model
years of regulatory lead time and three full model years of regulatory
stability, and provide sufficient time ``to permit the development and
application of the requisite technology'' for purposes of CAA section
202(a)(2). The Phase 2 program will progress in three-year stages with
an intermediate set of standards in MY 2024 and will continue to reduce
fuel consumption and CO2 emissions well beyond the full
implementation year of MY 2027. The agencies have identified a
technology path for each of these levels of improvement, as described
below.
Combining engine and vehicle technologies, vocational vehicles
powered by CI engines are projected to achieve improvements as much as
24
[[Page 73683]]
percent in MY 2027 over the MY 2017 baseline, as described below and in
the RIA Chapter 2.9. The agencies project up to 18 percent improvement
in fuel consumption and CO2 emissions in MY 2027 from SI-
powered vocational vehicles, as shown in Table V-3. The incremental
Phase 2 vocational vehicle standards will ensure steady progress toward
the MY 2027 standards, with improvements for CI-powered vehicles in MY
2021 of up to 12 percent and improvements for CI-powered vehicles in MY
2024 of up to 20 percent over the MY 2017 baseline vehicles, as shown
in Table V-3.
The agencies' analyses, as discussed in this Preamble and in the
RIA Chapter 2, show that these standards are appropriate under each
agency's respective statutory authority.
Table V-3--Projected Vocational Vehicle CO[ihel2] and Fuel Use Reductions (in Percent) from 2017 Baseline
----------------------------------------------------------------------------------------------------------------
Light heavy-
Model year Engine type Heavy heavy- Medium heavy- duty Class 2b-
duty Class 8 duty Class 6-7 5
----------------------------------------------------------------------------------------------------------------
2021.................................. CI Engine............... 7-9 6-11 7-12
SI Engine............... .............. 5-7 6-8
2024.................................. CI Engine............... 12-16 11-18 11-20
SI Engine............... .............. 9-12 9-14
2027.................................. CI Engine............... 14-20 12-22 13-24
SI Engine............... .............. 10-16 11-18
----------------------------------------------------------------------------------------------------------------
Based on our analysis and research, and our consideration of the
public comments, the agencies conclude that the improvements in
vocational vehicle fuel consumption and CO2 emissions can be
achieved through deployment and utilization of a greater set of
technologies than formed the technology basis for the Phase 1
standards. Further, since proposal, our assessment of technology
effectiveness has changed primarily due to revisions in duty cycles and
in some cases, the technologies themselves. The agencies received
comments addressing the vocational vehicle standards broadly, including
baselines, structure, and technologies. In response, in developing the
final standards, the agencies have reevaluated the current levels of
fuel consumption and emissions, the kinds of technologies that could be
utilized by manufacturers to reduce fuel consumption and emissions, the
associated lead time, the associated costs for the industry, fuel
savings for the owner/operator, and the magnitude of the CO2
reductions and fuel savings that may be achieved. After reexamining the
possibilities of vehicle improvements, the agencies are basing the
final standards on the performance of workday idle reduction
technologies, improved transmissions including mild hybrid powertrains,
axle technologies, weight reduction, electrified accessories, tire
pressure systems, and further tire rolling resistance improvements. The
EPA-only air conditioning standard is based on leakage improvements.
These are largely the same technologies as we considered for the
proposal, although some technologies that had been available only to
tractors at proposal are now recognized for vocational vehicles. Our
updated analysis shows that more stringent standards than proposed are
feasible, based in large part on our new assessment of the
effectiveness of workday idle controls.
The agencies' evaluation indicates that some of the above vehicle
technologies are commercially available today, though often in limited
volumes. Other technologies will need additional time for development.
Those that we believe are available today and may be adopted to a
limited extent in some vehicles include improved tire rolling
resistance, weight reduction, some types of conventional transmission
improvements, neutral idle, and air conditioning leakage improvements.
However, the first model year for the final Phase 2 standards will not
be until MY 2021.\395\ As at proposal, the EPA continues to believe
that any potential benefits that could be achieved by implementing
rules requiring some technologies on vocational vehicles earlier than
MY 2021 to be outweighed by several disadvantages. For one,
manufacturers will need lead time to develop compliance tracking tools.
Also, if the Phase 2 vocational vehicle standards began in a different
year than the tractor standards, this could create unnecessary added
complexity, and could strongly detract from the fuel savings and GHG
emission reductions that could otherwise be achieved. Therefore the
Phase 1 standards will continue to apply in model years 2018 to 2020.
No commenter suggested otherwise.
---------------------------------------------------------------------------
\395\ NHTSA is unable to adopt mandatory amended standards in
those model years since there will be less than the statutorily-
prescribed amount of lead time available. 49 U.S.C. 32902(k)(3)(A).
---------------------------------------------------------------------------
Vehicle technologies that we expect will be available in the near
term include neutral idle, low rolling resistance tires, improved axle
efficiency, and part-time 6x2 axles. Vehicle technologies that we have
determined will benefit from even more development time to integrate
engine and vehicle systems include stop-start idle reduction and hybrid
powertrains. The agencies have analyzed the technological feasibility
of achieving the fuel consumption and CO2 standards, based
on projections of what actions manufacturers may be expected to take to
reduce fuel consumption and emissions to achieve the standards, and
believe that the standards are technologically feasible throughout the
regulatory useful life of the program. The basis for this finding is
discussed below in Section V.C.3. EPA and NHTSA estimated vehicle
package costs are found in Section V.C.(2).
Table V-4 and Table V-5 present EPA's CO2 standards and
NHTSA's fuel consumption standards, respectively, for chassis
manufacturers of Class 2b through Class 8 vocational vehicles for the
beginning model year of the program, MY 2021. As in Phase 1, the
standards are in the form of the mass of emissions, or gallons of fuel,
associated with carrying a ton of cargo over a fixed distance. The EPA
standards are measured in units of grams CO2 per ton-mile
and the NHTSA standards are in gallons of fuel per 1,000 ton-miles.
With the mass of freight in the denominator of this term, the program
is designed to measure improved efficiency in terms of freight
efficiency. As in Phase 1, the Phase 2 program assigns a fixed default
payload in GEM for each vehicle weight class group (heavy heavy-duty,
medium heavy-duty, and light heavy-duty). Even though this
simplification does not allow individual vehicle freight efficiencies
to be recognized, the general capacity for larger vehicles to carry
more payload is represented in the
[[Page 73684]]
numerical values of these standards for each weight class group.
For each model year of the standards described below, the standards
for vehicles powered by CI engines reflect improvements that correspond
with performance of technologies projected to meet the separate CI
engine standard in that year, as modeled over the GEM vehicle cycles.
In other words, the CI vehicle standard directly reflects, and keeps
pace with, the increasing stringency of the CI engine standard. As
described above in Section II.D, the SI engine standard is remaining
unchanged from Phase 1. However, the standards in each model year for
vocational vehicles powered by SI engines are based in part on the
performance of some additional engine technologies beyond what is
required to meet the SI engine standards. In other words, certain SI
engine improvements are reflected in the stringency of the SI vehicle
standard.
EPA's vocational vehicle CO2 standards and NHTSA's fuel
consumption standards for the MY 2024 stage of the program are
presented in Table V-6 and Table V-7, respectively. These reflect
broader adoption rates of vehicle technologies already considered in
the technology basis for the MY 2021 standards. EPA's vocational
vehicle CO2 standards and NHTSA's fuel consumption standards
for the full implementation year of MY 2027 are presented in Table V-8
and Table V-9, respectively. These reflect even greater adoption rates
of the same vehicle technologies considered as the basis for the
previous stages of the Phase 2 standards.
These standards are based on highway cruise cycles that include a
final road grade profile that has been refined as a result of comment.
This enables the standard and the GEM certification results to better
reflect real world driving and to help recognize engine and driveline
technologies while seeking to assure that technologies result in real
world benefit. See the RIA Chapter 3.4.2.1.
As described in Section I, the agencies are continuing the Phase 1
approach to averaging, banking and trading (ABT), allowing ABT within
vehicle weight classes. For Phase 2, continuing this approach means
allowing averaging between CI-powered vehicles and SI-powered vehicles
of any subcategory belonging to the same weight class group, which have
the same regulatory useful life. However these averaging sets exclude
vehicles certified to the separate custom chassis standards. Although
we are further subdividing each vocational weight class group into
Urban, Multi-Purpose, and Regional subcategories, we are not
restricting credit exchanges between them. This is similar to the
allowance to trade between vocational vehicles and tractors within a
weight class. It is also consistent with the Phase 1 program, where the
different types of vehicles within a weight class were included in a
single averaging set.
Table V-4--EPA CO[ihel2] Standards for MY 2021 Class 2b-8 Vocational Vehicles
----------------------------------------------------------------------------------------------------------------
Light heavy-
Duty cycle duty Class 2b- Medium heavy- Heavy heavy-duty
5 duty Class 6-7 Class 8
----------------------------------------------------------------------------------------------------------------
EPA Standard for Vehicle with CI Engine Effective MY 2021 (gram CO[ihel2]/ton-mile)
----------------------------------------------------------------------------------------------------------------
Urban........................................................ 424 296 308
Multi-Purpose................................................ 373 265 261
Regional..................................................... 311 234 205
----------------------------------------------------------------------------------------------------------------
EPA Standard for Vehicle with SI Engine Effective MY 2021 (gram CO[ihel2]/ton-mile)
----------------------------------------------------------------------------------------------------------------
Duty cycle Light Medium heavy-
heavy-duty duty Class 6-7
Class 2b-5 (and C8
gasoline)
----------------------------------------------------------------------------------------------------------------
Urban........................................................ 461 328
Multi-Purpose................................................ 407 293
Regional..................................................... 335 261
----------------------------------------------------------------------------------------------------------------
Table V-5--NHTSA Fuel Consumption Standards for MY 2021 Class 2b-8 Vocational Vehicles
----------------------------------------------------------------------------------------------------------------
Light heavy- Medium heavy-
Duty cycle duty Class 2b- duty Class 6- Heavy heavy-duty
5 7 Class 8
----------------------------------------------------------------------------------------------------------------
NHTSA Standard for Vehicle with CI Engine Effective MY 2021 (Fuel Consumption gallon per 1,000 ton-mile)
----------------------------------------------------------------------------------------------------------------
Urban........................................................ 41.6503 29.0766 30.2554
Multi-Purpose................................................ 36.6405 26.0314 25.6385
Regional..................................................... 30.5501 22.9862 20.1375
----------------------------------------------------------------------------------------------------------------
NHTSA Standard for Vehicle with SI Engine Effective MY 2021 (Fuel Consumption gallon per 1,000 ton-mile)
----------------------------------------------------------------------------------------------------------------
Duty cycle Light Medium
heavy-duty heavy-duty
Class 2b-5 Class 6-7
(and C8
gasoline)
----------------------------------------------------------------------------------------------------------------
Urban........................................................ 51.8735 36.9078
Multi-Purpose................................................ 45.7972 32.9695
[[Page 73685]]
Regional..................................................... 37.6955 29.3687
----------------------------------------------------------------------------------------------------------------
Table V-6--EPA CO[ihel2] Standards for MY 2024 Class 2b-8 Vocational Vehicles
----------------------------------------------------------------------------------------------------------------
Light heavy-
Duty cycle duty Class 2b- Medium heavy- Heavy heavy-duty
5 duty Class 6-7 Class 8
----------------------------------------------------------------------------------------------------------------
EPA Standard for Vehicle with CI Engine Effective MY 2024 (gram CO[ihel2]/ton-mile)
----------------------------------------------------------------------------------------------------------------
Urban........................................................ 385 271 283
Multi-Purpose................................................ 344 246 242
Regional..................................................... 296 221 194
----------------------------------------------------------------------------------------------------------------
EPA Standard for Vehicle with SI Engine Effective MY 2024 (gram CO[ihel2]/ton-mile)
----------------------------------------------------------------------------------------------------------------
Duty cycle Light Medium
heavy-duty heavy-duty
Class 2b-5 Class 6-7
(and C8
gasoline)
----------------------------------------------------------------------------------------------------------------
Urban........................................................ 432 310
Multi-Purpose................................................ 385 279
Regional..................................................... 324 251
----------------------------------------------------------------------------------------------------------------
Table V-7--NHTSA Fuel Consumption Standards for MY 2024 Class 2b-8 Vocational Vehicles
----------------------------------------------------------------------------------------------------------------
Light heavy- Medium heavy-
Duty cycle duty Class 2b- duty Class 6- Heavy heavy-duty
5 7 Class 8
----------------------------------------------------------------------------------------------------------------
NHTSA Standard for Vehicle with CI Engine Effective MY 2024 (Fuel Consumption gallon per 1,000 ton-mile)
----------------------------------------------------------------------------------------------------------------
Urban........................................................ 37.8193 26.6208 27.7996
Multi-Purpose................................................ 33.7917 24.1650 23.7721
Regional..................................................... 29.0766 21.7092 19.0570
----------------------------------------------------------------------------------------------------------------
NHTSA Standard for Vehicle with SI Engine Effective MY 2024 (Fuel Consumption gallon per 1,000 ton-mile)
----------------------------------------------------------------------------------------------------------------
Duty cycle Light Medium
heavy-duty heavy-duty
Class 2b-5 Class 6-7
(and C8
gasoline)
----------------------------------------------------------------------------------------------------------------
Urban........................................................ 48.6103 34.8824
Multi-Purpose................................................ 43.3217 31.3942
Regional..................................................... 36.4577 28.2435
----------------------------------------------------------------------------------------------------------------
Table V-8--EPA CO[ihel2] Standards for MY 2027 Class 2b-8 Vocational Vehicles
----------------------------------------------------------------------------------------------------------------
Light heavy- Medium heavy-
Duty cycle duty Class 2b- duty Class 6- Heavy heavy-duty
5 7 Class 8
----------------------------------------------------------------------------------------------------------------
EPA Standard for Vehicle with CI Engine Effective MY 2027 (gram CO[ihel2]/ton-mile)
----------------------------------------------------------------------------------------------------------------
Urban........................................................ 367 258 269
Multi-Purpose................................................ 330 235 230
Regional..................................................... 291 218 189
----------------------------------------------------------------------------------------------------------------
[[Page 73686]]
EPA Standard for Vehicle with SI Engine Effective MY 2027 (gram CO[ihel2]/ton-mile)
----------------------------------------------------------------------------------------------------------------
Duty cycle Light Medium
heavy-duty heavy-duty
Class 2b-5 Class 6-7
(and C8
gasoline)
----------------------------------------------------------------------------------------------------------------
Urban........................................................ 413 297
Multi-Purpose................................................ 372 268
Regional..................................................... 319 247
----------------------------------------------------------------------------------------------------------------
Table V-9--NHTSA Fuel Consumption Standards for MY 2027 Class 2b-8 Vocational Vehicles
----------------------------------------------------------------------------------------------------------------
Light heavy- Medium heavy-
Duty cycle duty Class 2b- duty Class 6- Heavy heavy-duty
5 7 Class 8
----------------------------------------------------------------------------------------------------------------
NHTSA Standard for Vehicle with CI Engine Effective MY 2027 (Fuel Consumption gallon per 1,000 ton-mile)
----------------------------------------------------------------------------------------------------------------
Urban........................................................ 36.0511 25.3438 26.4244
Multi-Purpose................................................ 32.4165 23.0845 22.5933
Regional..................................................... 28.5855 21.4145 18.5658
----------------------------------------------------------------------------------------------------------------
NHTSA Standard for Vehicle with SI Engine Effective MY 2027 (Fuel Consumption gallon per 1,000 ton-mile)
----------------------------------------------------------------------------------------------------------------
Duty cycle Light Medium
heavy-duty heavy-duty
Class 2b-5 Class 6-7
(and C8
gasoline)
----------------------------------------------------------------------------------------------------------------
Urban........................................................ 46.4724 33.4196
Multi-Purpose................................................ 41.8589 30.1564
Regional..................................................... 35.8951 27.7934
----------------------------------------------------------------------------------------------------------------
As with the other regulatory categories of heavy-duty vehicles,
NHTSA and EPA 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 (e.g., throughout the
regulatory useful life of the vehicle). The derivation 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 V.C. and V.D and in the RIA Chapter 2.9.
(b) Custom Chassis Fuel Consumption and CO2 Standards
The agencies proposed a simplified compliance procedure and less
stringent standards for emergency vehicles, while requesting comment on
extending these flexibilities to other custom chassis such as
recreational vehicles and buses. 80 FR 40292-40293. As described below,
the agencies are finalizing a broader allowance that will also apply
for vehicles other than emergency vehicles.
In response to the proposed provisions for emergency vehicles, we
received comments in support of adopting separate, less stringent
standards for emergency vehicles through a simplified GEM process.
Based on the reasoning set forth at proposal, and supported in the
public comments, these final rules include optional emergency vehicle
standards based on the same technologies as described in the proposal,
and using a simplified version of GEM available through the custom
chassis program. The use of a default engine in GEM avoids penalizing
emergency vehicle manufacturers from installing engines that are likely
to be credit-using engines against the separate engine standard, and
avoids forcing emergency vehicles to be measured against an un-
representative baseline over an un-representative drive cycle.
(i) Justification for an Expanded Custom Chassis Program
In the proposal, we requested comment on other manufacturers who
could benefit from a similar regulatory approach, such as those
offering such a narrow range of products that averaging is not of
practical value as a compliance flexibility, and for whom there are not
large sales volumes over which to distribute technology development
costs, as well as having drive cycles and functions that may make the
primary standards either unrepresentative or unsuitable. Although this
issue has some implications for our consideration of small business
concerns, the custom chassis provisions discussed in the proposal were
not intended to be limited to small businesses, and the final custom
chassis standards are generally applicable (albeit optional). It is
important to consider that for some vocational applications the custom-
chassis manufacturers can have substantial market share. For example,
Blue Bird is a manufacturer of school buses and school bus chassis with
a substantial market share of its narrow product line.
We received comments in support of separate standards based on a
different technology mix than the primary program for seven vocational
vehicle applications. Gillig, New Flyer and Allison commented in
support of separate standards for transit buses. RVIA, Newell Coach,
Allison and Tiffin
[[Page 73687]]
Motor Homes commented in support of separate standards for motor homes.
OshKosh commented in support of separate standards for cement mixers.
Autocar and Volvo commented in support of separate standards for refuse
trucks. Volvo and ABC Bus Companies commented in support of separate
standards for motor coaches. Daimler and the School Bus Manufacturers
Technical Council commented in support of separate standards for school
buses.
The agencies received favorable comment on using a simplified
compliance procedure for custom chassis from most commenters, but some
expressed concerns. Autocar claimed that the simplified GEM interface
would not sufficiently reduce the administrative compliance burden of
small businesses, and recommended an engine-only certification method.
Custom chassis manufacturers that are not small businesses must
comply with the Phase 1 standards and are generally doing so, by
installing a mix of tires that, on average, meet the target coefficient
of rolling resistance. Large manufacturers were not enthusiastic about
offering a different approach for some vehicles, and urged that custom
chassis standards, if adopted, be generally available as a compliance
option. Based on public comment and extensive stakeholder outreach, the
agencies have identified over a dozen chassis manufacturers serving the
U.S. vocational market who produce a narrow spectrum of vehicles for
which many technologies underlying the primary standards will either be
less effective than projected, or are infeasible. Innovus commented
that regulatory flexibility should only be offered to small volume
producers who are also small entities. However, we do not believe it is
warranted to force any of these specialized manufacturers to certify
their narrow product line of vehicles to the primary standards, where
stringency is premised on performance of some technologies unsuited for
their specialized type of vehicle. Thus, the agencies have developed
optional standards tailored for these vehicle types, and are not
limiting eligibility to small entities.
Any manufacturer may certify their vehicles that we have identified
as custom chassis vehicles under the primary standards. We expect that
diversified chassis manufacturers selling a small number of their
products into these defined custom applications could likely meet the
primary Phase 2 standards on average, using internal credits. However,
because the baseline configurations and duty cycles for these custom
applications would be less representative and some technologies would
either be less effective or infeasible for them, these custom
applications would likely be credit-using vehicles in the averaging
set. Even so, we believe the primary Phase 2 standards are both
feasible and appropriate for diversified manufacturers, as their broad
mix of products allows them to average across their fleets, and some
vehicles are likely to over-comply because their in-use applications
are more compatible with the full range of available technologies. This
is a feature of setting performance-based average standards with less
than 100 percent adoption rates of technologies. Because we agree with
commenters, including OshKosh who noted this is an expected market
practice, we believe it is essential to not only set feasible targets
for chassis manufacturers offering a narrow range of products and for
whom fleet averaging will provide a smaller degree of compliance
flexibility, but to also make this option available to diversified
manufacturers. To address stakeholder concerns about large, diversified
manufacturers having greater ability to produce credit-using vehicles
than smaller, less diversified manufacturers, we are adopting
additional flexibilities for manufacturers certifying to the custom
chassis standards, including some flexibilities that will be available
only for small businesses.
We do not view these standards as achieving less improvement than
the primary program for these vehicles, and thus, we are not adopting
any sales limits. Nevertheless, we requested comments on an appropriate
sales volume that might be considered as a criterion to qualify for the
numerically less stringent standards, where vehicle quantities above
such sales threshold would need to be certified to the primary
standards. We received comments from Allison, Autocar, Innovus, the
School Bus Manufacturers Technical Council, and RVIA suggesting
appropriate low-volume thresholds ranging from 200 to 26,000 vehicles
per year. We received adverse comment from Daimler stating it would be
unfair to make less stringent standards available solely on the basis
of sales volume, because if a technology exists for one manufacturer,
it is available to all manufacturers. We received adverse comment from
OshKosh that less stringent regulations on a limited production volume
stifles a custom chassis manufacturers' opportunity to grow their
business. For each of the applications listed below in Table V-10, the
agencies have identified at least one manufacturer who produces chassis
regulated under the Phase 2 program that are generally finished as a
single vehicle type, as well as at least one competitor who is more
diversified. After considering these comments, we continue to believe
that no sales limits are needed.
After considering the comments on possible separate standards for
custom chassis, the agencies have evaluated the feasibility of
technologies for these vehicles on an application-specific basis. We
shared draft custom chassis technology packages with affected
stakeholders and received feedback.\396\ See Section V.C.1.a below
discussing the feasibility of each technology as it applies for custom
chassis vehicles. Section V.C.(2)(b) discusses the technology adoption
rates from which the stringency of the optional custom chassis
standards are derived.
---------------------------------------------------------------------------
\396\ See record of Webinar on Vocational Custom Chassis, March
2016, Docket ID EPA-HQ-OAR-2014-0827-1944.
---------------------------------------------------------------------------
Navistar commented with concerns that separate standards for custom
chassis could create an unleveled playing field for manufacturers.
ACEEE commented that the agencies should strengthen the primary
vocational vehicle standard by one percent to offset the weaker
standards for the custom chassis. ACEEE also commented that if chassis
manufacturers can identify the vehicle application with enough
specificity to take advantage of the custom chassis program, then they
should also be able to take advantage of the most appropriate fuel-
saving technologies, resulting in target stringencies that are not
weaker than the main program. Although we agree that the custom chassis
program should not result in a weakening of the overall vocational
program, we disagree with ACEEE's recommendation to arbitrarily add
back stringency. The agencies did not remove custom chassis in the
final stage of a feasibility analysis of the primary program; rather,
we separately considered the custom chassis vehicles as an integral
part of developing the feasibility analysis in support of the final
standards. The optional final standards are technology-advancing,
appropriate, and maximum feasible for these applications. No arbitrary
offset is needed or justified.
We disagree with claims made by commenters expressing concerns with
respect to a shortfall or gap in emissions reductions between the
primary vocational vehicle program and the custom chassis program. Some
commenters have attempted to quantify
[[Page 73688]]
a difference in stringency by comparing select technology packages for
custom chassis described in a February 2016 memorandum with the
proposed technology packages for comparable subcategories.\397\ Because
most of the baseline configurations for the custom chassis are tailored
for each vocational vehicle, the only vehicle types where this
comparison is straightforward is school buses and motor homes. In
comparing the MY 2027 stringency of the medium heavy-duty Urban
subcategory with the optional MY 2027 standard for school buses, for
example, it can be seen that diesel vehicles in the primary program are
projected to achieve 22 percent improvement on average, while school
buses are expected to achieve 18 percent improvement on average. This
is nowhere near the gap posited by certain commenters. Moreover, the
difference in stringency reflects the reasonable conclusion that
certain transmission technologies are not feasible for school buses.
---------------------------------------------------------------------------
\397\ See memorandum dated February 2016 on Vocational Vehicle
Technology Packages for Custom Chassis, Docket ID EPA-HQ-OAR-2014-
0827-1719.
---------------------------------------------------------------------------
This comparison is not straightforward for motor coaches and other
custom chassis types, however, because the baselines are different and
the vehicle attributes are not similar. For example, our baseline
configuration for coach buses includes a 350 hp 11-liter engine with a
6-speed automatic transmission. However, the primary program includes a
baseline for heavy heavy-duty Regional vehicles that is a weighted
average of 95 percent with 455 hp 15-liter engine with 10-speed manual
transmission and 5 percent with a 350 hp 11-liter engine with a 6-speed
automatic transmission. Due to the difference in performance of these
configurations in GEM, a non-diversified coach bus manufacturer may
find its fleet significantly ``in the hole'' in the first year of this
program due solely to baseline differences. As an example of a
technology difference, we have determined that regular HHD Regional
chassis may reasonably apply AES on average at a rate of 90 percent by
MY 2027, whereas we find that AES is not feasible at all for a
conventional coach bus. A diversified manufacturer choosing to certify
a coach bus in the HHD-R subcategory to the primary standards is likely
to need to apply other technologies or use credits from other types of
vehicles to meet the standard on average. A non-diversified coach bus
manufacturer would be unlikely to achieve the HHD-R primary program
standard unless some very advanced technology is applied (at costs
necessarily very different from those analyzed to be reasonable here).
Therefore, we do not believe it is accurate to draw a comparison, as
certain commenters maintained, between the HHD-R primary program
stringency of 14 percent and the coach bus MY 2027 stringency of 11
percent.
Nonetheless, because these optional custom chassis standards are
numerically less stringent than the primary Phase 2 vocational vehicle
standards, the agencies are adopting a more restrictive approach to
averaging, banking and trading (ABT), allowing averaging only within
each subcategory for vehicles certified to these optional standards.
Trading and banking will not be permitted except that small businesses
certifying vehicles to these optional standards may use traded credits
to comply. We are adopting these provisions to prevent generation of
windfall credits against the less numerically stringent custom chassis
standard. If a manufacturer wishes to generate tradeable credits from
production of these vehicles, one or more families may be certified to
the primary vocational vehicle standards.
Table V-10--Custom Chassis Population Estimates
------------------------------------------------------------------------
Percent of new
MY 2018 Average VMT in
Application type vocational first year \a\
population
------------------------------------------------------------------------
Coach (Intercity) Bus............. 1 85,000
Motor Home........................ 13 2,000
School Bus........................ 10 14,000
Transit Bus....................... 1 64,000
Refuse Truck...................... 3 34,000
Cement Mixer \b\.................. 1 16,000
Emergency Vehicle \c\............. 1 6,000
------------------------------------------------------------------------
Notes:
\a\ Source: MOVES 2014 for all except mixer and emergency.\398\
\b\ Source for cement mixer is UCS.\399\
\c\ Source for emergency is ICCT (2009) \400\ and FAMA (2004).\401\
As shown in Table V-10, some of these vehicle types are produced in
moderate volumes, and some are driven moderate distances annually.
However, those that are produced in slightly higher volumes (motor
homes and school buses) are among those driven the fewest miles.
Similarly, those driven the most miles (coach and transit buses) are
among those produced in the smallest volumes. Collectively, the
agencies estimate that the vehicles defined as custom vocational
chassis in Phase 2 comprise less than 30 percent of the projected new
vocational vehicle sales in MY 2018. Even so, because of the
collectively small number of miles driven, the agencies believe that
setting less numerically stringent GHG and fuel consumptions standards
for these vehicles will not detract from the greater benefits of this
rulemaking, and that such separate standards are warranted in any case.
---------------------------------------------------------------------------
\398\ Vehicle populations are estimated using MOVES2014. More
information on projecting populations in MOVES is available in the
following report: USEPA (2015). ``Population and Activity of On-road
Vehicles in MOVES2014--Draft Report'' Docket No. EPA-HQ-OAR-2014-
0827.
\399\ National Ready Mixed Association Fleet Benchmarking and
Costs Survey, http://www.nxtbook.com/naylor/NRCQ/NRCQ0315/index.php#/22, from UCS Custom Chassis Recommendations, May 2016.
\400\ ICCT, May 2009, ``Heavy-Duty Vehicle Market Analysis:
Vehicle Characteristics & Fuel Use, Manufacturer Market Shares.''
\401\ Fire Apparatus Manufacturer's Association, Fire Apparatus
Duty Cycle White Paper, August 2004, available at http://www.deepriverct.us/firehousestudy/reports/Apparatus-Duty-Cycle.pdf.
---------------------------------------------------------------------------
As proposed and discussed in the RIA Chapter 12, the agencies are
adopting a provision for chassis manufacturers qualifying as small
businesses to have
[[Page 73689]]
one extra year of lead time to comply with the initial Phase 2
standards.\402\ Daimler stated it only supported additional lead time
if it was provided equally to all custom chassis manufacturers. Because
the SBA threshold in this sector is generally 1,500 employees, we
believe that small entities have fewer in-house resources to collect
and analyze compliance data than do manufacturers with more employees.
Due to these resource constraints, the agencies believe it is
appropriate to offer this only to small businesses--the entities that
need further lead time. However, many custom chassis manufacturers do
not qualify as small entities under the SBA regulations. We received
comment from OshKosh that additional time to meet an impossible
stringency target is not helpful, a comment addressed by adopting the
separate custom chassis standards. The final program offers both a
feasible standard, as described below, and additional lead time for
small businesses.
---------------------------------------------------------------------------
\402\ See SBA regulations at 13 CFR 121.201. Thresholds
effective February 2016 are available at http://www.regulations.gov/#!documentDetail;D=SBA-2014-0011-0031, 81 FR 4469.
---------------------------------------------------------------------------
Vehicles certifying to the optional custom chassis standards will
be simulated in GEM using a default EPA engine map as well as many
other EPA default parameters that are required inputs for vehicles in
the primary program. While this is very similar to the Phase 1 GEM,
more inputs are available in the Phase 2 custom chassis program than in
Phase 1. Section V.D.(1) below describes the regulatory subcategory
identifiers that must be input to GEM to call default vehicle
specifications as part of obtaining valid simulation results for custom
chassis in GEM.
The optional custom chassis standards will phase in over the same
period as the primary vocational vehicle standards, beginning in the
2021 model year. However, there are no intermediate standards in MY
2024, so the optional MY 2021 custom chassis standards will continue
until the full implementation year of MY 2027. The agencies have
identified a technology path for each of these levels of improvement,
as described below.
Combining engine and vehicle technologies, custom chassis are
projected to achieve improvements from 6 to 18 percent in MY 2027 over
the MY 2017 baseline, as summarized in Table V-11. The incremental
standard in MY 2021 will achieve improvements of up to 10 percent over
the MY 2017 baseline vehicles when including improvements from MY 2021
diesel engines, as shown in Table V-11.
The agencies' analyses, summarized immediately below and discussed
in detail in the RIA Chapter 2.9, show that these optional standards
are justified under each agency's respective statutory authority. We
note that for each model year of the Phase 2 custom chassis standards,
the numerical value of the vehicle-level standard represents the
performance of a diesel engine meeting that year's separate CI engine
standard. Put another way, although the agencies are adopting distinct
standards for custom chassis vocational vehicles, those vehicles must
still use engines certified to the applicable Phase 2 engine standard.
As in Phase 1, the chassis manufacturer is free to install any
certified engine, and because GEM will run using a default map, the
choice of engine will not affect the GEM result.
Table V-11--Custom Chassis CO[ihel2] and Fuel Use Reductions (in
Percent) From 2017 Baseline
------------------------------------------------------------------------
Model year
Vehicle type -----------------
2021 2027
------------------------------------------------------------------------
Coach Bus............................................. 7 11
Motor Home............................................ 6 9
School Bus............................................ 10 18
Transit............................................... 7 14
Refuse................................................ 4 12
Mixer................................................. 3 7
Emergency............................................. 1 6
------------------------------------------------------------------------
It is worth noting that because the custom chassis version of GEM
will not recognize certain technology improvements that some of these
manufacturers will include based on market forces (after they have been
introduced into the market as a result of the primary program), we
expect actual in-use improvements for some of these vehicles to be
slightly greater than is required by the standards. For example, we
project that transmission manufacturers will improve the overall
efficiency of their transmissions to enable vehicle manufacturers to
comply with the primary standards. Once these transmissions have been
developed and made available, we would not expect custom chassis
manufacturers (or customers) to resist using them simply because they
would not impact compliance with the standards.
(ii) GEM-Based Custom Chassis Standards
Table V-12 and Table V-13 present EPA's CO2 standards
and NHTSA's fuel consumption standards, respectively, for custom
vocational chassis. The agencies have analyzed the technological
feasibility of achieving the fuel consumption and CO2
standards, based on projections of actions manufacturers may take to
reduce fuel consumption and emissions to achieve the standards, and
believe that the standards are technologically feasible throughout the
regulatory useful life of the program. EPA and NHTSA describe costs of
the custom chassis standards in Section V.C.(2). In all cases we expect
the technology package costs to be less than those of the primary Phase
2 standards, reflecting that the full set of technologies on which the
stringency of the primary standards are based is not suitable for
custom chassis applications. The costs of these standards are
reasonable in the context of the reductions achieved, should be offset
by fuel savings over the life of the vehicles.
These custom vehicle-level standards are predicated on a simpler
set of vehicle technologies than the primary Phase 2 standard for
vocational vehicles. (As already noted, these custom chassis vehicles
will be required to use engines meeting the Phase 2 engine standards,
and thus, should generally incorporate the same engine improvements as
other vocational vehicles). In developing these optional standards, the
agencies have evaluated the current levels of fuel consumption and
emissions, the kinds of technologies that could be utilized by custom
chassis manufacturers to reduce fuel consumption and emissions, the
associated lead time, the associated costs for the industry, fuel
savings for the owner/operator, and the magnitude of the CO2
reductions and fuel savings that may be achieved. After examining the
possibilities of vehicle improvements, the agencies are basing the
optional vehicle-level standards for motor homes on adoption of TPMS
and low rolling resistance tires. We are basing the optional standards
for transit buses and refuse trucks on the performance of workday idle
reduction technologies, tire pressure systems, simplified transmission
improvements, and further tire rolling resistance improvements. The
agencies are basing the standards for coach buses and school buses on
all of the above technologies as well as simplified transmission
improvements. The agencies are basing the standards for concrete mixers
and emergency vehicles on use of tires with current average levels of
rolling resistance. The EPA-only air conditioning standard is based on
leakage improvements. Of these technologies, we believe that improved
tire rolling resistance, neutral idle, and air conditioning leakage
improvements
[[Page 73690]]
are available today and may be adopted as early as MY 2021. As
described in the RIA 2.9.3.4 and 2.9.5, the vehicle technology that we
believe will benefit from more development time for engine and vehicle
integration is stop-start idle reduction.
EPA's custom chassis CO2 standards and NHTSA's fuel
consumption standards for the full implementation year of MY 2027
reflect even greater adoption rates of the same vehicle technologies
considered as the basis for the MY 2021 standards, described in more
detail in Section V.C below.
As with the other regulatory categories of heavy-duty vehicles,
NHTSA and EPA are adopting standards that apply to custom chassis
vocational vehicles at the time of production, and EPA is adopting
standards for a specified period of time in use (e.g., throughout the
regulatory useful life of the vehicle). The derivation 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 later in this document and in the RIA 2.9.3 to 2.9.6.
The optional standards shown below were derived using baseline
vehicle models with many attributes similar to those developed for the
primary program, with adjustments that are described below in Section
V.C.(2)(a). Details of these configurations are provided in the RIA
Chapter 2.9.2. For better transparency with respect to the incremental
difference between the MY 2021 and MY 2027 vehicle standards, we have
modeled a certified MY 2027 engine for both vehicle model years of
optional custom chassis standards. Thus, chassis manufacturers who do
not make their own engines may compare the two model years of standards
presented in Table V-12 and Table V-13 and know that any differences
are due solely to vehicle-level technologies.
Table V-12--EPA Emission Standards for Custom Chassis
[Gram CO2/ton-mile]
------------------------------------------------------------------------
MY 2021 MY 2027
------------------------------------------------------------------------
Coach Bus........................................... 210 205
Motor Home.......................................... 228 226
School Bus.......................................... 291 271
Transit............................................. 300 286
Refuse.............................................. 313 298
Mixer............................................... 319 316
Emergency........................................... 324 319
------------------------------------------------------------------------
Table V-13--NHTSA Fuel Consumption Standards for Custom Chassis
[Gallon per 1,000 ton-mile]
------------------------------------------------------------------------
MY 2021 MY 2027
------------------------------------------------------------------------
Coach Bus........................................... 20.6287 20.1375
Motor Home.......................................... 22.3969 22.2004
School Bus.......................................... 28.5855 26.6208
Transit............................................. 29.4695 28.0943
Refuse.............................................. 30.7466 29.2731
Mixer............................................... 31.3360 31.0413
Emergency........................................... 31.8271 31.3360
------------------------------------------------------------------------
The agencies are adopting definitional provisions for each of the
custom chassis subcategories to ensure that only eligible chassis will
be able to certify to these numerically less stringent standards. The
category with the most diversity and the greatest need for regulatory
clarification is refuse. We received comments from OshKosh that there
are seven distinct types of refuse trucks, including roll-on-roll-off
vehicles, type T container haulers (hauling trailers containing waste),
as well as residential front loaders, side loaders, and rear loaders.
After considering these comments and other available information, we
have determined that refuse trucks that do not compact waste are
ineligible to certify to the custom chassis standards. For example,
roll-off trucks do not engage in neighborhood waste collection and
typically transfer full containers to and from regional landfills and
construction sites. Furthermore, their driving patterns are more likely
to resemble our Regional cycle than the Urban cycle. These trucks do
engage in some PTO operation while parked when loading or unloading
waste containers using hydraulically operated beds and possibly a winch
or other onboard lift system; however, they do not use the PTO while
driving. The relevant definitions and certification provisions for
refuse and other vehicle types are discussed below in Section V.D.
As discussed above, we are not restricting the optional custom
chassis program to small businesses, nor is there a production cap.
Because we are allowing diversified manufacturers to certify some
vehicles to the optional custom chassis standards, but some large
manufacturers may not have a system for tracking what the final build
of a vehicle is, we are adopting compliance procedures to assure that
the final intended build will be one of the defined vehicle types. This
approach is intended to level the playing field by allowing large
manufacturers to choose this option where their tracking (and/or
controls imposed on the vehicle) is sufficient to know at the time of
certification what the final build will be. This avoids restricting
this path to a small subset of manufacturers.
(iii) Design Standards for Select Custom Chassis
The agencies are adopting an additional set of optional standards
where manufacturers of motor home, cement mixer, and emergency vehicle
chassis may elect to certify one or more families of vehicles to an
equivalent standard. Certification would not require use of GEM if a
manufacturer selects this option. Instead, certification using this
option requires installation of specific technologies on every vehicle.
This option does not allow any averaging, banking, or trading. These
standards are equivalent in stringency to the GEM-based option for
these three types of chassis. As mentioned above, the agencies received
compelling public comment from Autocar suggesting that use of even the
simplified GEM was unreasonably burdensome, and that further
simplification was warranted in some cases. For small businesses
especially, the certification burden of collecting data and running
even a simplified version of GEM can present a disproportionally high
burden, especially where there are very limited GEM inputs. Thus, the
agencies sought to offer an option that minimizes the certification
burden, recognizing the lesser complexity of the technology package
associated with the standards for these chassis.
These equivalent technology-based standards are not available for
manufacturers of coach bus, school bus, transit bus, and refuse truck
chassis, as the technology packages for these chassis are more complex
and cannot be projected to be installed at 100 percent adoption rates.
Table V-14 lists the technologies required to be applied to every
vehicle sold by a manufacturer as part of a family certified to the
optional non-GEM vocational vehicle standards. In addition, the vehicle
must have a certified Phase 2 engine and comply with the separate
standard to prevent leakage of HFC from the mobile air conditioning
system. The combined tire CRR values shown in the table are obtained
using Equation V-1.
Equation V-1 Vocational Tire CRR Level Formula
Steer tire CRR x 0.3 + Drive tire CRR x 0.7
Although manufacturers choosing this option will not have access to
the
[[Page 73691]]
heavy-duty ABT program, this formula provides a small degree of freedom
to allow for some product variability while meeting the target for
every vehicle.
Table V-14--Optional Design (Non-GEM) Standards
------------------------------------------------------------------------
Required technology
Vehicle type -------------------------------------------
MY 2021 MY 2027
------------------------------------------------------------------------
Motor Home.................. Combined CRR 6.7 kg/ Combined CRR 6.0 kg/
ton or less, and ton or less, and
either TPMS or ATIS. either TPMS or
ATIS.
Emergency................... Combined tire CRR Combined tire CRR
8.7 kg/ton or less. 8.4 kg/ton or less.
Mixer....................... Combined tire CRR Combined tire CRR
7.6 kg/ton or less. 7.1 kg/ton or less.
------------------------------------------------------------------------
(c) HFC Leakage Standards
The Phase 1 GHG standards do not include standards to control
direct HFC emissions from air conditioning systems on vocational
vehicles. EPA deferred such standards 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,'' See 76 FR 57194. During our stakeholder
outreach conducted for Phase 2, we learned that the majority of
vocational vehicles are sold as cab-completes with the dashboard-
mounted air conditioning systems installed by the chassis manufacturer.
For those vehicles that have A/C systems installed by a second stage
manufacturer, EPA is adopting revisions to our regulations that resolve
the issues identified in Phase 1, in what we believe is a practical and
feasible manner, as described below in Section V.D.2.
EPA received comments generally supportive of adoption of A/C
refrigerant leakage standards for Class 2b-8 vocational vehicles,
beginning with the 2021 model year. Chassis sold as cab-completes
typically have air conditioning systems installed by the chassis
manufacturer. For these configurations, the process for certifying that
low leakage components are used will follow the system in place
currently for comparable systems in tractors. In the case where a
chassis manufacturer will rely on a second stage manufacturer to
install a compliant air conditioning system, the chassis manufacturer
must follow the certifying manufacturer's installation instructions to
ensure that the final vehicle assembly is in a certified configuration.
(3) Exemptions and Exclusions
This section describes exemptions and exclusions related to
vocational vehicles, including some that are available only in Phase 1
and some on which we asked for comment but did not adopt in the final
program.
(a) Small Business Flexibilities
Although the Phase 1 program deferred the requirements for small
businesses, the Phase 2 program will require small businesses to
certify their affected vehicles. The RIA Chapter 12 presents a complete
discussion of the outreach process that EPA conducted to solicit input
from small businesses on the Phase 2 program. The RIA Chapter 12
explains why the agencies are adopting one year of additional lead time
for all small businesses in Phase 2. Thus, the first compliance year
for small entities is MY 2022 rather than MY 2021. The Small Business
Advocacy Review Panel included representatives who produce vocational
vehicle chassis, including emergency vehicles and concrete mixers.
Discussions specific to vocational vehicle chassis during that process
included exploration of a low volume production threshold below which
some manufacturers may avoid some obligations of this regulation.
Consistent with the recommendations of the Panel, the agencies
requested comments on how to design a small business vocational vehicle
program, including comments on a possible small volume threshold below
which some small business exemption may be available.\403\ Innovus
commented in support of a small volume threshold for vocational small
businesses of either 200 vehicles per year or a different threshold set
based on the market share of the entity. We received comments from
Allison, Autocar, the School Bus Manufacturers Technical Council, and
RVIA each suggesting different low-volume vocational chassis thresholds
ranging as high as 26,000 vehicles per year. We received adverse
comment from Daimler stating it would be unfair to make less stringent
standards available solely on the basis of sales volume, because if a
technology exists for one manufacturer, it is available to all
manufacturers. We received adverse comment from OshKosh that less
stringent regulations on a limited production volume stifles a custom
chassis manufacturers' opportunity to grow their business. Upon
consideration of these comments, the agencies are not finalizing a
broad sales volume threshold below which a vocational chassis
manufacturer may reduce their compliance burden. Instead we are
adopting the custom chassis program, and we are revising some of the
exemptions that are carrying forward from Phase 1.
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\403\ See proposed rules at 80 FR 40295, July 13, 2015.
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Autocar requested further consideration of the small business
concerns of manufacturers of specialty vehicle applications,
specifically recommending a low volume threshold if the agencies are
not inclined to use a manufacturer's business size as grounds for an
exemption. Examples of specialty vehicles listed by Autocar include
street sweepers, asphalt blasters, aircraft deicers, sewer cleaners,
and concrete pumpers. Innovus also requested additional flexibility for
meeting OBD requirements. Capacity Trucks commented that the terminal
tractor industry is primarily comprised of small businesses who produce
a total of less than 6,000 terminal tractors per year, 70 percent of
which are fully off-road vehicles. See Section V.B.(3)(c) for a
discussion of how we are addressing Innovus' comment. See the
discussion in Section V.B.(3)(b) for a discussion of how we are
addressing the comments on vehicles that are off-road and low-speed.
(b) Off-Road and Low-Speed Vocational Vehicle Exemptions
In considering the above comments regarding additional vehicles
that have significant operation at low speeds or off-road, the agencies
are revising the exemptions adopted in Phase 1 for off-road and low-
speed vocational vehicles at 40 CFR 1037.631 and 49 CFR 523.2. See
generally 76 FR 57175.
These provisions already apply in Phase 1 for vehicles that are
defined as ``motor vehicles'' per 40 CFR 85.1703, but may conduct most
of their operations off-road, such as drill rigs, mobile cranes and
yard hostlers.
[[Page 73692]]
Vehicles qualifying under these provisions must be built with engines
certified to meet the applicable engine standard, but need not comply
with a vehicle-level GHG or fuel consumption standard. To date,
according to EPA records, vehicles exempted under this provision using
the axle rating criterion included airport fire apparatus, airport
service, fire service, oil field service, utility repair, refuse, and
truck crane. Only two vehicles were exempted using the 45 mph speed
criterion, however those also had rear axles with GAWR of 29,000 lbs.
No vehicles were exempted under this provision using the 33 mph
criterion. Two manufacturers exempted several vehicles under this
provision using the 55-mph speed-limited tire criterion, including oil
field, mining, construction, rock body, and fertilizer spreader
applications.\404\ RMA commented that the agencies should not
discontinue the speed-limited tire exemption criterion, as was
proposed. However, their argument that it would be detrimental for a
vehicle to drive above 55 mph with speed-limited tires is not
compelling. It is too easy for a vehicle to be sold with speed-limited
tires and subsequently have replacement tires fitted that are
appropriate for higher speed operation. Although we are discontinuing
the criterion for exemption based solely on use of tires with maximum
speed rating at or below 55 mph, we are adding a new criterion whereby
a vehicle qualifies to be exempted under this provision if it would
exceed 95 percent of maximum engine test speed when traveling at 54 mph
or with tamper-proof equivalent electronic controls. We are retaining
the qualifying criteria related to design and use of the vehicle.
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\404\ See memorandum dated July 2016 with data on exempted off-
road vocational vehicles.
---------------------------------------------------------------------------
In considering the long list of specialty vehicle types raised by
Capacity, Autocar and others, the agencies note that many of these may
be primarily off-road vehicles in many respects, although some may not
qualify as either off-road or low-speed under our regulations. In
considering the drive cycle of those whose primary purpose is to
transport an affixed device to an off-road work site for extended PTO
operation, the agencies have concluded that the technologies we have
determined to be feasible for concrete mixers are also feasible for
this type of vehicle, and thus we are adopting a flexibility where
vocational chassis that meet one of the two sets of criteria at 40 CFR
1037.631(a) (but not both) may be optionally certified under the custom
chassis program to the standards established for concrete mixers. These
technologies include certified engines, low-leakage air conditioning
components, and by MY 2027, steer tires with level 3V rolling
resistance and drive tires with level 2v rolling resistance. We have
similarly determined these technologies are feasible and reasonable to
apply for vehicles whose primary purpose is to conduct work at slow
speeds, but do not have affixed devices designed to be used at off-road
work sites. This may include street sweepers and some terminal
tractors.
We interpret the comments from Capacity to mean that many terminal
tractors are produced in very small volumes by a large number of non-
diversified small businesses. This is corroborated by comments from
Autocar. Based on data from EPA's Smartway program, the drive cycles of
some port drayage tractors can include a significant amount of highway
time as well as idle time. According to available records, the average
fraction of highway operation of 1,740 participating port dray tractors
was 59 percent, and the average annual idle time was 762 hours.\405\ In
considering this drive cycle information along with vehicle attributes,
the agencies have determined that workday idle reduction technologies,
transmission technologies, low rolling resistance tires, and other
technologies factored into the primary vocational vehicle standards are
feasible for drayage tractors that are not speed-limited. Therefore,
the agencies believe that a standard reflecting performance of this
type of technology package has potential applicability for this subset
of drayage tractors. There is a competing consideration, however. As
discussed above regarding our justifications for an expanded custom
chassis program, we believe it is essential to set feasible targets for
those chassis manufacturers who offer a narrow range of products. This
is because fleet averaging provides a smaller degree of compliance
flexibility for such manufacturers. Therefore we have determined that
some type of alternative standard is warranted for non-diversified
manufacturers who produce non-speed-limited drayage tractors. The
transit bus custom chassis subcategory has a baseline with
characteristics reasonably similar to drayage tractors, and is
predicated on use of some but not all of the technologies that are
feasible for drayage tractors. The agencies are adopting this as an
alternative standard for non-speed-limited drayage tractors, with one
caveat. We are concerned that offering an optional standard based on
adoption of fewer technologies than are actually feasible for drayage
tractors could result in a loss of emission reductions that are
technically feasible. To address this concern, the agencies are
limiting the number of non-speed-limited drayage tractors that may be
certified under the alternative standard.\406\ As stated above in
Section V.B.(3)(a), Innovus commented that 200 vehicles per year would
be an appropriate small volume threshold. Further, Autocar's written
comments as well as information provided during follow-up meetings
indicate that this threshold would accommodate their production of non-
speed-limited drayage tractors. Therefore the agencies are adopting a
flexibility exclusively for small businesses to optionally certify up
to 200 drayage tractors annually under the custom chassis program to
the standards established for transit buses. Otherwise manufacturers
may elect to either certify their drayage tractors to the primary
standards or design them to satisfy the eligibility criteria of 40 CFR
1037.631 (i.e., to be speed-limited). We are adopting this as an
interim provision (although there is no automatic sunset) to allow
small businesses time to develop experience in the certification
process as well as to develop future product plans.
---------------------------------------------------------------------------
\405\ See memorandum dated July 2016 titled, ``Summary of
SmartWay Port Dray 2014 Data''.
\406\ See Note 403, above.
---------------------------------------------------------------------------
(c) Specialty Vehicle Exemption
As described in Section XIII of this Preamble, the agencies are
adopting alternate engine standards for specialty vehicles as part of
the final Phase 2 program. Because some vocational vehicles may have
engines certified under these specialty vehicle provisions found at 40
CFR 1037.605, we are clarifying here how these provisions interact.
According to the regulations at 40 CFR 1037.605, a manufacturer may
produce no more than 1,000 hybrid vehicles in a single model year under
this option, and no more than 200 amphibious vehicles, speed-limited
vehicles, or all-terrain vehicles. Under this provision, speed-limited
vehicles are those that cannot exceed 45 mi/hr by tamper-proof
calibration. Only vehicles with hybrid drivetrains that certify engines
under this provision must also have a vehicle-level Phase 2
certificate, as required under 40 CFR 1037.105. The three other types
would be exempt from the vehicle standards. Depending on the
manufacturer and vehicle type, this may mean that such hybrid vehicles
may need to meet the primary vocational
[[Page 73693]]
vehicle standards or one of the custom chassis standards.
C. Feasibility of the Vocational Vehicle Standards
This section describes the agencies' technological feasibility and
cost analysis. Further detail on all of these technologies can be found
in the RIA Chapter 2.4 and Chapter 2.9. The variation in the design and
use of vocational vehicles has led the agencies to project different
technology solutions for each regulatory subcategory. Manufacturers may
also find additional means to reduce emissions and lower fuel
consumption than the technologies identified by the agencies, and of
course may adopt any compliance path they deem most advantageous. This
section includes discussion of the feasibility of the final standards
for non-custom vocational vehicles using the full Phase 2 certification
path, as well as the final optional standards for custom chassis
standards.
NHTSA and EPA 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
Southwest Research Institute evaluation of heavy-duty vehicle fuel
efficiency and costs for NHTSA,\407\ the 2010 National Academy of
Sciences report of Technologies and Approaches to Reducing the Fuel
Consumption of Medium- and Heavy-Duty Vehicles,\408\ TIAX's assessment
of technologies to support the NAS panel report,\409\ the technology
cost analysis conducted by ICF for EPA,\410\ and the 2009 report from
Argonne National Laboratory on Evaluation of Fuel Consumption Potential
of Medium and Heavy Duty Vehicles through Modeling and Simulation.\411\
---------------------------------------------------------------------------
\407\ Reinhart, T. (February 2016). Commercial Medium- and
Heavy-Duty (MD/HD) Truck Fuel Efficiency Technology Study--Report
#2. Washington, DC: National Highway Traffic Safety Administration.
EPA-HQ-OAR-2014-0827-1623.; and Schubert, R., Chan, M., Law, K.
2015, Commercial Medium- and Heavy-Duty (MD/HD) Truck Fuel
Efficiency Cost Study. Washington, DC: National Highway Traffic
Safety Administration.
\408\ See NAS Report, Note 229 above.
\409\ See TIAX 2009, Note 230 above.
\410\ See ICF 2010, Note 232 above.
\411\ Argonne National Laboratory, ``Evaluation of Fuel
Consumption Potential of Medium and Heavy Duty Vehicles through
Modeling and Simulation.'' October 2009.
---------------------------------------------------------------------------
(1) What technologies are the Agencies considering to reduce the
CO2 emissions and fuel consumption of vocational vehicles?
In assessing the feasibility of the final Phase 2 vocational
vehicle standards, the agencies evaluated a suite of technologies,
including workday idle reduction, improved tire rolling resistance,
tire pressure monitoring or inflation systems, improved transmissions
including hybrids, improved axles, improved accessories, and weight
reduction, as well as their impact on reducing fuel consumption and GHG
emissions. The agencies also evaluated aerodynamic technologies and
full electric vehicles.
As discussed above, vocational vehicles may be powered by either SI
or CI engines. The technologies and feasibility of the engine standards
are discussed in Section II. At the vehicle level, the agencies have
considered the same suite of technologies and have applied the same
reasoning for including or rejecting these vehicle-level technologies
as part of the basis for the final standards, regardless of whether the
vehicle is powered by a CI or SI engine, since the vehicle level
technologies are not a function of engine type. Generally, the analysis
below does not distinguish between vehicles with different types of
engines. The resulting vehicle standards do reflect the differences
arising from the performance of CI (primarily diesel) or SI (primarily
gasoline) engines over the GEM cycles. Note that vehicles powered by
engines using fuels other than diesel or gasoline are subject to either
the SI or CI vehicle standards, as specified in 40 CFR 1037.101.
(a) Vehicle Technologies Considered in Standard-Setting
The agencies note that the effectiveness values estimated for the
technologies have been obtained using a variety of methods, including
average literature values, engineering calculation, and GEM simulation.
They do not reflect the potentially-limitless combination of possible
values that could result from adding the technology to different
vehicles. For example, while the agencies have estimated an
effectiveness of one percent for e-accessories, each vehicle could
experience a unique effectiveness depending on the actual accessory
load for that vehicle. On-balance the agencies believe this is the most
practicable approach for determining effectiveness for the technologies
in the Phase 2 vocational vehicle program. This section is organized to
first present the agencies' analyses of technology feasibility and
effectiveness in Section V.C.(1), and below in Section V.C.(2) we
present our projected technology adoption rates and estimated costs.
Where other details are not given, the feasibility sections set forth
our rationale for the projected adoption rates. Average vehicle
technology package costs by regulatory subcategory are presented below
in Section V.C.(2)(e). Individual technology costs are summarized in
the RIA Chapter 2.9.3, and full details behind all these costs are
presented in RIA Chapter 2.11, including the markups and learning
effects applied for each of the technologies.
(i) Transmissions
Transmission improvements present a significant opportunity for
reducing fuel consumption and CO2 emissions from vocational
vehicles. Transmission efficiency is important for all vocational
vehicles as their duty cycles involve significant amounts of driving
under transient operation. Even Regional vocational vehicles have 20
percent of their composite score based on the transient test cycle. The
three categories of transmission improvements the agencies proposed to
consider as part of a compliance path used to determine standard
stringency were driveline optimization, architectural improvements, and
hybrid powertrain systems. As a result of comments and enhanced
capabilities of GEM, we are adopting standards based on performance of
a revised set of transmission technologies. For each technology, we
have adjusted our projected penetration rates where we found that
comments provided a persuasive reason to do so, and the effectiveness
values are all updated according to the current GEM over the new drive
cycle weightings.
The technology we described at proposal as driveline integration,
80 FR 40296, is now defined as use of an advanced shift strategy. At
proposal the agencies included shift strategy, aggressive torque
converter lockup, and a high efficiency gearbox among the technologies
defined as driveline integration that would only be recognized by use
of powertrain testing. We also proposed a 70 percent adoption rate in
MY 2027 on the basis that this approach to improving fuel efficiency is
highly cost-effective and technically feasible in a wide range of
applications, and that the additional lead time would enable
manufacturers to overcome barriers related to the non-integrated nature
of businesses serving this sector. We received persuasive comments from
manufacturers emphasizing the diversity of their product lines and the
extent of testing that would be needed to apply this technology to 70
percent of their sales, and as a result we have reduced our projected
adoption rates for this technology. The agencies continue to believe
that an effective way to derive
[[Page 73694]]
efficiency improvements from a transmission is by optimizing it with
the engine and other driveline components to balance both performance
needs and fuel savings. One example of an engine manufacturer
partnering with a transmission manufacturer to achieve an optimized
driveline is the SmartAdvantage powertrain.\412\ The agencies project
transmission shift strategies, including those that make use of
enhanced communication between engine and driveline, can yield
efficiency improvements ranging from three percent for Regional
vehicles to nearly six percent for Urban vehicles, using engineering
calculations (see RIA 2.9.3.1) to estimate the benefits that can be
demonstrated over the powertrain test. We received comment that we had
poorly defined the technology that can bring about improvements related
to drive line integration. In considering the comments and available
information, we believe it is reasonable to project that transmissions
may feature advanced shift strategies where they make use of an
additional sensor to improve fuel efficiency such as by detecting
payload or road grade. See Section V.D.(1) and the RIA Chapter 3.6 for
a discussion of the powertrain test procedure.
---------------------------------------------------------------------------
\412\ See Cummins-Eaton partnership at http://smartadvantagepowertrain.com/.
---------------------------------------------------------------------------
The agencies have revised the GEM simulation tool to recognize
additional transmission technologies beyond what was possible at the
time of proposal. We are adopting a transmission efficiency test to
recognize improved mechanical gear efficiency and reduced transmission
friction, where the test results can be submitted as GEM inputs to
override the default efficiency values. Because this test can be
conducted with a bare transmission without needing to be paired with an
engine, each test will be valid for a much broader range of vehicle
configurations than for a powertrain test. The agencies project vehicle
fuel efficiency can be improved by up to one percent from improved
transmission gear efficiency, which we are projecting to be the same
during each of the driving cycles and zero while idling. RIA 2.9.3.1.1.
Actual test results are likely to show that some gears have more room
for improvement than others, especially where a direct drive gear is
already highly efficient. Commenters requested that the minimum torque
converter lockup gear be enabled as a GEM input without requiring
powertrain testing. In response, final GEM also requires an input field
for torque converter lockup gear. The baseline configurations with
automatic transmissions were run in GEM using lockup in third gear. The
agencies project vehicle fuel efficiency can be improved up to three
percent on a cycle average for torque converter lockup in first gear.
RIA 2.9.3.1.1. Using the library of agency transmission files, GEM
gives a different effectiveness value in every subcategory, because
this is influenced by the gear ratios, drive cycle, and torque
converter specifications. Manufacturers will obtain slightly different
results with their own driveline specifications. The RIA at Chapter
2.9.3.1 includes a table that summarizes the various effectiveness
values for different types of transmission improvements.
Although not factored into our stringency calculations, other non-
hybrid transmission technologies that can also be recognized by
powertrain testing include use of architectures not recognized by GEM
such as dual clutch systems, and designs with reduced parasitic losses.
Most vocational vehicles currently use torque converter automatic
transmissions (AT), especially in Classes 2b-6. Automatic transmissions
offer acceleration benefits over drive cycles with frequent stops,
which can enhance productivity. With the diversity of vocational
vehicles and drive cycles, other kinds of transmission architectures
can meet customer needs, including automated manual transmissions
(AMT), dual clutch transmissions (DCT), as well as manual transmissions
(MT).\413\ As at proposal, dual clutch transmissions are simulated as
AMT's in GEM. A manufacturer may elect to conduct powertrain testing to
obtain specific improvements for use of a DCT. The RIA Chapter 4
explains the EPA default shift strategy and the losses associated with
each transmission type, and discusses changes that have been made since
proposal. Although the representation of transmissions has improved
since proposal, the differences between AT and AMT are too difficult to
isolate for purposes of figuring this into our stringency calculations.
Although we expect manufacturers to have a reasonable model of
transmission behavior for certification purposes, we could not estimate
relative improvement values between AT and AMT for vocational vehicles
using any defensible estimation method. The agencies have not been able
to obtain conclusive data that could support a final vocational vehicle
standard, in any subcategory, predicated on adoption of an AMT or DCT
with a predictable level of improvement over an AT. As a result, the
only architectural changes on which the final vocational vehicle
standards are based are increasing the number of gears and automation
compared with a manual transmission.
---------------------------------------------------------------------------
\413\ See http://www.truckinginfo.com/channel/equipment/article/story/2014/10/2015-medium-duty-trucks-the-vehicles-and-trends-to-look-for/page/3.aspx (downloaded November 2014).
---------------------------------------------------------------------------
The benefit of adding more gears varies depending on whether the
gears are added in the range where most operation occurs. The TIAX 2009
report projected that 8-speed transmissions could incrementally reduce
fuel consumption by 2 to 3 percent over a 6-speed automatic
transmission, for Class 3-6 box and bucket trucks, refuse haulers, and
transit buses.\414\ We have run GEM simulations comparing 5-speed, 6-
speed, 7-speed, and 8-speed automatic transmissions where some cases
hold the total spread constant, some hold the high end ratio constant,
and some hold the low-end ratio constant, where all cases use a third
gear lockup and axle ratios are held constant. We have observed mixed
results, with some improvements over the highway cruise cycles as high
as six percent, and some cases where additional gears increased fuel
consumption. As proposed, we are allowing GEM to determine the
improvement, where manufacturers will enter the number of gears and
gear ratios and the model will simulate the efficiency over the
applicable test cycle. The agencies have revised GEM based on comment,
and we are confident that it fairly represents the fuel efficiency of
transmissions with different gear ratios. Consistent with literature
values, we are using engineering calculations to estimate that two
extra gears has an effectiveness of one percent improvement during
transient driving and two percent improvement during highway driving.
Weighting these improvements using our final composite duty cycles
(zero improvement at idle), for purposes of setting stringency, we are
conservatively estimating that adding two gears will improve vocational
vehicle efficiency between 0.9 and 1.7 percent.
---------------------------------------------------------------------------
\414\ See TIAX 2009, Table 4-48.
---------------------------------------------------------------------------
The final Phase 2 GEM has been calibrated to reflect a fixed two
percent difference between manual transmissions and automated
transmissions during the driving cycles (zero at idle). As in the HHD
Regional subcategory baseline, manual transmissions simulated in GEM
perform two percent worse than similarly-geared AMT. This fixed
[[Page 73695]]
improvement is discussed further in the RIA Chapter 2.4.
Hybrid powertrain systems are included under transmission
technologies because, depending on the design and degree of
hybridization, they may either replace a conventional transmission or
be deeply integrated with a conventional transmission. Further, these
systems are often manufactured by companies that also manufacture
conventional transmissions.
The agencies are including hybrid powertrains as a technology on
which some of the vocational vehicle standards are predicated. We
proposed ten percent overall adoption of strong hybrids by MY 2027,
which meant approximately 18 percent adoption in the Multipurpose and
Urban subcategories in that model year. 80 FR 40297. We received
extensive comments on the ability of the vocational vehicle market to
adopt hybrid drivetrains. EDF and Parker both highlighted the
successful demonstrations of Parker hydraulic hybrids for refuse
applications with effectiveness near 40 percent over refuse duty
cycles. Autocar commented that a significant portion of their refuse
truck sales have hydrostatic hybrid drives. Fleets such as Pepsico and
the City of Bloomington highlighted that they are actively purchasing
hybrids. ATA and UPS commented that hybrid technology applications
continue to be of interest to the trucking industry, but expressed
concern over the high costs that can deter uptake in the market. Eaton
commented that a combination of factors is needed to re-ignite the
hybrid business: lower battery costs and increased efficiency of the
hybrid systems for Class 6-8, lower cost mild hybrid powertrains in
Class 3-5, and continued regulatory pull. Eaton says the hybrid market
is still very fragile and they do not see market conditions improving
for hybrid commercial vehicles except for a few mild hybrids. Securing
America's Future Energy and ACEEE also commented in favor of including
mild hybrids as part of the vocational vehicle compliance package.
After considering all these comments, we agree with commenters that
mild hybrids are more likely than strong hybrids to succeed initially
in the vocational sector, especially outside of the bus market. We are
projecting adoption of two types of mild hybrids, defined using system
parameters based on actual systems commercially available in the market
today.\415\ NTEA and the Green Truck Association both commented that a
common way that today's hybrids are installed is by secondary or
intermediate manufacturers. We have taken this into consideration by
assuming that some mild hybrid systems will be integrated with an
engine sufficient to enable use of an engine stop-start feature, while
some mild hybrids will not be integrated and these ``bolt-on'' systems
will only provide transient benefits related to regenerative braking.
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\415\ For example, see XL Hybrids at http://www.xlhybrids.com/content/assets/Uploads/XL-BoxTruck-US-FLY-8.5x11-0519-LR.pdf, and
Crosspoint Kinetics at http://crosspointkinetics.com/members/kinetics-hybrid-partners/.
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Allison believes that hybrid vehicles should be certified on a duty
cycle on the same basis as non-hybrid vehicles because the vehicles
must perform the same work regardless of the powertrain technology. We
agree and the Phase 2 test cycles are the same for conventional and
hybrid drivelines. The Sierra Club asked the agencies to consider real
world duty cycle data to account for the effectiveness of hybrids for
vocational vehicles. Allison says investments for heavy-duty hybrids
will be made by component suppliers, not by the vehicle manufacturers.
The battery, inverter, and motor suppliers must make investments in
addition to the system supplier. In this regard--for a small market
like the heavy-duty hybrids--a significant investment, under current
conditions, are seen as risky and unlikely to occur according to
Allison. Allison commented that even though the transit bus industry
has had commercially available hybrids for over a decade, the adoption
rate of hybrids in the U.S. transit bus market is only 13.2 percent and
that to achieve an overall 5 percent adoption rate of hybrid
technology, the economics of the hybrid ownership would have to
substantially change over the period of time covered by this
rulemaking. In light of these concerns, we have adjusted our projected
adoption rates of hybrid technology as described below in Section
V.C.(2)(b)(i).
We also have reconsidered our effectiveness estimation method as a
result of comments. Instead of relying on previously published road
tests over varying drive cycles, we are applying engineering
calculations to account for defined hybrid system capacities and
inefficiencies over our certification test cycle. We are using a
spreadsheet model that calculates the recovered energy of a hybrid
system using road loads of the default baseline GEM vehicles over the
ARB Transient test cycle. See RIA Chapter 2.9.3.1.3 to read more about
the assumed motor and battery capacity, swing in the state of charge,
and system inefficiencies. The effectiveness is assumed
(conservatively) to be zero for the highway cruise cycles to obtain the
projected cycle-weighted effectiveness. For the non-integrated models,
the same system was assessed for all weight classes (not scaled up for
heavier vehicles); however, for the integrated models with stop-start
we have scaled up the system specifications to account for the larger
road loads, to ensure the projected effectiveness is not decreased for
systems on heavier vehicles relative to that projected for lighter
vehicles.
For the non-integrated mild hybrids, we are estimating an eight to
13 percent fuel efficiency improvement as measured over the powertrain
test, depending on the duty cycle (i.e. Multi-purpose or Urban) in GEM
for the applicable subcategory. See RIA 2.9.3.1. For the integrated
mild hybrids, we have combined the effectiveness calculated for the
scaled-up mild hybrid system with the effectiveness of stop-start,
described below. Id. 2.9.3.1. These combined effectiveness values range
from 18 to 21 percent efficiency improvement, depending on the duty
cycle (i.e. Multi-purpose or Urban). Even though the actual improvement
from hybrids in Phase 2 will be evaluated using the powertrain test,
because the model uses the same vehicle test cycle and conservative
estimates of realistic configurations, the agencies have concluded it
is reasonable to use these spreadsheet-based estimates as a basis for
setting stringency in the final rules.
Based on the public comments from hybrid suppliers and other
innovators providing evidence of hybrid systems in the market today
ranging from prototypes to commercialized, the agencies believe the
Phase 2 rulemaking timeframes will offer sufficient lead time to
develop, demonstrate, and conduct reliability testing for hybrid
technologies to enable market adoptions in the range that we are
projecting for the final rules.
The agencies are working to reduce barriers related to hybrid
vehicle certification. In Phase 1, there is a significant burden
associated with the optional test for demonstrating the GHG and fuel
efficiency performance of vehicles with hybrid powertrain systems. If
manufacturers wish to earn Phase 1 credit for a hybrid, they must
obtain a conventional vehicle that is identical to the hybrid vehicle
in every way except the transmission, test both, and compare the
results.\416\ In Phase 2,
[[Page 73696]]
manufacturers will conduct powertrain testing on the hybrid system
itself, and the results of that testing will become inputs to GEM for
simulation of the non-powertrain features of the hybrid vehicle,
removing a significant test burden. We will continue to work with
hybrid suppliers and manufacturers to address other test burden issues,
including test procedures to determine a balanced state of charge and
number of default configurations needed for the cycle average map.
---------------------------------------------------------------------------
\416\ See test procedures at 40 CFR 1037.555. In Phase 1,
evaluation of hybrid powertrain systems is an option for which
advanced technology credits are available.
---------------------------------------------------------------------------
Hybrid manufacturers commented that meeting the on-board diagnostic
requirements for criteria pollutant engine certification continues to
be a potential impediment to adoption of hybrid systems. See Section
XIII.A.1 for a discussion of regulatory changes to reduce the non-GHG
certification burden for engines paired with hybrid powertrain systems.
The agencies have also received comments on a letter from the
California Air Resources Board requesting consideration of supplemental
NOX testing of hybrids.\417\ Allison provided comment on
CARB's recommendations, noting that it is not possible to draw
conclusions about hybrid vehicles compared with conventional vehicles
using the method recommended by CARB. Allison suggests that EPA gather
additional data and conduct a future analysis based on data from both
low-kinetic intensity and high kinetic intensity vehicles. In the final
Phase 2 program, NOX emissions will be measured and reported
as a part of powertrain testing. This will allow EPA to monitor
NOX performance and identify potential problems long before
sales increase to a point at which significant in-use impacts could
occur. The information collected will also be used to inform EPA as to
the merits of future rulemaking. However, EPA believes that finalizing
the approach recommended at this time could represent an undue burden
for this emerging technology.
---------------------------------------------------------------------------
\417\ California Air Resources Board. Letter from Michael Carter
to Matthew Spears dated December 29, 2014. CARB Request for
Supplemental NOX Emission Check for Hybrid Vehicles.
Docket EPA-HA-OAR-2014-0827.
---------------------------------------------------------------------------
Based on comments received and stakeholder outreach, we have reason
to believe that some custom chassis manufacturers are better positioned
than others to adopt transmission technology to improve fuel
efficiency. Most have little or no in-house research capacity, and
purchase off-the-shelf transmissions. Some, such as Gillig and Autocar,
have partnered with suppliers to successfully implement hybrids on
their vehicles. Some bus chassis manufacturers are exploring the
benefits of applying transmissions with additional gears. In real world
driving, vehicles with a lot of transient operation, including custom
chassis, can see real fuel savings from adoption of improved
transmissions, including those with more efficient gears and advanced
shift strategies. We expect that suppliers will continue to develop
improved transmissions for vocational vehicles including some custom
chassis, and that manufacturers will continue to select transmissions
that deliver reliable products to fuel-conscious customers.
Specifically, we believe that bus manufacturers will continue to have
choices of competing products that offer performance characteristics
that improve over time. Below in V.C.(2)(b) we discuss the reasons why
we believe that a final Phase 2 program that is largely blind to these
transmission-based improvements for custom chassis will avoid adverse
unintended consequences.
(ii) Axles
The agencies are predicating part of the stringency of the final
vocational vehicle standards on performance of two types of axle
technologies. The first is advanced low friction axle lubricants and
efficiency as demonstrated using the separate axle test procedure
described in the RIA Chapter 3.8 and 40 CFR 1037.560. The agencies
received adverse comment on the proposal to assign a fixed 0.5 percent
improvement for this technology. In consideration of comments, the
agencies are instead assigning default axle efficiencies to all
vocational vehicles. Manufacturers may submit test data to over-ride
axle efficiency values in GEM. Our cost analysis for the final
rulemaking includes maintenance costs of replacing axle lubricants on a
periodic basis. See the RIA Chapter 7.1.3. Based on supplier
information, some advanced lubricants have a longer drain interval than
traditional lubricants. We are estimating the axle lubricating costs
for HHD to be the same as for tractors since those vehicles likewise
typically have three axles. However, for LHD and MHD vocational
vehicles, we scaled down the cost of this technology to reflect the
presence of a single rear axle. We expect that improved axle efficiency
is technically feasible on all vocational vehicles including custom
chassis. However, it's likely that axle suppliers may be more likely to
invest in design and lubrication improvements for high sales volume
products, such as axles that can serve both tractor and vocational
markets. Further, to the extent that extreme duty cycles require
lubricants with special performance features, it's likely that the most
advanced low-friction lubricants may not be feasible for some custom
chassis such as refuse trucks.
The second axle technology applies only for HHD vocational
vehicles, which typically are built with two rear axles. Part time 6x2
configuration or axle disconnect is a design that enables one of the
rear axles to temporarily disconnect or otherwise behave as if it's a
non-driven axle. The agencies proposed to base the HHD vocational
vehicle standard on some use of both part time and full time 6x2 axles.
The agencies received adverse comment on the application of the
permanent 6x2 configuration for vocational vehicles. The disconnect
configuration is one that keeps both drive axles engaged only during
some types of vehicle operation, such as when operating at construction
sites or in transient driving where traction especially for
acceleration is vital. Instead of calculating a fixed improvement as at
proposal, the agencies have refined GEM to recognize this configuration
as an input, and the benefit will be actively simulated over the
applicable drive cycle. Effectiveness based on simulations with EPA
axle files is projected to be as much as one percent for HHD Regional
vehicles. Further information about this technology is provided in RIA
Chapter 2.4.5. The feasibility of this technology depends on whether
the baseline axle configuration is a 6x4 and whether the vehicle is
likely to spend significant amounts of time on the highway. For
vocational vehicles, this is largely limited to Regional and
Multipurpose HHD vehicles. To the extent that any motor homes and coach
buses with GVWR over 33,000 lbs are built with two rear axles, this
technology could be technically feasible. However, because these
vehicles generally operate on paved roads and may not need the traction
of a 6x4, a popular axle configuration for these vehicles is a
permanent 6x2.
(iii) Lower 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.\418\ The two most helpful sources of data in establishing
the projected vocational vehicle tire rolling resistance levels for the
final Phase 2 standards are the comments from RMA and actual
certification data for model
[[Page 73697]]
year 2014. At proposal, we projected that all vocational vehicle
subcategories could achieve average steer tire coefficient of rolling
resistance (CRR) of 6.4 kg/ton and drive tire CRR of 7.0 kg/ton by MY
2027. These new data have informed our analysis to enable us to
differentiate the technology projections by subcategory. The RMA
comments included CRR values for a wide range of vocational vehicle
tires, for rim sizes from 17.5 inches to 24.5 inches, for steer/all
position tires as well as drive tires. The RMA data, while illustrating
a range of available tires, are not sales weighted. The 2014
certification data include actual production volumes for each vehicle
type, thus both steer and drive tire population-weighted data are
available for emergency vehicles, cement mixers, school buses, motor
homes, coach buses, transit buses, and other chassis cabs. The
certification data are consistent with the RMA assessment of the range
of tire CRR currently available. We also agree with RMA's suggestion to
set a future CRR level where a certain percent of current products can
meet future GEM targets. We disagree with RMA that the MY 2027 target
should be a level that 50 percent of today's product can meet. With
programmatic averaging, such a level would mean essentially no
improvements overall from tire rolling resistance, because today when
manufacturers comply on average, half their tires are above the target
and half are below. Further, with Phase 2 GEM requiring many more
vehicle inputs than tire CRR, manufacturers have many more degrees of
freedom to meet the performance standard than they do in Phase 1. In
these final rules, the agencies are generally projecting adoption of
LRR tires in MY 2027 at levels currently met by 25 to 40 percent of
today's vocational products, on a sales-weighted basis.\419\ We are
differentiating the improvement level by weight class and duty cycle,
recognizing that heavier vehicles designed for highway use can
generally apply tires with lower rolling resistance than other vehicle
types, and will see a greater benefit during use. None of the rolling
resistance levels projected for adoption in MY 2027 are lower than the
25th percentile of tire CRR on actual vocational vehicles sold in MY
2014. Thus, we believe the improvements will be achievable without need
to develop new tires not yet available. Further details are presented
in the RIA Chapter 2.9.
---------------------------------------------------------------------------
\418\ See Argonne National Laboratory 2009 report, Note 411,
page 91.
\419\ See memorandum dated May 2016 titled, Vocational Vehicle
Tire Rolling Resistance Certification Data.
---------------------------------------------------------------------------
In simulation, the benefit of LRR tires is reflected in GEM
differently for vehicles of different weight classes and duty cycles.
Based on simulations using the projected tire CRR, the agencies project
fuel efficiency improvements by MY 2027 for LRR tires on Regional
vocational vehicles between two and three percent, for Multipurpose
vehicles between one and three percent, and for Urban vehicles up to
one percent. This technology is also feasible on all custom chassis,
with similarly larger improvements feasible for coach buses and motor
homes with typically regional drive cycles, and similarly smaller
improvements feasible for school and transit buses, refuse trucks, and
concrete mixers with typically urban drive cycles.
As proposed, the agencies will continue the light truck (LT) tire
CRR adjustment factor that was adopted in Phase 1. 80 FR 40299; see
generally 76 FR 57172-57174. In Phase 1, the agencies developed this
adjustment factor by dividing the overall vocational test average CRR
of 7.7 by the LT vocational average CRR of 8.9. This yielded an
adjustment factor of 0.87. Because the MY 2014 certification data for
LHD vocational vehicles may have included some CRR levels to which this
adjustment factor may have already been applied, and because we did not
receive adverse comment on our proposal to continue this, the agencies
have concluded that we do not have a basis to discontinue allowing the
measured CRR values for LT tires to be multiplied by a 0.87 adjustment
factor before entering the values in the GEM for compliance.
In Table V-15, the descriptors 1v through 5v refer to levels of
rolling resistance that have been identified among the population of
tires installed on vocational vehicles certified for MY 2014. Each of
these levels is in production today and represents tires that have been
fitted on a certified vehicle. The agencies have defined these levels
for purposes of estimating the manufacturing costs associated with
applying improved tire rolling resistance to vocational vehicles. These
levels are not applicable for estimating degrees of improvement or
costs of LRR tires on tractors, trailers, or HD pickups and vans as
part of this rulemaking. Furthermore, these levels do not represent the
full range of tire CRR available for vocational vehicles. There are
both steer and drive tires on certified vocational vehicles today with
CRR ranging from 5 kg/ton to 15 kg/ton. We expect this full range of
tires will continue to be available in the market well into the future.
Table V-15--Defined Levels of Vocational Tire CRR
------------------------------------------------------------------------
Range Range
Rolling resistance level descriptor min. max.
------------------------------------------------------------------------
LRR level 1v............................................ 7.5 8.1
LRR level 2v............................................ 7.0 7.49
LRR level 3v............................................ 6.6 6.99
LRR level 4v............................................ 6.3 6.59
LRR level 5v............................................ 5.8 6.29
------------------------------------------------------------------------
(iv) Workday Idle Reduction
The Phase 2 idle reduction technologies considered for vocational
vehicles are those that reduce workday idling, unlike the overnight or
driver rest period idling of sleeper cab tractors. Idle reduction
technology is one type of technology that is particularly duty-cycle
dependent. In light of new information, the agencies have learned that
our proposal had mischaracterized the idling operation of vocational
vehicles, significantly underestimating the extent of this mode of
operation, and incorrectly calculating it using a drive idle cycle when
significant idling also occurs while parked. As described above in
Section V.B.(1), in these final rules we have revised our test cycles
to better reflect real world idle operation, including both parked idle
and drive idle test conditions. At proposal, we identified two types of
idle reduction technologies to reduce workday idle emissions and fuel
consumption for vocational vehicles: neutral idle and stop-start. After
considering the new duty cycle information and the many comments
received, we are basing our final vocational vehicle standards in part
on the performance of three types of workday idle reduction
technologies: neutral idle, stop-start, and automatic engine shutdown;
which we believe are effective, feasible, and cost-effective, as
discussed further in this section.
Neutral idle is essentially a transmission technology, but it also
requires a compatible engine calibration. Torque converter automatic
transmissions traditionally place a load on engines when a vehicle
applies the brake while in drive, which we call curb idle transmission
torque (CITT). When an engine is paired with a manual or automated
manual transmission, the CITT is naturally lower than when paired with
an automatic, as a clutch disengagement must occur for the vehicle to
stop without stalling the engine. We did not receive adverse comment on
our proposal to include this technology in our standard-setting for
vocational vehicles. The engineering
[[Page 73698]]
required to program sensors to detect the brake position and vehicle
speed, and enable a smooth re-engagement when the brake pedal is
released makes this a relatively low complexity technology that can be
deployed broadly. Navistar commented that idle reduction strategies
must have sufficient engine, aftertreatment and occupant protections in
place such that any fuel cost savings are a net benefit for the owner/
operator without compromising safety. We agree, and for neutral idle we
believe an example of an allowable override is if a vehicle is stopped
on a hill. Skilled drivers operating manual transmissions can safely
engage a forward gear from neutral when stopped on upslopes with
minimal roll-back. With an AT, the vehicle's computer would need to
handle such situations automatically. In addition, engagement of the
PTO while driving will be an allowable over-ride condition. In the
Phase 2 certification process, transmission suppliers will attest
whether the transmission has this feature present and active, and
certifying entities will be able to enter Yes or No as a GEM input for
the applicable field. The effectiveness of this technology will be
calculated using data points collected during the engine test, and the
appropriate fueling over the drive idle cycle and the transient cycle
will be used. Based on GEM simulations using the final vocational
vehicle test cycles, the agencies project neutral idle to provide fuel
efficiency improvements up to seven percent for diesel vehicles, and up
to two percent for gasoline vehicles, depending on the regulatory
subcategory.\420\ The lesser effectiveness for gasoline vehicles is due
to lower curb idle transmission torque present in the baseline
configurations for gasoline than the diesel vehicles, as documented in
the SwRI report.\421\
---------------------------------------------------------------------------
\420\ See spreadsheet file dated July 2016 titled,
``FRM_Vocational-Standards_GEMpostprocess.xls''. See EPA-HQ-OAR-
2014-0827.
\421\ See Reinhart 2015, Note 345 above.
---------------------------------------------------------------------------
Neutral idle may be programmed on any automatic transmission, and
can reasonably be applied for vocational vehicles where this feature
would not frequently encounter an over-ride condition. Vehicles with
high PTO operation can apply this technology, although they would see
reduced effectiveness in use.
Automatic engine shutdown (AES) is an engine technology that is
widely available in the market today, but has seen more adoption in the
tractor market than for vocational vehicles. Although we did not
propose to include this technology, we received many comments
suggesting this would be appropriate. Some commenters may have
conflated the concept of stop-start with AES, such as a comment we
received asking us to consider the on-board need to power accessories
while the vehicle is in stationary mode. We believe that automatic
engine shutdown is effective and feasible for many different types of
vehicles, depending on how significant a portion of the work day is
spent while parked. Most truck operators are aware of the cost of fuel
consumed while idling, and importantly, the wear on the engine due to
idling. Engine manufacturers caution owners to monitor the extent of
idling that occurs for each work truck and to reduce the oil change
interval if the idle time exceeds ten percent of the work day.\422\
Accordingly, many utility truck operators track their oil change
intervals in engine hours rather than in miles.
---------------------------------------------------------------------------
\422\ See Ford powerstroke guide at https://www.fleet.ford.com/truckbbas/non-html/DeiselTips/DLSIDLETIMESS.pdf (accessed March
2016); see also Cummins maintenance schedule, available at http://www.cumminsbridgeway.com/pdf/parts/Recommended_Maintenance_Schedule.pdf (accessed March 2016).
---------------------------------------------------------------------------
NTEA provided the agencies with a report with survey results on
which work truck fleets are adopting AES with backup power, and their
reasons for doing so.\423\ The most common reason given in the survey
is to allow an engine to shut down and still have vehicle power
available to run flashing safety lights. Some vocational vehicles also
need to conduct work using a power take-off (PTO) while stationary for
hours, such as on a boom truck. The agencies are adopting an allowable
AES over-ride for PTO use. Technologies that can reduce fuel
consumption during this type of high-load idle are discussed below in
V.C.(1)(c)(iii). We are also adopting an allowable AES over-ride if the
battery state of charge drops below a safe threshold. This would ensure
there is sufficient power to operate any engine-off accessories up to a
point where the battery capacity has reached a critical point. Where a
vocational vehicle has such extensive stationary accessory demands that
an auxiliary power source is impractical or that an over-ride condition
would be experienced frequently, we would not consider AES to be
feasible. In the Phase 2 certification process, engine suppliers will
attest whether this feature is present and tamper-proof, and certifying
entities will be able to enter Yes or No as a GEM input for the
applicable field.\424\ As with neutral idle described above, the
effectiveness of AES will be calculated in GEM using data obtained
through engine testing. The appropriate data points over the parked
idle cycle will be used for calculating the fueling. Based on GEM
simulations using the final vocational vehicle test cycles, the
agencies project AES to provide fuel efficiency improvements ranging
from one to seven percent, depending on the regulatory subcategory.
---------------------------------------------------------------------------
\423\ NTEA, 2015 Work Truck Electrification and Idle Management
Study.
\424\ We will consider non-tamper-proof AES as off-cycle
technologies for a lesser credit.
---------------------------------------------------------------------------
The agencies proposed to predicate the vocational vehicle standards
in part on 70 percent adoption of stop-start in MY 2027. We received
numerous comments from manufacturers and suppliers with concerns about
all aspects of this technology, including its feasibility, its
effectiveness, and the lead time to make it commercially available. As
discussed above, our assessment of workday idle reduction technologies
has been refined since proposal, and part of this refinement includes
less reliance on adoption of stop-start than at proposal.
Stop-start is a technology that requires an integration between
engine and vehicle systems, and is seeing increasing acceptance in
today's passenger vehicle market. The agencies are aware that for a
vocational vehicle's engine to turn off during workday driving
conditions, there must be a minimal reserve source of energy to
maintain engine-protection and safety functions such as power steering,
transmission pressure, engine lubrication and cooling, among others. As
such, stop-start systems can be viewed as having a place on the low-
cost end of the hybridization continuum. Effenco commented that a
minimum of additional hardware is required to deliver enough power to
frequently and seamlessly restart a large engine as well as to keep
accessories and equipment operational with the engine turned off.
Navistar commented persuasively that coking can occur if the cooling
and lubricating oil is removed. The agencies therefore would consider
electrified water and oil pumps to be part of the stop-start technology
package. However, we must be clear to distinguish this technology from
the AES described above. Stop-start technologies will be recognized
only over the drive idle cycle and the transient cycle in GEM, not the
parked idle cycle (whereas AES is recognized only over the parked idle
cycle). Accordingly, the purpose of the additional hardware is to
protect the engine for short duration stops such as at traffic lights,
not to power accessories while the vehicle is parked.
Volvo commented that stop-start is not feasible for HHD engines
(generally 11L and larger), and claims engine
[[Page 73699]]
development costs will be very high since stop-start cycling tests can
only be accelerated by a limited amount before the failure mechanisms
are altered. However, their objections relate more to the challenges of
stop-start for HHD engines and do not actually show the technology to
be infeasible. Although we disagree with Volvo that stop-start is
infeasible for HHD engines, we understand it may require more
development time and cost than for engines in lighter vehicles. It's
possible that some time may be needed for development work where
manufacturers elect to shift away from reliance on batteries for
starting the engine and begin to rely instead on ultracapacitors, which
do not have the same problems with cold weather operation and long term
fatigue as do batteries.\425\ Volvo and EMA commented that main and rod
bearings as well as other bearing surfaces would need to be
strengthened and improvements may be needed for starters and
lubrication systems. We agree with commenters that this type of
development work would likely be part of bringing this technology to
the vocational vehicle market, and thus we have included costs for
upgrades similar to those described for all sizes of engines, not just
those over 11L. In the event that an engine manufacturer needs to delay
adoption of stop start to roll these changes in to a planned platform
redesign, we believe our relatively modest adoption rate of 30 percent
in MY 2027 will accommodate this. Descriptions of costs for stop-start
may be found in the RIA Chapter 2.11.6.6.
---------------------------------------------------------------------------
\425\ Maxwell Technologies, How Ultracapacitors Improve Starting
Reliability for Truck Fleets, 2016.
---------------------------------------------------------------------------
We are not aware of stop-start systems that are commercially
available for conventional vocational vehicles today, but this feature
is available as part of some current hybrid systems. We are aware of
one supplier who is demonstrating today a capacitor-based stop-start
system with on-board electronics sufficient to protect a HHD engine and
even power a PTO.\426\ Furthermore, other manufacturers and suppliers
are researching this.\427\ Therefore we are confident heavy-duty stop-
start systems for conventional vehicles will be feasible in the time
frame of Phase 2. Where stop-start is relied upon as part of a
certified configuration with components installed by a secondary
manufacturer, these will be subject to specifications and installation
instructions of the certifying manufacturer.
---------------------------------------------------------------------------
\426\ See comment submitted by Effenco describing such a system
designed for a refuse packer.
\427\ See phone log for L. Steele, conversation with B. Van
Amburg, May 2016.
---------------------------------------------------------------------------
In response to comments, we are adopting some permissible over-ride
conditions under which a stop-start system may either restart sooner
than otherwise or not shut down an engine. Navistar, Waste Management
and others commented that vehicles with a significant power take-off
(PTO) load will not be able to accommodate start/stop technology. As
with neutral idle, we agree that engagement of the PTO while driving
should be an allowable over-ride condition, as there are some vehicles
that must conduct PTO work while underway. For example, cement mixers
must continually rotate the drum and refuse trucks routinely compact
their load throughout their neighborhood collection activity.
Additional over-rides are discussed in the RIA Chapter 2.9.3.4. If a
manufacturer designs a system that does not need as many over-rides due
to additional electrification or other on-board systems, then an
application for off-cycle credit may be submitted, to recognize a
greater effectiveness. The regulations at 40 CFR 1037.660 specify the
allowable over-rides.
The effectiveness of stop-start as recognized in GEM will be
engine-dependent. Engines with high emissions/fuel consumption at idle
will see greater reductions. Also, vehicles that idle frequently will
see greater reductions. Based on GEM simulations using the final
vocational vehicle test cycles, the agencies project stop-start to
provide fuel efficiency improvements up to 14 percent for diesel
vehicles, and up to 11 percent for gasoline vehicles, depending on the
regulatory subcategory. See RIA 2.9.3.4. The data points for
calculating the fueling over the transient and drive idle cycles are
obtained from the engine map, and vehicle certifiers may input Yes or
No when running GEM, to indicate whether the engine shuts off within
five seconds of zero vehicle speed with the service brake applied.
Allison commented that GEM should calculate fueling only for a couple
seconds before assuming the engine shuts down in a stop-start system.
Navistar suggested that we recognize that some fleets--e.g. heavy haul,
refuse, mixer trucks and tow trucks--may elect to have this feature set
as a programmable parameter to ensure maximum safety is maintained. We
believe that five seconds is appropriate because we expect a wide
variety of stop-start solutions to be deployed in the vocational
vehicle market, and we anticipate modest use of over-ride conditions.
Setting a shorter duration before shutdown could over-estimate the
reductions achieved by this technology in use. We believe this is a
fair way to represent that the system may not have the designed
effectiveness under all conditions.
As with the other idle reduction technologies described above,
stop-start can reasonably be applied for vocational vehicles where this
feature would not frequently encounter an over-ride condition. Vehicles
with very little driving in transient conditions or with high PTO
operation can apply this technology, although they would see reduced
effectiveness in use. Chassis manufacturers certifying refuse trucks to
the optional custom chassis standards may enter Yes in the input field
in GEM for stop-start and the effectiveness will be computed based on
the default 350 hp engine with 5-speed HHD automatic transmission..
Manufacturers opting to certify refuse trucks to the primary standards
will have an option to be recognized for enhanced stop-start systems
through the powertrain test See RIA 2.9.3.4 and 2.9.5.1.4.
The agencies received comments from Allison Transmission where they
observed a seven percent NOX co-benefit of stop-start idle
reduction technology on transit buses. Daimler also commented that it
is investigating the potential for improving heat retention in the SCR
system via stop-start, but because of early stages of development it
cannot verify or quantify actual benefits. The agencies also conducted
independent NOX testing of engines at idle; however, the
data are not conclusive enough for the agencies to quantify the
NOX co-benefits of vocational workday idle reduction as part
of this rulemaking.
(v) Weight Reduction
The agencies are predicating the final vocational vehicle standards
in part on use of material substitution for weight reduction. The
method of recognizing this technology is similar to the method used for
tractors. The agencies have created a menu of vocational chassis
components with fixed reductions in pounds that may be entered in GEM
when substituting a component made of a more lightweight material than
the base component made of mild steel. According to the 2009 TIAX
report, there are freight-efficiency benefits to reducing weight on
vocational vehicles that carry heavy cargo, and tax savings potentially
available to vocational vehicles that remain below excise tax weight
thresholds. This report also estimates that the cost effectiveness of
weight reduction over urban drive cycles is potentially greater than
the cost effectiveness of weight reduction
[[Page 73700]]
for long haul tractors and trailers. We are adopting as proposed a GEM
allocation of half the weight reduction to payload and half to reduced
chassis weight. We did not receive comment suggesting a different
weight allocation. The menu of components available for a vocational
vehicle weight reduction in GEM is presented in Section V.D.1 and in
the RIA Chapter 2.9, and is in the regulations at 40 CFR 1037.520. It
includes fewer options than proposed, due to persuasive comments from
Allison that aluminum transmission cases and clutch housings are
standard for automatic transmissions. The American Iron and Steel
Institute (AISI) commented that light weight values for high strength
steel should be adjusted upward, citing light-duty vehicle weight
reduction approaches using high strength steel and saying these
improvements should apply to the heavy-duty sector as well. AISI also
commented against the inclusion of any light-weight components as a
compliance mechanism for vocational vehicles without technical data to
support the weight saving values. At proposal, we based our weight
reduction values for class 8 vocational vehicles on the values adopted
for use in certifying tractors in Phase 1. We proposed to scale these
values down for lighter weight vehicles based either on number of axles
or other attributes based on engineering judgment. We also considered
information supplied by expert members of the Aluminum Transportation
Group.\428\ The final rules reflect revised weight reduction values in
response to the comments from AISI, and in further consideration of
information provided by the Aluminum Transportation Group. We were
unable to make use of the additional references submitted by AISI as
part of this standard-setting process, either because the technology
requires redesign rather than material substitution, or because we did
not see a way to apply the light-duty information to heavy-duty
vehicles. For setting stringency, however, we do not rely on any values
in the lookup table except those for aluminum wheels (although these
performance-based standards may be achieved in the manner deemed most
cost-effective by manufacturers). The stringency of the final
vocational vehicle standards for custom chassis transit buses and
vehicles in the primary program is based in part on use of aluminum
wheels in 10 positions on 3-axle vocational vehicles (250 lbs) and in 6
wheel positions on 2-axle vocational vehicles (150 lbs). Based on the
TIAX report and experience with the tractor program, the agencies are
confident that manufacturers who choose to incorporate weight reduction
on vocational vehicles will have a number of feasible material
substitution choices at the chassis level, which could add up to weight
savings of hundreds of pounds. The agencies do not have information
about any subset of vocational vehicles that would be unable to adopt
aluminum wheels, thus our projected adoption rates are much higher than
at proposal. Our projected adoption rate is revised upward based on the
determination that the technology package is smaller (fewer pounds
removed than at proposal) and that aluminum wheels are widely available
and feasible. We have learned through stakeholder outreach that weight-
sensitive applications such as ready-mix concrete and refuse have
already extensively applied weight reduction technologies, for freight
efficiency reasons.\429\ Therefore the agencies have not predicated the
standards for these custom chassis on further weight reduction.
---------------------------------------------------------------------------
\428\ See email to L. Steele from D. Richman dated March 19,
2015 with attachments.
\429\ See phone log for L. Steele, conversation with Terex (Aug
2015) and meeting with Autocar (April 2016).
---------------------------------------------------------------------------
Based on the default payloads in GEM, and depending on the
vocational vehicle subcategory, the agencies estimate a reduction of
250 lbs would offer a fuel efficiency improvement of up to one percent
for HHD vehicles, and a reduction of 150 pounds would offer a fuel
efficiency improvement up to 0.8 percent for MHD vehicles, and up to
1.5 percent for LHD vehicles. See RIA 2.9.3.5.
The agencies received comment that the HD Phase 2 program should
recognize the enhanced benefit of weight reduction of rotating
components, but the agencies lack sufficient data to incorporate the
necessary programming in GEM to enable this feature. Manufacturers
wishing to obtain credit for lightweight components beyond those on the
menu in the regulations or for use of lightweighting technologies that
are more effective than we have projected, may apply for off-cycle
credits.
(vi) Electrified Accessories
Although we did not propose to allow pre-defined credit for
electrified accessories as was proposed for tractors, we received
comment requesting that this be allowed for vocational vehicles. As
discussed above, the agencies are projecting that some electrified
accessories will be necessary as part of the development of stop-start
idle reduction systems for vocational vehicles. The technology package
for vocational stop-start includes costs for high-efficiency
alternator, electric water pump, electric cooling fan, and electric oil
pump. However, because the GEM algorithm for determining the fuel
benefit of stop-start does not account for any e-accessories, vehicles
certified with stop-start are also eligible to be certified using an
improvement value in the e-accessories column.
Daimler, ICCT, Bendix, Gentherm, Navistar, Odyne, and CARB asked
the agencies to consider electric cooling fans, variable speed water
pumps, clutched air compressors, electric air compressors, electric
power steering, electric alternators, and electric A/C compressors.
ICCT cautioned that certain accessories would be recognized over an
engine test and credit should not be duplicated at the vehicle level.
Bosch suggested that high-efficiency alternators be considered, and
suggested use of a standard component-level test for alternators to
determine their efficiency, and establishment of a minimum efficiency
level that must be attained. Although there are industry-accepted test
procedures for measuring the performance of alternators, we do not have
sufficient information about the baseline level performance of
alternators to define an improved level that would qualify for a
benefit at certification. We are not able to set a fixed improvement
for electric cooling fans or clutched accessories due to similar
challenges related to baselines and defining the qualifying technology.
In consideration of ICCT's comment, we are not including water pumps
and oil pumps among the components eligible for a fixed improvement
because we believe that our engine test procedure will recognize
improvements that would be seen in the real world from electrifying
these. Thus, we believe it is appropriate to offer a fixed technology
improvement for use of electric power steering and an electric A/C
compressor as an input to GEM.
The agencies have conducted modeling in GEM to compare
configurations with different default accessory loads, and have
demonstrated there is a measurable effect of reducing 1 kW of accessory
load for each vocational subcategory (see RIA 2.9.3.6). The agencies
have incorporated information from this GEM modeling with information
from comments provided by ICCT, the TIAX 2009 technology report, CARB's
Driveline Optimization report, and the 2010 NAS report to assign fixed
improvement values for the defined technologies as
[[Page 73701]]
shown in Table V-16. These values are consistent with the TIAX study
that 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.\430\ The RIA Chapter 2.9
explains how these effectiveness values were obtained.
---------------------------------------------------------------------------
\430\ TIAX 2009, pp. 3-5.
Table V-16--Effectiveness of Vocational E-Accessories
------------------------------------------------------------------------
Effectiveness
Technology % Subcategories
------------------------------------------------------------------------
Electric A/C Compressor........ 0.5 HHD.
1.0 MHD & LHD.
Electric Power Steering........ 0.5 Regional.
1.0 Multipurpose & Urban.
------------------------------------------------------------------------
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. Electrification of
accessories can individually improve fuel consumption, regardless of
whether the drivetrain is a strong hybrid. Some vocational vehicle
applications have much higher accessory loads than is assumed in the
default GEM configurations. In the real world, there may be some
vehicles for which there is a much larger potential improvement
available than those listed above, as well as some for which
electrification is not cost-effective. To date, accessory
electrification has been associated only with hybrids, although
CalStart commented they are optimistic that accessory electrification
will become more widespread among conventional vehicles in the time
frame of Phase 2.
Electric power steering (EPS) or Electrohydraulic power steering
(EHPS) provides a potential reduction in CO2 emissions and fuel
consumption over hydraulic power steering because of reduced overall
accessory loads. This eliminates the parasitic losses 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 is feasible for most vehicles with a
standard 12V system. Some heavier vehicles may require a higher voltage
system which may add cost and complexity.
Manufacturers wishing to obtain credit for technologies that are
more effective than we have projected, or technologies beyond the scope
of this defined technology improvement, may apply for off-cycle
credits.
(vii) Tire Pressure Systems
TPMS
The agencies did not propose to base the vocational vehicle
standards on the performance of tire pressure monitoring systems
(TPMS). However, we received comment that we should consider this
technology. See discussion in Section III.D.1.b. In addition to
comments related to tractors and trailers, RMA commented that TPMS can
also apply to the class 2b-6 vehicles, and if the agencies add TPMS to
the list of recognized technologies, that this choice should also be
made available to class 2b-6 vehicles. Bendix commented that TPMS is a
proven product, readily available from a number of truck, bus, and
motor coach OEMs. Autocar commented that TPMS is useful for refuse
truck applications. Tirestamp said that TPMS is ideal for trucks and
buses that are unable to apply ATIS due to difficulties plumbing air
lines externally of the axles. The agencies find these comments to be
persuasive. As a result, we are finalizing vocational vehicle standards
that are predicated on the performance of TPMS in all subcategories,
including all custom chassis except emergency vehicles and concrete
mixers. Available information indicates that it is feasible to utilize
TPMS on all vocational vehicles, though systems for heavy vehicles in
duty cycles where the air in the tires becomes very hot must be
ruggedized so that the sensors are protected from this heat. Such
devices are commercially available, though they cost more. To account
for this in our analysis, we have projected a lower adoption rate for
TPMS in Urban vehicles than for Regional or Multipurpose vehicles,
rather than by increasing the cost and applying an equal adoption rate.
We are assigning a fixed improvement in GEM for use of this technology
in vocational vehicles of one percent for Regional vehicles including
motor coaches and RV's (the same as for tractors and trailers) and 0.9
percent for Multipurpose, Urban, and other custom chassis vocational
vehicles, recognizing that the higher amount of idle is likely to
reduce the effectiveness for these vehicles. These values will be
specified as GEM inputs in the column designated for tire pressure
systems.
ATIS
The agencies did not propose to base the vocational vehicle
standards on the performance of automatic tire inflation systems
(ATIS), otherwise known as central tire inflation (CTI). However, we
did receive comment indicating that it is feasible on some vocational
vehicles. Air CTI commented that central tire inflation is not only
feasible but enhances safety on vehicles such as dump trucks and heavy
haul vehicles that need higher tire pressures under certain driving
conditions, such as when loaded, but need lower tire pressures when
running empty or operating off-road. Tirestamp commented that ATIS can
be plumbed externally for trucks and buses, but such systems have a
propensity for damage and Autocar has provided information about how
much extra weight this plumbing adds to the chassis. ATA commented that
some onboard air pressure systems may not be able to pressurize tires
sufficiently for very heavy vehicles. The primary vocational vehicle
standards are not predicated on any adoption of this because the
agencies do not have sufficient information about which chassis will
have an onboard air supply for purposes
[[Page 73702]]
of an air suspension or air brakes. ATIS would logically only be
adopted for vehicles that already need an onboard air supply for other
reasons. Comments received for custom chassis were supportive of
standards predicated on ATIS for buses with air suspensions. These
comments are again persuasive. As a result, we are basing the optional
standards for refuse trucks, school buses, coach buses, and transit
buses in part on the adoption of ATIS. Although many motor homes have
onboard air supply for other reasons making ATIS technically feasible,
it is sufficiently costly that it is not practically feasible.
Furthermore, for the same reasons stated above about the disadvantages
of installing external plumbing for ATIS on some trucks and buses, we
have determined it is not feasible for emergency vehicles or concrete
mixers. Nonetheless, we are allowing vocational vehicles including all
custom chassis to obtain credit for the performance of ATIS through a
GEM input with a fixed improvement of 1.2 percent for Regional vehicles
including motor coaches and RV's (the same as for tractors and
trailers) and 1.1 percent for Multipurpose, Urban, and other custom
chassis vocational vehicles, recognizing that the higher amount of idle
is likely to reduce the effectiveness for these vehicles. These values
will be specified as GEM inputs in the column designated for tire
pressure systems. See discussion in Section III.D.1.b for our reasoning
behind this effectiveness value.
(viii) HFC Refrigerant From Cabin Air Conditioning (A/C) Systems
Manufacturers can reduce direct A/C leakage emissions by utilizing
leak-tight components. EPA's HFC direct emission leakage standard is
independent of the CO2 vehicle standard. Manufacturers may
choose components from a menu of leak-reducing technologies sufficient
to comply with the standard, as opposed to using a test to measure
performance. See 76 FR 57194. A discussion of comments regarding use of
low global warming potential refrigerants and EPA's responses to those
comments can be found in Section I.F of this Preamble.
In Phase 1, EPA adopted a HFC leakage standard to assure that high-
quality, low-leakage components are used in each air conditioning
system installed in HD pickup trucks, vans, and combination tractors
(see 40 CFR 1037.115). We did not adopt a HFC leakage standard in Phase
1 for systems installed in vocational vehicles. In the final Phase 2
program, as proposed, EPA is extending the HFC leakage standard to all
vocational vehicles. Beginning in the 2021 model year, vocational
vehicle air conditioning systems with a refrigerant capacity of greater
than 733 grams must meet a leakage rate of 1.50 percent leakage per
year and systems with a refrigerant capacity of 733 grams or lower meet
a leakage standard of 11.0 grams per year. EPA has determined that an
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.
Research has demonstrated 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 began in the 2012 model year and the
HD Phase 1 rule that began in the 2014 model year. 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.\431\ 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 2021.
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' to 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.
---------------------------------------------------------------------------
\431\ Team 1-Refrigerant Leakage Reduction: Final Report to
Sponsors, SAE, 2007.
---------------------------------------------------------------------------
We received comments from CARB and Daimler in support of applying
these leakage standards to vocational vehicles. Daimler specifically
expressed support for excluding A/C systems used to cool the cargo area
of trucks, as well as for allowing helium testing as a compliance
option. Thus, we are adopting these provisions as proposed. EMA
commented with concerns about the burden of certifying A/C systems that
are installed by secondary manufacturers. Section V.D.2 discusses how
we have addressed the concerns related to secondary manufacturers. We
also received comments from RVIA asking for clarification whether the
cargo area exclusion also applied to A/C units that cool the living
space of recreational vehicles. In response, we are adding clarifying
language to the regulations at 40 CFR 1037.115 excluding A/C systems
that are not powered by the vehicle's propulsion engine.
The A/C system leakage control costs presented in the RIA Chapter
2.9 and 2.11 are applied to all heavy-duty vocational vehicles. 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.
(b) Engine Technologies Considered in Vehicle Standard-Setting
Section II explains the technical basis for the agencies' proposed
separate engine standards. The agencies are not predicating the
vocational vehicle standards on different diesel engine technology
packages than those presumed for compliance with the separate diesel
engine standards. However, for each model year of the Phase 2
standards, the agencies are predicating the SI-powered vocational
vehicle standards on a gasoline engine technology package that includes
additional technologies beyond those presumed for compliance with the
MY 2016 gasoline engine standard. Put another way, the stringency of
certain of the vocational vehicle standards, and those for vehicles
using SI engines in particular, reflect in part improvements in engine
efficiency which are not measured in the engine standard or in engine
certification.
The primary vocational vehicle standards vary depending on whether
the engines powering those vehicles are compression-ignition or spark-
ignition.\432\ As in Phase 1, this is not the case for the custom
chassis standards, because GEM uses a default engine that is the same
for every regulated custom chassis type, regardless of the actual
engine being installed. As described above in Section II, the Phase 2
vehicle certification tool, GEM, requires manufacturers certifying to
the primary standards to enter specific engine performance data, where
emissions and
[[Page 73703]]
fuel consumption profiles will differ significantly depending on the
engine's architecture.\433\
---------------------------------------------------------------------------
\432\ Specifically, EPA is adopting CO2,
N2O, and CH4 emission standards for new heavy-
duty engines over an EPA specified useful life period (See Section
II).
\433\ See Section II.D.5 for an explanation of which engine
architecture will need to meet which standard.
---------------------------------------------------------------------------
As explained in Section II.A.2, engines will continue to be
certified over the FTP test cycle via direct testing, not GEM
simulation. The FTP test cycle that is applicable for bare vocational
engines is very different than the test cycles for vocational vehicles
in GEM. The FTP is a very demanding transient cycle that exercises the
engine over its full range of capabilities. In contrast, the cycles
evaluated by GEM measure emissions over more frequently used engine
operating ranges. The ARB Transient vehicle cycle represents city
driving, and the highway cruise cycles measure engine operation that is
closer to steady state. Each of these cycles is described in the RIA
Chapter 3.4.2. A consequence of recognizing engine performance at the
vehicle level is that further engine improvements (i.e. improvements
measureable by duty cycles that more precisely represent driving
patterns for specific subcategories of vocational vehicles) can be
evaluated as components of a technical basis for a vocational vehicle
standard.\434\ For this reason, the agencies considered whether any
different engine technologies should be included in the feasibility
analysis for the vehicle standards (and potentially, in the standard
stringency).
---------------------------------------------------------------------------
\434\ As noted in Section II.B.2 above, manufacturers also have
greater flexibility to meet a vehicle standard if engine
improvements can be evaluated as part of compliance testing.
---------------------------------------------------------------------------
We did not propose to predicate any diesel vocational vehicle
standard on additional engine technology, including engine waste heat
recovery (WHR). We do not believe this technology would show
significant benefit in vocational vehicle applications due to their
driving cycles, which have fewer highway miles than tractors. Thus, the
final vocational vehicle standards assume that diesel engines perform
at the level of the certified engine configuration.
The agencies received extensive comment on our assessment of SI
engine technologies, and how these could be included in the vocational
vehicle technology packages. We predicated the proposed MY 2027 SI-
powered vocational vehicle standards on additional friction reduction,
for a 0.6 percent fuel efficiency improvement. UCS, EDF, NRDC, and ICCT
ask the agencies to rely on the 2015 SwRI study suggesting 8 percent
improvement is possible. UCS highlights packages #16 and #22 of the
SwRI report for the agencies' further consideration. These packages
were assembled by SwRI to simulate the combined performance of engine
technologies over some well-known vehicle drive cycles. Because none of
the technical data referenced by these commenters provides information
on how these technologies perform over the HD gasoline engine FTP test
procedure, the agencies are considering these to be comments on the
GEM-based vocational vehicle standards, not comments on the separate
FTP-based SI engine standard. Please see Section II.D.2(b) of this
Preamble for the agencies' response to comments on the stringency of
the separate SI engine standard.
SwRI package #16 applies variable valve actuation and exhaust gas
recirculation to a 3.5 liter V6 engine. SwRI package #22 applies
stoichiometric direct gas injection, exhaust gas recirculation, dual
cam phasers, and advanced friction reduction to a 6.2 liter V8 engine.
All of the SwRI packages compare the future vehicle performance to a
pre-Phase 1 baseline, thus counting all the improvements already
presumed in the MY 2016 engine standard, so the delta between what the
commenter seeks and what the agencies proposed is considerably less
than initially appears (and than the commenter appeared to believe).
The agencies' default SI engine map for setting the SI-powered
vocational vehicle standards is a MY 2016 6.8 liter V8 engine. The RIA
Chapter 2.9.1 presents the EPA default map that meets the MY 2016
engine standard. We are adhering to the proposed approach of
recognizing SI engine improvements only in the vocational vehicle
standard. In response to comments, the agencies are adopting final
vehicle-level standards for SI-powered vocational vehicles that are
predicated in part on adoption of cylinder deactivation in addition to
the advanced friction reduction reflected in the proposal, both of
which have incremental costs beyond those needed to meet the separate
FTP-based engine standard, and both of which will be recognized over
the GEM vehicle cycles. Indeed, cylinder deactivation would not be
expected to be recognized at all over the engine FTP cycle (another
reason the improvement is reflected in the final vehicle standard). As
proposed, the effectiveness and adoption rate of Level 2 engine
friction reduction yields a fuel efficiency improvement of 0.6 percent.
By adding 30 percent adoption of cylinder deactivation with a vehicle-
cycle average effectiveness of 1 percent, and accounting for a dis-
synergy factor of 0.9, this yields an overall package effectiveness of
0.8 percent. Upon consideration of comments and the data in the SwRI
reports, we are not including EGR as a technology for stringency
purposes. EGR is potentially feasible, is not already presumed to be
adopted in the 2016 engine standard, and may possibly be recognized
over the GEM vehicle cycles to some extent. However, we did not have
sufficient data to confidently project an effectiveness or adoption
rate for this technology on vocational SI engines. Further, the Phase 2
HD pickup truck and van standards are not predicated on any adoption of
EGR technologies for SI vehicles. The RIA Chapter 2.9.1 describes how
each of the SI engine technologies are expected to perform over the GEM
vehicle cycles, as well as the method for projecting that the fuel
efficiency improvement will be 0.8 percent compared to the baseline SI
vehicle performance.
With respect to standards for engines used in custom chassis, we
understand that engines designed for heavy-duty emergency vehicles are
generally higher-emitting than other engines. However, because we are
maintaining a separate engine standard and regulatory flexibility such
as ABT, fire apparatus manufacturers will be able to obtain engines
that, on average, meet the Phase 2 engine standards. The agencies
further recognize that the engine map inputs to GEM in the primary
program could pose a difficulty for emergency vehicle manufacturers. If
we required engine-specific inputs then these manufacturers will have
to apply extra vehicle technologies to compensate for the necessary but
higher-emitting engine. The agencies are therefore not recognizing
vehicle-specific engine performance as part of the vehicle standard for
emergency vehicles (although the standards for emergency vehicles and
custom chassis do presume use of a certified Phase 2 engine).
Manufacturers of these vehicles must install an engine that is
certified to the applicable separate Phase 2 engine standard. However,
under the custom chassis program emergency vehicle manufacturers need
not follow the otherwise applicable Phase 2 approach of entering an
engine map in GEM. Instead, use of a custom chassis subcategory
identifier will instruct GEM to simulate the vehicle using an EPA
default engine.
[[Page 73704]]
(c) Technologies the Agencies Assessed But Did Not Use In Standard-
Setting
(i) Aerodynamics
The agencies did not propose to include aerodynamic improvements as
a basis for the Phase 2 vocational vehicle standards. However, we did
request comment on an option to allow credits for use of aerodynamic
devices such as fairings on a very limited basis. We received public
comments from AAPC in support of offering this as an optional credit,
with a suggestion to allow this option for a wide range of vehicle
sizes, and suggesting that the grams per ton-mile benefit could be
scaled down for larger vehicles. CARB commented in support of a Phase 2
program that would include use of aerodynamic improvements as a basis
for the stringency, suggesting that a large fraction of the vocational
vehicle fleet could see real world benefits from use of aerodynamic
devices. Because we do not have sufficient fleet information to
establish a projected application rate for this technology, we are not
basing any of the final standards for vocational vehicles on use of
aerodynamic improvements. See 80 FR 40303. In consideration of
comments, however, we are adopting provisions for vocational vehicles
to optionally receive an improved GEM result by certifying use of a
pre-approved aerodynamic device, and are expanding eligibility criteria
from the relatively narrow criteria proposed.
Based on testing supported by CARB, the agencies have developed a
list of specific aerodynamic devices with pre-defined improvement
values (in delta CDA units), as well as criteria regarding
which vehicles are eligible to earn credit in this manner. See Chapter
2.9.4.1 of the RIA. In response to comments, we are allowing a wide
range of vehicles to be eligible to use this option. Regional
vocational vehicles in any weight class may use this option, subject to
restrictions on the size of the chassis (see 40 CFR 1037.520). The
degree of change in CDA for each pre-approved device has
been set at conservative values due to the small number of
configurations tested and the uncertainty inherent in those results.
Manufacturers wishing to receive credit for other aerodynamic
technologies or on other vehicle configurations may seek credit using
the test procedures described in 40 CFR 1037.527. Manufacturers using
this credit provision may enter the pre-defined delta CDA as
an input to GEM, and the simulation will determine the effectiveness
over the duty cycle. Using this approach, we do not need to set a
scaled benefit for different sizes of vehicles. When the vehicle weight
class and duty cycle is specified, a default chassis mass and payload
are simulated in GEM. When the pre-defined delta CDA is
entered, the simulation returns a resulting improved performance with
respect to the specified chassis configuration. GEM will logically
return a smaller improvement for heavier vehicles.
The final Regional composite duty cycle in GEM for vocational
vehicles has a weighted average speed of 38 mph, increased from the
average speed at proposal due to a heftier 56 percent composite
weighting of the 65 mph drive cycle. The agencies have learned from the
NREL duty cycle analysis that vocational vehicles with operational
behavior of a regional nature accumulate more miles at highway speeds
than previously assumed.
Using GEM simulation results, the agencies estimate the fuel
efficiency benefit of improving the CDA of a Class 6 box
truck by 11 percent (0.6 m\2\ delta CDA off of a default of
5.4 m\2\) at approximately five percent over the Regional composite
test cycle. This same delta CDA simulated in GEM on a class
8 Regional vocational vehicle results in an overall improvement of less
than four percent because the default CDA in GEM for class 8
vocational vehicles is 6.86 m\2\ so the change in CDA is
only nine percent. Although in actual operation the added weight of
aerodynamic fairings may reduce the operational benefits of these
technologies when driving at low speeds, the agencies are not applying
any weight penalty as part of the certification process for vocational
aerodynamic devices.
As described in the NPRM, we are requiring chassis manufacturers
employing this option to provide assurances to the agencies that these
devices will be installed as part of the certified configuration, even
if the installation is completed by another entity. We received many
comments on the requirements for secondary manufacturers as they apply
for vocational aerodynamics as well as other technologies that may be
specified by a chassis manufacturer but installed later. See Section
I.F.2 and Section V.D.2 for further discussion of delegated assembly
issues.
(ii) Full Electric Trucks
Given the high up-front costs and the developing nature of this
technology, the agencies do not project fully electric vocational
vehicles to be widely commercially available in the time frame of the
final rules. For this reason, the agencies have not based the Phase 2
standards on adoption of full-electric vocational vehicles. We received
many comments on electric trucks and buses. Specifically, EEI provided
information on the total cost of ownership for electric trucks, and
some applications may see attractive long term cost scenarios for
electric trucks or buses, when considering maintenance savings. While
we are not predicating the final vocational vehicle standards on
adoption of full electric trucks or buses, we have reinstated an
advanced technology credit multiplier, in response to comment. See
Section I.C.1.(b) for a discussion of credit multipliers.
To the extent this technology is able to be brought to market in
the time frame of the Phase 2 program, there is currently a
certification path for these chassis from Phase 1, as described in
EPA's regulations at 40 CFR 1037.150 and NHTSA's regulations at 49 CFR
535.8.
(iii) E-PTO
Although the primary program does not simulate vocational vehicles
over a test cycle that includes PTO operation, the agencies are
adopting a revised hybrid-PTO test procedure. See 76 FR 57247 and 40
CFR 1037.540. Recall that we regulate vocational vehicles at the
incomplete stage when a chassis manufacturer may not know at the time
of certification whether a PTO will be installed or how the vehicle
will be used. Chassis manufacturers may rarely know whether the PTO-
enabled vehicle will use this capability to maneuver a lift gate on a
delivery vehicle, to operate a utility boom, or merely to keep it as a
reserve item to add value in the secondary market. For these reasons,
it would not be fair to require every vocational vehicle to certify to
a standard test procedure with a PTO cycle in it. Thus, we are not
basing the final standards on use of technology that reduces emissions
in PTO mode.
There are products available today that can provide auxiliary
power, usually electric, to a vehicle that needs to work in PTO mode
for an extended time, to avoid idling the main engine. There are
different designs of electrified PTO systems on the market today. Some
designs have auxiliary power sources, typically batteries, with
sufficient energy storage to power an onboard tool or device for a
short period of time, and are intended to be recharged during the
workday by operating the main engine, either while driving between work
sites, or by idling the engine until a sufficient state of charge is
reached that the engine may shut off. Other designs have
[[Page 73705]]
sufficient energy storage to power an onboard tool or device for many
hours, and are intended to be recharged as a plug-in hybrid at a home
garage. In cases where a manufacturer can certify that a PTO with an
idle-reduction technology will be installed either by the chassis
manufacturer or by a second stage manufacturer, the hybrid-PTO test
cycle may be utilized by the certifying manufacturer to measure an
improvement factor over the GEM duty cycle that otherwise applies to
that vehicle. In addition, the delegated assembly provisions will apply
(see Section V.D). See RIA Chapter 3.7.4 for a discussion of the
revisions to the PTO test cycle.
The agencies will continue the hybrid-PTO test option that was
available in Phase 1, with a few revisions. See the regulations at 40
CFR 1037.540. The calculations recognize fuel savings over a portion of
the test that is determined to be charge-sustaining as well as a
portion that is determined to be charge-depleting for systems that are
designed to power a work truck during the day and return to the garage
where recharging from an external source occurs during off-hours. The
agencies requested comment on this idea, and received comment from
Odyne relating to the population and energy storage capacity of plug-in
e-PTO systems, for which a charge-depleting test cycle may be more
appropriate. We also partnered with DOE-NREL to characterize the PTO
operation of over 80 trucks with over 1,500 total operating days, and
our final regulations include a utility factor table based on these
data for use in determining the effectiveness of a hybrid PTO
system.\435\ Manufacturers wishing to conduct testing as specified may
apply for off-cycle credits derived from e-PTO or hybrid PTO
technologies.
---------------------------------------------------------------------------
\435\ National Renewable Energy Laboratory July 2016,
``Characterization of PTO and Idle Behavior for Utility Vehicles,''
NREL/TP-5400-66747.
---------------------------------------------------------------------------
(2) Projected Vehicle Technology Package Effectiveness and Cost
(a) Baseline Vocational Engine and Vehicle Performance
The baseline vocational vehicle configurations for each of the nine
regulatory subcategories for CI-powered and six SI-powered vehicles are
described in RIA Chapter 2.9.1, as well as the seven baseline custom
chassis configurations. The agencies set the baseline rolling
resistance coefficient for the 2017 vocational vehicle fleet at 7.7 kg/
metric ton, which assumes that 100 percent of tires meet the Phase 1
standard.
In the agencies' Phase 2 baseline configurations, we need to
specify transmission type, gear number, and gear ratios, as well as
axle ratios and tire sizes because these were all defaults in Phase 1.
Phase 1 GEM modeled all vehicles with a manual transmission, but as
explained elsewhere, the majority of vocational vehicles in today's
U.S. fleet have automatic transmissions. By specifying a mix of manual
and automatic transmissions with different sets of gears in the
baseline, we are not applying technology beyond what is needed to
comply with Phase 1, we are merely defining an appropriate set of
baselines. We do not consider these specifications to represent
technology that improves fuel efficiency beyond Phase 1, it is merely a
better representation of today's fleet than the Phase 1 GEM that had
100 percent default manual transmissions. In the Regional HHD diesel
subcategory, the baseline is a weighted average of two vehicle specs:
95 percent being a 455 hp engine paired with a manual transmission with
ten forward gears, and five percent being a 350 hp engine paired with a
6-speed automatic transmission. The HHD Multipurpose subcategory is a
weighted average of three vehicle specs: 80 percent being a 350 hp
engine paired with a 6-speed automatic transmission, 10 percent being a
455 hp engine paired with a 10-speed manual transmission, and 10
percent being a 350 hp engine paired with a 10-speed manual. The
automatic transmissions specified in the LHD, MHD, and HHD Regional and
Multipurpose subcategories have six forward gears in the baseline,
while automatic transmissions in the Urban subcategories have five
forward gears in the baseline. This is based on market research,
stakeholder outreach, and comments received on the NODA. No vehicle-
level efficiency-improving technology is included in the baseline
vehicles, nor in the agencies' analyses for the no-action reference
case. Specifically, we have assumed zero adoption rates for other types
of transmissions, other numbers of gears, idle reduction, and
technologies other than Phase 1 compliant LRR tires in both the
nominally flat baseline and the dynamic baseline reference cases.
Technology adoption rates for Alternative 1a (nominally flat baseline)
can be found in the RIA Chapter 2.11. Chapter 2.11.8 presents the
adoption rates for tires on vocational vehicles with different levels
of rolling resistance, including the 100 percentadoption rate of tires
with Level 1 CRR in the reference case and in model years preceding
Phase 2. In this manner, we have defined a reference vocational vehicle
fleet that meets the Phase 1 standards and includes reasonable
representations of vocational vehicle technology and configurations.
The agencies note that the baseline performance derived for the
final rules varies between regulatory subcategories--as noted above,
this is one of the reasons the agencies are adopting multiple
subcategories with discrete standards. The range of performance at
baseline is due to the range of attributes and modeling parameters,
such as transmission characteristics, final drive ratio, and vehicle
weight, which were selected to represent a range of performance across
this diverse segment. The agencies received persuasive comment
regarding the appropriateness of the baseline configurations, and have
made revisions accordingly. For example, we have reduced the LHD
default aerodynamic drag area from 5.4 to 3.4 square meters. We are
confident these adequately represent a reasonable range of vocational
chassis configurations currently manufactured in the US. Details of the
vehicle configurations, including reasons why they are reasonably
included as baseline technologies, are discussed in the RIA Chapter
2.9.2.
At proposal the agencies adjusted the vocational vehicle GEM
numerical baselines using assumptions about the sales mix in the
vocational fleet before applying the reductions from technologies. 80
FR 40308. In this process, we developed proposed baseline values that
we believed would minimize inappropriate incentives for manufacturers
to certify chassis in an inappropriate subcategory. The proposed
approach included testing each baseline vehicle over all three duty
cycles and applying weighted average adjustments to each GEM output to
create normalized baselines, 80 FR 40308. We received adverse comment
on this approach from many commenters--indeed, no commenter supported
this ``normalization'' approach. The proposed normalization approach
was an attempt to adjust for instances where the agencies' information
on baseline configurations was not fully complete. Most commenters
either opposed or were confused by the proposed normalization process.
As explained in this Section V., the agencies are adopting final
standards for vocational vehicles using the same methodology as for all
the other standards in this rulemaking, and
[[Page 73706]]
so are neither normalizing nor equalizing any of the data relating to
either the baseline or the standard. (Equalization is discussed
separately in Section V.C.(2)(d) below.) The agencies have received a
great deal of information from manufacturers since proposal which
rectify weaknesses in our baselines, and make any normalization
unnecessary.\436\ In the final rules we have applied other methods
(chiefly certain equipment-based constraints) to avoid creating
inappropriate incentives for manufacturers to certify chassis in
inappropriate subcategories. The final standards are calculated by
applying improvements as described below in Section V.C.(2)(c) to the
GEM results presented in Table V-17 and Table V-18--the same
methodology as used to develop the other Phase 2 standards.
---------------------------------------------------------------------------
\436\ See memorandum dated July 2016 titled, ``Summary of
Comments on Vocational Vehicle Baselines,'' see Docket EPA-HQ-OAR-
2014-0827.
---------------------------------------------------------------------------
Diesel engines used in vocational vehicles can be either Light,
Medium, or 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. Because of these
differences, the GEM simulation of baseline vocational CI engines
includes four engines--one for LHD, one for MHD, and two for HHD.
Detailed descriptions can be seen in Chapter 4 of the RIA. These four
engine models have been employed in setting the vocational vehicle
baselines, as described in the RIA Chapter 2.9.1.
The four baseline diesel engines represent fuel consumption
improvements beyond currently available engines to achieve the
performance level of a 2017 model year diesel engine, as described in
the RIA Chapter 2.9.1. Using the values for compression-ignition
engines, the baseline performance of vocational vehicles is shown in
Table V-17.
Table V-17--Baseline Vocational Vehicle Performance With CI Engines
----------------------------------------------------------------------------------------------------------------
Light heavy- Medium heavy-
Duty cycle duty Class 2b- duty Class 6- Heavy heavy-
5 7 duty Class 8
----------------------------------------------------------------------------------------------------------------
Baseline Emissions Performance in CO[ihel2] gram/ton-mile
----------------------------------------------------------------------------------------------------------------
Urban........................................................... 482 332 338
Multi-Purpose................................................... 420 294 287
Regional........................................................ 334 249 220
----------------------------------------------------------------------------------------------------------------
Baseline Fuel Efficiency Performance in gallon per 1,000 ton-mile
----------------------------------------------------------------------------------------------------------------
Urban........................................................... 47.3477 32.6130 33.2024
Multi-Purpose................................................... 41.2574 28.8802 28.1925
Regional........................................................ 32.8094 24.4597 21.6110
----------------------------------------------------------------------------------------------------------------
The agencies have developed a model in GEM of a MY 2016-compliant
gasoline engine. The agencies received comments on the process for
mapping gasoline engines for simulation purposes, as well as
information about the power rating and displacement that should be
considered as a baseline SI engine for vocational vehicle standard-
setting purposes. Upon consideration of comments, and based on
information obtained through testing at Southwest Research (see Chapter
5.5 of the SwRI report), we are adopting revised test procedures as
described in the RIA Chapter 3.1 that apply for mapping of both SI and
CI engines.\437\
---------------------------------------------------------------------------
\437\ Michael Ross, Validation Testing for Phase 2 Greenhouse
Gas Test Procedures and the Greenhouse Gas Emission Model (GEM) for
Medium and Heavy-Duty Engines and Powertrains, Final Report to EPA,
Southwest Research Institute, June 2016.
---------------------------------------------------------------------------
The baseline performance levels for vocational vehicles powered by
SI engines were derived using the EPA default fuel map described in the
RIA Chapter 2.9.1, for a 6.8 liter, V-8, 300 hp engine. We have used
the same engine rating and map for all weight classes of SI vocational
vehicles. This is because SI engines are not certified with a
regulatory structure that calls for declaring an intended service class
that is associated with a vehicle weight class. The agencies requested
comments on the merits of setting distinct numerical standards for HHD
vocational vehicles powered by SI engines, as well as comments on an
alternative approach that would have required any class 8 SI vocational
vehicles to certify to the standards for CI powered HHD vocational
vehicles, or to the MHD standards for SI vocational vehicles. In
response to comments expressing concern about orphaned vehicles as well
as concerns about mismatched engine and vehicle useful life, the
agencies are not finalizing distinct HHD SI vocational vehicle
standards. We are finalizing six subcategories for SI vocational
vehicles: Three LHD and three MHD. Where a manufacturer wishes to
certify a gasoline SI vocational vehicle with a GVWR over 33,000 lbs,
the final regulations allow that vehicle to be certified in one of the
MHD vehicle subcategories. Where a manufacturer wishes to certify an
alternative-fueled vocational vehicle with a GVWR over 33,000 lbs, the
regulations at 40 CFR 1036.108 specify whether that vehicle should be
treated as SI or CI for purposes of certification to the final Phase 2
standards. See Section II.D.5 of this Preamble for a discussion of
these provisions.
Table V-18 presents the baseline performance level for each weight
class computed by GEM by calculating the work done by the default
engine to move the GEM reference vehicles over the test cycles.
[[Page 73707]]
Table V-18--Baseline Vocational Vehicle Performance With SI Engines
------------------------------------------------------------------------
Medium heavy-
Light heavy-duty duty Class 6-7
Duty cycle Class 2b-5 (and Gasoline
c8) \a\
------------------------------------------------------------------------
Baseline Emissions Performance in CO[ihel2] gram/ton-mile
------------------------------------------------------------------------
Urban............................. 502 354
Multi-Purpose..................... 441 314
Regional.......................... 357 275
------------------------------------------------------------------------
Baseline Fuel Efficiency Performance in gallon per 1,000 ton-mile
------------------------------------------------------------------------
Urban............................. 56.4870 39.8335
Multi-Purpose..................... 49.6230 35.3325
Regional.......................... 40.1710 30.9441
------------------------------------------------------------------------
Note:
\a\ Vocational vehicles with GVWR over 33,000 lbs powered by alternate
fueled engines must certify to the vehicle standard corresponding with
the applicable engine standard.
(b) Technology Packages for Derivation of Final Standards
Prior to developing the numerical values for the final standards,
the agencies projected the mix of new technologies and technology
improvements that will be feasible within the available lead time. We
note that for some technologies, the adoption rates and effectiveness
may be very similar across subcategories. However, for other
technologies, either the adoption rate, effectiveness, or both differ
across subcategories. Where a technology performs differently over
different test cycles, these differences are reflected in the
derivation of the stringency of the standard. As discussed in Section
I.C.1, we assume manufacturers will incorporate appropriate compliance
margins for all measured GEM inputs. In other words, they will declare
values slightly higher than their measured values. As discussed in
Section II.D.5, compliance margins associated with fuel maps are likely
to be approximately one percent. For tire rolling resistance, our
feasibility rests on the Phase 1 standards, consistent with our
expectation that manufacturers will continue to incorporate the
compliance margins they considered necessary for Phase 1. With respect
to optional axle and/or transmission power loss maps, we believe
manufacturers will need very small compliance margins. These power loss
procedures require high precision so measurement uncertainty will
likely be on the order of 0.1 percent of the transmitted power. All of
these margins are reflected in our projections of the emission levels
that will be technologically feasible, as well as the associated costs.
In the package descriptions that follow, individual technology
costs are not presented, rather these can be found in the RIA Chapter
2.9 and 2.11. Section V.C.(2)(d) includes the costs estimated for
packages of technologies the agencies project can be applied to
vocational vehicles to meet the final Phase 2 standards.
(i) Transmission Packages
The agencies project an adoption rate of 50 percent in MY 2021, 60
percent in MY 2024, and nearly 70 percent in MY 2027 of transmissions
with improved gear efficiencies, with inputs over-riding the GEM
defaults obtained over the separate transmission efficiency test. We
are projecting an adoption rate of 10 percent in MY 2021, 20 percent in
MY 2024, and nearly 30 percent in MY 2027 of advanced shift strategies,
with demonstration of improvements recognized over the separate
powertrain test.
We are predicating the Phase 2 standards on zero adoption of added
gears in the HHD Regional subcategory, because it is modeled with a 10-
speed transmission, and vehicles already using that number of gears are
not expected to see any real world improvement by increasing the number
of available gears. For the Multipurpose and Urban HHD subcategories,
the MY 2021 projected adoption of adding gears is 5 percent, increasing
to 10 percent for MY 2024 and MY 2027. We are projecting 10 percent of
adding two gears in each of the other six subcategories for MY 2021,
increasing to 20 percent for MY 2024 and MY 2027. Commenters supported
the inclusion of this technology as part of the basis for the
standards. Allison commented that they have configured an 8-speed
vocational transmission. Eaton's new MHD dual clutch transmission has
seven forward gears. There is also a likelihood that suppliers of 8-
speed transmissions for HD pickups and vans may sell some into the LHD
vocational vehicle market.
We are also predicating the optional custom chassis standards for
school and coach buses in part on adoption of transmissions with
additional gears. In MY 2021, this adoption rate is five percent,
increasing to 10 percent in MY 2024 and 15 percent in MY 2027.
Manufacturers who certify these vehicles to the primary standards will
use GEM to model the actual gears and gear ratios; however,
manufacturers using custom chassis regulatory subcategory identifiers
will not have this flexibility. The agencies have estimated the cycle-
average benefit of adding an extra gear for school buses (modeled as
MHD Urban vehicles) at 0.9 percent and coach buses (with 6 gears in the
baseline) at 1.7 percent; therefore, manufacturers using custom chassis
regulatory subcategory identifiers for these vehicles will be permitted
to enter these pre-defined improvement values at the time of
certification.
Based on comment regarding our regulatory baselines, both the HHD
Regional and HHD Multipurpose subcategories now have manual
transmissions in the baseline configuration. For these vehicles, the
agencies project upgrades to automated transmissions such as either
AMT, DCT, or automatic, at an adoption rate of 30 percent in MY 2021,
50 percent in MY 2024, and 80 percent in MY 2027 for Regional vehicles.
For Multipurpose, beginning with 20 percent manuals in the baseline,
the adoption rate of automated transmissions is five percent in MY 2021
and 20 percent in MY 2024. Consistent with our projections of
technology adoption, the regulations require that any vocational
vehicles with manual transmissions must be certified as Regional in MY
2024 and beyond. This progression of
[[Page 73708]]
transmission automation is consistent with the agencies' projection of
10 percent manuals and 90 percent automated transmissions in the day
cab tractor subcategories in MY 2027. See Table III-13. HHD vocational
vehicles in regional service have many things in common with day cab
tractors, including the same assumed engine size and typical
transmission type, and a similar duty cycle. Thus, it is reasonable for
the agencies to make similar projections about the fraction of
automated vs manual transmissions adopted over the next decade among
these sectors. Also consistent with tractors, GEM simulates each of
these with a two percent fixed effectiveness improvement over the
performance of the MT in the baseline. To the extent any of these
transmissions provide additional effectiveness over the GEM cycles with
actual OEM data entered, it is not considered in the stringency of the
vocational vehicle HHD Regional standard (but would be recognized at
certification). The agencies have been unable to characterize the
relative effectiveness of DCT compared with AT sufficiently to apply it
as a technology on which stringency is predicated. This is consistent
with the public comment on this issue: Daimler did not support
inclusion of DCT as a technology with different effectiveness than AMT,
and Allison did not support treatment of either DCT or AMT as different
as AT.
In the seven subcategories (i.e. all of the remaining
subcategories) in which automatic transmissions are the base
technology, the agencies project that ten percent of the HHD vehicles
will apply an aggressive torque converter lockup strategy in MY 2021,
and 30 percent in the LHD and MHD subcategories. These adoption rates
are projected to increase to 20 percent for HHD and 40 percent for LHD
and MHD in MY 2024. We project adoption of aggressive torque converter
lockup for HHD automatics of 30 percent in MY 2027, and 50 percent for
LHD and MHD.
In setting the standard stringency, we have projected that non-
integrated (bolt-on) mild hybrids will not have the function to turn
off the engine at stop, while the integrated mild hybrids will have
this function. The agencies have estimated the effectiveness for
vehicles certified in the Urban subcategories will achieve as much as
13 percent improvement, and integrated systems that turn off at stop
will see up to 21 percent improvement depending on the subcategory. We
have also projected zero hybrid adoption rate (mild or otherwise) by
vehicles in the Regional subcategories, expecting that the benefit of
hybrids for those vehicles will be too low to merit use of that type of
technology. However, there is no fixed hybrid value assigned in GEM
and, for any vehicles utilizing hybrid technology, the actual
improvement over the applicable test cycle will be determined by
powertrain testing, which would likely reflect some benefit of hybrids
on Regional vehicles. By the full implementation year of MY 2027, the
agencies are projecting an overall vocational vehicle adoption rate of
12 percent mild hybrids, which we estimate will be 14 percent of
vehicles certified in the Multi-Purpose and Urban subcategories (six
percent integrated and eight percent non-integrated). We are projecting
a low adoption rate in the early years of the Phase 2 program, zero
integrated hybrid systems and two percent of the bolt-on systems in
these subcategories in MY 2021, and three percent integrated mild
hybrids in MY 2024 for vehicles certified in the Multi-Purpose and
Urban subcategories, plus 5 percent non-integrated mild hybrids in MY
2024. Based on our assumptions about the populations of vehicles in
different subcategories, these hybrid adoption rates are about two
percent overall in MY 2021 and six percent overall in MY 2024.
Navistar commented with concerns that the agencies may be double
counting some of the improvements of deep integration. For example, the
addition of a gear to a transmission may reduce the added benefit of
deep integration, as the transmission may already achieve a more
optimal operation state more often due to the greater number of gears.
The agencies have been careful to project adoption rates and
effectiveness of transmission technologies in a way that that avoids
over-estimating the achievable reductions. For example, as we developed
the packages, we reduced the adoption rate of advanced shift strategy
by the adoption rate of integrated hybrids, and we reduced the adoption
rate of transmission gear efficiency by the amount of non-integrated
hybrids. This is because we do not project that any driveline will
undergo testing over both the powertrain test and the separate
transmission efficiency test. Because we have projected adoption of
combinations of transmission technologies in some subcategories, the
sum of adoption rates of individual transmission technologies may
exceed 100 percent in some cases. However, the effectiveness values
have not been summed because we agree with the commenter that we should
not double count benefits. Instead of summing the combined
efficiencies, we combine multiplicatively as described in Equation V-1,
below. Thus, we have fairly accounted for dis-synergies of
effectiveness where multiple technologies are applied to a similar
vehicle system.
Custom chassis manufacturers have provided compelling comment that
the absence of recognition in the certification process of improved
transmission technology will not deter them from its adoption.
Therefore, although some types of improved transmissions are feasible
for some custom chassis, these vehicles are typically assembled from
off-the-shelf parts in low production volumes. For most components,
this is not a significant obstacle. However, this dynamic can limit
their access to the most advanced transmission technologies.
Transmission manufacturers would generally be willing to supply
advanced transmissions they developed for a larger customer, but would
be less likely to invest in developing a special low volume
transmission for the custom chassis. Similar circumstances would apply
for hybrids. Further, for the reasons described above about non-
representative drivelines in the baseline configurations, we believe
that allowing these to be certified with a default driveline is a
reasonable program structure. For school buses and others, if a
manufacturer wishes to be recognized beyond the levels described for
adopting improved transmissions, it has the option of certifying to the
primary standards. Nevertheless, technology improvements that some of
these manufacturers will include based on market forces (after they
have been introduced into the market as a result of the primary
program) will likely result in actual in-use improvements for many
these vehicles beyond what is projected by the standards.
(ii) Axle Packages
The agencies project that 10 percent of vocational vehicles in all
subcategories will adopt high efficiency axles in MY 2021, 20 percent
in MY 2024, and 30 percent in MY 2027. Fuel efficient lubricant
formulations are widespread across the heavy-duty market, though
advanced synthetic formulations are currently less popular.\438\ Axle
lubricants with improved viscosity and efficiency-enhancing performance
are projected to
[[Page 73709]]
be widely adopted by manufacturers in the time frame of Phase 2. Such
formulations are commercially available and the agencies see no reason
why they could not be feasible for most vehicles. Nonetheless, we have
refrained from projecting full adoption of this technology. The
agencies do not have specific information regarding reasons why axle
manufacturers may specify a specific type of lubricant over another,
and whether advanced lubricant formulations may not be recommended in
all cases. The agencies received adverse comment on allowing fixed
credit for use of high efficiency axles, whether from lubrication or
other mechanical designs. In response, we are adopting a separate axle
efficiency test, which can be used as an input to GEM to over-ride
default axle efficiency values. The low overall adoption rate indicates
that we expect axle suppliers to only offer high-efficiency axles for
their most high production volume products, especially those that can
serve both the tractor and vocational market. Therefore, we believe it
is unlikely that high-efficiency axles will be adopted in custom
chassis applications. Because we are no longer offering a fixed
improvement for this technology as at proposal, this is only available
for vocational vehicles that are certified to the primary program.
---------------------------------------------------------------------------
\438\ See meeting log for proposed rule, specifically the April
2014 meeting with Dana. https://www.regulations.gov/document?D=EPA-HQ-OAR-2014-0827-0702
---------------------------------------------------------------------------
The agencies estimate that 10 percent of HHD Regional vocational
vehicles and five percent of HHD Multipurpose vehicles will adopt part
time 6x2 axle technology in MY 2021. This technology is most likely to
be applied to Class 8 vocational vehicles (with 2 rear axles) that are
designed for frequent highway trips. The agencies project a 20 percent
adoption rate for HHD Regional and 15 percent adoption rate for HHD
Multipurpose for part time 6x2 axle technologies in MY 2024. In MY
2027, we project 30 percent adoption of part time 6x2 for HHD Regional
and 25 percent for HHD Multipurpose. We are establishing a custom
chassis baseline configuration for coach buses with a 6x2 axle, in
consideration of comments from UCS and manufacturers stating this is
the standard axle configuration for these vehicles. If a HHD coach bus
is sold with a 6x4 or part time 6x2 axle, the manufacturer must enter
the as-built axle configuration as a GEM input. This is true whether
the vehicle is in the primary program or if it is certified to the
custom chassis standard. Because the optional custom chassis standard
assumes a 6x2 axle in the coach bus baseline, manufacturers may only
qualify to obtain a reduced GEM result from use of the 300 pound weight
reduction value (specified in 40 CFR 1037.520 associated with use of a
permanent 6x2 axle) when certifying coach buses to the primary
standards.
(iii) Tire Packages
The agencies estimate that the per-vehicle average level of rolling
resistance from vocational vehicle tires could be reduced by up to 13
percent for many vehicles by full implementation of the Phase 2 program
in MY 2027, based on broader adoption of vocational vehicle tires
currently available. We estimate this will yield reductions in fuel use
and CO2 emissions of up to 3.3 percent for these vehicles.
All of our estimates of vehicle-level tire CRR improvements employ a
weighted average using an assumed axle load distribution of 30 percent
on the steer tires and 70 percent on the drive tires, as was
proposed.\439\ The projected adoption rates of tires with improved CRR
for chassis in the primary program are presented in Table V-19. The
levels noted in the table are defined above in Table V-15. By applying
the assumed axle load distribution, the estimated vehicle CRR
improvement projected as part of the MY 2021 standards ranges from 5 to
8 percent, which we project will achieve up to 1.9 percent reduction in
fuel use and CO2 emissions, depending on the vehicle
subcategory. The agencies estimate the vehicle CRR improvement in MY
2024 will range from 5 to 13 percent, yielding reductions in fuel use
and CO2 emissions up to 3.2 percent, depending on the
vehicle subcategory.
---------------------------------------------------------------------------
\439\ See Vehicle Valuation Services Quick Reference Guide,
available at. http://www.vvsi.com/training/TrainingGuide.pdf,
(accessed June 2014), the draft RIA at Chapter 2.9.2, and Docket ID
EPA-HQ-OAR-2014-0827-0434.
---------------------------------------------------------------------------
The agencies believe that these tire packages recognize the variety
of tire purposes and performance levels in the vocational vehicle
market, and maintain choices for manufacturers to use the most
efficient tires (i.e. those with lowest rolling resistance) only where
it makes sense given these vehicles' differing purposes and
applications.
Table V-19--Projected LRR Tire Adoption Rates
--------------------------------------------------------------------------------------------------------------------------------------------------------
Regional Multipurpose Urban
-----------------------------------------------------------------------------------------------------------------------
Steer Drive Steer Drive Steer Drive
--------------------------------------------------------------------------------------------------------------------------------------------------------
2021 HHD........................ 100% LRR 5v....... 100% LRR 2v....... 100% LRR 5v....... 100% LRR 2v....... 100% LRR 4v....... 100% LRR 1v.
2021 MHD........................ 100% LRR 3v....... 100% LRR 1v....... 100% LRR 3v....... 100% LRR 1v....... 100% LRR 3v....... 100% LRR 1v.
2021 LHD........................ 100% LRR 3v....... 100% LRR 3v....... 100% LRR 3v....... 100% LRR 3v....... 100% LRR 2v....... 100% LRR 2v.
2024 HHD........................ 100% LRR 5v....... 100% LRR 3v....... 100% LRR 5v....... 100% LRR 2v....... 100% LRR 4v....... 100% LRR 1v.
2024 MHD........................ 100% LRR 5v....... 100% LRR 3v....... 100% LRR 3v....... 50% LRR 1v, 50% 100% LRR 3v....... 100% LRR 1v.
LRR 2v.
2024 LHD........................ 100% LRR 5v....... 100% LRR 3v....... 100% LRR 3v....... 100% LRR 3v....... 100% LRR 2v....... 100% LRR 2v.
2027 HHD........................ 100% LRR 5v....... 100% LRR 3v....... 100% LRR 5v....... 100% LRR 3v....... 100% LRR 5v....... 100% LRR 2v.
2027 MHD........................ 100% LRR 5v....... 100% LRR 3v....... 100% LRR 5v....... 100% LRR 3v....... 100% LRR 3v....... 50% LRR 1v, 50%
LRR 2v.
2027 LHD........................ 100% LRR 5v....... 100% LRR 3v....... 100% LRR 5v....... 100% LRR 3v....... 100% LRR 3v....... 50% LRR 2v, 50%
LRR 3v.
--------------------------------------------------------------------------------------------------------------------------------------------------------
Table V-20 presents the projected adoption rates of LRR tires for
custom chassis. As noted above in Section V.C.(1)(a)(iii), the adoption
rates generally represent improvements in the range of the 25th to 40th
percentile using data from actual vehicles in each application that
were certified in MY 2014. A summary of these data is provided in a
memorandum to the docket.\440\ An exception to this is emergency
vehicles. The final emergency vehicle standards reflect adoption of
tires that progress to the 50th percentile by MY 2027, using steer and
drive tire data for certified emergency vehicles. At these adoption
rates, manufacturers need not change any of the tires they are
currently fitting on emergency vehicles, and they will comply on
average.
---------------------------------------------------------------------------
\440\ See memorandum on tire data, Note 419, above.
[[Page 73710]]
Table V-20--Projected LRR Tire Adoption Rates for Custom Chassis
----------------------------------------------------------------------------------------------------------------
MY 2021 MY 2027
-------------------------------------------------------------------------------
Steer Drive Steer Drive
----------------------------------------------------------------------------------------------------------------
Coach........................... 100% LRR 4v....... 100% LRR 4v....... 100% LRR 5v....... 100% LRR 5v.
RV.............................. 100% LRR 5v....... 100% LRR 5v....... 100% LRR 5v....... 100% LRR 5v.
School.......................... 100% LRR 4v....... 100% LRR 2v....... 100% LRR 5v....... 100% LRR 4v.
Transit......................... 100% LRR 1v....... 100% LRR 1v....... 100% LRR 3v....... 100% LRR 3v.
Refuse.......................... 100% LRR 1v....... 100% LRR 1v....... 100% LRR 3v....... 100% LRR 3v.
Mixer........................... 100% LRR 2v....... 100% LRR 1v....... 100% LRR 3v....... 100% LRR 2v.
Emergency....................... 100% LRR 2v....... 100% LRR 1v....... 100% LRR 4v....... 100% LRR 1v.
----------------------------------------------------------------------------------------------------------------
(iv) Idle Reduction Packages
In these rules, the adoption rate of AES for HHD Regional vehicles
is 40 percent in MY 2021, 80 percent in MY 2024, and 90 percent in MY
2027. This is because these vehicles have driving patterns with a
significant amount of parked idle, and the vast majority have
relatively modest accessory demands such that only a few would have
such large demands for backup power that turning the engine off while
parked would not be feasible. For all weight classes of Regional
vehicles except coach buses, the neutral idle and stop start adoption
rates remain zero in all model years because these vehicles have
driving patterns with such a small amount of transient driving that
this drive-idle technology would not likely provide real world
benefits. For coach buses we are predicating the optional custom
chassis standard in part on adoption of neutral idle for several
reasons. First, according to Volvo, we are underestimating the amount
of transient time for these vehicles by applying only a 20 percent
weighting of the transient cycle instead of 25 percent as noted in
their comment. Second, we estimate that neutral idle is a low cost
technology that would easily pay for itself with the miles accumulated
by coach buses. Finally, in the custom chassis program manufacturers
are able to qualify for a reduced emission rate in GEM through
selection of neutral idle even if the transmission architecture
inherently functions with neutral idle such as with an AMT or DCT. The
Regional vehicles carry a 40 percent, 80 percent, and 90 percent
adoption rate of AES in MYs 2021, 2024, and 2027 respectively because
these vehicles are not projected to apply any other idle reduction
technology and as long as large accessory loads are not required this
technology is widely feasible. As reflected in the Multipurpose and
Urban duty cycles with an overall composite test weighting of zero
speed operation of 50 percent with 25 percent composite weighting of
the parked idle cycle, idle reduction is a significant technology for
these vehicles. We are projecting 30 percent adoption of AES in all
weight classes of Multipurpose and Urban vocational vehicles in MY
2021, increasing to 60 percent in MY 2024 and 70% in MY 2027. This is
less than for Regional because we expect a larger fraction of vehicles
in these subcategories will need to run PTO or other accessories while
parked, such that fewer will be able to reasonably apply the low-cost
AES that we have identified in this rulemaking. Because we are
considering stop-start and neutral idle to be mutually exclusive on a
per-vehicle basis, the sum of these two technologies does not exceed 90
percent in MY 2027, and gradually ramps up to this level from the 50 to
60 percent range in MY 2021. Neutral idle adoption rates are greater in
the early years because we expect this will not need much lead time, if
any. An exception to the 90 percent maximum adoption rate is transit
buses, where we believe all vehicles of this type can reasonably apply
some form of drive idle reduction technology. The adoption rates of
idle reduction technologies for vocational vehicles in MY 2027 is
presented in Table V-21.
Table V-21--MY 2027 Adoption Rates of Idle Reduction Technologies
--------------------------------------------------------------------------------------------------------------------------------------------------------
Heavy heavy-duty Medium heavy-duty Light heavy-duty
--------------------------------------------------------------------------------------------------------------------
Technology Multi- Multi- Multi-
Regional purpose Urban Regional purpose Urban Regional purpose Urban
--------------------------------------------------------------------------------------------------------------------------------------------------------
Neutral Idle....................... 0 70 70 0 60 60 0 60 60
Stop-Start......................... 0 20 20 0 30 30 0 30 30
AES................................ 90 70 70 90 70 70 90 70 70
--------------------------------------------------------------------------------------------------------------------------------------------------------
Although it is possible that a vehicle could have both neutral idle
and stop-start, our stringency calculations only consider emissions
reductions where a vehicle either has one or the other of these
technologies. The final GEM input file allows users to apply multiple
idle reduction technologies within a single vehicle configuration.
Because we have included costs to maintain engine protection during
periods of shut-off, as well as over-rides to recognize instances where
it may not be safe to shut off an engine, we believe stop-start can
safely be applied at the rates described above in the time frames
described. Also, because we have defined two idle cycles where the
automatic engine shutoff technology addresses the condition of being
parked with the brake off, we believe this alleviates many of the
concerns expressed by commenters about stop-start. We believe many
commenters were (erroneously) imagining that stop-start systems would
be required to function during periods of extended parking.
We agree with commenters that stop-start is not feasible for
emergency vehicles and concrete mixers. We further believe that stop-
start would not provide any real world benefit for coach buses or motor
homes. However, for school buses, transit buses, and refuse trucks, we
believe stop-start is feasible and likely to result in real world
benefits. The only custom chassis standards that we are basing on
adoption of AES is school buses, because for the others, we believe the
simple shutdown timer would be likely to encounter an over-ride
condition frequently enough to yield a very small benefit from this
technology. To make AES practical for a coach or transit bus for
example, a much larger auxiliary power source would be needed than the
one projected as part of this rulemaking. Although many school buses
have voluntarily adopted idle reduction strategies for other reasons,
we do not believe many have tamper-proof automatic shutdown systems.
[[Page 73711]]
Table V-22--Custom Chassis Workday Idle Adoption Rates
----------------------------------------------------------------------------------------------------------------
Technology MY AES NI Stop-start
----------------------------------------------------------------------------------------------------------------
Coach........................................... 2021 .............. 40 ..............
2027 .............. 70 ..............
School.......................................... 2021 30 60 5
2027 70 60 30
Transit......................................... 2021 .............. 60 10
2027 .............. 70 30
Refuse.......................................... 2021 .............. 30 0
2027 .............. 50 20
----------------------------------------------------------------------------------------------------------------
As described above, the agencies are excluding refuse trucks that
do not compact waste from the optional custom chassis vocational
vehicle standards. We believe trucks that do not compact waste have
sufficiently low PTO operation (usually only while parked) to make
application of drive idle reduction technologies (and other
technologies projected for regular vocational chassis) quite feasible.
Front-loading refuse collection vehicles tend to have a relatively low
number of stops per day as they tend to collect waste from central
locations such as commercial buildings and apartment complexes. Because
these have a relatively low amount of PTO operation, we expect stop-
start will be reasonably effective for these vehicles. Rear-loading and
side-loading neighborhood waste and recycling collection trucks are the
refuse trucks where the largest number of stop-start and neutral idle
over-ride conditions are likely to be encountered. Because chassis
manufacturers, even those with small production volumes and close
customer relationships, do not always know whether a refuse truck
chassis will be fitted with a body designed for front loading, rear
loading, or side loading, we are applying an adoption rate of 20
percent stop-start in 2027 to refuse trucks certified as custom
chassis. In the case where a chassis manufacturer certifies a refuse
truck to the primary standards under the HHD Urban subcategory, the MY
2027 adoption rate of stop-start is also 20 percent as shown in Table
V-21. The stringency in both cases assumes a sufficiently capable stop-
start system to not require an excessive use of over-rides.
Manufacturers opting to certify refuse trucks to the primary standards
will have an option to be recognized for enhanced stop-start systems
through the powertrain test.
It may take some minor development effort to apply neutral idle to
high-torque automatic transmissions designed for the largest vocational
vehicles. Based on stakeholder input, the designs needed to avoid an
uncomfortable re-engagement bump when returning to drive from neutral
may require some engineering refinement as well as some work to enable
two-way communication between engines and transmissions. Nonetheless,
this technology should be available in the near term for many vehicles
and is low cost compared to many other technologies we considered.
Commenters asked for over-rides such as when on a steep hill and we
agree and are adopting this provision.
For the reasons described above, we see the above idle reduction
technologies being technically feasible on the majority of vocational
vehicles. The RIA Chapter 2.9.3.4 and RIA Chapter 2.9.5.1.4 provide
additional discussion on workday idle reduction technologies for
vocational vehicles.
(v) Weight Reduction Packages
As described in the RIA Chapter 2.11.10.3, weight reduction is a
relatively costly technology, at approximately $3 to $10 per pound for
a 200-lb package. Even so, for vehicles in service classes where dense,
heavy loads are frequently carried, weight reduction can translate
directly to additional payload. The agencies project that modest weight
reduction is feasible for all vocational vehicles. The agencies are
predicating the final standards on adoption of weight reduction
comparable to what can be achieved through use of aluminum wheels (an
easy material switch that does not alter load distribution on the
chassis). This package is estimated at 150 pounds for LHD and MHD
vehicles, and 250 pounds for HHD vehicles, based on six and 10 wheels,
respectively. This value is revised upward since proposal based on
compelling comments from the Aluminum Association recommending that we
set the same level of weight reduction for lightweight aluminum alloys
as for regular aluminum, at 25 pounds per wheel. More details on these
comments may be found in the Response to Comments Chapter 5. In MY
2021, we project an adoption rate of 10 percent, 30 percent in MY 2024,
and 50 percent in MY 2027 for all subcategories in the primary program.
The agencies project manufacturers will have sufficient options of
other components eligible for material substitution so that this level
of weight reduction will be feasible even where aluminum wheels are not
selected by customers. Based on comments, we have removed aluminum
transmission cases and aluminum clutch housings from the vocational
lookup table.
We are not predicating the custom chassis standards on any use of
weight reduction. We have learned that manufacturers of concrete
mixers, refuse trucks, and some high end buses have already made
extensive use of lightweighting technologies in the baseline fleet. We
also received persuasive comment cautioning us not to base the school
bus standards on weight reduction due to potential conflicts with
safety standards. In considering this information, we are allowing all
vehicles certified using custom chassis regulatory subcategory
identifiers to make use of weight reduction as a compliance
flexibility. We received compelling comment from UCS that weight
reduction should be considered feasible for transit buses. Upon
consideration of this comment as well as information regarding the
preponderance of city buses with overloaded axles, we are predicating
standard stringency for transit buses on use of aluminum wheels at the
same adoption rate as for the primary program. See the RIA at Chapter
2.9.5.1.5 for more information about transit bus axles.
(vi) Electrified Accessory Packages
The agencies are predicating the final vocational vehicle standards
in part on an adoption rate of five percent in MY 2021 of an
electrified accessory package that achieves one percent fuel efficiency
improvement. The discussion in Section V.C.(1)(a)(vi) describes some
pre-defined e-accessory improvements that are available in GEM for all
vocational vehicles. In MY 2024 we increase this adoption rate to ten
percent, and in MY
[[Page 73712]]
2027 the projected adoption rate is 15 percent, applicable in all
subcategories excluding custom chassis. Although we believe some
components could be electrified for some custom chassis, we do not have
sufficient information to estimate an incremental cost associated with
electrifying the more complex systems on custom chassis such as buses,
or to project a specific adoption rate for this type of improvement.
(vii) Tire Pressure System Packages
The agencies are predicating the vocational vehicle standards in
part on widespread adoption of tire pressure monitoring systems. These
are readily accepted by fleets as a cost-effective safety and fuel-
saving measure. Because there may be some minor challenges in applying
this technology to some vehicles where the payload and duty cycle lead
to very high tire temperatures and pressures (as described above), we
are applying a lower adoption rate to Urban and Multi-purpose vehicles
than to Regional vehicles, as shown in Table V-23. We are applying
similarly lower adoption rates for refuse trucks and transit buses. We
are not predicating the emergency vehicle or cement mixer standards on
adoption of TPMS.
We are predicating the optional school bus, coach bus, transit bus,
and refuse truck standards in part on limited adoption of automatic
tire inflation systems (ATIS), as shown in Table V-23. These are more
costly than TPMS, and require an onboard air supply and sometimes
extensive plumbing of air lines.
Table V-23--Vocational Tire Pressure System Adoption Rates
----------------------------------------------------------------------------------------------------------------
TPMS ATIS
Technology -------------------------------------------------------------------------------
MY 2021 MY 2024 MY 2027 MY 2021 MY 2027
----------------------------------------------------------------------------------------------------------------
Regional........................ 60 75 90 .............. ..............
Multi-Purpose................... 50 65 80 .............. ..............
Urban........................... 40 55 70 .............. ..............
School.......................... 70 .............. 80 .............. 20
Coach........................... 50 .............. 75 10 25
Transit......................... 40 .............. 50 10 20
Refuse.......................... 40 .............. 50 10 15
Motor Home...................... 60 .............. 90 .............. ..............
----------------------------------------------------------------------------------------------------------------
(c) GEM Inputs for Derivation of Vocational Vehicle Standards
To account for engine-level improvements consistent with those
projected to meet Phase 2 vocational engine standards, and which will
be reflected over the GEM vehicle test cycles, the agencies developed a
suite of fuel consumption maps for use with the GEM: One set of maps
that represent engines meeting the MY 2021 vocational diesel engine
standards, a second set of maps representing engines meeting the MY
2024 vocational diesel engine standards, and a third set of maps
representing engines meeting the MY 2027 vocational diesel engine
standards.\441\ By incorporating the engine technology packages
projected to be adopted to meet the Phase 2 vocational CI engine
standards, the agencies employed GEM engine models in deriving the
stringency of the Phase 2 CI-powered vocational vehicle standards.
Similarly, to account for the performance of Phase 2 SI engines in
deriving the stringency of the Phase 2 SI-powered vocational vehicle
standards, the agencies employed our baseline SI GEM engine model. The
extra engine technology on which the Phase 2 SI vocational vehicle
standards are based was applied in post-processing the GEM results, not
modeled with an improved GEM map. See the RIA Chapter 2.9.1 for more
details about the vocational engines used in standard-setting.
---------------------------------------------------------------------------
\441\ See Section II.D.2 of this Preamble for the derivation of
the engine standards.
---------------------------------------------------------------------------
The derivation of the vocational vehicle standards incorporates
several methods because some GEM inputs lend themselves to fleet-
average values, some are vehicle specific (either on or off) and some
improvements are not directly modeled in GEM. For each model year of
standards, the agencies derived a scenario vehicle for each subcategory
using the future model year engine map with fleet average input values
for tire rolling resistance and weight reduction. For example, the MY
2021 HHD weight reduction input value was derived as follows: 250
pounds times 10 percent adoption yields 25 pounds. Those scenario
vehicle performance results were combined in a post-process method with
subcategory-specific improvements from idle reduction, axle disconnect,
torque converter lockup, and transmission automation, using directly
modeled GEM improvements comparing results with these technologies on
or off the scenario vehicle. Subsequently, these performance values
were combined with estimated improvement values of technologies not
modeled in GEM, including TPMS, hybrids, and transmission gear
efficiency.
The set of fleet-average inputs for tire CRR and weight reduction
for MY 2021, as modeled in GEM is shown in Table V-24, along with the
respective adoption rates for idle reduction, axle disconnect, and
torque converter lockup. The agencies derived the level of the MY 2024
standards by using the GEM inputs and adoption rates shown in Table V-
25, below. The agencies derived the level of the MY 2027 standards by
using the GEM inputs and adoption rates shown in Table V-26, below.
Post-processing improvements for technologies not directly modeled,
including TPMS, e-accessories, hybrids, and axle and transmission
improvements are presented as a combined driveline improvement factor
in Table V-27, below. The values in this table for SI-powered
vocational vehicles include improvements due to adoption of SI engine
technology. The methodology for estimating these improvements is
described in the RIA Chapter 2.9.1. The final standards are presented
in Table V-4 through Table V-9.
[[Page 73713]]
Table V-24--GEM Inputs Used To Derive Final MY 2021 Vocational Vehicle Standards
--------------------------------------------------------------------------------------------------------------------------------------------------------
Class 2B-5 Class 6-7 Class 8
--------------------------------------------------------------------------------------------------------------------------------------------------------
Multi- Multi- Multi-
Urban purpose Regional Urban purpose Regional Urban purpose Regional
--------------------------------------------------------------------------------------------------------------------------------------------------------
SI Engine
--------------------------------------------------------------------------------------------------------------------------------------------------------
2018 MY 6.8L, 300 hp engine
--------------------------------------------------------------------------------------------------------------------------------------------------------
CI Engine
--------------------------------------------------------------------------------------------------------------------------------------------------------
2021 MY 7L, 200 hp Engine 2021 MY 7L, 270 hp Engine 2021 MY
11L, 350
hp Engine 2021 MY 11L, 350 hp
Engine and 2021 MY 15L
455hp Engine a
--------------------------------------------------------------------------------------------------------------------------------------------------------
Torque Converter Lockup in 1st (adoption rate)
--------------------------------------------------------------------------------------------------------------------------------------------------------
30%..................................................... 30% 30% 30% 30% 30% 10% 10% 0%
--------------------------------------------------------------------------------------------------------------------------------------------------------
6 x 2 Disconnect Axle (adoption rate)
--------------------------------------------------------------------------------------------------------------------------------------------------------
0%...................................................... 0% 0% 0% 0% 0% 0% 5% 10%
--------------------------------------------------------------------------------------------------------------------------------------------------------
AES (adoption rate)
--------------------------------------------------------------------------------------------------------------------------------------------------------
30%..................................................... 30% 40% 30% 30% 40% 30% 30% 40%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Stop-Start (adoption rate)
--------------------------------------------------------------------------------------------------------------------------------------------------------
10%..................................................... 10% 0% 10% 10% 0% 0% 0% 0%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Neutral Idle (adoption rate)
--------------------------------------------------------------------------------------------------------------------------------------------------------
50%..................................................... 50% 0% 50% 50% 0% 50% 50% 0%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Steer Tires (CRR kg/metric ton)
--------------------------------------------------------------------------------------------------------------------------------------------------------
7....................................................... 6.8 6.8 6.8 6.7 6.7 6.4 6.2 6.2
--------------------------------------------------------------------------------------------------------------------------------------------------------
Drive Tires (CRR kg/metric ton)
--------------------------------------------------------------------------------------------------------------------------------------------------------
7.2..................................................... 6.9 6.9 7.8 7.5 7.5 7.8 7.5 7.5
--------------------------------------------------------------------------------------------------------------------------------------------------------
Weight Reduction (lb)
--------------------------------------------------------------------------------------------------------------------------------------------------------
15...................................................... 15 15 15 15 15 25 25 25
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note:
\a\ The Multipurpose and Regional HHD standards are established using averages of configurations with different engines as described in RIA Chapter
2.9.2.
Table V-25--GEM Inputs Used To Derive Final MY 2024 Vocational Vehicle Standards
--------------------------------------------------------------------------------------------------------------------------------------------------------
Class 2b-5 Class 6-7 Class 8
--------------------------------------------------------------------------------------------------------------------------------------------------------
Multi- Multi- Multi-
Urban purpose Regional Urban purpose Regional Urban purpose Regional
--------------------------------------------------------------------------------------------------------------------------------------------------------
SI Engine
--------------------------------------------------------------------------------------------------------------------------------------------------------
2018 MY 6.8L, 300 hp engine
--------------------------------------------------------------------------------------------------------------------------------------------------------
CI Engine
--------------------------------------------------------------------------------------------------------------------------------------------------------
2024 MY 7L, 200 hp Engine 2024 MY 7L, 270 hp Engine 2024 MY
11L, 350
hp Engine 2024 MY 11L, 350 hp
Engine and 2024 MY 15L
455hp Engine a
--------------------------------------------------------------------------------------------------------------------------------------------------------
Torque Converter Lockup in 1st (adoption rate)
--------------------------------------------------------------------------------------------------------------------------------------------------------
40%..................................................... 40% 40% 40% 40% 40% 20% 20% 0%
--------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 73714]]
6 x 2 Disconnect Axle (adoption rate)
--------------------------------------------------------------------------------------------------------------------------------------------------------
0%...................................................... 0% 0% 0% 0% 0% 0% 15% 20%
--------------------------------------------------------------------------------------------------------------------------------------------------------
AES (adoption rate)
--------------------------------------------------------------------------------------------------------------------------------------------------------
60%..................................................... 60% 80% 60% 60% 80% 60% 60% 80%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Stop-Start (adoption rate)
--------------------------------------------------------------------------------------------------------------------------------------------------------
20%..................................................... 20% 0% 20% 20% 0% 10% 10% 0%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Neutral Idle (adoption rate)
--------------------------------------------------------------------------------------------------------------------------------------------------------
70%..................................................... 70% 0% 70% 70% 0% 70% 70% 0%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Steer Tires (CRR kg/metric ton)
--------------------------------------------------------------------------------------------------------------------------------------------------------
7.0..................................................... 6.8 6.2 6.8 6.7 6.2 6.4 6.2 6.2
--------------------------------------------------------------------------------------------------------------------------------------------------------
Drive Tires (CRR kg/metric ton)
--------------------------------------------------------------------------------------------------------------------------------------------------------
7.2..................................................... 6.9 6.9 7.8 7.5 6.9 7.8 7.5 6.9
--------------------------------------------------------------------------------------------------------------------------------------------------------
Weight Reduction (lb)
--------------------------------------------------------------------------------------------------------------------------------------------------------
45...................................................... 45 45 45 45 45 75 75 75
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note:
\a\ The Multipurpose and Regional HHD standards are established using averages of configurations with different engines as described in RIA Chapter
2.9.2.
Table V-26--GEM Inputs Used To Derive Final MY 2027 Vocational Vehicle Standards
--------------------------------------------------------------------------------------------------------------------------------------------------------
Class 2b-5 Class 6-7 Class 8
--------------------------------------------------------------------------------------------------------------------------------------------------------
Multi- Multi- Multi-
Urban purpose Regional Urban purpose Regional Urban purpose Regional
--------------------------------------------------------------------------------------------------------------------------------------------------------
SI Engine
--------------------------------------------------------------------------------------------------------------------------------------------------------
2018 MY 6.8L, 300 hp engine
--------------------------------------------------------------------------------------------------------------------------------------------------------
CI Engine
--------------------------------------------------------------------------------------------------------------------------------------------------------
2027 MY 7L, 200 hp Engine 2027 MY 7L, 270 hp Engine 2027 MY
11L, 350
hp Engine 2027 MY 11L, 350 hp
Engine and 2027 MY 15L
455hp Engine a
--------------------------------------------------------------------------------------------------------------------------------------------------------
Torque Converter Lockup in 1st (adoption rate)
--------------------------------------------------------------------------------------------------------------------------------------------------------
50%..................................................... 50% 50% 50% 50% 50% 30% 30% 0%
--------------------------------------------------------------------------------------------------------------------------------------------------------
6 x 2 Disconnect Axle (adoption rate)
--------------------------------------------------------------------------------------------------------------------------------------------------------
0%...................................................... 0% 0% 0% 0% 0% 0% 25% 30%
--------------------------------------------------------------------------------------------------------------------------------------------------------
AES (adoption rate)
--------------------------------------------------------------------------------------------------------------------------------------------------------
70%..................................................... 70% 90% 70% 70% 90% 70% 70% 90%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Stop-Start (adoption rate)
--------------------------------------------------------------------------------------------------------------------------------------------------------
30%..................................................... 30% 0% 30% 30% 0% 20% 20% 0%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Neutral Idle (adoption rate)
--------------------------------------------------------------------------------------------------------------------------------------------------------
60%..................................................... 60% 0% 60% 60% 0% 70% 70% 0%
--------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 73715]]
Steer Tires (CRR kg/metric ton)
--------------------------------------------------------------------------------------------------------------------------------------------------------
6.8..................................................... 6.2 6.2 6.7 6.2 6.2 6.2 6.2 6.2
--------------------------------------------------------------------------------------------------------------------------------------------------------
Drive Tires (CRR kg/metric ton)
--------------------------------------------------------------------------------------------------------------------------------------------------------
6.9..................................................... 6.9 6.9 7.5 6.9 6.9 7.5 6.9 6.9
--------------------------------------------------------------------------------------------------------------------------------------------------------
Weight Reduction (lb)
--------------------------------------------------------------------------------------------------------------------------------------------------------
75...................................................... 75 75 75 75 75 125 125 125
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note:
\a\ The Multipurpose and Regional HHD standards are established using averages of configurations with different engines as described in RIA Chapter
2.9.2.
Table V-27--Vocational Driveline Improvement Factors
--------------------------------------------------------------------------------------------------------------------------------------------------------
Class 2b-5 Class 6-7 Class 8
--------------------------------------------------------------------------------------------------
Multi- Multi- Multi-
Urban purpose Regional Urban purpose Regional Urban purpose Regional
--------------------------------------------------------------------------------------------------------------------------------------------------------
CI 2021.............................................. 0.019 0.018 0.018 0.019 0.019 0.019 0.019 0.018 0.017
CI 2024.............................................. 0.041 0.036 0.029 0.041 0.036 0.029 0.040 0.036 0.026
CI 2027.............................................. 0.061 0.053 0.037 0.061 0.053 0.037 0.060 0.052 0.034
SI 2021.............................................. 0.027 0.026 0.026 0.028 0.027 0.027 ......... ......... .........
SI 2024.............................................. 0.048 0.044 0.037 0.049 0.044 0.037 ......... ......... .........
SI 2027.............................................. 0.067 0.059 0.045 0.068 0.060 0.045 ......... ......... .........
--------------------------------------------------------------------------------------------------------------------------------------------------------
(d) Role of Fleet Averaging and Constraints in Vocational Vehicle
Standards
In part to avoid potentially creating incentives to misclassify
vehicles, the agencies proposed to ``equalize'' the standards for each
of the subcategories. 80 FR 40308. Thus, at proposal, the standards for
the Regional, Multipurpose, and Urban subcategories reflected the
arithmetic mean of the Regional, Multipurpose and Urban stringency
levels (i.e., all three drive cycle subcategory percent improvements
averaged together) in each weight class.\442\ Most commenters
criticized this proposed approach. For example, Navistar commented that
equalization could inappropriately benefit one manufacturer over
another based on their product mix. We also note that the equalization
process, if adopted, would have made the standards for the Regional
vehicles unattainable using the technology pathway identified by the
agencies, thus motivating manufacturers to select less appropriate test
cycles for vehicles that are designed for Regional service. Therefore,
we have decided not to apply ``equalization'' for finalizing the
vocational vehicle standards. Instead, we have developed the final
vocational vehicle standards using the same methodology as for all of
the other Phase 2 standards, where we apply fleet average technology
mixes to fleet average baseline vehicle configurations, and each
average baseline and technology mix is unique for each vehicle
subcategory. Along with this standard-setting approach, the agencies
are also adopting certain interim constraints on the otherwise
generally manufacturer-selected assignment of vehicle configurations to
one of the three drive cycle subcategories, as explained in Section
V.D.(1)(e) below.
---------------------------------------------------------------------------
\442\ See proposed rules at 80 FR 40308, July 13, 2015.
---------------------------------------------------------------------------
Elsewhere in this rulemaking we present overall costs and benefits,
which are based our projected distribution of vocational vehicles in
each subcategory. This projection includes our most updated population
distributions by weight class, which we have adjusted in part in
response to comments on the draft NREL report in the NODA and based on
an analysis of telematics data from Ryder's leased vehicles. We intend
to monitor whether our projection of distribution of vehicles among
subcategories is consistent with outcomes. Under the three drive cycle
subcategory structure, manufacturers must use good engineering judgment
(subject to the provisions of 40 CFR 1068.5) to choose a subcategory
for each vehicle configuration that represents the type of operation
the vehicle is configured to experience in use, and the agencies expect
the manufacturer and customer to specify a technology mix that is most
effective for that vehicle's likely operation. In other words, as long
as manufacturers work with their customers, the general rule describing
this greater flexibility in choice of subcategory could be that the
``customer knows best.'' In fact, our standards are predicated on the
premise that willful misclassification not reflecting good engineering
judgment will be rare, and thus environmentally inconsequential.
In considering our approach for setting the final standards, we
compared the relative stringencies in each subcategory with each
respective baseline, and we observed that Regional vehicles are
generally able to achieve the smallest percent improvement from the
lowest (most efficient) baseline. By contrast, the Urban vehicles are
generally able to achieve the greatest percent improvement from the
highest (least efficient) baseline. We are not particularly concerned
that adopting final standards with these unequal percent improvements
poses a danger of losing environmental benefits from this
[[Page 73716]]
program, as long as vehicle configurations are properly classified at
the time of certification. To test the potential impacts of
misclassification, we compared the performance of each of our baseline
configurations over all three drive cycles. This analysis is presented
in a memorandum to the docket.\443\ Results for LHD and MHD weight
classes were generally consistent with the rule's projections across
each drive cycle. Results for HHD were equivocal in some instances,
particularly for our baseline vehicles equipped with manual
transmissions. This issue appears to be related to both the difference
in the weighting of time spent in the drive idle mode in the Regional
versus Urban and Multi-purpose drive cycles, and whether or not
automatic transmissions are part of a baseline. In the analysis, that
combination of circumstances showed how manual transmission-equipped
vehicles could potentially become credit generators without any further
addition of technology, if certified to the Urban or Multi-purpose
cycles. The agencies are concerned that if this circumstance were to be
left unconstrained, it could create an incentive to misclassify some
Regional vehicles into one of the other two drive cycle subcategories,
even though manual transmissions are generally best suited for Regional
driving patterns, as discussed further below.
---------------------------------------------------------------------------
\443\ See spreadsheet file dated July 2016 titled,
VocationalStringencyComparison.xlsx.
---------------------------------------------------------------------------
In light of this analysis, and consistent with recent comments from
chassis manufacturers mentioned above in Section V.B.(1)(a), the
agencies are adopting some constraints to the otherwise generally
manufacturer-selected assignment of vocational chassis to regulatory
subcategories. These constraints are described in Section V.D.(1)(e). A
subset of the constraints prevents inappropriate classification based
on transmission type. These constraints restrict classification options
where a vocational vehicle is certifying with a manual transmission or
in some cases an automated manual transmission. We are adopting these
constraints as interim provisions in response to manufacturers'
concerns that the manual transmission constraints could present
competitive disadvantages, where different manufacturers produce very
different sales mixes of vehicles equipped with different transmission
types.\444\ However, at this time the final program structure,
including these constraints, will remain in place unless and until the
agencies determine that revisions to the vocational vehicle program
structure are warranted, in which case the agencies would undertake a
notice and comment rulemaking proposing to amend the programmatic
structure, consistent with such a determination.
---------------------------------------------------------------------------
\444\ See memorandum dated July 2016 titled, ``Summary of Late
Comments on Vocational Transmissions and N/V.''
---------------------------------------------------------------------------
It is important to clarify that we would consider all relevant
factors together before deciding whether to propose any revisions. If
we find that a significant discrepancy arises between our projections
and outcomes, such that our estimated GHG and fuel consumption benefits
are not being achieved because of the program structure, we may revisit
relevant aspects of the program structure, including the drive cycles,
subcategories and classification constraints. If we propose to revise
the structure in the future, it might also be necessary to propose
revising the numerical values of the standards to maintain equivalence
with the final stringency being established in this rulemaking. We
would of course find it acceptable if manufacturers implemented more
cost-effective technologies than we projected, while still achieving
the projected reductions in use. Similarly, if the structure results in
manufacturers generally adopting the projected cost-effective
technologies on the appropriate vehicles, but somehow this fails to
fully achieve the projected reductions in use, we do not believe
revisions necessarily would be warranted.
(e) Technology Package Costs Associated With Primary Vocational Vehicle
Standards
The agencies have estimated the costs of the technologies that
could be used to comply with the final Phase 2 vocational vehicle
standards. The estimated costs are shown in Table V-28 for MY 2021, in
Table V-29 for MY 2024, and Table V-30 for MY 2027. Fleet average costs
are shown for light, medium and heavy HD vocational vehicles in each
duty-cycle-based subcategory--Urban, Multi-Purpose, and Regional. As
shown in Table V-28, in MY 2021 these range from approximately $900 for
MHD and LHD Regional vehicles, up to $2,600 for HHD Regional vehicles.
Those two lower-cost packages reflect zero hybrids, and the higher-cost
package reflects significant adoption of automated transmissions. Many
changes have been made to the cost estimates since proposal. In the RIA
Chapter 2.12.2, the agencies present vocational vehicle technology
package costs differentiated by MOVES vehicle type. These costs do not
indicate the per-vehicle cost that may be incurred for any individual
technology. For more specific information about the agencies' estimates
of per-vehicle costs, please see the RIA Chapter 2.11. The engine costs
listed represent the cost of an average package of diesel engine
technologies as set out in Section II. Individual technology adoption
rates for engine packages are described in Section II.D. For gasoline
vocational vehicles, the agencies are projecting adoption of Level 2
engine friction reduction plus cylinder deactivation (i.e., all engine
improvements are reflected exclusively in the vehicle standard) for an
estimated $138 added to the average SI vocational vehicle package cost
beginning in MY 2021. Further details on how the SI vocational vehicle
costs were estimated are provided in the RIA Chapter 2.9.
The details behind all these costs are presented in RIA Chapter
2.11, including the markups and learning effects applied and how the
costs shown here are weighted to generate an overall cost for the
vocational segment. These estimates have changed significantly from
those presented in the proposal, due to changes in projected technology
adoption rates as well as changes in direct costs that reflect comments
received.
Table V-28--Final Vocational Vehicle Technology Incremental Costs in the 2021 Model Year a b
[2013$]
--------------------------------------------------------------------------------------------------------------------------------------------------------
Light HD Medium HD Heavy HD
--------------------------------------------------------------------------------------------------
Multi- Multi- Multi-
Urban purpose Regional Urban purpose Regional Urban purpose Regional
--------------------------------------------------------------------------------------------------------------------------------------------------------
Engine \c\........................................... $298 $298 $298 $275 $275 $275 $275 $275 $275
[[Page 73717]]
Tires................................................ 0 27 27 9 9 9 13 13 13
Tire Pressure Monitoring............................. 123 154 184 123 154 184 233 292 350
Transmission......................................... 217 217 217 217 217 217 186 413 1,519
Axle related......................................... 13 13 13 13 13 13 20 26 32
Weight Reduction..................................... 69 69 69 69 69 69 250 250 250
Idle reduction....................................... 155 155 12 160 160 12 68 68 12
Hybridization........................................ 178 178 0 178 178 0 178 178 0
Air Conditioning \d\................................. 22 22 22 22 22 22 22 22 22
Other \e\............................................ 30 30 30 49 49 49 89 89 89
--------------------------------------------------------------------------------------------------
Total............................................ 1,106 1,164 873 1,116 1,146 851 1,334 1,625 2,562
--------------------------------------------------------------------------------------------------------------------------------------------------------
Notes:
\a\ Costs shown are for the 2021 model year and are incremental to the costs of a vehicle meeting the Phase 1 standards. These costs include indirect
costs via markups along with learning impacts. For a description of the markups and learning impacts considered in this analysis and how it impacts
technology costs for other years, refer to Chapter 2 of the RIA (see RIA 2.11).
\b\ Note that values in this table include adoption rates. Therefore, the technology costs shown reflect the average cost expected for each of the
indicated vehicle classes. To see the actual estimated technology costs exclusive of adoption rates, refer to Chapter 2 of the RIA (see RIA 2.11 in
particular).
\c\ Engine costs are for a light HD, medium HD or heavy HD diesel engine. We are projecting $138 of additional costs beyond Phase 1 for gasoline
vocational engines.
\d\ EPA's air conditioning standards are presented in Section V.C above.
\e\ Other incremental technology costs include electrified accessories and advanced shift strategy.
The estimated fleet average vocational vehicle package costs are
shown in Table V-29 for MY 2024. As shown, these range from
approximately $1,300 for MHD and LHD Regional vehicles, up to $4,000
for HHD Regional vehicles. The increased costs above the MY 2021 values
reflect increased adoption rates of individual technologies, while the
individual technology costs are generally expected to remain the same
or decrease, as explained in the RIA Chapter 2.11. The engine costs
listed represent the average costs associated with the MY 2024
vocational diesel engine standard described in Section II.D.
Table V-29--Final Vocational Vehicle Technology Incremental Costs in the 2024 Model Year a b
[2013$]
--------------------------------------------------------------------------------------------------------------------------------------------------------
Light HD Medium HD Heavy HD
--------------------------------------------------------------------------------------------------
Multi- Multi- Multi-
Urban purpose Regional Urban purpose Regional Urban purpose Regional
--------------------------------------------------------------------------------------------------------------------------------------------------------
Engine \c\........................................... $446 $446 $446 $413 $413 $413 $413 $413 $413
Tires................................................ 0 31 33 10 10 33 13 13 53
Tire Pressure Monitoring............................. 155 183 211 155 183 211 294 347 401
Transmission......................................... 276 276 276 276 276 276 222 1,032 2,193
Axle related......................................... 24 24 24 24 24 24 37 54 60
Weight Reduction..................................... 186 186 186 186 186 186 684 684 684
Idle reduction....................................... 248 248 21 256 256 21 242 242 21
Hybridization........................................ 550 550 0 653 653 0 844 844 0
Air Conditioning \d\................................. 20 20 20 20 20 20 20 20 20
Other \e\............................................ 54 54 54 89 89 89 162 162 162
--------------------------------------------------------------------------------------------------
Total............................................ 1,959 2,018 1,272 2,082 2,110 1,274 2,932 3,813 4,009
--------------------------------------------------------------------------------------------------------------------------------------------------------
Notes:
\a\ Costs shown are for the 2024 model year and are incremental to the costs of a vehicle meeting the Phase 1 standards. These costs include indirect
costs via markups along with learning impacts. For a description of the markups and learning impacts considered in this analysis and how it impacts
technology costs for other years, refer to Chapter 2 of the RIA (see RIA 2.11).
\b\ Note that values in this table include adoption rates. Therefore, the technology costs shown reflect the average cost expected for each of the
indicated vehicle classes. To see the actual estimated technology costs exclusive of adoption rates, refer to Chapter 2 of the RIA (see RIA 2.9 in
particular).
\c\ Engine costs are for a light HD, medium HD or heavy HD diesel engine. We are projecting $136 additional costs beyond Phase 1 for gasoline vocational
engines.
\d\ EPA's air conditioning standards are presented in Section V.C above.
\e\ Other incremental technology costs include electrified accessories and advanced shift strategy.
The estimated fleet average vocational vehicle package costs are
shown in Table V-30 for MY 2027. As shown, these range from
approximately $1,500 for MHD and LHD Regional vehicles, up to $5,700
for HHD Regional vehicles. These per-vehicle technology package costs
were averaged using our projections of vehicle populations in the
[[Page 73718]]
nine regulatory subcategories and do not correspond to the MOVES
vehicle types. The engine costs shown represent the average costs
associated with the MY 2027 vocational diesel engine standard described
in Section II.D.
Purchase prices of non-custom vocational vehicles can range from
$60,000 for a light heavy-duty stake-bed landscape truck to over
$300,000 for a heavy heavy-duty boom truck. The costs of the vocational
vehicle standards can be put into perspective by comparing estimated
package costs with typical prices for those vehicles. For example, a
package cost of $3,000 on a $60,000 landscaping truck represents an
incremental increase of about five percent of the vehicle purchase
price. Similarly, a package cost of $4,000 on a $300,000 boom truck
represents an incremental increase of less than two percent of the
vehicle purchase price. The vocational vehicle industry
characterization report in the docket includes additional examples of
vehicle prices for a variety of vocational applications.\445\
---------------------------------------------------------------------------
\445\ See Heavy Duty Vocational Vehicle Industry
Characterization, EPA Contract No. EP-C-12-011. September 2013.
Table V-30--Final Vocational Vehicle Technology Incremental Costs in the 2027 Model Year a b
[2013$]
--------------------------------------------------------------------------------------------------------------------------------------------------------
Light HD Medium HD Heavy HD
--------------------------------------------------------------------------------------------------
Multi- Multi- Multi-
Urban purpose Regional Urban purpose Regional Urban purpose Regional
--------------------------------------------------------------------------------------------------------------------------------------------------------
Engine \c\........................................... $481 $481 $481 $446 $446 $446 $446 $446 $446
Tires................................................ 12 24 24 6 24 24 12 36 36
Tire Pressure Monitoring............................. 187 214 240 187 214 240 355 405 456
Transmission......................................... 271 271 293 271 271 293 220 990 3,269
Axle related......................................... 35 35 35 35 35 35 52 82 87
Weight Reduction..................................... 294 294 294 294 294 294 1,102 1,102 1,102
Idle reduction....................................... 303 303 23 314 314 23 365 365 23
Hybridization........................................ 857 857 0 1,032 1,032 0 1,353 1,353 0
Air Conditioning \d\................................. 20 20 20 20 20 20 20 20 20
Other \e\............................................ 73 73 77 122 122 127 227 227 231
--------------------------------------------------------------------------------------------------
Total............................................ 2,533 2,571 1,486 2,727 2,771 1,500 4,151 5,025 5,670
--------------------------------------------------------------------------------------------------------------------------------------------------------
Notes:
\a\ Costs shown are for the 2027 model year and are incremental to the costs of a vehicle meeting the Phase 1 standards. These costs include indirect
costs via markups along with learning impacts. For a description of the markups and learning impacts considered in this analysis and how it impacts
technology costs for other years, refer to Chapter 2 of the RIA (see RIA 2.11).
\b\ Note that values in this table include adoption rates. Therefore, the technology costs shown reflect the average cost expected for each of the
indicated vehicle classes. To see the actual estimated technology costs exclusive of adoption rates, refer to Chapter 2 of the RIA (see RIA 2.9 in
particular).
\c\ Engine costs are shown for a light HD, medium HD or heavy HD diesel engine. For gasoline-powered vocational vehicles we are projecting $125 of
additional engine-based costs beyond Phase 1.
\d\ EPA's air conditioning standards are presented in Section V.C above.
\e\ Other incremental technology costs include electrified accessories and advanced shift strategy.
(f) Custom Chassis Cost Estimates
The agencies have performed the above-described cost analysis using
the assumption that all custom chassis vocational vehicles are
certified to the primary standards, with full technology packages and
use of the regular Phase 2 GEM. In terms of costs, we expect that a
manufacturer will choose to certify a vehicle family to the optional
custom chassis standards only if it is less costly to do so. The cost-
benefit analysis found in the RIA Chapter 7 presents some estimates of
what the technology package costs of the primary standards are in terms
of MOVES vehicle types. For the MOVES types where a custom chassis
option is available, these are conservatively high cost estimates.
Table 6 and Table 7 of the RIA Executive Summary present estimates of
average custom chassis technology packages associated with the final
optional standards in MY 2021 and MY 2027, respectively.
The agencies are not aware of any custom chassis manufacturer that
produces engines. Thus, the engine costs will be borne by engine
manufacturers. While some of the added engine costs may be passed on to
vehicle manufacturers, and some vehicle costs may be passed on to
owners/operators, the overall technology costs of the custom chassis
standards are significantly less than the Phase 2 vocational vehicle
technology costs, which, as shown directly below, are highly cost-
effective.
(3) Consistency of the Vocational Vehicle Standards With the Agencies'
Legal Authority
NHTSA and EPA project these standards to be achievable within known
design cycles, and we believe these standards, although technology-
advancing, will allow many different paths to compliance in addition to
the technology paths on which standard stringency is predicated. These
standards are predicated on manufacturers implementing technologies
that we expect will be available in the time frame of these final
rules. We are projecting that most vehicles can adopt certain of the
technologies. For example, we project a 70 to 90 percent application
rate for TPMS. However, for other technologies, such as electrified
accessories, we are projecting an adoption rate of 15 percent. These
standards offer manufacturers the flexibility to apply the technologies
that make sense for their business and for customer needs.
As discussed above, average per-vehicle costs associated with the
2027 MY standards are projected to be generally less than five percent
of the overall price of a new vehicle. The annual cost-effectiveness of
these vocational vehicle standards in dollars
[[Page 73719]]
per metric ton is presented in the RIA Chapter 7 in Table 7-47. As
shown in that table, without fuel savings the cost per metric ton of
the final vocational vehicle standards in calendar year 2021 is $710,
decreasing to $100 by 2030. The cost effectiveness estimated for heavy-
duty pickup trucks and vans in this rulemaking is presented in Table 7-
46 in that same chapter of the RIA. Those Phase 2 standards have an
estimated annual cost per metric ton without fuel savings of $2,800 in
2020, decreasing to $110 (about the same as for vocational) by calendar
year 2030. The annual cost per ton of the MY 2017-2025 light-duty
greenhouse gas standards for pickup trucks as reported in 2010 dollars
without fuel savings is $430 in calendar year 2020, decreasing to $142
in 2030.\446\ The agencies have found these standards to be highly cost
effective. In addition, the vocational vehicle standards are clearly
effective from a net benefits perspective (see RIA Chapter 11.2).
Therefore, the agencies regard the cost of the final standards as
reasonable, even without considering that the costs are recovered due
decreased fuel consumption.
---------------------------------------------------------------------------
\446\ See Chapter 5.3 of the final RIA for the MY 2017-2025
Light-Duty GHG Rule, available at http://www3.epa.gov/otaq/climate/documents/420r12016.pdf.
---------------------------------------------------------------------------
The agencies note that while the projected costs are significantly
greater than the costs projected for Phase 1, we still consider these
costs to be reasonable, especially given that the first vehicle owner
may see the technologies pay for themselves in many cases. As discussed
above, the usual period of ownership for a vocational vehicle reflects
a lengthy trade cycle that may often exceed seven years. For most
vehicle types evaluated, the cost of these technologies, if passed on
fully to customers, will likely be recovered within four years or less
due to the associated fuel savings, as shown in the payback analysis
included in Section IX.M and in the RIA Chapter 7.1. Specifically, in
RIA Chapter 7.2.4, a summary is presented with estimated payback
periods for each of the MOVES vocational vehicle types, using the
annual vehicle miles traveled from the MOVES model for each vehicle
type. As noted above, the cost analysis presented for this rulemaking
assumes that all vocational vehicles are certified to the primary
standard. Using this assumption, the vocational vehicle type with the
shortest payback is intercity buses (less than one year), while most
other vehicles (with the exception of school buses and motor homes) are
projected to see paybacks in the fourth year or sooner. We expect that
manufacturers will certify to the optional custom chassis standards
where it is more cost-effective to do so; therefore, our analysis may
be overly conservative where it indicates very long paybacks for some
vocational vehicles.
The agencies note further that although the rules are technology-
advancing (especially with respect to driveline improvements) and the
estimated costs for each subcategory vary considerably (by a factor of
five in some cases), these costs represent only one of many possible
pathways to compliance for manufacturers. Manufacturers retain leeway
to develop alternative compliance paths, increasing the likelihood of
the standards' successful implementation. Based on available
information, the agencies believe the final vocational vehicle
standards are technically feasible within the lead time provided, are
cost effective while accounting for the fuel savings (see RIA Chapter
7.1.4), and have no apparent adverse collateral potential impacts
(e.g., there are no projected negative impacts on safety or vehicle
utility).
The final standards thus appear to represent a reasonable choice
under section 202(a) of the CAA and are maximum feasible under NHTSA's
EISA authority at 49 U.S.C. 32902(k)(2). The agencies believe that the
final standards are consistent with their respective authorities.
(4) Alternative Vocational Vehicle Standards Considered
The agencies developed and considered other alternative levels of
stringency for the Phase 2 program. The results of the analysis of
these alternatives, and comments received on alternatives, are
discussed below in Section X of the Preamble and the RIA Chapter 11.
For vocational vehicles, the agencies developed alternatives as shown
in Table V-31. The agencies are not adopting standards reflecting
Alternative 2, because as already described, technically feasible
standards are available that provide for greater emission reductions
and reduced fuel consumption than provided under Alternative 2. The
agencies are not adopting standards reflecting Alternative 4 or
Alternative 5 because we do not believe these standards to be feasible
considering lead time and other relevant factors. Nevertheless, we have
reevaluated each of the technology projections proposed for Alternative
4 and have determined that some engine and tire reductions will be
feasible on the Alternative 4 timeline.
Table V-31--Summary of Alternatives Considered for the Final Rulemaking
------------------------------------------------------------------------
Alternative 1 and 1b No action alternatives
------------------------------------------------------------------------
Alternative 2.............................. Less stringent than the
preferred alternative in
the proposal, applying off-
the-shelf technologies.
Final HD Phase 2 program................... Fully phased-in by MY 2027.
Alternative 4.............................. Same stringency as
preferred alternative in
the proposal, phasing in
by MY 2024.
Alternative 5.............................. More stringent alternative,
based on higher adoption
rates of advanced
technologies.
------------------------------------------------------------------------
D. Compliance Provisions for Vocational Vehicles
We are adopting many changes in the compliance provisions for
vocational vehicles compared with what we proposed, as described in
this section.
(1) Application and Certification Process
The agencies are adopting changes in the final Phase 2 version of
GEM, as described in Section II of this Preamble. Below we provide
cross-references to test procedures either that are either required or
optional, for generation of Phase 2 GEM input values. See Section
II.D.1 for details of engine testing and GEM inputs for engines.
As described above in Section I, the agencies will continue the
Phase 1 compliance process in terms of the manufacturer requirements
prior to the effective model year, during the model year, and after the
model year. The information that will be required to be submitted by
manufacturers is set forth
[[Page 73720]]
in 40 CFR 1037.205, 49 CFR 537.6, and 49 CFR 537.7. EPA will continue
to issue certificates upon approval based on information submitted
through the VERIFY database (see 40 CFR 1037.255). End of year reports
will continue to include the GEM results for all of the configurations
built, along with credit/deficit balances, if applicable (see 40 CFR
1037.250 and 1037.730).
(a) GEM Inputs
In Phase 1, there were two inputs to GEM for vocational vehicles:
Steer tire coefficient of rolling resistance, and
Drive tire coefficient of rolling resistance
As discussed above in Section II and III.D, there are several
additional inputs that we are adopting for Phase 2. In addition to the
steer and drive tire CRR, the inputs include the following:
Engine input file with fuel map, full-load torque curve,
and motoring curve,
Transmission input file including architecture type, gear
number and ratios, and minimum lockup gear for transmissions with
torque converters,
Drive axle ratio,
Axle configuration,
Tire size in revs/mi for drive and steer tires,
Idle Reduction,
Weight Reduction,
Vehicle Speed Limiter,
Aerodynamic Drag Area, and
Pre-defined technology inputs for Accessory Load and Tire
Pressure Systems
(i) Driveline Inputs
As with tractors, for each engine family, engine fuel maps, full
load torque curve, and motoring curve will be generated by engine
manufacturers and supplied to chassis manufacturers in a format
compatible with GEM. The test procedures for the torque and motoring
curves are found in 40 CFR part 1065. Section II.D.1.b describes these
procedures as well as the procedures for generating the engine fuel
maps. We require the steady state map approach for the 55 and 65 mph
cruise speed cycles, while the cycle average approach is required for
the ARB transient cycle. As an option, the cycle average map may also
be used for 55 and 65 mph cruise speed cycles. Also similar to
tractors, transmission specifications will be input to GEM. Any number
of gears may be entered with a numerical ratio for each, and
transmission type must be entered as either a Manual, Automated Manual,
or Automatic transmission.
As part of the driveline information needed to run GEM, drive axle
ratio will be a user input. If a configuration has a two-speed axle,
the agencies are adopting regulations to instruct a manufacturer to
enter the ratio that is expected to be engaged for the greatest driving
distance. We requested comment on whether the agencies should allow
this choice, and what the GEM input instructions should be. Both Dana
and Meritor commented that there should be an option to recognize two-
speed axles, but neither axle supplier offered a preference for how the
agencies should implement this. Two-speed axles are typically specified
for heavy-haul vehicles, where the higher numerical ratio axle is
engaged during transient driving conditions and to deliver performance
needed on work sites, while the lower numerical ratio axle may be
engaged during light-load highway driving.
Tire size is a Phase 2 input to GEM that is necessary for the model
to simulate the performance of the vehicle. As a result of comment and
further technical analysis, we are adopting the tire size input as
measured in revs/mile, rather than the measure of loaded radius in
meters, as was proposed. The RIA Chapter 3 includes a description of
how to measure tire size. For each model and nominal size of a tire,
there are numerous possible sizes that could be measured, depending on
whether the tire is new or ``grown,'' meaning whether it has been
broken in for at least 200 miles. Size can also vary based on load and
inflation levels, air temperature, and tread depth. The agencies
requested comment on aspects of measuring and reporting tire size. The
revised test procedure is described in the RIA Chapter 3.3.4.
For manufacturers electing to certify a vocational vehicle to the
optional custom chassis standards, none of the above driveline inputs
are applicable. In this case manufacturers must input one of the custom
chassis regulatory subcategory identifiers shown in Table V-32. After
the remaining input fields are either completed with values or N/A, GEM
will simulate the vehicle by calling the default engine and
transmission files, tire size, and axle radius from the GEM library.
The following subsections describe the required and optional inputs for
custom chassis.
Table V-32--Custom Chassis Subcategory Names
------------------------------------------------------------------------
Regulatory
Vehicle type subcategory GEM Default weight class
identifier and duty cycle
------------------------------------------------------------------------
Motor Home.................. MHD_CC_MH........... MHD Regional.
School Bus.................. MHD_CC_SB........... MHD Urban.
Coach Bus................... HHD_CC_CB........... HHD Regional.
Emergency Vehicle........... HHD_CC_EM........... HHD Urban.
Concrete Mixer.............. HHD_CC_CM........... HHD Urban.
Transit and Other bus....... HHD_CC_OB........... HHD Urban.
Refuse Truck................ HHD_CC_RF........... HHD Urban.
------------------------------------------------------------------------
The agencies requested comments on the merits of using an equation-
based compliance approach for emergency vehicle manufacturers, similar
to the approach for trailer manufacturers described in Section IV.F.
CARB commented in support of an equation-based compliance approach, but
in the same comment they also expressed support for using a Phase 1-
style GEM interface with a default engine simulated in GEM as
appropriate for the emergency vehicle category. We received adverse
comment on the equation-based approach from Daimler, because they
believed it would make the compliance process more complex if some
vehicles needed to be tracked differently. Our intent in soliciting
comment on an equation-based approach was to assess whether running GEM
was a burden for non-diversified manufacturers of low-technology
vehicles. Because we received sufficient support from non-diversified
manufacturers that a simplified GEM would meet their needs, we did not
pursue an equation-based approach.
The final certification approach is consistent with the approach
recommended by the Small Business Advocacy Review Panel, which believed
it will be feasible for small emergency
[[Page 73721]]
vehicle manufacturers to install a Phase 2-compliant engine, but
recommended a simplified certification approach to reduce the number of
required GEM inputs.
(ii) Idle Reduction Inputs
The agencies proposed two different idle reduction inputs for
vocational vehicles: Neutral idle and stop-start. Based on comment, we
are adding a third type of idle reduction input: Automatic engine
shutdown. Based on user inputs derived from engine testing described in
Section II and RIA Chapter 3.1, GEM will calculate CO2
emissions and fuel consumption at both zero torque (neutral idle) and
with torque set to Curb-Idle Transmission Torque for automatic
transmissions in ``drive'' (as described in the RIA Chapter 3.4.2.3)
for use in the CO2 emission calculation in 40 CFR
1037.510(b). At proposal, neutral idle and stop-start were not
recognized during the ARB transient cycle, they were recognized only
during the separate idle cycle. The agencies received comments
requesting recognition of neutral idle during the ARB transient test
cycle. We agree this is desirable and have adopted changes in GEM to
accomplish this. Also, with the adoption of the alternative engine
mapping procedure for the ARB transient cycle, the computation for idle
reduction has changed. Please see RIA Chapter 4.4.1.7 for a description
of how GEM recognizes idle reduction.
For vocational custom chassis certified to the optional standards,
all three idle reduction inputs will be available, however, the
computation will be based on the EPA default engine. As described in
the GEM User Guide, users will enter Y or N, and GEM will return a
predefined improvement.
(iii) Weight Reduction Inputs
In Phase 1, the agencies adopted tractor regulations that provided
manufacturers with the ability to utilize high strength steel and
aluminum components for weight reduction without the burden of entering
the curb weight of every tractor produced. In Phase 2, the agencies are
adopting a lookup table of lightweight components for use in certifying
vocational vehicles, similar to the process for tractors. As noted
above, the agencies will recognize weight reduction by allocating one
half of the weight reduction to payload in the denominator, while one
half of the weight reduction will be subtracted from the overall weight
of the vehicle in GEM.
The agencies are adopting lookup values for components on
vocational vehicles in all HD weight classes. Components available for
vocational vehicle manufacturers to select for weight reduction are
shown below in Table V-33, below. All of these weight reduction inputs
will be available for manufacturers of custom chassis certifying to the
optional standards. We received comments from Allison Transmission
noting that aluminum transmission cases and clutch housings are
standard for automatic transmissions so we agree it is inappropriate to
include these components in the lookup table. We have revised the
values in response to adverse comments from AISI, and after
reevaluating information available at proposal. Although we are not
projecting any adoption of permanent 6x2 axles for non-custom
vocational vehicles, if a manufacturer chooses to apply this technology
for class 8 vocational vehicles, users may enter an appropriate weight
reduction compared to the traditional 6x4 axle configuration.\447\ We
received adverse comments on the proposal to assign a fixed weight
increase to natural gas fueled vehicles to reflect the weight increase
of natural gas fuel tanks versus gasoline or diesel tanks. Based on
comments and further technical analysis, we have determined that to
provide equitable treatment to technologies, we will not require a
weight penalty for any technology applied to achieve certification in
Phase 2. We accounted for adoption of weight-increasing technologies in
our MOVES modeling.
---------------------------------------------------------------------------
\447\ See NACFE Confidence Findings on the Potential of 6x2
Axles.
Table V-33--Phase 2 Weight Reduction Technologies for Vocational Vehicles
----------------------------------------------------------------------------------------------------------------
Vocational vehicle class
Component Material -----------------------------------------------
Class 2b-5 Class 6-7 Class 8
----------------------------------------------------------------------------------------------------------------
Axle Hubs--Non-Drive.................. Aluminum................ 40 40
Axle Hubs--Non-Drive.................. High Strength Steel..... 5 5
Axle--Non-Drive....................... Aluminum................ 60 60
Axle--Non-Drive....................... High Strength Steel..... 15 15
Brake Drums--Non-Drive................ Aluminum................ 60 60
Brake Drums--Non-Drive................ High Strength Steel..... 42 42
Axle Hubs--Drive...................... Aluminum................ 40 80
Axle Hubs--Drive...................... High Strength Steel..... 10 20
Brake Drums--Drive.................... Aluminum................ 70 140
Brake Drums--Drive.................... High Strength Steel..... 37 74
Suspension Brackets, Hangers.......... Aluminum................ 67 100
Suspension Brackets, Hangers.......... High Strength Steel..... 20 30
-------------------------------------------------------------------------
Crossmember--Cab...................... Aluminum................ 10 15 15
Crossmember--Cab...................... High Strength Steel..... 2 5 5
Crossmember--Non-Suspension........... Aluminum................ 15 15 15
Crossmember--Non-Suspension........... High Strength Steel..... 5 5 5
Crossmember--Suspension............... Aluminum................ 15 25 25
Crossmember--Suspension............... High Strength Steel..... 6 6 6
Driveshaft............................ Aluminum................ 12 40 50
Driveshaft............................ High Strength Steel..... 5 10 12
Frame Rails........................... Aluminum................ 120 300 440
Frame Rails........................... High Strength Steel..... 40 40 87
Wheels--Dual.......................... Aluminum................ 150 150 250
Wheels--Dual.......................... High Strength Steel..... 48 48 80
Wheels--Wide Base Single.............. Aluminum................ 294 294 588
[[Page 73722]]
Wheels--Wide Base Single.............. High Strength Steel..... 168 168 336
Permanent 6x2 Axle Configuration...... Multi................... N/A N/A 300
----------------------------------------------------------------------------------------------------------------
(iv) Other Inputs
Certifying manufacturers may enter values in GEM as applicable for
vehicle speed limiters, fairings to reduce aerodynamic drag area,
electrified accessories, and tire pressure systems where such features
meet the criteria in the regulations at 40 CFR 1037.520.
(b) Test Procedures
Powertrain families are defined in Section II.C.3.b, and powertrain
test procedures are discussed in the RIA Chapter 3.6. The results from
testing a powertrain configuration using the matrix of tests described
in RIA Chapter 3.6 can be applied broadly across all vocational
vehicles in which that powertrain will be installed. Powertrain test
results become a GEM input file that replaces both the engine input
file and transmission input file.
As in Phase 1, 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 declare TRRLs (which may be equal to
or higher than the measured values) for the drive and steer tires
separately to be input into the GEM. For Phase 2 vocational vehicles,
GEM will distribute the vehicle load with 30 percent of the load over
the steer tires and 70 percent of the load over the drive tires. With
these data entered, the amount of GHG reduction attributed to tire
rolling resistance will be incorporated into the overall vehicle
compliance value.
The final Phase 2 GEM will accept as inputs results from a
transmission efficiency test. A procedure for this was discussed in the
NPRM, and received favorable comment. The transmission efficiency test
will be optional, but will allow manufacturers to reduce the
CO2 emissions and fuel consumption by designing better
transmissions with lower friction due to better gear design and/or
mandatory use of better lubricants.
In lieu of a fixed value for low friction axle lubricants as was
proposed, the agencies are adopting an axle efficiency test procedure,
as was discussed in the NPRM. See 80 FR 40323. The axle efficiency test
will be optional, but will allow manufacturers to reduce CO2
emissions and fuel consumption through improved axle gear designs and/
or mandatory use of low friction lubricants. The agencies are not
finalizing any other paths to recognize low friction axle lubricants.
(c) Useful Life and In-Use Standards
Section 202(a)(1) of the CAA specifies that emission standards are
to be applicable for the useful life of the vehicle. The standards that
EPA and NHTSA are adopting will apply to individual vehicles and
engines at production and in use. NHTSA is not adopting in-use
standards for vehicles or engines.
Manufacturers may be required to submit, as part of the application
for certification, an engineering analysis showing that emission
control performance will not deteriorate during the useful life, with
proper maintenance. If maintenance will be required to prevent or
minimize deterioration, a demonstration may be required that this
maintenance will be performed in use. See 40 CFR 1037.241.
EPA will continue the Phase 1 approach to adjustment factors and
deterioration factors for vehicles. The technologies on which the Phase
1 vocational vehicle standards were predicated were not expected to
have any deterioration of GHG effectiveness in use. However, the
regulations provided a process for manufacturers to develop
deterioration factors (DF) if they needed. We anticipate that some
hybrid powertrain systems may experience some deterioration of
effectiveness with age of the energy storage device. We believe the
regulations in place currently provide adequate instructions to
manufacturers for developing DF where needed. We received comments from
Daimler on deterioration factors for engines and the process for
extrapolating where DF's are nonlinear. See Section 3.7 of the RTC.
Allison Transmission commented that the amount of credits generated for
a hybrid system should be dependent, in part, on design limits of
batteries. We do not believe any changes are needed because the
regulations do account for this by basing the FELs on the highest
emissions during the useful life, including any effects from
deterioration.
As with engine certification, a chassis manufacturer must design
their vehicles to be durable enough to maintain compliance through the
regulatory useful life of the vehicle. Factors influencing vehicle-
level GHG performance over the life of the vehicle fall into two basic
categories: Vehicle attributes and maintenance items. Each category
merits different treatment from the perspective of assessing useful
life compliance, as each has varying degrees of manufacturer versus
owner/operator responsibility. The agencies require manufacturers to
explain how they meet these requirements as part of certification.
For vocational vehicles, attributes generally refers to components
that are installed by the manufacturer to meet the standard, whose
reduction properties are assessed at the time of certification, and
which are expected to last the full life of the vehicle with
effectiveness maintained as new for the life of the vehicle with no
special maintenance requirements. To assess useful life compliance, we
will follow a design-based approach that will ensure that the
manufacturer has robustly designed these features so they can
reasonably be expected to last the useful life of the vehicle.
For vocational vehicles, maintenance items generally refers to
items that are replaced, renewed, cleaned, inspected, or otherwise
addressed in the preventative maintenance schedule specified by the
vehicle manufacturer. Replacement items that have a direct influence on
GHG emissions are primarily tires and lubricants, but may also include
hybrid system batteries. Synthetic engine oil may be used by vehicle
manufacturers to reduce the GHG emissions of their vehicles.
Manufacturers may specify that these fluids be changed throughout the
useful life of the vehicle. If this is the case, the manufacturer
should have a reasonable basis that the owner/operator will use fluids
having the same properties. This may be accomplished by requiring (in
service documentation, labeling, etc.) that only these fluids can be
used as replacements. We received comments from EMA asking us to
consider maintenance costs for hybrids. In these final rules, we have
quantified
[[Page 73723]]
maintenance costs for tire replacement, stop-start, axle lubrication,
and hybrids, as described in Section IX.D and the RIA Chapter 7.1.
Aside from those technologies identified above, if the vehicle
remains in its original certified condition throughout its useful life,
it is not believed that GHG emissions will increase as a result of
service accumulation. As in Phase 1, the agencies will therefore allow
the use of an assigned deterioration factor of zero where appropriate
in Phase 2; however this does not negate the responsibility of the
manufacturer to ensure compliance with the emission standards
throughout the useful life.\448\ Under both Phase 1 and the new Phase
program, manufacturers must apply good engineering judgment when
considering deterioration and may not ignore any evidence that the
emissions performance will decline during actual use. The agencies may
require vehicle manufacturers to provide engineering analyses at the
time of certification demonstrating that vehicle attributes will last
for the full useful life of the vehicle. We anticipate this
demonstration would often need only show that components are
constructed of sufficiently robust materials and design practices so as
not to become dysfunctional under normal operating conditions.
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\448\ For most technologies, manufacturers may presume zero
deterioration unless good engineering judgment does not support such
a presumption. For example, it would not be appropriate to presume
no deterioration in hybrid battery performance.
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In Phase 1, EPA set the useful life for engines and vehicles with
respect to GHG emissions equal to the respective useful life periods
for criteria pollutants. In April 2014, as part of the Tier 3 light-
duty vehicle final rule, EPA extended the regulatory useful life period
for criteria pollutants to 150,000 miles or 15 years, whichever comes
first, for Class 2b and 3 pickup trucks and vans and some light-duty
trucks (79 FR 23414, April 28, 2014). Class 2 through Class 5 heavy-
duty vehicles subject to the GHG standards described in this section
for vocational applications generally use the same kinds of engines,
transmissions, and emission controls as the Class 2b and 3 vehicles
that are chassis-certified to the criteria standards under 40 CFR part
86, subpart S. In Phase 2, EPA and NHTSA are adopting a useful life of
150,000 miles or 15 years for vocational vehicles at or below 19,500
lbs GVWR. In many cases, this will result in aligned useful-life values
for criteria and GHG standards. Where this longer useful life is not
aligned with the useful life that applies for criteria standards
(generally in the case of engine-based certification under 40 CFR part
86, subpart A), EPA may revisit the useful-life values for both
criteria and GHG standards in a future rulemaking. For medium heavy-
duty vehicles (19,500 to 33,000 lbs GVWR) and heavy heavy-duty vehicles
(above 33,000 lbs GVWR) EPA will keep the useful-life values from Phase
1, which are 185,000 miles (or 10 years) and 435,000 miles (or 10
years), respectively. EPA received comments in support of this
approach, including support for the numerical values and the overall
process envisioned for achieving the long-term goal of adopting
harmonized useful-life specifications for criteria pollutant and GHG
standards that properly represent the manufacturers' obligation to meet
emission standards over the expected service life of the vehicles.
We received comment on what policies we should adopt to address the
situation where the engine and the vehicle are subject to emission
standards over different useful-life periods. For example, a medium
heavy-duty engine may power vehicles in weight classes ranging from 2b
to 8, with correspondingly different regulatory useful lives for those
vehicles. Please see Section I.F.2.f for a discussion of revisions made
to the final regulations to address this situation. The Response to
Comments also addresses this issue at Chapter 1.4.
(d) Definitions of Custom Chassis
Eligible emergency vehicles for Phase 2 purposes are ambulances and
fire trucks. The agencies requested comment on aligning the definition
of emergency vehicle for purposes of the Phase 2 program with the
definition of emergency vehicle for purposes of the light-duty GHG
provisions under 40 CFR 86.1818, which includes additional vehicles
such as those used by law enforcement.\449\ Daimler commented in
support of aligning these definitions of emergency vehicle. Daimler
further requested the agencies consider adopting the same definition as
in 13 CCR 1956.8(a)(6), the California regulations. We are adopting the
narrow definition as was proposed, with agency discretion to apply
these provisions to similar vehicles.
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\449\ See 40 CFR 86.1803-01 for the applicable definition of
emergency vehicle.
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RVIA commented in favor of adopting a motor home definition
consistent with NHTSA's definition at 49 CFR 571.3: Motor home means a
multipurpose passenger vehicle with motive power that is designed to
provide temporary residential accommodations, as evidenced by the
presence of at least four of the following facilities: Cooking;
refrigeration or ice box; self-contained toilet; heating and/or air
conditioning; a potable water supply system including a faucet and a
sink; and a separate 110-125 volt electrical power supply and/or
propane. The agencies are adopting a definition of motor home that is
generally consistent with this, without specifying detailed features.
Since 2003, NHTSA has implemented a broad definition of school bus
that includes multifunction school activity buses that don't have stop
arms or flashing lights, need not be painted yellow, and do not have an
upper weight limit. These are a category of school bus that must meet
the school bus structural standards or the equivalent set forth in 49
Code of Federal Regulations Part 571, and the emergency exit
requirements specified in FMVSS No. 217 for school buses, as well as
FMVSS 222 for passenger seating and crash protection. This definition
was created in part to allow for use of safe buses to transport school
age children on trips other those than between home and school. The
agencies are adopting Phase 2 provisions such that buses eligible to
certify to the custom chassis school bus standards are those that meet
NHTSA's definition of school bus, including multifunction school
activity buses.\450\
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\450\ See 68 FR 44892--Federal Motor Vehicle Safety Standards;
Definition of Multifunction School Activity Bus; https://www.govinfo.gov/content/pkg/FR-2003-07-31/pdf/03-19457.pdf.
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The most definitive attribute we have identified to distinguish
over-the-road coach buses from transit buses is whether passengers are
permitted to stand while the vehicle is driving. Therefore the only
buses permitted to certify to the final custom chassis coach bus
standards are those subject to NHTSA's Occupant Crash Protection
Rule.\451\
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\451\ See Occupant Crash Protection rule, November 25, 2013, 78
FR 70415, 49 CFR 571, FMVSS 208 https://www.gpo.gov/fdsys/pkg/FR-2013-11-25/html/2013-28211.htm, accessed February 2016.
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Allied Specialty Vehicles (aka Rev Group) commented on the need for
a clear distinction between transit buses and school buses.\452\ If the
pupils transported are not K-12 students, such as may be the case for
buses serving college campuses, then the chassis may not be easily
distinguishable from transit buses. The agencies are adopting
provisions in Phase 2 such that buses not qualifying as eligible to
certify as coach buses or school buses must meet the custom chassis
standards for transit
[[Page 73724]]
buses. Buses serving college campuses do not have the same design and
safety restrictions as those intended to transport primary and
secondary school children, and may apply the same technologies as
general-purpose urban buses.
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\452\ Phone conversation March 2016, see L. Steele phone log.
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Therefore, we are requiring refuse trucks that do not compact waste
to be certified to the primary vocational vehicle standards. Front-
loading refuse collection vehicles tend to have a relatively low number
of stops per day as they tend to collect waste from central locations
such as commercial buildings and apartment complexes. Because these
have a relatively low amount of PTO operation, we expect stop-start
will be reasonably effective for these vehicles. Rear-loading and side-
loading neighborhood waste and recycling collection trucks are the
refuse trucks where the largest number of stop-start and neutral idle
over-ride conditions are likely to be encountered. Because chassis
manufacturers, even those with small production volumes and close
customer relationships, do not always know whether a refuse truck will
be a front-loader, rear-loader, or side loader, we are grouping these
together in a subcategory.
We received comment on the need to clarify whether vehicles
designed to pump and convey concrete at a job site, but which do not
carry the wet mix concrete to the job site, would be included in the
definition of cement mixers. Although we are not defining other
vehicles as cement mixers, we are allowing miscellaneous vocational
vehicles meeting some but not all of the eligibility criteria at 40 CFR
1037.631 to be certified under the custom chassis program, using
technology equivalent to the cement mixer package, as described above
in Section V.B.
(e) Assigning Vehicles to Subcategories
In the NPRM, the agencies proposed criteria by which a vehicle
manufacturer would know in which vocational subcategory--Regional,
Urban, or Multipurpose--the vehicle should be certified. These cut-
points were defined using calculations relating engine speed to vehicle
speed. 80 FR 40287-40288. Specifically, we proposed a cutpoint for the
Urban duty cycle where a vehicle at 55 mph would have an engine working
above 90 percent of maximum engine test speed for vocational vehicles
powered by diesel engines and above 50 percent for vocational vehicles
powered by gasoline engines. Similarly, we proposed a cutpoint for the
Regional duty cycle where a vehicle at 65 mph would have an engine
working below 75 percent of maximum engine test speed for vocational
vehicles powered by diesel engines and below 45 percent for vocational
vehicles powered by gasoline engines. We received several comments that
identified weaknesses in that approach. Specifically, Allison explained
that vehicles with two shift schedules would need clarification which
top gear to use when calculating the applicable cut-point. Also,
Daimler noted that, to the extent that downspeeding occurs in this
sector over the next decade or more, cutpoints based on today's fleet
may not be valid for a future fleet. Allison noted that the presence of
additional top gears could strongly influence the subcategory placement
of vocational vehicles. These comments highlight the possibility of
misclassification, and the potential pitfalls in a mandated
classification scheme.
Two commenters pointed out important weaknesses in this approach,
namely that future trends in engine speeds, torque curves, and
transmission gear ratio spreads may cause the vocational fleet of 2027
to have drivelines that are sufficiently different than those of the
baseline fleet, so that segment cut-points based on the 2016 fleet may
not be valid a decade or more into the future. For example, if data on
today's fleet indicated an appropriate cut-point for Regional HHD
diesel vehicles of 1,400 rpm engine speed with a vehicle speed of 65
mph, while a future fleet might show that Regional vehicles operated at
1,200 rpm at 65 mph, then having a cut-point set by rule at 1,400 rpm
could result in an excess of future vehicles certifying as Regional.
However, we have further assessed the impact of manufacturers shifting
certification of chassis from Multipurpose to Regional subcategories,
and we have concluded this is not an unacceptable outcome. As explained
above in Section V.C.(2)(d), we are not particularly concerned that
adopting final standards with unequal percent improvements poses a
danger of losing environmental benefits from this program, as long as
vehicle configurations are properly classified at the time of
certification.
In a regulatory structure where baselines are equal but future
standards for vehicles in different subcategories have different
stringencies, the agencies would typically assign subcategorization
based on regulatory criteria rather than allowing the manufacturers
unconstrained choice because manufacturers would have a strong
incentive to simply choose the least stringent standards. However,
because the baseline performance levels of the different vocational
vehicle regulatory subcategories widely differ, the agencies have
determined that it is acceptable to adopt standards with unequal
percent stringencies. Further discussion of our reasons for this
determination is presented above in Section V.C.(2)(d). Another
weakness in the proposed approach was that even though we have obtained
a great deal of data thanks to manufacturer cooperation and NREL duty
cycle analysis, the only one of the proposed regulatory cut-points in
which we have a high degree of confidence is the cut-point between
Regional and Multipurpose class 8 diesels. Any cut-points we could
establish based on available data for lower weight class diesels or for
gasoline powered vocational vehicles would be less robust. These
weaknesses have led the agencies to take a different approach to
assigning vehicles to subcategories. The agencies are adopting final
regulations that generally allow manufacturers to choose a subcategory,
with a revised set of constraints as well as a provision requiring use
of good engineering judgment. The constraints discussed here are being
adopted as interim provisions in response to manufacturers' concerns
that some of them could present competitive disadvantages, where
different manufacturers produce very different sales mixes of vehicles
equipped with different transmission types, as discussed above in
Section V.C.(2)(d).
Because the baseline configurations against which vehicles in the
Urban subcategories will measure their future performance do not
include any manual transmissions, we have determined that vocational
vehicles with manual transmissions may not be certified as Urban. In
the real world, we do not expect any vehicles intended to be used in
urban driving patterns will be specified with manual transmissions.
Driver fatigue and other performance problems make this an illogical
choice of transmission, and thus it is appropriate for us to adopt this
constraint. As described in Chapter 2.9.2 of the RIA, both the HHD
Regional and HHD Multipurpose baselines have a blend of manual
transmissions, although the majority of manuals are in the HHD Regional
baseline. Further, by MY 2024, our adoption rate of transmission
technology reflects zero manuals in HHD Multipurpose. Thus, beginning
in MY 2024, any vocational vehicle certified with a manual transmission
must be classified in a Regional subcategory, except a vehicle with a
hybridized manual transmission may be certified in a Multipurpose
subcategory beyond MY 2024.
[[Page 73725]]
We are not adopting constraints on vehicles with automated manual
transmissions certifying in either Regional or Multipurpose
subcategories, because we believe this is a technology that can provide
real world benefits for vehicles with those driving patterns. However,
we are adopting an interim constraint to prevent vehicles with AMT from
being certified as Urban for a reason similar to one described above
for manuals, namely that in the real world, we do not expect any
vehicles intended to be used in urban driving patterns will be
specified with transmissions that do not have powershifts. Lack of
smooth shifting characteristics during low speed accelerations and
decelerations make AMT an illogical choice of transmission for urban
vehicles, and thus it is appropriate for us to adopt this constraint.
Dual clutch transmissions have very recently become available for
medium heavy-duty vocational vehicles and very little data are
available on their design or performance. We anticipate that in the
future, some designs may have features that make them perform similarly
to AMT's while others may have features that make them more similar to
automatics with torque converters. Because we are not confident that we
know in which duty cycle(s) they are best suited, we are adopting a
partial constraint on these, namely that dual clutch transmissions
without powershifting must also be constrained out of Urban. We are
finalizing as proposed that any vehicle whose engine is exclusively
certified over the SET must be certified in the Regional subcategory.
Further, to the extent manufacturers of intercity coach buses and
recreational vehicles certify these to the primary standards, these
also must be certified as Regional vehicles.\453\
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\453\ Based on NREL drive cycle analysis of the existing fleet,
we imagine that HHD vehicles with a diesel engine rpm of 1,400 and
below when the vehicle is at 65 mph would be appropriately certified
as Regional vehicles. However, this is illustrative only, and the
final rules do not include an engine speed cutpoint as a criterion
in subcategory selection.
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In the final regulatory structure, although the standards for
vehicles in different subcategories have different percent stringencies
from each baseline, the agencies can allow the manufacturers to choose
without risking a loss of environmental benefits because a standard
that may appear less stringent in terms of relative improvement from
each respective baseline may also be numerically lower (and farther
away from current model performance) due to a comparatively better-
performing regulatory baseline. As explained above, the final standards
described above in Section V.C.(2)(c) are derived directly from the
technology packages without applying any assumptions about fleet
averages. Thus, unlike at proposal, the final regulations will
generally allow manufacturers to certify in the particular duty-cycle
subcategory they believe to be most appropriate. Manufacturers may make
this choice as part of the certification process and will not be
allowed to change it after the vehicle has been introduced into
commerce. Under this structure, the agencies expect manufacturers to
choose a subcategory for each vehicle configuration that best
represents the type of operation that vehicle will actually experience
in use (presuming the manufacturer and customer would specify the
technologies to reflect such operation).
(2) Other Compliance Provisions
(a) Emission Control Labels
As proposed, EPA is removing the requirement to include the
emission control system identifiers required in 40 CFR 1037.135(c)(6)
and in Appendix III to 40 CFR part 1037 from the emission control
labels for vehicles certified to the Phase 2 standards. For vehicles
certified to the optional custom chassis standards, the label should
meet the requirements of 40 CFR 1037.105(h). Please see Section
I.C.(1)(g) of this Preamble for additional discussion of labeling.
(b) End of Year Reports
In the Phase 1 program, manufacturers participating in the ABT
program provided 90 day and 270 day reports to EPA and NHTSA after the
end of the model year. The agencies adopted two reports for the initial
program to help manufacturers become familiar with the reporting
process. For the HD Phase 2 program, the agencies proposed to simplify
reporting such that manufacturers would only be required to submit the
final report 90 days after the end of the model year with the potential
to obtain approval for a delay up to 30 days. We requested comments on
this approach. EMA, PACCAR, Navistar, Daimler, and Cummins recommended
keeping the 270 day report to allow sufficient time after the
production period is completed. We are accordingly keeping both the 90
day and 270 day reports, with the ability of the agencies' to waive the
90 day report.
(c) Delegated Assembly
The final standards for vocational vehicles are based on the
application of a wide range of technologies. Certifying vehicle
manufacturers manage their compliance demonstration to reflect this
range of technologies by describing their certified configurations in
the application for certification. In most cases, these technologies
are designed and assembled (or installed) directly by the certifying
vehicle manufacturer, which is typically the chassis manufacturer. In
these cases, it is straightforward to assign the responsibility to the
certifying vehicle manufacturer for ensuring that vehicles are in their
proper certified configuration before they are introduced into
commerce. In Phase 1, the only vehicle technology available for
certified vocational vehicles is LRR tires. Because these are generally
installed by the chassis manufacturer, there is no need to rely on a
second stage manufacturer for purposes of certification in Phase 1,
unless innovative credits are sought. Thus, the Phase 1 regulations did
not specify precise procedures for this.
In Phase 2, the agencies are projecting adoption of certain
technologies where the certifying vehicle manufacturer may want or need
to rely on a downstream manufacturing company (a secondary vehicle
manufacturer) to take steps to assemble or install certain components
or technologies to bring the vehicle into a certified configuration. A
similar relationship between manufacturers applies with aftertreatment
devices for certified engines. EPA previously adopted ``delegated
assembly'' provisions for engines at 40 CFR 1068.261 to describe how
manufacturers can share compliance responsibilities through these
cooperative assembly procedures, and proposed to also apply it for
vehicle-based GHG standards in 40 CFR part 1037, including the
vocational vehicle standards.
The delegated assembly provisions being finalized for Phase 2
vehicle standards are only invoked if a certifying manufacturer
includes in its certified configuration a technology that it does not
install itself. Examples may include fairings to reduce aerodynamic
drag, air conditioning systems, automatic tire inflation systems, or
hybrid systems. We are clarifying this regulatory process to enable
manufacturers to include technologies in their compliance plans that
might otherwise not be considered on the basis of what they can install
themselves. To the extent certifying manufacturers rely on secondary
vehicle manufacturers to bring the vehicle into a certified
configuration, the following provisions will apply:
[[Page 73726]]
The certifying manufacturer will describe its approach to
delegated assembly in the application for certification.
The certifying manufacturer will create installation
instructions to describe how the secondary vehicle manufacturer will
bring the vehicle into a certified configuration.
The certifying manufacturer must take additional steps for
certified configurations that include hybrid powertrain components,
auxiliary power units, aerodynamic devices, or natural gas fuel tanks.
In these cases, the certifying manufacturer must have a contractual
agreement with each affected secondary vehicle manufacturer obligating
the secondary vehicle manufacturer to build each vehicle into a
certified configuration and to provide affidavits confirming proper
assembly procedures, and to provide information regarding deployment of
each type of technology (if there are technology options that relate to
different GEM input values).
See Section I.F of this Preamble and Section 1.4.4 of the RTC for
further discussion of the comments received on delegated assembly
provisions.
The agencies have developed the delegated-assembly and other
provisions in 40 CFR 1037.620--1037.622 to clarify how manufacturers
have shared and separate responsibilities for complying with the
regulations. Vocational vehicles are the most likely vehicle types to
involve both primary and secondary manufacturers; however, other types
of vehicles may also involve multiple manufacturers, so these
regulatory provisions apply to all vehicles.
Secondary manufacturers (such as body builders) that build complete
vehicles from certified chassis are obligated to comply with the
emission-related installation instructions provided by the certifying
manufacturer. Secondary manufacturers that build complete vehicles from
exempted chassis are similarly obligated to comply with all of the
regulatory provisions related to the exemption.
(d) Demonstrating Compliance With HFC Leakage Standards
EPA's requirements for vocational chassis manufacturers to
demonstrate reductions in direct emissions of HFC in their A/C systems
and components through a design-based method. The method for
calculating A/C leakage is the same as was adopted in Phase 1 for
tractors and HD pickups and vans. It 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. As is
done currently for other HD vehicles, vocational chassis manufacturers
will choose from a menu of A/C equipment and components used in their
vehicles in order to establish leakage scores, to characterize their A/
C system leakage performance. The percent leakage per year will then be
calculated as this score divided by the system refrigerant capacity. We
received comments from transit bus manufacturers with concerns that the
air conditioning systems on their vehicles are much larger and more
complex than systems on typical heavy-duty trucks. As such, they
questioned whether our HFC leakage compliance process was valid for
their vehicles. Based on information provided by suppliers of air
conditioning systems for large buses, we believe some unusually large
systems may include components not adequately represented by those
listed in the standard compliance procedure, namely the hoses, fittings
or seals may not be listed with realistic leakage rates. Therefore EPA
is adopting in this final rule provisions allowing use of an alternate
compliance procedure where an air conditioning system with refrigerant
charge capacity greater than 3,000 grams is installed in a Phase 2
vocational vehicle.
Consistent with the light-duty rule and the Phase 1 program for
other HD vehicles, vocational chassis manufacturers will compare the
components of a vehicle's A/C system with a set of leakage-reduction
technologies and actions that is based closely on that 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. This approach associates each component with a
specific leakage rate in grams per year that is identical to the values
in J2727 and then sums together the component leakage values to develop
the total A/C system leakage. Unlike the light-duty program, in the
heavy-duty vehicle program, the total A/C leakage score is divided by
the value of the total refrigerant system capacity to develop a percent
leakage per year.
EPA concludes that the design-based approach results in estimates
of likely leakage emissions reductions that are comparable to those
that would result from performance-based testing. Where a manufacturer
installs an air conditioning system in a vocational vehicle that has a
working fluid consisting of an alternate refrigerant with a lower
global warming potential than HFC-134a, compliance with the leakage
standard is addressed in the regulations at 40 CFR 1037.115. Please see
Section I.F.(2)(b) for a discussion related to alternative
refrigerants.
Consistent with the HD Phase 1 program and 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 are requiring that manufacturers of heavy-duty
vocational vehicles attest to the durability of these systems, and
provide an engineering analysis that demonstrates component and system
durability.
(e) Glider Vehicles
EPA and NHTSA requested comment on gliders and received extensive
comment. The main issues involve standards for rebuilt engines
installed in new glider vehicles. These issues are fully addressed in
Preamble Section XIII.B and RTC Section 14.2. Of relevance for the
vocational vehicle sector, the final standards contain a number of
provisions allowing donor engines that are still within their
regulatory useful life to be used in new glider vehicles provided the
engine meets all standards applicable to the year in which the engine
was originally manufactured and also meets one of the following
criteria:
The engine is still within its original useful life in
terms of both miles and years.
The engine has less than 100,000 miles of engine
operation.
The engine is less than three years old.
Thus, if a donor engine meeting one of the above criteria was
manufactured before the Phase 1 GHG standards, it would not be subject
to those standards when installed in a glider vehicle. Similarly, if
such an engine was manufactured before 2010, it would be subject to the
pre-2010 criteria pollutant standards corresponding to its year of
manufacture. EPA is adopting this provision consistent with the
original purpose of glider vehicles as providing a means of salvaging
of relatively new powertrains from vehicle chassis that have been
damaged or have otherwise failed prematurely. See Section XIII.B of the
Preamble.
[[Page 73727]]
(3) Compliance Flexibility Provisions
EPA and NHTSA are adopting several flexibility provisions in the
Phase 2 program. Program-wide compliance flexibilities include an
averaging, banking and trading program for CO2 emissions and
fuel consumption credits, provisions for off-cycle credits for
technologies that are not included as inputs to the GEM, and advanced
technology credits. These are described below as well as in Section
I.B.3 to I.C.1. Provisions that are not program-wide include optional
chassis certification and a revised interim loose engines provision, as
described below.
(a) Averaging, Banking, and Trading (ABT) Program
Averaging, banking, and trading of emission credits have been an
important part of many EPA mobile source programs under CAA Title II.
ABT provisions provide manufacturers flexibilities that assist in the
efficient development and implementation of new technologies and
therefore enable new technologies to be implemented at a more
aggressive pace than without ABT. NHTSA and EPA are carrying-over the
Phase 1 ABT provisions for vocational vehicles into Phase 2, as it is
an important way to achieve each agency's programmatic goals. ABT is
also discussed in Section I and Section III.F.1.
Consistent with the Phase 1 averaging sets, the agencies are
allowing chassis manufacturers to average SI-powered vocational vehicle
chassis with CI-powered vocational vehicle chassis, within the same
vehicle weight class group. In Phase 1, all vocational and tractor
chassis within a vehicle weight class group were able to average with
each other, regardless of whether they were powered by a CI or SI
engine. The Phase 2 approach continues this. The only difference is
that in Phase 2, there are different numerical standards set for the
SI-powered and CI-powered vehicles, but that does not alter the basis
for averaging. This is consistent with the Phase 1 approach where, for
example, Class 8 day cab tractors, Class 8 sleeper cab tractors and
Class 8 vocational vehicles each have different numerical standards,
while they all belong to the same averaging set.
As discussed in V.D.(1)(c), EPA and NHTSA are adopting a revised
useful life for LHD vocational vehicles for GHG emissions from the
current 10 years/110,000 miles to 15 years/150,000 miles, to be
consistent with the useful life of criteria pollutants recently updated
in EPA's Tier 3 rule. For the same reasons, EPA and NHTSA are also
adopting a useful life adjustment for HD pickups and vans, as described
in Section VI.E.(1). According to the credits calculation formula at 40
CFR 1037.705 and 49 CFR 535.7, useful life in miles is a multiplicative
factor included in the calculation of CO2 and fuel
consumption credits. In order to ensure that banked credits will
maintain their value in the transition from Phase 1 to Phase 2, NHTSA
and EPA are adopting an interim vocational vehicle adjustment factor of
1.36 for credits that are carried forward from Phase 1 to the MY 2021
and later Phase 2 standards.\454\ Without this adjustment factor the
change in useful life would effectively result in a discount of banked
credits that are carried forward from Phase 1 to Phase 2, which is not
the intent of the change in the useful life. The agencies do not
believe that this adjustment will result in a loss of program benefits
because there is little or no deterioration anticipated for
CO2 emissions and fuel consumption over the life of the
vehicles. Also, the carry-forward of credits is an integral part of the
program, helping to smooth the transition to the Phase 2 standards. The
agencies believe that effectively discounting carry-forward credits
from Phase 1 to Phase 2 is unnecessary and could negatively impact the
feasibility of the Phase 2 standards. EPA and NHTSA requested comment
on all aspects of the averaging, banking, and trading program. A
complete discussion of the comments on credits and ABT can be found in
the RTC Section 1.4.
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\454\ See 40 CFR 1037.150(o) and 49 CFR 535.7.
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(b) Innovative and Off-Cycle Technology Credits
In Phase 1, the agencies adopted an emissions and fuel consumption
credit generating opportunity that applied to innovative technologies
that reduce fuel consumption and CO2 emissions. Eligible
technologies were required to not be in common use with heavy-duty
vehicles before the 2010MY and not reflected in the GEM simulation tool
(i.e., the benefits are ``off-cycle''). See 76 FR 57253. In Phase 2,
the agencies are re-designating it as an off-cycle technology program.
The agencies are maintaining the requirement that, in order for a
manufacturer to receive credits for Phase 2, the off-cycle technology
must not have been in common use prior to MY 2010.
The agencies recognize that there are emerging technologies today
that are being developed, but will not be accounted for in the GEM
tool, and therefore will be considered off-cycle. For vocational
vehicles, this could include technologies whose scope and effectiveness
surpass those defined and pre-approved in the HD Phase 2 program, such
as aerodynamics and electrified accessories. Any credits for these
technologies will need to be based on real-world fuel consumption and
GHG reductions that can be measured with verifiable test methods using
representative driving conditions typical of the engine or vehicle
application. More information about off-cycle technology credits can be
found at Section I.C.1.c.
As in Phase 1, the agencies will continue to provide two paths for
approval of the test procedure to measure the CO2 emissions
and fuel consumption reductions of an off-cycle technology used in
vocational vehicles. See 40 CFR 1037.610 and 49 CFR 535.7. The first
path will not require a public approval process of the test method. A
manufacturer may use ``pre-approved'' test methods for HD vehicles
including the A-to-B chassis testing, powerpack testing or on-road
testing. A manufacturer may also use any developed test procedure that
has known quantifiable benefits. A test plan detailing the testing
methodology will be required to be approved prior to collecting any
test data. The agencies are also continuing the second path, which
includes a public approval process of any testing method that could
have questionable benefits (i.e., an unknown usage rate for a
technology). Furthermore, the agencies are adopting revisions to
clarify what documentation must be submitted for approval, aligning
them with provisions in 40 CFR 86.1869-12. NHTSA is prohibiting credits
from technologies addressed by any of its crash avoidance safety
rulemakings (i.e., congestion management systems). See also 77 FR 62733
(discussion of similar issue in the light duty greenhouse gas/fuel
economy regulations). We received extensive comment on the off-cycle
technology approval process. In response to requests to develop a
streamlined path for off-cycle technology approval, we are not making
fundamental changes from the proposal at this time; however, we remain
open to working with stakeholders to look for ways to simplify the
process. For example, although we are including specific provisions to
recognize certain electrified accessories, recognizing others would
require the manufacturer to go through the off-cycle process. However,
it is quite possible that the agencies could gather sufficient data to
allow us to adopt specific provisions in a future rulemaking to
recognize other accessories in a simpler
[[Page 73728]]
manner. Please see Section I.C. of this Preamble for further discussion
of off-cycle credits.
There are some technologies that are entering the market today, and
although our model does not have the capability to simulate the
effectiveness over the test cycles, there are reliable estimates of
effectiveness available to the agencies. These will be recognized in
our HD Phase 2 certification procedures as pre-defined technologies,
and will not be considered off-cycle. Examples of such technologies for
vocational vehicles include narrowly-defined types of electrified
accessories or aerodynamic improvements. The agencies are specifying
default effectiveness values to be used as valid inputs to GEM for each
of these. The projected effectiveness of each vocational vehicle
technology is discussed in the RIA Chapter 2.9.3.
The agencies' approval for Phase 1 innovative technology credits
(approved prior to 2021 MY) will be carried into the Phase 2 program on
a limited basis for those technologies where the benefit is not
accounted for in the Phase 2 test procedure. Therefore, the
manufacturers will not be required to request new approval for any
innovative credits carried into the off-cycle program, but will have to
demonstrate, as part of the MY 2021 certification, the extent to which
the new cycle does not account for these improvements. The agencies
believe this is appropriate because technologies, such as those related
to the transmission or driveline, may no longer be ``off-cycle''
because of the addition of these technologies into the Phase 2 version
of GEM.
(c) Advanced Technology Credits
As described above in Section I, the agencies proposed to
discontinue advanced technology credits in Phase 2, which had been
intended to promote the early implementation of advanced technologies
that were not expected to be widely adopted in the market in the 2014
to 2018 time frame. These technologies were defined in Phase 1 as
hybrid powertrains, Rankine cycle engines, all-electric vehicles, and
fuel cell vehicles (see 40 CFR 1037.150(p)), at a 1.5 credit value. We
requested and received comments on the need for such incentives, and as
a result we are not only continuing these credits, we are adopting even
greater multipliers than before. See Section I of this Preamble for
further discussion of the comments received and the agencies' response
regarding advanced technology credits.
(d) Optional Chassis Certification
In Phase 2, the agencies are continuing the Phase 1 option to
chassis certify vehicles over 14,000 lbs GVWR, but only if there is a
family with vehicles at or below 14,000 pounds GVWR that can properly
accommodate the bigger vehicles as part of the same family. As adopted
in this final rule, chassis-certified vehicles above 14,000 pounds GVWR
may not rely on a work factor that is greater than the largest work
factor that applies for vehicles at or below 14,000 pounds GVWR from
the same family. Applying this work factor constraint avoids the need
to set a specific upper GVWR limit on vehicles eligible to use this
flexibility. See Section XIII.A.2 of this Preamble, and Section 14.3.2
of the RTC, for further discussion of this issue.
(e) Certifying Loose SI Engines in Vocational Vehicles in Phase 2
The agencies proposed not to continue the Phase 1 interim
flexibility known as the ``loose engine'' provision, receiving
favorable comment from Cummins and adverse comment on this from Isuzu
and AAPC. 80 FR 40331. Under this provision, SI engines produced by
manufacturers of HD pickup trucks and vans and sold to chassis
manufacturers and intended for use in vocational vehicles need not meet
the separate SI engine standard, and instead may be averaged with the
manufacturer's HD pickup and van fleet (see 40 CFR 86.1819-14(k)(8)).
The agencies are adopting a Phase 2 SI engine standard that is no more
stringent than the MY 2016 SI engine standard adopted in Phase 1, while
the Phase 2 standards for the HD pickup and van fleet is progressively
more stringent through MY 2027. The primary certification path designed
in the Phase 1 program for both CI and SI engines sold separately and
intended for use in vocational vehicles is that they are engine
certified while the vehicle is GEM certified under the GHG rules.
This provision was adopted primarily to address small volume sales
of engines used in complete vehicles that are also sold to other
manufacturers. The Phase 1 final rules explain that we set the
effective date of the Phase 1 SI engine standard as MY 2016 because we
projected by this time all manufacturers would have redesigned their
gasoline engine offerings to adopt the technologies needed to reduce
FTP-cycle emissions by five percent; technologies that cannot simply be
bolted on to an existing engine but can only be effectively applied
through an integrated design and development process (76 FR 57180,
57235). The Phase 1 final rules also explain that the compliance
flexibility provided by the loose engine provision is technically
appropriate because it provides manufacturers with an option to focus
their energy on improving the GHG and fuel consumption performance of
their complete vehicle products (including engine improvements), rather
than on concurrently calibrating for both vehicle and engine test
compliance (76 FR 57260). At proposal we noted that although gasoline
engine manufacturers have accomplished extensive improvements to comply
with HD pickup and vans standards as well as the light-duty vehicle
standards, the agencies had not seen evidence of the engine redesigns
that we had projected to occur by 2016, and we concluded that
discontinuation of this flexibility by MY 2021 was appropriate to
provide regulatory certainty on the date beyond which engine
certification would be mandatory for HD SI engines.
However, in response to persuasive comments from a chassis
manufacturer that purchases these engines, we are adopting a narrow
extension of this interim flexibility, where for MYs 2021-2023, each SI
engine manufacturer may sell an annual maximum of 10,000 SI engines
certified under this provision.\455\ We believe this three-year
extension is needed to prevent market disruptions. We are concerned
that SI engine manufacturers might not choose to certify any SI engines
that can be sold to other vocational chassis manufacturers, which would
significantly disrupt the market. With this limited extension, we are
ensuring no loss of environmental benefits because any vehicle
certified by a chassis manufacturer who obtains a high-emitting SI
engine must apply additional technology as needed to meet the
applicable vocational vehicle standard. We are generally not allowing
custom chassis manufacturers to use SI engines that have been certified
under this loose engine provision, if they are certifying using one of
the custom chassis regulatory subcategories. However, manufacturers
certifying motor homes or emergency vehicles to the optional standards
may install engines certified through the interim loose engine
provision. The typical annual miles driven by these vehicles is very
low, usually between 2,000 and 5,000 miles for either motor homes or
emergency vehicles, and thus their contribution to emissions and fuel
consumption is very small. See Section II of this Preamble for a
discussion of
[[Page 73729]]
the comments received and the agencies' response on the separate engine
standard for SI engines intended for vocational vehicles.
---------------------------------------------------------------------------
\455\ Meeting with Isuzu dated April 22, 2016.
---------------------------------------------------------------------------
(f) On-Board Diagnostics for Hybrid Vehicle Systems
In HD Phase 1, EPA adopted provisions to delay the onboard
diagnostics (OBD) requirements for heavy-duty hybrid powertrains (see
40 CFR 86.010-18(q)). This provision delayed full OBD requirements for
hybrids until MY 2016 and MY 2017. The agencies have received comments
from hybrid manufacturers regarding their progress toward meeting the
on-board diagnostic requirements for criteria pollutant engine
certification related to hybrid systems. See Section XIII.A.1 for a
discussion of comments received and EPA's response related to
certification of engines paired with hybrid powertrain systems.
VI. Heavy-Duty Pickups and Vans
In the NPRM, the agencies conducted coordinated and complementary
analyses using two analytical methods for the heavy-duty pickup and van
segment, both of which used the same version of NHTSA's CAFE model to
analyze technology. The agencies have also used two analytical methods
for the joint final rule. However, unlike the NPRM, for the joint final
rule, the agencies are using different versions of NHTSA's CAFE model
to analyze technology. The Method B approach continues to use the same
version of the model and inputs that was used for the NPRM. Method A
uses an updated version of the CAFE model and some updated inputs.
A. Summary of Phase 1 HD Pickup and Van Standards
In the Phase 1 rule, EPA and NHTSA established GHG and fuel
consumption standards and a program structure for complete Class 2b and
3 heavy-duty vehicles (referred to in these rules as ``HD pickups and
vans''), as described below. The Phase 1 standards began to be phased-
in in MY 2014 and the agencies believe the program is working well. The
agencies are retaining most elements from the structure of the program
established in the Phase 1 rule for the Phase 2 program while
establishing more stringent Phase 2 standards for MY 2027, phased in
over MYs 2021-2027, that will require additional GHG reductions and
fuel consumption improvements. As discussed below, the agencies are
adopting the Phase 2 standards as proposed. The MY 2027 standards will
remain in place unless and until amended by the agencies.
Heavy-duty vehicles with GVWR between 8,501 and 10,000 lbs. are
classified in the industry as Class 2b motor vehicles. Class 2b
includes vehicles classified as medium-duty passenger vehicles (MDPVs)
such as very large SUVs. Because MDPVs are frequently used like light-
duty passenger vehicles, they are regulated by the agencies under the
light-duty vehicle rules. Thus, the agencies did not adopt additional
requirements for MDPVs in the Phase 1 rule and are not adopting
additional requirements for MDPVs in this rulemaking. Heavy-duty
vehicles with GVWR between 10,001 and 14,000 lbs are classified as
Class 3 motor vehicles. Class 2b and Class 3 heavy-duty vehicles
together emit about 23 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. Most of these vehicles are produced by companies with major light-
duty markets in the United States, primarily Ford, General Motors, and
Fiat Chrysler. Often, the technologies available to reduce fuel
consumption and GHG emissions from this segment are similar to the
technologies used for the same purpose on light-duty pickup trucks and
vans, including both engine efficiency improvements (for gasoline and
diesel engines) and vehicle efficiency improvements.
In the Phase 1 rule, EPA adopted GHG standards for HD pickups and
vans based on the whole vehicle (including the engine), expressed as
grams of CO2 per mile, consistent with the way these
vehicles are regulated by EPA today for criteria pollutants. NHTSA
adopted corresponding gallons per 100 mile fuel consumption standards
that are likewise based on the whole vehicle. This complete vehicle
approach adopted by both agencies for HD pickups and vans was
consistent with the recommendations of the NAS Committee in its 2010
Report. EPA and NHTSA adopted a structure for the Phase 1 HD pickup and
van standards that in many respects paralleled long-standing NHTSA CAFE
standards and more recent coordinated EPA GHG standards for
manufacturers' fleets of new light-duty vehicles. 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
for both the HD and light-duty vehicle programs is 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).\456\
---------------------------------------------------------------------------
\456\ 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 \457\ 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).\458\ 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. EISA requires that NHTSA study
``the appropriate metric for measuring and expressing commercial
medium- and heavy-duty vehicle and work truck fuel efficiency
performance, taking into consideration, among other things, the work
performed by such on-highway vehicles and work trucks . . .'' See 49
U.S.C. 32902(k)(1)(B).\459\ For HD pickups and vans, the agencies also
set standards based on a vehicle attribute, but used a work-based
metric as the attribute rather than the footprint attribute utilized in
the light-duty vehicle 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 HD pickup or van. EPA and NHTSA therefore
finalized Phase 1 standards for HD pickups and vans based on a ``work
factor'' attribute that combines the vehicle's payload and towing
capabilities, with an added adjustment
[[Page 73730]]
for 4-wheel drive vehicles. See generally 76 FR 57161-57162.
---------------------------------------------------------------------------
\457\ Light duty fuel economy standards are expressed as miles
per gallon (mpg), which is inverse to the HD fuel consumption
standards which are expressed as gallons per 100 miles.
\458\ EISA requires CAFE standards for passenger cars and light
trucks to be attribute-based; See 49 U.S.C. 32902(b)(3)(A).
\459\ The NAS 2010 report likewise recommended standards
recognizing the work function of HD vehicles. See 76 FR 57161.
---------------------------------------------------------------------------
For Phase 1, the agencies adopted provisions such that each
manufacturer's fleet average standard is 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). The Phase 1 curves are shown in
the figures below for reference and are described in detail in the
Phase 1 final rule.\460\ The agencies established separate curves for
diesel and gasoline HD pickups and vans. The agencies will continue to
use the work-based attribute and gradually declining standards approach
for the Phase 2 standards, as discussed in Section VI.B. below. Note
that this approach does not create an incentive to reduce the
capabilities of these vehicles because less capable vehicles are
required to have proportionally lower emissions and fuel consumption
targets.
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\460\ The Phase 1 Final Rule provides a full discussion of the
standard curves including the equations and coefficients. See 76 FR
57162-57165, September 15 2011. The standards were previously
provided in the regulations at 40 CFR 1037.104, but they are now
being redesignated as 40 CFR 86.1819-14.
\461\ 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 the Phase 1 Preamble Section
II.C.(d)(ii).
[GRAPHIC] [TIFF OMITTED] TR25OC16.010
[[Page 73731]]
[GRAPHIC] [TIFF OMITTED] TR25OC16.011
EPA phased in its 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 the set of target standard
curves shown above, with increasing stringency in each model year. The
final EPA Phase 1 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 MY 2010 baseline.
EPA also finalized 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's Phase 1 program allows 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. This
option is consistent with EISA requirements that NHTSA provide 4 years
lead-time and 3 years of stability for standards. See 49 U.S.C.
32902(k)(3). The second alternative uses target curves that are
equivalent to EPA's 40-60-100 percent target curves in model years
2016-2017-2018, respectively. This option is also consistent with EISA
lead-time and stability requirements. Stringency for the alternatives
in Phase 1 was selected by the agencies to allow a manufacturer,
through the use of the credit carry-forward and carry-back provisions
that the agencies also finalized, to meet both NHTSA fuel efficiency
and EPA GHG emission standards using a single compliance strategy. If a
manufacturer cannot meet an applicable standard in a given model year,
it may make up its shortfall by over-complying in a subsequent year.
NHTSA also allows 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 Phase 1 phase-in options are summarized in Table VI-
1.
Table VI-1--Phase 1 Standards Phase-In Options
--------------------------------------------------------------------------------------------------------------------------------------------------------
2014 % 2015 % 2016 % 2017 % 2018 % 2019 %
--------------------------------------------------------------------------------------------------------------------------------------------------------
EPA Primary Phase-in.................................... 15 20 40 60 100 100
EPA Compliance Option................................... 15 20 67 67 67 100
[[Page 73732]]
NHTSA First Option...................................... 0 0 67 67 67 100
NHTSA Second Option..................................... 0 0 40 60 100 100
--------------------------------------------------------------------------------------------------------------------------------------------------------
The form and stringency of the Phase 1 standards curves are based
on the performance of a set of vehicle, engine, and transmission
technologies expected (although not required) to be used to meet the
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)
B. HD Pickup and Van Final Phase 2 Standards
As described in this section, NHTSA and EPA are adopting as
proposed Phase 2 standards that will be phased in over model years
2021-2027 and continue thereafter unless and until amended. These
standards are identical to those proposed as Alternative 3 (the
preferred alternative at proposal). The agencies are adopting standards
based on a year-over-year increase in stringency of 2.5 percent over
MYs 2021-2027 for a total increase in stringency for the Phase 2
program of about 16 percent compared to the MY 2018 Phase 1 standard.
Note that an individual manufacturer's fleet-wide target may differ
from this stringency increase due to changes in vehicle sales mix and
changes in work factor. We believe the standards the agencies are
adopting are feasible in the time frame of this rule.
As discussed in detail below in Sections C through F, the agencies
performed separate analyses, which we refer to as ``Method A'' and
``Method B.'' NHTSA considered Method A as the central analysis in its
determination of the stringency of the Phase 2 standards. EPA
considered the results of Method B as the central analysis for its
determination of the stringency of the Phase 2 standards. These
analyses are complementary, and independently support the same
conclusion.
In the proposal, the agencies also sought comment on a number of
alternatives, including an alternative (`Alternative 4') which would
have resulted in approximately the same stringency increase, but would
have done so two years earlier (in MY 2025 rather than MY 2027), so
that the effective year-over-year stringency would have been 3.5%. The
agencies are not adopting this alternative. The agencies' analyses show
that the additional lead-time provided by the Phase 2 standards that
the agencies are adopting will allow manufacturers to more fully
utilize lower cost technologies over vehicle life-cycles. In addition,
under the method B analysis, this would reduce the projected adoption
rate of more advanced higher cost technologies such as strong hybrids
compared to Alternative 4. As discussed in more detail in E.1 below,
both of the considered phase-ins are projected to require comparable
penetration rates of several non-hybrid technologies with some
approaching 100 percent penetration. However, as discussed below, the
additional lead-time provided by the final standards will allow
manufacturers more flexibility to implement technologies at later
redesigns and refreshes. The agencies received several comments
regarding the timing and stringency of the standards. These comments
are discussed in detail in Section E.1 below and in Chapter 7 of the
Response to Comments document.
When considering potential Phase 2 standards, the agencies
anticipate that the technologies listed above that were considered in
Phase 1 will continue to be available in the future, if not already
applied under Phase 1 standards, and that additional technologies will
also be available:
advanced engine improvements for friction reduction and low
friction lubricants
improved engine parasitics, including fuel pumps, oil pumps,
and coolant pumps
valvetrain variable lift and timing
cylinder deactivation
direct gasoline injection
cooled exhaust gas recirculation
turbo downsizing of gasoline engines
Diesel engine efficiency improvements
downsizing of diesel engines
8-speed automatic transmissions
electric power steering
high efficiency transmission gear boxes and driveline
further improvements in accessory loads
additional improvements in aerodynamics and tire rolling
resistance
low drag brakes
mass reduction
mild hybridization
strong hybridization
Sections VI.C below and Section 2 of the RIA provide a detailed
analysis of these and other potential technologies for Phase 2,
including their feasibility, costs, and effectiveness and projected
application rates for reducing fuel consumption and CO2
emissions when utilized in HD pickups and vans. Sections VI.D and
Section X also discuss the selection of the Phase 2 standards and the
alternatives considered.
In addition to EPA's CO2 emission standards and NHTSA's
fuel consumption standards for HD pickups and vans, EPA in Phase 1 also
finalized standards for two additional GHGs--N2O and
CH4, as well as standards for air conditioning-related HFC
emissions. EPA will continue these standards in Phase 2. Also,
consistent with CAA section 202(a)(1), EPA finalized Phase 1 standards
that apply to HD pickups and vans in use and EPA is likewise adopting
in-use standards for these vehicles in Phase 2. All of these standards
are discussed in more detail below. Program flexibilities and
compliance provisions related to the standards for HD pickups and vans
are discussed in Section VI.E.
A relatively small number of HD pickups and vans are sold by
vehicle manufacturers as incomplete vehicles, without the primary load-
carrying device or container attached. A sizeable
[[Page 73733]]
subset of these incomplete vehicles, often called cab-chassis vehicles,
are sold by the vehicle manufacturers in configurations with complete
cabs plus 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. The Phase 1 program includes provisions that allow
manufacturers to include these incomplete vehicles, as well as some
Class 4 through 6 vehicles, to be regulated under the chassis-based HD
pickup and van program (i.e. subject to the standards and chassis
certification for HD pickups and vans), rather than under the
vocational vehicle program.\462\ The agencies are continuing to allow
such incomplete vehicles the option of certifying under either the
heavy duty pickup and van standards or the standards for vocational
vehicles. As in Phase 1, if such an incomplete vehicle is certified as
a vocational vehicle, the engine would have to be certified separately
to the applicable engine standard.
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\462\ See 76 FR 57259-57260, September 15, 2011 and 78 FR 36374,
June 17, 2013.
---------------------------------------------------------------------------
Phase 1 also includes optional compliance paths for spark-ignition
engines identical to engines used in heavy-duty pickups and vans to
comply with 2b/3 standards. See 40 CFR 1037.150(m) and 49 CFR
535.5(a)(7). Manufacturers sell such engines as ``loose engines'' or
install these engines in incomplete vehicles that are not cab-complete
vehicles. The agencies are providing a temporary loose engine provision
for Phase 2 as described in Section V.D.3.e, under Compliance
Flexibility Provisions. These program elements are discussed above in
Section V.D. on vocational vehicles and XIII.A.2 on engines.
(1) Vehicle-Based Standards
For Phase 1, EPA and NHTSA chose to set vehicle-based standards
whereby the entire vehicle is chassis-tested. The agencies will retain
this approach for Phase 2. 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 complete HD pickups and vans are
covered by CAA vehicle emissions standards for criteria pollutants
(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 engines covered by CAA engine
emission standards for criteria pollutants, expressed in grams per
brake horsepower-hour. As a result, Class 2b and 3 complete vehicles
share both substantive elements and a regulatory structure much more in
common with light-duty trucks than with the other heavy-duty vehicles.
Three of these features in common 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 Fiat 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 criteria pollutant and GHG 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 a single manufacturer is generally responsible for both engine and
vehicle design. All of these factors together suggest that it is still
appropriate and reasonable to base standards on performance of 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. The chassis-based standards approach for
complete vehicles is also consistent with NAS \463\ recommendations and
there was consensus in the public comments in the Phase 1 rulemaking
supporting this approach. For all of these reasons, the agencies
proposed to continue this approach, and there was again supporting
consensus in the public comments.
---------------------------------------------------------------------------
\463\ The NAS 2010 report. See 76 FR 57161.
---------------------------------------------------------------------------
(a) Work-Based Attributes
In developing the Phase 1 HD rulemaking, the agencies emphasized
creating a program structure that achieves reductions in fuel
consumption and GHGs based on how vehicles are used and on the work
they perform in the real world. 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 the 2b and 3 categories have a
wide range of payload and towing capacities. These work-based
differences in design and in-use operation are 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 and the Phase 1 standards is conducted with the vehicle
loaded to half of its payload capacity (rather than to a flat 300 lbs.
as in the light-duty program), and the correlation between test weight
and fuel use is strong.
Towing, on the other hand, does not directly factor into test
weight as nothing is towed during the test. Hence, setting aside any
interdependence between towing capacity and payload, only the higher
curb weight caused by any heavier truck components plays 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
vehicle 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.
For these reasons, as noted above, EPA and NHTSA set Phase 1
standards for HD pickups and vans based on a ``work factor'' attribute
that combines vehicle payload capacity and vehicle towing capacity, in
lbs., with an additional fixed adjustment for four-wheel drive (4wd)
vehicles. This adjustment accounts for the fact that 4wd, critical to
enabling many off-road heavy-duty work applications, adds roughly 500
lbs. to the vehicle weight. The work factor is calculated as follows:
75 percent maximum payload + 25 percent of maximum towing + 375 lbs. if
4wd. Under this approach, target GHG and fuel consumption standards are
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. There was widespread support (and no opposition)
for the work factor-based approach to standards and fleet average
approach to compliance expressed in
[[Page 73734]]
the comments we received on the Phase 1 rule.
For Phase 2, the agencies proposed to continue using the work-based
attribute. The agencies received a variety of comments on the details
of the work factor approach. The agencies received comments from The
American Council for an Energy-Efficient Economy (ACEEE) regarding the
definition of payload and towing and manufacturer's discretion at
determining GVWR, GCWR and curb weight of the vehicle. In response, the
formula for payload, GVWR minus curb weight, is specified such that it
uses the same definition of the input terms as those which have always
been used by the agencies for light and heavy duty vehicle regulations,
including criteria pollutant emission standards and safety related
designations. The agencies feel that there is no ambiguity in the
definition of these terms and therefore that payload calculation
remains clearly defined with little or no opportunity for manipulation.
The agencies have successfully used the previously established
definitions of GVWR and curb weight to implement emissions and safety
related programs and have not experienced any adverse issues in
applying these definitions. The same is true for the definitions of
terms used to calculate towing--GCWR minus GVWR. While this definition
for towing capacity does not match the method used by manufacturers in
their consumer advertising, the agencies determined that the inputs of
GCWR and GVWR are clearly defined in our regulations and used for many
other emission and safety related determinations and therefore also
remain a clear and consistent method to define towing for the purposes
of calculating work factor. Again, the agencies have successfully used
the previously established definitions of GCWR and have not experienced
any issues that would warrant a change to the definition or use of
these parameters.
ACEEE commented on recent announcements from two manufacturers that
reported increases in payload capacity in their pick-ups due to a
decrease in the curb weight of the vehicles from changes to light-
weight materials. A reduction in vehicle weight while maintaining the
same GVWR will result in a higher payload capacity which will then
increase that vehicle's calculated work factor and therefore result in
a higher (less stringent) target GHG and fuel consumption standard.
Similar to the light-duty (LD) footprint based approach which allows
increases in GHG emissions and fuel consumption with increasing
footprints, the work factor is designed to allow increases in GHG
emissions and fuel consumption with increases in capability to do work,
primarily hauling payload and towing. Decreases in curb weight as
described in the comment actually demonstrate that the work factor is
operating both appropriately and as the agencies intended. By reducing
curb weight, these manufacturers are increasing the work capability of
their trucks specifically purchased by consumers to transport payload
and (sometimes) to tow. Additional payload capacity, while not always
needed, will allow the user to transport more goods resulting in an
overall reduction in GHGs and fuel used versus taking additional trips
to do the same work. This may differ from light-duty pick-ups where
transportation of goods may not be the primary use of the vehicle.
Additionally, the reduction in curb weight will be beneficial in all
other situations of unloaded and partially loaded transport of goods
because a reduction in curb weight of the vehicle results in less
energy wasted simply to move the vehicle regardless of payload. For
this reason, the agencies included mass reduction as among the
technologies on which the stringency of the final standards (as well as
the phase 1 standards) is based. Mass reduction is discussed in detail
in the technology descriptions section below.
Most of the comments supported the continued use of work factor-
based standards for heavy duty pickups and vans. The agencies received
several comments regarding surplus towing. The American Automotive
Policy Council (AAPC) commented that existing NHTSA Federal Motor
Vehicle Safety Standards effectively cap the towing and GCWR in this
vehicle segment. Cummins noted that the curves were data-based in Phase
1 and any changes to the curves would require a full study, similar to
Phase 1, in order to ensure feasibility and a fair framework for all
OEMs. Daimler commented in support of changing weighting of payload to
80 percent and towing to 20 percent of work factor formula and did not
oppose a cap on towing. Several commenters supported adopting a
mechanism to minimize the incentive the standards provide to increase
work factor. ACEEE supported further considering changing the shape of
the standards curves, shown below in Figure VI-3 and Figure VI-4, to be
flatter at higher work factors. Honeywell commented that towing
capacity has increased significantly over the last five years, beyond
the needs of most buyers, and that the curves should be flattened
starting at 7,500 lbs, noting that this change would impact less that
10 percent of all class 2b/3 vehicles. The International Council on
Clean Transportation (ICCT) similarly suggested a cut point of 5,500
lbs. for gasoline trucks and 8,000 lbs. for diesels, based on these
cutpoints being near the 90th percentile for the model year 2014 fleet.
The Union of Concerned Scientists (UCS) (like ACEEE) commented that
light-weighting is being used to increase payload and also supported
leveling off the curves to eliminate the incentive to add payload and
towing capacity.
After considering these comments, the agencies concluded that the
work factor approach established in the Phase 1 rule appropriately
accounts for the different utility aspects of heavy-duty vehicles.
While trucks and vans may be used differently depending on the required
job, the three main attributes of payload, towing and four wheel drive
remain properly accounted for at this time in the work factor equation
at the current weightings. While a small portion of the fleet may be
considered to have excess towing capacity relative to the actual
required towing capacity by the customer, the agencies determined that
the work factor design does not necessarily result in an incentive for
manufacturers to build excessive towing into the vehicle design. Towing
capacity increases require improvements to vehicle powertrains, cooling
and brakes, generally at the expense of payload, and therefore the work
factor reasonably balances an increase in towing with a reduction in
payload. Additionally, increases in vehicle weight for additional
towing capacity may result in an increase in the emission test weight,
further penalizing unnecessary towing capacity. Moreover, as AAPC
discusses in their comments, towing and payload are effectively already
capped by existing NHTSA safety requirements in this segment. Consumers
will ultimately decide on the appropriate balance of payload and towing
for their applications, and the agencies therefore believe that
establishing a work factor cap for the small percentage of vehicles
with the highest towing capabilities is not necessary and will not
result in emission increases or fuel consumption reductions under the
high towing conditions for which those vehicles were purchased.
The agencies also received comments regarding making changes to the
work factor formula for vans. AAPC commented that the payload, towing,
and 4wd inputs do not fully represent the intended uses of cargo and
passenger vans, where cargo or
[[Page 73735]]
passenger volumes are of primary importance. AAPC recommended that the
agencies add a volumetric term to the work factor for vans with high
(208 cubic feet or greater) cargo and passenger volumes. Vans with high
volumes would have higher work factors and therefore less stringent
targets with the AAPC recommended formula compared to the current
formula. ACEEE commented that the work factor is a far better predictor
of fuel efficiency for pickups than for vans and offered general
support for adopting different work factor formulas for pickups and
vans.
While it is likely that a portion of the vans are used exclusively
for cargo volume and that towing is not an important attribute for
these vans, the commenter failed to provide sufficient new information
to support a new work factor metric specifically to address cargo
focused vans. The commenter's suggested modification does not
sufficiently represent the different van cargo volumes available to
consumers today. A cargo volume based modification requires a complete
industry van analysis of all available van cargo volumes and GHG and
fuel economy performance levels from which an appropriately normalized
adjustment would be determined, consistent with the approach used to
establish the existing work factor equation for the attributes of
payload, towing and four wheel drive. The agencies did not receive the
level of detailed information required to determine the impact of cargo
volume and establish a work factor correlation. Accordingly, the
agencies are not incorporating the suggested change to the work factor
for vans.
As noted in the Phase 1 rule, the attribute-based CO2
and fuel consumption standards are meant to be as consistent as
practicable 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 continue to 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.
(b) Standards
The agencies are adopting Phase 2 standards as proposed based on
analyses performed to determine the appropriate HD pickup and van Phase
2 standards and the most appropriate phase in of those standards. These
analyses, described below and in the Final RIA, considered:
projections of future U.S. sales for HD pickups and vans
the estimates of corresponding CO2 emissions and
fuel consumption for these vehicles
forecasts of manufacturers' product redesign schedules
the technology available in new MY 2014 HD pickups and vans to
specify preexisting technology content to be included in the analysis
fleet (the fleet of vehicles used as a starting point for analysis)
extending through MY 2030
the estimated effectiveness, cost, applicability, and
availability of technologies for HD pickup and vans
manufacturers' ability to use credit carry-forward
the levels of technology that are projected to be added to the
analysis fleet through MY 2030 \464\ considering improvements needed in
order to achieve compliance with the Phase 1 standards (thus defining
the reference fleet--i.e., under the No-Action Alternative--relative to
which to measure incremental impacts of Phase 2 standards), and
---------------------------------------------------------------------------
\464\ Although the final standards are implemented in MY 2027,
the model looks out to MY 2030 to help account for the potential use
of credit carry-forward provisions.
---------------------------------------------------------------------------
the levels of technology that are projected to be added to the
analysis fleet through MY 2030 considering further improvements needed
in order to achieve compliance with standards defining each regulatory
(action) alternative for Phase 2.
Based on this analysis, EPA is adopting as proposed CO2
attribute-based target standards shown in Figure VI-3 and Figure VI-4,
and NHTSA is adopting as proposed the equivalent attribute-based fuel
consumption target standards, also shown in Figure VI-3 and Figure VI-
4, applicable in model year 2021-2027. As shown in these figures, the
Phase 2 standards will be phased in year-by-year commencing in MY 2021.
The agencies did not propose and are not adopting changes to the
standards for 2018-2020 and therefore the standards will remain at the
MY 2018 Phase 1 levels for MYs 2019 and 2020. EISA requires four years
of lead-time and three years stability for NHTSA standards and this
period of lead-time and stability for 2018-2020 is thus consistent with
the EISA requirements. For MYs 2021-2027, the agencies are finalizing
as proposed annual reductions (i.e., increases in stringency) in the
standards. These standards become 16 percent more stringent overall
between MY 2020 and MY 2027, compared to the MY 2018 Phase 1 levels.
This approach to the Phase 2 standards as a whole can be considered a
phase-in or implementation schedule of the MY 2027 standards (which, as
noted, will apply thereafter unless and until amended).
For EPA, Section 202(a) (1) provides the Administrator with the
authority to establish standards, and to revise those standards ``from
time to time,'' thus providing the Administrator with considerable
discretion in deciding when to revise the Phase 1 MY 2018 standards. As
noted above, EISA requires that NHTSA provide four full model years of
regulatory lead time and three full model years of regulatory stability
for its fuel economy standards. See 49 U.S.C. 32902(k)(3).
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.\465\ 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 predetermined stringency
increases.''
---------------------------------------------------------------------------
\465\ In contrast, light-duty standards must remain in place for
``at least 1, but not more than 5, model years.'' 49 U.S.C.
32902(b)(3)(B).
---------------------------------------------------------------------------
Consistent with these authorities, the agencies are adopting more
stringent standards beginning with MY 2021, and ending with MY 2027,
that consider the level of technology we judge can be applied to new
vehicles at reasonable cost to meet the standards. EPA believes the
Phase 2 standards are consistent with CAA requirements regarding lead-
time, cost, feasibility, and safety. NHTSA believes the Phase 2
standards are the maximum feasible under EISA. Manufacturers in the HD
pickup and van market segment have relatively few vehicle lines and
redesign cycles are typically longer compared to light-duty vehicles.
Also, the timing of vehicle
[[Page 73736]]
redesigns differs among manufacturers. To provide lead time needed to
accommodate these longer redesign cycles, the Phase 2 GHG standards
will not reach their highest stringency until 2027. Although these
standards will become more stringent each year between MYs 2021 and
2027, the agencies expect manufacturers will likely make improvements
as part of planned redesigns, such that some model years will likely
involve significant advances, while other model years will likely
involve little change. The agencies also expect manufacturers to use
program flexibilities (e.g., credit carry-forward provisions and
averaging and banking provisions) to help achieve compliance without
compressing redesign schedules and to efficiently manage resources and
capital over time. The MY 2018 standards are unchanged in MYs 2019-2020
to provide necessary lead time for the Phase 2 standards. However, some
manufacturers may choose to begin implementing technologies earlier (in
some cases potentially as soon as MY 2017) depending on their vehicle
redesign cycles. Although standards are not changing in MYs 2019-2020,
manufacturers may introduce additional technologies in order to earn
credits that may be carried-forward under the 5 year credit carry-
forward provisions established in Phase 1 and continuing for Phase 2.
The agencies received several comments on the Phase 2 standards and
the technological basis and feasibility of the standards. The comments
are discussed in Sections VI.D and 0below, which provide additional
discussion of vehicle redesign cycles and the feasibility of the final
Phase 2 standards, and also in Section 7 of the Response to Comments
document.
Recognizing that it is unlikely that there is a phase-in approach
that equally fits with all manufacturers' unique product redesign
schedules, the agencies requested comments on other ways the Phase 2
standards could be phased in. The agencies suggested one alternative
approach would be to phase in the standards in a few step changes, for
example in MYs 2021, 2024 and 2027 (as with the standards for
vocational vehicles, tractors, trailers, and the heavy duty engine
standards). Under this example, if the step changes on the order of 5
percent, 10 percent, and 16 percent improvements from the MY 2020
baseline in MYs 2021, 2024 and 2027 respectively, the program would
provide CO2 reductions and fuel improvements roughly
equivalent to the approach being adopted. EPA did not receive comments
on this alternative phase-in approach, which closely resembles the
phase-in approach used for the other sectors.
AAPC commented in support of an alternative year-over-year phase-in
that would phase-in stringency more gradually than proposed (and now
adopted). AAPC recommended that rather than a 2.5 percent per year
improvement, the increase should be at 1.75 percent per year through MY
2024 and then 3.5 percent per year for MY 2025 through 2027 with the MY
2027 level of stringency equally the proposed level. AAPC commented
that this more gradual approach was consistent with the Phase 1 phase-
in approach and would help manufacturers manage the long lead time
associated with developing the new vehicles and powertrains that will
be required in order to comply with the Phase 2 proposal.
The agencies are finalizing the proposed phase-in rather than
adopting the approach recommended by AAPC. The more gradual phase-in
recommended by AAPC would result in a loss of program benefits in each
of the interim years of the program compared to the promulgated
standards until the phase-in caught up with that phase-in in MY 2027.
Because of the slower phase-in, the overall reduction in each interim
year is lower than the phase-in being finalized. The phase-in adopted
for Phase 1 with a more gradual ramp-up in standards took into
consideration the shorter lead time associated with the Phase 1
standards and the uncertainty associated with implementing a new
program. Phase 2 provides more lead-time than Phase 1 and the agencies
believe based on their analyses of the standards that the lead-time
provided is sufficient, particularly considering the flexibility also
provided by credit carry-forward and carry-back provisions.
As with Phase 1 (and like the light-duty vehicle standards), the
Phase 2 standards must be met on a production-weighted fleet average
basis. No individual vehicle will have to meet a particular target (or
the individual fleet average level). Each manufacturer will also have
its own fleet average standard. Specifically, each manufacturer will
have its own unique fleet average requirement based on the production-
weighted average of the heavy duty pickups and vans it chooses to
produce. Moreover, averaging, banking, and trading provisions, just
alluded to and discussed further below, will provide significant
additional compliance flexibility in implementing the standards. It is
important to note, however, that while the standards will differ
numerically from manufacturer to manufacturer, effective stringency
should be essentially the same for each manufacturer. The agencies did
not receive comments suggesting changes to this general averaging
approach to establishing the standards.
Also, as with the Phase 1 standards, the agencies proposed and are
finalizing separate Phase 2 targets for gasoline-fueled (and any other
Otto-cycle) vehicles and diesel-fueled (and any other diesel-cycle)
vehicles. See 80 FR 40337. 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. The stringency increase discussed
above for Phase 2 applies equally to the separate gasoline and diesel
targets. For the proposal, the agencies considered different rates of
increase for the gasoline and diesel targets in order to more equally
balance compliance burdens across manufacturers with varying gasoline/
diesel fleet mixes. However, at least among major HD pickup and van
manufacturers, our analyses suggested limited potential for such
optimization, especially considering uncertainties involved with
manufacturers' future fleet mix. The agencies did not receive comments
on the specific topic of maintaining equivalent rates of increase for
gasoline and diesel-fueled vehicles. The agencies, however, received
several comments regarding maintaining separate standards for the two
vehicle types. Some of the comments recommended closing the gap between
diesel and gasoline-fueled vehicles by making the gasoline-fueled
vehicle standards more stringent. These comments are discussed below.
[[Page 73737]]
[GRAPHIC] [TIFF OMITTED] TR25OC16.012
Described mathematically, EPA's and NHTSA's target standards are
defined by the following formulas:
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 lbs. if the vehicle is equipped with 4wd, otherwise equals
0 lbs.
Towing Capacity = GCWR (lb.) - GVWR (lb.)
Coefficients a, b, c, and d are taken from TableVI-2.
[[Page 73738]]
TableVI-2--Phase 2 Coefficients for HD Pickup and Van Target Standards
----------------------------------------------------------------------------------------------------------------
Model year a b c d
----------------------------------------------------------------------------------------------------------------
Diesel Vehicles
----------------------------------------------------------------------------------------------------------------
2018-2020 \ a\.................................. 0.0416 320 0.0004086 3.143
2021............................................ 0.0406 312 0.0003988 3.065
2022............................................ 0.0395 304 0.0003880 2.986
2023............................................ 0.0386 297 0.0003792 2.917
2024............................................ 0.0376 289 0.0003694 2.839
2025............................................ 0.0367 282 0.0003605 2.770
2026............................................ 0.0357 275 0.0003507 2.701
2027 and later.................................. 0.0348 268 0.0003418 2.633
----------------------------------------------------------------------------------------------------------------
Gasoline Vehicles
----------------------------------------------------------------------------------------------------------------
2018-2020 \ a\.................................. 0.044 339 0.0004951 3.815
2021............................................ 0.0429 331 0.0004827 3.725
2022............................................ 0.0418 322 0.0004703 3.623
2023............................................ 0.0408 314 0.0004591 3.533
2024............................................ 0.0398 306 0.0004478 3.443
2025............................................ 0.0388 299 0.0004366 3.364
2026............................................ 0.0378 291 0.0004253 3.274
2027 and later.................................. 0.0369 284 0.0004152 3.196
----------------------------------------------------------------------------------------------------------------
Note:
\a\ Phase 1 primary phase-in coefficients. Alternative phase-in coefficients are different in MY 2018 only.
As noted above, the agencies did not propose and are not adopting
changes from the final Phase 1 standards for MYs 2018-2020. The MYs
2018-2020 standards are shown in the figures and tables above for
reference. The agencies did not receive comments recommending changes
to the standards in these model years.
NHTSA and EPA have also analyzed regulatory alternatives to these
standards, as discussed in Sections VI.D and 0and Section X. below. The
agencies requested comment on all of the alternatives analyzed for the
proposal, but requested comment on Alternative 4 in particular. The
agencies did not propose Alternative 4 because EPA and NHTSA had
outstanding questions regarding relative risks and benefits of
Alternative 4 due to the timeframe envisioned by that alternative. As
noted above, Alternative 4 would have provided less lead time for the
complete phase-in of the Phase 2 standards based on an annual
improvement of 3.5 percent per year in MYs 2021-2025 compared to the
Alternative 3 per year improvement of 2.5 percent in MYs 2021-2027.
In the proposal, the agencies requested comments, data, and
information that would help inform determination of the maximum
feasible (for NHTSA) and appropriate (for EPA) stringency for HD
pickups and vans and are particularly interested in information and
data related to the expected adoption rates of different emerging
technologies, such as mild and strong hybridization. The agencies
received comments both in support of and not in support of Alternative
4 and also received comments in support of standards more stringent
than either the proposal or the Alternative 4 pull ahead. The comments
regarding stringency and feasibility are discussed in Sections VI.D and
E. As described in these sections, and in Section X and RIA Chapter 11,
NHTSA and EPA believe the final Phase 2 standards represent,
respectively, the maximum feasible standards under EISA and the most
stringent standards reasonably achievable under the CAA considering
lead-time, reasonable cost, feasibility, and safety.
As with Phase 1 standards, to calculate a manufacturer's HD pickup
and van fleet average standard, the agencies proposed and are
finalizing separate target curves for gasoline and diesel vehicles in
Phase 2. While diesel and gasoline vehicles have separate work factor-
based target standard curves, all of a manufacturer's vehicles are
averaged together as a single averaging set to demonstrate compliance.
As noted above, the agencies' Phase 2 standards are estimated to result
in approximately 16 percent reductions in CO2 and fuel
consumption for both diesel and gasoline vehicles relative to the MY
2018 Phase 1 standards for HD pickup trucks and vans.
The agencies requested comment on both the level of stringency of
the standards and the continued separate targets for gasoline and
diesel HD pickups and vans. AAPC supported the agencies' proposal to
maintain separate targets noting that the approach ensures that
manufacturers of either engine type will implement the latest
CO2 reducing technologies. AAPC further commented that
significant technological and market-based differences exist between
heavy-duty gasoline and heavy-duty diesel engines. According to the
commenter, maintaining separate but comparably stringent spark ignition
and compression ignition targets will allow customers for specific
applications to take advantage of the combustion technology that best
meets their specific application requirements.
Several commenters did not support the proposed approach but
instead supported setting a single fuel-neutral set of targets. Cummins
commented that there is sufficient lead-time and technology to create a
pathway to fuel-neutral targets, and that fuel neutral targets would
eliminate any competitive advantage or preference to a particular GHG/
FE technology and maintain the environmental benefits envisioned for
the program. Daimler, Honeywell, and MEMA similarly commented in
support of fuel-neutral standards. Honeywell and Motor and Equipment
Manufacturers Association (MEMA) suggested basing the standards on a 16
percent improvement from the projected MY 2018 gasoline/diesel combined
baseline. ACEEE and ICCT commented in support of a single set of
standards set at or close to the capabilities of diesel technology.
These commenters suggested that gasoline engines should be subject to
more stringent standards than proposed and that gasoline and diesel
engines should be held to the same performance-based standards.
[[Page 73739]]
Bosch disagreed with maintaining separate targets for gasoline and
diesel HD pickups and vans. Bosch recommended that targets be fuel
neutral, as they are in the light-duty vehicle programs. Bosch
commented that it ``believes that a market shift towards spark-ignited
vehicles and away from HD pickups and vans powered by ``fundamentally
more efficient'' CI engines would be a very real possibility under
Phase 2 if the separate gasoline and diesel targets are finalized as
proposed.'' Bosch continues that ``any such shift would signify not
only a move towards less efficient internal combustion engines, but
would be counterproductive from a programmatic/environmental and energy
standpoint.'' Bosch further commented that ``diesels from a criteria
pollutant (especially NOX emissions perspective, have made
far greater strides over the years than gasoline engines, and for that
reason have incurred greater technological development costs than the
latter. While equivalent CO2 target values may be more
expensive, comparatively speaking, for SI engines to achieve (based on
the agencies' cost analysis), the additional cost imposed on these
engines likely would not rise to the level of, much less overtake CI
engines' historically higher technological development and system
costs.''
The agencies generally prefer to set standards that do not
distinguish between fuel types where technological or market-based
reasons do not strongly argue otherwise. However, as with Phase 1, we
continue to believe that fundamental differences between spark ignition
and compression ignition engines warrant unique fuel standards, which
is also important in ensuring that our program maintains product
choices available to vehicle buyers. In fact, gasoline and diesel fuel
behave so differently in the internal combustion engine that they have
historically required unique test procedures, emission control
technologies and emission standards. These technological differences
between gasoline and diesel engines for GHGs and fuel consumption exist
presently and will continue to exist after Phase 1 and through Phase 2
until advanced research evolves the gasoline fueled engine to diesel-
like efficiencies. This will require significant technological
breakthroughs currently in early stages of research such as homogeneous
charge compression ignition (HCCI) or similar concepts. Because these
technologies are still in the early research stages, we believe the
separate fuel type standards are appropriate in the timeframe of this
rule to assure the availability of both gasoline and diesel engines. We
also project that these separate standards will result in roughly
equivalent redesign burdens for engines of both fuel types as evidenced
by feasibility and cost analysis in RIA Chapter 10. For the same
reasons, the agencies are adopting separate standards for diesel and SI
vocational engines. See Section V. above.
In order to maintain the same overall level of stringency as
proposed for the program, a fuel neutral standard would result in an
increase in stringency for gasoline or spark ignition vehicles with a
matching relaxation of stringency for diesel or compression ignition
vehicles relative to the separate numerical levels established in the
proposal for gasoline and diesel vehicles. Based on the analysis of
available technologies for both types of vehicles, the agencies do not
feel it is appropriate to adopt such a change for either gasoline or
diesel vehicles. This change could lead to an undesirable reduction in
penetration of fuel efficient technologies in diesels, particularly
from manufacturers who produce predominately diesel vehicles, while
requiring a higher penetration of advanced technologies like strong
hybridization in gasoline vehicles, distorting consumer choice.
Additionally, the agencies do not agree with the comment stating that
maintaining separate gasoline and diesel targets of equal increases in
stringency of 2.5 percent per year from the Phase 1 final standards
will result in a shift to less efficient gasoline vehicles. The
agencies determined that manufacturers have similar technology
challenges and corresponding costs regardless of fuel type and
therefore manufacturers do not have an easier or lower cost long term
path to compliance by simply shifting production from one fuel type to
the other.
Note further that a manufacturer's fleet average standard is the
production weighted average of all its targets, both gasoline and
diesel. Thus, there is no separate gasoline vehicle standard, or
separate diesel standard. Commenters may have been confused on this
point (several of the commenters referred to gasoline `standards', or
diesel `standards'). This averaging feature of the standard further
increases incentives to add advanced technologies to either gasoline or
diesel vehicles if manufacturers perceive it advantageous to do so,
since the benefit is experienced fleet wide, not just for the gasoline
or diesel segment of a manufacturer's production line.
The NHTSA fuel consumption target curves and 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, Phase 1
established a provision that EPA is not changing for Phase 2 that
allows manufacturers, if they choose, to use CO2 credits to
help demonstrate compliance with N2O and CH4
emissions standards, by expressing any N2O and
CH4 under compliance in terms of their CO2-
equivalent and applying CO2 credits as needed. 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 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.
(2) What are the HD pickup and van test cycles and procedures?
The Phase 1 program established testing procedures for HD pickups
and vans and NHTSA and EPA are maintaining these testing protocols. The
vehicles will continue to be tested using the same heavy-duty chassis
test procedures currently used by EPA for measuring criteria pollutant
emissions from these vehicles, including the city fuel economy test
cycle (FTP) and the highway fuel economy test cycle (HFET). These test
procedures are used by manufacturers for certification and emissions
compliance demonstrations and by the agencies for compliance
verification and enforcement. While the FTP and the HFET driving
patterns are identical to that of the light-duty test cycles, other
test parameters for running them, such as test vehicle loaded weight,
are specific to complete heavy-duty vehicles. Please see Section II.C
(2) of the Phase 1 Preamble (76 FR 57166) for a discussion of how HD
pickups and vans are tested.
[[Page 73740]]
The test procedures for HD pickups and vans currently specify using
a fuel with properties established under the light-duty (LD) vehicle
Tier 2 program. EPA recently finalized new emission standards under the
Tier 3 program for both LD vehicles and HD pickups and vans which will
begin to phase-in in MY 2017 for LD vehicles and MY 2018 for vehicles
over 6000 pounds GVWR, including HD pickups and vans. As part of the
Tier 3 program, new test procedures for gasoline-fueled vehicles
requiring the use of a new test fuel containing 10 percent ethanol
which is more representative of in-use fuel that the vehicles will
encounter. The agencies are investigating any potential impact of
changes to the fuel properties on GHG emissions and fuel consumption
and have committed to providing appropriate adjustment to the test
procedures if necessary to ensure no change in stringency of the Phase
1 or the Phase 2 standards.
AAPC commented that the current methodology of grouping vehicles by
the Equivalent Test Weight (ETW) in increments of 500 pounds for
determining their GHG and FE performance is too large to capture weight
reductions that may occur within a 500 pound grouping. Under the
current test procedures, vehicles are tested at 500 lb. increments of
inertial weight classes when testing at or above 5500 lbs. test weight.
For example, the commenter stated that all vehicles having a calculated
test weight basis of 11,251 to 11,750 lbs. are tested at 11,500 lbs.
(i.e., the midpoint of the range). However, for some vehicles, the
existence of these bins and the large intervals between bins may reduce
or eliminate the incentive for mass reduction for some vehicles, as a
vehicle may require significant mass reduction before it could switch
from one test weight bin to the next lower bin. For other vehicles,
these bins may unduly reward relatively small reductions of vehicle
mass, as a vehicle's mass may be only slightly greater than that needed
to be assigned a 500-pound lighter inertia weight class. For example,
for a vehicle with a calculated test weight basis of 11,700 lbs., a
manufacturer would receive no regulatory benefit for reducing the
vehicle weight by 400 lbs., because the vehicle would stay within the
same weight bracket.
The agencies believe this (and similar comments) have some merit.
In response, the agencies are finalizing an option allowing
manufacturers to divide vehicle models into finer weight groupings of
vehicles for the different Adjusted Loaded Vehicle Weights (ALVW) for
purposes of more precise calculation of CO2 emissions
performance within the 500 pound increment test weight classes.
Manufacturers will be able to select 50, 100, 250, or 500 weight groups
for reporting emissions. ALVW will vary within a single ETW largely
depending on the varying models curb weights from customer option
selection and other production variations. The calculation of
CO2 emissions performance for the finer groupings is
performed as described in 40 CFR 86.1819-14(g))) for analytically
adjusting CO2 (ADCO2) emissions. The test results
at the existing 500 pound increment ETWs will be used to determine the
CO2 emissions performance level of the new groupings using
the analytically derived equation. This new ADCO2 emissions
level is only used for this new grouping and cannot be used to extend
determination of other ALVW groupings emission performance levels. The
vehicle specific values used to determine the change in ETW in the
ADCO2 emissions calculation to estimate the performance of
the smaller grouping should be consistent with value used to calculate
the single work factor of that same grouping. This change does not
impact the ETW of a group of vehicle models that are contained in the
500 pound increment of ETW when performing testing nor does it
eliminate any vehicle in that grouping from being responsible for
emission performance at the 500 pound increment test weight classes. As
described, this change only allows for more precise CO2
emissions estimation for the potentially different curb weights of
vehicles grouped in a single ETW class for purposes of fleet average
calculation. If a manufacturer chooses to use less than 500 pound
increments, they are required to use this option for all of their HD
vehicles that are chassis certified (including loose engines).
(3) Fleet Average Standards
As proposed, and as noted above, NHTSA and EPA are retaining the
fleet average standards approach finalized in the Phase 1 rule and
structurally similar to light-duty Corporate Average Fuel Economy
(CAFE) and GHG standards. 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, with separate targets for
gasoline and diesel vehicles (which are then combined into a production
weighted average which comprises that manufacturer's fleet average
standard). Each manufacturer will continue to have an average GHG
requirement and an average fuel consumption requirement unique to its
new HD pickup and van fleet in each model year, depending on the
characteristics (payload, towing, and drive type, as well as gasoline
and diesel) 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 and/or
four-wheel drive have individual targets at numerically higher
CO2 and fuel consumption levels than less capable vehicles,
as discussed in Section VI.B.(1). The agencies did not receive comments
suggesting changes to this fundamental approach to the standards.
The fleet average standard with which the manufacturer must comply
will continue to be 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. The assessment of compliance also
must consider the manufacturer's use of carry-forward and carry-back
credit provisions included in the averaging, banking, and trading
program. 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
(initial) 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
parallel program for light-duty vehicles, 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.
[[Page 73741]]
Please see Section II.C.(3)(a) of the Phase 1 Preamble (76 FR 57167)
for further discussion of the fleet average approach for HD pickups and
vans.
(4) 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. EPA
will continue the in-use standards approach for individual vehicles
that EPA finalized for the Phase 1 program. NHTSA did not adopt Phase 1
in-use standards and did not propose in-use standards for Phase 2. For
the EPA program, compliance with the in-use standard for individual
vehicles and vehicle models does not impact compliance with the fleet
average standard, which will be based on the production-weighted
average of the new vehicles. Vehicles that fail to meet their in-use
emission standards will be subject to recall to correct the
noncompliance. NHTSA is finalizing the use of EPA's useful life
requirements to ensure manufacturers consider in the design process the
need for fuel efficiency standards to apply for the same duration and
mileage as EPA standards. NHTSA will limit such penalties to situations
in which it determined that the vehicle or engine manufacturer failed
to comply with the standards.
As with Phase 1, the in-use Phase 2 GHG standards for HD pickups
and vans will be established by adding an adjustment factor to the full
useful life emissions used to calculate the GHG fleet average. Each
model's in-use CO2 standard will be the model-specific level
used in calculating the fleet average, plus 10 percent. No adverse
comments were received on this provision. Please see Section
II.C.(3)(b) of the Phase 1 Preamble (76 FR 57167) for further
discussion of in-use standards for HD pickups and vans. This provision,
along with the continuation of the Phase 1 test procedures, eliminates
that need for the agencies to include any additional compliance margin
in our feasibility analysis.
For Phase 1, EPA aligned the useful life for GHG emissions with the
useful life that was in place for criteria pollutants: 11 years or
120,000 miles, whichever occurs first (40 CFR 86.1805-04(a)). Since the
Phase 1 rule was finalized, EPA updated the useful life for criteria
pollutants as part of the Tier 3 rulemaking.\466\ The new useful life
implemented for Tier 3 is 150,000 miles or 15 years, whichever occurs
first. As proposed, the useful life for GHG emissions and fuel
consumption will also be 150,000 miles/15 years starting in MY 2021
when the Phase 2 standards begin so that the useful life remains
aligned for GHG and criteria pollutant standards long term. The
agencies did not receive adverse comments on this provision.
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\466\ 79 FR 23492, April 28, 2014 and 40 CFR 86.1805-17.
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(5) Other GHG Standards for HD Pickups and Vans
This section addresses greenhouse gases other than CO2.
Note that since these are greenhouse gases not directly related to fuel
consumption, NHTSA does not have equivalent standards.
(a) Nitrous Oxide (N2O) and Methane (CH4)
In the Phase 1 rule, EPA established emission standards for HD
pickups and vans for both nitrous oxide (N2O) and methane
(CH4). Similar to the CO2 standard approach, the
N2O and CH4 emission levels of a vehicle are
based on a composite of the light-duty FTP and HFET cycles with the
same 55 percent city weighting and 45 percent highway weighting. The
N2O and CH4 standards were both set by EPA at
0.05 g/mile. Unlike the CO2 standards, averaging between
vehicles is not allowed. The standards are designed to prevent
increases in N2O and CH4 emissions from current
levels, i.e., a no-backsliding standard. EPA did not propose and is not
adopting any changes the N2O or CH4 standards or
related provisions established in the Phase 1 rule. Please see Phase 1
Preamble Section II.E. (76 FR 57188-57193) for additional discussion of
N2O and CH4 emissions and standards.
Across both current gasoline- and diesel-fueled heavy-duty vehicle
designs, emissions of CH4 and N2O are relatively
low and the intent of the cap standards is to ensure that future
vehicle technologies or fuels do not result in an increase in these
emissions. Given the global warning potential (GWP) of CH4,
the 0.05 g/mile cap standard is equivalent to about 1.7 g/mile
CO2, which is much less than 1 percent of the overall GHG
emissions of most HD pickups and vans.\467\ The effectiveness of
oxidation of CH4 using a three-way or diesel oxidation
catalyst is limited by the activation energy, which tends to be higher
where the number of carbon atoms in the hydrocarbon molecule is low and
thus CH4 is very stable. At this time we are not aware of
any technologies beyond the already present catalyst systems which are
highly effective at oxidizing most hydrocarbon species for gasoline and
diesel fueled engines that would further lower the activation energy
across the catalyst or increase the energy content of the exhaust
(without further increasing fuel consumption and CO2
emissions) to further reduce CH4 emissions at the tailpipe.
The CH4 standard remains an important backstop to prevent
future increases in CH4 emissions. EPA did not receive
adverse comments regarding the proposal to not change the
CH4 standard for HD pickups and vans.
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\467\ N2O has a GWP of 298 and CH4 has a
GWP of 34 according to the IPCC AR5.
---------------------------------------------------------------------------
N2O is emitted from gasoline and diesel vehicles mainly
during specific catalyst temperature conditions conducive to
N2O formation. The 0.05 g/mile standard, which translates to
a CO2-equivalent value of 14.9 g/mile, ensures that systems
are not designed in a way that emphasizes efficient NOX
control while allowing the formation of significant quantities of
N2O. The Phase 1 N2O standard of 0.05 g/mile for
pickups and vans was finalized knowing that it is more stringent than
the Phase 1 N2O engine standard of 0.10 g/hp-hr, which is
being continued for Phase 2, as discussed in Section II.D.3. EPA
continues to believe that the 0.05 g/mile standard provides the
necessary assurance that N2O will not significantly
increase, given the mix of gasoline and diesel fueled engines in this
market and the upcoming implementation of the light-duty and heavy-duty
(up to 14,000 lbs. GVWR) Tier 3 NOX standards. EPA knows of
no technologies that would lower N2O emissions beyond the
control provided by the precise emissions control systems already being
implemented to meet EPA's criteria pollutant standards. Therefore, EPA
continues to believe the 0.05 g/mile N2O standard remains
appropriate.
The California Air Resources Board (CARB) suggested that EPA
investigate the feasibility of more stringent tailpipe standards. EPA
may consider more stringent standards in the future if data is
available to support adjustments to the standards as appropriate and
consistent with the CAA, but we repeat that at present we know of no
further emission reduction technologies for either N2O or
CH4.
If a manufacturer is unable to meet the N2O or
CH4 cap standards, the EPA program allows the manufacturer
to comply using CO2 credits. In other words, a manufacturer
may offset any N2O or CH4 emissions above the
standard by taking steps to further reduce CO2. A
manufacturer choosing this option would use GWPs to convert its
measured N2O and CH4 test results that are in
excess of the applicable
[[Page 73742]]
standards into CO2eq to determine the amount of
CO2 credits required. For example, for Phase 1, 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.\468\ By using the GWP 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 included in the
Phase 1 rule a compliance option for fuel conversion manufacturers to
comply with the N2O and CH4 standards that is
similar to the credit program described above. See 76 FR 57192. The
compliance option will allow conversion manufacturers, on an individual
engine family basis, to convert CO2 over compliance into
CO2 equivalents (CO2 eq) 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. EPA did not include
similar provisions allowing over compliance 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. As proposed, EPA is maintaining these provisions for Phase 2
as they provide important flexibility without reducing the overall GHG
benefits of the program.
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\468\ IPCC AR4 included a N2O GWP of 298 and a
CH4 GWP of 25. These factors are used in the Phase 1 rule
credits calculations.
---------------------------------------------------------------------------
EPA requested comments on updating GWPs used in the calculation of
credits discussed above. For Phase 2, EPA is updating the GWP for
methane from 25 to 34 based on IPCC AR5. Please see the full discussion
of this issue provided in Sections II.D and XI.D.
CARB suggested that EPA consider eliminating or at least phasing
out the use of CO2 credits in lieu of compliance with
tailpipe methane standards. In contrast, NGVAmerica strongly supported
extending this compliance option, noting that the ability to offset
methane (and also nitrous oxide) emissions with CO2 credits
is critical for new natural gas engines and vehicles. Cummins also
commented in support of continuing to allow the use of CO2-
equivalent credits to comply with N2O and CH4 standards.
Cummins commented that the flexibility has been applied by various
manufacturers in Phase 1 and is necessary for Phase 2. Review of MY
2014 certification GHG data confirmed that several manufacturers
utilized this Phase 1 program flexibility for either N2O or
CH4 debits on their diesel vehicles. EPA continues to
believe this flexibility is appropriate as it provides important
flexibility to manufacturers in an environmentally neutral manner.
(b) Air Conditioning Related Emissions
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. 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.\469\ Currently, the most commonly used
refrigerant in automotive applications--R134a, has a high GWP. 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.
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\469\ The U.S. EPA has reclamation requirements for refrigerants
in place under Title VI of the Clean Air Act. See 40 CFR part 82
Subpart B.
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In Phase 1, EPA finalized low leakage requirement for all air
conditioning systems installed in 2014 model year and later HDVs, with
the exception of Class 2b-8 vocational vehicles. As discussed in
Section V.B.(2)(c), EPA is extending leakage standards to vocational
vehicles for Phase 2. For air conditioning systems with a refrigerant
capacity greater than 733 grams, EPA finalized 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. EPA finalized a standard of 1.50 percent leakage per
year for heavy-duty pickup trucks and vans and Class 7 and 8 tractors.
See Section II.E.5. of the Phase 1 Preamble (76 FR 57194-57195) for
further discussion of the A/C leakage standard. The leakage standard
continues to apply for Phase 2 regardless of the refrigerant used in
the A/C system. See Section I.F. for how the Phase 2 program handles
the use of alternative refrigerants.
In addition to direct emissions from refrigerant leakage, air
conditioning systems 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 (as just noted) air
conditioners create load on the engine. See 74 FR 49529. In Phase 1,
the agencies did not set 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 were estimated to be minimal compared to
their overall emissions of CO2. 76 FR 57194-57196. This
continues to be the case. For this reason, EPA did not propose and is
not establishing A/C efficiency standards for Phase 2. This differs
from light-duty vehicles where CO2 emissions related to A/C
systems can be a significant portion of overall vehicle CO2
emissions and EPA has established appropriate standards and test
procedures.
AAPC and Nissan commented that the agencies should provide A/C
efficiency credits similar to those included in the light-duty vehicle
program. AAPC also commented that the AC17 test, included in the light-
duty vehicle program to confirm A/C system performance, would be
impractical and should not be required for heavy-duty vehicles. The
agencies did not propose and are not adopting A/C efficiency credits
for heavy-duty pickups and vans. AAPC suggests that the agencies could
allow the same credits as are available in the light-duty vehicle
program but no data is provided regarding the appropriateness of the
credits. The EPA would need to resolve a number of open issues relating
to environmental implications of A/C efficiency credits for these
vehicles (among them, potential credit generation rate, whether credits
would be windfall, implications for the standard stringency) before
considering adopting an A/C efficiency credit regime. Also, the AC17
test is an integral part of the light-duty vehicle program serving as a
confirmation that the credits are based on actual performance
improvements. EPA does not believe that it would be appropriate to
provide credits based only on the presumption that systems similar to
those used in light-duty trucks will
[[Page 73743]]
provide the same improvements in heavy-duty pickups and vans with no
confirmation through testing.
AAPC also recommended that EPA provide credits for reduced
refrigerant leakage and alternative refrigerant usage similar to the
light-duty vehicle program. In response, as discussed above and in
Section I.F, EPA has established standards for refrigerant leakage. EPA
does not believe that it would be appropriate to provide credits for
items that are essentially required. Providing such credits without an
increase in total program stringency similar to the light-duty approach
to A/C efficiency and refrigerant leakage would result in a loss of
program benefits.
C. Use of the CAFE Model in Heavy-Duty Rulemaking
NHTSA developed the CAFE model in 2002 to support the 2003 issuance
of CAFE standards for MYs 2005-2007 light trucks. NHTSA has since
significantly expanded and refined the model, and has applied the model
to support every ensuing CAFE rulemaking for both light-duty and heavy-
duty. For this analysis, the model was reconfigured to use the work
based attribute metric of ``work factor'' established in the Phase 1
rule instead of the light duty ``footprint'' attribute metric.
Past analyses conducted using the CAFE model have been subjected to
extensive and detailed review and comment, much of which has informed
the model's expansion and refinement. NHTSA's use of the model was
considered and supported in Center for Biological Diversity v. National
Highway Traffic Safety Admin., 538 F.3d 1172, 1194 (9th Cir. 2008). For
further discussion see 76 FR 57198, and the model has been subjected to
formal peer review and review by the General Accounting Office (GAO)
and National Research Council (NRC). NHTSA makes public the model,
source code, and--except insofar as doing so will compromise
confidential business information (CBI) manufacturers have provided to
NHTSA--all model inputs and outputs underlying published rulemaking
analyses.
Although the CAFE model can also be used for more aggregated
analysis (e.g., involving ``representative vehicles,'' single-year
snapshots, etc.), NHTSA designed the model with a view toward (a)
detailed simulation of manufacturers' potential actions given a defined
set of standards, followed by (b) calculation of resultant impacts and
economic costs and benefits. The model is intended to describe actions
manufacturers could take in light of defined standards and other input
assumptions and estimates, not to predict actions manufacturers will
take in light of competing product and market interests (e.g. engine
power, customer features, technology acceptance, etc.).
For the proposal, the agencies conducted coordinated and
complementary analyses using two analytical methods for the heavy-duty
pickup and van segment by employing both NHTSA's CAFE model and EPA's
MOVES model. The agencies used EPA's MOVES model to estimate fuel
consumption and emissions impacts for tractor-trailers (including the
engine that powers the tractor), and vocational vehicles (including the
engine that powers the vehicle). Additional calculations were performed
to determine corresponding monetized program costs and benefits. For
heavy-duty pickups and vans, the agencies performed complementary
analyses, which we refer to as ``Method A'' and ``Method B.''
For the final rule, NHTSA's Method A uses a modified version of the
CAFE model developed since the NPRM, as well as accompanying updates to
CAFE model inputs, to project a pathway the industry could use to
comply with each regulatory alternative and the estimated effects on
fuel consumption, emissions, benefits and costs were industry to do so.
Method A is presented below in Section D and differs from the Method A
analysis provided in the NPRM. NHTSA considered the results of the
Method A analysis for decision making for the final rule.
EPA's Method B analysis continues to use the CAFE model and inputs
developed for the NPRM to identify technology pathways the industry
could potentially use to comply with each regulatory alternative, along
with resultant impacts on per vehicle costs should that compliance path
be utilized, and the MOVES model was used to calculate corresponding
changes in total fuel consumption and annual emissions. The results are
presented in Section E. Additional calculations were performed to
determine corresponding monetized program costs and benefits. NHTSA's
consideration of the Method A analysis and EPA's consideration of the
Method B analysis led the agencies to the same conclusions regarding
the selection of the Phase 2 standards. See Sections D and E for
additional discussion of these two methods and the feasibility of the
standards.
(1) Overview of the CAFE Model
As a starting point, the model makes use of an input file defining
the analysis fleet--that is, a set of specific vehicle models (e.g.,
Ford F250) and model configurations (e.g., Ford F250 with 6.2-liter V8
engine, 4WD, and 6-speed manual transmission) estimated or assumed to
be produced by each manufacturer in each model year to be included in
the analysis. The analysis fleet includes key engineering attributes
(e.g., curb weight, payload and towing capacities, dimensions, presence
of various fuel-saving technologies) of each vehicle model, engine, and
transmissions, along with estimates or assumptions of future production
volumes. It also specifies the extent to which specific vehicle models
share engines, transmissions, and vehicle platforms, and describes each
manufacturer's estimated or assumed product cadence (i.e., timing for
freshening and redesigning different vehicles and platforms). This
input file also specifies a payback period used to estimate the
potential that each manufacturer might apply technology to improve fuel
economy beyond levels required by standards.
A second input file to the model contains a variety of contextual
estimates and assumptions. Some of these inputs, such as future fuel
prices and vehicle survival and mileage accumulation (versus vehicle
age), are relevant to estimating manufacturers' potential application
of fuel-saving technologies. Some others, such as fuel density and
carbon content, vehicular and upstream emission factors, the social
cost of carbon dioxide emissions, and the discount rate, are relevant
to calculating physical and economic impacts of manufacturers'
application of fuel-saving technologies.
A third input file contains estimates and assumptions regarding the
future applicability, availability, efficacy, and cost of various fuel-
saving technologies. Efficacy is expressed in terms of the percentage
reduction in fuel consumption, cost is expressed in dollars, and both
efficacy and cost are expressed on an incremental basis (i.e.,
estimates for more advanced technologies are specified as increments
beyond less advanced technologies). The input file also includes
``synergy factors'' used to make adjustments accounting for the
potential that some combinations of technologies may result fuel
savings or costs different from those indicated by incremental values.
Thus, the model itself does not evaluate which technologies will be
available, nor does it evaluate how effective or reliable they
[[Page 73744]]
will be. The technological availability and effectiveness are rather
predefined inputs to the model based on the agencies' judgements and
not outputs from the model, which is simply a tool for calculating the
effects of combining input assumptions.
Finally, a fourth model input file specifies standards to be
evaluated. Standards are defined on a year-by-year basis separately for
each regulatory class (passenger cars, light trucks, and heavy-duty
pickups and vans). Regulatory alternatives are specified as discrete
scenarios, with one scenario defining the no-action alternative or
``baseline,'' all other scenarios defining regulatory alternatives to
be evaluated relative to that no-action alternative.
Given these inputs, the model estimates each manufacturer's
potential year-by-year application of fuel-saving technologies to each
engine, transmission, and vehicle. Subject to a range of engineering
and planning-related constraints (e.g., secondary axle disconnect can't
be applied to 2-wheel drive vehicles, many major technologies can only
be applied practicably as part of a vehicle redesign, and applied
technologies carry forward between model years), the model attempts to
apply technology to each manufacturer's fleet in a manner that
minimizes ``effective costs'' (accounting, in particular, for
technology costs and avoided fuel outlays), continuing to add
improvements as long as doing so will help toward compliance with
specified standards or will produce fuel savings that ``pay back'' at
least as quickly as specified in the input file mentioned above.
After estimating the extent to which each manufacturer might add
fuel-saving technologies under each specified regulatory alternative,
the model calculates a range of physical impacts, such as changes in
highway travel (i.e., VMT), changes in fleetwide fuel consumption,
changes in highway fatalities, and changes in vehicular and upstream
greenhouse gas and criteria pollutant emissions. The model also applies
a variety of input estimates and assumptions to calculate economic
costs and benefits to vehicle owners and society, based on these
physical impacts. These are considered Method A results.
Since the manufacturers of HD pickups and vans generally only have
one basic pickup truck and van with different versions ((i.e.,
different wheelbases, cab sizes, two-wheel drive, four-wheel drive,
etc.) there exists less flexibility than in the light-duty fleet to
coordinate model improvements over several years. As such, the CAFE
model allows changes to the HD pickups and vans to meet new standards
according to estimated redesign cycles included as a model input. As
noted above, 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 eight or
more years for this analysis. However, opportunities for gradual
improvements not necessarily linked to large scale changes can occur
between the redesign cycles (i.e., model refresh). Examples of such
improvements are upgrades to an existing vehicle model's engine,
transmission and aftertreatment systems.
(2) How did the agencies develop the analysis fleet for the NPRM?
As discussed above, both agencies used a version of NHTSA's CAFE
modeling system to estimate technology costs and application rates
under each regulatory alternative considered. The modeling system
relies on many inputs, including an analysis fleet. In order to
estimate the impacts of potential standards, it is necessary to
estimate the composition of the future vehicle fleet. Doing so enables
estimation of the extent to which each manufacturer may need to add
technology in response to a given series of attribute-based standards,
accounting for the mix and fuel consumption of vehicles in each
manufacturer's regulated fleet. The agencies create an analysis fleet
in order to track the volumes and types of fuel economy-improving and
CO2-reducing technologies that are already present in the
existing vehicle fleet. This aspect of the analysis fleet helps to keep
the CAFE model from adding technologies to vehicles that already have
these technologies, which will result in ``double counting'' of
technologies' costs and benefits. An additional step involved
projecting the fleet sales into MYs 2019-2030. This represents the
fleet volumes that the agencies believe will exist in MYs 2019-2030.
The following presents an overview of the information and methods
applied to develop the analysis fleet, and some basic characteristics
of that fleet.
Most of the information about the vehicles that make up the 2014
analysis fleet (used in the NPRM and Method B of this FRM) and the 2015
analysis fleet (used in Method A of this FRM) was gathered from the
2014 and 2015 Pre-Model Year Reports submitted to EPA by the
manufacturers under Phase 1 of Fuel Efficiency and GHG Emission Program
for Medium- and Heavy-Duty Trucks, MYs 2014-2018. The major
manufacturers of class 2b and class 3 trucks (Chrysler, Ford and GM)
were asked to voluntarily submit updates to their Pre-Model Year
Reports. The agencies used these updated data in constructing the
analysis fleet for these manufacturers. The agencies agreed to treat
this information as Confidential Business Information (CBI) until the
publication of the proposed rule. This information can be made public
at this time because by now all MY 2014 and MY 2015 vehicle models have
been produced, which makes data about them essentially public
information.
In addition to information about each vehicle, the agencies need
additional information about the fuel economy-improving/CO2-
reducing technologies already on those vehicles in order to assess how
much and which technologies to apply to determine a path toward future
compliance. To correctly account for the cost and effectiveness of
adding technologies, it is necessary to know the technology penetration
in the existing vehicle fleet. Otherwise, ``double-counting'' of
technology could occur. Thus, in their respective analysis fleets, the
agencies augmented this information with data from public and
commercial sources \470\ that include more complete technology
descriptions, e.g. for specific engines and transmissions.
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\470\ e.g., manufacturers' Web sites, Wards Automotive.
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The resultant analysis fleets are provided in detail at NHTSA's Web
site, along with all other inputs to and outputs from both the NPRM and
the current analysis. The agencies invited but did not receive comment
on this analysis.
(a) Vehicle Redesign Schedules and Platforms
Product cadence in the Class 2b and 3 pickup market has
historically ranged from 7-9 years between major redesigns. However,
due to increasing competitive pressures and consumer demands the agency
anticipates that manufacturers will generally shift to shorter design
cycles resembling those of the light duty market. Pickup truck
manufacturers in the Class 2b and 3 segments are shown to adopt
redesign cycles of six years, allowing two redesigns prior to the end
of the regulatory period in 2025.
The Class 2b and 3 van market has changed markedly from five years
ago. Ford, Nissan, Ram and Daimler have adopted vans of ``Euro Van''
appearance, and in many cases now use smaller turbocharged gasoline or
diesel engines in the place of larger, naturally-aspirated V8s. The
2014 and 2015 model years used in this analysis
[[Page 73745]]
represent a period where most manufacturers, with the exception of
General Motors, have recently introduced a completely redesigned
product after many years. The van segment has historically been one of
the slowest to be redesigned of any product segment, with some products
going two decades or more between redesigns.
Due to new entrants in the field and increased competition, the
agencies anticipate that most manufacturers will increase the pace of
product redesigns in the van segment, but that they will continue to
trail other segments. The cycle time used in this analysis is
approximately ten years between major redesigns, allowing
manufacturers' only one major redesign during the regulatory period.
The agencies did not receive comment on this anticipated product design
cycle.
Additional detail on product cadence assumptions for specific
manufacturers is located in Chapter 10 of the RIA.
(b) Sales Volume Forecast
Since each manufacturer's required average fuel consumption and GHG
levels are sales-weighted averages of the fuel economy/GHG targets
across all model offerings, sales volumes play a critical role in
estimating that burden. The CAFE model requires a forecast of sales
volumes, at the vehicle model-variant level, in order to simulate the
technology application necessary for a manufacturer to achieve
compliance in each model year for which outcomes are simulated.
As stated above, the agencies relied on the pre-model-year
compliance submissions from manufacturers to provide sales volumes at
the model level based on the level of disaggregation in which the
models appear in the compliance data. However, the agencies only use
these reported volumes without adjustment for the reference fleet model
year (MY 2014 or MY 2015). For all future model years, we combine the
manufacturer submissions with sales projections from the 2014 (for the
NPRM and Method B of the FRM) or 2015 (for Method A of the FRM) Annual
Energy Outlook Reference Case and IHS Automotive to determine model
variant level sales volumes in future years.\471\ The projected sales
volumes by class that appear in the Annual Energy Outlook as a result
of a collection of assumptions about economic conditions, demand for
commercial miles traveled, and technology migration from light-duty
pickup trucks in response to the concurrent light-duty CAFE/GHG
standards. These are shown in Chapter 2 of the RIA.
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\471\ Tables from AEO's forecast are available at http://www.eia.gov/oiaf/aeo/tablebrowser/. The agencies also made use of
the IHS Automotive Light Vehicle Production Forecast (August 2014).
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The projection of total sales volumes for the Class 2b and 3 market
segment was based on the total volumes in the 2014 AEO Reference Case
in the NPRM and for Method B of this FRM. For the purposes of this
analysis, the AEO2014 calendar year volumes have been used to represent
the corresponding model-year volumes. While AEO2014 provides enough
resolution in its projections to separate the volumes for the Class 2b
and 3 segments, the agencies deferred to the vehicle manufacturers and
chose to rely on the relative shares present in the pre-model-year
compliance data. This methodology remains the same for the Method A FRM
analysis, but we have replaced the 2014 AEO reference case with the
2015 AEO reference case.
The relative sales share by vehicle type (van or pickup truck, in
this case) was derived from a sales forecast that the agencies
purchased from IHS Automotive, and applied to the total volumes in the
AEO2014 projection. Table VI-3 shows the implied shares of the total
new 2b/3 vehicle market broken down by manufacturer and vehicle type.
The same methodology was applied using 2015 IHS/Polk projections, and
the total volumes from the AEO2015 projection for Method A of the FRM.
The results of the 2015-based projections are presented in the
following section about changes made to the model since the NPRM.
Table VI-3--IHS Automotive Market Share Forecast for 2b/3 Vehicles
--------------------------------------------------------------------------------------------------------------------------------------------------------
Model year market share
Manufacturer Style -----------------------------------------------------------------------------------
2015 (%) 2016 (%) 2017 (%) 2018 (%) 2019 (%) 2020 (%) 2021 (%)
--------------------------------------------------------------------------------------------------------------------------------------------------------
Daimler................................. Van....................... 3 3 3 3 3 3 3
Fiat Chrysler........................... Van....................... 2 2 2 2 2 2 3
Ford.................................... Van....................... 16 17 17 17 18 18 18
General Motors.......................... Van....................... 12 12 11 12 13 13 13
Nissan.................................. Van....................... 2 2 2 2 2 2 2
Daimler................................. Pickup.................... 0 0 0 0 0 0 0
Fiat Chrysler........................... Pickup.................... 14 14 14 14 11 12 12
Ford.................................... Pickup.................... 28 27 30 30 30 27 26
General Motors.......................... Pickup.................... 23 23 21 21 21 22 23
Nissan.................................. Pickup.................... 0 0 0 0 0 0 0
--------------------------------------------------------------------------------------------------------------------------------------------------------
Within those broadly defined market shares, volumes at the
manufacturer/model-variant level were constructed by applying the
model-variant's share of manufacturer sales in the pre-model-year
compliance data for the relevant vehicle style, and multiplied by the
total volume estimated for that manufacturer and that style.
After building out a set of initial future sales volumes based on
the sources described above, the agencies attempted to incorporate new
information about changes in sales mix that are not captured by either
the existing sales forecasts or the simulated technology changes in
vehicle platforms. In particular, Ford has announced intentions to
phase out their existing Econoline vans, gradually shifting volumes to
the new Transit platform for some model variants (notably chassis cabs
and cutaways variants) and eliminating offerings outright for complete
Econoline vans as early as model year 2015. In the case of complete
Econoline vans, the volumes for those vehicles were allocated to MY
2015 Transit vehicles based on assumptions about likely production
splits for the powertrains of the new Transit platform. The volumes for
complete Econoline vans were shifted at ratios of 50 percent, 35
percent, and 15
[[Page 73746]]
percent for 3.7 L, 3.5 L Eco-boost, and 3.2 L diesel, respectively.
Within each powertrain, sales were allocated based on the percentage
shares present in the pre-model-year compliance data. The chassis cab
and cutaway variants of the Econolines were phased out linearly between
MY 2015 and MY 2020, at which time the Econolines cease to exist in any
form and all corresponding volume resides with the Transits.
(3) Other Analysis Inputs
In addition to the inputs summarized above, the analysis of
potential standards for HD pickups and vans makes use of a range of
other estimates and assumptions specified as inputs to the CAFE
modeling system. Some significant inputs (e.g., estimates of future
fuel prices) also applicable to other MDHD segments are discussed below
in Section IX. Others more specific to the analysis of HD pickups and
vans are as follows:
(a) Vehicle Survival and Mileage Accumulation
The analysis estimates the travel, fuel consumption, and emissions
over the useful lives of vehicles produced during model years 2014-
2030. Doing so requires initial estimates of these vehicles' survival
rates (i.e., shares expected to remain in service) and mileage
accumulation rates (i.e., anticipated annual travel by vehicles
remaining in service), both as a function of vehicle vintage (i.e.,
age). These estimates are based on an empirical analysis of changes in
the fleet of registered vehicles over time from HIS/Polk data, in the
case of survival rates. The NPRM and Method A of the FRM use data
collected as part of the last Vehicle In Use Survey (the 2002 VIUS) for
the mileage accumulation schedule. Method A of the FRM uses mileage
accumulation schedules from 2014 Polk/IHS odometer reading data. The
changes to the VMT schedules for Method A of the current analysis are
further described below in the Method A FRM specific changes.
(b) Rebound Effect
Expressed as an elasticity of mileage accumulation with respect to
the fuel cost per mile of operation, the agencies have applied a
rebound effect of 10 percent for today's analysis. Other rebound
effects are considered in sensitivity analyses in Sections D.
(c) On-Road ``Gap''
The model was run with a 20 percent adjustment to reflect
differences between on-road and laboratory performance.
(d) Fleet Population Profile
Though not reported here, cumulative fuel consumption and
CO2 emissions are presented in the accompanying EIS, and
these calculations utilize estimates of the numbers of vehicles
produced in each model year remaining in service in calendar year 2014.
The initial age distribution of the registered vehicle population in
2014 is based on vehicle registration data acquired by NHTSA from R.L.
Polk Company. For Method A, these values were updated to reflect newer
data acquired by NHTSA from Polk.
(e) Past Fuel Consumption Levels
Though not reported here, cumulative fuel consumption and
CO2 emissions are presented in the accompanying EIS, and
these calculations require estimates of the performance of vehicles
produced prior to model year 2014. Consistent with AEO 2014, the model
was run with the assumption that gasoline and diesel HD pickups and
vans averaged 14.9 mpg and 18.6 mpg, respectively, with gasoline
versions averaging about 48 percent of production. For Method A, these
values were updated to reflect AEO2015, such that gasoline and diesel
versions were projected to average 16.0 mpg and 20.0 mpg, respectively.
(f) Long-Term Fuel Consumption Levels
Though not reported here, longer-term estimates of fuel consumption
and emissions are presented in the accompanying EIS. These estimates
include calculations involving vehicle produced after MY 2030 and,
consistent with AEO 2014, the model was run with the assumption that
fuel consumption and CO2 emission levels will continue to
decline at 0.05 percent annually (compounded) after MY 2030.
(g) Payback Period
To estimate in what sequence and to what degree manufacturers might
add fuel-saving technologies to their respective fleets, the CAFE model
iteratively ranks remaining opportunities (i.e., applications of
specific technologies to specific vehicles) in terms of effective cost,
primary components of which are the technology cost and the avoided
fuel outlays, attempting to minimize effective costs incurred.\472\
Depending on inputs, the model also assumes manufacturers may improve
fuel consumption beyond requirements insofar as doing so will involve
applications of technology at negative effective cost--i.e., technology
application for which buyers' up-front costs are quickly paid back
through avoided fuel outlays. This calculation includes only fuel
outlays occurring within a specified payback period. For both Method A
and Method B, a payback period of 6 months was applied for the dynamic
baseline case, or Alternative 1b. Thus, for example, a manufacturer
already in compliance with standards is projected to apply a fuel
consumption improvement projected to cost $250 (i.e., as a cost that
could be charged to the buyer at normal profit to the manufacturer) and
reduce fuel costs by $500 in the first year of vehicle operation. The
agencies have conducted the same analysis applying a payback period of
0 months for the flat baseline case, or Alternative 1a. For Method A,
Alternative 1b is the primary analysis, and Alternative 1a is one of a
range of cases included in the sensitivity analysis.
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\472\ Volpe CAFE Model, available at http://www.nhtsa.gov/fuel-economy.
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(h) Civil Penalties in the NHTSA Analysis
EPCA and EISA require that a manufacturer pay civil penalties if it
does not have enough credits to cover a shortfall with one or both of
the light-duty CAFE standards in a model year. While these provisions
do not apply to HD pickups and vans, at this time, the CAFE model will
show civil penalties owed in cases where available technologies and
credits are estimated to be insufficient for a manufacturer to achieve
compliance with a standard. These model-reported estimates have been
excluded from this analysis. For Method A, this aspect of the model has
been modified to also exclude from the calculation of ``effective
cost'' used to select among available options to add specific
technologies to specific vehicles.
(i) Coefficients for Fatality Calculations
Both the NPRM and the current analysis consider the potential
effects on crash safety of the technologies manufacturers may apply to
their vehicles to meet each of the regulatory alternatives. NHTSA
research has shown that vehicle mass reduction affects overall societal
fatalities associated with crashes \473\ and, most relevant to this
rule, mass reduction in heavier light- and medium-duty vehicles has an
overall beneficial effect on societal fatalities. Reducing the mass of
a heavier vehicle involved in a crash with another vehicle(s) makes it
less
[[Page 73747]]
likely there will be fatalities among the occupants of the other
vehicles. In addition to the effects of mass reduction, the analysis
anticipates that these standards, by reducing the cost of driving HD
pickups and vans, will lead to increased travel by these vehicles and,
therefore, more crashes involving these vehicles. The Method B analysis
considers overall impacts considering both of these factors, using a
methodology similar to NHTSA's analyses for the MYs 2017-2025 CAFE and
GHG emission standards.
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\473\ U.S. DOT/NHTSA, Relationships Between Fatality Risk Mass
and Footprint in MY 2000-2007 PC and LTVs, ID: NHTSA-2010-0131-0336,
Posted August 21, 2012.
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The Method B analysis includes estimates of the extent to which HD
pickups and vans produced during MYs 2014-2030 may be involved in fatal
crashes, considering the mass, survival, and mileage accumulation of
these vehicles, taking into account changes in mass and mileage
accumulation under each regulatory alternative. These calculations make
use of the same coefficients applied to light trucks in the MYs 2017-
2025 CAFE rulemaking analysis. Baseline rates of involvement in fatal
crashes are 13.03 and 13.24 fatalities per billion miles for vehicles
with initial curb weights above and below 4,594 lbs, respectively.
Considering that the data underlying the corresponding statistical
analysis included observations through calendar year 2010, these rates
are reduced by 9.6 percent to account for subsequent impacts of recent
Federal Motor Vehicle Safety Standards (FMVSS) and anticipated
behavioral changes (e.g., continued increases in seat belt use). For
vehicles above 4,594 lbs--i.e., the majority of the HD pickup and van
fleet--mass reduction is estimated to reduce the net incidence of
highway fatalities by 0.34 percent per 100 lbs. of removed curb weight.
For the few HD pickups and vans below 4,594 lbs, mass reduction is
estimated to increase the net incidence of highway fatalities by 0.52
percent per 100 lbs. Consistent with DOT guidance, the social cost of
highway fatalities is estimated using a value of statistical life (VSL)
of $9.36m in 2014, increasing thereafter at 1.18 percent annually.
The Method A analysis uses the same methodology as described above,
but applies coefficients that have been updated to reflect more current
data, updated statistical analysis by NHTSA staff, and updated DOT
guidance regarding the VSL. Baseline rates of involvement in fatal
crashes are 16.06 and 14.35 fatalities per billion miles for pickups
and vans with initial curb weights above and below 4,947 lbs,
respectively. Considering that the data underlying the corresponding
statistical analysis included observations through calendar year 2012,
these rates are reduced by 9.6 percent to account for subsequent
impacts of recent Federal Motor Vehicle Safety Standards (FMVSS) and
anticipated behavioral changes (e.g., continued increases in seat belt
use). For vehicles above 4,947 lbs--i.e., the majority of the HD pickup
and van fleet--mass reduction is estimated to reduce the net incidence
of highway fatalities by 0.72 percent per 100 lbs. of removed curb
weight. For HD pickups and vans below 4,947 lbs (accounting for any
applied mass reduction), mass reduction is estimated to reduce the net
incidence of highway fatalities by 0.10 percent per 100 lbs. Consistent
with DOT guidance, the social cost of highway fatalities is estimated
using a value of statistical life (VSL) of $9.4m from 2015 forward.
(j) Compliance Credit Provisions
Today's analysis accounts for the potential to over comply with
standards and thereby earn compliance credits, applying these credits
to ensuring compliance requirements. In doing so, the agencies treat
any unused carried-forward credits as expiring after five model years,
consistent with current and standards. For today's analysis, the
agencies are not estimating the potential to ``borrow''--i.e., to carry
credits back to past model years.
(k) Emission Factors
While CAFE model calculates vehicular CO2 emissions
directly on a per-gallon basis using fuel consumption and fuel
properties (density and carbon content), the model calculates emissions
of other pollutants (methane, nitrogen oxides, ozone precursors, carbon
monoxide, sulfur dioxide, particulate matter, and air toxics) on a per-
mile basis. In doing so, the Method A analysis used corresponding
emission factors estimated using EPA's MOVES model.\474\ To estimate
emissions (including CO2) from upstream processes involved
in producing, distributing, and delivering fuel, NHTSA has applied
emission factors--all specified on a gram per gallon basis--derived
from Argonne National Laboratory's GREET model.\475\
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\474\ EPA MOVES model available at http://www3.epa.gov/otaq/models/moves/index.htm (last accessed Feb 23, 2015).
\475\ GREET (Greenhouse Gases, Regulated Emissions, and Energy
Use in Transportation) Model, Argonne National Laboratory, https://greet.es.anl.gov/.
---------------------------------------------------------------------------
(l) Refueling Time Benefits
To estimate the value of time savings associated with vehicle
refueling, the Method A analysis used estimates that an average
refueling event involves refilling 60 percent of the tank's capacity
over the course of 3.5 minutes, at an hourly cost of $27.22.
(m) External Costs of Travel
Changes in vehicle travel will entail economic externalities. To
estimate these costs, the Method A analysis used estimates that
congestion-, crash-, and noise-related externalities will total
5.1[cent]/mi., 2.8[cent]/mi., and 0.1[cent]/mi., respectively.
(n) Ownership and Operating Costs
Method A results predict that the total cost of vehicle ownership
and operation will change not just due to changes in vehicle price and
fuel outlays, but also due to some other costs likely to vary with
vehicle price. To estimate these costs, NHTSA has applied factors of
5.5 percent (of price) for taxes and fees, 15.3 percent for financing,
19.2 percent for insurance, 1.9 percent for relative value loss. The
Method A analysis also estimates that average vehicle resale value will
increase by 25 percent of any increase in new vehicle price.
(4) 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 2021-2027. The
majority of the technologies described in this section are readily
available, well known and proven in other vehicle sectors, and could be
incorporated into vehicles once production decisions are made. Other
technologies considered may not currently be in production, but are
beyond the research phase and under development, and are expected to be
in production in highway vehicles over the next few years. These are
technologies that 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 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 buyer's decision to purchase a diesel
versus gasoline engine
[[Page 73748]]
depends on several factors including initial purchase price, fuel
operating costs, durability, towing capability and payload capacity
amongst other reasons. As discussed in VI.B. above, the agencies
generally prefer to set standards that do not distinguish between fuel
types where technological or market-based reasons do not strongly argue
otherwise. However, as with Phase 1, we continue to believe that
fundamental differences between spark ignition and compression ignition
engines warrant unique fuel standards, which is also important in
ensuring that our program maintains product choices available to
vehicle buyers. Therefore, as discussed in Section B.1, we are
maintaining separate standards for gasoline and diesel vehicles. 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 these standards on a targeted switch in the mix of diesel and
gasoline vehicles. We believe our standards require similar levels of
technology development and cost for both diesel and gasoline vehicles.
Hence the program is not intended to force, nor discourage, changes in
a manufacturer's fleet mix between gasoline and diesel vehicles.
The following contains a description of technologies the agencies
considered as potentially available in the rule timeframe, and hence,
having potential to be part of a compliance pathway for these vehicles.
Additionally, the agencies did not receive any comments indicating that
the technology effectiveness estimates used in the determination of
potential reductions in GHGs and fuel consumption are not
representative of the expected ranges for expected duty cycles.
(a) Engine Technologies
The agencies reviewed the engine technology estimates used in the
2017-2025 light-duty rule, the 2014-2018 heavy-duty rule, and the 2015
NHTSA Technology Study. In doing so the agencies 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 will 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.
(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.\476\ 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. 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.
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\476\ ``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).
---------------------------------------------------------------------------
(iii) Engine Parasitic Demand Reduction
In addition to physical engine friction reduction, manufacturers
can reduce the mechanical load on the engine from parasitics, such as
oil, fuel, and coolant pumps. The high-pressure fuel pumps of direct-
injection gasoline and diesel engines have particularly high demand.
Example improvements include variable speed or variable displacement
water pumps, variable displacement oil pumps, more efficient high
pressure fuel pumps, valvetrain upgrades and shutting off piston
cooling when not needed.
(iv) 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.\477\ 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 (VVT) implementation option available and requires only one cam
phaser.\478\ We also considered variable valve lift (VVL), which alters
the intake valve lift in order to reduce pumping losses and more
efficiently ingest air.
---------------------------------------------------------------------------
\477\ Although couple cam phasing appears only in the single
overhead cam and overhead valve branches of the decision tree, it is
noted that a single phaser with a secondary chain drive would allow
couple cam phasing to be applied to direct overhead cam engines.
Since this would potentially be adopted on a limited number of
direct overhead cam engines NHTSA did not include it in that branch
of the decision tree.
\478\ It is also noted that coaxial camshaft developments would
allow other variable valve timing options to be applied to overhead
valve engines. However, since they would potentially be adopted on a
limited number of overhead valve engines, NHTSA did not include them
in the decision tree.
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(v) 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
[[Page 73749]]
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 has seen a recent resurgence thanks to better
valvetrain designs and engine controls. General Motors and Fiat
Chrysler have incorporated cylinder deactivation across a substantial
portion of their V8-powered lineups, including some heavy duty
applications.
(vi) 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.
Most manufacturers have introduced vehicles with SGDI engines in
light duty sectors, including GM and Ford and have announced their
plans to increase dramatically the number of SGDI engines in their
portfolios. SGDI has not been introduction on heavy duty applications
at this time however as these largely dedicated heavy duty engines
approach their redesign window, they are expected to become SGDI
engines.
(vii) Turbocharging and Downsizing
The specific power of a naturally aspirated engine is primarily
limited by the rate at which the engine is able to draw air into the
combustion chambers. Turbocharging and supercharging (grouped together
here as boosting) are two methods to increase the intake manifold
pressure and cylinder charge-air mass above naturally aspirated levels.
Boosting increases the airflow into the engine, thus increasing the
specific power level, and with it the ability to reduce engine
displacement while maintaining performance. This effectively reduces
the pumping losses at lighter loads in comparison to a larger,
naturally aspirated engine.
Almost every major manufacturer currently markets a vehicle with
some form of boosting. While boosting has been a common practice for
increasing performance for several decades, turbocharging has
considerable potential to improve fuel economy and reduce
CO2 emissions when the engine displacement is also reduced.
Specific power levels for a boosted engine often exceed 100 hp/L,
compared to average naturally aspirated engine power densities of
roughly 70 hp/L. As a result, engines can be downsized roughly 30
percent or higher while maintaining similar peak output levels. In the
last decade, improvements to turbocharger turbine and compressor design
have improved their reliability and performance across the entire
engine operating range. New variable geometry turbines and ball-bearing
center cartridges allow faster turbocharger spool-up (virtually
eliminating the once-common ``turbo lag'') while maintaining high flow
rates for increased boost at high engine speeds. Low speed torque
output has been dramatically improved for modern turbocharged engines.
However, even with turbocharger improvements, maximum engine torque at
very low engine speed conditions, for example launch from standstill,
is increased less than at mid and high engine speed conditions. The
potential to downsize engines may be less on vehicles with low
displacement to vehicle mass ratios for example a very small
displacement engine in a vehicle with significant curb weight, in order
to provide adequate acceleration from standstill, particularly up
grades or at high altitudes.
The use of GDI in combination with turbocharging and charge air
cooling reduces the fuel octane requirements for knock limited
combustion enabling the use of higher compression ratios and boosting
pressures. Recently published data with advanced spray-guided injection
systems and more aggressive engine downsizing targeted towards reduced
fuel consumption and CO2 emissions reductions indicate that
the potential for reducing CO2 emissions for turbocharged,
downsized GDI engines may be as much as 15 to 30 percent relative to
port-fuel-injected engines.14 15 16 17 18 Confidential
manufacturer data suggests an incremental range of fuel consumption and
CO2 emission reduction of 4.8 to 7.5 percent for
turbocharging and downsizing. Other publicly-available sources suggest
a fuel consumption and CO2 emission reduction of 8 to 13
percent compared to current-production naturally-aspirated engines
without friction reduction or other fuel economy technologies: A joint
technical paper by Bosch and Ricardo suggesting fuel economy gain of 8
to 10 percent for downsizing from a 5.7 liter port injection V8 to a
3.6 liter V6 with direct injection using a wall-guided direct injection
system; a Renault report suggesting a 11.9 percent NEDC fuel
consumption gain for downsizing from a 1.4 liter port injection in-line
4-cylinder engine to a 1.0 liter in-line 4-cylinder engine, also with
wall-guided direct injection; and a Robert Bosch paper suggesting a 13
percent NEDC gain for downsizing to a turbocharged DI engine, again
with wall-guided injection. These reported fuel economy benefits show a
wide range depending on the SGDI technology employed.
Note that for this analysis the agencies determined that this
technology path is only applicable to heavy duty applications that have
operating conditions more closely associated with light duty vehicles.
This includes vans designed mainly for cargo volume or modest payloads
and having similar GCWR to light duty applications. These vans cannot
tow trailers heavier than similar light duty vehicles and are largely
already sharing engines of significantly smaller displacement and
cylinder count compared to heavy duty vehicles designed mainly for
trailer towing.
ACEEE commented that 10 percent of pick-ups in the heavy duty
sector are candidates for turbocharging and downsizing if they do not
require higher payloads or towing capacity. Other commenters suggested
that downsizing that has occurred in light duty could also occur in
heavy duty. As discussed above, the agencies evaluated turbocharging
and downsizing in
[[Page 73750]]
vehicles like vans which are not typically designed for extensive
trailer towing. When we looked at pick-ups, we determined that
consumers needing a pick-up without higher payload or trailer towing
requirements would migrate to the lower cost light-duty versions which
are typically identical in cabin size and seating as the heavy-duty
versions but have less work capability. Because of this, in the
agencies' assessment, the heavy-duty pickups retained the high trailer
towing and payload requirements and the corresponding larger engines.
AAPC comments supported this approach as the correct combination of
engine to intended use and even provided in their comments data
indicating that turbocharged and downsized engines are more fuel
efficient at lighter loads however under working conditions expected of
a heavy-duty pick-up they are actually less fuel efficient than the
larger engines.
(viii) Cooled Exhaust-Gas Recirculation
Cooled exhaust gas recirculation or Boosted EGR is a combustion
concept that involves utilizing EGR as a charge diluent for controlling
combustion temperatures and cooling the EGR prior to its introduction
to the combustion system. Higher exhaust gas residual levels at part
load conditions reduce pumping losses for increased fuel economy. The
additional charge dilution enabled by cooled EGR reduces the incidence
of knocking combustion and obviates the need for fuel enrichment at
high engine power. This allows for higher boost pressure and/or
compression ratio and further reduction in engine displacement and both
pumping and friction losses while maintaining performance. Engines of
this type use GDI and both dual cam phasing and discrete variable valve
lift. The EGR systems considered in this final rule, consistent with
the rule, will use a dual-loop system with both high and low pressure
EGR loops and dual EGR coolers. The engines will also use single-stage,
variable geometry turbocharging with higher intake boost pressure
available across a broader range of engine operation than conventional
turbocharged SI engines. Such a system is estimated to be capable of an
additional 3 to 5 percent effectiveness relative to a turbocharged,
downsized GDI engine without cooled-EGR. The agencies have also
considered a more advanced version of such a cooled EGR system that
employs very high combustion pressures by using dual stage
turbocharging.
(ix) Lean-Burn Combustion
The agencies considered the concept that gasoline engines that are
normally stoichiometric mainly for emission reasons can run lean over a
range of operating conditions and utilize diesel like aftertreatment
systems to control NOX. For this analysis, we determined
that the modal operation nature of this technology is currently only
beneficial at light loads and will not be appropriate for a heavy duty
application purchase specifically for its high work and load capacity.
(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.\479\ 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.
---------------------------------------------------------------------------
\479\ 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 could be improved during the
timeframe of this final rule. 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 may result in a reduction in the amount of fuel used in
the process. However, due to uncertainties with these improvements
regarding the extent of current optimization and future criteria
emissions obligations, the agencies are not considering aftertreatment
improvements as a fuel-saving technology in the rulemaking analysis.
(ii) Engine Improvements
Diesel engines in the HD pickup and van segment are expected to
have several improvements in their base design in the 2021-2027
timeframe. These improvements include items such as improved combustion
management, optimal turbocharger design, and improved thermal
management.
(c) Transmission Technologies
The agencies have also reviewed the transmission technology
estimates used in the 2017-2015 light-duty and 2014-2018 heavy-duty
final rules. In doing so, NHTSA and EPA considered or reconsidered all
available sources including the 2015 NHTSA Technology Study and updated
the estimates as appropriate. The section below describes each of the
transmission technologies considered for this rule.
(i) Automatic 8-Speed Transmissions
Manufacturers can also choose to replace 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 gear sets are added, additional
weight and friction are introduced requiring additional countermeasures
to offset these losses. Some manufacturers are replacing 6-speed
automatics already, and 7 to 10-speed automatics have entered
production.
(ii) High Efficiency Transmission
For this rule, a high efficiency transmission refers to some or all
of a suite of incremental transmission improvement technologies that
should be available within the 2019 to 2027 timeframe. The majority of
these improvements address mechanical friction within the transmission.
These improvements include but are not limited to: Shifting clutch
technology improvements, improved kinematic design, dry sump
lubrication systems, more efficient seals, bearings and clutches
(reducing drag), component superfinishing and improved transmission
lubricants.
(iii) Secondary Axle Disconnect
The ability to disconnect some of the rotating components in the
front axle on 4wd vehicles when the secondary axle is not needed for
traction. This will reduce friction and increase fuel economy.
[[Page 73751]]
(d) Electrification/Accessory Technologies
(i) Electrical Power Steering or Electrohydraulic Power Steering
Electric power steering (EPS) or Electrohydraulic power steering
(EHPS) provides a potential reduction in CO2 emissions and
fuel consumption over hydraulic power steering because of reduced
overall accessory loads. This eliminates the parasitic losses
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.
(ii) Improved Accessories
The accessories on an engine, including the alternator, coolant and
oil pumps are traditionally mechanically-driven. A reduction in
CO2 emissions and fuel consumption can be realized by
driving them electrically, and only when needed (``on-demand'').
Electric water pumps and electric fans can provide better control
of engine cooling. For example, coolant flow from an electric water
pump can be reduced and the radiator fan can be shut off during engine
warm-up or cold ambient temperature conditions which will reduce warm-
up time, reduce warm-up fuel enrichment, and reduce parasitic losses.
Indirect benefit may be obtained by reducing the flow from the
water pump electrically during the engine warm-up period, allowing the
engine to heat more rapidly and thereby reducing the fuel enrichment
needed during cold operation and warm-up of the engine. Faster oil
warm-up may also result from better management of the coolant warm-up
period. Further benefit may be obtained when electrification is
combined with an improved, higher efficiency engine alternator used to
supply power to the electrified accessories.
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.\480\ However, towing vehicles tend to have large cooling system
capacity and flow scaled to required heat rejection levels when under
full load situations such as towing at GCWR in extreme ambient
conditions. During almost all other situations, this design
characteristic may result in unnecessary energy usage for coolant
pumping and heat rejection to the radiator.
---------------------------------------------------------------------------
\480\ In the CAFE model, improved accessories refers solely to
improved engine cooling.
---------------------------------------------------------------------------
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.
(iii) Mild Hybrid
Mild hybrid systems offer idle-stop functionality and a limited
level of regenerative braking and power assist. These systems replace
the conventional alternator with a belt or crank driven starter/
alternator and may add high voltage electrical accessories (which may
include electric power steering and an auxiliary automatic transmission
pump). The limited electrical requirements of these systems allow the
use of lead-acid batteries or supercapacitors for energy storage, or
the use of a small lithium-ion battery pack.
(iv) Strong Hybrid
A hybrid vehicle is a vehicle that combines two significant sources
of propulsion energy, where one uses a consumable fuel (like gasoline),
and one is rechargeable (during operation, or by another energy
source). Hybrid technology is well established in the U.S. light-duty
market and more manufacturers are adding hybrid models to their
lineups. Hybrids reduce fuel consumption through three major
mechanisms:
The internal combustion engine can be optimized (through
downsizing, modifying the operating cycle, or other control techniques)
to operate at or near its most efficient point more of the time. Power
loss from engine downsizing can be mitigated by employing power assist
from the secondary power source.
A significant amount of the energy normally lost as heat
while braking can be captured and stored in the energy storage system
for later use.
The engine is turned off when it is not needed, such as
when the vehicle is coasting or when stopped.
Hybrid vehicles utilize some combination of the three above
mechanisms to reduce fuel consumption and CO2 emissions. The
effectiveness of fuel consumption and CO2 reduction depends
on the utilization of the above mechanisms and how aggressively they
are pursued. One area where this variation is particularly prevalent is
in the choice of engine size and its effect on balancing fuel economy
and performance. Some manufacturers choose not to downsize the engine
when applying hybrid technologies. In these cases, overall performance
(acceleration) is typically improved beyond the conventional engine.
However, fuel efficiency improves less than if the engine was downsized
to maintain the same performance as the conventional version. The non-
downsizing approach is used for vehicles like trucks where towing and/
or hauling are an integral part of their performance requirements. In
these cases, if the engine is downsized, the battery can be quickly
drained during a long hill climb with a heavy load, leaving only a
downsized engine to carry the entire load. Because towing capability is
currently a heavily-marketed truck attribute, manufacturers are
hesitant to offer a truck with a downsized engine, which can lead to a
significantly diminished towing performance when the battery state of
charge level is low, and therefore engines are traditionally not
downsized for these vehicles. In assessing the cost of this technology,
the agencies consequently assumed the cost of a full size engine.
Strong Hybrid technology utilizes an axial electric motor connected
to the transmission input shaft and connected to the engine crankshaft
through a clutch. The axial motor is a motor/generator that can provide
sufficient torque for launch assist, all electric operation, and the
ability to recover significant levels of braking energy.
(e) Vehicle Technologies
(i) Mass Reduction
Mass reduction is a technology that can be used in a manufacturer's
strategy to meet the Heavy Duty Greenhouse Gas Phase 2 standards.
Vehicle mass reduction (also referred to as ``down-weighting'' or
``light-weighting''), decreases fuel consumption and GHG emissions by
reducing the energy demand needed to overcome inertia forces, and
rolling resistance. Automotive companies have worked with mass
reduction technologies for many years and a lot of these technologies
have been used in production vehicles. The weight savings achieved by
adopting mass reduction technologies offset weight gains due to
increased vehicle size, larger powertrains, and increased feature
content (sound insulation,
[[Page 73752]]
entertainment systems, improved climate control, panoramic roof, etc.).
Sometimes mass reduction has been used to increase vehicle towing and
payload capabilities.
Manufacturers employ a systematic approach to mass reduction, where
the net mass reduction is the addition of a direct component or system
mass reduction, also referred to as primary mass reduction, plus the
additional mass reduction taken from indirect ancillary systems and
components, also referred to as secondary mass reduction or mass
compounding. There are more secondary mass reductions achievable for
light-duty vehicles compared to heavy-duty vehicles, which are limited
due to the higher towing and payload requirements for these vehicles.
Mass reduction can be achieved through a number of approaches, even
while maintaining other vehicle functionalities. As summarized by NAS
in its 2011 light duty vehicle report,\481\ there are two key
strategies for primary mass reduction: (1) Changing the design to use
less material; (2) substituting lighter materials for heavier
materials.
---------------------------------------------------------------------------
\481\ Committee on the Assessment of Technologies for Improving
Light-Duty Vehicle Fuel Economy; National Research Council,
``Assessment of Fuel Economy Technologies for Light-Duty Vehicles,''
2011. Available at http://www.nap.edu/catalog.php?record_id=12924
(last accessed Jun 27, 2012).
---------------------------------------------------------------------------
The first key strategy of using less material compared to the
baseline component can be achieved by optimizing the design and
structure of vehicle components, systems and vehicle structure. Vehicle
manufacturers have long used these continually-improving CAE tools to
optimize vehicle designs. For example, the Future Steel Vehicle (FSV)
project \482\ sponsored by WorldAutoSteel used three levels of
optimization: Topology optimization, low fidelity 3G (Geometry Grade
and Gauge) optimization, and subsystem optimization, to achieve 30
percent mass reduction in the body structure of a vehicle with a mild
steel unibody structure. Using less material can also be achieved
through improving the manufacturing process, such as by using improved
joining technologies and parts consolidation. This method is often used
in combination with applying new materials.
---------------------------------------------------------------------------
\482\ SAE World Congress, ``Focus B-pillar `tailor rolled' to 8
different thicknesses,'' Feb. 24, 2010. Available at http://www.sae.org/mags/AEI/7695 (last accessed Jun. 10, 2012).
---------------------------------------------------------------------------
The second key strategy to reduce mass of an assembly or component
involves the substitution of lower density and/or higher strength
materials. Material substitution includes replacing materials, such as
mild steel, with higher-strength and advanced steels, aluminum,
magnesium, and composite materials. In practice, material substitution
tends to be quite specific to the manufacturer and situation. Some
materials work better than others for particular vehicle components,
and a manufacturer may invest more heavily in adjusting to a particular
type of advanced material, thus complicating its ability to consider
others. The agencies recognize that like any type of mass reduction,
material substitution has to be conducted not only with consideration
to maintaining equivalent component strength, but also to maintaining
all the other attributes of that component, system or vehicle, such as
crashworthiness, durability, and noise, vibration and harshness (NVH).
If vehicle mass is reduced sufficiently through application of the
two primary strategies of using less material and material substitution
described above, secondary mass reduction options may become available.
Secondary mass reduction is enabled when the load requirements of a
component are reduced as a result of primary mass reduction. If the
primary mass reduction reaches a sufficient level, a manufacturer may
use a smaller, lighter, and potentially more efficient powertrain while
maintaining vehicle acceleration performance. If a powertrain is
downsized, a portion of the mass reduction may be attributed to the
reduced torque requirement which results from the lower vehicle mass.
The lower torque requirement enables a reduction in engine
displacement, changes to transmission torque converter and gear ratios,
and changes to final drive gear ratio. The reduced powertrain torque
enables the downsizing and/or mass reduction of powertrain components
and accompanying reduced rotating mass (e.g., for transmission,
driveshafts/halfshafts, wheels, and tires) without sacrificing
powertrain durability. Likewise, the combined mass reductions of the
engine, drivetrain, and body in turn reduce stresses on the suspension
components, steering components, wheels, tires, and brakes, which can
allow further reductions in the mass of these subsystems. Reducing the
un-sprung masses such as the brakes, control arms, wheels, and tires
further reduce stresses in the suspension mounting points, which will
allow for further optimization and potential mass reduction. However,
pickup trucks have towing and hauling requirements which must be taken
into account when determining the amount of secondary mass reduction
that is possible and so it is less than that of passenger cars.
In 2015, EPA completed a multi-year study with FEV North America,
Inc. on the lightweighting of a light-duty pickup truck, a 2011 GMC
Silverado, titled ``Mass Reduction and Cost Analysis--Light-Duty Pickup
Trucks Model Years 2020-2025.'' \483\ Results contain a cost curve for
various mass reduction percentages with the main solution being
evaluated for a 20.8 percent (510 kg/1122 lb.) mass reduction resulting
in an increased direct incremental manufacturing cost of $2228. In
addition, the report outlines the compounding effect that occurs in a
vehicle with performance requirements including hauling and towing.
Secondary mass evaluation was performed on a component level based on
an overall 20 percent vehicle mass reduction. Results revealed 84 kg of
the 510 kg, or 20 percent of the overall mass reduction, were from
secondary mass reduction. Information on this study is summarized in
SAE paper 2015-01-0559. NHTSA has also sponsored an on-going pickup
truck lightweighting project. This project uses a more recent baseline
vehicle, a MY 2014 GMC Silverado, and the project will be finished in
2016. Both projects will be utilized for the light-duty GHG and CAFE
Midterm Evaluation mass reduction baseline characterization and may be
used to update assumptions of mass reduction for HD pickups and vans
for the final Phase 2 rulemaking.
---------------------------------------------------------------------------
\483\ ``Mass Reduction and Cost Analysis--Light-Duty Pickup
Trucks Model Years 2020-2025,'' FEV, North America, Inc., April
2015, Document no. EPA-420-R-15-006.
---------------------------------------------------------------------------
In order to determine if technologies identified on light duty
trucks are applicable to heavy-duty pickups, EPA contracted with FEV
North America, Inc. to perform a scaling study in order to evaluate
whether the technologies identified for the light-duty truck would be
applicable for a heavy-duty pickup truck. In this study a 2013MY
Silverado 2500, a 2007 Mercedes Sprinter and a 2010 Renault Master
\484\ were analyzed. A 2013MY Silverado 2500 was purchased and torn
down. The mass reduction results were 18.9 percent mass reduction at a
cost of $2,372 and focused on aluminum intensive with AHSS frame. The
Mercedes Sprinter and Renault Master analyses were performed based on
information from the A2Mac1 database. The results were 18.15 percent
mass reduction at a cost add of $2,293 for the Mercedes Sprinter
[[Page 73753]]
and 18.55 percent mass reduction at a cost add of $2,293 for the
Master.
---------------------------------------------------------------------------
\484\ ``Mass Reduction and Cost Analysis Heavy Duty Pickup Truck
and Light Commercial Vans,'' 2016, EPA-420-D-16-003.
---------------------------------------------------------------------------
In September 2015, Ford announced that its MY 2017 F-Series Super
duty pickup (F250) would be manufactured with an aluminum body and
overall the truck will be 350 lbs. lighter (5 percent-6 percent) than
the current generation truck with steel.485 486 This is less
overall mass reduction than the resultant lightweighting effort on the
MY 2015 F-150, which achieved up to 750 lb. decrease in curb weight (12
percent-13 percent) per vehicle.\487\ Strategies were employed by Ford
in the F250 to ``improve the productivity of the Super Duty.'' In
addition, Ford added several safety systems (and consequent mass)
including cameras, lane departure warning, brake assist, etc. More
details on the F250 will be known once it is released; however, a
review of the F150 vehicle aluminum intensive design shows that it has
an aluminum cab structure, body panels, and suspension components, as
well as a high strength steel frame and a smaller, lighter and more
efficient engine. The Executive Summary to Ducker Worldwide's 2014
report \488\ states that the MY 2015 F-150 contains 1080 lbs. of
aluminum with at least half being aluminum sheet and extrusions for
body and closures. Ford's engine range for its light duty truck fleet
includes a 2.7L EcoBoost V-6. The integrated loop, between Ford and the
aluminum sheet suppliers, of aluminum manufacturing scrap and new
aluminum sheet is integral to making aluminum a feasible lightweighting
technology option for Ford. It is also possible that the strategy of
aluminum body panels will be applied to the heavy duty F-350 version
when it is redesigned.\489\
---------------------------------------------------------------------------
\485\ http://www.techtimes.com/articles/87961/20150925/ford-s-2017-f-250-super-duty-with-an-aluminum-body-is-the-toughest-smartest-and-most-capable-super-duty-ever.htm, September 25, 2015.
\486\ https://www.ford.com/trucks/superduty/2017/ 2017/.
\487\ ``2008/9 Blueprint for Sustainability,'' Ford Motor
Company. Available at: http://www.ford.com/go/sustainability (last
accessed February 8, 2010).
\488\ ``2015 North American Light Vehicle Aluminum Content
Study--Executive Summary,'' June 2014, http://www.drivealuminum.org/research-resources/PDF/Research/2014/2014-ducker-report (last
accessed February 26, 2015).
\489\ http://www.foxnews.com/leisure/2014/09/30/ford-confirms-increased-aluminum-use-on-next-gen-super-duty-pickups/.
---------------------------------------------------------------------------
The RIA for this rulemaking shows that 10 percent or less mass
reduction is part of the projected strategy for compliance for HD
pickups and vans. The cost and effectiveness assumptions for mass
reduction technology are described in the RIA.
(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 will 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 will generally be accompanied with
additional changes to suspension tuning and/or suspension design.
(iii) Aerodynamic Drag Reduction
Many factors affect a vehicle's aerodynamic drag and the resulting
power required to move it through the air. While these factors change
with air density and the square and cube of vehicle speed,
respectively, the overall drag effect is determined by the product of
its frontal area and drag coefficient, Cd. Reductions in these
quantities can therefore reduce fuel consumption and CO2
emissions. Although frontal areas tend to be relatively similar within
a vehicle class (mostly due to market-competitive size requirements),
significant variations in drag coefficient can be observed. Significant
changes to a vehicle's aerodynamic performance may need to be
implemented during a redesign (e.g., changes in vehicle shape).
However, shorter-term aerodynamic reductions, with a somewhat lower
effectiveness, may be achieved through the use of revised exterior
components (typically at a model refresh in mid-cycle) and add-on
devices that currently being applied. The latter list will 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.
(f) Air Conditioning Technologies
These technologies include improved hoses, connectors and seats 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.\490\
---------------------------------------------------------------------------
\490\ See RIA Chapter 2.3 for more detailed technology
descriptions.
---------------------------------------------------------------------------
(5) How did the agencies determine the costs and effectiveness of each
of these technologies?
Building on the technical analysis underlying the 2017-2025 MY
light-duty vehicle rule, the 2014-2018 MY heavy-duty vehicle rule, and
the 2015 NHTSA Technology Study, the agencies took a fresh look at
technology cost and effectiveness values for purposes of this rule. 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 the agencies in the light-duty rule as well as referencing
costs from the 2014-2018 MY heavy-duty vehicle rule and a new cost
survey performed by Tetra Tech in 2014.
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.\491\
---------------------------------------------------------------------------
\491\ 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 2012 dollars, and indirect costs were accounted
for using a methodology consistent with the new ICM approach developed
by EPA and used in the Phase 1 rule, and the 2012-2016 and 2017-2025
light-duty rules. 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. We present the individual technology
costs used in this analysis in Chapter 2.11 of the RIA.
[[Page 73754]]
Regarding estimates for technology effectiveness, the agencies used
the estimates from the 2014 Southwest Research Institute study as a
baseline, which was designed specifically to inform this rulemaking. In
addition, the agencies used 2017-2025 light-duty rule as a reference,
and adjusted these estimates 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
lbs. 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 compliance data, and confidential manufacturer estimates of
technology effectiveness. The agencies reviewed effectiveness
information from the multiple sources for each technology and ensured
that such effectiveness estimates were based on technology hardware
consistent with the BOM components used to estimate costs. Together,
the agencies compared the multiple estimates and assessed their
validity, taking care to ensure that common BOM definitions and other
vehicle attributes such as performance and drivability were taken into
account.
The agencies note that the effectiveness values estimated for the
technologies may represent average values applied to the baseline fleet
described earlier, and do not reflect the potentially limitless
spectrum of possible values that could result from adding the
technology to different vehicles. For example, while the agencies have
estimated an effectiveness of 0.5 percent for low friction lubricants,
each vehicle could have a unique effectiveness estimate depending on
the baseline vehicle's oil viscosity rating. Similarly, the reduction
in rolling resistance (and thus the improvement in fuel efficiency and
the reduction in CO2 emissions) due to the application of
LRR tires depends not only on the unique characteristics of the tires
originally on the vehicle, but on the unique characteristics of the
tires being applied, characteristics which must be balanced between
fuel efficiency, safety, and performance. Aerodynamic drag reduction is
much the same--it can improve fuel efficiency and reduce CO2
emissions, but it is also highly dependent on vehicle-specific
functional objectives. For purposes of this final rule, the agencies
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 assessment of the technology effectiveness and costs was
determined from a combination of sources. First an assessment was
performed by SwRI under contract with the agencies to determine the
effectiveness and costs on several technologies that were generally not
considered in the Phase 1 GHG rule time frame. Some of the technologies
were common with the light-duty assessment but the effectiveness and
costs of individual technologies were appropriately adjusted to match
the expected effectiveness and costs when implemented in a heavy-duty
application. Finally, the agencies performed extensive outreach to
suppliers of engine, transmission and vehicle technologies applicable
to heavy-duty applications to get industry input on cost and
effectiveness of potential GHG and fuel consumption reducing
technologies. The agencies did not receive comments disputing the
expected technology effectiveness values or costs developed with input
from industry.
To achieve the levels of the Phase 2 standards for gasoline and
diesel powered heavy-duty vehicles, a combination of the technologies
previously discussed will be required respective to unique gasoline and
diesel technologies and their challenges. 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 will be expected, the available test
data show that some vehicle models will not need the full complement of
available technologies to achieve these 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 pickups and vans are shown in Table VI-4.
These costs reflect direct and indirect costs to the vehicle
manufacturer for the 2021 model year. See Chapter 2.11. of the RIA for
a more complete description of the basis of these costs.
Table VI-4--Technology Costs for HD Pickups & Vans Inclusive of Indirect
Cost Markups for MY 2021
[2012$]
------------------------------------------------------------------------
Technology Gasoline Diesel
------------------------------------------------------------------------
Engine changes to accommodate low 6 6
friction lubes.........................
Engine friction reduction--level 1...... 116 116
Engine friction reduction--level 2...... 254 254
Dual cam phasing........................ 183 183
Cylinder deactivation................... 196 N/A
Stoichiometric gasoline direct injection 451 N/A
Turbo improvements...................... N/A 16
Cooled EGR.............................. 373 373
Turbocharging & downsizing \a\.......... 671 N/A
``Right-sized'' diesel from larger N/A 0
diesel.................................
8s automatic transmission (increment to 457 457
6s automatic transmission).............
Improved accessories--level 1........... 82 82
Improved accessories--level 2........... 132 132
Low rolling resistance tires--level 1... 10 10
Passive aerodynamic improvements (aero 51 51
1).....................................
Passive plus Active aerodynamic 230 230
improvements (aero 2)..................
Electric (or electro/hydraulic) power 151 151
steering...............................
Mass reduction (10% on a 6500 lb 318 318
vehicle)...............................
Driveline friction reduction............ 139 139
Stop-start (no regenerative braking).... 539 539
Mild HEV................................ 2730 2730
[[Page 73755]]
Strong HEV, without inclusion of any 6779 6779
engine changes.........................
------------------------------------------------------------------------
Note:
\a\ Cost to downsize from a V8 OHC to a V6 OHC engine with twin turbos.
As explained above, the CAFE model works by adding technologies in
an incremental fashion to each particular vehicle in a manufacturer's
fleet until that fleet complies with the imposed standards. It does
this by following a predefined set of decision trees whereby the
particular vehicle is placed on the appropriate decision tree and it
follows the predefined progression of technology available on that
tree. At each step along the tree, a decision is made regarding the
cost of a given technology relative to what already exists on the
vehicle along with the fuel consumption improvement it provides
relative to the fuel consumption at the current location on the tree,
prior to deciding whether to take that next step on the tree or remain
in the current location. Because the model works in this way, the input
files must be structured to provide costs and effectiveness values for
each technology relative to whatever technologies have been added in
earlier steps along the tree. Table VI-5 presents the cost and
effectiveness values used in the CAFE model input files.
Table VI-5--CAFE Model Input Values for Cost & Effectiveness for Given Technologies \a\
----------------------------------------------------------------------------------------------------------------
Incremental cost (2012$) a b c
Technology FC savings (%) -----------------------------------------------
2021 2025 2027
----------------------------------------------------------------------------------------------------------------
Improved Lubricants and Engine Friction 1.60 24 24 23
Reduction......................................
Coupled Cam Phasing (SOHC)...................... 3.82 48 43 39
Dual Variable Valve Lift (SOHC)................. 2.47 42 37 34
Cylinder Deactivation (SOHC).................... 3.70 34 30 27
Intake Cam Phasing (DOHC)....................... 0.00 48 43 39
Dual Cam Phasing (DOHC)......................... 3.82 46 40 37
Dual Variable Valve Lift (DOHC)................. 2.47 42 37 34
Cylinder Deactivation (DOHC).................... 3.70 34 30 27
Stoichiometric Gasoline Direct Injection (OHC).. 0.50 71 61 56
Cylinder Deactivation (OHV)..................... 3.90 216 188 172
Variable Valve Actuation (OHV).................. 6.10 54 47 43
Stoichiometric Gasoline Direct Injection (OHV).. 0.50 71 61 56
Engine Turbocharging and Downsizing
Small Gasoline Engines...................... 8.00 518 441 407
Medium Gasoline Engines..................... 8.00 -12 -62 -44
Large Gasoline Engines...................... 8.00 623 522 456
Cooled Exhaust Gas Recirculation................ 3.04 382 332 303
Cylinder Deactivation on Turbo/downsized Eng.... 1.70 33 29 26
Lean-Burn Gasoline Direct Injection............. 4.30 1,758 1,485 1,282
Improved Diesel Engine Turbocharging............ 2.51 22 19 18
Engine Friction & Parasitic Reduction
Small Diesel Engines........................ 3.50 269 253 213
Medium Diesel Engines....................... 3.50 345 325 273
Large Diesel Engines........................ 3.50 421 397 334
Downsizing of Diesel Engines (V6 to I-4)........ 11.10 0 0 0
8-Speed Automatic Transmission \d\.............. 5.00 482 419 382
Electric Power Steering......................... 1.00 160 144 130
Improved Accessories (Level 1).................. 0.93 93 83 75
Improved Accessories (Level 2).................. 0.93 57 54 46
Stop-Start System............................... 1.10 612 517 446
Integrated Starter-Generator.................... 3.20 1,040 969 760
Strong Hybrid Electric Vehicle.................. 17.20 3,038 2,393 2,133
Mass Reduction (5%)............................. 1.50 0.28 0.24 0.21
Mass Reduction (additional 5%).................. 1.50 0.87 0.75 0.66
Reduced Rolling Resistance Tires................ 1.10 10 9 9
Low-Drag Brakes................................. 0.40 106 102 102
Driveline Friction Reduction.................... 0.50 153 137 124
Aerodynamic Improvements (10%).................. 0.70 58 52 47
Aerodynamic Improvements (add'l 10%)............ 0.70 193 182 153
----------------------------------------------------------------------------------------------------------------
Notes:
\a\ Values for other model years available in CAFE model input files available at NHTSA Web site.
\b\ For mass reduction, cost reported on mass basis (per pound of curb weight reduction).
\c\ The model output has been adjusted to 2013$.
\d\ 8-speed automatic transmission costs include costs for high efficiency gearbox and aggressive shift logic
whereas those costs were kept separate in prior analyses.
[[Page 73756]]
In addition to the base technology cost and effectiveness inputs
described above, the CAFE model accommodates inputs to adjust
accumulated effectiveness under circumstances when combining multiple
technologies could result in underestimation or overestimation of total
incremental effectiveness relative to an ``unevolved'' baseline
vehicle. These so-called synergy factors may be positive, where the
combination of the technologies results in greater improvement than the
additive improvement of each technology, or negative, where the
combination of the technologies is lower than the additive improvement
of each technology. The synergy factors used in the NPRM and Method B
of the FRM are described in Table VI-6 Method A of the FRM uses
synergies derived from a simulation project NHTSA undertook with
Autnomie Argonne National Lab. A description of these changes is given
in Section D.(8).
Table VI-6--Technology Pair Effectiveness Synergy Factors for HD Pickups and Vans
----------------------------------------------------------------------------------------------------------------
Adjustment Adjustment
Technology pair (%) Technology pair (%)
----------------------------------------------------------------------------------------------------------------
8SPD/CCPS..................................... -4.60 IATC/CCPS....................... -1.30
8SPD/DEACO.................................... -4.60 IATC/DEACO...................... -1.30
8SPD/ICP...................................... -4.60 IATC/ICP........................ -1.30
8SPD/TRBDS1................................... 4.60 IATC/TRBDS1..................... 1.30
AERO2/SHEV1................................... 1.40 MR1/CCPS........................ 0.40
CCPS/IACC1.................................... -0.40 MR1/DCP......................... 0.40
CCPS/IACC2.................................... -0.60 MR1/VVA......................... 0.40
DCP/IACC1..................................... -0.40 MR2/ROLL1....................... -0.10
DCP/IACC2..................................... -0.60 MR2/SHEV1....................... -0.40
DEACD/IATC.................................... -0.10 NAUTO/CCPS...................... -1.70
DEACO/IACC2................................... -0.80 NAUTO/DEACO..................... -1.70
DEACO/MHEV.................................... -0.70 NAUTO/ICP....................... -1.70
DEACS/IATC.................................... -0.10 NAUTO/SAX....................... -0.40
DTURB/IATC.................................... 1.00 NAUTO/TRBDS1.................... 1.70
DTURB/MHEV.................................... -0.60 ROLL1/AERO1..................... 0.10
DTURB/SHEV1................................... -1.00 ROLL1/SHEV1..................... 1.10
DVVLD/8SPD.................................... -0.60 ROLL2/AERO2..................... 0.20
DVVLD/IACC2................................... -0.80 SHFTOPT/MHEV.................... -0.30
DVVLD/IATC.................................... -0.60 TRBDS1/MHEV..................... 0.80
DVVLD/MHEV.................................... -0.70 TRBDS1/SHEV1.................... -3.30
DVVLS/8SPD.................................... -0.60 TRBDS1/VVA...................... -8.00
DVVLS/IACC2................................... -0.80 TRBDS2/EPS...................... -0.30
DVVLS/IATC.................................... -0.50 TRBDS2/IACC2.................... -0.30
DVVLS/MHEV.................................... -0.70 TRBDS2/NAUTO.................... -0.50
.............. VVA/IACC1....................... -0.40
.............. VVA/IACC2....................... -0.60
.............. VVA/IATC........................ -0.60
----------------------------------------------------------------------------------------------------------------
The CAFE model also accommodates inputs to adjust accumulated
incremental costs under circumstances when the application sequence
could result in underestimation or overestimation of total incremental
costs relative to an ``unevolved'' baseline vehicle. For today's
analysis, the agencies have applied one such adjustment, increasing the
cost of medium-sized gasoline engines by $513 in cases where
turbocharging and engine downsizing is applied with variable valve
actuation.
The analysis performed using Method A also applied cost inputs to
address some costs encompassed neither by the agencies' estimates of
the direct cost to apply these technologies, nor by the agencies'
methods for ``marking up'' these costs to arrive at increases in the
new vehicle purchase costs. To account for the additional costs that
could be incurred if a technology is applied and then quickly replaced,
the CAFE model accommodates inputs specifying a ``stranded capital
cost'' specific to each technology. For this analysis, the model was
run with inputs to apply about $78 of additional cost (per engine) if
gasoline engine turbocharging and downsizing (separately for each
``level'' considered) is applied and then immediately replaced,
declining steadily to zero by the tenth model year following initial
application of the technology. The model also accommodates inputs
specifying any additional changes owners might incur in maintenance and
post-warranty repair costs. For this analysis, the model was run with
inputs indicating that vehicles equipped with less rolling-resistant
tires could incur additional tire replacement costs equivalent to $21-
$23 (depending on model year) in additional costs to purchase the new
vehicle. The agencies did not, however, include inputs specifying any
potential changes repair costs that might accompany application of any
of the above technologies. A sensitivity analysis using Method A,
discussed below, includes a case in which repair costs are estimated
using factors consistent with those underlying the indirect cost
multipliers used to markup direct costs for the agencies' central
analysis.
(6) Regulatory Alternatives Considered by the Agencies
As discussed above, the model considers regulatory alternatives.
The results of regulatory alternatives are considered relative to a
``no action'' alternative where existing standards persist, but no
further regulatory action is taken (in this case the MY 2018 standards
from Phase I are the last regulatory action taken). The agencies also
considered four regulatory alternatives. The preferred alternative with
a standard that increases 2.5 percent in stringency annually for MY's
2021-2027, and three others with annual increases in stringency of: 2.0
percent, 3.5 percent, and 4.0 percent for MY's 2021-2025. For each of
the ``action alternatives'' (i.e., those involving stringency increases
beyond the no-action alternative), the annual
[[Page 73757]]
stringency increases are applied as follows: An annual stringency
increase of r is applied by multiplying the model year 2020 target
functions (identical to those applicable to model year 2018) by 1-r to
define the model year 2021 target functions, multiplying the model year
2021 target functions by 1-r to define the model year 2022 target
functions, continuing through 2025 for all alternatives except for the
preferred Alternative 3 which extends through 2027. In summary, the
agencies have considered the following five regulatory alternatives in
the CAFE model.
Table VI-7--Considered Regulatory Alternatives
----------------------------------------------------------------------------------------------------------------
Annual stringency increase
Regulatory alternative --------------------------------------------------------------------------
2019-2020 2021-2025 2026-2027
----------------------------------------------------------------------------------------------------------------
1: No Action......................... None................... None................... None.
2: 2.0%/y............................ None................... 2.0%................... None.
3: 2.5%/y............................ None................... 2.5%................... 2.5%
4: 3.5%/y............................ None................... 3.5%................... None.
5: 4.0%/y............................ None................... 4.0%................... None.
----------------------------------------------------------------------------------------------------------------
(7) NPRM Modifications of the Model
The NPRM analysis (and the current analysis) reflect several
changes made to the model since 2012, when NHTSA used the model to
estimate the effects, costs, and benefits of final CAFE standards for
light-duty vehicles produced during MYs 2017-2021, and augural
standards for MYs 2022-2025. Some of these changes specifically enable
analysis of potential fuel consumption standards (and, hence,
CO2 emissions standards harmonized with fuel consumption
standards) for heavy-duty pickups and vans; other changes implement
more general improvements to the model. Key changes include the
following:
Changes to accommodate standards for heavy-duty pickups
and vans, including attribute-based standards involving targets that
vary with ``work factor.''
Explicit calculation of test weight, taking into account
test weight ``bins'' and differences in the definition of test weight
for light-duty vehicles (curb weight plus 300 pound) and heavy-duty
pickups and vans (average of GVWR and curb weight).
Procedures to estimate increases in payload when curb
weight is reduced, increases in towing capacity if GVWR is reduced, and
calculation procedures to correspondingly update calculated work
factors.
Expansion of model inputs, procedures, and outputs to
accommodate technologies not included in prior analyses.
Changes to the algorithm used to apply technologies,
enabling more explicit accounting for shared vehicle platforms and
adoption and ``inheritance'' of major engine changes.
These changes are reflected in updated model documentation
available at NHTSA's Web site, the documentation also providing more
information about the model's purpose, scope, structure, design,
inputs, operation, and outputs. The agencies invited but did not
receive comments on the CAFE model used for the NPRM analysis and used
in this final rule for the Method B analysis.
(a) Product Cadence
Past comments on the CAFE model have stressed the importance of
product cadence--i.e., the development and periodic redesign and
freshening of vehicles--in terms of involving technical, financial, and
other practical constraints on applying new technologies, and NHTSA has
steadily made changes to the model with a view toward accounting for
these considerations. For example, early versions of the model added
explicit ``carrying forward'' of applied technologies between model
years, subsequent versions applied assumptions that most technologies
would be applied when vehicles are freshened or redesigned, and more
recent versions applied assumptions that manufacturers would sometimes
apply technology earlier than ``necessary'' in order to facilitate
compliance with standards in ensuing model years. Thus, for example, if
a manufacturer is expected to redesign many of its products in model
years 2018 and 2023, and the standard's stringency increases
significantly in model year 2021, the CAFE model will estimate the
potential that the manufacturer will add more technology than necessary
for compliance in MY 2018, in order to carry those product changes
forward through the next redesign and contribute to compliance with the
MY 2021 standard.
The model also accommodates estimates of overall limits (expressed
as ``phase-in caps'' in model inputs) on the rates at which
manufacturers' may practicably add technology to their respective
fleets. So, for example, even if a manufacturer is expected to redesign
half of its production in MY 2016, if the manufacturer is not already
producing any strong hybrid electric vehicles (SHEVs), a phase-in cap
can be specified in order to assume that manufacturer will stop
applying SHEVs in MY 2016 once it has done so to at least 3 percent of
its production in that model year.
After the light-duty rulemaking analysis accompanying the 2012
final rule regarding post-2016 CAFE standards and related GHG emissions
standards, NHTSA staff began work on CAFE model changes expected to
better reflect additional considerations involved with product planning
and cadence. These changes, summarized below, interact with preexisting
model characteristics discussed above.
(b) Platforms and Technology
The term ``platform'' is used loosely in industry, but generally
refers to a common structure shared by a group of vehicle variants. The
degree of commonality varies, with some platform variants exhibiting
traditional ``badge engineering'' where two products are differentiated
by little more than insignias, while other platforms be used to produce
a broad suite of vehicles that bear little outer resemblance to one
another.
Given the degree of commonality between variants of a single
platform, manufacturers do not have complete freedom to apply
technology to a vehicle: while some technologies (e.g. low rolling
resistance tires) are very nearly ``bolt-on'' technologies, others
involve substantial changes to the structure and design of the vehicle,
and therefore necessarily are constant between vehicles that share a
common platform. NHTSA staff has, therefore, modified the CAFE model
such that all mass reduction and aero technologies are forced to be
constant between variants of a platform. The agencies requested but did
not receive comment on the suitability of this viewpoint, and
[[Page 73758]]
which technologies can deviate from one platform variant to another.
Within the analysis fleet, each vehicle is associated with a
specific platform. As the CAFE model applies technology, it first
defines a platform ``leader'' as the vehicle variant of a platform with
the highest technology utilization vehicle of mass reduction and
aerodynamic technologies. As the vehicle applies technologies, it
effectively harmonizes to the highest common denominator of the
platform. If there is a tie, the CAFE model begins applying aerodynamic
and mass reduction technology to the vehicle with the lowest average
sales across all available model years. If there remains a tie, the
model begins by choosing the vehicle with the highest average MSRP
across all available model years. The model follows this formulation
due to previous market trends suggesting that many technologies begin
deployment at the high-end, low-volume end of the market as
manufacturers build their confidence and capability in a technology,
and later expand the technology across more mainstream product lines.
In the HD pickup and van market, there is a relatively small amount
of diversity in platforms produced by manufacturers: Typically 1-2
truck platforms and 1-2 van platforms. However, accounting for
platforms will take on greater significance in future analyses
involving the light-duty fleet. The agency requested but did not
receive comments on the general use of platforms within CAFE
rulemaking.
(c) Engine and Transmission Inheritance
In practice, manufacturers are limited in the number of engines and
transmissions that they produce. Typically a manufacturer produces a
number of engines--perhaps six or eight engines for a large
manufacturer--and tunes them for slight variants in output for a
variety of car and truck applications. Manufacturers limit complexity
in their engine portfolio for much the same reason as they limit
complexity in vehicle variants: They face engineering manpower
limitations, and supplier, production and service costs that scale with
the number of parts produced.
In previous usage of the CAFE model, engines and transmissions in
individual models were allowed relative freedom in technology
application, potentially leading to solutions that would, if followed,
involve unaccounted-for costs associated with increased complexity in
the product portfolio. The lack of a constraint in this area allowed
the model to apply different levels of technology to the engine in each
vehicle at the time of redesign or refresh, independent of what was
done to other vehicles using a previously identical engine.
In the current version of the CAFE model, engines and transmissions
that are shared between vehicles must apply the same levels of
technology in all technologies dictated by engine or transmission
inheritance. This forced adoption is referred to as ``engine
inheritance'' in the model documentation.
As with platform-shared technologies, the model first chooses an
``engine leader'' among vehicles sharing the same engine. The leader is
selected first by the vehicle with the lowest average sales across all
available model years. If there is a tie, the vehicle with the highest
average MSRP across model years is chosen. The model applies the same
logic with respect to the application of transmission changes. As with
platforms, this is driven by the concept that vehicle manufacturers
typically deploy new technologies in small numbers prior to deploying
widely across their product lines.
(d) Interactions Between Regulatory Classes
Like earlier versions, the current CAFE model provides for
integrated analysis spanning different regulatory classes, accounting
both for standards that apply separately to different classes and for
interactions between regulatory classes. Light vehicle CAFE standards
are specified separately for passenger cars and light trucks. However,
there is considerable sharing between these two regulatory classes.
Some specific engines and transmissions are used in both passenger cars
and light trucks, and some vehicle platforms span these regulatory
classes. For example, some sport-utility vehicles are offered in 2WD
versions classified as passenger cars and 4WD versions classified as
light trucks. Integrated analysis of manufacturers' passenger car and
light truck fleets provides the ability to account for such sharing and
reduce the likelihood of finding solutions that could involve
impractical levels of complexity in manufacturers' product lines. In
addition, integrated analysis provides the ability to simulate the
potential that manufactures could earn CAFE credits by over complying
with one standard and use those credits toward compliance with the
other standard (i.e., to simulate credit transfers between regulatory
classes).
HD pickups and vans are regulated separately from light-duty
vehicles. While manufacturers cannot transfer credits between light-
duty and MDHD classes, there is some sharing of engineering and
technology between light-duty vehicles and HD pickups and vans. For
example, some passenger vans with GVWR over 8,500 lbs. are classified
as medium-duty passenger vehicles (MDPVs) and thus included in
manufacturers' light-duty truck fleets, while cargo vans sharing the
same nameplate are classified as HD vans.
(e) Phase-In Caps
The CAFE model retains the ability to use phase-in caps (specified
in model inputs) as proxies for a variety of practical restrictions on
technology application. Unlike vehicle-specific restrictions related to
redesign, refreshes or platforms/engines, phase-in caps constrain
technology application at the vehicle manufacturer level. They are
intended to reflect a manufacturer's overall resource capacity
available for implementing new technologies (such as engineering and
development personnel and financial resources), thereby ensuring that
resource capacity is accounted for in the modeling process.
In previous CAFE rulemakings, redesign/refresh schedules and phase-
in caps were the primary mechanisms to reflect an OEM's limited pool of
available resources during the rulemaking time frame and the years
leading up to the rulemaking time frame, especially in years where many
models may be scheduled for refresh or redesign. The newly-introduced
representation platform-, engine-, and transmission-related
considerations discussed above augment the model's preexisting
representation of redesign cycles and accommodation of phase-in caps.
Considering these new constraints, inputs for today's analysis de-
emphasize reliance on phase-in caps.
In the NPRM and Method B of the FRM application of the CAFE model,
phase-in caps are used only for the most advanced technologies included
in the analysis, i.e., SHEVs and lean-burn GDI engines, considering
that these technologies are most likely to involve implementation costs
and risks not otherwise accounted for in corresponding input estimates
of technology cost. For these two technologies, the agencies have
applied caps that begin at 3 percent (i.e., 3 percent of the
manufacturer's production) in MY 2017, increase at 3 percent annually
during the ensuing nine years (reaching 30 percent in the MY 2026), and
subsequently increasing at 5 percent annually for four years (reaching
50 percent in MY 2030). Note that the agencies did not feel that lean-
burn engines were feasible in the
[[Page 73759]]
timeframe of this rulemaking, so decided to reject any model runs where
they were selected. (In any case, due to the cost ineffectiveness of
this technology, it was never chosen). The agencies did not receive
comments specifically on this approach for phase-in caps. The agencies
received comments regarding the general feasibility of SHEVs in this
market segment, with some commenters commenting that SHEVs are not
feasible for HD pickups and vans. These comments are discussed in
Section C.8. While the agencies have retained the above approach for
SHEV phase-in caps, the agencies have conducted a sensitivity analysis
setting the SHEV caps at zero, showing that the Phase 2 standards are
feasible and appropriate without the use of SHEVs. This sensitivity
analysis is described in Section E.
For Method A of the NPRM the phase-in caps have been set to 100
percent, so that the model no longer relies on phase-in caps to limit
the early-year application of advanced technologies. This changes is
further described in the Method B of the FRM specific section below.
(f) Impact of Vehicle Technology Application Requirements
Compared to prior analyses of light-duty standards, these model
changes, along with characteristics of the HD pickup and van fleet
result in some changes in the broad characteristics of the model's
application of technology to manufacturers' fleets. First, since the
number of HD pickup and van platforms in a portfolio is typically
small, compliance with standards may appear especially ``lumpy''
(compared to previous applications of the CAFE model to the more highly
segmented light-duty fleet), with significant over compliance when
widespread redesigns precede stringency increases, and/or significant
application of carried-forward (aka ``banked'') credits.
Second, since the use of phase-in caps has been de-emphasized and
manufacturer technology deployment remains tied strongly to estimated
product redesign and freshening schedules, technology penetration rates
may jump more quickly as manufacturers apply technology to high-volume
products in their portfolio.
By design, restrictions that enforce commonality of mass reduction
and aerodynamic technologies on variants of a platform, and those that
enforce engine inheritance, will result in fewer vehicle-technology
combinations in a manufacturer's future modeled fleet. These
restrictions are expected to more accurately capture the true costs
associated with producing and maintaining a product portfolio.
(g) Accounting for Test Weight, Payload, and Towing Capacity
As mentioned above, NHTSA has also revised the CAFE model to
explicitly account for the regulatory ``binning'' of test weights used
to certify light-duty fuel economy and HD pickup and van fuel
consumption for purposes of evaluating fleet-level compliance with fuel
economy and fuel consumption standards. For HD pickups and vans, test
weight (TW) is based on adjusted loaded vehicle weight (ALVW), which is
defined as the average of gross vehicle weight rating (GVWR) and curb
weight (CW). TW values are then rounded, resulting in TW ``bins'':
ALVW <= 4,000 lb.: TW rounded to nearest 125 lb.
4000 lb. < ALVW <= 5,500 lb.: TW rounded to nearest 250 lb.
ALVW > 5,500 lb.: TW rounded to nearest 500 lb.
This ``binning'' of TW is relevant to calculation of fuel
consumption reductions accompanying mass reduction. Model inputs for
mass reduction (as an applied technology) are expressed in terms of a
percentage reduction of curb weight and an accompanying estimate of the
percentage reduction in fuel consumption, setting aside rounding of
test weight. Therefore, to account for rounding of test weight, NHTSA
has modified these calculations as follows:
[GRAPHIC] [TIFF OMITTED] TR25OC16.013
Where:
[Delta]CW = % change in curb weight (from model input),
[Delta]FCunrounded_TW = % change in fuel consumption
(from model input), without TW rounding,
[Delta]TW = % change in test weight (calculated), and
[Delta]FCrounded_TW = % change in fuel consumption
(calculated), with TW rounding.
As a result, some applications of vehicle mass reduction will
produce no compliance benefit at all, in cases where the changes in
ALVW are too small to change test weight when rounding is taken into
account. On the other hand, some other applications of vehicle mass
reduction will produce significantly more compliance benefit than when
rounding is not taken into account, in cases where even small changes
in ALVW are sufficient to cause vehicles' test weights to increase by,
e.g., 500 lbs. when rounding is accounted for. Model outputs now
include initial and final TW, GVWR, and GCWR (and, as before, CW) for
each vehicle model in each model year. The agencies invited but did not
receive comment on how TW is modeled.
In addition, considering that the regulatory alternatives in the
agencies' analysis all involve attribute-based standards in which
underlying fuel consumption targets vary with ``work factor'' (defined
by the agencies as the sum of three quarters of payload, one quarter of
towing capacity, and 500 lb. for vehicles with 4WD), NHTSA has modified
the CAFE model to apply inputs defining shares of curb weight reduction
to be ``returned'' to payload and shares of GVWR reduction to be
returned to towing capacity. The standards' dependence on work factor
provides some incentive to increase payload and towing capacity, both
of which are buyer-facing measures of vehicle utility. In the agencies'
judgment, this provides reason to assume that if vehicle mass is
reduced, manufacturers are likely to ``return'' some of the change to
payload and/or towing capacity. For this analysis, the agencies have
applied the following assumptions:
GVWR will be reduced by half the amount by which curb
weight is reduced. In other words, 50 percent of the curb weight
reduction will be returned to payload.
GCWR will not be reduced. In other words, 100 percent of
any GVWR reduction will be returned to towing capacity.
GVWR/CW and GCWR/GVWR will not increase beyond levels
observed among the majority of similar vehicles (or, for outlier
vehicles, initial values):
[[Page 73760]]
Table VI-8 Ratios for Modifying GVW and GCW as a Function of Mass
Reduction
------------------------------------------------------------------------
Maximum ratios assumed
enabled by mass reduction
Group -------------------------------
GVWR/CW GCWR/GVWR
------------------------------------------------------------------------
Unibody................................. 1.75 1.50
Gasoline pickups > 13k GVWR............. 2.00 1.50
Other gasoline pickups.................. 1.75 2.25
Diesel SRW pickups...................... 1.75 2.50
All other............................... 1.75 2.25
------------------------------------------------------------------------
The first of two of these inputs are specified along with standards
for each regulatory alternative, and the GVWR/CW and GCWR/GVWR ``caps''
are specified separately for each vehicle model in the analysis fleet.
In addition, NHTSA has changed the model to prevent HD pickup and
van GVWR from falling below 8,500 lbs. when mass reduction is applied
(because doing so will cause vehicles to be reclassified as light-duty
vehicles), and to treat any additional mass for hybrid electric
vehicles as reducing payload by the same amount (e.g., if adding a
strong HEV package to a vehicle involves a 350 pound penalty, GVWR is
assumed to remain unchanged, such that payload is also reduced by 350
lbs).
The agencies invited but did not receive comment on estimating how
changes in vehicle mass may impact fuel consumption, GVWR, and GCWR.
(8) Subsequent Changes to the CAFE Model (for Method A)
Since issuing the NPRM, NHTSA has made further changes to the CAFE
model, in order to estimate the potential impacts of simultaneous
standards for both light-duty vehicles and HD pickups and vans. Among
the updates most relevant to analysis supporting the final standards
for HD pickups and vans, the current model: includes refinements to
enable accounting for platforms, engines, and transmissions sharing
between light-duty and HD pickups and vans; reflects refinements to how
models for the first application of new technology are identified among
shared platforms, engines, and transmissions; allows payback period,
discount rate, survival rates, and mileage accumulation schedules to be
specified separately for each vehicle class; makes use of large scale
simulation modeling to more accurately account for synergies among
technologies to estimate the fuel consumption impact of different
combinations of technologies; provides the ability to selectively
exclude fine payment from the ``effective cost'' calculation used to
simulation manufacturers' decisions regarding the application of fuel-
saving technologies; and expands the use of forward planning to
estimate decisions to use credits that would otherwise expire. Changes
to the CAFE model are discussed at greater length below and in the CAFE
model documentation.
Also since issuing the NPRM, NHTSA has revised many model inputs to
reflect information that has become available since the proposal. Among
the updates most relevant to analysis supporting the final rule, these
inputs reflect: an updated vehicle-level market forecast based on data
regarding the 2015 model year fleet and a new commercially-available
manufacturer- and segment-level market forecast, and spanning light-
duty vehicles and HD pickups and vans; newer fuel prices and total
vehicle production volumes from the Energy Information Administration's
Annual Energy Outlook 2015; a database, based on a large-scale full
vehicle simulation study, of estimates of the effect of thousands of
different combinations of technologies on fuel consumption; and updated
mileage accumulation schedules based on a database of more than 70
million odometer readings.
NHTSA implemented these changes to the CAFE model and accompanying
inputs to support both today's final rule promulgating new fuel
consumption standards for HD pickups and vans and the Draft Technical
Assessment Report regarding agency's consideration of CAFE standards
for light duty vehicles for model years 2022-2025. This provided a
basis to analyze the fleets simultaneously, accounting for interactions
between the fleets; the draft RIA (p. 10-18) accompanying the NPRM
identified this as a planned improvement for the final rule, and some
stakeholders' comments (e.g., CARB,\492\ UCS,\493\ and CBD \494\)
indicated that such interactions should be accounted for.
---------------------------------------------------------------------------
\492\ CARB, Docket No. NHTSA-2014-0132-0125, at 17-18; 52-53.
\493\ UCS, Docket No. EPA-HQ-OAR-2014-0827-1329, at pages 23-24.
\494\ CBD, Docket No. NHTSA-2014-0132-0101 at pages 8-9.
---------------------------------------------------------------------------
The remainder of this section summarizes changes to the CAFE model
and inputs made subsequent to the NPRM analysis, summarizes results of
the updated analysis, and discusses.
(a) Interactions Between Regulatory Classes
Like earlier versions, the current CAFE model provides for
integrated analysis spanning different regulatory classes, accounting
both for standards that apply separately to different classes and for
interactions between regulatory classes. Light vehicle CAFE standards
are specified separately for passenger cars and light trucks. However,
there is considerable sharing between these two regulatory classes.
Some specific engines and transmissions are used in both passenger cars
and light trucks, and some vehicle platforms span these regulatory
classes. For example, some sport-utility vehicles are offered in 2WD
versions classified as passenger cars and 4WD versions classified as
light trucks. Integrated analysis of manufacturers' passenger car and
light truck fleets provides the ability to account for such sharing and
reduce the likelihood of finding solutions that could involve
impractical levels of complexity in manufacturers' product lines. In
addition, integrated analysis provides the ability to simulate the
potential that manufactures could earn CAFE credits by over complying
with one standard and use those credits toward compliance with the
other standard (i.e., to simulate credit transfers between regulatory
classes).
HD pickups and vans are regulated separately from light-duty
vehicles. While manufacturers cannot transfer credits between light-
duty and MDHD classes, there is some sharing of engineering and
technology between light-duty vehicles and HD pickups and vans. For
example, some passenger vans with GVWR over 8,500 pounds are classified
as medium-duty passenger vehicles (MDPVs) and thus included in
manufacturers' light-duty truck fleets,
[[Page 73761]]
while cargo vans sharing the same nameplate are classified as HD vans.
The FRM Method A analysis uses an overall analysis fleet spanning
both the light-duty and HD pickup and van fleets. As discussed below,
doing so shows some technology ``spilling over'' to HD pickups and vans
due, for example, to the application of technology in response to
current light-duty standards. For most manufacturers, these
interactions appear relatively small. For Nissan, however, they appear
considerable, because Nissan's heavy-duty vans use engines also used in
Nissan's light-duty SUVs. Unlike the Method A analysis, the Method B
analysis is independent from the light-duty program.
In the NPRM proposing new standards for heavy-duty pickups and
vans, NHTSA and EPA requested comment on the expansion of the analysis
fleet such that the impacts of new HD pickup and van standards can be
estimated within the context of an integrated analysis of light-duty
vehicles and HD pickups and vans, accounting for interactions between
the fleets. As mentioned above, some environmental organizations
specifically cited commonalities and overlap between light- and heavy-
duty products.
(b) Phase-In Caps
The model also accommodates estimates of overall limits (expressed
as ``phase-in caps'' in model inputs) on the rates at which
manufacturers' may practicably add technology to their respective
fleets. So, for example, even if a manufacturer is expected to redesign
half of its production in MY 2016, if the manufacturer is not already
producing any strong hybrid electric vehicles (SHEVs), a phase-in cap
can be specified in order to assume that manufacturer will stop
applying SHEVs in MY 2016 once it has done so to at least 3 percent of
its production in that model year. Today's analysis sets all of these
caps at 100 percent, relying on other model constraints (in particular,
the assumption that many technologies are most practicably applied as
part of a vehicle freshening or redesign) to estimate practicable
technology application pathways.
The CAFE model retains the ability to use phase-in caps (specified
in model inputs) as proxies for a variety of practical restrictions on
technology application. Unlike vehicle-specific restrictions related to
redesign, refreshes or platforms/engines, phase-in caps constrain
technology application at the vehicle manufacturer level. Introduced in
the 2006 version of the CAFE model, they were intended to reflect a
manufacturer's overall resource capacity available for implementing new
technologies (such as engineering and development personnel and
financial resources), thereby ensuring that resource capacity is
accounted for in the modeling process.
In previous fuel efficiency rulemakings, redesign/refresh schedules
and phase-in caps were the primary mechanisms to reflect an OEM's
limited pool of available resources during the rulemaking time frame
and the years leading up to the rulemaking time frame, especially in
years where many models may be scheduled for refresh or redesign. The
newly-introduced representation platform-, engine-, and transmission-
related considerations discussed above augment the model's preexisting
representation of redesign cycles, and as discussed above, inputs for
today's analysis de-emphasize reliance on phase-in caps.
(c) Accounting for Credits
The changes discussed above relate specifically to the model's
approach to simulating manufacturers' potential addition of fuel-saving
technology in response to fuel efficiency standards and fuel prices
within an explicit product planning context. The model's approach to
simulating compliance decisions also accounts for the potential to earn
and use fuel consumption credits, as provided by EPCA/EISA. Like past
versions, the current CAFE model can be used to simulate credit carry-
forward (a.k.a. banking) between model years and transfers between the
passenger car and light truck fleets, but not credit carry-back (a.k.a.
borrowing) between model years or trading between manufacturers. Unlike
past versions, the current CAFE model provides a basis to specify (in
model inputs) fuel consumption credits available from model years
earlier than those being simulated explicitly. For example, with
today's analysis representing model years 2015-2032 explicitly, credits
specified as being available from model year 2014 are made available
for use through model year 2019 (given the current 5-year limit on
carry-forward of credits).
As discussed in the CAFE model documentation, the model's default
logic attempts to maximize credit carry-forward--that is to ``hold on''
to credits for as long as possible.\495\ Although the model uses
credits before expiry if needed to cover shortfalls when insufficient
opportunity to add technology is available to achieve compliance with a
standard, the model will otherwise carry forward credits until they are
about to expire, at which point it will use them before adding
technology. As further discussed in the CAFE model documentation, model
inputs can be used to adjust this logic to shift the use of credits
ahead by one or more model years.
---------------------------------------------------------------------------
\495\ Volpe CAFE Model Documentation, July 2016, pg 64.
Available at http://www.nhtsa.gov/Laws%20&%20Regulations/CAFE%20-%20Fuel%20Economy/cafe-volpe-model.
---------------------------------------------------------------------------
The example presented below illustrates how some of aspects of the
current model logic around credits impacts estimation of technology
application by a manufacturer within the context of a specified set of
standards, focusing here on the model's estimate of Ford's potential
technology application under the preferred alternative. Overall results
for Ford and other manufacturers are summarized in Section VI.D.
[[Page 73762]]
[GRAPHIC] [TIFF OMITTED] TR25OC16.014
Several aspects of the estimated achieved and required fuel
consumption levels shown above are notable. First, the characteristics
of Ford's fleet as represented in today's analysis fleet are such that
the heavy duty pickup and van fleet falls short of average fuel
efficiency standard in MY's 2023 through 2027. However, they exceed
their standard for MY's 2016 through 2022. The current analysis uses
logic that reflect the potential that Ford could use the 5-year carry
forward provision to use fuel efficiency credits earned in MY's 2018
through MY 2022, to cover the shortfalls for MY's 2023 to 2027. The
model assumes Ford will use as many of the MY 2018 expiring credits as
necessary to cover the shortfall in MY 2023. For MY 2024 they will use
all available MY 2019 credits before applying any additional MY 2020
credits necessary to cover the shortfall (in this particular case there
are enough MY 2019 credits to cover the shortfall in MY 2024). This
pattern continues for all model years where there is a shortfall--the
model applies the oldest remaining credits first. Even so, today's
analysis indicates Ford could be required to pay civil penalties for
noncompliance without the addition of modest fuel savings in MY 2027.
The change to the model which accounts for credits earned prior to MY
2015 is not illustrated in this example. However, Ford comes in with
fuel consumption credits from MY's prior to MY 2015; if they had come
in with an initial shortfall, they could have used these banked credits
to cover, at least a portion, of that shortfall.
As discussed above, these results provide an estimate, based on
analysis inputs, of one way General Motors could add fuel-saving
technologies to its products under the preferred alternative considered
here, and are not a prediction of what General Motors would do under
this alternative. In addition, it should be recognized that specific
results vary among manufacturers and among regulatory alternatives (and
under different analytical inputs). Still, the example should serve to
illustrate how the ability to model credit banking can impact results.
(d) Integrating Vehicle Simulation Results Into the Synergy Values
The CAFE model does not itself evaluate which technologies will be
available, nor does it evaluate how effective or reliable they will be.
The technological availability and effectiveness rather, are predefined
inputs to the model based on the agencies' judgements and not outputs
from the model, which is simply a tool for calculating the effects of
combining input assumptions.
In previous versions of the CAFE Model, technology effectiveness
values entered into the model as a single number for each technology
(for each of several classes), intended to represent the incremental
improvement in fuel consumption achieved by applying that technology to
a vehicle in a particular class. At a basic level, this implied that
successive application of new vehicle technologies resulted in an
improvement in fuel consumption (as a percentage) that was the product
of the individual incremental effectiveness of each technology applied.
Since this construction fails to capture interactive effects--cases
where a given technology either improves or degrades the impact of
subsequently applied technologies--the CAFE Model applied ``synergy
factors.'' The synergy factors were defined for a relatively small
number of technology pairs, and were intended to represent the result
of physical interactions among pairs of technologies--attempting to
account for situations where 2 x 2 [ne] 4.
For a more specific example, for a vehicle with an initial fuel
consumption of FC0, if two technologies are applied, one
with an incremental effectiveness of 5 percent, and a second with an
incremental effectiveness of 10 percent, the effectiveness after the
application of both technologies without consideration of synergies
could be expressed as follows:
FC0*(1-.05)*(1-.1)
Which is equivalent to:
FC0*(1-.145)
This suggests that the combined effectiveness of the two
technologies is 14.5 percent. The synergy factors aim to correct for
cases where fuel consumption improvements are not perfectly
multiplicative, and the combined fuel consumption in the example above
is either greater than or less than 14.5 percent.
[[Page 73763]]
For this analysis, the CAFE Model has been modified to accommodate
the results of the large-scale vehicle simulation study conducted by
Argonne National Laboratory (described in more detail in the light-duty
Draft TAR). While Autonomie, Argonne's vehicle simulation model,
produces absolute fuel consumption values for each simulation record,
the results have been modified in a way that preserves much of the
existing structure of the CAFE Model's compliance logic, but still
faithfully reproduces the totality of the simulation outcomes present
in the database. Fundamentally, the implementation represents a
translation of the absolute values in the simulation database into
incremental improvements and a substantially expanded set of synergy
factors.
Since the simulation efforts only included light-duty vehicles, the
effectiveness values for heavy duty were not integrated into the heavy-
duty fleet; for future rule-makings NHTSA hopes to extend the vehicle
simulation efforts to include simulations that would be relevant for
heavy-duty pickups and vans. While the effectiveness values for
individual technologies remain the same, the synergies between two or
more technologies incorporate information from Autonomie Argonne's
light-duty pickup simulations. While these synergy values are not a
perfect approximation of the interaction of technology applications
particular to heavy-duty vehicles, it is consistent with what we did in
the NPRM (where we also used synergy values from light-duty pickups).
Updating the synergy values to use Argonne's simulation efforts
does two things: (1) It allows that these synergies may occur between
more than two technologies, and (2) because the synergies are
multiplicative, rather than additive, it allows for the consideration
that the order of other technology applications matter in determining
the incremental percentage improvement correction of the synergy value.
Instead of having one additive incremental percentage synergy value for
a pair of technologies, regardless of the order of technology
application between these pair of technologies, the synergy values are
dependent on the initial state and ending point of a vehicle within the
database.
As stated, in the past, synergy values in the Volpe model were
represented as pairs. However, the new values are 7-tuples and there is
one for every point in the database. The synergy factors are based
(entirely) on values in the Argonne database, producing one for each
unique technology combination for each technology class, and are
calculated as
[GRAPHIC] [TIFF OMITTED] TR25OC16.015
where Sk is the synergy factor for technology combination k,
FC0 is the fuel consumption of the reference vehicle (in the
database), xi is the fuel consumption improvement of each
technology i represented in technology combination k (where some
technologies are present in combination k, and some are precedent
technologies that were applied, incrementally, before reaching the
current state on one of the paths).
In order to incorporate the results of the Argonne database, while
still preserving the basic structure of the CAFE model's technology
module, it was necessary to translate the points in the database into
locations on the technology tree.\496\ By recognizing that most of the
paths on the technology tree are unrelated, or separable, it is
possible to decompose the technology tree into a small number of paths
and branches by technology type. To achieve this level of linearity, we
define technology groups--only one of which is new. They are: engine
cam configuration (CONFIG), engine technologies (ENG), transmission
technologies (TRANS), electrification (ELEC), mass reduction levels
(MR), aerodynamic improvements (AERO), and rolling resistance (ROLL).
The combination of technology levels along each of these paths define a
unique technology combination that corresponds to a single point in the
database for each technology class. These technology state definitions
are more important for defining synergies than for determining
incremental effectiveness, but the paths are incorporated into both.
Again, because we did not simulate results applicable to the heavy-duty
fleet, we did not use the database to define the incremental technology
effectiveness, but only to adjust for the unique interaction of
different combinations of technology.
---------------------------------------------------------------------------
\496\ The technology tree used to create the synergies for this
rule are presented in the light-duty draft TAR.
---------------------------------------------------------------------------
As an example, a technology state vector describing a vehicle with
a SOHC engine, variable valve timing (only), a 6-speed automatic
transmission, a belt-integrated starter generator, mass reduction
(level 1), aerodynamic improvements (level 2), and rolling resistance
(level 1) would be specified as SOHC;VVT;AT6;BISG;MR1;AERO2;ROLL1. Once
a vehicle is assigned a technology state (one of the tens of thousands
of unique 7-tuples, defined as CONFIG;ENG;TRANS;ELEC;MR;AERO;ROLL),
adding a new technology to the vehicle simply represents progress from
one technology state to another. The vehicle's fuel consumption is:
FCi = FC0 [middot] (1 - FCIi) [middot] SK/0
where FCi is the fuel consumption resulting from the
application of technology i, FC0 is the vehicle's fuel
consumption before technology i is applied, FCIi is the
incremental fuel consumption (percentage) improvement associated with
technology i, Sk is the synergy factor associated with the
combination, k, of technologies the vehicle technology i is applied,
and S0 the synergy factor associated with the technology
state that produced fuel consumption FC0. The synergy factor
is defined in a way that captures the incremental improvement of moving
between points in the database, where each point is defined uniquely as
a 7-tuple describing its cam configuration, highest engine technology,
transmission, electrification type, mass reduction level, and level of
aerodynamic or rolling resistance improvement. For the current heavy-
duty adoption, it is only these synergy values that were used in the
current analysis. While, like with the individual fuel consumption
improvements, there is likely not a simple mapping from light-duty
pickups to heavy-duty pickups (size and power matter), the previous
synergy values were also an adoption from light-duty pickups. The
integration of the simulation data allows for a more complete set of
synergies that account for the order of technology application and the
interaction of more than two individual technologies.
(e) Updating Mileage Accumulation Schedules
In order to develop new mileage accumulation schedules for vehicles
regulated under NHTSA's fuel efficiency and CAFE programs (classes 1-
3), NHTSA purchased a data set of vehicle odometer readings from IHS/
Polk (Polk). Polk collects odometer readings from registered vehicles
when they encounter maintenance facilities, state inspection programs,
or interactions with dealerships and OEMs. The (average) odometer
readings in the data set NHTSA purchased are based on over 74 million
unique odometer readings across 16 model years (2000-2015) and vehicle
classes present in the data purchase (all registered vehicles less than
14,000 lbs. GVW).
The Polk data provide a measure of the cumulative lifetime vehicle
miles
[[Page 73764]]
traveled (VMT) for vehicles, at the time of measurement, aggregated by
the following parameters: make, model, model year, fuel type, drive
type, door count, and ownership type (commercial or personal). Within
each of these subcategories they provide the average odometer reading,
the number of odometer readings in the sample from which Polk
calculated the averages, and the total number of that subcategory of
vehicles in operation. From these NHTSA was able to develop new
estimates of vehicle miles traveled by age as inputs for the CAFE
Model.
(f) Impact of Vehicle Technology Application Requirements
Compared to prior analyses of light-duty standards, these model
changes result in some changes in the broad characteristics of the
model's application of technology to manufacturers' fleets. Since the
use of phase-in caps has been de-emphasized and manufacturer technology
deployment remains tied strongly to estimated product redesign and
freshening schedules, technology penetration rates may jump more
quickly as manufacturers apply technology to high-volume products in
their portfolio.
By design, restrictions that enforce commonality of mass reduction
and aerodynamic technologies on variants of a platform, and those that
enforce engine inheritance, will result in fewer vehicle-technology
combinations in a manufacturer's future modeled fleet. As explained in
the NPRM proposing new standards for HD pickups and vans, these
restrictions are expected to more accurately capture the true costs
associated with producing and maintaining a product portfolio.
(i) Updated Schedules
The new medium-duty van/pickup schedule in Figure VI-6 predicts
higher annual VMT for vehicles between ages one through five years, and
lower annual VMT for all other vehicle ages, than the old schedule.
Over the first 30-year span, the new schedule predicts that medium-duty
vans/pickups drive 24,249 (9 percent) fewer miles than the old
schedule. We predict the maximum average annual VMT for medium-duty
vehicles (23,307 miles) at age two. These changes to the schedule will
have important implications on certain benefits of the standards. More
monetary fuel savings will occur during the first five years of a
vehicle's life under the new schedule, but a decrease in fuel savings
will occur overall while using these schedules. For payback periods
shorter than 5 years, the new schedule will show shorter payback
periods than the old schedule. Section 10 of the RIA offers similar
figures for light-duty vehicles types. It also offers further
explanation about the shape of the new annual VMT schedule.
[GRAPHIC] [TIFF OMITTED] TR25OC16.016
Table VI-9 offers a summary of the comparison of lifetime VMT (by
class) under the new schedule, compared with lifetime VMT under the old
schedule. In addition to the total lifetime VMT expected under each
schedule for vehicles that survive to their full useful life, Table VI-
9also shows the survival-weighted lifetime VMT for both schedules. This
represents the average lifetime VMT for all vehicles, not only those
that survive to their full useful life. The percentage difference
between the two schedules is not as stark for the survival-weighted
schedules: The percentage decrease of survival-weighted lifetime VMT
under the new schedules range from 6.5 percent (for medium-duty trucks
and vans) to 21.2 percent (for passenger vans).
[[Page 73765]]
Table VI-9--Summary Comparison of Lifetime VMT of the New and Old Schedules
--------------------------------------------------------------------------------------------------------------------------------------------------------
Survival-Weighted
-----------------------------------------------------------------------------------------------
Lifetime VMT Lifetime VMT
-----------------------------------------------------------------------------------------------
New Old % difference New Old % difference
--------------------------------------------------------------------------------------------------------------------------------------------------------
Car..................................................... 204,233 301,115 32.2 142,119 179,399 20.8
Van..................................................... 237,623 362,482 34.4 155,115 196,725 21.2
SUV..................................................... 237,623 338,646 29.8 155,115 193,115 19.7
Pickup.................................................. 265,849 360,982 26.4 157,991 188,634 16.2
2b/3.................................................... 246,413 270,662 9.0 176,807 189,020 6.5
--------------------------------------------------------------------------------------------------------------------------------------------------------
(ii) Data Description
While the Polk data set contains model-level average odometer
readings, the CAFE model assigns lifetime VMT schedules at a lower
resolution based on vehicle body style. For the purposes of VMT
accounting, the CAFE model classifies every vehicle in the analysis
fleet as being one of the following: passenger car, SUV, pickup truck,
passenger van, or medium-duty pickup/van. In order to use the Polk data
to develop VMT schedules for each of the (VMT) classes in the CAFE
model, we constructed a mapping between the classification of each
model in the Polk data and the classes in the CAFE model. The only
difference between the mapping for the VMT schedules and the rest of
the CAFE model is that we merged the SUV and van body styles into one
class (for reasons described in our discussion of the SUV/van schedule
in Section 10 of the RIA). This mapping allowed us to predict the
lifetime miles traveled, by the age of a vehicle, for the categories in
the CAFE model.
In estimating the VMT models, we weighted each data point (make/
model classification) by the share of each make/model in the total
population of the corresponding CAFE class. This weighting ensures that
the predicted odometer readings, by class and model year, represent
each of vehicle classification among observed vehicles (i.e., the
vehicles for which Polk has odometer readings), based on each vehicles'
representation in the registered vehicle population of its class.
Implicit in this weighting scheme, is the assumption that the samples
used to calculate each average odometer reading by make, model, and
model year are representative of the total population of vehicles of
that type. Several indicators suggest that this is a reasonable
assumption.
First, the majority of each vehicle make/model is well-represented
in the sample. For more than 85 percent of make/model combinations, the
average odometer readings are collected for 20 percent or more of the
total population. Most make/model observations have sufficient sample
sizes, relative to their representation in the vehicle population, to
produce meaningful average odometer totals at that level.
We also considered whether the representativeness of the odometer
sample varies by vehicle age, since VMT schedules in the CAFE model are
specific to each age. To investigate, we calculated the percentage of
vehicle types (by make, model, and model year) that did not have
odometer readings. All model years, apart from 2015, have odometer
readings for 96 percent or more of the total types of vehicles observed
in the fleet.
While the preceding discussion supports the coverage of the
odometer sample across makes/models by each model year, it is possible
that, for some of those models, an insufficient number of odometer
readings is recorded to create an average that is likely to be
representative of all of those models in operation for a given year.
For all model years other than 2015, about 95 percent or more of
vehicles types are represented by at least 5 percent of their
population. For this reason, we included observations from all model
years, other than 2015, in the estimation of the new VMT schedules.
It is possible that the odometer sample is biased. If certain
vehicles are over-represented in the sample of odometer readings
relative to the registered vehicle population, a simple average, or
even one weighted by the number of odometer observations will be
biased. However, while weighting by the share of each vehicle in the
population will account for this bias, it would not correct for a
sample that entirely omits a large number of makes/models within a
model year. We tested for this by computing the proportion of the count
of odometer readings for each individual vehicle type--within a class
and model year--to the total count of readings for that class and model
year. We also compared the population of each make/model--within each
class and model year--to the population of the corresponding class and
model year. The difference of these two ratios shows the difference of
the representation of a vehicle type--in its respective class and model
year--in the sample versus the population. All vehicle types are
represented in the sample within 10 percent of their representation in
the population, and the variance between the two representations is
normally distributed. This suggests that, on average, the likelihood
that a vehicle is in the sample is comparable to its proportion in the
relevant population, and that there is little under or over sampling of
certain vehicle makes/models.\497\
---------------------------------------------------------------------------
\497\ For figures that support the conclusions about the
representativeness of the IHS/Polk data see Section 10 of the RIA.
---------------------------------------------------------------------------
(iii) Estimation
Since model years are sold in in the fall of the previous calendar
year, throughout the same calendar year, and even into the following
calendar year--not all registered vehicles of a make/model/model year
will have been registered for at least a year (or more) until age 3.
The result is that some MY 2014 vehicles may have been driven for
longer than one year, and some less, at the time the odometer was
observed. In order to consider this in our definition of age, we assign
the age of a vehicle to be the difference between the average reading
date of a make/model and the average first registration date of that
make/model. The result is that the continuous age variable reflects the
amount of time that a car has been registered at the time of odometer
reading, and presumably the time span that the car has accumulated the
miles.
After creating the ``Age'' variable, we fit the make/model lifetime
VMT data points to a weighted quartic polynomial regression of the age
of the vehicle (stratified by class). The predicted values of the
quartic regressions are used to calculate the marginal annual VMT by
age for each class by calculating differences in estimated lifetime
mileage accumulation by age. However, the Polk data acquired by NHTSA
only contains
[[Page 73766]]
observations for vehicles newer than 16 years of age. In order to
estimate the schedule for vehicles older than the age 15 vehicles in
the Polk data, we combined information about that portion of the
schedule from the VMT schedules used in both the 2017-2021 Final Light
Duty Rule and 2019-2025 Medium-Duty NPRM. The light-duty schedules were
derived from the survey data contained in the 2009 National Household
Travel Survey (NHTS) and the 2001 Vehicle in Use Survey (VIUS), for
medium-duty trucks.
Based on the vehicle ages for which we have data (from the Polk
purchase), the newly estimated annual schedules differ from the
previous version in important ways. Perhaps most significantly, the
annual mileage associated with ages beyond age 8 begin to, and continue
to, trend much lower. The approach taken here attempts to preserve the
results obtained through estimation on the Polk observations, while
leveraging the existing (NHTS-based) schedules to support estimation of
the higher ages (age 16 and beyond). Since the two schedules are so far
apart, simply splicing them together would have created not only a
discontinuity, but also precluded the possibility of a monotonically
decreasing scale with age (which is consistent with previous schedules,
the data acquired from Polk, and common sense).
From the old schedules, we expect that the annual VMT is decreasing
for all ages. Towards the end of our sample, the predictions for annual
VMT increase. In order to force the expected monotonicity, we perform a
triangular smoothing algorithm until the schedule is monotonic. This
performs a weighted average which weights the observations close to the
observation more than those farther from it. The result is a monotonic
function, which predicts similar lifetime VMT for the sample span as
the original function. Since we do not have data beyond 15 years of
age, we are not able to correctly capture that part of the annual VMT
curve using only the new dataset. For this reason, we use trends in the
old data to extrapolate the new schedule for ages beyond the sample
range.
In order to use the VMT information from the newer data source for
ages outside of the sample, we use the final in-sample age (15 years)
as a seed and then apply the proportional trend from the old schedules
to extrapolate the new schedules out to age 30. To do this, we
calculated the annual percentage difference in VMT of the old schedule
for ages 15-30. The same annual percentage difference in VMT is applied
to the new schedule to extend beyond the final in-sample value. This
assumes that the overall proportional trend in the outer years is
correctly modeled in the old VMT schedule, and imposes this same trend
for the outer years of the new schedule. The extrapolated schedules are
the final input for the VMT schedules in the CAFE model.
(iv) Comparison to Previous Schedules
The new VMT data suggests that the VMT schedule used in the last
Light-Duty CAFE Final Rule likely does not represent current annual VMT
rates. Across all classes, the previous VMT schedules overestimate the
average annual VMT. The previous schedules are based on data that is
outdated and self-reported, while the observations from Polk are
between 5 and 7 years newer than those in the NHTS and represent valid
odometer readings (rather than self-reported information).
Additionally, while the NHTS may be a representative sample of
households, it is less likely to be a representative sample of
vehicles. However, by properly accounting for vehicle population
weights in the new averages and models, we corrected for this issue in
the derivation of the new schedules.
Insofar as these changes better represent actual VMT, they lead to
better estimates of actual impacts, such as avoided fuel consumption
and GHG emissions, safety impacts, and monetized benefits.
(v) Future Direction
In consultation with other agencies closely involved with VMT
estimation (e.g., FHWA), NHTSA will continue to seek means to further
refine estimated mileage accumulation schedules. For example, one
option under consideration would be to obtain odometer reading data
from successive calendar years, thus providing a more robust basis to
consider, for example, the influence of changing fuel prices or
economic conditions on the accumulation of miles by vehicles of a given
age.
(g) Updated Analysis Fleet
For the current analysis we updated the reference fleet from MY
2014, to the latest available MY 2015. The projection of total sales
volumes for the Class 2b and 3 market segment was based on the total
volumes in the 2015 AEO Reference Case. For the purposes of this
analysis, the AEO2015 calendar year volumes have been used to represent
the corresponding model-year volumes. While AEO2015 provides enough
resolution in its projections to separate the volumes for the Class 2b
and 3 segments, the agencies deferred to the vehicle manufacturers and
chose to rely on the relative shares present in the pre-model-year
compliance data.
The relative sales share by vehicle type (van or pickup truck, in
this case) was derived from a sales forecast that the agencies
purchased from IHS Automotive, and applied to the total volumes in the
AEO2015 projection. Table VI-10 shows the implied shares of the total
new 2b/3 vehicle market broken down by manufacturer and vehicle type.
Table VI-10--2015 IHS Automotive Market Share Forecast for 2b/3 Vehicles
--------------------------------------------------------------------------------------------------------------------------------------------------------
Model year market share
Manufacturer Style -----------------------------------------------------------------------------------------------
2016 2017 2018 2019 2020 2021
--------------------------------------------------------------------------------------------------------------------------------------------------------
Daimler........................... Van................. 2% 2% 2% 3% 3% 3%
Fiat Chrysler..................... Van................. 3 3 3 3 3 3
Ford.............................. Van................. 16 16 16 17 18 19
General Motors.................... Van................. 7 7 7 7 8 8
Nissan............................ Van................. 1 1 1 1 2 2
Daimler........................... Pickup.............. 0 0 0 0 0 0
Fiat Chrysler..................... Pickup.............. 14 14 14 14 15 14
Ford.............................. Pickup.............. 29 30 31 31 28 28
General Motors.................... Pickup.............. 28 27 26 25 24 24
Nissan............................ Pickup.............. 0 0 0 0 0 0
--------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 73767]]
Within those broadly defined market shares, volumes at the
manufacturer/model-variant level were constructed by applying the
model-variant's share of manufacturer sales in the pre-model-year
compliance data for the relevant vehicle style, and multiplied by the
total volume estimated for that manufacturer and that style.
(h) Changes to Costs
(i) Use of Retail Price Equivalent (RPE) Multiplier To Calculate
Indirect Costs
To produce a unit of output, vehicle manufacturers incur direct and
indirect costs. Direct costs include cost of materials and labor costs.
Indirect costs are all the costs associated with producing the unit of
output that are not direct costs--for example, they may be related to
production (such as research and development [R&D]), corporate
operations (such as salaries, pensions, and health care costs for
corporate staff), or selling (such as transportation, dealer support,
and marketing). Indirect costs are generally recovered by allocating a
share of the costs to each unit of good sold. Although it is possible
to account for direct costs allocated to each unit of good sold, it is
more challenging to account for indirect costs allocated to a unit of
goods sold. To make a cost analysis process more feasible, markup
factors, which relate total indirect costs to total direct costs, have
been developed. These factors are often referred to as retail price
equivalent (RPE) multipliers.
Cost analysts and regulatory agencies (including both NHTSA and
EPA) have frequently used these multipliers to predict the resultant
impact on costs associated with manufacturers' responses to regulatory
requirements. The best approach, if it were possible, to determining
the impact of changes in direct manufacturing costs on a manufacturer's
indirect costs would be to actually estimate the cost impact on each
indirect cost element. However, doing this within the constraints of an
agency's time or budget is not always feasible, and the technical,
financial, and accounting information to carry out such an analysis may
simply be unavailable.
The one empirically derived metric that addresses the markup of
direct costs to consumer costs is the RPE multiplier, which is measured
from manufacturer 10-K accounting statements filed with the Securities
and Exchange Commission. Over roughly a three decade period, the
measured RPE has been remarkably stable, averaging 1.5, with minor
annual variation. The National Research Council notes that, ``Based on
available data, a reasonable RPE multiplier would be 1.5.'' The
historical trend in the RPE is illustrated in Figure VI.13.
[GRAPHIC] [TIFF OMITTED] TR25OC16.017
RPE multipliers provide, at an aggregate level, the relationship
between revenue and direct manufacturing costs. They are measured by
dividing total revenue by direct costs. However, because this provides
only a single aggregate measure, using RPE multipliers results in the
application of a common incremental markup to all technologies. It
assures that the aggregate cost impact across all technologies is
consistent with empirical data, but does not allow for indirect cost
discrimination among different technologies. Thus, a concern in using
the RPE multiplier in cost analysis for new technologies added in
response to regulatory requirements is that the indirect costs of
vehicle modifications are not likely to be the same for all different
technologies. For example, less complex technologies could require
fewer R&D efforts or less warranty coverage than more complex
technologies. In addition, some simple technological adjustments may,
for example, have no effect on the number of corporate personnel and
the indirect costs attributable to those personnel. The use of RPEs,
with their assumption that all technologies have the same proportion of
indirect costs, is likely to overestimate the costs of less complex
technologies and underestimate the costs of more complex technologies.
However, for regulations such as the CAFE and GHG emission standards
under consideration, which drive changes to nearly every vehicle
system, overall average indirect costs should align with the RPE value.
Applying RPE to the cost for each technology assures that alignment.
Modified multipliers have been developed by EPA, working with a
[[Page 73768]]
contractor, for use in rulemakings.\498\ These multipliers are referred
to as indirect cost multipliers (or ICMs). ICMs assign unique
incremental changes to each indirect cost contributor at several
different technology levels.
---------------------------------------------------------------------------
\498\ RTI International, ``Automobile Industry Retail Price
Equivalent and Indirect Cost Multipliers,'' February 2009; EPA-420-
R-09-003; http://www3.epa.gov/otaq/ld-hwy/420r09003.pdf.
---------------------------------------------------------------------------
ICM = (direct cost + adjusted indirect cost)/(direct cost)
Developing the ICMs from the RPE multipliers requires developing
adjustment factors based on the complexity of the technology and the
time frame under consideration: The less complex a technology, the
lower its ICM, and the longer the time frame for applying the
technology, the lower the ICM. This methodology was used in the cost
estimation for the recent light-duty MYs 2012-2016 and MYs 2017-2025
rulemaking and for the heavy-duty MYs 2014-2018 rulemaking. The ICMs
for the light-duty context were developed in a peer-reviewed report
from RTI International and were subsequently discussed in a peer-
reviewed journal article.\499\ Importantly, since publication of that
peer-reviewed journal article, the agencies have revised the
methodology to include a return on capital (i.e., profits) based on the
assumption implicit in ICMs (and RPEs) that capital costs are
proportional to direct costs, and businesses need to be able to earn
returns on their investments.
---------------------------------------------------------------------------
\499\ Rogozhin, A., et al., ``Using indirect cost multipliers to
estimate the total cost of adding new technology in the automobile
industry,'' International Journal of Production Economics (2009),
doi:10.1016/j.ijpe.2009.11.031.
---------------------------------------------------------------------------
Since their original development in February 2009, the agencies
have made some changes to both the ICMs factors and to the method of
applying those factors relative to the factors developed by RTI and
presented in their reports. We have described and explained those
changes in several rulemakings over the years, most notably the 2017-
2025 FRM for light vehicles and the more recent Heavy-duty GHG Phase 2
NPRM.\500\ In the 2015 NAS study, the committee stated a conceptual
agreement with the ICM method since ICM takes into account design
challenges and the activities required to implement each technology.
However, although endorsing ICMs as a concept, the NAS Committee stated
that ``. . . the empirical basis for such multipliers is still lacking,
and, since their application depends on expert judgment, it is not
possible to determine whether the Agencies' ICMs are accurate or not.''
NAS also states that ``. . . the specific values for the ICMs are
critical since they may affect the overall estimates of costs and
benefits for the overall standards and the cost effectiveness of the
individual technologies.'' The committee did encourage continued
research into ICMs given the lack of empirical data for them to
evaluate the ICMs used by the agencies in past analyses. EPA, for its
part, continues to study the issue surrounding ICMs but has not pursued
further efforts given resource constraints and demands in areas such as
technology benchmarking and cost teardowns.
---------------------------------------------------------------------------
\500\ 80 FR 40137.
---------------------------------------------------------------------------
On balance, NHTSA believes that the empirically derived RPE is a
more reliable basis for estimating indirect costs. To ensure overall
indirect costs in the analysis align with the RPE value, NHTSA has
developed its primary analysis based on applying the RPE value of 1.5
to each technology. NHTSA also has conducted a sensitivity analysis
examining the impact of applying the ICM approach in the sensitivity
analysis portion later in this Section. This marks a change from the
NPRM where we use the ICM multiplier to calculate indirect costs as the
central analysis and the RPE multiplier as a sensitivity case.
(ii) Updates to Mass Reduction Based on 2014 Silverado Study
As proposed in the NPRM we have updated the HD pickup and van mass
reduction cost curves with a MY 2014 GMC Silverado EDAG study. The
updated mass reduction study suggests that mass reduction will be more
costly for heavy-duty vans and pickups than was suggested in the NPRM.
This can explain the reduction in mass reduction in the current
analysis compared to the NPRM.
NHTSA awarded a contract to EDAG to conduct a vehicle weight
reduction feasibility and cost study of a 2014MY full size pick-up
truck. The light weighted version of the full size pick-up truck (LWT)
used manufacturing processes that will likely be available during the
model years 2025-2030 and be capable of high volume production. The
goal was to determine the maximum feasible weight reduction while
maintaining the same vehicle functionalities, such as towing, hauling,
performance, noise, vibration, harshness, safety, and crash rating, as
the baseline vehicle, as well as the functionality and capability of
designs to meet the needs of sharing components across same or cross
vehicle platform. Consideration was also given to the sharing of
engines and other components with vehicles built on other platforms to
achieve manufacturing economies of scale, and in recognition of
resource constraints which limit the ability to optimize every
component for every vehicle.
A comprehensive teardown/benchmarking of the baseline vehicle was
conducted for the engineering analysis. The analysis included geometric
optimization of load bearing vehicle structures, advanced material
utilization along with a manufacturing technology assessment that would
be available in the 2017 to 2025 time frame. The baseline vehicle's
overall mass, center of gravity and all key dimensions were determined.
Before the vehicle teardown, laboratory torsional stiffness tests,
bending stiffness tests and normal modes of vibration tests were
performed on baseline vehicles so that these results could be compared
with the CAE model of the light weighted design. After conducting a
full tear down and benchmarking of the baseline vehicle, a detailed CAE
model of the baseline vehicle was created and correlated with the
available crash test results. The project team then used computer
modeling and optimization techniques to design the light-weighted
pickup truck and optimized the vehicle structure considering redesign
of structural geometry, material grade and material gauge to achieve
the maximum amount of mass reduction while achieving comparable vehicle
performance as the baseline vehicle. Only technologies and materials
projected to be available for large scale production and available
within two to three design generations (e.g. model years 2020, 2025 and
2030) were chosen for the LWT design. Three design concepts were
evaluated: (1) A multi-material approach; (2) an aluminum intensive
approach; and (3) a Carbon Fiber Reinforced Plastics approach. The
multi-material approach was identified as the most cost effective. The
recommended materials (advanced high strength steels, aluminum,
magnesium and plastics), manufacturing processes, (stamping, hot
stamping, die casting, extrusions, and roll forming) and assembly
methods (spot welding, laser welding, riveting and adhesive bonding)
are currently used, although some to a lesser degree than others. These
technologies can be fully developed within the normal product design
cycle using the current design and development methods.
The design of the LWT was verified, through CAE modeling, that it
meets all relevant crash tests performance. The LS-DYNA finite element
software used by the EDAG team is an industry standard for crash
simulation and modeling. The researchers modeled the crashworthiness of
the LWT design
[[Page 73769]]
using the NCAP Frontal, Lateral Moving Deformable Barrier, and Lateral
Pole tests, along with the IIHS Roof, Lateral Moving Deformable
Barrier, and Frontal Offset (40 percent and 25 percent) tests. All of
the modeled tests were comparable to the actual crash tests performed
on the 2014 Silverado in the NHTSA database. Furthermore, the FMVSS No.
301 rear impact test was modeled and it showed no damage to the fuel
system.
The baseline 2014 MY Chevrolet Silverado's platform shares
components across several platforms. Some of the chassis components and
other structural components were designed to accommodate platform
derivatives, similar to the components in the baseline vehicle which
are shared across platforms such as GMT 920 (GM Tahoe, Cadillac
Escalade, GMC Yukon), GMT 930 platform (Chevy Suburban, Cadillac
Escalade ESV, GMC Yukon XL), and GMT 940 platform (Chevy Avalanche and
Cadillac Escalade EXT) and GMT 900 platform (GMC Sierra). As per the
National Academy of Science's guidelines, the study assumes engines
would be downsized or redesigned for mass reduction levels at or
greater than 10 percent. As a consequence of mass reduction, several of
the components used designs that were developed for other vehicles in
the weight category of light-weighted designed vehicles were used to
maximize economies of scale and resource limitations. Examples include
brake systems, fuel tanks, fuel lines, exhaust systems, wheels, and
other components.
Cost is a key consideration when vehicle manufacturers decide which
fuel-saving technology to apply to a vehicle. Incremental cost analysis
for all of the new technologies applied to reduce mass of the light-
duty full-size pickup truck designed were calculated. The cost
estimates include variable costs as well as non-variable costs, such as
the manufacturer's investment cost for tooling. The cost estimates
include all the costs directly related to manufacturing the components.
For example, for a stamped sheet metal part, the cost models estimate
the costs for each of the operations involved in the manufacturing
process, starting from blanking the steel from coil through the final
stamping operation to fabricate the component. The final estimated
total manufacturing cost and assembly cost are a sum total of all the
respective cost elements including the costs for material, tooling,
equipment, direct labor, energy, building and maintenance.
The information from the LWT design study was used to develop a
cost curve representing cost effective full vehicle solutions for a
wide range of mass reduction levels. At lower levels of mass reduction,
non-structural components and aluminum closures provide weight
reduction which can be incorporated independently without the redesign
of other components and are stand-alone solutions for the LWV. The
holistic vehicle design using a combination of AHSS and aluminum
provides good levels of mass reduction at reasonably acceptable cost.
The LWV solution achieves 17.6 percent mass reduction from the baseline
curb mass. Further two more analytical mass reduction solutions (all
aluminum and all carbon fiber reinforced plastics (CFRP)) were
developed to show additional mass reduction that could be potentially
achieved beyond the LWV mass reduction solution point. The aluminum
analytical solution predominantly uses aluminum including chassis frame
and other components. The carbon fiber reinforced plastics analytical
solution predominantly uses CFRP in many of the components. The CFRP
analytical solution shows higher level of mass reduction but at very
high costs. Note here that both all-Aluminum and all CFRP mass
reduction solutions are analytical solutions only and no computational
models were developed to examine all the performance metrics.
An analysis was also conducted to examine the cost sensitivity of
major vehicle systems to material cost and production volume
variations.
Table VI-11 lists the components included in the various levels of
mass reduction for the LWV solution. The components are incorporated in
a progression based on cost effectiveness.
Table VI-11--Components Included for Different Levels of Mass Reduction
----------------------------------------------------------------------------------------------------------------
Cumulative
Vehicle component/system mass saving Cumulative MR Cumulative Cumulative
(kg) (%) cost ($) cost ($/kg)
----------------------------------------------------------------------------------------------------------------
Interior Electrical Wiring...................... 1.38 0.06% (28.07) -20.34
Headliner....................................... 1.56 0.06 (29.00) -18.59
Trim--Plastic................................... 2.59 0.11 (34.30) -13.24
Trim--misc...................................... 4.32 0.18 (43.19) -10.00
Floor Covering.................................. 4.81 0.20 (45.69) -9.50
Headlamps....................................... 6.35 0.26 (45.69) -7.20
HVAC System..................................... 8.06 0.33 (45.69) -5.67
Tail Lamps...................................... 8.46 0.35 (45.69) -5.40
Chassis Frame................................... 54.82 2.25 2.57 0.05
Front Bumper.................................... 59.93 2.46 7.89 0.13
Rear Bumper..................................... 62.96 2.59 11.04 0.18
Towing Hitch.................................... 65.93 2.71 14.13 0.21
Rear Doors...................................... 77 3.17 28.09 0.36
Wheels.......................................... 102.25 4.20 68.89 0.67
Front Doors..................................... 116.66 4.80 92.53 0.79
Fenders......................................... 128.32 5.28 134.87 1.05
Front/Rear Seat & Console....................... 157.56 6.48 272.57 1.73
Steering Column Assy............................ 160.78 6.61 287.90 1.79
Pickup Box...................................... 204.74 8.42 498.35 2.43
Tailgate........................................ 213.14 8.76 538.55 2.53
Instrument Panel................................ 218.66 8.99 565.06 2.58
Instrument Panel Plastic Parts.................. 221.57 9.11 580.49 2.62
Cab............................................. 304.97 12.54 1,047.35 3.43
Radiator Support................................ 310.87 12.78 1,095.34 3.52
Powertrain...................................... 425.82 17.51 1246.68 2.93
----------------------------------------------------------------------------------------------------------------
[[Page 73770]]
A fitted curve was developed based on the above listed mass
reduction points to derive cost per kilogram at distinct mass reduction
points. The current curve shows costs per kilogram approximately six
times as expensive for 5 percent mass reduction (MR1) than in the NPRM,
and approximately twice as expensive per kilogram for 7.5 percent mass
reduction (MR2), which explains the reduction in mass reduction in the
current analysis relative to the NPRM.
D. NHTSA CAFE Model Analysis of the Regulatory Alternatives for HD
Pickups and Vans: Method A
EPCA and EISA require NHTSA 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 to establish corresponding fuel consumption standards
``that are appropriate, cost-effective, and technologically feasible.''
\501\ For both the NPRM and the current analysis of potential standards
for HD pickups and vans, NHTSA applied NHTSA's CAFE Compliance and
Effects Modeling System (sometimes referred to as ``the CAFE model'' or
``the Volpe model'') to aid in determination of the maximally feasible
standards. The subsequent analysis, referred to as ``Method A,''
includes several updates to the model and to accompanying inputs, as
discussed above in section 6.C. The ``Method A'' results are used as
the primary basis for NHTSA's final determination of the suitability of
the Phase 2 standards. Further discussion of the determination are
provided after the discussion of the ``Method A'' modeling results in
Section 6.C.(9) of this document.
---------------------------------------------------------------------------
\501\ 49 U.S.C. 32902(k)(2).
---------------------------------------------------------------------------
(1) Baseline Costs Across Manufacturers
As in the NPRM, the main analysis of Method A considers costs,
benefits and other effects of regulatory alternatives relative to the
dynamic baseline--or a baseline which assumes that manufacturers will
apply all technologies with associated cost that pays back from retail-
priced fuel savings within 6 months of purchase. The assumption is that
consumers are willing to pay additional technology costs that return in
fuel savings within 6-months of purchase, and that as a result,
manufacturers will adopt these technologies regardless of fuel
efficiency standards. We considered alternative runs with voluntary
overcompliance of technologies with a payback period of 0-months
(manufacturers will not voluntarily overcomply if there is a cost
associated with a technology), 12-months, 18-months, and 24-months in
the sensitivity analysis.
Before considering the effects of increases in the standards, it is
important to discuss the baseline costs. These costs are assumed to be
incurred even if no additional regulatory action is taken to increase
standards beyond the existing MY 2018 standards. Table VI-12 shows the
baseline average and total technology costs for each manufacturer in
the heavy duty market, and for the heavy duty industry as a whole for
the MY 2021 fleet (cost increases relative to the MY 2015 fleet). The
updated CAFE model suggests that under no further increasses to
stringency beyond MY 2018, manufacturers would spend $136 million--an
industry average of $180 per vehicle--on technologies that improve fuel
economy in MY 2021. The additonal baseline costs are not distributed
across all manufacturers proportional to their fleet size. The average
technology costs of an individual manufacturer fleet range from $80 per
vehicle for Fiat/Chrysler to $350 per vehicle for General Motors. In
order to explain this heterogeneity it is important to consider the
sources of increased technology costs: compliance actions, inheritance
from heavy duty vehicles, spillover inheritance from the light-duty
vehicles, and voluntary overcompliance.
Table VI-12--MY 2021 Costs (2013$) Under Alternative 1b (Central Baseline) for 2b3 Market
----------------------------------------------------------------------------------------------------------------
Average per Total Estimated MY
vehicle technology 2015 fuel Estimated MY
Manufacturer technology cost (million consumption (g/ 2018 standard
cost (2013$) 2013$) 100 mi) (g/100 mi)
----------------------------------------------------------------------------------------------------------------
Daimler......................................... 150 3 4.50 4.84
FCA............................................. 80 10 6.23 5.95
Ford............................................ 90 33 6.00 5.76
GM.............................................. 350 86 6.52 5.94
Nissan.......................................... 230 3 6.01 5.63
Industry........................................ 180 136 6.18 5.83
----------------------------------------------------------------------------------------------------------------
One reason manufacturers incur technology costs in the baseline for
MY 2021 vehicles is to achieve compliance with Phase 1 standards, which
end their stringency increases in MY 2018. Manufacturers will have
different standards and different starting positions relative to these
standards. In order to indicate which manufacturers make compliance
actions which increase their baseline technology costs, Table VI-12
includes the MY 2015 estimated average fuel consumption and the
estimated MY 2018 fuel consumption standard--manufacturers with higher
average fuel consumption in MY 2015 than the estimated MY 2018 fuel
consumption standard, will apply technology costs to comply with the
final MY 2018 standards. The fuel consumption standards are determined
by setting work factor based targets and computing the manufacturer's
sales-weighted average of these targets. While the individual vehicle
targets based on work factor are the same for all vehicles of the same
work factor for model years 2018 and beyond, the overall fuel
efficiency standard for a manufacturer may change from model year to
model year with changes to the work factors of individual vehicle
models, as well as changes in relative production volumes of each
vehicle model. The model does not capture all means by which a
manufacturer's average fuel efficiency standard may change under the MY
2018 attribute-based standards, but does capture changes to work
factor--and therefore individual vehicle targets--due to application of
mass reduction. The model also predicts changes to the fleet mix of
each manufacturer using inputs created from AEO2015 and 2015 IHS/Polk
production projections. The
[[Page 73771]]
technology cost for a manufacturer to meet MY 2018 standards is
primarily driven by the fuel consumption gap between the MY 2015
(baseline) compliance level and the 2018 standard. From Table VI.4 it
can be seen that only Daimler meets its most-stringent fuel consumption
standard in 2015 and does not have to apply technology in the baseline
to comply with Phase 1 standards.
A second source of technology costs is from inheritance; vehicles
with shared platforms are assumed to inherit technologies applied to
the platform leader at their next redesign or refresh to avoid creating
a new body or engine platform,\502\ even if these actions are no longer
necessary to reach compliance. Manufacturers produce a limited set of
engine and body platforms as a strategy to reduce their costs; there is
no reason to indicate they will modify this strategy to comply with
standards, for this reason this is an important constraint in the CAFE
model. A similar source of technology costs are costs associated with
spillover from the light-duty MY 2017-2021 standards. Regulatory
agencies distinctly define the heavy duty and light duty classes, but
from the manufacturer perspective these classes are not clearly
delineated. They share some engine and body platforms across regulatory
classes, and sometimes the most cost-effective choice to comply with
standards will involve making changes to these shared platforms.
Comments in the NPRM recommended that we run the model with the ability
to capture this spillover effect between the light-duty and heavy-duty
fleets--in response to these comments, in the current analysis we run
the two fleets together with all existing standards from the light-duty
fleet included for all scenarios. Since the MY 2017-2021 light-duty
CAFE standards are final, these and their effects are included in the
baseline of the model--they will be in effect whether or not additional
action is taken with heavy-duty standards. While we have included the
ability for the standards from one fleet to affect the other, our
modeling has shown that the spilloever effect from the light-duty fleet
into the heavy-duty fleet, and from the heavy-duty fleet into the
light-duty fleet is small. We hope to further develop the model's
ability to capture the spillover effects in future versions of the
model.
---------------------------------------------------------------------------
\502\ For a more complete discussion of inheritance in the model
see Chapter 6, Section C.
---------------------------------------------------------------------------
The final way that manufacturers might accrue additional technology
costs in the MY 2021 dynamic baseline scenario is through voluntary
overcompliance. As already discussed: In the baseline case of the
central analysis it is assumed that manufacturers will apply
technologies which payback in fuel savings within 6 months of
operation, regardless of whether or not the standards increase in
stringency. Depending on the existing technologies and vehicles in a
manufacturer's fleet, they may voluntarily overcomply by adding
different technologies, or none at all.
The MY 2021 costs of the dynamic baseline scenario are lower in the
updated analysis than they were in the NPRM for all manufacturers other
than Nissan and Daimler. The average technology costs across the
industry are less than half the NPRM costs--dropping from $440/vehicle
to $180/vehicle. The largest drop in average costs across the
manufacturers is for GM; their costs dropped from $780/vehicle to $350/
vehicle. The modeled costs for Nissan dropped from $280 to $230, and
for FCA, from $280 to $80.
While considering MY 2021 allows for comparision to the NPRM
analysis, not all baseline costs are incurred in MY 2021. Figure VI-
8shows the baseline total technology costs, andFigure VI-9, the average
technology costs, by manufacturer for all model years. Like the NPRM
analysis assumes manufacturers will likely apply most technologies as
part of vehicle redesign or freshening; as a result their technology
application comes in discrete blocks. GM applies $20 million in total
technolgy for their MY 2016 fleet, and an additional $60 million in for
MY 2018--their total technology costs vary slightly after this point
with the projection of their fleet size and with the effects of
technology learning. Similarly, Ford applies $30 million for MY 2017
and an additional $80 million in 2027. Chrysler/Fiat, Daimler, and
Nissan apply technology in only one year--Chrysler/Fiat applies $11
million in MY 2018, Daimler $3 million for MY 2020, and Nissan $3
million for MY 2021. While the total technology costs vary between
manufacturers, the per-vehicle baseline costs range between $0-350 for
all manufacturers and model years.
[[Page 73772]]
[GRAPHIC] [TIFF OMITTED] TR25OC16.018
(2) Relevant Model Updates
There are changes to model that help explain the decrease in
baseline technology costs for the current analysis. The current
analysis uses the synergies simulated by Argonne for the light-duty
fleet, while the NPRM analysis uses a limited set of synergy values
(also initially estimated for the light-duty fleet. The changes in
these synergy factors could impact which technologies are chosen, and
how effective the model calculates them to
[[Page 73773]]
be.\503\ Changes to the model input costs from the NPRM to the current
analysis could also change which technologies get picked by the model,
and the projected costs. One of the major changes to costs is a switch
from the ICM cost mark-up methodology used in the NPRM to the RPE cost
mark-up methodology of the current analysis.\504\ A more specific
change to the input costs is a change to the mass reduction curve to be
based off of the newer 2014 Silverado study, which suggests that 5
percent and 10 percent mass reduction is significantly more expensive
than was assumed in the NPRM.\505\
---------------------------------------------------------------------------
\503\ For a more complete discussion of the changes to the
Argonne simulation synergies see Chapter 6, Section C.
\504\ For further discussion on the switch from ICM to RPE for
the final analysis see Chapter 6, Section C.
\505\ More discussion of the change in mass reduction curves is
present in Chapter 6, Section C.
---------------------------------------------------------------------------
The final major input change is that the current model uses the
2015 fleet as its reference point, while the NPRM uses the 2014 fleet.
This affects the starting point of each manufacturer in the model, and
could change their predicted standard (through changes in sales mix and
work factor). In order to consider the impacts of using the 2015
reference fleet it is helpful to consider the sales-weighted fuel
economy and work factor distributions across the two reference fleets.
Figure VI-10 shows the sales-weighted empirical cumulative
distribution function (CDF) for GM's work factor and fuel economy for
the two reference fleets. The dashed line shows the values for the 2014
reference fleet, and the solid, for the 2015 reference fleet. The y-
axis shows the cumulative share of the manufacturer's fleet against the
two measures. For GM, the work factor CDF shifted to the right for work
factors between 3500 and 5500, suggesting that the proportion of the
fleet with work factors in this range increased in the GM fleet. Since
increases in work factor will decrease the target value for individual
vehicles, this average change in work factor decreases GM's initial
CAFE standard.
It should also be noted that some methods of increasing work factor
(mainly, decreasing curb weight) can increase the fuel efficiency of a
vehicle, while others (increasing the power) can decrease fuel
efficiency. The empirical CDF for GM's sales-weighted fuel consumption
shows GM's 2015 fleet as having more vehicles with fuel consumption
below 6.3 gal/100 mi, fewer with fuel consumption around 6.3 gal/100
mi, significantly more vehicles with fuel consumption around 7.0 gal/
100 mi. The average fuel consumption of GM's 2014 fleet was 6.27 gal/
100 mi, where the average fuel consumption of GM's 2015 fleet is 6.52
gal/100 mi. The overall increase in GM's average fuel consumption
diminishes the effect of the increase in work factor from MY 2014 to MY
2015 at improving their starting position in MY 2015 relative to MY
2014--their MY 2015 standard using the 2014 fleet was 6.36, and using
the 2014 fleet and is 6.59. Considering this, their initial shortfall
is about the same using either reference fleet.
[GRAPHIC] [TIFF OMITTED] TR25OC16.019
Figure VI-11 shows the same for Ford. There is a similar pattern of
a higher proportion of heavy duty vehicles in Ford's fleet with work
factors between 3500 and 5000. This will decrease Ford's initial
standard in the model. Ford also shows a decrease in the proportion of
heavy duty vehicles with higher fuel consumption, which will result in
an overall lower fuel consumption for the 2015 fleet. The result is
that Ford will start with a lower standard by using the 2015 fleet
rather than the 2014 fleet, and start with a higher fuel efficiency
level--both of which will work in the same direction to decrease Ford's
shortfall to MY 2018 standards. This suggests that Ford will not need
to apply as much technology to comply, and helps to explain their lower
baseline technology costs in the current analysis.
[[Page 73774]]
[GRAPHIC] [TIFF OMITTED] TR25OC16.020
Figure VI-12 shows the cumulative distribution function for the
work factor of Fiat/Chrysler. Although there is some increase in the
left tail of the distribution of FCA's work factor for MY 2015 relative
to MY 2014, it is smaller than for the Ford and GM fleets. The CDF of
fuel efficiency also shows that Fiat/Chrysler shows nearly identical
distribution of fuel consumption between the 2014 and 2015 fleets.
These two factors combine to explain why Fiat/Chrysler did not show
increases in costs from the NPRM to the current analysis--they did not
have as much of a change in shortfall to MY 2018 standards as both GM
and Ford.
[GRAPHIC] [TIFF OMITTED] TR25OC16.021
Figure VI-13 shows the same empirical distribution functions for
Nissan. Both the distribution of work factor and fuel consumption are
comparable for Nissan's 2014 and 2015 fleets. This helps explain the
small change in Nissan's baseline costs between the two analyses.
[[Page 73775]]
[GRAPHIC] [TIFF OMITTED] TR25OC16.022
Figure VI-14 shows the cumulative distribution function for work
factor and fuel consumption for Daimler for both the 2014 and 2015
fleets. The distribution of work factor shifted right for work factors
above 3500. The fuel consumption curve shifted right for all fuel
consumptions. This suggests that Daimler will face a lower standard
using the 2015 reference fleet, but that they may also start with a
lower initial fuel efficiency level. The change to the 2015 reference
fleet does not have clear implications on the relative starting point
of Daimler in the analysis relative to the NPRM analysis.
[GRAPHIC] [TIFF OMITTED] TR25OC16.023
(3) Industry-Level Results of Regulatory Alternatives
Table VI-13, below, summarizes the stringency of standards, the
estimated required fuel efficiency the estimated achieved fuel
efficiency, as well as the impacts of each alternative for the overall
industry for MY 2030. Using the updated fleet and analysis, the MY 2030
stringency is slightly less that in the NPRM (4.91 gallons/100 mile in
today's analysis compared to 4.86 gallons/100 mile in the NPRM for the
preferred alternative). As has been noted, the standards are set based
in part on the work factor of vehicles; by changing the average work
factor of their fleet, manufacturers can change the average stringency
of their standard. While the model does not simulate changes to work
factor which would increase the
[[Page 73776]]
power or GVWR, it does simulate changes in work factor due to mass
reduction. By lowering the curb weight and holding power constant,
manufacturers can increase the payload of a vehicle; since payload is a
component in calculating the work factor, by lowering curb weight
manufacturers can increase their work factor for a vehicle model and
reduce its target. However, the average absolute and proportional curb
weight reduction in the current analysis is less than it was in the
NPRM analysis across all alternatives, which can be explained by the
higher mass reduction costs under the current curve. This suggests that
the change in the average overall industry standard in today's analysis
is likely due in major part to changes in the work factor between the
2014 and 2015 reference fleet, and not to changes in the work factor
simulated within the model runs.
Table VI-13--Summary of Impacts on the MY 2030 HD Industry Fleet (vs. Alternative 1b)
----------------------------------------------------------------------------------------------------------------
Alternative 2 3 4 5
----------------------------------------------------------------------------------------------------------------
Stringency of Standards
----------------------------------------------------------------------------------------------------------------
Annual Increase in Stringency Beginning in MY 2021.......... 2.0% 2.5% 3.5% 4.0%
Increases Until............................................. MY 2025 MY 2027 MY 2025 MY 2025
Total Increase in MY 2030 Stringency Relative to Final Phase 9.6% 15.6% 15.6% 17.9%
1 Standards \a\............................................
----------------------------------------------------------------------------------------------------------------
Estimated Average Fuel Economy (miles per gallon)
----------------------------------------------------------------------------------------------------------------
Required in MY 2030......................................... 19.03 20.37 20.38 20.95
Achieved in MY 2030......................................... 19.20 20.47 20.45 20.98
----------------------------------------------------------------------------------------------------------------
Average Fuel Consumption (gallons/100 miles)
----------------------------------------------------------------------------------------------------------------
Required in MY 2030......................................... 5.25 4.91 4.91 4.77
Achieved in MY 2030......................................... 5.21 4.88 4.89 4.77
----------------------------------------------------------------------------------------------------------------
Estimated Average Greenhouse Gas Emissions (grams per mile)
----------------------------------------------------------------------------------------------------------------
CO[ihel2] Required in MY 2030............................... 494 462 462 450
CO[ihel2] Achieved in MY 2030............................... 490 460 460 449
----------------------------------------------------------------------------------------------------------------
Technology Penetration in MY 2030 (percent)
----------------------------------------------------------------------------------------------------------------
VVT and/or VVL.............................................. 56 56 56 56
Cylinder Deactivation....................................... 4 4 4 4
Direct Injection Engine..................................... 17 27 26 29
Turbo Charged Engine........................................ 59 69 68 68
8 Speed Auto. Trans......................................... 77 95 94 95
EPS, Accessories............................................ 52 80 80 96
12V Stop-start.............................................. 0 0 3 11
Strong Hybrid............................................... 0 2 2 7
Aero. Improvements.......................................... 46 80 80 98
----------------------------------------------------------------------------------------------------------------
Mass Reduction (vs. No-Action)
----------------------------------------------------------------------------------------------------------------
Mass Reduction (lb.)........................................ 28 240 24 289
Mass Reduction (percent of curb weight)..................... 0.43 3.6 3.7 4.3
----------------------------------------------------------------------------------------------------------------
Technology Costs (vs. No-Action)
----------------------------------------------------------------------------------------------------------------
Average Vehicle ($)......................................... $500 $1470 $1480 $1890
Payback Period (m) \b\...................................... 19 30 31 33
----------------------------------------------------------------------------------------------------------------
Notes:
\a\ This increase in stringency is based on the estimated percentage change in fuel consumption (gal/100mi)
stringency projected by the model for the MY 2030 fleet under the final Phase 2 standards relative to the
continuation of Phase 1 standards. Note that if manufacturers' have applied mass reduction to an individual
vehicle model in the CAF[Eacute] model that this will increase the work factor of that vehicle in the model,
and make the individual target less stringent. Thus, where any mass reduction is applied in the model, the
total increase in stringency of the fleet presented here will be lower than the total stringency increase of
the fleet if no mass reduction were applied.
\b\ Here payback period is calculated using estimated undiscounted retail fuel savings and the initial
technology costs for MY 2030.
Today's Method A analysis using the updated version of the CAFE
model and updated inputs shows that regulatory Alternatives 3 and 4
could be met with a small application of strong (P2) HEVs. However,
Alternative 5 could be met with the considerably greater application of
strong HEVs. Although there is some increase in the penetration rates
between alternatives as stringency increases, the current analysis
suggests that under all alternatives, nearly all of the MY 2030 heavy-
duty fleet could use 8-speed transmissions, VVT/VVL improvements and
turbo-charged engines with application across more than half of the
fleet, direct injection could be present in a quarter of the fleet, and
cylinder deactivation could play a minor part in the HD fleet. EPS and
improved electrical accessories vary more between alternatives; present
in 52 percent of the fleet in Alterative 2, 80 percent in Alternatives
3 and 4, and 96 percent in Alternative 5. Aerodynamic improvements and
mass reduction follow a similar pattern; with a larger penetration of
these technologies with Alternative 3 than with Alternative 2, a
similar penetration under Alternatives 3
[[Page 73777]]
and 4, and a higher in penetration in Alternative 5.
A way to measure the cost-effectiveness of the technologies on
consumers is to look at the payback period. In this context, the
payback period is defined as the number of months of driving it will
take a consumer to earn back the increased technology costs by the
amount they save in fuel by driving a more fuel efficient vehicle.
Under the current analysis, the average additional technology cost will
payback in fuel savings in under 17 months for Alternative 2, 27 months
for Alternatives 3 and 4, and 30 months for Alternative 5. It is
important to note that there are inputs other than the cost and
effectiveness of technologies which could affect the payback period;
the fuel prices and mileage accumulation schedules will affect how
quickly the cost of a fuel-saving technology pays back.
The current analysis uses updated fuel price estimates from AEO
2015 that are lower than in the NPRM analysis. Lower fuel prices will
decrease the absolute amount of fuel savings (assuming the same number
of gallons is consumed) and increase the payback period if the
technologies, their cost, and their effectiveness are unchanged.
Further, we have updated the vehicle use schedule (vehicle miles
traveled, or VMT) based on actual vehicle odometer readings from IHS/
Polk data as shown in Figure VI.6 While the overall survival-weighted
schedules show 6.5 percent fewer lifetime miles for heavy-duty
vehicles, they show more annual miles driven for the first 5-years of
use for heavy-duty vehicles. The result is that the overall lifetime
fuel savings will decrease, but the fuel savings will be higher for the
first 5 years. Since the payback periods under both analyses are
shorter than 5 years, using the updated vehicle schedules will show a
shorter payback period (if other factors are unchanged) than in the
NPRM analysis. The changes in fuel prices and the change in the mileage
accumulation schedule work in opposite directions on the payback
period; the total change in payback period is attributable to both of
these input changes as well as to the changes in the cost \506\ and
effectiveness \507\ of the different technology inputs, and the changes
in the reference fleet.
---------------------------------------------------------------------------
\506\ The costs now use RPE rather than ICM, and we updated the
mass reduction curve to the 2014 Silverado.
\507\ Nominal effectiveness input values are as for the NPRM
analysis. Synergy factors applied to adjust fuel consumption impacts
for specific combinations of technologies reflect current vehicle
simulation work conducted for NHTSA by Argonne National Laboratory.
---------------------------------------------------------------------------
Industry costs in MY 2030 provide one perspective on technology
costs. Industry cost in each model year provides additional perspective
on the timing, pace and the amount of resources and spending that would
need to be allocated to implement technologies and is important in the
consideration of the feasibility of the alternatives. Figures Figure
VI-15and Figure VI-16 show the total and average additional and total
additional technology costs for the industry by model year and
alternative. Note that the trend of the total and average costs are
very similar, this is because the fleets size the AEO projections
suggest a relatively constant fleet size during the considered MY's.
The total and average technology costs increase with alternative
stringency. It is important to note that Alternatives 3 and 4 both
increase total stringency for the MY 2030 industry fleet by 15.6
percent. Also note that these estimations of stringency increases
include the model projections of how the application of mass reduction
will alter work factor and individual vehicle targets.\508\ The annual
average and total technology costs of Alternative 3 approach those of
Alternative 4 by MY 2029 when both alternatives have reached maximum
stringency. If manufacturers are to reach the same stringency level
over a longer horizon, they will likely make similar technology
choices, but be given longer to implement them. This will make the
total technology costs lower, but should unsurprisingly make the
marginal technology costs for model years where both standards have
matured very similar.
---------------------------------------------------------------------------
\508\ The final Phase 2 standard target curves increase in
stringency by 16.2 percent compared to final Phase 1 standards, as
discussed in section VI.B.
---------------------------------------------------------------------------
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[[Page 73778]]
[GRAPHIC] [TIFF OMITTED] TR25OC16.024
The average incremental industry technology costs mature to around
$500 under Alternative 2, $1500 under Alternatives 3 and 4, and $1900
under Alternative 5. Figure VI-17 shows the cumulative total industry
costs by model year fleet. $4.2 billion in additional technology costs
for model years 2016-2030 are associated with Alternative 2, $9.9
billion with Alternative 3, $11.4 billion with Alternative 4, and $14.9
billion with Alternative 5. While the marginal technology costs of
Alternative 3 approach those of Alternative 4 as the
[[Page 73779]]
total stringencies converge, the total costs of Alternative 4 are $1.5
billion more by MY 2030. It is particularly noteworthy that costs and
the rate of increase in costs would be significantly different in the
MYs 2017-2021 timeframe among the alternatives. This identifies the
significant differences in the resources and capital that would be
required to implement the technologies required to comply with each of
the alternatives during this period, as well as the reduction in lead
time to implement the technologies which increases reliability risk.
These differences are an important consideration for the feasibility of
the alternatives and for the selection of the final standards, as
discussed further below.
[GRAPHIC] [TIFF OMITTED] TR25OC16.025
BILLING CODE 6560-50-C
(4) Manufacturer-Specific Results of Regulatory Alternatives
In addition to varying across scenario and model year, the impacts
of the standards vary across manufacturers. Manufacturers will have
different compliance strategies based on which technologies they have
already invested in, in both their heavy-duty and light-duty fleets,
and based on the effectiveness of new technology applications specific
to the vehicles in their heavy duty fleets. Table VI-14 summarizes the
initial technology utilization in the 2015 fleet by manufacturer. Ford
uses direct injection for 8 percent of their fleet, cylinder
deactivation for 13 percent of their fleet, and turbo-charged engines
for 8 percent of their fleet. Daimler has already invested to equip all
of its fleet with 8-speed automatic transmissions. These differences in
initial technology levels affect the new investments each manufacturer
would need to further improve the fuel efficiency of their fleets.
Table VI-14--Summary of MY 2015 Reference Fleet Technology Penetration
--------------------------------------------------------------------------------------------------------------------------------------------------------
Technology Penetration (percent)
Technology -----------------------------------------------------------------------------------------------
GM Ford FCA Daimler Nissan Industry
--------------------------------------------------------------------------------------------------------------------------------------------------------
Cylinder Deactivation................................... 0 0 13 0 0 2
Direct Injection Engine................................. 0 8 0 0 0 4
Turbo Charged Engine.................................... 0 8 0 0 0 4
8 Speed Auto. Trans..................................... 0 0 0 100 0 3
EPS, Accessories........................................ 0 0 0 0 0 0
12V Stop-start.......................................... 0 0 0 0 0 0
Strong Hybrid........................................... 0 0 0 0 0 0
Aero. Improvements...................................... 0 0 0 0 0 0
--------------------------------------------------------------------------------------------------------------------------------------------------------
[[Page 73780]]
Table VI-15 summarizes the alternatives, and a technology pathway
General Motors could use to comply with each of the alternatives. The
pathway includes implementing 8 speed automatic transmissions across
its entire fleet. For Alternatives 2 and 3, no stop-start or HEVs are
added to GM's fleet, for Alternative 4, 1 percent of GM's fleet uses
stop-start, and for Alternative 5, 2 percent uses stop-start and 13
percent are HEVs. For all alternatives, nearly all of the GM's fleet
would use electric power steering and improved electric accessories.
For all alternatives, VVT/VVL is applied to 65 percent of its
engines. For Alternative 2, none of its engines get direct injection
and 43 percent get turbocharging and downsizing, while for Alternatives
3-5, direct injection is applied to 28 percent of its engines and
turbocharging and downsizing is applied to 61 percent of its engines.
For all alternatives, all of GM's fleet gets aerodynamic improvements.
The average mass reduction is 52 lbs. (0.78 percent of the average curb
weight) under Alternative 2, and 350-380 lbs. (5.2-5.7 percent of the
average curb weight) under Alternatives 3-5. Similar technology is
applied for Alternatives 3 and 4 in MY 2030, but there are
significantly more strong hybrids under Alternative 5.
Table VI-15--Summary Impacts on General Motors HD Fleet by Alternative (vs. Alternative 1b)
----------------------------------------------------------------------------------------------------------------
Alternative 2 3 4 5
----------------------------------------------------------------------------------------------------------------
Alternative Stringency
----------------------------------------------------------------------------------------------------------------
Annual Increase in Stringency Beginning in MY 2021.......... 2.0% 2.5% 3.5% 4.0%
Increases Until............................................. MY 2025 MY 2027 MY 2025 MY 2025
Total Increase in MY 2030 Stringency Relative to Final Phase 9.6% 15.2% 15.4% 17.7%
1 Standards \a\............................................
----------------------------------------------------------------------------------------------------------------
Estimated Average Fuel Economy (miles per gallon)
----------------------------------------------------------------------------------------------------------------
Required in MY 2030......................................... 18.69 19.92 19.96 20.53
Achieved in MY 2030......................................... 18.70 20.04 20.04 20.6
----------------------------------------------------------------------------------------------------------------
Average Fuel Consumption (gallons/100 miles)
----------------------------------------------------------------------------------------------------------------
Required in MY 2030......................................... 5.35 5.02 5.01 4.87
Achieved in MY 2030......................................... 5.35 4.99 4.99 4.85
----------------------------------------------------------------------------------------------------------------
Estimated Average Greenhouse Gas Emissions (grams per mile)
----------------------------------------------------------------------------------------------------------------
CO[ihel2] Required in MY 2030............................... 498 467 466 453
CO[ihel2] Achieved in MY 2030............................... 496 464 464 452
----------------------------------------------------------------------------------------------------------------
Technology Penetration in MY 2030 (percent)
----------------------------------------------------------------------------------------------------------------
VVT and/or VVL.............................................. 65 65 65 65
Cylinder Deactivation....................................... 0 0 0 0
Direct Injection Engine..................................... 0 28 28 28
Turbo Charged Engine........................................ 33 61 61 61
8 Speed Auto. Trans......................................... 100 100 100 100
EPS, Accessories............................................ 100 100 100 100
12V Stop-start.............................................. 0 0 2 2
Strong Hybrid............................................... 0 0 0 13
Aero. Improvements.......................................... 100 100 100 100
----------------------------------------------------------------------------------------------------------------
Mass Reduction (vs. No-Action)
----------------------------------------------------------------------------------------------------------------
Curb Weight Mass Reduction (lb.)............................ 52 384 384 340
Mass Reduction (percent of curb weight)..................... 0.78 5.7 5.7 5.1
----------------------------------------------------------------------------------------------------------------
Note:
\a\ This increase in stringency is based on the estimated percentage change in fuel consumption (gal/100mi)
stringency projected by the model for the MY 2030 fleet under the final Phase 2 standards relative to the
continuation of Phase 1 standards. Note that if manufacturers' have applied mass reduction to an individual
vehicle model in the CAF[Eacute] model that this will increase the work factor of that vehicle in the model,
and make the individual target less stringent. Thus, where any mass reduction is applied in the model, the
total increase in stringency of the fleet presented here will be lower than the total stringency increase of
the fleet if no mass reduction were applied.
Figure VI-18 and Figure VI-19 show the total and average
incremental technology costs by alternative. Under Alternative 2
General Motors' incremental technology cost is $140M in MY 2019,
increasing to $180M in MY 2021. The pathways for Alternatives 3 and 4
are very similar, which again should not be surprising given that the
standards result in the same total stringency increase in MY 2027 and
beyond and the long redesign cycles in the segment. GM's incremental
technology cost is $190M in MY 2019, increasing to $400M in MY 2021,
and $530M in MY 2028. Under Alternative 5 GM could have a similar
compliance strategy as Alternative 3 and 4, but incremental technology
cost is $650M in MY 2028. The highest annual average technology cost
for GM is: $750 under Alternative 2, $1940 under Alternatives 3 and 4,
and $2370 under Alternative 5. In the case of GM, the added lead time
of Alternative 4 does not significantly change the cost of their
compliance strategy.
BILLING CODE 6560-50-P
[[Page 73781]]
[GRAPHIC] [TIFF OMITTED] TR25OC16.026
Figure VI-20 shows the cumulative total incremental costs for GM
under all alternatives. The total costs to comply with Alternative 2
for GM for MY's 2016-2030 is $2.1 billion, for Alternatives 3 and 4 it
is $4.8 billion, and for Alternative 5 it is $5.2 billion.
[[Page 73782]]
[GRAPHIC] [TIFF OMITTED] TR25OC16.027
BILLING CODE 6560-50-C
Table VI-16 gives the same summary of a potential compliance
strategy for Ford's heavy-duty fleet. Similar to GM, to reach
compliance Ford uses 8 speed automatic transmissions in their entire
fleet. For Alternatives 3 and 4, Ford uses hybrid technologies in 4
percent of their fleet, and for Alternative 5, they use hybrid
technologies in 7 percent of their fleet. In addition to strong
hybrids, Ford uses 12v stop-start in 4 percent of their fleet in
Alternative 4, and 12v stop-start in 19 percent of their fleet in
Alternative 5. The compliance strategy in the NPRM analysis shows Ford
using significantly more hybrids and 12v stop-start systems in
Alternatives 4 and 5 than the current analysis which likely explains
part of the lowered cost for Ford in the current analysis.
Under the current analysis possible compliance strategy, the
application of engine technologies for Ford come in discrete chunks, as
with GM. Ford uses VVT/VVL in 58 percent of their fleet under all
alternatives by MY 2030; they started with 8 percent direct-injection
engines, and end with 27 percent; they also started with 8 percent
turbo-charged engines, but end with 69 percent for all scenarios. The
application of EPS and improved accessories vary across the compliance
strategies of different regulatory alternatives; under Alternative 2,
only 13 percent of Ford's fleet improves these electrical features,
while under Alternatives 3-4, 64 percent, and Alternative 5, 96
percent.
For body-platform technologies, Ford applies in discrete chunks to
the same platforms across some Alternatives. They apply an average of
77 lb. (1.2 percent) mass reduction across their fleet in Alternative 2
and 132-142 lb. (2.0-2.2 percent) in Alternative 3-5. Progressively
less mass reduction is applied under Alternatives 4 and 5--this is
likely because more of the fleet was hybridized and mass reduction to
small platforms was no longer necessary to comply. Aerodynamic
improvements are not applied in Alternative 2, but are applied to 64
percent of the fleet in Alternative 3 and 4, and to all of the fleet in
Alternative 5.
Table VI-16--Summary of Impacts on Ford HD Fleet by Alternative (vs. Alternative 1b)
----------------------------------------------------------------------------------------------------------------
Alternative 2 3 4 5
----------------------------------------------------------------------------------------------------------------
Alternative Stringency
----------------------------------------------------------------------------------------------------------------
Annual Increase in Stringency Beginning in MY 2.0% 2.5% 3.5% 4.0%
2021...........................................
Increases Until................................. MY 2025 MY 2027 MY 2025 MY 2025
Total Increase in MY 2030 Stringency Relative to 9.6% 15.7% 15.7% 18.1%
Final Phase 1 Standards \a\....................
----------------------------------------------------------------------------------------------------------------
Estimated Average Fuel Economy (miles per gallon)
----------------------------------------------------------------------------------------------------------------
Required in MY 2030............................. 19.23 20.62 20.62 21.23
Achieved in MY 2030............................. 19.36 20.61 20.63 21.21
----------------------------------------------------------------------------------------------------------------
Average Fuel Consumption (gallons/100 miles)
----------------------------------------------------------------------------------------------------------------
Required in MY 2030............................. 5.2 4.85 4.85 4.71
Achieved in MY 2030............................. 5.16 4.85 4.85 4.71
----------------------------------------------------------------------------------------------------------------
[[Page 73783]]
Estimated Average Greenhouse Gas Emissions (grams per mile)
----------------------------------------------------------------------------------------------------------------
CO2 Required in MY 2030......................... 488 456 455 443
CO2 Achieved in MY 2030......................... 485 455 455 443
----------------------------------------------------------------------------------------------------------------
Technology Penetration in MY 2030 (percent)
----------------------------------------------------------------------------------------------------------------
VVT and/or VVL.................................. 58 58 58 58
Cylinder Deactivation........................... 0 0 0 0
Direct Injection Engine......................... 27 27 27 27
Turbo Charged Engine............................ 69 69 69 69
8 Speed Auto. Trans............................. 64 100 100 100
EPS, Accessories................................ 13 64 64 96
12V Stop-start.................................. 0 0 4 19
Hybridization................................... 0 4 4 7
Aero. Improvements.............................. 0 64 64 100
----------------------------------------------------------------------------------------------------------------
Mass Reduction (vs. No-Action)
----------------------------------------------------------------------------------------------------------------
Curb Weight Mass Reduction (lb.)................ 77 142 140 132
Mass Reduction (percent of curb weight)......... 1.2 2.2 2.1 2.0
----------------------------------------------------------------------------------------------------------------
Note:
\a\ This increase in stringency is based on the estimated percentage change in fuel consumption (gal/100mi)
stringency projected by the model for the MY 2030 fleet under the final Phase 2 standards relative to the
continuation of Phase 1 standards. Note that if manufacturers' have applied mass reduction to an individual
vehicle model in the CAF[Eacute] model that this will increase the work factor of that vehicle in the model,
and make the individual target less stringent. Thus, where any mass reduction is applied in the model, the
total increase in stringency of the fleet presented here will be lower than the total stringency increase of
the fleet if no mass reduction were applied.
BILLING CODE 6560-50-P
Figure VI-21 and Figure VI-22 show the total and average
incremental technology costs for Ford by alternative and model year.
Ford adds $80 million in technology costs for MY 2017 and an additional
$40 million in MY 2026 in Alternative 2. For the Preferred Alternative,
Ford adds $130 million in MY 2017 and an additional $300 million in MY
2026. Under Alternative 4, Ford adds $260 million in MY 2017 and $180
million in MY 2026. Similar to the industry pattern, Ford's compliance
strategy involves less annual technology costs early in Alternative 3
than Alternative 4, but their technology costs converge under the two
alternatives as the final stringency level is reached under Alternative
3 in MY 2027.
It is important to note that the increase in costs and rate of the
increase in costs is significantly different for MY 2017 among the
alternatives--with the incremental total cost increase for MY 2017
being double those of Alternative 3 for Alternative 4, and more than
double for Alternative 5. MY 2017 is the first redesign year and Ford
does not have another scheduled redesign until MY 2026. Under the
additional lead time of Alternative 3, the majority of Ford's cost
increases occur in the MY 2026 redesign, while Alternatives 4 and 5 put
most of the cost burden to reach compliance on the MY 2017 redesign (or
would require an additional redesign be added between MY 2017 and
2026).
NHTSA judges the lack of lead time would make Alternatives 4 and 5
beyond maximum feasibility for Ford because its designs for MY 2017 are
essentially complete and substantial resources and very high costs
would be required to add another vehicle redesign between MY 2017 and
MY 2026 to implement the technologies that would be needed to comply
with those alternatives.
BILLING CODE 6560-50-P
[[Page 73784]]
[GRAPHIC] [TIFF OMITTED] TR25OC16.028
Figure VI-23 below shows the cumulative total costs for Ford under
all action alternatives. The total costs for MY's 2015-2030 under
Alternative 2 are $1.3 billion, under Alternative 3 they are $3.4
billion, for Alternative 4 they are $4.5 billion, and finally for
Alternative 5 they are $6.7 billion. This further illustrates the point
that manufacturers act to minimize costs over multiple model years. The
added lead time from Alternative 4 allows them to delay some actions,
which will allow them more time to make sure that they are well-
implemented.
[[Page 73785]]
[GRAPHIC] [TIFF OMITTED] TR25OC16.029
BILLING CODE 6560-50-C
Table VI-17 shows the MY 2030 summary for Fiat/Chrysler. Fiat/
Chrysler is the only manufacturer which uses cylinder deactivation in
their reference fleet, and they are the only manufacturer to use
cylinder deactivation as a part of their possible compliance strategy.
Under all scenarios, FCA increases their initial cylinder deactivation
utilization of 13 percent to 24 percent. Under all scenarios turbo-
charged engines are applied to 76 percent of FCA's fleet by MY 2030.
Other technologies are applied to the FCA equally across all scenarios;
37 percent of their fleet uses VVT and/or VVL, and 64 percent uses 8-
speed automatic transmissions under all scenarios.
The additional stringency from Alternative 2 to Alternatives 3-5
results in other increased technology applications in the FCA fleet.
Under Alternatives 3-5, the presence of EPS/electrical accessories
increases from the 82 percent to the entirety of the FCA fleet.
Similarly, increased aerodynamic improvements increase from 84 percent
of the fleet to all of it. Finally, 12v stop-start enters 3 percent of
the fleet under Alternatives 3-5. Alternatives 3 and 4 look much the
same, except that Alternative 3 is the only alternative to use any (1
percent) SHEV-P2 hybrids. Alternative 5 uses twice as much mass
reduction than Alternatives 3-4; it uses 37 percent direct injection
versus the 24 percent in Alternatives 2-4. The resulting costs are
comparable under Alternatives 3 and 4, and almost 50 percent higher
under Alternative 5.
Table VI-17--Summary of Impacts on Fiat/Chrysler HD Fleet by Alternative (vs. Alternative 1b)
----------------------------------------------------------------------------------------------------------------
Alternative 2 3 4 5
----------------------------------------------------------------------------------------------------------------
Alternative Stringency
----------------------------------------------------------------------------------------------------------------
Annual Increase in Stringency Beginning in MY 2.0% 2.5% 3.5% 4.0%
2021...........................................
Increases Until................................. MY 2025 MY 2027 MY 2025 MY 2025
Total Increase in MY 2030 Stringency Relative to 9.6% 15.8% 15.8% 17.6%
Final Phase 1 Standards \a\....................
----------------------------------------------------------------------------------------------------------------
Estimated Average Fuel Economy (miles per gallon)
----------------------------------------------------------------------------------------------------------------
Required in MY 2030............................. 18.59 19.96 19.96 20.41
Achieved in MY 2030............................. 18.97 20.06 20.04 20.42
----------------------------------------------------------------------------------------------------------------
Average Fuel Consumption (gallons/100 miles)
----------------------------------------------------------------------------------------------------------------
Required in MY 2030............................. 5.38 5.01 5.01 4.9
Achieved in MY 2030............................. 5.27 4.99 4.99 4.9
----------------------------------------------------------------------------------------------------------------
Estimated Average Greenhouse Gas Emissions (grams per mile)
----------------------------------------------------------------------------------------------------------------
CO[ihel2] Required in MY 2030................... 520 485 485 474
CO[ihel2] Achieved in MY 2030................... 509 482 482 474
----------------------------------------------------------------------------------------------------------------
Technology Penetration in MY 2030 (percent)
----------------------------------------------------------------------------------------------------------------
VVT and/or VVL.................................. 37 37 37 37
[[Page 73786]]
Cylinder Deactivation........................... 24 24 24 24
Direct Injection Engine......................... 24 24 24 37
Turbo Charged Engine............................ 76 76 76 76
8 Speed Auto. Trans............................. 64 64 64 64
EPS, Accessories................................ 82 100 100 100
12V Stop-start.................................. 0 3 3 3
Hybridization................................... 0 1 0 0
Aero. Improvements.............................. 84 100 100 100
----------------------------------------------------------------------------------------------------------------
Mass Reduction (vs. No-Action)
----------------------------------------------------------------------------------------------------------------
Curb Weight Mass Reduction (lb.)................ 29 330 333 694
Mass Reduction (percent of curb weight)......... 0.4 4.6 4.6 9.6
----------------------------------------------------------------------------------------------------------------
Note:
\a\ This increase in stringency is based on the estimated percentage change in fuel consumption (gal/100mi)
stringency projected by the model for the MY 2030 fleet under the final Phase 2 standards relative to the
continuation of Phase 1 standards. Note that if manufacturers' have applied mass reduction to an individual
vehicle model in the CAF[Eacute] model that this will increase the work factor of that vehicle in the model,
and make the individual target less stringent. Thus, where any mass reduction is applied in the model, the
total increase in stringency of the fleet presented here will be lower than the total stringency increase of
the fleet if no mass reduction were applied.
Figures Figure VI-24 and Figure VI-25 show the incremental total
and average technology costs for Chrysler/Fiat by model year and
regulatory stringency. Chrysler/Fiat shows more technology costs for
higher stringency alternatives, with annual technology costs of
Alternative 3 approaching Alternative 4 annual technology costs as the
Alternative 3 approaches the final stringency level in MY 2027. Under
all alternatives Chrysler/Fiat incurs increased technology costs
starting in MY 2018 and MY 2025, because they are estimated redesign
years. The maximum annual technology costs for Chrysler are $92M in
Alternative 2, $213M in Alternative 3, $227M in Alternative 4, and
$330M in Alternative 5. This results in average technology costs of:
$680, $1640, $1690, and $2460, respectively.
As with Ford, the costs and the rate of increase in costs are
significantly different in the MY 2018 timeframe among the
alternatives, because MY 2018 is the first estimated model year for
redesign, and the next estimated redesign opportunity is in MY 2025.
Figure identifies the significant differences in the resources and
capital that would be required to implement the technologies required
to comply with each of the alternatives--with the estimated MY 2018
technology cost increases being 48M under Alternative 3, 78M under
Alternative 4, and 112M under Alternative 5. NHTSA judges the short
lead time would make Alternatives 4 and 5 beyond maximum feasible for
FCA because its designs for MY 2018 are nearing completion and
substantial resources and very high costs would be required to add
another vehicle redesign between MY 2018 and MY 2025 to implement the
technologies that would be needed to comply with those alternatives.
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[[Page 73787]]
[GRAPHIC] [TIFF OMITTED] TR25OC16.030
The cumulative technology costs attributable to the action
alternatives for FCA are represented in Figure VI-26 below. The total
costs for MY's 2016-2030 under alter Alternative 2 are $750 million,
under Alternative 3, they are $1.5 billion, for Alternative 4, $1.8
billion, and for Alternative 5 they are $2.6 billion.
[[Page 73788]]
[GRAPHIC] [TIFF OMITTED] TR25OC16.031
BILLING CODE 6560-50-C
Table VI-18 shows the manufacturer-specific MY 2030 summary for
Nissan. Nissan's 2015 reference fleet uses VVT and/or VVL on all of
their heavy-duty vehicles. Their fleet uses two engines on only one
body-style platform. As a result, technologies applied to Nissan's
fleet are applied to large proportions of their fleet. Under all
scenarios, their entire fleet gains 8-speed automatic transmissions.
Under Alternatives 3-5, all of their fleet gets level-2 body-level
aerodynamic improvements and all of their fleet gets electric accessory
and/or EPS improvements. Under Alternatives 2, 4, and 5, one of
Nissan's two heavy-duty engines gets direct-injection, while under
Alternative 3, both engines get the technology. Direct injection of
their entire fleet is the most cost-effective way to reach compliance
under Alternative 2, applying 5 percent mass reduction to their entire
fleet and direct injection of one of their engines is the most cost-
effective strategy under Alternative 4, and applying 10 percent mass
reduction to their entire fleet, direct injection to one of their
engines, and making their other engine hybrid is the most cost-
effective strategy under Alternative 5.
Note that without a change in the work factor or fleet mix, a
manufacturer will face the same MY 2030 standard under Alternatives 3
and 4, and a more stringent standard under Alternative 5. However, by
applying 5 percent mass reduction in Alternative 4, Nissan is able to
reduce their standard by .27 MPG, and by applying 10 percent mass
reduction in Alternative 5 to have the same MY 2030 standard under
Alternatives 3 and 5. The result is that the CAFE level for Nissan is
highest under Alternative 2, where direct injection of their entire
fleet is the most cost-effective compliance strategy. We assume that
manufacturers are able to make technologies more cost-effectively the
longer they are on the market--this is called ``learning.'' A likely
reason that the model prefers direct injection in Alternative 3 but not
in Alternatives 4 and 5, is that the longer horizon of the stringency
increase (until MY 2027) results in direct injection that is more cost-
effective than the shorter time span of Alternatives 4 and 5.
Table VI-18--Summary of Impacts on Nissan HD Fleet by Alternative (vs. Alternative 1b)
----------------------------------------------------------------------------------------------------------------
Alternative 2 3 4 5
----------------------------------------------------------------------------------------------------------------
Alternative Stringency
----------------------------------------------------------------------------------------------------------------
Annual Increase in Stringency Beginning in MY 2.0% 2.5% 3.5% 4.0%
2021...........................................
Increases Until................................. MY 2025 MY 2027 MY 2025 MY 2025
Total Increase in MY 2030 Stringency Relative to 9.6% 16.2% 15.1% 16.2%
Final Phase 1 Standards \a\....................
----------------------------------------------------------------------------------------------------------------
Estimated Average Fuel Economy (miles per gallon)
----------------------------------------------------------------------------------------------------------------
Required in MY 2030............................. 19.65 21.19 20.92 21.19
Achieved in MY 2030............................. 19.63 23.12 21.05 21.46
----------------------------------------------------------------------------------------------------------------
Average Fuel Consumption (gallons/100 miles)
----------------------------------------------------------------------------------------------------------------
Required in MY 2030............................. 5.09 4.72 4.78 4.72
Achieved in MY 2030............................. 5.09 4.32 4.75 4.66
----------------------------------------------------------------------------------------------------------------
[[Page 73789]]
Estimated Average Greenhouse Gas Emissions (grams per mile)
----------------------------------------------------------------------------------------------------------------
CO[ihel2] Required in MY 2030................... 452 419 425 420
CO[ihel2] Achieved in MY 2030................... 453 384 422 414
----------------------------------------------------------------------------------------------------------------
Technology Penetration in MY 2030 (percent)
----------------------------------------------------------------------------------------------------------------
VVT and/or VVL.................................. 100 100 100 100
Cylinder Deactivation........................... 0 0 0 0
Direct Injection Engine......................... 51 100 51 51
Turbo Charged Engine............................ 51 100 51 51
8 Speed Auto. Trans............................. 100 100 100 100
EPS, Accessories................................ 37 100 100 100
12V Stop-start.................................. 0 0 0 49
Hybridization................................... 0 0 0 0
Aero. Improvements.............................. 0 100 100 100
----------------------------------------------------------------------------------------------------------------
Mass Reduction (vs. No-Action)
----------------------------------------------------------------------------------------------------------------
Curb Weight Mass Reduction (lb.)................ 0 0 307 615
Mass Reduction (percent of curb weight)......... 0 0 5 10
----------------------------------------------------------------------------------------------------------------
Note:
\a\ This increase in stringency is based on the estimated percentage change in fuel consumption (gal/100mi)
stringency projected by the model for the MY 2030 fleet under the final Phase 2 standards relative to the
continuation of Phase 1 standards. Note that if manufacturers' have applied mass reduction to an individual
vehicle model in the CAF[Eacute] model that this will increase the work factor of that vehicle in the model,
and make the individual target less stringent. Thus, where any mass reduction is applied in the model, the
total increase in stringency of the fleet presented here will be lower than the total stringency increase of
the fleet if no mass reduction were applied.
Figures Figure VI-27 and Figure VI-28 show the total and average
incremental technology costs for Nissan across the different regulatory
alternatives. Nissan applies technology in all alternatives in MY 2021;
this is a redesign year for much of their fleet. As might be expected,
they incur less technology cost in less stringent scenarios at this
redesign. However, under Alternative 3 they apply more technology in MY
2029, making their marginal technology costs under Alternative 3 for MY
2029 and after higher than the marginal technology costs under
Alternative 4. They incur less technology costs in the early years and
more in MY's 2029 and beyond. In order to explain why the model
predicts this action of Nissan it is useful to look at the cumulative
total incremental costs in Figure VI-29.
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[[Page 73790]]
[GRAPHIC] [TIFF OMITTED] TR25OC16.032
By incurring less technology cost early, and more technology cost
later, Nissan has a lower cumulative total cost for MY's 2016-2030
under Alternative 3 than Alternative 4. The total cumulative cost for
MY's 2016-2030 of Alternative 2 is $86 million, $178 million for
Alternative 3, $258 for Alternative 4, and $387 for Alternative 5.
Since Nissan is trying to minimize their total cost under all model
years, and not their marginal cost under any single model year, the
model chooses a compliance strategy in this case which shows higher
marginal costs for Nissan in Alternative
[[Page 73791]]
3 than 4 for some model years, but lower cumulative total costs over
all model years.
[GRAPHIC] [TIFF OMITTED] TR25OC16.033
BILLING CODE 6560-50-C
Nissan's first redesign is in MY 2020, and they do not have another
redesign scheduled until 2029. Under Alternative 4 and 5 all of their
technological application is done in MY 2020, but under Alternative 3
the application can be spread out between the two redesign cycles.
NHTSA judges the short lead time to apply technology would make
Alternatives 4 and 5 beyond maximum feasibility for Nissan because it
puts the burden of all technological application on the MY 2020
redesign. Substantial resources and costs would be required to do so or
to add another vehicle redesign between MY 2020 and MY 2029. Since
manufacturers must spread out their capital for such deployment
endeavors between the light and heavy duty fleets, the ability to
spread costs between model years is important to consider.
Table VI-19 shows a MY 2030 summary for Daimler. Daimler came into
the analysis with all of their fleet using 8-speed automatic
transmissions. Their initial CAFE level in MY 2020 of 25.68 was
sufficient to meet their standard under Alternatives 2-5. Their only
action to turbo-charge all the engines in their fleet occurs in the
dynamic baseline. As a result, no additional actions or costs are
incurred under any of the alternatives. For this reason, a figure of
their annual technology costs, nor their cumulative total technology
costs has not been provided--if it were, it would be a horizontal line
showing zero costs for all model years.
Table VI-19--Summary of Impacts on Daimler HD Fleet by Alternative (vs. Alternative 1b)
----------------------------------------------------------------------------------------------------------------
Alternative 2 3 4 5
----------------------------------------------------------------------------------------------------------------
Alternative Stringency
----------------------------------------------------------------------------------------------------------------
Annual Increase in Stringency Beginning in MY 2.0% 2.5% 3.5% 4.0%
2021...........................................
Increases Until................................. MY 2025 MY 2027 MY 2025 MY 2025
Total Increase in Stringency Relative to Final 9.7% 16.3% 16.3% 18.4%
Phase 1 Standards \a\..........................
----------------------------------------------------------------------------------------------------------------
Estimated Average Fuel Economy (miles per gallon)
----------------------------------------------------------------------------------------------------------------
Required in MY 2030............................. 22.88 24.69 24.69 25.32
Achieved in MY 2030............................. 25.68 25.68 25.68 25.68
----------------------------------------------------------------------------------------------------------------
Average Fuel Consumption (gallons/100 miles)
----------------------------------------------------------------------------------------------------------------
Required in MY 2030............................. 4.37 4.05 4.05 3.95
Achieved in MY 2030............................. 3.89 3.89 3.89 3.89
----------------------------------------------------------------------------------------------------------------
[[Page 73792]]
Estimated Average Greenhouse Gas Emissions (grams per mile)
----------------------------------------------------------------------------------------------------------------
CO[ihel2] Required in MY 2030................... 445 413 412 402
CO[ihel2] Achieved in MY 2030................... 396 396 396 396
----------------------------------------------------------------------------------------------------------------
Technology Penetration in MY 2030 (percent)
----------------------------------------------------------------------------------------------------------------
VVT and/or VVL.................................. 0 0 0 0
Cylinder Deactivation........................... 0 0 0 0
Direct Injection Engine......................... 0 0 0 0
Turbo Charged Engine............................ 100 100 100 100
8 Speed Auto. Trans............................. 100 100 100 100
EPS, Accessories................................ 0 0 0 0
12V Stop-start.................................. 0 0 0 0
Hybridization................................... 0 0 0 0
Aero. Improvements.............................. 0 0 0 0
----------------------------------------------------------------------------------------------------------------
Mass Reduction (vs. No-Action)
----------------------------------------------------------------------------------------------------------------
Curb Weight Mass Reduction (lb.)................ 0 0 0 0
Mass Reduction (percent of curb weight)......... 0 0 0 0
----------------------------------------------------------------------------------------------------------------
Note:
\a\ This increase in stringency is based on the estimated percentage change in fuel consumption (gal/100mi)
stringency projected by the model for the MY 2030 fleet under the final Phase 2 standards relative to the
continuation of Phase 1 standards. Note that if manufacturers' have applied mass reduction to an individual
vehicle model in the CAF[Eacute] model that this will increase the work factor of that vehicle in the model,
and make the individual target less stringent. Thus, where any mass reduction is applied in the model, the
total increase in stringency of the fleet presented here will be lower than the total stringency increase of
the fleet if no mass reduction were applied.
(5) Summary of Consumer/Operator Impacts
Table VI-20 summarizes the impacts of the regulation on the
consumer/operator of the heavy-duty vehicles. Consumers of more fuel
efficient vehicles will benefit in several ways: They will spend less
on fuel to operate vehicles for the same amount of travel, some will
drive more because their per-mile travel costs less, and they will
spend less time refueling vehicles. In order to estimate the fuel
savings for each regulatory alternative, future gasoline prices must be
predicted and the rebound effect (per-mile elasticity of operating a
vehicle) must be assumed to account for the cost of additional driving.
In the main analysis, the rebound effect is assumed to be 10 percent,
so that, for example, a 10 percent reduction in the per-mile travel
costs will result in a 1 percent increase in the amount of miles
driven. Since the literature has also supported other rebound effects,
NHTSA tests several sensitivity cases assuming different rebounds: 5
percent, 15 percent, and 20 percent. Based on the average miles driven
of 2b/3 vans and trucks, the expected lifetime fuel savings for a
heavy-duty vehicle under the preferred scenario is $3636.
The other benefits of to the consumer of increasing fuel economy
are increased mobility and a decreased amount of time spent refueling
the vehicle. Because increasing the efficiency of a vehicle makes per-
mile travel cheaper to the operator, consumers of these vehicles can
travel more, at less than the total amount they are willing to pay--
this increase in welfare that is not accounted for by the cost of
travel is the consumer surplus. The estimated mobility benefit is $394
under the preferred alternative. The avoided time refueling also has a
value. In order to estimate this value we make several assumptions
outlined in more detail of the NPRM description of the model
assumptions (Section E). Over the lifetime of a MY 2030 vehicle, we
estimate the refueling surplus at $94 under the preferred alternative.
It is also important to note that the average manufacturer costs
will not be spread proportionally across the fleet--some vehicles will
have incurred more technology costs than others. How manufacturers
distribute costs among models will largely depend on the elasticity of
particular models and the importance of fleet mix in meeting standards
and on total profits. Without privy to this sort of information, we use
average technology cost increase as a proxy for measuring the industry
and consumer costs across different scenarios. The average technology
cost increase is $1472 under the preferred alternative. We assume that
all of this cost will be passed onto the consumer in the form of an
increase in price. However, we also consider that an increase in price
will have other costs to the operator of the vehicle.
More expensive vehicles will have higher taxes/fees associated with
their purchase, will be more expensive to insure (these costs are
related to the purchase price or value of a vehicle) and will be more
expensive to finance (higher loan values will be taken out which result
in higher amounts paid in total interest). The total additional costs
to the average consumer from the sum of these sources is $589 under the
preferred alternative. It is important to keep in mind that the
additional cost to finance a more expensive vehicle will have different
effects depending on the budget constraint of the consumer. For
consumers who are budget-constrained, they will finance more of the
vehicle and the costs of financing will be higher for these already-
constrained consumers. For consumers who do not have to finance the
vehicle, there will be no costs--and therefore, no additional costs--to
finance the vehicle. Since budget-constrained consumers likely have a
more elastic demand for new vehicles, the increase in price and the
heterogeneous increase in financing might work in the same direction to
price proportionally more of the most budget-constrained consumers out
of the new vehicle market.
Considering all the costs and benefits the standards will have to
the consumer, the result is a net benefit to the consumer under all the
considered alternatives. The net benefit to the
[[Page 73793]]
consumer is $2,063 under the preferred alternative, higher than the net
benefit under alternative 4. The payback period is another measure of
the effect of the rule on consumers--for all alternatives the payback
period is under 3 years--suggesting that consumers that own vehicles
for at least 3 years will receive a net benefit from the preferred
regulatory action.
Table VI-20--Summary of Consumer/Operator Impacts for MY 2030 (vs. Alternative 1b)
----------------------------------------------------------------------------------------------------------------
Alternative 2 3 4 5
----------------------------------------------------------------------------------------------------------------
Alternative Stringency
----------------------------------------------------------------------------------------------------------------
Annual Increase................................. 2.0% 2.5% 3.5% 4.0%
Increases Until................................. MY 2025 MY 2027 MY 2025 MY 2025
----------------------------------------------------------------------------------------------------------------
Average Value of Lifetime Fuel Savings, $2013 (vs. No-Action)
----------------------------------------------------------------------------------------------------------------
Pretax.......................................... $1,713 $3,256 $3,229 $3,804
Tax............................................. 200 381 377 448
---------------------------------------------------------------
Total....................................... 1,913 3,636 3,607 4,252
----------------------------------------------------------------------------------------------------------------
Average Value of Additional Economic Benefits, $2013 (vs. No-Action)
----------------------------------------------------------------------------------------------------------------
Mobility Increase............................... 220 394 390 453
Avoided Refueling............................... 49 94 93 112
----------------------------------------------------------------------------------------------------------------
Average New Vehicle Purchase (vs. No-Action)
----------------------------------------------------------------------------------------------------------------
Price Increase ($).............................. 496 1,472 1,481 1,893
Additional Costs ($) \a\........................ 103 306 336 393
Payback (months) \b\............................ 20 33 33 38
----------------------------------------------------------------------------------------------------------------
Net Lifetime Consumer/Operator Benefits (vs. No-Action)
----------------------------------------------------------------------------------------------------------------
Total Net Benefit ($)........................... 1,488 2,063 1,989 2,167
----------------------------------------------------------------------------------------------------------------
Notes:
\a\ Additional Costs include additional taxes, fees, maintenance costs, financing costs, and insurance costs
incurred under the regulatory alternatives.
\b\ The payback period from the consumer perspective uses a 7% discount rate of retail fuel savings starting at
the time of purchase. The cost increases paid back include: Technology costs, maintenance costs, taxes, and
fees.
(6) Summary of Societal Impacts
Table VI-21 summarizes the overall societal impacts of the
regulation under different scenarios (relative to the 1b baseline). Net
social benefits increase with the stringency of the standards. The net
benefits for the preferred alternative are $18.8 billion. The largest
benefit of the program comes in the form of fuel savings. The fuel
savings reported above do not include fuel tax savings, as taxes are
considered a transfer, and not a loss, of societal well-being. The fuel
savings are associated with a fuel security externality, which
monetizes the economic risk associated with potential fuel price
spikes--as fewer gallons of oil are necessary for transportation, this
risk decreases. The carbon externality represents the reduced cost of
carbon damage when fuel economy increases (and carbon emissions
decrease), and is also related directly with fuel savings.
Table VI-21--Summary of Lifetime Total Societal Impacts of MY's 2015-2029 (vs. Alternative 1b)
----------------------------------------------------------------------------------------------------------------
Alternative 2 3 4 5
----------------------------------------------------------------------------------------------------------------
Alternative Stringency
----------------------------------------------------------------------------------------------------------------
Annual Increase................................. 2.0% 2.5% 3.5% 4.0%
Increases Until................................. MY 2025 MY 2027 MY 2025 MY 2025
----------------------------------------------------------------------------------------------------------------
Fuel Purchases vs. No-Action (billion 2013$)
----------------------------------------------------------------------------------------------------------------
Pretax Savings.................................. $11.1 $17.8 $20.2 $22.7
----------------------------------------------------------------------------------------------------------------
Fuel-Related Externalities vs. No-Action (billion 2013$)
----------------------------------------------------------------------------------------------------------------
Energy Security................................. 0.7 1.2 1.4 1.5
CO[ihel2] Emissions............................. 2.4 3.8 4.4 4.9
----------------------------------------------------------------------------------------------------------------
VMT-Related Externalities vs. No-Action (billion 2013$)
----------------------------------------------------------------------------------------------------------------
Driving Surplus................................. 1.3 2.0 2.3 2.5
Refueling Surplus............................... 0.3 0.6 0.6 0.7
Congestion...................................... -0.3 -0.5 -0.5 -0.6
Crashes......................................... -0.2 -0.2 -0.3 -0.3
[[Page 73794]]
Noise........................................... 0.0 0.0 0.0 0.0
Fatalities...................................... -0.7 -0.3 -0.4 0.7
Criteria Emissions.............................. 0.7 1.2 1.4 1.5
----------------------------------------------------------------------------------------------------------------
Vehicle Purchase/Operating Costs vs. No-Action (billion 2013$)
----------------------------------------------------------------------------------------------------------------
Technology Costs................................ 2.9 6.5 7.7 10.2
Maintenance Costs............................... 0.1 0.3 0.3 0.5
----------------------------------------------------------------------------------------------------------------
Cost-Benefit Summary vs. No-Action (billion 2013$)
----------------------------------------------------------------------------------------------------------------
Total Social Cost............................... 4.2 7.8 9.2 11.6
Total Social Benefit............................ 16.5 26.6 30.3 34.5
Net Social Benefit.............................. 12.3 18.8 21.1 22.9
----------------------------------------------------------------------------------------------------------------
Increasing fuel economy decreases the cost of per-mile travel.
Since this reduction in the cost of travel results in an increase of
total travel, it also results in an increase of externalities
associated with increased total VMT. Of these, the driving surplus
represents the societal net increase in benefit from increased mobility
consumer surplus--the sum of the benefit to all operators of increased
travel which is not captured by the total cost of travel. Defined from
the societal perspective, the refueling benefit is the sum of all the
value of the time saved on refueling by increasing the average fuel
efficiency of the heavy duty fleet. Congestion represents the societal
cost of increases in congestion on the roads--the lost value of
additional time spent in traffic. The crash externality is the cost of
the damage done by the additional crashes that will happen with more
VMT exposure, and the noise externality represents the cost of a change
in noise related to increases in vehicle travel (in this analysis, it
is negligible for all alternatives).
Some VMT-related externalities are not always positive or negative,
but depend on the stringency of the standards. For this analysis the
criteria pollutant externality is always a benefit, but this need not
be the case. Reduction in overall fuel consumed reduces emissions
associated with production and distribution of fuels. Increases in VMT
will result in more emission of vehicle criteria pollutants and more
associated damages. However, increasing fuel-economy though vehicle
technologies, such as aerodynamics, mass reduction and improved tire
rolling resistance, will result in a decrease in vehicle emissions of
and damages from criteria pollutants. Shifts in technologies towards
electric and hybrid-electric alternatives can increase the emissions of
certain pollutants, and reduce the emissions of others. The stringency
increases considered in the heavy-duty analysis do not require these
technologies to penetrate the market at such a level that this is
visible in the results. For these reasons the externality associated
with changes in criteria pollutant emissions is always positive for
this analysis.
The vehicle mass reduction in HD pickup and vans is estimated to
reduce the net incidence of highway fatalities. By reducing mass on
some HD pickup and vans, the fatality rate associated with crashes
involving at least one HD pickup or van vehicles decreases. However,
the analysis anticipates that the indirect effect of the proposed
standards, by reducing the operating costs, would lead to increased
travel by HD pickups and vans and, therefore, more crashes involving
these vehicles. The sign of the fatality externality varies with the
stringency of the standards. Over the lifetime of MY's 2016-2029, for
Alternative 2 it is estimated approximately 120 additional fatalities
could occur relative to the 30,200 heavy-duty crash-related fatalities
in the baseline. For Alternatives 3 and 4 we estimate approximately 50
additional fatalities relative to the no-action alternative. The
additional risk of fatality is represented as a social cost in
Alternatives 2-4. For Alternative 5 we estimate approximately 110 fewer
fatalities (represented as a positive externality). For Alternatives 2-
4, the effect of removing mass from the heavier vehicles is less than
the effect of increased VMT-exposure; for Alternative 5, it is larger,
and the alternative could result in a decrease of fatalities.
The major direct costs of the program are increased technology
costs and costs associated with the resultant increase in new vehicle
prices and changes in technologies. The sum of technology costs across
the industry increase under all increases of stringency, as do the
increases in associated additional costs. Additional costs include:
additional costs of maintenance associated with certain technologies.
These costs will mostly be borne by the consumer, and paid back in the
form of fuel savings.
(7) Summary of Environmental Impacts
In addition to modeling the societal impacts from a monetary
standpoint, the CAFE model also considers the absolute change in the
physical emissions of various criteria pollutants across the
Alternatives. Table VI-22 summarizes the total environmental impacts
from increased fuel efficiency of MYs 2016-2030, taking into
consideration the reduction in emissions from increased efficiency, the
additional emissions associated with the increased VMT from cheaper
per-mile travel, and changes in emissions due to the production and
distribution of heavy-duty vehicles. Across all scenarios, the absolute
reduction in emissions increases. For context, the percentage change of
emissions relative to the baseline emission levels is also provided.
The proportional reduction in criteria pollutants greatly varies; the
greenhouse gases--carbon dioxide, methane, and nitrous oxide--as well
as the criteria pollutants--sulfur dioxide and diesel particulate
matter--show the largest proportional reductions across all scenarios.
[[Page 73795]]
Table VI-22--Summary of Lifetime Emission Impacts of MY's 2015-2029 (vs. Alternative 1b)
----------------------------------------------------------------------------------------------------------------
Alternative 2 3 4 5
----------------------------------------------------------------------------------------------------------------
Annual Increase................................. 2.0% 2.5% 3.5% 4.0%
Increases Until................................. MY 2025 MY 2027 MY 2025 MY 2025
----------------------------------------------------------------------------------------------------------------
Greenhouse Gas Emissions Reductions vs. No-Action
----------------------------------------------------------------------------------------------------------------
CO[ihel2] (mmt)................................. 66 107 120 135
CH4 and N[ihel2]O (tons)........................ 97,925 160,044 180,557 202,666
----------------------------------------------------------------------------------------------------------------
Greenhouse Gas Emissions Percent Reduction vs. No-Action
----------------------------------------------------------------------------------------------------------------
CO[ihel2]....................................... 3.8% 6.1% 6.9% 7.7%
CH4 and N[ihel2]O............................... 0.7% 1.2% 1.3% 1.5%
----------------------------------------------------------------------------------------------------------------
Other Emissions Absolute Reduction vs. No-Action
----------------------------------------------------------------------------------------------------------------
CO (tons)....................................... 13,747 22,828 26,375 29,589
VOC and NOX (tons).............................. 33,324 56,100 63,237 70,957
PM25 (tons)..................................... 1,320 2,213 2,498 2,806
SO[ihel2] (tons)................................ 10,713 17,877 20,172 22,669
Air Toxics (tons)............................... 53 75 84 94
Diesel PM10 (tons).............................. 2,357 3,944 4,450 5,004
----------------------------------------------------------------------------------------------------------------
Other Emissions Percent Reduction vs. No-Action
----------------------------------------------------------------------------------------------------------------
CO.............................................. 0.2 0.4 0.4 0.5
VOC and NOX..................................... 1.6 2.8 3.1 3.5
PM25............................................ 1.9 3.3 3.7 4.1
SO[ihel2]....................................... 3.7 6.2 6.9 7.8
Air Toxics...................................... 0.2 0.2 0.2 0.3
Diesel PM10..................................... 3.5 5.8 6.5 7.3
----------------------------------------------------------------------------------------------------------------
(8) Sensitivity Analysis Evaluating Different Inputs to the NHTSA CAFE
Model
This section describes some of the principal sensitivity results,
obtained by running the various scenarios describing the policy
alternatives with alternative inputs. OMB Circular A-4 indicates that
``it is usually necessary to provide a sensitivity analysis to reveal
whether, and to what extent, the results of the analysis are sensitive
to plausible changes in the main assumptions and numeric inputs.''
\509\ Considering this guidance, a number of sensitivity analyses were
performed using analysis Method A to examine important assumptions and
inputs, including the following, all of which are discussed in greater
detail in the accompanying RIA:
---------------------------------------------------------------------------
\509\ Available at http://www.whitehouse.gov/omb/circulars_a004_a-4/.
---------------------------------------------------------------------------
1. Payback Period: In addition to the 0 and 6 month payback periods
discussed above, also evaluated cases involving payback periods of 12,
18, and 24 months.
2. Fuel Prices: Evaluated cases involving fuel prices from the AEO
2015 low and high oil price scenarios. (See AEO-Low and AEO-High in the
tables).
3. Fuel Prices and Payback Period: Evaluated one side case
involving a 0 month payback period combined with fuel prices from the
AEO 2015 low oil price scenario, and one side case with a 24 month
payback period combined with fuel prices from the AEO 2014 high oil
price scenario.
4. Benefits to Vehicle Buyers: The main Method A analysis assumes
there is no loss in value to owner/operators resulting from vehicles
that have an increase in price and higher fuel economy. NHTSA performed
this sensitivity analysis assuming that there is a 25, or 50 percent
loss in value to owner/operators--equivalent to the assumption that
owner/operators will only value the calculated benefits they will
achieve at 75, or 50 percent, respectively, of the main analysis
estimates. (These are labeled as 75pctOwner/Operator Benefit and
50pctOwner/Operator Benefit.)
5. 7 Pct Discount Rate: The main analysis results are considered
using either a 0 or 3 percent discount rate. We also considered an
alternative case where future savings/costs are discounted 7 percent
annually.
6. Value of Avoided GHG Emissions: Evaluated side cases involving
lower and higher valuation of avoided CO2 emissions,
expressed as the social cost of carbon (SCC).
7. Rebound Effect: Evaluated side cases involving rebound effect
values of 5 percent, 15 percent, and 25 percent. (These are labeled as
05PctReboundEffect, 15PctReboundEffect and 25PctReboundEffect).
8. ICM-based Markup: Evaluated a side case using a retail price
equivalent (ICM) markup factor.
9. Mass-Safety Effect: Evaluated side cases with the mass-safety
impact coefficient at the values defining the 5th and 95th percent
points of the confidence interval estimated in the underlying
statistical analysis. (These are labeled MassFatalityCoeff05pct and
MassFatalityCoeff95pct).
10. VMT Schedules: Evaluated side cases considering the NHTS
considered in the NPRM analysis as a high-VMT case, and another
considered schedule as a low-VMT case.
11. Strong HEVs: Evaluated a side case in which strong HEVs were
excluded from the set of technology estimated to be available for HD
pickups and vans through model year 2030. As in Section VI.C. (8), this
``no SHEV'' case allowed turbocharging and downsizing on all GM vans to
provide a lower-cost path for compliance.
Table VI-23, below, summarizes key metrics for each of the cases
included in the sensitivity analysis using Method A for the
alternative. The table reflects the percent change in the metrics
(columns) relative to the main analysis, due to the particular
sensitivity case (rows) for the alternative 3. For each sensitivity
run, the change in the metric can we
[[Page 73796]]
described as the difference between the baseline and the preferred
alternative for the sensitivity case, minus the difference between the
preferred alternative and the baseline in the main analysis, divided by
the difference between the preferred alternative and the baseline in
the main analysis. Or,
[GRAPHIC] [TIFF OMITTED] TR25OC16.034
Each metric represents the sum of the impacts of the preferred
alternative over the model years 2015-2029, and the percent changes in
the table represent percent changes to those sums. More detailed
results for all alternatives are available in the accompanying RIA
Chapter 10.
Table VI-23--Sensitivity Analysis Results From CAFE Model in the HD Pickup and Van Market Segment Using Method A and Versus the Dynamic Baseline,
Alternative 1b
[2.5% growth in stringency: Cells are percent change from base case] \a\
--------------------------------------------------------------------------------------------------------------------------------------------------------
CO[ihel2] Social Social net
Sensitivity case Fuel savings savings (MMT) Fuel savings Social costs benefits benefits
(gallons) (%) (%) ($) (%) ($billion) (%) ($billion) (%) ($billion) (%)
--------------------------------------------------------------------------------------------------------------------------------------------------------
0 Month Payback......................................... 8.4 8.0 7.7 8.0 7.8 7.7
12 Month Payback........................................ -13 -14 -15 -2.8 -14 -19
18 Month Payback........................................ -30 -31 -32 -16 -31 -38
24 Month Payback........................................ -47 -47 -48 -32 -48 -54
AEO-Low................................................. -5.4 -5.8 -31 -19 -26 -29
AEO-High................................................ -27 -28 18 -2.8 13 20
AEO-Low, 0 Month Payback................................ 35 33 33 42 34 30
AEO-High, 24 Month Payback.............................. -50 -50 -51 -37 -51 -57
7pct Discount Rate...................................... 0.0 0.0 -41 -31 -35 -37
50pct Owner/Operator Benefit............................ 0.0 0.0 -50 0.0 -34 -48
75pct Owner/Operator Benefit............................ 0.0 0.0 -25 0.0 -17 -24
Low SCC................................................. 0.0 0.0 0.0 0.0 -11 -16
High SCC................................................ 0.0 0.0 0.0 0.0 8.2 12
Very High SCC........................................... 0.0 0.0 0.0 0.0 30 43
5pct Rebound............................................ 4.6 4.6 4.6 -13 0.37 5.5
15pct Rebound........................................... -4.6 -4.6 -4.6 12 -0.37 -5.5
25pct Rebound........................................... -14 -14 -14 37 -1.1 -17
5th Percentile Mass Fatality Coefficient................ 0.0 0.0 0.0 -11 0.0 4.6
95th Percentile Mass Fatality Coefficient............... 0.0 0.0 0.0 15 0.0 -6.0
No SHEV-P2's............................................ 0.18 0.29 0.29 -1.3 0.26 0.88
Non-CO[ihel2]eq GHG Values.............................. 0.0 0.0 0.0 0.0 0.0 0.0
ICM-Based Mark-Up....................................... -5.7 -6.0 -6.1 -16 -6.0 -1.8
High VMT................................................ 8.6 7.4 5.9 0.11 6.2 8.7
Low VMT................................................. -7.7 -8.3 -8.0 -14 -7.8 -5.4
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note:
\a\ For an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the less dynamic baseline, 1a, and more dynamic
baseline, 1b, please see Section X.A.1.
For some of the cases for which results are presented above, the
sensitivity of results to changes in inputs is simple, direct, and
easily observed. For example, changes to valuation of avoided GHG
emissions impact only this portion of the estimated economic benefits;
manufacturers' responses and corresponding costs are not impacted.
Similarly, a higher discount rate does not affect physical quantities
saved (gallons of fuel and metric tons of CO2 in the table),
but reduces the value of the costs and benefits attributable to these
standards in an intuitive way. Higher rebound results in fewer
volumetric fuel savings and social net benefits, as drivers are assumed
to be more responsive in their driving habits to changes in the cost
per mile of travel. Some other cases warrant closer consideration:
First, cases involving alternatives to the reference case involving
voluntary over compliance of technologies that pay back in six-months
involve different degrees of fuel consumption improvement. Increasing
the length of the payback period assumption for voluntary over
compliance amounts to increasing fuel economy improvements in the
absence of the rule (the baseline), and manufacturers are compelled to
add less technology in order to comply with the standards (in the
regulatory alternatives). Because all estimated impacts of these
standards are shown as incremental values relative to this baseline,
longer voluntary over compliance payback periods correspond to smaller
estimates of incremental impacts.
Table VI-24 shows the effect of varying the voluntary over
compliance assumption from the consumer perspective. The baseline over-
compliance payback period is as described above--the number of months
within which a technology must pay back to the consumer in the form of
undiscounted retail fuel savings for a manufacturer to voluntarily
apply that technology without regulatory action. The incremental per-
vehicle technology cost is the average additional cost of technology
applied to MY 2030 vehicles under the final regulation (incremental to
the baseline) of each sensitivity case. The per-vehicle lifetime fuel
savings is
[[Page 73797]]
the average lifetime retail value of fuel savings under each
sensitivity case discounted at 7 percent annually starting at the time
of purchase (MY 2030). Compliance payback period is the number of
months of ownership it would take the average consumer to recoup the
additional technology costs in discounted fuel savings.\510\
---------------------------------------------------------------------------
\510\ This is based on the VMT schedules of average miles driven
by age of MDHD pickups and vans and AEO fuel price projections.
---------------------------------------------------------------------------
As can be seen, the baseline voluntary over compliance assumption
changes how much of the technology costs and fuel savings are
attributed to the regulation; both fewer fuel savings and fewer
technology costs are attributed to the regulatory alternative as the
payback period defining voluntary over compliance increases. Further,
because the model only applies the technologies with the shortest
payback periods (the most cost-effective technologies) in the baseline,
the fuel savings decrease at a greater proportion than the technology
costs. The result is that the payback period of the regulatory
alternative increases (and at an increasing rate) as manufacturers are
assumed to apply more technology in the baseline.
Table VI-24--Sensitivity Analysis of the Voluntary Over Compliance Assumption on Compliance Payback Period and
Key Consumer Impacts for the MY 2030 MDHD Fleet
----------------------------------------------------------------------------------------------------------------
Incremental Technology
per-vehicle Per-vehicle cost payback
Baseline over-compliance payback (months) technology lifetime fuel period
cost savings (months) a
----------------------------------------------------------------------------------------------------------------
0............................................................... $1,471 $3,966 28
6............................................................... 1,472 3,636 31
12.............................................................. 1,317 3,031 33
18.............................................................. 1,214 2,556 38
24.............................................................. 944 1,684 45
----------------------------------------------------------------------------------------------------------------
Note:
\a\ Here the payback calculation uses a 7% discount rate of retail fuel savings starting at the time of purchase
and only considers the additional costs of technology application.
Cases involving different fuel prices similarly involve different
degrees of fuel economy improvement in the absence of the standard, as
more, or less, improvement occurs as a result of more, or fewer,
technologies appearing cost effective to owner/operators. Low fuel
prices change the amount of fuel savings for each technology, since the
choice in technology application also involves both the size of the
cost and the fuel savings, lower fuel prices can change the rank of the
technologies. Under low fuel prices, the model applies fewer SHEV-P2's.
The result is a reduction in volumetric fuel savings, and an even
larger reduction in monetary fuel savings, because the fuel savings are
worth less. There is also a reduction in social costs, and social net
benefits. Higher fuel prices correspond to reductions in the volumetric
fuel savings attributable to these standards as, but lead to increases
in the value of fuel saved (and net social benefits) because each
gallon saved is worth more when fuel prices are high.
The low price and 0-month payback case leads to a significant
increase in volumetric savings compared to the main analysis. Note that
the fuel savings are higher than in the 0-month payback case alone.
Part of the reason for this is that the lower fuel price case takes
into consideration that when fuel prices are lower, consumers buy more
heavy-duty vehicles (this is estimated from the AEO2015 low fuel price
case). Another piece of the explanation is that the lower fuel prices
result in a different technology cost-effectiveness ranking of
technologies, and that the 0 month payback baseline results in no
voluntary over compliance in the baseline. Different technologies are
picked than in the 0 month pay back sensitivity alone, and the most
cost effective that would have been applied in the baseline, are now
attributed to the preferred alternative. Similarly, the high price and
24-month payback case results in large reductions to volumetric savings
that can be attributed to these standards because more is applied in
the baseline. Further, the presence of high fuel prices is not
sufficient to lead to increases in either the dollar value of fuel
savings or net social benefits.
The case which involves the VIUS-based VMT schedules (the high VMT
case) results in greater volumetric fuel and GHG-savings attributable
to the standards. Under this case the higher estimate of VMT results in
more fuel consumption in the baseline, and a higher absolute change in
fuel consumption when fuel-saving technologies are applied in the
preferred alternative. These higher amount of gallons saved, results in
more monetary fuel savings, comparable social costs, and an increase in
overall net social benefits attributed to the standards. The low-VMT
schedule, developed as an alternative to the adopted VMT-schedule from
the IHS/Polk odometer readings, results in lower volumetric fuel
consumption and GHG reductions under the preferred alternative. Lower
VMT estimates result in less fuel consumption in the baseline, and a
lower absolute change in fuel consumption under the preferred
alternative. This schedule attributes lower costs to the standards--the
lower fuel savings under the low-VMT schedule changes the technology
application decisions of the model, since fewer fuel savings are
considered in measure the cost-effectiveness of technologies. The
result is lower absolute technology costs, but also lower social net
benefits.
The case which makes SHEV-P2's unavailable involves relatively
small increases to volumetric fuel savings and CO2
reductions--not surprising, since SHEV-P2's play only a minor role in
the compliance strategy of the preferred alternative in the Method A
central analysis. These small increases in fuel savings are associated
with small increases in social benefits, slightly larger proportional
increases in social costs, but still result in a small increase in
social net benefit.
The case that uses the ICM mark-up methodology rather than the RPE
methodology results in a reduction of volumetric fuel savings and GHG
reductions. The reduction in fuel
[[Page 73798]]
savings is accompanied by a reduction in monetary fuel savings, social
benefits, social costs, and social net benefits. This is likely due to
shifts in technology applications due to different costs mark-ups
associated with different types of technologies under the ICM mark-up
methodology.
If, instead of using the values in the main analysis, each
sensitivity case were itself the main analysis, the costs and benefits
attributable to the final rule will be as they appear in Table VI-25,
below.
Table VI-25--Costs and Benefits of Standards for MY 2015-2029 HD Pickups and Vans Under Alternative Assumptions
--------------------------------------------------------------------------------------------------------------------------------------------------------
Fuel savings CO[ihel2] Social Net social
Sensitivity case (billion reduction Fuel savings Social costs benefits benefits
gallons) (MMT) ($billion) ($billion) ($billion) ($billion)
--------------------------------------------------------------------------------------------------------------------------------------------------------
6 Month Payback......................................... 9.2 110 18 7.8 27 19
0 Month Payback......................................... 10 120 19 8.2 28 20
12 Month Payback........................................ 8.0 92 15 7.3 22 15
18 Month Payback........................................ 6.4 74 12 6.4 18 12
24 Month Payback........................................ 4.9 56 9.3 5.2 14 8.5
AEO-Low................................................. 8.7 100 12 6.1 19 13
AEO-High................................................ 6.7 77 21 7.3 30 22
AEO-Low, 0 Month Payback................................ 12 140 24 11 35 24
AEO-High, 24 Month Payback.............................. 4.7 53 8.8 4.8 13 8.0
7pct Discount Rate...................................... 9.2 110 11 5.2 17 12
50pct Owner/Operator Benefit............................ 9.2 110 8.9 7.5 17 9.7
75pct Owner/Operator Benefit............................ 9.2 110 13 7.5 22 14
Low SCC................................................. 9.2 110 18 7.5 23 16
High SCC................................................ 9.2 110 18 7.5 28 21
Very High SCC........................................... 9.2 110 18 7.5 34 27
5pct Rebound............................................ 9.7 110 19 6.6 26 20
15pct Rebound........................................... 8.8 100 17 8.5 26 18
25pct Rebound........................................... 8.0 92 15 10 26 16
5th Percentile Mass Fatality Coefficient................ 9.2 110 18 6.7 26 19
95th Percentile Mass Fatality Coefficient............... 9.2 110 18 8.7 26 18
No SHEV-P2's............................................ 9.3 110 18 7.5 26 19
Non-CO[ihel2]eq GHG Values.............................. 9.2 110 18 7.5 26 19
ICM-Based Mark-Up....................................... 8.7 100 17 6.3 25 18
High-VMT................................................ 10 110 19 7.6 28 20
Low-VMT................................................. 8.5 98 16 6.5 24 18
--------------------------------------------------------------------------------------------------------------------------------------------------------
(9) Discussion of the Maximum Feasibility of the Adopted Standards
As noted above, EPCA and EISA require NHTSA 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 to establish corresponding fuel consumption
standards ``that are appropriate, cost-effective, and technologically
feasible.'' \511\ In order to determine which of the regulatory
alternatives meets the requirements of the statute NHTSA has considered
both the modeling results of ``Method A'' and comments offered on the
proposed rulemaking.
---------------------------------------------------------------------------
\511\ 49 U.S.C. 32902(k)(2).
---------------------------------------------------------------------------
(a) Consideration of Modeling Results
For both the NPRM and the current analysis of potential standards
for HD pickups and vans, NHTSA applied NHTSA's CAFE Compliance and
Effects Modeling System (sometimes referred to as ``the CAFE model'' or
``the Volpe model''), which DOT's Volpe National Transportation Systems
Center (Volpe Center) developed, maintains, and applies to support
NHTSA CAFE analyses and rulemakings. NHTSA used this model in its
Method A analysis to evaluate regulatory alternatives for Phase 2
standards applicable to HD pickups and vans, and used results of this
analysis to inform its selection of the regulatory alternative that
will achieve the maximum feasible improvement in HD pickup and van fuel
efficiency. This analysis includes several updates to the model and to
accompanying inputs, as discussed above in this section.
In the proposal, the agencies proposed to adopt Alternative 3 from
among the five regulatory alternatives under consideration.\512\ As
discussed in the NPRM, the agencies found that Alternative 2 would
unduly forego significant fuel savings and avoided GHG emissions, and
that Alternative 5 could involve rapid and early cost increases and
necessitate significant application of the most advanced technologies
considered by the agencies. 80 FR 40494-40495. The agencies have
estimated the cost and efficacy of fuel-saving technologies assuming
performance and utility will be held constant or improved. In
particular, we have assumed payload will be preserved (and possibly
improved via reduced vehicle curb weight); however, some fuel-saving
technologies, such as hybrid electric vehicles, could reduce payload
via increased curb weight (due to the added electrical machine,
batteries and controls, and because of the physical size of those
components). If the increase in weight from the hybrid system is not
offset with a weight reduction elsewhere in the vehicle, the payload
capability will be reduced resulting in lost utility but also an
increase in stringency due to changes in work factor. Further, it is
also possible that applications such as vans where the advanced
technologies of downsized gasoline and diesel engines could be used in
conjunction with strong hybridization, extended high power demand
resulting from a vehicle at full payload or towing, certain types of
hybrid powertrains could experience a temporary loss of towing capacity
if the capacity of the hybrid's energy storage device (e.g., batteries,
hydraulic accumulator) is insufficient for the
[[Page 73799]]
extended power demand required to maintain expected vehicle speeds.
---------------------------------------------------------------------------
\512\ These Alternatives are defined in Section C(6).
---------------------------------------------------------------------------
The Method A analysis shows in the short term, MY 2017-2021
timeframe, that there are significant differences in the rate at which
technologies would need to be applied among the alternatives. NHTSA
believes the rates of technology application require for Alternatives 4
and 5 are beyond maximum feasible when considering the availability of
manufacturers' resources and capital to implement the technologies in
that timeframe, and that Alternatives 4 and 5 would not provide
adequate lead time for the industry to fully address reliability
considerations.
Like the NPRM analysis (i.e. the Method B analysis), Method A
indicates Alterative 4 would achieve little benefit beyond that
achieved by Alternative 3. For example, as shown in the following graph
of estimated total fuel consumed by HD pickups and vans over time under
the various regulatory alternatives, outcomes under Alternative 4 are
nearly indistinguishable from those under Alternative 3. By 2030, the
two are less than 0.5 percent apart.
[GRAPHIC] [TIFF OMITTED] TR25OC16.035
Weighing against the small additional benefit estimated to be
potentially available under Alternative 4, NHTSA also considered the
estimated additional costs. Method A analysis shows overall incremental
costs (i.e., costs beyond the No Action Alternative) under Alternative
4 to be about 12 percent more than under Alternative 3.
As mentioned above, these estimated differences were mostly small
on a relative basis. Averaged over all model years included in the
analysis, estimated incremental costs are $106 higher under Alternative
4 than under Alternative 3. For Daimler and General Motors, there is
little or no estimated difference in costs under these two
Alternatives. For FCA, Ford, and Nissan, differences are somewhat
larger, averaging $120, $173, and $272, respectively. However, as
explained in greater detail above, NHTSA's method A analysis shows
considerably greater total and average additional costs in earlier
model years under Alternative 4 than under Alternative 3.
Although NHTSA's Method A analysis also indicates that some
manufacturers could need to apply additional technology as soon as MY
2016 under baseline standards defining the No-Action Alternative,
average estimated costs (versus continuation today's technology) in MY
2017 are two thirds more under Alternative 4 than under the No Action
Alternative.
Beyond these directly-estimated costs, the agencies also considered
factors beyond those addressed quantitatively in either the NPRM
analysis or the updated analysis. In general, these other factors
reflect risk and uncertainty involved with standards for HD pickups and
vans. These risks and uncertainty appear considerably greater than for
light-duty vehicles. The HD pickup and van market has significantly
fewer vehicle models than the light-duty market making forecasting
uncertainty a greater risk to compliance. All current manufacturers of
HD pickups and vans also produce light-duty vehicles. These
manufacturers' light-duty offerings span wide ranges of models,
configurations, shared vehicle platforms, engines, transmissions, and
design schedules. As a result, if some specific aspects of production
do not progress as initially planned for light-duty vehicles (e.g., if
mass reduction on some platform does not achieve as much benefit as
planned, or if a new engine does not perform as
[[Page 73800]]
well as projected, or if limited engineering resources make it
necessary to delay a redesign), these manufacturers should have ample
opportunity to comply with light-duty CAFE and GHG standards by making
adjustments among other models, platforms, engines, and transmissions.
This is not the case for HD pickups and vans. Current HD PUV
manufacturers offer products spanning only 1-3 platforms, at most half
a dozen engines or transmissions, and only 1-3 schedules for redesigns.
As summarized below, this provides 5-10 times less flexibility than for
light-duty vehicles.
Table VI-26--MY 2015 Body and Engine Platforms by Manufacturer for Light- and Heavy-Duty Pickups
--------------------------------------------------------------------------------------------------------------------------------------------------------
Platforms Engines Transmissions Design Schedules
-------------------------------------------------------------------------------------------------------
Light-duty HD PUV Light-duty HD PUV Light-duty HD PUV Light-duty HD PUV
--------------------------------------------------------------------------------------------------------------------------------------------------------
Daimler......................................... 12 1 29 2 20 2 18 1
FCA............................................. 15 3 24 5 21 6 24 3
Ford............................................ 9 2 22 5 27 3 18 2
General Motors.................................. 17 2 26 5 39 3 21 2
Nissan.......................................... 6 1 13 2 21 2 23 1
--------------------------------------------------------------------------------------------------------------------------------------------------------
Considering further that credits from other manufacturers are not
potentially available as for light-duty vehicles (e.g., several
manufacturers currently have excess light-duty CAFE credits that could
be traded to other OEMs), this means that overestimating the industry's
capability to improve fuel efficiency and reduce GHG emissions, and
consequently setting standards at too stringent of a level, poses a
much greater compliance risk for HD PUV fleets than for light-duty
fleets. If the factors discussed here, for which the agencies are
currently unable to account in our analysis, lead manufacturers to fail
to comply with the standards, then the additional benefits of setting
standards at slightly more stringent levels would be lost. In the
agencies' judgment, even setting aside the somewhat higher estimated
costs under Alternative 4, the very small additional benefit that could
be achieved under Alternative 4 do not warrant the increased exposure
to this risk.
Regarding Alternative 5, the Method A analysis shows somewhat
greater benefits than under Alternatives 3 or 4, but Alternative 5
entails considerably greater costs and dependence on strong hybrid
technology, as well as even greater exposure to the above-mentioned
uncertainties and risks. Under the Method A analysis for Alternative 5,
incremental costs averaged across all model years considered are
estimated to be about $400 higher (about 46 percent) than under
Alternative 3, and that analysis shows an overall fleet application of
approximately 7 percent strong hybrids, with General Motors applying
approximately 13 percent and Ford approximately 7 percent.
We have also assumed that fuel-saving technologies will be no more
or less reliable than technologies already in production. However, if
there is insufficient lead-time to fully develop new technologies, they
could prove to be less reliable, perhaps leading to increased repair
costs and out-of-service time. If the fuel-saving technologies
considered here ultimately involve reliability problems, overall costs
will be greater than we have estimated. Method A analysis shows in the
short term, MYs 2017-2021 timeframe, there are significant differences
in the rate at which technologies would need to be applied among the
alternatives. Figures VI.15 and VI.16, above, shows the progression in
average and total technology costs and the rate of increase in those
costs among the alternatives using Method A. They highlight the
increases in resources and capital that would be required to implement
the technologies required to comply with each of the alternatives, as
well as the reduction in lead time to implement the technologies which
increases reliability risk. As discussed further above in the
manufacturer-specific effects, Ford and FCA are estimated to redesign
vehicles in MYs 2017 and 2018 respectively, and vehicle designs for
those model years are complete or nearly complete. The next estimated
redesign for Ford is in MY 2026, and for FCA in MY 2025, and
substantial resources and very high costs would be required to add
another vehicle redesign between the estimated redesign model years to
implement the technologies that would be needed to comply with those
alternatives.
(b) Consideration of Comments
NHTSA proposed that Alternative 3 represented the maximum feasible
alternative under EISA, and EPA proposed that Alternative 3 reflected a
reasonable consideration of the statutory factors of technology
effectiveness, feasibility, cost, lead time, and safety for purposes of
CAA sections 202(a)(1) and (2). Although the agencies and commenters
also found that Alternative 4 merited serious consideration, the
agencies noted that Alternative 3 was generally designed to achieve the
levels of fuel consumption and GHG stringency that Alternative 4 would
achieve, but with several years of additional lead time, meaning that
manufacturers could, in theory, apply new technology at a more gradual
pace, with greater reliability and flexibility.
Some comments on the proposal called for adoption of standards more
stringent and/or more rapidly advancing in stringency than those
defining Alternative 3. For example, CARB argued that Alternative 4
would, compared to Alternative 3, achieve greater benefits comparably
attractive in terms of cost effectiveness and while remaining less
stringent than CAFE standards for light-duty trucks.\513\ UCS provided
similar comments, indicating further that the standards should be
technology forcing and therefore more aggressive than Alternative 4,
they specifically suggested that gasoline vehicles could achieve up to
a 23.6 percent improvement in MY 2027 while diesel vehicles can achieve
an 18 percent improvement.\514\ ACEEE similarly recommended increasing
the stringency by 7 percent in MY 2027 and that standards should
reflect increased use of cylinder deactivation, cooled EGR, and GDI and
turbo downsizing in pickups. For diesels, ACEEE commented that
additional reductions were possible, based on an estimate of 10 percent
penetration of engine downsizing for pickups and 30 percent penetration
for vans in 2027, and also assuming 6 percent penetration of hybrids in
diesel vans.
---------------------------------------------------------------------------
\513\ CARB, Docket No. NHTSA-2014-0132-0125 at pages 52-53.
\514\ UCS, Docket No. EPA-HQ-OAR-2014-0827-1329, at pages 23-25.
---------------------------------------------------------------------------
Citing the potential for fuel-saving technology to migrate from
light-duty
[[Page 73801]]
pickups and vans to heavy-duty pickups and vans, CBD also called for
more stringent HD pickup and van standards that would ``close the gap''
with light-duty standards, as any gap allows manufacturers to
essentially choose to classify a pickup as heavy-duty to avoid more
stringent requirements if it was classified as a light-duty
vehicle.\515\ ICCT likewise commented that the proposed standards
represent only a 2.2 and 1.6 percent year-over-year improvement for the
gasoline and diesel fleets, respectively, from MYs 2014-2025 compared
to an almost 3 percent per year improvement for light-duty trucks in
the same time frame. ICCT recommended that the agencies' analysis
incorporate the full analysis and inputs from the light-duty rulemaking
and that the result would be improvements in the range of 35 percent
over the MYs 2014-2025 rather than the proposed 23 percent improvement
over this time frame.
---------------------------------------------------------------------------
\515\ CBD, Docket No. NHTSA-2014-0132-0101, at pages 8-9.
---------------------------------------------------------------------------
On the other hand, some other reviewers commented that the proposed
standards could be unduly aggressive considering the products and
technologies involved. GM commented that any attempt to force more
stringent regulations than proposed, such as Alternative 4, would be
extremely detrimental to manufacturers, consumers, the U.S. economy,
and the millions of transportation-related jobs. Daimler similarly
commented that the proposed standards would be a challenge for
automotive manufacturers. Under certain conditions, such a standard may
necessitate hybridization of the affected vehicle fleet, which would
require substantial development and material costs. All technologies
taken into account for the class 2b/3 stringencies should reflect cost
effectiveness calculations, especially alternative powertrains such as
hybrids, battery, and fuel cell driven electric vehicles. Daimler
recommends that the agencies adopt the proposed standard over
Alternative 4, as the additional two years of lead-time will be
critical for automotive manufacturers in developing the necessary
technologies to achieve compliance. Nissan commented that the
Alternative 4 3.5 percent per stringency level is simply not feasible,
as it does not provide the necessary lead-time to enable manufacturers
to balance competitive market constraints with the cost of applying new
technologies to a limited product offering. Nissan further commented
that to the extent that the more stringent alternative is predicated on
the adoption of hybrid and electric powertrain technology, Nissan does
not believe that such technology is feasible for this market segment.
The American Automotive Policy Council (AAPC, representing FCA,
Ford, and General Motors) further commented that proposals for greater
stringency than Alternative 3 are not supportable given the required
early introduction of unproven technologies with their associated
consumer acceptance risk, as well as the many implicit risks that
impact stringency. AAPC commented that the proposed standards are
aggressive and will challenge industry. AAPC noted that the baseline
fleet includes a high percentage of advanced diesel technology such as
SCR, making additional improvements considerably more challenging. In
the light-duty fleet, diesel technology accounts for 3 percent of fleet
whereas the heavy-duty fleet consists of over 50 percent diesel.
AAPC also noted that Phase 2 technologies are being used today. For
example, FCA's modern gasoline engine has robust combustion with
multiple spark plugs, variable cam phasing, cylinder deactivation, and
cooled EGR. AAPC commented that even with this level of gasoline engine
technology, FCA is challenged by the early year Phase 1 standards and
will need to look at adding even more technology for Phase 2. AAPC also
provided data showing that while smaller displacement boosted gasoline
engine technology may be applicable in some variants of commercial
vans, this technology is not suited for the pickup truck variants in
this segment because of customer demands for towing capability. AAPC
commented that concurrent stringency increases in Tier 3/LEV III
criteria emission requirements will negatively impact CO2
and fuel consumption. As an alternative to the standards proposed in
the NPRM, the American Automotive Policy Council (AAPC, representing
FCA, Ford, and General Motors) proposed standards that would achieve
the stringency by model year 2027, but that would do so at a more
gradual pace.\516\ As means of providing flexibility in complying with
these standards, AAPC also commented that the agencies should allow
credits to be banked for longer than 5 years, and should allow credits
to be transferred between the light- and heavy-duty fleets.\517\
---------------------------------------------------------------------------
\516\ AAPC, Docket No.NHTSA-2014-0132-0103 ], at pages 12-13.
\517\ AAPC, Docket No. NHTSA-2014-0132-0103 at pages 13-16.
---------------------------------------------------------------------------
(c) Determination
Having considered these comments as well as the updated analysis
summarized above, NHTSA is adopting standards under which the
stringency of fuel consumption standards for HD pickups and vans
advance at an annual rate of 2.5 percent during model years 2021-2027
relative to the 2018 MY Phase 1 standard level. In NHTSA's judgment,
this pace of stringency increase will appropriately accommodate
manufacturers' redesign workload and product schedules, especially in
light of this sector's limited product offerings \518\ and long product
cycles. Given the provided flexibility to carry credits forward (and
back) between model years, this approach strikes a balance between, on
one hand, meaningful early fuel efficiency improvements and, on the
other, providing manufacturers appropriate lead time.
---------------------------------------------------------------------------
\518\ Manufacturers generally have only one pickup platform and
one van platform in this segment.
---------------------------------------------------------------------------
Compared to Alternative 3, Alternative 2 would forego significant
cost-efficient opportunities to apply conventional and moderately
advanced technology in order to reduce fuel consumption and emissions.
Also, although the updated analysis summarized above shows costs for
Alternative 3 (as costs incremental to the No Action Alternative)
somewhat higher than estimated in the NPRM analysis, the agencies find
that under either the Method A or Method B analyses, AAPC's proposed
more gradual progression leading up to MY 2027 would also forego cost-
effective improvements which are readily feasible in the lead time
provided. Furthermore, the Method A analysis indicates that the
standards defining Alternative 3 can likely be met with minimal
reliance on hybrid technologies. Considering this, NHTSA also find it
unnecessary to extend the lifespan of banked credits or adopt other
credit related flexibilities to mitigate the stringency increases under
Alternative 3.
E. Analysis of the Regulatory Alternatives for HD Pickups and Vans:
Method B
Section 202(a)(1) and (2) of the Clean Air Act require EPA to
establish standards for emissions of pollutants from new motor vehicles
and engines which emissions cause or contribute to air pollution which
may reasonably be anticipated to endanger public health or welfare,
which include GHGs. See Section I.E. above. Under section 202(a)(1) and
(2), EPA considers such
[[Page 73802]]
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-GHG emissions; 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.
As part of the proposed feasibility analysis of potential standards
for HD pickups and vans, the agencies applied NHTSA's CAFE Model. The
agencies used this model to identify technology pathways that could be
used to meet a range of stringencies, based on our projections of
technology that will be available in the Phase 2 time frame. The
agencies considered these technology pathways and identified the
stringency level that will be technology-forcing (i.e. reflect levels
of stringency based on performance of emerging as well as currently
available control technologies) at reasonable cost, and leave
manufacturers the flexibility to adopt varying technology paths for
compliance and allow adequate lead time to develop, test, and deploy
the range of technologies.
As noted in Section I and discussed further below, the analyses
consider two versions of the CAFE model, one updated for the NPRM
analysis represented here in Method B, and one further updated for the
FRM represented in the Method A analysis described in D immediately
preceding this section. The results of both versions are reported
relative to two baselines, a flat baseline (designated Alternative 1a)
where no improvements are modeled beyond those needed to meet Phase 1
standards and a dynamic baseline (designated Alternative 1b) where
certain cost-effective technologies (i.e., those that payback within a
6 month period) are assumed to be applied by manufacturers to improve
fuel efficiency beyond the Phase 1 requirements in the absence of new
Phase 2 standards. NHTSA considered its primary analysis to be based on
the more dynamic baseline of Method A, whereas EPA considered the flat
baseline of Method B. As shown below and in Sections VII through X,
using the two different reference cases has little impact on the
results of the analysis and leads to the same conclusion regarding the
appropriateness of the Phase 2 standards. As such, the use of different
reference cases corroborates the results of the overall analysis.
For the NPRM, the agencies conducted coordinated and complementary
analyses by employing both NHTSA's CAFE model and EPA's MOVES model and
other analytical tools to project fuel consumption and GHG emissions
impacts resulting from the Phase 2 standards for HD pickups and vans,
against both the flat and dynamic baselines. EPA ran its MOVES model
for all HD categories, namely tractors and trailers, vocational
vehicles and HD pickups and vans, to develop a consistent set of fuel
consumption and CO2 reductions for all HD categories. The
MOVES runs followed largely the procedures described above, with some
differences. MOVES used the same technology application rates and costs
that are part of the inputs, and used cost per vehicle outputs of the
CAFE model to evaluate the Phase 2 standards for HD pickup trucks and
vans. The agencies note that these two independent analyses of
aggregate costs and benefits both support these standards. For the
final rule, NHTSA has conducted an analysis using a revised version of
the CAFE model, as discussed in Section D. This analysis has been
designated Method A. The EPA analysis based on the NPRM version of the
CAFE model along with EPA's MOVES model is designated Method B.
As noted earlier, the agencies are adopting as proposed a phase-in
schedule of reduction of 2.5 percent per year in fuel consumption and
CO2 levels relative to the 2018 MY Phase 1 standard level,
starting in MY 2021 and extending through MY 2027. We continue to
believe this phased-in implementation will appropriately accommodate
manufacturers' redesign workload and product schedules, especially in
light of this sector's limited product offerings \519\ and long product
cycles. This approach was chosen to strike a balance between meaningful
reductions in the early years and providing manufacturers with needed
lead time via a gradually accelerating ramp-up of technology
penetration. By expressing the phase-in in terms of increasing year to
year stringency for each manufacturer, while also providing for credit
generation and use (including averaging, carry-forward, and carry-
back), we believe our program will afford manufacturers substantial
flexibility to satisfy the phase-in through a variety of pathways: The
gradual application of technologies across the fleet, greater
application levels on only a portion of the fleet, and a sufficiently
broad set of available technologies to account for the variety of
current technology deployment among manufacturers and the lowest-cost
compliance paths available to each.
---------------------------------------------------------------------------
\519\ Manufacturers generally have only one pickup platform and
one van platform in this segment.
---------------------------------------------------------------------------
EPA did not estimate the cost of implementing these standards
immediately in 2021 without a phase-in, but we qualitatively assessed
it to be somewhat higher than the cost of the phase-in we are
establishing, due to the workload and product cycle disruptions it
could 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 75 FR 25451
(May 7, 2010) (documenting types of drastic cost increases associated
with trying to accelerate redesign schedules and concluding that ``[w]e
believe that it would be an inefficient use of societal resources to
incur such costs when they can be obtained much more cost effectively
just one year later''). On the other hand, waiting until 2027 before
applying any new standards could miss the opportunity to achieve
meaningful and cost-effective early reductions not requiring a major
product redesign. Comments on the phase-in are discussed in Section
B.2. and in the Response to Comments document.
As noted above, at proposal, the agencies requested comment in
particular on Alternative 4. EPA is not adopting Alternative 4 due to
uncertainty regarding whether or not the potential technologies and
market penetration rates included in Alternative 4 would be
technologically feasible. Alternative 4 would ultimately reach the same
levels of stringency as final Phase 2 standards, but would do so with
less lead time. As discussed below, this could require application of
both different technologies at higher application rates, neither of
which may be feasible (or, at the least, reliable implementable) by MY
2025.
Moreover, the two years of additional lead time provided by the
final standards compared to Alternative 4 eases compliance burden by
having more vehicle redesigns and lower stringency during the phase-in
period. As noted above, historically, the vehicles in this segment are
typically only redesigned every 6-10 years, so many of the vehicles may
not even be redesigned during the timeframe of the stringency increase.
In this case, a manufacturer must either make up for any vehicle that
falls short of its target through some combination of early compliance,
over compliance, credit carry-forward and carry-back, and
[[Page 73803]]
redesigning vehicles more frequently. Each of these will increase
technology costs to the manufacturers and vehicle purchasers, and early
redesigns will significantly increase capital costs and product
development costs. Also, the longer implementation time for the final
standards means that any manufacturer will have a slightly lower target
to meet from 2021-2026 than for the shorter phase-in of Alternative 4,
though by 2027 the manufacturers will have the same target in either
alternative.
Due to the projected higher technology adoption rates, Alternative
4 is also projected to result in higher costs, and risks of inadequate
time to successfully test and integrate new technology, than the
standards the agencies are adopting. Moreover, the additional emission
reductions and fuel savings predominately occur only during the program
phase-in period; from roughly 2030 on, the adopted standards and the
pull-ahead alternative are projected to be equivalent from an
environmental benefit standpoint. EPA's analysis and responses to
comments are discussed in detail below.
In some cases, the Method B (NPRM) version of the model selects
strong hybrids as a more cost effective technology over certain other
technologies including stop-start and mild hybrid. In other words,
strong hybrids are not a technology of last resort in the analysis.
Alternative 4 is projected to be met using a significantly higher
degree of hybridization including the use of more strong hybrids,
compared to the standards the agencies are finalizing. In order to
comply with a 3.5 percent per year increase in stringency over MYs
2021-2025, Method B modeling projects that manufacturers would need to
adopt more technology compared to the 2.5 percent per year increase in
stringency over MYs 2021-2027. The two years of additional lead time
provided by the Phase 2 standards reduces the potential number of
strong hybrids projected to be used by allowing for other more cost
effective technologies to be more fully utilized across the fleet. EPA
believes it is technologically feasible to apply this projected amount
of hybridization to HD pickups and vans in the lead time provided
(i.e., by MY 2027). However, strong hybrids present challenges in this
market segment compared to light-duty where there are several strong
hybrids already available. EPA does not believe that at this stage
there is enough information about the viability of strong hybrid
technology in this vehicle segment to assume that they can be a part of
large-volume deployment strategies for regulated manufacturers. For
example, EPA believes that hybrid electric technology could provide
significant GHG and fuel consumption benefits, but recognize that there
is uncertainty at this time over the real world effectiveness of these
systems in HD pickups and vans, and over customer acceptance of the
technology for vehicles with high GCWR towing large loads. Further, the
development, design, and tooling effort needed to apply this technology
to a vehicle model is quite large, and might not be cost-effective due
to the small sales volumes relative to the light-duty sector.
Additionally, EPA recognizes that sufficient engine horsepower and
torque needed to meet towing objectives which are important to pickup
truck buyers and accordingly the analysis does not down-size engines in
conjunction with hybridization. See Section VI.C.4.iv above. Therefore,
with no change projected for engine size, the strong hybrid costs do
not include costs for engine changes. In light-duty, the use of smaller
engines has an associated cost saving which facilitates much of a
hybrid's cost-effectiveness. Section E.2 discusses these issues
further, and explains further that the results of the updated CAFE
model used in Method A are consistent with these conclusions.
Due to these considerations in the NPRM and in the current Method B
analysis, EPA has conducted a sensitivity analysis using the Method B
version of the model that assumes the use of no strong hybrids. The
results of the analysis are also discussed below. The analysis
indicates that there will be a technology pathway that will allow
manufacturers to meet the final standards without the use of strong
hybrids. However, the analysis indicates that costs will be higher and
the cost effectiveness will be lower under the no strong hybrid
approach.
EPA also analyzed less stringent standards under which
manufacturers could comply by deploying a more limited set of
technologies than are needed to meet the Phase 2 standards being
adopted. However, our assessment concluded with a high degree of
confidence that the technologies on which the final Phase 2 standards
are premised will be available at reasonable cost in the 2021-2027
timeframe, and that the phase-in and other flexibility provisions allow
for their application in a very cost-effective manner, as discussed in
this section below. Accordingly, it would be inappropriate (within the
meaning of CAA section 202(a)(1) and (2)) to adopt standards of lesser
stringency.
More difficult to characterize is the degree to which more or less
stringent standards might be appropriate because of under- or over-
estimating the costs or effectiveness of the technologies whose
performance is the basis of the Phase 2 standards. For the most part,
these technologies have not yet been applied to HD pickups and vans,
even on a limited basis. EPA is therefore 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 a NHTSA contracted study at SwRI \520\ and
our recent rulemaking on light-duty vehicle GHGs and fuel economy, and
have generated a robust set of effectiveness values. Chapter 10 of the
RIA provides a detailed description of the CAFE Model and the analysis
performed for the rule.
---------------------------------------------------------------------------
\520\ Reinhart, T.E. (June 2015). Commercial Medium- and Heavy-
Duty Truck Fuel Efficiency Technology Study--Report #1. (Report No.
DOT HS 812 146). Washington, DC: National Highway Traffic Safety
Administration.
---------------------------------------------------------------------------
(1) Consistency of the Phase 2 Standards With the EPA's Legal Authority
Table VI-27 below shows projected technology adoption rates for
both the final Phase 2 standards and for a two-year pull ahead of those
standards (i.e. Alternative 4 from the NPRM). As at proposal, the table
shows that the Method B (EPA's central estimate) analysis estimates
that the most cost-effective way to meet the final Phase 2 standards
will be to use strong hybrids in up to 9.9 percent of pickups and 5.5
percent of vans on an industry-wide basis. The analysis of Alternative
4 shows strong hybrids on up to 19 percent of pickups (and two years
sooner). The analysis shows that the two years of additional lead time
provided by the Phase 2 standards compared to Alternative 4 will
provide manufacturers with a better opportunity to maximize the use of
technologies which are more cost effective than strong hybrids over
time thereby reducing the need for strong hybrids which may be
particularly challenging for this market segment, as well as providing
needed time for the more limited deployment of this technology
projected under alternative 3 (i.e. the Phase 2 standard).
[[Page 73804]]
Table VI-27--Method B CAFE Model Technology Adoption Rates for the Final Phase 2 Standards Rule and Alternative
4 Summary--Flat Baseline
----------------------------------------------------------------------------------------------------------------
Phase 2 standards (2.5% per Alternative 4 (3.5% per year)
year) 2021 to 2027 2021 to 2025
Technology ---------------------------------------------------------------
Pickup trucks Pickup trucks
% Vans % % Vans %
----------------------------------------------------------------------------------------------------------------
Low friction lubricants......................... 100 100 100 100
Engine friction reduction....................... 100 100 100 100
Cylinder deactivation........................... 22 19 22 19
Variable valve timing........................... 22 82 22 82
Gasoline direct injection....................... 0 63 0 80
Diesel engine improvements...................... 60 3.6 60 3.6
Turbo downsized engine.......................... 0 63 0 63
8 speed transmission............................ 98 92 98 92
Low rolling resistance tires.................... 100 92 100 59
Aerodynamic drag reduction...................... 100 100 100 100
Mass reduction and materials.................... 100 100 100 100
Electric power steering......................... 100 49 100 46
Improved accessories............................ 100 87 100 36
Low drag brakes................................. 100 45 100 45
Stop/start engine systems....................... 0 0 15 1.5
Mild hybrid..................................... 0 0 29 15
Strong hybrid................................... 9.9 5.5 19 0
----------------------------------------------------------------------------------------------------------------
As discussed earlier, EPA also conducted a sensitivity analysis
using the Method B version of the model to determine a compliance
pathway where no strong hybrids would be utilized. Although EPA in this
Method B analysis, projects that strong hybrids may be the most cost
effective approach, manufacturers may select another compliance path,
mainly a 20 percent penetration rate of mild hybrids. This no strong
hybrid analysis included the use of downsized turbocharged engines in
vans currently equipped with large V-8 engines. Turbo-downsized engines
were not allowed on 6+ liter gasoline vans in the primary analysis
because EPA sought to preserve consumer choice with respect to vans
that have large V-8s for towing. However, given the recent introduction
of vans with considerable towing capacity and turbo-downsized engines,
EPA believes it will be feasible for vans in the time-frame of these
final rules. The tables below reflect the difference in predicted
penetration rates of technologies if strong hybridization is not chosen
as a technology pathway. For simplicity, pickup trucks and vans are
combined into a single industry wide penetration rate.
The table also shows that when strong hybrids are used as a pathway
to compliance, penetration rates of all hybrid technologies would
increase substantially between the Phase 2 standards and Alternative 4.
The analysis predicts an increase in strong hybrid penetration from 8
percent to 12 percent, a 23 percent penetration of mild hybrids and a
10 percent penetration stop/start engine systems for Alternative 4
compared with the Phase 2 standards (hence much of the increased
projected cost between these options, as explained below). Also, by
having the final standards apply in MY 2027 instead of MY 2025, the
rule is not premised on use of any mild hybrids or stop/start engine
systems. This analysis shows that the few years of additional lead time
provided by the Phase 2 standards allows manufacturer's important
flexibility in choosing a mix of technologies that is best suited for
this market.
Table VI-28--CAFE Method B Model Technology Adoption Rates for Final Phase 2 Standards and Alternative 4
Combined Fleet and Fuels Summary--Flat Baseline
----------------------------------------------------------------------------------------------------------------
Phase 2 standards (2.5% per Alternative 4 (3.5% per year)
year) 2021 to 2027 2021 to 2025
---------------------------------------------------------------
Technology Without Without
With strong strong With strong strong
hybrids % hybrids % hybrids % hybrids %
----------------------------------------------------------------------------------------------------------------
Low friction lubricants......................... 100 100 100 100
Engine friction reduction....................... 100 100 100 100
Cylinder deactivation........................... 21 22 21 14
Variable valve timing........................... 46 46 46 46
Gasoline direct injection....................... 25 45 31 45
Diesel engine improvements...................... 38 38 38 38
Turbo downsized engine \a\...................... 25 31 25 31
8 speed transmission............................ 96 96 96 96
Low rolling resistance tires.................... 97 97 84 84
Aerodynamic drag reduction...................... 100 100 100 100
Mass reduction and materials.................... 100 100 100 100
Electric power steering......................... 80 92 79 79
Improved accessories............................ 67 77 75 75
[[Page 73805]]
Low drag brakes................................. 78 93 78 78
Stop/start engine systems....................... 0 1 10 4
Mild hybrid..................................... 0 20 23 66
Strong hybrid................................... 8 0 12 0
----------------------------------------------------------------------------------------------------------------
Note:
\a\ The 6+ liter V8 vans were allowed to convert to turbocharged and downsized engines in the ``without strong
hybrid'' analysis for both the Rule and the Alternative 4 to provide a compliance path.
The tables Table VI-29 and Table VI-30 below provide a further
breakdown of projected technology adoption rates specifically for
gasoline-fueled pickups and vans which shows potential adoption rates
of strong hybrids for each vehicle type. Strong hybrids are not
projected to be used in diesel applications. The Alternative 4 analysis
shows the use of strong hybrids in up to 48 percent of gasoline
pickups, depending on the mix of strong and mild hybrids, and stop/
start engine systems in 20 percent of gasoline pickups (the largest
gasoline HD segment). It is important to again note that this analysis
only shows one pathway to compliance, and the manufacturers may make
other decisions, e.g., changing the mix of strong vs. mild hybrids, or
applying electrification technologies to HD vans instead.
Table VI-29--CAFE Method B Model Technology Adoption Rates for Final Phase 2 Standards and Alternative 4 on
Gasoline Pickup Trucks--Flat Baseline
----------------------------------------------------------------------------------------------------------------
Phase 2 standards (2.5% per Alternative 4 (3.5% per year)
year) 2021 to 2027 2021 to 2025
---------------------------------------------------------------
Technology Without Without
With strong strong With strong strong
hybrids % hybrids % hybrids % hybrids %
----------------------------------------------------------------------------------------------------------------
Low friction lubricants......................... 100 100 100 100
Engine friction reduction....................... 100 100 100 100
Cylinder deactivation........................... 56 56 56 56
Variable valve timing........................... 56 56 56 56
Gasoline direct injection....................... 0 56 0 56
8 speed transmission............................ 100 100 100 100
Low rolling resistance tires.................... 100 100 100 100
Aerodynamic drag reduction...................... 100 100 100 100
Mass reduction and materials.................... 100 100 100 100
Electric power steering......................... 100 100 100 100
Improved accessories............................ 100 100 100 100
Low drag brakes................................. 100 100 100 100
Driveline friction reduction.................... 44 68 68 68
Stop/start engine systems....................... 0 0 20 0
Mild hybrid..................................... \a\ Up to 42 0 \a\ 18-86 86
Strong hybrid................................... Up to 25 .............. Up to 48
----------------------------------------------------------------------------------------------------------------
Note:
\a\ Depending on extent of strong hybrid adoption as hybrid technologies can replace each other, however they
will have different effectiveness and costs.
Table VI-30--CAFE Method B Model Technology Adoption Rates for Final Phase 2 Standards and Alternative 4 on
Gasoline Vans--Flat Baseline
----------------------------------------------------------------------------------------------------------------
Phase 2 Standards (2.5% per Alternative 4 (3.5% per year)
year) 2021 to 2027 2021 to 2025
---------------------------------------------------------------
Technology Without Without
With strong strong With strong strong
hybrids % hybrids % hybrids % hybrids %
----------------------------------------------------------------------------------------------------------------
Low friction lubricants......................... 100 100 100 100
[[Page 73806]]
Engine friction reduction....................... 100 100 100 100
Cylinder deactivation........................... 23 3 23 3
Variable valve timing........................... 100 100 100 100
Gasoline direct injection....................... 57 97 97 97
Turbo downsized engine \a\...................... 77 97 77 97
8 speed transmission............................ 97 97 97 97
Low rolling resistance tires.................... 100 100 60 60
Aerodynamic drag reduction...................... 100 100 100 100
Mass reduction and materials.................... 100 100 100 100
Electric power steering......................... 55 85 53 53
Improved accessories............................ 23 38 43 43
Low drag brakes................................. 53 89 53 100
Stop/start engine systems....................... 0 0 2 0
Mild hybrid..................................... \b\ Up to 13 13 18 40
Strong hybrid................................... Up to 7 .............. 0 ..............
----------------------------------------------------------------------------------------------------------------
Notes:
\a\ The 6+ liter V8 vans were allowed to convert to turbocharged and downsized engines in the ``without strong
hybrid'' analysis for both the Rule and the Alternative 4 to provide a compliance path.
\b\ Depending on extent of strong hybrid adoption as hybrid technologies can replace each other, however they
will have different effectiveness and costs.
EPA projects a compliance path for these standards showing
aggressive implementation of technologies that the agencies consider to
be available in the time frame of these rules. See Section VI.C.4.
Under this approach, manufacturers are expected to implement these
technologies at aggressive adoption rates on essentially all vehicles
across this sector by 2027 model year. In the case of several of these
technologies, adoption rates are projected to approach 100 percent.
This includes a combination of engine, transmission and vehicle
technologies as described in this section across every vehicle. The
standard also is premised on less aggressive penetration of particular
advanced technologies, including strong hybrid electric vehicles.
EPA projects the Phase 2 standards to be achievable within known
design cycles, and we believe these standards will allow different
paths to compliance in addition to the one we outline and cost here. As
discussed below and throughout this analysis, our rule places a high
value on the assurance of in use reliability and market acceptance of
new technology, particularly in initial model years of the program.
The NPRM analysis did not predict substantial amounts of technology
being added before the start of the MY 2021 standards, and in
particular, did not project that there would be substantial additions
of more advanced technologies in any redesign cycles occurring before
MY 2021. This continues to appear to be a reasonable assumption, since
substantial lead time is typically required to develop and implement
these advanced technologies. Indeed, as the previous discussion shows
(and as discussed again in responding to comments later in this
section), it is important to provide two additional years of lead time
between MY 2025 and 2027. More recent modeling used to update the NHTSA
Method A analysis as described in Section C above allows for technology
implementation in pre-2021 model years to both meet the final Phase 1
standards in MY 2018 and to also begin to introduce advanced
technologies that will eventually be needed in order to meet the Phase
2 standards. EPA considered this more recent modeling approach with
earlier redesign cycles and technology implementation and agrees with
NHTSA that this modelling shows that there would be insufficient lead
time to adopt the technologies to satisfy the compliance path modelled
for Alternatives 4 and 5 in the Method A analysis. See Section VI.D.4
above.
As discussed above, the agencies sought comment on the feasibility
and costs associated with the standards being finalized and also on
alternative standards. In particular, the agencies sought comment on
Alternative 4, which is based on a year-over-year increase in
stringency of 3.5 percent in MYs 2021-2025, essentially pulling ahead
the alternative 3 standard stringency by two model years. The agencies
received several comments in support of more stringent standards.
Several NGOs commented that more stringent standards than proposed are
feasible through the additional application of technology and that the
standards should more closely align with standards established for
light-duty trucks. UCS commented that gasoline vehicles could achieve
up to a 23.6 percent improvement in MY 2027 while diesel vehicles can
achieve an 18 percent improvement. ACEEE similarly recommended
increasing the stringency by 7 percent in MY 2027 and that standards
should reflect increased use of cylinder deactivation, cooled EGR, and
GDI and turbo downsizing in pickups. For diesels, ACEEE commented that
additional reductions were possible, based on an estimate of 10 percent
penetration of engine downsizing for pickups and 30 percent penetration
for vans in 2027, and also assuming 6 percent penetration of hybrids in
diesel vans. ICCT commented that the proposed standards represent only
a 2.2 and 1.6 percent year-over-year improvement for the gasoline and
diesel fleets, respectively, from MYs 2014-2025 compared to an almost 3
percent per year improvement for light-duty trucks in the same time
frame. ICCT recommended that the agencies' analysis incorporate the
full analysis
[[Page 73807]]
and inputs from the light-duty rulemaking and that the result would be
improvements in the range of 35 percent over the MYs 2014-2025 rather
than the proposed 23 percent improvement over this time frame.
The agencies also received comments that any gap between fuel
economy requirements for LD and HD pickups for which there is no
engineering rationale could produce distortions in the pickup market,
shifting sales toward the heavier vehicles. The Center for Biological
Diversity similarly commented that closing the gap between large light-
duty and heavy-duty pickups and vans is crucial because the overlap in
many characteristics allows manufacturers to essentially choose to
classify a pickup as ``heavy duty'' to avoid the more stringent
requirements for ``light duty'' pickups through minor adjustments to
the vehicle.
CARB staff commented in support of Alternative 4, commenting that
Alternative 4 is technologically feasible, cost-effective and superior
to Alternative 3. CARB noted that the Alternative 4 adds only three to
8 months to the payback period. CARB also commented that Alternative 4
remains significantly less stringent than the light-duty truck
standards. CARB further commented that Alternative 4 would result in
greater emissions and societal benefits than Alternative 3.
The agencies also received several comments opposing setting
standards more stringent than those proposed, although none of these
commenters opposed the actual proposal. AAPC commented that proposals
for greater stringency than Alternative 3 are not supportable given the
required early introduction of unproven technologies with their
(purportedly) associated consumer acceptance risk, as well as the many
implicit risks that impact stringency. AAPC commented that, in their
view, the proposed standards are aggressive and will challenge
industry. AAPC noted that the baseline fleet (which is over 50 percent
diesel) includes a high percentage of advanced diesel technology such
as SCR, making additional improvements more challenging. AAPC also
noted that Phase 2 technologies are being used today. For example,
FCA's modern gasoline engine has robust combustion with multiple spark
plugs, variable cam phasing, cylinder deactivation, and cooled EGR.
AAPC commented that even with this level of gasoline engine technology,
FCA is challenged by the early year Phase 1 standards and will need to
look at adding even more technology for Phase 2. AAPC also provided
data showing that while smaller displacement boosted gasoline engine
technology may be applicable in some variants of commercial vans, this
technology is not suited for the pickup truck variants in this segment
because of customer demands for towing capability. AAPC commented that
concurrent stringency increases in Tier 3/LEV III criteria emission
requirements will negatively impact CO2 and fuel
consumption.
GM commented that any attempt to force more stringent regulations
than proposed, such as Alternative 4, would be extremely detrimental to
manufacturers, consumers, the U.S. economy, and the millions of
transportation-related jobs. Daimler similarly commented that the
proposed standards would be a challenge for automotive manufacturers.
According to the commenter, under certain conditions, a more stringent
standard than proposed may necessitate hybridization of the affected
vehicle fleet, which would require substantial development and material
costs. Daimler recommends that EPA adopt the proposed standard over
Alternative 4, as the additional two years of lead-time will be
critical for automotive manufacturers in developing the necessary
technologies to achieve compliance. Nissan commented that Alternative 4
at 3.5 percent per year stringency level is simply not feasible, as it
does not provide the necessary lead-time to enable manufacturers to
balance competitive market constraints with the cost of applying new
technologies to a limited product offering. Nissan further commented
that to the extent that the more stringent alternative is predicated on
the adoption of hybrid and electric powertrain technology, Nissan does
not believe that such technology is feasible for this market segment.
After considering the comments, EPA believes that the Phase 2 final
standards that the agencies are adopting represent the most stringent
standards reasonably achievable within the MY 2021-2027 period. The
standards are based largely on the same technologies projected to be
used in the light-duty fleet with appropriate adjustments for the
heavy-duty fleet because of their specific higher load duty cycles. As
shown in the tables 28 and 29 above and repeated below, several
technologies are projected to be used at very high adoption rates at or
near 100 percent including mass reduction, 8-speed transmissions,
engine friction reduction, low rolling resistant tires, improved
accessories, and aerodynamic drag reductions. For gasoline engines,
some commenters noted that downsize turbo engines which are projected
to be used extensively in light-duty vehicles should also be relied on
in the heavy-duty analysis, including for HD pickups. As discussed in
VI.C.4.vii above, the agencies agree with the comments provided by AAPC
that turbo downsizing is likely to be counter-productive in heavy-duty
pickups. EPA (and NHTSA in the Method A analysis) thus is projecting
the use of downsized turbo engines only for vans. Under heavy loads,
turbo downsized engines may have higher CO2 and fuel
consumption than the engine it replaces. For this reason, EPA continues
to believe that the technology can only be projected to be available
for heavy-duty vans (and not pickups) and, for vans, is projecting its
use at 77 to 97 percent. One commenter argued for a standard predicated
on a more aggressive penetration rate for cylinder deactivation noting
that in the NPRM the agencies only projected cylinder deactivation at
an adoption rate of 22 percent of the overall fleet. The commenter
believes that an adoption rate of 40 percent would be more appropriate.
In response, cylinder deactivation is a gasoline engine technology and
EPA is projecting an adoption rate of 56 percent for pickups and an
adoption rate of essentially 100 percent for the gasoline engines in
vans not projected to be downsized turbo engines (i.e. a more
aggressive penetration rate than urged by the commenter).
EPA also remains concerned about projecting standards predicated on
high levels of hybridization in the heavy-duty pickup and van fleet.
Many heavy duty applications need maximum payload and cargo volume
which may compete with weight increases and lost cargo volume from
hybridization, directly reducing the capability and therefore work
factor of the vehicle. Additionally, it is likely not feasible to size
a hybridization system to be effective for any high or maximum payload
or towing operation without changing the utility of the vehicle. A
manufacturer choosing to hybridize a heavy duty vehicle would likely
target vans that are primarily used for cargo volumetric capacity
reasons where a reasonably sized hybrid system could be incorporated
and be effective under typical operation. EPA believes that the final
Phase 2 standards will drive the orderly use of technology while still
providing enough lead time that manufacturers could meet the standards
using technology paths other than high penetration rates of strong
hybrids. Thus, the gap in stringency between
[[Page 73808]]
light-duty trucks and the Phase 2 standards for HD pickups and vans
reflects constraints of the use of some technologies in the heavy-duty
market resulting from the intended use of the vehicles to do more work
than light-duty trucks.
The proposed rule discussed several considerations that EPA
believes remain valid. The NPRM projected that the higher rate of
increase in stringency associated with Alternative 4 and the shorter
lead time would necessitate the use of a different technology mix under
Alternative 4 compared to the Phase 2 standards that the agencies are
adopting. The Phase 2 standards are projected to achieve the same final
stringency increase as Alternative 4 at about 80 percent of the average
per-vehicle cost increase, and without the expected deployment of more
advanced technology at high penetration levels. In particular, under
EPA's primary analysis, which does not constrain the use of strong
hybrids, manufacturers are estimated to deploy strong hybrids in
approximately 8 percent of new vehicles (in MY 2027) under the Phase 2
standards, compared to 12 percent under Alternative 4 (in MY 2025).
Less aggressive electrification technologies also appear on 33 percent
of new vehicles simulated to be produced in MY 2027 under Alternative
4, but are not projected to be necessary under the Phase 2 standards.
Additionally, it is important to note that due to the shorter lead time
of Alternative 4, there are fewer vehicle refreshes and redesigns
during the phase-in period of MY 2021-2025. The longer, shallower
phase-in of advanced technologies in the standards that the agencies
are adopting allows for more compliance flexibility and closer matching
with the vehicle redesign cycles, which (as noted above) can be up to
ten years for HD vans. While the Method B CAFE model's algorithm
accounts for manufacturers' consideration of upcoming stringency
changes and credit carry-forward, the steeper ramp-up of the standard
in Alternative 4, coupled with the five-year credit life, results in a
prediction that manufacturers would need to take less cost-effective
means to comply with the standards compared with the final phase-in
period of MY 2021-2027. The public comments from industry commenters
confirmed that this is a realistic prediction. For example, the Method
B model predicts that some manufacturers will not implement any amount
of strong hybrids on their vans during the 2021-2025 timeframe and
instead will implement less effective technologies such as mild hybrids
at higher penetration rates. There is also a high degree of sensitivity
to the estimated effectiveness levels of individual technologies. At
high penetration rates of all technologies on a vehicle, the result of
a reduced effectiveness of even a single technology could be non-
compliance with the standards. If the standards do not account for this
uncertainty, there will be a real possibility that a manufacturer who
followed the exact technology path we project will not meet their
target because a technology performed slightly differently in their
application. In this Method B analysis, EPA considered all comments
regarding Alternative 4 and concluded that the longer lead time
provided by the Phase 2 standards that the agencies are adopting is
necessary as it better matches the redesign cycles for vehicles in this
market segment and provides the time necessary for manufacturers to
more fully utilize a range of technologies best suited for this market
segment. These technologies are projected to be available within the
lead time provided under the Phase 2 standards--i.e., by MY 2027, as
discussed in RIA Chapter 2.6. These standards will require a relatively
aggressive implementation schedule of most of these technologies during
the program phase-in. Heavy-duty pickups and vans will need to have a
combination of many individual technologies to achieve these standards.
These standards are projected to yield significant emission and fuel
consumption reductions without requiring a large segment transition to
strong hybrids, a technology that while successful in light-duty
passenger cars, cross-over vehicles and SUVs, may impact vehicle work
capabilities \521\ and have questionable customer acceptance in a large
portion of this segment dedicated to towing.\522\ See discussion above
and in Section VI.D.9.
---------------------------------------------------------------------------
\521\ As noted earlier, hybrid batteries, motors and electronics
generally add weight to a vehicle and require more space which can
result in conflicts with payload weight and volume objectives.
\522\ Hybrid electric systems are not sized for situations when
vehicles are required to do trailer towing where the combined weight
of vehicle and trailer is 2 to 4 times that of the vehicle alone.
During these conditions, the hybrid system will have reduced
effectiveness. Sizing the system for trailer towing is prohibitive
with respect to hybrid component required sizes and the availability
of locations to place larger components like batteries.
---------------------------------------------------------------------------
The tables above show that many technologies will be at or
potentially approach 100 percent adoption rates according to the
analysis. If certain technologies turn out to be not well suited for
certain vehicle models or less effective that projected, other
technology pathways will be needed. The additional lead time provided
by the Phase 2 standards reduces these concerns because manufacturers
will have more flexibility to implement their compliance strategy and
are more likely to do so within a product redesign cycle necessary for
many new technologies to be implemented.
The agencies also received comments that the standards should be
based exclusively on the GHG capabilities of diesel vehicles. The
commenters viewed the separate gasoline and diesel standards as
preferential treatment of gasoline-powered vehicles which have
inherently higher GHG and fuel consumption. As discussed in Section
B.1, the agencies are maintaining the separate gasoline and diesel
standards for heavy duty pickups and vans. As discussed earlier, diesel
engines are fundamentally more efficient than gasoline engines
providing the same power (even gasoline engines with the technologies
discussed above) while using less fuel. However, dieselization is not a
technology path the agencies included in the analysis for the Phase 1
rule or the Phase 2 rules. Gasoline-powered vehicles account for nearly
half of the heavy-duty pickup and van market and are used in
applications where a diesel may not make sense from a cost or consumer
choice standpoint. Commenters did not address the costs of extensive
dieselization.
More stringent standards, including Alternative 4, could result in
manufacturers switching from gasoline engines to diesel engines in
certain challenging segments. While technologically feasible, EPA
remains concerned that this pathway could cause a distortion in
consumer choices and significantly increase the cost of those vehicles,
particularly considering that more stringent standards are projected to
require penetration of some form of hybridization. Also, the agencies
did not consider the impact dieselization would have on lead-time, as
shifting nearly half the market from gasoline to diesel engines would
require substantial retooling of production. Commenters also did not
account for the costs or address the feasibility of such retooling in
the lead time available under either Phase 2 or Alternative 4. In
addition, if dieselization occurs by manufacturers equipping vehicles
with larger diesel engines designed for broad coverage of applications
typical of this sector rather than ``right-sized'' engines, the towing
capability of the vehicles could increase, resulting in higher work
factors for the vehicles, higher targets, and reduced program benefits.
Bosch commented that holding gasoline vehicles to the same GHG
standards as
[[Page 73809]]
diesels would bring the costs of compliance with all emissions
standards, including criteria pollutant standards, for gasoline
vehicles more in line with diesels, considering the costs of complying
with criteria pollutant standards are much higher for diesels compared
to gasoline vehicles. In response, EPA's Method B analysis shows that
significantly more stringent gasoline vehicle GHG standards may require
high levels of hybridization which, as discussed above, may not be
acceptable for this market segment. This, in turn, could lead to
dieselization, as manufacturers would opt to phase out gasoline-fueled
vehicles rather than opt for widespread hybridization of their product
offerings. EPA continues to believe that it is reasonable to adopt
Phase 2 standards that continue to preserve the opportunity for
manufacturers to produce and consumers to choose gasoline-powered
vehicles in this market segment.
Based on the information presented here in this Method B analysis,
EPA believes that the Phase 2 standards the agencies are finalizing are
appropriate within the meaning of CAA section 202(a)(1), for this
segment for the model years in question. EPA believes the standards
reflect a reasonable consideration of the statutory factors of
technology effectiveness, feasibility, cost, lead time, and safety for
purposes of CAA sections 202(a)(1) and (2). The standards are
appropriately technology-forcing, predicated on performance of
technologies not only currently deployed but those which reasonably can
be developed during the phase in period. EPA has indicated how
technologies not currently deployed in this sector can be reliably
commercialized in the lead time provided by the standard. See above and
RIA Chapter 2.5 ``Technology Application'' where the individual
technologies available during the phase-in are described in detail.
Note that advanced technologies like strong hybridization will require
several years of development prior to commercialization to meet
required reliability and durability goals in this sector. As noted, the
Method B analysis projects that the additional lead-time provided by
the Phase 2 standards allows for the implement CO2-reducing
technologies without the need for significant hybridization and at a
significantly lower cost compared to Alternative 4, as shown in the
tables above.
EPA has also carefully considered the costs of the standards. The
technologies associated with meeting the Phase 2 standards are
estimated to add costs to heavy-duty pickups and vans as shown in Table
VI-31 for the flat baseline. These costs are the average fleet-wide
incremental vehicle costs relative to a vehicle meeting the MY 2018
standard in each of the model years shown. Reductions associated with
these costs and technologies are considerable, estimated at a 16
percent reduction of fuel consumption and CO2eq emissions
from the MY 2018 baseline for gasoline and diesel engine equipped
vehicles.\523\ As shown by the analysis, the long-term cost
effectiveness of the rule is similar to that of the Phase 1 HD pickup
and van standards (found by the agencies to be highly cost effective,
without consideration of payback), and also falls within the range of
the cost effectiveness for Phase 2 standards for the other HD
sectors.\524\ The agencies have already found costs in this range to be
cost effective (including for the heavy duty pickup and van sector),
independent of the associated fuel savings. 76 FR 57228. EPA reiterates
that finding here. Moreover, the cost of controls reflected in
potential increased vehicle cost will be fully recovered by the
operator due to the associated fuel savings, with a payback period
somewhere in the third year of ownership, as shown in Section IX.M of
this Preamble. The rules' projected benefits far exceed costs (see
IX.K), and costs are actually projected to be negative when fuel
savings are considered.
---------------------------------------------------------------------------
\523\ See Table VI-27.
\524\ Analysis using the MOVES model indicates that the cost
effectiveness of these standards is $95 per ton CO2 eq
removed in MY 2030 (RIA Table 7-31), almost identical to the $90 per
ton CO2 eq removed (MY 2030) which the agencies found to
be highly cost effective for these same vehicles in Phase 1. See 76
FR 57228.
---------------------------------------------------------------------------
Consistent with EPA's authority under 42 U.S.C. 7521(a) and based
on its Method B analysis, EPA is thus finalizing the Phase 2 standards
as proposed.
Table VI-31--HD Pickups and Vans Incremental Technology Costs per Vehicle Final Phase 2 Standards vs. Flat Baseline
--------------------------------------------------------------------------------------------------------------------------------------------------------
2018 2019 2020 2021 2022 2023 2024 2025 2026 2027
--------------------------------------------------------------------------------------------------------------------------------------------------------
NPRM (2012$).............................. $112 $104 $106 $516 $508 $791 $948 $1,161 $1,224 $1,342
FRM (2013$)............................... 114 105 108 524 516 804 963 1,180 1,244 1,364
--------------------------------------------------------------------------------------------------------------------------------------------------------
(2) HD Pickups and Vans Industry Impacts (Method B)
The analysis fleet provides a starting point for estimating the
extent to which manufacturers might add fuel-saving (and, therefore,
CO2-avoiding) technologies under various regulatory
alternatives, including the no-action alternative that defines a
baseline against which to measure estimated impacts of new standards.
The analysis fleet is a forward-looking projection of production of new
HD pickups and vans, holding vehicle characteristics (e.g., technology
content and fuel consumption levels) constant at model year 2014
levels, and adjusting production volumes based on recent DOE and
commercially-available forecasts. This analysis fleet includes some
significant changes relative to the market characterization that was
used to develop the Phase 1 standards applicable starting in model year
2014; in particular, the analysis fleet includes some new HD vans
(e.g., Ford's Transit and Fiat Chrysler's Promaster) that are
considerably more fuel-efficient than HD vans these manufacturers have
previously produced for the U.S. market.
While the Phase 2 standards are scheduled to begin in model year
2021, the requirements they define are likely to influence
manufacturers' planning decisions several years in advance. This is
true in light-duty planning, and is accentuated by the comparatively
long redesign cycles and small number of models and platforms offered
for sale in the 2b/3 market segment. Additionally, manufacturers will
respond to the cost and efficacy of available fuel consumption
improvements, the price of fuel, and the requirements of the Phase 1
standards that specify maximum allowable average fuel consumption and
GHG levels for MY 2014-MY 2018 HD pickups and vans (the final standard
for MY 2018 is held constant for model years 2019 and
[[Page 73810]]
2020). The forward-looking nature of product plans that determine which
vehicle models will be offered in the model years affected by these
standards lead to additional technology application to vehicles in the
analysis fleet that occurs in the years prior to the start of these
standards. From the industry perspective, this means that manufacturers
will incur costs to comply with these standards in the baseline and
that the total cost of the regulations will include some costs that
occur prior to their start, and represent incremental changes over a
world in which manufacturers will have already modified their vehicle
offerings compared to today.
Table VI-32--MY 2021 Method B Baseline Costs for Manufacturers in 2b/3
Market Segment in the Dynamic Baseline, or Alternative 1b
------------------------------------------------------------------------
Average Total cost
Manufacturer technology increase
cost ($) ($m)
------------------------------------------------------------------------
Fiat Chrysler................................. 275 27
Daimler....................................... 18 0
Ford.......................................... 258 78
General Motors................................ 782 191
Nissan........................................ 282 3
Industry...................................... 442 300
------------------------------------------------------------------------
As Table VI-32 shows, the industry as a whole is expected to add
about $440 of new technology to each new vehicle model by 2021 under
the no-action alternative defined by the Phase 1 standards. Reflecting
differences in projected product offerings in the analysis fleet, some
manufacturers (notably Daimler) are significantly less constrained by
the Phase 1 standards than others and face lower cost increases as a
result. General Motors (GM) shows the largest increase in average
vehicle cost, but results for GM's closest competitors (Ford and Fiat
Chrysler) do not include the costs of their recent van redesigns, which
are already present in the analysis fleet (discussed in greater detail
below).
The above results reflect the assumption that manufacturers having
achieved compliance with standards might act as if buyers are willing
to pay for further fuel consumption improvements that ``pay back''
within 6 months (i.e., those improvements whose incremental costs are
exceeded by savings on fuel within the first six months of ownership).
It is also possible that manufacturers will choose not to migrate cost-
effective technologies to the 2b/3 market segment from similar vehicles
in the light-duty market. Resultant technology costs in model year 2021
results for the no-action alternative, summarized in Table VI-33 below,
are quite similar to those shown above for the 6-month payback period.
Due to the similarity between the two baseline characterizations,
results in the following discussion represent differences relative to
only the 6-month payback baseline.
Table VI-33--MY 2021 Method B Baseline Costs for HD Pickups and Vans in
the Flat Baseline, or Alternative 1a
------------------------------------------------------------------------
Average Total cost
Manufacturer technology increase
cost ($) ($m)
------------------------------------------------------------------------
Fiat Chrysler................................. 268 27
Daimler....................................... 0 0
Ford.......................................... 248 75
General Motors................................ 767 188
Nissan........................................ 257 3
Industry...................................... 431 292
------------------------------------------------------------------------
The results below represent the impacts of several regulatory
alternatives, including those defined by the Phase 2 standards, as
incremental changes over the baseline, where the baseline is defined as
the state of the world in the absence of this regulatory action (but,
of course, including the Phase 1 standards). Large-scale, macroeconomic
conditions like fuel prices are constant across all alternatives,
including the baseline, as are the fuel economy improvements under the
no-action alternative defined by the Phase 1 rule that covers model
years 2014-2018 and is constant from model year 2018 through 2020. In
the baseline scenario, the Phase 1 standards are assumed to remain in
place and at 2018 levels throughout the analysis (i.e. MY 2030). The
only difference between the definitions of the alternatives is the
stringency of these standards starting in MY 2021 and continuing
through either MY 2025 or MY 2027, and all of the differences in
outcomes across alternatives are attributable to differences in the
standards.
The standards vary in stringency across regulatory alternatives (1-
5), but as discussed above, all of the standards are based on the curve
developed in the Phase 1 standards that relate fuel economy and GHG
emissions to a vehicle's work factor. The alternatives considered here
represent different rates of annual increase in the curve defined for
model year 2018, growing from a 0 percent annual increase (Alternative
1, the baseline or ``no-action'' alternative) up to a 4 percent annual
increase (Alternative 5). Table VI-34 shows a summary \525\ of outcomes
by alternative incremental to the baseline (Alternative 1b) for Model
Year 2030 \526\, with the exception of technology penetration rates,
which are absolute.
---------------------------------------------------------------------------
\525\ NHTSA generated hundreds of outputs related to economic
and environmental impacts, each available technology, and the costs
associated with the rule. A more comprehensive treatment of these
outputs appears in Chapter 10 of the RIA.
\526\ As noted above, the NHTSA CAFE model estimates that
redesign schedules will ``straddle'' model year 2027, the latest
year for which the agencies are increasing the stringency of fuel
consumption and GHG standards. Considering also that today's
analysis estimates some earning and application of ``carried
forward'' compliance credits, the model was run extending the
analysis through model year 2030.
---------------------------------------------------------------------------
The technologies applied as inputs to the CAFE model (in either its
Method B or A iterations) have been grouped (in most cases) to give
readers a general sense of which types of technology are applied more
frequently than others, and are more likely to be offered in new class
2b/3 vehicles once manufacturers are fully compliant with the standards
in the alternative. Model year 2030 was chosen to account for
technology application that occurs once the standards have stabilized,
but manufacturers are still redesigning products to achieve
compliance--generating technology costs and benefits in those model
years. The summaries of technology penetration are also intended to
reflect the relationship between technology application and cost
increases across the alternatives. The table rows present the degree to
which specific technologies are predicted to be present in new class 2b
and class 3 vehicles in 2030, and correspond to: Variable valve timing
(VVT) and/or variable valve lift (VVL), cylinder deactivation, direct
injection, engine turbocharging, 8-speed automatic transmissions,
electric power-steering and accessory improvements, micro-hybridization
(which reduces engine idle, but does not assist propulsion), full
hybridization (integrated starter generator or strong hybrid that
assists propulsion and recaptures braking energy), and aerodynamic
improvements to the vehicle shape. In addition to the technologies in
the following tables, there are some lower-complexity technologies that
have high market penetration across all the alternatives and
manufacturers; low rolling-resistance tires, low friction lubricants,
and reduced engine friction are examples.
[[Page 73811]]
Table VI-34--Summary of HD Pickups and Vans Alternatives' Impact on Industry Versus the Dynamic Baseline,
Alternative 1b; Method B
----------------------------------------------------------------------------------------------------------------
Alternative 2 3 4 5
----------------------------------------------------------------------------------------------------------------
Annual Stringency Increase...................... 2.0%/y 2.5%/y 3.5%/y 4.0%/y
Stringency Increase Through MY.................. 2025 2027 2025 2025
Total Stringency Increase....................... 9.6% 16.2% 16.3% 18.5%
----------------------------------------------------------------------------------------------------------------
Average Fuel Economy (miles per gallon)
----------------------------------------------------------------------------------------------------------------
Required........................................ 19.04 20.57 20.57 21.14
Achieved........................................ 19.14 20.61 20.83 21.27
----------------------------------------------------------------------------------------------------------------
Average Fuel Consumption (gallons/100 mi.)
----------------------------------------------------------------------------------------------------------------
Required........................................ 5.25 4.86 4.86 4.73
Achieved........................................ 5.22 4.85 4.80 4.70
----------------------------------------------------------------------------------------------------------------
Average Greenhouse Gas Emissions (g/mi)
----------------------------------------------------------------------------------------------------------------
Required........................................ 495 458 458 446
Achieved........................................ 491 458 453 444
----------------------------------------------------------------------------------------------------------------
Technology Penetration (%)
----------------------------------------------------------------------------------------------------------------
VVT and/or VVL.................................. 46 46 46 46
Cylinder Deac................................... 29 21 21 21
Direct Injection................................ 17 25 31 32
Turbocharging................................... 55 63 63 63
8-Speed AT...................................... 67 96 96 97
EPS, Accessories................................ 54 80 79 79
Stop Start...................................... 0 0 10 13
Hybridization \a\............................... 0 8 35 51
Aero. Improvements.............................. 36 78 78 78
----------------------------------------------------------------------------------------------------------------
Mass Reduction (vs. No-Action)
----------------------------------------------------------------------------------------------------------------
CW (lb.)........................................ 239 243 325 313
CW (%).......................................... 3.7 3.7 5.0 4.8
----------------------------------------------------------------------------------------------------------------
Technology Cost (vs. No-Action)
----------------------------------------------------------------------------------------------------------------
Average ($) \b\................................. 578 1,348 1,655 2,080
Total ($m) \c\.................................. 437 1,019 1,251 1,572
Payback period (m) \c\.......................... 25 31 34 38
----------------------------------------------------------------------------------------------------------------
Notes:
\a\ Includes mild hybrids (ISG) and strong HEVs.
\b\ Values used in Methods A & B
\c\ Values used in Method A, calculated using a 3% discount rate.
In general, as stated above, the Method B model projected that the
standards will cause manufacturers to produce HD pickups and vans that
are lighter, more aerodynamic, and more technologically complex across
all the alternatives. As Table VI-34 shows, there is a difference
between the relatively small increases in required fuel economy and
average incremental technology cost between the alternatives,
suggesting that the challenge of improving fuel consumption and
CO2 emissions accelerates as stringency increases (i.e.,
that there may be a ``knee'' in the relationship between technology
cost and reductions in fuel consumption/GHG emissions).
The contrast between alternatives 3 and 4 is even more prominent,
with an identical required fuel economy improvement projected to lead
to price increases greater than 20 percent based on the more rapid rate
of increase and shorter time span of Alternative 4, which achieves all
of its increases by MY 2025 while Alternative 3 continues to increase
at a slower rate until MY 2027. Despite these differences, the increase
in average payback period when moving from Alternative 3 to Alternative
4 to Alternative 5 is fairly constant at around an additional three
months for each jump in stringency.
Manufacturers offer few models, typically only a pickup truck and/
or a cargo van, and while there are a large number of variants of each
model, the degree of component sharing across the variants can make
diversified technology application either economically impractical or
impossible. This forces manufacturers to apply some technologies more
broadly in order to achieve compliance than they might do in other
market segments (passenger cars, for example). This difference between
broad and narrow application--where some technologies must be applied
to entire platforms, while some can be applied to individual model
variants--also explains why certain technology penetration rates
decrease between alternatives of increasing stringency (cylinder
deactivation or mass reductions in Table VI-34, for example). For those
cases, narrowly applying a more advanced (and costly) technology can be
a more cost effective path to compliance and lead to reductions in the
amount of
[[Page 73812]]
lower-complexity technology that is applied.
As noted in Section E.1 above, one driver of the change in
technology cost between Alternative 3 and Alternative 4 in the Method B
analysis is the amount of hybridization projected to result from the
implementation of the standards. While only about 5 percent full
hybridization (defined as either integrated starter-generator or strong
hybrid) is expected to be needed to comply with Alternative 3, the
higher rate of increase and compressed schedule moving from Alternative
3 to Alternative 4 is enough to increase the percentage of the fleet
adopting full hybridization by a factor of two. To the extent that
manufacturers are concerned about introducing hybrid vehicles in the 2b
and 3 market, it is worth noting that new vehicles subject to
Alternative 3 achieve the same fuel economy as new vehicle subject to
Alternative 4 by 2030, with less full hybridization projected under
this Method B analysis as being needed to achieve the improvement.
The alternatives also lead to important differences in outcomes at
the manufacturer level, both from the industry average and from each
other. General Motors, Ford, and Fiat Chrysler, are expected to have
approximately 95 percent of the 2b/3 new vehicle market during the
years that these standards are being phased in. Due to their importance
to this market and the similarities between their model offerings,
these three manufacturers are discussed together and a summary of the
way each is impacted by the standards appears below in Table VI-35,
Table VI-36 and Table VI-37 for General Motors, Ford, and Fiat
Chrysler, respectively.
Table VI-35--Summary of Impacts on General Motors by 2030 in the HD Pickup and Van Market Versus the Dynamic
Baseline, Alternative 1b
----------------------------------------------------------------------------------------------------------------
Alternative 2 3 4 5
----------------------------------------------------------------------------------------------------------------
Annual Stringency Increase...................... 2.0%/y 2.5%/y 3.5%/y 4.0%/y
Stringency Increase Through MY.................. 2025 2027 2025 2025
----------------------------------------------------------------------------------------------------------------
Average Fuel Economy (miles per gallon)
----------------------------------------------------------------------------------------------------------------
Required........................................ 18.38 19.96 20 20.53
Achieved........................................ 18.43 19.95 20.24 20.51
----------------------------------------------------------------------------------------------------------------
Average Fuel Consumption (gallons/100 mi.)
----------------------------------------------------------------------------------------------------------------
Required........................................ 5.44 5.01 5 4.87
Achieved........................................ 5.42 5.01 4.94 4.87
----------------------------------------------------------------------------------------------------------------
Average Greenhouse Gas Emissions (g/mi)
----------------------------------------------------------------------------------------------------------------
Required........................................ 507 467 467 455
Achieved........................................ 505 468 461 455
----------------------------------------------------------------------------------------------------------------
Technology Penetration (%)
----------------------------------------------------------------------------------------------------------------
VVT and/or VVL.................................. 64 64 64 64
Cylinder Deac................................... 47 47 47 47
Direct Injection................................ 18 18 36 36
Turbocharging................................... 53 53 53 53
8-Speed AT...................................... 36 100 100 100
EPS, Accessories................................ 100 100 100 100
Stop Start...................................... 0 0 2 0
Hybridization................................... 0 19 79 100
Aero. Improvements.............................. 100 100 100 100
----------------------------------------------------------------------------------------------------------------
Mass Reduction (vs. No-Action)
----------------------------------------------------------------------------------------------------------------
CW (lb.)........................................ 325 161 158 164
CW (%).......................................... 5.3 2.6 2.6 2.7
----------------------------------------------------------------------------------------------------------------
Technology Cost (vs. No-Action)
----------------------------------------------------------------------------------------------------------------
Average ($) \a\................................. 785 1,706 2,244 2,736
Total ($m, undiscounted) \b\.................... 214 465 611 746
----------------------------------------------------------------------------------------------------------------
Notes:
\a\ Values used in Methods A & B.
\b\ Values used in Method A, calculated at a 3% discount rate.
Table VI-36--Summary of Impacts on Ford by 2030 in the HD Pickup and Van Market Versus the Dynamic Baseline,
Alternative 1b
----------------------------------------------------------------------------------------------------------------
Alternative 2 3 4 5
----------------------------------------------------------------------------------------------------------------
Annual Stringency Increase...................... 2.0%/y 2.5%/y 3.5%/y 4.0%/y
Stringency Increase Through MY.................. 2025 2027 2025 2025
----------------------------------------------------------------------------------------------------------------
[[Page 73813]]
Average Fuel Economy (miles per gallon)
----------------------------------------------------------------------------------------------------------------
Required........................................ 19.42 20.96 20.92 21.51
Achieved........................................ 19.5 21.04 21.28 21.8
----------------------------------------------------------------------------------------------------------------
Average Fuel Consumption (gallons/100 mi.)
----------------------------------------------------------------------------------------------------------------
Required........................................ 5.15 4.77 4.78 4.65
Achieved........................................ 5.13 4.75 4.70 4.59
----------------------------------------------------------------------------------------------------------------
Average Greenhouse Gas Emissions (g/mi)
----------------------------------------------------------------------------------------------------------------
Required........................................ 485 449 450 438
Achieved........................................ 482 447 443 433
----------------------------------------------------------------------------------------------------------------
Technology Penetration (%)
----------------------------------------------------------------------------------------------------------------
VVT and/or VVL.................................. 34 34 34 34
Cylinder Deac................................... 18 0 0 0
Direct Injection................................ 16 34 34 34
Turbocharging................................... 51 69 69 69
8-Speed AT...................................... 100 100 100 100
EPS, Accessories................................ 41 62 59 59
Stop Start...................................... 0 0 20 29
Hybridization................................... 0 2 14 30
Aero. Improvements.............................. 0 59 59 59
----------------------------------------------------------------------------------------------------------------
Mass Reduction (vs. No-Action)
----------------------------------------------------------------------------------------------------------------
CW (lb.)........................................ 210 202 379 356
CW (%).......................................... 3.2 3 5.7 5.3
----------------------------------------------------------------------------------------------------------------
Technology Cost (vs. No-Action)
----------------------------------------------------------------------------------------------------------------
Average ($) \a\................................. 506 1,110 1,353 1,801
Total ($m, undiscounted) \b\.................... 170 372 454 604
----------------------------------------------------------------------------------------------------------------
Notes:
\a\ Values used in Methods A & B.
\b\ Values used in Method A, calculated at a 3% discount rate.
Table VI-37--Summary of Impacts on Fiat Chrysler by 2030 in the HD Pickup and Van Market Versus the Dynamic
Baseline, Alternative 1b
----------------------------------------------------------------------------------------------------------------
Alternative 2 3 4 5
----------------------------------------------------------------------------------------------------------------
Annual Stringency Increase...................... 2.0%/y 2.5%/y 3.5%/y 4.0%/y
Stringency Increase Through MY.................. 2025 2027 2025 2025
----------------------------------------------------------------------------------------------------------------
Average Fuel Economy (miles per gallon)
----------------------------------------------------------------------------------------------------------------
Required........................................ 18.73 20.08 20.12 20.70
Achieved........................................ 18.83 20.06 20.10 20.70
----------------------------------------------------------------------------------------------------------------
Average Fuel Consumption (gallons/100 mi.)
----------------------------------------------------------------------------------------------------------------
Required........................................ 5.34 4.98 4.97 4.83
Achieved........................................ 5.31 4.99 4.97 4.83
----------------------------------------------------------------------------------------------------------------
Average Greenhouse Gas Emissions (g/mi)
----------------------------------------------------------------------------------------------------------------
Required........................................ 515 480 479 466
Achieved........................................ 512 481 480 467
----------------------------------------------------------------------------------------------------------------
Technology Penetration (%)
----------------------------------------------------------------------------------------------------------------
VVT and/or VVL.................................. 40 40 40 40
Cylinder Deac................................... 23 23 23 23
Direct Injection................................ 17 17 17 17
Turbocharging................................... 74 74 74 74
8-Speed AT...................................... 65 88 88 88
EPS, Accessories................................ 0 100 100 100
[[Page 73814]]
Stop-Start...................................... 0 0 0 0
Hybridization................................... 0 3 3 10
Aero. Improvements.............................. 0 100 100 100
----------------------------------------------------------------------------------------------------------------
Mass Reduction (vs. No-Action)
----------------------------------------------------------------------------------------------------------------
CW (lb.)........................................ 196 649 648 617
CW (%).......................................... 2.8 9.1 9.1 8.7
----------------------------------------------------------------------------------------------------------------
Technology Cost (vs. No-Action)
----------------------------------------------------------------------------------------------------------------
Average ($) \a\................................. 434 1,469 1,486 1,700
Total ($m, undiscounted) \b\.................... 48 163 164 188
----------------------------------------------------------------------------------------------------------------
Notes:
\a\ Values used in Methods A & B.
\b\ Values used in Method A, calculated at a 3% discount rate.
The fuel consumption and GHG standards require manufacturers to
achieve an average level of compliance, represented by a sales-weighted
average across the specific targets of all vehicles offered for sale in
a given model year, such that each manufacturer will have a unique
required consumption/emissions level determined by the composition of
its fleet, as illustrated above. However, there are more interesting
differences than the small differences in required fuel economy levels
among manufacturers. In particular, the average incremental technology
cost increases with the stringency of the alternative for each
manufacturer, but the size of the cost increase from one alternative to
the next varies among them, with General Motors showing considerably
larger increases in cost moving from Alternative 3 to Alternative 4,
than from either Alternative 2 to Alternative 3 or Alternative 4 to
Alternative 5. Ford is estimated to have more uniform cost increases
from each alternative to the next, in increasing stringency, though
still benefits from the reduced pace and longer period of increase
associated with Alternative 3 compared to Alternative 4.
The Method B simulation results show all three manufacturers facing
cost increases when the stringency of the standards move from 2.5
percent annual increases over the period from MY 2021-2027 to 3.5
percent annual increases from MY 2021-2025, but General Motors has the
largest at 75 percent more than the industry average price increase for
Alternative 4. GM also faces higher cost increases in Alternative 2
about 50 percent more than either Ford or Fiat Chrysler. And for the
most stringent alternative considered, EPA estimates that General
Motors will face average cost increases of more than $2,700, in
addition to the more than $700 increase in the baseline--approaching
nearly $3,500 per vehicle over today's prices.
Technology choices also differ by manufacturer, and some of those
decisions are directly responsible for the largest cost discrepancies.
For example, in this Method B analysis, GM is estimated to engage in
the least amount of mass reduction among the Big 3 after Phase 1, and
much less than Fiat Chrysler, but reduces average vehicle mass by over
300 lbs. in the baseline--suggesting that some of GM's easiest Phase 1
compliance opportunities can be found in lightweighting technologies.
Similarly, Fiat Chrysler is projected to apply less hybridization than
the others, and much less than General Motors, which is simulated in
Alternative 4 to have full hybrids (either integrated starter generator
or complete hybrid system) on all of its fleet by 2030, nearly 20
percent of which will be strong hybrids, and the strong hybrid share
decreases to about 18 percent in Alternative 5, as some lower level
technologies are applied more broadly. Because the analysis applies the
same technology inputs and the same logic for selecting among available
opportunities to apply technology, the unique situation of each
manufacturer determined which technology path is projected as the most
cost-effective.
In order to understand the differences in incremental technology
costs and fuel economy achievement across manufacturers in this market
segment, it is important to understand the differences in their
starting position relative to these standards. One important factor,
made more obvious in the following figures, is the difference between
the fuel economy and performance of the recently redesigned vans
offered by Fiat Chrysler and Ford (the Promaster and Transit,
respectively), and the more traditionally-styled vans that continue to
be offered by General Motors (the Express/Savannah). In MY 2014, Ford
began the phase-out of the Econoline van platform, moving those volumes
to the Euro-style Transit vans (discussed in more detail in Section
VI.D.2). The Transit platform represents a significant improvement over
the existing Econoline platform from the perspective of fuel economy,
and for the purpose of complying with the standards, the relationship
between the Transit's work factor and fuel economy is a more favorable
one than the Econoline vans it replaces. Since the redesign of van
offerings from both Fiat Chrysler and Ford occur in (or prior to) the
2014 model year, the costs, fuel consumption improvements, and
reductions of vehicle mass associated with those redesigns are included
in the analysis fleet, meaning they are not carried forward as part of
the compliance modeling exercise. By contrast, General Motors is
simulated to redesign their van offerings after 2014, such that there
is a greater potential for these vehicles to incur additional costs
attributable to new standards, unlike the costs associated with the
recent redesigns of their competitors. The inclusion of these new Ford
and Fiat Chrysler products in the analysis fleet is the primary driver
of the cost discrepancy between GM and its competitors in both the
baseline and Alternative 2 in this Method B analysis, when Ford and
Fiat Chrysler have to apply considerably less technology to achieve
compliance.
The remaining 5 percent of the 2b/3 market is attributed to two
manufacturers, Daimler and Nissan,
[[Page 73815]]
which, unlike the other manufacturers in this market segment, only
produce vans. The vans offered by both manufacturers currently utilize
two engines and two transmissions, although both Nissan engines are
gasoline engines and both Daimler engines are diesels. Despite the
logical grouping, these two manufacturers are projected to be impacted
much differently by these standards. For the least stringent
alternative considered, Daimler is projected to add no technology and
incurs no incremental cost in order to comply with the standards. At
stringency increases greater than or equal to 3.5 percent per year,
Daimler only really improves some of their transmissions and improves
the electrical accessories of its Sprinter vans. By contrast, Nissan's
starting position is much weaker and their compliance costs closer to
the industry average in Table VI-34. This difference could increase if
the analysis fleet supporting the final rule includes forthcoming
Nissan HD pickups.
Table VI-38--Summary of Impacts on Daimler by 2030 in the HD Pickup and Van Market Versus the Dynamic Baseline,
Alternative 1b
----------------------------------------------------------------------------------------------------------------
Alternative 2 3 4 5
----------------------------------------------------------------------------------------------------------------
Annual Stringency Increase...................... 2.0%/y 2.5%/y 3.5%/y 4.0%/y
Stringency Increase Through MY.................. 2025 2027 2025 2025
----------------------------------------------------------------------------------------------------------------
Average Fuel Economy (miles per gallon)
----------------------------------------------------------------------------------------------------------------
Required........................................ 23.36 25.19 25.25 25.91
Achieved........................................ 25.23 25.79 25.79 26.53
----------------------------------------------------------------------------------------------------------------
Average Fuel Consumption (gallons/100 mi.)
----------------------------------------------------------------------------------------------------------------
Required........................................ 4.28 3.97 3.96 3.86
Achieved........................................ 3.96 3.88 3.88 3.77
----------------------------------------------------------------------------------------------------------------
Average Greenhouse Gas Emissions (g/mi)
----------------------------------------------------------------------------------------------------------------
Required........................................ 436 404 404 393
Achieved........................................ 404 395 395 384
----------------------------------------------------------------------------------------------------------------
Technology Penetration (%)
----------------------------------------------------------------------------------------------------------------
VVT and/or VVL.................................. 0 0 0 0
Cylinder Deac................................... 0 0 0 0
Direct Injection................................ 0 0 0 0
Turbocharging................................... 44 44 44 44
8-Speed AT...................................... 0 44 44 100
EPS, Accessories................................ 0 0 0 0
Stop-Start...................................... 0 0 0 0
Hybridization................................... 0 0 0 0
Aero. Improvements.............................. 0 0 0 0
----------------------------------------------------------------------------------------------------------------
Mass Reduction (vs. No-Action)
----------------------------------------------------------------------------------------------------------------
CW (lb.)........................................ 0 0 0 0
CW (%).......................................... 0 0 0 0
----------------------------------------------------------------------------------------------------------------
Technology Cost (vs. No-Action)
----------------------------------------------------------------------------------------------------------------
Average ($) \a\................................. 0 165 165 374
Total ($m, undiscounted) \b\.................... 0 4 4 9
----------------------------------------------------------------------------------------------------------------
Notes:
\a\ Values used in Methods A & B.
\b\ Values used in Method A, calculated at a 3% discount rate.
Table VI-39--Summary of Impacts on Nissan by 2030 in the HD Pickup and Van Market Versus the Dynamic Baseline,
Alternative 1b
----------------------------------------------------------------------------------------------------------------
Alternative 2 3 4 5
----------------------------------------------------------------------------------------------------------------
Annual Stringency Increase...................... 2.0%/y 2.5%/y 3.5%/y 4.0%/y
Stringency Increase Through MY.................. 2025 2027 2025 2025
----------------------------------------------------------------------------------------------------------------
Average Fuel Economy (miles per gallon)
----------------------------------------------------------------------------------------------------------------
Required........................................ 19.64 21.19 20.92 21.46
Achieved........................................ 19.84 21.17 21.19 21.51
----------------------------------------------------------------------------------------------------------------
Average Fuel Consumption (gallons/100 mi.)
----------------------------------------------------------------------------------------------------------------
Required........................................ 5.09 44.72 4.78 4.66
[[Page 73816]]
Achieved........................................ 5.04 4.72 4.72 4.65
----------------------------------------------------------------------------------------------------------------
Average Greenhouse Gas Emissions (g/mi)
----------------------------------------------------------------------------------------------------------------
Required........................................ 452 419 425 414
Achieved........................................ 448 419 419 413
----------------------------------------------------------------------------------------------------------------
Technology Penetration (%)
----------------------------------------------------------------------------------------------------------------
VVT and/or VVL.................................. 100 100 100 100
Cylinder Deac................................... 49 49 49 49
Direct Injection................................ 51 51 51 100
Turbocharging................................... 51 51 51 50
8-Speed AT...................................... 0 51 51 51
EPS, Accessories................................ 0 100 100 100
Stop-Start...................................... 0 0 0 0
Hybridization................................... 0 0 0 28
Aero. Improvements.............................. 0 100 100 100
----------------------------------------------------------------------------------------------------------------
Mass Reduction (vs. No-Action)
----------------------------------------------------------------------------------------------------------------
CW (lb.)........................................ 0 0 307 303
CW (%).......................................... 0 0 5 4.9
----------------------------------------------------------------------------------------------------------------
Technology Cost (vs. No-Action)
----------------------------------------------------------------------------------------------------------------
Average ($) \a\................................. 378 1,150 1,347 1,935
Total ($m, undiscounted) \b\.................... 5 15.1 17.7 25.4
----------------------------------------------------------------------------------------------------------------
Notes:
\a\ Values used in Methods A & B.
\b\ Values used in Method A, calculated at a 3% discount rate.
As Table VI-38 and Table VI-39 show, Nissan is projected to apply
more technology than Daimler in the less stringent alternatives and
significantly more technology with increasing stringency. The Euro-
style Sprinter vans that comprise all of Daimler's model offerings in
this segment put Daimler in a favorable position. However, those vans
are already advanced--containing downsized diesel engines and advanced
aerodynamic profiles. Much like the Ford Transit vans, the recent
improvements to the Sprinter vans occurred outside the scope of the
compliance modeling so the costs of the improvements are not captured
in the analysis.
Although Daimler's required fuel economy level is much higher than
Nissan's (in miles per gallon), Nissan starts from a much weaker
position than Daimler and must incorporate additional engine,
transmission, platform-level technologies (e.g., mass reduction and
aerodynamic improvements) in order to achieve compliance. In fact, more
than 25 percent of Nissan's van offerings are projected to contain
integrated starter generators by 2030 in Alternative 5.
While the model does not allow sales volumes for any manufacturer
(or model) to vary across regulatory alternatives in the analysis, it
is conceivable that under the most stringent alternatives individual
manufacturers could lose market share to their competitors if the
prices of their new vehicles rise more than the industry average
without compensating fuel savings and/or changes to other features.
F. Compliance and Flexibility for HD Pickup and Van Standards
(1) Averaging, Banking, and Trading
The Phase 1 program established substantial flexibility in how
manufacturers can choose to implement EPA and NHTSA standards while
preserving the benefits for the environment and for energy consumption
and security. Primary among these flexibilities are the gradual phase-
in schedule, and the corporate fleet average approach which encompasses
averaging, banking and trading described below. See Section IV.A. of
the Phase 1 Preamble (76 FR 57238) for additional discussion of the
Phase 1 averaging, banking, and trading and Section IV.A (3) of the
Phase 1 Preamble (76 FR 57243) for a discussion of the credit
calculation methodology.
Manufacturers in this category typically offer gasoline and diesel
versions of HD pickup and van vehicle models. The agencies established
chassis-based Phase 1 standards that are equivalent in terms of
stringency for gasoline and diesel vehicles and are continuing this
same approach to stringency for Phase 2. In Phase 1, the agencies
established that HD pickups and vans are treated as one large averaging
set that includes both gasoline and diesel vehicles \527\ and the
agencies will maintain this averaging set approach for Phase 2, as
discussed above in Section VI.B.
---------------------------------------------------------------------------
\527\ See 40 CFR 1037.104(d) and the proposed 40 CFR 86.1819-
14(d). Credits may not be transferred or traded between this vehicle
averaging set and loose engines or other heavy-duty categories, as
discussed in Section I.
---------------------------------------------------------------------------
As explained in Section II.C.(3) of the Phase 1 Preamble (76 FR
57167), and in Section VI.B (3) above, the program is structured so
that final compliance is determined at the end of each model year, when
production for the model year is complete. At that point, each
manufacturer calculates production-weighted fleet average
CO2 emission and fuel consumption rates along with its
production-weighted fleet average standard. Under this approach, a
manufacturer's HD pickup and van fleet that achieves a fleet average
CO2 or fuel consumption level better than its
[[Page 73817]]
standard will be allowed to generate credits. Conversely, if the fleet
average CO2 or fuel consumption level does not meet its
standard, the fleet will 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 within the HD pickup and
van averaging set. These types of credit provisions also exist in the
light-duty 2012-2016 and 2017-2025 MY vehicle rules, 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. 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. Averaging vehicle credits with engine credits or between
vehicle weight classes is not allowed, as discussed in Section I. The
agencies did not propose and are not adopting any changes to any of
these provisions for the Phase 2 program.
While the agencies proposed to retain 5 year carry-forward of
credits for all HD sectors, the agencies requested comment on the
merits of a temporary credit carry-forward period of longer than 5
years for HD pickups and vans, allowing Phase 1 credits generated in
MYs 2014-2019 to be used through MY 2027. 80 FR 40388. The agencies
received several comments regarding credit carry-forward. AAPC
commented that manufacturers should be allowed to carry-forward credits
indefinitely until they are used to offset a deficit. AAPC commented
that longer credit life batter aligns with the longer redesign cycles
and the smaller production volumes for HD vehicles compared to light-
duty vehicles. AAPC also commented that longer credit life would
motivate earlier introduction of technology and lower compliance costs,
while not changing the overall effectiveness of the program. Nissan and
Daimler commented in support of a one-time credit carry-forward that
would allow Phase 1 credits to be used through MY 2027. The UAW also
generally supported extended credit carry-forward. The agencies also
received comments from CARB that the agencies should not allow Phase 1
credits to be carried forward into Phase 2. CARB commented that Phase 1
credits should be limited to a three year carry-forward or MY 2020
whichever is sooner. CARB is concerned that Phase 1 credits may reduce
the efficacy of the Phase 2 program and delay technology development
progress.
As noted above, the agencies are retaining the 5 year credit carry-
forward provisions as proposed for HD pickups and vans. As discussed in
Section VI.C., the agencies believe that the standards are feasible
without extending the credit carry-forward provisions. The agencies
continue to believe that credit carry-forward provides important
flexibility to manufacturer especially in transitioning to more
stringent standards and restricting the provision could be disruptive
to manufacturer product plans. However, the agencies understand CARB's
concerns regarding Phase 1 credits being used to postpone technology
progress if some manufacturers were to accumulate large credit banks
under Phase 1. Large banks of Phase 1 credits combined with unlimited
credit-forward could have the unintended effect of allowing some
manufacturers to delay the application of Phase 2 technologies. The 5
year credit carry-forward preserves needed flexibility for
transitioning to more stringent Phase 2 standards while also helping to
address concerns regarding delaying the introduction of technology in
Phase 2 for HD pickups and vans. As discussed in Section I.C.(1)(b)(i),
the agencies are extending credit life for certain vocational vehicle
subcategories during the transition to the Phase 2 standards. We are
doing this for two reasons. First, some manufacturers in these in
categories do not have diversified production, which limits the extent
to which they can use ABT. Second, the Phase 1 program offer little
opportunity for manufacturers to build up their credit balances.
Neither of these reasons apply for HD pickups and vans.
As discussed in Section VI.B.4., EPA and NHTSA are changing the HD
pickup and van useful life for GHG emissions and fuel consumption from
the current 11 years/120,000 miles to 15 years/150,000 miles to make
the useful life for GHG emissions consistent with the useful life of
criteria pollutants recently updated in the Tier 3 rule. As shown in
the Equation VI.1 credits calculation formula below, established by the
Phase 1 rule, useful life in miles is a multiplicative factor included
in the calculation of CO2 and fuel consumption credits. In
order to ensure banked credits maintain their value in the transition
from Phase 1 to Phase 2, NHTSA and EPA proposed and are finalizing an
adjustment factor of 1.25 (i.e., 150,000 / 120,000) for credits that
are carried forward from Phase 1 to the MY 2021 and later Phase 2
standards. Without this adjustment factor, the change in useful life
would effectively result in a discount of banked credits that are
carried forward from Phase 1 to Phase 2, which is not the intent of the
change in the useful life. Consider, for example, a vehicle
configuration with annual sales of 1,000 vehicles that was 10 g/mile
below the standard. Under Phase 1, those vehicles would generate 1,200
Mg of credit (10 x 1,000 x 120,000 / 1,000,000). Under Phase 2, the
same vehicles would generate 1,500 Mg of credit (10 x 1,000 x 150,000 /
1,000,000). The agencies do not believe that this adjustment results in
a loss of program benefits because there is little or no deterioration
anticipated for CO2 emissions and fuel consumption over the
life of the vehicles. Also, as described in the standards and
feasibility sections above, the carry-forward of credits is an integral
part of the program, helping to smoothing the transition to the new
Phase 2 standards. The agencies believe that effectively discounting
carry-forward credits from Phase 1 to Phase 2 is unnecessary and could
negatively impact the feasibility of the Phase 2 standards.
Equation VI.1 Total Model Year Credit (Debit) Calculation
CO2 Credits (Mg) = [(CO2 Std-CO2 Act)
x Volume x UL] / 1,000,000
Fuel Consumption Credits (gallons) = (FC Std-FC Act) x Volume x UL x
100
Where:
CO2 Std = Fleet average CO2 standard (g/mi)
FC Std = Fleet average fuel consumption standard (gal/100 mile)
CO2 Act = Fleet average actual CO2 value (g/
mi)
FC Act = Fleet average actual fuel consumption value (gal/100 mile)
Volume = the total production of vehicles in the regulatory category
UL = the useful life for the regulatory category (miles)
Manufacturers provided comments in support of applying the
adjustment factor discussed above. CARB recommended not including the
adjustment factor. CARB commented that the adjustment would take
benefits achieved under the Phase 1 program and allow them to be used
to reduce the potential benefits of Phase 2 standards. The agencies do
not view the 1.25 adjustment as reducing the benefits of the program
because the adjustment to the Phase 1 credits is completely offset by
the increase in the useful life used in the Phase 2 credits calculation
shown above. In other words, when the Phase 1 credits are used in Phase
2, 1.25 times more credits will be needed to cover a deficit than would
be needed under
[[Page 73818]]
Phase 1. The agencies continue to believe this is a reasonable and
indeed, necessary, way to address the change in useful life as it
applies to the credits calculations.
(2) Advanced Technology Credits
The Phase 1 program included on an interim basis advanced
technology credits for MYs 2014 and later in the form of a multiplier
of 1.5 for the following technologies:
Hybrid powertrain designs that include energy storage systems
Waste heat recovery
All-electric vehicles
Fuel cell vehicles
The advanced technology credit program is intended to encourage early
development of technologies that are not yet commercially available.
This multiplier approach means that each advanced technology vehicle
will count as 1.5 vehicles in a manufacturer's compliance
calculation.\528\ The advanced technology multipliers were included on
an interim basis in the Phase 1 program and the incentive multipliers
included for Phase 1and the 1.5 multiplier incentive adopted for Phase
1 will end beginning in MY 2021, when the more stringent Phase 2
standards are to begin phase-in. However, the agencies are including
new incentive multipliers for Phase 2 for PHEVs, EVs, and fuel cell
vehicles.
---------------------------------------------------------------------------
\528\ EPA and NHTSA similarly included temporary advanced
technology multipliers in the light-duty 2017-2025 program,
believing it was worthwhile to forego modest additional emissions
reductions and fuel consumption improvements in the near-term in
order to lay the foundation for the potential for much larger
``game-changing'' GHG and oil consumption reductions in the longer
term. The incentives in the light-duty vehicle program are available
through the 2021 model year. See 77 FR 62811, October 15, 2012.
---------------------------------------------------------------------------
As discussed in Section I, the agencies requested comment on
whether or not the incentive multiplier credits should be extended to
later model years for more advanced technologies such as EVs and fuel
cell vehicles. These technologies are not projected to be part of the
technology path used by manufacturers to meet the Phase 2 standards for
HD pickups and vans. EV and fuel cell technologies will presumably need
to overcome the highest hurdles to commercialization for HD pickups and
vans in the time frame of the final rules, and also have the potential
to provide the highest level of benefit. The agencies received several
comments encouraging the agencies to continue advanced technology
multipliers in Phase 2 for heavy-duty vehicles. After considering these
comments, and considering that EV and fuel technologies have the
potential for more significant emission reductions and fuel consumption
savings than any of the technologies projected to be used for Phase 2
compliance, the agencies are adopting new incentive multipliers for
Phase 2 for these technologies for all heavy-duty vehicle sectors. A
detailed discussion of these provisions is provided above in Section I.
NHTSA and EPA established that for Phase 1, EVs and other zero
tailpipe emission vehicles be factored into the fleet average GHG and
fuel consumption calculations based on the diesel standards targets for
their model year and work factor. The agencies also established for
electric and zero emission vehicles that in the credits equation the
actual emissions and fuel consumption performance be set to zero (i.e.,
that emissions be considered on a tailpipe basis exclusively) rather
than including upstream emissions or energy consumption associated with
electricity generation. As we look to the future, we are not projecting
the adoption of electric HD pickups and vans into the heavy duty
market; therefore, we believe that this provision is still appropriate.
Unlike the MY 2012-2016 light-duty rule, which adopted a cap whereby
upstream emissions will be counted after a certain volume of sales (see
75 FR 25434-25436), we believe there is no need to a cap for HD pickups
and vans because of the infrequent projected use of EV technologies in
the Phase 2 timeframe. In Phase 2, we thus continue to deem electric
vehicles as having zero CO2, CH4, and
N2O emissions as well as zero fuel consumption. See Section
I for a discussion of the treatment of lifecycle emissions for
alternative fuel vehicles, including comments regarding the treatment
of upstream emissions, and Section XI for the treatment of lifecycle
emissions for natural gas specifically.
(3) Off-Cycle Technology Credits
The Phase 1 program established an opportunity for manufacturers to
generate credits by applying innovative technologies whose
CO2 and fuel consumption benefits are not captured on the 2-
cycle test procedure (i.e., off-cycle).\529\ For HD pickups and vans,
the approach for off-cycle technologies established in Phase 1 is
similar to that established for light-duty vehicles due to the use of
the same basic chassis test procedures. The agencies are retaining this
approach for Phase 2 as proposed. See 80 FR 40389. To generate credits,
manufacturers are required to submit data and a methodology for
determining the level of credits for the off-cycle technology subject
to EPA and NHTSA review and approval. The application for off-cycle
technology credits is also subject to a public evaluation process and
comment period. EPA and NHTSA would approve the methodology and credits
only if certain criteria were met. Baseline emissions and fuel
consumption \530\ and control emissions and fuel consumption need to be
clearly demonstrated over a wide range of real world driving conditions
and over a sufficient number of vehicles to address issues of
uncertainty with the data. Data must be on a vehicle model-specific
basis unless a manufacturer demonstrated model-specific data were not
necessary. Once a complete application is submitted by the
manufacturer, the regulations require that the agencies publish a
notice of availability in the Federal Register notifying the public of
a manufacturer's off-cycle credit calculation methodology and provide
opportunity for comment.
---------------------------------------------------------------------------
\529\ See 76 FR 57251, September 15, 2011, 40 CFR
1037.104(d)(13), and 40 CFR 86.1819-14(d)(13). Note that for the
vocational vehicle and tractor standards, and off-cycle credit is to
evaluate technologies whose benefit is not recognized by GEM (rather
than the two-cycle test). See V.D.3 and III.F.3, respectively.
\530\ Fuel consumption is derived from measured CO2
emissions using conversion factors of 8,887 g CO2/gallon
for gasoline and 10,180 g CO2/gallon for diesel fuel.
---------------------------------------------------------------------------
EPA and NHTSA requested comment on establishing a pre-defined
technology menu list for HD pickups and vans similar to the approach
adopted for light-duty vehicles in the MY 2017-2025 rule.\531\ As with
the light-duty vehicle program, the agencies noted that a pre-defined
list could simplify the process for generating off-cycle credits and
may further encourage the introduction of these technologies. However,
the agencies also noted that appropriate default level of credits for
the heavier vehicles would need to be established. The agencies
requested comments with supporting HD pickup and van specific data and
analysis that would provide a substantive basis for appropriate credits
levels for the HD pickup and van category. The data and analysis would
need to demonstrate that the pre-defined credit level represents real-
world emissions reductions and fuel consumption improvements not
captured by the 2-cycle test procedures.
---------------------------------------------------------------------------
\531\ 77 FR 62832-62839, October 15, 2012.
---------------------------------------------------------------------------
The agencies received comments recommending off-cycle credits for
over a dozen technologies. There are three primary reasons that the
agencies are not adopting credits for the individual technologies
recommended by commenters. In many cases, the analysis provided by
commenters did not
[[Page 73819]]
include sufficient real-world heavy-duty vehicle data on which to base
the menu credit value recommended by the commenter. Thus, in several
cases, the analysis provided by commenters was based on light-duty
vehicle data or on simulations with little detail provided, which
analysis is not directly applicable to heavy duty pickups and vans for
purposes of technology performance quantification. Second, in several
cases, the technologies recommended for off-cycle credits for pickups
and vans provide significant on-cycle benefit. Such technologies are
considered to be adequately captured by the test procedures (within the
meaning of section 86.1819-14(d)(13)) \532\ and are not considered to
be eligible for off-cycle credits. Examples of adequately captured
technologies that commenters recommended for off-cycle credits include
cylinder deactivation and cooled EGR. Moreover, these are technologies
the agencies expect to be in the mix of technologies used to meet the
standards (and are projected to be used in the respective analyses of
compliance paths on which the stringency of the final standards are
predicated). EPA has already indicated that off-cycle credits are not
available for technologies that form part of the technology basis for
the greenhouse gas standards because these technologies' benefits would
already be reflected in the standard's stringencies (and costs). 77 FR
62835 (Oct. 12, 2012). Indeed, it is because of these technologies'
robust performance in two-cycle space that the agencies have projected
their use as part of the compliance path on which standard stringency
is predicated. Likewise, many of these technologies are inherent to
vehicle design and so are similarly ineligible. Id. at 62732, 62836.
Finally, a few other recommended technologies are considered safety-
related technologies not eligible for credits because they could
reasonably be expected to fall under vehicle safety standards in the
future and so would be adopted in any case. Granting off-cycle credits
for these technologies consequently would amount to an unwarranted
windfall. Adaptive cruise control and forward collision warning systems
are examples of these technologies. Chapter 7 of the Response to
Comments for this final rule provides a detailed response to these
comments
---------------------------------------------------------------------------
\532\ This provision states that an off-cycle credit must be for
a technology that is ``not adequately captured on the Federal Test
procedure (FTP) and/or the highway Fuel Economy Test (HFET).'' EPA
has indicated that this requires manufacturers to demonstrate ``an
incremental off-cycle benefit that is significantly greater than the
2-cycle benefit.'' 77 FR 62836 (Oct. 12, 2012).
---------------------------------------------------------------------------
(4) Demonstrating Compliance for Heavy-Duty Pickup Trucks and Vans
The Phase 1 rule established a comprehensive compliance program for
HD pickups and vans that NHTSA and EPA are generally retaining for
Phase 2. The compliance provisions cover details regarding the
implementation of the fleet average standards including vehicle
certification, demonstrating compliance at the end of the model year,
in-use standards and testing, carryover of certification test data, and
reporting requirements. Please see Section V.B.(1) of the Phase 1 rule
Preamble (76 FR 57256-57263) for a detailed discussion of these
provisions.
The Phase 1 rule contains special provisions regarding loose
engines and optional chassis certification of certain vocational
vehicles over 14,000 lbs. GVWR. As proposed, the agencies are extending
the optional chassis certification provisions to Phase 2 and are
providing a temporary loose engine provision for Phase 2 as described
in Section V.D.3.e, under Compliance Flexibility Provisions. See the
vocational vehicle Section V.D. and XIII.A.2 for a detailed discussion
of the rule for optional chassis certification and Section II.D. for
the discussion of loose engines.
VII. Aggregate GHG, Fuel Consumption, and Climate Impacts
Given that the purpose of setting these Phase 2 standards is to
reduce fuel consumption and greenhouse gas (GHG) emissions from heavy-
duty vehicles, it is necessary for the agencies to analyze the extent
to which these standards will accomplish that purpose. This section
describes the agencies' methodologies for projecting the reductions in
greenhouse gas (GHG) emissions and fuel consumption and the
methodologies the agencies used to quantify the impacts associated with
these standards. In addition, EPA's analyses of the projected change in
atmospheric carbon dioxide (CO2) concentration and
consequent climate change impacts are discussed. Because of NHTSA's
obligations under EPCA/EISA and NEPA, NHTSA further analyzes the
projected environmental impacts related to fuel consumption, GHG
emissions, and climate change, for each regulatory alternative.
Detailed documentation of this analysis is provided in Chapters 3, 4
and 5 of NHTSA's FEIS accompanying today's notice.
A. What methodologies did the Agencies use to project GHG emissions and
fuel consumption impacts?
Different tools exist for estimating potential fuel consumption and
GHG emissions impacts associated with fuel efficiency and GHG emission
standards. One such tool is EPA's official mobile source emissions
inventory model named Motor Vehicle Emissions Simulator (MOVES).\533\
The agencies used a revised version of MOVES2014a to quantify the
impacts of these standards for vocational vehicles and combination
tractor-trailers on GHG emissions and fuel consumption.
---------------------------------------------------------------------------
\533\ MOVES homepage: https://www3.epa.gov/otaq/models/moves/index.htm (last accessed May 27, 2016).
---------------------------------------------------------------------------
Since the notice of proposed rulemaking, EPA has made certain
updates to MOVES in response to the public comments on the proposal:
(1) The projections of vehicle sales, populations, and activity in the
version used for the final rulemaking were updated to incorporate the
latest projections from the U.S. Department of Energy's Annual Energy
Outlook 2015 report; \534\ (2) the extended idle and APU emission rates
in MOVES were updated based on the analyses of latest test programs
that reflect the current prevalence of clean idle certified engines;
and (3) the baseline adoption rates of idle reduction technology were
reassessed and projected to be lower than what was assumed in the
proposal, as described in Section III.D.1.a of the Preamble. In
addition, changes to APU emissions rates for PM2.5 were
implemented in MOVES reflecting the fact that EPA is adopting
requirements to control PM2.5 emissions from APUs installed
in new tractors, as discussed in Section III.C.3 of the Preamble.
Finally, methodological improvements were made in classifying vehicle
types and in forecasting vehicle populations and activity. The
aforementioned updates above, along with other changes, are documented
in the memorandum to the docket.\535\
---------------------------------------------------------------------------
\534\ Annual Energy Outlook 2015. http://www.eia.gov/forecasts/archive/aeo15/ (last accessed May 27, 2016).
\535\ U.S. EPA. Updates to MOVES for Emissions Analysis of
Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium-
and Heavy-Duty Engines and Vehicles--Phase 2 FRM. Docket No. EPA-HQ-
OAR-2016. July 2016.
---------------------------------------------------------------------------
MOVES was run with user input databases, described in more detail
below, that reflected the projected technological improvements
resulting from the final rules, such as the improvements in engine and
vehicle efficiency, aerodynamic drag, and tire rolling resistance. The
changes made to
[[Page 73820]]
the default MOVES database are described below in Section VII.B.(3).
All the input data, MOVES run spec files, and the scripts used for the
analysis, as well as the version of MOVES used to generate the
emissions inventories, can be found in the docket.\536\
---------------------------------------------------------------------------
\536\ Memorandum to the Docket ``Runspecs, Model Inputs, MOVES
Code and Database for HD GHG Phase 2 FRM Emissions Modeling'' Docket
No. EPA-HQ-OAR-2016. July 2016.
---------------------------------------------------------------------------
Another such tool is DOT's CAFE model, which estimates how
manufacturers could potentially apply technology improvements in
response to new standards, and then calculates, among other things,
resultant changes in national fuel consumption and GHG emissions. As
described in Section VI, two versions of this model were used for
analysis of potential new standards for HD pickups and vans. Both
versions use the work-based attribute metric of ``work factor''
established in the Phase 1 rule for heavy-duty pickups and vans instead
of the light-duty ``footprint'' attribute metric. The CAFE model takes
user-specified inputs on, among other things, vehicles that are
projected to be produced in a given model year, technologies available
to improve fuel efficiency on those vehicles, potential regulatory
standards that will drive improvements in fuel efficiency, and economic
assumptions. The CAFE model takes every vehicle in each manufacturer's
fleet and decides what technologies to add to those vehicles in order
to allow each manufacturer to comply with the standards in the most
cost-effective way. Based on those results, the CAFE model then
calculates total fuel consumption and GHG emissions impacts based on
those inputs, along with economic costs and benefits. The DOT's CAFE
model is further described in detail in Section VI of the Preamble and
Chapter 10 of the RIA.
For these rules, the agencies used two analytical methods for the
heavy-duty pickup and van segment employing both DOT's CAFE model and
EPA's MOVES model. The agencies used EPA's MOVES model to estimate fuel
consumption and emissions impacts for tractor-trailers (including the
engine that powers the tractor) and vocational vehicles (including the
engine that powers the vehicle).
For heavy-duty pickups and vans, the agencies performed separate
analyses, which we refer to as ``Method A'' and ``Method B.'' In Method
A, a modified version of the CAFE model was used to project a pathway
the industry could use to comply with each regulatory alternative and
the estimated effects on fuel consumption, emissions, benefits and
costs. In Method B, the MOVES model was used to estimate fuel
consumption and emissions from these vehicles. NHTSA considered Method
A as its central analysis. EPA considered the results of Method B as
its central analysis. The agencies concluded that these methods led the
agencies to the same conclusions and the same selection of the final
standards. See Chapter 5 of the RIA for additional discussions of these
two methods.
For both methods, the agencies analyzed the impact of the final
rules, relative to two different reference cases--``flat'' (Alternative
1a) and ``dynamic'' (Alternative 1b). The flat baseline projects very
little improvement in new vehicles in the absence of new Phase 2
standards. In contrast, the dynamic baseline projects more improvements
in vehicle fuel efficiency in the absence of new Phase 2 standards. The
agencies considered both reference cases (for additional details, see
Chapter 11 of the RIA). The results for all of the regulatory
alternatives relative to both reference cases, derived via the same
methodologies discussed in this section, are presented in Section X of
the Preamble.
For brevity, a subset of these analyses are presented in this
section, and the reader is referred to both Chapter 11 of the RIA and
NHTSA's FEIS Chapters 3, 4 and 5 for complete sets of these analyses.
In this section, Method A is presented for the final standards (i.e.,
Alternative 3--the agencies' preferred alternative), relative to both
the dynamic baseline (Alternative 1b) and the flat baseline
(Alternative 1a). Method B is presented for the final standards,
relative only to the flat baseline.
Because reducing fuel consumption also affects emissions that occur
as a result of fuel production and distribution (including renewable
fuels), the agencies also calculated those ``upstream'' changes using
the ``downstream'' fuel consumption reductions predicted by the CAFE
model (in ``Method A'') and the MOVES model (in ``Method B''). As
described in Section VI, Method A uses the CAFE model to estimate
vehicular fuel consumption and emissions impacts only for HD pickups
and vans and to calculate upstream impacts. For vocational vehicles and
combination tractor-trailers, both Method A and Method B use the same
upstream tools originally created for the Renewable Fuel Standard 2
(RFS2) rulemaking analysis,\537\ used in the LD GHG rulemakings,\538\
HD GHG Phase 1,\539\ and updated for the current analysis. The estimate
of emissions associated with production and distribution of gasoline
and diesel from crude oil is based on emission factors in the
``Greenhouse Gases, Regulated Emissions, and Energy Use in
Transportation'' model (GREET) developed by DOE's Argonne National Lab.
In some cases, the GREET values were modified or updated by the
agencies to be consistent with the National Emission Inventory (NEI)
and emission factors from MOVES. Method B uses the same tool described
above to estimate the upstream impacts for HD pickups and vans. For
additional details, see Chapter 5 of the RIA. The upstream tool used
for the Method B can be found in the docket.\540\ As noted in Section
VI above, these analyses corroborate each other's results.
---------------------------------------------------------------------------
\537\ U.S. EPA. Draft Regulatory Impact Analysis: Changes to
Renewable Fuel Standard Program. Chapters 2 and 3. May 26, 2009.
Docket ID: EPA-HQ-OAR-2009-0472-0119.
\538\ 2017 and Later Model Year Light-Duty Vehicle Greenhouse
Gas Emissions and Corporate Average Fuel Economy Standards (77 FR
62623, October 15, 2012).
\539\ Greenhouse Gas Emission Standards and Fuel Efficiency
Standards for Medium- and Heavy-Duty Engines and Vehicles (76 FR
57106, September 15, 2011).
\540\ Memorandum to the Docket ``Upstream Emissions Modeling
Files for HDGHG Phase 2 FRM'' Docket No. EPA-HQ-OAR-2016. July 2016.
---------------------------------------------------------------------------
The agencies analyzed the anticipated emissions impacts of the
final rules on carbon dioxide (CO2), methane
(CH4), nitrous oxide (N2O), and
hydrofluorocarbons (HFCs) for a number of calendar years (for purposes
of the discussion in these final rules, only 2025, 2040 and 2050 will
be shown) by comparing to both reference cases.\541\ Additional runs
were performed for just three of the greenhouse gases (CO2,
CH4, and N2O) and for fuel consumption for every
calendar year from 2016 to 2050, inclusive, which fed the economy-wide
modeling, monetized greenhouse gas benefits estimation, and climate
impacts analyses, discussed in sections below.\542\
---------------------------------------------------------------------------
\541\ The emissions impacts of the final rules on non-GHGs,
including air toxics, were also estimated using MOVES. See Section
VIII of the Preamble for more information.
\542\ The CAFE model estimates, among other things,
manufacturers' potential multiyear planning decisions within the
context of an estimated year-by-year product cadence (i.e., schedule
for redesigning and freshening vehicles). The model was allowed to
deploy technology in earlier model years in the analysis in order to
account for the potential that manufacturers might take anticipatory
actions in model years preceding those covered by today's rules.
---------------------------------------------------------------------------
[[Page 73821]]
B. Analysis of Fuel Consumption and GHG Emissions Impacts Resulting
From Final Standards
The following sections describe the model inputs and assumptions
for both the flat and dynamic reference cases and the control case
representing the agencies' final fuel efficiency and GHG standards. The
details of all the MOVES runs and input data tables, as well as the
MOVES code and database, can be found in the docket.\543\ See Section
VI.C for the discussion of the model inputs and assumptions for the
analysis of the HD pickups and vans using DOT's CAFE Model.
---------------------------------------------------------------------------
\543\ Memorandum to the Docket ``Runspecs, Model Inputs, MOVES
Code and Database for HD GHG Phase 2 FRM Emissions Modeling'' Docket
No. EPA-HQ-OAR-2016. July 2016.
---------------------------------------------------------------------------
(1) Model Inputs and Assumptions for the Flat Reference Case
The flat reference case (identified as Alternative 1a in Section
X), includes the impact of Phase 1, but assumes that fuel efficiency
and GHG emission standards are not improved beyond the required 2018
model year levels. Alternative 1a functions as one of the baselines
against which the impacts of the final standards can be evaluated. The
MOVES2014a default road load parameters and energy rates were used for
the vocational vehicles and HD pickups and vans for this alternative
because we assumed no market-driven improvements in fuel efficiency.
The tractor-trailer road load parameters were changed from the
MOVES2014a default values to account for projected improvements in the
efficiency of the box trailers pulled by combination tractors due to
increased penetration of aerodynamic technologies and low rolling
resistance tires attributed to both EPA's SmartWay Transport
Partnership and California Air Resources Board's Tractor-Trailer
Greenhouse Gas regulation, as described in Section IV of the Preamble.
We maintained the same road load inputs for tractor-trailers for 2018
and beyond. The flat reference case assumed the growth in vehicle
populations and miles traveled based on the relative annual VMT growth
from AEO2015 Final Release for model years 2014 and later.\544\
---------------------------------------------------------------------------
\544\ Annual Energy Outlook 2015. http://www.eia.gov/forecasts/archive/aeo15/ (last accessed May 27, 2016).
---------------------------------------------------------------------------
(2) Model Inputs and Assumptions for the Dynamic Reference Case
The dynamic reference case (identified as Alternative 1b in Section
X) also includes the impact of Phase 1 and generally assumes that fuel
efficiency and GHG emission standards are not improved beyond the
required 2018 model year levels. However, for this case, the agencies
assume market forces will lead to additional fuel efficiency
improvements for HD pickups and vans and tractor-trailers. These
additional assumed improvements are described in Section X of the
Preamble. No additional fuel efficiency improvements due to market
forces were assumed for vocational vehicles. For HD pickups and vans,
the agencies applied the CAFE model using the input assumption that
manufacturers having achieved compliance with Phase 1 standards will
continue to apply technologies for which increased purchase costs will
be ``paid back'' through corresponding fuel savings within the first
six months of vehicle operation. The agencies conducted the MOVES
analysis of this case in the same manner as for the flat reference
case.
(3) Model Inputs and Assumptions for ``Control'' Case
(a) Vocational Vehicles and Tractor-Trailers
The ``control'' case represents the agencies' final fuel efficiency
and GHG standards. The agencies developed additional user input data
for MOVES runs to estimate the control case inventories. The inputs to
MOVES for the control case account for improvements of engine and
vehicle efficiency in vocational vehicles and combination tractor-
trailers. The agencies used the percent reduction in aerodynamic drag
and tire rolling resistance coefficients and absolute changes in
average total running weight (gross combined weight) expected from the
final rules to develop the road load inputs for the control case, based
on the GEM analysis. The agencies developed energy inputs for the
control case runs using the percent reduction in CO2
emissions expected from the powertrain and other vehicle technologies
not accounted for in the aerodynamic drag and tire rolling resistance
in the final rules.
Table VII-1 and Table VII-2 describe the improvements in engine and
vehicle efficiency from the final rules for each affected model year
for vocational vehicles and combination tractor-trailers that were
input into MOVES for estimating the control case emissions inventories.
Additional details regarding the MOVES inputs are included in Chapter 5
of the RIA.
---------------------------------------------------------------------------
\545\ Vocational vehicles modeled in MOVES include heavy heavy-
duty, medium heavy-duty, and light heavy-duty vehicles. However, for
light heavy-duty vocational vehicles, class 2b and 3 vehicles are
not included in the inventories for the vocational sector. Instead,
all vocational vehicles with GVWR of less than 14,000 lbs. were
modeled using the energy rate reductions described below for HD
pickup trucks and vans. In practice, many manufacturers of these
vehicles choose to average the lightest vocational vehicles into
chassis-certified families (i.e., heavy-duty pickups and vans).
Table VII-1--Estimated Reductions in Energy Rates for the Final Standards
----------------------------------------------------------------------------------------------------------------
Reduction from
Vehicle type Fuel Model years flat baseline
(%)
----------------------------------------------------------------------------------------------------------------
Long-haul Tractor-Trailers and HHD Vocational. Diesel.......................... 2018-2020 1.0
2021-2023 7.9
2024-2026 12.4
2027+ 16.3
Short-haul Tractor-Trailers and HHD Vocational Diesel.......................... 2018-2020 0.6
2021-2023 7.4
2024-2026 11.9
2027+ 15.0
Single-Frame Vocational \545\................. Diesel.......................... 2021-2023 7.8
2024-2026 12.3
2027+ 16.0
[[Page 73822]]
Gasoline........................ 2021-2023 6.9
2024-2026 9.8
2027+ 13.3
Urban Bus..................................... Diesel and CNG.................. 2021-2023 7.0
2024-2026 11.8
2027+ 14.4
----------------------------------------------------------------------------------------------------------------
Table VII-2--Estimated Reductions in Road Load Factors for the Final Standards
----------------------------------------------------------------------------------------------------------------
Reduction in Reduction in
tire rolling aerodynamic Weight
Vehicle type Model years resistance drag reduction
coefficient coefficient (lb) \a\
(%) (%)
----------------------------------------------------------------------------------------------------------------
Combination Long-haul Tractor-Trailers 2018-2020............... 6.1 5.6 -140
2021-2023............... 13.3 12.5 -199
2024-2026............... 16.3 19.3 -294
2027+................... 18.0 28.2 -360
Combination Short-haul Tractor- 2018-2020............... 5.2 0.9 -23
Trailers.\546\ 2021-2023............... 11.9 4.0 -43
2024-2026............... 14.1 6.2 -43
2027+................... 15.9 8.8 -43
Intercity Buses....................... 2021-2023............... 18.2 0 0
2024-2026............... 20.8 0 0
2027+................... 24.7 0 0
Transit Buses......................... 2021-2023............... 0 0 0
2024-2026............... 0 0 0
2027+................... 12.1 0 0
School Buses.......................... 2021-2023............... 10.1 0 0
2024-2026............... 14.9 0 0
2027+................... 19.7 0 0
Refuse Trucks......................... 2021-2023............... 0 0 0
2024-2026............... 0 0 0
2027+................... 12.1 0 0
Single Unit Short-haul Trucks......... 2021-2023............... 6.4 0 4.4
2024-2026............... 6.4 0 10.4
2027+................... 10.2 0 16.5
Single Unit Long-haul Trucks.......... 2021-2023............... 8.4 0 7.9
2024-2026............... 13.3 0 23.6
2027+................... 13.3 0 39.4
Motor Homes........................... 2021-2023............... 20.8 0 0
2024-2026............... 20.8 0 0
2027+................... 24.7 0 0
----------------------------------------------------------------------------------------------------------------
Note:
\a\ Negative weight reductions reflect an expected weight increase as a byproduct of other vehicle and engine
improvements as described in Chapter 5 of the RIA.
In addition, the CO2 standard for tractors, reflecting
the use of idle reduction technologies such as diesel-powered auxiliary
power units (APUs) and battery-powered APUs, as discussed in Section
III.D of the Preamble, was included in the modeling for the long-haul
combination tractor-trailers, as shown below in Table VII-3.
---------------------------------------------------------------------------
\546\ Vocational tractors are included in the short-haul tractor
segment.
Table VII-3--Assumed APU Use During Extended Idling for Combination Long-Haul Tractor-Trailers a
----------------------------------------------------------------------------------------------------------------
Diesel APU Battery APU
Vehicle type Model year Penetration Penetration
(%) (%)
----------------------------------------------------------------------------------------------------------------
Combination Long-Haul Trucks.................................... 2010-2020 9 0
2021-2023 30 10
2024-2026 40 10
2027+ 40 15
----------------------------------------------------------------------------------------------------------------
Note:
[[Page 73823]]
\a\ Other idle reduction technologies (such as automatic engine shutdown, fuel operated heaters, and stop-start
systems) were modeled as part of the energy rates.
To account for the potential increase in vehicle use expected to
result from improvements in fuel efficiency for vocational vehicles and
combination tractor-trailers due to the final rules (also known as the
``rebound effect'' and described in more detail in Section IX.E of the
Preamble), the control case assumed an increase in VMT from the
reference levels by 0.30 percent for the vocational vehicles and 0.75
percent for the combination tractor-trailers.\547\
---------------------------------------------------------------------------
\547\ Memorandum to the Docket ``VMT Rebound Inputs to MOVES for
HDGHG2 Phase 2 FRM'' Docket No. EPA-HQ-OAR-2016. July 2016.
---------------------------------------------------------------------------
(b) Heavy-Duty Pickups and Vans
As explained above and as also discussed in the RIA, the agencies
used both DOT's CAFE model and EPA's MOVES model, for Method A and B,
respectively, to project fuel consumption and GHG emissions impacts
resulting from these standards for HD pickups and vans, including
downstream vehicular emissions as well as emissions from upstream
processes related to fuel production, distribution, and delivery.
(i) Method A for HD Pickups and Vans
For Method A, the agencies used the CAFE model which applies fuel
properties (density and carbon content) to estimated fuel consumption
in order to calculate vehicular CO2 emissions, applies per-
mile emission factors from MOVES to estimated VMT (for each regulatory
alternative, adjusted to account for the rebound effect) in order to
calculate vehicular CH4 and N2O emissions (as
well, as discussed below, of non-GHG pollutants), and applies per-
gallon upstream emission factors from GREET in order to calculate
upstream GHG (and non-GHG) emissions.
As discussed above in Section VI, the standards for HD pickups and
vans increase in stringency by 2.5 percent annually during model years
2021-2027. The standards define targets specific to each vehicle model,
but no individual vehicle is required to meet its target; instead, the
production-weighted averages of the vehicle-specific targets define
average fuel consumption and CO2 emission rates that a given
manufacturer's overall fleet of produced vehicles is required to
achieve as a whole. The standards are specified separately for gasoline
and diesel vehicles, and vary with work factor. Both the NPRM and
today's analysis assume that some application of mass reduction could
enable increased work factor in cases where manufacturers increase a
vehicle's rated payload and/or towing capacity without a change to GVWR
and GCWR, but there are other ways manufacturers may change work factor
which the analysis does not capture. Average required levels will
depend on the future mix of vehicles and the work factors of the
vehicles produced for sale in the U.S. Since these can only be
estimated at this time, average required and achieved fuel consumption
and CO2 emission rates are subject to uncertainty. Between
the NPRM and the issuance of today's final rules, the agencies updated
the market forecast (and other inputs) used to analyze HD pickup and
van standards, and doing so leads to different estimates of required
and achieved fuel consumption and CO2 emission rates (as
well as different estimates of impacts, costs, and benefits).
The following four tables present stringency increases and
estimated required and achieved fuel consumption and CO2
emission rates for the two No Action Alternatives (Alternative 1a and
1b) and the standards defining the final program. Stringency increases
are shown relative to standards applicable in model year 2018 (and
through model year 2020). As mathematical functions, the standards
themselves are not subject to uncertainty. By 2027, they are 16.2
percent more stringent (i.e., lower) than those applicable during 2018-
2020. NHTSA estimates that, by model 2027, these standards could reduce
average required fuel consumption and CO2 emission rates to
about 4.88 gallons/100 miles and about 4 grams/mile, respectively.
NHTSA further estimates that average achieved fuel consumption and
CO2 emission rates could correspondingly be reduced to about
the same levels. If, as represented by Alternative 1b, manufacturers
will, even absent today's standards, voluntarily make improvements that
pay back within six months, these model year 2027 levels are about 12
percent lower than the agencies estimate could be achieved under the
Phase 1 standards defining the No Action Alternative. If, as
represented by Alternative 1a, manufacturers will, absent today's
standards, only apply technology as required to achieve compliance,
these model year 2027 levels are about 13 percent lower than the
agencies estimate could be achieved under the Phase 1 standards. As
indicated below, the agencies estimate that these improvements in fuel
consumption and CO2 emission rates will build from model
year to model year, beginning as soon as model year 2017 (insofar as
manufacturers may make anticipatory improvements if warranted given
planned product cadence).
The NPRM analysis suggested that both the achieved and required
fuel consumption and CO2 reductions would be larger than the
current analysis suggests. The NPRM suggested that achieved reductions
would be 13.5 and 15 percent, for the dynamic and flat baselines,
respectively. The erosion of the standards and fuel consumption
reductions can be attributed to the increased work factor of the 2015
fleet relative to the 2014 fleet. Section 6 discusses in more detail
the changes in the distribution of work factor for key market players
from the MY 2014 to the MY 2015 fleet.
[[Page 73824]]
Table VII-4--Stringency of HD Pickup and Van Standards, Estimated Average Required and Achieved Fuel Consumption Rates for Method A, Relative to
Alternative 1b \a\
--------------------------------------------------------------------------------------------------------------------------------------------------------
Ave. required fuel cons. (gal./100 Ave. achieved fuel cons. (gal./100
mi.) mi.)
Model year Stringency (vs. 2018) -----------------------------------------------------------------------------
Reduction Reduction
No action Final (%) No action Final (%)
--------------------------------------------------------------------------------------------------------------------------------------------------------
2016.................................... MYs 2016-2020 Subject to Phase 1 6.32 6.32 0.0 6.14 6.14 0.0
2017.................................... Standards. 6.16 6.16 0.0 6.02 5.89 2.2
2018.................................... 5.83 5.83 0.0 5.97 5.78 3.2
2019.................................... 5.81 5.81 0.0 5.77 5.47 5.3
2020.................................... 5.80 5.80 0.0 5.75 5.46 5.1
2021.................................... 2.5............................. 5.79 5.65 2.4 5.68 5.28 7.2
2022.................................... 4.9............................. 5.80 5.52 4.8 5.64 5.22 7.5
2023.................................... 7.3............................. 5.80 5.38 7.2 5.64 5.21 7.6
2024.................................... 9.6............................. 5.80 5.25 9.5 5.65 5.22 7.6
2025.................................... 11.9............................ 5.81 5.12 11.8 5.65 5.14 9.1
2026.................................... 14.1............................ 5.81 5.01 13.7 5.65 5.02 11.1
2027.................................... 16.2............................ 5.80 4.88 15.8 5.57 4.92 11.7
2028 *.................................. 16.2............................ 5.81 4.91 15.5 5.57 4.89 12.2
2029 *.................................. 16.2............................ 5.81 4.91 15.6 5.57 4.88 12.4
2030 *.................................. 16.2............................ 5.81 4.91 15.6 5.57 4.88 12.4
--------------------------------------------------------------------------------------------------------------------------------------------------------
Notes:
a For an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 1b,
please see Section X.A.1.
* Absent further action, standards assumed to continue unchanged after model year 2027.
Table VII-5--Stringency of HD Pickup and Van Standards, Estimated Average Required and Achieved CO[ihel2] Emission Rates for Method A, Relative to
Alternative 1b a
--------------------------------------------------------------------------------------------------------------------------------------------------------
Ave. required CO[ihel2] Rate (g./mi.) Ave. achieved CO[ihel2] Rate (g./mi.)
Model year Stringency (vs. 2018) -----------------------------------------------------------------------------------------------
(%) No Action Final Reduction (%) No Action Final Reduction (%)
--------------------------------------------------------------------------------------------------------------------------------------------------------
2016............................ MYs 2016-2020 Subject 597 597 0.0 578 578 0.0
2017............................ to Phase 1 Standards. 582 582 0.0 567 554 2.2
2018............................ 550 550 0.0 562 544 3.2
2019............................ 548 548 0.0 543 514 5.3
2020............................ 547 547 0.0 541 513 5.1
2021............................ 2.5................... 545 532 2.4 534 496 7.1
2022............................ 4.9................... 546 519 4.9 530 491 7.4
2023............................ 7.3................... 545 506 7.2 529 490 7.5
2024............................ 9.6................... 547 494 9.5 531 491 7.5
2025............................ 11.9.................. 547 483 11.7 530 483 9.0
2026............................ 14.1.................. 547 472 13.7 530 472 11.0
2027............................ 16.2.................. 546 460 15.8 523 462 11.5
2028*........................... 16.2.................. 547 462 15.5 523 460 12.0
2029*........................... 16.2.................. 547 462 15.5 524 460 12.2
2030*........................... 16.2.................. 547 462 15.5 524 460 12.2
--------------------------------------------------------------------------------------------------------------------------------------------------------
Notes:
a For an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 1b,
please see Section X.A.1.
* Absent further action, standards assumed to continue unchanged after model year 2027.
Table VII-6--Stringency of HD Pickup and Van Standards, Estimated Average Required and Achieved Fuel Consumption Rates for Method A, Relative to
Alternative 1aa
--------------------------------------------------------------------------------------------------------------------------------------------------------
Ave. required fuel cons. (gal./100 mi.) Ave. achieved fuel cons. (gal./100 mi.)
Model year Stringency (vs. 2018) -----------------------------------------------------------------------------------------------
(%) No Action Final Reduction (%) No Action Final Reduction (%)
--------------------------------------------------------------------------------------------------------------------------------------------------------
2016............................ MYs 2016-2020 Subject 6.32 6.32 0.0 6.14 6.14 0.0
2017............................ to Phase 1 Standards. 6.16 6.16 0.0 6.00 5.85 2.4
2018............................ 5.83 5.83 0.0 5.94 5.75 3.2
2019............................ 5.81 5.81 0.0 5.74 5.43 5.4
2020............................ 5.80 5.80 0.0 5.73 5.43 5.2
2021............................ 2.5................... 5.79 5.65 2.4 5.70 5.27 7.5
2022............................ 4.9................... 5.80 5.52 4.8 5.69 5.23 8.2
2023............................ 7.3................... 5.80 5.38 7.2 5.69 5.22 8.3
2024............................ 9.6................... 5.80 5.25 9.5 5.70 5.22 8.3
[[Page 73825]]
2025............................ 11.9.................. 5.81 5.13 11.8 5.70 5.13 10.0
2026............................ 14.1.................. 5.81 5.02 13.6 5.70 5.03 11.9
2027............................ 16.2.................. 5.80 4.89 15.8 5.64 4.92 12.8
2028*........................... 16.2.................. 5.81 4.91 15.4 5.64 4.89 13.3
2029*........................... 16.2.................. 5.81 4.91 15.5 5.64 4.89 13.4
2030*........................... 16.2.................. 5.81 4.91 15.5 5.64 4.89 13.4
--------------------------------------------------------------------------------------------------------------------------------------------------------
Notes:
a For an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 1b,
please see Section X.A.1.
* Absent further action, standards assumed to continue unchanged after model year 2027.
** Increased work factor for some vehicles produces a slight increase in average required fuel consumption.
Table VII-7--Stringency of HD Pickup and Van Standards, Estimated Average Required and Achieved CO[ihel2] Emission Rates for Method A, Relative to
Alternative 1a a
--------------------------------------------------------------------------------------------------------------------------------------------------------
Ave. required CO[ihel2] Rate (g./mi.) Ave. achieved CO[ihel2] Rate (g./mi.)
Model year Stringency (vs. 2018) -----------------------------------------------------------------------------------------------
(%) No Action Final Reduction (%) No Action Final Reduction (%)
--------------------------------------------------------------------------------------------------------------------------------------------------------
2016............................ MYs 2016-2020 Subject 597 597 0.0 578 578 0.0
2017............................ to Phase 1 Standards. 582 582 0.0 564 551 2.3
2018............................ 550 550 0.0 559 541 3.2
2019............................ 548 548 0.0 540 511 5.4
2020............................ 547 547 0.0 538 510 5.2
2021............................ 2.5................... 545 532 2.4 535 495 7.4
2022............................ 4.9................... 546 519 4.8 534 491 8.0
2023............................ 7.3................... 545 506 7.2 533 490 8.2
2024............................ 9.6................... 547 494 9.5 535 491 8.2
2025............................ 11.9.................. 547 483 11.7 535 483 9.8
2026............................ 14.1.................. 547 472 13.6 535 473 11.7
F 2027.......................... 16.2.................. 546 460 15.8 529 462 12.6
2028*........................... 16.2.................. 547 462 15.5 530 460 13.1
2029*........................... 16.2.................. 547 462 15.5 530 460 13.2
2030*........................... 16.2.................. 547 462 15.5 530 460 13.2
--------------------------------------------------------------------------------------------------------------------------------------------------------
Notes:
a For an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 1b,
please see Section X.A.1.
* Absent further action, standards assumed to continue unchanged after model year 2027.
** Increased work factor for some vehicles produces a slight increase in the average required CO[ihel2] emission rate.
While the above tables show the agencies' estimates of average fuel
consumption and CO2 emission rates manufacturers of pickups
and vans might achieve under today's standards, total U.S. fuel
consumption and GHG emissions from HD pickups and vans will also depend
on how many of these vehicles are produced, and how they are operated
over their useful lives. Relevant to estimating these outcomes, the
CAFE model applies vintage-specific estimates of vehicle survival and
mileage accumulation, and adjusts the latter to account for the rebound
effect. This impact of the rebound effect is specific to each model
year (and, underlying, to each vehicle model in each model year),
varying with changes in achieved fuel consumption rates.
(ii) Method B for HD Pickups and Vans
For Method B, the MOVES model was used to estimate fuel consumption
and GHG emissions for HD pickups and vans. MOVES evaluated these
standards for HD pickup trucks and vans in terms of grams of
CO2 per mile or gallons of fuel per 100 miles. Since nearly
all HD pickup trucks and vans are certified on a chassis dynamometer,
the CO2 reductions for these vehicles were not represented
as engine and road load reduction components, but rather as total
vehicle CO2 reductions. The control case for HD pickups and
vans assumed an increase in VMT from the reference levels of 1.08
percent.\548\
---------------------------------------------------------------------------
\548\ Memorandum to the Docket ``VMT Rebound Inputs to MOVES for
HDGHG2 Phase 2 FRM'' Docket No. EPA-HQ-OAR-2016. July 2016.
[[Page 73826]]
Table VII-8--Estimated Total Vehicle CO[ihel2] Reductions for the Final Standards and In-Use Emissions for HD
Pickup Trucks and Vans in Method Ba
----------------------------------------------------------------------------------------------------------------
CO[ihel2]
reduction from
Vehicle type Fuel Model year flat baseline
(%)
----------------------------------------------------------------------------------------------------------------
HD pickup trucks and vans..................... Gasoline and Diesel............. 2021 2.50
2022 4.94
2023 7.31
2024 9.63
2025 11.89
2026 14.09
2027+ 16.24
----------------------------------------------------------------------------------------------------------------
Note:
a For an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat
baseline, 1a, and dynamic baseline, 1b, please see Section X.A.1.
C. What are the projected reductions in fuel consumption and GHG
emissions?
NHTSA and EPA expect significant reductions in GHG emissions and
fuel consumption from the final rules--fuel consumption reductions from
more efficient vehicles, emission reductions from both downstream
(tailpipe) and upstream (fuel production and distribution) sources, and
reduction in HFC emissions from the air conditioning leakage standards
(see Section V.B.(2)(c)). The following subsections summarize two
different analyses of the annual GHG emissions and fuel consumption
reductions expected from these final rules, as well as the reductions
in GHG emissions and fuel consumption expected over the lifetime of
each heavy-duty vehicle category. Section VII.C.(1) shows the impacts
of the final rules on fuel consumption and GHG emissions, using the
MOVES model for tractor-trailers and vocational vehicles and the DOT's
CAFE model for HD pickups and vans (Method A), relative to two
different reference cases--flat and dynamic. Section VII.C.2 shows the
impacts of the final standards, relative to the flat reference case
only, using the MOVES model for all heavy-duty vehicle categories.
NHTSA also analyzes these impacts resulting from the final rules and
reasonable alternatives in Chapters 3, 4 and 5 of its FEIS.
(1) Impacts of the Final Rules Using Analysis Method A
(a) Calendar Year Analysis
(i) Downstream (Tailpipe) Emissions Projections
As described in Section VII.A, for the analysis using Method A, the
agencies used MOVES to estimate downstream GHG inventories from the
final rules for vocational vehicles and tractor-trailers. For HD
pickups and vans, DOT's CAFE model was used.
The following two tables summarize the agencies' estimates of HD
pickup and van fuel consumption and GHG emissions under the current
standards defining the No-Action and final program, respectively, using
Method A. Table VII-9 shows results assuming manufacturers will
voluntarily make improvements that pay back within six months (i.e.,
Alternative 1b). Table VII-10 shows results assuming manufacturers will
only make improvements as needed to achieve compliance with standards
(i.e., Alternative 1a). While underlying calculations are all performed
for each calendar year during each vehicle's useful life, presentation
of outcomes on a model year basis aligns more clearly with
consideration of cost impacts in each model year, and with
consideration of standards specified on a model year basis. In
addition, Method A analyzes manufacturers' potential responses to HD
pickup and van standards on a model year basis through 2030, and any
longer-term costs presented in today's notice represent extrapolation
of these results absent any underlying analysis of longer-term
technology prospects and manufacturers' longer-term product offerings.
Table VII-9--Estimated Fuel Consumption and GHG Emissions Over Useful Life of HD Pickups and Vans Produced in Each Model Year for Method A, Relative to
Alternative 1b a
--------------------------------------------------------------------------------------------------------------------------------------------------------
Fuel consumption (b. gal.) over fleet's GHG emissions (MMT CO[ihel2]eq) over fleet's
useful life useful life
Model year -----------------------------------------------------------------------------------------------
No action Final Reduction (%) No action Final Reduction (%)
--------------------------------------------------------------------------------------------------------------------------------------------------------
2016.................................................... 10.4 10.4 0.0 127 127 0.0
2017.................................................... 10.4 10.2 2.0 127 124 2.0
2018.................................................... 10.5 10.2 2.9 127 124 2.9
2019.................................................... 10.1 9.60 4.8 123 117 4.8
2020.................................................... 10.1 9.60 4.6 123 117 4.6
2021.................................................... 9.82 9.17 6.6 120 112 6.5
2022.................................................... 9.67 9.01 6.9 118 110 6.8
2023.................................................... 9.64 8.97 7.0 117 109 6.9
2024.................................................... 9.67 9.00 7.0 118 110 6.9
2025.................................................... 9.79 8.98 8.3 119 109 8.2
2026.................................................... 9.91 8.90 10.2 121 109 10.1
2027.................................................... 9.89 8.84 10.7 120 108 10.5
2028.................................................... 10.0 8.89 11.1 122 108 10.9
[[Page 73827]]
2029.................................................... 10.1 8.97 11.2 123 109 11.1
2030.................................................... 10.1 8.94 11.2 123 109 11.1
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note:
\a\ For an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 1b,
please see Section X.A.1.
Table VII-10--Estimated Fuel Consumption and GHG Emissions Over Useful Life of HD Pickups and Vans Produced in Each Model Year for Method A, Relative to
Alternative 1a a
--------------------------------------------------------------------------------------------------------------------------------------------------------
Fuel consumption (b. gal.) over fleet's GHG emissions (MMT CO[ihel2]eq) over fleet's
useful life useful
Model year -----------------------------------------------------------------------------------------------
No action Final Reduction (%) No action Final Reduction (%)
--------------------------------------------------------------------------------------------------------------------------------------------------------
2016.................................................... 10.43 10.43 0.0 122 122 0.0
2017.................................................... 10.37 10.15 2.2 122 119 2.2
2018.................................................... 10.41 10.10 3.0 122 118 3.1
2019.................................................... 10.04 9.55 4.9 118 112 5.1
2020.................................................... 10.03 9.56 4.7 118 112 4.9
2021.................................................... 9.84 9.16 6.9 115 107 7.1
2022.................................................... 9.74 9.01 7.5 114 105 7.7
2023.................................................... 9.71 8.97 7.6 114 105 7.8
2024.................................................... 9.75 9.00 7.6 114 105 7.8
2025.................................................... 9.88 8.97 9.1 116 105 9.3
2026.................................................... 10.00 8.92 10.8 117 104 11.1
2027.................................................... 10.01 8.84 11.7 117 103 11.9
2028.................................................... 10.12 8.89 12.1 119 104 12.4
2029.................................................... 10.22 8.98 12.1 120 105 12.4
2030.................................................... 10.18 8.95 12.2 119 105 12.4
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note:
\a\ For an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 1b,
please see Section X.A.1.
To more clearly communicate these trends visually, the following
two charts present the above results graphically for Method A, relative
to Alternative 1b. As shown, fuel consumption and GHG emissions follow
parallel though not precisely identical paths. Though not presented,
the charts for Alternative 1a will appear sufficiently similar that
differences between Alternative 1a and Alternative 1b remain best
communicated by comparing values in the above tables.
[[Page 73828]]
[GRAPHIC] [TIFF OMITTED] TR25OC16.036
[[Page 73829]]
Table VII-11--Annual Downstream GHG Emissions Impacts in Calendar Years 2025, 2040 and 2050--Final Program vs.
Alt 1b Using Analysis Method A \a\
----------------------------------------------------------------------------------------------------------------
Total downstream
CO[ihel2] CH4 (MMT N[ihel2]O -------------------------------
CY (MMT) CO[ihel2]eq) (MMT MMT
CO[ihel2]eq) CO[ihel2]eq % Change
----------------------------------------------------------------------------------------------------------------
2025............................ -26.5 -0.004 0.002 -26.6 -4.9
2040............................ -103.3 -0.02 0.006 -103.3 -17.0
2050............................ -123.8 -0.03 0.007 -123.8 -18.0
----------------------------------------------------------------------------------------------------------------
Note:
\a\ For an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat
baseline, 1a, and dynamic baseline, 1b, please see Section X.A.1.
Table VII-12--Annual Fuel Savings in Calendar Years 2025, 2040 and 2050--Final Program vs. Alt 1b Using Analysis
Method A \a\
----------------------------------------------------------------------------------------------------------------
Diesel Gasoline
---------------------------------------------------------------
CY Billion Billion
gallons % Savings gallons % Savings
----------------------------------------------------------------------------------------------------------------
2025............................................ 2.3 4.9 0.4 5.0
2040............................................ 9.2 17.8 1.0 12.2
2050............................................ 11.1 19.3 1.2 12.8
----------------------------------------------------------------------------------------------------------------
Note:
\a\ For an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat
baseline, 1a, and dynamic baseline, 1b, please see Section X.A.1.
Table VII-13--Annual Downstream GHG Emissions Impacts in Calendar Years 2025, 2040 and 2050--Final Program vs.
Alt 1a Using Analysis Method A \a\
----------------------------------------------------------------------------------------------------------------
Total downstream
CO[ihel2] CH4 (MMT N[ihel2]O (MMT -------------------------------
CY (MMT) CO[ihel2]eq) CO[ihel2]eq) MMT
CO[ihel2]eq % Change
----------------------------------------------------------------------------------------------------------------
2025............................ -28.9 -0.005 0.003 -28.9 -5.3
2040............................ -114.1 -0.02 0.006 -114.1 -18.0
2050............................ -136.9 -0.03 0.007 -136.9 -20.0
----------------------------------------------------------------------------------------------------------------
Note:
\a\ For an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat
baseline, 1a, and dynamic baseline, 1b, please see Section X.A.1.
Table VII-14--Annual Fuel Savings in Calendar Years 2025, 2040 and 2050--Final Program vs. Alt 1a Using Analysis
Method A \a\
----------------------------------------------------------------------------------------------------------------
Diesel Gasoline
---------------------------------------------------------------
CY Billion Billion
gallons % Savings gallons % Savings
--------------------------------------------------------------------------------------------------
2025.............................. 2.4 5.2 0.5 5.6
2040.............................. 10.2 19.0 1.2 13.0
2050.............................. 12.3 21.0 1.3 14.0
----------------------------------------------------------------------------------------------------------------
Note:
\a\ For an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat
baseline, 1a, and dynamic baseline, 1b, please see Section X.A.1.
(ii) Upstream (Fuel Production and Distribution) Emissions Projections
Table VII-15--Annual Upstream GHG Emissions Impacts in Calendar Years 2025, 2040 and 2050--Final Program vs. Alt
1b Using Analysis Method A \a\
----------------------------------------------------------------------------------------------------------------
Total upstream
CO[ihel2] CH4 (MMT N[ihel2]O (MMT -------------------------------
CY (MMT) CO[ihel2]eq) CO[ihel2]eq) MMT
CO[ihel2]eq % Change
----------------------------------------------------------------------------------------------------------------
2025............................ -8.1 -0.9 -0.08 -9.0 -4.9
2040............................ -31.8 -3.4 -0.2 -35.5 -17.0
2050............................ -38.1 -4.2 -0.2 -42.5 -19.0
----------------------------------------------------------------------------------------------------------------
Note:
[[Page 73830]]
\a\ For an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat
baseline, 1a, and dynamic baseline, 1b, please see Section X.A.1.
Table VII-16--Annual Upstream GHG Emissions Impacts in Calendar Years 2025, 2040 and 2050--Final Program vs. Alt
1a Using Analysis Method A \a\
----------------------------------------------------------------------------------------------------------------
Total upstream
CO[ihel2] CH4 (MMT N[ihel2]O (MMT -------------------------------
CY (MMT) CO[ihel2]eq) CO[ihel2]eq) MMT
CO[ihel2]eq % Change
----------------------------------------------------------------------------------------------------------------
2025............................ -8.7 -0.9 -0.09 -9.8 -5.3
2040............................ -35.2 -3.9 -0.2 -39.3 -19.0
2050............................ -42.2 -4.6 -0.3 -47.2 -20.0
----------------------------------------------------------------------------------------------------------------
Note:
\a\ For an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat
baseline, 1a, and dynamic baseline, 1b, please see Section X.A.1.
(iii) HFC Emissions Projections
The projected HFC emission reductions due to the HD Phase 2 air
conditioning leakage standards for vocational vehicles are 86,735
metric tons of CO2eq in 2025, 256,061 metric tons of
CO2eq in 2040, and 314,930 metric tons CO2eq in
2050. See Chapter 5 of the RIA for additional details on calculations
of HFC emissions.
(iv) Total (Downstream + Upstream + HFC) Emissions Projections
Table VII-17--Annual Total GHG Emissions Impacts in Calendar Years 2025, 2040 and 2050--Final Program vs. Alt 1b Using Analysis Method A \a\
--------------------------------------------------------------------------------------------------------------------------------------------------------
CY2025 CY2040 CY2050
-----------------------------------------------------------------------------------------------
MMT MMT MMT
CO[ihel2]eq % Change CO[ihel2]eq % Change CO[ihel2]eq % Change
--------------------------------------------------------------------------------------------------------------------------------------------------------
Downstream.............................................. -26.6 -4.9 -103.3 -17.0 -123.8 -18.0
Upstream................................................ -9.0 -4.9 -35.5 -17.0 -42.5 -19.0
HFCb.................................................... -0.1 -15.0 -0.3 -13.0 -0.3 -13.0
Total................................................... -35.7 -4.9 -139.1 -17.0 -166.6 -19.0
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note:
\a\ For an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 1b,
please see Section X.A.1.
\b\ HFC represents HFC emission reductions and percent change from the vocational vehicle category only.
Table VII-18 Annual Total GHG Emissions Impacts in Calendar Years 2025, 2040 and 2050--Final Program vs. Alt 1a Using Analysis Method A \a\
--------------------------------------------------------------------------------------------------------------------------------------------------------
CY2025 CY2040 CY2050
-----------------------------------------------------------------------------------------------
MMT MMT MMT
CO[ihel2]eq % Change CO[ihel2]eq % Change CO[ihel2]eq % Change
--------------------------------------------------------------------------------------------------------------------------------------------------------
Downstream.............................................. -28.9 -5.3 -114.1 -18.0 -136.9 -20.0
Upstream................................................ -9.8 -5.3 -39.3 -19.0 -47.2 -20.0
HFC..................................................... -0.1 -15.0 -0.3 -13.0 -0.3 -13.0
Total................................................... -38.8 -5.3 -153.7 -19.0 -184.4 -20.0
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note:
\a\ For an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 1b,
please see Section X.A.1.
(b) Model Year Lifetime Analysis
Table VII-19--Lifetime GHG Reductions and Fuel Savings Using Analysis
Method A--Summary for Model Years 2018-2029 \a\
------------------------------------------------------------------------
Final program (alternative 3)
No-action alternative (baseline) -------------------------------
1b (dynamic) 1a (flat)
------------------------------------------------------------------------
Fuel Savings (Billion Gallons).......... 71.1 77.7
Total GHG Reductions (MMT CO[ihel2]eq).. 958 1,049
Downstream (MMT CO[ihel2]eq)........ 715 781
Upstream (MMT CO[ihel2]eq).......... 243 268
------------------------------------------------------------------------
Note:
\a\ For an explanation of analytical Methods A and B, please see Section
I.D; for an explanation of the flat baseline, 1a, and dynamic
baseline, 1b, please see Section X.A.1.
[[Page 73831]]
(2) Impacts of the Final Rules Using Analysis Method B
(a) Calendar Year Analysis
(i) Downstream (Tailpipe) Emissions Projections
As described in Section VII.A., Method B used MOVES to estimate
downstream GHG inventories from the final rules, relative to
Alternative 1a, for all heavy-duty vehicle categories (including the
engines associated with tractor-trailer combinations and vocational
vehicles). The agencies expect reductions in CO2 emissions
from all heavy-duty vehicle categories due to engine and vehicle
improvements. We expect N2O emissions to increase very
slightly because of a rebound in vehicle miles traveled (VMT). However,
since N2O is produced as a byproduct of fuel combustion, the
increase in N2O emissions is expected to be more than offset
by the improvements in fuel efficiency from the final rules.\549\ We
expect methane emissions to decrease primarily due to reduced refueling
from improved fuel efficiency and the differences in hydrocarbon
emission characteristics between on-road diesel engines and APUs. The
amount of methane emitted as a fraction of total hydrocarbons is
expected to be less for APUs than for on-road diesel engines during
extended idling. Overall, the downstream GHG emissions will be reduced
significantly and are described in the following subsections.
---------------------------------------------------------------------------
\549\ MOVES is not capable of modeling the changes in exhaust
N2O emissions from the improvements in fuel efficiency.
Due to this limitation, a conservative approach was taken to only
model the VMT rebound in estimating the emissions impact on
N2O from the final rules, resulting in a slight increase
in downstream N2O inventory.
---------------------------------------------------------------------------
Fuel consumption is calculated from the MOVES output of total
energy consumption converted using the fuel heating values assumed in
the Renewable Fuels Standard rulemaking \550\ and in MOVES.\551\
---------------------------------------------------------------------------
\550\ Renewable Fuels Standards assumptions of 115,000 BTU/
gallon gasoline (E0) and 76,330 BTU/gallon ethanol (E100) were
weighted 90 percent and 10 percent, respectively, for E10 and 85
percent and 15 percent, respectively, for E15 and converted to kJ at
1.055 kJ/BTU. The conversion factors are 117,245 kJ/gallon for
gasoline blended with ten percent ethanol (E10) and 115,205 kJ/
gallon for gasoline blended with fifteen percent ethanol (E15).
\551\ The conversion factor for diesel is 138,451 kJ/gallon. See
MOVES2004 Energy and Emission Inputs. EPA420-P-05-003, March 2005.
http://www3.epa.gov/otaq/models/ngm/420p05003.pdf (last accessed Mar
15, 2016).
---------------------------------------------------------------------------
Table VII-20 shows the impacts on downstream GHG emissions and fuel
savings in 2025, 2040 and 2050, relative to Alternative 1a, for the
final program.
Table VII-21 shows the estimated fuel savings from the final
program in 2025, 2040, and 2050, relative to Alternative 1a. The
results from the comparable analyses relative to Alternative 1b are
presented in Section VII.C.(1).
Table VII-20--Annual Downstream GHG Emissions Impacts in Calendar Years 2025, 2040 and 2050--Final Program vs.
Alt 1a Using Analysis Method B \a\
----------------------------------------------------------------------------------------------------------------
Total downstream
CO[ihel2] CH4 (MMT N[ihel2]O (MMT -------------------------------
CY (MMT) CO[ihel2]eq) CO[ihel2]eq) MMT
CO[ihel2]eq % Change
----------------------------------------------------------------------------------------------------------------
2025............................ -27.8 -0.01 0.002 -27.8 -4.6
2040............................ -124.3 -0.02 0.003 -124.3 -18.4
2050............................ -148.4 -0.03 0.004 -148.4 -0.0
----------------------------------------------------------------------------------------------------------------
Note:
\a\ For an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat
baseline, 1a, and dynamic baseline, 1b, please see Section X.A.1.
Table VII-21--Annual Fuel Savings in Calendar Years 2025, 2040 and 2050--Final Program vs. Alt 1a Using Analysis
Method B \a\
----------------------------------------------------------------------------------------------------------------
Diesel Gasoline
---------------------------------------------------------------
CY Billion Billion
gallons % Savings gallons % Savings
----------------------------------------------------------------------------------------------------------------
2025............................................ 2.5 5.0 0.3 2.8
2040............................................ 10.8 19.4 1.7 13.3
2050............................................ 13.0 21.0 1.9 14.4
----------------------------------------------------------------------------------------------------------------
Note:
\a\ For an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat
baseline, 1a, and dynamic baseline, 1b, please see Section X.A.1.
(ii) Upstream (Fuel Production and Distribution) Emissions Projections
The upstream GHG emission reductions associated with the production
and distribution of gasoline and diesel from crude oil include the
domestic emission reductions only. Additionally, since this rulemaking
is not expected to impact biofuel volumes mandated by the annual
Renewable Fuel Standards (RFS) regulations \552\, the impacts on
upstream emissions from changes in biofuel feedstock (i.e.,
agricultural sources such as fertilizer, fugitive dust, and livestock)
are not shown. In other words, we attribute decreased fuel consumption
from this program to petroleum-based fuels only, while assuming no net
effect on volumes of renewable fuels. We used this approach because
annual renewable fuel volumes are mandated independently from this
rulemaking under RFS. As a consequence, it is not possible to conclude
whether the decreasing petroleum consumption projected here would
increase the fraction of the U.S. fuel supply that is made up by
renewable fuels (if RFS volumes remained constant), or whether future
renewable fuel volume mandates would decrease in proportion to the
decreased petroleum consumption projected here.
---------------------------------------------------------------------------
\552\ U.S. EPA. 2014 Standards for the Renewable Fuel Standard
Program. 40 CFR part 80. EPA-HQ-OAR-2013-0479; FRL-9900-90-OAR, RIN
2060-AR76.
---------------------------------------------------------------------------
As background, EPA sets annual renewable fuel volume mandates
through a separate RFS notice-and-comment rulemaking process, and the
[[Page 73832]]
final volumes are based on EIA projections, EPA's own market
assessment, and information obtained from the RFS notice and comment
process. Also, RFS standards are nested within each other, which means
that a fuel with a higher GHG reduction threshold can be used to meet
the standards for a lower GHG reduction threshold. This creates
additional uncertainty in projecting this rule's net effect on future
annual RFS standards.
In conclusion, the impacts of this rulemaking on annual renewable
fuel volume mandates are difficult to project at the present time.
However, since it is not centrally relevant to the analysis for this
rulemaking, we have not included any impacts on renewable fuel volumes
in this analysis. The upstream GHG emission reductions of the final
program can be found in Table VII-22.
Table VII-22--Annual Upstream GHG Emissions Impacts in Calendar Years 2025, 2040 and 2050--Final Program vs. Alt
1a Using Analysis Method B \a\
----------------------------------------------------------------------------------------------------------------
Total upstream
CO[ihel2] CH4 (MMT N[ihel2]O (MMT -------------------------------
CY (MMT) CO[ihel2]eq) CO[ihel2]eq) MMT
CO[ihel2]eq % CHANGE
----------------------------------------------------------------------------------------------------------------
2025............................ -8.6 -0.9 -0.04 -9.5 -4.7
2040............................ -38.0 -4.0 -0.2 -42.2 -18.7
2050............................ -45.5 -4.8 -0.2 -50.5 -20.3
----------------------------------------------------------------------------------------------------------------
Note:
\a\ For an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat
baseline, 1a, and dynamic baseline, 1b, please see Section X.A.1.
(iii) HFC Emissions Projections
The projected HFC emission reductions due to the HD Phase 2 air
conditioning leakage standards for vocational vehicles are 86,735
metric tons of CO2eq in 2025, 256,061 metric tons of
CO2eq in 2040, and 314,930 metric tons CO2eq in
2050. See Chapter 5 of the RIA for additional details on calculations
of HFC emissions.
(iv) Total (Downstream + Upstream + HFC) Emissions Projections
Table VII-23 combines the impacts of the final program from
downstream (Table VII-20), upstream (Table VII-22), and HFC to
summarize the total GHG reductions in calendar years 2025, 2040 and
2050, relative to Alternative 1a.
Table VII-23--Annual Total GHG Emissions Impacts in Calendar Years 2025, 2040 and 2050--Final Program vs. Alt 1a Using Analysis Method B \a\
--------------------------------------------------------------------------------------------------------------------------------------------------------
CY2025 CY2040 CY2050
-----------------------------------------------------------------------------------------------
MMT MMT MMT
CO[ihel2]eq % Change CO[ihel2]eq % Change CO[ihel2]eq % Change
--------------------------------------------------------------------------------------------------------------------------------------------------------
Downstream.............................................. -27.8 -4.6 -124.3 -18.4 -148.4 -20.0
Upstream................................................ -9.5 -4.7 -42.2 -18.7 -50.5 -20.3
HFC b................................................... -0.1 -15.0 -0.3 -13.0 -0.3 -13.0
Total................................................... -37.4 -4.7 -166.8 -18.5 -199.2 -20.1
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note:
\a\ For an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 1b,
please see Section X.A.1.
\b\ HFC represents HFC emission reductions and percent change from the vocational vehicle category only.
(b) Model Year Lifetime Analysis
In addition to the annual GHG emissions and fuel consumption
reductions expected from the final rules, we estimated the combined
(downstream and upstream) GHG and fuel consumption impacts for the
lifetime of the impacted vehicles sold in the regulatory timeframe.
Table VII-24 shows the fleet-wide GHG reductions and fuel savings from
the final program, relative to Alternative 1a, through the lifetime of
heavy-duty vehicles.\553\ For the lifetime GHG reductions and fuel
savings by vehicle categories, see Chapter 5 of the RIA.
---------------------------------------------------------------------------
\553\ A lifetime of 30 years is assumed in MOVES.
Table VII-24--Lifetime GHG Reductions and Fuel Savings Using Analysis
Method B--Summary for Model Years 2018-2029 a
------------------------------------------------------------------------
Model years Final program
------------------------------------------------------ (Alternative 3)
------------------
No-action alternative (baseline) 1a (Flat)
------------------------------------------------------------------------
Fuel Savings (Billion Gallons)....................... 82.2
Total GHG Reductions (MMT CO[ihel2]eq)............... 1,097.6
Downstream (MMT CO[ihel2]eq)......................... 819.2
Upstream (MMT CO[ihel2]eq)........................... 278.4
------------------------------------------------------------------------
Note:
[[Page 73833]]
\a\ For an explanation of analytical Methods A and B, please see Section
I.D; for an explanation of the flat baseline, 1a, and dynamic
baseline, 1b, please see Section X.A.1.
D. Climate Impacts and Indicators
(1) Climate Change Impacts From GHG Emissions
The impact of GHG emissions on the climate has been reviewed in the
2009 Endangerment and Cause or Contribute Findings for Greenhouse Gases
under Section 202(a) of the Clean Air Act, the 2012-2016 light-duty
vehicle rulemaking, the 2014-2018 heavy-duty vehicle GHG and fuel
efficiency rulemaking, the 2017-2025 light-duty vehicle rulemaking, and
the standards for new electricity utility generating units. See 74 FR
66496; 75 FR 25491; 76 FR 57294; 77 FR 62894; 79 FR 1456-1459; 80 FR
64662. This section briefly discusses again some of the climate impact
of EPA's actions in context of transportation emissions. NHTSA has
analyzed the climate impacts of its specific actions (i.e., excluding
EPA's HFC regulatory provisions) as well as reasonable alternatives in
its DEIS that accompanies this final rules. DOT has considered the
potential climate impacts documented in the DEIS as part of the
rulemaking process.
Once emitted, GHGs that are the subject of this regulation can
remain in the atmosphere for decades to millennia, meaning that (1)
their concentrations become well-mixed throughout the global atmosphere
regardless of emission origin, and (2) their effects on climate are
long lasting. GHG emissions come mainly from the combustion of fossil
fuels (coal, oil, and gas), with additional contributions from the
clearing of forests, agricultural activities, cement production, and
some industrial activities. Transportation activities, in aggregate,
were the second largest contributor to total U.S. GHG emissions in 2010
(27 percent of total emissions).\554\
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\554\ U.S. EPA (2012) Inventory of U.S. Greenhouse Gas Emissions
and Sinks: 1990-2010. EPA 430-R-12-001. Available at http://epa.gov/climatechange/emissions/downloads12/US-GHG-Inventory-2012-Main-Text.pdf.
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The EPA Administrator relied on thorough and peer-reviewed
assessments of climate change science prepared by the Intergovernmental
Panel on Climate Change (``IPCC''), the United States Global Change
Research Program (``USGCRP''), and the National Research Council of the
National Academies (``NRC'') \555\ as the primary scientific and
technical basis for the Endangerment and Cause or Contribute Findings
for Greenhouse Gases Under Section 202(a) of the Clean Air Act (74 FR
66496, December 15, 2009). These assessments comprehensively address
the scientific issues the EPA Administrator had to examine, providing
her data and information on a wide range of issues pertinent to the
Endangerment Finding. These assessments have been rigorously reviewed
by the expert community, and also by United States government agencies
and scientists, including by EPA itself.
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\555\ For a complete list of core references from IPCC, USGCRP/
CCSP, NRC and others relied upon for development of the TSD for
EPA's Endangerment and Cause or Contribute Findings see Section
1(b), specifically, Table 1.1 of the TSD. (Docket EPA-HQ-OAR-2010-
0799).
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Based on these assessments, the EPA Administrator determined that
the emissions from new motor vehicles and engines contribute to
elevated concentrations of greenhouse gases; that these greenhouse
gases cause warming; that the recent warming has been attributed to the
increase in greenhouse gases; and that warming of the climate endangers
the public health and welfare of current and future generations. See
Coalition for Responsible Regulation v. EPA, 684 F. 3d 102, 121 (D.C.
Cir. 2012) (upholding all of EPA's findings and stating ``EPA had
before it substantial record evidence that anthropogenic emissions of
greenhouse gases `very likely' caused warming of the climate over the
last several decades. EPA further had evidence of current and future
effects of this warming on public health and welfare. Relying again
upon substantial scientific evidence, EPA determined that
anthropogenically induced climate change threatens both public health
and public welfare. It found that extreme weather events, changes in
air quality, increases in food- and water-borne pathogens, and
increases in temperatures are likely to have adverse health effects.
The record also supports EPA's conclusion that climate change endangers
human welfare by creating risk to food production and agriculture,
forestry, energy, infrastructure, ecosystems, and wildlife. Substantial
evidence further supported EPA's conclusion that the warming resulting
from the greenhouse gas emissions could be expected to create risks to
water resources and in general to coastal areas as a result of expected
increase in sea level.'')
A number of major peer-reviewed scientific assessments have been
released since the administrative record concerning the Endangerment
Finding closed following EPA's 2010 Reconsideration Denial.\556\ These
assessments include the ``Special Report on Managing the Risks of
Extreme Events and Disasters to Advance Climate Change Adaptation''
\557\, the 2013-14 Fifth Assessment Report (AR5),\558\ the 2014
National Climate Assessment report,\559\ the ``Ocean Acidification: A
National Strategy to Meet the Challenges of a Changing Ocean,'' \560\
``Report on Climate Stabilization Targets: Emissions, Concentrations,
and Impacts over Decades to Millennia,'' \561\ ``National Security
Implications for U.S. Naval Forces'' (National Security
Implications),\562\ ``Understanding Earth's Deep Past: Lessons for Our
Climate Future,'' \563\ ``Sea Level Rise for
[[Page 73834]]
the Coasts of California, Oregon, and Washington: Past, Present, and
Future,'' \564\ ``Climate and Social Stress: Implications for Security
Analysis,'' \565\ and ``Abrupt Impacts of Climate Change'' (Abrupt
Impacts) assessments.\566\
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\556\ ``EPA's Denial of the Petitions to Reconsider the
Endangerment and Cause or Contribute Findings for Greenhouse Gases
under Section 202(a) of the Clean Air Act,'' 75 FR 49,556 (Aug. 13,
2010) (``Reconsideration Denial'').
\557\ Intergovernmental Panel on Climate Change (IPCC). 2012:
Managing the Risks of Extreme Events and Disasters to Advance
Climate Change Adaptation. A Special Report of Working Groups I and
II of the Intergovernmental Panel on Climate Change. Cambridge
University Press, Cambridge, UK, and New York, NY, USA.
\558\ Intergovernmental Panel on Climate Change (IPCC). 2013.
Climate Change 2013: The Physical Science Basis. Contribution of
Working Group I to the Fifth Assessment Report of the
Intergovernmental Panel on Climate Change. Cambridge University
Press, Cambridge, United Kingdom and New York, NY, USA,
Intergovernmental Panel on Climate Change (IPCC). 2014. Climate
Change 2014: Impacts, Adaptation, and Vulnerability. Contribution of
Working Group II to the Fifth Assessment Report of the
Intergovernmental Panel on Climate Change. Cambridge University
Press, Cambridge, United Kingdom and New York, NY, USA,
Intergovernmental Panel on Climate Change (IPCC). 2014. Climate
Change 2014: Mitigation of Climate Change. Contribution of Working
Group III to the Fifth Assessment Report of the Intergovernmental
Panel on Climate Change. Cambridge University Press, Cambridge,
United Kingdom and New York, NY, USA.
\559\ Melillo, Jerry M., Terese (T.C.) Richmond, and Gary W.
Yohe, Eds. 2014. Climate Change Impacts in the United States: The
Third National Climate Assessment. U.S. Global Change Research
Program. Available at http://nca2014.globalchange.gov.
\560\ National Research Council (NRC). 2010. Ocean
Acidification: A National Strategy to Meet the Challenges of a
Changing Ocean. National Academies Press. Washington, DC.
\561\ National Research Council (NRC). 2011. Climate
Stabilization Targets: Emissions, Concentrations, and Impacts over
Decades to Millennia. National Academies Press, Washington, DC.
\562\ National Research Council (NRC) 2011. National Security
Implications of Climate Change for U.S. Naval Forces. National
Academies Press. Washington, DC.
\563\ National Research Council (NRC). 2012. Sea-Level Rise for
the Coasts of California, Oregon, and Washington: Past, Present, and
Future. National Academies Press. Washington, DC.
\564\ National Research Council (NRC). 2012. Sea-Level Rise for
the Coasts of California, Oregon, and Washington: Past, Present, and
Future. National Academies Press. Washington, DC.
\565\ National Research Council (NRC). 2013. Climate and Social
Stress: Implications for Security Analysis. National Academies
Press. Washington, DC.
\566\ National Research Council (NRC). 2013. Abrupt Impacts of
Climate Change: Anticipating Surprises. National Academies Press.
Washington, DC.
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EPA has reviewed these assessments and finds that, in general, the
improved understanding of the climate system they present is consistent
with the assessments underlying the 2009 Endangerment Finding.
The most recent assessments released were the IPCC AR5 assessments
between September 2013 and April 2014, the NRC Abrupt Impacts
assessment in December of 2013, and the U.S. National Climate
Assessment in May of 2014. The NRC Abrupt Impacts report examines the
potential for tipping points, thresholds beyond which major and rapid
changes occur in the Earth's climate system or other systems impacted
by the climate. The Abrupt Impacts report did find less cause for
concern than some previous assessments regarding some abrupt events
within the next century, such as disruption of the Atlantic Meridional
Overturning Circulation (AMOC) and sudden releases of high-latitude
methane from hydrates and permafrost, but found that the potential for
abrupt changes in ecosystems, weather and climate extremes, and
groundwater supplies critical for agriculture now seem more likely,
severe, and imminent. The assessment found that some abrupt changes
were already underway (Arctic sea ice retreat and increases in
extinction risk due to the speed of climate change) but cautioned that
even abrupt changes such as the AMOC disruption that are not expected
in this century can have severe impacts when they happen.
The IPCC AR5 assessments are also generally consistent with the
underlying science supporting the 2009 Endangerment Finding. For
example, confidence in attributing recent warming to human causes has
increased: The IPCC stated that it is extremely likely (>95 percent
confidence) that human influences have been the dominant cause of
recent warming. Moreover, the IPCC found that the last 30 years were
likely (>66 percent confidence) the warmest 30 year period in the
Northern Hemisphere of the past 1400 years, that the rate of ice loss
of worldwide glaciers and the Greenland and Antarctic ice sheets has
likely increased, that there is medium confidence that the recent
summer sea ice retreat in the Arctic is larger than it has been in 1450
years, and that concentrations of carbon dioxide and several other of
the major greenhouse gases are higher than they have been in at least
800,000 years. Climate-change induced impacts have been observed in
changing precipitation patterns, melting snow and ice, species
migration, negative impacts on crops, increased heat and decreased cold
mortality, and altered ranges for water-borne illnesses and disease
vectors. Additional risks from future changes include death, injury,
and disrupted livelihoods in coastal zones and regions vulnerable to
inland flooding, food insecurity linked to warming, drought, and
flooding, especially for poor populations, reduced access to drinking
and irrigation water for those with minimal capital in semi-arid
regions, and decreased biodiversity in marine ecosystems, especially in
the Arctic and tropics, with implications for coastal livelihoods. The
IPCC determined that ``[c]ontinued emissions of greenhouse gases will
cause further warming and changes in all components of the climate
system. Limiting climate change will require substantial and sustained
reductions of greenhouse gases emissions.''
Finally, the recently released National Climate Assessment stated,
``Climate change is already affecting the American people in far
reaching ways. Certain types of extreme weather events with links to
climate change have become more frequent and/or intense, including
prolonged periods of heat, heavy downpours, and, in some regions,
floods and droughts. In addition, warming is causing sea level to rise
and glaciers and Arctic sea ice to melt, and oceans are becoming more
acidic as they absorb carbon dioxide. These and other aspects of
climate change are disrupting people's lives and damaging some sectors
of our economy.''
Assessments from these bodies represent the current state of
knowledge, comprehensively cover and synthesize thousands of individual
studies to obtain the majority conclusions from the body of scientific
literature and undergo a rigorous and exacting standard of review by
the peer expert community and U.S. government.
Based on modeling analysis performed by the agencies, reductions in
CO2 and other GHG emissions associated with these final
rules will affect future climate change. Since GHGs are well-mixed in
the atmosphere and have long atmospheric lifetimes, changes in GHG
emissions will affect atmospheric concentrations of greenhouse gases
and future climate for decades to millennia, depending on the gas. This
section provides estimates of the projected change in atmospheric
CO2 concentrations based on the emission reductions
estimated for these final rules, compared to the reference case. In
addition, this section analyzes the response to the changes in GHG
concentrations of the following climate-related variables: Global mean
temperature, sea level rise, and ocean pH.
(2) Projected Change in Atmospheric CO2 Concentrations,
Global Mean Surface Temperature and Sea Level Rise
To assess the impact of the emissions reductions from the final
rules, EPA estimated changes in projected atmospheric CO2
concentrations, global mean surface temperature and sea-level rise to
2100 using the GCAM (Global Change Assessment Model, formerly MiniCAM),
integrated assessment model \567\ coupled with the MAGICC (Model for
the Assessment of Greenhouse-gas Induced Climate Change) simple climate
model.\568\ GCAM was used to create the globally and temporally
consistent set of climate relevant emissions required for running
MAGICC. MAGICC was then used to estimate the projected change in
relevant climate variables over time. Given the magnitude of the
estimated
[[Page 73835]]
emissions reductions associated with these rules, a simple climate
model such as MAGICC is appropriate for estimating the atmospheric and
climate response.
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\567\ GCAM is a long-term, global integrated assessment model of
energy, economy, agriculture and land use that considers the sources
of emissions of a suite of greenhouse gases (GHG's), emitted in 14
globally disaggregated regions, the fate of emissions to the
atmosphere, and the consequences of changing concentrations of
greenhouse related gases for climate change. GCAM begins with a
representation of demographic and economic developments in each
region and combines these with assumptions about technology
development to describe an internally consistent representation of
energy, agriculture, land-use, and economic developments that in
turn shape global emissions.
\568\ MAGICC consists of a suite of coupled gas-cycle, climate
and ice-melt models integrated into a single framework. The
framework allows the user to determine changes in greenhouse-gas
concentrations, global-mean surface air temperature and sea-level
resulting from anthropogenic emissions of carbon dioxide
(CO2), methane (CH4), nitrous oxide (N2O),
reactive gases (CO, NOX, VOCs), the halocarbons (e.g.
HCFCs, HFCs, PFCs) and sulfur dioxide (SO2). MAGICC
emulates the global-mean temperature responses of more sophisticated
coupled Atmosphere/Ocean General Circulation Models (AOGCMs) with
high accuracy.
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The analysis projects that the final rules will reduce atmospheric
concentrations of CO2, global climate warming, ocean
acidification, and sea level rise relative to the reference case.
Although the projected reductions and improvements are small in
comparison to the total projected climate change, they are
quantifiable, directionally consistent, and will contribute to reducing
the risks associated with climate change. Climate change is a global
phenomenon, and EPA recognizes that this one national action alone will
not prevent it; EPA notes this would be true for any given GHG
mitigation action when taken alone or when considered in isolation. EPA
also notes that a substantial portion of CO2 emitted into
the atmosphere is not removed by natural processes for millennia, and
therefore each unit of CO2 not emitted into the atmosphere
due to this rules avoids essentially permanent climate change on
centennial time scales.
EPA determines that the projected reductions in atmospheric
CO2, global mean temperature, sea level rise, and ocean pH
are meaningful in the context of this action. The results of the
analysis, summarized in Table VII-25, demonstrate that relative to the
reference case, by 2100 projected atmospheric CO2
concentrations are estimated to be reduced by 1.2 to 1.3 part per
million by volume (ppmv), global mean temperature is estimated to be
reduced by 0.0027 to 0.0065 [deg]C, and sea-level rise is projected to
be reduced by approximately 0.026 to 0.058 cm, based on a range of
climate sensitivities (described below). Details about this modeling
analysis can be found in the RIA Chapter 6.3.
Table VII-25--Impact of GHG Emissions Reductions on Projected Changes in Global Climate Associated With Phase 2
Standards for MY 2018-2024
[Based on a range of climate sensitivities from 1.5-6 [deg]C]
----------------------------------------------------------------------------------------------------------------
Variable Units Year Projected change
----------------------------------------------------------------------------------------------------------------
Atmospheric CO[ihel2] Concentration........... ppmv 2100 -1.2 to -1.3
Global Mean Surface Temperature............... [deg]C 2100 -0.0027 to -0.0065
Sea Level Rise................................ cm 2100 -0.026 to -0.058
Ocean pH...................................... pH units 2100 +0.0006 \a\
----------------------------------------------------------------------------------------------------------------
Note:
\a\ The value for projected change in ocean pH is based on a climate sensitivity of 3.0.
The projected reductions are small relative to the change in
temperature (1.8-4.8 [deg]C), CO2 concentration (404 to 470
ppm), sea level rise (23-56 cm), and ocean acidity (-0.30 pH units)
from 1990 to 2100 from the MAGICC simulations for the GCAM reference
case. However, this is to be expected given the magnitude of emissions
reductions expected from the program in the context of global
emissions. Moreover, these effects are occurring everywhere around the
globe, so benefits that appear to be marginal for any one location,
such as a reduction in sea level rise of half a millimeter, can be
sizable when the effects are summed along thousands of miles of
coastline. This uncertainty range does not include the effects of
uncertainty in future emissions. It should also be noted that the
calculations in MAGICC do not include the possible effects of
accelerated ice flow in Greenland and/or Antarctica: estimates of sea
level rise from the recent NRC, IPCC, and NCA assessments range from 26
cm to 2 meters depending on the emissions scenario, the processes
included, and the likelihood range assessed; inclusion of these effects
would lead to correspondingly larger benefits of mitigation. Further
discussion of EPA's modeling analysis is found in the RIA, Chapter 6.3.
Based on the projected atmospheric CO2 concentration
reductions resulting from these final rules, EPA calculates an increase
in ocean pH of 0.0006 pH units in 2100 relative to the baseline case
(this is a reduction in the expected acidification of the ocean of a
decrease of 0.3 pH units from 1990 to 2100 in the baseline case). Thus,
this analysis indicates the projected decrease in atmospheric
CO2 concentrations from the Phase 2 standards will result in
an increase in ocean pH (i.e., a reduction in the expected
acidification of the ocean in the reference case). A more detailed
discussion of the modeling analysis associated with ocean pH is
provided in the RIA, Chapter 6.3.
The 2011 NRC assessment on ``Climate Stabilization Targets:
Emissions, Concentrations, and Impacts over Decades to Millennia''
determined how a number of climate impacts--such as heaviest daily
rainfalls, crop yields, and Arctic sea ice extent--would change with a
temperature change of 1 degree Celsius (C) of warming. These
relationships of impacts with temperature change could be combined with
the calculated reductions in warming in Table VII-25 to estimate
changes in these impacts associated with this final rulemaking.
As a substantial portion of CO2 emitted into the
atmosphere is not removed by natural processes for millennia, each unit
of CO2 not emitted into the atmosphere avoids some degree of
effectively permanent climate change. Therefore, reductions in
emissions in the near term are important in determining climate impacts
experienced not just over the next decades but over thousands of
years.\569\ Though the magnitude of the avoided climate change
projected here in isolation is small in comparison to the total
projected changes, these reductions represent a reduction in the
adverse risks associated with climate change (though these risks were
not formally estimated for this action) across a range of equilibrium
climate sensitivities. In addition, these reductions are part of a
larger suite of domestic and international mitigation actions, and
should be considered in that context.
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\569\ National Research Council (NRC) (2011). Climate
Stabilization Targets: Emissions, Concentrations, and Impacts over
Decades to Millennia. National Academy Press. Washington, DC.
(Docket EPA-HQ-OAR-2010-0799).
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EPA's analysis of this final rule's impact on global climate
conditions is intended to quantify these potential reductions using the
best available science. EPA's modeling results show consistent
reductions relative to the baseline case in changes of CO2
concentration, temperature, sea-level rise, and ocean pH over the next
century.
[[Page 73836]]
VIII. How will these rules impact non-GHG emissions and their
associated effects?
The heavy-duty vehicle standards are expected to influence the
emissions of criteria air pollutants and several hazardous air
pollutants (air toxics). This section describes the projected impacts
of the final rules on non-GHG emissions and air quality and the health
and environmental effects associated with these pollutants. NHTSA
further analyzes these projected health and environmental effects
resulting from its final rules and reasonable alternatives in Chapter 4
of its FEIS.
A. Health Effects of Non-GHG Pollutants
In this section, we discuss health effects associated with exposure
to some of the criteria and air toxic pollutants impacted by the final
heavy-duty vehicle standards.
(1) Particulate Matter
(a) Background
Particulate matter is a highly complex mixture of solid particles
and liquid droplets distributed among numerous atmospheric gases which
interact with solid and liquid phases. Particles range in size from
those smaller than 1 nanometer (10-9 meter) to over 100
micrometers ([mu]m, or 10-6 meter) in diameter (for
reference, a typical strand of human hair is 70 [mu]m in diameter and a
grain of salt is about 100 [mu]m). Atmospheric particles can be grouped
into several classes according to their aerodynamic and physical sizes.
Generally, the three broad classes of particles include ultrafine
particles (UFPs, generally considered as particulates with a diameter
less than or equal to 0.1 [mu]m [typically based on physical size,
thermal diffusivity or electrical mobility])), ``fine'' particles
(PM2.5; particles with a nominal mean aerodynamic diameter
less than or equal to 2.5 [mu]m), and ``thoracic'' particles
(PM10; particles with a nominal mean aerodynamic diameter
less than or equal to 10 [mu]m).\570\ Particles that fall within the
size range between PM2.5 and PM10, are referred
to as ``thoracic coarse particles'' (PM10-2.5, particles
with a nominal mean aerodynamic diameter less than or equal to 10 [mu]m
and greater than 2.5 [mu]m). EPA currently has standards that regulate
PM2.5 and PM10.\571\
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\570\ U.S. EPA. (2009). Integrated Science Assessment for
Particulate Matter (Final Report). U.S. Environmental Protection
Agency, Washington, DC, EPA/600/R-08/139F. Figure 3-1.
\571\ Regulatory definitions of PM size fractions, and
information on reference and equivalent methods for measuring PM in
ambient air, are provided in 40 CFR parts 50, 53, and 58. With
regard to national ambient air quality standards (NAAQS) which
provide protection against health and welfare effects, the 24-hour
PM10 standard provides protection against effects
associated with short-term exposure to thoracic coarse particles
(i.e., PM10-2.5).
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Particles span many sizes and shapes and may consist of hundreds of
different chemicals. Particles are emitted directly from sources and
are also formed through atmospheric chemical reactions; the former are
often referred to as ``primary'' particles, and the latter as
``secondary'' particles. Particle concentration and composition varies
by time of year and location, and, in addition to differences in source
emissions, is affected by several weather-related factors, such as
temperature, clouds, humidity, and wind. A further layer of complexity
comes from particles' ability to shift between solid/liquid and gaseous
phases, which is influenced by concentration and meteorology,
especially temperature.
Fine particles are produced primarily by combustion processes and
by transformations of gaseous emissions (e.g., sulfur oxides
(SOX), oxides of nitrogen, and volatile organic compounds
(VOC)) in the atmosphere. The chemical and physical properties of
PM2.5 may vary greatly with time, region, meteorology, and
source category. Thus, PM2.5 may include a complex mixture
of different components including sulfates, nitrates, organic
compounds, elemental carbon and metal compounds. These particles can
remain in the atmosphere for days to weeks and travel hundreds to
thousands of kilometers.
(b) Health Effects of PM
Scientific studies show exposure to ambient PM is associated with a
broad range of health effects. These health effects are discussed in
detail in the Integrated Science Assessment for Particulate Matter (PM
ISA), which was finalized in December 2009.\572\ The PM ISA summarizes
health effects evidence for short- and long-term exposures to
PM2.5, PM10-2.5, and ultrafine particles.\573\
The PM ISA concludes that human exposures to ambient PM2.5
are associated with a number of adverse health effects and
characterizes the weight of evidence for broad health categories (e.g.,
cardiovascular effects, respiratory effects, etc.).\574\ The discussion
below highlights the PM ISA's conclusions pertaining to health effects
associated with both short- and long-term PM exposures. Further
discussion of health effects associated with PM can also be found in
the rulemaking documents for the most recent review of the PM NAAQS
completed in 2012.575 576
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\572\ U.S. EPA. (2009). Integrated Science Assessment for
Particulate Matter (Final Report). U.S. Environmental Protection
Agency, Washington, DC, EPA/600/R-08/139F.
\573\ The ISA also evaluated evidence for PM components but did
not reach causal determinations for components.
\574\ The causal framework draws upon the assessment and
integration of evidence from across epidemiological, controlled
human exposure, and toxicological studies, and the related
uncertainties that ultimately influence our understanding of the
evidence. This framework employs a five-level hierarchy that
classifies the overall weight of evidence and causality using the
following categorizations: causal relationship, likely to be causal
relationship, suggestive of a causal relationship, inadequate to
infer a causal relationship, and not likely to be a causal
relationship (U.S. EPA. (2009). Integrated Science Assessment for
Particulate Matter (Final Report). U.S. Environmental Protection
Agency, Washington, DC, EPA/600/R-08/139F, Table 1-3).
\575\ 78 FR 3103-3104, January 15, 2013.
\576\ 77 FR 38906-38911, June 29, 2012.
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EPA has concluded that ``a causal relationship exists'' between
both long- and short-term exposures to PM2.5 and premature
mortality and cardiovascular effects and that ``a causal relationship
is likely to exist'' between long- and short-term PM2.5
exposures and respiratory effects. Further, there is evidence
``suggestive of a causal relationship'' between long-term
PM2.5 exposures and other health effects, including
developmental and reproductive effects (e.g., low birth weight, infant
mortality) and carcinogenic, mutagenic, and genotoxic effects (e.g.,
lung cancer mortality).\577\
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\577\ These causal inferences are based not only on the more
expansive epidemiological evidence available in this review but also
reflect consideration of important progress that has been made to
advance our understanding of a number of potential biologic modes of
action or pathways for PM-related cardiovascular and respiratory
effects (U.S. EPA. (2009). Integrated Science Assessment for
Particulate Matter (Final Report). U.S. Environmental Protection
Agency, Washington, DC, EPA/600/R-08/139F, Chapter 5).
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As summarized in the final rule resulting from the last review
(2012) of the PM NAAQS, and discussed extensively in the 2009 p.m. ISA,
the available scientific evidence significantly strengthens the link
between long- and short-term exposure to PM2.5 and
mortality, while providing indications that the magnitude of the
PM2.5- mortality association with long-term exposures may be
larger than previously estimated.578 579 The strongest
evidence comes from recent
[[Page 73837]]
studies investigating long-term exposure to PM2.5 and
cardiovascular-related mortality. The evidence supporting a causal
relationship between long-term PM2.5 exposure and mortality
also includes consideration of studies that demonstrated an improvement
in community health following reductions in ambient fine particles.
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\578\ 78 FR 3103-3104, January 15, 2013.
\579\ U.S. EPA. (2009). Integrated Science Assessment for
Particulate Matter (Final Report). U.S. Environmental Protection
Agency, Washington, DC, EPA/600/R-08/139F, Chapter 6 (Section 6.5)
and Chapter 7 (Section 7.6).
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Several studies evaluated in the 2009 p.m. ISA have examined the
association between cardiovascular effects and long-term
PM2.5 exposures in multi-city epidemiological studies
conducted in the U.S. and Europe. These studies have provided new
evidence linking long-term exposure to PM2.5 with an array
of cardiovascular effects such as heart attacks, congestive heart
failure, stroke, and mortality. This evidence is coherent with studies
of effects associated with short-term exposure to PM2.5 that
have observed associations with a continuum of effects ranging from
subtle changes in indicators of cardiovascular health to serious
clinical events, such as increased hospitalizations and emergency
department visits due to cardiovascular disease and cardiovascular
mortality.\580\
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\580\ U.S. EPA. (2009). Integrated Science Assessment for
Particulate Matter (Final Report). U.S. Environmental Protection
Agency, Washington, DC, EPA/600/R-08/139F, Chapter 2 (Section 2.3.1
and 2.3.2) and Chapter 6.
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As detailed in the 2009 p.m. ISA, extended analyses of seminal
epidemiological studies, as well as more recent epidemiological studies
conducted in the U.S. and abroad, provide strong evidence of
respiratory-related morbidity effects associated with long-term
PM2.5 exposure. The strongest evidence for respiratory-
related effects is from studies that evaluated decrements in lung
function growth (in children), increased respiratory symptoms, and
asthma development. The strongest evidence from short-term
PM2.5 exposure studies has been observed for increased
respiratory-related emergency department visits and hospital admissions
for chronic obstructive pulmonary disease (COPD) and respiratory
infections.\581\
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\581\ U.S. EPA. (2009). Integrated Science Assessment for
Particulate Matter (Final Report). U.S. Environmental Protection
Agency, Washington, DC, EPA/600/R-08/139F, Chapter 2 (Section 2.3.1
and 2.3.2) and Chapter 6.
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The body of scientific evidence detailed in the 2009 PM ISA is
still limited with respect to associations between long-term
PM2.5 exposures and developmental and reproductive effects
as well as cancer, mutagenic, and genotoxic effects. The strongest
evidence for an association between PM2.5 and developmental
and reproductive effects comes from epidemiological studies of low
birth weight and infant mortality, especially due to respiratory causes
during the post-neonatal period (i.e., 1 month to 12 months of
age).\582\ With regard to cancer effects, ``[m]ultiple epidemiologic
studies have shown a consistent positive association between
PM2.5 and lung cancer mortality, but studies have generally
not reported associations between PM2.5 and lung cancer
incidence.'' \583\
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\582\ U.S. EPA. (2009). Integrated Science Assessment for
Particulate Matter (Final Report). U.S. Environmental Protection
Agency, Washington, DC, EPA/600/R-08/139F, Chapter 2 (Section 2.3.1
and 2.3.2) and Chapter 7.
\583\ U.S. EPA. (2009). Integrated Science Assessment for
Particulate Matter (Final Report). U.S. Environmental Protection
Agency, Washington, DC, EPA/600/R-08/139F. pg 2-13.
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In addition to evaluating the health effects attributed to short-
and long-term exposure to PM2.5, the 2009 PM ISA also
evaluated whether specific components or sources of PM2.5
are more strongly associated with specific health effects. An
evaluation of those studies resulted in the 2009 PM ISA concluding that
``many [components] of PM can be linked with differing health effects
and the evidence is not yet sufficient to allow differentiation of
those [components] or sources that are more closely related to specific
health outcomes.'' \584\
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\584\ U.S. EPA. (2009). Integrated Science Assessment for
Particulate Matter (Final Report). U.S. Environmental Protection
Agency, Washington, DC, EPA/600/R-08/139F. pg 2-26.
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For PM10-2.5, the 2009 PM ISA concluded that available
evidence was ``suggestive of a causal relationship'' between short-term
exposures to PM10-2.5 and cardiovascular effects (e.g.,
hospital admissions and Emergency Department (ED) visits, changes in
cardiovascular function), respiratory effects (e.g., ED visits and
hospital admissions, increase in markers of pulmonary inflammation),
and premature mortality. The scientific evidence was ``inadequate to
infer a causal relationship'' between long-term exposure to
PM10-2.5 and various health effects.585 586 587
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\585\ U.S. EPA. (2009). Integrated Science Assessment for
Particulate Matter (Final Report). U.S. Environmental Protection
Agency, Washington, DC, EPA/600/R-08/139F. Section 2.3.4 and Table
2-6.
\586\ 78 FR 3167-3168, January 15, 2013.
\587\ 77 FR 38947-38951, June 29, 2012.
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For UFPs, the 2009 PM ISA concluded that the evidence was
``suggestive of a causal relationship'' between short-term exposures
and cardiovascular effects, including changes in heart rhythm and
vasomotor function (the ability of blood vessels to expand and
contract). It also concluded that there was evidence ``suggestive of a
causal relationship'' between short-term exposure to UFPs and
respiratory effects, including lung function and pulmonary
inflammation, with limited and inconsistent evidence for increases in
ED visits and hospital admissions. Scientific evidence was ``inadequate
to infer a causal relationship'' between short-term exposure to UFPs
and additional health effects including premature mortality as well as
long-term exposure to UFPs and all health outcomes
evaluated.588 589
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\588\ U.S. EPA. (2009). Integrated Science Assessment for
Particulate Matter (Final Report). U.S. Environmental Protection
Agency, Washington, DC, EPA/600/R-08/139F. Section 2.3.5 and Table
2-6.
\589\ 78 FR 3121, January 15, 2013.
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The 2009 PM ISA conducted an evaluation of specific groups within
the general population potentially at increased risk for experiencing
adverse health effects related to PM
exposures.590 591 592 593 The evidence detailed in the 2009
PM ISA expands our understanding of previously identified at-risk
populations and lifestages (i.e., children, older adults, and
individuals with pre-existing heart and lung disease) and supports the
identification of additional at-risk populations (e.g., persons with
lower socioeconomic status, genetic differences). Additionally, there
is emerging, though still limited, evidence for additional potentially
at-risk populations and lifestages, such as those with diabetes, people
who are obese, pregnant women, and the developing fetus.\594\
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\590\ U.S. EPA. (2009). Integrated Science Assessment for
Particulate Matter (Final Report). U.S. Environmental Protection
Agency, Washington, DC, EPA/600/R-08/139F. Chapter 8 and Chapter 2.
\591\ 77 FR 38890, June 29, 2012.
\592\ 78 FR 3104, January 15, 2013.
\593\ U.S. EPA. (2011). Policy Assessment for the Review of the
PM NAAQS. U.S. Environmental Protection Agency, Washington, DC, EPA/
452/R-11-003. Section 2.2.1.
\594\ U.S. EPA. (2009). Integrated Science Assessment for
Particulate Matter (Final Report). U.S. Environmental Protection
Agency, Washington, DC, EPA/600/R-08/139F. Chapter 8 and Chapter 2
(Section 2.4.1).
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(2) Ozone
(a) Background
Ground-level ozone pollution is typically formed through reactions
involving VOC and NOX in the lower atmosphere in the
presence of sunlight. These pollutants, often referred to as ozone
precursors, are emitted by many types of pollution sources, such as
highway and nonroad motor vehicles and engines, power plants, chemical
[[Page 73838]]
plants, refineries, makers of consumer and commercial products,
industrial facilities, and smaller area sources.
The science of ozone formation, transport, and accumulation is
complex. Ground-level ozone is produced and destroyed in a cyclical set
of chemical reactions, many of which are sensitive to temperature and
sunlight. When ambient temperatures and sunlight levels remain high for
several days and the air is relatively stagnant, ozone and its
precursors can build up and result in more ozone than typically occurs
on a single high-temperature day. Ozone and its precursors can be
transported hundreds of miles downwind from precursor emissions,
resulting in elevated ozone levels even in areas with low local VOC or
NOX emissions.
(b) Health Effects of Ozone
This section provides a summary of the health effects associated
with exposure to ambient concentrations of ozone.\595\ The information
in this section is based on the information and conclusions in the
February 2013 Integrated Science Assessment for Ozone (Ozone ISA),
which formed the basis for EPA's revision to the primary and secondary
standards in 2015.\596\ The Ozone ISA concludes that human exposures to
ambient concentrations of ozone are associated with a number of adverse
health effects and characterizes the weight of evidence for these
health effects.\597\ The discussion below highlights the Ozone ISA's
conclusions pertaining to health effects associated with both short-
term and long-term periods of exposure to ozone.
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\595\ Human exposure to ozone varies over time due to changes in
ambient ozone concentration and because people move between
locations which have notable different ozone concentrations. Also,
the amount of ozone delivered to the lung is not only influenced by
the ambient concentrations but also by the individuals breathing
route and rate.
\596\ U.S. EPA. Integrated Science Assessment of Ozone and
Related Photochemical Oxidants (Final Report). U.S. Environmental
Protection Agency, Washington, DC, EPA/600/R-10/076F, 2013. The ISA
is available at http://cfpub.epa.gov/ncea/isa/recordisplay.cfm?deid=247492#Download.
\597\ The ISA evaluates evidence and draws conclusions on the
causal nature of relationship between relevant pollutant exposures
and health effects, assigning one of five ``weight of evidence''
determinations: causal relationship, likely to be a causal
relationship, suggestive of, but not sufficient to infer, a causal
relationship, inadequate to infer a causal relationship, and not
likely to be a causal relationship. For more information on these
levels of evidence, please refer to Table II in the Preamble of the
ISA.
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For short-term exposure to ozone, the Ozone ISA concludes that
respiratory effects, including lung function decrements, pulmonary
inflammation, exacerbation of asthma, respiratory-related hospital
admissions, and mortality, are causally associated with ozone exposure.
It also concludes that cardiovascular effects, including decreased
cardiac function and increased vascular disease, and total mortality
are likely to be causally associated with short-term exposure to ozone
and that evidence is suggestive of a causal relationship between
central nervous system effects and short-term exposure to ozone.
For long-term exposure to ozone, the Ozone ISA concludes that
respiratory effects, including new onset asthma, pulmonary inflammation
and injury, are likely to be causally related with ozone exposure. The
Ozone ISA characterizes the evidence as suggestive of a causal
relationship for associations between long-term ozone exposure and
cardiovascular effects, reproductive and developmental effects, central
nervous system effects and total mortality. The evidence is inadequate
to infer a causal relationship between chronic ozone exposure and
increased risk of lung cancer.
Finally, inter-individual variation in human responses to ozone
exposure can result in some groups being at increased risk for
detrimental effects in response to exposure. In addition, some groups
are at increased risk of exposure due to their activities, such as
outdoor workers or children. The Ozone ISA identified several groups
that are at increased risk for ozone-related health effects. These
groups are people with asthma, children and older adults, individuals
with reduced intake of certain nutrients (i.e., Vitamins C and E),
outdoor workers, and individuals having certain genetic variants
related to oxidative metabolism or inflammation. Ozone exposure during
childhood can have lasting effects through adulthood. Such effects
include altered function of the respiratory and immune systems.
Children absorb higher doses (normalized to lung surface area) of
ambient ozone, compared to adults, due to their increased time spent
outdoors, higher ventilation rates relative to body size, and a
tendency to breathe a greater fraction of air through the mouth.
Children also have a higher asthma prevalence compared to adults.
Additional children's vulnerability and susceptibility factors are
listed in Section XIV.
(3) Nitrogen Oxides
(a) Background
Oxides of nitrogen (NOX) refers to nitric oxide and
nitrogen dioxide (NO2). For the NOX NAAQS,
NO2 is the indicator. Most NO2 is formed in the
air through the oxidation of nitric oxide (NO) emitted when fuel is
burned at a high temperature. NOX is also a major
contributor to secondary PM2.5 formation. The health effects
of ambient PM are discussed in Section VIII.A.1.b of this Preamble.
NOX and VOC are the two major precursors of ozone. The
health effects of ozone are covered in Section VIII.A.2.b.
(b) Health Effects of Nitrogen Oxides
The most recent review of the health effects of oxides of nitrogen
completed by EPA can be found in the 2016 Integrated Science Assessment
for Oxides of Nitrogen--Health Criteria (Oxides of Nitrogen ISA).\598\
The primary source of NO2 is motor vehicle emissions, and
ambient NO2 concentrations tend to be highly correlated with
other traffic-related pollutants. Thus, a key issue in characterizing
the causality of NO2-health effect relationships was
evaluating the extent to which studies supported an effect of
NO2 that is independent of other traffic-related pollutants.
EPA concluded that the findings for asthma exacerbation integrated from
epidemiologic and controlled human exposure studies provided evidence
that is sufficient to infer a causal relationship between respiratory
effects and short-term NO2 exposure. The strongest evidence
supporting an independent effect of NO2 exposure comes from
controlled human exposure studies demonstrating increased airway
responsiveness in individuals with asthma following ambient-relevant
NO2 exposures. The coherence of this evidence with
epidemiologic findings for asthma hospital admissions and ED visits as
well as lung function decrements and increased pulmonary inflammation
in children with asthma describe a plausible pathway by which
NO2 exposure can cause an asthma exacerbation. The 2016 ISA
for Oxides of Nitrogen also concluded that there is likely to be a
causal relationship between long-term NO2 exposure and
respiratory effects. This conclusion is based on new epidemiologic
evidence for associations of NO2 with asthma development in
children combined with biological plausibility from experimental
studies.
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\598\ U.S. EPA. Integrated Science Assessment for Oxides of
Nitrogen--Health Criteria (2016 Final Report). U.S. Environmental
Protection Agency, Washington, DC, EPA/600/R-15/068, 2016.
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In evaluating a broader range of health effects, the 2016 ISA for
Oxides of Nitrogen concluded evidence is ``suggestive of, but not
sufficient to infer, a causal relationship'' between
[[Page 73839]]
short-term NO2 exposure and cardiovascular effects and
mortality and between long-term NO2 exposure and
cardiovascular effects and diabetes, birth outcomes, and cancer. In
addition, the scientific evidence is inadequate (insufficient
consistency of epidemiologic and toxicological evidence) to infer a
causal relationship for long-term NO2 exposure with
fertility, reproduction, and pregnancy, as well as with postnatal
development. A key uncertainty in understanding the relationship
between these non-respiratory health effects and short- or long-term
exposure to NO2 is copollutant confounding, particularly by
other roadway pollutants. The available evidence for non-respiratory
health effects does not adequately address whether NO2 has
an independent effect or whether it primarily represents effects
related to other or a mixture of traffic-related pollutants.
The 2016 ISA for Oxides of Nitrogen concluded that people with
asthma, children, and older adults are at increased risk for
NO2-related health effects. In these groups and lifestages,
NO2 is consistently related to larger effects on outcomes
related to asthma exacerbation, for which there is confidence in the
relationship with NO2 exposure.
(4) Sulfur Oxides
(a) Background
Sulfur dioxide (SO2), a member of the sulfur oxide
(SOX) family of gases, is formed from burning fuels
containing sulfur (e.g., coal or oil derived), extracting gasoline from
oil, or extracting metals from ore. SO2 and its gas phase
oxidation products can dissolve in water droplets and further oxidize
to form sulfuric acid which reacts with ammonia to form sulfates, which
are important components of ambient PM. The health effects of ambient
PM are discussed in Section VIII.A.1.b of this Preamble.
(b) Health Effects of SO2
Information on the health effects of SO2 can be found in
the 2008 Integrated Science Assessment for Sulfur Oxides--Health
Criteria (SOX ISA).\599\ Short-term peaks (5-10 minutes) of
SO2 have long been known to cause adverse respiratory health
effects, particularly among individuals with asthma. In addition to
those with asthma (both children and adults), potentially at-risk
lifestages include all children and the elderly. During periods of
elevated ventilation, asthmatics may experience symptomatic
bronchoconstriction within minutes of exposure. Following an extensive
evaluation of health evidence from epidemiologic and laboratory
studies, EPA concluded that there is a causal relationship between
respiratory health effects and short-term exposure to SO2.
Separately, based on an evaluation of the epidemiologic evidence of
associations between short-term exposure to SO2 and
mortality, EPA concluded that the overall evidence is suggestive of a
causal relationship between short-term exposure to SO2 and
mortality. Additional information on the health effects of
SO2 is available in Chapter 6.1.1.4.2 of the RIA.
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\599\ U.S. EPA. (2008). Integrated Science Assessment (ISA) for
Sulfur Oxides--Health Criteria (Final Report). EPA/600/R-08/047F.
Washington, DC: U.S. Environmental Protection Agency.
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(5) Carbon Monoxide
(a) Background
Carbon monoxide (CO) is a colorless, odorless gas emitted from
combustion processes. Nationally, particularly in urban areas, the
majority of CO emissions to ambient air come from mobile sources.\600\
---------------------------------------------------------------------------
\600\ U.S. EPA, (2010). Integrated Science Assessment for Carbon
Monoxide (Final Report). U.S. Environmental Protection Agency,
Washington, DC, EPA/600/R-09/019F, 2010. Available at http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=218686. See Section
2.1.
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(b) Health Effects of Carbon Monoxide
Information on the health effects of CO can be found in the January
2010 Integrated Science Assessment for Carbon Monoxide (CO ISA).\601\
The CO ISA presents conclusions regarding the presence of causal
relationships between CO exposure and categories of adverse health
effects.\602\ This section provides a summary of the health effects
associated with exposure to ambient concentrations of CO, along with
the ISA conclusions.\603\
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\601\ U.S. EPA, (2010). Integrated Science Assessment for Carbon
Monoxide (Final Report). U.S. Environmental Protection Agency,
Washington, DC, EPA/600/R-09/019F, 2010. Available at http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=218686.
\602\ The ISA evaluates the health evidence associated with
different health effects, assigning one of five ``weight of
evidence'' determinations: causal relationship, likely to be a
causal relationship, suggestive of a causal relationship, inadequate
to infer a causal relationship, and not likely to be a causal
relationship. For definitions of these levels of evidence, please
refer to Section 1.6 of the ISA.
\603\ Personal exposure includes contributions from many
sources, and in many different environments. Total personal exposure
to CO includes both ambient and nonambient components; and both
components may contribute to adverse health effects.
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Controlled human exposure studies of subjects with coronary artery
disease show a decrease in the time to onset of exercise-induced angina
(chest pain) and electrocardiogram changes following CO exposure. In
addition, epidemiologic studies observed associations between short-
term CO exposure and cardiovascular morbidity, particularly increased
emergency room visits and hospital admissions for coronary heart
disease (including ischemic heart disease, myocardial infarction, and
angina). Some epidemiologic evidence is also available for increased
hospital admissions and emergency room visits for congestive heart
failure and cardiovascular disease as a whole. The CO ISA concludes
that a causal relationship is likely to exist between short-term
exposures to CO and cardiovascular morbidity. It also concludes that
available data are inadequate to conclude that a causal relationship
exists between long-term exposures to CO and cardiovascular morbidity.
Animal studies show various neurological effects with in-utero CO
exposure. Controlled human exposure studies report central nervous
system and behavioral effects following low-level CO exposures,
although the findings have not been consistent across all studies. The
CO ISA concludes the evidence is suggestive of a causal relationship
with both short- and long-term exposure to CO and central nervous
system effects.
A number of studies cited in the CO ISA have evaluated the role of
CO exposure in birth outcomes such as preterm birth or cardiac birth
defects. There is limited epidemiologic evidence of a CO-induced effect
on preterm births and birth defects, with weak evidence for a decrease
in birth weight. Animal toxicological studies have found perinatal CO
exposure to affect birth weight, as well as other developmental
outcomes. The CO ISA concludes the evidence is suggestive of a causal
relationship between long-term exposures to CO and developmental
effects and birth outcomes.
Epidemiologic studies provide evidence of associations between
short-term CO concentrations and respiratory morbidity such as changes
in pulmonary function, respiratory symptoms, and hospital admissions. A
limited number of epidemiologic studies considered copollutants such as
ozone, SO2, and PM in two-pollutant models and found that CO
risk estimates were generally robust, although this limited evidence
makes it difficult to disentangle effects attributed to CO itself from
those of the larger complex air pollution mixture. Controlled human
exposure studies have not extensively
[[Page 73840]]
evaluated the effect of CO on respiratory morbidity. Animal studies at
levels of 50-100 ppm CO show preliminary evidence of altered pulmonary
vascular remodeling and oxidative injury. The CO ISA concludes that the
evidence is suggestive of a causal relationship between short-term CO
exposure and respiratory morbidity, and inadequate to conclude that a
causal relationship exists between long-term exposure and respiratory
morbidity.
Finally, the CO ISA concludes that the epidemiologic evidence is
suggestive of a causal relationship between short-term concentrations
of CO and mortality. Epidemiologic evidence suggests an association
exists between short-term exposure to CO and mortality, but limited
evidence is available to evaluate cause-specific mortality outcomes
associated with CO exposure. In addition, the attenuation of CO risk
estimates which was often observed in copollutant models contributes to
the uncertainty as to whether CO is acting alone or as an indicator for
other combustion-related pollutants. The CO ISA also concludes that
there is not likely to be a causal relationship between relevant long-
term exposures to CO and mortality.
(6) Diesel Exhaust
(a) Background
Diesel exhaust consists of a complex mixture composed of
particulate matter, carbon dioxide, oxygen, nitrogen, water vapor,
carbon monoxide, nitrogen compounds, sulfur compounds and numerous low-
molecular-weight hydrocarbons. A number of these gaseous hydrocarbon
components are individually known to be toxic, including aldehydes,
benzene and 1,3-butadiene. The diesel particulate matter present in
diesel exhaust consists mostly of fine particles (<2.5 [mu]m), of which
a significant fraction is ultrafine particles (<0.1 [mu]m). These
particles have a large surface area which makes them an excellent
medium for adsorbing organics, and their small size makes them highly
respirable. Many of the organic compounds present in the gases and on
the particles, such as polycyclic organic matter, are individually
known to have mutagenic and carcinogenic properties.
Diesel exhaust varies significantly in chemical composition and
particle sizes between different engine types (heavy-duty, light-duty),
engine operating conditions (idle, acceleration, deceleration), and
fuel formulations (high/low sulfur fuel). Also, there are emissions
differences between on-road and nonroad engines because the nonroad
engines are generally of older technology. After being emitted in the
engine exhaust, diesel exhaust undergoes dilution as well as chemical
and physical changes in the atmosphere. The lifetime for some of the
compounds present in diesel exhaust ranges from hours to days.
(b) Health Effects of Diesel Exhaust
In EPA's 2002 Diesel Health Assessment Document (Diesel HAD),
exposure to diesel exhaust was classified as likely to be carcinogenic
to humans by inhalation from environmental exposures, in accordance
with the revised draft 1996/1999 EPA cancer
guidelines.604 605 A number of other agencies (National
Institute for Occupational Safety and Health, the International Agency
for Research on Cancer, the World Health Organization, California EPA,
and the U.S. Department of Health and Human Services) had made similar
hazard classifications prior to 2002. EPA also concluded in the 2002
Diesel HAD that it was not possible to calculate a cancer unit risk for
diesel exhaust due to limitations in the exposure data for the
occupational groups or the absence of a dose-response relationship.
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\604\ U.S. EPA. (1999). Guidelines for Carcinogen Risk
Assessment. Review Draft. NCEA-F-0644, July. Washington, DC: U.S.
EPA. Retrieved on March 19, 2009 from http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=54932.
\605\ U.S. EPA (2002). Health Assessment Document for Diesel
Engine Exhaust. EPA/600/8-90/057F Office of Research and
Development, Washington DC. Retrieved on March 17, 2009 from http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=29060. pp. 1-1 1-2.
---------------------------------------------------------------------------
In the absence of a cancer unit risk, the Diesel HAD sought to
provide additional insight into the significance of the diesel exhaust
cancer hazard by estimating possible ranges of risk that might be
present in the population. An exploratory analysis was used to
characterize a range of possible lung cancer risk. The outcome was that
environmental risks of cancer from long-term diesel exhaust exposures
could plausibly range from as low as 10-5 to as high as
10-3. Because of uncertainties, the analysis acknowledged
that the risks could be lower than 10-5, and a zero risk
from diesel exhaust exposure could not be ruled out.
Non-cancer health effects of acute and chronic exposure to diesel
exhaust emissions are also of concern to EPA. EPA derived a diesel
exhaust reference concentration (RfC) from consideration of four well-
conducted chronic rat inhalation studies showing adverse pulmonary
effects. The RfC is 5 [mu]g/m\3\ for diesel exhaust measured as diesel
particulate matter. This RfC does not consider allergenic effects such
as those associated with asthma or immunologic or the potential for
cardiac effects. There was emerging evidence in 2002, discussed in the
Diesel HAD, that exposure to diesel exhaust can exacerbate these
effects, but the exposure-response data were lacking at that time to
derive an RfC based on these then-emerging considerations. The EPA
Diesel HAD states, ``With [diesel particulate matter] being a
ubiquitous component of ambient PM, there is an uncertainty about the
adequacy of the existing [diesel exhaust] noncancer database to
identify all of the pertinent [diesel exhaust]-caused noncancer health
hazards.'' The Diesel HAD also notes ``that acute exposure to [diesel
exhaust] has been associated with irritation of the eye, nose, and
throat, respiratory symptoms (cough and phlegm), and neurophysiological
symptoms such as headache, lightheadedness, nausea, vomiting, and
numbness or tingling of the extremities.'' The Diesel HAD noted that
the cancer and noncancer hazard conclusions applied to the general use
of diesel engines then on the market and as cleaner engines replace a
substantial number of existing ones, the applicability of the
conclusions would need to be reevaluated.
It is important to note that the Diesel HAD also briefly summarizes
health effects associated with ambient PM and discusses EPA's then-
annual PM2.5 NAAQS of 15 [mu]g/m\3\. In 2012, EPA revised
the annual PM2.5 NAAQS to 12 [mu]g/m\3\. There is a large
and extensive body of human data showing a wide spectrum of adverse
health effects associated with exposure to ambient PM, of which diesel
exhaust is an important component. The PM2.5 NAAQS is
designed to provide protection from the noncancer health effects and
premature mortality attributed to exposure to PM2.5. The
contribution of diesel PM to total ambient PM varies in different
regions of the country and also, within a region, from one area to
another. The contribution can be high in near-roadway environments, for
example, or in other locations where diesel engine use is concentrated.
Since 2002, several new studies have been published which continue
to report increased lung cancer risk with occupational exposure to
diesel exhaust from older engines. Of particular note since 2011 are
three new epidemiology studies which have examined lung cancer in
occupational populations, for example, truck drivers, underground
nonmetal miners and other diesel
[[Page 73841]]
motor-related occupations. These studies reported increased risk of
lung cancer with exposure to diesel exhaust with evidence of positive
exposure-response relationships to varying
degrees.606 607 608 These newer studies (along with others
that have appeared in the scientific literature) add to the evidence
EPA evaluated in the 2002 Diesel HAD and further reinforces the concern
that diesel exhaust exposure likely poses a lung cancer hazard. The
findings from these newer studies do not necessarily apply to newer
technology diesel engines since the newer engines have large reductions
in the emission constituents compared to older technology diesel
engines.
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\606\ Garshick, Eric, Francine Laden, Jaime E. Hart, Mary E.
Davis, Ellen A. Eisen, and Thomas J. Smith. 2012. Lung cancer and
elemental carbon exposure in trucking industry workers.
Environmental Health Perspectives 120(9): 1301-1306.
\607\ Silverman, D. T., Samanic, C. M., Lubin, J. H., Blair, A.
E., Stewart, P. A., Vermeulen, R., & Attfield, M. D. (2012). The
diesel exhaust in miners study: A nested case-control study of lung
cancer and diesel exhaust. Journal of the National Cancer Institute.
\608\ Olsson, Ann C., et al. ``Exposure to diesel motor exhaust
and lung cancer risk in a pooled analysis from case-control studies
in Europe and Canada.'' American journal of respiratory and critical
care medicine 183.7 (2011): 941-948.
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In light of the growing body of scientific literature evaluating
the health effects of exposure to diesel exhaust, in June 2012 the
World Health Organization's International Agency for Research on Cancer
(IARC), a recognized international authority on the carcinogenic
potential of chemicals and other agents, evaluated the full range of
cancer-related health effects data for diesel engine exhaust. IARC
concluded that diesel exhaust should be regarded as ``carcinogenic to
humans.'' \609\ This designation was an update from its 1988 evaluation
that considered the evidence to be indicative of a ``probable human
carcinogen.''
---------------------------------------------------------------------------
\609\ IARC [International Agency for Research on Cancer].
(2013). Diesel and gasoline engine exhausts and some nitroarenes.
IARC Monographs Volume 105. [Online at http://monographs.iarc.fr/ENG/Monographs/vol105/index.php].
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(7) Air Toxics
(a) Background
Heavy-duty vehicle emissions contribute to ambient levels of air
toxics that are known or suspected human or animal carcinogens, or that
have noncancer health effects. The population experiences an elevated
risk of cancer and other noncancer health effects from exposure to the
class of pollutants known collectively as ``air toxics.'' \610\ These
compounds include, but are not limited to, benzene, 1,3-butadiene,
formaldehyde, acetaldehyde, acrolein, polycyclic organic matter, and
naphthalene. These compounds were identified as national or regional
risk drivers or contributors in the 2011 National-scale Air Toxics
Assessment and have significant inventory contributions from mobile
sources.\611\
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\610\ U.S. EPA. (2015) Summary of Results for the 2011 National-
Scale Assessment. http://www3.epa.gov/sites/production/files/2015-12/documents/2011-nata-summary-results.pdf.
\611\ U.S. EPA (2015) 2011 National Air Toxics Assessment.
http://www3.epa.gov/national-air-toxics-assessment/2011-national-air-toxics-assessment.
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(b) Benzene
EPA's Integrated Risk Information System (IRIS) database lists
benzene as a known human carcinogen (causing leukemia) by all routes of
exposure, and concludes that exposure is associated with additional
health effects, including genetic changes in both humans and animals
and increased proliferation of bone marrow cells in
mice.612 613 614 EPA states in its IRIS database that data
indicate a causal relationship between benzene exposure and acute
lymphocytic leukemia and suggest a relationship between benzene
exposure and chronic non-lymphocytic leukemia and chronic lymphocytic
leukemia. EPA's IRIS documentation for benzene also lists a range of
2.2 x 10-6 to 7.8 x 10-6 per [mu]g/m\3\ as the
unit risk estimate (URE) for benzene.615 616 The
International Agency for Research on Cancer (IARC) has determined that
benzene is a human carcinogen and the U.S. Department of Health and
Human Services (DHHS) has characterized benzene as a known human
carcinogen.617 618
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\612\ U.S. EPA. (2000). Integrated Risk Information System File
for Benzene. This material is available electronically at: http://www3.epa.gov/iris/subst/0276.htm.
\613\ International Agency for Research on Cancer, IARC
monographs on the evaluation of carcinogenic risk of chemicals to
humans, Volume 29, some industrial chemicals and dyestuffs,
International Agency for Research on Cancer, World Health
Organization, Lyon, France 1982.
\614\ Irons, R.D.; Stillman, W.S.; Colagiovanni, D.B.; Henry,
V.A. (1992). Synergistic action of the benzene metabolite
hydroquinone on myelopoietic stimulating activity of granulocyte/
macrophage colony-stimulating factor in vitro, Proc. Natl. Acad.
Sci. 89:3691-3695.
\615\ A unit risk estimate is defined as the increase in the
lifetime risk of an individual who is exposed for a lifetime to 1
[mu]g/m3 benzene in air.
\616\ U.S. EPA. (2000). Integrated Risk Information System File
for Benzene. This material is available electronically at: http://www3.epa.gov/iris/subst/0276.htm.
\617\ International Agency for Research on Cancer (IARC).
(1987). Monographs on the evaluation of carcinogenic risk of
chemicals to humans, Volume 29, Supplement 7, Some industrial
chemicals and dyestuffs, World Health Organization, Lyon, France.
\618\ NTP. (2014). 13th Report on Carcinogens. Research Triangle
Park, NC: U.S. Department of Health and Human Services, Public
Health Service, National Toxicology Program.
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A number of adverse noncancer health effects including blood
disorders, such as pre- leukemia and aplastic anemia, have also been
associated with long-term exposure to benzene.619 620 The
most sensitive noncancer effect observed in humans, based on current
data, is the depression of the absolute lymphocyte count in
blood.621 622 EPA's inhalation reference concentration (RfC)
for benzene is 30 [mu]g/m\3\. The RfC is based on suppressed absolute
lymphocyte counts seen in humans under occupational exposure
conditions. In addition, recent work, including studies sponsored by
the Health Effects Institute, provides evidence that biochemical
responses are occurring at lower levels of benzene exposure than
previously known.623 624 625 626 EPA's IRIS program has not
yet evaluated these new data. EPA does not currently have an acute
reference concentration for benzene. The Agency for Toxic Substances
and Disease Registry (ATSDR) Minimal Risk Level (MRL) for acute
exposure to benzene is 29 [mu]g/m\3\ for 1-14 days
exposure.627 628
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\619\ Aksoy, M. (1989). Hematotoxicity and carcinogenicity of
benzene. Environ. Health Perspect. 82: 193-197.
\620\ Goldstein, B.D. (1988). Benzene toxicity. Occupational
medicine. State of the Art Reviews. 3: 541-554.
\621\ Rothman, N., G.L. Li, M. Dosemeci, W.E. Bechtold, G.E.
Marti, Y.Z. Wang, M. Linet, L.Q. Xi, W. Lu, M.T. Smith, N. Titenko-
Holland, L.P. Zhang, W. Blot, S.N. Yin, and R.B. Hayes. (1996).
Hematotoxicity among Chinese workers heavily exposed to benzene. Am.
J. Ind. Med. 29: 236-246.
\622\ U.S. EPA. (2002). Toxicological Review of Benzene
(Noncancer Effects). Environmental Protection Agency, Integrated
Risk Information System (IRIS), Research and Development, National
Center for Environmental Assessment, Washington DC. This material is
available electronically at http://www3.epa.gov/iris/subst/0276.htm.
\623\ Qu, O.; Shore, R.; Li, G.; Jin, X.; Chen, C.L.; Cohen, B.;
Melikian, A.; Eastmond, D.; Rappaport, S.; Li, H.; Rupa, D.;
Suramaya, R.; Songnian, W.; Huifant, Y.; Meng, M.; Winnik, M.; Kwok,
E.; Li, Y.; Mu, R.; Xu, B.; Zhang, X.; Li, K. (2003). HEI Report
115, Validation & Evaluation of Biomarkers in Workers Exposed to
Benzene in China.
\624\ Qu, Q., R. Shore, G. Li, X. Jin, L.C. Chen, B. Cohen, et
al. (2002). Hematological changes among Chinese workers with a broad
range of benzene exposures. Am. J. Industr. Med. 42: 275-285.
\625\ Lan, Qing, Zhang, L., Li, G., Vermeulen, R., et al.
(2004). Hematotoxically in Workers Exposed to Low Levels of Benzene.
Science 306: 1774-1776.
\626\ Turtletaub, K.W. and Mani, C. (2003). Benzene metabolism
in rodents at doses relevant to human exposure from Urban Air.
Research Reports Health Effect Inst. Report No.113.
\627\ U.S. Agency for Toxic Substances and Disease Registry
(ATSDR). (2007). Toxicological profile for benzene. Atlanta, GA:
U.S. Department of Health and Human Services, Public Health Service.
http://www.atsdr.cdc.gov/ToxProfiles/tp3.pdf.
\628\ A minimal risk level (MRL) is defined as an estimate of
the daily human exposure to a hazardous substance that is likely to
be without appreciable risk of adverse noncancer health effects over
a specified duration of exposure.
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[[Page 73842]]
(c) 1,3-Butadiene
EPA has characterized 1,3-butadiene as carcinogenic to humans by
inhalation.629 630 The IARC has determined that 1,3-
butadiene is a human carcinogen and the U.S. DHHS has characterized
1,3-butadiene as a known human carcinogen.631 632 633 There
are numerous studies consistently demonstrating that 1,3-butadiene is
metabolized into genotoxic metabolites by experimental animals and
humans. The specific mechanisms of 1,3-butadiene-induced carcinogenesis
are unknown; however, the scientific evidence strongly suggests that
the carcinogenic effects are mediated by genotoxic metabolites. Animal
data suggest that females may be more sensitive than males for cancer
effects associated with 1,3-butadiene exposure; there are insufficient
data in humans from which to draw conclusions about sensitive
subpopulations. The URE for 1,3-butadiene is 3 x 10-5 per
[mu]g/m\3\.\634\ 1,3-butadiene also causes a variety of reproductive
and developmental effects in mice; no human data on these effects are
available. The most sensitive effect was ovarian atrophy observed in a
lifetime bioassay of female mice.\635\ Based on this critical effect
and the benchmark concentration methodology, an RfC for chronic health
effects was calculated at 0.9 ppb (approximately 2 [mu]g/m\3\).
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\629\ U.S. EPA. (2002). Health Assessment of 1,3-Butadiene.
Office of Research and Development, National Center for
Environmental Assessment, Washington Office, Washington, DC. Report
No. EPA600-P-98-001F. This document is available electronically at
http://www3.epa.gov/iris/supdocs/buta-sup.pdf.
\630\ U.S. EPA. (2002). ``Full IRIS Summary for 1,3-butadiene
(CASRN 106-99-0)'' Environmental Protection Agency, Integrated Risk
Information System (IRIS), Research and Development, National Center
for Environmental Assessment, Washington, DC http://www3.epa.gov/iris/subst/0139.htm.
\631\ International Agency for Research on Cancer (IARC).
(1999). Monographs on the evaluation of carcinogenic risk of
chemicals to humans, Volume 71, Re-evaluation of some organic
chemicals, hydrazine and hydrogen peroxide and Volume 97 (in
preparation), World Health Organization, Lyon, France.
\632\ International Agency for Research on Cancer (IARC).
(2008). Monographs on the evaluation of carcinogenic risk of
chemicals to humans, 1,3-Butadiene, Ethylene Oxide and Vinyl Halides
(Vinyl Fluoride, Vinyl Chloride and Vinyl Bromide) Volume 97, World
Health Organization, Lyon, France.
\633\ NTP. (2014). 13th Report on Carcinogens. Research Triangle
Park, NC: U.S. Department of Health and Human Services, Public
Health Service, National Toxicology Program.
\634\ U.S. EPA. (2002). ``Full IRIS Summary for 1,3-butadiene
(CASRN 106-99-0)'' Environmental Protection Agency, Integrated Risk
Information System (IRIS), Research and Development, National Center
for Environmental Assessment, Washington, DC http://www3.epa.gov/iris/subst/0139.htm.
\635\ Bevan, C.; Stadler, J.C.; Elliot, G.S.; et al. (1996).
Subchronic toxicity of 4-vinylcyclohexene in rats and mice by
inhalation. Fundam. Appl. Toxicol. 32:1-10.
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(d) Formaldehyde
In 1991, EPA concluded that formaldehyde is a carcinogen based on
nasal tumors in animal bioassays.\636\ An Inhalation URE for cancer and
a Reference Dose for oral noncancer effects were developed by the
agency and posted on the IRIS database. Since that time, the National
Toxicology Program (NTP) and International Agency for Research on
Cancer (IARC) have concluded that formaldehyde is a known human
carcinogen.637 638
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\636\ EPA. Integrated Risk Information System. Formaldehyde
(CASRN 50-00-0) http://www3.epa.gov/iris/subst/0419/htm.
\637\ NTP. (2014). 13th Report on Carcinogens. Research Triangle
Park, NC: U.S. Department of Health and Human Services, Public
Health Service, National Toxicology Program.
\638\ IARC Monographs on the Evaluation of Carcinogenic Risks to
Humans Volume 100F (2012): Formaldehyde.
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The conclusions by IARC and NTP reflect the results of
epidemiologic research published since 1991 in combination with
previous animal, human and mechanistic evidence. Research conducted by
the National Cancer Institute reported an increased risk of
nasopharyngeal cancer and specific lymph hematopoietic malignancies
among workers exposed to formaldehyde.639 640 641 A National
Institute of Occupational Safety and Health study of garment workers
also reported increased risk of death due to leukemia among workers
exposed to formaldehyde.\642\ Extended follow-up of a cohort of British
chemical workers did not report evidence of an increase in
nasopharyngeal or lymph hematopoietic cancers, but a continuing
statistically significant excess in lung cancers was reported.\643\
Finally, a study of embalmers reported formaldehyde exposures to be
associated with an increased risk of myeloid leukemia but not brain
cancer.\644\
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\639\ Hauptmann, M.; Lubin, J. H.; Stewart, P. A.; Hayes, R. B.;
Blair, A. 2003. Mortality from lymphohematopoetic malignancies among
workers in formaldehyde industries. Journal of the National Cancer
Institute 95: 1615-1623.
\640\ Hauptmann, M.; Lubin, J. H.; Stewart, P. A.; Hayes, R. B.;
Blair, A. 2004. Mortality from solid cancers among workers in
formaldehyde industries. American Journal of Epidemiology 159: 1117-
1130.
\641\ Beane Freeman, L. E.; Blair, A.; Lubin, J. H.; Stewart, P.
A.; Hayes, R. B.; Hoover, R. N.; Hauptmann, M. 2009. Mortality from
lymph hematopoietic malignancies among workers in formaldehyde
industries: The National Cancer Institute cohort. J. National Cancer
Inst. 101: 751-761.
\642\ Pinkerton, L. E. 2004. Mortality among a cohort of garment
workers exposed to formaldehyde: an update. Occup. Environ. Med. 61:
193-200.
\643\ Coggon, D, EC Harris, J Poole, KT Palmer. 2003. Extended
follow-up of a cohort of British chemical workers exposed to
formaldehyde. J National Cancer Inst. 95:1608-1615.
\644\ Hauptmann, M,; Stewart P. A.; Lubin J. H.; Beane Freeman,
L. E.; Hornung, R. W.; Herrick, R. F.; Hoover, R. N.; Fraumeni, J.
F.; Hayes, R. B. 2009. Mortality from lymph hematopoietic
malignancies and brain cancer among embalmers exposed to
formaldehyde. Journal of the National Cancer Institute 101:1696-
1708.
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Health effects of formaldehyde in addition to cancer were reviewed
by the Agency for Toxics Substances and Disease Registry in 1999 \645\,
supplemented in 2010,\646\ and by the World Health Organization.\647\
These organizations reviewed the scientific literature concerning
health effects linked to formaldehyde exposure to evaluate hazards and
dose response relationships and defined exposure concentrations for
minimal risk levels (MRLs). The health endpoints reviewed included
sensory irritation of eyes and respiratory tract, reduced pulmonary
function, nasal histopathology, and immune system effects. In addition,
research on reproductive and developmental effects and neurological
effects were discussed along with several studies that suggest that
formaldehyde may increase the risk of asthma--particularly in the
young.
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\645\ ATSDR. 1999. Toxicological Profile for Formaldehyde, U.S.
Department of Health and Human Services (HHS), July 1999.
\646\ ATSDR. 2010. Addendum to the Toxicological Profile for
Formaldehyde. U.S. Department of Health and Human Services (HHS),
October 2010.
\647\ IPCS. 2002. Concise International Chemical Assessment
Document 40. Formaldehyde. World Health Organization.
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EPA released a draft Toxicological Review of Formaldehyde--
Inhalation Assessment through the IRIS program for peer review by the
National Research Council (NRC) and public comment in June 2010.\648\
The draft assessment reviewed more recent research from animal and
human studies on cancer and other health effects. The NRC released
their review report in April 2011.\649\ EPA is currently developing a
revised draft assessment in response to this review.
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\648\ EPA (U.S. Environmental Protection Agency). 2010.
Toxicological Review of Formaldehyde (CAS No. 50-00-0)--Inhalation
Assessment: In Support of Summary Information on the Integrated Risk
Information System (IRIS). External Review Draft. EPA/635/R-10/002A.
U.S. Environmental Protection Agency, Washington DC [online].
Available: http://cfpub.epa.gov/ncea/irs_drats/recordisplay.cfm?deid=223614.
\649\ NRC (National Research Council). 2011. Review of the
Environmental Protection Agency's Draft IRIS Assessment of
Formaldehyde. Washington DC: National Academies Press. http://books.nap.edu/openbook.php?record_id=13142.
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[[Page 73843]]
(e) Acetaldehyde
Acetaldehyde is classified in EPA's IRIS database as a probable
human carcinogen, based on nasal tumors in rats, and is considered
toxic by the inhalation, oral, and intravenous routes.\650\ The URE in
IRIS for acetaldehyde is 2.2 x 10-6 per [mu]g/m\3\.\651\
Acetaldehyde is reasonably anticipated to be a human carcinogen by the
U.S. DHHS in the 13th Report on Carcinogens and is classified as
possibly carcinogenic to humans (Group 2B) by the
IARC.652 653 Acetaldehyde is currently listed on the IRIS
Program Multi-Year Agenda for reassessment within the next few years.
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\650\ U.S. EPA (1991). Integrated Risk Information System File
of Acetaldehyde. Research and Development, National Center for
Environmental Assessment, Washington, DC. This material is available
electronically at http://www3.epa.gov/iris/subst/0290.htm.
\651\ U.S. EPA (1991). Integrated Risk Information System File
of Acetaldehyde. This material is available electronically at http://www3.epa.gov/iris/subst/0290.htm.
\652\ NTP. (2014). 13th Report on Carcinogens. Research Triangle
Park, NC: U.S. Department of Health and Human Services, Public
Health Service, National Toxicology Program.
\653\ International Agency for Research on Cancer (IARC).
(1999). Re-evaluation of some organic chemicals, hydrazine, and
hydrogen peroxide. IARC Monographs on the Evaluation of Carcinogenic
Risk of Chemical to Humans, Vol 71. Lyon, France.
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The primary noncancer effects of exposure to acetaldehyde vapors
include irritation of the eyes, skin, and respiratory tract.\654\ In
short-term (4 week) rat studies, degeneration of olfactory epithelium
was observed at various concentration levels of acetaldehyde
exposure.655 656 Data from these studies were used by EPA to
develop an inhalation reference concentration of 9 [mu]g/m\3\. Some
asthmatics have been shown to be a sensitive subpopulation to
decrements in functional expiratory volume (FEV1 test) and
bronchoconstriction upon acetaldehyde inhalation.\657\
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\654\ U.S. EPA (1991). Integrated Risk Information System File
of Acetaldehyde. This material is available electronically at http://www3.epa.gov/iris/subst/0290.htm.
\655\ U.S. EPA. (2003). Integrated Risk Information System File
of Acrolein. Research and Development, National Center for
Environmental Assessment, Washington, DC. This material is available
electronically at http://www3.epa.gov/iris/subst/0364.htm.
\656\ Appleman, L.M., R.A. Woutersen, and V.J. Feron. (1982).
Inhalation toxicity of acetaldehyde in rats. I. Acute and subacute
studies. Toxicology. 23: 293-297.
\657\ Myou, S.; Fujimura, M.; Nishi K.; Ohka, T.; and Matsuda,
T. (1993) Aerosolized acetaldehyde induces histamine-mediated
bronchoconstriction in asthmatics. Am. Rev. Respir. Dis. 148(4 Pt
1): 940-943.
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(f) Acrolein
EPA most recently evaluated the toxicological and health effects
literature related to acrolein in 2003 and concluded that the human
carcinogenic potential of acrolein could not be determined because the
available data were inadequate. No information was available on the
carcinogenic effects of acrolein in humans and the animal data provided
inadequate evidence of carcinogenicity.\658\ The IARC determined in
1995 that acrolein was not classifiable as to its carcinogenicity in
humans.\659\
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\658\ U.S. EPA. (2003). Integrated Risk Information System File
of Acrolein. Research and Development, National Center for
Environmental Assessment, Washington, DC. This material is available
at http://www3.epa.gov/iris/subst/0364.htm.
\659\ International Agency for Research on Cancer (IARC).
(1995). Monographs on the evaluation of carcinogenic risk of
chemicals to humans, Volume 63. Dry cleaning, some chlorinated
solvents and other industrial chemicals, World Health Organization,
Lyon, France.
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Lesions to the lungs and upper respiratory tract of rats, rabbits,
and hamsters have been observed after subchronic exposure to
acrolein.\660\ The agency has developed an RfC for acrolein of 0.02
[mu]g/m\3\ and an RfD of 0.5 [mu]g/kg-day.\661\
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\660\ U.S. EPA. (2003). Integrated Risk Information System File
of Acrolein. Office of Research and Development, National Center for
Environmental Assessment, Washington, DC. This material is available
at http://www3.epa.gov/iris/subst/0364.htm.
\661\ U.S. EPA. (2003). Integrated Risk Information System File
of Acrolein. Office of Research and Development, National Center for
Environmental Assessment, Washington, DC. This material is available
at http://www3.epa.gov/iris/subst/0364.htm.
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Acrolein is extremely acrid and irritating to humans when inhaled,
with acute exposure resulting in upper respiratory tract irritation,
mucus hypersecretion and congestion. The intense irritancy of this
carbonyl has been demonstrated during controlled tests in human
subjects, who suffer intolerable eye and nasal mucosal sensory
reactions within minutes of exposure.\662\ These data and additional
studies regarding acute effects of human exposure to acrolein are
summarized in EPA's 2003 Toxicological Review of Acrolein.\663\ Studies
in humans indicate that levels as low as 0.09 ppm (0.21 mg/m\3\) for
five minutes may elicit subjective complaints of eye irritation with
increasing concentrations leading to more extensive eye, nose and
respiratory symptoms. Acute exposures in animal studies report
bronchial hyper-responsiveness. Based on animal data (more pronounced
respiratory irritancy in mice with allergic airway disease in
comparison to non-diseased mice) \664\ and demonstration of similar
effects in humans (e.g., reduction in respiratory rate), individuals
with compromised respiratory function (e.g., emphysema, asthma) are
expected to be at increased risk of developing adverse responses to
strong respiratory irritants such as acrolein. EPA does not currently
have an acute reference concentration for acrolein. The available
health effect reference values for acrolein have been summarized by EPA
and include an ATSDR MRL for acute exposure to acrolein of 7 [mu]g/m\3\
for 1-14 days exposure; and Reference Exposure Level (REL) values from
the California Office of Environmental Health Hazard Assessment (OEHHA)
for one-hour and 8-hour exposures of 2.5 [mu]g/m\3\ and 0.7 [mu]g/m\3\,
respectively.\665\
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\662\ U.S. EPA. (2003) Toxicological review of acrolein in
support of summary information on Integrated Risk Information System
(IRIS) National Center for Environmental Assessment, Washington, DC.
EPA/635/R-03/003. p. 10. Available online at: http://www3.epa.gov/ncea/iris/toxreviews/0364tr.pdf.
\663\ U.S. EPA. (2003) Toxicological review of acrolein in
support of summary information on Integrated Risk Information System
(IRIS) National Center for Environmental Assessment, Washington, DC.
EPA/635/R-03/003. Available online at: http://www3.epa.gov/ncea/iris/toxreviews/0364tr.pdf.
\664\ Morris JB, Symanowicz PT, Olsen JE, et al. (2003).
Immediate sensory nerve-mediated respiratory responses to irritants
in healthy and allergic airway-diseased mice. J Appl Physiol
94(4):1563-1571.
\665\ U.S. EPA. (2009). Graphical Arrays of Chemical-Specific
Health Effect Reference Values for Inhalation Exposures (Final
Report). U.S. Environmental Protection Agency, Washington, DC, EPA/
600/R-09/061, 2009. http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=211003.
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(g) Polycyclic Organic Matter
The term polycyclic organic matter (POM) defines a broad class of
compounds that includes the polycyclic aromatic hydrocarbon compounds
(PAHs). One of these compounds, naphthalene, is discussed separately
below. POM compounds are formed primarily from combustion and are
present in the atmosphere in gas and particulate form. Cancer is the
major concern from exposure to POM. Epidemiologic studies have reported
an increase in lung cancer in humans exposed to diesel exhaust, coke
oven emissions, roofing tar emissions, and cigarette smoke; all of
these mixtures contain POM compounds.666 667 Animal studies
have reported respiratory tract tumors from inhalation exposure to
[[Page 73844]]
benzo[a]pyrene and alimentary tract and liver tumors from oral exposure
to benzo[a]pyrene.\668\ In 1997 EPA classified seven PAHs
(benzo[a]pyrene, benz[a]anthracene, chrysene, benzo[b]fluoranthene,
benzo[k]fluoranthene, dibenz[a,h]anthracene, and indeno[1,2,3-
cd]pyrene) as Group B2, probable human carcinogens.\669\ Since that
time, studies have found that maternal exposures to PAHs in a
population of pregnant women were associated with several adverse birth
outcomes, including low birth weight and reduced length at birth, as
well as impaired cognitive development in preschool children (3 years
of age).670 671 These and similar studies are being
evaluated as a part of the ongoing IRIS reassessment of health effects
associated with exposure to benzo[a]pyrene.
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\666\ Agency for Toxic Substances and Disease Registry (ATSDR).
(1995). Toxicological profile for Polycyclic Aromatic Hydrocarbons
(PAHs). Atlanta, GA: U.S. Department of Health and Human Services,
Public Health Service. Available electronically at http://www.atsdr.cdc.gov/ToxProfiles/TP.asp?id=122&tid=25.
\667\ U.S. EPA (2002). Health Assessment Document for Diesel
Engine Exhaust. EPA/600/8-90/057F Office of Research and
Development, Washington DC. http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=29060.
\668\ International Agency for Research on Cancer (IARC).
(2012). Monographs on the Evaluation of the Carcinogenic Risk of
Chemicals for Humans, Chemical Agents and Related Occupations. Vol.
100F. Lyon, France.
\669\ U.S. EPA (1997). Integrated Risk Information System File
of indeno (1,2,3-cd) pyrene. Research and Development, National
Center for Environmental Assessment, Washington, DC. This material
is available electronically at http://www3.epa.gov/ncea/iris/subst/0457.htm.
\670\ Perera, F.P.; Rauh, V.; Tsai, W-Y.; et al. (2002). Effect
of transplacental exposure to environmental pollutants on birth
outcomes in a multiethnic population. Environ Health Perspect. 111:
201-205.
\671\ Perera, F.P.; Rauh, V.; Whyatt, R.M.; Tsai, W.Y.; Tang,
D.; Diaz, D.; Hoepner, L.; Barr, D.; Tu, Y.H.; Camann, D.; Kinney,
P. (2006). Effect of prenatal exposure to airborne polycyclic
aromatic hydrocarbons on neurodevelopment in the first 3 years of
life among inner-city children. Environ Health Perspect 114: 1287-
1292.
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(h) Naphthalene
Naphthalene is found in small quantities in gasoline and diesel
fuels. Naphthalene emissions have been measured in larger quantities in
both gasoline and diesel exhaust compared with evaporative emissions
from mobile sources, indicating it is primarily a product of
combustion. Acute (short-term) exposure of humans to naphthalene by
inhalation, ingestion, or dermal contact is associated with hemolytic
anemia and damage to the liver and the nervous system.\672\ Chronic
(long term) exposure of workers and rodents to naphthalene has been
reported to cause cataracts and retinal damage.\673\ EPA released an
external review draft of a reassessment of the inhalation
carcinogenicity of naphthalene based on a number of recent animal
carcinogenicity studies.\674\ The draft reassessment completed external
peer review.\675\ Based on external peer review comments received, a
revised draft assessment that considers all routes of exposure, as well
as cancer and noncancer effects, is under development. The external
review draft does not represent official agency opinion and was
released solely for the purposes of external peer review and public
comment. The National Toxicology Program listed naphthalene as
``reasonably anticipated to be a human carcinogen'' in 2004 on the
basis of bioassays reporting clear evidence of carcinogenicity in rats
and some evidence of carcinogenicity in mice.\676\ California EPA has
released a new risk assessment for naphthalene, and the IARC has
reevaluated naphthalene and re-classified it as Group 2B: possibly
carcinogenic to humans.\677\
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\672\ U. S. EPA. 1998. Toxicological Review of Naphthalene
(Reassessment of the Inhalation Cancer Risk), Environmental
Protection Agency, Integrated Risk Information System, Research and
Development, National Center for Environmental Assessment,
Washington, DC. This material is available electronically at http://www3.epa.gov/iris/subst/0436.htm.
\673\ U. S. EPA. 1998. Toxicological Review of Naphthalene
(Reassessment of the Inhalation Cancer Risk), Environmental
Protection Agency, Integrated Risk Information System, Research and
Development, National Center for Environmental Assessment,
Washington, DC. This material is available electronically at http://www3.epa.gov/iris/subst/0436.htm.
\674\ U. S. EPA. (1998). Toxicological Review of Naphthalene
(Reassessment of the Inhalation Cancer Risk), Environmental
Protection Agency, Integrated Risk Information System, Research and
Development, National Center for Environmental Assessment,
Washington, DC. This material is available electronically at http://www3.epa.gov/iris/subst/0436.htm.
\675\ Oak Ridge Institute for Science and Education. (2004).
External Peer Review for the IRIS Reassessment of the Inhalation
Carcinogenicity of Naphthalene. August 2004. http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=84403.
\676\ NTP. (2014). 13th Report on Carcinogens. U.S. Department
of Health and Human Services, Public Health Service, National
Toxicology Program.
\677\ International Agency for Research on Cancer (IARC).
(2002). Monographs on the Evaluation of the Carcinogenic Risk of
Chemicals for Humans. Vol. 82. Lyon, France.
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Naphthalene also causes a number of chronic non-cancer effects in
animals, including abnormal cell changes and growth in respiratory and
nasal tissues.\678\ The current EPA IRIS assessment includes noncancer
data on hyperplasia and metaplasia in nasal tissue that form the basis
of the inhalation RfC of 3 [mu]g/m\3\.\679\ The ATSDR MRL for acute
exposure to naphthalene is 0.6 mg/kg/day.
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\678\ U. S. EPA. (1998). Toxicological Review of Naphthalene,
Environmental Protection Agency, Integrated Risk Information System,
Research and Development, National Center for Environmental
Assessment, Washington, DC. This material is available
electronically at http://www3.epa.gov/iris/subst/0436.htm.
\679\ U.S. EPA. (1998). Toxicological Review of Naphthalene.
Environmental Protection Agency, Integrated Risk Information System
(IRIS), Research and Development, National Center for Environmental
Assessment, Washington, DC http://www3.epa.gov/iris/subst/0436.htm.
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(i) Other Air Toxics
In addition to the compounds described above, other compounds in
gaseous hydrocarbon and PM emissions from motor vehicles will be
affected by this action. Mobile source air toxic compounds that will
potentially be impacted include ethylbenzene, propionaldehyde, toluene,
and xylene. Information regarding the health effects of these compounds
can be found in EPA's IRIS database.\680\
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\680\ U.S. EPA Integrated Risk Information System (IRIS)
database is available at: www3.epa.gov/iris.
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(8) Exposure and Health Effects Associated With Traffic
Locations in close proximity to major roadways generally have
elevated concentrations of many air pollutants emitted from motor
vehicles. Hundreds of such studies have been published in peer-reviewed
journals, concluding that concentrations of CO, NO, NO2,
benzene, aldehydes, particulate matter, black carbon, and many other
compounds are elevated in ambient air within approximately 300-600
meters (about 1,000-2,000 feet) of major roadways. Highest
concentrations of most pollutants emitted directly by motor vehicles
are found at locations within 50 meters (about 165 feet) of the edge of
a roadway's traffic lanes.
A large-scale review of air quality measurements in the vicinity of
major roadways between 1978 and 2008 concluded that the pollutants with
the steepest concentration gradients in vicinities of roadways were CO,
ultrafine particles, metals, elemental carbon (EC), NO, NOX,
and several VOCs.\681\ These pollutants showed a large reduction in
concentrations within 100 meters downwind of the roadway. Pollutants
that showed more gradual reductions with distance from roadways
included benzene, NO2, PM2.5, and
PM10. In the review article, results varied based on the
method of statistical analysis used to determine the trend.
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\681\ Karner, A.A.; Eisinger, D.S.; Niemeier, D.A. (2010). Near-
roadway air quality: synthesizing the findings from real-world data.
Environ Sci Technol 44: 5334-5344.
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For pollutants with relatively high background concentrations
relative to near-road concentrations, detecting concentration gradients
can be difficult. For example, many aldehydes have high background
concentrations as a result of photochemical breakdown of precursors
from many different organic compounds. This can make detection of
gradients around roadways and other primary emission sources difficult.
[[Page 73845]]
However, several studies have measured aldehydes in multiple weather
conditions and found higher concentrations of many carbonyls downwind
of roadways.682 683 These findings suggest a substantial
roadway source of these carbonyls.
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\682\ Liu, W.; Zhang, J.; Kwon, J.L.; et al. (2006).
Concentrations and source characteristics of airborne carbonyl
comlbs measured outside urban residences. J Air Waste Manage Assoc
56: 1196-1204.
\683\ Cahill, T.M.; Charles, M.J.; Seaman, V.Y. (2010).
Development and application of a sensitive method to determine
concentrations of acrolein and other carbonyls in ambient air.
Health Effects Institute Research Report 149.Available at http://dx.doi.org.
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In the past 15 years, many studies have been published with results
reporting that populations who live, work, or go to school near high-
traffic roadways experience higher rates of numerous adverse health
effects, compared to populations far away from major roads.\684\ In
addition, numerous studies have found adverse health effects associated
with spending time in traffic, such as commuting or walking along high-
traffic roadways.685 686 687 688 The health outcomes with
the strongest evidence linking them with traffic-associated air
pollutants are respiratory effects, particularly in asthmatic children,
and cardiovascular effects.
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\684\ In the widely-used PubMed database of health publications,
between January 1, 1990 and August 18, 2011, 605 publications
contained the keywords ``traffic, pollution, epidemiology,'' with
approximately half the studies published after 2007.
\685\ Laden, F.; Hart, J.E.; Smith, T.J.; Davis, M.E.; Garshick,
E. (2007) Cause-specific mortality in the unionized U.S. trucking
industry. Environmental Health Perspect 115:1192-1196.
\686\ Peters, A.; von Klot, S.; Heier, M.; Trentinaglia, I.;
H[ouml]rmann, A.; Wichmann, H.E.; L[ouml]wel, H. (2004) Exposure to
traffic and the onset of myocardial infarction. New England J Med
351: 1721-1730.
\687\ Zanobetti, A.; Stone, P.H.; Spelzer, F.E.; Schwartz, J.D.;
Coull, B.A.; Suh, H.H.; Nearling, B.D.; Mittleman, M.A.; Verrier,
R.L.; Gold, D.R. (2009) T-wave alternans, air pollution and traffic
in high-risk subjects. Am J Cardiol 104: 665-670.
\688\ Dubowsky Adar, S.; Adamkiewicz, G.; Gold, D.R.; Schwartz,
J.; Coull, B.A.; Suh, H. (2007) Ambient and microenvironmental
particles and exhaled nitric oxide before and after a group bus
trip. Environ Health Perspect 115: 507-512.
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Numerous reviews of this body of health literature have been
published as well. In 2010, an expert panel of the Health Effects
Institute (HEI) published a review of hundreds of exposure,
epidemiology, and toxicology studies.\689\ The panel rated how the
evidence for each type of health outcome supported a conclusion of a
causal association with traffic-associated air pollution as either
``sufficient,'' ``suggestive but not sufficient,'' or ``inadequate and
insufficient.'' The panel categorized evidence of a causal association
for exacerbation of childhood asthma as ``sufficient.'' The panel
categorized evidence of a causal association for new onset asthma as
between ``sufficient'' and ``suggestive but not sufficient.''
``Suggestive of a causal association'' was how the panel categorized
evidence linking traffic-associated air pollutants with exacerbation of
adult respiratory symptoms and lung function decrement. It categorized
as ``inadequate and insufficient'' evidence of a causal relationship
between traffic-related air pollution and health care utilization for
respiratory problems, new onset adult asthma, chronic obstructive
pulmonary disease (COPD), nonasthmatic respiratory allergy, and cancer
in adults and children. Other literature reviews have been published
with conclusions generally similar to the HEI
panel's.690 691 692 693 However, in 2014, researchers from
the U.S. Centers for Disease Control and Prevention (CDC) published a
systematic review and meta-analysis of studies evaluating the risk of
childhood leukemia associated with traffic exposure and reported
positive associations between ``postnatal'' proximity to traffic and
leukemia risks, but no such association for ``prenatal''
exposures.\694\
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\689\ Health Effects Institute Panel on the Health Effects of
Traffic-Related Air Pollution. (2010). Traffic-related air
pollution: a critical review of the literature on emissions,
exposure, and health effects. HEI Special Report 17. Available at
http://www.healtheffects.org.
\690\ Boothe, V.L.; Shendell, D.G. (2008). Potential health
effects associated with residential proximity to freeways and
primary roads: review of scientific literature, 1999-2006. J Environ
Health 70: 33-41.
\691\ Salam, M.T.; Islam, T.; Gilliland, F.D. (2008). Recent
evidence for adverse effects of residential proximity to traffic
sources on asthma. Curr Opin Pulm Med 14: 3-8.
\692\ Sun, X.; Zhang, S.; Ma, X. (2014) No association between
traffic density and risk of childhood leukemia: a meta-analysis.
Asia Pac J Cancer Prev 15: 5229-5232.
\693\ Raaschou-Nielsen, O.; Reynolds, P. (2006). Air pollution
and childhood cancer: a review of the epidemiological literature.
Int J Cancer 118: 2920-9.
\694\ Boothe, VL.; Boehmer, T.K.; Wendel, A.M.; Yip, F.Y. (2014)
Residential traffic exposure and childhood leukemia: a systematic
review and meta-analysis. Am J Prev Med 46: 413-422.
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Health outcomes with few publications suggest the possibility of
other effects still lacking sufficient evidence to draw definitive
conclusions. Among these outcomes with a small number of positive
studies are neurological impacts (e.g., autism and reduced cognitive
function) and reproductive outcomes (e.g., preterm birth, low birth
weight).695 696 697 698
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\695\ Volk, H.E.; Hertz-Picciotto, I.; Delwiche, L.; et al.
(2011). Residential proximity to freeways and autism in the CHARGE
study. Environ Health Perspect 119: 873-877.
\696\ Franco-Suglia, S.; Gryparis, A.; Wright, R.O.; et al.
(2007). Association of black carbon with cognition among children in
a prospective birth cohort study. Am J Epidemiol. doi: 10.1093/aje/
kwm308. [Online at http://dx.doi.org].
\697\ Power, M.C.; Weisskopf, M.G.; Alexeef, SE.; et al. (2011).
Traffic-related air pollution and cognitive function in a cohort of
older men. Environ Health Perspect 2011: 682-687.
\698\ Wu, J.; Wilhelm, M.; Chung, J.; et al. (2011). Comparing
exposure assessment methods for traffic-related air pollution in and
adverse pregnancy outcome study. Environ Res 111: 685-6692.
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In addition to health outcomes, particularly cardiopulmonary
effects, conclusions of numerous studies suggest mechanisms by which
traffic-related air pollution affects health. Numerous studies indicate
that near-roadway exposures may increase systemic inflammation,
affecting organ systems, including blood vessels and
lungs.699 700 701 702 Long-term exposures in near-road
environments have been associated with inflammation-associated
conditions, such as atherosclerosis and asthma.\703\ \704\ \705\
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\699\ Riediker, M. (2007). Cardiovascular effects of fine
particulate matter components in highway patrol officers. Inhal
Toxicol 19: 99-105. doi: 10.1080/08958370701495238 Available at
http://dx.doi.org.
\700\ Alexeef, SE.; Coull, B.A.; Gryparis, A.; et al. (2011).
Medium-term exposure to traffic-related air pollution and markers of
inflammation and endothelial function. Environ Health Perspect 119:
481-486. doi:10.1289/ehp.1002560 Available at http://dx.doi.org.
\701\ Eckel. S.P.; Berhane, K.; Salam, M.T.; et al. (2011).
Traffic-related pollution exposure and exhaled nitric oxide in the
Children's Health Study. Environ Health Perspect (IN PRESS).
doi:10.1289/ehp.1103516. Available at http://dx.doi.org.
\702\ Zhang, J.; McCreanor, J.E.; Cullinan, P.; et al. (2009).
Health effects of real-world exposure diesel exhaust in persons with
asthma. Res Rep Health Effects Inst 138. [Online at http://www.healtheffects.org].
\703\ Adar, S.D.; Klein, R.; Klein, E.K.; et al. (2010). Air
pollution and the microvasculatory: a cross-sectional assessment of
in vivo retinal images in the population-based Multi-Ethnic Study of
Atherosclerosis. PLoS Med 7(11): E1000372. doi:10.1371/
journal.pmed.1000372. Available at http://dx.doi.org.
\704\ Kan, H.; Heiss, G.; Rose, K.M.; et al. (2008). Prospective
analysis of traffic exposure as a risk factor for incident coronary
heart disease: the Atherosclerosis Risk in Communities (ARIC) study.
Environ Health Perspect 116: 1463-1468. doi:10.1289/ehp.11290.
Available at http://dx.doi.org.
\705\ McConnell, R.; Islam, T.; Shankardass, K.; et al. (2010).
Childhood incident asthma and traffic-related air pollution at home
and school. Environ Health Perspect 1021-1026.
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Several studies suggest that some factors may increase
susceptibility to the effects of traffic-associated air pollution.
Several studies have found stronger respiratory associations in
children experiencing chronic social stress, such as in violent
neighborhoods or in homes with high family
stress.706 707 708
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\706\ Islam, T.; Urban, R.; Gauderman, W.J.; et al. (2011).
Parental stress increases the detrimental effect of traffic exposure
on children's lung function. Am J Respir Crit Care Med (In press).
\707\ Clougherty, J.E.; Levy, J.I.; Kubzansky, L.D.; et al.
(2007). Synergistic effects of traffic-related air pollution and
exposure to violence on urban asthma etiology. Environ Health
Perspect 115: 1140-1146.
\708\ Chen, E.; Schrier, H.M.; Strunk, R.C.; et al. (2008).
Chronic traffic-related air pollution and stress interact to predict
biologic and clinical outcomes in asthma. Environ Health Perspect
116: 970-5.
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[[Page 73846]]
The risks associated with residence, workplace, or schools near
major roads are of potentially high public health significance due to
the large population in such locations. According to the 2009 American
Housing Survey, over 22 million homes (17.0 percent of all U.S. housing
units) were located within 300 feet of an airport, railroad, or highway
with four or more lanes. This corresponds to a population of more than
50 million U.S. residents in close proximity to high-traffic roadways
or other transportation sources. Based on 2010 Census data, a 2013
publication estimated that 19 percent of the U.S. population (over 59
million people) lived within 500 meters of roads with at least 25,000
annual average daily traffic (AADT), while about 3.2 percent of the
population lived within 100 meters (about 300 feet) of such roads.\709\
Another 2013 study estimated that 3.7 percent of the U.S. population
(about 11.3 million people) lived within 150 meters (about 500 feet) of
interstate highways or other freeways and expressways.\710\ As
discussed in Section VIII.A.(9), on average, populations near major
roads have higher fractions of minority residents and lower
socioeconomic status. Furthermore, on average, Americans spend more
than an hour traveling each day, bringing nearly all residents into a
high-exposure microenvironment for part of the day.
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\709\ Rowangould, G.M. (2013) A census of the U.S. near-roadway
population: public health and environmental justice considerations.
Transportation Research Part D 25: 59-67.
\710\ Boehmer, T.K.; Foster, S.L.; Henry, J.R.; Woghiren-
Akinnifesi, E.L.; Yip, F.Y. (2013) Residential proximity to major
highways--United States, 2010. Morbidity and Mortality Weekly Report
62(3); 46-50.
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In light of these concerns, EPA has required through the NAAQS
process that air quality monitors be placed near high-traffic roadways
for determining concentrations of CO, NO2, and
PM2.5 (in addition to those existing monitors located in
neighborhoods and other locations farther away from pollution sources).
Near-roadway monitors for NO2 begin operation between 2014
and 2017 in Core Based Statistical Areas (CBSAs) with population of at
least 500,000. Monitors for CO and PM2.5 begin operation
between 2015 and 2017. These monitors will further our understanding of
exposure in these locations.
EPA and DOT continue to research near-road air quality, including
the types of pollutants found in high concentrations near major roads
and health problems associated with the mixture of pollutants near
roads.
(9) Environmental Justice
Environmental justice (EJ) is a principle asserting that all people
deserve fair treatment and meaningful involvement with respect to
environmental laws, regulations, and policies. EPA seeks to provide the
same degree of protection from environmental health hazards for all
people. DOT shares this goal and is informed about the potential
environmental impacts of its rulemakings through its NEPA process (see
NHTSA's DEIS). As referenced below, numerous studies have found that
some environmental hazards are more prevalent in areas where racial/
ethnic minorities and people with low socioeconomic status (SES)
represent a higher fraction of the population compared with the general
population. In addition, compared to non-Hispanic whites, some types of
minorities may have greater levels of health problems during some life
stages. For example, in 2014, about 13 percent of Black, non-Hispanic
and 24 percent of Puerto Rican children were estimated to currently
have asthma, compared with 8 percent of white, non-Hispanic
children.\711\
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\711\ http://www.cdc.gov/asthma/most_recent_data.htm.
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As discussed in Section VIII.A.(8) of this document and NHTSA's
FEIS, concentrations of many air pollutants are elevated near high-
traffic roadways. If minority populations and low-income populations
disproportionately live near such roads, then an issue of EJ may be
present. We reviewed existing scholarly literature examining the
potential for disproportionate exposure among minorities and people
with low SES, and we conducted our own evaluation of two national
datasets: The U.S. Census Bureau's American Housing Survey for calendar
year 2009 and the U.S. Department of Education's database of school
locations.
Publications that address EJ issues generally report that
populations living near major roadways (and other types of
transportation infrastructure) tend to be composed of larger fractions
of nonwhite residents. People living in neighborhoods near such sources
of air pollution also tend to be lower in income than people living
elsewhere. Numerous studies evaluating the demographics and
socioeconomic status of populations or schools near roadways have found
that they include a greater percentage of minority residents, as well
as lower SES (indicated by variables such as median household income).
Locations in these studies include Los Angeles, CA; Seattle, WA; Wayne
County, MI; Orange County, FL; and the State of California
712 713 714 715 716 717 Such disparities may be due to
multiple factors.\718\
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\712\ Marshall, J.D. (2008) Environmental inequality: air
pollution exposures in California's South Coast Air Basin.
\713\ Su, J.G.; Larson, T.; Gould, T.; Cohen, M.; Buzzelli, M.
(2010) Transboundary air pollution and environmental justice:
Vancouver and Seattle compared. GeoJournal 57: 595-608. doi:10.1007/
s10708-009-9269-6 [Online at http://dx.doi.org].
\714\ Chakraborty, J.; Zandbergen, P.A. (2007) Children at risk:
measuring racial/ethnic disparities in potential exposure to air
pollution at school and home. J Epidemiol Community Health 61: 1074-
1079. doi: 10.1136/jech.2006.054130 [Online at http://dx.doi.org].
\715\ Green, R.S.; Smorodinsky, S.; Kim, J.J.; McLaughlin, R.;
Ostro, B. (2003) Proximity of California public schools to busy
roads. Environ Health Perspect 112: 61-66. doi:10.1289/ehp.6566
[http://dx.doi.org].
\716\ Wu, Y; Batterman, S.A. (2006) Proximity of schools in
Detroit, Michigan to automobile and truck traffic. J Exposure Sci &
Environ Epidemiol. doi:10.1038/sj.jes.7500484 [Online at http://dx.doi.org].
\717\ Su, J.G.; Jerrett, M.; de Nazelle, A.; Wolch, J. (2011)
Does exposure to air pollution in urban parks have socioeconomic,
racial, or ethnic gradients? Environ Res 111: 319-328.
\718\ Depro, B.; Timmins, C. (2008) Mobility and environmental
equity: do housing choices determine exposure to air pollution?
North Caroline State University Center for Environmental and
Resource Economic Policy.
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People with low SES often live in neighborhoods with multiple
stressors and health risk factors, including reduced health insurance
coverage rates, higher smoking and drug use rates, limited access to
fresh food, visible neighborhood violence, and elevated rates of
obesity and some diseases such as asthma, diabetes, and ischemic heart
disease. Although questions remain, several studies find stronger
associations between air pollution and health in locations with such
chronic neighborhood stress, suggesting that populations in these areas
may be more susceptible to the effects of air pollution.
719 720 721 722 Household-level
[[Page 73847]]
stressors such as parental smoking and relationship stress also may
increase susceptibility to the adverse effects of air
pollution.723 724
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\719\ Clougherty, J.E.; Kubzansky, L.D. (2009) A framework for
examining social stress and susceptibility to air pollution in
respiratory health. Environ Health Perspect 117: 1351-1358.
Doi:10.1289/ehp.0900612 [Online at http://dx.doi.org].
\720\ Clougherty, J.E.; Levy, J.I.; Kubzansky, L.D.; Ryan, P.B.;
Franco Suglia, S.; Jacobson Canner, M.; Wright, R.J. (2007)
Synergistic effects of traffic-related air pollution and exposure to
violence on urban asthma etiology. Environ Health Perspect 115:
1140-1146. doi:10.1289/ehp.9863 [Online at http://dx.doi.org].
\721\ Finkelstein, M.M.; Jerrett, M.; DeLuca, P.; Finkelstein,
N.; Verma, D.K.; Chapman, K.; Sears, M.R. (2003) Relation between
income, air pollution and mortality: a cohort study. Canadian Med
Assn J 169: 397-402.
\722\ Shankardass, K.; McConnell, R.; Jerrett, M.; Milam, J.;
Richardson, J.; Berhane, K. (2009) Parental stress increases the
effect of traffic-related air pollution on childhood asthma
incidence. Proc Natl Acad Sci 106: 12406-12411. doi:10.1073/
pnas.0812910106 [Online at http://dx.doi.org].
\723\ Lewis, A.S.; Sax, S.N.; Wason, S.C.; Campleman, S.L (2011)
Non-chemical stressors and cumulative risk assessment: an overview
of current initiatives and potential air pollutant interactions. Int
J Environ Res Public Health 8: 2020-2073. Doi:10.3390/ijerph8062020
[Online at http://dx.doi.org].
\724\ Rosa, M.J.; Jung, K.H.; Perzanowski, M.S.; Kelvin, E.A.;
Darling, K.W.; Camann, D.E.; Chillrud, S.N.; Whyatt, R.M.; Kinney,
P.L.; Perera, F.P.; Miller, R.L (2010) Prenatal exposure to
polycyclic aromatic hydrocarbons, environmental tobacco smoke and
asthma. Respir Med (In press). doi:10.1016/j.rmed.2010.11.022
[Online at http://dx.doi.org].
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More recently, three publications report nationwide analyses that
compare the demographic patterns of people who do or do not live near
major roadways.725 726 727 All three of these studies found
that people living near major roadways are more likely to be minorities
or low in SES. They also found that the outcomes of their analyses
varied between regions within the U.S. However, only one such study
looked at whether such conclusions were confounded by living in a
location with higher population density and how demographics differ
between locations nationwide. In general, it found that higher density
areas have higher proportions of low income and minority residents.
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\725\ Rowangould, G.M. (2013) A census of the U.S. near-roadway
population: public health and environmental justice considerations.
Transportation Research Part D; 59-67.
\726\ Tian, N.; Xue, J.; Barzyk. T.M. (2013) Evaluating
socioeconomic and racial differences in traffic-related metrics in
the United States using a GIS approach. J Exposure Sci Environ
Epidemiol 23: 215-222.
\727\ Boehmer, T.K.; Foster, S.L.; Henry, J.R.; Woghiren-
Akinnifesi, E.L.; Yip, F.Y. (2013) Residential proximity to major
highways--United States, 2010. Morbidity and Mortality Weekly Report
62(3): 46-50.
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We analyzed two national databases that allowed us to evaluate
whether homes and schools were located near a major road and whether
disparities in exposure may be occurring in these environments. The
American Housing Survey (AHS) includes descriptive statistics of over
70,000 housing units across the nation. The study survey is conducted
every two years by the U.S. Census Bureau. The second database we
analyzed was the U.S. Department of Education's Common Core of Data,
which includes enrollment and location information for schools across
the U.S.
In analyzing the 2009 AHS, we focused on whether or not a housing
unit was located within 300 feet of ``4-or-more lane highway, railroad,
or airport.'' \728\ We analyzed whether there were differences between
households in such locations compared with those in locations farther
from these transportation facilities.\729\ We included other variables,
such as land use category, region of country, and housing type. We
found that homes with a nonwhite householder were 22-34 percent more
likely to be located within 300 feet of these large transportation
facilities than homes with white householders. Homes with a Hispanic
householder were 17-33 percent more likely to be located within 300
feet of these large transportation facilities than homes with non-
Hispanic householders. Households near large transportation facilities
were, on average, lower in income and educational attainment, more
likely to be a rental property and located in an urban area compared
with households more distant from transportation facilities.
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\728\ This variable primarily represents roadway proximity.
According to the Central Intelligence Agency's World Factbook, in
2010, the United States had 6,506,204 km or roadways, 224,792 km of
railways, and 15,079 airports. Highways thus represent the
overwhelming majority of transportation facilities described by this
factor in the AHS.
\729\ Bailey, C. (2011) Demographic and Social Patterns in
Housing Units Near Large Highways and other Transportation Sources.
Memorandum to docket.
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In examining schools near major roadways, we examined the Common
Core of Data (CCD) from the U.S. Department of Education, which
includes information on all public elementary and secondary schools and
school districts nationwide.\730\ To determine school proximities to
major roadways, we used a geographic information system (GIS) to map
each school and roadways based on the U.S. Census's TIGER roadway
file.\731\ We found that minority students were overrepresented at
schools within 200 meters of the largest roadways, and that schools
within 200 meters of the largest roadways also had higher than expected
numbers of students eligible for free or reduced-price lunches. For
example, Black students represent 22 percent of students at schools
located within 200 meters of a primary road, whereas Black students
represent 17 percent of students in all U.S. schools. Hispanic students
represent 30 percent of students at schools located within 200 meters
of a primary road, whereas Hispanic students represent 22 percent of
students in all U.S. schools.
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\730\ http://nces.ed.gov/ccd/.
\731\ Pedde, M.; Bailey, C. (2011) Identification of Schools
within 200 Meters of U.S. Primary and Secondary Roads. Memorandum to
the docket.
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Overall, there is substantial evidence that people who live or
attend school near major roadways are more likely to be of a minority
race, Hispanic ethnicity, and/or low SES. The emission reductions from
these final rules will likely result in widespread air quality
improvements, but the impact on pollution levels in close proximity to
roadways will be most direct. Thus, these final rules will likely help
in mitigating the disparity in racial, ethnic, and economically based
exposures.
B. Environmental Effects of Non-GHG Pollutants
(1) Visibility
Visibility can be defined as the degree to which the atmosphere is
transparent to visible light.\732\ Visibility impairment is caused by
light scattering and absorption by suspended particles and gases.
Visibility is important because it has direct significance to people's
enjoyment of daily activities in all parts of the country. Individuals
value good visibility for the well-being it provides them directly,
where they live and work, and in places where they enjoy recreational
opportunities. Visibility is also highly valued in significant natural
areas, such as national parks and wilderness areas, and special
emphasis is given to protecting visibility in these areas. For more
information on visibility see the final 2009 p.m. ISA.\733\
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\732\ National Research Council, (1993). Protecting Visibility
in National Parks and Wilderness Areas. National Academy of Sciences
Committee on Haze in National Parks and Wilderness Areas. National
Academy Press, Washington, DC. This book can be viewed on the
National Academy Press Web site at http://www.nap.edu/books/0309048443/html/.
\733\ U.S. EPA. (2009). Integrated Science Assessment for
Particulate Matter (Final Report). U.S. Environmental Protection
Agency, Washington, DC, EPA/600/R-08/139F.
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EPA is working to address visibility impairment. Reductions in air
pollution from implementation of various programs associated with the
Clean Air Act Amendments of 1990 (CAAA) provisions have resulted in
substantial improvements in visibility and will continue to do so in
the future. Because trends in haze are closely associated with trends
in particulate sulfate and nitrate due to the relationship between
their concentration and light extinction, visibility trends have
improved as emissions of SO2 and NOX have
decreased over time due to air pollution
[[Page 73848]]
regulations such as the Acid Rain Program.\734\
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\734\ U.S. EPA. 2009 Final Report: Integrated Science Assessment
for Particulate Matter. U.S. Environmental Protection Agency,
Washington, DC, EPA/600/R-08/139F, 2009.
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In the Clean Air Act Amendments of 1977, Congress recognized
visibility's value to society by establishing a national goal to
protect national parks and wilderness areas from visibility impairment
caused by manmade pollution.\735\ In 1999, EPA finalized the regional
haze program to protect the visibility in Mandatory Class I Federal
areas.\736\ There are 156 national parks, forests and wilderness areas
categorized as Mandatory Class I Federal areas.\737\ These areas are
defined in CAA Section 162 as those national parks exceeding 6,000
acres, wilderness areas and memorial parks exceeding 5,000 acres, and
all international parks which were in existence on August 7, 1977.
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\735\ See Section 169(a) of the Clean Air Act.
\736\ 64 FR 35714, July 1, 1999.
\737\ 62 FR 38680-38681, July 18, 1997.
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EPA has also concluded that PM2.5 causes adverse effects
on visibility in other areas that are not targeted by the Regional Haze
Rule, such as urban areas, depending on PM2.5 concentrations
and other factors such as dry chemical composition and relative
humidity (i.e., an indicator of the water composition of the
particles). EPA revised the PM2.5 standards in December 2012
and established a target level of protection that is expected to be met
through attainment of the existing secondary standards for
PM2.5.
(2) Plant and Ecosystem Effects of Ozone
The welfare effects of ozone can be observed across a variety of
scales, i.e. subcellular, cellular, leaf, whole plant, population and
ecosystem. Ozone effects that begin at small spatial scales, such as
the leaf of an individual plant, when they occur at sufficient
magnitudes (or to a sufficient degree) can result in effects being
propagated along a continuum to larger and larger spatial scales. For
example, effects at the individual plant level, such as altered rates
of leaf gas exchange, growth and reproduction, can, when widespread,
result in broad changes in ecosystems, such as productivity, carbon
storage, water cycling, nutrient cycling, and community composition.
Ozone can produce both acute and chronic injury in sensitive
species depending on the concentration level and the duration of the
exposure.\738\ In those sensitive species,\739\ effects from repeated
exposure to ozone throughout the growing season of the plant tend to
accumulate, so that even low concentrations experienced for a longer
duration have the potential to create chronic stress on
vegetation.\740\ Ozone damage to sensitive species includes impaired
photosynthesis and visible injury to leaves. The impairment of
photosynthesis, the process by which the plant makes carbohydrates (its
source of energy and food), can lead to reduced crop yields, timber
production, and plant productivity and growth. Impaired photosynthesis
can also lead to a reduction in root growth and carbohydrate storage
below ground, resulting in other, more subtle plant and ecosystems
impacts.\741\ These latter impacts include increased susceptibility of
plants to insect attack, disease, harsh weather, interspecies
competition and overall decreased plant vigor. The adverse effects of
ozone on areas with sensitive species could potentially lead to species
shifts and loss from the affected ecosystems,\742\ resulting in a loss
or reduction in associated ecosystem goods and services. Additionally,
visible ozone injury to leaves can result in a loss of aesthetic value
in areas of special scenic significance like national parks and
wilderness areas and reduced use of sensitive ornamentals in
landscaping.\743\
---------------------------------------------------------------------------
\738\ 73 FR 16486, March 27, 2008.
\739\ 73 FR 16491, March 27, 2008. Only a small percentage of
all the plant species growing within the U.S. (over 43,000 species
have been catalogued in the USDA PLANTS database) have been studied
with respect to ozone sensitivity.
\740\ The concentration at which ozone levels overwhelm a
plant's ability to detoxify or compensate for oxidant exposure
varies. Thus, whether a plant is classified as sensitive or tolerant
depends in part on the exposure levels being considered. Chapter 9,
Section 9.3.4 of U.S. EPA, 2013 Integrated Science Assessment for
Ozone and Related Photochemical Oxidants. Office of Research and
Development/National Center for Environmental Assessment. U.S.
Environmental Protection Agency. EPA 600/R-10/076F.
\741\ 73 FR 16492, March 27, 2008.
\742\ 73 FR 16493-16494, March 27, 2008, Ozone impacts could be
occurring in areas where plant species sensitive to ozone have not
yet been studied or identified.
\743\ 73 FR 16490-16497, March 27, 2008.
---------------------------------------------------------------------------
The most recent Integrated Science Assessment (ISA) for Ozone
presents more detailed information on how ozone affects vegetation and
ecosystems.\744\ The ISA concludes that ambient concentrations of ozone
are associated with a number of adverse welfare effects and
characterizes the weight of evidence for different effects associated
with ozone.\745\ The ISA concludes that visible foliar injury effects
on vegetation, reduced vegetation growth, reduced productivity in
terrestrial ecosystems, reduced yield and quality of agricultural
crops, and alteration of below-ground biogeochemical cycles are
causally associated with exposure to ozone. It also concludes that
reduced carbon sequestration in terrestrial ecosystems, alteration of
terrestrial ecosystem water cycling, and alteration of terrestrial
community composition are likely to be causally associated with
exposure to ozone.
---------------------------------------------------------------------------
\744\ U.S. EPA. Integrated Science Assessment of Ozone and
Related Photochemical Oxidants (Final Report). U.S. Environmental
Protection Agency, Washington, DC, EPA/600/R-10/076F, 2013. The ISA
is available at http://cfpub.epa.gov/ncea/isa/recordisplay.cfm?deid=247492#Download.
\745\ The Ozone ISA evaluates the evidence associated with
different ozone related health and welfare effects, assigning one of
five ``weight of evidence'' determinations: causal relationship,
likely to be a causal relationship, suggestive of a causal
relationship, inadequate to infer a causal relationship, and not
likely to be a causal relationship. For more information on these
levels of evidence, please refer to Table II of the ISA.
---------------------------------------------------------------------------
(3) Atmospheric Deposition
Wet and dry deposition of ambient particulate matter delivers a
complex mixture of metals (e.g., mercury, zinc, lead, nickel, aluminum,
and cadmium), organic compounds (e.g., polycyclic organic matter,
dioxins, and furans) and inorganic compounds (e.g., nitrate, sulfate)
to terrestrial and aquatic ecosystems. The chemical form of the
compounds deposited depends on a variety of factors including ambient
conditions (e.g., temperature, humidity, oxidant levels) and the
sources of the material. Chemical and physical transformations of the
compounds occur in the atmosphere as well as the media onto which they
deposit. These transformations in turn influence the fate,
bioavailability and potential toxicity of these compounds.
Adverse impacts to human health and the environment can occur when
particulate matter is deposited to soils, water, and biota.\746\
Deposition of heavy metals or other toxics may lead to the human
ingestion of contaminated fish, impairment of drinking water, damage to
terrestrial, freshwater and marine ecosystem components, and limits to
recreational uses. Atmospheric deposition has been identified as a key
component of the environmental and human health hazard posed by several
pollutants including mercury, dioxin and PCBs.\747\
---------------------------------------------------------------------------
\746\ U.S. EPA. Integrated Science Assessment for Particulate
Matter (Final Report). U.S. Environmental Protection Agency,
Washington, DC, EPA/600/R-08/139F, 2009.
\747\ U.S. EPA. (2000). Deposition of Air Pollutants to the
Great Waters: Third Report to Congress. Office of Air Quality
Planning and Standards. EPA-453/R-00-0005.
---------------------------------------------------------------------------
[[Page 73849]]
The ecological effects of acidifying deposition and nutrient
enrichment are detailed in the Integrated Science Assessment for Oxides
of Nitrogen and Sulfur-Ecological Criteria.\748\ Atmospheric deposition
of nitrogen and sulfur contributes to acidification, altering
biogeochemistry and affecting animal and plant life in terrestrial and
aquatic ecosystems across the United States. The sensitivity of
terrestrial and aquatic ecosystems to acidification from nitrogen and
sulfur deposition is predominantly governed by geology. Prolonged
exposure to excess nitrogen and sulfur deposition in sensitive areas
acidifies lakes, rivers and soils. Increased acidity in surface waters
creates inhospitable conditions for biota and affects the abundance and
biodiversity of fishes, zooplankton and macroinvertebrates and
ecosystem function. Over time, acidifying deposition also removes
essential nutrients from forest soils, depleting the capacity of soils
to neutralize future acid loadings and negatively affecting forest
sustainability. Major effects in forests include a decline in sensitive
tree species, such as red spruce (Picea rubens) and sugar maple (Acer
saccharum). In addition to the role nitrogen deposition plays in
acidification, nitrogen deposition also leads to nutrient enrichment
and altered biogeochemical cycling. In aquatic systems increased
nitrogen can alter species assemblages and cause eutrophication. In
terrestrial systems nitrogen loading can lead to loss of nitrogen-
sensitive lichen species, decreased biodiversity of grasslands, meadows
and other sensitive habitats, and increased potential for invasive
species. For a broader explanation of the topics treated here, refer to
the description in Chapter 8.1.2.3 of the RIA.
---------------------------------------------------------------------------
\748\ NOX and SOX secondary ISA\1\ U.S.
EPA. Integrated Science Assessment (ISA) for Oxides of Nitrogen and
Sulfur Ecological Criteria (Final Report). U.S. Environmental
Protection Agency, Washington, DC, EPA/600/R-08/082F, 2008.
---------------------------------------------------------------------------
Building materials including metals, stones, cements, and paints
undergo natural weathering processes from exposure to environmental
elements (e.g., wind, moisture, temperature fluctuations, sunlight,
etc.). Pollution can worsen and accelerate these effects. Deposition of
PM is associated with both physical damage (materials damage effects)
and impaired aesthetic qualities (soiling effects). Wet and dry
deposition of PM can physically affect materials, adding to the effects
of natural weathering processes, by potentially promoting or
accelerating the corrosion of metals, by degrading paints and by
deteriorating building materials such as stone, concrete and
marble.\749\ The effects of PM are exacerbated by the presence of
acidic gases and can be additive or synergistic due to the complex
mixture of pollutants in the air and surface characteristics of the
material. Acidic deposition has been shown to have an effect on
materials including zinc/galvanized steel and other metal, carbonate
stone (as monuments and building facings), and surface coatings
(paints).\750\ The effects on historic buildings and outdoor works of
art are of particular concern because of the uniqueness and
irreplaceability of many of these objects.
---------------------------------------------------------------------------
\749\ U.S. Environmental Protection Agency (U.S. EPA). 2009.
Integrated Science Assessment for Particulate Matter (Final Report).
EPA-600-R-08-139F. National Center for Environmental Assessment--RTP
Division. December. Available on the Internet at <http://cfpub.epa.gov/ncea/cfm/recordisplay.cfm?deid=216546>.
\750\ Irving, P.M., e.d. 1991. Acid Deposition: State of Science
and Technology, Volume III, Terrestrial, Materials, Health, and
Visibility Effects, The U.S. National Acid Precipitation Assessment
Program, Chapter 24, page 24-76.
---------------------------------------------------------------------------
(4) Environmental Effects of Air Toxics
Emissions from producing, transporting and combusting fuel
contribute to ambient levels of pollutants that contribute to adverse
effects on vegetation. Volatile organic compounds, some of which are
considered air toxics, have long been suspected to play a role in
vegetation damage.\751\ In laboratory experiments, a wide range of
tolerance to VOCs has been observed.\752\ Decreases in harvested seed
pod weight have been reported for the more sensitive plants, and some
studies have reported effects on seed germination, flowering and fruit
ripening. Effects of individual VOCs or their role in conjunction with
other stressors (e.g., acidification, drought, temperature extremes)
have not been well studied. In a recent study of a mixture of VOCs
including ethanol and toluene on herbaceous plants, significant effects
on seed production, leaf water content and photosynthetic efficiency
were reported for some plant species.\753\
---------------------------------------------------------------------------
\751\ U.S. EPA. (1991). Effects of organic chemicals in the
atmosphere on terrestrial plants. EPA/600/3-91/001.
\752\ Cape JN, ID Leith, J Binnie, J Content, M Donkin, M
Skewes, DN Price AR Brown, AD Sharpe. (2003). Effects of VOCs on
herbaceous plants in an open-top chamber experiment. Environ.
Pollut. 124:341-343.
\753\ Cape JN, ID Leith, J Binnie, J Content, M Donkin, M
Skewes, DN Price AR Brown, AD Sharpe. (2003). Effects of VOCs on
herbaceous plants in an open-top chamber experiment. Environ.
Pollut. 124:341-343.
---------------------------------------------------------------------------
Research suggests an adverse impact of vehicle exhaust on plants,
which has in some cases been attributed to aromatic compounds and in
other cases to nitrogen oxides.754 755 756
---------------------------------------------------------------------------
\754\ Viskari E-L. (2000). Epicuticular wax of Norway spruce
needles as indicator of traffic pollutant deposition. Water, Air,
and Soil Pollut. 121:327-337.
\755\ Ugrekhelidze D, F Korte, G Kvesitadze. (1997). Uptake and
transformation of benzene and toluene by plant leaves. Ecotox.
Environ. Safety 37:24-29.
\756\ Kammerbauer H, H Selinger, R Rommelt, A Ziegler-Jons, D
Knoppik, B Hock. (1987). Toxic components of motor vehicle emissions
for the spruce Picea abies. Environ. Pollut. 48:235-243.
---------------------------------------------------------------------------
C. Emissions Inventory Impacts
As described in Section VII, the agencies conducted two analyses
for these rules using DOT's CAFE model and EPA's MOVES model, relative
to different reference cases (i.e., different baselines). The agencies
used EPA's MOVES model to estimate the non-GHG impacts for tractor-
trailers (including the engine that powers the vehicle) and vocational
vehicles (including the engine that powers the vehicle). For heavy-duty
pickups and vans, the agencies performed separate analyses using the
CAFE model (included in NHTSA's ``Method A;'' See Section VI) and the
MOVES model (included in EPA's ``Method B;'' See Section VI) to
estimate non-GHG emissions from these vehicles. For these methods, the
agencies analyzed the impact of the rules relative to two different
reference cases--flat and dynamic. The flat baseline projects very
little improvement in new vehicles in the absence of new Phase 2
standards. In contrast, the dynamic baseline projects more significant
improvements in vehicle fuel efficiency. The agencies considered both
reference cases. The results for all of the regulatory alternatives
relative to both reference cases, derived via the same methodologies
discussed in Section VII of the Preamble, are presented in Section X of
the Preamble.
For brevity, a subset of these analyses are presented in this
section and the reader is referred to both Chapter 11 of the RIA and
NHTSA's FEIS Chapters 3, 4 and 5 for complete sets of these analyses.
In this section, Method A is presented for the final standards,
relative to both the dynamic baseline (Alternative 1b) and the flat
baseline (Alternative 1a). Method B is presented for the final
standards, relative only to the flat baseline.
The following subsections summarize two slightly different analyses
of the annual non-GHG emissions reductions expected from these
standards. Section VIII.A.(1) presents the impacts of the
[[Page 73850]]
final rules on non-GHG emissions using the analytical Method A,
relative to two different reference cases--flat and dynamic. Section
VIII.A.(2) presents the impacts of these standards, relative to the
flat reference case only, using the MOVES model for all heavy-duty
vehicle categories.
(1) Impacts of the Final Rules Using Analysis Method A
(a) Calendar Year Analysis
(i) Upstream Impacts of the Final Program
Increasing efficiency in heavy-duty vehicles will result in reduced
fuel demand and, therefore, reductions in the emissions associated with
all processes involved in getting petroleum to the pump. Both Method A
and Method B project these impacts for fuel consumed by vocational
vehicles and combination tractor-trailers, using EPA's MOVES model. See
Section VII.A. for the description of this methodology. To project
these impacts for fuel consumed by HD pickups and vans, Method A used
similar calculations and inputs applicable to the CAFE model, as
discussed above in Section VI. More information on the development of
the emission factors used in this analysis can be found in Chapter 5 of
the RIA.
The following two tables summarize the projected upstream emission
impacts of the final program on both criteria pollutants and air toxics
from the heavy-duty sector, relative to Alternative 1b (dynamic
baseline conditions under the No-Action Alternative) and Alternative 1a
(flat baseline conditions under the No-Action Alternative), using
analysis method A. Using either No-Action Alternative shows decreases
in upstream emissions of all criteria pollutants, precursors, and air
toxics; using Alternative 1a as the reference point attributes more of
the emission reduction to the standards. Note that the rule is
projected, in all analyses, of reducing emissions of NOX,
contrary to implications in some of the public comments that fuel
efficiency/GHG controls come at the expense of increased NOX
emissions.
Table VIII-1--Annual Upstream Impacts on Criteria Pollutants and Air Toxics From Heavy-Duty Sector in Calendar Years 2025, 2040 and 2050--Final Program
vs. Alt 1b Using Analysis Method A a
--------------------------------------------------------------------------------------------------------------------------------------------------------
CY2025 CY2040 CY2050
Pollutant -----------------------------------------------------------------------------------------------
US short tons % Change US short tons % Change US short tons % Change
--------------------------------------------------------------------------------------------------------------------------------------------------------
1,3-Butadiene........................................... -1 -4.9 -4 -18 -5 -19
Acetaldehyde............................................ -3 -4.4 -14 -15 -16 -16
Acrolein................................................ -0.4 -4.6 -2 -16 -2 -17
Benzene................................................. -23 -4.8 -88 -16 -105 -18
CO...................................................... -3,785 -4.9 -14,714 -17 -17,629 -19
Formaldehyde............................................ -18 -4.9 -71 -17 -86 -19
NOX..................................................... -9,255 -4.9 -35,964 -17 -43,089 -19
PM2.5................................................... -975 -4.9 -3,850 -18 -4,618 -19
SOX..................................................... -5,804 -4.9 -22,550 -17 -27,019 -19
VOC..................................................... -4,419 -4.8 -14,857 -15 -17,385 -16
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note:
\a\ For an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 1b,
please see Section X.A.1.
Table VIII-2--Annual Upstream Impacts on Criteria Pollutants and Air Toxics From Heavy-Duty Sector in Calendar Years 2025, 2040 and 2050--Final Program
vs. Alt 1a Using Analysis Method A a
--------------------------------------------------------------------------------------------------------------------------------------------------------
CY2025 CY2040 CY2050
Pollutant -----------------------------------------------------------------------------------------------
US short tons % Change US short tons % Change US short tons % Change
--------------------------------------------------------------------------------------------------------------------------------------------------------
1,3-Butadiene........................................... -1 -5.3 -4 -20 -5 -21
Acetaldehyde............................................ -4 -4.6 -15 -16 -17 -17
Acrolein................................................ -0.4 -4.9 -2 -17 -2 -18
Benzene................................................. -25 -5.1 -96 -18 -115 -19
CO...................................................... -4,142 -5.4 -16,298 -19 -19,558 -20
Formaldehyde............................................ -20 -5.3 -79 -19 -95 -20
NOX..................................................... -10,124 -5.4 -39,813 -19 -47,779 -20
PM2.5................................................... -1,065 -5.3 -4,258 -19 -5,117 -21
SOX..................................................... -6,349 -5.4 -24,961 -19 -29,958 -20
VOC..................................................... -4,810 -5.2 -16,218 -16 -19,004 -17
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note:
\a\ For an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 1b,
please see Section X.A.1.
(ii) Downstream Impacts of the Final Program
For vocational vehicles and tractor-trailers, the agencies used the
MOVES model to determine non-GHG emissions inventories. The
improvements in engine efficiency and road load, the increased use of
APUs, and VMT rebound were included in the MOVES analysis. For NHTSA's
Method A analysis, presented in this section, the DOT CAFE model was
used for HD pickups and vans. Further information about DOT's CAFE
model is available in Section VI.C and Chapter 10 of the RIA. The
following two tables summarize the projected downstream emission
impacts of the final program on both criteria pollutants and air toxics
from the heavy-duty sector, relative to Alternative 1b and Alternative
1a, using analysis Method A. Using either baseline shows a reduction in
all criteria pollutants and air toxics--except for 1,3-Butadiene,
[[Page 73851]]
and CY2025 levels of acrolein, which show small increases in downstream
emissions.
Table VIII-3--Annual Downstream Impacts on Criteria Pollutants and Air Toxics From Heavy-Duty Sector in Calendar Years 2025, 2040 and 2050--Final
Program vs. Alt 1b Using Analysis Method A a
--------------------------------------------------------------------------------------------------------------------------------------------------------
CY2025 CY2040 CY2050
Pollutant -----------------------------------------------------------------------------------------------
US short tons % Change US short tons % Change US short tons % Change
--------------------------------------------------------------------------------------------------------------------------------------------------------
1,3-Butadiene........................................... 1 0.5 4 3.6 4 3.4
Acetaldehyde............................................ -1 0.0 -16 -0.7 -19 -0.8
Acrolein................................................ 0.2 0.0 -0.3 -0.1 -1 -0.4
Benzene................................................. -2 -0.1 -13 -1.2 -13 -1.1
CO...................................................... -9,045 -0.6 -34,702 -2.8 -42,095 -3.0
Formaldehyde............................................ -21 -0.3 -96 -1.6 -119 -1.8
NOX..................................................... -12,082 -1.3 -53,254 -9.1 -65,068 -9.9
PM2.5 \b\............................................... -58 -0.2 -363 -2.0 -453 -2.2
SOX..................................................... -201 -4.1 -851 -16 -1,028 -17
VOC..................................................... -769 -0.8 -3,436 -5.3 -4,128 -5.8
--------------------------------------------------------------------------------------------------------------------------------------------------------
Notes:
\a\ For an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 1b,
please see Section X.A.1.
\b\ PM2.5 from tire wear and brake wear are included.
Table VIII-4--Annual Downstream Impacts on Criteria Pollutants and Air Toxics From Heavy-Duty Sector in Calendar Years 2025, 2040 and 2050--Final
Program vs. Alt 1a Using Analysis Method A a
--------------------------------------------------------------------------------------------------------------------------------------------------------
CY2025 CY2040 CY2050
Pollutant -----------------------------------------------------------------------------------------------
US short tons % Change US short tons % Change US short tons % Change
--------------------------------------------------------------------------------------------------------------------------------------------------------
1,3-Butadiene........................................... 1 0.5 4 3.7 4 3.5
Acetaldehyde............................................ -1 0.0 -14 -0.7 -18 -0.8
Acrolein................................................ 0.2 0.0 -0.3 -0.1 -1 -0.4
Benzene................................................. -2 -0.2 -13 -1.2 -14 -1.2
CO...................................................... -8,944 -0.6 -34,502 -2.8 -41,880 -3.0
Formaldehyde............................................ -20 -0.3 -91 -1.6 -113 -1.7
NOX..................................................... -13,368 -1.5 -60,594 -10.2 -74,206 -11
PM2.5 \b\............................................... -78 -0.2 -473 -2.6 -591 -2.9
SOX..................................................... -219 -4.5 -941 -17 -1,138 -19
VOC..................................................... -831 -0.8 -3,736 -5.8 -4,499 -6.3
--------------------------------------------------------------------------------------------------------------------------------------------------------
Notes:
\a\ For an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 1b,
please see Section X.A.1.
\b\ PM2.5 from tire wear and brake wear are included.
(iii) Total Impacts of the Final Program
The following two tables summarize the projected upstream emission
impacts of the final program on both criteria pollutants and air toxics
from the heavy-duty sector, relative to Alternative 1b and Alternative
1a, using analysis Method A. Under both baselines, Method A predicts a
decrease in total emissions by calendar year 2050, but the amount
attributable to the standards is larger using the flat baseline than
the dynamic baseline.
Table VIII-5--Annual Total Impacts (Upstream and Downstream) of Criteria Pollutants and Air Toxics From Heavy-Duty Sector in Calendar Years 2025, 2040
and 2050--Final Program vs. Alt 1b Using Analysis Method A a
--------------------------------------------------------------------------------------------------------------------------------------------------------
CY2025 CY2040 CY2050
Pollutant -----------------------------------------------------------------------------------------------
US short tons % Change US short tons % Change US short tons % Change
--------------------------------------------------------------------------------------------------------------------------------------------------------
1,3-Butadiene........................................... 0.3 0.1 0.1 0.1 -0.4 -0.3
Acetaldehyde............................................ -4 -0.1 -30 -1.3 -35 -1.4
Acrolein................................................ -0.2 0.0 -2 -0.7 -3 -0.9
Benzene................................................. -25 -1.2 -101 -6.3 -118 -6.7
CO...................................................... -12,830 -0.9 -49,416 -3.7 -59,724 -4.0
Formaldehyde............................................ -39 -0.5 -167 -2.7 -205 -2.9
NOX..................................................... -21,337 -2.0 -89,218 -11 -108,157 -12
PM2.5................................................... -1,033 -2.0 -4,213 -10 -5,071 -11
SOX..................................................... -6,005 -4.9 -23,401 -17 -28,047 -19
VOC..................................................... -5,188 -2.7 -18,293 -11 -21,513 -12
--------------------------------------------------------------------------------------------------------------------------------------------------------
Notes:
[[Page 73852]]
\a\ For an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 1b,
please see Section X.A.1.
Table VIII-6--Annual Total Impacts (Upstream and Downstream) of Criteria Pollutants and Air Toxics From Heavy-Duty Sector in Calendar Years 2025, 2040
and 2050--Final Program vs. Alt 1a Using Analysis Method A a
--------------------------------------------------------------------------------------------------------------------------------------------------------
CY2025 CY2040 CY2050
Pollutant -----------------------------------------------------------------------------------------------
US short tons % Change US short tons % Change US short tons % Change
--------------------------------------------------------------------------------------------------------------------------------------------------------
1,3-Butadiene........................................... 0.2 0.1 -0.2 -0.1 -1.0 -0.5
Acetaldehyde............................................ -5 -0.2 -29 -1.3 -35 -1.4
Acrolein................................................ -0.2 0.0 -2 -0.7 -3 -1.0
Benzene................................................. -27 -1.4 -109 -6.8 -129 -7.2
CO...................................................... -13,086 -0.9 -50,800 -3.8 -61,438 -4.1
Formaldehyde............................................ -40 -0.5 -170 -2.7 -208 -2.9
NOX..................................................... -23,492 -2.2 -100,407 -12 -121,985 -14
PM2.5................................................... -1,143 -2.2 -4,731 -12 -5,708 -13
SOX..................................................... -6,568 -5.3 -25,902 -19 -31,096 -20
VOC..................................................... -5,641 -3.0 -19,954 -12 -23,503 -13
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note:
\a\ For an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 1b,
please see Section X.A.1.
(b) Model Year Lifetime Analysis
Table VIII-7 shows the lifetime Non-GHG reductions for model years
2018-2029 attributable to the standards using Method A relative to both
No-Action Alternatives. For NOX, approximately half of the
emission reductions are downstream and half are upstream. However, for
PM2.5 and SOX proportionally more of the emission
reductions are attributable to upstream emission reductions than to
downstream emission reductions. A similar pattern emerges as with
single calendar year snapshots; more emission reductions are
attributable to the standards using the 1a baseline as the reference
point than by using the 1b baseline as the reference point.
Table VIII-7--Lifetime Non-GHG Reductions Using Analysis Method A--
Summary for Model Years 2018-2029
[U.S. Short Tons] a
------------------------------------------------------------------------
Final program
NO-action alternative (baseline) -------------------------------
1b (Dynamic) 1a (Flat)
------------------------------------------------------------------------
NOX..................................... 494,495 548,630
Downstream.......................... 246,509 276,413
Upstream............................ 247,986 272,217
PM2.5................................... 27,827 30,838
Downstream\b\....................... 1,437 1,891
Upstream............................ 26,390 28,947
SOX..................................... 159,367 174,918
Downstream.......................... 3,849 4,214
Upstream............................ 155,518 170,704
------------------------------------------------------------------------
Notes:
\a\ For an explanation of analytical Methods A and B, please see Section
I.D; for an explanation of the flat baseline, 1a, and dynamic
baseline, 1b, please see Section X.A.1.
\b\ PM2.5 from tire wear and brake wear are included.
(2) Impacts of the Final Rules Using Analysis Method B
(a) Calendar Year Analysis
(i) Upstream Impacts of the Final Program
Increasing efficiency in heavy-duty vehicles will result in reduced
fuel demand and, therefore, reductions in the emissions associated with
all processes involved in getting petroleum to the pump. To project
these impacts, Method B estimated the impact of reduced petroleum
volumes on the extraction and transportation of crude oil as well as
the production and distribution of finished gasoline and diesel. For
the purpose of assessing domestic-only emission reductions, it was
necessary to estimate the fraction of fuel savings attributable to
domestic finished gasoline and diesel and, of this fuel, what fraction
is produced from domestic crude. Method B estimated the emissions
associated with production and distribution of gasoline and diesel from
crude oil based on emission factors in the ``Greenhouse Gases,
Regulated Emissions, and Energy used in Transportation'' model (GREET)
developed by DOE's Argonne National Laboratory. In some cases, the
GREET values were modified or updated by the agencies to be consistent
with the National Emission Inventory (NEI) and emission factors from
MOVES. Method B estimated the projected corresponding changes in
upstream emissions using the same tools originally created for the
Renewable Fuel Standard 2 (RFS2) rulemaking analysis,\757\ used in the
LD
[[Page 73853]]
GHG rulemakings,\758\ HD GHG Phase 1,\759\ and updated for the current
analysis. More information on the development of the emission factors
used in this analysis can be found in Chapter 5 of the RIA.
---------------------------------------------------------------------------
\757\ U.S. EPA. Draft Regulatory Impact Analysis: Changes to
Renewable Fuel Standard Program. Chapters 2 and 3. May 26, 2009.
Docket ID: EPA-HQ-OAR-2009-0472-0119.
\758\ 2017 and Later Model Year Light-Duty Vehicle Greenhouse
Gas Emissions and Corporate Average Fuel Economy Standards (77 FR
62623, October 15, 2012).
\759\ Greenhouse Gas Emission Standards and Fuel Efficiency
Standards for Medium- and Heavy-Duty Engines and Vehicles (76 FR
57106, September 15, 2011).
---------------------------------------------------------------------------
Table VIII-8 summarizes the projected upstream emission impacts of
the final program on both criteria pollutants and air toxics from the
heavy-duty sector, relative to Alternative 1a, using analysis Method B.
The comparable estimates relative to Alternative 1b are presented in
Section VIII.C.(1).
Table VIII-8--Annual Upstream Impacts on Criteria Pollutants and Air Toxics From Heavy-Duty Sector in Calendar Years 2025, 2040 and 2050--Final Program
vs. Alt 1a Using Analysis Method B a
--------------------------------------------------------------------------------------------------------------------------------------------------------
CY2025 CY2040 CY2050
Pollutant -----------------------------------------------------------------------------------------------
US short tons % Change US short tons % Change US short tons % Change
--------------------------------------------------------------------------------------------------------------------------------------------------------
1,3-Butadiene........................................... -1 -4.8 -5 -19.0 -6 -20.6
Acetaldehyde............................................ -7 -3.2 -35 -14.5 -38 -15.9
Acrolein................................................ -1 -3.5 -3 -15.2 -4 -16.7
Benzene................................................. -30 -3.8 -143 -16.1 -166 -17.6
CO...................................................... -3,809 -4.8 -16,884 -18.9 -20,227 -20.5
Formaldehyde............................................ -20 -4.6 -90 -18.3 -107 -19.9
NOX..................................................... -9,314 -4.8 -41,280 -18.9 -49,462 -20.5
PM2.5................................................... -1,037 -4.7 -4,619 -18.7 -5,520 -20.3
SOX..................................................... -5,828 -4.8 -25,811 -18.9 -30,941 -20.5
VOC..................................................... -4,234 -3.7 -20,010 -15.9 -23,240 -17.4
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note:
\a\ For an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 1b,
please see Section X.A.1.
(ii) Downstream Impacts of the Final Program
The final program will impact the downstream emissions of non-GHG
pollutants. These pollutants include oxides of nitrogen
(NOX), oxides of sulfur (SOX), volatile organic
compounds (VOC), carbon monoxide (CO), fine particulate matter
(PM2.5), and air toxics. The agencies expect reductions in
downstream emissions of NOX, PM2.5, VOC,
SOX, CO, and air toxics. Much of these estimated net
reductions are a result of the agencies' anticipation of increased use
of auxiliary power units (APUs) in combination tractors during extended
idling; APUs emit these pollutants at a lower rate than on-road engines
during extended idle operation, with the exception of PM2.5.
As discussed in Section III.C.3, EPA is adopting Phase 1 and Phase 2
requirements to control PM2.5 emissions from APUs installed
in new tractors and therefore, eliminate the unintended consequence of
increased PM2.5 emissions from increased APU use.
Additional reductions in tailpipe emissions of NOX and
CO and refueling emissions of VOC will be achieved through improvements
in engine efficiency and reduced road load (improved aerodynamics and
tire rolling resistance), which reduces the amount of work required to
travel a given distance and increases fuel economy. For vehicle types
not affected by road load improvements, such as HD pickups and vans
\760\, non-GHG emissions will increase very slightly due to VMT
rebound. In addition, brake wear and tire wear emissions of
PM2.5 will also increase very slightly due to VMT rebound.
The agencies estimate that downstream emissions of SOX will
be reduced, because they are roughly proportional to fuel consumption.
---------------------------------------------------------------------------
\760\ HD pickups and vans are subject to gram per mile
(distance) emission standards, as opposed to larger heavy-duty
vehicles which are certified to a gram per brake horsepower (work)
standard.
---------------------------------------------------------------------------
For vocational vehicles and tractor-trailers, the agencies used
MOVES to determine non-GHG emissions impacts of the final rules,
relative to the flat baseline (Alternative 1a) and the dynamic baseline
(Alternative 1b). The improvements in engine efficiency and road load,
the increased use of APUs, and VMT rebound were included in the MOVES
analysis. For this analysis, Method B also used the MOVES model for HD
pickups and vans.
The downstream criteria pollutant and air toxics impacts of the
final program, relative to Alternative 1a, using analysis Method B, are
presented in Table VIII-9.
Table VIII-9--Annual Downstream Impacts on Criteria Pollutants and Air Toxics From Heavy-Duty Sector in Calendar Years 2025, 2040 and 2050--Final
Program vs. Alt 1a Using Analysis Method B a
--------------------------------------------------------------------------------------------------------------------------------------------------------
CY2025 CY2040 CY2050
Pollutant -----------------------------------------------------------------------------------------------
US short tons % Change US short tons % Change US short tons % Change
--------------------------------------------------------------------------------------------------------------------------------------------------------
1,3-Butadiene........................................... -1 -0.2 -3 -1.5 -3 -1.8
Acetaldehyde............................................ -3 -0.1 -18 -0.8 -23 -0.9
Acrolein................................................ -0.1 0 -1 -0.3 -1 -0.4
Benzene................................................. -5 -0.2 -22 -1.4 -26 -1.6
CO...................................................... -9,445 -0.4 -35,710 -2.4 -43,642 -2.7
[[Page 73854]]
Formaldehyde............................................ -20 -0.2 -97 -1.5 -120 -1.7
NOX..................................................... -13,396 -1.4 -60,681 -9.7 -74,362 -10.8
PM2.5 \b\............................................... -73 -0.2 -462 -2.2 -580 -2.5
SOX..................................................... -252 -4.7 -1,122 -18.5 -1,341 -20.1
VOC..................................................... -1,071 -0.8 -5,060 -5.9 -6,013 -6.6
--------------------------------------------------------------------------------------------------------------------------------------------------------
Notes:
\a\ For an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 1b,
please see Section X.A.1.
\b\ PM2.5 from tire wear and brake wear are included.
As noted above, EPA is adopting Phase 1 and Phase 2 requirements to
control PM2.5 emissions from APUs installed in new tractors.
In the NPRM, EPA projected an unintended increase in downstream
PM2.5 emissions because engines powering APUs are currently
required to meet less stringent PM standards (40 CFR 1039.101) than on-
road engines (40 CFR 86.007-11) and because the increase in emissions
from APUs more than offset the reduced tailpipe emissions from improved
engine efficiency and road load. However, with the new requirements for
APUs, the final program is projected to lead to reduced downstream
PM2.5 emissions of 462 tons in 2040 and 580 tons in 2050
(Table VIII-9). The net reductions in national PM2.5
emissions from the requirements for APUs are 927 tons and 1,114 tons in
2040 and 2050, respectively (Table VIII-10). See Section III.C.3 of the
Preamble for additional details on EPA's PM emission standards for
APUs. The development of APU emission rates with PM control is
documented in a memorandum to the docket.\761\
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\761\ U.S. EPA. Updates to MOVES for Emissions Analysis of
Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium-
and Heavy-Duty Engines and Vehicles--Phase 2 FRM. Docket No. EPA-HQ-
OAR-2016, July 2016.
Table VIII-10--Impact on PM2.5 Emissions of Further PM2.5 Control on APUs--Final Program vs. Alt 1a Using
Analysis Method B
[US Short Tons] a
----------------------------------------------------------------------------------------------------------------
Final HD phase
Baseline 2 program Final HD phase Net impact on
national heavy- national PM2.5 2 program national PM2.5
CY duty vehicle emissions national PM2.5 emission with
PM2.5 without emissions with further PM
emissions further PM further PM control on
(tons) control (tons) control (tons) APUs (tons)
----------------------------------------------------------------------------------------------------------------
2040............................................ 20,939 21,403 20,476 -927
2050............................................ 22,995 23,529 22,416 -1,114
----------------------------------------------------------------------------------------------------------------
Note:
\a\ For an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat
baseline, 1a, and dynamic baseline, 1b, please see Section X.A.1.
It is worth noting that the emission reductions shown in Table
VIII-9 are not incremental to the emissions reductions projected in the
Phase 1 rulemaking. This is because, as described in Sections
III.D.(1).a of the Preamble, the agencies have revised their
assumptions about the adoption rate of APUs. This final rule assumes
that without the Phase 2 program (i.e., in the Phase 2 baselines), the
APU adoption rate will be 9 percent for model years 2010 and later. EPA
conducted an analysis to estimate the combined emissions impacts of the
Phase 1 and the Phase 2 programs for NOX, VOC,
SOX and PM2.5 in calendar year 2050 using
MOVES2014a. The results are shown in Table VIII-11. For NOX
and PM2.5 only, we also estimated the combined Phase 1 and
Phase 2 downstream and upstream emissions impacts for calendar year
2025, and project that the two rules combined will reduce
NOX by up to 55,000 tons and PM2.5 by up to
33,000 tons in that year. For additional details, see Chapter 5 of the
RIA.
Table VIII-11--Combined Phase 1 and Phase 2 Annual Downstream Impacts on Criteria Pollutants From Heavy-Duty
Sector in Calendar Year 2050--Final Program vs. Alt 1a Using Analysis Method B
[US Short Tons] a
----------------------------------------------------------------------------------------------------------------
CY NOX VOC SOX PM2.5 \b\
----------------------------------------------------------------------------------------------------------------
2050........................................ -100,878 -10,067 -2,249 -1,001
----------------------------------------------------------------------------------------------------------------
Notes:
[[Page 73855]]
\a\ For an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat
baseline, 1a, and more dynamic baseline, 1b, please see Section X.A.1.
(iii) Total Impacts of the Final Program
As shown in Table VIII-12, EPA estimates that the final program
will result in overall net reductions of NOX, VOC,
SOX, CO, PM2.5, and air toxics emissions. The
results are shown both in changes in absolute tons and in percent
reductions from the flat reference to the final program for the heavy-
duty sector.
Table VIII-12--Annual Total Impacts (Upstream and Downstream) of Criteria Pollutants and Air Toxics From Heavy-Duty Sector in Calendar Years 2025, 2040
and 2050--Final Program vs. Alt 1a Using Analysis Method B \a\
--------------------------------------------------------------------------------------------------------------------------------------------------------
CY2025 CY2040 CY2050
Pollutant -----------------------------------------------------------------------------------------------
US short tons % Change US short tons % Change US short tons % Change
--------------------------------------------------------------------------------------------------------------------------------------------------------
1,3-Butadiene........................................... -2 -0.5 -8 -3.7 -9 -4.1
Acetaldehyde............................................ -10 -0.3 -53 -2.0 -61 -2.1
Acrolein................................................ -1 -0.1 -4 -1.3 -5 -1.3
Benzene................................................. -35 -1.1 -165 -6.8 -192 -7.5
CO...................................................... -13,254 -0.6 -52,594 -3.3 -63,869 -3.8
Formaldehyde............................................ -40 -0.5 -187 -2.7 -227 -2.9
NOX..................................................... -22,710 -1.9 -101,961 -12.1 -123,824 -13.3
PM2.5................................................... -1,110 -1.9 -5,081 -11.1 -6,100 -12.1
SOX..................................................... -6,080 -4.8 -26,933 -18.9 -32,282 -20.5
VOC..................................................... -5,305 -2.2 -25,070 -11.9 -29,253 -13.0
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note:
\a\ For an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 1b,
please see Section X.A.1.
(b) Model Year Lifetime Analysis
In addition to the annual non-GHG emissions reductions expected
from the final rules, EPA estimated the combined (downstream and
upstream) non-GHG impacts for the lifetime of the impacted vehicles.
Table VIII-13 shows the fleet-wide reductions of NOX,
PM2.5 and SOX from the final program, relative to
Alternative 1a, through the lifetime \762\ of heavy-duty vehicles. For
the lifetime non-GHG reductions by vehicle categories, see Chapter 5 of
the RIA.
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\762\ A lifetime of 30 years is assumed in MOVES.
Table VIII-13--Lifetime Non-GHG Reductions Using Analysis Method B--
Summary for Model Years 2018-2029
[U.S. Short Tons] a
------------------------------------------------------------------------
Final program
No-action alternative (baseline) ---------------
1a (Flat)
------------------------------------------------------------------------
NOX..................................................... 549,881
Downstream.......................................... 277,644
Upstream............................................ 272,237
PM2.5................................................... 32,251
Downstream \b\...................................... 1,824
Upstream............................................ 30,427
SOX..................................................... 175,202
Downstream.......................................... 4,931
Upstream............................................ 170,272
------------------------------------------------------------------------
Note:
\a\ For an explanation of analytical Methods A and B, please see Section
I.D; for an explanation of the flat baseline, 1a, and dynamic
baseline, 1b, please see Section X.A.1.
\b\ PM2.5 from tire wear and brake wear are included.
D. Air Quality Impacts of Non-GHG Pollutants
Changes in emissions of non-GHG pollutants due to these rules will
impact air quality. Information on current air quality and the results
of our air quality modeling of the projected impacts of these rules are
summarized in the following section. Additional information is
available in Chapter 6 of the RIA.
(1) Current Concentrations of Non-GHG Pollutants
Nationally, levels of PM2.5, ozone, NOX,
SOX, CO and air toxics are declining.\763\ However, as of
April 22, 2016, more than 125 million people lived in counties
designated nonattainment for one or more of the NAAQS, and this figure
does not include the people living in areas with a risk of exceeding a
NAAQS in the future.\764\ Many Americans continue to be exposed to
ambient concentrations of air toxics at levels which have the potential
to cause adverse health effects.\765\ In addition, populations who
live, work, or attend school near major roads experience elevated
exposure concentrations to a wide range of air pollutants.\766\
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\763\ U.S. EPA, 2011. Our Nation's Air: Status and Trends
through 2010. EPA-454/R-12-001. February 2012. Available at: http://www3.epa.gov/airtrends/2011/.
\764\ Data come from Summary Nonattainment Area Population
Exposure Report, current as of April 22, 2016 at: https://www3.epa.gov/airquality/greenbk/popexp.html and contained in Docket
EPA-HQ-OAR-2014-0827.
\765\ U.S. EPA. (2015) Summary of Results for the 2011 National-
Scale Assessment. https://www3.epa.gov/sites/production/files/2015-12/documents/2011-nata-summary-results.pdf.
\766\ Health Effects Institute Panel on the Health Effects of
Traffic-Related Air Pollution. (2010) Traffic-related air pollution:
A critical review of the literature on emissions, exposure, and
health effects. HEI Special Report 17. Available at http://www.healtheffects.org].
---------------------------------------------------------------------------
(a) Particulate Matter
There are two primary NAAQS for PM2.5: An annual
standard (12.0 micrograms per cubic meter ([mu]g/m\3\)) set in 2012 and
a 24-hour standard (35 [mu]g/m\3\) set in 2006, and two secondary NAAQS
for PM2.5: An annual standard (15.0 [mu]g/m\3\) set in 1997
and a 24-hour standard (35 [mu]g/m\3\) set in 2006.
There are many areas of the country that are currently in
nonattainment for the annual and 24-hour primary PM2.5
NAAQS. In 2005 the EPA designated 39 nonattainment areas for the 1997
PM2.5 NAAQS.\767\ As of April 22, 2016, more than 23 million
people lived in the 7 areas that are still designated as nonattainment
for the 1997 annual PM2.5 NAAQS. These PM2.5
[[Page 73856]]
nonattainment areas are comprised of 33 full or partial counties. In
December 2014 EPA designated 14 nonattainment areas for the 2012 annual
PM2.5 NAAQS.\768\ In March 2015, EPA changed the initial
designation from nonattainment to unclassifiable/attainment for four
areas based on the availability of complete, certified 2014 air quality
data showing these areas met the 2012 annual PM2.5 NAAQS.
The EPA also changed the initial 2012 annual PM2.5 NAAQS
designation from nonattainment to unclassifiable for the Louisville,
Indiana-Kentucky area. \769\ As of April 22, 2016, 9 of these areas
remain designated as nonattainment, and they are composed of 20 full or
partial counties with a population of over 23 million. On November 13,
2009 and February 3, 2011, the EPA designated 32 nonattainment areas
for the 2006 24-hour PM2.5 NAAQS.\770\ As of April 22, 2016,
16 of these areas remain designated as nonattainment for the 2006 24-
hour PM2.5 NAAQS, and they are composed of 46 full or
partial counties with a population of over 32 million. In total, there
are currently 24 PM2.5 nonattainment areas with a population
of more than 39 million people.\771\
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\767\ 70 FR 19844 (April 14, 2005).
\768\ EPA 2014. Fact Sheet: Final Area Designations for the
Annual Fine Particle Standard. https://www3.epa.gov/pmdesignations/2012standards/final/20141218fs.pdf.
\769\ https://www3.epa.gov/pmdesignations/2012standards/final/20150331fs.pdf.
\770\ 74 FR 58688 (November 13, 2009) and 76 FR 6056 (February
3, 2011).
\771\ The 39 million total is calculated by summing, without
double counting, the 1997, 2006 and 2012 PM2.5
nonattainment populations contained in the Summary Nonattainment
Area Population Exposure report (https://www3.epa.gov/airquality/greenbk/popexp.html). If there is a population associated with more
than one of the 1997, 2006 and 2012 nonattainment areas, and they
are not the same, then the larger of the populations is included in
the sum.
---------------------------------------------------------------------------
The EPA has already adopted many mobile source emission control
programs that are expected to reduce ambient PM concentrations. As a
result of these and other federal, state and local programs, the number
of areas that fail to meet the PM2.5 NAAQS in the future is
expected to decrease. However, even with the implementation of all
current state and federal regulations, there are projected to be
counties violating the PM2.5 NAAQS well into the future.
States will need to meet the 2006 24-hour standards in the 2015-2019
timeframe and the 2012 primary annual standard in the 2021-2025
timeframe. The emission reductions and improvements in ambient
PM2.5 concentrations from this action, which will take
effect as early as model year 2018, will be helpful to states as they
work to attain and maintain the PM2.5 NAAQS.\772\ The
standards can assist areas with attainment dates in 2018 and beyond in
attaining the NAAQS as expeditiously as practicable and may relieve
areas with already stringent local regulations from some of the burden
associated with adopting additional local controls.
---------------------------------------------------------------------------
\772\ The final Phase 2 trailer standards and PM controls for
APUs begin with model year 2018.
---------------------------------------------------------------------------
(b) Ozone
The primary and secondary NAAQS for ozone are 8-hour standards with
a level of 0.07 ppm. The most recent revision to the ozone standards
was in 2015; the previous 8-hour ozone primary standard, set in 2008,
had a level of 0.075 ppm. Final nonattainment designations for the 2008
ozone standard were issued on April 30, 2012, and May 31, 2012.\773\ As
of April 22, 2016, there were 44 ozone nonattainment areas for the 2008
ozone NAAQS, composed of 216 full or partial counties, with a
population of more than 120 million. In addition, EPA plans to finalize
nonattainment areas for the 2015 ozone NAAQS in October 2017.
---------------------------------------------------------------------------
\773\ 77 FR 30088 (May 21, 2012) and 77 FR 34221 (June 11,
2012).
---------------------------------------------------------------------------
States with ozone nonattainment areas are required to take action
to bring those areas into attainment. The attainment date assigned to
an ozone nonattainment area is based on the area's classification. The
attainment dates for areas designated nonattainment for the 2008 8-hour
ozone NAAQS are in the 2015 to 2032 timeframe, depending on the
severity of the problem in each area. Nonattainment area attainment
dates associated with areas designated for the 2015 NAAQS will be in
the 2020-2037 timeframe, depending on the severity of the problem in
each area.\774\
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\774\ https://www3.epa.gov/ozone-pollution/2015-ozone-naaqs-timelines.
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EPA has already adopted many emission control programs that are
expected to reduce ambient ozone levels. As a result of these and other
federal, state and local programs, 8-hour ozone levels are expected to
improve in the future. However, even with the implementation of all
current state and federal regulations, there are projected to be
counties violating the ozone NAAQS well into the future. The emission
reductions from this action, which will take effect as early as model
year 2018, will be helpful to states as they work to attain and
maintain the ozone NAAQS.\775\ The standards can assist areas with
attainment dates in 2018 and beyond in attaining the NAAQS as
expeditiously as practicable and may relieve areas with already
stringent local regulations from some of the burden associated with
adopting additional local controls.
---------------------------------------------------------------------------
\775\ The final Phase 2 trailer standards begin with model year
2018.
---------------------------------------------------------------------------
(c) Nitrogen Dioxide
The EPA most recently completed a review of the primary NAAQS for
NO2 in January 2010. There are two primary NAAQS for
NO2: An annual standard (53 ppb) and a 1-hour standard (100
ppb). The EPA promulgated area designations in the Federal Register on
February 17, 2012. In this initial round of designations, all areas of
the country were designated as ``unclassifiable/attainment'' for the
2010 NO2 NAAQS based on data from the existing air quality
monitoring network. The EPA and state agencies are working to establish
an expanded network of NO2 monitors, expected to be deployed
in the 2014-2017 time frame. Once three years of air quality data have
been collected from the expanded network, the EPA will be able to
evaluate NO2 air quality in additional
locations.776 777
---------------------------------------------------------------------------
\776\ U.S. EPA. (2012). Fact Sheet--Air Quality Designations for
the 2010 Primary Nitrogen Dioxide (NO2) National Ambient
Air Quality Standards. http://www3.epa.gov/airquality/nitrogenoxides/designations/pdfs/20120120FS.pdf.
\777\ U.S. Environmental Protection Agency (2013). Revision to
Ambient Nitrogen Dioxide Monitoring Requirements. March 7, 2013.
http://www3.epa.gov/airquality/nitrogenoxides/pdfs/20130307fr.pdf.
---------------------------------------------------------------------------
(d) Sulfur Dioxide
The EPA most recently completed a review of the primary
SO2 NAAQS in June 2010. The current primary NAAQS for
SO2 is a 1-hour standard of 75 ppb. The EPA finalized the
initial area designations for 29 nonattainment areas in 16 states in a
notice published in the Federal Register on August 5, 2013. In this
first round of designations, EPA only designated nonattainment areas
that were violating the standard based on existing air quality
monitoring data provided by the states. The agency did not have
sufficient information to designate any area as ``attainment'' or make
final decisions about areas for which additional modeling or monitoring
is needed (78 FR 47191, August 5, 2013). On March 2, 2015, the U.S.
District Court for the Northern District of California accepted, as an
enforceable order, an agreement between the EPA and Sierra Club and
Natural Resources Defense Council to resolve litigation concerning the
deadline for completing designations.\778\ The court's order directs
the EPA to complete designations for all remaining
[[Page 73857]]
areas in the country in up to three additional rounds: The first round
by July 2, 2016, the second round by December 31, 2017, and the final
round by December 31, 2020.
---------------------------------------------------------------------------
\778\ Sierra Club v. McCarthy, No. 3-13-cv-3953 (SI) (N.D. Cal.
Mar. 2, 2015).
---------------------------------------------------------------------------
(e) Carbon Monoxide
There are two primary NAAQS for CO: An 8-hour standard (9 ppm) and
a 1-hour standard (35 ppm). The primary NAAQS for CO were retained in
August 2011. There are currently no CO nonattainment areas; as of
September 27, 2010, all CO nonattainment areas have been redesignated
to attainment.
The past designations were based on the existing community-wide
monitoring network. EPA is making changes to the ambient air monitoring
requirements for CO. The new requirements are expected to result in
approximately 52 CO monitors operating near roads within 52 urban areas
by January 2015 (76 FR 54294, August 31, 2011).
(f) Diesel Exhaust PM
Because DPM is part of overall ambient PM and cannot be easily
distinguished from overall PM, we do not have direct measurements of
DPM in the ambient air. DPM concentrations are estimated using ambient
air quality modeling based on DPM emission inventories. DPM emission
inventories are computed as the exhaust PM emissions from mobile
sources combusting diesel or residual oil fuel. DPM concentrations were
recently estimated as part of the 2011 NATA.\779\ Areas with high
concentrations are clustered in the Northeast, Great Lake States,
California, and the Gulf Coast States and are also distributed
throughout the rest of the U.S. The median DPM concentration calculated
nationwide is 0.76 [mu]g/m\3\. Half of the DPM can be attributed to
heavy-duty diesel vehicles.
---------------------------------------------------------------------------
\779\ U.S. EPA (2015) 2011 National-Scale Air Toxics Assessment.
https://www3.epa.gov/national-air-toxics-assessment/2011-nata-assessment-results#emissions.
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(g) Air Toxics
The most recent available data indicate that the majority of
Americans continue to be exposed to ambient concentrations of air
toxics at levels which have the potential to cause adverse health
effects. The levels of air toxics to which people are exposed vary
depending on where people live and work and the kinds of activities in
which they engage, as discussed in detail in EPA's most recent Mobile
Source Air Toxics Rule.\780\ According to the National Air Toxic
Assessment (NATA) for 2011, mobile sources were responsible for 50
percent of outdoor anthropogenic toxic emissions and were the largest
contributor to cancer and noncancer risk from directly emitted
pollutants.781 782 Mobile sources are also large
contributors to precursor emissions which react to form air toxics.
Formaldehyde is the largest contributor to cancer risk of all 71
pollutants quantitatively assessed in the 2011 NATA. Mobile sources
were responsible for more than 25 percent of primary anthropogenic
emissions of this pollutant in 2011 and are major contributors to
formaldehyde precursor emissions. Benzene is also a large contributor
to cancer risk, and mobile sources account for almost 80 percent of
ambient exposure. Over the years, EPA has implemented a number of
mobile source and fuel controls which have resulted in VOC reductions,
which also reduced formaldehyde, benzene and other air toxic emissions.
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\780\ U.S. Environmental Protection Agency (2007). Control of
Hazardous Air Pollutants from Mobile Sources; Final Rule. 72 FR
8434, February 26, 2007.
\781\ U.S. EPA. (2015) 2011 NATA: Assessment Results. https://www3.epa.gov/national-air-toxics-assessment/2011-nata-assessment-results.
\782\ NATA also includes estimates of risk attributable to
background concentrations, which includes contributions from long-
range transport, persistent air toxics, and natural sources; as well
as secondary concentrations, where toxics are formed via secondary
formation. Mobile sources substantially contribute to long-range
transport and secondarily formed air toxics.
---------------------------------------------------------------------------
(2) Impacts of the Rule on Projected Air Quality
Along with reducing GHGs, the Phase 2 standards also have an impact
on non-GHG, criteria and air toxic pollutant, emissions. As shown above
in Section VIII.C, the standards will impact exhaust emissions of these
pollutants from vehicles and will also impact emissions that occur
during the refining and distribution of fuel (upstream sources).
Reductions in emissions of NOX, VOC, PM2.5 and
air toxics expected as a result of the Phase 2 standards will lead to
improvements in air quality, specifically decreases in ambient
concentrations of PM2.5, ozone, NO2 and air
toxics, as well as better visibility and reduced deposition.
Emissions and air quality modeling decisions are made early in the
analytical process because of the time and resources associated with
full-scale photochemical air quality modeling. As a result, the
inventories used in the air quality modeling and the benefits modeling
are different from the final emissions inventories presented in Section
VIII.C. The air quality inventories and the final inventories are
consistent in many ways, but there are some important differences. For
example, in this final rulemaking, EPA is adopting Phase 1 and Phase 2
requirements to control PM2.5 emissions from APUs installed
in new tractors, so we do not expect increases in downstream
PM2.5 emissions from the Phase 2 program; however, the air
quality inventories do not reflect these requirements and therefore
show increases in downstream PM2.5 emissions. Chapter 5 of
the RIA has more detail on the differences between the air quality and
final inventories. The results of our air quality modeling of the
criteria pollutant and air toxics impacts of the Phase 2 standards are
summarized in the RIA and presented in more detail in Appendix 6A to
the RIA.
IX. Economic and Other Impacts
This section presents the costs, benefits and other economic
impacts of the Phase 2 standards. It is important to note that NHTSA's
fuel consumption standards and EPA's GHG standards will both be in
effect, and each will lead to average fuel efficiency increases and GHG
emission reductions.
The net benefits of the Phase 2 standards consist of the effects of
the program on:
vehicle program costs (costs of complying with the vehicle
CO2 and fuel consumption standards)
changes in fuel expenditures associated with reduced fuel use
resulting from more efficient vehicles and increased fuel use
associated with the ``rebound'' effect, both of which result from the
program
economic value of reductions in GHGs
economic value of reductions in non-GHG pollutants
costs associated with increases in noise, congestion, and
crashes resulting from increased vehicle use
savings in drivers' time from less frequent refueling
benefits of increased vehicle use associated with the
``rebound'' effect
economic value of improvements in U.S. energy security
The benefits and costs of these rules are analyzed using 3 percent
and 7 percent discount rates, consistent with current OMB
guidance.\783\ These rates
[[Page 73858]]
are intended to represent consumers' preference for current over future
consumption (3 percent), and the real rate of return on private
investment (7 percent) which indicates the opportunity cost of capital.
However, neither of these rates necessarily represents the discount
rate that individual decision-makers use.
---------------------------------------------------------------------------
\783\ The range of Social Cost of Carbon (SC-CO2)
values uses several discount rates because the literature shows that
the SC-CO2 is quite sensitive to assumptions about the
discount rate, and because no consensus exists on the appropriate
rate to use in an intergenerational context (where costs and
benefits are incurred by different generations). Refer to Section
IX.F.1 for more information.
---------------------------------------------------------------------------
The program may also have other economic effects that are not
included here. As discussed in Sections III through VI of this Preamble
and in Chapter 2 of the RIA, the technology cost estimates developed
here take into account the costs to hold other vehicle attributes, such
as size and performance, constant. With these assumptions, and because
welfare losses represent monetary estimates of how much buyers would
have to be compensated to be made as well off as they would have been
in the absence of this regulation,\784\ price increases for new
vehicles measure the welfare losses to the vehicle buyers.\785\ If the
full technology cost gets passed along to the buyer as an increase in
price, the technology cost thus measures the primary welfare loss of
the standards, including impacts on buyers. Increasing fuel efficiency
would have to lead to other changes in the vehicles that buyers find
undesirable for there to be additional welfare losses that are not
included in the technology costs.
---------------------------------------------------------------------------
\784\ This approach describes the economic concept of
compensating variation, a payment of money after a change that would
make a consumer as well off after the change as before it. A related
concept, equivalent variation, estimates the income change that
would be an alternative to the change taking place. The difference
between them is whether the consumer's point of reference is her
welfare before the change (compensating variation) or after the
change (equivalent variation). In practice, these two measures are
typically very close together.
\785\ Indeed, it is likely to be an overestimate of the loss to
the consumer, because the buyer has choices other than buying the
same vehicle with a higher price; she could choose a different
vehicle, or decide not to buy a new vehicle. The buyer would choose
one of those options only if the alternative involves less loss than
paying the higher price. Thus, the increase in price that the buyer
faces would be the upper bound of loss of consumer welfare, unless
there are other changes to the vehicle due to the fuel efficiency
improvements that make the vehicle less desirable to consumers.
---------------------------------------------------------------------------
As the 2012-2016 and 2017-2025 light-duty GHG/CAFE rules discussed,
if other vehicle attributes are not held constant, then the technology
cost estimates do not capture the losses to vehicle buyers associated
with these changes.\786\ The light-duty rules also discussed other
potential issues that could affect the calculation of the welfare
impacts of these types of changes, such as aspects of buyers' behavior
that might affect the demand for technology investments, uncertainty in
buyers' investment horizons, and the rate at which truck owner's trade
off higher vehicle purchase price against future fuel savings.
---------------------------------------------------------------------------
\786\ Environmental Protection Agency and Department of
Transportation, ``Light-Duty Vehicle Greenhouse Gas Emission
Standards and Corporate Average Fuel Economy Standards; Final
Rule,'' 75 FR 25324, May 7, 2010, especially Sections III.H.1
(25510-25513) and IV.G.6 (25651-25657); Environmental Protection
Agency and Department of Transportation, ''2017 and Later Model Year
Light-Duty Vehicle Greenhouse Gas Emissions and Corporate Average
Fuel Economy Standards; Final Rule,'' 77 FR 62624, October 15, 2012,
especially Sections III.H.1 (62913-62919) and IV.G.5.a (63102-
63104).
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Where possible, we identify the uncertain aspects of these economic
impacts and attempt to quantify them (e.g., sensitivity ranges
associated with quantified and monetized GHG impacts; range of dollar-
per-ton values to monetize non-GHG health benefits; uncertainty with
respect to learning and markups). The agencies have examined the
sensitivity of oil prices on fuel expenditures; results of this
sensitivity analysis can be found in Chapter 8 of the RIA. NHTSA's EIS
also characterizes the uncertainty in economic impacts associated with
the HD national program. For other impacts, however, there is
inadequate information to inform a thorough, quantitative assessment of
uncertainty. EPA and NHTSA continue to work toward developing a
comprehensive strategy for characterizing the aggregate impact of
uncertainty in key elements of its analyses and we will continue to
work to refine these uncertainty analyses in the future as time and
resources permit.
This and other sections of the Preamble address Section 317 of the
Clean Air Act on economic analysis. Section IX.L addresses Section 321
of the Clean Air Act on employment analysis. The total monetized
benefits and costs of the program are summarized in Section IX.K for
the final program and in Section X for all alternatives.
The agencies sought comment on numerous aspects of the analyses
presented in this section, such as the potential omissions of costs or
benefits, additional impacts of the standards on vehicle attributes and
performance, and the quantification of uncertainty. Responses to
comments on specific aspects of the analysis are addressed as
appropriate in the relevant sections below, and in Sections III through
VI of this Preamble as they relate to certain technologies. Further
detail can be found in Section 11 of the RTC.
A. Conceptual Framework
The HD Phase 2 standards will implement both the 2007 Energy
Independence and Security Act requirement that NHTSA establish fuel
efficiency standards for medium- and heavy-duty vehicles and the Clean
Air Act requirement that EPA adopt technology-based standards to
control pollutant emissions from motor vehicles and engines
contributing to air pollution that endangers public health and welfare.
NHTSA's statutory mandate is intended to further the agency's long-
standing goals of reducing U.S. consumption and imports of petroleum
energy to improve the nation's energy security.
From an economics perspective, government actions to improve our
nation's energy security and to protect our nation from the potential
threats of climate change address ``externalities,'' or economic
consequences of decisions by individuals and businesses that extend
beyond those who make these decisions. For example, users of
transportation fuels increase the entire U.S. economy's risk of having
to make costly adjustments due to rapid increases in oil prices, but
these users generally do not consider such costs when they decide to
consume more fuel.
Similarly, consuming transportation fuel also increases emissions
of greenhouse gases and other more localized air pollutants that occur
when fuel is refined, distributed, and consumed. Some of these
emissions increase the likelihood and severity of potential climate-
related economic damages, and others cause economic damages by
adversely affecting human health. The need to address these external
costs and other adverse effects provides a well-established economic
rationale that supports the statutory direction given to government
agencies to establish regulatory programs that reduce the magnitude of
these adverse effects at reasonable costs.
The Phase 2 standards will require manufacturers of new heavy-duty
vehicles, including trailers (HDVs), to improve the fuel efficiency of
the products that they produce. As HDV users purchase and operate these
new vehicles, they will consume significantly less fuel, in turn
reducing U.S. petroleum consumption and imports as well as emissions of
GHGs and other air pollutants. Thus, as a consequence of the agencies'
efforts to meet our statutory obligations to improve U.S. energy
security and EPA's obligation to issue standards ``to regulate
emissions of the deleterious pollutant . . . from motor vehicles'' that
endangers public health and welfare,\787\
[[Page 73859]]
the fuel efficiency and GHG emission standards will also reduce HDV
operators' outlays for fuel purchases. These fuel savings are one
measure of the final rule's effectiveness in promoting NHTSA's
statutory goal of conserving energy, as well as EPA's obligation under
section 202(a)(1) and (2) of the Clean Air Act to assess the cost of
standards. Although these savings are not the agencies' primary
motivation for adopting higher fuel efficiency standards, these
substantial fuel savings represent significant additional economic
benefits of these rules.
---------------------------------------------------------------------------
\787\ State of Massachusetts v. EPA, 549 U.S. at 533.
---------------------------------------------------------------------------
Potential savings in fuel costs appear to offer HDV buyer's strong
incentives to pay higher prices for vehicles that feature technology or
equipment that reduces fuel consumption. These potential savings also
appear to offer HDV manufacturers similarly strong incentives to
produce more fuel-efficient vehicles. Economic theory suggests that
interactions between vehicle buyers and sellers in a normally-
functioning competitive market would lead HDV manufacturers to
incorporate all technologies that contribute to lower net costs into
the vehicles they offer, and buyers to purchase them willingly.
Nevertheless, many readily available technologies that appear to offer
cost-effective increases in HDV fuel efficiency (when evaluated over
their expected lifetimes using conventional discount rates) have not
been widely adopted, despite their potential to repay buyers' initial
investments rapidly.
This economic situation is commonly known as the ``energy
efficiency gap'' or ``energy paradox.'' This situation is perhaps more
challenging to understand with respect to the heavy-duty sector versus
the light-duty vehicle sector. Unlike light-duty vehicles--which are
purchased and used mainly by individuals and households--the vast
majority of HDVs are purchased and operated by profit-seeking
businesses for which fuel costs represent a substantial operating
expense. We asked for comments on our hypotheses about causes of the
gap, as well as data or other information that can inform our
understanding of why this situation seems to persist. The California
Air Resources Board, CALSTART, Consumer Federation of America,
Institute for Policy Integrity at NYU School of Law, and International
Council on Clean Transportation supported, either in whole or in part,
the agencies' arguments for potential barriers to market adoption.
Caterpillar Inc. et al., Competitive Enterprise Institute (CEI),
Randall Lutter, Brian Mannix, NAFA Fleet Management Association (NAFA),
Owner-Operator Independent Drivers Association (OOIDA), Truck Renting
and Leasing Association (TRALA), and Utility Trailer Manufacturing
Company express skepticism or raise concerns about the agencies'
discussion. The skeptical comments, discussed in more depth in context
below, generally find it implausible that regulations can save money
for profit-seeking businesses. If the savings were real, they argue,
then private markets would have adopted these technologies without
regulations; the agencies must therefore have exaggerated the benefits
or underestimated the costs of the standards. Problems exist not in
private market operations, they claim, but rather in the economic
analysis of those operations.
The economic analysis of these standards is based on the
engineering analysis of the costs and effectiveness of the
technologies. The agencies have detailed their findings on costs and
effectiveness in Preamble Sections III, IV, V, and VI, and RIA Chapter
2. If these cost and effectiveness estimates are correct, and if the
agencies have not omitted key costs or benefits, then the efficiency
gap exists, even if it seems implausible to some. As will be discussed
further below, comments that raise issues with that technical analysis,
such as concerns about maintenance and reliability costs of the
technologies, present possible reasons that the gap is not as large as
the agencies have found, and are discussed in the cost and
effectiveness sections mentioned above. Comments that question the
explanations provided for the gap without addressing the cost and
effectiveness analyses do not provide evidence of an absence of the
gap. Explaining why the gap exists is a separate and difficult
challenge from observing the existence of the gap, because of the
difficulties involved in developing tests of the different possible
explanations. As discussed below, there is very little empirical
evidence on behaviors that might lead to the gap, even while there
continues to be substantial evidence, via the cost and effectiveness
analysis, of the gap's existence. On the basis of that evidence, the
agencies believe that a significant number of fuel efficiency improving
technologies would remain far less widely adopted in the absence of
these standards.
Economic research offers several possible explanations for why the
prospect of these apparent savings might not lead HDV manufacturers and
buyers to adopt technologies that would be expected to reduce HDV
operating costs. Some of these explanations involve failures of the HDV
market for reasons other than the externalities caused by producing and
consuming fuel. Examples include situations where information about the
performance of fuel economy technologies is incomplete, costly to
obtain, or available only to one party to a transaction (or
``asymmetrical''), as well as behavioral rigidities in either the HDV
manufacturing or HDV-operating industries, such as standardized or
inflexibly administered operating procedures, or requirements of other
regulations on HDVs. Examples that do not involve market failures
include possible effects on the performance, reliability, carrying
capacity, maintenance requirements of new technology under the demands
of everyday use, or transaction or adjustment costs. We note again that
these and other hypotheses are presented as potential explanations of
the finding of an efficiency gap based on an engineering analysis. They
are not themselves the basis for regulation.
In the HD Phase 1 rulemaking (which, in contrast to these
standards, did not apply to trailers), and in the Phase 2 NPRM, the
agencies raised various hypotheses that might explain this energy
efficiency gap or paradox.
Imperfect information in the new vehicle market:
Information available to prospective buyers about the effectiveness of
some fuel-saving technologies for new vehicles may be inadequate or
unreliable. If reliable information on their effectiveness in reducing
fuel consumption is unavailable or difficult to obtain, HDV buyers will
understandably be reluctant to pay higher prices to purchase vehicles
equipped with unproven technologies.
Some commenters argue that this explanation implies implausibly
that the agencies have information that those with profit motives do
not, and that EPA's SmartWay Program has already served the function of
sharing public information with the private sector. Other commenters
agree with the agencies that imperfect information is a potential
market barrier.
As discussed in the NPRM, one common theme from recent research
\788\
[[Page 73860]]
is the inability of HDV buyers to obtain reliable information about the
fuel savings, reliability, and maintenance costs of technologies that
improve fuel efficiency. See 80 FR 40436. In the trucking industry, the
performance of fuel-saving technology is likely to depend on many firm-
specific attributes, including the intensity of HDV use, the typical
distance and routing of HDV trips, driver characteristics, road
conditions, regional geography and traffic patterns. As a result,
businesses that operate HDVs have strong preferences for testing fuel-
saving technologies ``in-house'' because they are concerned that their
patterns of vehicle use may lead to different results from those
reported in published information. Businesses with less capability to
do in-house testing often seek information from peers, yet often remain
skeptical of its applicability due to differences in the nature of
their operations.
---------------------------------------------------------------------------
\788\ Klemick, Heather, Elizabeth Kopits, Keith Sargent, and Ann
Wolverton (2015). ``Heavy-Duty Trucking and the Energy Efficiency
Paradox: Evidence form Focus Groups and Interviews.'' Transportation
Research Part A 77: 154-166, Docket EPA-HQ-OAR-2014-0827; Roeth,
Mike, Dave Kircher, Joel Smith, and Rob Swim (2013). ``Barriers to
the Increased Adoption of Fuel Efficiency Technologies in the North
American On-Road Freight Sector.'' NACFE report for the
International Council on Clean Transportation, Docket EPA-HQ-OAR-
2014-0827-0084; Aarnink, Sanne, Jasper Faber, and Eelco den Boer
(2012). ``Market Barriers to Increased Efficiency in the European
On-road Freight Sector.'' CE Delft report for the International
Council on Clean Transportation, Docket EPA-HQ-OAR-2014-0827-0076.
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Imperfect information in the resale market: Buyers in the
used vehicle market may not be willing to pay adequate premiums for
more fuel efficient vehicles when they are offered for resale to ensure
that buyers of new vehicles can recover the remaining value of their
original investment in higher fuel efficiency. The prospect of an
inadequate return on their original owners' investments in higher fuel
efficiency may contribute to the short payback periods that buyers of
new vehicles appear to demand.\789\
---------------------------------------------------------------------------
\789\ 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 2010''). Washington, DC The National Academies Press.
Available electronically from the National Academies Press Web site
at http://www.nap.edu/catalog.php?record_id=12845 (accessed
September 10, 2010), Docket EPA-HQ-OAR-2014-0827-0122.
---------------------------------------------------------------------------
CEI rejects this hypothesis, asserting that buyers in this market
do consider the value of technologies on used vehicles; other
commenters support this possibility.
The recent research cited above (Klemick et al. 2015, Roeth et al.
2013, Aarnink et al. 2012) found mixed evidence for imperfect
information in the market for used HDVs. On the one hand, some studies
noted that fuel-saving technology is often not appreciated in the used
vehicle market, because of imperfect information about its benefits, or
greater mistrust of its performance among buyers in the used vehicle
market than among buyers of new vehicles. When buyers of new vehicles
considered features that would affect value in the secondary market,
those features were rarely related to fuel economy. In addition, some
used-vehicle buyers might have a larger ``knowledge gap'' than new-
vehicle buyers. In other cases, the lack of interest might be due to
the intended use of the used HDVs, which may not reward the presence of
certain fuel-saving technologies. In other cases, however, fuel-saving
technology can lead to a premium in the used market, as for instance to
meet the more stringent requirements for HDVs operating in California.
Principal-agent problems causing split incentives: An HDV
buyer may not be directly responsible for its future fuel costs, or the
individual who will be responsible for fuel costs may not participate
in the HDV purchase decision. In these cases, the signal to invest in
higher fuel efficiency normally provided by savings in fuel costs may
not be transmitted effectively to HDV buyers, and the incentives of HDV
buyers and fuel buyers will diverge, or be ``split.'' The trailers
towed by heavy-duty tractors, which are typically not supplied by the
tractor manufacturer or seller, present an obvious potential situation
of split incentives that was not addressed in the HD Phase 1
rulemaking, but which may apply in this rulemaking. If there is
inadequate pass-through of price signals from trailer users to their
buyers, then low adoption of fuel-saving technologies may result.
CEI argues that, even if these split incentives existed, vehicle
purchasers still might not invest in fuel-saving technologies due to
capital constraints. As discussed below, capital constraints may be an
issue for smaller companies, but they do not appear to be a significant
concern for larger companies. Mr. Lutter provides a working paper \790\
in which the authors do not find a statistically significant or
negative relationship when the box trailer has different ownership than
the tractor, a result that does not support evidence of the split-
incentives problem between tractors and trailers. As the papers below
discuss, the split-incentives problem can take more forms than the
difference in ownership between tractors and box trailers examined in
this comment.
---------------------------------------------------------------------------
\790\ Fraas, Art, Randall Lutter, Zachary Porter, and Alexander
Wallace (2016). ``The Energy Paradox and the Adoption of Energy-
Saving Technologies in the Trucking Industry.'' Working Paper,
Mercatus Center, George Mason University, Docket EPA-HQ-OAR-2014-
0827-1879.
---------------------------------------------------------------------------
Other recent research identifies split incentives, or principal-
agent problems, as a potential barrier to technology adoption. For
instance, Vernon and Meier (2012) estimate that 23 percent of trailers
may be exposed to split incentives due to businesses that own and lease
trailers to HDV operators not having an incentive to invest in trailer-
specific fuel-saving technology.\791\ They also estimate that 5 percent
of HDV fuel use is subject to split incentives that arise when the firm
paying fuel costs does not make the tractor investment decision (e.g.,
because a carrier subcontracts to an owner-operator but still pays for
fuel). As CEI points out, in the case of a split incentive when the
driver is not responsible for paying fuel costs, the owner is the
principal who seeks fuel savings, and the driver is the agent with
potentially low incentive to provide those savings; there are a number
of potential sources of inefficiency in fuel use, though not all of
them are expected to result in underinvestment in fuel-saving
technologies. Vernon and Meier (2012) do not quantify the financial
significance of these problems.
---------------------------------------------------------------------------
\791\ Vernon, David and Alan Meier (2012). ``Identification and
quantification of principal-agent problems affecting energy
efficiency investments and use decisions in the trucking industry.''
Energy Policy, 49(C), pp. 266-273, Docket EPA-HQ-OAR-2014-0827-0090.
---------------------------------------------------------------------------
Klemick et al. (2015), Aarnink et al. (2012), and Roeth et al.
(2013) provide mixed evidence on the severity of the split-incentive
problem. Focus groups often identify diverging incentives between
drivers and the decision-makers responsible for purchasing vehicles.
Aarnink et al. (2012) and Roeth et al. (2013) cite examples of split
incentives involving trailers and fuel surcharges, although the latter
also cites other examples where these same issues do not lead to split
incentives. In an effort to minimize problems that can arise from split
incentives, many businesses that operate HDVs also train drivers in the
use of specific technologies or to modify their driving behavior in
order to improve fuel efficiency, while some also offer financial
incentives to their drivers to conserve fuel. All of these options can
help to reduce the split incentive problem.
Uncertainty about future fuel cost savings: HDV buyers may
be uncertain about future fuel prices, or about maintenance costs and
reliability of some fuel efficiency technologies. In contrast, the
costs of fuel-saving technologies are immediate. If buyers
[[Page 73861]]
are loss-averse, they may react to this uncertainty by underinvesting
in technologies to improve fuel economy. In this situation, potential
variability about buyers' expected returns on capital investments to
achieve higher fuel efficiency may shorten the payback period--the time
required to repay those investments--they demand in order to make them.
Various commenters support this hypothesis. The CEI draws on the
experience of nitrogen oxides (NOX) regulations from 2004
and 2007 to support its arguments. As discussed more below, the
NOX standards are unlikely to provide much, if any,
precedential value for the GHG/fuel economy standards. Other commenters
raise questions related to uncertainty about future costs for fuel and
maintenance, as well as about the reliability of new technology that
could result in costly downtime. Section IX.D. below discusses
maintenance expenditures under these standards. These examples
illustrate the problem of uncertain or unreliable information about the
actual performance of fuel efficiency technology discussed above. Roeth
et al. (2013) and Klemick et al. (2015) both document the short payback
periods that HDV buyers require on their investments--usually about 2
years--which may be partly attributable to these uncertainties.
Adjustment and transactions costs: Potential resistance to
new technologies--stemming, for example, from drivers' reluctance or
slowness to adjust to changes in the way vehicles operate--may slow or
inhibit new technology adoption. If a conservative approach to new
technologies leads HDV buyers to adopt them slowly, then successful new
technologies will be adopted over time without market intervention, but
only with potentially significant delays in achieving the fuel saving,
environmental, and energy security benefits they offer. There also may
be costs associated with training drivers to realize potential fuel
savings enabled by new technologies, or with accelerating fleet
operators' scheduled fleet turnover and replacement to hasten their
acquisition of vehicles equipped with these technologies. These factors
might present real resource costs to firms that are not reflected in a
typical engineering analysis.
CEI argues that these costs are normal aspects of the innovation
process, and competition continually drives firms to innovate in most
industries. As discussed below, innovation is not always a continual
and smooth response to competition as CEI suggests.
Klemick et al. (2015), Roeth et al. (2013), and Aarnink et al.
(2012) provide some support for the view that adjustment and
transactions costs may impede HDV buyers from investing in higher fuel
efficiency. These studies note that HDV buyers are less likely to
select new technology when it is not available from their preferred
manufacturers. Some technologies are only available as after-market
additions, which can add other costs to adopting them.
Driver acceptance of new equipment or technologies as a
barrier to their adoption. HDV driver turnover is high in the U.S., and
businesses that operate HDVs are concerned about retaining their best
drivers. Therefore, they may avoid technologies that require
significant new training or adjustments in driver behavior.
NAFA Fleet Management Association states that the standards will
increase pressure on already strained driver and technician resources.
The agencies understand that the industry experiences a great deal of
driver turnover; we do not know how the standards will affect that
turnover. Changes to vehicles that require some changes in driver
behavior may increase driver turnover. For instance, drivers who prefer
manual transmissions may respond poorly to vehicles with automatic
transmissions. On the other hand, the switch to automatic transmissions
may facilitate entry of new drivers who no longer need to learn as much
about shifting.
For some technologies that can be used to meet these standards,
such as automatic tire inflation systems, training costs are likely to
be minimal. Other technologies, such as stop-start systems, may require
drivers to adjust their expectations about vehicle operation, and it is
difficult for the agencies to anticipate how drivers will respond to
such changes.\792\
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\792\ The distinction between simply requiring drivers (or
mechanics) to adjust their expectations and compromises in vehicle
performance or utility is subtle. While the former may not impose
significant compliance costs in the long run, the latter would
represent additional economic costs of complying with the standard.
---------------------------------------------------------------------------
Constraints on access to capital for investment. If buyers
of new vehicles have limited funds available, then they must choose
between investing in fuel-saving technology and other vehicle
technologies or attributes.
CEI states that investments require tradeoffs: Investment in fuel
economy crowds out other investments. There would be tradeoffs in
purchasing choices if capital markets are constrained, and fuel-saving
technologies do not provide returns sufficient to achieve the hurdle
rates that the buyers require. Klemick et al. (2015) did not find
capital constraints to be a problem for the medium- and large-sized
businesses participating in their study. On the other hand, Roeth et
al. (2013) noted that access to capital can be a significant challenge
to smaller or independent businesses, and that price is always a
concern to buyers. Section XIV.D. discusses the agencies' outreach to
small businesses to learn about their special circumstances. These are
reflected in various flexibilities for small businesses in the
regulations.
``Network externalities,'' where the benefits to new users
of a technology depend on how many others have already adopted it. If
the value of a technology increases with increasing adoption, then it
can be difficult for the adoption process to begin: Each potential
adopter has an incentive to wait for others to adopt before making the
investment. If all adopters wait for others, then adoption may not
happen.
One example where network externalities seem likely to arise is the
market for natural gas-fueled HDVs: The limited availability of
refueling stations may reduce potential buyers' willingness to purchase
natural gas-fueled HDVs, while the small number of such HDVs in use
does not provide sufficient economic incentive to construct more
natural gas refueling stations. Some businesses that operate HDVs may
also be concerned about the difficulty in locating repair facilities or
replacement parts, such as single-wide tires, wherever their vehicles
operate. When a technology has been widely adopted, then it is likely
to be serviceable even in remote or rural places, but until it becomes
widely available, its early adopters may face difficulties with repairs
or replacements. By accelerating the widespread adoption of these
technologies, these standards may assist in overcoming these
difficulties.
Consumer Federation of America states that network externalities
are a potentially important barrier to adoption of fuel-saving
technologies.
First-mover disadvantage. Many manufacturers prefer to
observe the market and follow other manufacturers rather than be the
first to market with a specific technology. The ``first-mover
disadvantage'' has been recognized in other research where the ``first-
mover'' pays a higher proportion of the costs of developing technology,
but loses the long-term advantage when other
[[Page 73862]]
businesses follow quickly.\793\ In this way, there may be barriers to
innovation on the supply side that result in lower adoption rates of
fuel-efficiency technology than would be optimal.
---------------------------------------------------------------------------
\793\ Blumstein, Carl and Margaret Taylor (2013). ``Rethinking
the Energy-Efficiency Gap: Producers, Intermediaries, and
Innovation,'' Energy Institute at Haas Working Paper 243, University
of California at Berkeley, Docket EPA-HQ-OAR-2014-0827-0075; Tirole,
Jean (1998). The Theory of Industrial Organization. Cambridge, MA:
MIT Press, pp.400, 402, Docket EPA-HQ-OAR-2014-0827-0089. This
first-mover disadvantage must be large enough to overcome the
potential incentive for first movers to earn unusually high but
temporary profit levels.
---------------------------------------------------------------------------
Several commenters support the existence of the first-mover
disadvantage. Roeth et al. (2013) noted that HDV buyers often prefer to
have technology or equipment installed by their favored original
equipment manufacturers. However, some technologies may not be
available through these preferred sources, or may be available only as
after-market installations from third parties (Aarnink et al. 2012,
Roeth et al. 2013). Manufacturers may be hesitant to offer technologies
for which there is not strong demand, especially if the technologies
require significant research and development expenses and other costs
of bringing the technology to a market of uncertain demand. Roeth et
al. (2013) noted that it can take years, and sometimes as much as a
decade, for a specific technology to become available from all
manufacturers.
As mentioned above, the Competitive Enterprise Institute argues
that EPA regulations on nitrogen oxides (NOX and other
pollutants from heavy duty engines in the 2000s hindered development of
fuel-saving technologies, in part because the technologies increased
fuel consumption, and in part because, if manufacturers invested in
NOX controls, they could not invest in reducing fuel
consumption. The agencies do not find these potential explanations
compelling. Most obviously, the NOX and other standards do
not provide a useful analogy for industry response to the GHG/fuel
efficiency standards, because those standards imposed costs without
returning fuel savings to operators. In addition, as the discussion of
technology cost and effectiveness indicates, technologies that are not
in widespread use seem to be available to reduce fuel consumption with
reasonable payback periods. Finally, the agencies consider it possible
to reduce NOX in the presence of GHG controls, and to reduce
GHG emissions in the presence of NOX controls; the cost
analysis for this rulemaking accounts for achieving NOX
emissions standards. See also RTC Sections 11.2.2.3 and 11.7.2.
In summary, the agencies recognize that businesses that operate
HDVs are under competitive pressure to reduce operating costs, which
should compel HDV buyers to identify and rapidly adopt cost-effective
fuel-saving technologies. Outlays for labor and fuel generally
constitute the two largest shares of HDV operating costs, depending on
the price of fuel, distance traveled, type of HDV, and commodity
transported (if any), so businesses that operate HDVs face strong
incentives to reduce these costs.794 795
---------------------------------------------------------------------------
\794\ American Transportation Research Institute, An Analysis of
the Operational Costs of Trucking, September 2013 (Docket ID: EPA-
HQ-OAR-2014-0827-0512).
\795\ Transport Canada, Operating Cost of Trucks, 2005. See
http://www.tc.gc.ca/eng/policy/report-acg-operatingcost2005-2005-e-2-1727.htm, accessed on July 16, 2010 (Docket ID: EPA-HQ-OAR-2014-
0827-0070).
---------------------------------------------------------------------------
However, the relatively short payback periods that buyers of new
HDVs appear to require suggest that some combination of the factors
cited above impedes this process. Markets for both new and used HDVs
may face these problems, although it is difficult to assess empirically
the degree to which they actually do. Even if the benefits from
widespread adoption of fuel-saving technologies exceed their costs,
their use may remain limited or spread slowly because their early
adopters bear a disproportionate share of those costs. In this case, as
CFA says in its comments, these standards may help to overcome such
barriers by ensuring that these measures will be widely adopted.
Providing information about fuel-saving technologies, offering
incentives for their adoption, and sharing HDV operators' real-world
experiences with their performance through voluntary programs such as
EPA's SmartWay Transport Partnership should assist in the adoption of
new cost-saving technologies. Nevertheless, other barriers that impede
the diffusion of new technologies are likely to remain. Buyers who are
willing to experiment with new technologies expect to find cost
savings, but those savings may be difficult to verify or replicate. As
noted previously, because benefits from employing these technologies
are likely to vary with the characteristics of individual routes and
traffic patterns, buyers of new HDVs may find it difficult to identify
or verify the effects of fuel-saving technologies in their operations.
Risk-averse buyers may also avoid new technologies out of concerns over
the possibility of inadequate returns on their investments, or with
other possible adverse impacts.
As various commenters note, competitive pressures in the HDV
freight transport industry can provide a strong incentive to reduce
fuel consumption and improve environmental performance. Nevertheless,
HDV manufacturers may delay in investing in the development and
production of new technologies, instead waiting for other manufacturers
to bear the initial risks of those investments. In addition, not every
HDV operator has the requisite ability or interest to access and
utilize the technical information, or the resources necessary to
evaluate this information within the context of his or her own
operations.
As discussed previously, whether the technologies available to
improve HDVs' fuel efficiency would be adopted widely in the absence of
the program is challenging to assess. To the extent that these
technologies would be adopted in its absence, neither their costs nor
their benefits should be attributed to the program.
The agencies will continue to explore reasons for the slow adoption
of readily available and apparently cost-effective technologies for
improving fuel efficiency.
B. Vehicle-Related Costs Associated With the Program
(1) Technology Cost Methodology
(a) Direct Manufacturing Costs
The direct manufacturing costs (DMCs) used throughout this analysis
are derived from several sources. Many of the tractor, vocational and
trailer DMCs can be sourced to the Phase 1 rule which, in turn, were
sourced largely from a contracted study by ICF International for
EPA.\796\ We have updated those costs by converting them to 2013
dollars, as described in Section IX.B.1.e below, and by continuing the
learning effects described in the Phase 1 rule and in Section IX.B.1.c
below. The new tractor, vocational and trailer costs can be sourced to
a more recent study conducted by Tetra Tech under contract to
NHTSA.\797\ The cost methodology used by Tetra Tech was to estimate
retail costs and work backward from there to derive a DMC for each
technology. The agencies did not agree with the approach used by Tetra
Tech
[[Page 73863]]
to move from retail cost to DMC as the approach was to simply divide
retail costs by 2 and use the result as a DMC. Our research, discussed
below, suggests that a divisor of 2 is too high. Therefore, where we
have used a Tetra Tech derived retail estimate, we have divided by our
researched markups to arrive at many of the DMCs used in this analysis.
In this way, the agencies have used an approach consistent with past
GHG/CAFE/fuel consumption rules by dividing estimated retail prices by
our estimated retail price equivalent (RPE) markups to derive an
appropriate DMC for each technology. We describe our RPEs in Section
IX.B.1.b, below. Importantly, nearly all of the technology costs used
in the final analysis are identical to those used in the proposal,
except for updating those costs from 2012 dollars to 2013 dollars.
Notable changes are the costs for waste heat recovery and the use of
new technologies (e.g., APU with DPF, battery powered APU and a
different stop-start technology on vocational vehicles) that were not
considered in the proposal. We describe these changes in Chapter 2
.11of the RIA.
---------------------------------------------------------------------------
\796\ ICF International. Investigation of Costs for Strategies
to Reduce Greenhouse Gas Emissions for Heavy-Duty On-Road Vehicles.
July 2010.
\797\ Schubert, R., Chan, M., Law, K. (2015). Commercial Medium-
and Heavy-Duty (MD/HD) Truck Fuel Efficiency Cost Study. Washington,
DC: National Highway Traffic Safety Administration.
---------------------------------------------------------------------------
Importantly, technology costs differ from package costs which
include adoption rates. Package costs have changed more significantly
due to changes to the adoption rates as described throughout the
earlier sections of this Preamble and briefly below in Section
IX.B.1.(d).
For HD pickups and vans, we have similarly used costs from the
proposal except for the updating to 2013 dollars. As explained in the
proposal, we relied primarily on the Phase 1 rule and the recent light-
duty 2017-2025 model year rule since most technologies expected on
these vehicles are, in effect, the same as those used on light-duty
pickups. Many of those technology DMCs are based on cost teardown
studies which the agencies consider to be the most robust method of
cost estimation. However, because most of the HD versions of those
technologies are expected to be more costly than their light-duty
counterparts, we have scaled upward most of the light-duty DMCs for
this analysis. We have also used some costs developed under contract to
NHTSA by Tetra Tech.\798\
---------------------------------------------------------------------------
\798\ Schubert, R., Chan, M., Law, K. (2015). Commercial Medium-
and Heavy-Duty (MD/HD) Truck Fuel Efficiency Cost Study. Washington,
DC: National Highway Traffic Safety Administration.
---------------------------------------------------------------------------
Importantly, in our methodology, all technologies are treated as
being sourced from a supplier rather than being developed and produced
in-house. As a result, some portion of the total indirect costs of
making a technology or system--those costs incurred by the supplier for
research, development, transportation, marketing etc.--are contained in
the sales price to the engine and/or vehicle/trailer manufacturer
(i.e., the original equipment manufacturer (OEM)). That sale price paid
by the OEM to the supplier is the DMC we estimate.
We present the details--sources, DMC values, scaling from light-
duty values, markups, learning effects, adoption rates--behind all our
costs in Chapter 2 of the RIA.
(b) Indirect Costs
To produce a unit of output, engine and truck manufacturers incur
direct and indirect costs. Direct costs include cost of materials and
labor costs. Indirect costs are all the costs associated with producing
the unit of output that are not direct costs--for example, they may be
related to production (such as research and development [R&D]),
corporate operations (such as salaries, pensions, and health care costs
for corporate staff), or selling (such as transportation, dealer
support, and marketing). Indirect costs are generally recovered by
allocating a share of the costs to each unit of good sold. Although it
is possible to account for direct costs allocated to each unit of good
sold, it is more challenging to account for indirect costs allocated to
a unit of goods sold. To make a cost analysis process more feasible,
markup factors, which relate total indirect costs to total direct
costs, have been developed. These factors are often referred to as
retail price equivalent (RPE) multipliers.
While the agencies have traditionally used RPE multipliers to
estimate indirect costs, in recent GHG/CAFE/fuel consumption rules RPEs
have been replaced in the primary analysis with indirect cost
multipliers (ICMs). ICMs differ from RPEs in that they attempt to
estimate not all indirect costs incurred to bring a product to point of
sale, but only those indirect costs that change as a result of a
government action or regulatory requirement. As such, some indirect
costs, notably health and retirement benefits of retired employees,
among other indirect costs, will not be expected to change due to a
government action and, therefore, the portion of the RPE that covered
those costs does not change.
Further, the ICM is not a ``one-size-fits-all'' markup as is the
traditional RPE. With ICMs, higher complexity technologies like
hybridization or moving from a manual to automatic transmission may
require higher indirect costs--more research and development, more
integration work, etc.--suggesting a higher markup. Conversely, lower
complexity technologies like reducing friction or adding passive aero
features may require fewer indirect costs thereby suggesting a lower
markup.
Notably, ICMs are also not a simple multiplier as are traditional
RPEs. The ICM is broken into two parts--warranty related and non-
warranty related costs. The warranty related portion of the ICM is
relatively small while the non-warranty portion represents typically
over 95 percent of indirect costs. These two portions are applied to
different DMC values to arrive at total costs (TC). The warranty
portion of the markup is applied to a DMC that decreases year-over-year
due to learning effects (described below in Section IX.B.1.c).\799\ As
learning effects decrease the DMC with production volumes, it makes
sense that warranty costs will decrease since those parts replaced
under warranty should be less costly. In contrast, the non-warranty
portion of the markup is applied to a static DMC year-over-year
resulting in static indirect costs. This is logical since the
production plants and transportation networks and general overhead
required to build parts, market them, deliver them and integrate them
into vehicles do not necessarily decrease in cost year-over-year.
Because the warranty and non-warranty portions of the ICM are applied
differently, one cannot compare the markup itself to the RPE to
determine which markup will result in higher indirect cost estimates,
at least in the time periods typically considered in our rules (four to
ten years).
---------------------------------------------------------------------------
\799\ We note that the labor portion of warranty repairs does
not decrease due to learning. However, we do not have data to
separate this portion and so we apply learning to the entire
warranty cost. Because warranty costs are a small portion of overall
indirect costs, this has only a minor impact on the analysis.
---------------------------------------------------------------------------
In the NPRM, the agencies expressed concern that some potential
costs associated with this rulemaking may not be adequately captured by
our ICMs. ICMs are estimated based on a few specific technologies and
these technologies may not be representative of the changes actually
made to meet the requirements. We requested and received comment on
this issue. Specifically, some commenters argued that we had
underestimated costs associated with R&D and costs associated with our
compliance programs, both of which are indirect costs. However, we
address those indirect costs separately because GHG-related R&D and
GHG-related
[[Page 73864]]
compliance were not part of the retail price equivalent markups upon
which our indirect cost multipliers are based. We discuss these R&D and
compliance costs more below and in Chapter 7 of the RIA.
We provide more details on our ICM approach and the markups used
for each technology in Chapter 2.12 of the RIA.
(c) Learning Effects on Direct and Indirect Costs
For some of the technologies considered in this analysis,
manufacturer learning effects will be expected to play a role in the
actual end costs. The ``learning curve'' or ``experience curve''
describes the reduction in unit production costs as a function of
accumulated production volume. In theory, the cost behavior it
describes applies to cumulative production volume measured at the level
of an individual manufacturer, although it is often assumed--as both
agencies have done in past regulatory analyses--to apply at the
industry-wide level, particularly in industries that utilize many
common technologies and component supply sources. Both agencies believe
there are indeed many factors that cause costs to decrease over time.
Research in the costs of manufacturing has consistently shown that, as
manufacturers gain experience in production, they are able to apply
innovations to simplify machining and assembly operations, use lower
cost materials, and reduce the number or complexity of component parts.
All of these factors allow manufacturers to lower the per-unit cost of
production (i.e., the manufacturing learning curve).\800\
---------------------------------------------------------------------------
\800\ See ``Learning Curves in Manufacturing,'' L. Argote and D.
Epple, Science, Volume 247; ``Toward Cost Buy down Via Learning-by-
Doing for Environmental Energy Technologies, R. Williams, Princeton
University, Workshop on Learning-by-Doing in Energy Technologies,
June 2003; ``Industry Learning Environmental and the Heterogeneity
of Firm Performance, N. Balasubramanian and M. Lieberman, UCLA
Anderson School of Management, December 2006, Discussion Papers,
Center for Economic Studies, Washington DC.
---------------------------------------------------------------------------
In this analysis, the agencies are using the same approach to
learning as done in the proposal and in past GHG/CAFE/fuel consumption
rules. In short, learning effects result in rapid cost reductions in
the early years following introduction of a new technology. The
agencies have estimated those cost reductions as resulting in 20
percent lower costs for every doubling of production volume. As
production volumes increase, learning rates continue at the same pace
but flatten asymptotically due to the nature of the persistent doubling
of production required to realize that cost reduction. As such, the
cost reductions flatten out as production volumes continue to increase.
Consistent with the Phase 1 rule, we refer to these two distinct
portions of the ``learning cost reduction curve'' or ``learning curve''
as the steeper and flatter portions of the curve. On that steep portion
of the curve, costs are estimated to decrease by 20 percent for each
double of production or, by proxy, in the third and then fifth year of
production following introduction. On the flat portion of the curve,
costs are estimated to decrease by 3 percent per year for 5 years, then
2 percent per year for 5 years, then 1 percent per year for 5 years.
Also consistent with the Phase 1 rule, the majority of the technologies
we expect will be adopted are considered to be on the flat portion of
the learning curve meaning that the 20 percent cost reductions are
rarely applied. The agencies requested and received comments on our
approach to estimating learning effects, specifically with respect to
cost reductions applied to waste heat recovery and APUs. Commenters
suggested that, since waste heat recovery is not in production, the
agencies should not have applied learning effect to that technology.
They also argued that, since APUs have been around for years, applying
any cost reduction effects to their costs is ``questionable.'' The
agencies disagree with both of these comments. Whether production-
related learning-by-doing cost reductions or from other factors, we are
aware of dramatic changes to waste heat recovery systems that clearly
make that technology less costly. We describe these changes in more
detail in Chapter 2 of the RIA. Also, to suggest that APUs cannot
undergo any cost reductions from learning does not seem reasonable. The
agencies have placed that technology on the flat portion of the
learning curve since it is well established. As a result, the estimated
learning effects are not large in scale, but to suggest that an APU
will cost the same in the 2020s as it does today, in constant dollar
terms, is not reasonable. Further, the commenter provided no supporting
data or information to support this claim.
We provide more details on the concept of learning-by-doing and the
learning effects applied in this analysis in Chapter 2.11 of the RIA.
(d) Technology Adoption Rates and Developing Package Costs
Determining the stringency of these standards involves a balancing
of relevant factors--chiefly technology feasibility and effectiveness,
costs, and lead time. For vocational vehicles, tractors and trailers,
the agencies have projected a technology path to achieve these
standards reflecting an application rate of those technologies the
agencies consider to be available at reasonable cost in the lead times
provided. The agencies do not expect (and do not require) each of the
technologies for which costs have been developed to be employed by all
trucks and trailers across the board.\801\ Further, many of today's
vehicles are already equipped with some of the technologies and/or are
expected to adopt them by MY 2018 to comply with the HD Phase 1
standards. Estimated adoption rates in both the reference and control
cases are necessary for each vehicle/trailer category. The adoption
rates for most technologies are zero in the reference case; however,
for some technologies--notably aero and tire technologies--the adoption
rate is not zero in the reference case. These reference and control
case adoption rates are then applied to the technology costs with the
result being a package cost for each vehicle/trailer category.
Technology adoption rates were presented in Sections II through V for
engines, tractors, vocational vehicles and trailers. Individual
technology costs are presented in Chapter 2.11 of the final RIA.
---------------------------------------------------------------------------
\801\ The one exception are the design standards for non-aero
box vans and non-box trailers, which do mandate use of certain tire-
related technologies.
---------------------------------------------------------------------------
For HD pickups and vans, the CAFE model determines the technology
adoption rates that are estimated to most cost effectively meet the
standards. Similar to vocational vehicles, tractors and trailers,
package costs are rarely if ever a simple sum of all the technology
costs since each technology will be expected to be adopted at different
rates. The methods for estimating technology adoption rates and
resultant costs per vehicle (and other impacts) for HD pickups and vans
are discussed above in Section VI. Individual technology costs are
presented in Chapter 2.11 of the final RIA.
We provide details of expected technology adoption rates for each
of the regulatory subcategories in Chapter 2 of the RIA. We present
package costs both in Sections III through VI of this Preamble and in
more detail in Chapter 2 of the RIA.
(e) Conversion of Technology Costs to 2013 U.S. Dollars
As noted above in Section IX.B.1, the agencies are using technology
costs from many different sources. These sources, having been published
in different years, present costs in different year dollars (i.e., 2009
dollars or 2010
[[Page 73865]]
dollars). For this analysis, the agencies sought to have all costs in
terms of 2013 dollars to be consistent with the dollars used by AEO in
its 2015 Annual Energy Outlook.\802\ The agencies have used the GDP
Implicit Price Deflator for Gross Domestic Product as the converter,
with the actual factors used as shown in Table IX-1.\803\
---------------------------------------------------------------------------
\802\ U.S. Energy Information Administration, Annual Energy
Outlook 2015, Early Release; Report Number DOE/EIA-0383(2015), April
2015.
\803\ Bureau of Economic Analysis, Table 1.1.9 Implicit Price
Deflators for Gross Domestic Product; as revised on August 27, 2015.
Table IX-1--Implicit Price Deflators and Conversion Factors for Conversion to 2013$
--------------------------------------------------------------------------------------------------------------------------------------------------------
2006 2007 2008 2009 2010 2011 2012 2013
--------------------------------------------------------------------------------------------------------------------------------------------------------
Price index for GDP............................................. 94.814 97.337 99.246 100 101.221 103.311 105.214 106.929
Factor applied for 2012$........................................ 1.128 1.099 1.077 1.069 1.056 1.035 1.016 1.000
--------------------------------------------------------------------------------------------------------------------------------------------------------
(2) Compliance Program Costs
The agencies have also estimated additional and/or new compliance
costs associated with these standards. Normally, compliance program
costs will be considered part of the indirect costs and, therefore,
will be accounted for via the markup applied to direct manufacturing
costs. However, since the agencies are proposing new compliance
elements that were not present during development of the indirect cost
markups used in this analysis, additional compliance program costs are
being accounted for via a separate ``line-item.'' New research and
development costs (see below) are being handled in the same way.
The new compliance program elements included in this rule are new
powertrain testing within the vocational vehicle program, and an all-
new compliance program (since none has existed to date) for the trailer
program. The remaining compliance provisions are identical to those in
Phase 1, and the estimated costs therefore are derived using the same
methodology used to estimate compliance costs in the Phase 1 rule.
Compliance program costs cover costs associated with any necessary
compliance testing and reporting to the agencies. The details behind
the estimated compliance program costs are provided in Chapter 7 of the
RIA.
The agencies requested and received comments on our compliance cost
estimates. Some commenters were concerned that we had significantly
underestimated costs. In response, we have adjusted our compliance
costs estimates, including those for testing and reporting, and have
increased our annual compliance costs from roughly $6 million per year
to nearly $11 million per year. This excludes the estimated $16 million
in 2020 to build and/or upgrade facilities to conduct testing. We
discuss our updated estimates in more detail in Chapter 7 of the RIA.
(3) Research and Development Costs
Much like the compliance program costs described above, we have
estimated additional HDD engine, vocational vehicle and tractor R&D
associated with these standards that is not accounted for via the
indirect cost markups used for these segments. Much like the Phase 1
rule, EPA is estimating these additional R&D costs will occur over a 4-
year timeframe as these standards come into force and industry works on
means to comply. After that period, the additional R&D costs go to $0
as R&D expenditures return to their normal levels and R&D costs are
accounted for via the ICMs--and the RPEs behind them--used for these
segments. The details behind the estimated R&D costs are provided in
Chapter 7 of the RIA
The agencies requested and received comments on our R&D estimates.
One commenter suggested that our estimate of $960 million over four
years, for hundreds of types of disparate vehicles was unrealistic
given the $80 million of R&D spent on the Super Truck program over 5
years. Unfortunately, no better estimate was provided by commenters. We
have increased our estimated R&D, relative to that estimated in the
proposal, by roughly $14 million per year for 4 years resulting in a
total additional R&D estimate of over $1 billion. Importantly, as
noted, this R&D spending is an additional expenditure above and beyond
that estimated as part of the indirect cost markups which include in
them an estimate of roughly 4 percent of revenues spent on R&D. Another
way of stating this is that roughly 4 percent of our technology costs
are actually estimated as R&D-related costs. Given our annual
technology costs of $2 billion to $5 billion per year from 2021 through
2027, or over $24 billion over those 7 years, we are estimating another
$1 billion in R&D via our indirect cost markups (4 percent of $24
billion). In other words, we are really estimating roughly $2 billion
in R&D spending during the calendar years 2021 through 2027.
(4) Summary of Costs of the Vehicle Programs
The agencies have estimated the costs of the vehicle standards on
an annual basis for the years 2018 through 2050, and have also
estimated costs for the full model year lifetimes of MY 2018 through MY
2029 vehicles. Table IX-2 shows the annual costs of these standards
along with net present values using both 3 percent and 7 percent
discount rates. Table IX-3 shows the discounted model year lifetime
costs of these standards at both 3 percent and 7 percent discount rates
along with sums across applicable model years.
Table IX-2--Annual Costs of the Final Program and Net Present Values at 3% and 7% Discount Rates Using Method B
and Relative to the Flat Baseline
[$Millions of 2013$] \a\
----------------------------------------------------------------------------------------------------------------
Calendar year New technology Compliance R&D Sum
----------------------------------------------------------------------------------------------------------------
2018............................................ $227 $0 $0 $227
2019............................................ 215 0 0 215
2020............................................ 220 17 0 237
2021............................................ 2,270 11 259 2,540
[[Page 73866]]
2022............................................ 2,243 11 259 2,512
2023............................................ 2,485 11 259 2,755
2024............................................ 3,890 11 259 4,160
2025............................................ 4,146 11 0 4,157
2026............................................ 4,203 11 0 4,213
2027............................................ 5,219 11 0 5,230
2028............................................ 5,176 11 0 5,186
2029............................................ 5,195 11 0 5,206
2030............................................ 5,219 11 0 5,229
2035............................................ 5,642 11 0 5,653
2040............................................ 6,245 11 0 6,255
2050............................................ 7,270 11 0 7,280
NPV, 3%......................................... 86,780 191 818 87,788
NPV, 7%......................................... 41,148 102 604 41,854
----------------------------------------------------------------------------------------------------------------
Note:
\a\ For an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat
baseline, 1a, and dynamic baseline, 1b, please see Section X.A.1.
Table IX-3--Discounted MY Lifetime Costs of the Final Program Using Method B and Relative to the Flat Baseline
[$Millions of 2013$] \a\
--------------------------------------------------------------------------------------------------------------------------------------------------------
Discounted at 3% Discounted at 7%
-------------------------------------------------------------------------------------------------------
Model year New New
technology Compliance R&D Sum technology Compliance R&D Sum
--------------------------------------------------------------------------------------------------------------------------------------------------------
2018............................................ $205 $0 $0 $205 $179 $0 $0 $179
2019............................................ 188 0 0 188 159 0 0 159
2020............................................ 187 14 0 201 152 12 0 163
2021............................................ 1,873 9 214 2,096 1,462 7 167 1,636
2022............................................ 1,797 8 207 2,013 1,350 6 156 1,513
2023............................................ 1,933 8 201 2,143 1,398 6 146 1,550
2024............................................ 2,938 8 195 3,141 2,046 6 136 2,187
2025............................................ 3,040 8 0 3,048 2,038 5 0 2,043
2026............................................ 2,992 8 0 2,999 1,930 5 0 1,935
2027............................................ 3,607 7 0 3,614 2,240 5 0 2,245
2028............................................ 3,473 7 0 3,480 2,076 4 0 2,080
2029............................................ 3,384 7 0 3,391 1,948 4 0 1,952
Sum......................................... 25,617 84 818 26,519 16,978 59 604 17,642
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note:
\a\ For an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 1b,
please see Section X.A.1.
New technology costs begin in MY 2018 as trailers begin to add new
technology. Compliance costs begin with the new standards with capital
cost expenditure in that year for building and upgrading test
facilities to conduct the powertrain testing in the vocational program.
Research and development costs begin in 2021 and last for 4 years as
engine, tractor and vocational vehicle manufacturers conduct research
and development testing to integrate new technologies into their
engines and vehicles.
C. Changes in Fuel Consumption and Expenditures
(1) Changes in Fuel Consumption
The new GHG and fuel consumption standards will result in
significant improvements in the fuel efficiency of affected vehicles,
and drivers of those vehicles will see corresponding savings associated
with reduced fuel expenditures. The agencies have estimated the impacts
on fuel consumption for these standards. Details behind how these
changes in fuel consumption were calculated are presented in Section
VII of this Preamble and in Chapter 5 of the RIA. The total number of
miles that vehicles are driven each year is different under the
regulatory alternatives than in the reference case due to the ``rebound
effect'' (discussed below in Section IX.E), so the changes in fuel
consumption associated with each alternative are not strictly
proportional to differences in the fuel economy levels they require.
The expected annual impacts on fuel consumption are shown in Table
IX-4. Table IX-5 shows the MY lifetime changes in fuel consumption. The
gallons shown in these tables as reductions in fuel consumption reflect
reductions due to these standards and include any increased consumption
resulting from the rebound effect (discussed below in Section IX.E).
[[Page 73867]]
Table IX-4--Annual Fuel Consumption Reductions due to the Final Program Using Method B and Relative to the Flat Baseline
[Millions of gallons] \a\
--------------------------------------------------------------------------------------------------------------------------------------------------------
Retail gasoline Diesel
-----------------------------------------------------------------------------------------------
Calendar year Fuel Fuel
Reference case consumption % Reduction Reference case consumption % Reduction
reduction reduction
--------------------------------------------------------------------------------------------------------------------------------------------------------
2018.................................................... 10,958 0 0 46,636 37 0
2019.................................................... 11,118 0 0 47,056 76 0
2020.................................................... 11,265 0 0 47,397 117 0
2021.................................................... 11,391 28 0 47,548 428 1
2022.................................................... 11,515 74 1 47,813 812 2
2023.................................................... 11,633 138 1 48,146 1,211 3
2024.................................................... 11,745 226 2 48,572 1,835 4
2025.................................................... 11,843 330 3 48,941 2,457 5
2026.................................................... 11,936 448 4 49,194 3,063 6
2027.................................................... 12,039 588 5 49,483 3,853 8
2028.................................................... 12,138 723 6 49,753 4,610 9
2029.................................................... 12,234 852 7 50,036 5,335 11
2030.................................................... 12,324 974 8 50,393 6,031 12
2035.................................................... 12,680 1,454 11 52,492 8,883 17
2040.................................................... 12,920 1,724 13 55,399 10,778 19
2050.................................................... 13,185 1,904 14 61,663 12,986 21
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note:
\a\ For an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 1b,
please see Section X.A.1.
Table IX-5--Model Year Lifetime Fuel Consumption Reductions due to the Final Program Using Method B and Relative to the Flat Baseline
[Millions of gallons] \a\
--------------------------------------------------------------------------------------------------------------------------------------------------------
Retail gasoline Diesel
-----------------------------------------------------------------------------------------------
Model year Fuel Fuel
Reference consumption % Reduction Reference consumption % Reduction
reduction reduction
--------------------------------------------------------------------------------------------------------------------------------------------------------
2018.................................................... 12,541 0 0 46,628 302 1
2019.................................................... 12,409 0 0 47,583 293 1
2020.................................................... 12,455 0 0 49,084 286 1
2021.................................................... 12,328 322 3 48,950 4,643 9
2022.................................................... 12,252 550 4 48,994 4,807 10
2023.................................................... 12,233 772 6 48,884 4,947 10
2024.................................................... 12,342 1,075 9 49,924 7,742 16
2025.................................................... 12,452 1,301 10 50,364 7,954 16
2026.................................................... 12,555 1,525 12 50,477 8,111 16
2027.................................................... 12,591 1,836 15 50,664 10,646 21
2028.................................................... 12,619 1,840 15 50,916 10,698 21
2029.................................................... 12,631 1,841 15 51,381 10,800 21
Sum................................................. 149,408 11,062 7 593,848 71,229 12
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note:
\a\ For an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 1b,
please see Section X.A.1.
(2) Fuel Savings
We have also estimated the changes in fuel expenditures, or the
fuel savings, using fuel prices estimated in the Energy and Information
Administration's 2015 Annual Energy Outlook.\804\ As the AEO fuel price
projections go through 2040 and not beyond, fuel prices beyond 2040
were set equal to the 2040 values. These estimates do not account for
the significant uncertainty in future fuel prices; the monetized fuel
savings will be understated if actual fuel prices are higher (or
overstated if fuel prices are lower) than estimated. The Annual Energy
Outlook (AEO) is a standard reference used by NHTSA and EPA and many
other government agencies to estimate the projected price of fuel. This
has been done using both the pre-tax and post-tax fuel prices. Since
the post-tax fuel prices are the prices paid at fuel pumps, the fuel
savings calculated using these prices represent the changes fuel
purchasers will see. The pre-tax fuel savings measure the value to
society of the resources saved when less fuel is refined and consumed.
Assuming no change in fuel tax rates, the difference between these two
columns represents the reduction in fuel tax revenues that will be
received by state and federal governments, or about $204 million in
2021 and $5.8 billion by 2050 as shown in Table IX-6 where annual
changes in monetized fuel savings are shown along with net present
values using 3 percent
[[Page 73868]]
and 7 percent discount rates. Table IX-7 and Table IX-8 show the
discounted model year lifetime fuel savings using 3 percent and 7
percent discount rates, respectively.
---------------------------------------------------------------------------
\804\ U.S. Energy Information Administration, Annual Energy
Outlook 2015; Report Number DOE/EIA-0383(2015), April 2015.
Table IX-6--Annual Fuel Savings and Net Present Values at 3% and 7% Discount Rates Using Method B for the Final Program and Relative to the Flat
Baseline
[$Millions of 2013$] \a\
--------------------------------------------------------------------------------------------------------------------------------------------------------
Fuel savings--retail Fuel savings--untaxed
Model year ------------------------------------------------------------------------------------------------ Change in
Gasoline Diesel Sum Gasoline Diesel Sum transfer
--------------------------------------------------------------------------------------------------------------------------------------------------------
2018.................................... $0 $114 $114 $0 $97 $97 $17
2019.................................... 0 237 237 0 202 202 35
2020.................................... 0 371 371 0 319 319 53
2021.................................... 78 1,384 1,462 67 1,191 1,258 204
2022.................................... 210 2,689 2,899 181 2,323 2,504 395
2023.................................... 396 4,081 4,476 342 3,548 3,889 587
2024.................................... 657 6,296 6,952 571 5,488 6,059 894
2025.................................... 973 8,576 9,550 848 7,495 8,343 1,207
2026.................................... 1,343 10,903 12,246 1,173 9,586 10,759 1,487
2027.................................... 1,787 13,985 15,772 1,564 12,328 13,892 1,880
2028.................................... 2,234 17,057 19,290 1,959 15,074 17,033 2,257
2029.................................... 2,675 20,114 22,789 2,351 17,873 20,224 2,565
2030.................................... 3,116 23,160 26,276 2,746 20,627 23,373 2,903
2035.................................... 5,131 37,840 42,971 4,593 34,287 38,880 4,091
2040.................................... 6,722 51,194 57,916 6,102 46,991 53,093 4,824
2050.................................... 7,426 61,684 69,109 6,740 56,619 63,359 5,750
NPV, 3%................................. 65,703 511,060 576,763 59,061 464,240 523,301 53,462
NPR, 7%................................. 26,936 209,666 236,602 24,131 189,702 213,833 22,769
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note:
\a\ For an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 1b,
please see Section X.A.1.
Table IX-7--Discounted Model Year Lifetime Fuel Savings, 3% Discount Rate Using Method B for the Final Program and Relative to the Flat Baseline
[$Millions of 2013$] \a\
--------------------------------------------------------------------------------------------------------------------------------------------------------
Fuel savings--retail Fuel savings--untaxed
Model year ------------------------------------------------------------------------------------------------ Change in
Gasoline Diesel Sum Gasoline Diesel Sum transfer
--------------------------------------------------------------------------------------------------------------------------------------------------------
2018.................................... $0 $781 $781 $0 $680 $680 $101
2019.................................... 0 747 747 0 653 653 94
2020.................................... 0 719 719 0 631 631 87
2021.................................... 674 11,497 12,171 590 10,155 10,746 1,426
2022.................................... 1,132 11,781 12,912 994 10,440 11,435 1,478
2023.................................... 1,567 11,990 13,557 1,381 10,660 12,041 1,516
2024.................................... 2,154 18,556 20,709 1,903 16,548 18,451 2,259
2025.................................... 2,571 18,849 21,420 2,278 16,859 19,137 2,283
2026.................................... 2,973 19,003 21,976 2,640 17,048 19,688 2,288
2027.................................... 3,532 24,648 28,180 3,144 22,171 25,315 2,865
2028.................................... 3,493 24,459 27,953 3,116 22,060 25,176 2,776
2029.................................... 3,449 24,378 27,828 3,084 22,044 25,128 2,700
Sum..................................... 21,545 167,408 188,954 19,131 149,950 169,081 19,873
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note:
\a\ For an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 1b,
please see Section X.A.1.
Table IX-8--Discounted Model Year Lifetime Fuel Savings, 7% Discount Rate Using Method B for the Final Program and Relative to the Flat Baseline
[$Millions of 2013$] \a\
--------------------------------------------------------------------------------------------------------------------------------------------------------
Fuel savings--retail Fuel savings--untaxed
Model year ------------------------------------------------------------------------------------------------ Change in
Gasoline Diesel Sum Gasoline Diesel Sum transfer
--------------------------------------------------------------------------------------------------------------------------------------------------------
2018.................................... $0 $558 $558 $0 $483 $483 $74
2019.................................... 0 510 510 0 444 444 66
2020.................................... 0 466 466 0 408 408 58
2021.................................... 420 7,031 7,451 367 6,188 6,554 897
2022.................................... 674 6,946 7,620 591 6,134 6,725 895
2023.................................... 896 6,814 7,710 788 6,038 6,826 884
[[Page 73869]]
2024.................................... 1,186 10,161 11,347 1,045 9,033 10,078 1,269
2025.................................... 1,362 9,947 11,309 1,204 8,870 10,074 1,235
2026.................................... 1,516 9,666 11,182 1,343 8,648 9,991 1,191
2027.................................... 1,737 12,081 13,818 1,542 10,839 12,381 1,436
2028.................................... 1,655 11,551 13,206 1,474 10,393 11,866 1,340
2029.................................... 1,576 11,097 12,672 1,406 10,013 11,419 1,254
Sum..................................... 11,022 86,827 97,849 9,759 77,491 87,249 10,600
--------------------------------------------------------------------------------------------------------------------------------------------------------
Note:
\a\ For an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 1b,
please see Section X.A.1.
D. Maintenance Expenditures
The agencies expect increases in maintenance costs under these
standards. In the NPRM, we estimated maintenance costs associated with
lower rolling resistance tires. In the final rule, we have included
maintenance costs for many more systems, including waste heat recovery,
APUs, transmission fluids, etc. We have estimated that these
maintenance costs will be incurred throughout the vehicle lifetime at
intervals consistent with typical replacement intervals. Those
intervals are difficult to quantify given the variety of vehicles and
operating modes within the HD industry. We detail the inputs used to
estimate maintenance impacts in Chapter 7.3.3 of the RIA.
We have heard from at least one source \805\ that strong hybrid
maintenance can be higher in some ways, including possible battery
replacement, but may also be much lower for some vehicle systems like
brakes and general engine wear. New for the FRM, relative to the
proposal, are maintenance costs on hybrid battery systems in vocational
vehicles and some reduction in oil change costs on vocational vehicles
with stop-start systems since less idling should result in fewer oil
changes. See RIA 2.11.7. We have also included new costs for axle fluid
replacements for vocational vehicles adding high efficiency axles, and
transmission fluid replacements for vehicles projected to move from
manual to automated transmissions. For tractors, we have added these
same axle and transmission fluid costs and for the same reasons. For
tractors, we have also added maintenance costs associated with
auxiliary power units and for fuel operated heaters. All of the new
cost estimates and the maintenance intervals are presented in more
detail in Chapter 7.2.3 of the RIA.
---------------------------------------------------------------------------
\805\ Allison Transmission's Responses to EPA's Hybrid
Questions, November 6, 2014.
---------------------------------------------------------------------------
Table IX-9 shows the annual increased maintenance costs of the
final program along with net present values using both 3 percent and 7
percent discount rates. Table IX-10 shows the discounted model year
lifetime increased maintenance costs of the final program at both 3
percent and 7 percent discount rates along with sums across applicable
model years.
Table IX-9--Annual Maintenance Expenditure Increase due to the Rule and
Net Present Values at 3% and 7% Discount Rates Using Method B and
Relative to the Flat Baseline
[$Millions of 2013$] \a\
------------------------------------------------------------------------
Maintenance
Calendar year expenditure
increase
------------------------------------------------------------------------
2018.................................................... $1
2019.................................................... 1
2020.................................................... 2
2021.................................................... 20
2022.................................................... 39
2023.................................................... 60
2024.................................................... 83
2025.................................................... 106
2026.................................................... 127
2027.................................................... 167
2028.................................................... 206
2029.................................................... 244
2030.................................................... 244
2035.................................................... 244
2040.................................................... 244
2050.................................................... 244
NPV, 3%................................................. 3,188
NPV, 7%................................................. 1,463
------------------------------------------------------------------------
Note:
\a\ For an explanation of analytical Methods A and B, please see Section
I.D; for an explanation of the flat baseline, 1a, and dynamic
baseline, 1b, please see Section X.A.1.
Table IX-10--Discounted MY Lifetime Maintenance Expenditure Increase Due
to the Rule Using Method B and Relative to the Flat Baseline
[$Millions of 2013$] \a\
------------------------------------------------------------------------
3% Discount 7% Discount
Model year rate rate
------------------------------------------------------------------------
2018........................................ $7 $5
2019........................................ 6 4
2020........................................ 6 4
2021........................................ 155 96
2022........................................ 156 94
2023........................................ 160 93
2024........................................ 175 98
2025........................................ 177 96
2026........................................ 165 86
2027........................................ 303 152
2028........................................ 293 141
2029........................................ 285 132
---------------------------
Sum..................................... 1,889 1,000
------------------------------------------------------------------------
Note:
\a\ For an explanation of analytical Methods A and B, please see Section
I.D; for an explanation of the flat baseline, 1a, and dynamic
baseline, 1b, please see Section X.A.1.
E. Analysis of the Rebound Effect
The ``rebound effect'' has been defined in a variety of different
ways in the energy policy and economics literature. One common
definition states that the rebound effect is the increase in demand for
an energy service when the cost of the energy service is reduced due to
efficiency improvements.806 807 808 In
[[Page 73870]]
the context of heavy-duty vehicles (HDVs), this can be interpreted as
an increase in HDV fuel consumption resulting from more intensive
vehicle use in response to increased vehicle fuel efficiency.\809\
Although much of this vehicle use increase is likely to take the form
of increases in the number of miles vehicles are driven, it can also
take the form of increases in the loaded weight at which vehicles
operate or changes in traffic and road conditions vehicles encounter as
operators alter their routes and schedules in response to improved fuel
efficiency. Because this more intensive use consumes fuel and generates
emissions, it reduces the fuel savings and avoided emissions that would
otherwise be expected to result from the increases in fuel efficiency
in this rulemaking.
---------------------------------------------------------------------------
\806\ Winebrake, J.J., Green, E.H., Comer, B., Corbett, J.J.,
Froman, S., 2012. Estimating the direct rebound effect for on-road
freight transportation. Energy Policy 48, 252-259.
\807\ Greene, D.L., Kahn, J.R., Gibson, R.C., 1999, ``Fuel
economy rebound effect for U.S. household vehicles,'' The Energy
Journal, 20.
\808\ For a discussion of the wide range of definitions found in
the literature, see Appendix D: Discrepancy in Rebound Effect
Definitions, in EERA (2014), ``Research to Inform Analysis of the
Heavy-Duty vehicle Rebound Effect,'' Excerpts of Draft Final Report
of Phase 1 under EPA contract EP-C-13-025. (Docket ID: EPA-HQ-OAR-
2014-0827). See also Greening, L.A., Greene, D.L., Difiglio, C.,
2000, ``Energy efficiency and consumption--the rebound effect--a
survey,'' Energy Policy, 28, 389-401.
\809\ We discuss other potential rebound effects in Section
E.3.b., such as the indirect and economy-wide rebound effects. Note
also that there is more than one way to measure HDV energy services
and vehicle use. The agencies' analyses use VMT as a measure (as
discussed below); other potential measures include ton-miles, cube-
miles, and fuel consumption.
---------------------------------------------------------------------------
In our analysis and discussion below, we focus on one widely-used
metric to estimate the rebound effect associated with all types of more
intensive vehicle use, the increase in vehicle miles traveled (VMT)
that results from improved fuel efficiency. VMT can often provide a
reasonable approximation for all types of more intensive vehicle use.
For simplicity, we refer to this as ``the VMT rebound effect'' or ``the
direct VMT rebound'' throughout this section, although we acknowledge
that it is an approximation to the rebound effect associated with all
types of more intensive vehicle use. The agencies use our VMT rebound
estimates to generate VMT inputs that are then entered into the EPA
MOVES national emissions inventory model and the Volpe Center's HD CAFE
model. Both of these models use these inputs along with many others to
generate projected emissions and fuel consumption changes resulting
from each of the regulatory alternatives analyzed.
The following sections describe the factors affecting the magnitude
of HDV VMT rebound; review the econometric and other evidence related
to HDV VMT rebound; and summarize how we estimated the HDV rebound
effect for this rulemaking.
(1) Factors Affecting the Magnitude of HDV VMT Rebound
The magnitude and timing of HDV VMT rebound are driven by the
interaction of many different factors.\810\ Fuel savings resulting from
fuel efficiency standards may cause HDV operators and their customers
to change their patterns of HDV use and fuel consumption in a variety
of ways. As discussed in the RIA (Chapter 8), HDV VMT rebound estimates
determined via other proxy elasticities vary, but in no case has there
been an estimate that fully offsets the fuel saved due to efficiency
improvements (i.e., no rebound effect greater than or equal to 100
percent).\811\
---------------------------------------------------------------------------
\810\ These factors are discussed more fully in a report to EPA
from EERA, which illustrates in a series of diagrams the complex
system of decisions and decision-makers that could influence the
magnitude and timing of the rebound effect. See Sections 2.2.2,
2.2.3, 2.2.4, and 2.3 in EERA (2014), ``Research to Inform Analysis
of the Heavy-Duty Vehicle Rebound Effect,'' Excerpts of Draft Final
Report of Phase 1 under EPA contract EP-C-13-025 (EPA-HQ-OAR-2014-
0827-0514).
\811\ Elasticity is the measurement of how responsive an
economic variable is to a change in another. For example: Price
elasticity of demand is a measure used in economics to show the
responsiveness, or elasticity, of the quantity demanded of a good or
service to a change in its price. More precisely, it gives the
percentage change in quantity demanded in response to a one percent
change in price.
---------------------------------------------------------------------------
If fuel cost savings are passed on to the HDV operators' customers
(e.g., logistics businesses, manufacturers, retailers, municipalities,
utilities consumers, etc.), those customers might reorganize their
logistics and distribution networks over time to take advantage of
lower operating costs. For example, customers might order more frequent
shipments or choose products that entail longer shipping distances,
while freight carriers might divert some shipments to trucks from other
shipping modes such as rail, barge or air. In addition, customers might
choose to reduce their number of warehouses, reduce shipment rates or
make smaller but more frequent shipments, all of which could lead to an
increase in HDV VMT. Ultimately, fuel cost savings could ripple through
the entire economy, thus increasing demand for goods and services
shipped by trucks, and therefore increase HDV VMT due to increased
gross domestic product (GDP).
Conversely, if fuel efficiency standards lead to net increases in
the total costs of HDV operation because fuel cost savings do not fully
offset the increase in HDV purchase prices and associated depreciation
costs, then the price of HDV services could rise. This is likely to
spur a decrease in HDV VMT, and perhaps a shift to alternative shipping
modes. These effects could also ripple through the economy and affect
GDP. Note, however, that we project fuel cost savings will offset
technology costs in our analysis supporting the final standards.
It is also important to note that any increase in HDV VMT resulting
from the final standards may be offset, to some extent, by a decrease
in VMT by older HDVs. This may occur if lower fuel costs resulting from
our standards cause multi-vehicle fleet operators to shift VMT to
newer, more efficient HDVs in their fleet or cause operators with
newer, more efficient HDVs to be more successful at winning contracts
than operators with older HDVs.
Also, as discussed in Chapter 8.2 of the RIA, the magnitude of the
rebound effect is likely to be influenced by the extent of any market
failures that affect the demand for more fuel efficient HDVs, as well
as by HDV operators' responses to their perception of the tradeoff
between higher upfront HDV purchase costs versus lower but uncertain
future expenditures on fuel.
(2) Recent Econometric and Other Evidence Related to HDV VMT Rebound
As discussed above, HDV VMT rebound is defined as the change in HDV
VMT that occurs in response to an increase in HDV fuel efficiency. We
are not aware of any studies that directly estimate this elasticity for
the U.S. In the proposal, we discussed a number of econometric analyses
of other related elasticities that could potentially be used as a proxy
for measuring HDV VMT rebound, as well as several other analyses that
may provide insight into the magnitude of HDV VMT rebound.\812\ These
studies produced a wide range of estimates for HDV VMT rebound,
however, and we were unable to draw any strong conclusions about the
magnitude of rebound based on this available literature.
---------------------------------------------------------------------------
\812\ See 80 FR 40448-40452.
---------------------------------------------------------------------------
We also discussed several challenges that researchers face in
attempting to quantify the VMT rebound effect for HDVs,\813\ including
limited data on the HD sector and the difficulty of specifying
mathematical models that reflect the complex set of factors that
influence HD VMT. Given these limitations, the agencies requested
comment on a number of aspects of the proposed VMT rebound analysis,
including procedures for measuring the rebound effect and the studies
discussed in the proposal. The agencies also committed to reviewing and
considering revisions to VMT rebound estimates for
[[Page 73871]]
the final rule based on submissions from public commenters and new
research on the rebound effect.
---------------------------------------------------------------------------
\813\ See 80 FR 40448-40452.
---------------------------------------------------------------------------
This section reviews new econometric analyses that have been
produced since the release of the proposal. All of these analyses study
the change in HDV use (measured in VMT, ton-mile, or fuel consumption)
in response to changes in fuel price ($/gallon) or fuel cost ($/mile or
$/ton-mile). The studies presented below attempt to estimate these
elasticities in the HDV sector using varying approaches and data
sources.
Concurrent with the development of the proposal for this rule, EPA
contracted with Energy and Environmental Research Associates (EERA) to
analyze the HDV rebound effect for regulatory assessment purposes.
Excerpts of EERA's initial report to EPA are included in the NPRM
docket and contain detailed qualitative discussions of the rebound
effect as well as data sources that could be used in quantitative
analysis.\814\ EERA also conducted follow-on quantitative analyses
focused on estimating the impact of fuel prices on VMT and fuel
consumption. We included a Working Paper in the NPRM docket that
described much of this work.\815\ Note that EERA's Working Paper was
not available at the time the agencies conducted the analysis of the
rebound effect for the proposal, but that the agencies agreed to
consider this work and any other work in the analysis supporting the
final rule.
---------------------------------------------------------------------------
\814\ EERA (2014), ``Research to Inform Analysis of the Heavy-
Duty Vehicle Rebound Effect,'' Excerpts of Draft Final Report of
Phase 1 under EPA contract EP-C-13-025, EPA-HQ-OAR-2014-0827-0514.
\815\ EERA (2015), ``Working Paper on Fuel Price Elasticities
for Heavy Duty Vehicles,'' Draft Final Report of Phase 2 under EPA
contract EP-C-11-046, EPA-HQ-OAR-2014-0827-0515.
---------------------------------------------------------------------------
At the time of publication of the NPRM, Winebrake et al. (2015)
published two papers in Transportation Research Part D: Transport and
Environment based on the EERA work mentioned above.\816\ These two
papers have been filed in each agency's docket and received public
review and comment. In the first paper, the fuel price elasticities of
VMT and fuel consumption for combination trucks are estimated with
regression models. The combination trucks paper uses annual data for
the period 1970-2012. VMT and fuel consumption are used as the
dependent variables. The control variables include: A macroeconomic
variable (e.g., gross domestic product (GDP)), imports/exports, and
fuel price, among other variables. In the second paper, the fuel price
elasticity of VMT for single unit vehicles is estimated by using annual
data for the period 1980-2012. The single unit vehicle paper uses
similar control variables but includes additional variables related to
lane miles and housing construction. VMT is the only dependent variable
modeled in the single unit vehicle paper (i.e., fuel consumption is not
modeled).
---------------------------------------------------------------------------
\816\ Winebrake, J.J., et al., Fuel price elasticities in the
U.S. combination trucking sector. Transportation Research Part D:
Transport and Environment, 2015. 38: p. 166-177.
Winebrake, J.J., et al., Fuel price elasticities for single unit
truck operations in the United States. Transportation Research Part
D: Transport and Environment, 2015. 38: p. 178-187.
---------------------------------------------------------------------------
The results in Winebrake et al. are that the null hypothesis--which
states that the fuel price elasticity of VMT and the fuel price
elasticity of fuel consumption are zero--cannot be rejected with
statistical confidence. The papers hypothesize that low elasticities
may be due to a range of possibilities including: (1) The common use of
fuel surcharges; (2) adjustments in other operational costs such as
labor; (3) possible principal-agent problems affecting driver behavior;
and (4) the nature of freight transportation as an input to a larger
supply chain system that is driven by other factors. These two papers
suggest that previous regulatory analysis that uses a five percent
rebound effect for combination trucks and a 15 percent rebound effect
for single unit trucks may be overestimating the direct VMT rebound
effect.
To the best of our knowledge, the Winebrake et al. paper represents
the first peer-reviewed work in the last two decades, after Gately
(1990),\817\ that attempts to estimate quantitatively the impact of a
change in fuel costs on HDV VMT in the U.S. context. A subsequent paper
by Wadud, discussed in more detail below, states that there is ``only
one creditable study'' on ``the responses of different [heavy duty]
vehicle sectors to fuel price or income changes,'' specifically the
Winebrake et al. combination truck work.
---------------------------------------------------------------------------
\817\ Gately, D., 1990. The U.S. demand for highway travel and
motor fuel. Energy J. 11, 59-74.
---------------------------------------------------------------------------
However, there is also other recent work that has not been peer
reviewed, or that studies HD VMT rebound in other countries, that bears
mention. Resources for the Future (RFF) filed a comment on the proposal
with a Working Paper by Leard et al. (2015) to address HDV rebound
effects.818 819 Leard et al.'s paper uses detailed truck-
level micro-data from the Vehicle Inventory and Use Survey (VIUS) for
six survey years (specifically, 1977, 1982, 1987, 1992, 1997, and
2002). The ``rebound effect'' in this paper is defined to be a
combination of a ``VMT elasticity with respect to fuel costs per mile''
($/mile); and a ``truck count elasticity with respect to fuel costs per
mile.'' Fuel costs per mile are defined as fuel price ($/gal) divided
by efficiency (mpg). Because the agencies do not estimate the
directional impact of this rulemaking on vehicle sales, the portion of
Leard et al.'s estimates associated with VMT rebound with respect to
fuel costs per mile are the most useful point of comparison to the
estimates in the proposal for this rulemaking.
---------------------------------------------------------------------------
\818\ Resources for the Future (RFF) comment, EPA-HQ-OAR-2014-
0827-1200.
\819\ Leard, B., et al., Fuel Costs, Economic Activity, and the
Rebound Effect for Heavy-Duty Trucks. September 2015, Resources for
the Future: RF DP 15-43, Washington, DC. EPA-HQ-OAR-2014-0827-1200-
A1.
---------------------------------------------------------------------------
Leard et al. report a VMT rebound effect result of 18.5 percent
with respect to fuel costs per mile for combination trucks.\820\ This
finding suggests that previous estimates of combination truck rebound
effects used in the proposed rule, a five percent rebound effect, may
be underestimating the true rebound effect. Leard et al. also report a
VMT rebound effect with respect to fuel costs per mile of 12.2 percent
for single unit trucks.\821\ This finding (like the findings of the
Winebrake paper) suggests that the previous use of a 15 percent rebound
effect for single unit vehicles in the proposed rule may be
overestimating the true rebound effect. As noted, VIUS was discontinued
in 2002, so the most recent data in this study is 2002, which is
fourteen years old. The Leard et al. Working Paper has not yet been
peer reviewed or published.
---------------------------------------------------------------------------
\820\ Leard et al. report a total VMT rebound effect result of
29.7 percent for combination trucks, which is a sum of separate
estimates associated with both VMT elasticity and truck count
elasticity with respect to fuel costs per mile.
\821\ For vocational trucks, Leard et al. report an overall 9.3
percent rebound value, which is a sum of separate estimates
associated with both VMT elasticity and truck count elasticity with
respect to fuel costs per mile.
---------------------------------------------------------------------------
Recently, Wadud (2016) has estimated price elasticities of diesel
demand in the U.K.\822\ The paper aims to model diesel demand
elasticities for different freight duty vehicle types in the U.K. Wadud
uses a similar model specification as Winebrake et al. in the
regression analysis. Wadud finds that diesel consumption in freight
vehicles overall is quite inelastic. Diesel demand from articulated
trucks and large goods vehicles (similar to combination trucks in the
U.S.) does not respond to changes
[[Page 73872]]
in diesel prices. Demand in rigid trucks (similar to single unit trucks
in the U.S.) responds to fuel price changes with a 15 percent
elasticity. Wadud's work presents empirical results in the U.K., which
might not be necessarily be appropriate to apply to the U.S.
---------------------------------------------------------------------------
\822\ Wadud, Zia, Diesel Demand in the Road Freight Sector in
the UK: Estimates for Different Vehicle Types. Applied Energy 165
(2016), p. 849-857.
---------------------------------------------------------------------------
(3) How the Agencies Estimated the HDV Rebound Effect for the Final
Rule
(a) Values Used in the Phase 2 NPRM Analysis
At the time the agencies conducted their analysis of the proposed
Phase 2 HD fuel efficiency and GHG emissions standards, the agencies
determined that the evidence did not lend itself to any changes in the
values used to estimate the VMT rebound effect in the HD Phase 1
rulemaking. The agencies used the rebound effects estimate of 15
percent for vocational vehicles five percent for combination tractors,
and 10 percent for HD pickup trucks and vans from the HD Phase 1
rulemaking.
(b) How the Agencies Analyzed VMT Rebound in This Final Rulemaking
The emergence of new information as well as public comment are
cause for updating the quantitative values used to estimate the VMT
rebound effect from those estimated by the analysis conducted for the
HD Phase 1 rulemaking. For vocational trucks, the Winebrake et al.
study found no responsiveness of truck travel to diesel fuel prices,
suggesting a VMT rebound of essentially zero. Leard et al. suggested a
VMT rebound effect for vocational trucks of roughly 12 percent. For
combination trucks, the Winebrake et al. study found a rebound effect
of essentially zero percent. The Leard et al. study found a VMT
elasticity rebound effect of roughly 18 percent for combination trucks.
In addition to the RFF comments to which Leard et al. was included, EPA
and NHTSA received ten other comments on HDV rebound during the comment
period for the proposal, six of which were substantive. One of these
commenters suggested that the agencies' rebound numbers ``appear
reasonable.'' The five others commented that the rebound estimates for
both combination and vocational vehicles used in the proposal were
overestimated, and suggested using the Winebrake et al. estimates.
In revising the HD VMT rebound estimates, we give somewhat greater
consideration to the findings of Winebrake et al. because it is peer-
reviewed and published, whereas Leard et al. is a Working Paper. Based
on this consideration and on the comments that we received in response
to the proposal, the agencies have chosen to revise the VMT rebound
estimate for vocational trucks down to five percent, and have elected
to maintain the use of the five percent rebound effect for tractors. We
note that while the Winebrake et al. work supports rebound estimates of
zero percent for vocational vehicles and tractors, using a five percent
value is conservative and leaves some consideration of uncertainty, as
well as some consideration of the (un-peer reviewed and unpublished)
findings of the Leard et al. study. The five percent value is in range
of the two U.S. studies and generally addresses the issues raised by
the commenters. We did not receive new data or comments on our
estimated VMT rebound effect for heavy-duty pick-up trucks and vans.
Therefore, we have elected to use the 10 percent value used for the
proposal.
It should be noted that the rebound estimates we have selected for
our analysis represent the VMT impact from the final standards with
respect to changes in the fuel cost per mile driven. As described in
the RIA (Chapter 8), the HDV rebound effect should ideally be a measure
of the change in fuel consumed with respect to the change in overall
operating costs due to a change in HDV fuel efficiency. Such a measure
would incorporate all impacts from our rules, including those from
incremental increases in vehicle prices that reflect costs for
improving their fuel efficiency. Therefore, VMT rebound estimates with
respect to fuel costs per mile must be ``scaled'' to apply to total
operating costs, by dividing them by the fraction of total operating
costs accounted for by fuel use.
In the NPRM, due to timing constraints, we used the same
``overall'' VMT rebound value for each of the alternatives. For the
final rulemaking, we determined VMT rebound separately for each HDV
category and for each alternative. The agencies made simplifying
assumptions in the VMT rebound analysis for this final rulemaking,
similar to the approach taken during HD Phase 1 final rules. For
example, due to timing constraints, the agencies did not have the final
technology package costs for each of the alternatives prior to the need
to conduct the emission inventory analysis. Therefore, the agencies
used the technology package costs developed for each of the NPRM
alternatives. Chapter 8.3.3 in the RIA provides more details on our
assessment of HDV VMT rebound. In addition, Chapter 7 of the RIA
presents VMT rebound for each HDV sector that we estimated for the
final program. These VMT impacts are reflected in the estimates of
total fuel savings and reductions in emissions of GHG and other air
pollutants presented in Section VII and VIII of this Preamble for all
categories.
For the purposes of this final rulemaking, we have not taken into
account any potential fuel savings or GHG emission reductions from the
rail sector due to mode shift because estimates of this effect seem too
speculative at this time. Similarly, we have not taken into account any
fuel savings or GHG emissions reductions from the potential shift in
VMT from older HDVs to newer, more efficient HDVs because we have found
no evidence of this potential effect from fuel efficiency standards.
The agencies requested comment on these assumptions in the NPRM, but
did not receive any.
Note that while we focus on the VMT rebound effect in our analysis
of these final rules, there are at least two other types of rebound
effects discussed in the energy policy and economics literature. In
addition to VMT rebound effects, there are ``indirect'' rebound
effects, which refers to the purchase of other goods or services (that
consume energy) with the costs savings from energy efficiency
improvements; and ``economy-wide'' rebound effects, which refers to the
increased demand for energy throughout the economy in response to the
reduced market price of energy that happens as a result of energy
efficiency improvements. One commenter pointed out that consumers may
use their savings from lower fuel costs as a result of the direct
rebound effect to buy more goods and services, which indirectly
increases the use of energy (i.e., the indirect rebound effect).\823\
The commenter states that the indirect rebound effect represents a
positive economic result for consumers, since consumer welfare
increases, although it could result in increased energy use and GHG
emissions. We agree with the commenter's observation that, to the
extent that indirect rebound does occur, it could have both positive
and negative impacts.
---------------------------------------------------------------------------
\823\ EPA-HQ-OAR-2014-0827-1336.
---------------------------------------------------------------------------
Another commenter suggested that the indirect or economy-wide
rebound effect could be large enough so as to fully offset the fuel
savings and GHG emissions benefits of the rule.\824\ The commenter
provides multiple estimates of the potential size of the indirect
rebound effect. However, the unpublished methodology used to perform
these estimates has not undergone peer review and, as explained in the
response to comment
[[Page 73873]]
document, the agencies find it to be dubious. Further, as discussed in
detail in the proposal rule and our response to comment document, there
are a number of other important questions not addressed by the
commenter that must be examined before we can have enough confidence in
these kinds of estimates to include them in our economic analysis.
---------------------------------------------------------------------------
\824\ EPA-HQ-OAR-2014-0827-1467.
---------------------------------------------------------------------------
As discussed in this rule, all of the fuel costs savings will not
necessarily be passed through to the consumer in terms of cheaper goods
and services. First, there may be market barriers that impede trucking
companies from passing along the fuel cost savings from the rule in the
form of lower rates. Second, there are upfront vehicle costs (and
potentially transaction or transition costs associated with the
adoption of new technologies) that would partially offset some of the
fuel cost savings from our rule, thereby limiting the magnitude of the
impact on prices of final goods and services. Also, it is not clear how
the fuel savings from the rule would be utilized by trucking firms. For
example, trucking firms may reinvest fuel savings in their own company;
retain fuel savings as profits; pass fuel savings onto customers or
others; or increase driver pay. Finally, it is not clear how the
different pathways that fuel savings would be utilized would affect
greenhouse gas emissions.
Research on indirect and economy-wide rebound effects is scant, and
we have not identified any peer-reviewed research that attempts to
quantify indirect or economy-wide rebound effects for HDVs. In
particular, the agencies are not aware of any peer-reviewed approach
which indicates that the magnitude of indirect or economy-wide rebound
effects, if any, would be significant for this final rule.\825\
Therefore, we rely on the analysis of vehicle miles traveled to
estimate the rebound effect in this rule, as we did for the HD Phase 1
rule, where we attempted to quantify only rebound effects from our rule
that impact HDV VMT.
---------------------------------------------------------------------------
\825\ The same entity responsible for these comments also sought
reconsideration of the Phase 1 rule on the grounds that indirect
rebound effects had not been considered by the agencies and could
negate all of the benefits of the standards. This assertion rested
on an unsupported affidavit lacking any peer review or other indicia
of objectivity. This affidavit cited only one published study. The
study cited did not deal with vehicle efficiency, has methodological
limitations (many of them acknowledged), and otherwise was not
pertinent. EPA and NHTSA thus declined to reconsider the Phase 1
rule based on these speculative assertions. See generally 77 FR
51703-51704, August 27, 2012 and 77 FR 51502-51503, August 24, 2012.
The analysis in this entity's comments on this rulemaking rests
largely on that same unsupported affidavit.
---------------------------------------------------------------------------
In order to test the effect of alternative assumptions about the
rebound effect, NHTSA examined the sensitivity of its estimates of
benefits and costs of the proposed Phase 2 program for HD pickups and
vans to alternative assumptions about the rebound effect. While the
main analysis for pickups and vans assumes a 10 percent rebound effect,
the sensitivity analysis estimates the benefits and costs of these
standards under the assumptions of 5, 15, and 20 percent rebound
effects. This sensitivity analysis can be found in Section IX.E.3 of
the NPRM Preamble \826\ and shows that (a) using a 5 percent value for
the rebound effect reduced benefits and costs of the proposed standards
by identical amounts, leaving net benefits unaffected; and (b) rebound
effects of 15 percent and 20 percent increased costs and reduced
benefits compared to their values in the main analysis, thus reducing
net benefits of the proposed standards. Nevertheless, the proposed and
now the final program have significant net benefits and these
alternative values of the rebound effect would not have affected the
agencies' selection of the final program stringency, as that selection
is based on NHTSA's assessment of the maximum feasible fuel efficiency
standards and EPA's selection of appropriate GHG standards to address
energy security and the environment.
---------------------------------------------------------------------------
\826\ 80 FR 40137.
---------------------------------------------------------------------------
F. Impact on Class Shifting, Fleet Turnover, and Sales
The agencies considered two additional potential indirect effects
which may lead to unintended consequences of the program to improve the
fuel efficiency and reduce GHG emissions from HD trucks. The next
sections cover the agencies' qualitative discussions on potential class
shifting and fleet turnover effects.
(1) Class Shifting
Heavy-duty vehicles are typically configured and purchased to
perform a function. For example, a concrete mixer truck is purchased to
transport concrete, a combination tractor is purchased to move freight
with the use of a trailer, and a Class 3 pickup truck could be
purchased by a landscape company to pull a trailer carrying lawnmowers.
The purchaser makes decisions based on many attributes of the vehicle,
including the gross vehicle weight rating of the vehicle, which in part
determines the amount of freight or equipment that can be carried. If
the Phase 2 standards impact either the performance of the vehicle or
the marginal cost of the vehicle relative to the other vehicle classes,
then consumers may choose to purchase a different vehicle, resulting in
the unintended consequence of increased fuel consumption and GHG
emissions in-use.
The agencies, along with the NAS panel, found that there is little
or no literature which evaluates class shifting between trucks.\827\ In
addition, the agencies did not receive comments specifically raising
concerns about class shifting. NHTSA and EPA qualitatively evaluated
the final rules in light of potential class shifting. The agencies
looked at four potential cases of shifting: From light-duty pickup
trucks to heavy-duty pickup trucks; from sleeper cabs to day cabs; from
combination tractors to vocational vehicles; and within vocational
vehicles.
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\827\ See 2010 NAS Report, page 152.
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Light-duty pickup trucks, those with a GVWR of less than 8,500 lbs,
are currently regulated under the existing GHG/CAFE standards for light
duty vehicles. The increased stringency of the light-duty 2017-2025 MY
vehicle rule has led some to speculate that vehicle consumers may
choose to purchase heavy-duty pickup trucks that are currently
regulated under the HD Phase 1 program if the cost of the light-duty
regulation is high relative to the cost to buy the larger heavy-duty
pickup trucks. Since fuel consumption and GHG emissions rise
significantly with vehicle mass, a shift from light-duty trucks to
heavy-duty trucks would likely lead to higher fuel consumption and GHG
emissions, an untended consequence of the regulations. Given the
significant price premium of a heavy-duty truck (often five to ten
thousand dollars more than a light-duty pickup), we believe that such a
class shift would be unlikely whether or not this program exited. These
final rules would continue to diminish any incentive for such a class
shift because they would narrow the GHG and fuel efficiency performance
gap between light-duty and heavy-duty pickup trucks. The regulations
for the HD pickup trucks, and similarly for vans, are based on similar
technologies and therefore reflect a similar expected increase in cost
when compared to the light-duty GHG regulation. Hence, the combination
of the two regulations provides little incentive for a shift from
light-duty trucks to HD trucks. To the extent that this regulation of
heavy-duty pickups and vans could conceivably encourage a class shift
towards lighter pickups, this unintended consequence
[[Page 73874]]
would in fact be expected to lead to lower fuel consumption and GHG
emissions as the smaller light-duty pickups have significantly better
fuel economy ratings than heavy-duty pickup trucks.
The projected cost increases for this action differ between Class 8
day cabs and Class 8 sleeper cabs, reflecting our conservative
assumption for purposes of this analysis on shifting that compliance
with these standards would lead truck consumers to specify sleeper cabs
equipped with APUs or alternatives to APU while day cab consumers would
not. Since Class 8 day cab and sleeper cab trucks perform essentially
the same function when hauling a trailer, this raises the possibility
that the additional cost for an APU or alternatives to APU equipped
sleeper cab could lead to a shift from sleeper cab to day cab trucks.
We do not believe that such an intended consequence would occur for the
following reasons. The addition of a sleeper berth to a tractor cab is
not a consumer-selectable attribute in quite the same way as other
vehicle features. The sleeper cab provides a utility that long-distance
trucking fleets need to conduct their operations--an on-board sleeping
berth that lets a driver comply with federally-mandated rest periods,
as required by the Department of Transportation Federal Motor Carrier
Safety Administration's hours-of-service regulations. The cost of
sleeper trucks is already higher than the cost of day cabs, yet the
fleets that need this utility purchase them.\828\ A day cab simply
cannot provide this utility with a single driver. The need for this
utility would not be changed even if the additional costs to reduce
greenhouse gas emissions from sleeper cabs exceed those for reducing
greenhouse gas emissions from day cabs.\829\
---------------------------------------------------------------------------
\828\ A baseline tractor price of a new day cab is $89,500
versus $113,000 for a new sleeper cab based on information gathered
by ICF in the ``Investigation of Costs for Strategies to Reduce
Greenhouse Gas Emissions for Heavy-Duty On-Road Vehicles,'' July
2010. Page 3. Docket Identification Number EPA-HQ-OAR-2014--0827.
\829\ The average marginal cost difference between sleeper cabs
and day cabs in the rule is roughly $2,500.
---------------------------------------------------------------------------
A trucking fleet could instead decide to put its drivers in hotels
in lieu of using sleeper berths, and switch to day cabs. However, this
is unlikely to occur in any great number, since the added cost for the
hotel stays would far overwhelm differences in the marginal cost
between day and sleeper cabs. Even if some fleets do opt to buy hotel
rooms and switch to day cabs, they would be highly unlikely to purchase
a day cab that was aerodynamically worse than the sleeper cab they
replaced, since the need for features optimized for long-distance
hauling would not have changed. So in practice, there would likely be
little difference to the environment for any switching that might
occur. Further, while our projected costs in the NPRM assumed the
purchase of an APU for compliance for nearly all sleeper cabs, the
updated analysis reflects additional flexibility in the final rules
that would allow manufacturers to use several other alternatives to
APUs that would be much less expensive. Thus, even though we are now
projecting that APU costs will be somewhat higher than what we
projected for the NPRM, manufacturers and consumers will not be
required to use them. In fact, this regulatory structure would allow
compliance using a near zero cost software utility that eliminates
tractor idling after five minutes. Using this compliance approach, the
cost difference between a Class 8 sleeper cab and day cab due to these
regulations is small. We are proposing this alternative compliance
approach reflecting that some sleeper cabs are used in team driving
situations where one driver sleeps while the other drives. In that
situation, an APU is unnecessary since the tractor is continually being
driven when occupied. When it is parked, it would automatically
eliminate any additional idling through the shutdown software. If
trucking businesses choose this option, then costs based on purchase of
APUs may overestimate the costs of this program to this sector.
Class shifting from combination tractors to vocational vehicles may
occur if a customer deems the additional marginal cost of tractors due
to the regulation to be greater than the utility provided by the
tractor. The agencies initially considered this issue when deciding
whether to include Class 7 tractors with the Class 8 tractors or
regulate them as vocational vehicles. The agencies' evaluation of the
combined vehicle weight rating of the Class 7 shows that if these
vehicles were treated significantly differently from the Class 8
tractors, then they could be easily substituted for Class 8 tractors.
Therefore, the agencies will continue to include both classes in the
tractor category. The agencies believe that a shift from tractors to
vocational vehicles would be limited because of the ability of tractors
to pick up and drop off trailers at locations which cannot be done by
vocational vehicles.
The agencies do not envision that the regulatory program would
cause class shifting within the vocational vehicle class. As vocational
vehicles include a wide variety of vehicle types, and serve a wide
range of functions, the diversity in the vocational vehicle segment can
be primarily attributed to the variety of customer needs for
specialized vehicle bodies and added equipment, rather than to the
chassis. The new standards are projected to lead to a small increase in
the incremental cost per vehicle. However, these cost increases are
consistent across the board for both vocational vehicles and the
engines used in the vehicle (Table V-30 at Preamble Section
V.C.(2)(e)). The agencies believe that the utility gained from the
additional technology package would outweigh the additional cost for
vocational vehicles.\830\
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\830\ The final rule projects the average per-vehicle costs
associated with the 2027 MY standards to be generally less than five
percent of the overall price of a new vehicle. The cost-
effectiveness of these vocational vehicle standards in dollars per
ton is similar to the cost effectiveness estimated for light-duty
trucks in the 2017-2025 light duty greenhouse gas standards
(Preamble section V.C.3).
---------------------------------------------------------------------------
In conclusion, NHTSA and EPA believe that the regulatory structure
for HD vehicles and engines would not significantly change the current
competitive and market factors that determine purchaser preferences.
Furthermore, even if a small amount of shifting would occur, any
resulting GHG impacts would likely to be negligible because any vehicle
class that sees an uptick in sales is also being regulated for GHG
emission control and fuel efficiency. Therefore, the agencies did not
include an impact of class shifting on the vehicle populations used to
assess the benefits of the program.
(2) Fleet Turnover and Sales Effects
A regulation that affects the cost to purchase and/or operate
trucks could affect whether a consumer decides to purchase a new truck
and the timing of that purchase. The term pre-buy refers to the idea
that truck purchases may occur earlier than otherwise planned to avoid
the additional costs associated with a new regulatory requirement.
Slower fleet turnover, or low-buys, may occur when owners opt to keep
their existing truck rather than purchase a new truck due to the
incremental cost of the regulation.
Several commenters raised the possibility of pre-buy for these
standards. Allison Transmission, the National Automobile Dealers
Association, the Owner-Operator Independent Drivers Association, and
the Truck Renting and Leasing Association point toward pre-buy
associated with standards from the 2000s for nitrogen oxides
(NOX) regulations as evidence of the likelihood
[[Page 73875]]
of pre-buy for vehicle GHG and fuel efficiency standards. Daimler
Trucks North America, the International Union, United Automobile,
Aerospace, and Agricultural Implement Workers of America, and the Truck
and Engine Manufacturers Association express concern about pre-buy
specifically in the context of NPRM Alternative 4, due to concerns that
the time frame for technology development and adoption was too short.
Daimler Trucks and the Environmental Defense Fund note that Phase 1 did
not appear to result in pre-buy. Volvo Group notes that the phase-in
approach of Phase 1 plus the flexibilities available eased the
transition to new technologies, and that gradual market acceptance of
new technologies will lead to less disruption than an accelerated
program. The Recreational Vehicle Industry Association expressed
concern that the standards will have a negative effect on recreational
vehicle sales.
The 2010 NAS HD Report discussed the topics associated with medium-
and heavy-duty vehicle fleet turnover. NAS noted that there is some
empirical evidence of pre-buy behavior in response to the 2004 and 2007
heavy-duty engine emission standards, with larger impacts occurring in
response to higher costs.\831\ However, those regulations increased
upfront costs to firms without any offsetting future cost savings from
reduced fuel purchases. In summary, NAS stated that:
---------------------------------------------------------------------------
\831\ Committee to Assess Fuel Economy Technologies for Medium-
and Heavy-Duty Vehicles; National Research Council; Transportation
Research Board (2010). ``Technologies and Approaches to Reducing the
Fuel Consumption of Medium- and Heavy-Duty Vehicles,'' (hereafter,
``NAS Report''). Washington, DC, the National Academies Press.
Available electronically from the National Academies Press Web site
at http://www.nap.edu/catalog.php?record_id=12845., pp. 150-151,
Docket EPA-HQ-OAR-2014-0827-0276.
. . . during periods of stable or growing demand in the freight
sector, pre-buy behavior may have significant impact on purchase
patterns, especially for larger fleets with better access to capital
and financing. Under these same conditions, smaller operators may
simply elect to keep their current equipment on the road longer, all
the more likely given continued improvements in diesel engine
durability over time. On the other hand, to the extent that fuel
economy improvements can offset incremental purchase costs, these
impacts will be lessened. Nevertheless, when it comes to efficiency
investments, most heavy-duty fleet operators require relatively quick
payback periods, on the order of two to three years.\832\
---------------------------------------------------------------------------
\832\ See NAS Report, Note 831, page 151, Docket EPA-HQ-OAR-
2014-0827-0276.
The regulations are projected to return fuel savings to the vehicle
owners that offset the cost of the regulation within a few years. The
effects of the regulation on purchasing behavior and sales will depend
on the nature of the market failures and the extent to which firms
consider the projected future fuel savings in their purchasing
decisions.
If trucking firms or other buyers account for the rapid payback,
they are unlikely to strategically accelerate or delay their purchase
plans at additional cost in capital to avoid a regulation that will
lower their overall operating costs. As discussed in Section IX.A.,
this scenario may occur if this program reduces uncertainty about fuel-
saving technologies. More reliable information about ways to reduce
fuel consumption allows truck purchasers to evaluate better the
benefits and costs of additional fuel savings, primarily in the
original vehicle market, but possibly in the resale market as well. In
addition, these standards are expected to lead manufacturers to install
more fuel-saving technologies and promote their purchase; the increased
availability and promotion may encourage sales.
Other market failures may leave open the possibility of some pre-
buy or delayed purchasing behavior. Firms may not consider the full
value of the future fuel savings for several reasons. For instance,
truck purchasers may not want to invest in fuel efficiency because of
uncertainty about fuel prices. Another explanation is that the resale
market may not fully recognize the value of fuel savings, due to lack
of trust of new technologies or changes in the uses of the vehicles.
Lack of coordination (also called split incentives--see Section IX.A)
between truck purchasers (who may emphasize the up-front costs of the
trucks) and truck operators, who like the fuel savings, can also lead
to pre-buy or delayed purchasing behavior. If these market failures
prevent firms from fully internalizing fuel savings when deciding on
vehicle purchases, then pre-buy and delayed purchase could occur and
could result in a slight decrease in the GHG benefits of the
regulation.
Thus, whether pre-buy or delayed purchase is likely to play a
significant role in the truck market depends on the specific behaviors
of purchasers in that market. Without additional information about
which scenario is more likely to be prevalent, the agencies are not
projecting a change in fleet turnover characteristics due to this
regulation.
Industry purchasing in relation to the advent of the Phase 1
standards offers at least some insight into the impacts of these
standards. The Environmental Defense Fund observes that MY 2014 heavy-
duty trucks had the highest sales since 2005. Any trends in sales are
likely to be affected by macroeconomic conditions, which have been
recovering since 2009-2010. The standards may have affected sales, but
the size of that effect is likely to be swamped by the effects of the
economic recovery. It is unlikely to be possible to separate the
effects of the existing standards from other confounding factors.
G. Monetized GHG Impacts
(1) Monetized CO2 Impacts--The Social Cost of Carbon (SC-
CO2)
We estimate the global social benefits of CO2 emission
reductions expected from the heavy-duty GHG and fuel efficiency
standards using the social cost of carbon (SC-CO2) estimates
presented in the Technical Support Document: Technical Update of the
Social Cost of Carbon for Regulatory Impact Analysis Under Executive
Order 12866 (May 2013, Revised July 2015) (``current SC-CO2
TSD'').\833\ (The SC-CO2 estimates are presented in Table
IX-11). We refer to these estimates, which were developed by the U.S.
government, as ``SC-CO2 estimates.'' The SC-CO2
is a metric that estimates the monetary value of impacts associated
with marginal changes in CO2 emissions in a given year. It
includes a wide range of anticipated climate impacts, such as net
changes in agricultural productivity and human health, property damage
from increased flood risk, and changes in energy system costs, such as
reduced costs for heating and increased costs for air conditioning. It
is typically used to assess the avoided damages as a result of
regulatory actions (i.e., benefits of rulemakings that lead to an
incremental reduction in cumulative global CO2 emissions).
---------------------------------------------------------------------------
\833\ Technical Support Document: Technical Update of the Social
Cost of Carbon for Regulatory Impact Analysis Under Executive Order
12866 (May 2013, Revised July 2015), Interagency Working Group on
Social Cost of Carbon, with participation by Council of Economic
Advisers, Council on Environmental Quality, Department of
Agriculture, Department of Commerce, Department of Energy,
Department of Transportation, Environmental Protection Agency,
National Economic Council, Office of Energy and Climate Change,
Office of Management and Budget, Office of Science and Technology
Policy, and Department of Treasury. Available at: https://www.whitehouse.gov/sites/default/files/omb/inforeg/scc-tsd-final-july-2015.pdf.
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The SC-CO2 estimates used in this analysis were
developed over many
[[Page 73876]]
years, using the best science available, and with input from the
public. Specifically, an interagency working group (IWG) that included
EPA, DOT, and other executive branch agencies and offices used three
integrated assessment models (IAMs) to develop the SC-CO2
estimates and recommended four global values for use in regulatory
analyses. The SC-CO2 estimates were first released in
February 2010 and updated in 2013 using new versions of each IAM. The
2013 update did not revisit the 2010 modeling decisions (e.g., with
regard to the discount rate, reference case socioeconomic and emission
scenarios or equilibrium climate sensitivity). Rather, improvements in
the way damages are modeled are confined to those that have been
incorporated into the latest versions of the models by the developers
themselves and used for analyses in peer-reviewed publications. The
2010 SC-CO2 Technical Support Document (2010 SC-
CO2 TSD) provides a complete discussion of the methods used
to develop these estimates and the current SC-CO2 TSD
presents and discusses the update (including recent minor technical
corrections to the estimates).\834\
---------------------------------------------------------------------------
\834\ Both the 2010 SC-CO2 TSD and the current TSD
are available at: https://www.whitehouse.gov/omb/oira/social-cost-of-carbon. The 2010 SC-CO2 TSD also available in the
docket: Docket ID EPA-HQ-OAR-2009-0472-114577, Technical Support
Document: Social Cost of Carbon for Regulatory Impact Analysis Under
Executive Order 12866, Interagency Working Group on Social Cost of
Carbon, with participation by the Council of Economic Advisers,
Council on Environmental Quality, Department of Agriculture,
Department of Commerce, Department of Energy, Department of
Transportation, Environmental Protection Agency, National Economic
Council, Office of Energy and Climate Change, Office of Management
and Budget, Office of Science and Technology Policy, and Department
of Treasury (February 2010). Also available at: http://www.whitehouse.gov/sites/default/files/omb/inforeg/for-agencies/Social-Cost-of-Carbon-for-RIA.pdf.
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The 2010 SC-CO2 TSD noted a number of limitations to the
SC-CO2 analysis, including the incomplete way in which the
IAMs capture catastrophic and non-catastrophic impacts, their
incomplete treatment of adaptation and technological change,
uncertainty in the extrapolation of damages to high temperatures, and
assumptions regarding risk aversion. Currently IAMs do not assign value
to all of the important physical, ecological, and economic impacts of
climate change recognized in the climate change literature due to a
lack of precise information on the nature of damages and because the
science incorporated into these models understandably lags behind the
most recent research. Nonetheless, these estimates and the discussion
of their limitations represent the best available information about the
social benefits of CO2 reductions to inform benefit-cost
analysis; see RIA of this rule and the SC-CO2 TSDs for
additional details. The new versions of the models used to estimate the
values presented below offer some improvements in these areas, although
further work is warranted.
Accordingly, EPA and other agencies continue to engage in research
on modeling and valuation of climate impacts with the goal to improve
these estimates. The EPA and other federal agencies also continue to
consider feedback on the SC-CO2 estimates from stakeholders
through a range of channels, including public comments on Agency
rulemakings that use the SC-CO2 in supporting analyses and
through regular interactions with stakeholders and research analysts
implementing the SC-CO2 methodology used by the IWG. The SC-
CO2 comments received on this rulemaking covered the
technical details of the modeling conducted to develop the SC-
CO2 estimates and some also provided constructive
recommendations for potential opportunities to improve the SC-
CO2 estimates in future updates. EPA has carefully
considered all of these comments and continues to conclude that the
current estimates represent the best scientific information on the
impacts of climate change available in a form appropriate for
incorporating the damages from incremental CO2 emissions
changes into regulatory analysis. Therefore, EPA has presented the
current SC-CO2 estimates in this rulemaking. See Section
11.8 of the RTC document for a summary of and response to the SC-
CO2 comments submitted to this rulemaking. In addition, OMB
sought public comment on the approach used to develop the SC-
CO2 estimates through a separate comment period and
published a response to those comments in 2015.\835\
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\835\ See https://www.whitehouse.gov/sites/default/files/omb/inforeg/scc-response-to-comments-final-july-2015.pdf.
---------------------------------------------------------------------------
After careful evaluation of the full range of comments submitted to
OMB, the IWG continues to recommend the use of the SC-CO2
estimates in regulatory impact analysis. With the July 2015 release of
the response to comments, the IWG announced plans to obtain expert
independent advice from the National Academies of Sciences, Engineering
and Medicine to ensure that the SC-CO2 estimates continue to
reflect the best available scientific and economic information on
climate change. The Academies then convened a committee, ``Assessing
Approaches to Updating the Social Cost of Carbon,'' (Committee) which
is reviewing the state of the science on estimating the SC-
CO2, and will provide expert, independent advice on the
merits of different technical approaches for modeling and highlight
research priorities going forward. EPA will evaluate its approach based
upon any feedback received from the Academies' panel.
To date, the Committee has released an interim report, which
recommended against doing a near term update of the SC-CO2
estimates. For future revisions, the Committee recommended the IWG move
efforts towards a broader update of the climate system module
consistent with the most recent, best available science, and also
offered recommendations for how to enhance the discussion and
presentation of uncertainty in the SC-CO2 estimates.
Specifically, the Committee recommended that ``the IWG provide guidance
in their technical support documents about how [SC-CO2]
uncertainty should be represented and discussed in individual
regulatory impact analyses that use the [SC-CO2]'' and that
the technical support document for each update of the estimates present
a section discussing the uncertainty in the overall approach, in the
models used, and uncertainty that may not be included in the estimates.
At the time of this writing, the IWG is reviewing the interim report
and considering the recommendations. EPA looks forward to working with
the IWG to respond to the recommendations and will continue to follow
IWG guidance on SC-CO2.
The four global SC-CO2 estimates are as follows: $13,
$46, $68, and $140 per metric ton of CO2 emissions in the
year 2020 (2013$).\836\ The first three values are based on the average
SC-CO2 from the three IAMs, at discount rates of 5, 3, and
2.5 percent, respectively. SC-CO2 estimates for several
discount rates are included because the literature shows that the SC-
CO2 is quite sensitive to assumptions about the discount
rate, and because no consensus exists on the appropriate rate to use in
an intergenerational context (where costs and benefits are incurred by
different generations). The fourth value is the 95th percentile of the
SC-CO2 from all three models at a 3 percent discount rate.
It is included to represent lower probability but higher outcomes from
[[Page 73877]]
climate change, which are captured further out in the tail of the SC-
CO2 distribution, and while less likely than those reflected
by the average SC-CO2 estimates, would be much more harmful
to society and therefore, are relevant to policy makers. The SC-
CO2 increases over time because future emissions are
expected to produce larger incremental damages as economies grow and
physical and economic systems become more stressed in response to
greater climate change. The SC-CO2 values are presented in
Table IX-11.
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\836\ The current SC-CO2 TSD presents the SC-
CO2 estimates in $2007. These estimates were adjusted to
2013$ using the GDP Implicit Price Deflator. Bureau of Economic
Analysis, Table 1.1.9 Implicit Price Deflators for Gross Domestic
Product; last revised on September 25, 2015.
---------------------------------------------------------------------------
Applying the global SC-CO2 estimates, shown in Table, to
the estimated reductions in domestic CO2 emissions for the
program, yields estimates of the dollar value of the climate related
benefits for each analysis year. These estimates are then discounted
back to the analysis year using the same discount rate used to estimate
the SC-CO2. For internal consistency, the annual benefits
are discounted back to net present value terms using the same discount
rate as each SC-CO2 estimate (i.e., 5 percent, 3 percent,
and 2.5 percent) rather than the discount rates of 3 percent and 7
percent used to derive the net present value of other streams of costs
and benefits of the final rule.\837\ The SC-CO2 benefit
estimates for each calendar year are shown in Table. The SC-
CO2 benefit estimates for each model year are shown in Table
IX-13.
---------------------------------------------------------------------------
\837\ See more discussion on the appropriate discounting of
climate benefits using SC-CO2 in the 2010 SCC TSD. Other
benefits and costs of proposed regulations unrelated to
CO2 emissions are discounted at the 3% and 7% rates
specified in OMB guidance for regulatory analysis.
Table IX-11--Social Cost of CO[ihel2], 2012-2050 \a\
[in 2013$ per Metric Ton]
----------------------------------------------------------------------------------------------------------------
3%, 95th
Calendar year 5% Average 3% Average 2.5% Average Percentile
----------------------------------------------------------------------------------------------------------------
2012............................................ $12 $36 $58 $100
2015............................................ 12 40 62 120
2020............................................ 13 46 68 140
2025............................................ 15 51 75 150
2030............................................ 18 55 80 170
2035............................................ 20 60 86 180
2040............................................ 23 66 92 200
2045............................................ 25 70 98 220
2050............................................ 29 76 100 230
----------------------------------------------------------------------------------------------------------------
Note:
\a\ The SC-CO[ihel2] values are dollar-year and emissions-year specific and have been rounded to two significant
digits. Unrounded numbers from the current SC-CO[ihel2] TSD were used to calculate the CO[ihel2] benefits.
Table IX-12--Upstream and Downstream Annual CO[ihel2] Benefits for the Given SC-CO[ihel2] Value a Using Method B
and Relative to the Flat Baseline
[Millions of 2013$] \b\
----------------------------------------------------------------------------------------------------------------
3% 95th
Calendar year 5% average 3% average 2.5% average percentile
----------------------------------------------------------------------------------------------------------------
2018............................................ $7 $22 $33 $63
2019............................................ 13 46 68 130
2020............................................ 21 73 110 210
2021............................................ 80 280 420 840
2022............................................ 170 550 820 1,700
2023............................................ 250 850 1,300 2,600
2024............................................ 390 1,300 2,000 4,000
2025............................................ 560 1,800 2,700 5,500
2026............................................ 700 2,400 3,500 7,100
2027............................................ 950 3,000 4,400 9,100
2028............................................ 1,100 3,700 5,400 11,000
2029............................................ 1,300 4,300 6,400 13,000
2030............................................ 1,600 5,000 7,300 15,000
2035............................................ 2,700 8,100 11,000 25,000
2040............................................ 3,700 11,000 15,000 33,000
2050............................................ 5,500 15,000 20,000 45,000
NPV............................................. 24,000 110,000 180,000 340,000
----------------------------------------------------------------------------------------------------------------
Notes:
\a\ The SC-CO[ihel2] values are dollar-year and emissions-year specific.
\b\ For an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat
baseline, 1a, and dynamic baseline, 1b, please see Section X.A.1.
[[Page 73878]]
Table IX-13--Upstream and Downstream Discounted Model Year Lifetime CO[ihel2] Benefits for the Given SC-
CO[ihel2] Value Using Method B and Relative to the Flat Baseline
[Millions of 2013$] a b
----------------------------------------------------------------------------------------------------------------
3% 95th
Model year 5% average 3% average 2.5% average percentile
----------------------------------------------------------------------------------------------------------------
2018............................................ $38 $150 $230 $450
2019............................................ 36 140 220 430
2020............................................ 34 140 220 420
2021............................................ 560 2,300 3,600 7,000
2022............................................ 590 2,500 3,900 7,500
2023............................................ 610 2,600 4,000 7,800
2024............................................ 920 4,000 6,200 12,000
2025............................................ 940 4,100 6,400 12,000
2026............................................ 950 4,200 6,600 13,000
2027............................................ 1,200 5,400 8,500 16,000
2028............................................ 1,200 5,300 8,400 16,000
2029............................................ 1,200 5,300 8,400 16,000
Sum............................................. 8,200 36,000 57,000 110,000
----------------------------------------------------------------------------------------------------------------
Notes:
\a\ The SC-CO[ihel2] values are dollar-year and emissions-year specific.
\b\ For an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat
baseline, 1a, and dynamic baseline, 1b, please see Section X.A.1.
(2) Monetized Non-CO2 GHG Impacts
EPA calculated the global social benefits of CH4 and
N2O emissions reductions expected from the final rulemaking
using estimates of the social cost of methane (SC-CH4) and
the social cost of nitrous oxide (SC-N2O). Similar to the
SC-CO2, the SC-CH4 and SC-N2O estimate
the monetary value of impacts associated with marginal changes in
CH4 and N2O emissions, respectively, in a given
year. Each metric includes a wide range of anticipated climate impacts,
such as net changes in agricultural productivity and human health,
property damage from increased flood risk, and changes in energy system
costs, such as reduced costs for heating and increased costs for air
conditioning. The SC-CH4 and SC-N2O estimates
applied in this analysis were developed by Marten et al. (2014) and are
discussed in greater detail below. EPA is unaware of analogous
estimates of HFC-134a and has therefore presented a sensitivity
analysis, separate from the main benefit cost analysis, that
approximates the benefits of HFC-134a reductions based on global
warming potential (GWP) gas comparison metrics (``GWP approach'').
Other unquantified non-CO2 benefits are discussed in this
section as well. Additional details are provided in the RIA of these
rules.
(a) Monetized CH4 and N2O Impacts
As discussed in the proposed rulemaking, a challenge particularly
relevant to the monetization of non-CO2 GHG impacts is that
the IWG did not estimate the social costs of non-CO2 GHG
emissions at the time the SC-CO2 estimates were developed.
While there are other estimates of the social cost of non-
CO2 GHGs in the peer review literature, none of those
estimates are consistent with the SC-CO2 estimates developed
by the IWG and most are likely underestimates due to changes in the
underlying science subsequent to their publication.\838\
---------------------------------------------------------------------------
\838\ As discussed in the RIA, there is considerable variation
among these published estimates in the models and input assumptions
they employ. These studies differ in the emission perturbation year,
employ a wide range of constant and variable discount rate
specifications, and consider a range of baseline socioeconomic and
emissions scenarios that have been developed over the last 20 years.
See also Reilly and Richards, 1993; Schmalensee, 1993; Fankhauser,
1994; Marten and Newbold, 2012.
---------------------------------------------------------------------------
However, in the time leading up to the proposal for this
rulemaking, a paper by Marten et al. (2014) provided the first set of
published SC-CH4 and SC-N2O estimates in the
peer-reviewed literature that are consistent with the modeling
assumptions the IWG used to develop the SC-CO2
estimates.\839\ Specifically, the estimation approach of Marten et al.
(2014) used the same set of three IAMs, five socioeconomic-emissions
scenarios, equilibrium climate sensitivity distribution, three constant
discount rates, and aggregation approach used to develop the SC-
CO2 estimates. Marten et al. also used the same rationale as
the IWG to develop global estimates of the SC-CH4 and the
SC-N2O, given that CH4 and N2O are
global pollutants.
---------------------------------------------------------------------------
\839\ Marten, A.L., E.A. Kopits, C.W. Griffiths, S.C. Newbold &
A. Wolverton (2014). Incremental CH4 and N2O
mitigation benefits consistent with the U.S. Government's SC-
CO2 estimates, Climate Policy, DOI: 10.1080/
14693062.2014.912981.
---------------------------------------------------------------------------
The resulting SC-CH4 and SC-N2O estimates are
presented in Table IX-14. More detailed discussion of their
methodology, results and a comparison to other published estimates can
be found in the RIA and in Marten et al. (2014).
Table IX-14--Social Cost of CH4 and N[ihel2]O, 2012-2050 a
[In 2013$ per metric ton] [Source: Marten et al., 2014 b]
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
SC-CH4 SC-N[ihel2]O
-------------------------------------------------------------------------------------------------------------------------------
Year 3% 95th 3% 95th
5% average 3% average 2.5% average percentile 5% average 3% average 2.5% average percentile
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
2012............................................................ $440 $1,000 $1,400 $2,800 $4,000 $14,000 $21,000 $36,000
2015............................................................ 490 1,100 1,500 3,100 4,400 14,000 22,000 38,000
2020............................................................ 590 1,300 1,800 3,500 5,200 16,000 24,000 43,000
2025............................................................ 710 1,500 2,000 4,100 6,000 19,000 26,000 48,000
2030............................................................ 830 1,800 2,200 4,600 6,900 21,000 30,000 54,000
2035............................................................ 990 2,000 2,500 5,400 8,100 23,000 32,000 60,000
[[Page 73879]]
2040............................................................ 1,100 2,200 2,900 6,000 9,200 25,000 35,000 66,000
2045............................................................ 1,300 2,500 3,100 6,700 10,000 27,000 37,000 73,000
2050............................................................ 1,400 2,700 3,400 7,400 12,000 30,000 41,000 79,000
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Notes:
\a\ The values are emissions-year specific and have been rounded to two significant digits. Unrounded numbers were used to calculate the GHG benefits.
\b\ The estimates in this table have been adjusted to reflect the minor technical corrections to the SC-CO[ihel2] estimates described above. See the Corrigendum to Marten et al. (2014), http://www.tandfonline.com/doi/abs/10.1080/14693062.2015.1070550.
In addition to requesting comment on these estimates in the
proposed rulemaking, EPA noted that it had initiated a peer review of
the application of the Marten et al (2014) non-CO2 social
cost estimates in regulatory analysis.\840\ EPA also stated that,
pending a favorable peer review, it planned to use the Marten et al
(2014) estimates to monetize benefits of CH4 and
N2O emission reduction in the main benefit-cost analysis of
the final rule.
---------------------------------------------------------------------------
\840\ For a copy of the peer review and the responses, see
https://cfpub.epa.gov/si/si_public_pra_view.cfm?dirEntryID=291976
(see ``SCCH4 EPA PEER REVIEW FILES.PDF'').
---------------------------------------------------------------------------
Since then, EPA received responses that supported use of the Marten
et al. estimates. Three reviewers considered seven charge questions
that covered issues such as the EPA's interpretation of the Marten et
al. estimates, the consistency of the estimates with the SC-
CO2 estimates, the EPA's characterization of the limits of
the GWP-approach to value non-CO2 GHG impacts, and the
appropriateness of using the Marten et al. estimates in regulatory
impact analyses. The reviewers agreed with the EPA's interpretation of
Marten et al.'s estimates, generally found the estimates to be
consistent with the SC-CO2 estimates, and concurred with the
limitations of the GWP approach, finding directly modeled estimates to
be more appropriate. While outside of the scope of the review, the
reviewers briefly considered the limitations in the SC-CO2
methodology (e.g., those discussed earlier in this section) and noted
that because the SC-CO2 and SC-CH4 and SC-
N2O methodologies are similar, the limitations also apply to
the resulting SC-CH4 and SC-N2O estimates. Two of
the reviewers concluded that use of the SC-CH4 and SC-
N2O estimates developed by Marten et al. and published in
the peer-reviewed literature is appropriate in RIAs, provided that the
Agency discuss the limitations, similar to the discussion provided for
SC-CO2 and other economic analyses. All three reviewers
encouraged continued improvements in the SC-CO2 estimates
and suggested that as those improvements are realized they should also
be reflected in the SC-CH4 and SC-N2O estimates,
with one reviewer suggesting the SC-CH4 and SC-
N2O estimates lag this process. The EPA supports continued
improvement in the SC-CO2 estimates developed by the U.S.
government and agrees that improvements in the SC-CO2
estimates should also be reflected in the SC-CH4 and SC-
N2O estimates. The fact that the reviewers agree that the
SC-CH4 and SC-N2O estimates are generally
consistent with the SC-CO2 estimates that are recommended by
OMB's guidance on valuing CO2 emissions reductions, leads
the EPA to conclude that use of the SC-CH4 and SC-
N2O estimates is an analytical improvement over excluding
CH4 and N2O emissions from the monetized portion
of the benefit cost analysis.
The EPA also carefully considered the full range of public comments
and associated technical issues on the Marten et al. estimates received
in this rulemaking and determined that it would continue to use the
estimates in the final rulemaking analysis. Based on the evaluation of
the public comments on this rulemaking, the favorable peer review of
the application of Marten et al. estimates, and past comments urging
EPA to value non-CO2 GHG impacts in its rulemakings, EPA
concluded that the estimates represent the best scientific information
on the impacts of climate change available in a form appropriate for
incorporating the damages from incremental CH4 and
N2O emissions changes into regulatory analysis and has
included those benefits in the main benefits analysis. Please see RTC
Section 11.8 for detailed responses to the comments on non-
CO2 GHG valuation.
The application of directly modeled estimates from Marten et al.
(2014) to benefit-cost analysis of a regulatory action is analogous to
the use of the SC-CO2 estimates. Specifically, the SC-
CH4 and SC-N2O estimates in Table IX-15 are used
to monetize the benefits of changes in CH4 and
N2O emissions expected as a result of the final rulemaking.
Forecast changes in CH4 and N2O emissions in a
given year resulting from the regulatory action are multiplied by the
SC-CH4 and SC-N2O estimate for that year,
respectively. To obtain a present value estimate, the monetized stream
of future non-CO2 benefits are discounted back to the
analysis year using the same discount rate used to estimate the social
cost of the non-CO2 GHG emission changes.
The CH4 and N2O benefits based on Marten et
al. (2014) are presented for each calendar year in Table IX-15.
[[Page 73880]]
Table IX-15--Annual Upstream and Downstream non-CO[ihel2] GHG Benefits for the Given SC-non-CO[ihel2] Value Using Method B and Relative to the Flat
Baseline, using the Directly Modeled Approach \a\ \b\
[Millions of 2012$] \c\
--------------------------------------------------------------------------------------------------------------------------------------------------------
CH4 N[ihel2]O
-------------------------------------------------------------------------------------------------------
Calendar year 2.5% 3% 95th 2.5% 3% 95th
5% Average 3% Average Average percentile 5% Average 3% Average Average percentile
--------------------------------------------------------------------------------------------------------------------------------------------------------
2018............................................ $0 $1 $1 $2 $0 $0 $0 $0
2019............................................ 1 1 2 3 0 0 0 0
2020............................................ 1 2 3 5 0 0 0 0
2021............................................ 4 8 11 22 0 0 1 1
2022............................................ 7 16 21 43 0 1 1 2
2023............................................ 12 26 33 68 0 1 2 3
2024............................................ 19 40 52 110 1 2 3 5
2025............................................ 26 56 72 150 1 3 4 7
2026............................................ 34 72 92 190 1 3 5 9
2027............................................ 44 94 120 250 1 4 6 11
2028............................................ 54 120 150 300 2 5 7 13
2029............................................ 65 140 170 360 2 6 9 16
2030............................................ 76 160 200 420 2 7 10 19
2035............................................ 130 260 340 720 4 12 16 31
2040............................................ 180 360 460 980 6 16 22 41
2050............................................ 280 530 660 1,400 9 22 30 58
NPV............................................. 1,200 3,800 5,400 10,000 37 160 250 430
--------------------------------------------------------------------------------------------------------------------------------------------------------
Notes:
\a\ The SC-CH4 and SC-N[ihel2]O values are dollar-year and emissions-year specific.
\b\ Note that net present discounted values of reduced GHG emissions is are calculated differently than other benefits. The same discount rate used to
discount the value of damages from future emissions (SC-CH4 and SC-N[ihel2]O at 5, 3, and 2.5 percent) is used to calculate net present value
discounted values of SC-CH4 and SC-N[ihel2]O for internal consistency. Refer to the 2010 SC-CO[ihel2] TSD for more detail.
\c\ For an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 1b,
please see Section X.A.1.
(b) Sensitivity Analysis--HFC-134a Benefits Based on the GWP
Approximation Approach
While the rulemaking will result in reductions of HFC-134a, EPA is
unaware of analogous estimates of the social cost of HFC-134a and has
therefore used an alternative valuation approach and presented the
results in this sensitivity analysis, separate from the main benefit
cost analysis. Specifically, EPA has used the global warming potential
(GWP) for HFC-134a to convert the emissions of this gas to
CO2 equivalents, which are then valued using the SC-
CO2 estimates. This approach, henceforth referred to as the
``GWP approach,'' has been used in sensitivity analyses to estimate the
non-CO2 benefits in previous EPA rulemakings (see U.S. EPA
2012, 2013).\841\ EPA has not presented these estimates in a main
benefit-cost analysis due to the limitations associated with using the
GWP approach to value changes in non-CO2 GHG emissions, and
considered the GWP approach as an interim method of analysis until
social cost estimates for non-CO2 GHGs, consistent with the
SC-CO2 estimates, were developed.
---------------------------------------------------------------------------
\841\ U.S. EPA. (2012). ``Regulatory impact analysis supporting
the 2012 U.S. Environmental Protection Agency final new source
performance standards and amendments to the national emission
standards for hazardous air pollutants for the oil and natural gas
industry.'' Retrieved from http://www3.epa.gov/ttn/ecas/regdata/RIAs/oil_natural_gas_final_neshap_nsps_ria.pdf. U.S. EPA. (2013).
``Regulatory impact analysis: Final rulemaking for 2017-2025 light-
duty vehicle greenhouse gas emission standards and corporate average
fuel economy standards.'' Retrieved from http://www3.epa.gov/otaq/climate/documents/420r12016.pdf.
---------------------------------------------------------------------------
The GWP is a simple, transparent, and well-established metric for
assessing the relative impacts of non-CO2 emissions compared
to CO2 on a purely physical basis. However, as discussed
both in the 2010 SC-CO2 TSD and previous rulemakings (e.g.,
U.S. EPA 2012, 2013), the GWP approximation approach to measuring non-
CO2 GHG benefits has several well-documented limitations.
These metrics are not ideally suited for use in benefit-cost analyses
to approximate the social cost of non-CO2 GHGs because the
approach would assume all subsequent linkages leading to damages are
linear in radiative forcing, which would be inconsistent with the most
recent scientific literature. Detailed discussion of limitations of the
GWP approach can be found in the RIA.
EPA applies the GWP approach to estimate the benefits associated
with reductions of HFCs in each calendar year. Under the GWP Approach,
EPA converted HFC-134a to CO2 equivalents using the AR4 100-
year GWP for HFC-134a (1,430).\842\ These CO2-equivalent
emission reductions are multiplied by the SC-CO2 estimate
corresponding to each year of emission reductions. As with the
calculation of annual benefits of CO2 emission reductions,
the annual benefits of non-CO2 emission reductions based on
the GWP approach are discounted back to net present value terms using
the same discount rate as each SC-CO2 estimate. The
estimated HFC-134a benefits using the GWP approach are presented in
Table IX-16.
---------------------------------------------------------------------------
\842\ Source: Table 2.14 (Errata). Lifetimes, radiative
efficiencies and direct (except for CH4) GWPs relative to
CO2. IPCC Fourth Assessment Report ``Climate Change 2007:
Working Group I: The Physical Science Basis.''
---------------------------------------------------------------------------
[[Page 73881]]
Vol. 81
Tuesday,
No. 206
October 25, 2016
Part II--Continued
Book 2 of 2 Books
Pages 73881-74278
Environmental Protection Agency
[[Page 73882]]
Table IX-16--Annual Upstream and Downstream HFC-134a Benefits for the Given SC-CO[ihel2] Value Using Method B
and Relative to the Flat Baseline, using the GWP Approach \a\ \b\
[Millions of 2013$] \b\
----------------------------------------------------------------------------------------------------------------
HFC-134a
---------------------------------------------------------------
Calendar year 3%, 95th
5% Average 3% Average 2.5% Average Percentile
----------------------------------------------------------------------------------------------------------------
2018............................................ $0 $0 $0 $0
2019............................................ $0 $0 $0 $0
2020............................................ $0 $0 $0 $0
2021............................................ $0 $1 $1 $3
2022............................................ $1 $2 $3 $5
2023............................................ $1 $3 $4 $8
2024............................................ $1 $4 $5 $11
2025............................................ $1 $5 $7 $14
2026............................................ $2 $6 $9 $18
2027............................................ $2 $7 $10 $21
2028............................................ $3 $8 $12 $25
2029............................................ $3 $10 $14 $29
2030............................................ $4 $11 $16 $33
2035............................................ $5 $15 $22 $47
2040............................................ $6 $18 $25 $54
2050............................................ $9 $23 $31 $70
NPV............................................. $44 $200 $320 $620
----------------------------------------------------------------------------------------------------------------
Notes:
\a\ The SC-CO[ihel2] values are dollar-year and emissions-year specific.
\b\ For an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat
baseline, 1a, and dynamic baseline, 1b, please see Section X.A.1.
(c) Additional Non-CO2 GHGs Co-Benefits
In determining the relative social costs of the different gases,
the Marten et al. (2014) analysis accounts for differences in lifetime
and radiative efficiency between the non-CO2 GHGs and
CO2. The analysis also accounts for radiative forcing
resulting from methane's effects on tropospheric ozone and
stratospheric water vapor, and for at least some of the fertilization
effects of elevated carbon dioxide concentrations. However, there exist
several other differences between these gases that have not yet been
captured in this analysis, for example the non-radiative effects of
methane-driven elevated tropospheric ozone levels on human health,
agriculture, and ecosystems, and the effects of carbon dioxide on ocean
acidification. Inclusion of these additional non-radiative effects
would potentially change both the absolute and relative value of the
various gases.
Of these effects, the human health effect of elevated tropospheric
ozone levels resulting from methane emissions is the closest to being
monetized in a way that would be comparable to the SCC. Premature
ozone-related cardiopulmonary deaths resulting from global increases in
tropospheric ozone concentrations produced by the methane oxidation
process have been the focus of a number of studies over the past decade
(e.g., West et al. 2006; \843\ Anenberg et al. 2012; \844\ Shindell et
al. 2012 \845\). Recently, a paper was published in the peer-reviewed
scientific literature that presented a range of estimates of the
monetized ozone-related mortality benefits of reducing methane
emissions (Sarofim et al. 2015). For example, under their base case
assumptions using a 3 percent discount rate, Sarofim et al. find global
ozone-related mortality benefits of methane emissions reductions to be
$790 per ton of methane in 2020, with 10.6 percent, or $80, of this
amount resulting from mortality reductions in the United States. The
methodology used in this study is consistent in some (but not all)
aspects with the modeling underlying the SC-CO2 and SC-
CH4 estimates discussed above, and required a number of
additional assumptions such as baseline mortality rates and mortality
response to ozone concentrations. While the EPA does consider the
methane impacts on ozone to be important, there remain unresolved
questions regarding several methodological choices involved in applying
the Sarofim et al. (2015) approach in the context of an EPA benefits
analysis, and therefore the EPA is not including a quantitative
analysis of this effect in this rule at this time.
---------------------------------------------------------------------------
\843\ West JJ, Fiore AM, Horowitz LW, Mauzerall DL (2006) Global
health benefits of mitigating ozone pollution with methane emission
controls. Proc Natl Acad Sci USA 103 (11):3988-3993. doi:10.1073/
pnas.0600201103
\844\ Anenberg SC, Schwartz J, Shindell D, Amann M, Faluvegi G,
Klimont Z, . . . , Vignati E (2012) Global air quality and health
co-benefits of mitigating near-term climate change through methane
and black carbon emission controls. Environ Health Perspect 120
(6):831. doi:10.1289/ehp.1104301.
\845\ Shindell D, Kuylenstierna JCI, Vignati E, van Dingenen R,
Amann M, Klimont Z, . . ., Fowler D (2012) Simultaneously Mitigating
Near-Term Climate Change and Improving Human Health and Food
Security. Science 335 (6065):183-189. doi:10.1126/science.1210026.
---------------------------------------------------------------------------
H. Monetized Non-GHG Health Impacts
This section discusses the economic benefits from reductions in
health and environmental impacts resulting from non-GHG emission
reductions that can be expected to occur as a result of the Phase 2
standards. CO2 emissions are predominantly the byproduct of
fossil fuel combustion processes that also produce criteria and
hazardous air pollutant emissions. The vehicles that are subject to the
Phase 2 standards are also significant sources of mobile source air
pollution such as direct PM, NOX, VOCs and air toxics. The
standards will affect exhaust emissions of these pollutants from
vehicles and will also affect emissions from upstream sources that
occur during the refining and distribution of fuel. Changes in ambient
concentrations of ozone, PM2.5, and air toxics that will
result from the Phase 2 standards are expected to affect human health
by reducing premature deaths and other serious human health effects, as
well as other important improvements in public health and
[[Page 73883]]
welfare. Children especially benefit from reduced exposures to criteria
and toxic pollutants, because they tend to be more sensitive to the
effects of these respiratory pollutants. Ozone and particulate matter
have been associated with increased incidence of asthma and other
respiratory effects in children, and particulate matter has been
associated with a decrease in lung maturation. Some minority groups and
children living under the poverty line are even more vulnerable with
higher prevalence of asthma.
It is important to quantify the health and environmental impacts
associated with the standards because a failure to adequately consider
ancillary impacts could lead to an incorrect assessment of their costs
and benefits. Moreover, the health and other impacts of exposure to
criteria air pollutants and airborne toxics tend to occur in the near
term, while most effects from reduced climate change are likely to
occur only over a time frame of several decades or longer.
Impacts such as emissions reductions, costs and benefits are
presented in this analysis from two perspectives:
A ``model year lifetime analysis'' (MY), which shows
impacts of the program that occur over the lifetime of the vehicles
produced during the model years subject to the Phase 2 standards (MYs
2018 through 2029).,
A ``calendar year analysis'' (CY), which shows annual
costs and benefits of the Phase 2 standards for each year from 2018
through 2050. We assume the standard in the last model year subject to
the standards applies to all subsequent MY fleets developed in the
future.
In previous light-duty and heavy-duty GHG rulemakings, EPA has
quantified and monetized non-GHG health impacts using two different
methods. For the MY analysis, EPA applies PM-related ``benefits per-
ton'' values to the stream of lifetime estimated emission reductions as
a reduced-form approach to estimating the PM2.5-related
benefits of the rule.846 847 For the CY analysis, EPA
typically conducts full-scale photochemical air quality modeling to
quantify and monetize the PM2.5- and ozone-related health
impacts of a single representative future year. EPA then assumes these
benefits are repeated in subsequent future years when criteria
pollutant emission reductions are equal to or greater than those
modeled in the representative future year.
---------------------------------------------------------------------------
\846\ Fann, N., Baker, K.R., and Fulcher, C.M. (2012).
Characterizing the PM 2.5-related health benefits of
emission reductions for 17 industrial, area and mobile emission
sectors across the U.S., Environment International, 49, 241-151,
published online September 28, 2012.
\847\ See also: http://www3.epa.gov/airquality/benmap/sabpt.html. The current values available on the Web page have been
updated since the publication of the Fann et al., 2012 paper. For
more information regarding the updated values, see: http://www3.epa.gov/airquality/benmap/models/Source_Apportionment_BPT_TSD_1_31_13.pdf (accessed September 9,
2014).
---------------------------------------------------------------------------
This two-pronged approach to estimating non-GHG impacts is
precipitated by the length of time needed to prepare the necessary
emissions inventories and the processing time associated with full-
scale photochemical air quality modeling for a single representative
future year. The timing requirements (along with other resource
limitations) preclude EPA from being able to do the more detailed
photochemical modeling for every year that we include in our benefit
and cost estimates, and require EPA to make air quality modeling input
decisions early in the analytical process. As a result, it was
necessary to use emissions from the proposed program to conduct the air
quality modeling.
The chief limitation when using air quality inventories based on
emissions from the proposal in the CY modeling analysis is that they
can diverge from the estimated emissions of the final rulemaking. How
much the emissions might diverge and how that difference would impact
the air quality modeling and health benefit results is difficult to
anticipate. For the FRM, EPA concluded that when comparing the proposal
and final rule inventories, the differences were enough to justify the
move of the typical CY benefits analysis (based on air quality
modeling) from the primary estimate of costs and benefits to a
supplemental analysis in an appendix to the RIA (See RIA Appendix
8.A).\848\ While we believe this supplemental analysis is still
illustrative of the standard's potential benefits, EPA has instead
chosen to characterize the CY benefits in a manner consistent with the
MY lifetime analysis. That is, we apply the PM-related ``benefits per-
ton'' values to the CY final rule emission reductions to estimate the
PM-related benefits of the final rule.
---------------------------------------------------------------------------
\848\ Chapter 5 of the RIA has more detail on the differences
between the air quality and final inventories.
---------------------------------------------------------------------------
This section presents the benefits-per-ton values used to monetize
the benefits from reducing population exposure to PM associated with
the standards. EPA bases its analyses on peer-reviewed studies of air
quality and health and welfare effects and peer-reviewed studies of the
monetary values of public health and welfare improvements, and is
generally consistent with benefits analyses performed for the analysis
of the final Tier 3 Vehicle Rule,\849\ the final 2012 p.m. NAAQS
Revision,\850\ and the final 2017-2025 Light Duty Vehicle GHG
Rule.\851\
---------------------------------------------------------------------------
\849\ U.S. Environmental Protection Agency. (2014). Control of
Air Pollution from Motor Vehicles: Tier 3 Motor Vehicle Emission and
Fuel Standards Final Rule: Regulatory Impact Analysis, Assessment
and Standards Division, Office of Transportation and Air Quality,
EPA-420-R-14-005, March 2014. Available on the internet: http://www3.epa.gov/otaq/documents/tier3/420r14005.pdf.
\850\ U.S. Environmental Protection Agency. (2012). Regulatory
Impact Analysis for the Final Revisions to the National Ambient Air
Quality Standards for Particulate Matter, Health and Environmental
Impacts Division, Office of Air Quality Planning and Standards, EPA-
452-R-12-005, December 2012. Available on the internet: http://www3.epa.gov/ttnecas1/regdata/RIAs/finalria.pdf.
\851\ U.S. Environmental Protection Agency (U.S. EPA). (2012).
Regulatory Impact Analysis: Final Rulemaking for 2017-2025 Light-
Duty Vehicle Greenhouse Gas Emission Standards and Corporate Average
Fuel Economy Standards, Assessment and Standards Division, Office of
Transportation and Air Quality, EPA-420-R-12-016, August 2012.
Available on the Internet at: http://www3.epa.gov/otaq/climate/documents/420r12016.pdf.
---------------------------------------------------------------------------
EPA is also requiring that rebuilt engines installed in new
incomplete vehicles (i.e., ``glider kit'' vehicles) meet the emission
standards applicable in the year of assembly of the new vehicle,
including all applicable standards for criteria pollutants (Section
XIII.B). For the final rule, EPA has updated its analysis of the
environmental impacts of these glider kit vehicles (see Section
XIII.B.1). These standards will decrease PM and NOX
emissions dramatically, leading to substantial public health-related
benefits. Although we only present these benefits as a sensitivity
analysis in Section XIII.B, it is clear that removing even a fraction
of glider kit vehicles from the road will yield substantial health-
related benefits that are not captured by the primary estimate of
monetized non-GHG health impacts described in this section.
(1) Economic Value of Reductions in Particulate Matter
As described in Section VIII, the standards will reduce emissions
of several criteria and toxic pollutants and their precursors. In this
analysis, EPA only estimates the economic value of the human health
benefits associated with the resulting reductions in PM2.5
exposure. Due to analytical limitations with the benefit per ton
method, this analysis does not estimate benefits resulting from
reductions in population exposure to other criteria pollutants such as
ozone.\852\ Furthermore, the
[[Page 73884]]
benefits per-ton method, like all air quality impact analyses, does not
monetize all of the potential health and welfare effects associated
with reduced concentrations of PM2.5.
---------------------------------------------------------------------------
\852\ The air quality modeling that underlies the PM-related
benefit per ton values also produced estimates of ozone levels
attributable to each sector. However, the complex non-linear
chemistry governing ozone formation prevented EPA from developing a
complementary array of ozone benefit per ton values. This limitation
notwithstanding, we anticipate that the ozone-related benefits
associated with reducing emissions of NOX and VOC are
substantial. Refer to RIA Appendix 8.A for the ozone benefits
results from the supplemental CY benefits analysis.
---------------------------------------------------------------------------
This analysis uses estimates of the benefits from reducing the
incidence of the specific PM2.5-related health impacts
described below. These estimates, which are expressed per ton of
PM2.5-related emissions eliminated by the final program,
represent the monetized value of human health benefits (including
reductions in both premature mortality and premature morbidity) from
reducing each ton of directly emitted PM2.5 or its
precursors (SO2 and NOX), from a specified
source. Ideally, the human health benefits would be estimated based on
changes in ambient PM2.5 as determined by full-scale air
quality modeling. However, the length of time needed to prepare the
necessary emissions inventories, in addition to the processing time
associated with the modeling itself, has precluded us from performing
air quality modeling that reflects the emissions and air quality
impacts associated with the final program.
EPA received comment regarding the omission of ozone-related
benefits from the non-GHG benefits analysis included in the proposal.
EPA agrees that total benefits are underestimated when ozone-related
benefits are not included in the primary analysis. However, for reasons
described in the introduction to this section, PM- and ozone-related
health benefits based on air quality modeling for the CY analysis are
not included in the primary estimate of costs and benefits. Instead,
they can be found as a supplemental analysis to the RIA in Appendix 8A.
The PM-related dollar-per-ton benefit estimates used in this
analysis are provided in Table IX-17. As the table indicates, these
values differ among pollutants, and also depend on their original
source, because emissions from different sources can result in
different degrees of population exposure and resulting health impacts.
In the summary of costs and benefits, Section IX.K of this Preamble,
EPA presents the monetized value of PM-related improvements associated
with the final program.
Table IX-17--PM-Related Benefits-per-Ton Values
[Thousands, 2013$] a
--------------------------------------------------------------------------------------------------------------------------------------------------------
On-road mobile sources Upstream sources \d\
Year \c\ -----------------------------------------------------------------------------------------------
Direct PM2.5 SO[ihel2] NOX Direct PM2.5 SO[ihel2] NOX
--------------------------------------------------------------------------------------------------------------------------------------------------------
Estimated Using a 3 Percent Discount Rate \b\
--------------------------------------------------------------------------------------------------------------------------------------------------------
2016.................................................... $380-$870 $20-$46 $7.8-$18 $330-$760 $71-$160 $6.9-$16
2020.................................................... 410-920 22-50 8.2-18 350-800 76-170 7.5-17
2025.................................................... 450-1,000 25-56 9.0-20 400-890 84-190 8.2-18
2030.................................................... 490-1,100 28-62 9.7-22 430-960 92-200 8.9-20
--------------------------------------------------------------------------------------------------------------------------------------------------------
Estimated Using a 7 Percent Discount Rate \b\
--------------------------------------------------------------------------------------------------------------------------------------------------------
2016.................................................... $340-$780 $18-$42 $7.1-$16 $300-$680 $64-$140 $6.3-$14
2020.................................................... 370-830 20-45 7.5-17 320-730 68-150 6.7-15
2025.................................................... 410-920 22-50 8.1-18 350-800 76-170 7.4-17
2030.................................................... 440-990 25-56 8.8-20 380-870 82-180 8.0-18
--------------------------------------------------------------------------------------------------------------------------------------------------------
Notes:
\a\ The benefit-per-ton estimates presented in this table are based on a range of premature mortality estimates derived from the ACS study (Krewski et
al., 2009) and the Six-Cities study (Lepeule et al., 2012). See Chapter VIII of the RIA for a description of these studies.
\b\ The benefit-per-ton estimates presented in this table assume either a 3 percent or 7 percent discount rate in the valuation of premature mortality
to account for a twenty-year segmented premature mortality cessation lag.
\c\ Benefit-per-ton values were estimated for the years 2016, 2020, 2025 and 2030. We hold values constant for intervening years (e.g., the 2016 values
are assumed to apply to years 2017-2019; 2020 values for years 2021-2024; 2030 values for years 2031 and beyond).
\d\ We assume for the purpose of this analysis that total ``upstream emissions'' are most appropriately monetized using the refinery sector benefit per-
ton values. The majority of upstream emission reductions associated with the final rule are related to domestic onsite refinery emissions and domestic
crude production. While total upstream emissions also include storage and transport sources, as well as sources upstream from the refinery, we have
chosen to simply apply the refinery values.
The benefit-per-ton technique has been used in previous analyses,
including EPA's 2017-2025 Light-Duty Vehicle Greenhouse Gas Rule,\853\
the Reciprocating Internal Combustion Engine rules,854 855
and the Residential Wood Heaters NSPS.\856\ Table IX-18 shows the
quantified PM2.5-related co-benefits captured in those
benefit per-ton estimates, as well as unquantified effects the benefit
per-ton estimates are unable to capture.
---------------------------------------------------------------------------
\853\ U.S. Environmental Protection Agency (U.S. EPA). (2012).
Regulatory Impact Analysis: Final Rulemaking for 2017-2025 Light-
Duty Vehicle Greenhouse Gas Emission Standards and Corporate Average
Fuel Economy Standards, Assessment and Standards Division, Office of
Transportation and Air Quality, EPA-420-R-12-016, August 2012.
Available on the Internet at: http://www3.epa.gov/otaq/climate/documents/420r12016.pdf.
\854\ U.S. Environmental Protection Agency (U.S. EPA). (2013).
Regulatory Impact Analysis for the Reconsideration of the Existing
Stationary Compression Ignition (CI) Engines NESHAP, Office of Air
Quality Planning and Standards, Research Triangle Park, NC. January.
EPA-452/R-13-001. Available at http://www3.epa.gov/ttnecas1/regdata/RIAs/RICE_NESHAPreconsideration_Compression_Ignition_Engines_RIA_final2013_EPA.pdf.
\855\ U.S. Environmental Protection Agency (U.S. EPA). (2013).
Regulatory Impact Analysis for Reconsideration of Existing
Stationary Spark Ignition (SI) RICE NESHAP, Office of Air Quality
Planning and Standards, Research Triangle Park, NC. January. EPA-
452/R-13-002. Available at http://www3.epa.gov/ttnecas1/regdata/RIAs/NESHAP_RICE_Spark_Ignition_RIA_finalreconsideration2013_EPA.pdf.
\856\ U.S. Environmental Protection Agency (U.S. EPA). (2015).
Regulatory Impact Analysis for Residential Wood Heaters NSPS
Revision. Office of Air Quality Planning and Standards, Research
Triangle Park, NC. February. EPA-452/R-15-001. Available at http://www2.epa.gov/sites/production/files/2015-02/documents/20150204-residential-wood-heaters-ria.pdf.
[[Page 73885]]
Table IX-18--Human Health and Welfare Effects of PM2.5
----------------------------------------------------------------------------------------------------------------
Quantified and monetized in primary
Pollutant/ effect estimates Unquantified effects changes in:
----------------------------------------------------------------------------------------------------------------
PM2.5...................... Adult premature mortality................ Chronic and subchronic bronchitis cases.
Acute bronchitis......................... Strokes and cerebrovascular disease.
Hospital Admissions: Respiratory and Low birth weight.
cardiovascular.
Emergency room visits for asthma......... Pulmonary function.
Nonfatal heart attacks (myocardial Chronic respiratory diseases other than
infarction). chronic bronchitis.
Lower and upper respiratory illness...... Non-asthma respiratory emergency room
visits.
Minor restricted-activity days........... Visibility.
Work loss days........................... Household soiling.
Asthma exacerbations (asthmatic
population).
Infant mortality.........................
----------------------------------------------------------------------------------------------------------------
A more detailed description of the benefit-per-ton estimates is
provided in Chapter 8 of the RIA that accompanies this rulemaking.
Readers interested in reviewing the complete methodology for creating
the benefit-per-ton estimates used in this analysis can consult EPA's
``Technical Support Document: Estimating the Benefit per Ton of
Reducing PM2.5 Precursors from 17 Sectors.'' \857\ Readers
can also refer to Fann et al. (2012) \858\ for a detailed description
of the benefit-per-ton methodology.
---------------------------------------------------------------------------
\857\ For more information regarding the updated values, see:
http://www3.epa.gov/airquality/benmap/models/Source_Apportionment_BPT_TSD_1_31_13.pdf (accessed September 9,
2014).
\858\ Fann, N., Baker, K.R., and Fulcher, C.M. (2012).
Characterizing the PM2.5-related health benefits of emission
reductions for 17 industrial, area and mobile emission sectors
across the U.S., Environment International, 49, 241-151, published
online September 28, 2012.
---------------------------------------------------------------------------
As Table IX-17 indicates, EPA projects that the per-ton values for
reducing emissions of non-GHG pollutants from both vehicle use and
upstream sources such as fuel refineries will increase over time.\859\
These projected increases reflect rising income levels, which increase
affected individuals' willingness to pay for reduced exposure to health
threats from air pollution.\860\ They also reflect future population
growth and increased life expectancy, which expands the size of the
population exposed to air pollution in both urban and rural areas,
especially among older age groups with the highest mortality risk.\861\
---------------------------------------------------------------------------
\859\ As we discuss in the emissions chapter of the RIA (Chapter
V), the rule will yield emission reductions from upstream refining
and fuel distribution due to decreased petroleum consumption.
\860\ The issue is discussed in more detail in the 2012 p.m.
NAAQS RIA. See U.S. Environmental Protection Agency. (2012).
Regulatory Impact Analysis for the Final Revisions to the National
Ambient Air Quality Standards for Particulate Matter, Health and
Environmental Impacts Division, Office of Air Quality Planning and
Standards, EPA-452-R-12-005, December 2012. Available on the
internet: http://www3.epa.gov/ttnecas1/regdata/RIAs/finalria.pdf.
\861\ For more information about EPA's population projections,
please refer to the following: http://www3.epa.gov/air/benmap/models/BenMAPManualAppendicesAugust2010.pdf (See Appendix K).
---------------------------------------------------------------------------
(2) Unquantified Health and Environmental Impacts
One commenter supported the inclusion of all quantifiable impacts
of reductions in non-GHG pollutants. Specifically, they suggested the
inclusion of ecosystem benefits from reduced non-GHG pollutants
including those to crops as well as consideration of the impacts on
toxic air contaminants such as diesel PM.
In addition to the PM-related co-pollutant health impacts EPA
quantifies in this analysis, EPA acknowledges that there are a number
of other health and human welfare endpoints that we are not able to
quantify or monetize because of current limitations in the methods or
available data. These impacts are associated with emissions of air
toxics (including benzene, 1,3-butadiene, formaldehyde, acetaldehyde,
acrolein, naphthalene and ethanol), ambient ozone, and ambient
PM2.5 exposures. Chapter 8 of the RIA lists these
unquantified health and environmental impacts. While there will be
impacts associated with air toxic pollutant emission changes that
result from the final standard, EPA will not attempt to monetize those
impacts. This is primarily because currently available tools and
methods to assess air toxics risk from mobile sources at the national
scale are not adequate for extrapolation to incidence estimations or
benefits assessment. The best suite of tools and methods currently
available for assessment at the national scale are those used in the
National-Scale Air Toxics Assessment (NATA). EPA's Science Advisory
Board specifically commented in their review of the 1996 NATA that
these tools were not yet ready for use in a national-scale benefits
analysis, because they did not consider the full distribution of
exposure and risk, or address sub-chronic health effects.\862\ While
EPA has since improved the tools, there remain critical limitations for
estimating incidence and assessing benefits of reducing mobile source
air toxics.\863\ EPA continues to work to address these limitations;
however, EPA does not have the methods and tools available for
national-scale application in time for the analysis of the final
rules.\864\
---------------------------------------------------------------------------
\862\ Science Advisory Board. 2001. NATA--Evaluating the
National-Scale Air Toxics Assessment for 1996--an SAB Advisory.
http://www3.epa.gov/ttn/atw/sab/sabrev.html.
\863\ Examples include gaps in toxicological data, uncertainties
in extrapolating results from high-dose animal experiments to
estimate human effects at lower does, limited ambient and personal
exposure monitoring data, and insufficient economic research to
support valuation of the health impacts often associated with
exposure to individual air toxics. See Gwinn et al., 2011. Meeting
Report: Estimating the Benefits of Reducing Hazardous Air
Pollutants--Summary of 2009 Workshop and Future Considerations.
Environ Health Perspectives, Jan 2011; 119(1): 125-130.
\864\ In April, 2009, EPA hosted a workshop on estimating the
benefits of reducing hazardous air pollutants. This workshop built
upon the work accomplished in the June 2000 in an earlier (2000)
Science Advisory Board/EPA Workshop on the Benefits of Reductions in
Exposure to Hazardous Air Pollutants, which generated thoughtful
discussion on approaches to estimating human health benefits from
reductions in air toxics exposure, but no consensus was reached on
methods that could be implemented in the near term for a broad
selection of air toxics. Please visit http://epa.gov/air/toxicair/2009workshop.html for more information about the workshop and its
associated materials.
---------------------------------------------------------------------------
I. Energy Security Impacts
The Phase 2 standards are designed to require improvements in the
fuel efficiency of medium- and heavy-duty vehicles and, thereby, reduce
fuel consumption and GHG emissions. In turn, the Phase 2 standards help
to reduce U.S. petroleum imports. A reduction of U.S. petroleum imports
reduces both financial and strategic risks caused by potential sudden
disruptions in the supply of imported petroleum to the U.S., thus
increasing
[[Page 73886]]
U.S. energy security. This section summarizes the agency's estimates of
U.S. oil import reductions and energy security benefits of the Phase 2
final standards. Additional discussion of this issue can be found in
Chapter 8.8 of the RIA.
(1) Implications of Reduced Petroleum Use on U.S. Imports
U.S. energy security is generally considered as the continued
availability of energy sources at an acceptable price. Most discussion
of U.S. energy security revolves around the topic of the economic costs
of U.S. dependence on oil imports. While the U.S. has reduced its
consumption and increased its production of oil in recent years, it
still relies on oil from potentially unstable sources. In addition, oil
exporters with a large share of global production have the ability to
raise the price of oil by exerting the monopoly power associated with a
cartel, the Organization of Petroleum Exporting Countries (OPEC), to
restrict oil supply relative to demand. These factors contribute to the
vulnerability of the U.S. economy to episodic oil supply shocks and
price spikes.
In 2014, U.S. expenditures for imports of crude oil and petroleum
products, net of revenues for exports, were $178 billion and
expenditures on both imported oil and domestic petroleum and refined
products totaled $469 billion (in 2013$) (see Figure IX-1).\865\
Recently, as a result of strong growth in domestic oil production
mainly from tight shale formations, U.S. production of oil has
increased while U.S. oil imports have decreased. For example, from 2012
to 2015, domestic oil production increased by 44 percent while net oil
imports and products decreased by 38 percent. While U.S. oil import
costs have declined since 2011, total oil expenditures (domestic and
imported) remained near historical highs through 2014. Post-2015 oil
expenditures are projected (AEO 2015) to remain between double and
triple the inflation-adjusted levels experienced by the U.S. from 1986
to 2002.C
---------------------------------------------------------------------------
\865\ See EIA Annual Energy Review, various editions. For data
2011-2013, and projected data: EIA Annual Energy Outlook (AEO) 2014
(Reference Case). See Table 11, file ``aeotab_11.xls.''
---------------------------------------------------------------------------
Focusing on changes in oil import levels as a source of
vulnerability has been standard practice in assessing energy security
in the past, but given current market trends both from domestic and
international levels, adding changes in consumption of petroleum to
this assessment may provide better information about U.S. energy
security. The major mechanism through which the economy sustains harm
due to fluctuations in the (world) energy market is through price,
which itself is leveraged through both imports and consumption.
However, the United States, may be increasingly insulated from the
physical effects of overseas oil disruptions, though the price impacts
of an oil disruption anywhere will continue to be transmitted to U.S.
markets. As of 2015, Canada accounted for 63 percent of U.S. net oil
imports of crude oil and petroleum products. The implications of the
U.S. becoming a significant petroleum producer have yet to be discerned
in the literature, but it can be anticipated that this will have some
impact on energy security.
In 2010, just over 40 percent of world oil supply came from OPEC
nations. The AEO 2015 projects that this share will stay high; dipping
slightly from 37 percent by 2020 and then rising gradually to over 40
percent by 2035 and thereafter. Approximately 30 percent of global
supply is from Middle East and North African countries alone, a share
that is also expected to grow. Measured in terms of the share of world
oil resources or the share of global oil export supply, rather than oil
production, the concentration of global petroleum resources in OPEC
nations is even larger. As another measure of concentration, of the 137
countries/principalities that export either crude or refined products,
the top 12 have recently accounted for over 55 percent of exports.\866\
Eight of these countries are members of OPEC, and a ninth is
Russia.\867\ In a market where even a 1-2 percent supply loss can raise
prices noticeably, and where a 10 percent supply loss could lead to an
unprecedented price shock, this regional concentration is of
concern.\868\ Historically, the countries of the Middle East have been
the source of eight of the ten major world oil disruptions,\869\ with
the ninth originating in Venezuela, an OPEC country, and the tenth
being Hurricanes Katrina and Rita.
---------------------------------------------------------------------------
\866\ Based on data from the CIA, combining various recent
years, https://www.cia.gov/library/publications/the-world-factbook/rankorder/2242rank.html.
\867\ The other three are Norway, Canada, and the EU, an
exporter of product.
\868\ For example, the 2005 Hurricanes Katrina/Rita and the 2011
Libyan conflict both led to a 1.8 percent reduction in global crude
supply. While the price impact of the latter is not easily
distinguished given the rapidly rising post-recession prices, the
former event was associated with a 10-15 percent world oil price
increase. There are a range of smaller events with smaller but
noticeable impacts. Somewhat larger events, such as the 2002/3
Venezuelan Strike and the War in Iraq, corresponded to about a 2.9
percent sustained loss of supply, and were associated with a 28
percent world oil price increase.
Compiled from EIA oil price data, IEA2012 [IEA Response System
for Oil Supply Emergencies (http://www.iea.org/publications/freepublications/publication/EPPD_Brochure_English_2012_02.pdf)
See table on P. 11.and Hamilton 2011 ``Historical Oil
Shocks,''(http://econweb.ucsd.edu/~jhamilto/oil_history.pdf) in
*Routledge Handbook of Major Events in Economic History*, pp. 239-
265, edited by Randall E. Parker and Robert Whaples, New York:
Routledge Taylor and Francis Group, 2013). Available in bookstores.
\869\ IEA 2011 ``IEA Response System for Oil Supply
Emergencies.''
\870\ For historical data: EIA Annual Energy Review, various
editions. For data 2011-2013, and projected data: EIA Annual Energy
Outlook (AEO) 2014 (Reference Case). See Table 11, file
``aeotab_11.xls.''
---------------------------------------------------------------------------
[[Page 73887]]
[GRAPHIC] [TIFF OMITTED] TR25OC16.037
The agencies used EPA's MOVES model to estimate the reductions in
U.S. fuel consumption due to these final rules for vocational vehicles
and tractors. For HD pickups and vans, the agencies used both DOT's
CAFE model and EPA's MOVES model to estimate the fuel consumption
impacts. (Detailed explanations of the MOVES and CAFE models can be
found in Chapter 5 of the RIA. See IX.C of the Preamble for estimates
of reduced fuel consumption from these final rules). Based on a
detailed analysis of differences in U.S. fuel consumption, petroleum
imports, and imports of petroleum products, the agencies estimate that
approximately 90 percent of the reduction in fuel consumption resulting
from adopting improved GHG emission and fuel efficiency standards is
likely to be reflected in reduced U.S. imports of crude oil and net
imported petroleum products.\871\ Thus, on balance, each gallon of fuel
saved as a consequence of the HD GHG and fuel efficiency standards is
anticipated to reduce total U.S. imports of petroleum by 0.90 gallons.
Based upon the fuel savings estimated by the MOVES/CAFE models and the
90 percent oil import factor, the reduction in U.S. oil imports and
exports from these final rules are estimated for the years 2020, 2025,
2030, 2040, and 2050 (in millions of barrels per day (MMBD)) in Table
IX-19 below. For comparison purposes, Table IX-19 also shows U.S.
imports of crude oil in 2020, 2025, 2030 and 2040 as projected by DOE
in the Annual Energy Outlook 2015 Reference Case. U.S. Gross Domestic
Product (GDP) is projected to grow by roughly 48 percent over the same
time frame (e.g., from 2020 to 2040) in the AEO 2015 projections.
---------------------------------------------------------------------------
\871\ We looked at changes in U.S. crude oil imports and net
petroleum products in the AEO 2015 Reference Case in comparison the
Low (i.e., Economic Growth) Demand Case to undertake this analysis.
See the spreadsheet ``Impact of Fuel Demand on Imports
AEO2015.xlsx.'' We also considered a paper entitled ``Effect of a
U.S. Demand Reduction on Imports and Domestic Supply Levels'' by
Leiby, P., 4/16/2013. This paper suggests that ``Given a particular
reduction in oil demand stemming from a policy or significant
technology change, the fraction of oil use savings that shows up as
reduced U.S. imports, rather than reduced U.S. supply, is actually
quite close to 90 percent, and probably close to 95 percent.''
Table IX-19--Projected U.S. Imports and Exports of Oil and U.S. Oil Import Reductions Resulting From the Final
Phase 2 Program in 2020, 2025, 2030, 2040 and 2050 Using Method B and Relative to a Flat Baseline
[Millions of barrels per day (MMBD)] \a\
----------------------------------------------------------------------------------------------------------------
U.S. oil
U.S. net U.S. net import
Year U.S. oil U.S. oil product crude & reductions
exports imports imports * product from final HD
imports Rules
----------------------------------------------------------------------------------------------------------------
2020............................ 0.63 6.14 -2.80 2.71 0.007
2025............................ 0.63 6.72 -3.24 2.85 0.162
2030............................ 0.63 7.07 -3.56 2.88 0.405
2040............................ 0.63 8.21 -4.26 3.32 0.721
[[Page 73888]]
2050............................ (**) (**) (**) (**) 0.861
----------------------------------------------------------------------------------------------------------------
Notes:
* Negative U.S. Net Product Imports imply positive exports.
** The AEO 2015 only projects energy market and economic trends through 2040.
(2) Energy Security Implications
In order to understand the energy security implications of reducing
U.S. oil imports, EPA has worked with Oak Ridge National Laboratory
(ORNL), which has developed approaches for evaluating the social costs
and energy security implications of oil use. The energy security
estimates provided below are based upon a methodology developed in a
peer-reviewed study entitled, ``The Energy Security Benefits of Reduced
Oil Use, 2006-2015'', completed in March 2008. This ORNL study is an
updated version of the approach used for estimating the energy security
benefits of U.S. oil import reductions developed in a 1997 ORNL
Report.\872\ For EPA and NHTSA rulemakings, the ORNL methodology is
updated periodically to account for forecasts of future energy market
and economic trends reported in the U.S. Energy Information
Administration's Annual Energy Outlook.
---------------------------------------------------------------------------
\872\ Leiby, Paul N., Donald W. Jones, T. Randall Curlee, and
Russell Lee, Oil Imports: An Assessment of Benefits and Costs, ORNL-
6851, Oak Ridge National Laboratory, November, 1997.
---------------------------------------------------------------------------
When conducting this analysis, ORNL considered the full cost of
importing petroleum into the U.S. The full economic cost is defined to
include two components in addition to the purchase price of petroleum
itself. These are: (1) The higher costs for oil imports resulting from
the effect of U.S. demand on the world oil price (i.e., the ``demand''
or ``monopsony'' costs); and (2) the risk of reductions in U.S.
economic output and disruption to the U.S. economy caused by sudden
disruptions in the supply of imported oil to the U.S. (i.e.,
macroeconomic disruption/adjustment costs).
The literature on energy security for the last two decades has
routinely combined the monopsony and the macroeconomic disruption
components when calculating the total value of the energy security
premium. However, in the context of using a global value for the Social
Cost of Carbon (SCC) the question arises: how should the energy
security premium be used when some benefits from these rules, such as
the benefits of reducing greenhouse gas emissions, are calculated from
a global perspective? Monopsony benefits represent avoided payments by
U.S. consumers to oil producers that result from a decrease in the
world oil price as the U.S. decreases its demand for oil. Although
there is clearly an overall benefit to the U.S. when considered from a
domestic perspective, the decrease in price due to decreased demand in
the U.S. also represents a loss to oil producing countries, one of
which is the U.S. Given the redistributive nature of this monopsony
effect from a global perspective, it is excluded in the energy security
benefits calculations for these final rules.
In contrast, the other portion of the energy security premium, the
avoided U.S. macroeconomic disruption and adjustment cost that arises
from reductions in U.S. petroleum imports, does not have offsetting
impacts outside of the U.S., and, thus, is included in the energy
security benefits estimated for these final rules. To summarize, the
agencies have included only the avoided macroeconomic disruption
portion of the energy security benefits to estimate the monetary value
of the total energy security benefits of these final rules.
For this rulemaking, ORNL updated the energy security premiums by
incorporating the most recent oil price forecast and energy market
trends, particularly regional oil supplies and demands, from the AEO
2015 into its model.\873\ ORNL developed energy security premium
estimates for a number of different years. Table IX-20 provides
estimates for energy security premiums for the years 2020, 2025, 2030
and 2040,\874\ as well as a breakdown of the components of the energy
security premiums for each year. The components of the energy security
premiums and their values are discussed below.
---------------------------------------------------------------------------
\873\ Leiby, P., Factors Influencing Estimate of Energy Security
Premium for Heavy-Duty Phase 2 Final Rule, 11/1/2014, Oak Ridge
National Laboratory.
\874\ AEO 2015 forecasts energy market trends and values only to
2040. The post-2040 energy security premium values are assumed to be
equal to the 2040 estimate.
Table IX-20--Energy Security Premiums in 2020, 2025, 2030 and 2040
[2013$/Barrel] *
----------------------------------------------------------------------------------------------------------------
Avoided macroeconomic
Year (range) Monopsony (range) disruption/adjustment Total mid-point
costs (range) (range)
----------------------------------------------------------------------------------------------------------------
2020................................. $2.21 ($0.65-$3.59).... $5.48 ($2.51-$8.92).... $7.69 ($4.54-$11.14)
2025................................. $2.59 ($0.76-$4.14).... $6.30 ($2.92-$10.22)... $8.89 ($5.22-$12.83)
2030................................. $2.83 (0.83-$4.56)..... $7.26 ($3.40-$11.73)... $10.09 ($5.90-$14.59)
[[Page 73889]]
2040................................. $4.09 ($1.19-$6.67).... $9.61 ($4.54-$15.39)... $13.69 ($8.12-$19.64)
----------------------------------------------------------------------------------------------------------------
Note:
* Top values in each cell are the midpoints, the values in parentheses are the 90 percent confidence intervals.
(a) Effect of Oil Use on the Long-Run Oil Price
The first component of the full economic costs of importing
petroleum into the U.S. follows from the effect of U.S. import demand
on the world oil price over the long-run. Because the U.S. is a
sufficiently large purchaser of global oil supplies, its purchases can
affect the world oil price. This monopsony power means that increases
in U.S. petroleum demand can cause the world price of crude oil to
rise, and conversely, that reduced U.S. petroleum demand can reduce the
world price of crude oil. Thus, one benefit of decreasing U.S. oil
purchases, due to improvements in the fuel efficiency of medium- and
heavy-duty vehicles, is the potential decrease in the crude oil price
paid for all crude oil purchased.
There is disagreement in the literature about the magnitude of the
monopsony component, and its relevance for policy analysis. Brown and
Huntington (2013) \875\ for example, argue that the United States'
refusal to exercise its market power to reduce the world oil price does
not represent a proper externality, and that the monopsony component
should not be considered in calculations of the energy security
externality. However, they also note in their earlier discussion paper
(Brown and Huntington 2010) \876\ that this is a departure from the
traditional energy security literature, which includes sustained wealth
transfers associated with stable but higher-price oil markets. On the
other hand, Greene (2010) \877\ and others in prior literature (e.g.,
Toman 1993) \878\ have emphasized that the monopsony cost component is
policy-relevant because the world oil market is non-competitive and
strongly influenced by cartelized and government-controlled supply
decisions. Thus, while sometimes couched as an externality, Greene
notes that the monopsony component is best viewed as stemming from a
completely different market failure than an externality (Ledyard
2008),\879\ yet still implying marginal social costs to importers.
---------------------------------------------------------------------------
\875\ Brown, Stephen P.A. and Hillard G. Huntington. 2013.
Assessing the U.S. Oil Security Premium. Energy Economics, vol. 38,
pp 118-127.
\876\ Reassessing the Oil Security Premium. RFF Discussion Paper
Series, (RFF DP 10-05). doi: RFF DP 10-05
\877\ Greene, D. L. 2010. Measuring energy security: Can the
United States achieve oil independence?, Energy Policy, 38(4), 1614-
1621. doi:10.1016/j.enpol.2009.01.041.
\878\ Toman, M., 1993, The economics of energy security: theory,
evidence and policy, Chapter 25, Handbook of Natural Resources and
Energy Economics, Volume 3, pp. 1167-1218.
\879\ Ledyard, John O. ``Market Failure.'' The New Palgrave
Dictionary of Economics. Second Edition. Eds. Steven N. Durlauf and
Lawrence E. Blume. Palgrave Macmillan, 2008.
---------------------------------------------------------------------------
Recently, the Council on Foreign Relations (i.e., ``the Council'')
(2015) released a discussion paper that assesses NHTSA's analysis of
the benefits and costs of CAFE in a lower-oil-price world.\880\ In this
paper, the Council notes that while NHTSA cites the monopsony effect of
the CAFE standards for 2017-2025, NHTSA does not include it when
calculating the cost-benefit calculation for the rule. The Council
argues that the monopsony benefit should be included in the CAFE cost-
benefit analysis and that including the monopsony benefit is more
consistent with the legislators' intent in mandating CAFE standards in
the first place.
---------------------------------------------------------------------------
\880\ Council on Foreign Relations, ``Automobile Fuel Economy
Standards in a Lower-Oil-Price World,'' Sivarm & Levi, November
2015.
---------------------------------------------------------------------------
The recent National Academy of Science (NAS 2015) Report, ``Cost,
Effectiveness and the Deployment of Fuel Economy Technologies for
Light-Duty Vehicles,'' \881\ suggests that the agencies' logic about
not accounting for monopsony benefits is inaccurate. According to the
NAS, the fallacy lies in treating the two problems, oil dependence and
climate change, similarly. According to the NAS, ``Like national
defense, it [oil dependence] is inherently adversarial (i.e., oil
consumers against producers using monopoly power to raise prices). The
problem of climate change is inherently global and requires global
action. If each nation considered only the benefits to itself in
determining what actions to take to mitigate climate change, an
adequate solution could not be achieved. Likewise, if the U.S.
considers the economic harm its reduced petroleum use will do to
monopolistic oil producers it will not adequately address its oil
dependence problem. Thus, if the United States is to solve both of
these problems it must take full account of the costs and benefits of
each, using the appropriate scope for each problem.'' At this point in
time, we are continuing to exclude monopsony premiums for the cost
benefit analysis of these final rules, but we will be taking comment on
this issue in a near term future rulemaking.
---------------------------------------------------------------------------
\881\ Transitions to Alternative Vehicles and Fuels,'' Committee
on Transitions to Alternative Vehicles and Fuels, National Research
Council, 2013.
---------------------------------------------------------------------------
There is also a question about the ability of gradual, long-term
reductions, such as those resulting from these final rules, to reduce
the world oil price in the presence of OPEC's monopoly power. OPEC is
currently the world's marginal petroleum supplier, and could
conceivably respond to gradual reductions in U.S. demand with gradual
reductions in supply over the course of several years as the fuel
savings resulting from these rules grow. However, if OPEC opts for a
long-term strategy to preserve its market share, rather than maintain a
particular price level (as they have done recently in response to
increasing U.S. petroleum production), reduced demand will create
downward pressure on the global price. The Oak Ridge analysis assumes
that OPEC does respond to demand reductions over the long run, but
there is still a price effect in the model. Under the mid-case
behavioral assumption used in the premium calculations, OPEC responds
by gradually reducing supply to maintain market share (consistent with
the long-term self-interested strategy suggested by Gately (2004,
2007)).\882\
---------------------------------------------------------------------------
\882\ Gately, Dermot, 2004. ``OPEC's Incentives for Faster
Output Growth,'' The Energy Journal, 25 (2):75-96; Gately, Dermot,
2007. ``What Oil Export Levels Should We Expect From OPEC?'', The
Energy Journal, 28(2):151-173.
---------------------------------------------------------------------------
[[Page 73890]]
(b) Macroeconomic Disruption Adjustment Costs
The second component of the oil import premium, ``avoided
macroeconomic disruption/adjustment costs,'' arises from the effect of
oil imports on the expected cost of supply disruptions and accompanying
price increases. A sudden increase in oil prices triggered by a
disruption in world oil supplies has two main effects: (1) It increases
the costs of oil imports in the short-run and (2) it can lead to
macroeconomic contraction, dislocation and Gross Domestic Product (GDP)
losses. For example, ORNL estimates the combined value of these two
factors to be $6.30/barrel (2013$) when U.S. oil imports are reduced in
2025, with a range from $2.92/barrel to $10.22/barrel of imported oil
reduced.
Since future disruptions in foreign oil supplies are an uncertain
prospect, each of the disruption cost components must be weighted by
the probability that the supply of petroleum to the U.S. will actually
be disrupted. Thus, the ``expected value'' of these costs--the product
of the probability that a supply disruption will occur and the sum of
costs from reduced economic output and the economy's abrupt adjustment
to sharply higher petroleum prices--is the relevant measure of their
magnitude. Further, when assessing the energy security value of a
policy to reduce oil use, it is only the change in the expected costs
of disruption that results from the policy that is relevant. The
expected costs of disruption may change from lowering the normal (i.e.,
pre-disruption) level of domestic petroleum use and imports, from any
induced alteration in the likelihood or size of disruption, or from
altering the short-run flexibility (e.g., elasticity) of petroleum use.
By late 2015/early 2016, world oil prices were sharply lower than
in 2014. Future prices remain uncertain, but sustained markedly lower
oil prices can have mixed implications for U.S. energy security. Under
lower prices U.S. expenditures on oil consumption are lower, and they
are a less prominent component of the U.S. economy. This would lessen
the issue of imported oil as an energy security problem for the U.S. On
the other hand, sustained lower oil prices encourage greater oil
consumption, and reduce the competitiveness of new U.S. oil supplies
and alternative fuels. The AEO 2015 low oil price outlook, for example,
projects that by 2030 total U.S. petroleum supply would be 10 percent
lower and imports would be 78 percent higher than the AEO Reference
Case. Under the low-price case, 2030 prices are 35 percent lower, so
that import expenditures are 16 percent higher.
A second potential proposed energy security effect of lower oil
prices is increased instability of supply, due to greater global
reliance on fewer suppling nations,\883\ and because lower prices may
increase economic and geopolitical instability in some supplier
nations.884 885 886 The International Monetary Fund reported
that low oil prices are creating substantial economic tension in the
Middle East oil producers on top of the economic costs of ongoing
conflicts, and noted the risk that Middle East countries including
Saudi Arabia could run out of financial assets without substantial
change in policy.\887\ The concern raised is that oil revenues are
essential for some exporting nations to fund domestic programs and
avoid domestic unrest.
---------------------------------------------------------------------------
\883\ Fatih Birol, Executive Director of the International
Energy Agency, warns that prolonged lower oil prices would trigger
energy security concerns by increasing reliance on a small number of
low-cost producers ``or risk a sharp rebound in price if investment
falls short.'' ``It would be a grave mistake to index our attention
to energy security to changes in the oil price,'' Birol said. ``Now
is not the time to relax. Quite the opposite: a period of low oil
prices is the moment to reinforce our capacity to deal with future
energy security threats.'' Hussain, Y. (2015). ``Grave mistake'' to
be complacent on energy security, International Energy Agency warns.
Financial Post, (November 10). Retrieved from http://business.financialpost.com/news/energy/grave-mistake-to-be-complacent-on-energy-security-international-energy-agency-warns.
\884\ Batovic, A. (2015). Low oil prices fuel political and
economic instability. Global Risk Insights, 18-19. Retrieved from
http://globalriskinsights.com/2015/09/low-oil-prices-fuel-political-and-economic-instability/.
\885\ Monaldi, F. (2015). The Impact of the Decline in Oil
Prices on the Economics, Politics and Oil Industry of Venezuela.
Columbia Center on Global Energy Policy Discussion Papers,
(September). Retrieved from http://energypolicy.columbia.edu/sites/default/files/energy/Impact of the Decline in Oil Prices on
Venezuela, September 2015.pdf.
\886\ Even, S., & Guzansky, Y. (2015). Falling oil prices and
Saudi stability--Opinion. Jerusalem Post, (September 30). Retrieved
from http://www.jpost.com/Opinion/Falling-oil-prices-and-Saudi-stability-419534.
\887\ International Monetary Fund (IMF). (2015). IMF Regional
Economic Outlook--Middle East and Central Asia. Regional Economic
Outlook (Vol. 33). Tomkiw, L. (2015). Oil Rich Saudi Arabia Running
Out Of Assets? IMF Report Says It's Possible In Next 5 Years.
International Business Times, October 21, 19-22. Retrieved from
http://www.ibtimes.com/oil-rich-saudi-arabia-running-out-assets-imf-report-says-its-possible-next-5-years-215017.
---------------------------------------------------------------------------
The Competitive Enterprise Institute (CEI) and others argue that
there are little, if any, energy security benefits associated with
these rules. In large part CEI argues that oil supplies are plentiful
and that current oil prices are low so that reduced consumption of
petroleum products due to these rules would have no effect on energy
security. However, the discussion of current low oil prices (``lowest
Labor Day gasoline prices in a decade'') does not assure the absence of
future oil supply shocks or price shocks, or even speak to their
reduced likelihood. CEI points out that the current low oil prices have
been observed before as recently as a decade ago, as they have in more
than one instance before that. For example, oil prices were even lower
in 1999. But in the intervening periods, oil supply and price shocks
have continued to recur, and the recent price record only amplifies
oil's high historical price volatility.
Also, sharply lower world oil prices do not clearly imply greater
energy security for the U.S. Current low world oil prices may reduce
the U.S.'s fracking industry's tight oil production (as CEI points
out), or other sources of oil supplies around the world. Some have
hypothesized that reduction in oil production outside of OPEC may be
the objective of some OPEC producers. With low oil prices, U.S.' oil
import share over time might be larger, increasing the U.S.' dependence
on imported oil.
Securing America's Future Energy (SAFE), Operation Free and the
Investor Network on Climate Risk agree that these rules do improve
America's energy security. SAFE goes on to state that several policy
options should be included in these rules to further enhance energy
security. The agencies agree that these rules enhances America's energy
security, but do not have information to evaluate the policy options
that SAFE proposes.
The recent economics literature on whether oil shocks are the
threat to economic stability that they once were is mixed. Some of the
current literature asserts that the macroeconomic component of the
energy security externality is small. For example, the National
Research Council (2009) argued that the non-environmental externalities
associated with dependence on foreign oil are small, and potentially
trivial.\888\ Analyses by Nordhaus (2007) and Blanchard and Gali (2010)
question the impact of more recent oil price shocks on the
economy.\889\ They were motivated by
[[Page 73891]]
attempts to explain why the economy actually expanded immediately after
the last shocks, and why there was no evidence of higher energy prices
being passed on through higher wage inflation. Using different
methodologies, they conclude that the economy has largely gotten over
its concern with dramatic swings in oil prices.
---------------------------------------------------------------------------
\888\ National Research Council, 2009. Hidden Costs of Energy:
Unpriced Consequences of Energy Production and Use. National Academy
of Science, Washington, DC.
\889\ See, William Nordhaus, ``Who's Afraid of a Big Bad Oil
Shock?'', available at http://aida.econ.yale.edu/~nordhaus/homepage/
Big_Bad_Oil_Shock_Meeting.pdf, and Olivier Blanchard and Jordi Gali,
``The macroeconomic Effects of Oil price Shocks: Why are the 2000s
so different from the 1970s?'', pp. 373-421, in The International
Dimensions of Monetary Policy, Jordi Gali and Mark Gertler, editors,
University of Chicago Press, February 2010, available at http://www.nber.org/chapters/c0517.pdf.
---------------------------------------------------------------------------
One reason, according to Nordhaus, is that monetary policy has
become more accommodating to the price impacts of oil shocks. Another
is that consumers have simply decided that such movements are
temporary, and have noted that price impacts are not passed on as
inflation in other parts of the economy. He also notes that real
changes to productivity due to oil price increases are incredibly
modest, \890\ and that the general direction of the economy matters a
great deal regarding how the economy responds to a shock. Estimates of
the impact of a price shock on aggregate demand are insignificantly
different from zero.
---------------------------------------------------------------------------
\890\ In fact, ``. . . energy-price changes have no effect on
multifactor productivity and very little effect on labor
productivity.'' Page 19. He calculates the productivity effect of a
doubling of oil prices as a decrease of 0.11 percent for one year
and 0.04 percent a year for ten years. Page 5. (The doubling
reflects the historical experience of the post-war shocks, as
described in Table 7.1 in Blanchard and Gali, p. 380).
---------------------------------------------------------------------------
Blanchard and Gali (2010) contend that improvements in monetary
policy (as noted above), more flexible labor markets, and lessening of
energy intensity in the economy, combined with an absence of concurrent
shocks, all contributed to lessen the impact of oil shocks after 1980.
They find ``. . . the effects of oil price shocks have changed over
time, with steadily smaller effects on prices and wages, as well as on
output and employment.'' \891\ In a comment at the chapter's end, this
work is summarized as follows: ``The message of this chapter is thus
optimistic in that it suggests a transformation in U.S. institutions
has inoculated the economy against the responses that we saw in the
past.''
---------------------------------------------------------------------------
\891\ Blanchard and Gali, p. 414.
---------------------------------------------------------------------------
At the same time, the implications of the ``Shale Oil Revolution''
are now being felt in the international markets, with current prices at
four year lows. Analysts generally attribute this result in part to the
significant increase in supply resulting from U.S. production, which
has put liquid petroleum production roughly on par with Saudi Arabia.
The price decline is also attributed to the sustained reductions in
U.S. consumption and global demand growth from fuel efficiency policies
and previously high oil prices. The resulting decrease in foreign
imports, down to about one-third of domestic consumption (from 60
percent in 2005, for example \892\), effectively permits U.S. supply to
act as a buffer against artificial or other supply restrictions (the
latter due to conflict or a natural disaster, for example).
---------------------------------------------------------------------------
\892\ See, Oil price Drops on Oversupply, http://www.oil-price.net/en/articles/oil-price-drops-on-oversupply.php, 10/6/2014.
---------------------------------------------------------------------------
However, other papers suggest that oil shocks, particularly sudden
supply shocks, remain a concern. Both Blanchard and Gali's and Nordhaus
work were based on data and analysis through 2006, ending with a period
of strong global economic growth and growing global oil demand. The
Nordhaus work particularly stressed the effects of the price increase
from 2002-2006 that were comparatively gradual (about half the growth
rate of the 1973 event and one-third that of the 1990 event). The
Nordhaus study emphasizes the robustness of the U.S. economy during a
time period through 2006. This time period was just before rapid
further increases in the price of oil and other commodities with oil
prices more-than-doubling to over $130/barrel by mid-2008, only to drop
after the onset of the largest recession since the Great Depression.
Hamilton (2012) reviewed the empirical literature on oil shocks and
suggested that the results are mixed, noting that some work (e.g.
Rasmussen and Roitman (2011) finds less evidence for economic effects
of oil shocks, or declining effects of shocks (Blanchard and Gali
2010), while other work continues to find evidence regarding the
economic importance of oil shocks. For example, Baumeister and Peersman
(2011) found that an oil price increase had a decreasing effect over
time. But they note that with a declining price-elasticity of demand
that a given physical oil disruption would have a bigger effect on
price and a similar effect on output as in the earlier data.\893\
Hamilton observes that ``a negative effect of oil prices on real output
has also been reported for a number of other countries, particularly
when nonlinear functional forms have been employed''. Alternatively,
rather than a declining effect, Ramey and Vine (2010) \894\ found
``remarkable stability in the response of aggregate real variables to
oil shocks once we account for the extra costs imposed on the economy
in the 1970s by price controls and a complex system of entitlements
that led to some rationing and shortages.''
---------------------------------------------------------------------------
\893\ Hamilton, J. D. (2012). Oil Prices, Exhaustible Resources,
and Economic Growth. In Handbook of Energy and Climate Change.
Retrieved from http://econweb.ucsd.edu/~jhamilto/
handbook_climate.pdf.
\894\ Ramey, V. and Vine, D., 2010, ``Oil, Automobiles, and the
U.S. Economy: How Much have Things Really Changed?'' National Bureau
of Economic Research Working Papers, WP 16067. Retrieved from http://www.nber.org/papers/w16067.pdf [EPA-HQ-OAR-2014-0827-0601].
---------------------------------------------------------------------------
Some of the recent literature on oil price shocks has emphasized
that economic impacts depend on the nature of the oil shock, with
differences between price increases caused by sudden supply loss and
those caused by rapidly growing demand. Most recent analyses of oil
price shocks have confirmed that ``demand-driven'' oil price shocks
have greater effects on oil prices and tend to have positive effects on
the economy while ``supply-driven'' oil shocks still have negative
economic impacts (Baumeister, Peersman and Van Robays (2010)).\895\ A
recent paper by Kilian and Vigfusson (2014), \896\ for example,
assigned a more prominent role to the effects of price increases that
are unusual, in the sense of being beyond range of recent experience.
Kilian and Vigfusson also conclude that the difference in response to
oil shocks may well stem from the different effects of demand- and
supply-based price increases: ``One explanation is that oil price
shocks are associated with a range of oil demand and oil supply shocks,
some of which stimulate the U.S. economy in the short run and some of
which slow down U.S. growth (see Kilian (2009)). How recessionary the
response to an oil price shock is thus depends on the average
composition of oil demand and oil supply shocks over the sample
period.''
---------------------------------------------------------------------------
\895\ Baumeister, C., Peersman, G., Van Robays, I., 2010, ``The
Economic Consequences of Oil Shocks: Differences across Countries
and Time'', Workshop and Conference on Inflation Challenges in the
Era of Relative Price Shocks.
\896\ Kilian, L., Vigfusson, R.J., 2014, ``The Role of Oil Price
Shocks in Causing U.S. Recessions'', Board of Governors of the
Federal Reserve System. International Finance Discussion Papers.
---------------------------------------------------------------------------
The general conclusion that oil supply-driven shocks reduce
economic output is also reached in a recently published paper by Cashin
et al. (2014) \897\ for 38 countries from 1979-2011. ``The results
indicate that the economic consequences of a supply-driven oil-price
shock are very different from those of an oil-demand shock
[[Page 73892]]
driven by global economic activity, and vary for oil-importing
countries compared to energy exporters,'' and ``oil importers
[including the U.S.] typically face a long-lived fall in economic
activity in response to a supply-driven surge in oil prices'' but
almost all countries see an increase in real output for an oil-demand
disturbance. Note that the energy security premium calculation in this
analysis is based on price shocks from potential future supply events
only.
---------------------------------------------------------------------------
\897\ Cashin, P., Mohaddes, K., Raissi, Maziar, and Raissi, M.,
2014, ``The differential effects of oil demand and supply shocks on
the global economy''. Energy Economics.
---------------------------------------------------------------------------
Finally, despite continuing uncertainty about oil market behavior
and outcomes and the sensitivity of the U.S. economy to oil shocks, it
is generally agreed that it is beneficial to reduce petroleum fuel
consumption from an energy security standpoint. It is not just imports
alone, but both imports and consumption of petroleum from all sources
and their role in economic activity, that may expose the U.S. to risk
from price shocks in the world oil price. Reducing fuel consumption
reduces the amount of domestic economic activity associated with a
commodity whose price depends on volatile international markets.
(c) Cost of Existing U.S. Energy Security Policies
The last often-identified component of the full economic costs of
U.S. oil imports are the costs to the U.S. taxpayers of existing U.S.
energy security policies. The two primary examples are maintaining the
Strategic Petroleum Reserve (SPR) and maintaining a military presence
to help secure a stable oil supply from potentially vulnerable regions
of the world. The SPR is the largest stockpile of government-owned
emergency crude oil in the world. Established in the aftermath of the
1973/1974 oil embargo, the SPR provides the U.S. with a response option
should a disruption in commercial oil supplies threaten the U.S.
economy. It also allows the U.S. to meet part of its International
Energy Agency obligation to maintain emergency oil stocks, and it
provides a national defense fuel reserve. While the costs for building
and maintaining the SPR are more clearly related to U.S. oil use and
imports, historically these costs have not varied in response to
changes in U.S. oil import levels. Thus, while the effect of the SPR in
moderating price shocks is factored into the ORNL analysis, the cost of
maintaining the SPR is excluded.
U.S. military costs are excluded from the analysis performed by
ORNL because their attribution to particular missions or activities is
difficult, and because it is not clear that these outlays would decline
in response to incremental reductions in U.S. oil imports. Most
military forces serve a broad range of security and foreign policy
objectives. The agencies also recognize that attempts to attribute some
share of U.S. military costs to oil imports are further challenged by
the need to estimate how those costs might vary with incremental
variations in U.S. oil imports.
In the proposal to these rules, the agencies solicited comments on
quantifying the military benefits from reduced U.S. imports of oil. The
California Air Resources Board (CARB) notes that the National Research
Council (NRC) \898\ attempted to estimate the military costs associated
with U.S. imports and consumption of petroleum. The NRC cited estimates
of the national defense costs of oil dependence from the literature
that range from less than $5 to $50 billion per year or more. Assuming
a range of approximate range of $10 to $50 billion per year, the NRC
divided national defense costs by a projected U.S. consumption rate of
approximately 6.4 billion barrels per year (EIA, 2012). This procedure
yielded a range of average national defense cost of $1.50-$8.00 per
barrel (rounded to the nearest $0.50), with a mid-point of $5/barrel
(in 2009$). The agencies acknowledge this NRC study, but have not
included the estimates as part of the cost-benefit analysis for these
rules.
---------------------------------------------------------------------------
\898\ National Research Council, ``Transitions to alternative
vehicles and fuels,'' 2013.
---------------------------------------------------------------------------
(3) Energy Security Benefits of This Program
Using the ORNL ``oil premium'' methodology, updating world oil
price values and energy trends using AEO 2015 and using the estimated
fuel savings from these final rules estimated from the MOVES/CAFE
models, the agencies have calculated the annual energy security
benefits of these final rules through 2050.\899\ Since the agencies are
taking a global perspective with respect to valuing greenhouse gas
benefits from the rules, only the avoided macroeconomic adjustment/
disruption portion of the energy security premium is used in the energy
security benefits estimates present below. These results are shown
below in Table IX-21. The agencies have also calculated the net present
value at 3 percent and 7 percent discount rates of model year lifetime
benefits associated with energy security; these values are presented in
Table IX-22.
---------------------------------------------------------------------------
\899\ In order to determine the energy security benefits beyond
2040, we use the 2040 energy security premium multiplied by the
estimate fuel savings from the final rule. Since the AEO 2015 only
goes to 2040, we only calculate energy security premiums to 2040.
Table IX-21--Annual U.S. Energy Security Benefits of the Final Program
and Net Present Values at 3% and 7% Discount Rates Using Method B and
Relative to a Flat Baseline for Final HDV Rules
[In Millions of 2013$] \a\
------------------------------------------------------------------------
Benefits
Year (2013$)
------------------------------------------------------------------------
2018......................................................... $4
2019......................................................... 9
2020......................................................... 14
2021......................................................... 55
2022......................................................... 109
2023......................................................... 171
2024......................................................... 268
2025......................................................... 372
2026......................................................... 482
2027......................................................... 627
2028......................................................... 775
2029......................................................... 923
2030......................................................... 1,074
2035......................................................... 1,847
2040......................................................... 2,533
2050......................................................... 3,025
NPV, 3%...................................................... 24,716
NPV, 7%...................................................... 10,050
------------------------------------------------------------------------
Table IX-22--Discounted Model Year Lifetime Energy Security Benefits Due
to the Final Program at 3% and 7% Discount Rates Using Method B and
Relative to a Flat Baseline for Final HDV Rules
[Millions of 2013$] \a\
------------------------------------------------------------------------
3% 7%
Calendar year Discount Discount
rate rate
------------------------------------------------------------------------
2018.............................................. $30 $21
2019.............................................. 29 20
2020.............................................. 28 18
2021.............................................. 485 294
2022.............................................. 520 304
2023.............................................. 552 311
2024.............................................. 849 461
2025.............................................. 886 464
2026.............................................. 917 463
2027.............................................. 1,183 577
2028.............................................. 1,182 555
2029.............................................. 1,184 536
------------------------------------------------------------------------
Sum........................................... 7,844 4,026
------------------------------------------------------------------------
J. Other Impacts
(1) Costs of Noise, Congestion and Crashes Associated With Additional
(Rebound) Driving
Although it provides benefits to drivers as described above,
increased vehicle use associated with the rebound effect also
contributes to increased
[[Page 73893]]
traffic congestion, motor vehicle crashes, and highway noise. Depending
on how the additional travel is distributed over the day and where it
takes place, additional vehicle use can contribute to traffic
congestion and delays by increasing the number of vehicles using
facilities that are already heavily traveled. These added delays impose
higher costs on drivers and other vehicle occupants in the form of
increased travel time and operating expenses. At the same time, this
additional travel also increases costs associated with traffic crashes
and vehicle noise.
The agencies estimate these costs using the same methodology as
used in the two light-duty and the HD Phase 1 rule analyses, which
relies on estimates of congestion, crash, and noise costs imposed by
automobiles and light trucks developed by the Federal Highway
Administration to estimate these increased external costs caused by
added driving.\900\ We provide the details behind the estimates in
Chapter 8.7 of the RIA. Table IX-23 presents the estimated annual
impacts associated with crash, congestion and noise along with net
present values at both 3 percent and 7 percent discount rates. Table
IX-24 presents the estimated discounted model year lifetime impacts
associated with crashes, congestion and noise. The methodology used in
this final rule is the same as that used in the proposal, except that
costs were updated to 2013 dollars.
---------------------------------------------------------------------------
\900\ These estimates were developed by FHWA for use in its 1997
Federal Highway Cost Allocation Study; http://www.fhwa.dot.gov/policy/hcas/final/index.htm (last accessed July 8, 2012).
Table IX-23--Annual Costs Associated With Crashes, Congestion and Noise
and Net Present Values at 3% and 7% Discount Rates Using Method B and
Relative to the Flat Baseline
[Millions of 2013$] \a\
------------------------------------------------------------------------
Costs of
crashes,
Calendar year congestion,
and noise
------------------------------------------------------------------------
2018...................................................... $0
2019...................................................... 0
2020...................................................... 0
2021...................................................... 99
2022...................................................... 139
2023...................................................... 178
2024...................................................... 216
2025...................................................... 252
2026...................................................... 285
2027...................................................... 317
2028...................................................... 345
2029...................................................... 372
2030...................................................... 396
2035...................................................... 487
2040...................................................... 541
2050...................................................... 604
NPV, 3%................................................... 6,755
NPV, 7%................................................... 3,070
------------------------------------------------------------------------
Note:
\a\ For an explanation of analytical Methods A and B, please see Section
I.D; for an explanation of the flat baseline, 1a, and dynamic
baseline, 1b, please see Section X.A.1.
Table IX-24--Discounted Model Year Lifetime Costs of Crashes, Congestion
and Noise at 3% and 7% Discount Rates Using Method B and Relative to the
Flat Baseline
[Millions of 2013$] \a\
------------------------------------------------------------------------
3% 7%
Calendar year discount Discount
rate rate
------------------------------------------------------------------------
2018.............................................. $124 $80
2019.............................................. 140 89
2020.............................................. 158 100
2021.............................................. 343 215
2022.............................................. 333 201
2023.............................................. 323 187
2024.............................................. 319 178
2025.............................................. 313 168
2026.............................................. 305 158
2027.............................................. 297 148
2028.............................................. 289 139
2029.............................................. 283 131
---------------------
Sum........................................... 3,227 1,793
------------------------------------------------------------------------
Note:
\a\ For an explanation of analytical Methods A and B, please see Section
I.D; for an explanation of the flat baseline, 1a, and dynamic
baseline, 1b, please see Section X.A.1.
(2) Benefits Associated With Reduced Refueling Time
By reducing the frequency with which drivers typically refuel their
vehicles and by extending the upper limit of the range that can be
traveled before requiring refueling (i.e., future fuel tank sizes
remain constant), savings will be realized associated with less time
spent refueling vehicles. Alternatively, refill intervals may remain
the same (i.e., future fuel tank sizes get smaller), resulting in the
same number of refills as today but less time spent per refill because
there will be less fuel to refill. The agencies have estimated this
impact using the former approach--by assuming that future tank sizes
remain constant.
The savings in refueling time are calculated as the total amount of
time the driver of a typical truck in each class will save each year as
a consequence of pumping less fuel into the vehicle's tank. The
calculation does not include any reduction in time spent searching for
a fueling station or other time spent at the station; it is assumed
that time savings occur only when truck operators are actually
refueling their vehicles.
The calculation uses the reduced number of gallons consumed by
truck type and divides that value by the tank volume and refill amount
to get the number of refills, then multiplies that by the time per
refill to determine the number of hours saved in a given year. The
calculation then applies DOT-recommended values of travel time savings
to convert the resulting time savings to their economic value,
including a 1.2 percent growth rate in those time savings going
forward.\901\ The input metrics used in the analysis are presented in
greater detail in RIA Chapter 9.7. The annual benefits associated with
reduced refueling time are shown in Table IX-25 along with net present
values at both 3 percent and 7 percent discount rates. The discounted
model year lifetime benefits are shown in Table IX-26. The methodology
used in this final rule is the same as that used in the proposal,
except that costs have been updated to 2013 dollars.
---------------------------------------------------------------------------
\901\ U.S. Department of Transportation, Valuation of Travel
Guidance, July 9, 2014, at page 14.
Table IX-25--Annual Refueling Benefits and Net Present Values at 3% and
7% Discount Rates Using Method B and Relative to the Flat Baseline
[Millions of 2013$] a
------------------------------------------------------------------------
Refueling
Calendar year benefits
------------------------------------------------------------------------
2018....................................................... $1
2019....................................................... 3
2020....................................................... 5
2021....................................................... 27
2022....................................................... 56
2023....................................................... 91
2024....................................................... 144
2025....................................................... 202
2026....................................................... 264
2027....................................................... 342
2028....................................................... 420
2029....................................................... 495
2030....................................................... 570
2035....................................................... 895
2040....................................................... 1,141
[[Page 73894]]
2050....................................................... 1,497
NPV, 3%.................................................... 11,985
NPV, 7%.................................................... 4,925
------------------------------------------------------------------------
Note:
\a\ For an explanation of analytical Methods A and B, please see Section
I.D; for an explanation of the flat baseline, 1a, and dynamic
baseline, 1b, please see Section X.A.1.
Table IX-26--Discounted Model Year Lifetime Refueling Benefits Using
Method B and Relative to the Flat Baseline
[Millions of 2013$] a
------------------------------------------------------------------------
3% 7%
Model year discount discount
rate rate
------------------------------------------------------------------------
2018.............................................. $9 $7
2019.............................................. 9 6
2020.............................................. 8 6
2021.............................................. 218 135
2022.............................................. 255 152
2023.............................................. 290 166
2024.............................................. 428 236
2025.............................................. 461 245
2026.............................................. 491 251
2027.............................................. 609 300
2028.............................................. 601 285
2029.............................................. 594 272
---------------------
Sum............................................... 3,976 2,061
------------------------------------------------------------------------
Note:
\a\ For an explanation of analytical Methods A and B, please see Section
I.D; for an explanation of the flat baseline, 1a, and dynamic
baseline, 1b, please see Section X.A.1.
(3) Benefits of Increased Travel Associated With Rebound Driving
The increase in travel associated with the rebound effect produces
additional benefits to vehicle owners and operators, which reflect the
value of the added (or more desirable) social and economic
opportunities that become accessible with additional travel. The
analysis estimates the economic benefits from increased rebound-effect
driving as the sum of fuel expenditures incurred plus the consumer
surplus from the additional accessibility it provides. As evidenced by
the fact that vehicles make more frequent or longer trips when the cost
of driving declines, the benefits from this added travel exceed added
expenditures for the fuel consumed. The amount by which the benefits
from this increased driving exceed its increased fuel costs measures
the net benefits from the additional travel, usually referred to as
increased consumer surplus.
The agencies' analysis estimates the economic value of the
increased consumer surplus provided by added driving using the
conventional approximation, which is one half of the product of the
decline in vehicle operating costs per vehicle-mile and the resulting
increase in the annual number of miles driven. Because it depends on
the extent of improvement in fuel economy, the value of benefits from
increased vehicle use changes by model year and varies among
alternative standards. Under even those alternatives that will impose
the highest standards, however, the magnitude of the consumer surplus
from additional vehicle use represents a small fraction of this
benefit.
The annual benefits associated with increased travel are shown in
Table IX-27 along with net present values at both 3 percent and 7
percent discount rates. The discounted model year lifetime benefits are
shown in Table IX-28. The methodology used in this final rule is the
same as that used in the proposal, except that costs have been updated
to 2013 dollars.
Table IX-27--Annual Value of Increased Travel and Net Present Values at
3% and 7% Discount Rates Using Method B and Relative to the Flat
Baseline
[Millions of 2013$] a
------------------------------------------------------------------------
Benefits of
Calendar year increased
travel
------------------------------------------------------------------------
2018...................................................... $0
2019...................................................... 0
2020...................................................... 0
2021...................................................... 298
2022...................................................... 417
2023...................................................... 534
2024...................................................... 648
2025...................................................... 759
2026...................................................... 866
2027...................................................... 967
2028...................................................... 1,064
2029...................................................... 1,157
2030...................................................... 1,247
2035...................................................... 1,660
2040...................................................... 2,043
2050...................................................... 2,284
NPV, 3%................................................... 23,357
NPV, 7%................................................... 10,343
------------------------------------------------------------------------
Note:
\a\ For an explanation of analytical Methods A and B, please see Section
I.D; for an explanation of the flat baseline, 1a, and dynamic
baseline, 1b, please see Section X.A.1.
Table IX-28--Discounted Model Year Lifetime Value of Increased Travel at
3% and 7% Discount Rates Using Method B and Relative to the Flat
Baseline
[Millions of 2013$] a
------------------------------------------------------------------------
3% 7%
Calendar year discount discount
rate rate
------------------------------------------------------------------------
2018.............................................. $452 $285
2019.............................................. 511 319
2020.............................................. 580 358
2021.............................................. 1,054 647
2022.............................................. 1,038 613
2023.............................................. 1,020 580
2024.............................................. 1,001 549
2025.............................................. 994 525
2026.............................................. 982 500
2027.............................................. 951 466
2028.............................................. 942 445
2029.............................................. 937 427
---------------------
Sum........................................... 10,462 5,715
------------------------------------------------------------------------
Note:
\a\ For an explanation of analytical Methods A and B, please see Section
I.D; for an explanation of the flat baseline, 1a, and dynamic
baseline, 1b, please see Section X.A.1.
K. Summary of Benefits and Costs
This section presents the costs, benefits, and other economic
impacts of the Phase 2 standards. It is important to note that NHTSA's
fuel consumption standards and EPA's GHG standards will both be in
effect, and will jointly lead to increased fuel efficiency and
reductions in GHG and non-GHG emissions. The individual categories of
benefits and costs presented in the tables below are defined more fully
and presented in more detail in Chapter 8 of the RIA. These include:
The vehicle program costs (costs of complying with the
vehicle COa; and fuel consumption standards),
changes in fuel expenditures associated with reduced fuel
use by more efficient vehicles and increased fuel use associated with
the ``rebound'' effect, both of which result from the program,
the global economic value of reductions in GHGs,
the economic value of reductions in non-GHG pollutants,
costs associated with increases in noise, congestion, and
crashes resulting from increased vehicle use,
savings in drivers' time from less frequent refueling,
benefits of increased vehicle use associated with the
``rebound'' effect, and
the economic value of improvements in U.S. energy security
impacts.
[[Page 73895]]
For a discussion of the cost of ownership and the agencies' payback
analysis of vehicles covered by this rule, please see Section IX.M.
The agencies conducted two analyses using two analytical methods
referred to as Method A and Method B. For an explanation of these
methods, please see Section I.D. And as discussed in Section X.A.1, the
agencies present estimates of benefits and costs that are measured
against two different assumptions about improvements in fuel efficiency
that might occur in the absence of the Phase 2 standards. The first
case (Alternative 1a) uses a baseline that projects very little
improvement in new vehicles in the absence of new Phase 2 standards,
and the second (Alternative 1b) uses a more dynamic baseline that
projects more significant improvements in vehicle fuel efficiency.
Table IX-29 shows benefits and costs for these standards from the
perspective of a program designed to improve the nation's energy
security and conserve energy by improving fuel efficiency. From this
viewpoint, technology costs occur when the vehicle is purchased. Fuel
savings are counted as benefits that occur over the lifetimes of the
vehicles produced during the model years subject to the Phase 2
standards as they consume less fuel. The table shows that benefits far
outweigh the costs, and the final program is anticipated to result in
large net benefits to the U.S economy.
Table IX-29--Lifetime Benefits & Costs of the Final Program for Model Years 2018-2029 Vehicles Using Analysis
Method A
[Billions of 2013$ discounted at 3% and 7%]
----------------------------------------------------------------------------------------------------------------
Baseline 1a Baseline 1b
Category ---------------------------------------------------------------
3% 7% 3% 7%
----------------------------------------------------------------------------------------------------------------
Vehicle Program: Technology and Indirect Costs, 24.4 16.6 23.7 16.1
Normal Profit on Additional Investments........
Additional Routine Maintenance.................. 1.7 0.9 1.7 0.9
Congestion, Crashes, Fatalities and Noise from 3.2 1.9 3.1 1.8
Increased Vehicle Use \a\......................
---------------------------------------------------------------
Total Costs................................. 29.3 19.4 28.5 18.8
----------------------------------------------------------------------------------------------------------------
Fuel Savings (valued at pre-tax prices)......... 163.0 87.0 149.1 79.7
Savings from Less Frequent Refueling............ 3.2 1.7 3.0 1.6
Economic Benefits from Additional Vehicle Use... 5.5 3.5 5.4 3.4
---------------------------------------------------------------
Reduced Climate Damages from GHG Emissions \b\.. 36.0
33.0
---------------------------------------------------------------
Reduced Health Damages from Non-GHG Emissions... 30.0 16.1 27.1 14.6
Increased U.S. Energy Security.................. 7.9 4.2 7.3 3.9
---------------------------------------------------------------
Total Benefits.............................. 246 149 225 136
Net Benefits................................ 216 129 197 117
----------------------------------------------------------------------------------------------------------------
Notes:
\a\ ``Congestion, Crashes, Fatalities and Noise from Increased Vehicle Use'' includes NHTSA's monetized value of
estimated reductions in the incidence of highway fatalities associated with mass reduction in HD pickup and
vans, but this does not include these reductions from tractor-trailers or vocational vehicles. This likely
results in a conservative overestimate of these costs.
\b\ Benefits and net benefits use the 3 percent average global SC-CO[ihel2], SC-CH4, and SC-N[ihel2]O value
applied to CO[ihel2], CH4, and N[ihel2]O emissions, respectively; GHG reductions also include HFC reductions,
and include benefits to other nations as well as the U.S. See RIA Chapter 8.5 and Preamble Section IX.G for
further discussion.
Table IX-30 through Table IX-32 report benefits and cost from the
perspective of reducing GHG. Table IX-30 shows the annual impacts and
net benefits of the final program for selected future years, together
with the net present values of cumulative annual impacts from 2018
through 2050, discounted at 3 percent and 7 percent rates.
Table IX-31 and Table IX-32 show the discounted lifetime costs and
benefits for each model year affected by the Phase 2 standards at 3
percent and 7 percent discount rates, respectively.
Table IX-30--Annual Benefits & Costs of the Final Program and Net Present Values at 3% and 7% Discount Rates Using Method B and Relative to the Flat
Baseline
[Billions of 2013$] \a\
--------------------------------------------------------------------------------------------------------------------------------------------------------
2018 2021 2024 2030 2035 2040 2050 NPV, 3% NPV, 7%
--------------------------------------------------------------------------------------------------------------------------------------------------------
Vehicle program................................................ -$0.2 -$2.5 -$4.2 -$5.2 -$5.7 -$6.3 -$7.3 -$87.8 -$41.9
Maintenance.................................................... 0.0 0.0 -0.1 -0.2 -0.2 -0.2 -0.2 -3.2 -1.5
Pre-tax fuel................................................... 0.1 1.3 6.1 23.4 38.9 53.1 63.4 523.3 213.8
Energy security................................................ 0.0 0.1 0.3 1.1 1.8 2.5 3.0 24.7 10.1
Crashes/Congestion/Noise....................................... 0.0 -0.1 -0.2 -0.4 -0.5 -0.5 -0.6 -6.8 -3.1
Refueling impacts.............................................. 0.0 0.0 0.1 0.6 0.9 1.1 1.5 12.0 4.9
Travel value................................................... 0.0 0.3 0.6 1.2 1.7 2.0 2.3 23.4 10.3
Non-GHG impacts................................................ 0.0 to 0.2 to 0.7 to 2.7 to 4.1 to 5.0 to 6.0 to 58.8 to 22.1 to
0.0 0.5 1.8 6.8 10.1 12.5 15.0 132.0 49.7
GHG: \b\ \c\
SC-GHG; 5% Avg............................................. 0.0 0.1 0.4 1.7 2.8 3.9 5.8 25.1 25.1
SC-GHG; 3% Avg............................................. 0.0 0.3 1.4 5.2 8.4 11.1 15.2 115.4 115.4
SC-GHG; 2.5% Avg........................................... 0.0 0.4 2.0 7.5 11.9 15.5 20.9 183.1 183.1
SC-GHG; 3% 95th............................................ 0.1 0.9 4.1 15.6 25.5 33.6 46.6 351.0 351.0
[[Page 73896]]
Net benefits:
SC-GHG; 5% Avg............................................. -0.1 -0.6 4.3 26.7 46.6 64.3 78.2 606.2 253.8
SC-GHG; 3% Avg............................................. -0.1 -0.4 5.2 30.2 52.2 71.4 87.6 696.4 344.0
SC-GHG; 2.5% Avg........................................... -0.1 -0.3 5.9 32.6 55.7 75.8 93.3 764.2 411.8
SC-GHG; 3% 95th............................................ 0.0 0.2 8.0 40.7 69.4 94.0 119.0 932.1 579.7
--------------------------------------------------------------------------------------------------------------------------------------------------------
Notes:
\a\ Positive values denote decreased social costs (benefits); negative values denote increased social costs. For an explanation of analytical Methods A
and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 1b, please see Section X.A.1.
\b\ GHG benefit estimates include reductions in CO[ihel2], CH[ihel4], and N[ihel2]O but do not include the HFC reductions, as discussed in Section IX.G.
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 (SC-CO[ihel2], SC-CH[ihel4], and SC-N[ihel2]O, each discounted at rates of 5, 3, 2.5 percent) is used to calculate net present
value of SC-CO[ihel2], SC-CH[ihel4], and SC-N[ihel2]O, respectively, for internal consistency. Refer to the SC-CO[ihel2] TSD for more detail.
\c\ Section IX.G notes that SC-GHGs increases over time. For the years 2012-2050, the SC-CO[ihel2] estimates range as follows: For Average SC-CO[ihel2]
at 5%: $12-$28; for Average SC-CO[ihel2] at 3%: $37-$77; for Average SC-CO[ihel2] at 2.5%: $58-$105; and for 95th percentile SC-CO[ihel2] at 3%: $105-
$237. For the years 2012-2050, the SC-CH4 estimates range as follows: For Average SC-CH[ihel4] at 5%: $440-$1,400; for Average SC-CH[ihel4] at 3%:
$1,000-$2,700; for Average SC-CH[ihel4] at 2.5%: $1,400-$3,400; and for 95th percentile SC-CH[ihel4] at 3%: $2,800-$7,400. For the years 2012-2050,
the SC-N[ihel2]O estimates range as follows: For Average SC-N[ihel2]O at 5%: $4,000-$12,000; for Average SC-N[ihel2]O at 3%: $14,000-$30,000; for
Average SC-N[ihel2]O at 2.5%: $21,000-$41,000; and for 95th percentile SC-N[ihel2]O at 3%: $36,000-$79,000. Section IX.G also presents these SC-GHG
estimates.
Table IX-31--Discounted Model Year Lifetime Benefits & Costs of the Final Program Using Method B and Relative to the Flat Baseline
[Billions of 2013$ discounted at 3%] \a\
--------------------------------------------------------------------------------------------------------------------------------------------------------
2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 Sum
--------------------------------------------------------------------------------------------------------------------------------------------------------
Vehicle program.................. -$0.2 -$0.2 -$0.2 -$2.1 -$2.0 -$2.1 -$3.1 -$3.0 -$3.0 -$3.6 -$3.5 -$3.4 -$26.5
Maintenance...................... -0.01 -0.01 -0.01 -0.15 -0.16 -0.16 -0.18 -0.18 -0.17 -0.30 -0.29 -0.29 -1.9
Pre-tax fuel..................... 0.7 0.7 0.6 10.7 11.4 12.0 18.5 19.1 19.7 25.3 25.2 25.1 169.1
Energy security.................. 0.0 0.0 0.0 0.5 0.5 0.6 0.8 0.9 0.9 1.2 1.2 1.2 7.8
Crashes/Congestion/Noise......... -0.1 -0.1 -0.2 -0.3 -0.3 -0.3 -0.3 -0.3 -0.3 -0.3 -0.3 -0.3 -3.2
Refueling........................ 0.0 0.0 0.0 0.2 0.3 0.3 0.4 0.5 0.5 0.6 0.6 0.6 4.0
Travel value..................... 0.5 0.5 0.6 1.1 1.0 1.0 1.0 1.0 1.0 1.0 0.9 0.9 10.5
Non-GHG.......................... 0.1 to 0.1 to 0.1 to 1.4 to 1.4 to 1.5 to 2.3 to 2.3 to 2.2 to 2.8 to 2.7 to 2.7 to 19.6 to
0.3 0.2 0.2 3.2 3.2 3.3 5.2 5.3 4.8 6.2 6.1 6.0 44.1
GHG: \b\ \c\
SC-GHG; 5% Avg............... 0.0 0.0 0.0 0.6 0.6 0.6 1.0 1.0 1.0 1.3 1.2 1.2 8.6
SC-GHG; 3% Avg............... 0.2 0.1 0.1 2.4 2.6 2.7 4.1 4.2 4.3 5.5 5.5 5.5 37.2
SC-GHG; 2.5% Avg............. 0.2 0.2 0.2 3.7 4.0 4.2 6.4 6.6 6.8 8.7 8.6 8.6 58.3
SC-GHG; 3% 95th.............. 0.5 0.4 0.4 7.2 7.7 8.0 12.3 12.7 13.1 16.8 16.7 16.6 112.5
Net benefits:
SC-GHG; 5% Avg............... 1.1 1.1 1.1 12.8 13.7 14.3 21.8 22.7 23.1 29.6 29.5 29.5 200.2
SC-GHG; 3% Avg............... 1.2 1.2 1.2 14.6 15.6 16.3 24.9 26.0 26.4 33.9 33.8 33.7 228.8
SC-GHG; 2.5% Avg............. 1.3 1.3 1.3 16.0 17.1 17.8 27.2 28.4 28.9 37.0 36.9 36.9 249.9
SC-GHG; 3% 95th.............. 1.5 1.5 1.5 19.5 20.8 21.7 33.2 34.5 35.2 45.1 44.9 44.9 304.1
--------------------------------------------------------------------------------------------------------------------------------------------------------
Notes:
\a\ Positive values denote decreased social costs (benefits); negative values denote increased social costs. For an explanation of analytical Methods A
and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 1b, please see Section X.A.1.c
\b\ GHG benefit estimates include reductions in CO[ihel2], CH[ihel4], and N[ihel2]O but do not include the HFC reductions, as discussed in Section IX.G.
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 (SC-CO[ihel2], SC-CH[ihel4], and SC-N[ihel2]O, each discounted at rates of 5, 3, 2.5 percent) is used to calculate net present
value of SC-CO[ihel2], SC-CH[ihel4], and SC-N[ihel2]O, respectively, for internal consistency. Refer to the SC-CO[ihel2] TSD for more detail.
\c\ Section IX.G notes that SC-GHG increases over time. For the years 2012-2050, the SC-CO[ihel2] estimates range as follows: For Average SC-CO[ihel2]
at 5%: $12-$28; for Average SC-CO[ihel2] at 3%: $37-$77; for Average SC-CO[ihel2] at 2.5%: $58-$105; and for 95th percentile SC-CO[ihel2] at 3%: $105-
$237. For the years 2012-2050, the SC-CH4 estimates range as follows: For Average SC-CH[ihel4] at 5%: $440-$1,400; for Average SC-CH[ihel4] at 3%:
$1,000-$2,700; for Average SC-CH[ihel4] at 2.5%: $1,400-$3,400; and for 95th percentile SC-CH[ihel4] at 3%: $2,800-$7,400. For the years 2012-2050,
the SC-N[ihel2]O estimates range as follows: For Average SC-N[ihel2]O at 5%: $4,000-$12,000; for Average SC-N[ihel2]O at 3%: $14,000-$30,000; for
Average SC-N[ihel2]O at 2.5%: $21,000-$41,000; and for 95th percentile SC-N[ihel2]O at 3%: $36,000-$79,000. Section IX.G also presents these SC-GHG
estimates.
Table IX-32--Discounted Model Year Lifetime Benefits & Costs of the Final Program Using Method B and Relative to the Flat Baseline
[Billions of 2013$ discounted at 7%] \a\ \b\
--------------------------------------------------------------------------------------------------------------------------------------------------------
2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 Sum
--------------------------------------------------------------------------------------------------------------------------------------------------------
Vehicle program................ -$0.2 -$0.2 -$0.2 -$1.6 -$1.5 -$1.5 -$2.2 -$2.0 -$1.9 -$2.2 -$2.1 -$2.0 -$17.6
Maintenance.................... 0.00 0.00 0.00 -0.10 -0.09 -0.09 -0.10 -0.10 -0.09 -0.15 -0.14 -0.13 -1.0
Pre-tax fuel................... 0.5 0.4 0.4 6.6 6.7 6.8 10.1 10.1 10.0 12.4 11.9 11.4 87.2
Energy security................ 0.0 0.0 0.0 0.3 0.3 0.3 0.5 0.5 0.5 0.6 0.6 0.5 4.0
Crashes/Congestion/Noise....... -0.1 -0.1 -0.1 -0.2 -0.2 -0.2 -0.2 -0.2 -0.2 -0.1 -0.1 -0.1 -1.8
Refueling...................... 0.0 0.0 0.0 0.1 0.2 0.2 0.2 0.2 0.3 0.3 0.3 0.3 2.1
Travel value................... 0.3 0.3 0.4 0.6 0.6 0.6 0.5 0.5 0.5 0.5 0.4 0.4 5.7
Non-GHG........................ 0.1 to 0.1 to 0.1 to 0.8 to 0.8 to 0.8 to 1.1 to 1.1 to 1.0 to 1.2 to 1.2 to 1.1 to 9.2 to
0.2 0.1 0.1 1.8 1.7 1.7 2.6 2.5 2.2 2.7 2.6 2.5 20.8
GHG: \b\ \c\
SC-GHG; 5% Avg............. 0.0 0.0 0.0 0.6 0.6 0.6 1.0 1.0 1.0 1.3 1.2 1.2 8.6
SC-GHG; 3% Avg............. 0.2 0.1 0.1 2.4 2.6 2.7 4.1 4.2 4.3 5.5 5.5 5.5 37.2
SC-GHG; 2.5% Avg........... 0.2 0.2 0.2 3.7 4.0 4.2 6.4 6.6 6.8 8.7 8.6 8.6 58.3
SC-GHG; 3% 95th............ 0.5 0.4 0.4 7.2 7.7 8.0 12.3 12.7 13.1 16.8 16.7 16.6 112.5
Net benefits:
SC-GHG; 5% Avg............. 0.7 0.7 0.6 7.6 7.9 7.9 11.7 11.8 11.6 14.4 13.9 13.5 102.3
SC-GHG; 3% Avg............. 0.8 0.8 0.8 9.4 9.8 10.0 14.8 15.1 15.0 18.7 18.2 17.7 130.9
SC-GHG; 2.5% Avg........... 0.9 0.9 0.8 10.7 11.2 11.4 17.1 17.4 17.4 21.9 21.3 20.9 151.9
SC-GHG; 3% 95th............ 1.1 1.1 1.0 14.2 14.9 15.3 23.0 23.6 23.7 29.9 29.3 28.9 206.1
--------------------------------------------------------------------------------------------------------------------------------------------------------
Notes:
[[Page 73897]]
\a\ Positive values denote decreased social costs (benefits); negative values denote increased social costs. For an explanation of analytical Methods A
and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 1b, please see Section X.A.1.
\b\ GHG benefit estimates include reductions in CO[ihel2], CH4, and N[ihel2]O but do not include the HFC reductions, as discussed in Section IX.G. 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 (SC-CO[ihel2], SC-CH4, and SC-N[ihel2]O, each discounted at rates of 5, 3, 2.5 percent) is used to calculate net present value
of SC-CO[ihel2], SC-CH4, and SC-N[ihel2]O, respectively, for internal consistency. Refer to the SC-CO[ihel2] TSD for more detail.
\c\ Section IX.G notes that SC-GHG increases over time. For the years 2012-2050, the SC-CO[ihel2] estimates range as follows: For Average SC-CO[ihel2]
at 5%: $12-$28; for Average SC-CO[ihel2] at 3%: $37-$77; for Average SC-CO[ihel2] at 2.5%: $58-$105; and for 95th percentile SCCO[ihel2] at 3%: $105-
$237. For the years 2012-2050, the SC-CH4 estimates range as follows: For Average SC-CH4 at 5%: $440-$1,400; for Average SC-CH4 at 3%: $1,000-$2,700;
for Average SC-CH4 at 2.5%: $1,400-$3,400; and for 95th percentile SC-CH4 at 3%: $2,800-$7,400. For the years 2012-2050, the SC-N[ihel2]O estimates
range as follows: For Average SC-N[ihel2]O at 5%: $4,000-$12,000; for Average SC-N[ihel2]O at 3%: $14,000-$30,000; for Average SC-N[ihel2]O at 2.5%:
$21,000-$41,000; and for 95th percentile SC-N[ihel2]O at 3%: $36,000-$79,000. Section IX.G also presents these SC-GHG estimates.
L. Employment Impacts
Executive Order 13563 (January 18, 2011) directs federal agencies
to consider regulatory impacts on, among other criteria, job
creation.\902\ According to the Executive Order ``Our regulatory system
must protect public health, welfare, safety, and our environment while
promoting economic growth, innovation, competitiveness, and job
creation. It must be based on the best available science.'' Analysis of
employment impacts of a regulation is not part of a standard benefit-
cost analysis (except to the extent that labor costs contribute to
costs). Employment impacts of federal rules are of general interest,
however, and have been particularly so, historically, in the auto
sector during periods of challenging labor market conditions. For this
reason, we are describing the connections of these standards to
employment in the regulated sector, the motor vehicle manufacturing
sector, as well as the motor vehicle body and trailer and motor vehicle
parts manufacturing sectors.\903\
---------------------------------------------------------------------------
\902\ Available at http://www.whitehouse.gov/sites/default/files/omb/inforeg/eo12866/eo13563_01182011.pdf.
\903\ The employment analysis in this RIA is part of EPA's
ongoing effort to ``conduct continuing evaluations of potential loss
or shifts of employment which may result from the administration or
enforcement of [the Act]'' pursuant to CAA section 321(a).
---------------------------------------------------------------------------
The overall effect of the final rules on motor vehicle sector
employment depends on the relative magnitude of output and substitution
effects, described below. Because we do not have quantitative estimates
of the output effect, and only a partial estimate of the substitution
effect, we cannot reach a quantitative estimate of the overall
employment effects of the final rules on motor vehicle sector
employment or even whether the total effect will be positive or
negative.
According to the U.S. Bureau of Labor Statistics, in 2015, about
910,000 people in the U.S. were employed in the Motor Vehicle and Parts
Manufacturing Sector (NAICS 3361, 3362, and 3363),\904\ the directly
regulated sector. The employment effects of these final rules are
expected to expand beyond the regulated sector. Though some of the
parts used to achieve these standards are likely to be built by motor
vehicle manufacturers (including trailer manufacturers) themselves, the
motor vehicle parts manufacturing sector also plays a significant role
in providing those parts, and will also be affected by changes in
vehicle sales. Changes in truck sales, discussed in Section IX.F.(2),
could also affect employment for truck and trailer vendors. As
discussed in Section IX.C., this final rule is expected to reduce the
amount of fuel these vehicles use, and thus affect the petroleum
refinery and supply industries as well. Finally, since the net
reduction in cost associated with these final rules is expected to lead
to lower transportation and shipping costs, in a competitive market a
substantial portion of those cost savings will be passed along to
consumers, who then will have additional discretionary income (how much
of the cost is passed along to consumers depends on market structure
and the relative price elasticities). The final rules are not expected
to have any notable inflationary or recessionary effect.
---------------------------------------------------------------------------
\904\ U.S. Department of Labor, Bureau of Labor Statistics.
``Automotive Industry; Employment, Earnings, and Hours.'' http://www.bls.gov/iag/tgs/iagauto.htm, accessed 4/20/16.
---------------------------------------------------------------------------
The employment effects of environmental regulation are difficult to
disentangle from other economic changes and business decisions that
affect employment, over time and across regions and industries. In
light of these difficulties, we lean on economic theory to provide a
constructive framework for approaching these assessments and for better
understanding the inherent complexities in such assessments.
Neoclassical microeconomic theory describes how profit-maximizing firms
adjust their use of productive inputs in response to changes in their
economic conditions.\905\ Berman and Bui (2001, pp. 274-75) model two
components that drive changes in firm-level labor demand: Output
effects and substitution effects.\906\ Regulation can affect the
profit-maximizing quantity of output by changing the marginal cost of
production. If regulation causes marginal cost to increase, it will
place upward pressure on output prices, leading to a decrease in the
quantity demanded, and resulting in a decrease in production. The
output effect describes how, holding labor intensity constant, a
decrease in production causes a decrease in labor demand. As noted by
Berman and Bui, although many assume that regulation increases marginal
cost, it need not be the case. A regulation could induce a firm to
upgrade to less polluting and more efficient equipment that lowers
marginal production costs, or it may induce use of technologies that
may prove popular with buyers or provide positive network externalities
(see Section IX.A. for discussion of this effect). In such a case,
output could increase.
---------------------------------------------------------------------------
\905\ See Layard, P.R.G., and A. A. Walters (1978),
Microeconomic Theory (McGraw-Hill, Inc.), Chapter 9 (Docket ID EPA-
HQ-OAR-2014-0827-0070), a standard microeconomic theory textbook
treatment, for a discussion.
\906\ Berman, E. and L. T. M. Bui (2001). ``Environmental
Regulation and Labor Demand: Evidence from the South Coast Air
Basin.'' Journal of Public Economics 79(2): 265-295 (Docket EPA-HQ-
OAR-2014-0827-0074). The authors also discuss a third component, the
impact of regulation on factor prices, but conclude that this effect
is unlikely to be important for large competitive factor markets,
such as labor and capital. Morgenstern, Pizer and Shih (Morgenstern,
Richard D., William A. Pizer, and Jhih-Shyang Shih (2002). ``Jobs
versus the Environment: An Industry-Level Perspective.'' Journal of
Environmental Economics and Management 43: 412-436, Docket EPA-HQ-
OAR-2014-0827-0088) use a similar model, but they break the
employment effect into three parts: (1) A demand effect; (2) a cost
effect; and (3) a factor-shift effect.
---------------------------------------------------------------------------
The substitution effect describes how, holding output constant,
regulation affects labor intensity of production. Although increased
environmental regulation may increase use of pollution control
equipment and energy to operate that equipment, the impact on labor
demand is ambiguous. For example, equipment inspection requirements,
specialized waste handling, or pollution technologies that alter the
production process may affect the number of workers necessary to
produce a unit of output. Berman and Bui (2001) model the substitution
effect as the effect of regulation on pollution control equipment and
expenditures required
[[Page 73898]]
by the regulation and the corresponding change in labor intensity of
production.
In summary, as output and substitution effects may be positive or
negative, theory alone cannot predict the direction of the net effect
of regulation on labor demand at the level of the regulated firm.
Operating within the bounds of standard economic theory, empirical
estimation of net employment effects on regulated firms is possible
when data and methods of sufficient detail and quality are available.
The literature, however, illustrates difficulties with empirical
estimation. For example, studies sometimes rely on confidential plant-
level employment data from the U.S. Census Bureau, possibly combined
with pollution abatement expenditure data that are too dated to be
reliably informative. In addition, the most commonly used empirical
methods do not permit estimation of net effects.
The conceptual framework described thus far focused on regulatory
effects on plant-level decisions within a regulated industry.
Employment impacts at an individual plant do not necessarily represent
impacts for the sector as a whole. The approach must be modified when
applied at the industry level. At the industry level, labor demand is
more responsive if: (1) The price elasticity of demand for the product
is high, (2) other factors of production can be easily substituted for
labor, (3) the supply of other factors is highly elastic, or (4) labor
costs are a large share of total production costs.\907\ For example, if
all firms in an industry are faced with the same regulatory compliance
costs and product demand is inelastic, then industry output may not
change much, and output of individual firms may change slightly.\908\
In this case, the output effect may be small, while the substitution
effect depends on input substitutability. Suppose, for example, that
new equipment for fuel efficiency improvements requires labor to
install and operate. In this case, the substitution effect may be
positive, and with a small output effect, the total effect may be
positive. As with potential effects for an individual firm, theory
cannot determine the sign or magnitude of industry-level regulatory
effects on labor demand. Determining these signs and magnitudes
requires additional sector-specific empirical study. For environmental
rules, much of the data needed for these empirical studies is not
publicly available, would require significant time and resources in
order to access confidential U.S. Census data for research, and also
would not be necessary for other components of a typical RIA.
---------------------------------------------------------------------------
\907\ See Ehrenberg, Ronald G., and Robert S. Smith (2000),
Modern Labor Economics: Theory and Public Policy (Addison Wesley
Longman, Inc.), p. 108, Docket EPA-HQ-OAR-2014-0827-0077.
\908\ This discussion draws from Berman, E. and L. T. M. Bui
(2001). ``Environmental Regulation and Labor Demand: Evidence from
the South Coast Air Basin.'' Journal of Public Economics 79(2): 265-
295 (Docket EPA-HQ-OAR-2014-0827), p. 293, Docket EPA-HQ-OAR-2014-
0827-0074.
---------------------------------------------------------------------------
In addition to changes to labor demand in the regulated industry,
net employment impacts encompass changes in other related sectors. For
example, these standards are expected to increase demand for fuel-
saving technologies. This increased demand may increase revenue and
employment in the firms providing these technologies. At the same time,
the regulated industry is purchasing the equipment, and these costs may
impact labor demand at regulated firms. Therefore, it is important to
consider the net effect of compliance actions on employment across
multiple sectors or industries.
If the U.S. economy is at full employment, even a large-scale
environmental regulation is unlikely to have a noticeable impact on
aggregate net employment.\909\ Instead, labor would primarily be
reallocated from one productive use to another, and net national
employment effects from environmental regulation would be small and
transitory (e.g., as workers move from one job to another).\910\ The
International Union, United Automobile, Aerospace and Agricultural
Implement Workers of America (UAW) commented that, when the 900,000
workers in the auto sector are combined with ``jobs from other sectors
that are dependent on the industry,'' the industry ``is responsible for
7.25 million jobs nationwide, or about 3.8 percent of private-sector
employment.'' The agencies consider the 900,000 motor-vehicle-sector
jobs to be in the industry directly affected by these standards; for
the reasons discussed here, the overall state of the U.S. economy is
likely to have a much more significant effect on the people employed in
other sectors than these standards.
---------------------------------------------------------------------------
\909\ Full employment is a conceptual target for the economy
where everyone who wants to work and is available to do so at
prevailing wages is actively employed. The unemployment rate at full
employment is not zero.
\910\ Arrow et al. (1996). ``Benefit-Cost Analysis in
Environmental, Health, and Safety Regulation: A Statement of
Principles.'' American Enterprise Institute, the Annapolis Center,
and Resources for the Future, Docket EPA-HQ-OAR-2014-0827-0073. See
discussion on bottom of p. 6. In practice, distributional impacts on
individual workers can be important, as discussed later in this
section.
---------------------------------------------------------------------------
Affected sectors may experience transitory effects as workers
change jobs. Some workers may retrain or relocate in anticipation of
new requirements or require time to search for new jobs, while
shortages in some sectors or regions could bid up wages to attract
workers. These adjustment costs can lead to local labor disruptions.
Although the net change in the national workforce is expected to be
small, localized reductions in employment may adversely impact
individuals and communities just as localized increases may have
positive impacts.
If the economy is operating at less than full employment, economic
theory does not clearly indicate the direction or magnitude of the net
impact of environmental regulation on employment; it could cause either
a short-run net increase or short-run net decrease.\911\ An important
research question is how to accommodate unemployment as a structural
feature in economic models. This feature may be important in assessing
large-scale regulatory impacts on employment.\912\
---------------------------------------------------------------------------
\911\ Schmalensee, Richard, and Robert N. Stavins. ``A Guide to
Economic and Policy Analysis of EPA's Transport Rule.'' White paper
commissioned by Excelon Corporation, March 2011, Docket EPA-HQ-OAR-
2014-0827-0071.
\912\ Klaiber, H. Allen, and V. Kerry Smith (2012). ``Developing
General Equilibrium Benefit Analyses for Social Programs: An
Introduction and Example.'' Journal of Benefit-Cost Analysis 3(2),
Docket EPA-HQ-OAR-2014-0827-0086.
---------------------------------------------------------------------------
Environmental regulation may also affect labor supply. In
particular, pollution and other environmental risks may impact labor
productivity or employees' ability to work.\913\ While the theoretical
framework for analyzing labor supply effects is analogous to that for
labor demand, it is more difficult to study empirically. There is a
small emerging literature described in the next section that uses
detailed labor and environmental data to assess these impacts.
---------------------------------------------------------------------------
\913\ E.g. Graff Zivin, J., and M. Neidell (2012). ``The Impact
of Pollution on Worker Productivity.'' American Economic Review 102:
3652-3673, Docket EPA-HQ-OAR-2014-0827-0092.
---------------------------------------------------------------------------
To summarize, economic theory provides a framework for analyzing
the impacts of environmental regulation on employment. The net
employment effect incorporates expected employment changes (both
positive and negative) in the regulated sector and elsewhere. Labor
demand impacts for regulated firms, and also for the regulated
industry, can be decomposed into output and substitution effects which
may be either negative or positive. Estimation of net employment
effects for regulated sectors is possible when data of sufficient
detail and quality are
[[Page 73899]]
available. Finally, economic theory suggests that labor supply effects
are also possible. In the next section, we discuss the empirical
literature.
Achates Power, the American Council for an Energy-Efficient
Economy, BlueGreen Alliance, Ceres, Environmental Defense Fund (EDF),
Natural Resources Defense Council, and JD Gilroy expressed support for
the standards' potential to increase employment in the vehicle
manufacturing industry. They argued that the standards will drive new
jobs, reward organizations that innovate with respect to fuel
efficiency, and help maintain the U.S. position as a leader in
industries related to truck manufacturing and fuel efficiency
technology. Brian Mannix points out the difficulty associated with
generating complete employment forecasts that include all direct and
indirect effects. He concludes that the agencies are correct to be
careful about estimating a definitive forecast.
Comments from the International Union, United Automobile, Aerospace
and Agricultural Implement Workers of America (UAW) urge EPA and NHTSA
to ensure that the standards avoid market disruptions or ``pre-buy/no-
buy'' boom and bust cycles. UAW suggests that in the past, market
disruptions caused by pre-buy in anticipation of the 2007 and 2010
NOX and PM standards contributed to the layoff of 10,000 UAW
workers in 2009, though these layoffs were also partly driven by the
Great Recession. As pointed out in the comments from EDF, fuel economy
standards are fundamentally different from the past standards, because
increases in costs for new technology are offset by fuel savings that
accrue to the buyer. As a result these standards are less likely to
cause disruptions to vehicle purchasing trends. Moreover, as discussed
in Section IX.F.(2) above, there is no evidence to date that the HD
GHG/fuel consumption rules have resulted in pre-buy/no-buys.
NAFA Fleet Management Association expressed concern that the
standards would make it more difficult to hire qualified drivers and
technicians, and would require additional employee training. As
discussed in Section IX.A., the effects of the standards on hiring and
retention of drivers and technicians are not well understood. The
agencies expect that normal market forces should help to alleviate any
labor shortages, whether or not they are associated with the standards.
The Recreational Vehicle (RV) Industry Association expresses concern
that buyers RVs do not consider fuel expenditures when purchasing
vehicles; as a result, increased up-front costs of the vehicle might
reduce their sales. The RV industry was disproportionately hurt during
the Great Recession and has only recently experienced a
recovery.914 915 However, one of the main drivers of the
turn-around appears to be low gas prices,\916\ which suggests that RV
buyers may put some weight on fuel savings in their buying decisions;
if so, the reduction in expected fuel costs may mitigate at least some
of the effect of higher up-front prices.
---------------------------------------------------------------------------
\914\ Quiggle, Ben. ``RV sales projected to be stronger in 2016
thanks to low gas prices, steady economy,'' The Elkhart Truth, March
6, 2016. http://www.elkharttruth.com/news/business/2016/03/03/RV-sales-projected-to-be-stronger-in-2016-thanks-to-low-gas-prices-steady-economy.html, accessed 3/28/2016, Docket EPA-HQ-OAR-2014-
0827.
\915\ Morris, Frank. ``Ready For A Road Trip? RVs Are Rolling
Back Into Fashion,'' Morning Edition on NPR, March 28, 2016. http://www.npr.org/2016/03/28/468172578/ready-for-a-road-trip-rvs-are-rolling-back-into-fashion, accessed 3/28/2016, Docket EPA-HQ-OAR-
2014-0827.
\916\ Quiggle, Ben. ``RV sales projected to be stronger in 2016
thanks to low gas prices, steady economy,'' The Elkhart Truth, March
6, 2016. http://www.elkharttruth.com/news/business/2016/03/03/RV-sales-projected-to-be-stronger-in-2016-thanks-to-low-gas-prices-steady-economy.html, accessed 3/28/2016, Docket EPA-HQ-OAR-2014-
0827.
---------------------------------------------------------------------------
(1) Current State of Knowledge Based on the Peer-Reviewed Literature
In the labor economics literature there is an extensive body of
peer-reviewed empirical work analyzing various aspects of labor demand,
relying on the above theoretical framework.\917\ This work focuses
primarily on the effects of employment policies, e.g. labor taxes,
minimum wage, etc.\918\ In contrast, the peer-reviewed empirical
literature specifically estimating employment effects of environmental
regulations is very limited. Several empirical studies \919\ suggest
that net employment impacts may be zero or slightly positive but small
even in the regulated sector. Other research suggests that more highly
regulated counties may generate fewer jobs than less regulated
ones.\920\ However, since these latter studies compare more regulated
to less regulated counties, they overstate the net national impact of
regulation to the extent that regulation causes plants to locate in one
area of the country rather than another. List et al. (2003) \921\ find
some evidence that this type of geographic relocation may be occurring.
Overall, the peer-reviewed literature does not contain evidence that
environmental regulation has a large impact on net employment (either
negative or positive) in the long run across the whole economy.
---------------------------------------------------------------------------
\917\ See Hamermesh (1993), Labor Demand (Princeton, NJ:
Princeton University Press), Chapter 2 (Docket EPA-HQ-OAR-2014-0827-
0082) for a detailed treatment.
\918\ See Ehrenberg, Ronald G., and Robert S. Smith (2000),
Modern Labor Economics: Theory and Public Policy (Addison Wesley
Longman, Inc.), Chapter 4 (Docket EPA-HQ-OAR-2014-0827-0077), for a
concise overview.
\919\ Berman, E. and L. T. M. Bui (2001). ``Environmental
Regulation and Labor Demand: Evidence from the South Coast Air
Basin.'' Journal of Public Economics 79(2): 265-295 (Docket EPA-HQ-
OAR2014-0827-0074). Morgenstern, Richard D., William A. Pizer, and
Jhih-Shyang Shih. ``Jobs Versus the Environment: An Industry-Level
Perspective.'' Journal of Environmental Economics and Management 43
(2002): 412-436, Docket EPA-HQ-OAR-2014-0827-0088; Gray et al.
(2014), ``Do EPA Regulations Affect Labor Demand? Evidence from the
Pulp and Paper Industry,'' Journal of Environmental Economics and
Management 68: 188-202, Docket EPA-HQ-OAR-2014-0827-0080; and
Ferris, Shadbegian and Wolverton (2014), ``The Effect of
Environmental Regulation on Power Sector Employment: Phase I of the
Title IV SO2 Trading Program,'' Journal of the
Association of Environmental and Resource Economists 1: 521-553,
Docket EPA-HQ-OAR-2014-0827-0078.
\920\ Greenstone, M. (2002). ``The Impacts of Environmental
Regulations on Industrial Activity: Evidence from the 1970 and 1977
Clean Air Act Amendments and the Census of Manufactures,'' Journal
of Political Economy 110(6): 1175-1219 (Docket EPA-HQ-OAR-2014-0827-
0081); Walker, Reed. (2011). ``Environmental Regulation and Labor
Reallocation.'' American Economic Review: Papers and Proceedings
101(3): 442-447 (Docket EPA-HQ-OAR-2014-0827-0091).
\921\ List, J. A., D. L. Millimet, P. G. Fredriksson, and W. W.
McHone (2003). ``Effects of Environmental Regulations on
Manufacturing Plant Births: Evidence from a Propensity Score
Matching Estimator.'' The Review of Economics and Statistics 85(4):
944-952 (Docket EPA-HQ-OAR2014-0827-0087).
---------------------------------------------------------------------------
Analytic challenges make it very difficult to accurately produce
net employment estimates for the whole economy that would appropriately
capture the way in which costs, compliance spending, and environmental
benefits propagate through the macro-economy. Quantitative estimates
are further complicated by the fact that macroeconomic models often
have very little sectoral detail and usually assume that the economy is
at full employment. EPA is currently in the process of seeking input
from an independent expert panel on modeling economy-wide impacts,
including employment effects. For more information, see: https://federalregister.gov/a/2014-02471.
(2) Employment Impacts in the Motor Vehicle and Parts Manufacturing
Sector
This section describes changes in employment in the motor vehicle,
trailer, and parts (hence, motor vehicle) manufacturing sectors due to
these final rules. We focus on the motor vehicle manufacturing sector
because it is directly regulated, and because it is likely to bear a
substantial share of
[[Page 73900]]
changes in employment due to these final rules. We include discussion
of effects on the parts manufacturing sector, because the motor vehicle
manufacturing sector can either produce parts internally or buy them
from an external supplier, and we do not have estimates of the likely
breakdown of effort between the two sectors.
We follow the theoretical structure of Berman and Bui \922\ of the
impacts of regulation in employment in the regulated sectors. In Berman
and Bui's (2001, p. 274-75) theoretical model, as described above, the
change in a firm's labor demand arising from a change in regulation is
decomposed into two main components: Output and substitution
effects.\923\ As the output and substitution effects may be both
positive, both negative, or some combination, standard neoclassical
theory alone does not point to a definitive net effect of regulation on
labor demand at regulated firms.
---------------------------------------------------------------------------
\922\ Berman, E. and L. T. M. Bui (2001). ``Environmental
Regulation and Labor Demand: Evidence from the South Coast Air
Basin.'' Journal of Public Economics 79(2): 265-295 (Docket EPA-HQ-
OAR2014-0827-0074).
\923\ The authors also discuss a third component, the impact of
regulation on factor prices, but conclude that this effect is
unlikely to be important for large competitive factor markets, such
as labor and capital. Morgenstern, Pizer and Shih (2002) use a
similar model, but they break the employment effect into three
parts: (1) The demand effect; (2) the cost effect; and (3) the
factor-shift effect. See Morgenstern, Richard D., William A. Pizer,
and Jhih-Shyang Shih. ``Jobs Versus the Environment: An Industry-
Level Perspective.'' Journal of Environmental Economics and
Management 43 (2002): 412-436 (Docket EPA-HQ-OAR-2014-0827-0088).
---------------------------------------------------------------------------
Following the Berman and Bui framework for the impacts of
regulation on employment in the regulated sector, we consider two
effects for the motor vehicle sector: The output effect and the
substitution effect.
(a) The Output Effect
If truck or trailer sales increase, then more people will be
required to assemble trucks, trailers, and their components. If truck
or trailer sales decrease, employment associated with these activities
will decrease. The effects of this final rulemaking on HD vehicle sales
thus depend on the perceived desirability of the new vehicles. On one
hand, this final rulemaking will increase truck and trailer costs; by
itself, this effect would reduce truck and trailer sales. In addition,
while decreases in truck performance would also decrease sales, this
program is not expected to have any negative effect on truck
performance. On the other hand, this final rulemaking will reduce the
fuel costs of operating the trucks; by itself, this effect would
increase truck sales, especially if potential buyers have an
expectation of higher fuel prices. The agencies have not made an
estimate of the potential change in truck or trailer sales. However, as
discussed in IX.E., the agencies have estimated an increase in vehicle
miles traveled (i.e., VMT rebound) due to the reduced operating costs
of trucks meeting these standards. Since increased VMT is most likely
to be met with more drivers and more trucks, our projection of VMT
rebound is suggestive of an increase in vehicle sales and truck driver
employment (recognizing that these increases may be partially offset by
a decrease in manufacturing and sales for equipment of other modes of
transportation such as rail cars or barges).
(b) The Substitution Effect
The output effect, above, measures the effect due to new truck and
trailer sales only. The substitution effect includes the impacts due to
the changes in technologies needed for vehicles to meet these
standards, separate from the effect on output (that is, as though
holding output constant). This effect includes both changes in
employment due to incorporation of abatement technologies and overall
changes in the labor intensity of manufacturing. We present estimates
for this effect to provide a sense of the order of magnitude of
expected impacts on employment, which we expect to be small in the
automotive sector, and to repeat that regulations may have positive as
well as negative effects on employment.
One way to estimate this effect, given the cost estimates for
complying with the final rule, is to use the ratio of workers to each
$1 million of expenditures in that sector. The use of these ratios has
both advantages and limitations. It is often possible to estimate these
ratios for quite specific sectors of the economy: For instance, it is
possible to estimate the average number of workers in the motor vehicle
body and trailer manufacturing sector per $1 million spent in the
sector, rather than use the ratio from another, more aggregated sector,
such as motor vehicle manufacturing. As a result, it is not necessary
to extrapolate employment ratios from possibly unrelated sectors. On
the other hand, these estimates are averages for the sectors, covering
all the activities in those sectors; they may not be representative of
the labor required when expenditures are required on specific
activities, or when manufacturing processes change sufficiently that
labor intensity changes. For instance, the ratio for the motor vehicle
manufacturing sector represents the ratio for all vehicle
manufacturing, not just for emissions reductions associated with
compliance activities. In addition, these estimates do not include
changes in sectors that supply these sectors, such as steel or
electronics producers. They thus may best be viewed as the effects on
employment in the motor vehicle sector due to the changes in
expenditures in that sector, rather than as an assessment of all
employment changes due to these changes in expenditures. In addition,
this approach estimates the effects of increased expenditures while
holding constant the labor intensity of manufacturing; it does not take
into account changes in labor intensity due to changes in the nature of
production. This latter effect could either increase or decrease the
employment impacts estimated here.\924\
---------------------------------------------------------------------------
\924\ As noted above, Morgenstern et al. (2002) separate the
effect of holding output constant into two effects: The cost effect,
which holds labor intensity constant, and the factor shift effect,
which estimates those changes in labor intensity.
---------------------------------------------------------------------------
Some of the costs of these final rules will be spent directly in
the motor vehicle manufacturing sector, but it is also likely that some
of the costs will be spent in the motor vehicle body and trailer and
motor vehicle parts manufacturing sectors. The analysis here draws on
estimates of workers per $1 million of expenditures for each of these
sectors.
There are several public sources for estimates of employment per $1
million expenditures. The U.S. Bureau of Labor Statistics (BLS)
provides its Employment Requirements Matrix (ERM),\925\ which provides
direct estimates of the employment per $1 million in sales of goods in
202 sectors. The values considered here are for Motor Vehicle
Manufacturing (NAICS 3361), Motor Vehicle Body and Trailer
Manufacturing (NAICS 3362), and Motor Vehicle Parts Manufacturing
(NAICS 3363) for 2014.
---------------------------------------------------------------------------
\925\ http://www.bls.gov/emp/ep_data_emp_requirements.htm; see
``HD Substitution Effect Employment Impacts,'' Docket EPA-HQ-OAR-
2014-0827.
---------------------------------------------------------------------------
The Census Bureau provides the Annual Survey of Manufacturers \926\
(ASM), a subset of the Economic Census (EC), based on a sample of
establishments; though the EC itself is more complete, it is conducted
only every 5 years, while the ASM is annual. Both include more sectoral
detail than the BLS ERM: For instance, while the ERM includes the Motor
Vehicle
[[Page 73901]]
Manufacturing sector, the ASM and EC have detail at the 6-digit NAICS
code level (e.g., light truck and utility vehicle manufacturing). While
the ERM provides direct estimates of employees/$1 million in
expenditures, the ASM and EC separately provide number of employees and
value of shipments; the direct employment estimates here are the ratio
of those values. The values reported are for Motor Vehicle
Manufacturing (NAICS 3361), Light Truck and Utility Vehicle
Manufacturing (NAICS 336112), Heavy Duty Truck Manufacturing (NAICS
33612), Motor Vehicle Body and Trailer manufacturing (NAICS 3362), and
Motor Vehicle Parts Manufacturing (NAICS 3363).
---------------------------------------------------------------------------
\926\ http://www.census.gov/manufacturing/asm/index.html; see
``HD Substitution Effect Employment Impacts,'' Docket EPA-HQ-OAR-
2014-0827.
---------------------------------------------------------------------------
RIA Chapter 8.11.2.2 provides the details on the values of workers
per $1 million in expenditures in 2014 (2012 for EC) for the sectors
mentioned above. In 2013$, these range from 0.4 workers per $1 million
for Motor Vehicle Manufacturing in the ERM as well as for Light Truck &
Utility Vehicle Manufacturing in the ASM, to 3.5 workers per $1 million
in expenditures for Motor Vehicle Body and Trailer Manufacturing in the
EC. These values are then adjusted to remove the employment effects of
imports through use of a ratio of domestic production to domestic sales
of 0.78.\927\
---------------------------------------------------------------------------
\927\ To estimate the proportion of domestic production affected
by the change in sales, we use data from Ward's Automotive Group for
total truck production in the U.S. compared to total truck sales in
the U.S. For the period 2006-2015, the proportion is 78 percent (HD
Substitution Effect Employment Impacts, Docket EPA-HQ-OAR-2014-
0827), ranging from 68 percent (2009) to 83 percent (2012) over that
time.
---------------------------------------------------------------------------
Over time, the amount of labor needed in the motor vehicle industry
has changed: Automation and improved methods have led to significant
productivity increases. The BLS ERM, for instance, provided estimates
that, in 1997, 1.09 workers in the Motor Vehicle Manufacturing sector
were needed per $1 million, but only 0.39 workers by 2014 (in
2013$).\928\ Because the ERM is available annually for 1997-2014, we
used these data to estimate productivity improvements over time. We
then used these productivity estimates to project the ERM through 2027,
and to adjust the ASM values for 2014 and the EC values for 2012. RIA
Chapter 8.11.2 provides detail on these calculations.
---------------------------------------------------------------------------
\928\ http://www.bls.gov/emp/ep_data_emp_requirements.htm; see
``HD Substitution Effect Employment Impacts,'' Docket EPA-HQ-OAR-
2014-0827. This analysis used data for sectors 80 (Motor Vehicle
Manufacturing), 81 (Motor Vehicle Body and Trailer Manufacturing),
and 82 (Motor Vehicle Parts Manufacturing) from ``Chain-weighted
(2009 dollars) real domestic employment requirements tables.''
---------------------------------------------------------------------------
Finally, to simplify the presentation and give a range of
estimates, we compared the projected employment among the 3 sectors for
the ERM, EC, and ASM, and we provide only the maximum and minimum
employment effects estimated across the ERM, EC, and ASM. We provide
the range rather than a point estimate because of the inherent
difficulties in estimating employment impacts; the range gives an
estimate of the expected magnitude. The ERM estimates in the Motor
Vehicle Manufacturing Sector are consistently the minimum values. The
ASM estimates in the Motor Vehicle Body and Trailer Manufacturing
Sector are the maximum values for all years but 2027, when the ASM
values for Motor Vehicle Parts Manufacturing provide the maximum
values.
Section IX.B. of the Preamble discusses the vehicle cost estimates
developed for these final rules. The final step in estimating
employment impacts is to multiply costs (in $ millions) by workers per
$1 million in costs, to estimate employment impacts in the regulated
and parts manufacturing sectors. Increased costs of vehicles and parts
will, by itself, and holding labor intensity constant, be expected to
increase employment between 2018 and 2027 between zero and 4.5 thousand
jobs each year.
While we estimate employment impacts, measured in job-years,
beginning with program implementation, some of these employment gains
may occur earlier as motor vehicle manufacturers and parts suppliers
hire staff in anticipation of compliance with the standards. A job-year
is a way to calculate the amount of work needed to complete a specific
task. For example, a job-year is one year of work for one person.
Table IX-33--Employment Effects Due to Increased Costs of Vehicles and Parts (Substitution Effect), in Job-Years
----------------------------------------------------------------------------------------------------------------
Minimum employment due to Maximum employment due to
substitution effect (ERM substitution effect (ASM
Year Costs (millions estimates, expenditures in estimates, expenditures in
of 2013$) the Motor Vehicles Mfg the Body and Trailer Mfg
sector) sector \a\)
----------------------------------------------------------------------------------------------------------------
2018............................... 227 0 400
2019............................... 215 0 400
2020............................... 220 0 300
2021............................... 2,270 300 3,100
2022............................... 2,243 300 2,900
2023............................... 2,485 300 2,900
2024............................... 3,890 400 4,200
2025............................... 4,146 400 4,100
2026............................... 4,203 400 3,800
2027............................... 5,219 500 4,500
----------------------------------------------------------------------------------------------------------------
Note:
\a\ For 2027, the maximum employment effects are associated with the ASM's Motor Vehicle Parts Manufacturing
sector.
(c) Summary of Employment Effects in the Motor Vehicle Sector
The overall effect of these final rules on motor vehicle sector
employment depends on the relative magnitude of the output effect and
the substitution effect. Because we do not have quantitative estimates
of the output effect, and only a partial estimate of the substitution
effect, we cannot reach a quantitative estimate of the overall
employment effects of these final rules on motor vehicle sector
employment or even whether the total effect will be positive or
negative.
These standards are not expected to provide incentives for
manufacturers to shift employment between domestic and
[[Page 73902]]
foreign production. This is because these standards will apply to
vehicles sold in the U.S. regardless of where they are produced. If
foreign manufacturers already have increased expertise in satisfying
the requirements of the standards, there may be some initial incentive
for foreign production, but the opportunity for domestic manufacturers
to sell in other markets might increase. To the extent that the
requirements of these final rules might lead to installation and use of
technologies that other countries may seek now or in the future,
developing this capacity for domestic production now may provide some
additional ability to serve those markets.
(3) Employment Impacts in Other Affected Sectors
(a) Transport and Shipping Sectors
Although not directly regulated by these final rules, employment
effects in the transport and shipping sector are likely to result from
these regulations. If the overall cost of shipping a ton of freight
decreases because of increased fuel efficiency (taking into account the
increase in upfront purchasing costs), in a perfectly competitive
industry some of these costs savings, depending on the relative
elasticities of supply and demand, will be passed along to customers.
Consumer Federation of America expects reduced shipping costs to be
passed along to customers. With lower prices, demand for shipping would
lead to an increase in demand for truck shipping services (consistent
with the VMT rebound effect analysis) and therefore an increase in
employment in the truck shipping sector. In addition, if the relative
cost of shipping freight via trucks becomes cheaper than shipping by
other modes (e.g., rail or barge), then employment in the truck
transport industry is likely to increase. If the trucking industry is
more labor intensive than other modes, we would expect this effect to
lead to an overall increase in employment in the transport and shipping
sectors.929 930 Such a shift would, however, be at the
expense of employment in the sectors that are losing business to
trucking. The first effect--a gain due to lower shipping costs--is
likely to lead to a net increase in employment. The second effect, due
to mode-shifting, may increase employment in trucking, but decrease
employment in other shipping sectors (e.g., rail or barge), with the
net effects dependent on the labor-intensity of the sectors and the
volumes.
---------------------------------------------------------------------------
\929\ American Transportation Research Institute, ``An Analysis
of the Operational Costs of Trucking: 2011 Update.'' See http://www.atri-online.org/research/results/Op_Costs_2011_Update_one_page_summary.pdf, Docket EPA-HQ-OAR-2014-
0827-512.
\930\ Association of American Railroads, ``All Inclusive Index
and Rail Adjustment Factor.'' June 3, 2011. See http://www.aar.org/
~/media/aar/RailCostIndexes/AAR-RCAF-2011-Q3.ashx, Docket EPA-HQ-
OAR-2014-0827-0065.
---------------------------------------------------------------------------
(b) Fuel Suppliers
In addition to the effects on the trucking industry and related
truck parts sector, these final rules will result in reductions in fuel
use that lower GHG emissions. Fuel saving, principally reductions in
liquid fuels such as diesel and gasoline, will affect employment in the
fuel suppliers industry sectors, principally the Petroleum Refinery
sector.
Section IX.C. of this Preamble provides estimates of the effects of
these standards on expected fuel consumption. While reduced fuel
consumption represents savings for purchasers of fuel, it also
represents a loss in value of output for the petroleum refinery
industry, which will result in reduced sectoral employment. Because
this sector is material-intensive, the employment effect is not
expected to be large.\931\
---------------------------------------------------------------------------
\931\ In the 2014 BLS ERM cited above, the Petroleum and Coal
Products Manufacturing sector has a ratio of workers per $1 million
of 0.215, lower than all but two of the 181 sectors with non-zero
employment per $1 million.
---------------------------------------------------------------------------
(c) Fuel Savings
As a result of this final rulemaking, it is anticipated that
trucking firms will experience fuel savings. Fuel savings lower the
costs of transportation goods and services. In a competitive market,
some of the fuel savings that initially accrue to trucking firms are
likely to be passed along as lower transportation costs that, in turn,
could result in lower prices for final goods and services. Some
commenters provide estimates of per-household fuel savings ranging from
$150 per year by 2030 (Clean Fuels Ohio, Edison Solar, a mass comment
campaign sponsored by Pew Charitable Trusts, Quasar Energy Group), to
$400 in 2035 (Environmental Defense Fund); they view these savings as
providing benefits to the wider economy. The National Ready Mixed
Concrete Association emphasizes concerns about the costs that the
standards will impose. Although the agencies do not endorse the
particular values provided in the comments, we agree that the standards
will provide net benefits to the U.S.; as shown in Section IX.K., the
benefits exceed the costs by a wide margin. As noted above, the
Consumer Federation of America expects consumers to recover these fuel
savings via the costs of goods and services relying on HD vehicles. The
agencies note that some of the savings might also be retained by firms
for investments or for distributions to firm owners. Again, how much
accrues to customers versus firm owners will depend on the relative
elasticities of supply and demand. Regardless, the savings will accrue
to some segment of consumers: Either owners of trucking firms or the
general public, and the effect will be increased spending by consumers
in other sectors of the economy, creating jobs in a diverse set of
sectors, including retail and service industries.
As described in Section IX.C.(2), the retail value of fuel savings
from this final rulemaking is projected to be $15.8 billion (2013$) in
2027, according to Table IX-6. If all those savings are spent, the fuel
savings will stimulate increased employment in the economy through
those expenditures. If the fuel savings accrue primarily to firm
owners, they may either reinvest the money or take it as profit.
Reinvesting the money in firm operations could increase employment
directly. If they take the money as profit, to the extent that these
owners are wealthier than the general public, they may spend less of
the savings, and the resulting employment impacts would be smaller than
if the savings went to the public. Thus, while fuel savings are
expected to decrease employment in the refinery sector, they are
expected to increase employment through increased consumer
expenditures.
(4) Summary of Employment Impacts
The primary employment effects of these rules are expected to be
found throughout several key sectors: Truck and engine manufacturers,
the trucking industry, truck parts manufacturing, fuel production, and
consumers. These rules initially takes effect in model year 2018; the
unemployment rate at that time is unknowable. In an economy with full
employment, the primary employment effect of a rulemaking is likely to
be to move employment from one sector to another, rather than to
increase or decrease employment. For that reason, we focus our partial
quantitative analysis on employment in the regulated sector, to examine
the impacts on that sector directly. We discuss the likely direction of
other impacts in the regulated sector as well as in other directly
related sectors, but we do not quantify those impacts, because they are
more difficult to quantify with reasonable accuracy, particularly so
far into the future.
For the regulated sector, we have not quantified the output effect.
The
[[Page 73903]]
substitution effect is associated with potential increased employment
between zero and 4.5 thousand jobs per year between 2018 and 2027,
depending on the share of employment impacts in the affected sectors
(Motor Vehicle Manufacturing, Motor Vehicle Body and Trailer
Manufacturing, and Motor Vehicle Parts Manufacturing). These estimates
do not include potential changes, either greater or less, in labor
intensity of production. As mentioned above, some of these job gains
may occur earlier as auto manufacturers and parts suppliers hire staff
to prepare to comply with the standard.
Lower prices for shipping are expected to lead to an increase in
demand for truck shipping services and, therefore, an increase in
employment in that sector, though this effect may be offset somewhat by
changes in employment in other shipping sectors. Reduced fuel
production implies less employment in the fuel provision sectors.
Finally, any net cost savings are expected to be passed along to some
segment of consumers: Either the general public or the owners of
trucking firms, who are expected then to increase employment through
their expenditures. Under conditions of full employment, any changes in
employment levels in the regulated sector due to this program are
mostly expected to be offset by changes in employment in other sectors.
M. Cost of Ownership and Payback Analysis
This section examines the economic impacts of the Phase 2 standards
from the perspective of buyers, operators, and subsequent owners of new
HD vehicles at the level of individual purchasers of different types of
vehicles. In each case, the analysis assumes that HD vehicle
manufacturers are able to recover their costs for improving fuel
efficiency--including direct technology outlays, indirect costs, and
normal profits on any additional capital investments--by charging
higher prices to HD vehicle buyers.
Table IX-34 reports aggregate benefits and costs to buyers and
operators of new HD vehicles for the final program using Method A. The
table reports economic impacts on buyers using only the 7 percent
discount rate, since that rate is intended to represent the opportunity
cost of capital that HD vehicle buyers and users must divert from other
investment opportunities to purchase more costly vehicles. As it shows,
fuel savings and the other benefits from increased fuel efficiency--
savings from less frequent refueling and benefits from additional truck
use--far outweigh the higher costs to buyers of new HD vehicles. As a
consequence, buyers, operators, and subsequent owners of HD vehicles
subject to the Phase 2 standards are together projected to experience
large economic gains under the final program. It should be noted that,
because the original buyers may not hold the vehicles for their
lifetimes, and because those who own or operate the vehicles may not
pay for the fuel, these benefits and costs do not necessarily represent
benefits and costs to identifiable individuals.
As Table IX-34 shows, the agencies have estimated the increased
costs for maintenance of the new technologies that HD vehicle
manufacturers will employ to decrease fuel consumption, and these costs
are included together with those for purchasing more fuel-efficient
vehicles. Manufacturers' efforts to comply with the Phase 2 standards
could also result in changes to vehicle performance and capacity for
certain vehicles. For example, reducing the mass of HD vehicles in
order to improve fuel efficiency could be used to improve their load-
carrying capabilities, while some engine technologies and aerodynamic
modifications could reduce payload capacity.
Table IX-34--MY 2018-2029 Lifetime Aggregate Impacts of the Final
Program on All HD Vehicle Buyers and Operators Using Method A
[Billions of 2013$, Discounted at 7%] \a\
------------------------------------------------------------------------
Baseline 1a Baseline 1b
------------------------------------------------------------------------
Vehicle costs........................... 16.6 16.1
Maintenance costs....................... 0.9 0.9
rrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrr
Total costs to HD vehicle buyers.... 17.5 17.0
Fuel savings \b\ (valued at retail 97.7 89.5
prices)................................
Refueling benefits...................... 1.7 1.6
Increased travel benefits............... 3.5 3.4
rrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrr
Total benefits to HD vehicle buyers/ 103 94.5
operators..........................
Net benefits to HD vehicle buyers/ 85.4 77.5
operators \c\......................
------------------------------------------------------------------------
Notes:
\a\ For an explanation of analytical Methods A and B, please see Section
I.D; for an explanation of the less dynamic baseline, 1a, and more
dynamic baseline, 1b, please see Section X.A.1.
\b\ Fuel savings includes fuel consumed during additional rebound
driving.
\c\ Net benefits shown do not include benefits associated with carbon or
other co-pollutant emission reductions, crash/congestion/noise
impacts, energy security, etc.
It is also useful to examine the cost of purchasing and owning a
new vehicle that complies with the Phase 2 standards and its payback
period--the point at which cumulative savings from lower fuel
expenditures outpace increased vehicle costs. For example, a new MY
2027 tractor is estimated to cost roughly $13,550 more (on average, or
roughly 13 to 14 percent of a typical $100,000 reference case tractor)
due to the addition of new GHG reducing/fuel consumption improving
technology. This new technology will result in lower fuel consumption
and, therefore, reduced fuel expenditures. But how many months or years
will pass before the reduced fuel expenditures will surpass the
increased upfront costs?
Table IX-35 presents the discounted annual increased vehicle costs
and fuel savings associated with owning a new MY 2027 HD pickup or van
using both 3 percent and 7 percent discount rates. Table IX-36 and
Table IX-37 show the same information for a MY 2027 vocational vehicle
and a tractor/trailer, respectively. These comparisons include sales
taxes, excise taxes (for vocational and tractor/trailer) and increased
insurance expenditures on the higher value vehicles, as well as
maintenance costs throughout the lifetimes of affected vehicles.
[[Page 73904]]
The fuel expenditure column uses retail fuel prices specific to
gasoline and diesel fuel as projected in AEO2015.\932\ This payback
analysis does not include other impacts, such as reduced refueling
events, the value of driving potential rebound miles, or noise,
congestion and crashes. We use retail fuel prices and exclude these
other private and social impacts because the analysis is intended to
focus on those factors that are most important to buyers when
considering a new vehicle purchase, and to include only those factors
that have clear dollar impacts on HD vehicle buyers.
---------------------------------------------------------------------------
\932\ U.S. Energy Information Administration, Annual Energy
Outlook 2015; Report Number DOE/EIA-0383(2015), April 2015.
---------------------------------------------------------------------------
As shown, payback will occur in the 3rd year of ownership for HD
pickups and vans (the first year where cumulative net costs turn
negative), in the 4th year for vocational vehicles and early in the 2nd
year for tractor/trailers. Note that each table reflects the average
vehicle and reflects proper weighting of fuel consumption/costs
(gasoline vs. diesel).
Table IX-35--Discounted Annual Incremental Expenditures for a MY 2027 HD Pickup or Van Using Method B and Relative to the Flat Baseline
[2013$] \a\
--------------------------------------------------------------------------------------------------------------------------------------------------------
3% Discount rate 7% Discount rate
-------------------------------------------------------------------------------------------------------
Age in years Cumulative Cumulative
Vehicle \b\ Maint \c\ Fuel \d\ net Vehicle \b\ Maint \c\ Fuel \d\ net
--------------------------------------------------------------------------------------------------------------------------------------------------------
1............................................... -$1,451 -$4 $550 -$905 -$1,424 -$4 $540 -$888
2............................................... -25 -4 539 -395 -24 -3 509 -406
3............................................... -24 -3 527 105 -21 -3 479 49
4............................................... -22 -3 515 595 -19 -3 451 477
5............................................... -21 -3 492 1,064 -17 -3 415 872
6............................................... -19 -3 469 1,511 -16 -2 381 1,235
7............................................... -18 -3 446 1,936 -14 -2 348 1,567
8............................................... -17 -2 423 2,340 -13 -2 318 1,870
--------------------------------------------------------------------------------------------------------------------------------------------------------
Notes:
\a\ For an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 1b,
please see Section X.A.1.
\b\ Includes new technology costs, insurance costs and sales taxes.
\c\ Maintenance costs.
\d\ Uses AEO2015 retail fuel prices.
Table IX-36--Discounted Annual Incremental Expenditures for a MY 2027 Vocational Vehicle Using Method B and Relative to the Flat Baseline
[2013$] \a\
--------------------------------------------------------------------------------------------------------------------------------------------------------
3% Discount rate 7% Discount rate
-------------------------------------------------------------------------------------------------------
Age in years Cumulative Cumulative
Vehicle \b\ Maint \c\ Fuel \d\ net Vehicle \b\ Maint \c\ Fuel \d\ net
--------------------------------------------------------------------------------------------------------------------------------------------------------
1............................................... -$3,147 -$25 $1,022 -$2,151 -$3,088 -$25 $1,003 -$2,110
2............................................... -49 -24 1,004 -1,220 -46 -23 948 -1,231
3............................................... -46 -24 987 -303 -42 -21 898 -397
4............................................... -43 -23 970 602 -38 -20 849 394
5............................................... -40 -21 909 1,450 -34 -18 766 1,109
6............................................... -38 -19 850 2,243 -31 -15 689 1,752
7............................................... -35 -17 796 2,987 -27 -14 622 2,333
8............................................... -33 -16 743 3,681 -25 -12 558 2,854
--------------------------------------------------------------------------------------------------------------------------------------------------------
Notes:
\a\ For an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 1b,
please see Section X.A.1.
\b\ Includes new technology costs, insurance costs, excise and sales taxes.
\c\ Maintenance costs.
\d\ Uses AEO2015 retail fuel prices.
Table IX-37--Discounted Annual Incremental Expenditures for a MY 2027 Tractor/Trailer Using Method B and Relative to the Flat Baseline
[2013$] \a\
--------------------------------------------------------------------------------------------------------------------------------------------------------
3% Discount rate 7% Discount rate
-------------------------------------------------------------------------------------------------------
Age in years Cumulative Cumulative
Vehicle \b\ Maint \c\ Fuel \d\ net Vehicle \b\ Maint \c\ Fuel \d\ net
--------------------------------------------------------------------------------------------------------------------------------------------------------
1............................................... -$16,022 -$169 $15,310 -$880 -$15,719 -$166 $15,021 -$864
2............................................... -251 -163 15,095 13,801 -237 -154 14,256 13,002
3............................................... -235 -158 14,872 28,280 -214 -144 13,521 26,166
[[Page 73905]]
4............................................... -220 -153 14,637 42,545 -192 -134 12,809 38,649
5............................................... -206 -140 13,683 55,882 -173 -118 11,527 49,885
6............................................... -192 -127 12,730 68,292 -156 -103 10,323 59,950
7............................................... -179 -116 11,880 79,878 -140 -90 9,274 68,993
8............................................... -166 -105 11,025 90,630 -125 -79 8,285 77,074
--------------------------------------------------------------------------------------------------------------------------------------------------------
Notes:
\a\ For an explanation of analytical Methods A and B, please see Section I.D; for an explanation of the flat baseline, 1a, and dynamic baseline, 1b,
please see Section X.A.1.
\b\ Includes new technology costs, insurance costs, excise and sales taxes.
\c\ Maintenance costs.
\d\ Uses AEO2015 retail fuel prices.
N. Safety Impacts
(1) Summary of Supporting HD Vehicle Safety Research
As discussed in the Notice of Proposed Rulemaking, NHTSA and EPA
considered the potential safety impact of technologies that improve
Medium- and Heavy-Duty vehicle fuel efficiency and GHG emissions when
determining potential regulatory alternatives. The safety assessment of
the technologies in this rule was informed by two comprehensive NAS
reports, an extensive analysis of safety effects of HD pickups and vans
using estimates from the DOT report on the effect of mass reduction and
vehicle size on safety, and focused agency-sponsored safety testing and
research. The following section provides a concise summary of the
literature and work considered by the agencies in development of this
final rule.
(a) National Academy of Sciences Medium and Heavy Duty Phase 1 and
Phase 2 Reports
As required by EISA, the National Research Council has been
conducting continuing studies of the technologies and approaches for
reducing the fuel consumption of medium- and heavy-duty vehicles. The
first was a report issued in 2010, ``Technologies and Approaches to
Reducing the Fuel Consumption of Medium- and Heavy-Duty Vehicles''
(``NAS Report''). The second was a report issued in 2014, ``Reducing
the Fuel Consumption and Greenhouse Gas Emissions of Medium- and Heavy-
Duty Vehicles, Phase Two-First Report'' (``NAS HD Phase 2 First
Report''). While the reports primarily focused on reducing vehicle fuel
consumption and emissions through technology application, and examined
potential regulatory frameworks, both reports contain findings and
recommendations related to safety. In developing this rule, the
agencies carefully considered the reports' findings related to safety.
In particular, NAS indicated that idle reduction strategies can
also accommodate for the safety of the driver in both hot and cold
weather conditions. The agencies considered this potential approach for
application of idle reduction technologies by allowing for override
provisions, as defined in 40 CFR 1037.660(b), where operator safety is
a primary consideration. Override is allowed if the external ambient
temperature reaches a level below which or above which the cabin
temperature cannot be maintained within reasonable heat or cold
exposure threshold limit values for the health and safety of the
operator (not merely comfort).
NAS also reported extensively on the emergence of natural gas (NG)
as a viable fuel option for commercial vehicles, but alluded to the
existence of uncertainties regarding its safety. The committee found
that while the public crash databases do not contain information on
vehicle fuel type, the information, at the time of the report,
indicates that the crash-related safety risk for NG storage on vehicles
does not appear to be appreciably different from diesel fuel risks. The
committee also found that while there are two existing SAE-recommended
practice standards for NG-powered HD vehicles, the industry could
benefit from best practice directives to minimize crash risks for NG
fuel tanks, such as on shielding to prevent punctures during crashes.
As a final point, NAS stated that manufacturers and operators have a
great incentive to prevent possible NG leakage from a vehicle fuel
system because it will be a significant safety concern and reduce
vehicle range. No recommendations were made for additional Federal
safety regulations for these vehicles. In response, the agencies
reviewed and discussed the existing NG vehicle standards and best
practices cited by NAS in Section XI of the NPRM.
In the NAS Committee's Phase 1 report, the Committee indicated that
aerodynamic fairings detaching from trucks on the road could be a
potential safety issue. However, the Phase 2 interim report stated that
``Anecdotal information gained during the observations of on-road
trailers indicates a few skirts badly damaged or missing from one side.
The skirt manufacturers report no safety concerns (such as side skirts
falling off) and little maintenance needed.''
The NAS report also identified the link between tire inflation and
condition and vehicle stopping distance and handling, which impacts
overall safety. The committee found that tire pressure monitoring
systems and automatic tire inflation systems are being adopted by
fleets at an increasing rate. However, the committee noted that there
are no standards for performance, display, and system validation. The
committee recommended that NHTSA issue a white paper on the minimum
performance of tire pressure systems from a safety perspective.
The agencies considered the safety findings in both NAS reports in
developing this rule and conducted additional research on safety to
further examine information and findings of the reports.
(b) DOT CAFE Model Heavy-Duty Pickup and Van Safety Analysis
This analysis considered the potential crash safety effects on the
technologies manufacturers may apply to HD pickups
[[Page 73906]]
and vans to meet each of the regulatory alternatives evaluated in the
NPRM. NHTSA research has shown that vehicle mass reduction affects
overall societal fatalities associated with crashes and, most relevant
to this rule, that mass reduction in heavier light- and medium-duty
vehicles has an overall beneficial effect on societal fatalities.
Reducing the mass of a heavier vehicle involved in a multiple vehicle
crash reduces the likelihood of fatalities among the occupants of the
other vehicle(s). In addition to the effects of mass reduction, the
analysis anticipates that these standards, by reducing the cost of
driving HD pickups and vans, will lead to increased travel by these
vehicles and, therefore, more crashes involving these vehicles. Both
the Method A and B analyses, both of which are included in the NPRM and
are part of this final rulemaking, consider overall impacts from both
of these factors, using a methodology similar to NHTSA's analyses for
the MYs 2017-2025 CAFE and GHG emission standards.
The Method A analysis included estimates of the extent to which HD
pickups and vans produced during MYs 2014-2030 may be involved in fatal
crashes, considering the mass, survival, and mileage accumulation of
these vehicles, taking into account changes in mass and mileage
accumulation under each regulatory alternative. These calculations make
use of the same coefficients applied to light trucks in the MYs 2017-
2025 CAFE rulemaking analysis. As discussed above, vehicle miles
traveled may increase due to the fuel economy rebound effect, resulting
from improvements in vehicle fuel efficiency and cost of fuel, as well
as the assumed future growth in average vehicle use. Increases in total
lifetime mileage increase exposure to vehicle crashes, including those
that result in fatalities. Consequently, the modeling system computes
total fatalities attributed to vehicle use for vehicles of a given
model year based on safety class and weight threshold. These
calculations also include a term that accounts for the fact that some
of the vehicles involved in future crashes will comply with more
stringent safety standards than those involved in past crashes upon
which the base rates of involvement in fatal crashes were estimated.
Since the use of mass reducing technology is present within the model,
safety impacts may also be observed whenever a vehicle's base weight
decreases. Thus, in addition to computing total fatalities related to
vehicle use, the modeling system also estimates changes in fatalities
due to reduction in a vehicle's curb weight.
The total fatalities attributed to vehicle use and vehicle weight
change for vehicles of a given model year are then summed. Lastly,
total fatalities occurring within the industry in a given model year
are accumulated across all vehicles. In addition to using inputs to
estimate the future involvement of modeled vehicles in crashes
involving fatalities, the model also applies inputs defining other
crash-related externalities estimated on a dollar per mile basis. For
vehicles above 4,594 lbs--i.e., the majority of the HD pickup and van
fleet--mass reduction is estimated to reduce the net incidence of
highway fatalities by 0.34 percent per 100 lbs of removed curb weight.
For the few HD pickups and vans below 4,594 lbs, mass reduction is
estimated to increase the net incidence of highway fatalities by 0.52
percent per 100 lbs. The overall effect of mass reduction in the
segment is estimated to reduce the incidence of highway fatalities as
there are more HD pickups and vans above 4,594 lbs than below. The
projected increase in vehicle miles traveled, due to the fuel economy
rebound effect, also potentially increases exposure to vehicle crashes
and offsets these reductions.
(c) Volpe Research on MD/HD Fuel Efficiency Technologies
The 2010 National Research Council report ``Technologies and
Approaches to Reducing the Fuel Consumption of Medium- and Heavy-Duty
Vehicles'' recommended that NHTSA perform a thorough safety analysis to
identify and evaluate potential safety issues with fuel efficiency-
improving technologies. The Department of Transportation Volpe Center's
2015 report titled ``Review and Analysis of Potential Safety Impacts
and Regulatory Barriers to Fuel Efficiency Technologies and Alternative
Fuels in Medium- and Heavy-Duty Vehicles'' summarizes research and
analysis findings on potential safety issues associated with both the
diverse alternative fuels (natural gas-CNG and LNG, propane, biodiesel,
and power train electrification), and the specific FE technologies
recently adopted by the MD/HDV fleets.\933\ These include Intelligent
Transportation Systems (ITS) and telematics, speed limiters, idle
reduction devices, tire technologies (single-wide tires, and tire
pressure monitoring systems-TPMS and Automated Tire Inflation Systems-
ATIS), aerodynamic components, vehicle light-weighting materials, and
Long Combination Vehicles (LCVs).
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\933\ Brecher, A., Epstein, A. K., & Breck, A. (2015, June).
Review and analysis of potential safety impacts of and regulatory
barriers to fuel efficiency technologies and alternative fuels in
medium- and heavy-duty vehicles. (Report No. DOT HS 812 159).
Washington, DC: National Highway Traffic Safety Administration.
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Chapter 1 provides an overview of the study's rationale,
background, and key objective, namely, to identify the technical and
operational/behavioral safety benefits and disbenefits of MD/HDVs
equipped with FE technologies and using emerging alternative fuels
(AFs). Recent MD/HDV national fleet crash safety statistical averages
are also provided for context, although no information exists in crash
reports relating to specific vehicle FE technologies and fuels. (NHTSA/
FARS and FMCSA/CSA databases do not include detailed information on
vehicle fuel economy technologies, since the state crash report forms
are not coded down to an individual fuel economy technology level).
Chapters 2 and 3 are organized by clusters of functionally-related
FE technologies for vehicles and trailers (e.g., tire systems, ITS,
light-weighting materials, and aerodynamic systems) and alternative
fuels, which are described and their respective associated potential
safety issues are discussed. Chapter 2 summarizes the findings from a
comprehensive review of available technical and trade literature and
Internet sources regarding the benefits, potential safety hazards, and
the applicable safety regulations and standards for deployed FE
technologies and alternative fuels. Chapter 2 safety-relevant fuel-
specific findings include:
Both CNG- and LNG-powered vehicles present potential
hazards, and call for well-known engineering and process controls to
assure safe operability and crashworthiness. However, based on the
reported incident rates of NGVs and the experiences of adopting fleets,
it appears that NGVs can be operated at least as safely as diesel MD/
HDVs.